#5039_2016_0413_BS_FINAL

To be attached to all inspection reports in-house only.
Laboratory Cert. #:
Laboratory Name:
Inspection Type:
Inspector Name(s):
Inspection Date:
Date Report Completed:
Date Forwarded to Reviewer:
Reviewed by:
Date Review Completed:
Cover Letter to use:
Unit Supervisor/Chemist III:
Date Received:
Date Forwarded to Admin:
Date Mailed:
5039
Wayne Farms LLC
Field Maintenance
Beth Swanson, Gary Francies
April 13, 2016
April 25, 2016
April 25, 2016
Tonia Springer
May 3, 2016
❑ Insp. Initial ❑ Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
® Corrected ❑ Insp. Reg. Delay
Gary Francies
May 3, 2016
5/17/2016
5/17/2016

t., 4
f l�rt
WaterResources
ENVHRONMEN rAL QUALtry
May 17, 2016
5039
Mr. Jeremy Bowlin
Wayne Farms LLC
PO Box 383
Dobson, NC 2701
PAT MCCRORY
DONALD R. VAN DER VAART
S. JAY ZIMMERMAN
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Bowlin:
Enclosed is a report for the inspection performed on April 13, 2016 by Beth Swanson and myself. Since
the Finding(s) cited during the inspection were all corrected prior to the completion of the enclosed
report, a response is not required. The staff is commended for taking the initiative in correcting the
Findings in such a timely manner. For Certification maintenance, your laboratory must continue to carry
out the requirements set forth in 15A NCAC 2H .0800.
Copies of the checklists completed during the inspection may be requested from this office. Thank you
for your cooperation during the inspection. If you wish to obtain an electronic copy of this report by
email, or if you have questions or need additional information, please contact me at [phone].
Sincerely,
Gary Francies, Technical Assistance/Compliance Specialist
Division of Water Resources
Attachment
cc: Beth Swanson
master file

LABORATORY NAME: Wayne Farms LLC
NPDES PERMIT #: NC0006548
ADDRESS: P.O. Box 383
Dobson, NC 2701
CERTIFICATE #: 5039
DATE OF INSPECTION: April 13, 2016
TYPE OF INSPECTION: Field Maintenance
AUDITOR(S): Beth Swanson and Gary Francies
LOCAL PERSON(S) CONTACTED: Jeremy Bowlin
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.
GENERAL COMMENTS:
During the inspection, the supervisor, Mr. Bowlin was very forthcoming and ready to adopt any
necessary changes. We found the records well organized and easy to retrieve. It was evident that
Mr. Bowlin takes pride in his work.
All required Proficiency Testing (PT) samples have been analyzed for the 2016 PT calendar year
and the graded results were 100% acceptable.
Contracted analyses are performed by Pace Analytical Services, Inc. — Eden (Certification #633).
Current Quality Assurance Policies for Field Laboratories and Approved Procedure documents for
the analysis of the facility's currently certified methods were provided at the time of the inspection.
FINDINGS-2 REQUIREMENTS COMMENTS AND RECOMMENDATIONS:
General
Comment: The laboratory was not Certified for Dissolved Oxygen (DO). The facility's NPDES
permit requires DO to be analyzed once per month on the Upstream and Downstream sites. The
North Carolina Administrative Code, 15A NCAC 2H .0804 (a) states: Commercial, Municipal,
Industrial and Other facilities are required to obtain certification for field parameters which will be
reported by the client to comply with State surface water, ground water, and pretreatment Rules.
Acceptable corrective action (i.e., the laboratory requested and was granted Certification of DO)
was implemented on 4/19/2016. No further response is necessary for this Finding.

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#5039 Wayne Farms LLC
Documentation
Comment: Process control data was not documented as such. The North Carolina Administrative
Code, 15A NCAC 2H .0805 (g) (1) states: 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. Notification of
acceptable corrective action (i.e., updated benchsheet to only include effluent data, which is
labeled as such, with an implementation date of 4/18/2016) was received by email on 4/19/2016.
No further response is necessary for this Finding.
Comment: Error corrections were not performed properly. The Quality Assurance Policies for
Field Laboratories document states: 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 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.
Notification of acceptable corrective action (i.e., statements that a meeting was held with all
analysts on the proper procedure for correcting errors on 4/22/2016 and that the procedure was
posted at the facility on 4/25/2016) was received by email on 4/22/2016 and 4/25/2016. No
further response is necessary for this Finding.
Comment: The laboratory did not retain documentation of traceability. The facility recorded date
received and date opened on the bottles, but the traceable connection is lost once the bottles are
discarded. This is a new requirement that has been implemented since the last inspection. The
Quality Assurance Policies for Field Laboratories document states: 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.
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. Notification of acceptable corrective action (i.e., a statement that the receipt log
supplied by the auditor was implemented 4/22/2016) was received by email on 4/22/2016. No
further response is necessary for this Finding.
Proficiency Testing
Comment: The laboratory was not documenting PT sample analyses in the same manner as
environmental samples. This is a new requirement that has been implemented since the last
inspection. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2 document
states: All PT sample analyses must be recorded in the daily analysis records as for any
environmental sample. This serves as the permanent laboratory record. Notification of acceptable
corrective action (i.e., a statement that recording the results on the benchsheet will be
implemented with the 2017 PT samples) was received by email on 4/19/2016. No further
response is necessary for this Finding.
Comment: The preparation of PT samples was not being documented. This is a new requirement
that has been implemented since the last inspection. The Proficiency Testing Requirements,
February 20, 2012, Revision 1.2 document states: 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. Notification of

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acceptable corrective action (i.e., a statement that the practice of initialing, dating and retaining
the instruction sheet for the Total Residual Chlorine sample will be implemented with the 2017 PT
sample) was received by email on 4/19/2016. No further response is necessary for this
Finding.
Comment: The laboratory was not analyzing PT samples in the same manner as compliance
samples. This is a new requirement that has been implemented since the last inspection. The PT
sample was being analyzed multiple times. The Proficiency Testing Requirements, February 20,
2012, Revision 1.2 document states: All PT samples are to be analyzed and the results reported
in a manner consistent with the routine analysis and reporting requirements of compliance
samples and any other samples analyzed according to the requirements of 15A NCAC 2H .0800.
Notification of acceptable corrective action (i.e., a statement that the practice of not analyzing the
PT samples multiple times will be implemented with the 2017 PT samples) was received by email
on 4/19/2016. No further response is necessary for this Finding.
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Temperature — Standard Methods, 2550 B-2000 (Aqueous)
Comment: The benchsheets were lacking pertinent data: Instrument identification. This is a new
requirement that has been implemented since the last inspection. The Approved Procedure for
the Analysis of pH, the Approved Procedure for the Analysis of Total Residual Chlorine and the
Approved Procedure for the Analysis of Temperature documents state: The following must be
documented in indelible ink whenever sample analysis is performed: Instrument Identification.
Notification of acceptable corrective action (i.e., updated benchsheet that included instrument
identification with an implementation date of 4/18/2016) was received by email on 4/19/2016.
No further response is necessary for this Finding.
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Comment: The check standard and calibration standard buffers were not distinguished from
each other. This is considered pertinent data. The benchsheet had true values for a 3, 10, and 7
SU buffer, but there was no indication which were used for calibration and which for the check
standard. The Approved Procedure for the Analysis of pH document states: The following must
be documented in indelible ink whenever sample analysis is performed. True value for the check
standard buffer. Notification of acceptable corrective action (i.e., updated benchsheet with the 7
pH buffer denoted as the QC buffer with an implementation date of 4/18/2016) was received by
email on 4/19/2016. No further response is necessary for this Finding.
Comment: Values were reported that exceed the method specified accuracy of 0.1 units. This
is a new requirement that has been implemented since the last inspection. Standard Methods,
4500 H+ B-2000, (6) states: However, ± 0.1 pH unit represents the limit of accuracy under
normal conditions, especially for measurement of water and poorly buffered solutions. For this
reason, resort pH values to the nearest 0.1 pH unit. Notification of acceptable corrective action
(i.e., a statement that reporting pH results to 0.1 units will be implemented on the April 2016
electronic Discharge Monitoring Report (eDMR)) was received by e-mail on 4/19/2016. No
further response is necessary for this Finding.
Comment: The meter was not always calibrated before use. Occasionally on the weekends, an
analyst would check pH and Temperature of the effluent as an internal systems check, not part of
required monitoring. The values were recorded on the operator's log with no calibration performed
and reported on the eDMR. This was specifically noted on January 10, 2016 and January 22,

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2016. The Approved Procedure for the Analysis of pH document states: Instruments are to be
calibrated according to the manufacturer's calibration procedure prior to analysis of samples each
day compliance monitoring is performed. Notification of acceptable corrective action (i.e., a
statement that the weekend operators will either analyze at the clarifier or if analyzing the effluent,
calibrate the instrument and record on the effluent benchsheet with an implementation date of
4/14/2016) was received by email on 4/25/2016, No further response is necessary for this
Finding.
Temperature — Standard Methods, 2550 B-2000 (Aqueous)
Comment: Temperature was not being analyzed immediately. The sample was being brought
into the lab and analyzed approximately 5 minutes after collection. The Code of Federal
Regulations, Title 40, Part 136; Federal Register Vol. 77, No. 97, May 18, 2012: Table II states:
Parameter number/name: 69. Temperature. Maximum holding time: Analyze. Notification of
acceptable corrective action (i.e., a statement that analyzing Temperature immediately was
implemented on 4/14/2016) was received by e-mail on 4/19/2016. No further response is
necessary for this Finding.
Comment: The temperature sensor on the DO meter had not been verified. Temperature is
measured once per month with the DO meter for the upstream and downstream samples. The
effluent Temperature data was being analyzed with the pH meter, which has been properly
verified. The Approved Procedure for the Analysis of Temperature document states: Any
temperature sensing device, used to measure temperature for compliance monitoring, must be
verified prior to initial use and re -verified any time an instrument is serviced. All thermometers and
temperature measurinq devices must be checked every 12 months against a National Institute of
Standards and Technology (NIST) traceable thermometer. Notification of acceptable corrective
action (i.e., documentation that the temperature sensor on the DO meter was verified on
4/21/2016 with a correction of 0°C) was received by e-mail on 4/22/2016. No further response
is necessary for this Finding.
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
Comment: The meter's internal calibration curve had not been verified. The laboratory purchased
a new meter and put it into use approximately three months ago, without first verifying the internal
curve. The analyst assumed, since it was a new meter, that the manufacture's curve would be
acceptable for 12 months, at which time, the annual curve verification would be performed. Annual
verifications were performed correctly on the previous meter. The Approved Procedure for the
Analysis of Total Residual Chlorine document states: Instruments are to be calibrated according
to the manufacturer's calibration procedure or a standard curve verification must be performed
prior to analysis of samples each day compliance monitoring is performed. Notification of
acceptable corrective action (i.e., documentation showing that the curve verification was
performed satisfactorily on 4/21/2016, with 10 pg/L as the lowest standard) was received by email
on 4/22/2016. No further response is necessary for this Finding.
Comment: The gel standard true value had not been assigned. The value used for the daily gel
check standard was the true value assigned to the old meter. The Approved Procedure for the
Analysis of Total Residual Chlorine document states: The gel/liquid standard verification must be
performed for each instrument on which they are to be used. Notification of acceptable
corrective action (i.e., documentation showing that the gel standard was assigned a true value of
147 pg/L on 4/21/2016 to the new meter and the value is documented on the benchsheet
implemented on 4/25/2016) was received by email on 4/22/2016 and 4/25/2016. No further
response is necessary for this Finding.

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*5039 Wayne Farms LLC
Comment: Values less than the established reporting limit were being reported on the eDMR.
Although the current meter calibration curve had not been verified at the time of the inspection,
the lowest calibration standard concentration verified on the previous meter was 10 pg/L. The
Approved Procedure for the Analysis of Total Residual Chlorine document states: The
concentrations of the calibration standards must bracket the concentrations of the samples
analyzed. One of the standards must have a concentration equal to or below the lower reporting
concentration for Total Residual Chlorine. The lower reporting limit must be less than or equal to
the permit limit. Notification of acceptable corrective action (i.e., a statement that reporting any
sample result below 10 pg/L as <10 pg/L will be implemented on the April 2016 eDMR) was
received by email on 4/25/2016. No further response is necessary for this Finding.
Comment: A reagent blank was not analyzed when preparing and analyzing the annual PT
sample. The Approved Procedure for the Analysis of Total Residual Chlorine document states:
Each day that prepared standards are analyzed a reagent blank must be analyzed to determine
if method analytes or other interferences are present in the laboratory environment, the reagents
or the apparatus. Although the Approved Procedure does not explicitly state that a reagent blank
is required when preparing and analyzing the PT sample, it is the intent that this also applies to
the PT as a Quality Control element that is prepared with reagent water. A reagent blank is made
from the same laboratory water source used to make quality control and/or calibration standards
with DPD. The concentration of reagent blanks must not exceed 50% of the reporting limit (i.e.,
the lowest calibration or calibration verification standard concentration), unless otherwise specified
by the reference method or corrective action must be taken. Notification of acceptable corrective
action (i.e., a statement that the practice of analyzing a reagent blank with the PT sample will be
implemented with the 2017 PT sample) was received by email on 4/22/2016. No further
response is necessary for this Finding.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to eDMRs submitted to the North Carolina Division of Water
Resources. Data were reviewed for January, February and March 2016. The following error was
noted:
Date
Parameter
Location
Value on Client Report
Value on DMR
1/13/2016
rl.fr , .kI .h fl f-
BOD
Effluent
*10.6 mg/L
10.9 mg/L
This is likely a transcription error due to the proximity of 6 and 9 on the number pad of the
keyboard. It appears the facility is doing a good job of accurately transcribing data overall.
V. CONCLUSIONS:
All Findings noted during the inspection were adequately addressed prior to the completion of
this report. The inspector would like to thank the staff for its assistance during the inspection and
data review process. No response is required.
Report prepared by: Beth Swanson Date: April 25, 2016
Report reviewed by: Tonja Springer Date: May 3, 2016