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EPA Region 5 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 02/28/2023 12:45 PM (ET) 02/28/2023 03:45 PM (ET) Announced: Yes Access: Granted Water Clean Water Act, NPDES, WWTP CSO - Combined Sewer Overflow Inspection, SSO - Sanitary Sewer Overflow Inspection Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County/Borough/Parish Facility GPS Coordinates Mailing Address (If different) City, State, Zip Code Elkhart Public Works and Utilities Elkhart Public Works and Utilities 1201 S Nappanee St Elkhart, IN 46516 41.676583, -86.003833 FRS ID 110000573237 Permit Number(s) (If Applicable) IN0025674 SIC and/or NAICS 4952 Regulatory Representatives Participating in Inspection: See Attendees list below Lead Inspector: Dean Maraldo Supervisor Review: Ryan Bahr [Signature] EPA Region 5 [Signature] EPA Region 5 DINO MARALDO Digitally signed by DINO MARALDO Date: 2023.03.03 15:46:20 -06'00' Maraldo.Dean@epa.gov (312) 353-2098 Digitally signed by RYAN RYAN BAHR Date: 2023.03.06 BAHR 14:27:42 -06'00' bahr.ryan@epa.gov 1 of 12 Elkhart Public Works and Utilities Inspection Date: 02/28/2023 SECTION I - INTRODUCTION Site Entry and Inspection Objectives I, EPA Region 5 Lead Inspector Dean Maraldo, arrived at the Elkhart Public Works and Utilities (the "Site" or "Facility"), located at 1201 S Nappanee St, Elkhart, IN 46516, at 12:45 PM (ET) on 02/28/2023 for an announced inspection. I was joined by EPA inspector Jake Berger. We presented credentials to Bryan Cress and informed the group that this was an EPA Region 5 focused inspection to determine compliance as authorized by Clean Water Act (CWA) Section 308 and implementing regulations. This report is based on information supplied by Elkhart Public Works and Utilities ("city") representatives, direct observations made by the EPA Region 5 inspectors, records and reports maintained by the permittee and other information including: photographs taken by EPA Region 5 inspectors, physical evidence collected by the EPA Region 5 inspectors, verbal or written statements made by information supplied by city representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA Region 5 inspectors by city representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of EPA, State, and/or public records may be included in this report. We began the opening conference with introductions and a review of the purpose of the inspection - to review progress of the LTCP program, review recent effluent limit exceedances, and review records of SSOs since 2018. I also mentioned that we may want to look at current construction of the Cloth Media Disc Filter ("CMDF") treatment system at the wastewater treatment plant. Attendees Organization U.S. EPA Region 5 City of Elkhart City of Elkhart City of Elkhart City of Elkhart City of Elkhart IDEM U.S. EPA Region 5 Attendee Name Dean Maraldo Tory Irwin Joseph Foy Laura Kolo Bryan Cress Paul Wunderlich Eddy Depositar Jake Berger Title Lead Inspector City Engineer Stormwater Manager Environmental Resources Manager Regulatory Affairs Director Utility Engineer Inspector Inspector Present in Opening Conf. Yes Yes Yes Yes Yes Yes Yes Yes Present in Closing Conf. Yes Yes Yes Yes No Yes Yes Yes Facility/Site Description I went over the facility description provided in the permit (excerpt below) and the city representatives confirmed that information was accurate. The permittee currently operates a Class IV, 20 MGD activated sludge treatment facility consisting of grit removal, primary clarification, secondary aeration, final clarification, ultraviolet light disinfection, and influent and effluent flow meters. The permittee also has been issued construction Permit Approval No. L-0621 for plant improvements and the installation of Cloth Media Disc Filters (CMDF) to 2 of 12 Elkhart Public Works and Utilities Inspection Date: 02/28/2023 increase wet weather flow to the facility. The collection system is comprised of combined sanitary and storm sewers with twenty-nine (29) Combined Sewer Overflow (CSO) locations. The CSO locations have been identified and permitted with provisions in Attachment A of the permit. The wastewater treatment plant discharges treated effluent to the St. Joseph River via Outfall #035. We then began the Interview portion of the inspection. SECTION II - OBSERVATIONS Location: Interview/CSO/WWTP Review Observation #: DM1-OB-001 Date: 02/28/2023 Tory Irwin provided an update on the CMDF construction progress and said although they've experienced ordering and shipping delays, they are on track for construction completion by November 15, 2024, consistent with the approved LTCP schedule. He added that they also bid out first part of Oakland Avenue Controls pursuant to the LTCP schedule. Bryan Cress estimated the City of Elkhart sewer system served a population of just under 50,000, including 42,517 within the city, and the remainder made up of other smaller communities in St. Joseph County and Cass County in Michigan. I asked for a breakdown of the miles of sewer, by type, in the city's sewer collection system. Bryan Cress provided the following response: Miles of combined sewer: 121 Miles of separate sewer passing through combined sewers: 129 Miles of separate sanitary sewers: 28 Miles of separate storm sewer: 77 Miles of sanitary force main: 18 Miles of storm only force main: 0.9 I asked who signed DMRs. Laura Kolo confirmed that she signs all DMRs. I asked about staffing for sewer operations. Laura Kolo said that they have 15 operators and 15 maintenance staff. She added that about 75% of the operators are certified and the rest are working towards certification. Ten additional staff work on collection system maintenance. Tory Irwin added that the plant is in operation 24/7, 365 days per year, with workdays made up of three eight-hour shifts. Before proceeding with the inspection and reviewing records, I asked if there were any confidential business information (CBI) concerns. The city representatives said there were no CBI concerns. Next, we reviewed the LTCP schedule and milestones. Tory Irwin provided an update on progress of current projects including the Oakland Ave. controls and St. Joseph River CSO controls - sewer separation. Other than potential cost inflation and general delays experienced in the construction industry, he said there were no other concerns regarding schedule. He also added that the city is working on a rate increase to cover work through the end of the LTCP. I asked if there was a summary of CSO activations in 2022. Bryan Cress said he would provide a summary after the inspection. 3 of 12 Elkhart Public Works and Utilities Inspection Date: 02/28/2023 Location: Interview/WWTP Effluent Limit Exceedances Observation #: DM1-OB-002 Date: 02/28/2023 I reviewed effluent limit exceedances over the last two years. The facility reported phosphorus percent removal exceedances in March and April 2022, and an E.coli effluent limit exceedance in June 2022. Laura Kolo said that the phosphorus issue was the result of a period of low influent phosphorus, which made it difficult to meet the percent reduction limit in the permit. She added that the E.coli effluent limit exceedance was the result of a channel maintenance and sensor issue. Both issues appear to be resolved as no E.coli or phosphorus effluent limit exceedances were reported by the facility since April (phosphorus) and June (E.coli) 2022. I asked how the wastewater treatment plant was currently operating. Laura Kolo said that one aeration tank is out of service due to construction (upgrades to diffusers and blowers). There are five aeration tanks in total. Laura Kolo also mentioned challenges with filamentous bacteria, managed through wasting. She added that they recently failed a biomonitoring test and are retesting pursuant to permit requirements. I asked for a copy of the biomonitoring retest and Laura Kolo said she would provide a copy once received. Before concluding the effluent limit exceedance discussion, I asked about citizen complaints. Bryan Cress said that most citizen complaints are related to odors at the plant. Location: Interview/Sanitary Sewer Overflows Observation #: DM1-OB-003 Date: 02/28/2023 I began the sanitary sewer overflow (SSO) discussion with a question about any current SSO-related projects in the city. Tory Irwin said there were no SSO-specific projects underway currently, but they do have a cleaning and backflow prevention program. The backflow prevention program is partially subsidized by the city, however, not a lot of residents are taking advantage of the program. Tory Irwin said that the goal of the sewer cleaning program was to clean all city sewers in a seven-year cycle. They also have a goal to televise all sewers within ten years and the city now owns its own televising equipment. I asked about lift stations in the sewer system. Bryan Cress said there were 66 lift stations of various types (sewer, storm, etc). He said he would provide a detailed list after the inspection. At this point in the inspection, the city representatives provided me with copies of the Bypass/Overflow Incident Reports I requested, from 2018 to present. Bryan Cress clarified that some of the Bypass/Overflow Incident Reports were mistakenly labelled as CSOs, but all the reports provided represented Bypass/Overflow incidents involving SSOs. [I did not review the Bypass/Overflow Incident Reports during the inspection]. I asked if there were any known chronic SSO areas in the city. Tory Irwin said there are some backups in a residential area near a pork processing plant. He added that the city has taken enforcement against the company. I asked if the city maintains a log for sewer-related complaints. The city maintains a work order log that is based largely on complaints. Bryan Cress provided a copy of the work order summary. I asked if the city had a map that clearly delineates the combined and separated sewers, or perhaps a GIS layer they could share. Tory Irwin said they would have their GIS staff reach out to me after the inspection. Before concluding this portion of the inspection, Tory Irwin said he wanted to let me know that the city is behind on reissuing industrial user (IU) permits. Laura Kolo later clarified that the city is about 15 IU permits behind. 4 of 12 Elkhart Public Works and Utilities Inspection Date: 02/28/2023 Location: Wastewater Treatment Plant Physical Inspection/CMDF Construction Observation #: DM1-OB-004 Date: 02/28/2023 Weather: Sunny, cool At 2:45 PM, I, along with Inspector Berger, the IDEM inspector, and Joseph Foy, drove across the road to the wastewater plant to view the current construction related to the CMDF wet-weather treatment system. We met Joe Henderson and Jim Miller with Donohue and Associates, consultants to the city for wastewater plant construction upgrades, including the CMDF project. They described the current wastewater treatment process and provided an update on construction of the CMDF system. They provided a copy of the map they used to describe the wastewater treatment process and CMDF construction progress (see Appendix 2). Jim Miller said the CMDF diversion structure was already built and the CMDF building was currently under construction. The remaining physical inspection observations are described in the Photo Log (see Appendix 1). We concluded the physical inspection of CMDF-related construction at the wastewater treatment plant at 3:15 PM, then returned to the Public Works office to conduct the closing conference. Photo(s) 1. ELKH0195.JPG 2. ELKH0196.JPG 3. ELKH0197.JPG SECTION III - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION IV - AREA OF CONCERN Area(s) of Concern may not be in sequential order. The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. AOC Reference #: DM1-OB-002 Location: Interview/WWTP Effluent Limit Exceedances Regulation and/or Permit Requirement Permit Part I.D. and Part III.B.1 AOC: Challenges with filamentous bacteria. City recently failed a biomonitoring test and are retesting pursuant to permit requirements. AOC Reference #: DM1-OB-003 Location: Interview/Sanitary Sewer Overflows Regulation and/or Permit Requirement Permit Part III.A.2 AOC: The city is behind on reissuing approximately 15 industrial user (IU) permits. 5 of 12 Elkhart Public Works and Utilities Inspection Date: 02/28/2023 AOC Reference #: DM1-OB-003 Location: Interview/Sanitary Sewer Overflows Regulation and/or Permit Requirement Permit Part II.B.6 AOC: Chronic sewer backups in a residential area near a pork processing plant. SECTION V - CLOSING CONFERENCE AND FOLLOW UP Closing Conference We began the closing conference at 3:30 PM. I first reviewed the follow-up items requested during the inspection, including: Summary of CSO activations. Results of biomonitoring retest. Detailed list of lift stations and types. Follow-up call from GIS staff regarding sewer maps. The city agreed to provide all requested material by March 14, 2023. Next, I reviewed the documents I received during the inspection, including: Map of wastewater treatment plant. Bypass/Overflow Incident Reports (2018-2023). Work Order Log (2018-2022). Other than the biomonitoring test failure, overdue IU permits, and mention of chronic backups in a residential area near a pork processing plant, there were no other preliminary areas of concern. I mentioned that there may be additional follow-up areas based on review of the SSO records provided by the city. Before concluding the inspection, I asked if there were any questions. With no questions for me, I provided an estimated timeframe for completing the inspection report, and we concluded the inspection at 3:45 PM, on February 28, 2023. Note, Observations and Area(s) of Concern have not yet been evaluated for a formal compliance determination. Follow Up The following items were requested by the inspector at the time of the inspection. City agreed to provide items by March 14, 2023. Location: Interview DM1-OB-001 Area: CSO/WWTP Review Summary of CSO activations in 2022 after the inspection. Location: Interview DM1-OB-002 Area: WWTP Effluent Limit Exceedances Copy of the biomonitoring retest results once received. 6 of 12 Elkhart Public Works and Utilities Inspection Date: Location: Interview DM1-OB-003 Detailed lift station list. Area: Sanitary Sewer Overflows GIS staff to contact me regarding access to sewer GIS layers. Communication Log No additional information received by EPA Region 5 after exiting the Facility on 02/28/2023. SECTION VI - LIST OF APPENDICES 1. Photo Log 2. Document Log 02/28/2023 7 of 12 Elkhart Public Works and Utilities Inspection Date: APPENDIX 1: PHOTO LOG 02/28/2023 CMDF Building ELKH0195.JPG 02/28/2023 03:04 PM Photographer: Dean Maraldo Wastewater Treatment Plant Physical Inspection/Physical Inspection No CBI No PII Image captures current construction of the CMDF building (#350). 8 of 12 Elkhart Public Works and Utilities Inspection Date: 02/28/2023 CMDF Diversion Structure Building ELKH0196.JPG 02/28/2023 03:04 PM Photographer: Dean Maraldo Wastewater Treatment Plant Physical Inspection/Physical Inspection No CBI No PII Image captures the recently completed building (#210) for the CMDF diversion system. CMDF Shaft ELKH0197.JPG 02/28/2023 03:10 PM Photographer: Dean Maraldo Wastewater Treatment Plant Physical Inspection/Physical Inspection No CBI No PII Image of a staged CMDF shaft. At this location we were joined by Matt Ripey, Operations Supervisor, who provided an update on the aeration tank upgrade project. 9 of 12 Elkhart Public Works and Utilities Inspection Date: APPENDIX 2: DOCUMENT LOG Document Received Name Map of wastewater treatment plant Bypass/Overflow Incident Reports (2018-2023) Work Order Log (2018-2022) 02/28/2023 Date Received 02/28/2023 02/28/2023 02/28/2023 Pages 2 127 14 Attached to report below? Yes No No 10 of 12 Elkhart Public Works and Utilities Inspection Date: 02/28/2023 Appendix 2, page 11 of 12 Elkhart Public Works and Utilities Inspection Date: 02/28/2023 Appendix 2, page 12 of 12