#5420_0113_finalTC_2015_

a
900CRDERK
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R, van der Vaart
Governor Secretary
January 23, 2015
5420
Mr. Josh Batchelor
Butterball, LLC
PO Box 589
Mt. Olive, NC 28365
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Batchelor:
Enclosed is a report for the inspection performed on January 13, 2015 by Mr. Todd Crawford.
Where finding(s) are cited in this report, a response is required. Within thirty days of receipt, please
supply this office with a written item for item description of how these finding(s) were corrected. If
the finding(s) cited in the enclosed report are not corrected, 'enforcement actions may be
recommended. 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 us at (919)
733-3908.
Attachment
cc: Todd Crawford
Sincerely,
Dana Satterwhite, Environmental Program Supervisor
Division of Water Resources
Water Sciences Section
NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mail Service Center, Raleigh, North Carolina 27699-1623
Location, 4405 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone]
Internet: www.dwalab.orq
An Equal Opportunity 1 Affirmative Action, Employer

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5420
Laboratory Name:
Butterball, LLC
Inspection Type:
Industrial Maintenance
Inspector Name(s):
Todd Crawford
Inspection Date:
January 13,
2015
Date Report Completed:
January 14,
2015
Date Forwarded to Reviewer:
January 14,
2015
Reviewed by:
Tonia Springer
Date Review Completed:
January 16,
2015
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:
January 16,
2015
Date Forwarded to Linda:
January 23,
2015
Date Mailed:
January 23,
2015

LABORATORY NAME:
WATER QUALITY PERMIT # :
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
On -Site Inspection Report
Butterball, LLC
W00000884
PO Box 589
Mt. Olive, NC 28365
5420
January 13, 2015
Industrial Maintenance
Todd Crawford
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
Josh Batchelor and Jefferson Foy
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:
The facility has all the equipment necessary to perform the analyses. Laboratory personnel communicate
well with sample collectors and coordinate sample analyses effectively to manage workload and holding
times.
Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2014 proficiency
testing calendar year and the graded results were 100% acceptable. PT samples for the 2015 proficiency
testing calendar year have not yet been analyzed. The laboratory is reminded that these results must be
submitted to this office directly from the vendor by September 30, 2015.
Contracted analyses are performed by Environmental Chemists, Inc. (Certification #94).
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:
Documentation
Comment: The benchsheet for pH and Total Residual Chlorine (TRC) was lacking the following required
information: .
• Sample site including facility name and location, ID, etc.
• Date and time of sample collection.

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• Date and time of sample analysis to verify the 15 minute holding time is met.
• Collector's/analyst's name or initials.
• Meter calibration and meter calibration time(s).
• True values of the standards used for calibration or standard curve verification.
• True value of the TRC check standard and pH check standard buffer.
• Value obtained for the TRC check standard (verification of ± 10% recovery).
• Units of measure.
• Instrument identification.
The NC WW/GW LC Approved Procedure for the Analysis of pH and the NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine documents both state: The following must be
documented in indelible ink whenever sample analysis is performed:
• Date and time of sample collection.
• Date and time of sample analysis to verify the 15 minute holding time is met.
• Sample site including facility name and location, ID, etc.
• Collector's/analyst's name or initials.
• Meter calibration and meter calibration time(s).
• Instrument identification.
The NC WW/GW LC Approved Procedure for the Analysis of pH document states: The following must be
documented in indelible ink whenever sample analysis is performed:
• True values of buffers used for calibration.
• True value for the check standard buffer.
• Value obtained for the check standard buffer (verification of ± 0.1 S.U.).
• True value and value obtained for the post analysis calibration verification(s), where applicable.
• Report all data values to the nearest 0.1 pH unit.
The NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine document states:
The following must be documented in indelible ink whenever sample analysis is performed:
• True values of the standards used for calibration or standard curve verification.
• True value of the check standard.
• Value obtained for the check standard (verification of ± 10% recovery).
• All data must be reported in mg/L or pg/L (i.e., as specified in the permit).
Portions of these requirements are new policies that have been implemented by our program since the
last inspection. Notification of acceptable corrective action (i.e., a statement that an updated benchsheet,
provided by the auditor, which includes all the required documentation listed above, would be put into use
on January 15, 2015) was received by email on January 14, 2015. Demonstration of acceptable
corrective action (i.e., a completed benchsheet for samples analyzed from 1/19/2015 through 1/21/2015)
was received by email on January 22, 2015. No further response is necessary for this finding.
Comment: The laboratory needed to increase the documentation of purchased materials and reagents.
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. 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

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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. Demonstration of acceptable corrective action (i.e., a copy of the auditor supplied Lab
Supply Receipt Log showing all required documentation for reagents currently in use) was received by
email on January 16, 2015. No further response is necessary for this finding.
A. 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
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: Obliterated and over -written entries, as well as the use of correction tape were
observed.
Total Residual Chlorine — SM 4500 Cl G-2000
Comment: The analysis of a calibration check standard was not being consistently performed. The NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine states: When a five -
standard annual standard curve verification is used, the laboratory must check the calibration curve each
analysis day. To do this, the laboratory must analyze a calibration blank to zero the instrument and
analyze a check standard each day that samples are analyzed. The value obtained for the check
standard must read within 10% of the true value of the check standard. If the obtained value is outside of
the ±10% range, corrective action must be taken. Demonstration of acceptable corrective action (i.e., a
completed benchsheet with documented analysis of a calibration verification standard for samples
analyzed from 1/19/2015 through 1/21/2015) was received by email on January 22, 2015.
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 September, October and November, 2014. The following error
was noted: The "less than" signs were consistently omitted from applicable concentration values in the
daily cells of the DMR. When this occurred, the monthly averages were incorrectly calculated. The NC
DWR NPDES Permitting Calculation of Data document states: Complications may arise in calculations
when dealing with testing results showing values of less than a minimum detection level for the testing
method. Current Division policy gives permittees the benefit of doubt all the way to the lowest levels when
performing calculations using such 'less than" values. When calculating an arithmetic mean, you may
consider a 'less than" value as equal to zero. For the calculation of a geometric mean, a 'less than" value
may be considered to be equal to one. Remember, this procedure pertains only to the calculation of an
average. You must report individual data values on the DMR exactly as reported to you by your
laboratory. The NC DWR NPDES Permitting Instructions for Completing a DMR states: Values of results
which are less than a detectable limit should be reported in the daily cells using the 'less than" symbol (<)
and the detectable limit used during the testing (or the value with appropriate unit conversion). Please
note there is never a case when an average would need to be recorded along with a "less than" symbol.

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In order to avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether amended Discharge Monitoring Reports will be required. A copy of
this report will be made available to the Regional Office.
V. CONCLUSIONS:
Correcting the above -cited finding 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: January 14, 2015
Report reviewed by: Tonja Springer Date: January 16, 2015