#5158-final

INSPECTION REPORT ROUTING SHEET

To be attached to all inspection reports in-house only.

Laboratory Cert. #: 5158

Laboratory Name: Topsail Greens Subdivision

Inspection Type: Field Municipal Maintenance

Inspector Name(s): Todd Crawford

Inspection Date: April 6, 2011

Date Report Completed: April 18, 2011

Date Forwarded to Reviewer: April 18, 2011

Reviewed by: Tonja Springer

Date Review Completed: April 20, 2011

Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP _ Corrected

Unit Supervisor: Dana Satterwhite

Date Received: April 26, 2011

Date Forwarded to Alberta: April 28, 2011

Date Mailed: April 28, 2011

_____________________________________________________________________
On-Site Inspection Report

LABORATORY NAME: Topsail Greens Subdivision

NPDES PERMIT #: NC0487797

ADDRESS: P.O. Box 70
Hampstead, NC 28443

CERTIFICATE #: 5158

DATE OF INSPECTION: April 6, 2011

TYPE OF INSPECTION: Field Municipal Maintenance

AUDITOR(S): Todd Crawford

LOCAL PERSON(S) CONTACTED: Gregory H. Wright

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 facility has no enclosed area in which to do analyses. Analyses are performed out in the open or
under the lid of a large permanent enclosure used to store equipment. All equipment necessary to
perform the certified parameters were present and appeared well maintained.

A description of current field lab policies and technical assistance documents for the analysis of the
facility’s currently certified parameters were provided at the time of the inspection.

III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:

pH – Standard Methods, 18th Edition, 4500 H+ B

A. Finding: Data values are reported on the Discharge Monitoring Report to 0.01 S.U. not 0.1
S.U. as required by the method.

Requirement: A variance of ± 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. Ref: Standard Methods, 18th Edition, 4500 H+ B.
(6).

B. Finding: The temperature sensing device on the pH meter has not been calibrated against an
NIST certified or traceable thermometer annually (every 12 months).

Requirement: All temperature sensing devices on meters must be calibrated against a NIST
certified or NIST traceable thermometer annually (every 12 months) and proper corrections
made and documented. The meter reading must be less than 1ºC from the NIST certified
reading to be acceptable. Document the serial number and manufacturer of the NIST
thermometer that was used in the comparison. Document any correction that applies (even if
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#5158 Topsail Greens Subdivision

zero) on both the meter and on a separate sheet to be filed. Ref: Technical Assistance for Field
Analysis of pH.

pH – SW-846 Method 9040 C

C. Finding: The values of the buffers used for calibration are not being documented.

Requirement: The value of buffers used for calibration must be documented whenever sample
analysis is performed. Ref: Technical Assistance for Field Analysis of pH.

D. Finding: The sample collection time is not being documented.

Requirement: The time and date of sample collection must be documented whenever sample
analysis is performed. Ref: Technical Assistance for Field Analysis of pH.

Residue, Settleable – Standard Methods, 18th Edition, 2540 F

Recommendation: It is recommended that the Imhoff cone be replaced due to a hazing of the plastic
that is obscuring the graduations.

E. Finding: The time of the sample collection is not being documented.

Requirement: The time of sample collection must be documented whenever sample analysis is
performed. Ref: Technical Assistance for Field Analysis of Settleable Solids.

F. Finding: The time of the 45 minute sample stir is not being documented.

Requirement: The time of 45 minute sample stir must be documented whenever sample
analysis is performed. Ref: Technical Assistance for Field Analysis of Settleable Solids.

IV. PAPER TRAIL INVESTIGATION:

The paper trail consisted of comparing field testing records and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Field testing
data were reviewed for NPDES permit # NC0487797 for December, 2010, and January and February,
2011.

No transcription errors were detected, however, values with a “less than” sign were reported in the
“average” field on the DMR. When calculating an arithmetic mean, you may consider a "less than"
value as equal to zero. Therefore, if all monthly values are “less than” values, the monthly arithmetic
average would be “zero”. Please see the attached documents (i.e., NC DWQ NPDES Permitting
Guidance for DMR Calculations and Directions for Completing Monthly Discharge Monitoring Reports)
for additional guidance.

V. CONCLUSIONS:

Correcting the above-cited findings and implementing the recommendation will help this lab to produce
quality data and meet certification requirements. The inspector would like to thank the staff for its
honesty and assistance during the inspection and subsequent data discovery and review process.
Please respond to all findings.

Report prepared by: Todd Crawford Date: April 18, 2011
Report reviewed by: Tonja Springer Date: April 20, 2011

NC DWQ NPDES Permitting Guidance for DMR Calculations

Averages
Data “averages” recorded on DMRs should produce the arithmetic mean for all parameters with the exception of
Fecal Coliform. The average for Fecal Coliform should be calculated as the geometric mean of the values.

Arithmetic Mean
This is the simple, common averaging of a series of numbers. You add a group of numbers together to get the
sum. Then you divide the sum by the number of values you added to get the sum. The result is the arithmetic
mean or average of the series of numbers.

Example:

5.30

6.21

4.00

5.25

+ 8.72
______________

29.48

29.48 / 5 = 5.896 (round off to 5.90 = average)

This calculation is used for averaging of all parameters except for Fecal Coliform (code number 31616).

Geometric Mean
There are two ways to go about calculating the geometric mean. The two procedures are really just different ways
of doing the same thing and either way yields the same result, but both require the use of a scientific calculator.
Calculators adequate for performing such operations as the geometric mean can probably be purchased for less
than $15.00. With the calculator, follow these steps:

PROCEDURE 1 (we think this is the easier of the two)

1. Multiply all the data values together.

2. Take the "nth" root of the product of the multiplication, where "n" is the number of values multiplied. In other
words, if you multiply 4 values and get a result, take the 4th root of the product. This is the geometric mean.

To do this on the calculator, get the product of multiplication, then press (1) the "INV" key, (2) the "yx" key, and (3)
the "nth" root number. Labeling of keys and functions will vary with different brands of calculators. Consult your
calculator’s user’s manual for the specific procedure to perform these functions.

Example: (Using as data the numbers: 50, 100, 150 and 200)

50 x 100 x 150 x 200 = 150,000,000 (1.5x108)

4th root of 150,000,000 = 111 (rounded from 110.66819 - value on calculator)

use only whole numbers when reporting fecal coliform back to top

PROCEDURE 2

1. Add together the base 10 logarithms for the data values.

2. Divide the sum by the number of values added.

3. Take the antilog of the result of step 2. This will again be the geometric mean.

To do this on the calculator, key the data value and press the "log" key. Then press "+" and repeat for all values.
After the last logarithm is entered, press "=" to get the sum. Divide by the number of values that were added.
Press the "INV"key and then press the "log" key.

Example: (again, using 50, 100, 150 and 200 as data values)

Base 10 logarithm of: 50 is 1.69897

100 is 2.0

150 is 2.1760913

200 is + 2.30103

Sum = 8.1760913

8.1760613 / 4 = 2.0440228

Antilog of 2.0440228 = 111 (rounded from 110.66819 - value on calculator)

* Calculation may be performed in the same manner (although calculation values will be different) using natural
logarithms (lnx).

Use of "Less Than" Values
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. If you
are doing calculations with "less than" (<) values, here is how they should be handled:

a) Calculating an arithmetic mean

In calculating the arithmetic mean, "less than" values may be considered to equal zero (0). If all results for a
particular parameter during the month are "less than," the average for the month would be zero. The maximum
and minimum, however, should be recorded as the "less than" values.

Example: (using 10, 15, 20 and <5 as data values)

10

15

20

+ 0 (<5)
_________________

45

45 / 4 = 11.25 (round off to 11

b) Calculating a geometric mean

In calculating the geometric mean, all "less than" values may be considered to equal one (1). This is due to t he
nature of the calculation; zeros may not be used in the calculation of the geometric mean. If all testing results for
Fecal Coliform during a particular month came back as "less than" values, the geometric mean for the month

would be one (1). The maximum and minimum for the month, however, should be recorded as the "less than"
values.

Example: (using Procedure 1 noted above and 10, 15, 20 and <5 as data)

10

15

20

x 1 (<5)
_________________

3000

4th root of 3000 = 7.400828 (record on DMR as 7)

If these procedures are followed, there is never an instance when a "less than" value should be reported as a
monthly average. Using these procedures, a discreet value can always be obtained for either the arithmetic or
geometric mean. We (the compliance staff) realize that this policy does not necessarily represent good chemistry,
but it allows for a standard practice in dealing with this type of data.

Please note that it is a requirement of your permit that you utilize testing methods that can evaluate the discharge
to levels low enough so as to demonstrate compliance with permit limits. For example, if you are required to
monitor for a parameter with a limit of 50 m g/L, you must utilize a test that can analyze to at least that level. If
current laboratory technology will not allow for a parameter to be analyzed to the permit limit, you must utilize the
best available method for that parameter. If the analyses using that method show no detection of the parameter in
question, you will be considered in compliance. Questions regarding laboratory methods and practices can be
answered by the staff of the Division of Water Quality’s Laboratory Section, by calling [phone].

Use of "Greater Than" Values
Such values are only expected (infrequently) in the reporting of Fecal Coliform and (even less frequently) BOD. It
is a violation of reporting rules to report a Fecal Coliform value of "Too Numerous To Count" (TNTC). For fecal
coliform, "greater than" (> ##,###) values denote at least one, and possibly all volumes of the evaluated sample
yielded results outside the method range for accurate counting of the colonies of bacteria (or TNTC). Laboratories
should perform enough dilutions to the sample to produce a discreet number as the result of testing. If a "greater
than" value is reported, the numeric portion of the value should be sufficiently high so as to make the facility aware
of the extent of any problems with disinfection.

For both fecal coliform and BOD, the generation of a "greater than" value usua lly occurs when characteristics of
the effluent differ from what is normally discharged. If laboratories "set up" the test procedures based upon normal
conditions, they may not have the capacity to get an accurate measurement of higher fecal coliform or BO D
concentrations, hence the reported "greater than" value. If you are suspicious or aware of conditions at your plant
that cause you to believe effluent pollutant concentrations are beyond their normal levels, you should inform your
laboratory of your concern so modifications to testing procedures can be made.

For calculation purposes only, when you report a "greater than" value, the numeric portion of the value must be
used to calculate the average (arithmetic or geometric mean). The actual result of test ing must be reported in the
daily cell on the DMR.

Conversion from mg/L to lbs/day
Some permits have parameters limited in units of pounds per day (lbs/day). Laboratories report the concentrations
(such as mg/L) of sample characteristics as a result of testing. They cannot report the daily load in lbs/day
because that total is dependant upon the amount of flow carrying a known concentration. But if the concentration
of a pollutant and the daily flow from the facility are known, the daily load in lbs/day can be calculated:

Multiply the concentration (in mg/L) x daily flow (in MGD) x 8.34 (a constant). This formula will yield the result in
units of lbs/day. You must be certain to use data values with the noted units of measurement to get the proper

result from this particular formula. Other units of measurement (like m g/L or GPD) may be used, but you will need
to modify the constant (which is a composite number representing all the unit conversions).

Estimated Results

“Estimated” results should be reported as the number with the “estimated” qualifier. When averaging results with
estimated values, use the estimated number and report the average as “estimated”.

Example: (using 10, 15, 20 and e5 as data values)

10

15

20

+ 5 (e5)
_________________

50

50 / 4 = 12.5 Round the result to 12 and report as “estimated”

* Remember when rounding numbers that end 5, to round off the preceding digit to the nearest even number: thus
2.25 becomes 2.2 and 2.35 becomes 2.4, as described in Standard Methods 1050 B. (2)

DIRECTIONS FOR COMPLETING MONTHLY DISCHARGE MONITORING REPORTS
Revised 3/2009
(Forms MR-1, MR-1.1, MR-2 & MR-3)

I: FACILITY INFORMATION
1. NPDES Permit No. Operator In Responsible Charge
2. Discharge No. Grade
3. Facility Name Certified Laboratory
4. Class Person(s) Collecting Samples
5. County Signature Of Operator In Responsible Charge
II: DATA REPORTING
1. Operator Arrival Time Units of Measurement
2. Operator Time On Site Additional Parameters
3. ORC on Site? Average, Maximum, Minimum
4. Data Sample Type
5. Flow Monthly Limit
6. Parameter Codes
III: FACILITY STATUS INFORMATION
1. Status Information
2. Signature of Permittee
IV: STREAM MONITORING INFORMATION
1. Stream
2. Location
V: GENERAL
1. Submitting Reports Calculations
2. Appearance Enforcement
3. Order of Report Forms Number of Reports
4. Multiple Submittals Permits for Other Program Areas
5. Toxicity Reporting Corrected or Amended Reports
6. Contacts

I. FACILITY INFORMATION
1. NPDES Permit No. - Number issued by the Division of Water Quality consisting of
the letters "NC" followed by a seven digit number. Information from non-discharge
facilities should not be reported on the MR series of forms.
2. Discharge No. - Three-digit number which corresponds to the effluent pipe for which
the data are being reported (i.e., 001, 002, 003, etc.). Numbers are found within the
NPDES permit.
3. Facility Name - Name of the facility as it appears on the NPDES permit.
4. Class - The class of the facility as designated by the Water Pollution Control System
Operators Certification Commission. The rating will be either 0, I, II, III or IV. You
should enter the water quality classification of the receiving stream in this space.
Revised 3/2009
5. County - County in which the discharge outfall is located.
6. Operator In Responsible Charge -The printed name of the certified WWTP operator
designated as operator in responsible charge. Unrated (class 0) facilities do not require an
operator in responsible charge.
7. Grade - Certificate grade of the operator in responsible charge as awarded by the
Water Pollution Control System Operators Certification Commission.
8. Certified Laboratory - Name of the certified laboratory (-ies) performing analyses (if
applicable).
9. Person(s) Collecting Samples - Printed name of the individual who collected the
sample for which the data was reported. In the case of several individuals, please specify
as a group name, such as "operators" or "staff," etc.

10. Signature Of Operator In Responsible Charge - Dated signature of the operator in
responsible charge. Each month’s report must include an original signature in ink. Copies
are not acceptable.

II. DATA REPORTING
1. Operator Arrival Time -Record the time of arrival of a certified operator using a
2400 clock value. If the facility is staffed by operators 24 hours a day, record the arrival
time of the 1st shift operator.
2. Operator Time On Site - Record the number of hours spent by certified operators at
the facility. If the facility is staffed on all three shifts, enter "24." If more t han one
operator is on duty at the same time, this value is not the sum of all hours worked by the
operators, but the total number of hours the facility was staffed.
3. ORC On Site? - Record yes (Y) or no (N) as to whether the designated ORC visited
the site on that date. If the designated backup operator served as ORC on a particular day,
record "B" in this column for that date. It is also appropriate to record "H" in the cell if
the date is a legal holiday.
4. Data - Enter the analytical results for each sample under the appropriate parameter
code in the row that corresponds to the day upon which the sample was taken. Please note
that Flow should always be reported as a decimal number (do not use scientific notation)
in units of millions of gallons per day (MGD), unless the permit states otherwise.
5. Parameter Codes - Codes for the more commonly monitored parameters can be found
on the back of form MR-1 or MR-1.1. A complete list of parameter codes can be found
on the NPDES website.
6. Units of Measurement - All data values must be accompanied by corresponding units
of measurement, noted at the top of the data column for the particular parameter. If your
permit contains a numeric limit for any parameter, then the reporting units must be the
same units of measurement of that limit. If your reporting units are other than those on
Revised 3/2009
the pre-printed form, the printed units should be marked out and the reporting units be
clearly designated at the top of the column.
7. Additional Parameters - Enter the appropriate parameter code, name of the parameter
and units of measurement in the space provided.
8. Average, Maximum, Minimum - Enter the average, maximum and minimum values
for the results recorded in the data column. Please note no average is to be calculated for
pH. Any average for Fecal Coliform is to be calculated as a geometric mean. If you are
uncertain about how to calculate the geometric mean, please contact your local DWQ
Regional Office or a member of the NPDES Compliance/Enforcement Unit staff at (919)
807-6300. If only one value is reported for a parameter during the reporting month, that
value should be reported as the average, maximum and minimum.
9. Sample Type - Enter the sample description in each column for which data is being
reported. Enter the letter "C" for composite or the letter "G" for grab.
10. Monthly Limit - Enter the monthly limit for each parameter as found in the current
NPDES permit, Special Order by Consent or Judicial Order by Consent.

III. FACILITY STATUS INFORMATION
1. Facility Status - Mark the appropriate box to show whether facility was compliant or
noncompliant with regard to permit, SOC or JOC requirements. If noncompliant, use the
comment section to explain in detail the course of action taken or to be taken to achieve
compliance.
2. Signature of Permittee - Record the name of the permittee or his or her authorized
agent (printed or typed), the dated signature of that person and a mailing address and
phone number at which he or she may be reached during working hours. If someone other
than the permittee is to be the signatory, the requirement noted by the double asterisk
"**" must be met. Also record the expiration date of the current permit in this section.

While this is not on the form, you may also wish to provide an e-mail address in this
space that can provide the Division with another avenue of communication.

IV. STREAM MONITORING INFORMATION
1. Stream - Name of the stream from which the upstream or downstream monitoring
samples are taken.
2. Location - Location of the site on the stream from which the sample was taken. This
may be recorded as a distance (e.g. "100 feet upstream of outfall") or a specific location
(e.g. "S.R. 1111").
V. GENERAL
1. Submitting Reports - An original and one copy of each month’s monitoring report is
required to be submitted to the Division of Water Quality’s Central Files office (address
Revised 3/2009
listed on form MR-1) and must be received by the Division within thirty (30) days after
the end of the month for which the report is made.
2. Appearance - Forms must be completed in ink. Please make all entries on forms
legible. All information other than signatures must be printed or typed. If you fill out
forms by hand, please make sure the originals are completed in ink and that all entries are
legible. Copies of the original report must also be readable and must include a
reproduction of the backside of the effluent reporting form containing the permittee’s
certification. If you utilize a computer-generated report, you must also ensure that the
report is legible and that proper copies are made. DWQ will notify if you are the user of
a form that is deemed deficient and will advise you of what modifications need to be
made.
3. Calculations
(a) Averages. All averages are to be calculated as the arithmetic mean of the
recorded values with the exception of that of Fecal Coliform, which is to be
calculated as a geometric mean. If you are uncertain about how to calculate the
geometric mean, please contact your local DWQ Regional Office or a member of
the NPDES Compliance/Enforcement Unit staff at [phone].
(b) Use of "less than" values. For calculation purposes only, recorded values of
less than a detectable limit (< #.##) may be considered to equal zero (0) for all
parameters except Fecal Coliform, for which values of "less than" may be
considered to be equal to one (1). 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.
(c) Use of "greater than" values. Such values are only expected (and then only
infrequently) in the reporting of Fecal Coliform and BOD. If a "greater than"
value is reported, the numeric portion of the value should be sufficiently high so
as to make the facility aware of the extent of any problems with treatment
efficiency. Upon receipt of "greater than" testing results, a facility should consult
its laboratory to see if changes in testing procedure need to be made in order to
get discreet values from the analysis. For calculation purposes only, the numeric
portion of the value must be used to calculate either an arithmetic or geometric
mean.
4. Enforcement - Failure to comply with any of the requirements listed above may result
in the facility being issued a Notice of Violation or being subject to other appropriate
enforcement action.
5. Order of Report Forms - DMR submittals typically include the results of monitoring
of the facility’s effluent, its influent and its receiving stream. It is requested that for any
DMR, the report be bound with the Effluent page(s) (DWQ form MR-1 or MR-1.1) on
top, followed by the Influent page (form MR-2, if influent monitoring is required) and
finally the Upstream/Downstream page (form MR-3).

6. Number of Reports - You are required to submit the original and one copy of the
report to DWQ. Each copy should be a discreet report for the month, put together in the
order described above.
7. Multiple Submittals - School systems and contract operations, please take note of this
request. If you submit reports for multiple permits within one mailing, please bind
together the submittals (original and one copy) for the various facilities. Please do not
segregate the reports into any other type of organization (e.g., binding together all
effluent or stream monitoring pages). To do so will cause reports to be taken apart and
placed together properly, which slows processing and introduces opportunity for mistakes
to be made. If you send many DMRs in one envelope, it is advisable that you send a
summary sheet along with the DMRs that lists what reports are contained in the package.
8. Permits for Other Program Areas - Please note that this discussion pertains to
submittal of DMRs required of NPDES permittees (point source discharge pipes to
streams). You may have permits for activities in other program areas such as DWQ’s non
discharge program (wastewater spray irrigation or land application of residuals) or the
Division of Environmental Health’s public water supply program (drinking water). Please
consult those permits for instructions for their submittal. It is not advisable to submit any
other reports along with your DMR submittals.
9. Toxicity Reporting - Some permittees will have monitoring requirements for Toxicity
within their permits. Please be aware that this parameter has a dual reporting requirement.
Results of toxicity testing should be reported on DMR forms, but the toxicity testing
results forms must be submitted to the Aquatic Toxicity Unit at the address listed below.
Aquatic Toxicology Unit
DWQ Environmental Sciences Branch
1621 Mail Service Center Raleigh, NC 27699-1621
10. Corrected or Amended Reports - In the event that you omit or erroneously report
data on a DMR, the information should be updated with the submittal of an amended
report. To best handle the amended data, the following procedure is recommended:
1. Regenerate or make a copy from your files of the DMR previously submitted to
DWQ.
2. Make changes to the individual data points on the form, including updated
summary information.
3. Initial and highlight changes to the original submittal.
4. At the top of the reporting page, write very conspicuously: "Amended Report" or
"Corrected Report."
5. Provide a short cover page describing the changes to the DMR or note changes in
the comment area on the back of the MR-1 form.
Use of this procedure will be a great help to DWQ’s data entry staff. Without
specifically identifying changes on the DMR, each data point must be evaluated
between the original and amended reports to ensure the values in our database are
correct. Calling attention to just those values that are changed both speeds up our
processes and decreases the possibility for errors to be made.
Revised 3/2009
11. Contacts - DWQ deals with a tremendous number of permitted entities that may be
experiencing their own changes involving administration and personnel. In dealing with
NPDES permit matters, DWQ must deal with only one representative of the permitted
facility (someone with authority to see that changes are made at the facility if they are
necessary) in order to be effective. You are encouraged to keep DWQ informed of any
updates as to the person responsible for the permit, addresses or phone numbers in order
to facilitate the best possible communication between our two organizations. This can be
done by sending an e-mail to our Unit or by using the back of the MR-1 form under the
permittee certification section. Regulations regarding who may be deemed responsible
for a permit and who may sign as the "permittee" on the DMR can be found
(respectively) in the North Carolina Administrative Code in sections 15A NCAC 2H
.106(e) and 15A NCAC 2B .0506 (b)(2).