#5263_0113_final

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NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R, van der Vaart
Governor Secretary
January 28, 2015
5263
Ms. Peggy Henry
Bay Valley Foods, LLC
354 N. Faison Ave.
Faison, NC 28341
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Ms. Henry:
Enclosed is a report for the inspection performed on January 13, 2015 by Mr. Todd Crawford.
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 electronic mail, or if you have questions or need additional information, please contact
me at [phone].
Sincerely,
Dana Satterwhite, Environmental Program Supervisor
Division of Water Resources
Attachment
cc: Todd Crawford
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.d_ tab.or
An Fqual OppMundty tAHiRnafive Action Employer

INSPECTION REPORT ROUTING SHEET
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 Linda:
Date Mailed:
5263
Bay Valley Foods, LLC
Industrial Maintenance
Todd Crawford
January 13, 2015
January 21, 2015
January 21, 2015
Jason Smith
January 21. 2015
❑ Insp. Initial ❑ Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
® Corrected ❑ Insp. Reg. Delay
Dana Satterwhite
1 /22/2015
1 /27/2015
1 /28/2015

On -Site Inspection Report
LABORATORY NAME:
NPDES PERMIT #:
NC GENERAL PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
Bay Valley Foods, LLC
NC0001970
NCG060000
354 N. Faison Ave.
Faison, NC 28341
5263
January 13, 2015
Industrial Maintenance
Todd Crawford
Donovan Brock and Johnny Killette
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.
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 Pace Analytical Services, Inc. (Certification #'s 40 and 67).
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 used for pH, Dissolved Oxygen (DO) and Temperature was missing
instrument identification information. The NC WW/GW LC Approved Procedure for the Analysis of pH,
the NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen and the NC WW/GW LC
Approved Procedure for the Analysis of Temperature documents state: The following must be
documented in indelible ink whenever sample analysis is performed: Instrument identification. This
requirement is a new policy that has been implemented by our program since the last inspection.
Demonstration of acceptable corrective action (i.e., an updated benchsheet showing the meter

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#5263 Bay Valley Foods, LLC
identifications) was received by email on January 16, 2015. No further response is necessary for this
finding.
Comment: The laboratory was only writing the date received and the date opened on the reagent bottles.
Additional documentation of purchased materials and reagents was needed. 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. Consumable materials such as pH buffers and lots of
pre -made standards are included in this requirement. This requirement is a new policy that has been
implemented by our program since the last inspection. 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 21, 2015. No further response is necessary for this
finding.
Comment: Data qualifiers on the contract lab reports were not being transferred to the Discharge
Monitoring Report (DMR). The Quality Assurance Policies for Field Laboratories document states: When
quality control (QC) failures occur, the laboratory must attempt to determine the source of the problem
and must apply corrective action. Part of the corrective action is notification to the end user. If data
qualifiers are used to qualify samples not meeting QC requirements, the data may not be useable for the
intended purposes. It is the responsibility of the laboratory to provide the client or end -user of the data
with sufficient information to determine the usability of the qualified data. Where applicable, a notation
must be made on the Discharge Monitoring Report (DMR) form, in the comment section or on a separate
sheet attached to the DMR form, when any required sample quality control does not meet specified
criteria and another sample cannot be obtained. This requirement is a new policy that has been
implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., a
statement that all future data qualifiers would be transferred to the monthly DMRs) was received by email
on January 15, 2015. No further response is necessary for this finding.
Comment: Values were reported that exceed the method specified accuracy of 0.1 units. Standard
Methods, 4500 H+ B-2000, (6) states in part: 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, report PH values to the nearest 0.1 PH unit. Notification of acceptable corrective action (i.e., a
statement that pH results would be reported to 0.1 units) was received by e-mail on January 15, 2015. No
further response is necessary for this finding.
Comment: The laboratory was not documenting Proficiency Testing (PT) sample analyses in the same
manner as environmental samples. The Proficiency Testing Requirements, February 20, 2012, Revision
1.2 document states: The analysis of PT samples is designed to evaluate the entire process used to
routinely report environmental analytical results; therefore, PT samples must be analyzed and the process
documented in the same manner as environmental samples. All PT sample analyses must be recorded
in the daily analysis records as for any environmental sample. This requirement is a new policy that has
been implemented by our program since the last inspection. Notification of acceptable corrective action
(i.e., a statement that all future PT sample analyses would be documented in the same manner and on
the same benchsheet as routine compliance samples) was received by email on January 15, 2015. No
further response is necessary for this finding.
Comment: Error corrections were not performed properly. The use of correction tape, as a means of
error correction, was observed. 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.

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#5263 Bay Valley Foods, LLC
I UT
Notification of acceptable corrective action (i.e., a statement that the use of correction tape has been
ended and that all future error corrections would be correctly performed) was received by email on
January 15, 2015. No further response is necessary for this finding.
Dissolved Oxygen — Standard Methods, 4500 O G-2001
Comment: The Dissolved Oxygen (DO) meter was not being calibrated according the manufacturer's
instructions. The meter was being calibrated with the probe exposed to the ambient air instead of being
in the meter's calibration well and exposed to water saturated air. The calibration section of the YSI 55
operator's manual states in part: Insure the sponge is in the chamber and wet. Insert the probe into the
calibration chamber. Notification of acceptable corrective action (i.e., a statement that the full calibration
instructions have been printed out and attached to the benchsheet and that calibrations are now being
properly performed) was received by email on January 14, 2015. No further response is necessary for
this finding.
Comment: The NC WW/GW LC Approved Procedure for Analysis of Dissolved Oxygen (DO) document
states: When performing analyses away from the certified laboratory's primary location, a post analysis
calibration verification must be analyzed at the end of the run. It is recommended that a mid -day
calibration verification be performed when samples are analyzed over an extended period of time. The
calculated DO value must verify the meter reading within ±0.5 mg/L. If the meter verification does not
read within ±0.5 mg/L of the theoretical DO, corrective action must be taken. The laboratory was
already performing post analysis calibration verifications at the end of the run; however, the procedure
was being performed with the probe outside of the calibration well. Post analysis drift checks must be
performed with the probe in the calibration well.
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 Bay Valley Foods, LLC (NPDES Permit # NC0001970) for
September, October and November, 2014. The following error was noted:
Date
Parameter
Location
Value on Benchsheet/
Value on DMR
*Contract Lab Data
10/14/14
Conductivity
Effluent
* 6570 µmhos/cm
6670 µmhos/cm
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 made available to the Regional Office.
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: Todd Crawford
Report reviewed by: Jason Smith
Date: January 21, 2015
Date: January 21, 2015