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Home My WebLink About#5149 11-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5149 Laboratory Name: Conner Consulting, LLC Inspection Type: Field Maintenance Inspector Name(s): Jeffrey R. Adams Inspection Date: March 1, 2011 Date Report Completed: March 17, 2011 Date Forwarded to Reviewer: March 17, 2011 Reviewed by: Chet Whiting Date Review Completed: March 29, 2011 Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP Unit Supervisor: Dana Satterwhite Date Received: March 29, 2011 Date Forwarded to Alberta: April 6, 2011 Date Mailed: April 6, 2011 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Conner Consulting, LLC NPDES PERMIT #: WQ0018173, WQ0019755, WQ0019704, WQ0031717, WQ0007345, WQ0013808, WQ0021950, WQ0011777 ADDRESS: 1284 Windy Ridge Rd. Chapel Hill, NC 27517 CERTIFICATE #: 5149 DATE OF INSPECTION: March 1, 2011 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Jeffrey R. Adams LOCAL PERSON(S) CONTACTED: Chad Leinbach I. INTRODUCTION: This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. II. GENERAL COMMENTS: The laboratory was neat; however, laboratory records were sometimes incomplete and not well organized. The laboratory was unable to produce contract laboratory reports within the scope of the audit and had to locate and send the requested documentation several days later. It was also noted that the analyst’s handwriting is very difficult to read. This could cause defensibility issues and inaccurate data may be reported if transcribed incorrectly. Lack of supporting documentation or disagreement between reported values and those recorded on supporting documentation may be viewed as falsification. The errors noted in Section IV of this report underscore the importance of legible documentation. Additional quality control procedures need to be implemented. The laboratory was given a packet containing the Technical Assistance Documents and quality control requirements for all field parameters during the inspection. Finding B is a new policy that has been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation A. Finding: Units of measure are not always documented in the field lab notebooks. Requirement: Data pertinent to each analysis must be maintained for five years. Certified data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. The field benchsheets must provide a space for the signature or initials of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC 02H .0805 (g) (1). Page 2 #5149 Conner Consulting, LLC Comment: The laboratory is transcribing data in small notebooks and at times it was very difficult to discern site location, date of analysis, parameter being analyzed and measurements obtained due to legibility problems, possibly contributing to the data transcription errors. Recommendation: It is recommended that the laboratory use a version of the example benchsheet left with the analyst at the time of the inspection and must significantly improve data organization. Recommendation: It is recommended that the laboratory establish a more organized filing system to ensure contract data reports, laboratory benchsheets and/or notebooks, and support documentation is readily accessible. B. Finding: The laboratory needs to increase the documentation of purchased materials and reagents in the laboratory. The date chemicals are opened and put into use is not documented. Requirement: All chemicals, reagents, standards and consumables used by the laboratory must have the following information documented: Date Received, Date Opened (in use), Vendor, Lot Number, and Expiration Date. A system (e.g., traceable identifiers) must be in place that links standard/reagent preparation information to analytical batches in which the solutions are used. Documentation of solution preparation must include the analyst’s initials, date of preparation, the volume or weight of standard(s) used, the solvent and final volume of the solution. This information, as well as the vendor and/or manufacturer, lot number, and expiration date must be retained for chemicals, reagents, standards and consumables used, for a period of five years. Consumable materials such as pH buffers, lots of pre -made standards are included in this requirement. Ref: Quality Assurance Policies for Field Laboratories. Recommendation: It is recommended that the laboratory use a version of the example laboratory benchsheet that was given at the time of the inspection. This benchsheet includes spaces to record the traceability information. Dissolved Oxygen – Standard Methods, 18th Edition, 4500 O G C. Finding: The laboratory is not checking the temperature sensor on the DO meter annually against a National Institute of Standards and Technology (NIST) or NIST traceable thermometer and posting corrections on meter. Requirement: The temperature sensor in the meter must be check ed every 12 months against an NIST certified or NIST traceable thermometer and the process documented even if the instrument is not used for reporting temperature results. The temperature correction (even if it is zero) must be posted on the meter as well as in hard copy format (to be retained for 5 years). Ref: Technical Assistance for Field Analysis of Dissolved Oxygen. pH – Standard Methods, 18th Edition, 4500 H+ B D. Finding: The laboratory is not posting NIST temperature corrections on the pH meter. Requirement: The temperature correction (even if it is zero) must be posted on the meter as well as in hard copy format (to be retained for 5 years). Ref: Technical Assistance for Field Analysis of pH. E. Finding: The proper units of measure (i.e., S.U. for pH) are not documented on the benchsheet. Page 3 #5149 Conner Consulting, LLC Requirement: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. The field bench sheets must provide a space for the signature or initials of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC 02H .0805 (g) (1). IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing laboratory benchsheets and contract lab reports to Non- Discharge Monitoring Reports (NDMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for the following locations: Ready Mix Rougemont (NPDES permit #WQ0007345); Summerfield (NPDES permit #WQ0013808); Oak Ridge Commons (NPDES permit #WQ0019755); Old Chatham Golf Club (NPDES permit #WQ0019704); Talley Pointe (NPDES permit #WQ0031717); Clegg’s Chapel Church (NPDES permit #WQ0021950); Montessouri (NPDES permit #WQ0018173) for the following months: October, November and December, 2010. The following errors were noted: (Ready Mix Rougemont) Date Parameter Location Value on Benchsheet Value on DMR 10/06/10 pH Effluent 6.49 S.U. 7.06 S.U. 10/06/10 Total Residual Chlorine Effluent 5.1 mg/L 240 µg/L (Oak Ridge Commons) 12/30/10 Settleable Solids Effluent <0.1 ml/L 0.2 ml/L In order to avoid questions of legality, it is recommended that you contact the appropriate Regional Office for guidance as to whether an amended Discharge Monitoring Report will be required. A copy of this report will be forwarded to the Regional Office. V. CONCLUSIONS: Correcting the above-cited findings and implementing the recommendations will help this lab to produce quality data and meet certification requirements. The inspector would like to thank the staff for its assistance in the inspection and data review process. Please respond to all findings. Report prepared by: Jeffrey R. Adams Date: March 17, 2011 Report reviewed by: Chet Whiting Date: March 29, 2011