#5523 11-final

INSPECTION REPORT ROUTING SHEET

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

Laboratory Cert. #: #5523

Laboratory Name: Total Environmental Solutions

Inspection Type: Field Commercial Maintenance

Inspector Name(s): Jeffrey R. Adams & Dana Satterwhite

Inspection Date: July 26, 2011

Date Report Completed: August 15, 2011

Date Forwarded to Reviewer: August 23, 2011

Reviewed by: Jason Smith

Date Review Completed: August 26, 2011

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

Unit Supervisor: Dana Satterwhite

Date Received: September 1, 2011

Date Forwarded to Linda: September 2, 2011

Date Mailed: September 2, 2011

____________________________________________________________________

On-Site Inspection Report

LABORATORY NAME: Total Environmental Solutions, Inc.

NPDES PERMIT #: NC0042510

ADDRESS: 20 Lake Royale
194 Chippewa Drive
Louisburg, NC, 27549

CERTIFICATE #: 5523

DATE OF INSPECTION: July 26, 2011

TYPE OF INSPECTION: Field Commercial Maintenance

AUDITOR(S): Jeffrey R. Adams and Dana Satterwhite

LOCAL PERSON(S) CONTACTED: Jack Gibbons

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 organized. All chemicals and reagents were within their expiration dates. Records
were well maintained, however, some quality control procedures need to be implemented.

The inspection was prompted by two unacceptable Proficiency Testing (PT) sample results for Total
Residual Chlorine (TRC) and failure to respond to requests for information from this office. It was found
that the laboratory had not received communications from this office and multiple methods for
communicating with the lab were given during the audit. With respect to the PT failures, it was discovered
that the laboratory did not have the proper volumetric glassware and equipment to prepare the PT
samples for analysis. The laboratory obtained appropriate glassware and prepared and analyzed two PT
samples during the inspection. Since the inspection, the results have been received from the PT vendor
and the two consecutive TRC PTs were graded acceptable. Because the instrument measures
environmental samples against an internal factory-set calibration and because environmental samples do
not have to be measured using volumetric glassware, it is believed the PT failures are not indicative of
error in routine effluent sample testing.

The laboratory has fulfilled its 2010 and 2011 PT requirements for TRC and its 2010 PT requirements for
pH. As a reminder, the 2011 PT results for pH must be received in this office no later than October 31,
2011.

The laboratory was given a packet containing North Carolina Laboratory Certification quality control
requirements and policies during the inspection.

The requirement associated with Finding A is a new policy that has been implemented since the last
inspection.

III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:

Traceability

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. 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. Refer to the Standard and Reagent Preparation Log and Reagent Receipt Log
examples attached to the report.

pH – Standard Methods, 18th Edition, 4500 H+ B
Dissolved Oxygen – Standard Methods, 18th Edition, 4500 O G

Comment: It was noted that the laboratory analyst was not recording the check buffer and calibration
buffer measurements under the correct column headings on the laboratory benchsheet for pH.
Accurate data records are vital to the legal defensibility of data.

Recommendation: The laboratory states the temperature sensor checks were performed by a
commercial laboratory. It is recommended that the laboratory request that the commercial lab label the
instruments with the date and the correction factor, even if zero, when the temperature sensor checks
are performed. If the commercial lab does not provide this service, then you must transcribe this
information to your meter.

B. Finding: The laboratory is not posting the temperature correction on the pH and Dissolved Oxygen
(D.O.) meters.

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 documentation must include the
serial number of the NIST certified thermometer or NIST traceable thermometer that was used
in the comparison. 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; Technical Assistance for Field Analysis of Dissolved Oxygen.

D. Finding: The laboratory is not recording units of measure (i.e., S.U. for pH and mg/L for DO)
on the benchsheet.

Requirement: Data pertinent to each analysis must be maintained for five years. Certified Data
must consist of date collected, time collected, sample site, sample collector, and sample
analysis time. The field benchsheets must provide a space for the sig nature or initials of the
analyst, and proper units of measure for all analyses. Ref: 15A NCAC 02H .0805 (g) (1). See
attachment for copy of an example benchsheet.

Total Residual Chlorine – Standard Methods, 18th Edition, 4500 Cl G

Recommendation: It is recommended that the laboratory obtain the following supplies for accurate
environmental analysis and PT sample preparation: lens wipes to clean fingerprints from
spectrophotometer cuvettes, a pipetting bulb or other pipette filler to safely draw liquid into volumetric
pipettes and a Nalgene® squirt bottle to accurately bring standards and/or PT samples to volume with
deionized water.

Recommendation: It is recommended that the laboratory use the instrument timer to monitor the three
minute reaction time for color development after DPD addition.

E. Finding: The spectrophotometer’s internal calibration curve was verified using the incorrect meter
program.

Requirement: A verification of the internal calibration curve must be performed annually. This is
performed by verifying the readings of five standards. The concentrations of the five standards
must bracket the concentration of the samples analyzed. One of the standards must have a
concentration equal to or below the permitted discharge limit. The values obtained must not
vary by more than 10% of the true value for standards equal to or greater than 50 µg/L and 25%
of the true value for standards less than 50 µg/L. If the stored program readings vary by more
than the above acceptance criteria, the stored calibration program should not be used for
quantitation until troubleshooting is carried out to determine and correct the source of error. Ref:
Technical Assistance for Field Analysis of Total Residual Chlorine. Please submit a copy of the
new verification curve with the inspection report reply.

Comment: An annual verification curve was performed in October, 2010 by Tritest, Inc., but it
was analyzed on the wrong program (i.e., program 85). The Ultra Low Level Total Residual
Chlorine program (86) is used for compliance monitoring and must be verified annually.

Recommendation: It is recommended that the laboratory verify the internal calibration using
the concentrations: 10, 20, 50, 200 and 400µg/L. This will verify the analytical range used to
measure Proficiency Testing (PT) samples as well as environmental samples.

F. Finding: The gel standard, used as the daily check standard, has not been assigned a true
value on the meter program used for routine samples.

Requirement: Purchased “Gel-type” or sealed liquid ampoule standards used for daily
calibration verification must be verified initially and every 12 months thereafter, with the
standard curve. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Please
submit a copy of the new verification curve with the inspection report reply.

G. Finding: PT samples are not documented in the same manner as environmental samples.

Requirement: The analysis of PT samples is designed to evaluate the entire process used to
routinely report environmental analytical results. Therefore, PT samples must be analyzed and
the process documented in the same manner as environmental samples. Ref: Quality
Assurance Policies for Field Laboratories.

IV. PAPER TRAIL INVESTIGATION:

The paper trail consisted of comparing laboratory benchsheets and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were

reviewed for the Lake Royale Bathhouse Facility (NPDES permit #NC0042510) for March, April, and
May, 2011.

No transcription errors were detected, however, the laboratory was calculating an arithmetic mean for
fecal coliform instead of a monthly geometric mean and values reported with a “less than” sign in the
daily cells were not used correctly for monthly average calculations. When calculating an arithmetic
mean, you may consider a "less than" value as equal to zero. W hen calculating a geometric mean for
fecal coliform, you may consider a “less than” value as equal to 1. 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 DMR reporting guidance and instructions for
calculating a geometric mean.

In order to avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether amended Discharge Monitoring Reports will be required. A copy of
this report will be 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: August 15, 2011
Report reviewed by: Jason Smith Date: August 26, 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" k ey. 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
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 neces sarily 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 f requently) 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 meas urement (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 unit s 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 t he
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)

Standard and Reagent Prep Log
Lab ID Chemical Name Date
Prepared
Procedure Followed Expiration
Date
Date
Discarded

Lab Supply Receipt Log
Lab ID Item Name Vendor Lot # Date
Received
Expiration
Date
Date
Opened
Date
Discarded