Document R22ggzDvGn99myzrK8r3bDg8X

Report Prepared by: Report Approved by: NPDES Compliance Sampling Inspection Report HP Hood Lafargeville Plant NPDES Permit: NY0002607 20700 Street Route 411 Lafargeville, New York 13656 Inspection Date: April 2-3, 2024 Hillenbrand, Digitally signed by Hillenbrand, Molly Molly Date: 2024.05.23 _________________10_:_13_:_50__-0_4_'0_0_' _____ Molly Hillenbrand, Life Scientist PHILIP Digitally signed by PHILIP COCUZZA COCUZZA Date: 2024.05.23 _________________10_:_3_9_:0_4_-_0_4_'0_0_' ____ Phil Cocuzza, Chief Monitoring Operations Section HP Hood Lafargeville Plant NPDES # NY0002607 Inspection Date: April 2-3, 2024 1.0 OBJECTIVE On April 2-3, 2024, at the request of the Water Compliance Branch, the United States Environmental Protection Agency (USEPA) conducted a National Pollutant Discharge Elimination System (NPDES) Compliance Sampling Inspection (CSI) at HP Hood Lafargeville DBA Crowley Foods LLC. The objective of the CSI was to gather information necessary to determine compliance with the requirements and limitations of the NPDES Permit NY0002607. The permit became effective on May 1, 1991, and expired on May 1, 1996. The permit has been administratively extended and is still effective until October 31, 2026. There are currently plans to initiate a permit modification in Spring 2024 due to the age of the permit, changes to the wastewater treatment process, and the closure of outfall 001B. 2.0 KEY PARTICIPANTS Listed below are key inspection participants and contact information, grouped by organization. U.S. Environmental Protection Agency Molly Hillenbrand, Lead Inspector Hillenbrand.molly@epa.gov, (732) 321-4452 Thuan Tran, Physical Scientist HP Hood LLC Leonhard Wiegandt, Plant Manager Leonhard.wiegandt@hphood.com, (315) 530-8744 Brent Levey, Environmental Health Safety Manager Brent.Levely@hphood.com, (315) 658-5364 Bill William Huston, Wastewater Treatment Plant Lead New York Department of Environmental Conservation Paula Jacobs, Environmental Program Specialist Paula.jacobs@dec.ny.gov, (315) 785-2513 Page 2 of 9 HP Hood Lafargeville Plant NPDES # NY0002607 3.0 FACILITY DESCRIPTION 3.1 General Information Inspection Date: April 2-3, 2024 Crowley Foods LLC Lafargeville Plant, now a subsidiary of HP Hood LLC, is located on 20700 Street Route 411, Lafargeville, New York (NY) 13656. Crowley Foods LLC Lafargeville Plant was built in the 1920's and currently operates as a cultured dairy plant. The facility produces approximately 90 million pounds of cottage cheese, sour cream, dip, and yogurt annually. The plant employs 127 people, receives milk 7 days per week, and runs packaging lines 3 to 5 days per week. The plant is situated on approximately 180 acres, consisting of the manufacturing facility and an on-site wastewater treatment facility with settling ponds. HP Hood Lafargeville Plant is categorized under Standard Industrialized Classification (SIC) codes 2022- Cheese, Natural, Processed, 2026- Fluid Milk, and 2023- Dry, Condensed, Evaporated Products. 3.2 Process Information The HP Hood Lafargeville Plant utilizes well water for its manufacturing and sanitary systems. The sanitary and process wastewater is separately discharged. The sanitary wastewater is discharged to the LaFargeville Publicly Owned Treatment Works (POTW). The process wastewater is directed to the on-site Wastewater treatment Plant (WWTP) and directly discharged to the Chaumont River. The manufacturing process begins with raw milk and cream delivered from primarily NY dairies. The facility receives an average of about 7 to 8 tanker truckloads per day. Upon arrival at the facility, a representative sample of the raw milk is collected and tested for quality assurance by the laboratory. Once the samples are determined to meet quality standards, trucks enter the receiving station. The trucks are connected to an unloading hose and raw milk is directed to holding silos/ tanks. The flow of the manufacturing process is dependent on the product being made (cottage cheese, sour cream, dip, or yogurt). From the storage tanks, the raw milk may be pumped for separation, to separate into different fat contents and pasteurized to kill harmful bacteria. Standardized milk components are stored in the milk component storage tanks or directed to the cheese room. For products entering the Cheese Room, milk is pumped into cheese vats and heated to product specifications. The whey is drained and filtered; the whey permeate is used by farmers for cow feed. The curd is cooled and washed, drained, blended with dressing followed by product packaging. From the milk component storage tanks, milk may proceed to the batching area. Pasteurization and homogenization occur, followed by the inoculation of culture. The sit time for product fermentation is dependent on the product being processed. Page 3 of 9 HP Hood Lafargeville Plant NPDES # NY0002607 Inspection Date: April 2-3, 2024 Attachments used in the transfer of raw milk to the raw milk storage tanks are rinsed and cleaned after each use. Process wastewater is generated from the clean-in-place (CIP) solution that is used for cleaning tanks and lines. Residual product, cleaning solution and washed water are captured by drains throughout the processing plant. Process water generated is captured by the drains of the processing plant; from there wastewater is directed to the on-site wastewater treatment plant (WWTP) located at the rear of the property. The inflow into the WWTP is monitored by a Parshall Flume with an ultrasonic flow sensor. As the waste stream passes through the Parshall Flume, it is directed to a sidehill screen. Wastewater flows by gravity over the sidehill screen removing coarse solids. The wastewater continues to the diffused bubbler Equalization (EQ) tank, and then cycles between the EQ tank and the biotower. In the EQ tank ammonium hydroxide is added for pH adjustment. Following the biotower, the wastewater is pumped to the rectangular primary clarifier for phase separation. The effluent then flows to a holding tank and is pumped to the aeration basin. From the aeration basin the effluent flows through a shear gate into a mix tank in which ferric chloride is added as a polymer. The effluent from the mix tank flows to the circular final clarifier for phase separation. The effluent from the final clarifier flows into a diversion structure in which the effluent can be diverted to a series of three settling ponds via Outfall 01A or flow directly to Outfall 001. Flow through Outfall 01A is directed over a rectangular weir and recorded by an ultrasonic sensor. From the settling ponds the treated effluent is directed to Outfall 001 and into the Chaumont River. Coarse solids from the side hill screen are collected in a dumpster and hauled to a landfill, along with grit settled in the EQ tank, which is manually removed. From the primary clarifier, floating scum collected by the skimmer and sludge are pumped to the Primary digestor. Sludge from the final clarifier can be pumped to the Primary digestor as Waste Activated Sludge (WAS) or returned to the aeration basin as Returned Activated Sludge (RAS). Liquid sludge from the primary digestor is transported to the Gerry Thomaspn farm, field #6 in Lafargeville, NY for land application. 3.3 Facility Self-Monitoring Information Permit compliance sampling is preformed and collected by HP hood LLC employees. On-site samples are collected and analyzed for settleable solids, pH, and temperature; dissolved oxygen is analyzed June 1st to October 31st. In coordination with Life Science Laboratories Inc., facility staff collect composite samples for 5-day Biochemical Oxygen Demand (BOD5), Total Suspended Solids (TSS), phosphorous, and from June 1st to October 31st ammonia (NH3). Samples are transferred into laboratory bottles supplied by Life Science Laboratories Inc., and a courier from Life Science Laboratories Inc. transports the samples to the laboratory for analysis. Page 4 of 9 HP Hood Lafargeville Plant NPDES # NY0002607 4.0 EPA SAMPLING/INSPECTION ACTIVITIES Inspection Date: April 2-3, 2024 4.1 Sampling Activities An ISCO automatic composite sampler was programmed to take 96 sample aliquots during the 24-hour sampling event at Outfall 001. A 24-hour composite sample was collected and analyzed for BOD5, TSS, and total phosphrous. In addition, on-site grab samples were collected and analyzed for pH, temperature and settleable solids. All sample containers, preservation techniques and holding times were in accordance with US EPA requirements specified in 40 CFR Part 136. Signed and dated custody seal tape was placed across the lids and along the sides of the sample containers. The custody sealed sample containers were then placed inside plastic sample bags and sealed. All samples were transported on ice to the USEPA Laboratory in Edison, New Jersey for analyses. Flow data was obtained directly from the HP Hood Lafargeville Plant's instrumentation, which was last calibrated on November 6, 2023. Split samples were collected and given to the facility representative. 4.2 Inspection Activities A NPDES compliance sampling inspection was conducted on April 2-3, 2024. The inspectors met with Leonhard Wiegandt, Plant Manager; Brent Levey, Environmental Health Safety (EHS) Manager; Bill William Huston, Wastewater Treatment Plant Lead; and Paula Jacobs, New York State Department of Environmental Conservation (NYDEC), Environmental Program Specialist. Inspector's credentials were presented, and the facility representatives were informed that the purpose of the inspection with supporting on-site activities was to determine if the facility is in compliance with their NPDES permit NY0002607. On-site supporting activities consisted of collecting samples at the monitoring location, observing and evaluating the monitoring location, observing and evaluating the flow monitoring equipment, observing and evaluating the facility sampling equipment, reviewing and evaluating the facility's laboratory data and test procedures, touring the manufacturing operation to observe where process wastewater is generated, touring the On-site Wastewater Treatment System, and interviewing the facility's representatives. During the closing conference, the facility representatives were briefed on the inspection activities. On-site sample results and concerns observed during the inspection were communicated to the facility representatives. Page 5 of 9 HP Hood Lafargeville Plant NPDES # NY0002607 4.3 Deviations and/or Environmental Conditions Inspection Date: April 2-3, 2024 Cooling water is a closed loop system and is no longer discharged via Outfall 01B. Due to the age of the permit, and to changes to the wastewater treatment process and the closure of outfall 001B, there are currently plans to initiate a permit modification in Spring, 2024. 5.0 ANALYTICAL RESULTS Parameter Units NPDES Permit Limitations Flow MGD Monitor TSS lb/day 104 Daily Avg. 120 Dail Max BOD5 lb/day 84 Daily Avg. 96 Daily Max Phosphorous, lb/day 8.34 Daily Avg. Total as P *** Monitor Daily Max pH SU 6.0-9.0 Temperature C 32.2 Settleable solids ml/l 0.3 U- The analyte was not detected at or above the Reporting Limit. EPA Results 0.482779 MGD U 47.54 12.41 7.46 13 Trace 6.0 FINDINGS 6.1 Sampling Result Findings The EPA analytical results obtained during this inspection show the following parameter(s) as being outside of the acceptable limits: According to the NPDES Permit, the daily average limitation for total phosphorous is 8.34 lb/day. The analytical result for phosphorous was calculated to be 12.41 lb/day. 0.482779 3.08 8.345 12.41 = 6.2 Inspection Findings In addition to the sampling, an inspection of the facility operations was conducted as discussed in Section 4.2 above. During this inspection the following observations were noted which may contravene the requirements of the permit or the applicable regulations: 6.2.1 Effluent composite sampling silastic tubing was observed to have a buildup of algae. During the purging process, the algae built up in the silastic tubing can become dislodged, potentially biasing the sample result. According to 40 CFR 122.41(e): Proper Operation and Maintenance, "The permittee shall at all times properly operate and maintain all facilities and Page 6 of 9 HP Hood Lafargeville Plant NPDES # NY0002607 Inspection Date: April 2-3, 2024 systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also include adequate laboratory controls and appropriate quality assurance procedures.". 6.2.2 The effluent composite sampling probe was resting at the side of the channel at the bottom of the stream. At any point in the sampling process, sediment could potentially become part of the sample, biasing the sample result. In addition, the sample should be collected where the wastewater is well mixed; the sampling probe should be positioned in the center of the flow channel at mid-depth. According to 40 CFR 122.41 (j)(1) "Samples and measurements taken for the purpose of monitoring shall be representative of the monitored activity." Furthermore, as stated in Title 6 of the Official Compilation of Codes, Rules and Regulations of the State of New York (NYCRR) Part 750-2.5 (a)(2)(i), "A representative sample is one that adequately reflects the actual condition of the wastewater. The most representative sample will be drawn from a point that represents the wastewater discharged. When appropriate, that point should be at a depth where the flow is turbulent and well-mixed and the likelihood of solids settling is minimal." 6.2.3 The approaching upstream channel does not have a smooth transition to the parshall flume. Turbulence in the upstream channel, can potentially bias the flow readings. The upstream channel should be straight, horizontal, and of a uniform cross-section for a distance that is at least ten times the flume throat width. According to the ISCO Open Channel Flow Measurement Handbook, Fifth Edition, Page 73 of Chapter 4: Flumes, "The approaching flow should enter the converging section reasonably well distributed across the entrance width, and the flowlines should be essentially parallel to the flume centerline. Surges and waves of any appreciable size should be eliminated. Also, the flow at the flume entrance should be free of "white" water and free from turbulence in the form of visible surface boils." In addition, as stated in 40 CFR Part 122.41 (e) Proper Operation and Maintenance under Subpart C - Permit Condition, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permitted to achieve compliance with the conditions of this permit..." 6.2.4 Foam was observed flowing through the Parshall flume continuing to the Outfall 001 discharge. Foaming through the parshall flume can potentially bias the flow readings. As stated in 40 CFR Part 122.41 (e) Proper Operation and Maintenance under Subpart C - Permit Condition, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permitted to achieve compliance with the conditions of this permit..." In addition, according to Title 6 of the Official Compilation of Codes, Rules and Regulations of the State of New York (NYCRR) Part 750 -2.8(a)(4), "The permittee shall not discharge floating solids or visible foam." 6.2.5 Pin floc were observed in the final clarifier. According to 40 CFR 122.41(e): Proper Operation and Maintenance, "The permittee shall at all times properly operate and maintain Page 7 of 9 HP Hood Lafargeville Plant NPDES # NY0002607 Inspection Date: April 2-3, 2024 all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of the permit." 6.2.6 The pH buffers used for the calibration of the pH meter were transferred to a secondary container for storage; the secondary containers were observed to not be labeled with expiration dates. According to 40 CFR 122.41(e): Proper Operation and Maintenance under Subpart C - Permit Condition, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures." 6.2.7 It was observed that the working thermometer does not have a correction factor. A correction factor tag/sticker with the necessary information should accompany the meter to ensure accurate temperature readings are recorded. According to 40 CFR Part 122.41 (e) Proper Operation and Maintenance under Subpart C - Permit Condition, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permitted to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures." In addition, 40 CFR Part 136.7 Quality Assurance and Quality Control states, "The permittee/laboratory shall use suitable QA/QC procedures when conducting compliance analyses with any Part 136 chemical method or any alternative method specified by the permitting authority." 6.2.8 When running the Settleable Solids (SS) test, the facility fills the Imhoff cone to the 1-liter mark. The sample is allowed to settle for 1 hour before gently stirring. The sample is then allowed to settle for an additional 1 hour before the SS volume is recorded. Section 3 (Procedure for Settleable Solids (SM-2540 F)) of Standard Methods for the Determination of Water and Wastewater, 23rd edition (2018), states, "Fill an Imhoff cone or graduated cylinder to the 1-L mark with a well-mixed sample. Settle for 45 min, then gently agitate sample near the cone sides with a rod or by spinning. Allow sample to settle for another 15 min, and record volume of settleable solids in the cone as mL/L." 6.2.9 The Discharge monitoring report (DMR) data review for April 2023 noted the holding time for the analysis of Total Suspended Solids (TSS) exceeded the holding time limit. According to the DMR, the TSS sample collected on April 13, 2023, was analyzed by Life Science Laboratories Inc. on April 24, 2023. According to 40 CFR Part 136 Table II - Required Containers, Preservation Techniques, and Holding Times, the maximum holding time for TSS is 7 days. Page 8 of 9 HP Hood Lafargeville Plant NPDES # NY0002607 7.0 Attachments Inspection Date: April 2-3, 2024 7.1 USEPA Chain of Custody for Samples was submitted to the USEPA Region 2 Laboratory in Edison, NJ on April 3, 2024 7.2 The USEPA Analytical Data Package was received on April 16, 2024 7.3 HP Hood Lafargeville Plant diagram of the on-site wastewater treatment process 8.0 Photographs 8.1 At outfall 001 the facilities silastic sampling tubing (right) was observed to be dirty and/or contained algal growth. In addition, the sampling probe was resting at the side of the channel at the bottom of the stream. 8.2 The approaching upstream channel does not have a smooth transition to the parshall flume. In addition, foam was observed passing through the Parshall flume. 8.3 Foam was observed to be discharged from Outfall 001. 8.4 The pH buffer solutions used for compliance sampling were stored in containers with no expiration date indicated. Page 9 of 9 ATTACHMENTS Attachment 1: USEPA Chain of Custody for Samples was submitted to the USEPA Region 2 Laboratory in Edison, NJ on April 3, 2024 Attachment 2: The USEPA Analytical Data Package was received on April 16, 2024 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory 2890 Woodbridge Avenue Edison , New Jersey 08837 732-906-6886 Phone 732-906-6165 Fax April 16, 2024 Molly Hillenbrand Monitoring & Assessment Branch LSASD/MAB Edison, NJ 08837 RE: HP Hood Lafargeville - 2404018 Enclosed are the results of analyses for samples received by the laboratory on 04/04/2024. The signature below reflects the laboratory's approval of the reported results. If you have any questions concerning this report, please refer to Project Number 2404018 and contact the laboratory. Sincerely, John R. Bourbon Chief, LSASD/LB Project Narrative: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory Final Report Project: HP Hood Lafargeville - 2404018 Project Number: 2404018 The National Environmental Laboratory Accreditation Conference Institute (TNI) is a voluntary environmental laboratory accreditation association of State and Federal agencies. TNI established and promoted a National Environmental Laboratory Accreditation Program (NELAP) that provides a uniform set of standards for the generation of environmental data that are of known and defensible quality. The EPA Region 2 Laboratory is NELAP accredited. The Laboratory tests that are accredited have met all the requirements established under the TNI Standards. Condition Comments None Comment(s): The "Sample Analysis Date and Time" is included in the results section for any analyte with a prescribed holding time of 72 hours or less. Data Qualifier(s): U- The analyte was not detected at or above the Reporting Limit. J- The identification of the analyte is acceptable; the reported value is an estimate. K- The identification of the analyte is acceptable; the reported value may be biased high. L- The identification of the analyte is acceptable; the reported value may be biased low. NJ- There is presumptive evidence that the analyte is present; the analyte is reported as a tentative identification. The reported value is an estimate. U.S.E.P.A Region 2 Laboratory NOTE: The results recorded in this report relate only to the samples as received on the date and at the time noted Reported: 4/16/2024 Page 1 of 6 Reporting Limit(s): UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory Final Report Project: HP Hood Lafargeville - 2404018 Project Number: 2404018 The Laboratory was able to achieve the appropriate limit for each analyte requested. Field ID Outfall 001 SUMMARY REPORT FOR SAMPLES Laboratory ID 2404018-01 Matrix Aqueous Date Sampled 04/03/2024 10:00 Date Received 04/04/2024 10:00 U.S.E.P.A Region 2 Laboratory NOTE: The results recorded in this report relate only to the samples as received on the date and at the time noted Reported: 4/16/2024 Page 2 of 6 Analysis Biochemical Oxygen Demand Phosphorus Residue, Non-Filterable UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory Final Report Project: HP Hood Lafargeville - 2404018 Project Number: 2404018 SUMMARY REPORT FOR METHODS Method SM 5210B SOP C-21 Rev 2.8 EPA 365.1 SOP C-68 Rev 2.8 SM 2540D SOP C-33 Rev 3.8 Certification NELAP NELAP NELAP Matrix Aqueous Aqueous Aqueous U.S.E.P.A Region 2 Laboratory NOTE: The results recorded in this report relate only to the samples as received on the date and at the time noted Reported: 4/16/2024 Page 3 of 6 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory Final Report Project: HP Hood Lafargeville - 2404018 Project Number: 2404018 Analyte Field ID: Outfall 001 Sanitary Biochemical Oxygen Demand Phosphorus Total Suspended Solids Result Qualifier Reporting Limit Units Batch Sample ID: 2404018-01 Date and Time of Analysis* 11.8 2.00 mg/L B404023 04/10/2024 09:51 3.08 0.250 mg/L B404046 --- U 10.0 mg/L B404038 U.S.E.P.A Region 2 Laboratory NOTE: The results recorded in this report relate only to the samples as received on the date and at the time noted Reported: 4/16/2024 Page 4 of 6 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory Final Report Project: HP Hood Lafargeville - 2404018 Project Number: 2404018 Sanitary - Quality Control Analyte Batch B404023 Blank (B404023-BLK1) Biochemical Oxygen Demand LCS (B404023-BS1) Biochemical Oxygen Demand LCS (B404023-BS2) Biochemical Oxygen Demand LCS (B404023-BS3) Biochemical Oxygen Demand Duplicate (B404023-DUP1) Biochemical Oxygen Demand Matrix Spike (B404023-MS1) Biochemical Oxygen Demand Matrix Spike Dup (B404023-MSD1) Biochemical Oxygen Demand Batch B404038 Blank (B404038-BLK1) Residue, Non-Filterable Blank (B404038-BLK2) Residue, Non-Filterable Result Reporting Limit Units Spike Source %REC Level Result %REC Limits RPD RPD Limit --- U 2.00 mg/L 174 mg/L 198.0 88.1 84.6-115.4 169 mg/L 198.0 85.6 84.6-115.4 169 mg/L 198.0 85.3 84.6-115.4 Source: 2404018-01 12.4 2.00 mg/L 11.8 4.55 25 Source: 2404018-01 46.8 2.00 mg/L 31.68 11.8 110 75-125 Source: 2404018-01 35.3 2.00 mg/L 23.76 11.8 99.0 75-125 27.9 200 --- U 10.0 mg/L --- U 10.0 mg/L U.S.E.P.A Region 2 Laboratory NOTE: The results recorded in this report relate only to the samples as received on the date and at the time noted Reported: 4/16/2024 Page 5 of 6 Analyte Batch B404038 LCS (B404038-BS1) Residue, Non-Filterable LCS Dup (B404038-BSD1) Residue, Non-Filterable Duplicate (B404038-DUP1) Residue, Non-Filterable Batch B404046 Blank (B404046-BLK1) Phosphorus Blank (B404046-BLK2) Phosphorus LCS (B404046-BS1) Phosphorus LCS Dup (B404046-BSD1) Phosphorus Matrix Spike (B404046-MS1) Phosphorus UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory Final Report Project: HP Hood Lafargeville - 2404018 Project Number: 2404018 Sanitary - Quality Control Result Reporting Limit Units Spike Source %REC Level Result %REC Limits RPD RPD Limit 36.0 10.0 mg/L 37.10 97.0 85-115 38.0 10.0 mg/L 37.10 102 85-115 5.41 20 Source: 2404016-01 26.0 10.0 mg/L 25.0 3.92 20 --- U 0.0500 mg/L --- U 0.0500 mg/L 8.95 0.250 mg/L 8.450 106 90-110 8.93 0.250 mg/L 8.450 106 90-110 0.2 20 Source: 2404018-01 3.57 0.250 mg/L 1.000 3.08 49 90-110 U.S.E.P.A Region 2 Laboratory NOTE: The results recorded in this report relate only to the samples as received on the date and at the time noted Reported: 4/16/2024 Page 6 of 6 ,W,ZZ>WZZZ Wastewater Monitoring Locations HP Hood LLC. Process Wastewater Cooling Water discharge 001B Wastewater Treatment and Holding 001A Pond 1 Pond 3 001 Chaumont River Pond 2 PHOTOGRAPHS 8.1 At outfall 001 the facilities silastic sampling tubing (right) was observed to be dirty and/or contained algal growth. In addition, the sampling probe was resting at the side of the channel at the bottom of the stream. 8.2 The approaching upstream channel does not have a smooth transition to the parshall flume. In addition, foam was observed passing through the Parshall flume. 8. 3 Foam was observed to be discharged from Outfall 001. 8.4 The pH buffer solutions used for compliance sampling were stored in containers with no expiration date indicated.