HomeMy WebLinkAboutNC0027103_Biomonitoring Inspection_20010216North Carolina
Department of Environment and Natural Resources
Division of Water Quality
Fayetteville Regional Office
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Kerr T. Stevens, Director February 16, 2001
Mr. McDuffie Cummings, Town Manager
Town of Pembroke
P.O. Box 866
Pembroke, NC 28372
Subject: COMPLIANCE BIOMOMTORING INSPECTION
Town of Pembroke Wastewater Treatment Plant
NPDES Permit No. NC0027103
Robeson County
Dear Mr. Cummings:
ATA 4:1
NCDENR
Enclosed you will find a copy of the Compliance Biomonitoring Inspection report for the
inspection conducted the week of February 5, 2001. The inspection included the same objectives as that
of a routine Compliance Evaluation Inspection (conducted on February 6, 2001) plus an Aquatic Toxicity
(AT) test to evaluate the biological effect of the facility's discharge on test organisms. As part of the
inspection a tour of the Wastewater Treatment Plant was conducted. All observations and
recommendations are in Part D: Summary of Findings/Comments of this inspection report. A 24-hour
effluent composite sample at Outfall 001 was collected on February 6 and February 9 by Dale Lopez and
Don Register of the Division of Water Quality for use in a chronic Ceriodaphnia dubia pass/fail toxicity
test. The aquatic toxicity analysis was completed by the Division of Water Quality Aquatic Toxicology
Laboratory, located on Reedy Creek Road in Raleigh. The pass/fail toxicity test, using these samples,
resulted in a Pass, indicating that the effluent would not be predicted to have water quality impacts on the
receiving waters. Additionally, on February 6, 2001, the above mentioned 24-hour Outfall 001
composite was sampled for the .following parameters: Biochemical Oxygen Demarid (BOD), Total
Suspended Solids (TSS), Ammonia as nitrogen, Total Kjeldahl Nitrogen, Nitrite plus Nitrate as nitrogen,
and Total Phosphorus. The results of these analyses will be forwarded to you when they are completed
by the Division of Water Quality Chemistry Laboratory, located on Reedy Creek Road in Raleigh.
If you have any questions or comments concerning this report or require clarification on part(s) of
this report, please feel free to contact me at 910/486-1541.
incerely,
Dale Lopez
Environmental Specialist II
/dl
Enclosures
cc: DWQ, ESB, ATU, Kevin Bowden
Gerry Harris, Town of Pembroke, (ORC)
225 GREEN STREET —SUITE 714 / SYSTEL BUILDING / FAYETTEVILLE, NC 28301-5043
PHONE (910) 486-1541 FAX (910) 486-0707 WWWV.ENR.STATE.NC.US/ENR/
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER— 50% RECYCLED/10% POST CONSUMER PAPER
DENR TOLL FREE HOTLINE: 1-877-623-6748
1
NPDES COMPLIANCE INSPECTION REPORT
North Carolina Division of Water Quality
Fayetteville Regional Office
Section A. National Data System Coding
Transaction Code: N NPDES NO. NC0027103 Date: 010206 Inspection Type: B
Inspector: S Facility Type: 1 Reserved:
Facility Evaluation Rating: 4 BI: N QA: N Reserved:
Section B: Facility Data
Name and Location of Facility Inspected:
Town of Pembroke WWTP
Entry Time: 02:00 PM Permit Effective Date: 000601
Exit Time/Date: 04:30 PM/010206 Permit Expiration Date: 040731
Name(s), Title(s) of On -Site Representative(s):
Garry Harris, Public Works Director — (Certified Grade III) — "ORC"
Karen Dial, WWTP Manager — (Certified Grade III) — "Backup Operator"
Rhonda Locklear - (Certified Grade II) — "Laboratory Supervisor"
Jerry Brooks "Maintenance Operator"
Phone Number: (910) 521-2989
Name, Title and Address of Responsible Official:
Mr. McDuffie Cummings, Town Manager
Town of Pembroke
P.O.Box866
Pembroke, North Carolina 28372
• Section C: Areas Evaluated during Inspection
Contacted: No
(S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated, N/A = Not Applicable
Permit: S .
. Records/Reports:. S.
Facility Site Review: S
Flow Measurement: S
Laboratory: S
Effluent/Receiving Waters: S",.. .
Pretreatment: N/A
Compliance Schedule: 'NIA
Self -Monitoring Program: S .
Operation&Maintenance: S.
Sludge Disposal: S
Other:: `: .
Pembroke Wastewater Treatment Plant (WWTP)
BIOMONITORING EVALUTATION INSPECTION
performed during the week of February 5, 2001
DESCRIPTION of Pembroke WWTP:
The 1.33 MGD wastewater treatment plant consists of a mechanical bar screen, grit removal, influent
pump station, dual oxidation ditches (one ditch is being used, 534,000 gallons capacity each), dual
clarification (both are being used, 206,000 gallons capacity each), chlorine contact chamber, de -
chlorination, cascade post -aeration, and sludge digestion.
SECTION D: SUMMARY OF FINDINGS/COMMENTS:
PLANT TOUR---
1. Measurements of the clarifier sludge blankets:
clarifier #
clarifier depth
sludge blanket depth
1
14 feet
7 feet
2
14 feet
9 feet
2. The Outfall 001 Discharger Monitoring Report (DMR) for October 2000, was cross-checked with the
laboratory bench sheets. There were 81 data points that were cross-checked for pH, residual
chlorine, Biochemical Oxygen Demand (BOD), ammonia nitrogen, Total Suspended Solids (TSS),
fecal coliform. All data were in agreement.
3. The grit pump was not operating in the automated mode, (needs mechanical repair).
4. The screenings, grit, and grease removal were hauled to the Robeson County Landfill.
5. The influent pump station has three pumps. VFD #2 was not operating, the drive unit has been out -
of service for the last six months.
6. One oxidation ditch was in operation. The dissolved oxygen was 0.8 to 1.0 mg/L. The most recent
Mixed Liquor Suspended Solids (MLSS) results were 4,000 mg/L.
7. Chlorine was flow paced and the sulfur dioxide was residual paced. The chlorine residual meter
readout was 0.4.
8. The effluent Outfall 001 was easily accessible.
9. CITI, LLC-Systems Integrator last calibrated the flow meter on February 28, 2000 ["Flow
measurement devices shall be accurately calibrated at a minimum of once per year": 15A NCAC 2B
.0505 (b)(1)].
10. Sludge is handled by Porter Environmental, permitted through Porter, to be land applied on land
owned by Porter, at a maximum of 100,000 gallons per month.
11. The aerobic sludge digester appeared to have a level over full.
12. The solids did not appear to be settling well. A 30-minute Settleability Test was performed on the
oxidation ditch's Mixed Liquor, and the solids remained in suspension (this indicates an old sludge
with a low F/M ratio).
13. Technical assistance is available at our office upon request.
14. Before the inspection, there was not a thermometer in the effluent compositor refrigerator. The
temperature of the effluent sample was routinely being recorded after it was received at the
laboratory, and the temperatures met the acceptable temperature rang' of 0 to 4. degrees Centigrade
(as according to the official storage temperature requirement published in 40 CFR Part 136.3(e),
Table II). During the inspection a thermometer was placed in the effluent compositor refrigerator,
and the temperature of the effluent compositor is now being recorded. It will be cross-checked
annually with an NIST certified thermometer.
15. The telescopic valve in the aerobic digester was under repair. As of Monday, February 12, it has
been repaired and put back into service for supernating..
LABORATORY TOUR---
1. Laboratory parameters that are analyzed on site: pH, Residual Chlorine, Biochemical Oxygen
Demand (BOD), Ammonia Nitrogen, Total Suspended Solids (TSS), Fecal Coliform, Dissolved
Oxygen, SOUR test, and temperature.
2. Mercury, Total Nitrogen, and Total Phosphorus are sent to Environmental Science Corporation in Mt.
Juliet, TN (NC Cert. #375).
3. Chronic Toxicity is analyzed by Meritech.
4. The pH buffer expiration dates are:
Buffer
Date
pH 4
10/01/01
pH 10
09/30/01
pH 7
11/30/01
5. The millivolts of the 7 pH buffer is 14.7 mV.
6. The pH, chlorine, and dissolved oxygen analyses are performed within fifteen minutes of collection.
7. TSS weights are measured on a Mettler AE 160. A 0.2 gram weight crosscheck is performed daily.
8. Laboratory temperatures:
Instrument
Temperature (degrees C)
BOD Incubator
21.0
Sample Refrigerator
0.5
TSS Drying Oven
105
Fecal Coliform
44.6
9. The pH meter is sloped with the pH 7 and pH 4 buffers. Afterwards, the 7 pH buffer is read. It
should read between 6.9 to 7.1 pH units.
10. An NIST crosscheck of all of the thermometers is performed and documented annually.
•
RECOMMENDATIONS---
1. Recommend that, in order to calculate the % error, the ultrasonic flowmeter calibration report for
the V-Notch Weir have the ultrasonic's reading before and after calibration, and the V-Notch
Weir's head measurement (in feet or meters at the ultrasonic flowmeter location). According to
15A NCAC 2B .0505 (b)(1): "Devices selected shall be capable of measuring flows with a
maximum deviation of less than 10 percent from true discharge volumes. Flow measurement
devices shall be accurately calibrated at a minimum of once per year and maintained to ensure
that the accuracy of the measurements is consistent with the accepted capability of that type of
device."
2. Considering that the VFD #2 has been out of service for over a year, and the apparent difficulty in
obtaining spare parts and repairs for the VFD pumps, it is suggested that the Town repair or
replace this pump immediately. Further, the Town should evaluate the feasibility of replacing
these pumps with equipment that can be repaired in a more timely manner.
Name and Sig aure of Inspector Agency/Office/Telephone
Don Register ,j J e-1 NCDENR/Fayetteville/(910)486-1541/44/J
Dale Lopez \ \ NCDENR/Fayetteville/(910) 486-1541
Name and Signature of evie'4ei ) Agency/Office/Telephone
Belinda S. Henson -u `J.(1.'` Yt(krLl' NCDENR/Fayetteville/(910) 486-1541
Regulatory Office Use Only
Action Taken
Compliance Status
Noncompliance
Compliance
Date
Date
a, JL1cI
Date
s.
1/4;/0,0 or is /✓ 8vri„ z ; 6r
Section D: Summary of Findings/Comments
Brief Facility Description: .
FACILITY SITE REVIEW
F's) No N/A - 1. Treatment units properly operated and maintained.
6s) No N/A 2. Standby power or other equivalent provision provided.
CYesNo N/A 3. Adequate alarm system for power or equipment failure available..•4)1Pv/4L Fm)
'E 1T f°t'4
�`,t°;-c Lc.� Its
4. Sludge disposal procedures appropriate:
e ' No N/A a. Disposal of sludge according to regulations
es' No N/A b. State approval for sludge disposal received.
�Ye9 No N/A 5. All treatment units other than backup units in service.
(Yes) No N/A 6. Sufficient sludge disposed of to maintain treatment process equilibrium.
Yes) No N/A 7. Adequate number of qualified operators on staff. Fer)/ t'l"r%�'• 11)i'ss
No N/A 8. Established procedures available for training new employees.
No N/A 9. Adequate spare parts and supplies inventory maintained.
Yes LNd N/-A 10. a. Hydraulic overflows and/or organic overloads experienced
Yes No : b. Untreated bypass discharge occurs during power failure
Yes No c. Untreated overflows occurred since last inspection.
ces No N/A 11. Plant has general safety structures such as rails around or covers over
tanks, pits, or wells.
Y No N/A 12. Plant is generallyclean, free from open trash areas.
Yes No
es) No N/A
Yes N/A
cYY S No N/A
13. Screening:
a. Manual
b. Mechanical
c. Buildup of debris
d. Screenings properly disposed of.
14. Grit Removal:
Yes N/A a. Excessive organic content in the grit chamber
Yes (o' N/A b. Excessive. odors
es' No N/A c. Grit properly disposed of.
Yes. No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No. N/A
Yes No N/A
Yes No N/A
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Yes No N/A
Page 2
15. Primary clarifier:
a. Excessive gas bubbles
b. Black and odorous wastewater
c. Poor suspended solids removed
d. Excessive buildup of solids in center well of circular clarifier
e. Weirs level
f. Weir blockage
g. Evidence of short circuiting
h. Lack of adequate scum removal
I. Excessive floating sludge
j. Broken sludge scraper.
16. Trickling Filter:
a. Trickling filter ponding(indicating clogged media)
b. Leak at center column of trickling filter's distribution arms
c.. Uneven distribution of flow on trickling filter surface
d` Uneven or discolored growth
-e. Excessive sloughing of growth
f. Odor
g. Clogging of trickling filter's distribution arm orifices
h. Filter flies, worms, or snails.
17. Rotating Biological Contactors (RBC):
a. Development of white biomass on rotating biological contactor
media
b. Excessive sloughing of growth
c. Excessive breakage of rotating disks or shafts in RBC units
d. Excessive breakage of paddles on brush aerators
e. Shaft, bearing, drive gear, or motor failure•on disk or brush aerators.
}J6= mt;/9DAiL
Yes N/A
Yes 67 N/A
Yes o> N/A
Yes of N/A
Yes N/A
Yes o /
Yes No iIV/AA)"
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
/yam
No . N/A
No N/A
No N/A
No N/A
} N/A
o) N/A
o N/A
o; N/A
2 N/A
N/A
1oiN/A
N/A
(,) N/A
'KO N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes o 1 N/A
Yes o� N/A
Yes o) N/A
Yes o N/A
Yes No . N/A
No N/A
des` No N/A
Yes &:)- N/A
Page 3
18. Activated Sludge Basins/Oxidation Ditches:
a. Dead spots
b. Failure of surface aerators
c. Air rising in clumps
d. Dark foam or bad color
e. Thick billows of white, sudsy foam
f. Air rising unevenly
g. Excessive air leaks in compressed air piping.
19. Stabilization Ponds/Lagoons:
a. Excessive weeds including duckweed in stabilization ponds
b. Dead fish or aquatic organisms
c. Buildup of solids around influent pipe
d. Excessive scum on surface.
20. Secondary Clarifier:
a. Excessive gas bubbles on surface
b. Unlevel overflow weirs
c. Weir blockage
d. Evidence of short circuiting
e. Excessive buildup of solids in center well of circular clarifier
f. Pin floc in overflow
g. Ineffective scum rake
h. Floating sludge on surface
i. Excessive high sludge blanket
j. Clogged sludge withdrawal ports on secondary clarifier.
21.
Filtration:
a: ' Filter surface clogging
b. Short filter nin
c. Gravel displacement of filter media
d. Loss of filter media during backwashing
e. Recycled filter backwash water in excess of 5 percent
f. Formation of mudballs in filter media.
22 Chlorination Unit:
a. Sludge buildup in contact chamber
b. Gas bubbles
c. Floating scum and/or solids
d. Adequate ventilation of chlorine feeding room and storage
e. NIOSH-approved 30 minute air pack
f. All standing chlorine cylinders chained in place
g. All personnel trained in the use of chlorine
h. Proper chlorine feed, storage, and reserve supply.
area
/ f»2 &if tx
Page 4
Yes NoC/Z 23. Ultraviolet radiation disinfection present and in use.
24. Dechlorination:
Yes Ta' N/A a. Proper storage of sulfur dioxide cylinders
Yes r N/A b Adequate ventilation of sulfur dioxide feeding room
Yes N/A c. Automatic sulfur dioxide feed or feedback control not operating
properly.
Yes
Yes
Yes o ) N/_
Yes No
N/A
N/A
/3)
Yes No N/A
Yes No N/A
Yes No N/A
25. Aerobic Digester:
a. Excessive foaming in tank
b. Noxious odor
c. Mechanical aeration failure
d. Clogging of diffusers.
26. Anaerobic Digester:
a. Floating cover tilting
b. Gas burner operative
c. Supernatant has a sour odor.
27. Sludge Drying and/or disposal:
Yes No /rA> a. Poor sludge distribution on drying beds
Yes No b. Vegetation in drying beds
Yes No 7:0 c. Dry sludge remaining in drying beds
Yes No A d. Dry sludge stored on site
Yes No /A) e. Filtrate from sludge drying beds returned to front of plant
es) No N/A f. Approved disposal site for the sludge
es- No N/A g. Sludge land applied.
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
i 1
N/A.
N/A
N/A
N/A
N/A
N/A
N/A
28. Filter Press:
A. High level of solids in filtrate from filter presses or vacuum filters
b. Thin filter cake caused by poor dewatering
c. Sludge buildup on belts and/or rollers of filter press
d. Excessive moisture in belt filter press sludge cake.
29. Polishing Ponds or Tanks:
a. Objectionable odor, excessive foam, floating solids, or oil sheens on
water surface
b. Solids or scum accumulations in tank or at side of pond
c. Evidence of bypassed polishing ponds or tanks because of low
capacity.
/c 41,B)C . /< C
Page
30. Plant Effluent:
Yes c) N/A a. Excessive suspended solids, turbidity, foam, grease, scum, color, and
other macroscopic particulate matter present
Yes No) N/A b. Potential toxicity (dead fish, dead plant at discharge)
jJNo N/A. c. Outfall discharge line easily accessible.
31. Flow Measurement:
Yes 1(o) N/A a. Proper placement of flow measurement device
Yes o N/A b. Flow meter calibrated
Yes o N/A . 'c: Buildup of solids in flume or weir
Yes o N/A d. Broken or cracked flume or weir
Yes o e. Properly functioning magnetic flowmeter
Yes No A. f Clogged or broken stilling wells
Yes fA g. Weir plate edge corroded or damaged
Yes ( o) N/A h. System capable of measuring maximum flow
Yes 1Qo N/A i. Flow measurement error less than 10%.
32. Sampling:
No N/A a. Sampling and analysis completed on parameters specified by penult
No N/A b. Samples refrigerated during compositing
No N/A c. Composite sample temperatures maintained at 0 to 4 degrees Celsius
during sampling
es) No N/A d. Contract laboratory used for sample analysis
e No N/A e. Composite samples obtained are flow proportional. C04'.gi2v % T ��
i�r> '19i3LE-
VI) 1,,E e
RECORDKEEPING AND REPORTING
e) No . N/A 1: Records and reports maintained as required by peumit.
es No N/A 2. All required information available, complete, and current.
FyNo N/A 3. Records maintained for 3 years and all sludge records maintained for 5
years.
'fel) No N/A 4. Analytical results consistent with data reported on DMRs.
5. Sampling and analyses data adequate and include:
No N/A a. Dates, times, and location of sampling
es) No N/A b. Name of individual performing sampling
No N/A c. Results of analyses and calibration
es:No N/A d. Dates of analyses •
s) No N/A e. Name of person performing analyses.
Page 6
6. Monitoring records adequate and include:
es No N/A a. Monitoring charts kept for 3 years
es) No N/A b. Floi,vmeter calibration records kept for 3 years.
6s-)No N/A 7. Laboratory equipment calibration and maintenance records adequate.
No N/A 8. BOD incubator temperature maintained at 20 +/- 1 Degrees Celsius
and the temperature maintained in a log for every day of operation.
ems /No N/A 9. Fecal coliforin incubator maintained at 44.5 +/- 0.2 Degrees
Celsius and the temperature maintained in a log for every day of
operation.
s' No N/A
Yes: No N/A
(Ye No N/A
`yes No 6A %
10. Plant records adequate and include:
a. 0 & M Manual
b. "As -built" engineering drawings
c. Schedules and dates of equipment maintenance repairs
d. Equipment data cards.
Yes No 2_,A, 11. Permittee is meeting compliance schedule.
es ) No N/A 12. DMRs complete and include all NPDES perrnitrequired parameters.
Cie No- N/A 13. ORC visitation logs available and current.
es/ No N/A 14. ORC certified at a level equal to or greater than the classification of
the wastewater facility.
Ces) No N/A
Ye,$) No N/A
Yes: No N/A
Revised 7/11/00
by Belinda Henson
15. Backup Operator certified at one level less than the classification of
the wastewater -facility or greater.
16. Current copy of the complete NPDES permit on site.
17. Facility description verified as contained in NPDES permit.
INSPECTION REPORT
UPDATE OPTION: TRX: 5IF KEY: NC0027103INSBIO 010205
SYSMSG: *** DATA ADDED SUCCESSFULLY ***
PERMIT--- NC0027103 REG/COUNTY-- 06 ROBESON
FACILITY-- PEMBROKE (TOWN).- WWTP LOC-- PEMBROKE
INS TYPE
BIO
NEXT PLANNED
INSPECTION INSPECTED BY:
DATE: 010205
LD/RD
REPORT INSPECTION DMR RESPONSE RECEIVED
DATE STATUS STATUS DUE DATE DATE
010216 C C
COMMENTS:
North Carolina
Department of. Environment and Natural Resources
Division of Water Quality'
Fayetteville Regional Office
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Kerr T. Stevens, Director
February 28, 2001
Mr. McDuffie Cummings, Town Manager
Town of Pembroke
P.O. Box 866
Pembroke, NC 28372
A7A
NCDENR
Subject: CORRECTION TO THE COMPLIANCE BIOMONITORING INSPECTION
CONCERNING FLOW MEASUREMENT DEVICE
Town of PembrokeWastewater Treatment Plant
NPDES Permit No. NC0027103
Robeson County .
Dear Mr. Cummings:
Two errors .were made on page 5 of the Section D: Summary of Findings/Comments of the
COMPLIANCE BIOMONITORING INSPECTION letter dated February 16, 2001. Number 31 parts
"a" and "b" of the FACILITY SITE REVIEW were erroneously circled as "No" for both: "a. Proper
placement of flow measurement device" and "b. Flow meter calibrated". In both cases, the correct
response is "Yes". Enclosed with this letter is page 5 of the corrected inspection checklist.
If you have any, questions or comments concerning this letter please feel free to contact me at
910/486-1541.
Dale Lopez
Environmental Specialist II
/dl
Enclosure
cc: DWQ, ESB, ATU, Kevin Bowden
Gerry Harris, Town of Pembroke, (ORC)
225 GREEN STREET - SUITE 714 / SYSTEL BUILDING / FAYETTEVILLE, NC 28301-5043
PHONE (910) 486-1541 FAX (910) 486-0707 WWW'.ENR.STATE.NC.US/ENR/
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER- 50% RECYCLED/10% POST CONSUMER PAPER
DENR TOLL FREE HOTLINE: 1-877-623-6748
CaREc .T ED
r6tJ)11;f,NyE
Yes
Yes 61 N/A
No N/A
Page 5
30. Plant Effluent:
N/A a. Excessive suspended solids, turbidity, foam, grease, scum, color, and
other macroscopic particulate matter present
b. Potential toxicity (dead fish, dead plant at discharge)
c. Outfall discharge line easily accessible.
31. Flow Measurement:
No N/A a. Proper placement of flow measurement device
es) No N/A b. Flow meter calibrated
es o' N/A c .. Buildup of solids in flume or weir
Yes 9' N/A d. Broken or cracked flume or weir
Yes o /A e. Properly functioning magnetic flowmeter
Yes No /A) f. Clogged or broken stilling wells
Yes N A g. Weir plate edge corroded or damaged
Yes N/A h. System capable of measuring maximum flow
Yes To N/A i. Flowmeasurement error less than 10%.
32. Sampling:
�e No N/A a. Sampling and analysis completed on parameters specified by permit
63) No N/A b. Samples refrigerated during compositing
No N/A c. Composite sample temperatures maintained at 0 to 4 degrees Celsius
during sampling
No N/A d. Contract laboratory used for sample analysis
Gres) No N/A e. Composite samples obtained are flow proportional.
RECORDKEEPING AND REPORTING
es) No N/A 1. Records and reports maintained as required by permit.
No N/A 2. All required information available, complete, and current.
(!----4). No -N/A 3. Records maintained for 3 years and all sludge records maintained for 5
years.
9) No N/A 4. Analytical results consistent with data reported on DMRs.
es;) No N/A
pes)
No N/A
No N/A
g No N/A
No N/A
5. Sampling and analyses data adequate and include:
a. Dates, times, and location of sampling
b. Name of individual performing sampling
c. Results of analyses and calibration '�'
d. Dates of analyses
e. Name of person performing analyses.