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INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #: 5632
Laboratory Name: Jeffery Jarman
Inspection Type: Field Commercial Initial
Inspector Name(s): Todd Crawford and Beth Swanson
Inspection Date: 11/19/2014
Date Report Completed: 11/21/2014
Date Forwarded to Reviewer: 11/21/2014
Reviewed by: Beth Swanson
Date Review Completed: 11/24/2014
Cover Letter to use: Insp. Initial Insp. Reg.
Insp. No Finding Insp. CP
Corrected Insp. Reg. Delay
Unit Supervisor/Chemist III: Dana Satterwhite
Date Received: November 24, 2014
Date Forwarded to Linda: December 2, 2014
Date Mailed: December 3, 2014
_____________________________________________________________________
On-Site Inspection Report
LABORATORY NAME: Jeffrey Jarman
ADDRESS: 2925 Richlands Hwy.
Jacksonville, NC 28540
CERTIFICATE #: 5632
DATE OF INSPECTION: November 19, 2014
TYPE OF INSPECTION: Field Commercial Initial
AUDITOR(S): Todd Crawford and Beth Swanson
LOCAL PERSON(S) CONTACTED: Jeffrey Jarman
I. INTRODUCTION:
This laboratory was inspected by a representative of the North Carolina Wastewater/Groundwater
Laboratory Certification (NC WW/GW LC) program to verify its compliance with the requirements of 15A
NCAC 2H .0800 for the analysis of environmental samples.
II. GENERAL COMMENTS:
This was the laboratory’s first inspection. The facility has all the equipment necessary to perform the
analyses. A system for traceability of reagents was in place but did not include all the required
information.
Contracted analyses are performed by Beacham Laboratory (Certification #1).
Current quality assurance policies for Field Laboratories and approved procedures for the analysis of the
facility’s currently certified parameters were provided at the time of the inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Quality Control
A. Finding: Rounding off by dropping insignificant digits is not being properly done.
Requirement: Round off by dropping digits that are not significant. If the digit 6, 7, 8, or 9 is
dropped, increase preceding digit by one unit; if the digit 0, 1, 2, 3, or 4 is dropped, do not alter
preceding digit. If the digit 5 is dropped, round off preceding digit to the nearest even number:
thus 2.25 becomes 2.2 and 2.35 becomes 2.4. Ref: Standard Methods 1050 B-2006. (2).
Documentation
B. Finding: Error corrections are not performed properly.
Requirement: All documentation errors must be corrected by drawing a single line through the
error so that the original entry remains legible. Entries shall not be obliterated by erasures or
markings. Wite-Out®, correction tape or similar products designed to obliterate documentation are
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not to be used. Write the correction adjacent to the error. The correction must be initialed by the
responsible individual and the date of change documented. All data and log entries must be
written in indelible ink. Pencil entries are not acceptable. Ref: Quality Assurance Policies for Field
Laboratories.
Comment: Instances of writing over the error were observed.
C. Finding: The laboratory needs to increase the documentation of purchased reagents.
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 and lots of pre-made standards are included in this
requirement. Ref: Quality Assurance Policies for Field Laboratories.
Comment: All required information except for date opened (in use) was being documented.
Proficiency Testing
D. Finding: The preparation of Total Residual Chlorine (TRC) Proficiency Testing (PT) samples is
not documented.
Requirement: PT samples received as ampules must be diluted according to the PT provider’s
instructions. The preparation of PT samples must be documented in a traceable log or other
traceable format. The diluted PT sample becomes a routine environmental sample and is added
to a routine sample batch for analysis. Ref: Proficiency Testing Requirements, February 20,
2012, Revision 1.2.
Comment: Dating and initialing the instruction sheet for the preparation of the TRC PT would
satisfy the documentation requirement.
E. Finding: The laboratory benchsheets used for Carolina Plantation and Blue Creek Utilities were
lacking pertinent data: Instrument identification.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: Instrument Identification. Ref: NC WW/GW LC Approved Procedure for the Analysis
of pH, NC WW/GW LC Approved Procedure for the Analysis of Temperature, NC WW/GW LC
Approved Procedure for the Analysis of Dissolved Oxygen, NC WW/GW LC Approved Procedure
for the Analysis of Total Residual Chlorine.
F. Finding: The analyst is not signing or initialing laboratory benchsheets used for Carolina
Plantation.
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 analytes. Ref: 15A NCAC 2H .0805 (g) (1).
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pH – Standard Methods, 4500 H+ B-2000
Comment: The tip of the pH probe was dirty and in need of cleaning. The manufacturer’s cleaning
instructions should be followed.
Comment: A three-point calibration procedure is being followed. The calibration sheet for Carolina
Plantation has columns for two calibration buffers, a check buffer and the slope. This needs to be
amended to indicate that three buffers are used for the calibration.
G. Finding: The laboratory benchsheets used for Blue Creek Utilities was lacking pertinent data:
Units of measure.
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).
Comment: The unit of measure for pH is Standard Units, abbreviated as S.U.
Total Residual Chlorine – Standard Methods, 4500 Cl G-2000
H. Finding: The laboratory benchsheet for Blue Creek WWTP was lacking pertinent data: True
value of the check standard.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: True value of the check standard. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Total Residual Chlorine.
Comment: The true value of the Gel® standard used for the daily calibration check had been
updated on November 11, 2014, when the 5-standard curve verification was performed. The
Gel® standard’s true value and acceptance concentration range stated on the benchsheet for
Blue Creek WWTP still reflected the values from the previous Gel® standard true value
assignment. The benchsheet simply needs to be updated with the current values.
I. Finding: The HACH Pocket Colorimeter II has not had its factory set curve verified.
Requirement: Analyze a water blank to zero the instrument and then analyze a series of five
standards. The curve verification must check 5 concentrations (not counting the blank) that
bracket the range of the samples to be analyzed. This type of curve verification must be
performed at least every 12 months. The values obtained must not vary by more than 10% of the
known value for standard concentrations. The overall correlation coefficient of the curve must be
≥0.995. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: The lowest allowable reporting level for pocket colorimeters is 0.1 mg/L.
J. Finding: The laboratory has not verified the concentration of the Gel® standard used with the
HACH Pocket Colorimeter II.
Requirement: Purchased “Gel-type” or sealed liquid ampoule standards may be used for daily
standard curve verification only. These standards must be verified initially and every 12 months
thereafter, with the standard curve. When this is done, these standards may be used after the
manufacturer’s expiration date. It is only necessary to verify the gel or sealed liquid standard
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which falls within the concentration range of the curve used to measure sample concentrations.
Ref: Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: The value of the Gel® standard obtained at the time of the 5 point verification, will be
the “true value” used throughout the year and until a new curve is verified.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.)
and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division
of Water Resources. Data were reviewed for Carolina Plantation WWTP (WQ0033770) for July, 2014
and Blue Creek WWTP (NC0056952 for August and September, 2014. The following errors were noted:
Sample
Collection
Date
Parameter Location Value on Benchsheet/
*Contract Lab Data
Value on
DMR
7/9/14 Chloride Carolina Plantation/
Effluent * 61 mg/L Not Reported
7/9/14 Total Dissolved Residue Carolina Plantation/
Effluent * 532 mg/L Not Reported
7/14/14 Dissolved Oxygen Carolina Plantation/
Effluent 1.2 mg/L 0.8 mg/L
7/15/14 Dissolved Oxygen Carolina Plantation/
Effluent 1.0 mg/L 0.6 mg/L
7/16/14 Dissolved Oxygen Carolina Plantation/
Effluent 1.4 mg/L 1.5 mg/L
7/17/14 Dissolved Oxygen Carolina Plantation/
Effluent 1.1 mg/L 1.5 mg/L
7/18/14 Dissolved Oxygen Carolina Plantation/
Effluent 0.9 mg/L 0.4 mg/L
7/28/14 Dissolved Oxygen Carolina Plantation/
Effluent 2.3 mg/L 0.8 mg/L
7/29/14 Dissolved Oxygen Carolina Plantation/
Effluent 2.6 mg/L 0.7 mg/L
7/30/14 Dissolved Oxygen Carolina Plantation/
Effluent 1.8 mg/L 0.5 mg/L
7/31/14 Dissolved Oxygen Carolina Plantation/
Effluent 0.8 mg/L 0.5 mg/L
9/2/14
BOD, Total Phosphorus,
Ammonia as Nitrogen
and Enterococci
Blue Creek/
Effluent Reported as being collected on 9/1/14
9/3/14
BOD, Total Phosphorus,
Ammonia as Nitrogen
and Enterococci
Blue Creek/
Effluent Reported as being collected on 9/2/14
9/4/14
BOD, Total Phosphorus,
Ammonia as Nitrogen
and Enterococci
Blue Creek/
Effluent Reported as being collected on 9/3/14
All of Sept. Enterococci Blue Creek/
Effluent * < 1 cfu/100 ml 1 cfu/100 ml
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Comment: A qualifier associated with a BOD result for Carolina Plantation WWTP was observed on one
of the contract lab reports. This qualifier was not transferred to the DMR. However, Jeffrey Jarman does
not fill out the DMRs for Carolina Plantation WWTP. He simply sends his analytical results to Carolina
Plantation WWTP. Contract lab reports are also sent directly to Carolina Plantation WWTP. The DMRs
are then filled out and submitted to the North Carolina Division of Water Resources by Carolina Plantation
WWTP staff. The NC WW/GW LC program will contact Carolina Plantation WWTP and the appropriate
Regional Office regarding this finding and the transcription errors noted in the table above.
Comment: Jeffrey Jarman does complete the DMRs for Blue Creek WWTP.
Recommendation: Due to the number of errors noted in the paper trail investigation it is recommended
that a system of checking the data entered on the DMR be implemented for Blue Creek WWTP DMRs. It
would be beneficial to have a second person review the accuracy of data transcription to the DMR. At a
minimum, the person entering the data should review the transcriptions to the DMR after some time has
passed from the original data entry.
Recommendation: 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 for
the Blue Creek WWTP will be required. A copy of this report will be made available 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 during the inspection and data review process. Please respond to all findings.
Report prepared by: Todd Crawford Date: November 21, 2014
Report reviewed by: Beth Swanson Date: November 24, 2014