Document GKr22LpJgp7Je7Dakv51DK6p4

March 21, 2024 Anna Hatke US EPA New England Region 1 United States Environmental Protection Agency Laboratory Services and Applied Science Division 11 Technology Drive North Chelmsford, MA 01863-2431 Laboratory Report Page 1 of 13 Project Number: 24020024 Project: Tender Corp SIU - Littleton, NH Analysis: VOAs in Water EPA Chemist: Allison Connors Date Samples Received by the Laboratory: 02/23/2024 Analytical Procedure: All samples were received and logged in by the laboratory according to the USEPA New England Laboratory SOP for Sample Log-in. Sample preparation and analysis was done following the EPA Region I SOP, LSBSOP-VOAGCMS12. Samples were analyzed by GC/MS. Samples were introduced to the GC via an autosampler and purge and trap preconcentrator system.. The analysis SOP is based on US EPA Method 8260D SW846 update VI, rev 4, 2018, method 5030B, rev 2.0 SW-846, Rev 2.0,1996. Method 624.1, 40CFR Part 136 Appendix A, December, 2014, and USEPA CLP SOW for Organic Analysis OLM04.2, 1999. Data were reviewed in accordance with the internal verification procedures described in the EPA New England Quality Manual for NERL. Results relate only to the items tested or to the samples as received by the Laboratory. This analytical report shall not be reproduced except in full, without written approval of the laboratory. If you have any questions please call me at 617-918-8340 . Sincerely, DANIEL Digitally signed by DANIEL BOUDREAU BOUDREAU 10:05:36 -04'00' Date: 2024.03.21 24020024$VOAMW Qualifiers: RL = Reporting limit ND = Not Detected above Reporting limit NA = Not Applicable due to high sample dilutions or sample interferences NC = Not calculated since analyte concentration is ND. J = Estimated value J1 = Estimated value due to MS recovery outside accceptance criteria J2 = Estimated value due to LFB result outside acceptance criteria J3 = Estimated value due to RPD result outside acceptance criteria J4 = Estimated value due to LCS result outside acceptance criteria E = Estimated value exceeds the calibration range L = Estimated value is below the calibration range B = Analyte is associated with the lab blank or trip blank contamination. Values are qualified when the observed concentration of the contamination in the sample extract is less than 10 times the concentration in the blank. R = No recovery was calculated since the analyte concentration is greater than four times the spike level. P = The confirmation value exceeded 35% difference and is less than 100%. The lower value is reported. C = The identification has been confirmed by GC/MS. A = Suspected Aldol condensation product. N = Tentatively identified compound. ANR = Analysis not required. Page 2 of 13 24020024$VOAMW Client Sample ID: Date of Collection: Date of Preparation: Date of Analysis: Dry Weight Prepared: Wet Weight Prepared: Volume Extracted: Final Volume: CAS Number 67-64-1 75-09-2 US ENVIRONMENTAL PROTECTION AGENCY NEW ENGLAND LABORATORY Tender Corp SIU - Littleton, NH VOAs in Water Tender-01 2/21/2024 2/27/2024 2/27/2024 N/A N/A 5 mL N/A Compound 2-Propanone (acetone) Methylene Chloride Concentration ug/L 11 ND Page 3 of 13 Lab Sample ID: Matrix: Amount Prepared: Percent Solids: Extract Dilution: pH: GPC Factor: AC11462 Wastewater 5 mL N/A 1 <2 N/A RL ug/L Qualifier 5.0 1.0 Surrogate Compounds 1,2-Dichloroethane-D4 Toluene-D8 1,4-Bromofluorobenzene Recoveries (%) 104 97 89 QC Ranges 86 - 123 94 - 104 92 - 106 Comments: Tentatively Identified Compound(s): D-Limonene 12 ppb, J Eucalyptol 82 ppb, J gamma-Terpinene 49 ppb,J 24020024$VOAMW Client Sample ID: Date of Collection: Date of Preparation: Date of Analysis: Dry Weight Prepared: Wet Weight Prepared: Volume Extracted: Final Volume: CAS Number 67-64-1 75-09-2 US ENVIRONMENTAL PROTECTION AGENCY NEW ENGLAND LABORATORY Tender Corp SIU - Littleton, NH Laboratory Blank for $VOAMW N/A N/A 2/27/2024 2/27/2024 N/A N/A 5.0 mL N/A Compound 2-Propanone (acetone) Methylene Chloride Concentration ug/L ND ND Page 4 of 13 Lab Sample ID: Matrix: Amount Prepared: Percent Solids: Extract Dilution: pH: GPC Factor: N/A Wastewater 5.0 mL N/A 1 <2 N/A RL ug/L Qualifier 5.0 1.0 Surrogate Compounds 1,2-Dichloroethane-D4 Toluene-D8 1,4-Bromofluorobenzene Recoveries (%) 115 96 90 QC Ranges 86 - 123 94 - 104 92 - 106 24020024$VOAMW Client Sample ID: Date of Collection: Date of Preparation: Date of Analysis: Dry Weight Prepared: Wet Weight Prepared: Volume Extracted: Final Volume: CAS Number 67-64-1 75-09-2 US ENVIRONMENTAL PROTECTION AGENCY NEW ENGLAND LABORATORY Tender Corp SIU - Littleton, NH VOAs in Water DUP-01 2/21/2024 2/27/2024 2/27/2024 N/A N/A 5 mL N/A Compound 2-Propanone (acetone) Methylene Chloride Concentration ug/L 12 ND Page 5 of 13 Lab Sample ID: Matrix: Amount Prepared: Percent Solids: Extract Dilution: pH: GPC Factor: AC11463 Wastewater 5 mL N/A 1 <2 N/A RL ug/L Qualifier 5.0 1.0 Surrogate Compounds 1,2-Dichloroethane-D4 Toluene-D8 1,4-Bromofluorobenzene Recoveries (%) 100 95 88 QC Ranges 86 - 123 94 - 104 92 - 106 Comments: Tentatively Identified Compound(s): Eucalyptol 72 ppb, J gamma-Terpinene 30 ppb,J 24020024$VOAMW Client Sample ID: Date of Collection: Date of Preparation: Date of Analysis: Dry Weight Prepared: Wet Weight Prepared: Volume Extracted: Final Volume: CAS Number 67-64-1 75-09-2 US ENVIRONMENTAL PROTECTION AGENCY NEW ENGLAND LABORATORY Tender Corp SIU - Littleton, NH VOAs in Water Trip Blanks 2/21/2024 2/27/2024 2/27/2024 N/A N/A 5 mL N/A Compound 2-Propanone (acetone) Methylene Chloride Concentration ug/L ND ND Page 6 of 13 Lab Sample ID: Matrix: Amount Prepared: Percent Solids: Extract Dilution: pH: GPC Factor: AC11464 Wastewater 5 mL N/A 1 <2 N/A RL ug/L Qualifier 5.0 1.0 Surrogate Compounds 1,2-Dichloroethane-D4 Toluene-D8 1,4-Bromofluorobenzene Recoveries (%) 110 95 88 QC Ranges 86 - 123 94 - 104 92 - 106 24020024$VOAMW PARAMETER 2-Propanone (acetone) Methylene Chloride US ENVIRONMENTAL PROTECTION AGENCY NEW ENGLAND LABORATORY Tender Corp SIU - Littleton, NH MATRIX SPIKE (MS) RECOVERY Sample ID: AC11463 Page 7 of 13 SPIKE ADDED ug/L 20.0 20.0 SAMPLE CONCENTRATION ug/L 12.0 ND MS MS CONCENTRATION % ug/L REC 31.0 91 20.0 101 QC LIMITS (% REC) 29 - 164 55 - 151 24020024$VOAMW PARAMETER 2-Propanone (acetone) Methylene Chloride US ENVIRONMENTAL PROTECTION AGENCY NEW ENGLAND LABORATORY Tender Corp SIU - Littleton, NH MATRIX SPIKE DUPLICATE (MSD) RECOVERY Sample ID:AC11463 MSD SPIKE ADDED 20.0 20.0 MSD CONCENTRATION ug/L 30.0 19.0 MSD % REC 88 95 Page 8 of 13 RPD QC % LIMITS RPD 2.80 40 6.12 40 24020024$VOAMW PARAMETER 2-Propanone (acetone) Methylene Chloride US ENVIRONMENTAL PROTECTION AGENCY NEW ENGLAND LABORATORY Tender Corp SIU - Littleton, NH Laboratory Duplicate Results Sample ID: AC11462 SAMPLE RESULT ug/L 11.0 ND SAMPLE DUPLICATE RESULT ug/L 13.0 ND PRECISION RPD % 16.7 NC Page 9 of 13 QC LIMITS 30 30 24020024$VOAMW PARAMETER 2-Propanone (acetone) Methylene Chloride Comments: US ENVIRONMENTAL PROTECTION AGENCY NEW ENGLAND LABORATORY Tender Corp SIU - Littleton, NH Laboratory Fortified Blank (LFB) Results LFB AMOUNT SPIKED ug/mL 20 20 LFB RESULT ug/mL 17.0 20.0 LFB RECOVERY % 86 100 Page 10 of 13 QC LIMITS % 12 - 209 70 - 134 24020024$VOAMW US ENVIRONMENTAL PROTECTION AGENCY NEW ENGLAND LABORATORY Tender Corp SIU - Littleton, NH LABORATORY FORTIFIED DUPLICATE (LFB Dup) RECOVERY COMPOUND LFB Dup LFB Dup RPD CONCENTRATION RECOVERY % ug/L % 2-Propanone (acetone) Methylene Chloride 17.9 90 4 21.4 107 7 Samples in Batch: AC11462, AC11463, AC11464 Page 11 of 13 QC LIMITS RPD 50 50 24020024$VOAMW Page 12 of 13 Page 13 of 13 Date: 4/17/2024 Subject: From: Inspection Report Compliance Sampling Inspection Tender Corporation d/b/a Adventure Ready BrandsTM William Sommer, Inspector Field Services Branch (FSB) Digitally signed by WILLIAM WILLIAM SOMMER SOMMER Date: 2024.04.17 08:52:45 -04'00' Laboratory Services and Applied Science Division (LSASD) Anna Hatke, Life Scientist LSASD-FSB ANNA HATKE Digitally signed by ANNA HATKE Date: 2024.04.17 08:46:49 -04'00' Reviewed By: LSASD-FSB Jerome Keefe, Field Team Leader JEROME KEEFE Date: 2024.04.18 08:07:06 -04'00' Digitally signed by JEROME KEEFE To: Newton Tedder, Acting Manager Water Compliance Section 1 Enforcement and Compliance Assurance Division (ECAD) CC: Damian Bednarz, Inspector ECAD-EWC I. Facility Information A. Facility Name: Tender Corporation d/b/a Adventure Ready BrandsTM B. Facility Location: 944 Industrial Park Road, Littleton, NH 03561 C. Facility Contact(s): John Gaulin, Chief Operating Officer jgaulin@adventurereadybrands.com (800) 258- 4696, Patience Marsh, QAIRA Manager, Anastasia Keats, QC Manager D. National Pollutant Discharge Elimination System ("NPDES") ID Number: NHPIU0014 II. Background Information A. Date and time of inspection: 2/21/2024 Facility entrance: 13:00 Tender Corporation d/b/a Adventure Ready BrandsTM (NHPIU0014) EPA IU Compliance Sampling Inspection Facility exit: 15:41 B. Weather Conditions: 34 F, sunny, with little cloud cover C. US EPA Representative(s): William Sommer, Nafisah Ali, Ryan Leo, Anna Hatke D. State/Local Representative(s): Doug Damko, Director of Public Works , The Town of Littleton POTW) ddamko@townoflittleton.org, Eric Oliver, Public Works Pre-Treatment Coordinator, The Town of Littleton POTW eoliver@townoflittleton.org E. Federally Enforceable Requirements Covered During the Inspection: 40 C.F.R. Part 403, General Pretreatment Regulations, 40 CFR Part 439.27- Pharmaceutical Manufacturing Point Source Category Subpart B-Extraction Products 40 C.F.R. Part 455.47- Pesticide Chemicals Formulating and Packaging Regulations F. Previous Enforcement Actions: Administrative- Formal Docket Number: CWA-AO-R01-FY20-29 Enforcement Type: CWA 309A AO For Compliance III. Disclaimer Unless otherwise noted, this report describes conditions at the facility/property as observed by EPA inspector(s), and/or through records provided to and/or information reported to EPA inspector(s) by facility representatives and as understood by the inspector(s). This report may not capture all operations or activities ongoing at the time of the inspection. This report does not make final determinations on potential areas of concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. IV. Type and Purpose of Inspection US EPA Region 1 representatives William Sommer, Nafisah Ali, Anna Hatke, Ryan Leo, and Damian Bednarz (the "EPA Inspection Team") conducted an announced NPDES Industrial User ("IU") pretreatment sampling inspection at Tender Corporation d/b/a Adventure Ready BrandsTM, a privately-owned industrial facility ("the facility"), located in Littleton, NH. The purpose of this inspection was to collect representative effluent wastewater samples and assess the facility's compliance with the EPA general pretreatment regulations in 40 CFR 403, the applicable EPA categorical pretreatment standards in 40 CFR 439.27 and 40 C.F.R. Part 455.47, and applicable provisions including but not limited to industrial local limits in the facility's industrial discharge permit (IDP) issued by the Town of Littleton, NH. V. Facility Description According to the facility's website, Tender Corporation d/b/a Adventure Ready Brands was established in 1975. The facility manufactures pharmaceutical and pesticide products for Page 2 of 10 Inspection Date: 2/21/2024 Tender Corporation d/b/a Adventure Ready BrandsTM (NHPIU0014) EPA IU Compliance Sampling Inspection external or internal human consumption, primarily in the form of ampoules, tablets, capsules, vials, ointments, medicinal powders, solutions, and suspensions. Specific brands and products produced by this facility include After Bite,Ben's and Natrapel insect repellant, first aid kits from Adventure Medical Kits, Easy Care First AidTM, survival products from Survive Outdoors Longer, RapidPureoutdoor water purifiers, bear spray from Counter Assault, and newly acquired LuminAID that provides solar powered lanterns. According to a prior facility inspection report, one discharge point is present in the facility, "Outfall 1", which discharges to the Littleton Publicly Owned Treatment Works ("POTW") (NPDES Permit No. NH0100153). Two processing lines are present at the facility, one pharmaceutical processing line and one pesticides processing line. "Outfall 1" is located at the end of the pharmaceutical processing line. According to John Gaulin, Chief Operating Officer of the facility, there is no discharge from the pesticide processing line to Littleton POTW. The facility's Significant Industrial User ("SIC") Codes are 2834 (Pharmaceutical Preparations), and 2879 (Pesticides and Agricultural Chemicals, Not Elsewhere Classified). VI. Inspection On 2/6/2024 Damian Bednarz announced the inspection to the facility. On 2/21/24 the EPA Inspection Team entered the facility at approximately 13:00. VI.A. Opening Conference At 13:10, the EPA Inspection Team held an opening conference with Doug Damko and Eric Oliver from the Town of Littleton POTW (the "Local Representatives"), and facility representatives John Gaulin, Patience Marsh, and Anastasia Keats (the "Facility Representatives"). Mr. Sommer and Mr. Bednarz presented credentials to the facility and Local Representatives. Mr. Sommer explained the purpose of the wastewater sampling inspection. Mr. Gaulin explained that Tender Corporation d/b/a Adventure Ready BrandsTM employs 78 fulltime employees and 2 part-time employees in manufacturing. The facility has two ten-hour operating shifts on Monday through Thursday. Mr. Gaulin explained that the facility has an automated wastewater pretreatment system that batch discharges to the Littleton POTW. Wastewater sent to the pretreatment system is generated from the facility's pharmaceutical processing line. The pesticide processing line present at the facility does not discharge to the facility's pretreatment system and does not discharge to the POTW. All floor drains present in the pesticide process line room are plugged. Mr. Gaulin explained that in the past, Veolia, a third-party contractor, was hired for wastewater removal from the facility's pesticide processing line. Mr. Gaulin explained the facility recycles rinsate through the facility pesticide processing line and removal is no longer necessary. Veolia is now utilized for disposal of expired key product returns. Page 3 of 10 Inspection Date: 2/21/2024 Tender Corporation d/b/a Adventure Ready BrandsTM (NHPIU0014) EPA IU Compliance Sampling Inspection Mr. Gaulin explained that in November through December of 2022, the facility underwent renovations. A new dividing wall was installed between the pharmaceutical process line and the pretreatment room. This addition was included in the updated facility schematic. Mr. Gaulin explained two emergency stop buttons were installed, one of which is located at the automatic sump pump in the pharmaceutical pretreatment room. Ms. Ali asked if the addition of the emergency stop buttons were included in the updated facility schematic. Mr. Gaulin explained they were not included on the updated facility schematic. Ms. Ali asked if "Outfall 1" is labeled on the updated facility schematic. Mr. Gaulin explained that "Outfall 1" is not labeled on the updated facility schematic. Ms. Hatke asked if emergency shutoff valves are present at the facility. Ms. Marsh explained that the facility requires employees to attend training for use of facility shut off valves upon hiring and during document changes. Mr. Gaulin explained grab samples are collected from "Outfall 1" by facility personnel once a week for pH measurements. Mr. Bednarz explained, upon review of facility records, that the facility reported weekly and monthly averages for pH and monthly averages for flow. He explained that there was one periodic report for compliance ("PRC") that did not have discharge representative pH data, and that flow is typically reported as one representative month of flow out of the 6-month operational duration of the PRC. Mr. Gaulin explained the facility uses Chemserve, a contract laboratory, for facility sample analysis. Samples collected by facility personnel are sent to Chemserve within 24 hours of collection. The Facility Representatives announced that the wastewater pretreatment system would not be discharging during the sampling. The Facility Representatives explained sanitized water would have to be fed into the wastewater pretreatment system to generate effluent. Mr. Sommer asked if the facility wanted split samples. Mr. Gaulin declined. VI.B. Plant Inspection At 14:04, the Local Representatives departed the facility for the day. The Facility Representatives lead the EPA Inspection Team to the personal protective equipment outfitting room and the EPA Inspection Team donned Tyvek suits, gloves, safety glasses and hair nets. The EPA Inspection Team, except for Mr. Bednarz, and the Facility Representatives, except for Mr. Gaulin, walked to the facility pretreatment system. Mr. Gaulin and Mr. Bednarz agreed to conduct an inspection of the remainder of the footprint of the Facility while sampling was conducted in the pretreatment room. Page 4 of 10 Inspection Date: 2/21/2024 Tender Corporation d/b/a Adventure Ready BrandsTM (NHPIU0014) EPA IU Compliance Sampling Inspection At the pretreatment system, the EPA Inspection Team observed the emergency stop for the automatic sump-pump (Photo 1) and the 300 and 1,000-gallon pharmaceutical mix tanks. The EPA Inspection Team observed two floor drains, one on the upper level, and one on the lower level beneath the tanks, both of which lead to the sump. Ms. Marsh and Ms. Keats showed the EPA Inspection Team the pH neutralization unit which is attached to the sump. They explained that a digital meter attached to the pretreatment system depicts flow and pH. The station also has a paper flow meter attached to the pretreatment system (Photo 2). The EPA Inspection Team observed a valve, labeled "Outfall 1", where Mr. Gaulin said the facility samples treated wastewater is sampled (Photo 4). The EPA Inspection Team began sampling set up at approximately 14:34 at "Outfall 1". To trigger the batch discharge from the pretreatment system Ms. Marsh fed a sanitized water line hose to a port in the "wastewater" pipeline (Photo 3). Samples were collected from the "Outfall 1" valve on the "Treated Water" pipeline. Prior to sample collection, the valve was opened and allowed to run for proximately 30 seconds into a catch bucket to purge the line. Grab and duplicate sample collection occurred at 15:00. Details of the sampling event can be found in Section VII: "Wastewater Sampling". The EPA Inspection Team rejoined Mr. Gaulin and Mr. Bednarz in front of a packaging room after completion of the sampling event. VI.C. Closing Conference At approximately 15:20, the EPA Inspection Team and Facility Representatives reconvened for the closing conference. Mr. Bednarz stated he witnessed a spill during his tour of the pesticide process line, due to the overfilling of a mixing tank. Mr. Gaulin stated that the material from the spill clean-up will be stored in 55-gallon drums, as well as the mop heads used to clean up the spill. Ms. Marsh stated that an email would be sent to Mr. Bednarz outlining the volume of water used to wash out tanks in the pesticide process room. Mr. Bednarz reiterated that pH and flow data ought to be representative of every instance where discharge is occurring to the POTW. Ms. Ali and Mr. Sommer requested an updated schematic from the facility to include e-stops, drains, and "Outfall 1". The EPA Inspection Team departed at 15:41. VII. Wastewater Sampling Page 5 of 10 Inspection Date: 2/21/2024 Tender Corporation d/b/a Adventure Ready BrandsTM (NHPIU0014) EPA IU Compliance Sampling Inspection The sampling activities were conducted in accordance with the FSB Standard Operating Procedure (SOP) for Collection of NPDES Water and Wastewater Samples contained in FSBSOPNPDESWATERSOP, Revision 2, 2020, and the signed Sampling and Analysis Plan (SAP). Mr. Sommer, Ms. Ali, and Mr. Leo collected all the samples described below. Grab samples ("Tender-01") were collected from Outfall 1 valve on the "Treated Water" pipeline for the analysis of Volatile Organic Analytes (VOAs), acetone and methylene chloride. A field duplicate sample ("DUP-01") was collected for each analysis during the sampling inspection. An instantaneous grab sample was collected for the in-situ measurement of pH and Total Residual Chlorine ("TRC"). The sample was field tested for pH using an Oakton "pH tester" pH meter. The pH reading was 8.44 S.U. The pH meter was calibrated prior to the inspection by Ms. Hatke on 2/20/24, using National Institute of Standards and Technology traceable standards. TRC was analyzed in the field using a HACH "DR300" colorimeter by Ms. Ali. The TRC reading was 0.00 mg/L. The Hach DR300 colorimeter was verified according to manufacturer specifications, prior to the inspection using SpecCheck DPD chlorine standards by Ms. Hatke on 2/20/2024. The VOA samples were collected in 40-mL amber vials and preserved with hydrochloric acid to attain a pH of less than 2 S.U. After collection, all samples were placed in coolers with ice to maintain an internal temperature of less than 4 degrees Celsius and delivered to the EPA New England Regional Laboratory in North Chelmsford, MA to be analyzed. VIII. EPA Sampling and Analytical Results The table below provides a summary of the laboratory analytical results and field parameters collected during the inspection. For a full list of compounds analyzed for each parameter and their results, refer to the laboratory reports that are attached to this inspection report, Attachment A. Table 1: Summary of Field Parameters and Laboratory Analytical Results for Inspection of Tender Corporation d/b/a Adventure Ready BrandsTM on February 21, 2024 Sample # Tender01 Sample Date and Time 2/21/24 15:00 Sample Type Grab pH (S.U.) 8.44 TRC (mg/L) 0.00 EPA Analytical Results (mg/L unless otherwise noted) VOCs acetone VOCs methylene chloride 0.011 ND (<.001)1 Pretreatment Standards for 40 CFR Part 439.27 Daily Monthly Maximum Average (mg/L) (mg/L) 20.7 8.2 3.0 0.7 Page 6 of 10 Inspection Date: 2/21/2024 Tender Corporation d/b/a Adventure Ready BrandsTM (NHPIU0014) EPA IU Compliance Sampling Inspection DUP-01 2/21/24 Dup. of N/A N/A VOCs 0.012 20.7 8.2 15:00 Grab acetone VOCs ND 3.0 0.7 methylene (<.001)1 chloride Footnotes: 1. Reporting Level Compounds that were analyzed but not listed in Table 1 are Not Detected above Reporting Limit (ND). The trip blanks were prepared prior to the mobilization. IX. Appendices A: Photos Emergency sewer shut-off Photo 1: Emergency shut off button located in the facility's pretreatment room. Page 7 of 10 Inspection Date: 2/21/2024 Tender Corporation d/b/a Adventure Ready BrandsTM (NHPIU0014) EPA IU Compliance Sampling Inspection Paper flow Electric flow and pH monitor Categorical sampling location for Outfall 1 Photo 2. Facility's pretreatment system with paper flow monitor, and electronic flow and pH monitor. The categorical sampling location for "Outfall 1" is located on the bottom right above the catch bucket. Categorical sampling location for Outfall 1 Page 8 of 10 Port where sanitized water hose was connected Inspection Date: 2/21/2024 Tender Corporation d/b/a Adventure Ready BrandsTM (NHPIU0014) EPA IU Compliance Sampling Inspection Photo 3. The port where the sanitized water hose was connected to is located on the righthand side, on the "Wastewater" pipe. The categorical sampling location for "Outfall 1" is located on the left over the catch bucket. Treated water line Photo 4. The categorical sampling location for "Outfall 1" which is connected to the "treated Water" line and from where sampling occurs. B. Laboratory Analysis Page 9 of 10 Inspection Date: 2/21/2024 Tender Corporation d/b/a Adventure Ready BrandsTM (NHPIU0014) EPA IU Compliance Sampling Inspection End of Report Page 10 of 10 Inspection Date: 2/21/2024