HomeMy WebLinkAboutNC0020605_CEI 05.07.2024_20240507 DocuSign Envelope ID 83B386A1-1895AD56-B402-C78A58BB3724
ROY COOPER
Governor
ELIZABETH S. BISER
secretary
RICHARD E. ROGERS,
Director NORTH CAROLINA
Eff4wwmfa1Qwdtly
May 7,2024
Troy R.Lewis,Town Manager
Town of Tarboro
P.O.Box 220
Tarboro,NC 27886-0220
Subject: Compliance Evaluation Inspection
Tarboro WWTP
NPDES Permit NCO020605
Edgecombe County
Dear Mr. Lewis:
On April 24,2024,Danny Smith from the Raleigh Regional Office of the Division of Water Resources(DWR)
conducted a Compliance Evaluation Inspection(CEI)of the Town of Tarboro Wastewater Treatment Plant
located at Hwy 64&Service Road 268,in Edgecombe County. The purpose of this visit was to review the
facility's compliance with the subject NPDES permit. During the inspection,the presence and cooperation of
Kevin Peaden,Wastewater Treatment Supervisor-Operator in Responsible Charge(ORC),and Brian Parish,
Backup ORC(bORC)were greatly appreciated and very helpful to this review process.
The facility is a Grade 1V Biological Water Pollution Control System with a permitted flow of 5 MGD.
Through compliance with NPDES permit(NC0020605),the Town of Tarboro is authorized to discharge treated
wastewater through outfall 001 to receiving waters designated as Tar River,a waterbody classified as C Nutrient
Sensitive Waters(NSW)within the Tar-Pamlico River Basin.
This NPDES compliance evaluation inspection consists of the following:
• Review of the NPDES permit;
• Review of the owner/facility information;
• Review of January 2021 through February 2024 monitoring data and compliance history;
• On-site inspection of the wastewater treatment units;
• On-site inspection of the discharge outfall;and
• Written response request for item 12.
Findings during the pre-inspection file review are as follows:
1. The current NPDES permit(NC0020605)was issued effective August 1,2020,and will expire September
30,2024. A permit renewal application will need to be submitted at least 180 days prior to the expiration of
the permit. Mr.Kevin Peaden explained that the Town's consultant is in the process of submitting the
renewal application.
2. Since the implementation of EPA's NPDES Electronic Reporting Rule,the Town has been submitting its
discharge monitoring reports(DMRs)electronically, instead of on paper. The first DMR the Division
received electronically from the permittee was for September 2016.
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DocuSign Envelope ID:83B386A1-1895-4D56-B402-C78A58BB3724
Tarboro WWTP -NC0020605
Compliance Evaluation Inspection
Page 2 of 5
Please note:As of October 7,2019,all NPDBS discharge ntonitoring reports submitted In the eDMR
Mum are accepted with electronic signature;signed hardcoples are no longer required to be nwiled to
the Dlvlsion.
3. The Town has designated Kevin Peaden as Operator in Responsible Charge(ORC)and Brian Parish as
Backup Operator in Responsible Charge(bORC). All designated operators have a Grade 4 Certification,
and all have an active certification status.
During the inspection it was explained that Mr. Melvin Farmer(bORC)has retired and is no longer
employed by the Town of Tarboro. (Mr.Peaden and Mr. Parish both agreed and offered to follow up on this
issue by sending in a request for removal of Mr.Farmer's name from the Designated Operator List.)
4. For the review period January 2021 through February 2024,the following permit limit exceedance was
noted
December 2022 annual total nitrogen annual load(lbs/year)was exceeded by 1.5%. [The Town of Tarboro
(NC0020506)is a member of the Tar Pamlico Basin Association.]
S. Special Condition A.(4.)of the subject/current permit required the permittee to perform Effluent Pollutant
Scans during calendar years 2020,2021 and 2022. It was explained that the effluent pollutant scan data has
been collected.
6. The required Annual Administering and Compliance Monitoring Fee for the current billing period is paid
through August 31,2024. There are no overdue fees.
Findings during the inspection were as follows:
7. Permittees who own or operate facilities that collect or treat municipal or domestic waste am required to
provide an annual report to its userstcustomers summarizing the performance of the collection or
treatment system. The report shall be provided no later than sixty days after the end of the calendar or
fiscal year. (NPDES permit-Part II., Section E. Condition 12.)
The Town's FY 2022-2023 Annual Sanitary Sewer System Report was available for review and is mailed
out to customers annually. (It is recommended that the Annual Sanitary Sewer System Report be added to
the Town's website.)
8. During the inspection operations data and logbooks were reviewed. These documents included maintenance
logs,lab data,bench sheets,contract lab data,chain-of-custody,flow data,calibration logs,chemical
purchases,and the chemical solution/mcdia make-up and solutions tracking information etc. This
information was observed to be maintained and readily available for inspection.
Per discussions during the inspection,it is recommendation that that the Operator in Responsible Charge
begin to maintain an additional bound,paginated logbook. This logbook is for the recording/documentation
of day plant operations(e.g.daily plant operations/routine activities,adjustments made,equipment out of
service,weather,rain fall etc.).
DocuSign Envelope ID 83B386A1-1895-4D56-B442-C78A58BB3724
Tarboro W WTP -NC0020605
Compliance Evaluation Inspection
Page 3 of 5
The purposelintent of this logbook is to ensure the accomplishment and documentation of the
operation,maintenance,and all visitation of the treatment system and for this logbook to be
maintained at the system(on-site)per 15NCAC 08G .0204(5).
9. The Town of Tarboro uses Waypoint Analytica-Greenville(certification# 10),for the nutrients(TP,Nitrate
-Nitrite,T .N)and metals analyses. Also, Pace Analytical conducts the toxicity analysis and annual
pollutant scan.
The Town collects and analyses the remaining influent,effluent and filed parameters(Certification# 159).
10. A cursory review of the laboratory meter calibration logs and standards showed the laboratory to be
compliant with record-keeping requirements. Also,the thermometer used for the self-monitoring program
is NIST certified,and its calibration is checked annually. This NIST thermometer is used to check the
calibration of other thermometers in use at the W WTP.
11. The inspector compared the August 2023 and February 2024 eDMR data against the bench lab data and
analytical results. No discrepancies were noted.
12. During the walk-through of the wastewater plant,the inspector observed the treatment units as listed in the
permit text. The inspector noted the following observations:
a) Preliminary Treatment. Preliminary treatment consists of influent pumpstation,automatic,manual
bar screen and grit removal.
While all units were operational,the automatic and manual bar screen, grit removal units and respective
metal catwalks were rusted,exhibiting severe degradation. Caution should be used traversing the
equipment due to severe rusted condition of portions of the catwalk(s). Mr.Peaden(ORC)explain
the Town is in the process of trying to secure monies and are working with consultants to replace the
influent units.
Within 60-days of receipt of this letter, please respond to this letter in writing. Please
detail in your written response the status and the anticipated timeline to accomplish the
upgrades for the influent wastewater treatment units.
Note: The area around these influent units were clean. The ORC informed the inspector that the
screenings and grit are collected in a dumpster and hauled by GFL to the landfill for disposal.
b) Primary&Secondary Treatment. Treatment units include three(3)primary clarifiers,two(2)
trickling filters,two(2)aeration basins,(4)secondary clarifiers.
One(1)of the trickling filters,the oldest and smallest unit, is operable but was not in use at the time of
the inspection. The ORC explained that 2 A trickle filter is put into service when needed during high
flows for use as an equalization basin. The two aeration basins(the older basin has mechanical air and
the newer basin has diffuse air),and four(4)secondary clarifier were operational and all were in use.
DocuSign Envelope ID 83B386A1-1895-4D56-B402-C78A58BB3724
Tarboro W WTP -NC0020605
Compliance Evaluation Inspection
Page 4 of 5
Clarifier number#4 is approximately 13 feet deep and was in operation during the inspection.During
the inspection,the ORC measured the sludge level in clarifier#4 at an approximate depth of 5.0 ft. The
inspector observed some pin floc and floating solids within the unit.
c) DWnfectlon.Chlorine Contact,apt De-chlQtingtion'. The facility disinfects the treated wastewater
prior to discharge using chlorine gas.The facility has two chlorine contact basins and both were in used
on the day of the inspection. The facility use sulfite for de-chlorination. De-chlorination is fed into a
manhole located just past chlorine contact chambers&flow meter. No issues of concern were observed
with the disinfection system.
d) SaNdl Handling.The Town of Tarboro's W WTP has two(2)sludge drying beds,two(2)anaerobic
digesters,three(3)aerobic digesters,and an aerated sludge holding lagoon(w/Bfuefrog aerators).
-D?*g beds.One of the drying beds was in use during the inspection. On going efforts to dewater
supernate from the aerated sludge holding lagoon into the drying beds were observed. Mr.Peaden
explained that the dewatering efforts are intended to help thicken the solids and decrease the sludge
volumes for hauling. (Granville Farms is the sludge hauler.)
Anaerobic digesters.One of the anaerobic digesters is used,the other is not in use and is not operable.
Aerobic digesters.One(1)of the three(3)pumps has been removed for repairs from the aerobic
digesters. Mr.Peaden explained that the pump has been repaired and is ready to be reinstalled. The
Town is trying to schedule the installation with the contractor. (This work requires use of a crane to
reinstall the pump.)
e) Flow meters. Effluent Flow is reported on the DMR. Both the influent and effluent flow meters are
calibrated quarterly by Chadwick. Both flow meters were last calibrated on April 4,2024. No issues of
concern were observed with the flow measurement devices.
Please continue to ensure that current calibration stickers/identification and calibration documentation
are maintained and available for review.
f) 11Aflaent and effluent. As required by the subject permit, influent and effluent sampling is achieved
either by grab or composite sampling. The effluent composite samplers are set up to collect flow-
proportional samples over a 24-hour period. The observed temperature for both the influent and effluent
composite sampler refrigerators were less than 5 degrees Celsius. No issues of concern were observed
with the composite samplers.
g} ft.CkUR . The facility has one emergency generator that will operate the entire WWTP. The on-
site generator is maintained monthly by a contractor.
h.) Effluent(Outf&U 0011 and cascade aer Aden.The inspector observed the cascade aeration/effluent
discharge from the outfall pipe to Tar River to be clear with no observable solids or foam. No
detrimental impacts to the receiving waters from the effluent discharge were observed.
DocuSign Envelope ID:83B386A1-1895-4D56-B402-C78A58BB3724
Tarboro W WTP -NC0020605
Compliance Evaluation Inspection
Page 5 of 5
The overall condition of the subject facility was compliant with the NPDES permit requirements as observed on
the day of the inspection. Please respond In writing to item number 12 listed above. If you have questions
or comments about the inspection,this report or the requirements to take corrective action(if applicable),please
contact Danny Smith at(919)791-4248 or me at 919-791-4232 or via email at VVanessa.Manuel@dpq.nc.gg_v.
Sincerely,
CDoeuagnw by:
VA.IALSSX f. h &A Ut.,(,
BMUMB37144F
Vanessa Manuel,Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources,NCDEQ
Attachment: EPA Water Compliance Inspection Report
Cc: Laserfiche
DocuSign Envelope ID:83B386A1-1895-4D56-6402.C78A58BB3724
Unitad Stabs Environmental Protection Apmcy Form Approved.
EPA "yam^ D.C.20M OMB No.2040-W57
Water Compliance Inspectlon Report Approval ay;*aee-31-98
Section A:National Data System CodIng Q.e.,PCS
Transaction Code NPOES yr/nWday Inspection Type Inspector Fee Type
1 AIN I 2 I+� I 3 I W0Q20S0g. I11 12 24IM4 17 181C1 19I G F 201 i
211 L[-�
Inspection Work Days FacnRy SaN-MoMM4 Evaluation Raft 81 OA Re
�p
67 70 U 71 U 72 LIJ L I ti l 731 I 174 7 _I I I I I
Section B:Facilily Data 11�
Name and Looatbn Of Facility Inspected(For hdttW@I Users diaoherging to POTW,81e0 InDtvde Entry Time/Dste Penrdt Effective Date
POTW name and NPDES Darn)!Number) 09:30AM 24104/24 20/08101
Tarboro WWTP
101 Sewer Plant Rd Exit TbnelDala Permit Expiration pate
Tarboro NC 27M MOPM 24/04124 24AAM
Name(s)of Onalte Reprasantatlw(eyTWas(syPhone and Fax Numbers) Other Facility Data
it/
Name,Address of Respons6te OfBciaYTHLoftone and Fax Number
KeWn Ray Peaden,PO Box 220 Tarboro NC 27886022011252-641-42041 eta
No
Section C:Areas Evaluated During Inspection(Check only those areas evaluated)
Penttltt M Flow Measurement M Operations 6 Maintem M R ports
Stiff-Monitortnp Piogran 0 Sludge Handling Dispof ■Facility Site Review 0 EftluenURec&hg Wate
Laboratory
Section D:Summary of FindlnpCornments(Attach additional Ghosts of narrative and cheddists as necessary)
(See attachment summary)
Names)and Sipruture(s)of Inspector(s) Agency/OfAcalPtwne and Fax Numbers Date
SUOm 0&nlh I DmuftnM by DWR/RRO VV(V919-791.42001
5/6/2024
9EC87Be2381D/T6
Signature of M Agency/Otlfoe/Ptwns and Fax Numbers Date
Vav,ssx ff, kAVAALL 5/6/2024
EPA Form 3580.3(Rev 9-94)Previous editions are obsolete.
Page# 1
DocuSign Envelope ID 83B386A1-18954D56-B402-C78A58BB3724
NPDES yr/mo/day IrMP-0 n Type 1
NC0020805 11 1 242u24 17 18 UC
Soclion D:Summary of FIndk4Commerlts(Attech addMonel$heats of nerrativo and choc*dats as neco nary)
PsW 2
DocuSign Envelope ID 8313386A1-18954D56-B402-C78A58BB3724
Perak: NCO02OWS Owner-Fa lUty: TarboroWWTP
tnsprrotlon 040: 04MMM4 inaprrotlon Type: Comptianoe Evaluation
Operafte& MaintenanceYes No M NE
Is the plant generally dean 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:
Perm Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑ N ❑
application?
Is the facility as descrbed in the permit? 0 ❑ ❑ ❑
#Are there any special conditions for the permit? 0 ❑ ❑ 0
Is access to the plant site restricted to the general public? M ❑ ❑ ❑
Is the Inspector granted access to all areas for inspection? M ❑ ❑ ❑
Comment:
consultant,
AomW.q Monte Yes No NA HE
Is the capacity adequate? 0 ❑ ❑ ❑
Is the mixing adequate? 0 ❑ ❑ ❑
Is the site free of excessive foaming in the tank? M ❑ ❑ ❑
#Is the odor acceptable? ■ ❑ ❑ ❑
#Is tankage available for properly waste sludge? 0 ❑ ❑ ❑
Comment: note:ong of the three pump for tW aerobic digester wal out for repairs. (it Ma
Pump.)
Anaerobic Dlasster Yes No NA ME
Type of operation:
Is the capacity adequate? 0 ❑ ❑ ❑
#Is gas stored on site? 13 0 ❑
Is the digester(s)free of tilting covers? 13 ❑ ❑ ■
Is the gas burner operational? ❑ ❑ ❑
Is the digester heated? ❑ ❑ ❑
Is the temperature malntahned constantly? ❑ 0 ❑ ■
Is tankage avallable for property waste sludge? 0 ❑ ❑ ❑
Comment: One anaerobic dEoester Is used. The other diaeste, o r is not not in use and Is not gArable.
Page# 3
DocuSign Envetope ID 836386A1-18954D56-8402-C78A58BB3724
P*Mft NCO020605 owner .-FactEr. Tarboro WKM
anspakstlon Data: 0444=4 kwpecdon rye; CamOawe Evsked n
Anaerobic Dicester YeL.No NA NE
Qrvinu Beds Yes No NA NE
Is there adequate drying bed space? 0 0 ❑ ❑
Is the sludge distribution on drying beds appropriate? ❑ 13 0 ❑
Are the drying beds free of vegetation? M ❑ ❑ ❑
#Is the site free of dry sludge remaining In beds? 0 ❑ ❑ ❑
fa the site free of stockpiled sludge? 0 ❑ p ❑
Is the filtrate from sludge drying beds returned to the front of the plant? M ❑ ❑ ❑
#Is the sludge disposed of through county landfill? ❑ 0 ❑ 0
#is the sludge land applied? 0 13 ❑ D
(Vacuum filters)Is polymer mixing adequate? ❑ ❑ E ❑
Comment: Is the studgg haulffi,
RK SC ins Yes No NA HE
Type of bar screen
a.Manual
b.Mechanical 0
Are the bars adequately screening debris? 0 ❑ ❑ ❑
Is the screen has of excessive debris? 0 000
Is disposal of screening In compliance? 0 ❑ ❑ ❑
Is the unit In good condition? ❑ M ❑ ❑
Comment Infusnt Dumosttaiion,automatic manual bar screen, grit Mmoval_catwalks are nMW
and needs feptac=mnt. ORC a ._ tend the town is trying to secure monies to realaw
I
the Towns'repairs efigrts. ))
grk Removal Yes No NA NE
Type of grit removal
a.Manual ❑
b.Mechanical
Is the grit free of excessive organic matter? ❑ ❑ D
Is the grit free of excessive odor? 0 ❑ ❑ ❑
#Is disposal of grit in compliance? 0 ❑ ❑ ❑
Comment:
Page# 4
DocuSign Envelope ID:83B386A1-1 895-4D56-B402-C78A58BB3724
Pmntt NCO020805 Owmar-Faculty: Tarboro VYwTP
IRapocUm Date 04r24W24 Icspetfth Type: Compliance EvaluaW
Prima rclarifie Yes No NA NE
Is the clarifier free of black and odorous wastewater? ■ ❑ ❑ ❑
Is the site free of excessive buildup of solids In center well of circular clarifier? 0 ❑ ❑ ❑
Are weirs level? ❑ ❑ ❑ M
Is the site free of weir blockage? ❑ ❑ ❑ ■
Is the site free of evidence of short-circuiting? ❑ ❑ ❑ 0
Is scum removal adequate? ■ ❑ ❑ ❑
Is the site free of excessive floating sludge? M ❑ ❑ ❑
Is the drive unit operational? M ❑ p ❑
Is the sludge blanket level acceptable? ❑ ❑ Q
Is the sludge blanket level acceptable?(Approximately'/,of the sidewall depth) ❑ ❑ ❑
Comment:
ftCOnd8N C� Yes No NA NE
Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑
Is the site free of excessive buildup of solids in center well of circular clarifier'? 0 ❑ ❑ ❑
Are weirs level? ❑ ❑ ❑
Is the site free of weir blockage? Q ❑ ❑
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 dear of excessive solids/pin floc? 0 ❑ ❑ ❑
Is the sludge blanket level acceptable?(Approximately'/.of the sidewall depth) 0 ❑ Q ❑
Comment:
Trickline Filter Yes No NA HE
Is the filter free of ponding? 0 ❑ ❑ ❑
Is the filter free of leaks at the center column of filter's distribution arms? ❑ ❑ ❑ 0
Is the distribution of flow even from the distribution arms? 0 ❑ ❑ []
Is the filter free of uneven or discolored growth? ❑ ❑ ❑ 0
Is the filter free of sloughing of excessive growth? 13 ❑ ❑ N
Are the filter's distribution arms orifices free of dogging? M ❑ ❑ ❑
Page# 5
DocuSign Envelope ID:83B386A1-1895-4D56-B402-C78A58BB3724
Pam f: NCO02OWS Owner•Radl@Y: Tob—WWTP
Iupecft Data: 04/24rJO24 Inapt Type: Compserwe Eveluatlon
Trickling Fiifiter Yes No NA HE
Is the fitter free of excessive fitter flies,worms or snails? 0 ❑ ❑ ❑
Comment: One of two units In-operation.the other used for En. Unit In nnoration was 2t served
fooWnt.
&MUQn B8911ne Yes No NA NE
Mode of operation
Type of aeration system
Is the basin free of dead spots? 0 ❑ ❑ ❑
Are surface aerators and rrdxers 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? ❑ ❑ ❑ ■
Is the DO level acceptable? ❑ ❑ ❑ ■
Is the DO level acceptable?(1.0 to 3.0 mgA) ❑ ❑ ❑ ■
Comment:
DISIOCtlo Yes No NA NE
Are cylinders secured adequately? 0 ❑ ❑ ❑
Are cylinders protected from direct sunlight? ■ ❑ ❑ ❑
Is there adequate reserve supply of disinfectant? [J ❑ ❑
Is the level of chlorine residual acceptable? ■ ❑ ❑ ❑
Is the contact chamber free of growth,or sludge buildup? 0 ❑ ❑ ❑
Is there crdorine residual prior to de-chlorination? E ❑ ❑ ❑
Does the Stationary Source have more than 2500 Ibs of Chlorine(CAS No. ❑ ❑ ❑ 0
7782-50-5)?
If yes,then is there a Rlsk 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:
De-chlo, nation Yes No rr1A NE
Type of system?
Is the feed ratio proportional to chlorine amount(1 to 1)? N ❑ ❑ ❑
Paige# 6
DocuSign Envelope ID:83B386A1-1895-4D56-B402-C78A58BB3724
Permit: NC0020605 Owner .•Faailliy: TwbOro VWVTP
Inspeabon Date: 04124f2p24 Impaction Type: COMPIW ce Evafuetlon
DR-Chlorination Yss No NA NE
Is storage appropriate for cylinders? ❑ ❑ ❑ 0
#Is de-chlorination substance stored away from chlorine containers? M ❑ ❑ ❑
Comment:
Are the tablets the proper size and type? ❑ ❑ 0 ❑
Are tablet de-chlorinators operatonal? ❑ ❑ ■ ❑
Number of tubes In use?
Comment:
Standby Power Yes No NA NE
Is automatically activated standby power available? ■ ❑ ❑ 0
Is the generator tested by interrupting primary power source? ❑ ❑ ❑ 0
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? M ❑ ❑ ❑
Comment: ORC exiftned that he Muld look intg status of emergencyn for
(may already
Influent Sampling Yes No NA NE
#Is composite sampling flow proportional? M ❑ ❑ ❑
Is sample collected above side streams? 0 ❑ ❑ ❑
Is proper volume collected? ❑ ❑ ❑
Is the tubing clean? M ❑ ❑ ❑
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 0 ❑ ❑ ❑
degrees Celsius)?
Is sampling performed according to the permit? 0 ❑ ❑ ❑
Comment:
Effluent Semolina Yn_No NA NE
Is composite sampling flow proportional? M ❑ ❑ ❑
Is sample collected below all treatment units? ❑ ❑ ❑
is proper volume collected? ❑ ❑ ❑ ■
Page# 7
DocuSign Envelope ID:83B386A1-1895-4D56-B402-C78A58BB3724
Permit• N00020606 owner.FadBtr Tarboro WVVTP
hu"wetion Date: 0M24/2024 pppeayen Type Compliance EvWwrUm
Meal Samplinji YIL_No NA NE
Is the tubing dean? M ❑ 0 13
#Is proper ternperature set for sample storage(kept at less than or equal to 6.0 r ❑ 1313
degrees Celsius)?
Is the facility sampling perbrmed as required by the permit(frequency,sampling type M ❑ ❑ ❑
representative)?
Comment:
Page# 8