Document mBXKKNQ1xQGjMMa9XyJ1Jd6jZ

Report Prepared by: Report Approved by: NPDES Pretreatment Compliance Sampling Inspection Report Henkel Corporation - Geneva Site (formerly Zotos International) 300 Forge Avenue, Geneva, NY 14456 Permit #: NYP000301 Inspection Dates: June 8-9, 2021 Digitally signed by THUAN THUAN TRAN TRAN Date: 2021.08.10 08:52:40 ______________-0_4'_00_' _______________ Thuan Tran; Physical Scientist Date: _Friday, July 30, 2021_ PHILIP Digitally signed by PHILIP COCUZZA _C_O_C__U_Z_Z_A______D-_0a4t_'e0:0_2' 0_21_.08_.1_0 0_8:_43_:01________ Phil Cocuzza, Chief Monitoring Operations Section Date: ________________ Henkel Corporation - Geneva Site, 300 Forge Ave. NYP000301 Inspection Dates: June 8-9, 2021 1.0 OBJECTIVE On June 8-9, 2021, at the request of the New York State Department of Environmental Conservation (NYSDEC), the United States Environmental Protection Agency (USEPA) conducted a Pretreatment Compliance Sampling Inspection (CSI) at Henkel Corporation - Geneva Site. The objective of the CSI was to gather information necessary to determine compliance with the requirements and limitations of the City of Geneva Marsh Creek Wastewater Treatment Plant 2021 Industrial Waste Discharge Permit and related Federal Regulations. 2.0 KEY PARTICIPANTS Listed below are key inspection participants and contact information, grouped by organization. U.S. Environmental Protection Agency Thuan Tran; Physical Scientist, Lead Inspector 732-321-4455; email: tran.thuan@epa.gov Robert Morrell; Geologist New York State Department of Environmental Conservation (NYSDEC) Pradeep Jangbari; Environmental Engineer 858-226-5321; email: Pradeep.jangbari@dec.ny.gov Henkel Corporation - Geneva Site Emily Johnson; Engineering Manager - Geneva Beauty Care Site 315-781-9300; email: Emily.johnson@henkel.com Jonathan Alackna; Safety, Health & Environmental Engineer - Geneva Beauty Care Site 315-230-5232; email: Jonathan.alackna@henkel.com Sarah Baker; Plant Manager - Geneva Beauty Care Site Marsh Creek Wastewater Treatment Plant (WWTP) William Czaplak; Chief Plant Operator 315-789-8040; email: wcc@geneva.ny.us Nick DeMaria; Assistant Plant Operator Page 2 of 11 Henkel Corporation - Geneva Site, 300 Forge Ave. NYP000301 Inspection Dates: June 8-9, 2021 3.0 FACILITY DESCRIPTION 3.1 General Information Henkel Corporation - Geneva Site is located at 300 Forge Avenue and began operations in 1929 as Zotos International which was founded by Ralph Evans for the invention of "permanent waves." Conair Corporation purchased Zotos International in 1982, then sold it to Shiseido in 1988. Henkel Corporation purchased the Geneva site in 2019. The Geneva Site is a manufacturer of personal/health care (moisturizers, deodorants, hair colors, conditioners, shampoos) products and is categorized as Standard Industrial Classification (SIC) 2844 - Perfumes, Cosmetics, and Other Toilet Preparations. Henkel Corporation - Geneva Site employs 451 full-time and 112 temporary personnel and operates under three main shifts; 6:30AM to 2:30PM; 2:30PM to 10:30PM; and 10:30PM to 6:30AM. Departmental shifts are staggered around the main shifts to limit contact due to the coronavirus pandemic. 3.2 Process Information Raw materials arrive at the facility's Receiving/Storage/Quality Assurance (QA) Dock via tankers, totes, 55-gallon and 30-gallon drums, buckets, boxes, and bags in liquid and powder forms. A pallet of the material is moved to the QA sampling room where the raw materials are sampled and verified for identification. QA/QC tests to verify acceptance quality consist of IR Spectrometer, oder, active ingredients, pH, viscosity, acid content, HPLC, etc. Once confirmed, the raw material is moved to the storage area of the warehouse where appropriate locations are assigned. Raw materials are gathered from storage to one of the pre-weight booths. Materials are transported via forklift or hand cart to the compounding and mixing areas. Each batch is created based on order specifications. Depending on material storage requirements, certain raw materials are not weighted up until the time of addition to the batch. Once a batch is produced at one of the six (6) decks, a sample is tested for QA. Deck 1 consists of hair color and hair care batching tanks. Deck 2 consists of storage vessels for hair care. Deck 3 consists of hair care and liquid hand soap batching tanks. Deck 4 consists of neutralizer and perm batching tanks. Deck 5 consists of hair color batching tanks. Finally, Deck 6 consists of hair stylers. All 6 decks were in operation during the June 8-9, 2021 Pretreatment Compliance Sampling Inspections. Each deck consists of multiple kettles, each kettle or batch ranges between 100-5,000 gallons. Approximately 10-15 batches are generated per day. Once the batch is approved, the product is transferred into totes, drums, or a storage tank that is connected to the filling line. Bulk products are connected to the filling lines via stainless steel overhead pipes. Through a combination of automated and manual processes, lot codes are assigned, closures are applied, units are package in corrugated cartons and are pelletized. Upon completion of the pallet, the Page 3 of 11 Henkel Corporation - Geneva Site, 300 Forge Ave. NYP000301 Inspection Dates: June 8-9, 2021 inventory is electronically identified, moved to the distribution center. The main distributors of Henkel Corporation - Geneva Site are Beauty Supply Group and Sally Beauty Holdings to retailers, such as Cosmoprof, Ulta Beauty, and Sally Beauty Supply. City water is used for sanitary and manufacturing operation process. Sanitary wastewater is drained into the City of Geneva Sewer Collection System to the Marsh Creek Wastewater Treatment Plant. Before City water can be used in the manufacturing process, it is treated through filtration, followed by Reverse Osmosis (RO). After RO, the treated City water is disinfected with Ultraviolet Rays (UV), then stored in 14,000 gallon holding tanks. The kettle goes through a cleaning process after each batch. The kettle is filled with treated City water, heated to 180C, while mixing for 30 minutes. The hot washed water is drained. Micro-swaps are taken of the washed kettle to determine the sterility of the cleaning process. After the micro-swap, the kettle is rinsed with treated City water and drained. Most of the generated process waste streams from the 6 decks are pumped to the on-site wastewater treatment system. The manufacturing process waste streams from the liquid hand soap batching tanks in Deck 3 and the hair color batching tanks in Deck 5 are segregated and hauled out as non-hazardous waste for incineration. As the process waste streams are pumped to the on-site wastewater treatment system, the process wastewater is conveyed into the influent sump tank where hydrogen peroxide (H2O2) and a defoamer are added to control sulfide and phenols built-up. The influent sump tank operates on a hi-low water level sensor which triggers the pump at the designated water levels. As the process wastewater is pumped from the influent sump tank, it is screened to remove large matters from potentially damaging downstream equipment to the influent equalization (IEQ) tanks. An air blower provides constant mixing and agitation to maintain a homogeneous content in the IEQ tanks where process side-streams are also received. The wastewater in the IEQ tanks is pumped to the Dissolved Air Floatation (DAF) treatment system. Polymer and caustic (NaOH) are injected in-line at the head of the DAF to create an optimum solid removal condition as it enters the DAF. Aeration is provided from the bottom of the DAF system to allow solids in the water column to adhere to the fine air bubbles to lift the solids to the surface. The effluent from the DAF system flows to the DAF sump tank where H2O2 is added. The DAF sump tank operates on a hi-lo water level sensor that pumps pretreated process wastewater through a magnetic flow meter before discharging through a dedicated sewer line to the Marsh Creek WWTP. Solids from the DAF system are collected in the raw sludge storage tank. From the storage tank, the sludge is pumped onto the belt filter press. Anionic and cationic polymers are mixed with the sludge at the head of the belt filter press. The sludge cake is collected, hauled, and disposed of by Casella as an alternative daily cover for local landfill through a Page 4 of 11 Henkel Corporation - Geneva Site, 300 Forge Ave. NYP000301 Inspection Dates: June 8-9, 2021 Beneficial Reuse Determination (BUD). The filtrate from the belt filter press is pumped to the influent sump tank. 3.3 Facility Self-Monitoring Information Safety, Health & Environmental (SHE) Department of Henkel Corporation - Geneva Site conducts sampling at the designated monitoring location to comply with the City of Geneva Marsh Creek WWTP 2021 Industrial Waste Discharge Permit. The facility utilizes a multibottles composite sampler to collect an aliquot sample every hour during the twenty-four (24) hour sampling duration. The bottles are distributed between the preserved and unpreserved sample containers provided by Pace Laboratories in Melville, New York. The parameters are 5-Day Biochemical Oxygen Demand (BOD5), Total Suspended Solids (TSS), Volatile Organic Compounds (VOAs), Hexavalent Chromium (Cr+6), Chemical Oxygen Demand (COD), Total Phosphorus, Sulfide, Total Phenolics, Total Cyanides, Total Organic Carbon (TOC), and Low Level Mercury, and Metals. Grab samples for Oil & Grease (O&G), hydrogen ion (pH), and temperature are collected using the composite sampler assembly. The samples are packed into the cooler and shipped to Pace Laboratories for analysis. Temperature and pH are analyzed by the SHE Department of Henkel Corporation - Geneva Site for process control. When samples arrived at Pace Laboratories, an analyst checked the pH of the preserved samples. The pH results are provided to the Marsh Creek WWTP by Henkel Corporation - Geneva Site to determine compliance with their industrial user permit. 4.0 EPA SAMPLING/INSPECTION ACTIVITIES 4.1 Sampling Activities ISCO automatic composite samplers were programmed to take 96 sample aliquots during the 24-hour sampling event from the pretreated effluent monitoring location at Marsh Creek Wastewater Treatment Plant. The 24-hour composite sample was collected and analyzed for 5-Day Biochemical Oxygen Demand (BOD5), Total Suspended Solids (TSS), Phosphorus, Chemical Oxygen Demand (COD), Total Organic Carbon (TOC), Sulfide, Hexavalent Chromium, Mercury, and Metals (Arsenic, Cadmium, Iron, Chromium, Copper, Lead, Nickel, Selenium, Silver, Zinc, Aluminum and Barium). Grab-Composite samples were collected and analyzed for Cyanide and Total Phenolics. Multiple grab samples were collected or Volatile Organic Analytes (VOAs). The VOA grab samples were composited in the laboratory. Grab sample was collected and analyzed for Oil and Grease (O&G). On-site grab samples of the pretreated discharge to the Marsh Creek WWTP were collected and analyzed for pH, Temperature and Total Residual Chlorine (TRC). All sample containers, preservation techniques and holding times were in accordance with USEPA requirements specified in 40 CFR Part 136. Signed and dated custody seals were placed across the lids and along the sides of the sample containers. The custody sealed sample containers were placed inside plastic sample bags and sealed up. All samples were Page 5 of 11 Henkel Corporation - Geneva Site, 300 Forge Ave. NYP000301 Inspection Dates: June 8-9, 2021 packed inside a lined cooler with wet ice and the chain of custody attached to the underside of the lid. The cooler was wrapped with strapping tape and affixed with custody seal tapes for shipping via UPS for overnight delivery to the USEPA Laboratory in Edison, New Jersey for analysis. Flow data was obtained directly from a dedicated instrumentation at the Marsh Creek Wastewater Treatment Plant for the Henkel Corporation - Geneva Site discharge that was last calibrated on August 3, 2020. Split samples were collected and given to the facility representative. 4.2 Inspection Activities A Pretreatment Compliance Sampling Inspection at Henkel Corporation - Geneva Site was conducted on June 8-9, 2021. The inspectors met with Emily Johnson; Engineering Manager, Johnathan Alackna; Safety Health and Environmental Engineer (SHE), Sarah Baker; Plant Manager, William Czaplak; Marsh Creek WWTP Chief Plant Operator, Nick DeMaria; Marsh Creek WWTP Assistant Plant Operator, and Pradeep Jangbari; NYSDEC Environmental Engineer. Inspector's credentials were shown, and business cards were provided. The facility's representatives were explained that the inspection purpose with supporting on-site activities was to determine if Henkel Corporation - Geneva Site is in compliance with the City of Geneva Marsh Creek Wastewater Treatment Plant 2021 Industrial Waste Discharge Permit and related Federal Regulations. Supporting on-site activities consist of collecting samples from the pretreated process wastewater discharge at the alternate monitoring location, observing and evaluating the monitoring location and the alternate monitoring location, observing and evaluating the flow monitoring equipment, observation and evaluation of the facility's sampling protocol, touring and evaluating the manufacturing operation process, and the on-site Dissolved Air Floatation treatment system, reviewing and evaluating the chain-of-custody, sample containers, sample preservation inside the containers, and analytical data, and interviewing the facility's representatives. The facility's representatives were briefed on the inspection activities throughout the inspection and during the closing conference. On-site sample results and concerns discovered during the inspection were communicated so that the facility's representatives understood their responsibilities to comply with the conditions and limitations set forth in the City of Geneva Marsh Creek Wastewater Treatment Plant 2021 Industrial Waste Discharge Permit and the related Federal Regulations. 4.3 Deviations and/or Environmental Conditions During the observation and evaluation process of the monitoring location, the facility's automatic sampler is attached to a fixed nozzle that is connected to the discharge pipe. No other access points were available before or after the monitoring location to obtain grab Page 6 of 11 Henkel Corporation - Geneva Site, 300 Forge Ave. NYP000301 Inspection Dates: June 8-9, 2021 and/or grab-composite samples for certain parameters that are in the 2021 Industrial Waste Discharge Permit. The alternate monitoring location, a dedicated sewer line connecting from the facility's discharge pipe to Marsh Creek WWTP, was observed and evaluated. A professional judgement was made to collect Henkel Corporation - Geneva Site compliance samples at the alternate monitoring location. No discharge was observed for a short period of time on the morning of the 2nd day of the inspection. Henkel's representatives explained that during shift change, the pretreated discharge is temporary shut-down so that the next crew can perform a maintenance service check and supply check before resuming operation as part of their normal procedure. As a result, the discharge timeframes during the sampling event was between 8:30AM to 3:30PM on June 8th, 6PM on June 8th to 5:45AM on June 9th, and 8:50AM on June 9th to sample completion. In addition, Henkel is required to analyzed low-level mercury using EPA Method 1631. EPA Laboratory will be analyzing low-level mercury using EPA Method 245.1. The low-level mercury result will only be use as data and not for permit compliance. 5.0 ANALYTICAL RESULTS Parameter Arsenic (As) Cadmium (Cd) Hexavalent Chromium Total Chromium (Cr) Copper (Cu) Total Cyanide (CN) Iron (Fe) Lead (Pb) Mercury (Hg) Nickel (Ni) Oil & Grease Phenolic Compounds Total Phosphorus Selenium (Se) Silver (Ag) Sulfides (S) Zinc (Zn) BOD COD TOC TSS BOD (Cr+6) Henkel Corporation - Geneva Site Inspection Dates: June 8-9, 2021 Units Permit Limit mg/L </= 0.10 " </= 0.20 " </= 0.10 " </= 1.00 " </= 1.00 " </= 0.80 " </= 10.0 " </= 0.10 " </= 0.001 " </= 2.00 " </= 100 " </= 5.00 " </= 24.0 " </= 0.05 " </= 0.10 " </= 3.00 " </= 0.60 " </= 2878 " </= 5995 " </= 1439 " </=360 lbs/day </= 1680 Page 7 of 11 EPA U U 0.024 J U 0.013 U 0.47 U U U 90.2 J 6.59 0.191 U U 0.307 0.051 389 967 273 34 146 Result Henkel Corporation - Geneva Site, 300 Forge Ave. NYP000301 Inspection Dates: June 8-9, 2021 Parameter COD TOC TSS Aluminum (Al) Barium (Ba) Bromodichloromethane Dibromochloromethane 1,1,1-Trichloroethane Benzene Ethyl Benzene Dichlorobenzene Bromoform Xylenes Chloroform Methyl Chloride Toluene Temperature pH Flow Ethyl Acetate Isopropyl Acetate N-Amyl Acetate Acetone Methylene Chloride TRC Units lbs/day " " mg/L " " " " " " " " " " " " C SU GPD mg/L " " " " " Permit Limit </= 3500 </= 840 </= 210 Monitor Monitor Monitor Monitor Monitor Monitor Monitor Monitor Monitor Monitor Monitor Monitor Monitor < 40 (104F) > 6.0 to </= 9.5 </= 70,000 Monitor Monitor Monitor Monitor Monitor For Sample Preservation EPA Result 363 102 12.8 1.870 U U U U U U U U U U U U D1: 27 D2: 27 D1: 6.79 D2: 7.11 45,460 (0.045 MGD) No data No data No data 30.4 J U Zero U = analyte was not detected at or above the reporting limit. J = estimated value D1 = Day 1 D2 = Day 2 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: 6.1.1 According to the City of Geneva Marsh Creek WWTP 2021 Industrial User Permit, the limitation for total phenols is less than or equal to 5.00 milligrams per liter (mg/L). The analytical data was determined to be 6.59 mg/L. 6.2 Inspection Findings In addition to the samples, an inspection of the facility operations was conducted as discussed in Section 4.2. During this inspection the following observations were noted which may contravene the requirements of the permit or the applicable regulations: Page 8 of 11 Henkel Corporation - Geneva Site, 300 Forge Ave. NYP000301 Inspection Dates: June 8-9, 2021 6.2.1 The facility's multiple-bottles composite sampler is not refrigerated or chilled during the sampling event. Preservation is necessary to ensure that the composite sample is chilled to </= 6C during the twenty-four (24) hour sampling duration. According to 40 CFR Part 136 footnote 2 of Table II- Required Containers, Preservation Techniques, and Holding Times, it states, " Except when noted in this Table II and the method of the parameter, preserve each grab sample within 15 minutes of collection. For a composite sample collected with automated sample (e.g. using a 24-hr composite; see 40 CFR Part 122.21(g)(7)(i) or 40 CFR Part 403 appendix E), refrigerate the sample </= 6C during collection unless specified otherwise in this Table II or in the method(s)." 6.2.2 Dirty sampling tube and composite sample bottles were observed during the inspection. Algae growth was observed inside the sample bottles, as well. The sampling equipment should be clean and algae-free to ensure representative sample aliquots are collected of the discharged waste stream so that the sample is not contaminated and/or bias the results. Under Section 4.7 Sample Point Locations of the 2021 Industrial Waste Discharge Permit, it states, "The primary sampling location for Henkel shall be the point of discharge from the Dissolved Air Floatation pretreatment system at the Henkel facility. Care must be taken to gather samples that are representative of the flow loadings that are sent to the treatment plant." Furthermore, the 2021 Industrial Waste Discharge Permit references to 40 CFR Part 122 through 40 CFR Part 136. According to 40 CFR Part 122.41(j)(1) Monitoring and Records, it states, "Samples and measurements taken for the purpose of monitoring shall be representative of the monitoring activity." 6.2.3 The discharged wastewater is monitored by a magnetic flow meter to the Marsh Creek Wastewater Treatment Plant. The flow meter is calibrated but does not have a calibration sticker/tag indicating when it was last calibrated or when it is to be calibrated. Under Section 1.1 Monitoring and Recording of the 2021 Industrial Waste Discharge Permit, it states, "......At least once every calendar year, Henkel shall be required to have all wastewater discharge flow meters calibrated by a third-party calibration service provider who is approved by the Director of Public Works or the Chief Operator." This includes the calibration sticker/tag with the necessary information. Furthermore, 40 CFR Part 136 references 40 CFR Part 122. According to the 40 CFR Part 122.41(e) - Proper Operation and Maintenance, it states, " 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 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." 6.2.4 According to the 2021 Industrial Waste Discharge Permit, Total Phenols, Cyanide, and Volatile Organic Compounds are collected as 24-hour composite samples using an automatic composite sampler. This is incorrect. According to 40 CFR Part 403.12(g)(3) - Monitoring Page 9 of 11 Henkel Corporation - Geneva Site, 300 Forge Ave. NYP000301 Inspection Dates: June 8-9, 2021 and analysis to demonstrate continued compliance, it states, ".....Grab samples must be used for pH, cyanide, total phenols, oil and grease, sulfide, and volatile organic compounds. For all other pollutants, 24-hr composite sample must be obtained through flow-proportional composite sampling techniques, unless time-proportional composite sampling or grab sampling is authorized by the Control Authority. When time-proportional sampling is authorized by the Control Authority, the samples must be representative of the Discharge and the decision to allow the alternative sampling must be documented in the Industrial User file for that facility or facilities. Using protocols (including appropriate preservation) specified in 40 CFR Part 136 and appropriate EPA guidance, multiple grab samples collected during a 24-hr period may be composited prior to the analysis as follows: For cyanide, total phenols, and sulfides the samples may be composited in the laboratory or in the field; for volatile organics and oil and grease the samples may be composited in the laboratory. Composite samples for other parameters unaffected by the compositing procedures as documented in approved EPA methodologies may be authorized by the Control Authority, as appropriate." 6.2.5 Henkel Corporation - Geneva Site is submitting pH results that Pace Laboratories checked on the received samples to Marsh Creek WWTP to show compliance with their permit. This is incorrect. According to 40 CFR Part 136 Table II - Required Containers, Preservation Techniques, and Holding Times, hydrogen ion (pH) readings must be "analyzed within 15 minutes" or immediately at the discharged waste stream. 6.2.6 Samples for Oil & Grease cannot be collected using the automatic sampler. According to EPA Method 1664A: N-Hexane Extractable Materials (HEM; Oil and Grease) and Silica Gel Treated N-Hexane Extractable Material (SGTHEM; Non-polar Material) by Extraction and Gravimetry, Section 8.3 for Sample Collection, Preservation & Storage; It states, "The high probability that extractable matter may adhere to sampling equipment and result in measurements that are biased low precludes the collection of composite samples for determination of oil and grease. Therefore, samples must be collected as grab samples. If a composite measurement is required, individual grab samples collected at prescribed time intervals must be analyzed separately and the concentrations averaged. Alternatively, samples can be collected in the field and composited in the laboratory." 7.0 ATTACHMENTS Attachment #1. Henkel Corporation - Geneva Site overview map shows the building breakdown. Attachment #2. The manufacturing operation flow process shows the work areas within the facility. Attachment #3. Process wastewater is generated from various areas of the manufacturing operation. Page 10 of 11 Henkel Corporation - Geneva Site, 300 Forge Ave. NYP000301 Inspection Dates: June 8-9, 2021 Attachment #4. Process wastewater is pretreated by the on-site pretreatment wastewater system before discharging to Marsh Creek WWTP. Attachment #5. The Chain of Custody for Samples was submitted and received by the USEPA Region 2 Laboratory on Thursday, June 10, 2021. Attachment #6. The Analytical Data of the Henkel Corporation - Geneva Site sampling inspection was received on July 7, 2021. 8.0 PHOTOGRAPHS Photo #1: Henkel Corporation - Geneva Site compliance samples for the 2021 Industrial Waste Discharge Permit are collected at the designated discharge monitoring location at the facility. Photo #2: Alternate discharge monitoring location for Henkel Corporation - Geneva Site is located at the Marsh Creek WWTP. Page 11 of 11 Attachment #1. An overview map of Henkel Corporation - Geneva Site shows the building breakdown. 0 !lml.d:,-iti'I) / 1 a .., OLD FORGE AVENUE Building 1 Building 2 Building 3 Building4 Building 5 Building 5A Building 6 Building 6A Building 7 Building 8 Building 9 Building 10 Building 11 Building 12 Building 12A Building 12W PWDR Total 48,802 28,076 63,547 11,834 3,018 2,286 51,187 3,268 38,459 1,791 8,707 55,393 2,194 254,712 21,000 3978 2842 SQ_Fr_ SQ.Fr. SQ_Fr_ SQ.Fr. SQ_Fr_ SQ_FT. SQ_Fr_ SQ_Fr_ SQ_Fr_ SQ_Fr_ SQ_Fr_ SQ_Fr_ SQ_Ff_ SQ.Fr. SQ_Fr_ SQfl. SQ_Fr_ 601,094 SQ_Fr_ 4,534 SQ.m 2,608 SQ.m 5,904 SQ. Ill 1,099 SQ.m 280 SQ.m 212SQ.m 4,755 SQ. m 304 SQ. m 3,573 SQ.m 166 SQ.m 809 SQ.m 5,146 SQ.m 204 SQ.m 23,664 SQ.m 1,95 l SQ. Ill 369 SQ_m 264 SQ_ m 55,843 SQ. Ill Compounding Compounding XP Hair Color - Comp. Hair Color - Prod_ Blow Molding Silk Screening Production Production XP 14,700 SQ_Fr_ 1,800 SQ_Fr_ 772 SQ_Fr_ 4,280 SQ_Fr_ 8,655 SQ.Fr_ 9_800 SQ_Fr_ 50,740 SQ_Fr_ 2,800 SQ_Fr_ 1,365.7 SQ. m 167.2 SQ_ ru 71.7 SQ_ ru 397.6 SQ_ ru 804.1 SQ_ m 910.4 SQ. ru 4,713.9 SQ. m 260.1 SQ. ru OFFICE AREA (SQ FT) WORK STATIONS I I Supply Chain/Training Office 5,570 28 Shipping Office 660 7 I SSIBM Manager Office 163 1 Bldg 1 Receiving Office 144 2 Bldg 7 Receiving Office 164 2 Bldg 12 Receiving Office 292 4 Production Office 554 5 Maintainance Office 163 2 Plant "IYfaintainauce Office 142 4 Quality Control 3,212 11 -- Silk Screening 1,237 2 0 Front Office 5,726 16 Attachment #2. The manufacturing operation process flows within the facility's work areas. BLO W MOLDING SILK SCREENING RAIL RECIEPT OF RESIN HC PRE-WEIGH Henkel GENEVA SITE FLOW DIAGRAM Raw & Component Receiving ALCOHOL BATCHING FLAMMABLE STORAGE ALCOHOL FILLING AEROSOL FILLING Warehousing & Bulk Storage Pre-Kitting Compounding Blow Molding Silk Screening Filling (All Categories) Distribution Center Shipping DISTRIBUTION CENTER AEROSOL FINSIHED GOOD STORAGE BULK CHEMICAL RECEIVING OUTBOUND SHIPPING PALLETIZING BOTTLE STORAGE PERM FILLING SILICONE & LHC FILLING WET GOODS FILLING ALCOHOL COLOR BATCHING PERM, COLOR, HAIR CARE MAKING RAW AND COMPONENT STORAGE HAIR COLOR FILLING TUBE FILLING HAIR CARE STORAGE FHW/LHS FILLING QUALITY RECIEVING PRE-WEIGH INBOUND & OUTBOUND MATERIALS 1 INBOUND MATERIALS Attachment #3. Process wastewater from various operating areas is directed to the on-site treatment system. GENEVA SITE WASTE WATER SOURCES Waste Water Treatment Sources ALCOHOL BATCHING FLAMMABLE STORAGE ALCOHOL FILLING AEROSOL FILLING 3 Avg Discharge: 12.8M gpy (35K gpd) TO POTW 1. Compounding ZTC Pit 2. Boiler Blowdown Pit 3. Aerosol Filling Pit 4. Bldg 11 & 12 Sinks 5. Bldg 11 Tank Room Pit 6. Filling Line 50 Pit 7. Filling Line 2 Pit 8. Blow Molding Pit 9. ST Area Pits 10. HC Filling Washout Pit 11. Compounding Washout Pit 12. Central Weigh Pit/Sink 13. HC Preweigh Pit/Sink Foaming Hand Wash Water A. Compounding Deck 5 B. Filling Line 3A C. RO Water Area Pit BLO W MOLDING SILK SCREENING RAIL RECIEPT OF RESIN HC PRE-WEIGH DISTRIBUTION CENTER AEROSOL FINSIHED GOOD STORAGE FHW Water (reused) Scrap Product (non-haz disposal) Filter Cake (BUD re-use) PALLETIZING 4 BOTTLE STORAGE PERM FILLING SILICONE & LHC FILLING 65 2 1 ALCOHOL COLOR A BATCHING PERM, 8 HAIR WET GOODS FILLING 9 7 B HAIR CARE STORAGE COLOR, HAIR CARE MAKING 11 COLOR FILLING 10 TUBE C FILLING FHW/LHS FILLING QUALITY RAW AND COMPONENT STORAGE RECEIVING 12 PRE-WEIGH 13 1 INBOUND CITY WATER Avg Usage: 26.5M gpy (73K gpd) Attachment #4. Process wastewater is treated by the on-site treatment system utilizing the Dissolved Air Floatation (DAF). Henkel Geneva Waste Water Operation Status 6/8/2021 Commissioned New Influent Investment Transitioning to Commissioning Chemical Feed & Treatment Basket Strainer Attachment #5. Samples were submitted to the USEPA Region 2 Laboratory through the Chain of Custody/Field Data Form. , US EPA REGION 2 LABORATORY Page .:': _ of CHAIN OF CUSTODYI FIELD DATA FORM /) J- pages SURVEY NAME & LOCALITY PROGRAM: SF D Decision Unit Code Y206 I Permit #: _NYP000301 LAB 10/ FIELD 10 RCRA 0210 I Henkel (formerly Zotos International) SITE 10 D RCRA ENF D 0307 NPDES g B304 OPERABLE SDWA D C215 o ~ ~ '*I: ~~ DESCRIPTION & INSTRUCTIONS s:: CHECK IF ESTIMATED CONCENTRATIONS, ~ SPLIT LIMITS, ~ SAMPLE UNIT AM D B224 _ CAA D A305 INCLUDING LOCATION SPECIAL REPORTING' PROJECT LEADER Thuan Tran PROGRAM RESULTS CODE _ TSCA D L306 00 D B253 FIFRA D CRIMINAL ENF D IRes CL I Checked . I Preservative I I +(circle) Collection Time (24hr clock) ////////1//1// Begin I End . Collection Date mm/dd/yy ~:~_t:~_~~~9~_~~~_~':I:~_..e?:~~~~_C?~ ~ _A __~ ?,_~~~_i!~!"_p!~~tl~~__~~t!~?_~_:?~_~ ~~~!!: _<:_~~P:_?!~-'~-:_~_/9_. 0 fa~pJA; _:-I: ~ 7A ~/_~~~[?_~ _ ~ f I \ ----------------------------------------------"---~r 1, 500-ml plastic bottle: TSS 24-Hr Camp. _(l r Dol: ------------------------------------------------------------------------------------------------------ ----t ---~---------6-/-8---9-/-2-1------ ---------------------------------------------"--if --------1--,-2-5--0---m-l--p-la-s-t-ic---b-o--ttle--:--C-O--D--I-TO--C------2-4---H--r--C--a-m--p-. --------~--~-,---0------------------0-1------I:----:--------6-/-8--9-/-2-1----- - ............. _1_ . ~_ 1, 250-ml plastic bottle: Metals* 24-Hr _ .... __ ... __ . Camp. .-o~ 0 __ ...... 02: __ ... ! 6/8_-9_/21 __ . -------------------------------------------------if--------~-~,- ~".1!__-~_------------------~---- i ______ -- -- 1_ - - - ~ - - - - - - - - ~,-?~~~~! p'1_~?!~_~~?_t!~I~~_~:__r_~~0-'_- ---~~:!!: _<:_~~p.. - C? ?~~~! p'1_~?!~_~~?_t!I_-e~:~:_-~~-~~~.-----~~:!!: _<:_~~p.-._--- -- ~ _2 - - - - - - - -: - - - - - - - - ~~~~~[?--~--- -li - - - ~'-8:9'-2_1_- - -- ______________________________________ -- 1_ - - - ~ - - - - - - - - ~,- ~ ?~~~! p'1_~?!~_~~?_t!I_?e~::__~?p'~?_r_-~_~~~:!!: _<:_~~p.. ~-:_/~. _~ ~_1 - - - - - - - - - f - - - - - - __ ~/_~~~[?_~ _ _____________________________________________~~ __~ ~,_~?~~~! p'1_~?!i_~?_t!I_~e~::)_!i~~ ~~~!!: _<:_~~p.. ~ ?)__g 0_ ~ _9 :: __ ~ ., .. ~/_~~~[?_~ _ ~:~_t:~_~~~9~_~~~~_':I:~__-e_~: >.<_~_C?_-_C? ? _of\. __[tiT 1 COMMENTS & SPECIAL REQUIREMENTS: Notes: ~,_?~~~~! _~~~~: _~~~?~:_~~~~?_I~~?~~~ 1, 125-ml plastic bottle: Cyanide lXs _~-_<:_~~p. ~~?:-_~ G-Comp "'irr-~:z-q - ~rI- : Metals*: AI, Ba, As, Cd, Cr, Cu, Fe, Pb, Ni, Se, Ag & Zn : IJ() ~ ~/,.:c -'L~~!~ ~_1_ ~ :_~ ?_~!_8_~ _1~ i ~ 012345678 910 ~ _~_\i;J.~A~/_~~~[?_~ _ 6/8-9/21 I Preservative Added & Checked O=ice 7=FAS 1=H2S04 pH<2 8=ZnAc 2=HN03 pH<2 9=NaOH pH>12 3=HCI pH<2 10=NH4CI 4=Na2S203 5=NaOH pH>9 6=Ascorbic Acid A=aqueous B=aqueous C=soil D=sediment E=sludge atrix: (chlorinated) F=multiphasic G=solvent H=biota I=oil J=other I Survey Complete? Y ti1' N D I Relinquished By: Received By: Iert;;J- :; Lf oL (rJ Iec--T,tJ G //0/2/ revised 10/25/2004 US EPA REGION 2 LABORATORY CHAIN OF CUSTODYI FIELD DATA FORM " /) Page ~ of //-- pages SURVEY NAME & LOCALITY PROGRAM: SF D Decision Unit Code Y206 Henkel (formerly SITE ID RCRAD 0210 RCRAENFD 0307 Zotos International) __ NPDES g B304 OPERABLE SDWA D C215 UNIT AM D B224 _ CAA D A305 PROJECT LEADER Thuan Tran PROGRAM RESULTS CODE _ TSCA D L306 00 D B253 FIFRA D CRIMINAL ENF D ~~~'b~0301 I CHECK IF IDESCRIPTION & INSTRUCTIONS ESTIMATED CONCENTRATIONS, INCLUDING LOCATION, SPECIAL REPORTING I Preservative I I Collection Time (24hr clock) Collection LAB 101 FIELD 10 SPLIT SAIVJPLE LIMITS, TRIP BLANK 3 A '---' :::;:;~:;::~:;::::~::;::::::::::::::::::.::~:~:: :~:~;;g:~~:::: ~~fbi;!::Q:::;,:;~:;;:;,;~::;:;:::::::~:~:~:~:::~:::::: ~:~_t:~_~!_~~_9~~~_~~:~_~_-_~:?I__~~_!~ ~ 3, 40-ml clear glass vials Grab ~I O&O)S~~C7 D :ii~:::1:::::::::::::: ~"_~~~_i!~!"_'!Y_~_~I~~:)~~~:_~_~~ ~_r~~ -:-:_~L_[_~ (circle) 012345678910 ~: /1/1//1/1/1//1 Begin End / (J :JJ ~:~_~ Date mm/dd/yy 6/7/2021 ?!~/_~g?:~_ ----------------- \ elf- ----- ~!~~~ ~".~~-.~I. .~I.~~?~.i~)?:.,!.c?~? ~.r.~~.~.~. . _-:::!'._ or;:! ~ _1~_:_~ ?~:.8_~_1.0 . !/3~A_ ?!~!_~g?~:_ .......................................+....~.. 3,.4():11l1. cle.ar.QI.assv.ials_yO.A'- gr"b.#~ ~~~ [] o.'.23.4567-'.9.'0 '1:; .1: 6/~/20:21. ---z - - - - - - - - r~... .t;jp-J---.~ ~~~~_ ... - .. 'r:.. \ ,..~ /"-: : - __ --'- -/:. ~!~_~~ - -, .....,.., -'- 0::: / - -. - ,,~ - -. -~" -~~-.~I. _~I_~~~?_J~)~.'!:_?_~? .~'-!..~--~":"b;~'_3 -'1~.~_~/' . =:~~-~...~ iW~1?P-.~?!~?_~: ~~.1? Z~~":'?~-_,!J.~!~~I-.QI-~~?-~~?)?:-'!-~----.;!-~-~--.l.:.-~ ..... ~.1.~ .3. .~ ?_~:.8. ~ .1.0 --7 ~ J~~. ?_,,!_~g?:~. g ~ ~ , ,/ -r> -./ ,: \-. 0123456789'lq -, '::.:;l-----------~/--'---~.---./~;!c-:/ii '<-----------.- ... -~\----.- -----------~~~~-------------------tj"-~" ~--~-1-~~~~-~~8~1~ --"------.--- --.---~.~-.=.-.- --------.[j-'---..-;~ --l.-4=-- ...... ----I-C;,-"t t>;-..~ 6/- --1/- ---_J._ -----"'~ -------- -- ''',' ----------- .. --------,," -- ) -, ~. D '0 1 23456789 10 '" -. COMMENTS & SPECIAL REQUIREMENTS: v' Preservative Added & Checked Notes: VOAs Grab #1 thru #fl must be laboratory composite. O=ice 1=H2S04 pH<2 2=HN03 pH<2 7=FAS 8=ZnAc 9=NaOH pH>12 ~~t- ;J, cj /0 n..-i M!' jV ~ GhI2~JJ2-/~z: .2 3=HCI pH<2 4=Na2S203 5=NaOH pH>9 6=Ascorbic Acid 10=NH4CI ate (s): A=aqueous B=aqueous C=soil D=sediment E=sludge atrix: (chlorinated) F=multiphasic G=solvent H=biota I=oil J=other I Survey Complete? Y [q" N D I Relinquished By Received By: 1-, "20 revised 10/25/2004 Attachment #6. Analytical data from the sampling inspection was received on July 7, 2021. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory 2890 Woodbridge Avenue Edison , New Jersey 08837 732-906-6886 Phone 732-906-6165 Fax July 07, 2021 Philip Cocuzza Monitoring & Assessment Branch LSASD/MAB Edison, NJ 08837 RE: Henkel (formerly Zotos Intn'l - 2106018 Enclosed are the results of analyses for samples received by the laboratory on 06/10/2021. 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 2106018 and contact the laboratory. Sincerely, Gregory J. Santacroce Acting Chief, LSASD/LB Project Narrative: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory Final Report Project: Henkel (formerly Zotos Intn'l - 2106018 Project Number: 2106018 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 Hexavalent Chromium - Sample 2106018-01 was received by the laboratory after the holding time had expired. In addition, the sample matrix spike was below acceptance criteria. The sample results are qualified with a J as estimated. VOA analysis - Sample 2106018-08 foamed excessively at analysis. A dilution was done in order to analyze without damaging instrumentation. This resulted in an RL of 250 ug/L. 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: 7/7/2021 Page 1 of 7 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory Final Report Project: Henkel (formerly Zotos Intn'l - 2106018 Project Number: 2106018 Reporting Limit(s): The Laboratory was able to achieve the appropriate limit for each analyte requested. SUMMARY REPORT FOR SAMPLES Field ID Laboratory ID Pretreated Discharge-24-Hr Comp. 2106018-01 Pretreated Discharge-3Xs G-C 2106018-02 TRIP BLANK 2106018-03 Pretreated Discharge - Grab 2106018-04 Pretreated Discharge(Lab Composite-Grab#211,026,30)18-08 Matrix Aqueous Aqueous Aqueous Aqueous Aqueous Date Sampled 06/09/2021 09:47 06/09/2021 09:15 06/07/2021 10:21 06/09/2021 09:30 06/10/2021 00:01 Date Received 06/10/2021 10:20 06/10/2021 10:20 06/10/2021 10:20 06/10/2021 10:20 06/10/2021 10:20 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: 7/7/2021 Page 2 of 7 Analysis 624.1 VOA EPA-NPDES Biochemical Oxygen Demand Chemical Oxygen Demand Chromium, Hexavalent Cyanide, Total Mercury Metals ICP TAL NPDES/DW Oil & Grease Organic Carbon Phenolics, Total Phosphorus Sulfide Residue, Non-Filterable UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory Final Report Project: Henkel (formerly Zotos Intn'l - 2106018 Project Number: 2106018 SUMMARY REPORT FOR METHODS Method EPA 624.1 SOP C-89 Rev 3.6 SM 5210B SOP C-21 Rev 2.7 EPA 410.4 SOP C-53 Rev 2.7 HACH 8023 SOP C-96 Rev 2.7 EPA 335.4 SOP C-28 Rev 2.7 EPA 245.1 SOP C-110 Rev 2.7 EPA 200.7 SOP C-109 Rev 3.6 EPA 1664A SOP C-126 Rev 1.6 SM 5310 B SOP C-83 Rev 2.8 EPA 420.4 SOP C-29 Rev 2.7 EPA 365.1 SOP C-68 Rev 2.7 SM 4500 S2 D SOP C-115 Rev 2.7 SM 2540D SOP C-33 Rev 3.7 Certification NELAP NELAP NELAP NELAP NELAP NELAP NELAP NELAP NELAP NELAP NELAP NELAP NELAP Matrix Aqueous Aqueous Aqueous Aqueous Aqueous Aqueous Aqueous Aqueous Aqueous Aqueous 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: 7/7/2021 Page 3 of 7 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory Final Report Project: Henkel (formerly Zotos Intn'l - 2106018 Project Number: 2106018 Analyte Field ID: Pretreated Discharge-24-Hr Comp. Metals ICP Aluminum Arsenic Barium Cadmium Chromium Copper Iron Lead Nickel Selenium Silver Zinc Mercury CVAA Mercury Sanitary Biochemical Oxygen Demand Chemical Oxygen Demand Chromium, Hexavalent Organic Carbon Phosphorus Sulfide Residue, Non-Filterable Field ID: Pretreated Discharge-3Xs G-C Sanitary Cyanide, Total Phenolics, Total Reporting Result Qualifier Limit Units Date and Time of Analysis* Sample ID: 2106018-01 1870 100 ug/L --- U 8.00 ug/L --- U 100 ug/L --- U 3.00 ug/L --- U 5.00 ug/L 13.4 10.0 ug/L 469 50.0 ug/L --- U 8.00 ug/L --- U 20.0 ug/L --- U 20.0 ug/L --- U 5.00 ug/L 50.8 20.0 ug/L --- U 0.050 ug/L 389 2.00 967 200 23.8 J 10.0 273 10.0 0.191 0.0500 0.307 L 0.0100 34.0 10.0 mg/L mg/L ug/L mg/L mg/L mg/L mg/L 6/10/2021 10:56:00AM 6/10/2021 11:04:00AM Sample ID: 2106018-02 --- U 10.0 ug/L 6590 200 ug/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: 7/7/2021 Page 4 of 7 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory Final Report Project: Henkel (formerly Zotos Intn'l - 2106018 Project Number: 2106018 Analyte Field ID: TRIP BLANK VOA GCMS Chloromethane Vinyl Chloride Bromomethane Chloroethane Trichlorofluoromethane 1,1-Dichloroethene Methylene Chloride Acrylonitrile trans-1,2-Dichloroethene 1,1-Dichloroethane Acetone Chloroform 1,1,1-Trichloroethane Carbon Tetrachloride 1,2-Dichloroethane Benzene Trichloroethene 1,2-Dichloropropane Bromodichloromethane cis-1,3-Dichloropropene Toluene trans-1,3-Dichloropropene 1,1,2-Trichloroethane Tetrachloroethene Dibromochloromethane Chlorobenzene Ethylbenzene Bromoform Reporting Result Qualifier Limit Units Date and Time of Analysis* Sample ID: 2106018-03 --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 10.0 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/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: 7/7/2021 Page 5 of 7 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory Final Report Project: Henkel (formerly Zotos Intn'l - 2106018 Project Number: 2106018 Analyte Field ID: TRIP BLANK VOA GCMS 1,1,2,2-Tetrachloroethane 1,3-Dichlorobenzene 1,4-Dichlorobenzene 1,2-Dichlorobenzene m,p-Xylene o-Xylene Field ID: Pretreated Discharge - Grab GC - Sanitary Oil & Grease Field ID: Pretreated Discharge(Lab Composite-Grab#1,2 VOA GCMS Chloromethane Vinyl Chloride Bromomethane Chloroethane Trichlorofluoromethane 1,1-Dichloroethene Methylene Chloride Acrylonitrile trans-1,2-Dichloroethene 1,1-Dichloroethane Acetone Chloroform 1,1,1-Trichloroethane Carbon Tetrachloride 1,2-Dichloroethane Benzene Reporting Result Qualifier Limit Units Date and Time of Analysis* Sample ID: 2106018-03 --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L --- U 5.00 ug/L Sample ID: 2106018-04 90.2 J 6.20 mg/L Sample ID: 2106018-08 --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L 30400 J 500 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/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: 7/7/2021 Page 6 of 7 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory Final Report Project: Henkel (formerly Zotos Intn'l - 2106018 Project Number: 2106018 Analyte Field ID: Pretreated Discharge(Lab Composite-Grab#1,2 VOA GCMS Trichloroethene 1,2-Dichloropropane Bromodichloromethane cis-1,3-Dichloropropene Toluene trans-1,3-Dichloropropene 1,1,2-Trichloroethane Tetrachloroethene Dibromochloromethane Chlorobenzene Ethylbenzene Bromoform 1,1,2,2-Tetrachloroethane 1,3-Dichlorobenzene 1,4-Dichlorobenzene 1,2-Dichlorobenzene m,p-Xylene o-Xylene Reporting Result Qualifier Limit Units Date and Time of Analysis* Sample ID: 2106018-08 --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/L --- U 250 ug/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: 7/7/2021 Page 7 of 7