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Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
03/13/2025 Water Clean Water Act, LPDES, WWTP
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Phone Number Facility Contact:
City of Breaux Bridge
Breaux Bridge Wastewater Treatment Facility
1201 Begnaud St.
Breaux Bridge, LA 70517
101 Berard St., Ste. A
Breaux Bridge, LA 70517
St. Martin Parish
(337) 332-8301
Honorable Ricky Calais
Mayor
rcalais@breauxbridgela.net
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
110039166693 LA0033014 N/A 221320 4952
Personnel participating in inspection:
Sharron A. Crayton
R6 ECAD-WR
Kenneth AuBuchon
R6 ECAD-WM
Shane Miller
LDEQ Acadiana Regional Office
Alex Breaux
LDEQ Acadiana Regional Office
Beau Powers
LDEQ Acadiana Regional Office
Rita George
City of Breaux Bridge
Neil Angelle
City of Breaux Bridge
Joseph Guidry
City of Breaux Bridge
Inspector/Enforcement Officer Inspector/Enforcement Officer ES Senior ES III ES I Human Resource Director Chief Wastewater Facility Operator Water System Manager
EPA Lead Inspector Signature/Date
Sharron A. Crayton Sharron A. Crayton
05/07/2025 Date
Supervisor Signature/Date
Digitally signed by RUBEN ALAYON-
RUBEN ALAYON-GONZALEZ GONZALEZ
Date: 2025.05.09 09:39:05 -05'00'
Ruben Alayon-Gonzalez
05/09/2025 Date
6ENFORM-019-R9 (02/27/2025)
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Section I - INTRODUCTION
City of Breaux Bridge Breaux Bridge Wastewater Treatment Facility
LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
PURPOSE OF THE INSPECTION
EPA Region 6 Inspectors, Sharron Crayton (Lead Inspector) and Kenneth AuBuchon (Mentoring Inspector), arrived at the Breaux Bridge Wastewater Treatment Facility (the "Site" or "Facility"), located at 1201 Begnaud Street, Breaux Bridge, LA 70517, at approximately 12:05 PM on March 13, 2025, for an unannounced inspection. Prior to arriving to the site, the EPA Region 6 Inspectors arrived at the City of Breaux Bridge's City Hall complex located at 101 Berard Street, Breaux Bridge, LA 70517, at approximately 10:15 AM for the opening meeting, where the lead inspector presented credentials to Ms. Rita George, Human Resource Director, Mr. Neil Angelle, Chief Wastewater Facility Operator, and Mr. Joseph Guidry, Water System Manager and informed them that this was an EPA Region 6 inspection to determine compliance as authorized by the Clean Water Act (CWA) Section 308 and implementing regulations, as well as the facility's compliance with its Louisiana Pollutant Discharge Elimination System (LPDES) Permit No. LA0033014. This report is based on information supplied by the City of Breaux Bridge (the permittee) and the Breaux Bridge Wastewater Facility representatives, direct observations made by the EPA Region 6 inspector(s), records and reports maintained by the permittee and other information including, but not limited to: photographs taken by the EPA Region 6 inspector(s); physical evidence collected by the EPA Region 6 inspector(s); measurements taken by EPA Region 6 inspector(s); verbal or written statements made by information supplied by the Facility representatives during or subsequent to the on-site inspection; and materials, processes, data, photographs, or documents shown, demonstrated, and/or submitted to the EPA Region 6 inspector(s) by the Facility representatives during or subsequent to the onsite inspection. In addition, information gathered prior to or after the inspection from a review of EPA, State, and/or public records may be included in this report.
This inspection was an EPA-lead CEI, which also provided required EPA oversight and On-the-Job training to new EPA staff, as well as training to Louisiana Department of Environmental Quality (LDEQ) staff. At the opening meeting, the EPA inspector also informed the facility representatives of the objectives of the inspection and explained that the CEI was being conducted to determine compliance status with permit conditions and other program requirements, verify the accuracy of information submitted to EPA and/or LDEQ, and verify the adequacy of sampling and monitoring conducted by the facility. During the closing conference, which began and ended at 1:40 PM and 1:53 PM, respectively, with Mr. Neil Angelle, Chief Wastewater Facility Operator for the City of Breaux Bridge, the inspectors discussed areas of concern (AOCs) noted during the inspection and items further detailed in this report. The EPA inspector contacted Facility representatives via email on the following dates, regarding requests for additional documents: March 14th, 20th, 21st, 25th 26th, 27th, and 28th (see Section IV of this report for additional details).
FACILITY DESCRIPTION
The Breaux Bridge Wastewater Treatment Facility is a publicly owned treatment works serving the City of Breaux Bridge. The treatment facility consists of a three-celled oxidation pond operated in series followed
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City of Breaux Bridge Breaux Bridge Wastewater Treatment Facility
LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
by chlorination, dechlorination, and metering. The discharge of treated sanitary wastewater is distributed into a forested wetlands assimilation area through five (5) alternating discharge points, which are located along a 1,600-foot pipeline adjacent to the Cypriere Perdue Swamp with ultimate discharge thence into Ruth Canal; thence into Bayou Vermilion River. When sludge is required to be removed, the ponds will be dredged, sludge dewatered and disposed of in a landfill. The City of Breaux Bridge is responsible for compliance with LPDES permit conditions relating to treated sanitary discharges as authorized via LPDES Permit No. LA0033014, issued on September 22, 2022, with an effective date of October 15, 2022. A minor modification was issued on September 27, 2023, correcting a typographical error by changing the concentration units for the parameter Fecal Coliform from milligrams per liter (mg/L) to #100 (the number of bacteria colonies per 100 milliliters of sample water). LPDES Permit No. LA0033014 will expire at midnight, October 15, 2027. Below, a schematic of the treatment system, including flow direction is presented as Exhibit 1: Site Diagram.
Section II - OBSERVATIONS Prior to conducting the visual field observations, the Lead EPA Inspector conducted an on-site records review, which included requests and/or identification of records required to be submitted and/or
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City of Breaux Bridge Breaux Bridge Wastewater Treatment Facility
LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
maintained on site, per the LPDES permit. During the inspection, the facility representatives were challenged with locating and subsequently providing various requested files (see Section III of this report for additional details). The on-site records review portion of the inspection concluded at approximately 11:50 AM. The EPA and LDEQ Inspectors and Mr. Angelle proceeded to the treatment facility to perform visual observations of the process unit(s).
I observed the three-celled oxidation pond system, chlorine contact chamber (CCC), dechlorination compartment, five (5) discharge points, and the immediate front section of the wetlands assimilation area. The external and internal levees boarding the oxidation ponds were in good condition with no evidence of breakthroughs, leaks and/or overflows. There was a moderate presence of trees and heavy vegetation immediately at the entry point of untreated wastewater into the oxidation pond, at cell #1. There were approximately 15 mobile propellers located in cell #1 to assist with cutting/chopping up weeds. Cell #1 contained condensed vegetation; however, the integrity of the levees was observed to be sufficient, and there was no indication that the heavy vegetation hindered and/or limited wastewater treatment (see Appendix 1, Photographs 1, 2, and 3). Cells #2 and #3 were clear of aquatic vegetation. Water in the CCC was clear and free of floating solids. Chlorine was present for disinfection and foam was observed in the compartment for dechlorination. However, there was no foam and/or visible solids observed at the final effluent discharge point into the wetlands assimilation area. A 3-foot rectangular weir serves as the primary flow measurement device and a Siemens Hydroranger 200 meter is utilized to continually record flow. The flow meter was last calibrated on March 12, 2024. During the inspection, the permittee was discharging via discharge point #4. At 1:13 PM, the continuous recorder registered a flow of 2.21 million gallons per day (MGD). The same flow was also recorded in the March 2025 Flow Meter Monthly Flow Sheet for the 8:00 AM hour.
In addition, I reviewed operator process logs for flow and pH, as well as the 4.0, 7.0 and 10.0 pH buffer solutions/standards. The 10.0 pH buffer solution was expired (see Section III for additional details). The on-site refrigerator, which is also housed in the laboratory and utilized to store effluent composite samples demonstrated a properly installed thermometer and was reading 40o Fahrenheit at 1:40 PM.
The facility is also near completion of building an automatic and manual-combined bar screen and subsequent grit chamber, which is expected to be placed online and in service by the end of the 2nd Quarter 2025.
Section III - AREAS OF CONCERN
Areas of concern (AOCs) are derived from on-site process observations and/or records review from the March 13th CEI, and from subsequent documents provided electronically by city personnel and/or the city's environmental consultant, via email, after the EPA's on-site inspection.
The following are AOCs are specific to visual field/process observations I noted, as the Lead EPA Inspector (with the applicable LPDES permit reference(s) followed by bold/italic text):
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City of Breaux Bridge Breaux Bridge Wastewater Treatment Facility
LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
1. The 10.0 pH buffer solution/standard did not demonstrate to be within the expiration date. Specifically, the buffer solution displayed an expiration date of February 2025 (see Appendix 1, Photographs 4 and 5). LPDES Permit LA0033014, Standard Conditions for LPDES Permits Section C. Monitoring and Records, Item 5. Monitoring Procedures
2. The month and year for some of the pH calibration records were left blank. As such, the inspector(s) (and the facility operator) were unable to determine which month and/or year the calibration readings were performed (see Appendix 1, Photographs 6, 7, and 8). LPDES Permit LA0033014, Standard Conditions for LPDES Permits Section C. Monitoring and Records, Item 4. Record Contents
I noted the following AOCs specific to both on-site and post off-site (office) inspection record reviews (with the applicable LPDES permit reference(s) followed by bold/italic text):
1. The permittee was unable to provide a copy of the facility's Storm Water Pollution Prevention Plan (SWP3) or other specific components required by the plan (i.e., documentation that the plan was reviewed and/or updated within six (6) months after the permit effective date, annual inspection reports, site map, and certification that the facility is in compliance with the SWP3). During and after the on-site inspection, the permittee offered instead information regarding their Municipal Separate Storm Sewer System-Storm Water Management Plan (MS4-SWMP), as required per LPDES Permit No. LAR041016, which is a separate permitting authorization for MS4s with different requirements from those specific to the SWP3. After multiple EPA efforts to provide clarity to the permittee that the two (2) programs and required plans were different, the permittee's environmental consultant, Mr. Adam Latiolais, Professional Engineer with A&E Consultants, Inc., informed EPA on March 28, 2025, that the SWP3 does exist. However, the original signed document could not be located, but once received from the engineering firm who prepared the plan, a review and update of the SWP3, if necessary, would be completed and provided. As of the date of this inspection report, the SWP3 has not been provided to EPA. LPDES Permit LA0033014, Other Conditions for LPDES Permits Item L. Stormwater Discharges, L.3, L.4.a, L.4.b, L.4.d, L.4.e, and L.6.a
2. Quarterly inspection reports associated with the facility's SWP3 were inconsistent with regards to the date the inspection(s) were performed; lacking the actual time the inspection(s) were conducted; and the certification by the permittee's responsible official. In addition, there were handwritten notes (and dates) on the January 18, 2023, 1st Quarter inspection report, which indicated additional visits were made (by the consultant who performed the inspections); however, other than the dates listed, no additional inspection details were documented, and no other quarterly reports for the calendar year 2023 were provided.
Furthermore, no reports for the 1st and 2nd Quarter 2024 were provided and an inspection report for the 3rd Quarter, 2024, dated July 15, 2024 was provided. There were various inclusions of the calendar year 2023 throughout the July 2024 document, as well as indication that a 1st Quarter 2024 inspection may have been conducted on January 18th; however, the page was blank. October 15, 2024 was referenced as an inspection conducted in 2024; however, the inspection form also referenced the 3rd Quarter throughout the October 15th inspection report (see Appendix 2, 2023 and 2024 SWP3 Quarterly Inspection Reports with AOCs highlighted and/or
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
outlined). LPDES Permit LA0033014, Other Conditions for LPDES Permits Item L. Stormwater Discharges, L.4.d and L.4.e 3. On March 28th, via email, the permittee's environmental consultant provided to EPA stormwater training material that was presented to various city personnel, on December 3rd and 5th, 2024. The training material was more specific to the facility's MS4 and details germane to the associated SWMP versus the LPDES SWP3 requirements. Specifically, the training did not address the following SWP3 required components: petroleum production management; process chemical management; fueling procedures; and proper procedures for using fertilizer, herbicides and pesticides (see Appendix 3, City of Breaux Bridge Employee Training). LPDES Permit LA0033014, Other Conditions for LPDES Permits Item L. Stormwater Discharges, L.6.b
Closing Conference
On March 13, 2025, at approximately 1:40 PM, EPA Region 6 Inspector Sharron Crayton facilitated and conducted a closing conference in the on-site laboratory at the Facility. EPA Region 6 Inspector Kenneth AuBuchon, along with the three (3) LDEQ Inspectors, and the city's Chief Wastewater Facility Operator also participated in the closing conference. Lead Inspector Crayton reviewed the preliminary AOCs noted during visual field observations, additional requests for information and anticipated due dates, and information about the next steps in the inspection process, including issuance of the final inspection report. The mayor, other city personnel, the city's environmental consultant, and/or contract laboratory personnel were contacted, via email communications sent by EPA on March 14th, 20th, 21st, 25th 26th, 27th, and/or 28th, regarding requests for additional documents (as detailed in Section IV of this report). Additionally, AOCs discussed in Section III (under the records review portion) were determined after the conclusion of the inspection and were not included in the closing conference.
Section IV - FOLLOW UP
The following information was requested by EPA via email on March 14, 2025, after exiting the Facility on March 13, 2025:
Analytical Data (for Conventional and Non-Conventional Parameters)
Laboratory reports for the following monitoring periods:
1. 3rd Quarter 2023 (July - September);
2. 4th Quarter 2023 (October - December)
3. June 2024;
4. July 2024; and
5. January 2025.
Analytical Data (for Biomonitoring)
Laboratory reports for the following monitoring periods:
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City of Breaux Bridge Breaux Bridge Wastewater Treatment Facility
LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
1. November 2022; 2. December 2022 (Retest #1); 3. January 2023 (Retest #2); and 4. February 2023 (Retest #3). Wetland Systems Monitoring Requirements Monthly water stage readings for the set points within each of the Wetland Area sites for the following monitoring periods: 1. March 2023; 2. August 2024; 3. November 2024; and 4. February 2025. Storm Water Discharges An electronic dated and certified copy of the facility's Storm Water Pollution Prevention Plan (SWP3), including, but not limited to the following:
1. Support information to confirm that the plan was reviewed and updated, if needed within six (6) months of the renewal permit issuance date;
2. A site map, which reflects areas where stormwater may contact potential pollutants or substances which can cause pollution;
3. A copy of the 2023 and 2024 Annual Inspection Report, including visual inspection results, and a record summarizing the annual inspection results and certification that the facility is in compliance with the SWP3; and
4. Records for 2023 and 2024 confirming stormwater employee training, who addended and what topics were covered.
Annual Biosolids (Sludge) Reports Annual sludge reports for the following monitoring periods: Calendar Years 2023 and 2024. Except for not receiving an electronic dated and certified copy of the SWP3, and Items 1 and 2 listed under Storm Water Discharges, all other items listed above were either provided by the permittee, the city's environmental consultant, contract laboratory (HOH-PAK Labs), and/or obtained via EPA's search in the LDEQ's Electronic Data Management System (EDMS) filing repository.
Section V - LIST OF APPENDICES Appendix 1 - Photo Log - Eight (8) photos taken 03/13/2025
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City of Breaux Bridge Breaux Bridge Wastewater Treatment Facility
LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
Appendix 2 - 2023 and 2024 SWP3 Quarterly Inspection Report(s) with AOCs highlighted and/or outlined
Appendix 3 - City of Breaux Bridge Employee Training (Minus Sign-In Sheets Containing DOB, Names and Signatures)
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City of Breaux Bridge Breaux Bridge Wastewater Treatment Facility
LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
Appendix 1 Photograph Log
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City of Breaux Bridge Breaux Bridge Wastewater Treatment Facility
LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Appendix 1: Photograph Log
Photo No. 1
Location: Breaux Bridge Wastewater Treatment Facility
City: Breaux Bridge
Parish: St. Martin
State: LA
Description: View, of three-celled oxidation pond cell #1. General Observation Note: there was a moderate presence of trees and heavy vegetative greenery immediately at the entry point of untreated wastewater into the oxidation pond (as noted by blue arrows). There were approximately 15 mobile propellers located in cell #1 (identified by yellow arrows) to assist with cutting/chopping up weeds. The levees were observed to be in good condition with no breakthroughs identified/noticed, during the inspection. Date of Photo: 03/13/2025 Photographer: Sharron Crayton
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City of Breaux Bridge Breaux Bridge Wastewater Treatment Facility
LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Appendix 1: Photograph Log
Photo No. 2
Location: Breaux Bridge Wastewater Treatment Facility
City: Breaux Bridge
Parish: St. Martin
State: LA
Description: An additional view, of three-celled oxidation pond cell #1. General Observation Note: there was a moderate presence of trees and heavy vegetation and sludge (as noted by blue arrows) immediately at the entry point of untreated wastewater into the oxidation pond (identified by yellow arrow).
Date of Photo: 03/13/2025 Photographer: Sharron Crayton
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City of Breaux Bridge Breaux Bridge Wastewater Treatment Facility
LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Appendix 1: Photograph Log
Photo No. 3
Location: Breaux Bridge Wastewater Treatment Facility
City: Breaux Bridge
Parish: St. Martin
State: LA
Description: Additional view, moderate presence of trees and heavy vegetation (and sludge) immediately at the entry point of untreated wastewater into the oxidation pond (as noted by blue arrows). There were approximately 15 mobile propellers located in cell #1 (identified by yellow arrows) to assist with cutting/chopping up weeds.
Date of Photo: 03/13/2025 Photographer: Sharron Crayton
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City of Breaux Bridge Breaux Bridge Wastewater Treatment Facility
LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Appendix 1: Photograph Log
Photo No. 4
Location: Breaux Bridge Wastewater Treatment Facility
City: Breaux Bridge
Parish: St. Martin
State: LA
Description: View, 10.0 pH buffer solution/standard (as noted by yellow arrow). Date of Photo: 03/13/2025 Photographer: Sharron Crayton
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City of Breaux Bridge Breaux Bridge Wastewater Treatment Facility
LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Appendix 1: Photograph Log
Photo No. 5
Location: Breaux Bridge Wastewater Treatment Facility
City: Breaux Bridge
Parish: St. Martin
State: LA
Description: View, of 10.0 pH buffer solution/standard, which displayed an expiration date of February 2025 (as noted by red arrow). Date of Photo: 03/13/2025 Photographer: Sharron Crayton
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City of Breaux Bridge Breaux Bridge Wastewater Treatment Facility
LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Appendix 1: Photograph Log
Photo No. 6
Location: Breaux Bridge Wastewater Treatment Facility
City: Breaux Bridge
Parish: St. Martin
State: LA
Description: View of, pH calibration record(s) correctly noting the month and year for calibrations recorded (as of date) for March 2025 (as noted by green arrow). Date of Photo: 03/13/2025 Photographer: Sharron Crayton
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City of Breaux Bridge Breaux Bridge Wastewater Treatment Facility
LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Appendix 1: Photograph Log
Photo No. 7
Location: Breaux Bridge Wastewater Treatment Facility
City: Breaux Bridge
Parish: St. Martin
State: LA
Description: View of, a pH calibration record where the month and year were left blank thus making it difficult to determine which month and/or year the calibration readings were performed (as noted by red arrow).
Date of Photo: 03/13/2025 Photographer: Sharron Crayton
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City of Breaux Bridge Breaux Bridge Wastewater Treatment Facility
LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Appendix 1: Photograph Log
Photo No. 8
Location: Breaux Bridge Wastewater Treatment Facility
City: Breaux Bridge
Parish: St. Martin
State: LA
Description: Additional view of, a pH calibration record where the month and year were left blank thus making it difficult to determine which month and/or year the calibration readings were performed (as noted by red arrow).
Date of Photo: 03/13/2025 Photographer: Sharron Crayton
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City of Breaux Bridge Breaux Bridge Wastewater Treatment Facility
LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
Appendix 2 2023 and 2024 SWP3 Quarterly Inspection Reports
(With AOCs Highlighted and/or Outlined)
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
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City of Breaux Bridge Breaux Bridge Wastewater Treatment Facility
LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
Appendix 3 City of Breaux Bridge Employee Training (Minus Sign-In Sheets Containing DOB, Names and Signatures)
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
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LPDES Permit No. LA0033014 Inspection Date: 03/13/2025
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