Document VjMXYvQ6oyGoO29LgM5rRnJep

NPDES Compliance Inspection Report Entiat National Fish Hatchery NPDES Permit Tracking Number # WAG130002 Inspection Date: July 19, 2023 Prepared by: Vanessa Oquendo U.S. Environmental Protection Agency, Region 10 Enforcement & Compliance Assurance Division Water Enforcement & Field Branch Surface Water Enforcement Section Inspector Signature/Date: VANESSA OQUENDO Date: 2023.09.05 15:29:44 -07'00' Digitally signed by VANESSA OQUENDO Supervisor Signature/Date: Marshalonis, Daniel (Dino) Date: 2023.09.06 09:55:49 -07'00' Digitally signed by Marshalonis, Daniel (Dino) Contents I. Facility Information ............................................................................................................ 3 II. Inspection Information........................................................................................................ 3 III. Permit Information.............................................................................................................. 4 IV. Facility Background............................................................................................................ 4 V. Inspection Chronology........................................................................................................ 5 VI. Opening Conference ........................................................................................................... 5 VII. Site Review ..................................................................................................................... 5 VIII. File Review ..................................................................................................................... 7 IX. Areas of Concern ................................................................................................................ 9 A. Hatchery Monitoring Requirements - Composite Sampling ..........................................9 B. Best Management Practices Plan..........................................................................................9 C. Quality Assurance Plan ..................................................................................................... 10 D. Incomplete Notice of Intent ........................................................................................................10 E. Annual Reports of Operations Required Information....................................................... 10 F. Discharge Monitoring Reports........................... ..............................................10 X. Closing Conference..................................................................................11 ATTACHMENT A - Aerial Image (Google Earth) ATTACHMENT B - Site Map ATTACHMENT C - Photograph Log ATTACHMENT D - Lab Letter [Unless otherwise noted, all details in this inspection report were obtained from conversations with Mr. Craig Chisam and Mr. Austin Hansen or from observations made during the inspection.] I. Facility Information Facility Name: Entiat National Fish Hatchery Facility Address: 6970 Fish Hatchery Drive, Entiat, WA 98822 Facility Operator: U.S. Fish and Wildlife Service Facility Owner: U.S. Fish and Wildlife Service Ketchum, ID 83340 Facility Contact(s): Craig Chisam Hatchery Manager Phone: (509) 784-1131, Fax: (509) 784-2964 Email: craig_chisam@fws.gov Brock Everts Assistant Hatchery Manager Phone: (509) 784-1131, Fax: (509) 784-2964 Email: brock_everts@fws.gov Austin Hansen Fisheries Technician Phone: (509) 784-1131, Fax: (509) 784-2964 Email: austin_hansen@fws.gov Latitude/Longitude: 47.697682N, -120.322871W NPDES Tracking Number: WAG130002 NAICS Code(s): 112511 SIC Code(s): 0921 Facility Size: Approximately 43 acres II. Inspection Information Inspection Date: July 19, 2023 Inspector(s): Vanessa Oquendo EPA Region 10, ECAD / SWES Arrival Time: Departure Time: Weather: 09:01 AM 1:15 PM Sunny; hot Purpose: To evaluate compliance with the requirements of the Clean Water Act and the National Pollutant Discharge Elimination System (NPDES) Federal Aquaculture Facilities and Aquaculture Facilities Located in Indian Country Within the boundaries of the State of Washington. III. Permit Information This facility is permitted under NPDES permit WAG130002. The permit became effective on August 1, 2016. The expiration date of the permit was July 31, 2021 and has been administratively extended. IV. Facility Background The Entiat National Fish Hatchery is a mitigation hatchery established by the Grand Coulee Fish Maintenance Project (1937) to compensate for anadromous fish losses above Grand Coulee Dam. The Facility encompasses approximately 43 acres. See Attachment A, Aerial Photo (Google Earth). It was built in 1940, and its primary activities are the spawning and rearing of Chinook salmon producing approximately 400,000 individual Chinook salmon per year, equating to approximately 25,000 pounds per year. The hatchery consists of a spawning building, incubation building, thirty raceways, adult holding ponds and a fish ladder. Spawning and egg incubation occur indoors and growth from fry and smolts to juvenile release occur outdoors. Between October and the first week of May, eggs are collected, incubated, and juvenile salmon are put in the raceways and released. Influent sources include the Entiat River, a network of six groundwater wells, an infiltration gallery, and a spring. From May to October, the facility uses groundwater exclusively, and for the remainder of the year, influent includes river water that passes through a screen and sand settling basin. The Facility has three outfalls. Outfall 001 is discharge of salmon via the Facility's fish ladder into the Entiat River. Outfall 002 is discharge to the Facility's abatement pond. Outfall 003 is intermittent discharge to the spring channel. The Entiat River is the receiving waterbody for Outfalls 002 and 003. The Facility has three sampling locations, one at each outfall. The Facility installed a sophisticated monitoring and alarm notification system called the Supervisory Control and Data Acquisition (SCADA) system in 2020. The system allows the continuous collection of water use data in real time. Water use data is recorded to provide legal documentation for water rights, for water quality sampling purposes, and for aquaculture purposes. Detailed monthly use reports are generated and stored electronically as well as by hard-copy. The incoming surface water, the six wells, the infiltration gallery, and the spring are all metered. There are also flow meters in adult ponds and raceways. Detailed V. VI. VII. daily recordings from the SCADA system are generated from individual meters to document the monthly total from each water source. The monthly totals from all sources are then combined to calculate the total monthly effluent flow. According to Mr. Chisam, the Facility was previously inspected by EPA in June of 2017 and confirmed by compliance monitoring data in EPA's Enforcement and Compliance History Online (ECHO). Inspection Chronology This was an announced inspection. On Tuesday June 20, 2023, I emailed Mr. Craig Chisam, Hatchery Manager, originally announcing the routine inspection for the morning of Wednesday June 28, 2023. Mr. Chisam responded to my email the next day (June 21st) happy to accommodate a site inspection as soon as possible, but informed me of his preference for the inspection to occur when he had full staff available to participate. I responded to Mr. Chisam understanding his desire to have all staff available to experience the inspection and proposed conducting the inspection the week of July 17, 2023. Mr. Chisam replied with July 18th and July 19th as his preferred dates. On June 22, 2023, I emailed Mr. Chisam officially announcing the inspection for Wednesday July 19, 2023 at 9:00am. Mr. Chisam confirmed the inspection date and time the same day. Upon arriving on-site, I made my way to the Facility's main office from the main parking area where I met Mr. Chisam and Mr. Austin Hansen, Assistant Hatchery Manager. Mr. Chisam informed me Mr. Brock Everts was unavailable to join the inspection, but he would assist with any post-inspection action items. The inspection consisted of an opening conference, a walk-through of the Facility's hatchery operations from influent sources to discharge point, a cursory records review, and ended with a closing conference. I was accompanied by Mr. Chisam and Mr. Hansen throughout the inspection. Opening Conference Opening conference began at 9:01AM. The opening conference was held with Mr. Chisam and Mr. Hansen shortly after my arrival. I held initial introductions and presented my inspector credentials to Mr. Chisam and Mr. Hansen. Then I discussed the purpose and scope of the inspection. During the opening conference Mr. Chisam and Mr. Hansen provided a general background of the Facility operations, current staffing, and general hatchery management responsibilities. Site Review I began the site walkthrough with Mr. Chisam and Mr. Hansen starting at the Facility's main intake source from the Entiat River. See Attachment B for a detailed site map and Attachment C for a photograph log of pictures taken during the site walk-through. While inside the main river intake building, river water intake was taking place to supply water for adult ponds due to insufficient groundwater (Photo 1 and Photo 2). A rack in front of the intake area catches debris (Photo 2), and a valve draws water into vault and runs 1000 feet underground via a 36-inch concrete pipe to the screen chamber building. Sampling is conducted in front of black grate using a bucket. The sample is immediately measured with a multi-meter for pH and then refrigerated. The meter is calibrated monthly before each pH measurement. We walked to the trout pond that was previously used for a kids fishing program (Photo 3). The kids fishing program went away during COVID, and the trout pond is currently used for site irrigation and for landscaping. We then stopped at the screen chamber building where water enters through screens and then into sand settling basin (Photo 4 and Photo 5). The screens allow for safe bypass of incidental fish and are scrubbed twice per day. The groundwater infiltration gallery is also located next to the sand settling basin (Photo 6), which only goes 15-20 feet underground and does not produce sufficient water as an intake source for the Facility. On our way to the aeration chamber, we passed a maintenance building where vehicle and other equipment maintenance is conducted (Photo 7). Some chemicals are stored in the building, and oil/grease is properly disposed of at an O'Reilly's auto parts store in Wenatchee, WA. I did not observe any improper storage of oil or chemicals in the maintenance building. At the aeration chamber, all ground water collects in the chamber (Photo 8). Each cylinder receives water from different intake sources: 6 wells, spring, and infiltration gallery. Intake sampling is conducted in the aeration chamber using a bucket to take three samples at 0.5-hour intervals. I informed Mr. Chisam and Mr. Hansen of the required four or more discrete samples for influent composite samples for net TSS analysis. When the Facility is using both the aeration chamber and the river as intake sources, composite samples incorporating both intake categories are taken. Groundwater from the aeration chamber is pumped underground to the adult ponds in raceways. We walked by some of the raceways (Photo 9). Approximately 75,000 fish can fit in each raceway. There have been fish in the raceways since the first week of May. A staggered approach is used to move fish to different raceway pods as fish grow and require more space over time. Groundwater is reused to help spread fish into all 30 raceways. A vet visits the Facility once a month to conduct routine fish health checks. None of the raceways are drained until fish release occurs in mid-April. Raceway fish are pumped directly into the Entiat River using a hose. Raceways are cleaned using a vacuum brush (Photo 10), and any vacuumed flows are pumped to the pollution abatement pond, also called the offline settling basin. Algae build-up is pressure washed using only water and then gravity flows to the pollution abatement pond/offline settling basin. We then walked to the spawning building where I observed the adult pond with the brood stock that will remain until spawning in October (Photo 11). The right side of this pond was a trap side that uses river water to run the fish ladder. The left side was a brood stock with reused groundwater. Fish from the fish ladder go into the trap side to be sorted and then moved to the brood side by opening a channel. Any fish not meeting Facility quality standards are given to the native tribe for sustenance. We followed the fish ladder to where it meets the Entiat River at Outfall 001, where discharge was occurring at the time of inspection from spillover of raceway water (Photo 12, Photo 13, Photo 14, and Photo 15). Evidence of fish released from the raceways via a hose into the river can be seen looking at Photo 16 in which the Facility cut a hole in the fence to fit the hose through. Effluent sampling is conducted by standing on top of the screen area and dropping a bucket tied to a rope. We walked to Outfall 002 at the abatement pond which was not running at the time of inspection (Photo 17). Effluent sampling is conducted using a bucket tied to a rope collecting effluent after the weir, and flow is measured by hand using a ruler to ascertain the height of water flow over the weir (Photo 18). We then walked to observe Outfall 003 from a bridge. This outfall only visibly discharges when it is pumped but does trickle when not pumped and is still monitored. At the time of inspection, it was challenging to see an actual discharge through the vegetation, however I observed a small trickle over the board (Photo 19). I did not observe an obvious conveyance to the Entiat River, however Facility representatives explained to me that there was little flow from the outfall making it difficult to track the discharge to the river. Effluent sampling point using a bucket is conducted by the weir board, and the same flow measurement by hand as for Outfall 002 is done at Outfall 003. The Facility contracted with Cascade Analytical, Inc located in Wenatchee, WA for all influent and effluent sampling analyses, and the Facility used to deliver samples there directly. In 2022, Eurofins bought out Cascade Analytical and now all of the Facility's samples are shipped to Tacoma, WA. Each month, samples are collected in bottles and transferred to a cooler and then taken to FedEx shipping services in Wenatchee, WA to ship to the Eurofins lab in Tacoma, WA. Some of the monthly samples also serve as quarterly samples for quarterly monitoring requirements. Mr. Chisam then showed me the flow meters scattered throughout facility. Examples of influent flow meters I observed for some of the underground wells were Sierra brand meters (Photo 20 and Photo 21) and are calibrated as required by the manufacturer. Flow meters are also replaced as needed when maintenance is performed on the wells. The site walkthrough ended at the incubation building where I observed empty green tanks and empty stacks (Photo 22 and Photo 23). Eggs from the spawning area are transported in Ziploc bags into incubation stacks. Iodine is applied during incubation to harden eggs. We then proceeded back to the main building's office where I asked about the Facility's disposal methods. Adult and brood fish mortalities are taken to a landfill via a trailer, and other solid waste is placed in the dumpsters outside. I then completed a cursory records review and held the closing conference. Examples of records I preliminarily reviewed were the Facility's Best Management Practices Plan (Photo 25), Quality Assurance Plan (Photo 24), training documentation (Photo 26) and sampling documents VIII. (Photo 27 and Photo 28). I requested documents to be sent to me electronically postinspection for further review. File Review The following documents were reviewed post-inspection (all documents received electronically on August 4, 2023 - sent by Mr. Everts): Best Management Practices Plan (BMP Plan) - The Facility had a current BMP Plan onsite that was certified on January 9, 2023 (Photo 25). According to EPA's ECHO and EPA's Integrated Compliance Information System (ICIS), the Facility has submitted timely annual review certification statements. Upon deeper review of the BMP Plan, I observed the following deficiencies: o Additional detail is needed to describe fish grading, harvesting, egg taking, and other activities within ponds or raceways and how the discharge of accumulated solids and blood wastes are minimized as described in Part IV.G.5.e.3 of the permit. o Additional detail is needed to describe if any non-chlorinated disinfectants are used in rearing and holding unit water or in hauling trucks as described in Part IV.G.5.e.5. Quality Assurance Plan (QAP) - The Facility had a current QAP onsite that was certified on January 9, 2023 (Photo 24). The Facility submitted a timely QAP within 90 days of receiving authorization to discharge under the permit. Upon deeper review, the QAP's sampling analyses procedures needs to be updated to reflect that samples are now being shipped to a new lab, Eurofins, in Tacoma, WA. Notice of Intent - The Facility's most recent NOI was reviewed. It was certified by a former assistant hatchery manager, Travis Collier on 12/22/2020. NOI information generally aligned with hatchery operations observed during the inspection and during post-inspection records review with the exception that it did not list Virkon aquatic disinfectant as a disinfectant but was reported as a chemical used in the Facility's 2020, 2021, and 2022 annual reports. Annual Reports -Years reviewed included 2020, 2021, and 2022. All reports were timely submitted to EPA. Upon deeper review, the Facility did not provide dates (or date ranges) or maximum concentrations for the iodine and Virkon reported in Section VIII Chemical Usage of the annual reports of operations. Monthly monitoring results - Discharge Monitoring Reports (DMRs): I reviewed the following random sample of DMRs in 2021, 2022, and 2023 covering all three outfalls and compared submitted DMR data for monitored parameters with laboratory sample analysis reports and with internal Facility log sheets: o Outfall 001 November of 2022 April of 2023 o Outfall 002 June of 2021 January of 2022 Quarter 2 (April, May, June) of 2023 o Outfall 003 February of 2021 July of 2021 o All DMRs were timely submitted and there were no effluent limit exceedances. This observation also was confirmed by EPA's ICIS and ECHO. o I had the following observations from the random sample DMR review: The DMR for quarterly surface water monitoring period ending on 6/30/2021 for Outfall 002 did not have a sample value for Nitrogen, ammonia total [as N] reported due to the laboratory (Eurofins-Cascade Analytical) failing to complete the analysis because of laboratory backlog from personnel and equipment issues (See Attachment D - Lab Letter) The November 2022 DMR for Outfall 001 had "B - Below Detection Limit/No Detection" selected as a No Discharge (NODI) Code value and aligned with "Not Detected" results from the laboratory report for net TSS and net settleable solids. For the purposes of reporting on a DMR for a single sample, if a value is less than the Method Detection Limit (MDL), the Facility must report "less than [numeric value of the MDL]". The DMR for quarterly surface water monitoring period ending on 6/30/2023 for Outfall 002 had a pH range input of 7.74 - 7.77 that could not be corroborated with pH log sheets submitted by the Facility. Laboratory sampling reports including chain of custody forms and internal pH and temperature log sheets: o The pH log sheet did not contain pH recordings that corroborated with the quarterly surface monitoring DMR for Quarter 2 of 2023. Annual production logs o Total annual harvestable fish weight produced and pounds of fish feed reported in the Facility's 2020, 2021, and 2022 annual reports could not be corroborated by production logs the Facility submitted. IX. Areas of Concern Observations during the inspection and post inspection records review identified the following areas of concern: A. Hatchery Monitoring Requirements - Composite Sampling Part IV.B.1 of the General Aquaculture Permit describes hatchery effluent monitoring requirements in which Table 3 outlines that composite samples for both influent and effluent analysis of net TSS "must consist of four or more discrete samples taken at one-half hour intervals or greater over a 24-hour period." The Facility takes three samples at 0.5-hour intervals for influent composite sampling in the aeration chamber instead of four samples. I informed Mr. Chisam and Mr. Hansen of the required four or more discrete samples for influent composite samples for net TSS analysis, and they indicated they will start collecting four samples for the next monthly monitoring event. B. Best Management Practices Plan Part IV.G.5 of the General Aquaculture Permit describes the content requirements of the BMP Plan such as operational requirements. Upon deeper review of the Facility's BMP Plan post-inspection, I observed these deficiencies: o Additional detail is needed to describe fish grading, harvesting, egg taking, and other activities within ponds or raceways and how the discharge of accumulated solids and blood wastes are minimized as described in Part IV.G.5.e.3 of the permit. o Additional detail is needed to describe if any non-chlorinated disinfectants are used in rearing and holding unit water or in hauling trucks as described in Part IV.G.5.e.5. C. Quality Assurance Plan Parts IV.F.d.1 and IV.F.d.5 of the General Aquaculture Permit describes QAP content requirements such as sampling procedures including sample shipping methods and the "name, address and telephone number of the laboratory used by or proposed to be used by the Permittee." Upon deeper review of the Facility's QAP post-inspection, sampling analyses procedures needs to be updated to reflect that samples are now being shipped to a new lab, Eurofins, in Tacoma, WA. D. Incomplete Notice of Intent Part III.A of the General Aquaculture Permit describes the requirement for a timely and complete NOI to be submitted to EPA Region 10. Upon deeper review of the Facility's NOI post-inspection, the Facility did not list Virkon aquatic disinfectant as a disinfectant or chemical used in the "Chemical Usage" section of the NOI, but it was reported as a chemical used in the Facility's 2020, 2021, and 2022 annual reports of operations. E. Annual Reports of Operations Required Information Part V.G.5 of the General Aquaculture Permit describes that annual report of operations "must include the information specified in Appendix E". Appendix E is the actual annual report of operations form that contains a section to summarize a facility's aquaculture drug and chemical usage. Upon deeper review of the Facility's annual reports post-inspection, the Facility did not provide specific dates (or at least date ranges) or maximum concentrations for the iodine and Virkon reported in the chemical and drug usage section of its 2020, 2021, and 2022 annual reports. F. Discharge Monitoring Reports Part IV.C.a of the General Aquaculture Permit indicates that "all permittees that have off-line settling basins that discharge directly to surface waters must conduct surface water monitoring quarterly for ammonia, pH, and temperature..."; Table 7 of this part illustrates ammonia as nitrogen. Additionally, Part VI.C of the General Aquaculture Permit describes the requirements of reporting monitoring results. Permittees "must summarize monthly monitoring results on the DMR." The DMR for quarterly surface water monitoring period ending on 6/30/2021 for Outfall 002 did not have a sample value for Nitrogen, ammonia total [as N] reported due to the laboratory (Eurofins-Cascade Analytical) failing to complete the analysis because of laboratory backlog from personnel and equipment issues (See Attachment D - Lab Letter). The November 2022 DMR for Outfall 001 had "B - Below Detection Limit/No Detection" selected as a No Discharge (NODI) Code value and aligned with "Not Detected" results from the laboratory report for net TSS and net settleable solids. For the purposes of reporting on a DMR for a single sample, if a value is less than the Method Detection Limit (MDL), the Facility must report "less than [numeric value of the MDL]". The DMR for quarterly surface water monitoring period ending on 6/30/2023 for Outfall 002 had a pH range input of 7.74 - 7.77 that could not be corroborated with pH log sheets submitted by the Facility. X. Closing Conference Following the walk-through and cursory file review, a closing conference was held with Mr. Chisam and Mr. Hansen where I shared my observations, areas of concern, and next steps regarding post inspection file review and inspection report transmittal. I thanked them for their time and cooperation. Closing conference concluded at 1:15PM. ATTACHMENT A Aerial Image (Google Earth) ATTACHMENT B Site Map Entiat NFH Important Features ATTACHMENT C Photograph Log All photographs taken by Vanessa Oquendo on July 19, 2023 Olympus Tough TG-6/F2.0 Camera Photo Log- Entiat National Fish Hatchery Photo #:01 (P7190160) Description: Facing north, photo of the Entiat River at the intake area. Photo #:02 (P7190164) Description: Facing north, photo of river intake going through grates and screens. Photo #:03 (P7190167) Description: Facing southeast, photo of the Facility's trout pond used for irrigation and landscaping. Photo #:04 (P7190171) Description: Photo of intake water going through screens in the Facility's screen chamber building. Photo Log- Entiat National Fish Hatchery Photo #:05 (P7190174) Description: Facing north, photo of the river intake sand settling basin after going through the screen chamber building. Photo #:06 (P7190175) Description: Facing east, photo of the Facility's infiltration gallery. Photo #:07 (P7190177) Description: Facing west, photo of the Facility's maintenance building where vehicle and equipment maintenance is conducted. Photo #:08 (P7190179) Description: Photo of inside the Facility's aeration chamber where different intake sources meet and where influent sampling occurs. Photo Log- Entiat National Fish Hatchery Photo #:09 (P7190183) Description: Facing west, photo of some of the adult pond raceways. Photo #:10 (P7190184) Description: Facing west, photo of the vacuum brush used to clean raceways. Vacuumed flow is then pumped to the offline settling basin. Photo #:11 (P7190195) Description: Facing southeast, photo of the adult and brood holding and trap ponds next to the spawning building. The right side is the river water trap side whereas the left side is the brood side and where fish are held. Photo #:12 (P7190199) Description: Facing northwest, photo of the Facility's fish ladder that brings fish into the river trap side of the adult holding pond for spawning. Photo Log- Entiat National Fish Hatchery Photo #:13 (P7190204) Description: Facing southeast, photo of the fish ladder between the Entiat River and spawning building. Photo #:14 (P7190207) Description: Facing southeast, photo of outfall 001 connected to the Facility's fish ladder. Photo #:15 (P7190208) Description: Facing south, another photo of the Facility's outfall 001 with active discharge coming through screens. Photo #:16 (P7190209) Description: Facing southeast, photo of the hole in the fence so that the Facility can fit a hose through for the release of fish into the Entiat River. Photo Log- Entiat National Fish Hatchery Photo #:17 (P7190211) Description: Facing northwest, photo of the Facility's pollution abatement pond/offline settling basin at Outfall 002. Photo #:18 (P7190214) Description: Facing southeast, photo of where sampling and flow measurement occurs at outfall 002. Photo #:19 (P7190216) Description: Facing northwest, photo of the Facility's outfall 003 that trickles until the Facility actually pumps to cause a visible discharge. Photo #:20 (P7190219) Description: Photo of Sierra model flow meters for some of the Facility's groundwater wells. Photo Log- Entiat National Fish Hatchery Photo #:21 (P7190223) Description: Another photo of the one of the Facility's groundwater well flow meters. Photo #:22 (P7190228) Description: Photo of empty green tanks inside the Facility's incubation building. Quality uranee Plan .lnaary 2023 PDES Permit umber WAG-13--0002 Entiat atlonal Fl h Hatchery f>'f:>of,ofl l lM<i...,u, ., J n,,.1. v.,.v~~: ' ""-1-,1..... 111 1 In !~j7M=- eJ Photo #:23 (P7190229) Description: Photo of the Facility's egg incubation trays inside the incubation building. Photo #:24 (P7190230) Description: Photo of the Facility's QAP cover sheet certified in January of 2023. ___ --.... ... Photo Log- Entiat National Fish Hatchery ....................... tJlbal .......... tillll..._, ,pnt,;,l'cffnll,...,bcl\l,A(,I \-OOII\ ,t:..:ri;:,~~~ ,pl, 1w:,n,unrtcn,aMcJllthcllltlMNlll1t-1tilh i.i,t,1c,1ocntr'--')_ .......,np.,nl>cpartm,mlOlt~ 11 : : , : : ~ : : : : Ne f., uupk.-1 ffll !he H'11'rl-' ha~c ~ ~ a n d ~0-~)0J3 -Plan Implementation ,_.:..:,4.,::.l,,:::.;___~,, '--. .~ ...;- - ~ rud andfamlllarlzed myself- - - - trained on BMP Plan lmplem-on, _ _ _ _ _ _ _ _ __, Photo #:25 (P7190232) Description: Photo of the Facility's BMP Plan cover sheet certified in January of 2023. Photo #:26 (P7190238) Description: Photo of one of the Facility's training documents certifying training in BMP Plan implementation. Photo #:27 (P7190242) Description: Photo of one of the Facility's sampling chain of custody forms for January 2023 monthly monitoring. Photo #:28 (P7190246) Description: Photo of an example of one of the Facility's laboratory analytical report results for settleable solids. ATTACHMENT D Lab Letter