HomeMy WebLinkAboutNC0047384_Compliance Evaluation Inspection_20180501 �;. ROY COOPER
?.y
Governor
MICHAEL S.REGAN
Secretary
Water Resources LINDA CULPEPPER
Environmental Quality Interim Director
May 1, 2018
Mr. Steven Drew,Director
Water Resources Department
City of Greensboro
P.O.Box 3136
Greensboro,NC 27402-3136
SUBJECT: Compliance Evaluation Inspection RECE1V�®�®���®W�
City of Greensboro-T.Z. Osborne WWTP MAY 10 2018
NPDES Permit No.NC0047384
Guilford County Water Resources
Permitting Section
Dear Mr. Drew:
On April 27, 2018, Jenny Graznak of this office met with Bradley Flynt,Elijah Williams, Martie Groome
and Alicia Goots to perform a Compliance Evaluation Inspection of the NPDES wastewater discharge from
the T.Z. Osborne facility(TZO). The inspection fmdings are detailed below and an inspection checklist is
attached.
1.Permit
The current NPDES permit was issued on July 1, 2014, and a complete copy was available for review
during the inspection. TZO is currently being upgraded from 40.0 MGD to 56.0 MGD to accommodate the
flow from the decommissioning of the North Buffalo facility and to meet new nutrient limitations.
2. Self-Monitoring Program
The monthly Discharge Monitoring Reports (DMRs)were reviewed for the period January 2017 through
February 2018 for this inspection. The facility was found to be non-compliant with permit limits for
Carbonaceous BOD, Fecal coliform, and TSS during this time. These violations resulted in Notices of
Violation,as well as a civil penalty assessment,and were addressed through previous correspondence from
this office(see violation list attached).Regarding the permit monitoring requirements, it was noted that all
sampling seems to have been performed per the frequencies specified in the permit.
3.Flow Measurement
The plant has three ultrasonic meters with parshall flumes that are used to report effluent flow on the DMRs.
The three meters were last calibrated in February 2018 by City staff. In addition, flow proportional
composite effluent samples are collected as required by the permit.
4.Sludge Handling and Disposal
Sludge treatment units consist of sludge receiving tanks, gravity thickeners, centrifuges, thickened sludge
holding tanks and fluidized bed incinerators.
5.Operations and Maintenance
The operation and maintenance at this facility appears to be excellent. The laboratory also appeared to be
excellently maintained and organized.
R' Nothing Compares'-� .
State of North Carolina I Environmental Quality
450 W.Hanes Mill Road,Suite 300,Winston-Salem,North Carolina 27105
Phone:336-776-98001 FAX:336-776-9797
6.Facility Site Review
Please see the attached inspection checklist for specific comments on the system components. Construction
at the facility is ongoing to upgrade the plant for Biological Nutrient Removal and increase the capacity
from 40.0 MGD to 56.0 MGD. The estimated completion of the project is 2020.Four new bar screens have
been installed recently. Six Aqua Diamond Cloth Media Filters have also been installed and appeared to be
operating well. Ultimately, twelve aeration basins will all have new blowers and diffusers. The current
average daily flow at the plant is approximately 31 MGD, according to operators.
7.Records/Reports
All required information was readily available, complete, and current. A comparison of the October 2017
DMR with the laboratory data for Fecal coliform,Carbonaceous BOD,Ammonia,Total Residual Chlorine,
and Total Suspended Solids revealed that these parameters were accurately transcribed onto the monitoring
report. In addition, the Mercury Minimization Plan and the 2017 Annual Performance Report were
available for review.
8.Effluent/Receiving Waters
The system discharges into South Buffalo Creek,a class WS-V;NSW stream in the Cape Fear River Basin.
The effluent was clear on the day of inspection.
This office appreciates the efforts by City of Greensboro to comply with the permit requirements. Should
you have any questions concerning this letter and attached inspection report,please contact Jenny Graznak
or me at(336)776-9800.
Sincerely,
Ac,“,Sherri V.Knight,P.E.
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources
cc: Elijah Williams(elijah.williamsa,greensboro-nc.gov)
Bradley Flynt(Bradley.flynt@greensboro-nc.gov)
Martie Groome(martie.groome@,greensboro-nc.gov)
Central Files
WSRO
NPDES Unit
Attachments: Inspection Report
Monitoring Violations Report
United States Environmental Protection Agency Form Approved.
E PA 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 h,j 2 LI 3 I NC0047384 I11 12 I 18/04/27
117
18 Li,„I 19 i i 201
211 h i l i I I I I I I I I I I I I I I I I I 1 1 I I I I I Ii I I I I I I I I I r6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA Reserved
671 I 701LJ 4 I 71I JI 72 LJ `N 731 I 174 751 1 1 1 1 1 1 180
Section B.FacilityData
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number) 09 OOAM 18/04/27 14/07/01
T.Z Osborne WWTP
2350 Huffine Mill Rd Exit Time/Date Permit Expiration Date
Mc Leansville NC 27301 12 30PM 18/04/27 19/06/30
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
///
Bradley Todd Flynt/ORD/336-433-7262/
Eltah Lamont Williams//336-373-4632/
Martie Groome//336-433-7229/3363737720
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Steven Drew,PO Box 3136 Greensboro NC 274023136//336-373-2055/3364126305
No
Section C Areas Evaluated During Inspection(Check only those areas evaluated)
Permit • Flow Measurement El Operations&Maintenance • Records/Reports
II Self-Monitoring Program II Sludge Handling Disposal • Facility Site Review I Effluent/Receiving Waters
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/2-Ci
Jennifer F Graznaka WSRO WQ//336-771-5000/
$ itjtA44
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
gi /
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete
Page# 1
NPDES yr/mo/day Inspection Type (Cont) 1
31 NC0047384 111 121 18/04/27 117 18 Li
Section D.Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
1. Permit
The current NPDES permit was issued on July 1, 2014, and a complete copy was available for review
during the inspection. TZO is currently being upgraded from 40 0 MGD to 56.0 MGD to accommodate
the flow from the decommissioning of the North Buffalo facility and to meet new nutrient limitations.
2. Self-Monitoring Program
The monthly Discharge Monitoring Reports (DMRs)were reviewed for the period January 2017 through
February 2018 for this inspection. The facility was found to be non-compliant with permit limits for
Carbonaceous BOD, Fecal coliform, and TSS during this time. These violations resulted in Notices of
Violation as well as a civil penalty assessment and were addressed through previous correspondence
from this office (see violation list attached). Regarding the permit monitoring requirements, it was noted
that all sampling seems to have been performed per the frequencies specified in the permit.
3 Flow Measurement
The plant has three ultrasonic meters with parshall flumes that are used to report effluent flow on the
DMRs The three meters were last calibrated in February 2018 by City staff. In addition,flow
proportional composite effluent samples are collected as required by the permit.
4. Sludge Handling and Disposal
Sludge treatment units consist of sludge receiving tanks, gravity thickeners, centrifuges, thickened
sludge holding tanks and fluidized bed incinerators.
5. Operations and Maintenance
The operation and maintenance at this facility appears to be excellent. The laboratory also appeared to
be excellently maintained and organized.
6. Facility Site Review
Please see the attached inspection checklist for specific comments on the system components
Construction at the facility is ongoing to upgrade the plant for Biological Nutrient Removal and the
increase the capacity from 40.0 MGD to 56.0 MGD. Th estimate for completion of the project is 2020.
Four new bar screens have been installed recently. Six Aqua Diamond Cloth Media Filters have also
been installed and appeared to be operating well. Ultimately,twelve aeration basins will all have new
blowers and diffusers.The current average daily flow at the plant is approximately 31 MGD, according
to operators.
7. Records/Reports
All required information was readily available, complete, and current. A comparison of the October
2017 DMR with the laboratory data for Fecal coliform, Carbonaceous BOD,Ammonia,Total Residual
Chlorine, and Total Suspended Solids revealed that these parameters were accurately transcribed
onto the monitoring report. In addition,the Mercury Minimization Plan and the 2017 Annual
Performance Report were available for review.
8. Effluent/Receiving Waters
The system discharges into South Buffalo Creek, a class WS-V, NSW stream in the Cape Fear River
Basin. The effluent was clear on the day of inspection.
Page# 2
Permit: NC0047384 Owner-Facility: T.Z.Osborne WWTP
Inspection Date: 04/27/2018 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 0 0 • 0
application?
Is the facility as described in the permit? • 000
#Are there any special conditions for the permit? • 000
Is access to the plant site restricted to the general public? • ❑ ❑ ❑
Is the Inspector granted access to all areas for inspection? • 000
Comment. The current NPDES permit was issued on July 1, 2014, and a complete copy was available
for review during the inspection. TZO is currently being upgraded from 40.0 MGD to 56.0
MGD to accommodate the flow from the decommissioning of the North Buffalo facility and to
meet new nutrient limitations.
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 • ❑ ❑ 0
Solids,pH, DO, Sludge Judge, and other that are applicable?
Comment: The operation and maintenance at this facility appears to be excellent. The laboratory also
appeared to be excellently maintained and organized.
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit? - I ❑ ❑ ❑
Is all required information readily available, complete and current? M ❑ ❑ ❑
Are all records maintained for 3 years(lab. reg required 5 years)? • 000
Are analytical results consistent with data reported on DMRs? U ❑ ❑ ❑
Is the chain-of-custody complete? • 000
Dates,times and location of sampling •
Name of individual performing the sampling E
Results of analysis and calibration •
Dates of analysis U
Name of person performing analyses III
Transported COCs •
Are DMRs complete do they include all permit parameters? • 000
Has the facility submitted its annual compliance report to users and DWQ? • C11=10
(If the facility is=or>5 MGD permitted flow) Do they operate 24/7 with a certified operator • •I0 ❑ ❑
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? U ❑ ❑ ❑
Page# 3
Permit: NC0047384 Owner-Facility: T Z.Osborne wwrP
Inspection Dater 04/27/2018 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Is the backup operator certified at one grade less or greater than the facility classification? • ❑ 0 0
Is a copy of the current NPDES permit available on site? • 0 0 0
Facility has copy of previous year's Annual Report on file for review? • 0 0 0
Comment: All required information was readily available, complete, and current. A comparison of the
October 2017 DMR with the laboratory data for Fecal coliform, Carbonaceous BOD,
Ammonia,Total Residual Chlorine, and Total Suspended Solids revealed that these
parameters were accurately transcribed onto the monitoring report. In addition,the Mercury
Minimization Plan and the 2017 Annual Performance Report were available for review.
Influent Sampling Yes No NA NE
#Is composite sampling flow proportional'? • ❑ ❑ p
Is sample collected above side streams? • ❑ ❑ ❑
Is proper volume collected'? • 0 0 0
Is the tubing clean'? • ❑ ❑ ❑
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees • ❑ ❑ 0
Celsius)'
Is sampling performed according to the permit? • ❑ ❑ ❑
Comment: The influent sampler refrigeration unit was 3 degrees at the time of the inspection. Since the
North Buffalo facility shut down, the City has been working to incorporate that flow stream
into the sampling protocol.
Equalization Basins Yes No NA NE
Is the basin aerated'? ❑ MI ❑ ❑
Is the basin free of bypass lines or structures to the natural environment's • ❑ ❑ 0
Is the basin free of excessive grease'? • 0 ❑ ❑
Are all pumps present? 0 ❑ ❑ •
Are all pumps operable', 0 0 ❑ •
Are float controls operable'? ❑ ❑ 0 •
Are audible and visual alarms operable'? ❑ ❑ 0 •
#Is basin size/volume adequate'? • ❑ 0 ❑
Comment: The facility now has 3.5 MG and 4 MG basins.The flow goes through the bar screen prior to
the equalization basin and then is re-screened before entering through the plant.There is an
odor control apparatus in use at the EQ basins
Bar Screens Yes No NA NE
Type of bar screen
Page# 4
Permit: NC0047384 Owner-Facility: T Z.Osborne VVWTP
Inspection Date: 04/27/2018 Inspection Type: Compliance Evaluation
Bar Screens Yes No NA NE
a.Manual 0
b.Mechanical •
Are the bars adequately screening debris? E ❑ ❑ ❑
Is the screen free of excessive debns? • 000
Is disposal of screening in compliance? • 000
Is the unit in good condition? • 000
Comment: The facility has four new bar screens.The screenings shoot out into a dumbster that is
taken to the landfill.
Grit Removal Yes No NA NE
Type of grit removal
a Manual ❑
b.Mechanical III
Is the grit free of excessive organic matter? • ❑ ❑ ❑
Is the grit free of excessive odor'? • ❑ ❑ ❑
#Is disposal of grit in compliance? • ❑ ❑ ❑
Comment: The stirred vortex grit removal system has four cyclones and two classifiers to dewater the
inorganics.The removed grit goes to the landfill.
Primary Clarifier 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'? • 000
Are weirs level? • ❑ ❑ ❑
Is the site free of weir blockage'? • 000
Is the site free of evidence of short-circuiting? • ❑ ❑ ❑
Is scum removal adequate'? • ❑ ❑ ❑
Is the site free of excessive floating sludge'? • 000
Is the drive unit operational'? M ❑ ❑ ❑
Is the sludge blanket level acceptable? ❑ ❑ DI
Is the sludge blanket level acceptable'?(Approximately%<of the sidewall depth) 000 •
Comment:
Aeration Basins Yes No NA NE
Mode of operation Ext.Air
Page# 5
Permit: NC0047384 Owner-Facility: T.Z Osborne VW/TP
Inspection Date: 04/27/2018 Inspection Type: Compliance Evaluation
Aeration Basins Yes No NA NE
Type of aeration system Diffused
Is the basin free of dead spots'? • 0 0 0
Are surface aerators and mixers operational'? ❑ 0 • 0
Are the diffusers operational? • ❑ ❑ ❑
Is the foam the proper color for the treatment process'? • 0 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 mg/I) ❑ ❑ 0 MI
Comment: Ultimately, twelve aeration basins will all have new blowers and fine bubble membrane filter
diffusers.
Nutrient Removal Yes No NA NE
#Is total nitrogen removal required? • ❑ ❑ ❑
#Is total phosphorous removal required'? • 0 ❑ ❑
Type Biological
#Is chemical feed required to sustain process? 0 ❑ ❑ •
Is nutrient removal process operating properly'? ❑ ❑ ❑ •
Comment: Construction at the facility is ongoing to upgrade the plant for Biological Nutrient Removal
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? • 0 ❑ 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'? U 0 ❑ ❑
Is the site free of evidence of short-circuiting? • 0 ❑ ❑
Is scum removal adequate'? • 0 0 0
Is the site free of excessive floating sludge'? U ❑ ❑ ❑
Is the drive unit operational'? • ❑ ❑ ❑
Is the return rate acceptable(low turbulence)? • 0 ❑ ❑
Is the overflow clear of excessive solids/pin floc'? - • ❑ ❑ ❑
Is the sludge blanket level acceptable'?(Approximately% of the sidewall depth) ❑ ❑ ❑ II
Comment:
Page# 6
Permit: NC0047384 Owner-Facility: T Z.Osborne WWTP
Inspection Date: 04/27/2018 Inspection Type: Compliance Evaluation
Filtration (High Rate Tertiary) Yes No NA NE
Type of operation. Down flow
Is the filter media present? • ❑ ❑ ❑
Is the filter surface free of clogging'? • 000
Is the filter free of growth? • 000
Is the air scour operational? • 000
Is the scouring acceptable'? • 000
Is the clear well free of excessive solids and filter media'? • 000
Comment. Six new Aqua Diamon Cloth Media Filters that have been installed over the past 5 years.The
sand filter effluent was clear on the day of the inspection.The"dirty"water from the filters
goes back to headworks.
Disinfection-Liquid Yes No NA NE
Is there adequate reserve supply of disinfectant? M ❑ ❑ ❑
(Sodium Hypochlorite)Is pump feed system operational'? • 000
Is bulk storage tank containment area adequate'?(free of leaks/open drains) • 000
Is the level of chlorine residual acceptable? • ❑ ❑ 0
Is the contact chamber free of growth, or sludge buildup'? • ❑ ❑ ❑
Is there chlorine residual prior to de-chlorination'? • 000
Comment. Sodium hypochlorite is fed at the sand filters and at the effluent for disinfection.The contact
chamber is brand new.
De-chlorination Yes No NA NE
Type of system 9 Liquid
Is the feed ratio proportional to chlorine amount(1 to 1)? ❑ • ❑ ❑
Is storage appropriate for cylinders? ❑ 0110
#Is de-chlorination substance stored away from chlorine containers'? ❑ ❑ E ❑
Are the tablets the proper size and type'? ❑ ❑ • ❑
Comment. The sodium bisulfate feed is adjusted manually.
Are tablet de-chlorinators operational' ❑ ❑ • ❑
Number of tubes in use'?
Comment. _
Flow Measurement-Effluent Yes No NA NE
#Is flow meter used for reporting'? • ❑ ❑ ❑
Page# 7
Permit: NC0047384 Owner-Facility: T Z.Osborne WWTP
Inspection Date: 04/27/2018 Inspection Type: Compliance Evaluation
Flow Measurement-Effluent Yes No NA NE
Is flow meter calibrated annually'? • 0 0 0
Is the flow meter operational? • 0 0 0
(If units are separated)Does the chart recorder match the flow meter'? 0 0 0 •
Comment The three effluent meters were last calibrated in February 2018 by City staff.
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional'? • 0 0 0
Is sample collected below all treatment units? • 0 0 0
Is proper yolume collected'? • 0 0 0
Is the tubing clean' 0 0 0 II
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees 0 0 0 •
Celsius)'
Is the facility sampling performed as required by the permit(frequency,sampling type • 0 0 0
representative)?
Comment
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained'? • 0 0 0
Are the receiving water free of foam other than trace amounts and other debris'? • 0 0 0
If effluent (diffuser pipes are required) are they operating properly'? 0 ❑ • 0
Comment: The system discharges into South Buffalo Creek, a class WS-V; NSW stream in the Cape
Fear River Basin. The effluent was clear on the day of inspection.
Solids Handling Equipment Yes No NA NE
Is the equipment operational? • ❑ ❑ 0
Is the chemical feed equipment operational'? • 0 0 0
Is storage adequate'? • 0 0 0
Is the site free of high level of solids in filtrate from filter presses or vacuum filters'? ❑ ❑ II ❑
Is the site free of sludge buildup on belts and/or rollers of filter press? 0 0 II 0
Is the site free of excessive moisture in belt filter press sludge cake'? 0 0 • 0
The facility has an approved sludge management plan'? • 0 0 0
Comment' Sludge treatment units consist of sludge receiving tanks, gravity thickeners, centrifuges,
thickened sludge holding tanks and fluidized bed incinerators.
Standby Power Yes No NA NE
Page# 8
Permit: NC0047384 Owner-Facility: T Z.Osborne WWTP
Inspection Date: 04/27/2018 Inspection Type: Compliance Evaluation
Standby Power Yes No NA NE
Is automatically activated standby power available? • 0 ❑ ❑
Is the generator tested by interrupting primary power source? • El 0 ❑
Is the generator tested under load? U 0 El ❑
Was generator tested&operational during the inspection'? ❑ U ❑ ❑
Do the generator(s)have adequate capacity to operate the entire wastewater site? I. 0 ❑ ❑
Is there an emergency agreement with a fuel vendor for extended run on back-up power? ❑ ❑ El U
Is the generator fuel level monitored'? • ❑ ❑ ❑
Comment Three generators can operate the entire plant.They automatically switch over during a
power failure.The Air Quality permit requires plant to run the generator for 30 to 60 minutes
every month.
Page# 9
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MONITORING REPORT(MR)VIOLATIONS for: Report Date 05/01/18 Page. 1 of 1 .
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PERMIT: NC0047384 FACILITY: City of Greensboro-T.Z.Osborne WWTP COUNTY:Guilford REGION: Winston-Salem
Limit Violation
MONITORING OUTFALL/
'
LOCATION PARAMETER VIOLATION UNIT OF CALCULATED %
REPORT PPI
DATE MEASURE VALUE Over
FREQUENCY LIMIT VIOLATION TYPE VIOLATION ACTION
04-2017 001 Effluent BOD,Carbonaceous 05 Day, 04/29/17 2 X week mg/I 6 9 58 59 6 Weekly Average Proceed to NOV
20 C Exceeded
06-2017 001 Effluent BOD,Carbonaceous 05 Day, 06/24/17 2 X week mg/I 6 16 02 167 Weekly Average Proceed to NOV
20 C Exceeded
06_2017 001 Effluent BOD,Carbonaceous 05 Day, 06/30/17 2 X week mg/I 4 4 33 8 3 Monthly Average Proceed to NOV
20 C Exceeded
07-2017 001 Effluent BOD,Carbonaceous 05 Day, 07/15/17 2 X week mg/I 6 7 05 17 5 Weekly Average Proceed to NOV
20 C Exceeded
07_2017 001 Effluent BOD,Carbonaceous 05 Day, 07/31/17 2 X week mg/I 4 5 47 36 7 Monthly Average Proceed to NOV
20 C Exceeded
10-2017 001 Effluent Chlorine,Total Residual 10/20/17 5 X week ug/I 18 65 261 1 Daily Maximum Proceed to NOV
Exceeded
04_2017 001 Effluent Coliform,Fecal MF,MFC 04/29/17 2 X week #/100m1 400 753 91 88 5 Weekly Geometric Mean Proceed to NOV
Broth,44 5 C Exceeded
06-2017 001 Effluent Coliform,Fecal MF,MFC 06/03/17 2 X week #/100m1 400 500 97 25 2 Weekly Geometric Mean Proceed to NOV
Broth,44 5 C Exceeded
06_2017 001 Effluent Coliform,Fecal MF,MFC 06/24/17 2 X week #/100m1 400 5,291 16 1,222.8 Weekly Geometric Mean Proceed to NOV
Broth,44 5 C Exceeded
06-2017 001 Effluent Coliform,Fecal MF,MFC 06/30/17 2 X week #/100m1 200 597 37 198 7 Monthly Geometric Mean Proceed to NOV
Broth,44 5 C Exceeded
10-2017 001 Effluent Coliform,Fecal MF,MFC 10/07/17 2 X week #/100m1 400 685 12 71 3 Weekly Geometric Mean Proceed to NOV
Broth,44 5 C Exceeded
MONITORING REPORT(MR)VIOLATIONS for: Report Date. 05/01/18 Page. 1 of 1
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