Document rB7ynQZ6QbprLJR9gO97R1GEv

WASTEWATER TREATMENT SYSTEM DIAGNOSTIC INSPECTION REPORT Purpose: NPDES Diagnostic Inspection Facility: Gabriel Performance Products 725 State Road Ashtabula, Ohio 44004 NPDES Permit Number: OH-0029149 Date of Inspection: July 13, 2021 U.S. EPA Inspector: Dean Maraldo, EPA Region 5; (312) 353-2098; maraldo.dean@epa.gov U.S. EPA Chemist: Ken Gunter, EPA Region 5; (312) 353-9076; gunter.kenneth@epa.gov Gabriel Performance Products Representatives: Kenna Coltman, Corporate Environmental Manager; (440) 992-3247; Kenna.Coltman@gabrielchem.com Kari Demorest, Laboratory Technician Heather Mays, QA Supervisor Kelly Mitchell, Environmental Health and Safety Manager Jose Rivera, Maintenance Technician Tyce Workman, Site Director Ohio Environmental Protection Agency Inspector: Brianne Workman, (330) 963-1179; Brianne.Workman@epa.ohio.gov Report Prepared by: Dean Maraldo, EPA Region 5 Inspector Maraldo, Digitally signed by Maraldo, Dean EPA Inspector Signature: _D__e_a_n_________D07a_:t0e_1::2_206_2-10_.50'_70.03_'0____________ Approver Name & Title: Ryan Bahr, Chief, Section 2, Water Enforcement and Compliance Assurance Branch Digitally signed by RYAN RYAN BAHR BAHR Date: 2021.07.30 Approver Signature/Date: ______________08_:3_9:_15_-0_5'_00_' ______________ Gabriel Performance Products Diagnostic Inspection Report [This page intentionally left blank] Gabriel Performance Products Diagnostic Inspection Report TABLE OF CONTENTS I. Introduction .................................................................................................................................. 1 II. Background................................................................................................................................... 1 III. Inspection Activity Summary ....................................................................................................... 2 IV. Closing Conference, Areas of Concern, and Other Observations ................................................ 6 V. Documents Received and References........................................................................................... 8 LIST OF ATTACHMENTS Attachment A: Facility maps and diagrams Attachment B: Permit effluent limit exceedances from August 2016 to May 2021 Attachment C: Documents provided by Gabriel Performance Products Attachment D: Photo Log Gabriel Performance Products Diagnostic Inspection Report [This page intentionally left blank] Gabriel Performance Products Diagnostic Inspection Report I. INTRODUCTION On July 13, 2021, I inspected the Gabriel Performance Products facility in Ashtabula, Ohio ("Facility") (see Facility Overview Plan in Attachment A). The main purpose of the inspection was to diagnose potential causes of chronic permit effluent limit exceedances for total suspended solids ("TSS"), total residual chlorine ("TRC"), biochemical oxygen demand ("BOD"), and E. coli. I assessed the Facility's compliance with its National Pollutant Discharge Elimination System ("NPDES") permit and the Clean Water Act, with a focus on monitoring and sampling issues. The inspection consisted of the following major activities: Inspection opening conference; Interview/discussions with representatives from the Facility including a description of facility operations and maintenance ("O&M"), results of Discharge Monitoring Report (DMR) review, potential causes of effluent limit exceedances, and review of selfmonitoring and laboratory activities; Physical inspection of the Facility, including the in-house laboratory; and Closing conference. This report summarizes the results of the inspection. II. BACKGROUND The Facility is authorized to discharge under NPDES permit OH-0029149 ("permit"). Gabriel Performance Products ("GPP") is responsible for the Facility's operation and compliance with NPDES permit requirements. GPP is responsible for conducting monitoring activities and reporting monitoring results to the Ohio Environmental Protection Agency ("Ohio EPA"). According to the NPDES Permit Fact Sheet (Ohio EPA, 2016), Gabriel Performance Products manufactures limited runs of specialty organic chemicals. The Facility's production operations are classified under Standard Industrial Classification ("SIC") Code 2869, "Industrial Organic Chemicals, Not Elsewhere Classified." Process wastewaters from these operations are regulated under the Federal Effluent Limitation Guidelines ("ELGs") for existing point sources listed in Title 40 of the Code of Federal Regulations ("40 CFR"), Part 414 - "Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF)". Subparts H and J apply to this facility based on the materials produced and the type of wastewater treatment employed. Subpart H (40 CFR 414.8083) - "Specialty Organic Chemicals" provides limits for BOD, TSS, and pH. Subpart J (40 CFR 414.100-101) - "Direct Discharge Point Sources That Do Not Use End of Pipe Biological Treatment" lists the applicable organic chemical limits. All process wastewater, cooling water, boiler blowdown, collected storm water and groundwater, and sanitary wastewater at Gabriel Performance Products are commingled prior to treatment and discharge. The discharge from Internal Monitoring Station 601 is comprised of treated sanitary effluent. The sanitary wastewater is pretreated by an extended aeration activated sludge package plant, clarification, slow sand filtration, and chlorination prior to commingling with other wastewater sources. The commingling wastewater is treated by neutralization (secondary and final pH treatment), equalization and settling, multimedia filtration, and carbon adsorption prior to discharge via Outfall 001 (see Permit Fact Sheet water balance diagram in Attachment A). 1 Gabriel Performance Products Diagnostic Inspection Report Prior to 2010, Gabriel Performance Products had a permitted design flow of 0.220 MGD. Approximately 39 percent of this flow, 0.086 MGD, was considered process wastewater. Subsequent to a capacity expansion of its wastewater treatment system, Gabriel Performance Products requested an increase in its permitted flow rate in 2010. The requested increase to 0.320 MGD was designed to facilitate greater flexibility in the operation of the batch treatment system. GPP is subject to a U.S. EPA Administrative Order on Consent ("AOC"), dated June 22, 2021, to address chronic permit effluent limit exceedances at the Facility. The AOC requires GPP to submit, by August 22, 2021, a corrective action plan to address chronic effluent limit exceedances. The Facility reported, via electronic discharge monitoring reports ("DMRs") submitted to Ohio EPA, 77 permit effluent limit exceedances from August 2016 to May 2021 (Attachment B). III. INSPECTION ACTIVITY SUMMARY III. A. Opening Conference I arrived at the Facility, along with U.S. EPA Chemist Ken Gunter on July 13, 2021 at 8:45 a.m.. We met Kelly Mitchell at the security booth and escorted into an office building. After signing the visitor log, we were brought to a conference room and introduced to Heather Myers and Tyce Workman. I presented my U.S. EPA Inspector credentials to Heather Myers and Tyce Workman. Kenna Coltman and Brianne Workman joined us a few minutes later and we started the opening conference with formal introductions at 9:15 a.m.. I started by going over the intended scope of the inspection. I asked if there were any concerns regarding confidential business information ("CBI") and specifically with respect to photographs. I offered to alert the GPP representatives prior to taking any photographs to make sure images did not capture any potential CBI. Kenna Coltman agreed. We then began the Interview portion of the inspection. III. B. Interview I started the interview portion of the inspection by asking for an overview of GPP's activities at this site. Kenna Coltman said the Facility produces specialty chemicals including "GPM", a mercaptan-based epoxy, along with other custom manufactured products. GPP manufactures products in five work areas across the Facility. However, only Area 1, the GPM production area, is currently active. Kenna Coltman added that all process wastewater is shipped off site, except for some plant clean-up wash water. Kelly Mitchell mentioned the names of companies that accept Facility process waste, including Buckeye Brine, Interstate Recovery, and Enviroclean. Kelly Mitchell also described the on-site sanitary sewage treatment system as a package plant (see Sanitary System Detail Figure in Attachment A), including an aerator, clarifier, sand beds, and a chlorine feed system that disinfects effluent prior to discharge via internal monitoring station (outfall 601) to the on-site equalization ponds (2). Currently, one of the ponds needs a new liner and is offline. Kelly Mitchell described the system of groundwater interceptor trenches across the Facility, designed to collect groundwater contaminated with chlorinated solvents and volatile organic compounds. The groundwater is pumped out of the trenches and treated with an air stripper before going to the ponds for equalization/settling, then to pH treatment, filtration, and carbon treatment prior to discharge out of outfall 001. 2 Gabriel Performance Products Diagnostic Inspection Report Next, I asked about Facility staffing related to wastewater management, and operations and maintenance ("O&M"). Kelly Mitchell is working on operator training certification and mentioned that dedicated utility operators do rounds once per shift and complete an effluent log checklist. I requested a copy of the checklist which was provided via email on July 19, 2021 (Attachment C). Kenna Coltman said she has Ohio class 3 operator certification and mentioned that Kelly Mitchell does all of the NPDES sampling, other than the in-house monitoring (e.g., pH and TRC). Maintenance crews are responsible for O&M of the wastewater treatment systems. Kenna Coltman added that a consultant, ATC, does the O&M for the groundwater infiltration trenches and air stripper. At this point in the interview we started a discussion regarding potential sources of effluent limit violations at outfall 601 (sanitary sewer treatment system discharge). Kelly Mitchell said that TSS issues may be due to unknown residue (perhaps deteriorating vault material) and the use of chlorine tablets for disinfection, and explained that the chlorine tablets appear to break apart in the tablet holders (see tablet holder in Photograph GPPI0006.jpg), potentially creating solids in the effluent. In addition, the procedure for collecting samples at outfall 601 changed, now requiring the use of a stainless steel sample jug instead of a plastic jug, and collection of flowing samples as of June 2021. Kenna Coltman added that the recent E.coli exceedance (May 2021) may be attributed to the past practice of sampling stagnant effluent at 601, and hoped the change to collection of flowing effluent would address the issue. We also discussed whether there was sufficient contact time for the effluent moving through the chlorine tablets. Kenna Coltman added that a consultant (Arcadis) was looking into the chlorine contact time issue. We shifted the discussion to potential sources of effluent limit violations at outfall 001. I asked for a list of potential water sources coming into the ponds prior to treatment and eventual discharge from outfall 001. Kenna Coltman listed treated flows from the sanitary system, all stormwater, treated groundwater, boiler/steam condensate, cooling tower blowdown, and ASHCO water (untreated lake water used for cooling water and fire suppression). We started the pollutant-specific discussion with TRC. Heather Myers mentioned that sampling error was first believed to be the source of TRC effluent limit exceedances. Now they are looking into potential sources of instrument interference. Kenna Coltman and Heather Myers then discussed the ongoing interference monitoring study and provided a copy of the detailed monitoring study spreadsheet indicating the sampling frequencies, parameters, and monitoring locations (Attachment C). Heather Myers also mentioned that they have had issues with Hach Pocket Colorimeter method detection limits ("MDLs") and that they are looking into the use of a Hach DR3900 benchtop spectrophotometer to potentially improve MDLs. Heather Myers noted elevated levels of TRC in the ponds the day prior to the inspection and suspected the cause may be related to cleaning crews recently using chlorinated city water for general cleaning. I asked about treatment processes and daily discharge rates for outfall 001. Kenna Coltman said batch discharges occur about 10 times per month and range from 0.25 to 0.3 MGD. Outfall 001 discharges are controlled by pH levels in the two equalization ponds. If pH is greater than 8.5, then further treatment and batch discharge can occur. If pH is below 8.5, pH adjustment (via HCL addition) and recirculation occurs until pH is greater than 8.5. I recommended they 3 Gabriel Performance Products Diagnostic Inspection Report investigate the potential contribution of HCL addition to elevated TRC concentrations. Kenna Coltman continued describing treatment after pH adjustment, including multimedia filtration (2 filters) and carbon treatment (2 carbon beds in series). After carbon treatment, effluent discharges to outfall 001, and sludge is collected for off-site disposal (see Permit Fact Sheet water balance diagram in Attachment A). Kelly Mitchell added that they now monitor TRC at the outfall and can keep effluent in recirculation, rather than discharge, if TRC is elevated. I asked if GPP considered any O&M-related causes of effluent limit exceedances, such as excessive debris coating the inside of composite sampler tubing or timing of carbon bed replacement. Kelly Mitchell described the timing of recent carbon bed replacements and mentioned that the multimedia beds were changed out in August 2020. She also stated that the multimedia beds had the wrong type of media. Kenna Coltman said TSS issues may be a result of insufficient backwashing of carbon beds. I recommended they follow manufacturers recommendations for backwashing to minimize preferential channeling within the carbon beds. I also suggested GPP consider testing TRC concentrations before and after each carbon bed and see if there are any relationships between carbon bed change outs and TRC concentrations over the last couple years. At this point we agreed to end the interview and break for lunch. We agreed to return around 1 p.m. and start the physical inspection of the wastewater treatment systems. III. C. Physical Facility Inspection We returned to the Facility at 12:50 p.m. and began the physical inspection of the Facility at 1:10 p.m.. The physical inspection is summarized below. Photographs referenced below are included in the Photo Log (Attachment D). Sanitary Sewage Treatment System (internal outfall 601): Kenna Coltman and Kelly Mitchell led the group to the sanitary sewage treatment system, located in front of the office building. The sanitary treatment system includes a septic tank, small package plant (aeration and clarifier), sand filter, and a disinfection (chlorination) station (see Sanitary System Detail diagram in Attachment A). Upon our arrival, Kelly Mitchell opened the vault doors to the package plant (see Photographs GPPI0001.jpg and GPPI0002.jpg), and pointed out the aeration chamber and clarifier. The package plant appeared to be in poor condition. Kenna Coltman said the system was installed in the 1960s. I did not observe bubbling in the aeration chamber and it was clear that the system was not working properly. The surface of the clarifier also appeared to be covered by a thick layer of dark sludge. Kenna Coltman remarked that the issue may be due to a stuck aeration valve. A maintenance crew arrived and was able to fix the issue and the aeration system appeared to be working. I was concerned about the thick dark sludge in the clarifier and asked if it was possible to measure sludge depth in the clarifier. Kelly Mitchell grabbed a sample pole and dipped it into the clarifier to the bottom. There appeared to be a few feet of liquid in the clarifier with a thick layer of dark sludge on top. The package plant clarifier is designed to skim floating material. I observed an inlet just above the level of the floating sludge and asked if this was an inlet designed to capture floating sludge. Jose Rivera, one of GPP's maintenance technicians, confirmed that the inlet collected floating sludge, but none of the GPP representatives present knew where the inlet returned any skimmed sludge. 4 Gabriel Performance Products Diagnostic Inspection Report We followed the treatment train to the pump vault (Photograph GPPI0003.jpg) and sand filter (Photograph GPPI0004.jpg). I observed some plant growth on top of the sand bed but since the system was not in operation I could not tell if the flow was distributed across the filter or if plant growth was excessive enough to cause preferential channeling at the surface of the sand bed. Next, we observed the chlorination station where GPP uses chlorine tablets to disinfect the effluent from the sand filter. This is also the location where GPP collects permit compliance samples required for internal monitoring station 601. Kelly Mitchell opened the vault cover and I observed the outlet from the sand filter, the inlet to the pipe conveying disinfected effluent to the equalization ponds, and the two metal chlorine tablet feeders (Photograph GPPI0005.jpg; note the lighting was insufficient to capture the influent outlet and effluent inlet). Based on my observation of flow through the tablet feeders, it seemed unlikely that there was sufficient contact time between effluent and chlorine tablets to fully disinfect the wastewater. Kelly Mitchell stated that she often sees debris, specifically white particles, in the effluent in the chlorine station, adding that the debris could be pieces of the vault walls or pieces of chlorine tablets. I asked to see a sample of the effluent after the chlorine tablets feeders. Kelly Mitchell pulled up a sample of the effluent and I observed small white particles which appeared to be chlorine tablet particles (see Photograph GPPI0006.jpg; showing the vault, and chlorine tablet feeder. The white particles are difficult to see in the photograph). I recommended using a microscope to examine any small particles found in the chlorine tablet feeder and the effluent channel, to help assess the source of the particles. North Rain Sump: With the physical inspection of the sanitary sewage treatment system complete, we walked to the North Rain Sump which, according to Kenna Coltman, collects all stormwater from the north end of the Facility (Photograph GPPI0007.jpg). From here, stormwater is conveyed to the equalization ponds. Outfall 001 Treatment System: We began the inspection of the outfall 001 wastewater treatment system at the Effluent Building (Photograph GPPI0008.jpg). The Effluent Building houses two multimedia filters (Photograph GPPI0009.jpg), two carbon beds (Photograph GPPI0010.jpg), a low-profile air stripper (center of Photograph GPPI0008.jpg, behind the Bisco control panel), and an effluent composite sampler. I observed the tubing bringing the effluent into the composite sampler and noticed heavy staining on the inside walls of the tube (Photograph GPPI0011.jpg). I mentioned that a dirty sampling tubing can introduce contaminants and affect sample results. I asked if composite samples are collected as flow-based samples, as required by the permit. Kenna Coltman said she didn't think the composite sampler was set up for flow-based samples. [On July 19, 2021, Kelly Mitchell sent an email confirming that the composite sampler was set up for flow-based sampling and provided a print-out of the composite sampler input parameters for flow-based sample collection]. From the Effluent Building, we walked to the two lined equalization ponds. The north pond was out of service at the time of the inspection. Kenna Coltman said they were waiting for final approvals to get the north pond back in service. I noted that the south pond was partially covered by algae (Photograph GPPI0012.jpg). Kenna Coltman said the inlet for the pond was toward the bottom of the pond. We completed the physical inspection of the wastewater treatment systems at 2:25 p.m. and returned to the office building to conduct a review of the laboratory. 5 Gabriel Performance Products Diagnostic Inspection Report Laboratory: In the laboratory we met Kari Demorest, laboratory technician. I asked if we could see a demonstration of chlorine analysis using the Hach Pocket Colorimeter test kit. Kari Demorest properly performed the analysis using tap water and provided a result of 1.78 mg/l. We also observed the sample log for the Hach Pocket Colorimeter and associated calibration standards. Ken Gunter asked if the laboratory conducts MDL and DMR QA studies. Heather Myers said they did and would provide copies. [Heather Myers provided electronic copies of MDL and DMR QA studies on July 19, 2021]. No issues were identified in the laboratory. We concluded the physical inspection and returned to the office building to conduct the closing conference. IV. CLOSING CONFERENCE, AREAS OF CONCERN, AND OTHER OBSERVATIONS Ken Gunter and I returned to the office building conference room at 2:25 p.m. to conduct the closing conference. We were joined by Brianne Workman, Kenna Coltman, Heather Myers, and Kelly Mitchell. First, I went over preliminary areas of concern, and noted that I may identify other areas of concern after further review of inspection notes and documents received as part of the inspection. Areas of Concern The Facility reported, via electronic DMRs submitted to Ohio EPA, 77 permit effluent limit exceedances from August 2016 to May 2021 (Attachment B). Recent E.coli exceedance (May 2021) may be attributed to the past practice of sampling stagnant effluent at internal outfall 601. Operations and Maintenance Areas of Concern [noting that Permit Part III.3.A requires "[a]t all times, the permittee shall maintain in good working order and operate as efficiently as possible all treatment or control facilities or systems installed or used by the permittee necessary to achieve compliance with the terms and conditions of this permit."] Sanitary Sewage Treatment System: o Lack of aeration in the sanitary package plant. I did not observe bubbling in the aeration chamber and it was clear that the system was not working properly. The surface of the clarifier also appeared to be covered by a thick layer of dark sludge. o An inlet in the package plant was designed to collect floating material but none of the GPP representatives present knew where the inlet returned any skimmed material. o I observed some plant growth on top of the sand bed but since the system was not in operation I could not tell if the flow was distributed across the filter or if plant growth was excessive enough to cause preferential channeling at the surface of the sand bed. o Contact time for the effluent moving through the chlorine tablets may be insufficient for disinfection. Potential to contribute to E.coli limit exceedances. 6 Gabriel Performance Products Diagnostic Inspection Report o TSS issues may be due to observed unknown residue (perhaps deteriorating vault material) and the use of chlorine tablets for disinfection. Chlorine tablets appear to break apart in the tablet holders, potentially creating solids in the effluent. Outfall 001 Treatment System: o Multimedia beds were operated with the wrong type of filter media prior to August 2020. o I observed the tubing bringing the effluent into the composite sampler and noticed heavy staining on the inside walls of the tube. Dirty sample tubing can introduce contaminants and affect sample results. o The north equalization pond was out of service at the time of the inspection. Other Observations GPP representatives will explore the use of a Hach DR3900 benchtop spectrophotometer to determine if better MDLs can be achieved compared to the Hach Pocket Colorimeter. Outfall 001 Treatment System: Elevated TRC concentrations were measured in the equalization pond the day prior to the inspection. GPP representatives suspect the cause may be related to cleaning crews recently using chlorinated city water for general cleaning. Outfall 001 Treatment System: pH adjustment via HCL addition occurs until pH is greater than 8.5 in the equalization pond. Addition of HCL may contribute to elevated TRC concentrations. Outfall 001 Treatment System: TSS issues may be a result of insufficient backwashing of carbon beds. Manufacturer's recommendations should be followed for backwashing to minimize preferential channeling within the carbon beds. Testing TRC concentrations before and after each carbon bed may reveal relationships between carbon bed change outs and TRC concentrations. Sanitary sewage treatment system: Microscope examination of any small particles found in the chlorination station chlorine tablet feeder and the effluent channel may help to assess the source of the solids in effluent at outfall 601. Next, I went over the list of documents requested during the inspection, including: Laboratory MDL and QA DMR studies; Daily Effluent Log Sheets; and Flow meter type [the above documents were provided via email on July 19, 2021; see Attachment C] Prior to concluding the closing conference, I provided an estimated timeframe for preparing an inspection report and asked if there were any questions. With no further questions, we 7 Gabriel Performance Products Diagnostic Inspection Report concluded the closing conference at 3:30 p.m. Ken Gunter and I signed out on the visitor log and departed the Facility at 3:50 p.m. on July 13, 2021. V. DOCUMENTS RECEIVED AND REFERENCES Documents received during the inspection (see Attachment C): Sanitary Septic Tank System Diagram General Plot of Ashtabula Plant Interference Study Monitoring Spreadsheet Documents received after the inspection (see Attachment C): Laboratory MDL and QA DMR studies Daily Effluent Log Sheets Effluent Discharge Auto Sample Parameters Specific resources included by reference: Gabriel Performance Products NPDES Permit# OH-0029149 (Ohio ID# 3IF00002*ND); issued by Ohio EPA on April 11, 2019; expiration date April 30, 2024; Fact Sheet: Gabriel Performance Products NPDES Permit# OH-0029149 (Ohio ID# 3IF00002*ND), Public Notice Date - November 14, 2018. 8 Attachment A, page 1 Gabriel Performance Products Inspection Report Attachment A: Facility maps and diagrams Facility Overview Plan Sanitary Sewer System Detail Plan Water Balance Diagram (NPDES Permit Fact Sheet, 2018) Attachment A, page 2 Gabriel Performance Products Inspection Report ALL surface water flow within the active portions of the facility ultimately ends up in the retention ponds. Each retention pond holds 1.3 Million gallons of water Attachment A, page 3 Sanitary System Detail Gabriel Performance Products Inspection Report From the Septic Tank to the Sand Filter Feed Sump the system operates by gravity. The Primary Sand Filter Dosing Pump operates on floats, with a backup pump available in case of failure. West Sand Filter Trash Trap Skimmer Aerator: Aerobic Digestion Clarifier Sand Filter Feed Dosing Pump Hour Meters Septic Tank: Anaerobic Digestion (underground) Clarifier Return There are a series of underdrains in the bottom of the sand beds that collect the flow and routes it to the final discharge vault across the drive where disinfection occurs with a flow through chlorine tablet feeder. Distribution Box East Sand Filter Underground Drains to Discharge Disinfection Attachment A, page 4 )LJXUH:DWHU%DODQFH'LDJUDP Gabriel Performance Products Inspection Report Fact Sheet for NPDES Permit Renewal, *DEULHO3HUIRUPDQFH3URGXFWV, 2018 Attachment B, page 1 Gabriel Performance Products Inspection Report Attachment B: Permit effluent limit exceedances from August 2016 to May 2021 Attachment B, page 2 Gabriel Performance Products Inspection Report Effluent Limit Exceedances Report OH0029149: GABRIEL PERFORMANCE PRODUCTS LLC, ASHTABULA, OH 44004-3934 Monitoring Period Date Range: 08/01/2016 to 05/31/2021 Monitoring Period Date 8/31/2016 8/31/2016 8/31/2016 8/31/2016 3/31/2017 3/31/2017 4/30/2017 5/31/2017 6/30/2017 9/30/2017 10/31/2017 12/31/2017 12/31/2017 2/28/2018 2/28/2018 3/31/2018 5/31/2018 5/31/2018 6/30/2018 6/30/2018 10/31/2018 10/31/2018 11/30/2018 11/30/2018 1/31/2019 3/31/2019 3/31/2019 4/30/2019 4/30/2019 8/31/2019 8/31/2019 8/31/2019 8/31/2019 9/30/2019 9/30/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 Outfall 1 1 601 601 1 1 1 601 1 1 1 601 601 1 1 1 1 1 1 1 601 601 1 1 1 1 1 1 1 1 1 601 601 1 1 1 1 1 1 Parameter Description Mercury, total low level Mercury, total low level Coliform, fecal MF, MFC broth, 44.5 C Coliform, fecal MF, MFC broth, 44.5 C Zinc, total (as Zn) Carbon tetrachloride pH Solids, total suspended Mercury, total low level BOD, 5-day, 20 deg. C BOD, 5-day, 20 deg. C Solids, total suspended Solids, total suspended Zinc, total (as Zn) Zinc, total (as Zn) Mercury, total low level Zinc, total (as Zn) Zinc, total (as Zn) Zinc, total (as Zn) Zinc, total (as Zn) Coliform, fecal MF, MFC broth, 44.5 C Coliform, fecal MF, MFC broth, 44.5 C Zinc, total (as Zn) Zinc, total (as Zn) pH Zinc, total (as Zn) Zinc, total (as Zn) Zinc, total (as Zn) Zinc, total (as Zn) Zinc, total (as Zn) Zinc, total (as Zn) Solids, total suspended Solids, total suspended Zinc, total (as Zn) Zinc, total (as Zn) BOD, 5-day, 20 deg. C BOD, 5-day, 20 deg. C Zinc, total (as Zn) Zinc, total (as Zn) Limit Type MO AVG MO AVG DAILY MX MO GEOMN DAILY MX MO AVG DAILY MX MO AVG MO AVG MO AVG MO AVG DAILY MX MO AVG DAILY MX DAILY MX MO AVG DAILY MX DAILY MX DAILY MX DAILY MX MO GEOMN DAILY MX DAILY MX DAILY MX DAILY MX DAILY MX DAILY MX DAILY MX DAILY MX DAILY MX DAILY MX MO AVG DAILY MX DAILY MX DAILY MX MO AVG MO AVG DAILY MX DAILY MX DMR Value 0.00001 2.5E-05 8400 1137 0.118 0.02 9.26 37 7.47E-06 15 15 57 34 0.149 0.174 6.62E-06 0.182 0.196 0.217 0.206 1.07 1.025 9.5 0.155 0.155 0.833 0.945 0.444 0.374 33 85 0.143 0.155 26 24 0.213 0.228 DMR Value Unit kg/d mg/L #/100mL #/100mL mg/L mg/L SU mg/L mg/L kg/d kg/d mg/L mg/L mg/L kg/d mg/L mg/L kg/d kg/d mg/L #/100mL #/100mL mg/L kg/d SU kg/d mg/L mg/L kg/d mg/L kg/d mg/L mg/L kg/d mg/L mg/L kg/d kg/d mg/L Limit Value 0.000008 6.2E-06 2000 1000 0.117 0.019 9 30 6.2E-06 13.3 13.3 45 30 0.117 0.142 6.2E-06 0.117 0.142 0.142 0.117 1000 2000 0.117 0.142 9 0.142 0.117 0.117 0.142 0.117 0.142 30 45 0.142 0.117 11 13.3 0.142 0.117 Limit Value Qualifier <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= Attachment B, page 3 Gabriel Performance Products Inspection Report Effluent Limit Exceedances Report OH0029149: GABRIEL PERFORMANCE PRODUCTS LLC, ASHTABULA, OH 44004-3934 Monitoring Period Date Range: 08/01/2016 to 05/31/2021 Monitoring Period Date 10/31/2019 11/30/2019 12/31/2019 12/31/2019 1/31/2020 1/31/2020 2/29/2020 2/29/2020 2/29/2020 5/31/2020 5/31/2020 5/31/2020 5/31/2020 8/31/2020 8/31/2020 8/31/2020 9/30/2020 9/30/2020 10/31/2020 10/31/2020 11/30/2020 11/30/2020 12/31/2020 12/31/2020 12/31/2020 12/31/2020 1/31/2021 1/31/2021 1/31/2021 1/31/2021 2/28/2021 2/28/2021 2/28/2021 3/31/2021 3/31/2021 3/31/2021 3/31/2021 5/31/2021 Outfall 601 1 1 1 1 1 1 1 1 1 1 601 601 1 1 601 1 1 601 601 601 601 1 1 601 601 1 1 1 1 1 1 601 1 1 1 1 601 Parameter Description Solids, total suspended Zinc, total (as Zn) Zinc, total (as Zn) Zinc, total (as Zn) Zinc, total (as Zn) Zinc, total (as Zn) BOD, 5-day, 20 deg. C Solids, total suspended Solids, total suspended Chlorine, total residual Chlorine, total residual E. coli, MTEC-MF E. coli, MTEC-MF Chlorine, total residual Chlorine, total residual E. coli, MTEC-MF Mercury, total low level Mercury, total low level Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Chlorine, total residual Chlorine, total residual Solids, total suspended Solids, total suspended BOD, 5-day, 20 deg. C Solids, total suspended Chlorine, total residual Chlorine, total residual BOD, 5-day, 20 deg. C BOD, 5-day, 20 deg. C BOD, carbonaceous, 05 day, 20 C Solids, total suspended Solids, total suspended Chlorine, total residual Chlorine, total residual E. coli, MTEC-MF Limit Type MO AVG DAILY MX DAILY MX DAILY MX DAILY MX DAILY MX MO AVG MO AVG MO AVG MO AVG DAILY MX MO GEOMN WK GEOMN MO AVG DAILY MX MO GEOMN MO AVG MO AVG DAILY MX MO AVG MO AVG DAILY MX MO AVG DAILY MX MO AVG DAILY MX MO AVG MO AVG DAILY MX MO AVG MO AVG MO AVG MO AVG MO AVG MO AVG MO AVG DAILY MX WK GEOMN DMR Value 35 0.198 0.241 0.222 0.172 0.245 13.4 21 19 0.0289 0.185 3449.88 141000 0.0321 0.0733 199 2.34E-05 0.0000178 1450 1450 1450 1450 0.025 0.09 85.5 162 20 23 0.067 0.018 15 16 29 18 20 0.037 0.07 6490 DMR Value Limit Unit Value mg/L 30 mg/L 0.117 kg/d 0.142 mg/L 0.117 mg/L 0.117 kg/d 0.142 mg/L 11 mg/L 14.3 kg/d 17.5 mg/L 0.011 mg/L 0.019 MPN/100m126 MPN/100m284 mg/L 0.011 mg/L 0.019 MPN/100m126 mg/L 6.2E-06 kg/d 0.000008 mg/L 45 mg/L 30 mg/L 30 mg/L 45 mg/L 0.011 mg/L 0.019 mg/L 30 mg/L 45 kg/d 13.3 kg/d 17.5 mg/L 0.019 mg/L 0.011 mg/L 11 kg/d 13.3 mg/L 25 mg/L 14.3 kg/d 17.5 mg/L 0.011 mg/L 0.019 MPN/100m284 Limit Value Qualifier <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= Attachment C, page 1 Gabriel Performance Products Inspection Report Attachment C: Documents provided by Gabriel Performance Products Documents received during the inspection: Sanitary Septic Tank System Diagram General Plot of Ashtabula Plant Interference Study Monitoring Spreadsheet Documents received after the inspection: Laboratory MDL and QA DMR studies Daily Effluent Log Sheets Effluent Discharge Auto Sample Parameters Attachment C, page 2 Gabriel Performance Products Inspection Report Attachment C, page 3 Gabriel Performance Products Inspection Report Attachment C, page 4 Gabriel Performance Products Inspection Report Attachment C, page 5 Gabriel Performance Products Inspection Report Attachment C, page 6 Gabriel Performance Products Inspection Report Attachment C, page 7 Gabriel Performance Products Inspection Report Attachment C, page 8 Ver. 1 Page 1 of 18 Gabriel Performance Products Inspection Report Kenna Coltman Gabriel Performance Products 725 State Road Ashtabula, OH 44004 USA DMR-QA 39 Final Report NPDES Permit: OH0029149 DMR-QA Study Open Date: 03/22/19 Close Date: 07/19/19 Report Issued Date: 08/16/19 Study # : DMR-QA 39 Attachment C, page 9 Ver. 1 Page 2 of 18 Gabriel Performance Products Inspection Report August 16, 2019 Kenna Coltman Gabriel Performance Products 725 State Road Ashtabula, OH 44004 Enclosed is your final report for ERA's DMR-QA 39 Proficiency Testing study. Please note that reports were sent on your behalf to your state or regional DMR-QA coordinator. As the permit holder, you are required to review and sign the attached EPA forms and checklists and forward them to your DMR-QA coordinator by September 13, 2019. Your coordinator's contact information is provided below. All analytes in ERA's DMR-QA 39 Proficiency Testing study have been evaluated by comparing the reported result to the acceptance limits generated using the criteria contained in the most current TNI FoPT tables. If you have any "Not Acceptable" evaluations for the DMR-QA 39 study, a letter of corrective action and an order form for the required remedial samples are attached for your convenience. If you have a "Not Acceptable" evaluation, but there is not an order form or a list of standards for your in-house or outside laboratories, ERA recommends that you contact your DMR-QA coordinator for their corrective action requirements, if any. Thank you for your participation in ERA's DMR-QA 39 Proficiency Testing study. If you have any questions, please contact the Proficiency Testing Department at 1-800-372-0122. Your DMR-QA coordinator is: Ohio EPA Steve Roberts 8955 East Main Street Reynoldsburg, OH 43068 Phone: 614-644-4225 Fax: 614-644-4272 steven.roberts@epa.ohio.gov Sincerely, Matthew Seebeck Quality Officer attachments 16341 Table Mountain Pkwy Golden, CO 80403 800.372.0122 303.431.8454 fax 303.421.0159 www.eraqc.com Study # : DMR-QA 39 Attachment C, page 10 Ver. 1 Page 3 of 18 Gabriel Performance Products Inspection Report DMR-QA 39 Definitions & Study Discussion Study Dates: 03/22/19 - 07/19/19 Report Issued: 08/16/19 DMRQA Study Definitions The Reported Value is the value that the laboratory reported to ERA. The ERA Assigned Values are compliant with the current FoPT tables. The assigned values are directly traceable to the commercially prepared starting materials used to manufacture the PT standards. The Acceptance Limits are established per the criteria contained in the most current TNI FoPT tables, or ERA's SOP for the Generation of Performance Acceptance LimitsTM as applicable. The Performance Evaluation: Acceptable = Reported Value falls within the Acceptance Limits. Not Acceptable = Reported Value falls outside the Acceptance Limits. No Evaluation = Reported Value cannot be evaluated. Not Reported = No Value reported. The Method Description is the method the laboratory reported to ERA. DMRQA Study Discussion ERA's DMR-QA 39 Proficiency Testing study has been reviewed by ERA senior management and certified compliant with the requirements of the 2009 TNI PT Standards and the criteria contained in the most current TNI FoPT tables. ERA's DMR-QA 39 study standards were examined for any anomalies. A full review of all homogeneity, stability and accuracy verification data was completed. All analytical verification data for all analytes met the acceptance criteria contained in the 2009 TNI PT Standard and the criteria contained in the most current TNI Fields of Proficiency Testing (FoPT) tables. All activities associated with this proficiency testing study were performed by Waters/ERA with the exception of those noted below. The following physical samples/products were manufactured for Waters/ERA by a subcontractor: Microbiology products with the following catalog numbers: 880, 935, 079, 077, 080, 595, 595A, 576, 576A The data submitted by participating laboratories was also examined for study anomalies. There were no anomalies observed during the statistical review of the data. ERA's DMR-QA 39 study reports shall not be reproduced except in their entirety and not without the permission of the participating laboratories. The report must not be used by the participating laboratories to claim product endorsement by any agency of the U. S. government. The data contained herein are confidential and intended for your use only. If you have any questions or concerns regarding your assessment in ERA's DMRQA Proficiency Testing program, please contact our Proficiency Testing Department at 1-800372-0122. Study # : DMR-QA 39 Attachment C, page 11 Ver. 1 Page 4 of 18 Gabriel Performance Products Inspection Report Study: DMR-QA 39 NPDES Permit #: OH0029149 Laboratory Name: Gabriel Performance Products Inorganic Results 16341 Table Mountain Pkwy Golden, CO 80403 800.372.0122 303.431.8454 fax 303.421.0159 www.eraqc.com Study # : DMR-QA 39 Attachment C, page 12 Ver. 1 Page 5 of 18 Gabriel Performance Products Inspection Report DMR-QA 39 Final Report NPDES Permit #: OH0029149 Permit Holder: Kenna Coltman Gabriel Performance Products 725 State Road Ashtabula, OH 44004 ERA Customer Number: G234480 Report Issued: 08/16/19 Study Dates: 03/22/19 - 07/19/19 TNI Analyte Code Analyte Units WP Minerals (cat# 581, lot# P289-506) 1955 Total Dissolved Solids at 180C mg/L WP Hardness (cat# 580, lot# P289-507) 1960 Total Suspended Solids mg/L DMRQA pH (cat# 577, lot# Q039-977) 1900 pH S.U. WP Demand (cat# 578, lot# P289-516) 1530 BOD 1555 CBOD mg/L mg/L WP Oil & Grease (cat# 582, lot# P289-518) 1803 n-Hexane Extractable Material(O&G)(Grav) mg/L WP Trace Metals (cat# 586, lot# P289-500) 1040 Chromium 1055 Copper 1075 Lead 1105 Nickel 1190 Zinc g/L g/L g/L g/L g/L DMRQA Total Residual Chlorine (cat# 587, lot# Q039-501) 1945 Free Residual Chlorine mg/L 1940 Total Residual Chlorine mg/L Performance Evaluation Reported Value Assigned Value Acceptance Method Description Study Mean Limits Study Standard Deviation USEPA Lab Code Study Acceptable 280 299 254 - 344 SM2540C online 290 11.9 OH00232 WP289 Acceptable 75 80.6 65.8 - 89.8 SM2540D online 77.2 2.66 OH00232 WP289 Acceptable 6.7 6.82 6.62 - 7.02 123-00-002 4 6.83 0.0592 OH01205 DMRQA39 Acceptable 158 Acceptable 131 142 77.1 - 207 SM5210B online 144 129 60.7 - 197 SM5210B online 128 22.2 OH00232 20.4 OH00232 WP289 WP289 Acceptable 127 160 118 - 182 EPA 1664A 1999 144 13.5 OH00232 WP289 Acceptable Acceptable Acceptable Acceptable Acceptable 586 812 172 670 1140 602 739 177 663 1120 512 - 692 628 - 850 150 - 204 581 - 750 952 - 1290 EPA 200.7 4.4 1994 EPA 200.7 4.4 1994 EPA 200.7 4.4 1994 EPA 200.7 4.4 1994 EPA 200.7 4.4 1994 605 752 177 672 1110 32.2 OH00232 39.8 OH00232 10.2 OH00232 33.2 OH00232 50.2 OH00232 WP289 WP289 WP289 WP289 WP289 Not Reported Acceptable 0.71 0.762 0.762 0.572 - 0.930 0.572 - 0.930 123-00-026 8 0.695 0.751 0.102 0.0663 OH01205 OH01205 DMRQA39 DMRQA39 All analytes are included in ERA's A2LA accreditation. Lab Code: 1539-01 16341 Table Mountain Pkwy Golden, CO 80403 800.372.0122 303.431.8454 fax 303.421.0159 www.eraqc.com Study # : DMR-QA 39 Attachment C, page 13 Ver. 1 Page 6 of 18 Gabriel Performance Products Inspection Report Study: DMR-QA 39 NPDES Permit #: OH0029149 Laboratory Name: Gabriel Performance Products WET Results 16341 Table Mountain Pkwy Golden, CO 80403 800.372.0122 303.431.8454 fax 303.421.0159 www.eraqc.com Study # : DMR-QA 39 Attachment C, page 14 Ver. 1 Page 7 of 18 Gabriel Performance Products Inspection Report DMR-QA 39 Final Report NPDES Permit #: OH0029149 Permit Holder: Kenna Coltman Gabriel Performance Products 725 State Road Ashtabula, OH 44004 ERA Customer Number: G234480 Report Issued: 08/16/19 Study Dates: 03/22/19 - 07/19/19 Analyte Code Test End Point Performance Evaluation Reported Value % DMRWet Fathead minnow (Test Code 13) (cat# WET002, lot# Q039-002) 48Hr., Acute, Non-Renewal, 25 C, MHSF Potassium chloride 0754 LC50 Acceptable DMRWet Fathead minnow (Test Code 16) (cat# WET005, lot# Q039-005) 7-day Chronic, Daily Renewal, 20% DMW Potassium chloride 0812 IC25 (ON) Growth Acceptable 42.33 56.29 0814 NOEC (ON) Growth Acceptable 50 0759 NOEC Survival Acceptable DMRWet Ceriodaphnia dubia (Test Code 19) (cat# WET008, lot# Q039-008) 48-Hr Acute, Nonrenewal, 25 C, MHSF Potassium chloride 0764 LC50 Acceptable DMRWet Ceriodaphnia dubia (Test Code 21) (cat# WET010, lot# Q039-010) 3-Brood Chronic, Daily Renewal, MHSF Potassium chloride 0767 IC25 Reproduction Acceptable 50 34.15 29.92 0768 NOEC Reproduction Acceptable 25 0766 NOEC Survival Acceptable DMRWet Daphnia magna (Test Code 32) (cat# WET012, lot# Q039-012) 48Hr., Acute, Non-Renewal, 25 C, MHSF Potassium chloride 0788 LC50 Acceptable 25 70.71 Assigned Value % Acceptance Method Description Study Mean Limits % Study Standard Deviation USEPA Lab Code 45.2 24.7 - 65.6 EPA 2000.0 MHSF 25 deg C 5th ED 2002 45.2 10.2 OH01191 39.3 25.0 25.0 13.8 - 64.8 12.5 - 50.0 12.5 - 50.0 EPA 1000.0 DMW 2002 EPA 1000.0 DMW 2002 EPA 1000.0 DMW 2002 39.3 12.8 OH01191 OH01191 OH01191 37.0 24.1 - 49.9 EPA 2002.0 MHSF 25 deg C 5th ED 2002 37.0 6.45 OH01191 27.6 25.0 25.0 20.9 - 34.3 12.5 - 50.0 12.5 - 50.0 EPA 1002.0 MHSF 2002 EPA 1002.0 MHSF 2002 EPA 1002.0 MHSF 2002 27.6 3.33 OH01191 OH01191 OH01191 60.8 30.1 - 91.4 EPA 2021.0 60.8 15.3 OH01191 Study DMRWet39 DMRWet39 DMRWet39 DMRWet39 DMRWet39 DMRWet39 DMRWet39 DMRWet39 DMRWet39 All analytes are included in ERA's A2LA accreditation. Lab Code: 1539-01 16341 Table Mountain Pkwy Golden, CO 80403 800.372.0122 303.431.8454 fax 303.421.0159 www.eraqc.com Study # : DMR-QA 39 Attachment C, page 15 USEPA DMR-QA 39 Ver. 1 Page 8 of 18 Gabriel Performance Products Inspection Report NPDES PERMITTEE DATA REPORT FORM Due September 13, 2019 USEPA NPDES Permit #: OH0029149 Permittee Name: Gabriel Performance Products Permit Ext: Facility Address: 725 State Road City: Ashtabula Phone Number: - - E-mail address: kenna.coltman@gabrielchem.com State: OH Postal Code: 44004 - Fax Number: - - Optional: If WP study was used, list PT provider name: Environmental Resource Associates Optional: WP study number(s): WP-289 For DMRQA-39, conducted in 2019, the Permittee ensured that their laboratory(s) performing the required analyses: Received PT Samples Submitted Complete and Accurate Data by July 19, 2019 Received a Graded Report by August 16, 2019 Yes No Yes No Yes No Certification by Permit Holder or Authorized Representative (as per 40 C.F.R. Section 122.22) I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate and complete. Each reported value was produced from a single analytical run using the analytical system that rountinely performs these analyses to produce compliance monitoring data required under our National Pollutant Discharge Elimination System (NPDES) Permit. Neither I nor any of my subordinates compared our results from independent analyses conducted by us or any other laboratory before we reported our results to the USEPA. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Name of Certifying Official: Kenna Coltman Title: Signature: Mailing Address: 725 State Road (enter only if different from address above) City: Ashtabula Phone Number: - - Please make corrections in boxes above Date Signed: / / State: OH Postal Code: 44004 - E-mail address: kenna.coltman@gabrielchem.com Attachment C, page 16 Ver. 1 Page 9 of 18 Gabriel Performance Products Inspection Report United States ENVIRONMENTAL PROTECTION AGENCY Laboratory Performance Evaluation Laboratory DMR-QA Evaluation Study 39 USEPA NPDES Permit #: OH0029149 Permit Ext: Identification of all CHEM, MICRO and TOX laboratories who did analyses for this permit Lab Analysis Name of Laboratory Address of Laboratory U.S. EPA Lab Code Check box(es) that apply CHEM MICRO TOX Lab Type* Statecertified Lab** EA Group 7118 Industrial Park Blvd Mentor,OH 44060 OH00232 Enviroscience Inc 5070 Stow Rd Stow,OH 44224 OH01191 Gabriel Performance Products 725 State Road Ashtabula,OH 44004 OH01205 * Lab Types: C = Commercial F = Federal G = Local Government ** See Footnote 2 on DMRQA-39, Frequently Asked Questions page I = Industrial O = Other S = State Attachment C, page 17 Permittee Name: Gabriel Performance Products Ver. 1 Page 10 of 18 Gabriel Performance Products Inspection Report Permit Number: OH0029149 EPA Lab Code: OH00232 Analyte Test / Method Minerals Alkalinity as CaCO3 Chloride Conductivity at 25C Fluoride Potassium Sodium Sulfate Total Dissolved Solids at 180C SM2540C Total Solids at 105C Hardness Total Suspended Solids SM2540D Calcium Magnesium Calcium Hardness as CaCO3 Total Hardness as CaCO3 pH pH Settleable Solids Settleable Solids Solids Concentrate Total Suspended Solids Total Dissolved Solids at 180C Total Solids at 105C Solids Total Suspended Solids Total Dissolved Solids at 180C Total Solids at 105C Simple Nutrients Ammonia as N Nitrate + Nitrite as N Nitrate as N ortho-Phosphate as P Complex Nutrients Total Kjeldahl Nitrogen Total phosphorus as P Nitrite Nitrite as N Demand BOD SM5210B Chemistry/Microbiology Analyte Checklist WP Study 289 Laboratory's Graded Result Test Required Acceptable Not Acceptable (Corrective Action Required) Analyte determined by state-certified lab o x o o o x o o o x o o Attachment C, page 18 Permittee Name: Gabriel Performance Products Ver. 1 Page 11 of 18 Gabriel Performance Products Inspection Report Permit Number: OH0029149 EPA Lab Code: OH00232 Analyte Test / Method CBOD SM5210B COD TOC Oil & Grease Concentrate n-Hexane Extractable Material(O&G) (Grav) Oil & Grease n-Hexane Extractable Material(O&G) (Grav) EPA 1664A n-Hexane Extractable Material(O&G) (IR) Trace Metals Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Chromium EPA 200.7 Cobalt Copper EPA 200.7 Iron Lead EPA 200.7 Manganese Molybdenum Nickel EPA 200.7 Selenium Silver Strontium Thallium Vanadium Zinc EPA 200.7 Mercury Mercury Low-Level Mercury Low Level Mercury Chemistry/Microbiology Analyte Checklist WP Study 289 Laboratory's Graded Result Test Required Acceptable Not Acceptable (Corrective Action Required) o x o Analyte determined by state-certified lab o o x o o o x o o o x o o o x o o o x o o o x o o Attachment C, page 19 Permittee Name: Gabriel Performance Products Ver. 1 Page 12 of 18 Gabriel Performance Products Inspection Report Permit Number: OH0029149 EPA Lab Code: OH00232 Analyte Test / Method Hexavalent Chromium Hexavalent Chromium Turbidity Turbidity Total Cyanide Cyanide, total Amenable Cyanide Total Phenolics (4-AAP) Phenolics, total Total Residual Chlorine Free Residual Chlorine Total Residual Chlorine Low-Level Total Residual Chlorine Low Level Total Residual Chlorine WasteWatRTM Coliform MicrobETM Total Coliforms (MF) Fecal Coliforms (MF) E.coli (MF) Total Coliforms (MPN) Fecal Coliforms (MPN) E.coli (MPN) WasteWatRTM Coliform MicrobETM - SM 9221 Total Coliforms (MPN) Fecal Coliforms (MPN) E.coli (MPN) Chemistry/Microbiology Analyte Checklist WP Study 289 Laboratory's Graded Result Test Required Acceptable Not Acceptable (Corrective Action Required) Analyte determined by state-certified lab Print Name Signature/Title Date Use a separate checklist for EACH lab used Attachment C, page 20 Permittee Name: Gabriel Performance Products Ver. 1 Page 13 of 18 Gabriel Performance Products Inspection Report Permit Number: OH0029149 EPA Lab Code: OH01191 WET Organisms/Test Conditions/End Points Checklist DMRWet Study 39 Laboratory's Graded Result Analyte Number Organisms / Conditions Fathead minnow (Test Code 13) 0754 48Hr., Acute, Non-Renewal, 25 C, MHSF End Points LC50 Test Req Acceptable Not Acceptable (Corrective Action Required) EPA 2000.0 MHSF 25 deg C Fathead minnow (Test Code 14) 0755 48Hr., Acute, Non-Renewal, 25 C, 20% DMW LC50 o x o Fathead minnow (Test Code 15) 0808 7-day Chronic, Daily Renewal, MHSF 0810 7-day Chronic, Daily Renewal, MHSF 0756 7-day Chronic, Daily Renewal, MHSF IC25 (ON) Growth NOEC (ON) Growth NOEC Survival Fathead minnow (Test Code 16) 0812 7-day Chronic, Daily Renewal, 20% DMW 0814 EPA 1000.0 DMW 7-day Chronic, Daily Renewal, 20% DMW 0759 EPA 1000.0 DMW 7-day Chronic, Daily Renewal, 20% DMW IC25 (ON) Growth o x o NOEC (ON) Growth o x o NOEC Survival EPA 1000.0 DMW Ceriodaphnia dubia (Test Code 19) 0764 48-Hr Acute, Nonrenewal, 25 C, MHSF LC50 o x o EPA 2002.0 MHSF 25 deg C Ceriodaphnia dubia (Test Code 20) 0765 48-Hr Acute, Nonrenewal, 25 C, 20% DMW LC50 o x o Ceriodaphnia dubia (Test Code 21) 0767 3-Brood Chronic, Daily Renewal, MHSF 0768 EPA 1002.0 MHSF 3-Brood Chronic, Daily Renewal, MHSF 0766 EPA 1002.0 MHSF 3-Brood Chronic, Daily Renewal, MHSF IC25 Reproduction o x o NOEC Reproduction o x o NOEC Survival EPA 1002.0 MHSF Ceriodaphnia dubia (Test Code 22) 0770 3-Brood Chronic, Daily Renewal, 20% DMW 0771 3-Brood Chronic, Daily Renewal, 20% DMW 0769 3-Brood Chronic, Daily Renewal, 20% DMW o x o IC25 Reproduction NOEC Reproduction NOEC Survival Daphnia magna (Test Code 32) 0788 48Hr., Acute, Non-Renewal, 25 C, MHSF LC50 EPA 2021.0 o x o Analyte determined by state-certified lab o o o o o o o o o Attachment C, page 21 Permittee Name: Gabriel Performance Products Ver. 1 Page 14 of 18 Gabriel Performance Products Inspection Report Permit Number: OH0029149 EPA Lab Code: OH01191 WET Organisms/Test Conditions/End Points Checklist DMRWet Study 39 Laboratory's Graded Result Analyte Number Organisms / Conditions Daphnia pulex (Test Code 38) 0794 48Hr., Acute, Non-Renewal, 25 C, MHSF End Points LC50 Test Req Acceptable Not Acceptable (Corrective Action Required) Mysid (Test Code 42) 0798 48-Hr Acute, Nonrenewal, 25 C, SSW LC50 Mysid (Test Code 43) 0816 7-day Chronic, Daily Renewal, SSW 0818 7-day Chronic, Daily Renewal, SSW 0799 7-day Chronic, Daily Renewal, SSW IC25 (ON) Growth NOEC (ON) Growth NOEC Survival Inland silverside (Test Code 44) 0803 48-Hr Acute, Nonrenewal, 25 C, SSW LC50 Inland Silverside (Test Code 45) 0825 7-day Chronic, Daily Renewal, SSW 0826 7-day Chronic, Daily Renewal, SSW 0824 7-day Chronic, Daily Renewal, SSW IC25 (ON) Growth NOEC (ON) Growth NOEC Survival Sheepshead minnow (Test Code 46) 0804 48-Hr Acute, Nonrenewal, 25 C, SSW LC50 Sheepshead minnow (Test Code 47) 0820 7-day Chronic, Daily Renewal, SSW 0822 7-day Chronic, Daily Renewal, SSW 0805 7-day Chronic, Daily Renewal, SSW IC25 (ON) Growth NOEC (ON) Growth NOEC Survival Analyte determined by state-certified lab Print Name Signature/Title Date Use a separate checklist for EACH lab used Attachment C, page 22 Permittee Name: Gabriel Performance Products Ver. 1 Page 15 of 18 Gabriel Performance Products Inspection Report Permit Number: OH0029149 EPA Lab Code: OH01205 Analyte Test / Method Minerals Alkalinity as CaCO3 Chloride Conductivity at 25C Fluoride Potassium Sodium Sulfate Total Dissolved Solids at 180C Total Solids at 105C Hardness Total Suspended Solids Calcium Magnesium Calcium Hardness as CaCO3 Total Hardness as CaCO3 pH pH 123-00-002 Settleable Solids Settleable Solids Solids Concentrate Total Suspended Solids Total Dissolved Solids at 180C Total Solids at 105C Solids Total Suspended Solids Total Dissolved Solids at 180C Total Solids at 105C Simple Nutrients Ammonia as N Nitrate + Nitrite as N Nitrate as N ortho-Phosphate as P Complex Nutrients Total Kjeldahl Nitrogen Total phosphorus as P Nitrite Nitrite as N Demand BOD CBOD COD TOC Chemistry/Microbiology Analyte Checklist DMRQA Study 39 Laboratory's Graded Result Test Required Acceptable Not Acceptable (Corrective Action Required) Analyte determined by state-certified lab o x o o Attachment C, page 23 Permittee Name: Gabriel Performance Products Ver. 1 Page 16 of 18 Gabriel Performance Products Inspection Report Permit Number: OH0029149 EPA Lab Code: OH01205 Analyte Test / Method Oil & Grease Concentrate n-Hexane Extractable Material(O&G) (Grav) Oil & Grease n-Hexane Extractable Material(O&G) (Grav) n-Hexane Extractable Material(O&G) (IR) Trace Metals Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Chromium Cobalt Copper Iron Lead Manganese Molybdenum Nickel Selenium Silver Strontium Thallium Vanadium Zinc Mercury Mercury Low-Level Mercury Low Level Mercury Hexavalent Chromium Hexavalent Chromium Turbidity Turbidity Total Cyanide Cyanide, total Amenable Cyanide Total Phenolics (4-AAP) Phenolics, total Chemistry/Microbiology Analyte Checklist DMRQA Study 39 Laboratory's Graded Result Test Required Acceptable Not Acceptable (Corrective Action Required) Analyte determined by state-certified lab Attachment C, page 24 Permittee Name: Gabriel Performance Products Ver. 1 Page 17 of 18 Gabriel Performance Products Inspection Report Permit Number: OH0029149 EPA Lab Code: OH01205 Analyte Test / Method Total Residual Chlorine Free Residual Chlorine Total Residual Chlorine 123-00-026 Low-Level Total Residual Chlorine Low Level Total Residual Chlorine WasteWatRTM Coliform MicrobETM Total Coliforms (MF) Fecal Coliforms (MF) E.coli (MF) Total Coliforms (MPN) Fecal Coliforms (MPN) E.coli (MPN) WasteWatRTM Coliform MicrobETM - SM 9221 Total Coliforms (MPN) Fecal Coliforms (MPN) E.coli (MPN) Chemistry/Microbiology Analyte Checklist DMRQA Study 39 Laboratory's Graded Result Test Required Acceptable Not Acceptable (Corrective Action Required) o x o Analyte determined by state-certified lab o Print Name Signature/Title Date Use a separate checklist for EACH lab used Attachment C, page 25 Ver. 1 Page 18 of 18 Gabriel Performance Products Inspection Report CERTIFICATE OF RECOGNITION ERA congratulates GABRIEL PERFORMANCE PRODUCTS for your participation and successful evaluation in DMR-QA 39. We recognize the performance of this laboratory for achieving acceptable evaluations for the following analytes. pH Total Residual Chlorine Matthew Seebeck Quality Officer G234480 Attachment C, page 26 Ver. 1 Page 1 of 18 Gabriel Performance Products Inspection Report Kenna Coltman Gabriel Performance Products 725 State Road Ashtabula, OH 44004 USA DMR-QA 40 Final Report NPDES Permit: OH0029149 DMR-QA Study Open Date: 03/20/20 Close Date: 09/18/20 Report Issued Date: 10/16/20 Study # : DMR-QA 40 Attachment C, page 27 Ver. 1 Page 2 of 18 Gabriel Performance Products Inspection Report October 16, 2020 Kenna Coltman Gabriel Performance Products 725 State Road Ashtabula, OH 44004 Enclosed is your final report for ERA's DMR-QA 40 Proficiency Testing study. Please note that reports were sent on your behalf to your state or regional DMR-QA coordinator. As the permit holder, you are required to review and sign the attached EPA forms and checklists and forward them to your DMR-QA coordinator by November 20, 2020. Your coordinator's contact information is provided below. All analytes in ERA's DMR-QA 40 Proficiency Testing study have been evaluated by comparing the reported result to the acceptance limits generated using the criteria contained in the most current TNI/NELAP and Whole Effluent Toxicity Testing-Non Potable Water Fields of Proficiency Testing (FoPT) tables. If you have any "Not Acceptable" evaluations for the DMR-QA 40 study, a letter of corrective action and an order form for the required remedial samples are attached for your convenience. If you have a "Not Acceptable" evaluation, but there is not an order form or a list of standards for your in-house or outside laboratories, ERA recommends that you contact your DMR-QA coordinator for their corrective action requirements, if any. Thank you for your participation in ERA's DMR-QA 40 Proficiency Testing study. If you have any questions, please contact the Proficiency Testing Department at 1-800-372-0122. Your DMR-QA coordinator is: Ohio EPA Steve Roberts 8955 East Main Street Reynoldsburg, OH 43068 Phone: 614-644-4225 steven.roberts@epa.ohio.gov Sincerely, Matthew Seebeck Quality Officer attachments 16341 Table Mountain Pkwy Golden, CO 80403 800.372.0122 303.431.8454 fax 303.421.0159 www.eraqc.com Study # : DMR-QA 40 Attachment C, page 28 Ver. 1 Page 3 of 18 Gabriel Performance Products Inspection Report DMR-QA 40 Definitions & Study Discussion Study Dates: 03/20/20 - 09/18/20 DMRQA Study Definitions The Reported Value is the value that the laboratory reported to ERA. The ERA Assigned Values are compliant with the most current TNI/NELAP Fields of Proficiency Testing (FoPT) table. A parameter not added to the standard is given an Assigned Value of "< PTRL" per the guidelines contained in the 2009 TNI Standards. The assigned values are directly traceable to the commercially prepared starting materials used to manufacture the PT standards. The Acceptance Limits are established per the criteria contained in the most current TNI/NELAP FoPT table or ERA's SOP for the Generation of Performance Acceptance LimitsTM as applicable. This report is scored by the criteria in the 2016 TNI Standard, Volume 3, instead of by the criteria in the 2009 TNI Standard to which the Proficiency Testing Provider is accredited. This is a planned change and is endorsed by the TNI Proficiency Testing Program Executive Committee for transition to the 2016 TNI Standard. The Performance Evaluation: Report Issued: 10/16/20 DMRQA Study Discussion ERA's DMR-QA 40 Proficiency Testing study has been reviewed by ERA senior management and certified compliant with the requirements of the 2009 TNI PT Standards and the 2016 TNI Standard, Volume 3, Section 5.9 and the criteria contained in the most current TNI/NELAP FoPT table. ERA's DMR-QA 40 study standards were examined for any anomalies. A full review of all homogeneity, stability and accuracy verification data was completed. All analytical verification data for all analytes met the acceptance criteria contained in the 2009 TNI Standard and the criteria contained in the most current TNI/NELAP FoPT table. All analytes are included in ERA's A2LA accreditation, certification number 1539.01. All activities associated with this proficiency testing study were performed by Waters/ERA with the exception of those noted below. The following physical samples/products were manufactured for Waters/ERA by a subcontractor: Microbiology products with the following catalog numbers: 880, 935, 079, 077, 080, 595, 595A, 576, 576A Acceptable = Reported Value falls within the Acceptance Limits. Not Acceptable = Reported Value falls outside the Acceptance Limits. No Evaluation = Reported Value cannot be evaluated. Not Reported = No Value reported. The Method Description is the method the laboratory reported to ERA. The data submitted by participating laboratories was also examined for study anomalies. There were no anomalies observed during the statistical review of the data. ERA's DMR-QA 40 study reports shall not be reproduced except in their entirety and not without the permission of the participating laboratories. The report must not be used by the participating laboratories to claim product endorsement by any agency of the U. S. government. The data contained herein are confidential and intended for your use only. If you have any questions or concerns regarding your assessment in ERA's DMRQA Proficiency Testing program, please contact our Proficiency Testing Department at 1-800372-0122. Study # : DMR-QA 40 Attachment C, page 29 Ver. 1 Page 4 of 18 Gabriel Performance Products Inspection Report Study: DMR-QA 40 NPDES Permit #: OH0029149 Laboratory Name: Gabriel Performance Products Inorganic Results This report is scored by the criteria in the 2016 TNI Standard, Volume 3, instead of by the criteria in the 2009 TNI Standard to which the Proficiency Testing Provider is accredited. This is a planned change and is endorsed by the TNI Proficiency Testing Program Executive Committee for transition to the 2016 TNI Standard. 16341 Table Mountain Pkwy Golden, CO 80403 800.372.0122 303.431.8454 fax 303.421.0159 www.eraqc.com Study # : DMR-QA 40 Attachment C, page 30 Ver. 1 Page 5 of 18 Gabriel Performance Products Inspection Report DMR-QA 40 Final Report NPDES Permit #: OH0029149 Permit Holder: Kenna Coltman Gabriel Performance Products 725 State Road Ashtabula, OH 44004 ERA Customer Number: G234480 Report Issued: 10/16/20 Study Dates: 03/20/20 - 09/18/20 TNI Analyte Code Analyte Units Performance Evaluation WP Minerals (cat# 581, lot# P301-506) 1955 Total Dissolved Solids at 180C mg/L Acceptable WP Hardness (cat# 580, lot# P301-507) 1960 Total Suspended Solids mg/L Acceptable DMRQA pH (cat# 577, lot# Q040-977) 1900 pH S.U. Acceptable WP Demand (cat# 578, lot# P301-516) 1530 BOD 1555 CBOD mg/L mg/L Acceptable Acceptable WP Oil & Grease (cat# 582, lot# P301-518) 1803 n-Hexane Extractable Material(O&G)(Grav) mg/L Acceptable WP Trace Metals (cat# 586, lot# P301-500) 1040 Chromium 1055 Copper 1075 Lead 1105 Nickel 1190 Zinc g/L Acceptable g/L Acceptable g/L Acceptable g/L Acceptable g/L Acceptable DMRQA Low-Level Total Residual Chlorine (cat# 881, lot# Q040-917) 1940 Low Level Total Residual Chlorine g/L Acceptable Reported Value 300 26 6.32 42.5 36.0 110 510 698 527 1820 1390 40 Assigned Value Acceptance Method Description Study Mean Limits Study Standard Deviation USEPA Lab Code 309 264 - 354 SM2540C online 299 19.4 OH00232 27.6 19.0 - 33.4 SM2540D online 25.6 1.53 OH00232 6.30 6.10 - 6.50 EPA 9040C 2004 6.31 0.0607 OH01205 33.2 30.1 16.7 - 49.7 12.5 - 47.7 SM5210B online SM5210B online 32.9 30.5 5.81 OH00232 6.60 OH00232 132 95.8 - 151 EPA 1664A 1999 127 6.91 OH00232 502 658 518 1760 1360 427 - 577 559 - 757 440 - 596 1560 - 1970 1160 - 1560 EPA 200.7 4.4 1994 EPA 200.7 4.4 1994 EPA 200.7 4.4 1994 EPA 200.7 4.4 1994 EPA 200.7 4.4 1994 509 661 524 1780 1370 28.9 OH00232 39.1 OH00232 31.5 OH00232 111 OH00232 94.2 OH00232 79.0 19.0 - 139 SM 450200-C11l G-2011 80.9 15.3 OH01205 Study WP301 WP301 DMRQA40 WP301 WP301 WP301 WP301 WP301 WP301 WP301 WP301 DMRQA40 This report is scored by the criteria in the 2016 TNI Standard, Volume 3, instead of by the criteria in the 2009 TNI Standard to which the Proficiency Testing Provider is accredited. This is a planned change and is endorsed by the TNI Proficiency Testing Program Executive Committee for transition to the 2016 TNI Standard. 16341 Table Mountain Pkwy Golden, CO 80403 800.372.0122 303.431.8454 fax 303.421.0159 www.eraqc.com Study # : DMR-QA 40 Attachment C, page 31 Ver. 1 Page 6 of 18 Gabriel Performance Products Inspection Report Study: DMR-QA 40 NPDES Permit #: OH0029149 Laboratory Name: Gabriel Performance Products WET Results This report is scored by the criteria in the 2016 TNI Standard, Volume 3, instead of by the criteria in the 2009 TNI Standard to which the Proficiency Testing Provider is accredited. This is a planned change and is endorsed by the TNI Proficiency Testing Program Executive Committee for transition to the 2016 TNI Standard. 16341 Table Mountain Pkwy Golden, CO 80403 800.372.0122 303.431.8454 fax 303.421.0159 www.eraqc.com Study # : DMR-QA 40 Attachment C, page 32 Ver. 1 Page 7 of 18 Gabriel Performance Products Inspection Report DMR-QA 40 Final Report NPDES Permit #: OH0029149 Permit Holder: Kenna Coltman Gabriel Performance Products 725 State Road Ashtabula, OH 44004 ERA Customer Number: G234480 Report Issued: 10/16/20 Study Dates: 03/20/20 - 09/18/20 Analyte Code Test End Point Performance Evaluation DMRWet Fathead minnow (Test Code 13) (cat# WET002, lot# Q040-002) 48Hr., Acute, Non-Renewal, 25 C, MHSF Potassium chloride 0754 LC50 Acceptable DMRWet Fathead minnow (Test Code 16) (cat# WET005, lot# Q040-005) 7-day Chronic, Daily Renewal, 20% DMW Potassium chloride 0812 IC25 (ON) Growth Acceptable 0814 NOEC (ON) Growth Acceptable 0759 NOEC Survival Acceptable DMRWet Ceriodaphnia dubia (Test Code 19) (cat# WET008, lot# Q040-008) 48-Hr Acute, Nonrenewal, 25 C, MHSF Potassium chloride 0764 LC50 Acceptable DMRWet Ceriodaphnia dubia (Test Code 21) (cat# WET010, lot# Q040-010) 3-Brood Chronic, Daily Renewal, MHSF Potassium chloride 0767 IC25 Reproduction Acceptable 0768 NOEC Reproduction Acceptable 0766 NOEC Survival Acceptable DMRWet Daphnia magna (Test Code 32) (cat# WET012, lot# Q040-012) 48Hr., Acute, Non-Renewal, 25 C, MHSF Potassium chloride 0788 LC50 Acceptable Reported Value % 65.98 60.46 50 50 25.88 27.06 12.5 50 55.48 Assigned Value % Acceptance Method Description Study Mean Limits % Study Standard Deviation USEPA Lab Code 53.2 28.1 - 78.4 EPA 2000.0 MHSF 25 deg C 5th ED 2002 53.2 12.6 OH01191 46.8 50.0 25.0 24.5 - 69.1 25.0 - 100 12.5 - 50.0 EPA 1000.0 DMW 2002 EPA 1000.0 DMW 2002 EPA 1000.0 DMW 2002 46.8 11.2 OH01191 OH01191 OH01191 37.9 13.7 - 62.2 EPA 2002.0 MHSF 25 deg C 5th ED 2002 37.9 12.1 OH01191 29.4 25.0 25.0 22.7 - 36.2 12.5 - 50.0 12.5 - 50.0 EPA 1002.0 MHSF 2002 EPA 1002.0 MHSF 2002 EPA 1002.0 MHSF 2002 29.4 3.37 OH01191 OH01191 OH01191 36.8 9.58 - 64.1 EPA 2021.0 MHSF 20 deg C 5th ED 2002 36.8 13.6 OH01191 Study DMRWet40 DMRWet40 DMRWet40 DMRWet40 DMRWet40 DMRWet40 DMRWet40 DMRWet40 DMRWet40 This report is scored by the criteria in the 2016 TNI Standard, Volume 3, instead of by the criteria in the 2009 TNI Standard to which the Proficiency Testing Provider is accredited. This is a planned change and is endorsed by the TNI Proficiency Testing Program Executive Committee for transition to the 2016 TNI Standard. 16341 Table Mountain Pkwy Golden, CO 80403 800.372.0122 303.431.8454 fax 303.421.0159 www.eraqc.com Study # : DMR-QA 40 Attachment C, page 33 USEPA DMR-QA 40 Ver. 1 Page 8 of 18 Gabriel Performance Products Inspection Report NPDES PERMITTEE DATA REPORT FORM Due November 20, 2020 USEPA NPDES Permit #: OH0029149 Permittee Name: Gabriel Performance Products Permit Ext: Facility Address: 725 State Road City: Ashtabula Phone Number: - - E-mail address: kenna.coltman@gabrielchem.com State: OH Postal Code: 44004 - Fax Number: - - Optional: If WP study was used, list PT provider name: Environmental Resource Associates Optional: WP study number(s): WP-301 For DMRQA-40, conducted in 2020, the Permittee ensured that their laboratory(s) performing the required analyses: Received PT Samples Submitted Complete and Accurate Data by September 18, 2020 Received a Graded Report by October 16, 2020 Yes No Yes No Yes No Certification by Permit Holder or Authorized Representative (as per 40 C.F.R. Section 122.22) I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate and complete. Each reported value was produced from a single analytical run using the analytical system that rountinely performs these analyses to produce compliance monitoring data required under our National Pollutant Discharge Elimination System (NPDES) Permit. Neither I nor any of my subordinates compared our results from independent analyses conducted by us or any other laboratory before we reported our results to the USEPA. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Name of Certifying Official: Kenna Coltman Title: Signature: Mailing Address: 725 State Road (enter only if different from address above) City: Ashtabula Phone Number: - - Please make corrections in boxes above Date Signed: / / State: OH Postal Code: 44004 - E-mail address: kenna.coltman@gabrielchem.com Attachment C, page 34 Ver. 1 Page 9 of 18 Gabriel Performance Products Inspection Report United States ENVIRONMENTAL PROTECTION AGENCY Laboratory Performance Evaluation Laboratory DMR-QA Evaluation Study 40 USEPA NPDES Permit #: OH0029149 Permit Ext: Identification of all CHEM, MICRO and TOX laboratories who did analyses for this permit Lab Analysis Name of Laboratory Address of Laboratory U.S. EPA Lab Code Check box(es) that apply CHEM MICRO TOX Lab Type* Statecertified Lab** EA Group 7118 Industrial Park Blvd Mentor,OH 44060 OH00232 Enviroscience Inc 5070 Stow Rd Stow,OH 44224 OH01191 Gabriel Performance Products 725 State Road Ashtabula,OH 44004 OH01205 * Lab Types: C = Commercial F = Federal G = Local Government ** See Footnote 2 on DMRQA-40, Frequently Asked Questions page I = Industrial O = Other S = State Attachment C, page 35 Permittee Name: Gabriel Performance Products Ver. 1 Page 10 of 18 Gabriel Performance Products Inspection Report Permit Number: OH0029149 EPA Lab Code: OH00232 Analyte Test / Method Minerals Alkalinity as CaCO3 Chloride Conductivity at 25C Fluoride Potassium Sodium Sulfate Total Dissolved Solids at 180C SM2540C Total Solids at 105C Hardness Total Suspended Solids SM2540D Calcium Magnesium Calcium Hardness as CaCO3 Total Hardness as CaCO3 pH pH Settleable Solids Settleable Solids Solids Concentrate Total Suspended Solids Total Dissolved Solids at 180C Total Solids at 105C Solids Total Suspended Solids Total Dissolved Solids at 180C Total Solids at 105C Simple Nutrients Ammonia as N Nitrate + Nitrite as N Nitrate as N ortho-Phosphate as P Complex Nutrients Total Kjeldahl Nitrogen Total phosphorus as P Nitrite Nitrite as N Demand BOD SM5210B Chemistry/Microbiology Analyte Checklist WP Study 301 Laboratory's Graded Result Test Required Acceptable Not Acceptable (Corrective Action Required) Analyte determined by state-certified lab o x o o o x o o o x o o Attachment C, page 36 Permittee Name: Gabriel Performance Products Ver. 1 Page 11 of 18 Gabriel Performance Products Inspection Report Permit Number: OH0029149 EPA Lab Code: OH00232 Analyte Test / Method CBOD SM5210B COD TOC Oil & Grease Concentrate n-Hexane Extractable Material(O&G) (Grav) Oil & Grease n-Hexane Extractable Material(O&G) (Grav) EPA 1664A n-Hexane Extractable Material(O&G) (IR) Trace Metals Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Chromium EPA 200.7 Cobalt Copper EPA 200.7 Iron Lead EPA 200.7 Manganese Molybdenum Nickel EPA 200.7 Selenium Silver Strontium Thallium Vanadium Zinc EPA 200.7 Mercury Mercury Low-Level Mercury Low Level Mercury Chemistry/Microbiology Analyte Checklist WP Study 301 Laboratory's Graded Result Test Required Acceptable Not Acceptable (Corrective Action Required) o x o Analyte determined by state-certified lab o o x o o o x o o o x o o o x o o o x o o o x o o Attachment C, page 37 Permittee Name: Gabriel Performance Products Ver. 1 Page 12 of 18 Gabriel Performance Products Inspection Report Permit Number: OH0029149 EPA Lab Code: OH00232 Analyte Test / Method Hexavalent Chromium Hexavalent Chromium Turbidity Turbidity Total Cyanide Cyanide, total Amenable Cyanide Total Phenolics (4-AAP) Phenolics, total Total Residual Chlorine Free Residual Chlorine Total Residual Chlorine Low-Level Total Residual Chlorine Low Level Total Residual Chlorine WasteWatRTM Coliform MicrobETM Total Coliforms (MF) Fecal Coliforms (MF) E.coli (MF) Total Coliforms (MPN) Fecal Coliforms (MPN) E.coli (MPN) WasteWatRTM Coliform MicrobETM - SM 9221 Total Coliforms (MPN) Fecal Coliforms (MPN) E.coli (MPN) Chemistry/Microbiology Analyte Checklist WP Study 301 Laboratory's Graded Result Test Required Acceptable Not Acceptable (Corrective Action Required) Analyte determined by state-certified lab Print Name Signature/Title Date Use a separate checklist for EACH lab used Attachment C, page 38 Permittee Name: Gabriel Performance Products Ver. 1 Page 13 of 18 Gabriel Performance Products Inspection Report Permit Number: OH0029149 EPA Lab Code: OH01191 WET Organisms/Test Conditions/End Points Checklist DMRWet Study 40 Laboratory's Graded Result Analyte Number Organisms / Conditions Fathead minnow (Test Code 13) 0754 48Hr., Acute, Non-Renewal, 25 C, MHSF End Points LC50 Test Req Acceptable Not Acceptable (Corrective Action Required) EPA 2000.0 MHSF 25 deg C Fathead minnow (Test Code 14) 0755 48Hr., Acute, Non-Renewal, 25 C, 20% DMW LC50 o x o Fathead minnow (Test Code 15) 0808 7-day Chronic, Daily Renewal, MHSF 0810 7-day Chronic, Daily Renewal, MHSF 0756 7-day Chronic, Daily Renewal, MHSF IC25 (ON) Growth NOEC (ON) Growth NOEC Survival Fathead minnow (Test Code 16) 0812 7-day Chronic, Daily Renewal, 20% DMW 0814 EPA 1000.0 DMW 7-day Chronic, Daily Renewal, 20% DMW 0759 EPA 1000.0 DMW 7-day Chronic, Daily Renewal, 20% DMW IC25 (ON) Growth o x o NOEC (ON) Growth o x o NOEC Survival EPA 1000.0 DMW Ceriodaphnia dubia (Test Code 19) 0764 48-Hr Acute, Nonrenewal, 25 C, MHSF LC50 o x o EPA 2002.0 MHSF 25 deg C Ceriodaphnia dubia (Test Code 20) 0765 48-Hr Acute, Nonrenewal, 25 C, 20% DMW LC50 o x o Ceriodaphnia dubia (Test Code 21) 0767 3-Brood Chronic, Daily Renewal, MHSF 0768 EPA 1002.0 MHSF 3-Brood Chronic, Daily Renewal, MHSF 0766 EPA 1002.0 MHSF 3-Brood Chronic, Daily Renewal, MHSF IC25 Reproduction o x o NOEC Reproduction o x o NOEC Survival EPA 1002.0 MHSF Ceriodaphnia dubia (Test Code 22) 0770 3-Brood Chronic, Daily Renewal, 20% DMW 0771 3-Brood Chronic, Daily Renewal, 20% DMW 0769 3-Brood Chronic, Daily Renewal, 20% DMW o x o IC25 Reproduction NOEC Reproduction NOEC Survival Daphnia magna (Test Code 32) 0788 48Hr., Acute, Non-Renewal, 25 C, MHSF LC50 EPA 2021.0 MHSF 20 deg C o x o Analyte determined by state-certified lab o o o o o o o o o Attachment C, page 39 Permittee Name: Gabriel Performance Products Ver. 1 Page 14 of 18 Gabriel Performance Products Inspection Report Permit Number: OH0029149 EPA Lab Code: OH01191 WET Organisms/Test Conditions/End Points Checklist DMRWet Study 40 Laboratory's Graded Result Analyte Number Organisms / Conditions Daphnia pulex (Test Code 38) 0794 48Hr., Acute, Non-Renewal, 25 C, MHSF End Points LC50 Test Req Acceptable Not Acceptable (Corrective Action Required) Mysid (Test Code 42) 0798 48-Hr Acute, Nonrenewal, 25 C, SSW LC50 Mysid (Test Code 43) 0816 7-day Chronic, Daily Renewal, SSW 0818 7-day Chronic, Daily Renewal, SSW 0799 7-day Chronic, Daily Renewal, SSW IC25 (ON) Growth NOEC (ON) Growth NOEC Survival Inland silverside (Test Code 44) 0803 48-Hr Acute, Nonrenewal, 25 C, SSW LC50 Inland Silverside (Test Code 45) 0825 7-day Chronic, Daily Renewal, SSW 0826 7-day Chronic, Daily Renewal, SSW 0824 7-day Chronic, Daily Renewal, SSW IC25 (ON) Growth NOEC (ON) Growth NOEC Survival Sheepshead minnow (Test Code 46) 0804 48-Hr Acute, Nonrenewal, 25 C, SSW LC50 Sheepshead minnow (Test Code 47) 0820 7-day Chronic, Daily Renewal, SSW 0822 7-day Chronic, Daily Renewal, SSW 0805 7-day Chronic, Daily Renewal, SSW IC25 (ON) Growth NOEC (ON) Growth NOEC Survival Analyte determined by state-certified lab Print Name Signature/Title Date Use a separate checklist for EACH lab used Attachment C, page 40 Permittee Name: Gabriel Performance Products Ver. 1 Page 15 of 18 Gabriel Performance Products Inspection Report Permit Number: OH0029149 EPA Lab Code: OH01205 Analyte Test / Method Minerals Alkalinity as CaCO3 Chloride Conductivity at 25C Fluoride Potassium Sodium Sulfate Total Dissolved Solids at 180C Total Solids at 105C Hardness Total Suspended Solids Calcium Magnesium Calcium Hardness as CaCO3 Total Hardness as CaCO3 pH pH EPA 9040C Settleable Solids Settleable Solids Solids Concentrate Total Suspended Solids Total Dissolved Solids at 180C Total Solids at 105C Solids Total Suspended Solids Total Dissolved Solids at 180C Total Solids at 105C Simple Nutrients Ammonia as N Nitrate + Nitrite as N Nitrate as N ortho-Phosphate as P Complex Nutrients Total Kjeldahl Nitrogen Total phosphorus as P Nitrite Nitrite as N Demand BOD CBOD COD TOC Chemistry/Microbiology Analyte Checklist DMRQA Study 40 Laboratory's Graded Result Test Required Acceptable Not Acceptable (Corrective Action Required) Analyte determined by state-certified lab o x o o Attachment C, page 41 Permittee Name: Gabriel Performance Products Ver. 1 Page 16 of 18 Gabriel Performance Products Inspection Report Permit Number: OH0029149 EPA Lab Code: OH01205 Analyte Test / Method Oil & Grease Concentrate n-Hexane Extractable Material(O&G) (Grav) Oil & Grease n-Hexane Extractable Material(O&G) (Grav) n-Hexane Extractable Material(O&G) (IR) Trace Metals Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Chromium Cobalt Copper Iron Lead Manganese Molybdenum Nickel Selenium Silver Strontium Thallium Vanadium Zinc Mercury Mercury Low-Level Mercury Low Level Mercury Hexavalent Chromium Hexavalent Chromium Turbidity Turbidity Total Cyanide Cyanide, total Amenable Cyanide Total Phenolics (4-AAP) Phenolics, total Chemistry/Microbiology Analyte Checklist DMRQA Study 40 Laboratory's Graded Result Test Required Acceptable Not Acceptable (Corrective Action Required) Analyte determined by state-certified lab Attachment C, page 42 Permittee Name: Gabriel Performance Products Ver. 1 Page 17 of 18 Gabriel Performance Products Inspection Report Permit Number: OH0029149 EPA Lab Code: OH01205 Analyte Test / Method Total Residual Chlorine Free Residual Chlorine Total Residual Chlorine Low-Level Total Residual Chlorine Low Level Total Residual Chlorine SM 4500-Cl G-2011 WasteWatRTM Coliform MicrobETM Total Coliforms (MF) Fecal Coliforms (MF) E.coli (MF) Total Coliforms (MPN) Fecal Coliforms (MPN) E.coli (MPN) WasteWatRTM Coliform MicrobETM - SM 9221 Total Coliforms (MPN) Fecal Coliforms (MPN) E.coli (MPN) Chemistry/Microbiology Analyte Checklist DMRQA Study 40 Laboratory's Graded Result Test Required Acceptable Not Acceptable (Corrective Action Required) o x o Analyte determined by state-certified lab o Print Name Signature/Title Date Use a separate checklist for EACH lab used Attachment C, page 43 Ver. 1 Page 18 of 18 Gabriel Performance Products Inspection Report CERTIFICATE OF RECOGNITION ERA congratulates GABRIEL PERFORMANCE PRODUCTS for your participation and successful evaluation in DMR-QA 40. We recognize the performance of this laboratory for achieving acceptable evaluations for the following analytes. Low Level Total Residual pH Chlorine Matthew Seebeck Quality Officer G234480 Attachment C, page 44 Gabriel Performance Products Inspection Report MDL Study Initial MDL (For Annual Verification and new methods only) Method: 480A Instrument: HACH DR 300 Analyte: Residual Chlorine Dates of Study: 7/8/2020, 7/9/2020, 7/10/2020 Spike Level:0.275 Analyte Units : mg/L g/L ng/L Revised MDL Aqueous Solid Spike No. Spike 1 Spike 2 Spike 3 Spike 4 Spike 5 Spike 6 Spike 7 Spike 8 Spike 9 Spike 10 Spike 11 RESULTS 0.25 0.25 0.23 0.2 0.22 0.23 0.21 0.2 0.21 0.26 0.23 Blank No. Blank 1 Blank 2 Blank 3 Blank 4 Blank 5 Blank 6 Blank 7 Blank 8 Blank 9 Blank 10 Blank 11 RESULTS 0 0 0 0 0 0 0 0 0 0 0 PREP BATCH ID PREP DATE ANALYST ANALYSIS BATCH ID NA NA NA NA NA NA NA NA NA NA NA ANALYSIS DATE 7/8/2020 7/8/2020 7/8/2020 7/8/2020 7/9/2020 7/9/2020 7/9/2020 7/9/2020 7/10/2020 7/10/2020 7/10/2020 ANALYST MC JS RL LM MC JS RL LM MC JS LM Spike Avg SD 0.226 0.021 Blank Avg SD 0.00000 0.00000 Student's t-value MDLS PQL 2.76400 0.057 Student's t-value MDLB 0.1140 2.76400 0.00000 Notes: -A minimum of 7 blanks and spikes, prepped and analyzed across 3 calendar days are required. -Add rows to spreadsheet if number of spikes and blanks is > 10. Also, use t-values for n > 10 found in SOP 5019. Make sure to update sheet and calculations according to number of replicates; calculations default to a max of 10 spikes/blanks only -Record all numerical values. If any spike is 0, MDL study must be re-run. If blanks are all 'ND', MDLb calculation does not apply -MDLspike MUST be less than spike level; if not re-run study at different spike level -A negative average for blanks means that MDLb does not apply. -If blanks are a combination of 'ND' and numerical results, set MDLb to highest blank value. -Ensure that PQL is at least 2x MDL and any regulatory requirement is met Comments: Supervisor Approval Signature: QA Review Only: Date: Page 1 of 1 Revised: 2/11/2020 Attachment C, page 45 Doc. No. EHSS-037A.7 Effective Date: 02/22/2021 Supersedes: EHSS-037A.6 Supersedes Date: 11/18/2020 Subject: Gabriel Performance Products Inspection Report Effluent Log Sheet Approved By: EHS Department DATE: ___________________________ SANITARY SYSTEM: OPERATORS SIGNATURES : TIME : 0700 1300 1900 Everyday 0100 EVERY MONDAY: Clean weeds & solids from unused bed, then switch flow to unused bed. Circle bed in service: EAST / WEST Change Blower in service (turn one that is running off, turn other on). Circle blower in service: NORTH / SOUTH EVERY MONDAY: Record the secondary dosing pump hour reading Prev. Day Today Difference EVERY DAY RECORD PRIMARY DOSING PUMP HOUR READING COLOR, ODOR, TURBIDITY & TR CHLORINE SCREEN AT DISCHARGE C,O,T: TR Chlorine: CLEAN SAMPLE COLLECTION BOTTLE DAILY, AND DISCHARGE FLUE AS NECESSARY CHECK CHLORINATOR - TABLETS PRESENT AND FEEDING PROPERLY SAMPLE AERATOR ALKALINITY M,W,F (units: mg/l CaCO3) Mon, Wed and Fri Sodium bicarb addition at aerator & lab sink: If Alkalinity is <150 add 2lb/shift / If Alkalinity is <200 add 1lb/shift BOILER CHECKS Weekly checks are to be performed every Monday on Night Shift Operator Time Montly Checks to be performed first Monday Night Shift of the Month EFFLUENT SYSTEM TAKE 1 pt. GRAB SAMPLES FOR LAB & RECORD: WEST PIT OUTLET Appearance WEST PIT OUTLET Color WEST PIT OUTLET Odor OUTLET FROM CARBON BEDS pH *Lab-tested pH must be between 6.5 and 9.0SU* Operator Time IF lab-tested pH is out of spec - confirm that the system is in RECIRC OUTLET FROM CARBON BEDS TRCl (Must be <0.04 mg/l) OUTLET FROM CARBON BEDS COND NORTH RAIN SUMP Appearance NORTH RAIN SUMP Color NORTH RAIN SUMP Odor T-97 ("New" HCL Tank ) ACID TANK LEVEL (GALS.) P-304 NORTH POND PUMP NORTH POND LEVEL NORTH POND UNDERDRAIN HOUR READING (2 X PER WEEK) SOUTH POND LEVEL SOUTH POND UNDERDRAIN HOUR READING (2 X PER WEEK) NORTH RAIN SUMP PH READING NORTH RAIN VISUAL CHECK B/South sump level is below inlet line & overflow screen is clear STORM WATER RETENTION BASIN LEVEL ACCUM / DISCH (circle) FINAL DISCHARGE FLOW (GPM) (Should be <225 GPM) FINAL DISCHARGE TEMP SAMPLE PLANT DISCHARGE AT ~0730 HR'S CLEAN FINAL SAMPLE JUG daily after EHS collects samples (1st shift) FINAL AUTOSAMPLER "STANDBY"(ACCUM) FINAL AUTOSAMPLER "PROGRAM RUNNING" (DISCHARGE) TEMP IN SAMPLE JUG REFRIG. (ADJUST IF < 2 OR >7C) FINAL SAMPLE JUG LEVEL (GALS.) * Note that totalizer resets at 10,000. If (B) < (A), then Difference = 10,000 - (A) + (B): RECORD TOTALIZER READING (Daily) Page 1 of 4 Readings on Mon. and on Fri. Readings on Mon. and on Fri. Prev Day (A) Today (B) Difference (B)-(A)* 7/21/20213:01 PM Attachment C, page 46 Gabriel Performance Products Inspection Report Doc. No. EHSS-037A.7 Effective Date: 02/22/2021 Supersedes: EHSS-037A.6 Supersedes Date: 11/18/2020 Subject: Effluent Log Sheet Approved By: EHS Department DATE: ___________________________ OPERATORS SIGNATURES : TIME : SAND FILTERS: P-301 DISCHARGE PRESSURE P-302 DISCHARGE PRESSURE (WHEN IN SERVICE) P-303 DISCHARGE PRESSURE (WHEN IN SERVICE) SAND FILTER INLET PRESS SAND FILTER OUTLET PRESS CARBON BEDS: INLET PRESS CARBON BED-A OUTLET PRESS CARBON BED-A INLET PRESS CARBON BED-B OUTLET PRESS CARBON BED-B FIRST DAY OF EACH MONTH DO VITAL EQUIPMENT CHECKLIST (EHSS-037D) 0700 1300 1900 0100 DAILY ON DAY SHIFT : CHECK FOR LEAKS, CONDITION OF AREA +THAT DRAINS ARE CLOSED (BB/CC RQTS) DIKE # Tanks Note A > Tank Pump Lines Areas Near Dike #1 T38, 39, 40 & 82 #2 T-44, 86, 61, 220 #3 T-57,77,79,85,94,96 #4 T- 62,78,80,81,88,92 #5 T-66,67,70,90,91 #6 T-1, 2 #7 T-87 #8 Distallation Column T-8 T-87 T-41 T-93 ACID FRAC TANKS T-41, T-95 T-93 T97 NOTE: PLEASE LIST BELOW >Note A- DAILY ON DAY SHIFT, SAMPLE AND PUMP DRY IF NEEDED (see legend below). Complete Containment Log (EHSS-037C) accordingly. LEGEND: "D" = DRY "P" = PRECIPITATION "S&PD" = SAMPLED& PUMPED DRY NOTE B: ANY ISSUE, LEAK OR PROBLEM WITH ANY PIECE OF EQUIPMENT ABOVE MUST BE REPORTED IMMEDIATELY TO THE SHIFT SUPERVISOR AND EHS PERSONNEL. EVERY WEDENSDAY - EMPTY FUNDABAC HOPPER TOWMOTORS: #33 & 34 COMPLETE INSPECTION SHEET (EHSS-032A) PLANT HOIST SHEETS: ALL HOISTS PLANT HOISTS CHECK LISTS AREAS I AND IV MONDAY COLLECT INSPECTION SHEETS, SUBMIT TO EHS, & INSTALL NEW ONES Wednesdays Everyday Mondays Page 2 of 4 7/21/20213:01 PM Doc. No. EHSAtStac-h0m3e7ntAC.,7page 47 Effective Date: 02/22/2021 Supersedes: EHSS-037A.6 Supersedes Date: 11/18/2020 Subject: Gabriel Performance Products Inspection Report Effluent Log Sheet Approved By: EHS Department DATE: ___________________________ OPERATORS SIGNATURES : TIME : GENERAL PLANT & SECURITY CHECKS: RCRA HEATED AREA WAREHOUSE INCLUDING C BUILDING IT Room Secured (confirm locked/secure) Gates & Guard House Secured (confirm locked/secure) DCS Room Secured (confirm locked/secure) H2S Rail Cars Secured (confirm locked derailer is secure) Every Monday 'Inspect: Showers/Eye washes Sign off on tag for both eye wash and safety shower Effluent ES4 Boiler House ES7 Sulfuric Acid Mini-Bulk ES23 0700 1300 1900 0100 Mondays Mondays Mondays ASHCO WATER: RECORD TOTALIZER READING ON DAY SHIFT COOLING TOWERS: RECORD CTW TEMP C INSPECT TRAYS/AREA/TOWERS COOLING PUMPS: A. STARTUP CTW PUMP A-II-4 THAT IS DOWN & PUT ONLINE. B. SHUT DOWN & TAKE OTHER PUMP OFF LINE. HAYWARD STRAINER: ONE TIME PER SHIFT: MANUALLY BACKWASH Note: Notify foreman if Hayward is"Off line" MISCELLANEOUS CHECKS: TANKAGE FOR LEAKS RAILROAD CARS FOR LEAKS ROOF INSPECTION-REPORT ISSUES TO FOREMAN ASAP RECORD LEVEL IN NORTH FAT TRAP RECORD LEVEL IN SOUTH FAT TRAP CHECK AREA V SUMP Saturdays on Day Shift Saturdays on Day Shift COLD WEATHER CHECKLIST: DO LIST 2 TIMES PER SHIFT WHEN EVER TEMP. IS BELOW 33o F IF ANY ANSWER BELOW IS NO, CONTACT FOREMAN/ENGINEERING IMMEDIATELY NOTE: T-2: Napthalene - Freezing Point of 85C IS THE RECIRC. PUMP PUMPING? YES NO 0700 1300 1900 0100 IS THERE A LEVEL IN THE PUMP SEAL POT? YES NO IS THE TEMPERATURE at ~100C? YES NO T-87 (HRI-1) TANK TEMP. / Pump Seal Pot C C C C CHECK 3 TIMES PER SHIFT TIME TEMP. Seal Pot SeaPl Pot Level 0700 HR'S 1100 HR'S C C # # 1500 HR'S C # 1900 HR'S C # 2400 HR'S 0400 HR'S C C # # NOTE: IF TEMP OF T-87 IS NOT 70 - 75 C : NOTIFY THE HRI OPERATOR - DO NOT TRY TO ADJUST TEMP. HOT BOXES CHECK ON DAY SHIFT TIME #1 TEMP #2 TEMP #3 TEMP 0700 HR'S 1100 HR'S C C C C C C 1900 HR'S C C Page 3 of 4 C 0100 HR'S C C C T-96 mesurements 0700 hrs 1300 hrs pH pH 1900 h7r/s21/20021030:0h1rPsM Attachment C, page 48 Gabriel Performance Products Inspection Report Doc. No. EHSS-037A.7 Effective Date: 02/22/2021 Supersedes: EHSS-037A.6 Supersedes Date: 11/18/2020 Subject: Effluent Log Sheet Approved By: EHS Department DATE: ___________________________ MELT ROOM C OPERATORS SIGNATURES : TIME : C C 0700 C 1300 1900 pH 0100 pH Page 4 of 4 7/21/20213:01 PM Attachment C, page 49 Bottle Quantity Bottle Volume Tubing length Intake Tubing type Program Delay Sample Collection Flow Source Select Unit Map 4 ma Input Map 20 ma Input Take sample every Override Time Take First sample Run Mode Liquid Sensor Sample Volume Intake rinses Sample entries Site ID Adv Sampling Auto Sampler Parameters 1 5.2 gals 14 foot 3/8" Vinyl Disable Flow based 4-20 ma Input gpm 0.00 gpm 500.00 gpm 12,000 gal Disable Immediately Continuous Enable 300 ml 1 2 000000000001 No Gabriel Performance Products Inspection Report Attachment D, page 1 Gabriel Performance Products Inspection Report Attachment D: Photo Log Gabriel Performance Products EPA Inspection July 13, 2021 All photos taken by Dean Maraldo, Inspector, U.S. EPA Camera: Ricoh-WG4 1: GPPI0001 Description: Sanitary sewer package plant. View of aeration tank. Location: Sanitary Sewer Treatment System; NE quadrant of Facility Camera Direction: 160 Date/Time: July 13, 2021; 1:10 p.m. Attachment D, page 2 Gabriel Performance Products Inspection Report 2: GPPI0002 Description: Sanitary sewer package plant. View of aeration tank (center) and clarifier (top). Location: Sanitary Sewer Treatment System; NE quadrant of Facility Camera Direction: 40 Date/Time: July 13, 2021; 1:13 p.m. 3: GPPI0003 Description: Sanitary sewer pump vault. Location: Sanitary Sewer Treatment System; NE quadrant of Facility Camera Direction: 200 Date/Time: July 13, 2021; 1:20 p.m. Attachment D, page 3 Gabriel Performance Products Inspection Report 4: GPPI0004 Description: View of sand filter. Location: Sanitary Sewer Treatment System; NE quadrant of Facility Camera Direction: 316 Date/Time: July 13, 2021; 1:21 p.m. 5: GPPI0005 Description: Chlorine station vault, with two chlorine feeders in the center. Location: Sanitary Sewer Treatment System; NE quadrant of Facility Camera Direction: 272 Date/Time: July 13, 2021; 1:42 p.m. Attachment D, page 4 Gabriel Performance Products Inspection Report 6: GPPI0006 Description: Chlorine station vault. Sample of the effluent after the chlorine tablets feeders. Note small white particles (outlined in red) in the bottom of the sampler. Location: Sanitary Sewer Treatment System; NE quadrant of Facility Camera Direction: 96 Date/Time: July 13, 2021; 1:47 p.m. Attachment D, page 5 Gabriel Performance Products Inspection Report 7: GPPI0007 Description: North Rain Sump. Location: SE quadrant of Facility Camera Direction: 126 Date/Time: July 13, 2021; 1:56 p.m. 8: GPPI0008 Description: Effluent Building. Note low-profile air stripper behind Bisco control panel (center), carbon beds (2) on the right, and a multimedia filter on the left. The second multimedia filter is not captured in the photo. Location: Outfall 001 Treatment System. SE quadrant of Facility Camera Direction: 186 Date/Time: July 13, 2021; 1:58 p.m. Attachment D, page 6 Gabriel Performance Products Inspection Report 9: GPPI0009 Description: Multimedia filters (2) in the Effluent Building. Location: Outfall 001 Treatment System. SE quadrant of Facility Camera Direction: 155 Date/Time: July 13, 2021; 2:00 p.m. 10: GPPI0010 Description: Carbon Beds (2) in the Effluent Building. Location: Outfall 001 Treatment System. SE quadrant of Facility Camera Direction: 232 Date/Time: July 13, 2021; 2:00 p.m. Attachment D, page 7 Gabriel Performance Products Inspection Report 11: GPPI0011 Description: Inside of effluent composite sampler in the Effluent Building. Note heavy staining/debris on inside walls of sample tubing. Location: Outfall 001 Treatment System. SE quadrant of Facility Camera Direction: 271 Date/Time: July 13, 2021; 2:02 p.m. 12: GPPI0012 Description: South equalization pond. Note algae on surface of the pond. Location: Outfall 001 Treatment System. SW quadrant of Facility Camera Direction: 256 Date/Time: July 13, 2021; 2:14 p.m.