HomeMy WebLinkAbout#5317_05_2014_Final
INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #: 5317
Laboratory Name: Town of Rose Hill WWTP
Inspection Type: Field Maintenance
Inspector Name(s): Todd Crawford
Inspection Date: May 8, 2014
Date Report Completed: May 23, 2014
Date Forwarded to Reviewer: May 23, 2014
Reviewed by: Nick Jones
Date Review Completed: May 27, 2014
Cover Letter to use: Insp. Initial Insp. Reg.
Insp. No Finding Insp. CP
Corrected
Unit Supervisor/Chemist III: Dana Satterwhite
Date Received: May 29, 2014
Date Forwarded to Linda: June 16, 2014
Date Mailed: June 16, 2014
_____________________________________________________________________
On-Site Inspection Report
LABORATORY NAME: Town of Rose Hill WWTP
NPDES PERMIT #: NC0056863
ADDRESS: PO Box 8
Rose Hill, NC 28458
CERTIFICATE #: 5317
DATE OF INSPECTION: May 8, 2014
TYPE OF INSPECTION: Field Maintenance
AUDITOR(S): Todd Crawford
LOCAL PERSON(S) CONTACTED: Ben Hilliard
I. INTRODUCTION:
This laboratory was inspected by a representative of the North Carolina Wastewater/Groundwater
Laboratory Certification (NC WW/GW LC) program to verify its compliance with the requirements of 15A
NCAC 2H .0800 for the analysis of environmental samples.
II. GENERAL COMMENTS:
The laboratory was clean and well organized. The facility has all the equipment necessary to perform the
analyses. Records were also well organized and quickly retrieved upon request.
Proficiency Testing (PT) samples for the 2014 proficiency testing calendar year have not yet been
analyzed. The laboratory is reminded that these results must be submitted to this office directly from the
vendor by September 30, 2014.
Current quality assurance policies for Field Laboratories and approved procedures for the analysis of
the facility’s currently certified parameters were provided at the time of the inspection.
The requirements associated with Findings B through K have been implemented by our program since
the last inspection.
Contracted analyses are performed by Vann Labs (Certification #22) and Environmental Chemists, Inc.
(Certification #94).
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Equipment
Comment: The pH meter manual has been lost and it could not be confirmed that the calibration was
being performed according to the manufacturer’s instructions. In the absence of the manufacturer’s
instructions, Standard Methods 4500 H+ B-2000 states: Although manufacturers provide operating
instructions, the use of different descriptive terms may be confusing. For most instruments, there are two
controls: intercept (set buffer, asymmetry, standardize) and slope (temperature, offset): their functions are
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shown diagrammatically in Figures 4500-H’:1 and 2. The intercept control shifts the response curve
laterally to pass through the isopotential point with no change in slope. This permits bringing the
instrument on scale (0 mV) with a pl-l 7 buffer that has no change in potential with temperature. The slope
control rotates the emf/pH slope about the isopotential point (0 mV/pH 7). To adjust slope for temperature
without disturbing the intercept. select a buffer that brackets the sample with pH 7 buffer and adjust slope
control to pH of this buffer. The instrument will indicate correct millivolt change per unit pH at the test
temperature.
The calibration procedure that was in place did not satisfy the method requirements. Until such time that a
manual can be produced or a new meter can be purchased, the calibration procedure will be performed
as was agreed to by the analyst in a phone conversation on June 9, 2014. That procedure is as follows:
1. Set meter setting to “pH”.
2. Place probe in the pH 7 buffer and allow reading to stabilize.
3. Adjust the reading to 7.00 with the “calibration” knob.
4. Rinse probe and place in the pH 10.00 buffer.
5. Allow meter to stabilize and adjust reading to 10.00 with the “temperature” knob.
6. Set meter setting to “ATC”.
7. Rinse probe and place in the pH 4.00 buffer and allow reading to stabilize.
8. pH 4.00 buffer must read between 3.9 and 4.1 with no adjustment.
9. It is also recommended to check the 7.00 buffer again and make sure it reads between 6.9
and 7.1 with no adjustment.
Requirement: Please provide copies of the benchsheets from June 9th through the date of the
response to this report as documentation of the acceptability of the calibration procedure as it is
described above.
Documentation
A. Finding: The laboratory needs to increase the documentation of purchased reagents.
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.
Comment: Dates received and opened were written on the pH buffer bottles and Total Residual
Chlorine reagent packages. While this can provide a traceability link to analyses by looking at the
dates that the chemicals were in use, that link is lost once the bottles/packages are discarded.
Comment: A form was provided during the inspection that could be used to satisfy this
requirement.
B. Finding: The meters used for Temperature, pH, Dissolved Oxygen and Total Residual Chlorine
were not identified on the benchsheets.
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Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: Instrument identification. Ref: NC WW/GW LC Approved Procedure for the Analysis of
Temperature, NC WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC
Approved Procedure for the Analysis of Dissolved Oxygen and NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine.
C. Finding: The facility was not identified on the benchsheets for Temperature, pH, and Dissolved
Oxygen.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: Sample site including facility name and location, ID, etc. Ref: NC WW/GW LC
Approved Procedure for the Analysis of Temperature, NC WW/GW LC Approved Procedure for
the Analysis of pH and NC WW/GW LC Approved Procedure for the Analysis of Dissolved
Oxygen.
D. 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.
Comment: The use of Wite-Out® was observed.
Proficiency Testing
E. Finding: The preparation of the Total Residual Chlorine Proficiency Testing (PT) sample is not
documented.
Requirement: PT samples received as ampules must be diluted according to the PT provider’s
instructions. The preparation of PT samples must be documented in a traceable log or other
traceable format. The diluted PT sample becomes a routine environmental sample and is added
to a routine sample batch for analysis. Ref: Proficiency Testing Requirements, February 20,
2012, Revision 1.2.
Comment: Dating and initialing the instruction sheet for the preparation of the Total Residual
Chlorine PT would satisfy the documentation requirement.
F. Finding: The laboratory is not analyzing Proficiency Testing (PT) samples in the same manner
as environmental samples.
Requirement: All PT samples are to be analyzed and the results reported in a manner
consistent with the routine analysis and reporting requirements of compliance samples and any
other samples analyzed according to the requirements of 15A NCAC 2H .0800. Ref: Proficiency
Testing Requirements, February 20, 2012, Revision 1.2.
Comment: The laboratory was analyzing pH PT samples multiple times and reporting an
average of all results. Environmental samples are not analyzed and reported in this manner.
Comment: The laboratory’s common practice was to analyze a known standard along with the
PT sample as additional quality control. Since this is not performed with all environmental
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samples, it is considered additional quality control. However, known samples are recommended
when analyzing remedial PT samples as part of the troubleshooting and corrective action
process.
G. Finding: The laboratory is not documenting Proficiency Testing (PT) sample analyses in the
same manner as environmental samples.
Requirement: All PT sample analyses must be recorded in the daily analysis records as for any
environmental sample. This serves as the permanent laboratory record. Ref: Proficiency
Testing Requirements, February 20, 2012, Revision 1.2.
Comment: 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.
Total Residual Chlorine – Standard Methods, 4500 Cl G-2000
H. Finding: Two of the five standards used in the calibration curve verification did not meet the
required acceptance criteria.
Requirement: 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. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Total Residual Chlorine. Submit all documentation with your response to this
report.
Comment: The 10 µg/L standard had a percent recovery of 140 and the 30 µg/L standard had a
percent recovery of 133.
Recommendation: Since the permitted discharge limit is 17µg/L, it is recommended that the
lowest concentration standard in the five-standard annual standard curve verification be 15 µg/L
I. Finding: A check standard is not analyzed each day that samples are analyzed.
Requirement: When a five-standard annual standard curve verification is used, the laboratory
must check the calibration curve each analysis day. To do this, the laboratory must analyze a
calibration blank to zero the instrument and analyze a check standard each day that samples
are analyzed. The value obtained for the check standard must read within 10% of the true value
of the check standard. If the obtained value is outside of the ±10% range, corrective action
must be taken. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual
Chlorine.
Comment: Purchased “Gel-type” or sealed liquid ampoule standards may be used for daily
standard curve verification only. These standards must be verified initially and every 12
months thereafter, with the standard curve. When gel standard concentrations are verified
every 12 months with five-standard curve verification, they may be used after the
manufacturer’s expiration date. It is only necessary to verify the gel standard which falls within
the concentration range of the curve used to measure sample concentrations. For example, if
you are measuring samples against a low range curve, a 200 g/L standard would be verified,
and not the 800 g/L standard since the 800 g/L standard would be outside of the low level
curve concentration range. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total
Residual Chlorine.
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J. Finding: The analyst’s signature or initials are not documented 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 bench sheets must provide a space for the signature or initials of the
analyst, and proper units of measure for all analyses. Ref: 15A NCAC 02H .0805 (g) (1) and
NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine.
K. Finding: Results below the reporting limit of 10 µg/L are routinely reported in the Discharge
Monitoring Report (DMR).
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 10 μg/L residual chlorine lower reporting limit, then you must analyze at least a 10 µg/L or
lower standard and report lower concentrations as “< 10 μg/L” or less than the concentration of
the chosen standard. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total
Residual Chlorine.
Comment: Values should be documented on the benchsheet exactly as they are displayed on
the meter. However, if that value is less than lowest standard concentration in the 5-point curve
verification (10 µg/L), then it must be documented as “<10 µg/L” in the daily cell on the DMR.
When calculating an arithmetic mean for the monthly average, you may consider a "less than"
value as equal to zero.
pH - Standard Methods, 4500 H+ B-2000
L. Finding: Values were reported that exceed the method specified accuracy of 0.1 units.
Requirement: By careful use of a laboratory pH meter with good electrodes, a precision of
±0.02 unit and an accuracy of ±0.05 unit can be achieved. However, ± 0.1 pH unit represents
the limit of accuracy under normal conditions, especially for measurement of water and poorly
buffered solutions. For this reason, report pH values to the nearest 0.1 pH unit. Ref: Standard
Methods, 4500 H+ B-2000, (6).
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 Resources. Data were
reviewed for December, 2013 and January and February, 2014. The following errors were noted:
Date Parameter Location Value on Benchsheet
*Contract Lab Data Value on DMR
01/15/14 pH Effluent 7.69 S. U.# 7.50 S. U.
02/05/14 Fecal Coliform Effluent * <1 col/100 ml 0.5 col/100 ml##
# Following the requirement cited in Finding L, this value should have been reported as 7.7 S.U. on the DMR.
## This value should have been reported as <1 col/100 ml in the daily cell of the DMR. When calculating a geometric
mean for fecal coliform, you may consider a “less than” value as equal to “one”.
It was also noted that all values for samples collected on January 27th were report as being collected on
January 28th and all values for samples collected on January 28th were report as being collected on
January 29th.
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In addition, it was also noted that values with a “less than” sign were reported in the “average” field on the
DMR. When calculating an arithmetic mean, you may consider a "less than" value as equal to zero.
Therefore, if all monthly values are “less than” values, the monthly arithmetic average would be “zero”.
Please see the attached documents (i.e., NC DWQ NPDES Permitting Guidance for DMR Calculations
and Directions for Completing Monthly Discharge Monitoring Reports) for additional guidance.
In order to avoid questions of legality, it is recommended that you contact the appropriate Regional Office
for guidance as to whether an amended Discharge Monitoring Report will be required. A copy of this
report will be made available to the Regional Office
V. CONCLUSIONS:
Correcting the above-cited findings will help this lab to produce quality data and meet certification
requirements. The inspector would like to thank the staff for its assistance during t he inspection and
data review process. Please respond to all findings.
Report prepared by: Todd Crawford Date: May 23, 2014
Report reviewed by: Nick Jones Date: May 27, 2014
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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" k ey, (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)
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4th root of 150,000,000 = 111 (rounded from 110.66819 - value on calculator)
use only whole numbers when reporting fecal coliform back to top
PROCEDURE 2
1. Add together the base 10 logarithms for the data values.
2. Divide the sum by the number of values added.
3. Take the antilog of the result of step 2. This will again be the geometric mean.
To do this on the calculator, key the data value and press the "log" key. Then press "+" and repeat for all
values. After the last logarithm is entered, press "=" to get the sum. Divide by the number of values that
were added. Press the "INV"key and then press the "log" key.
Example: (again, using 50, 100, 150 and 200 as data values)
Base 10 logarithm of: 50 is 1.69897
100 is 2.0
150 is 2.1760913
200 is + 2.30103
Sum = 8.1760913
8.1760613 / 4 = 2.0440228
Antilog of 2.0440228 = 111 (rounded from 110.66819 - value on calculator)
* Calculation may be performed in the same manner (although calculation values will be different) using
natural logarithms (lnx).
Use of "Less Than" Values
Complications may arise in calculations when dealing with testing results showing values of less than a
minimum detection level for the testing method. Current Division policy gives permittees the benefit of
doubt all the way to the lowest levels when performing calculations using such "less than" values. When
calculating an arithmetic mean, you may consider a "less than" value as equal to zero. For the calculation
of a geometric mean, a "less than" value may be considered to be equal to one. Remember, this
procedure pertains only to the calculation of an average. You must report individual data values on the
DMR exactly as reported to you by your laboratory. If you are doing calculations with "less than" (<)
values, here is how they should be handled:
a) Calculating an arithmetic mean
In calculating the arithmetic mean, "less than" values may be considered to equal zero (0). If all results for
a particular parameter during the month are "less than," the average for the month would be zero. The
maximum and minimum, however, should be recorded as the "less than" values.
Example: (using 10, 15, 20 and <5 as data values)
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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.
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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 dependent 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”
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* 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)
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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.
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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
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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.
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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
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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).