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HomeMy WebLinkAbout#5511 11-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5511 Laboratory Name: Nature Trails MHP WWTP Inspection Type: Field Maintenance Inspector Name(s): Jeffrey R. Adams Inspection Date: April 19, 2011 Date Report Completed: May 3, 2011 Date Forwarded to Reviewer: May 3, 2011 Reviewed by: Todd Crawford Date Review Completed: May 4, 2011 Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP ___ Corrected Unit Supervisor: Dana Satterwhite Date Received: May 4, 2011 Date Forwarded to Alberta: May 18, 2011 Date Mailed: May 18, 2011 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Nature Trails MHP WWTP NPDES PERMIT #: NC0043257 ADDRESS: 10006 Hammock Bend Chapel Hill, NC 27517 CERTIFICATE #: 5511 DATE OF INSPECTION: April 19, 2011 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Jeffrey R. Adams LOCAL PERSON(S) CONTACTED: Pete Saulsbury 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 laboratory was clean and well organized. The facility has all the equipment necessary to perform the analyses. Proficiency testing samples have been analyzed for all certified parameters for the 2010 proficiency testing calendar year and the graded results were 100% acceptable. The laboratory is operating under a new operator-analyst and significant improvements in instrument maintenance, data recording and overall organization of the laboratory were observed since the last inspection. The laboratory was given a packet containing technical assistance documents describing individual parameter requirements, North Carolina Wastewater/Groundwater Laboratory Certification quality control requirements and policies during the inspection. Findings A and B are new policies that have been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation A. 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 (where specified). 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, Page 2 #5511 Nature Trails MHP WWTP 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 primary standards, chemicals, reagents, and materials used for a period of five years. Consumable materials such as pH buffers, lots of pre-made standards and/or media, solids and bacteria filters, etc. are included in this requirement. Ref: Quality Assurance Policies for Field Laboratories. Comment: The laboratory is sharing pH buffers with a municipal laboratory; however, the manufacturer’s name, lot number and expiration date is not labeled on the sub-sampled containers, and a hard copy record of traceability to the parent bulk containers is not kept. Recommendation: It is recommended that the laboratory use a laboratory benchsheet, which includes spaces to record the traceability information. An example benchsheet was left at the lab during the audit. Dissolved Oxygen – HACH Method 10360 (LDO) Comment: The laboratory is analyzing Dissolved Oxygen (DO) with a Luminescence Dissolved Oxygen (LDO) meter, but only the membrane DO method is listed on the laboratory’s field parameter certificate. Please submit an Amendment to Application form requesting the addition of the LDO technology so that your laboratory certificate attachment accurately reflects the DO method currently being used. B. Finding: The Luminescence Dissolved Oxygen (LDO) meter calibration is not being verified each day of use. Requirement: LDO probes must be calibrated or have the calibration verified each day of use. Ref: North Carolina W astewater/Groundwater Laboratory Certification document, Luminescence DO (LDO) Daily Check. Comment: A copy of the solubility table and verification procedure was left with the analyst during the inspection. Dissolved Oxygen – Standard Methods, 18th Edition, 4500 O G Dissolved Oxygen – HACH Method 10360 (LDO) pH – Standard Methods, 18th Edition, 4500 H+ B Comment: The laboratory was not recording units of measure (i.e., mg/L for DO and S.U. for pH) on benchsheets. 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, samples site, sample collector, and sample analysis time. The field bench sheets must provide a space for the signature of the analyst, and proper units of measure for all analyses. Laboratory personnel corrected the benchsheets by adding the units of measure to the column headers during the inspection. No further response is necessary for this finding. C. Finding: The temperature sensing device on the D.O. and pH meters has not been calibrated against an NIST certified or traceable thermometer annually (i.e., every 12 months). Requirement: The temperature sensor in the meter must be checked every 12 months against an NIST certified or NIST traceable thermometer and the process documented even if the instrument is not used for reporting temperature results. The temperature correction (even if it is zero) must be posted on the meter as well as in hard copy format (to be retained for 5 years). Ref: Technical Assistance for Field Analysis of pH. A copy of the NIST temperature sensor verification check must be submitted with this report. Page 3 #5511 Nature Trails MHP WWTP Comment: You may have trouble getting your NIST thermometer re-certified. As part of an initiative to reduce the use of mercury in products, EPA is working with stakeholders to reduce the use of mercury-containing non-fever thermometers in industrial and commercial settings. The National Institute of Standards and Technology (NIST), which is working with EPA on this effort, announced on February 2, 2011 that it will no longer calibrate mercury-in-glass thermometers for traceability purposes beginning on March 1, 2011. Other vendors may follow this lead. Additional information on the phase-out of mercury-filled thermometers and selecting alternatives to mercury-filled thermometers can be found on the following EPA website: http://www.epa.gov/hg/thermometer.htm. Total Residual Chlorine – Standard Methods, 18th Edition, 4500 Cl G D. Finding: The laboratory’s observed value for the 10 µg/L calibration verification standard varied by more than 25% of the known value. Requirement: Analyze a water blank to zero the instrument and then analyze a series of five standards. The curve verification must check 5 concentrations (not counting the blank) that bracket the range of the samples to be analyzed. This type of curve verification must be performed at least every 12 months. The values obtained must not vary by more than 10% of the known value for standard concentrations greater than or equal to 50 g/L and must not vary by more than 25% of the known value for standard concentrations less than 50 g/L. The overall correlation coefficient of the curve must be ≥0.995. Comment: The value obtained for the 10 µg/L verification standard was 14 µg/L. Recommendation: It is recommended that the laboratory take extreme care when pipetting the calibration verification standards and refer to the technical assistance document when preparing the calibration verification curve. A copy of this document was presented to the analyst during the inspection. Comment: This verification procedure may be performed by the permitted facility or may be contracted to a vendor or another laboratory. E. Finding: The laboratory is using an incorrect reporting limit. Results of <14 µg/L are being routinely reported even though the calibration curve verification is performed at 10 µg/L. Requirement: One of the standards must have a concentration equal to or below the lower reporting concentration for Total Residual Chlorine. Example: If the laboratory chooses to have a lower reporting limit of 100 μg/L for residual chlorine, you must analyze at least 100 µg/L or lower standard and report lower concentrations as < 100 μg/L or < the concentration of the chosen standard. Ref: NC WW/GW LC Technical Assistance for Field Analysis of Total Residual Chlorine (revision date 9/07). A new annual calibration verification curve must be prepared and a copy of the results submitted with the response to this report. F. Finding: The laboratory has not assigned a meter-specific concentration on program 86 to the gel standard being used as a daily check standard. Requirement: When the laboratory analyzes the new 5-point calibration verification, analyze the 200 µg/L gel standard with the new curve. The assigned values will be used for the next twelve months, or until a new curve verification is performed. The gel/liquid standard verification must be performed for each instrument on which they are to be used. If multiple instruments and/or standard sets are used, each must have assigned values specific for the Page 4 #5511 Nature Trails MHP WWTP instrument and standard set. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Submit a copy of the documentation of the new curve and gel standard analysis with the response to this report. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing field data and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for Nature Trails MHP WWTP (NPDES permit #NC0043257) for December, 2010, January and February, 2011. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing data. Comment: All Total Residual Chlorine data was recorded on benchsheets as <14 µg/L but was recorded on the DMRs as 14 µg/L in the daily cells. The analyst stated the electronic DMR form would not accept “less than” values in the daily cells. The Directions for Completing Monthly Discharge Monitoring Reports states: 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. 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. Comment: For Total Suspended Solids, the contract laboratory is reporting an improper Practical Quantitation Limit (PQL). The contract laboratory PQL is 1.0 mg/L. The minimum weight gain allowed by any approved method is 2.5 mg. Laboratories must choose a sample volume to yield between 2.5 and 200 mg dried residue. This establishes a minimum reporting value of 2.5 mg/L when 1000 mL of sample is analyzed. In instances where the weight gain is less than the required 2.5 mg, the value must be reported as less than the appropriate value based upon the volume used. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods, 20th and 21st Editions, 2540 D. (3) (b). The inspector contacted the contract laboratory and was assured that all future reporting results would be based on the 2.5 mg minimum weight gain requirement; however, it is recommended that the laboratory also contact its contract laboratory and the regional office regarding this data reporting discrepancy. 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 assistance during the inspection and data review process. Please respond to all findings. Report prepared by: Jeffrey R. Adams Date: May 3, 2011 Report reviewed by: Todd Crawford Date: May 4, 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. Page 2 #5511 Nature Trails MHP WWTP 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 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 Page 3 #5511 Nature Trails MHP WWTP 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 dete ction 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 sam ple 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 concentra tions (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: Page 4 #5511 Nature Trails MHP WWTP 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) Page 5 #5511 Nature Trails MHP WWTP 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 Page 6 #5511 Nature Trails MHP WWTP 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 Page 7 #5511 Nature Trails MHP WWTP 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 Page 8 #5511 Nature Trails MHP WWTP 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 Page 9 #5511 Nature Trails MHP WWTP 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).