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HomeMy WebLinkAboutNC0026565_Compliance Evaluation Inspection_20240209ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Vicki Caudle Town of Ramseur PO Box 545 Ramseur, NC 27316-0545 NORTH CAROLINA Environmental Quality February 09, 2024 Subject: Compliance Evaluation Inspection & Notice of Violation Tracking Number: NOV-2024-PC-0102 Permit No. NCO026565 Ramseur WWTP Randolph County Dear Ms. Caudle: On January 17, 2024, Division of Water Resources (DWR) Winston-Salem Regional Office (WSRO) staff Jesse Barnes conducted a routine compliance evaluation inspection at the Town of Ramseur WWTP in reference to NPDES permit NC0026565. ORC Terry Lewallen was present during the inspection. A review of the subject permit, records, data, laboratory, treatment components, sampling methods, operations, and maintenance was completed. This review reflected noncompliance with the subject permit. The determined permit violations and items of concern are listed below. Inspection findings are detailed in the attached Water Compliance Inspection Report. Permit Violations 1. Recent DMRs have reported effluent flow, but no effluent flow meter was present during the inspection. Mr. Lewallen stated that he reports effluent flow using readings from the influent flow meter. Part I, Section A. (1.) (a.) of the subject permit requires the permittee to report either influent or effluent flow. Influent and effluent flows may not be assumed as equivalent. Additionally, Mr. Lewallen stated that the effluent composite sampler has been programmed to collect 250 mL aliquots once per hour and is therefore not flow proportional. Part II. Section A. of the subject permit requires composite samples to be collected in a manner that is proportional to the rate of flow. To achieve permit compliance, an effluent flow meter and effluent flow -proportional composite sampler must be installed within 90 days of receiving this notice. 2. According to DWR records, a Back-up ORC has not been properly designated and reported to the Division. Part II, Section C. (1.) (b.) of the subject permit requires the permit owner to designate at least one Back-up ORC who possesses a valid certificate of the type of system and no more than one grade less than the grade of the system. Please complete and submit the attached ORC Designation Form with the required Back-up ORC information. DffNorth Carolina Department of Environmental Quality I Division of Water Resources oan caaouNn Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 M336.776.9800 oep.m.m or em�.nmen� Qualm 3. Calibration and/or verification records for the field lab dissolved oxygen (DO) meter were not present during the inspection and have not been provided to DWR staff. Part II, Section D. (4.) requires test procedures to conform to EMC regulations, which state that DO instruments must be calibrated according to the manufacturer's calibration procedure each day prior to the analysis of compliance monitoring samples. For LDO sensors that cannot be calibrated by the user, the internal calibration must be verified each day of use. Please see the attached Approved Procedure for the Analysis of Dissolved Oxygen for detailed requirements. Additionally, Section D. (6.) of the subject permit requires all calibration records to be maintained for at least three years. 4. Mr. Lewallen stated that upstream sampling has been conducted at the nearest upstream bridge, which appears to be the Brooklyn Avenue bridge located approximately one mile upstream from the outfall. Part I, Section A. (1.) of the subject permit designates the upstream sampling location as approximately 50 feet upstream from the outfall. If the upstream sampling location cannot be accessed safely, the permittee may submit a permit modification request to Charles Weaver at charles.weaver@deq.nc.gov to propose a new upstream sampling location. 5. No standby power source was present during the inspection. Part II, Section C. (7.) states that the permittee must maintain adequate safeguards to prevent the discharge of untreated or inadequately treated wastes during power failures either by means of alternate power sources, standby generators, or retention of inadequately treated effluent. items or concern 1. An influent manual bar screen is present and in use but is not listed on the supplement to permit cover sheet. Please list the bar screen as a facility component on the next permit renewal application. 2. Mr. Lewallen stated that debris removed by the influent bar screen is either disposed of in an on -site dumpster and then transported to a landfill or dumped in a city -owned "dead - animal it". Solids from the bar screen should be properly disposed. 3. The on -site copy of the subject permit did not include a technical correction issued May 9, 2022. A copy of the technical correction was sent to Mr. Lewallen via email after the inspection. Please insert the corrected pages into the permit and discard the old pages. 4. Field laboratory parameters have been performed by the Ramseur WWTP field lab (NC certified lab #5103), but this information has not been listed on discharge monitoring reports (DMRs). Please list all certified labs used during each month on future DMRs. 5. Foam, solids, and dead vegetation appeared to cover approximately 25% of the aeration basin's surface during the inspection. 6. The center well of the secondary clarifier appeared to be full of excessive solids during the inspection. 7. Some excessive algal growth was observed along the walls, weirs, and trough of the secondary clarifier. 8. Mr. Lewallen stated that the influent composite sampler has been programmed to collect 250 mL aliquots once per hour and is therefore not flow proportional. Plans or measures should be taken to address the indicated violation(s) and/or item(s) of concern, if applicable. Please be aware that the Division may take enforcement action against any individual who fails to comply with the requirements of all applicable permits, regulations, and/or statutes. Pursuant to NC General Statute (NCGS) 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who North Carolina Department of Environmental Quality 1 Division of Water Resources D E Q�� Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105 NORTH CARCLINA q.p. .mmEnNm.m.nfnlq..i\ 336.776.9800 violates or fails to act in accordance with the terms, conditions, or requirements of any permit, or applicable regulations, issued pursuant to G.S. 143-215.1. If you have questions or concerns, contact Jesse Barnes by phone at 336-776-9701 or by email at iesse.barnes@deq.nc.gov. Sincerely, DocuSigned by: OD2D3CE3F1 B7456... Jennifer F. Graznak, Assistant Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Attachments: 1. Water Compliance Inspection Report, NCO026565 2. ORC Designation Form 3. Approved Procedure for the Analysis of Dissolved Oxygen REQ� North Carolina Department ofEnvironmental Quality I Division ofWater Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105 NORTH CAROLINA 336.776.9800 naparMeM of EmironmanW 9uallly United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 IN 1 2 u 3 I NCO026565 I11 121 24/01/17 I17 18I � I 19 I s I 20L] 21111I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 I 72 I ni I 71 I 74 79 I I I I I I I80 701 I 71 I LL -1 I I LJ Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES Dermit Number) 10:45AM 24/01/17 22/05/01 Ramseur WWTP 4737 Roundleaf Rd Exit Time/Date Permit Expiration Date Ramseur NC 27316 12:OOPM 24/01/17 27/01/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Terry Cheyenne Lewallen/ORC/336-824-3939/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Terry Cheyenne Lewallen,PO Box 725 Ramseur NC 27316//336-824-3939/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran 0 Facility Site Review Effluent/Receiving Wate Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Jesse Barnes Docusigned by: DWR/WSRO WQ/336-776-9701/ 5. eo 2/8/2024 B'-t 41797473D3194ED... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date Docu signed by: 2/9/2024 DWR/WSRo 336-776-9695 EPA Form-38KYKV-544) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type NCO026565 I11 12I 24/01 /17 117 18 i c i (Cont.) Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On January 17, 2024, Division of Water Resources (DWR) Winston-Salem Regional Office (WSRO) staff Jesse Barnes conducted a routine compliance evaluation inspection at the Town of Ramseur WWTP in reference to NPDES permit NC0026565. ORC Terry Lewallen was present during the inspection. A review of the subject permit, records, data, laboratory, treatment components, sampling methods, operations, and maintenance was completed. This review reflected noncompliance with the subject permit. The determined permit violations and items of concern are listed below. Inspection findings are detailed in the attached Water Compliance Inspection Report. Permit Violations: 1. Recent DMRs have reported effluent flow, but no effluent flow meter was present during the inspection. Mr. Lewallen stated that he reports effluent flow using readings from the influent flow meter. Part I, Section A. (1.) (a.) of the subject permit requires the permittee to report either influent or effluent flow. Influent and effluent flows may not be assumed as equivalent. Additionally, Mr. Lewallen stated that the effluent composite sampler has been programmed to pull aliquots of 250 mL once per hour and is therefore not flow proportional. Part II. Section A. of the subject permit requires composite samples to be collected in a manner that is proportional to the rate of flow. To achieve permit compliance, an effluent flow meter and effluent flow -proportional composite sampler must be installed within 90 days of receiving this notice. 2. According to DWR records, a Back-up ORC has not been properly designated and reported to the Division. Part II, Section C. (1.) (b.) of the subject permit requires the permit owner to designate at least one Back-up ORC who possesses a valid certificate of the type of system and no more than one grade less than the grade of the system. Please complete and submit the attached ORC Designation Form with the required Back-up ORC information. 3. Calibration and/or verification records for the field lab dissolved oxygen (DO) meter were not present during the inspection and have not been provided to DWR staff. Part ll, Section D. (4.) requires test procedures to conform to EMC regulations, which state that DO instruments must be calibrated according to the manufacturer's calibration procedure each day prior to the analysis of compliance monitoring samples. For LDO sensors that cannot be calibrated by the user, the internal calibration must be verified each day of use. Please see the attached Approved Procedure for the Analysis of Dissolved Oxygen for detailed requirements. Additionally, Section D. (6.) of the subject permit requires all calibration records to be maintained for at least three years. 4. Mr. Lewallen stated that upstream sampling has been conducted at the nearest upstream bridge, which appears to be the Brooklyn Avenue bridge located approximately one mile upstream from the outfall. Part I, Section A. (1.) of the subject permit designates the upstream sampling location as approximately 50 feet upstream from the outfall. If the upstream sampling location cannot be accessed safely, the permittee may submit a permit modification request to Charles Weaver at charles.weaver@deq.nc.gov to propose a new upstream sampling location. 5. No standby power source was present during the inspection. Part II, Section C. (7.) states that the permittee must maintain adequate safeguards to prevent the discharge of untreated or inadequately treated wastes during power failures either by means of alternate power sources, standby generators, or retention of inadequately treated effluent. Items of Concern: 1. An influent manual bar screen is present and in use but is not listed on the supplement to permit cover sheet. Please list the bar screen as a facility component on the next permit renewal application. 2. Mr. Lewallen stated that debris removed by the influent bar screen is either disposed of in an on -site dumpster and then transported to a landfill or dumped in a city -owned "dead -animal pit" . Solids from the bar screen should be properly disposed. 3. The on -site copy of the subject permit did not include a technical correction issued May 9, 2022. A copy of the technical correction was sent to Mr. Lewallen via email after the inspection. Please insert the corrected pages into the permit and discard the old pages. Page# Permit: NCO026565 Inspection Date: 01/17/2024 Owner -Facility: Ramseur WWTP Inspection Type: Compliance Evaluation 4. Field laboratory parameters have been performed by the Ramseur WWTP field lab (NC certified lab #5103), but this information has not been listed on discharge monitoring reports (DMRs). Please list all certified labs used during each month on future DMRs. 5. Foam, solids, and dead vegetation appeared to cover approximately 25% of the aeration basin's surface during the inspection. 6. The center well of the secondary clarifier appeared to be full of excessive solids during the inspection. 7. Some excessive algal growth was observed along the walls, weirs, and trough of the secondary clarifier. Other observations: The current version of NPDES permit NCO026565 became effective May 1, 2022, and will expire January 31, 2027. The facility is as described in the permit, except for the undocumented presence of an influent manual bar screen as mentioned in the above items of concern. Access to the plant site is restricted by a fence. The DMR and associated laboratory records for September 2023 were reviewed during the inspection and appeared to be complete with no errors found. The influent flow meter is a Fischer + Porter ultrasonic model mounted over a Parshall flume, was last calibrated April 10, 2023, and appeared to be operating properly during the inspection. Chlorine gas and sulfur dioxide gas were in use for disinfection and de -chlorination, respectively. Both gas systems appeared to be operating properly during the inspection. The effluent outfall area was not inspected due to time constraints. Page# Permit: NCO026565 Owner -Facility: Ramseur WWTP Inspection Date: 01/17/2024 Inspection Type: Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑ ■ ❑ application? Is the facility as described in the permit? ❑ ■ ❑ ❑ # Are there any special conditions for the permit? ❑ ■ ❑ ❑ Is access to the plant site restricted to the general public? ■ ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? ■ ❑ ❑ ❑ Comment: An influent manual bar screen is present and in use but is not listed on the supplement to permit cover sheet. Please list the bar screen as a facility component on the next permit renewal application. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ■ ❑ ❑ ❑ Is all required information readily available, complete and current? ■ ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? ■ ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? ■ ❑ ❑ ❑ Is the chain -of -custody complete? ■ ❑ ❑ ❑ Dates, times and location of sampling ■ Name of individual performing the sampling ■ Results of analysis and calibration ■ Dates of analysis ■ Name of person performing analyses ■ Transported COCs ■ Are DMRs complete: do they include all permit parameters? ■ ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ ❑ ■ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified ❑ ❑ ■ ❑ operator on each shift? Is the ORC visitation log available and current? ■ ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? ■ ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility ❑ ■ ❑ ❑ classification? Is a copy of the current NPDES permit available on site? ■ ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ❑ ■ Comment: According to DWR records, a Back-up ORC has not been properly designated and reported to the Division. Page# 4 Permit: NCO026565 Inspection Date: 01/17/2024 Owner -Facility: Ramseur WWTP Inspection Type: Compliance Evaluation Laboratory Are field parameters performed by certified personnel or laboratory? Are all other parameters(excluding field parameters) performed by a certified lab? # Is the facility using a contract lab? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ Comment: Field laboratory parameters have been performed by the Ramseur WWTP field lab (NC certified lab #5103), but this information has not been listed on discharge monitoring reports (DMRs). Please list all certified labs used during each month on future DMRs. Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Influent Sampling Yes No NA NE # Is composite sampling flow proportional? ❑ N ❑ ❑ Is sample collected above side streams? 0 ❑ ❑ ❑ Is proper volume collected? 0 ❑ ❑ ❑ Is the tubing clean? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 ■ ❑ ❑ ❑ degrees Celsius)? Is sampling performed according to the permit? 0 ❑ ❑ ❑ Comment: Mr. Lewallen stated that the influent composite sampler has been programmed to collect 250 mL aliquots once per hour and is therefore not flow proportional. Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? 0 ❑ ❑ ❑ Are surface aerators and mixers operational? ❑ ❑ 0 ❑ Are the diffusers operational? 0 ❑ ❑ ❑ Is the foam the proper color for the treatment process? 0 ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? ❑ 0 ❑ ❑ Page# 5 Permit: NCO026565 Inspection Date: 01/17/2024 Aeration Basins Is the DO level acceptable? Is the DO level acceptable?(1.0 to 3.0 mg/1) Owner -Facility: Ramseur WWTP Inspection Type: Compliance Evaluation Yes No NA NE ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ Comment: Foam, solids, and dead vegetation appeared to cover approximately 25% of the aeration basin's surface during the inspection. Secondary Clarifier Is the clarifier free of black and odorous wastewater? Is the site free of excessive buildup of solids in center well of circular clarifier? Are weirs level? Is the site free of weir blockage? Is the site free of evidence of short-circuiting? Is scum removal adequate? Is the site free of excessive floating sludge? Is the drive unit operational? Is the return rate acceptable (low turbulence)? Is the overflow clear of excessive solids/pin floc? Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) Yes No NA NE ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: The center well of the secondary clarifier appeared to be full of excessive solids during the inspection. Some excessive algal growth was observed along the walls, weirs, and trough of the secondary clarifier. Disinfection -Gas Yes No NA NE Are cylinders secured adequately? 0 ❑ ❑ ❑ Are cylinders protected from direct sunlight? ■ ❑ ❑ ❑ Is there adequate reserve supply of disinfectant? 0 ❑ ❑ ❑ Is the level of chlorine residual acceptable? ❑ ❑ ❑ ■ Is the contact chamber free of growth, or sludge buildup? ■ ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? ❑ ❑ ❑ Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. ❑ ❑ ❑ 7782-50-5)? If yes, then is there a Risk Management Plan on site? ❑ ❑ ❑ If yes, then what is the EPA twelve digit ID Number? (1000- If yes, then when was the RMP last updated? Comment: Page# 6 Permit: NC0026565 Inspection Date: 01/17/2024 De -chlorination Type of system ? Is the feed ratio proportional to chlorine amount (1 to 1)? Owner -Facility: Ramseur WWTP Inspection Type: Compliance Evaluation Is storage appropriate for cylinders? # Is de -chlorination substance stored away from chlorine containers? Comment: Are the tablets the proper size and type? Are tablet de -chlorinators operational? Number of tubes in use? Comment: Lagoons Type of lagoons? # Number of lagoons in operation at time of visit? Are lagoons operated in? # Is a re -circulation line present? Is lagoon free of excessive floating materials? # Are baffles between ponds or effluent baffles adjustable? Are dike slopes clear of woody vegetation? Are weeds controlled around the edge of the lagoon? Are dikes free of seepage? Are dikes free of erosion? Are dikes free of burrowing animals? # Has the sludge blanket in the lagoon (s) been measured periodically in multiple locations? # If excessive algae is present, has barley straw been used to help control the growth? Is the lagoon surface free of weeds? Is the lagoon free of short circuiting? Comment: Flow Measurement - Effluent # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? Yes No NA NE Gas ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Yes No NA NE 1 ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Yes No NA NE ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ Page# 7 Permit: NCO026565 Owner -Facility: Ramseur WWTP Inspection Date: 01/17/2024 Inspection Type: Compliance Evaluation Flow Measurement - Effluent Yes No NA NE (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ ❑ Comment: Recent DMRs have reported effluent flow, but no effluent flow meter was present during the inspection. Mr. Lewallen stated that he reports effluent flow using readings from the influent flow meter. Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Yes No NA NE ❑ ■ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ Comment: Mr. Lewallen stated that the effluent composite sampler has been programmed to collect 250 mL aliquots once per hour and is therefore not flow proportional. Standby Power Is automatically activated standby power available? Is the generator tested by interrupting primary power source? Is the generator tested under load? Was generator tested & operational during the inspection? Do the generator(s) have adequate capacity to operate the entire wastewater site? Is there an emergency agreement with a fuel vendor for extended run on back-up power? Is the generator fuel level monitored? Comment: No standby power source was present during the inspection. Effluent Pipe Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? Comment: Upstream / Downstream Sampling Yes No NA NE ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ Yes No NA NE Page# 8 Permit: NCO026565 Owner -Facility: Ramseur WWTP Inspection Date: 01/17/2024 Inspection Type: Compliance Evaluation Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, ❑ 0 ❑ ❑ and sampling location)? Comment: Mr. Lewallen stated that upstream sampling has been conducted at the nearest upstream bridge, which appears to be the Brooklyn Avenue bridge located approximately one mile upstream from the outfall. Part I, Section A. (1.) of the subject permit designates the upstream sampling location as approximately 50 feet upstream from the outfall. Page#