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HomeMy WebLinkAbout#5086-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5086 Laboratory Name: Aqua North Carolina, Inc. Inspection Type: Commercial Field Maintenance Inspector Name(s): Todd Crawford Inspection Date: March 2, 2011 Date Report Completed: March 11, 2011 Date Forwarded to Reviewer: March 11, 2011 Reviewed by: Tonja Springer Date Review Completed: March 15, 2011 Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP Unit Supervisor: Dana Satterwhite Date Received: March 15, 2011 Date Forwarded to Alberta: April 1, 2011 Date Mailed: April 1, 2011 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Aqua North Carolina, Inc. NPDES PERMIT #: NC0055107, NC0065480 and NC0057703 ADDRESS: 105 Hampstead Village Building 24-1 Hampstead, NC 28443 CERTIFICATE #: 5086 DATE OF INSPECTION: March 2, 2011 TYPE OF INSPECTION: Field Commercial Maintenance AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: Ethel Bedgood and Dave McDaniel 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 lab area was clean and well organized. All equipment necessary to perform the certified parameters were present and appeared well maintained. Improvements in quality control and documentation are needed. 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. The requirements associated with Findings A and C are new since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Quality Control A. Finding: The auto-pipettors have not been calibrated annually as required. Requirement: Mechanical volumetric liquid-dispensing devices (e.g., fixed and adjustable auto- pipettors, bottle-top dispensers, etc.) must be calibrated at least every twelve months and documented. Each liquid-dispensing device must meet the manufacturer’s statement of accuracy. For variable volume devices used at more than one setting, check the accuracy at the maximum, middle and minimum values. Testing at more than three volumes is optional. When a device capable of variable settings is dedicated to dispense a single specific volume, calibration is required at that setting only. Ref: Quality Assurance Policies for Field Laboratories. Page 2 # 5086 Aqua North Carolina, Inc. B. Finding: Neither the pH meter, nor the DO meter has had its temperature sensor reading compared to a National Institute of Standards and Technology (NIST) thermometer. 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 zero) on both the meter and on a separate sheet to be filed. Ref: Technical Assistance for Field Analysis of Dissolved Oxygen and Technical Assistance for Field Analysis of pH. Documentation Recommendation: Arrange process control data so that it is not mixed together with regulatory data on the benchsheets and clearly label it as process control data. Recommendation: Arrange documentation on the benchsheet so that each parameter is more clearly linked to its own particular sample collection time and sample analysis time. Recommendation: Add a statement to the benchsheet that pH and Dissolved Oxygen analyses are performed in stream to explain why no sampling time is documented. C. Finding: The laboratory needs to increase the documentation of purchased materials and reagents, as well as, documentation of standards and reagents prepared in the laboratory. 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. D. Finding: Qualifiers on the contract lab reports are not being documented on the Discharge Monitoring Report (DMR). Requirement: 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. Ref: Quality Assurance Policies for Field Laboratories. Page 3 # 5086 Aqua North Carolina, Inc. Comment: Any time that required sample quality control does not meet specified criteria and another sample cannot be obtained, a notation must be made on a comment page and attached to the DMR form. Instructions for filling out a DMR are attached to this report. E. 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. Total Residual Chlorine – Standard Methods, 18th Edition, 4500 Cl G F. Finding: The HACH DR 2700 Chlorine Meter has not had its internal curve on Program 86 verified. Requirement: Most field photometric instruments have factory-set (i.e., stored) calibration programs, which when selected in combination with the optimum wavelength for a particular analysis, give a direct readout in concentration. These stored calibration programs are acceptable for quantitation, but due to possible analyst error, variation in sample or standard preparation, variation in reagents or malfunction of the instrument, the stored calibration must be verified with a laboratory-generated calibration at least every 12 months. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Requirement: For analytical procedures requiring analysis of a series of standards, the concentrations of those standards must bracket the concentration of the samples analyzed. One of the standards must have a concentration equal to the laboratory’s lower reporting concentration for the parameter involved. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Recommendation: It is recommended that the laboratory verify the internal calibration using the concentrations: 25, 40, 50, 200 and 400 µg/L. This will verify the analytical range used to measure Proficiency Testing (PT) samples as well as environmental samples. G. Finding: A calibration check standard is not being analyzed each day that samples are analyzed. Requirement: Instruments are to be calibrated or a calibration check must be performed prior to analysis of samples each day compliance monitoring is performed. Calibration checks must be for the curve and/or program used for sample analysis. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Include all documentation of this process with your response to this report. Recommendation: It is recommended that the laboratory use a 200 µg/L gel-type standard for the daily calibration verification check. This gel-type standard must first be assigned a true value for the specific meter on which it will be used as the daily check standard. The Page 4 # 5086 Aqua North Carolina, Inc. instructions for doing so can found in the Technical Assistance for Field Analysis of Total Residual Chlorine document provided during the inspection. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing field testing records and cont ract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Field testing data were reviewed for NPDES permit # NC0065480 for October, November and December, 2010. The only contract lab data associated with this permit that was reviewed was from October, 2010. The following errors were noted: Date Parameter Location Value on Benchsheet Value on DMR 10/06/10 Suspended Residue Effluent < 3.0 mg/L 2.0 mg/L 10/06/10 Enterococci Effluent <2 est col/100ml 1.0 col/100/ml 10/13/10 Enterococci Effluent <2 est col/100ml 1.0 col/100/ml 10/20/10 Ammonia Effluent < 0.2 mg/L 0.1 mg/L 10/20/10 Enterococci Effluent <2 est col/100ml 1.0 col/100/ml 10/06/10 Suspended Residue Effluent < 2.9 mg/L 2.8 mg/L 10/27/10 Enterococci Effluent e 8 col/100ml 8.0 col/100/ml Please see the attached documents (i.e., NC DWQ NPDES Permitting Guidance for DMR Calculations and Directions For Completing Monthly Discharge Monitoring Reports) for guidance on how to handle calculations involving “less than” and “estimated” results. 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 forwarded 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 honesty and assistance during the inspection and subsequent data discovery and review process. Please respond to all findings. Report prepared by: Todd Crawford Date: March 11, 2011 Report reviewed by: Tonja Springer Date: March 14, 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 b e 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. W hen 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 the 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 (919) 733-3908. 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 usually 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 BOD 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 testing 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 than 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 (919) 807-6300. (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).