Document 154KGEEYJpL8b3dMdnRxLOj2Z
REGION 5 Enforcement and Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Time: Media: Statute(s)/Program(s): Type of inspection: Access:
06/15/2021 - 06/16/2021 Inspection Announced: Yes
Entry: 08:15 AM (ET)
Exit: 11:20 AM (ET)
Water
Clean Water Act, NPDES, Industrial
CEI - Compliance Evaluation Inspection
Granted
Permittee Name: Facility or Site Name: Facility/Site Physical Address: (city, state, zip code) County/Parish: Facility GPS Coordinates:
Campbell Soup Supply Corporation, LLC Campbell Soup Supply Corporation, LLC 12-773 State Route 110 Napoleon, OH 43545 Henry 41.35606, -84.114479
Facility/Site Identifier: Permit Number: SIC or NAICS:
110006108942 OH0003298 SIC 2032 and 2033
Persons Participating in Inspection:
Title Lead Inspector
Name
Phone
Mark Conti (440) 250-1706
Email conti.mark@epa.gov
Present at Opening Conference
Yes
Present at Closing
Conference
Yes
Physical Scientist Matthew (312) 886-2405 schulte.matthew@epa.gov
Yes
Yes
Schulte
Environmental, Cary Drewes (419) 599-6723 cary_drewes@campbellsoup.com Yes
Yes
Health & Safety
Manager
Wastewater Ernie Shafer
--
ernest.shafer@campbells.com
Yes
Yes
Treatment Plant
Manager
Manager, Water Aaron McCoy
--
Treatment
--
Yes
No
Page 1 of 12
CAMPBELL SOUP SUPPLY COMPANY Inspection Date(s):
Persons Participating in Inspection:
Environmental & Sue Cameron
--
Sustainability
Analyst
6/15/2021 - 6/16/2021
--
No
Yes
Lead Inspector: Mark Conti
MARK CONTI
Digitally signed by MARK CONTI Date: 2021.08.05 09:40:17 -04'00'
Region 5
conti.mark@epa.gov
(440) 250-1706
Additional Persons Participating in Inspection:
Matthew Schulte
Region 5
schulte.matthew@epa.gov
(312) 886-2405
Supervisor Review: Brooke Furio
Furio, Brooke
Digitally signed by Furio, Brooke Date: 2021.08.05 10:58:20 -04'00'
Region 5
furio.brooke@epa.gov
(440) 250-1705
SECTION I - INTRODUCTION
Site Entry and Inspection Objectives
Region 5 Lead Inspector, Mark Conti, arrived at Campbell Soup Supply Corporation (the "Site" or "Facility"), located at 12-773 State Route 110, at 08:15 AM (ET) on 06/15/2021 for an announced inspection. The Lead Inspector presented his credentials to Cary Drewes, Ernie Shafer, and Aaron McCoy and informed them that this was a Region 5 inspection to determine compliance with the Clean Water Act (CWA) and the National Pollutant Discharge Elimination System (NPDES) permit program. The inspection was conducted under the authority of the Region 5 NPDES permit program and Section 308 of the CWA. The table above identifies the attendees that participated in the inspection.
This report is based on information supplied by Campbell Soup Supply Corporation representatives, observations made by the Region 5 inspectors, and records and reports maintained by the permittee and Region 5 including the following: direct observations made by the Region 5 inspector(s), photographs taken by Region 5 inspectors, physical evidence collected by Region 5 inspectors, measurements taken by Region 5 inspectors, verbal or written statements made or supplied by Campbell Soup Supply Corporation representatives (the permittee) during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the Region 5 inspectors by Campbell Soup Supply Corporation representatives during or subsequent to the on-site inspection. In addition, information
Page 2 of 12
CAMPBELL SOUP SUPPLY COMPANY Inspection Date(s):
6/15/2021 - 6/16/2021
gathered prior to or subsequent to the inspection from a review of U.S. EPA, State, and public records may be included in this report.
Facility/Site Description
Region 5 Lead Inspector confirmed the following facility information:
The Facility cans fruit and vegetable juices, sauces, and soups. Wastewater is generated from cleaning and peeling vegetables, evaporators, washdown in processing areas, boiler blowdown, chiller water, water treatment, laundry, and restrooms. Two-piece cans and PET injection blow-molded bottles are also manufactured on the Facility property. Metal cans are manufactured by Silgan Containers and PET bottles are manufactured by Amcor Rigid Plastics USA (Amcor). Rinse water from canmaking and miscellaneous water used by Amcor is treated and discharged by the Facility.
Wastewater is treated at the on-site wastewater treatment plant and/or by rotary screens and spray field overland flow treatment. The wastewater treatment plant includes grit removal, dissolved air flotation tanks, primary and secondary roughing towers, settling tanks, primary and secondary trickling filters, final settling tanks, post aeration tanks, and a chlorination basin. Sludge is anaerobically digested and stored in lagoons along with spent lime from water treatment. Sludge lagoon supernatant can be pumped to spray fields or returned to the wastewater treatment plant. Sludge is land-applied to Facility spray fields beginning in late summer.
Wastewater treatment plant effluent is discharged at Outfall 001. Spray fields discharge at Outfalls 006, 007, 008, and 009. There are two permitted stormwater outfalls and four internal monitoring stations.
SECTION II - OBSERVATIONS Observations may not be in sequential order.
No. MC3-OB-001 MC3-OB-002 MC3-OB-003
MC3-OB-004
Observation The Facility measures dissolved oxygen at Outfall 001 twice per shift. There was not a functioning continuous analyzer at the outfall. Composite samples at Outfall 001 are collected as flow-proportioned samples with a refrigerated Hach AS950 sampler. The sampler's storage temperature was 4 C. Flow at Outfall 001 is measured with an 18-inch Parshall flume and Endress+Hauser Prosonic S FMU90 ultrasonic transducer and recorder. Flow through the flume was turbulent with waves and surface boils (see Photos 11 and 12). The flow rate was spot-checked against the staff gauge. The gauge measurement was about 1.7 feet, which corresponds to 6,090 gallons per minute. The meter readout was 5,700 gallons per minute. Samples at Internal Monitoring Station 605 are collected from the overflow of a holding pit. Wastewater is pumped out of one end of the overflow trough to
Area of Concern?
Yes No Yes
Yes
Page 3 of 12
CAMPBELL SOUP SUPPLY COMPANY Inspection Date(s):
6/15/2021 - 6/16/2021
No.
MC3-OB-005 MC3-OB-006 MC3-OB-007
Observation the Facility's wastewater treatment plant. Canmaking return flow from two pipes discharges into the end of the trough that is pumped out (see Photo 19). The sampling location is at the end of the trough that is opposite of where it is pumped out. The set up may not allow for adequate mixing and a representative sample at the monitoring location. Samples at Internal Monitoring Station 605 are collected as time-composite samples. An aliquot is collected every 15 minutes. Composite samples at Internal Monitoring Station 605 are not cooled during collection. The readout on the flow meter recording device at Internal Monitoring Station 605 was erratic. The instantaneous readout varied between 12 and 45 gallons per minute over a period of about a minute. Wastewater is pumped with a fixed speed pump (see Photo 15) through an inline, horizontally-mounted meter (see Photo 16).
Area of Concern?
Yes Yes Yes
The meter appeared to be a magnetic flow meter. Magnetic flow meters are
often mounted vertically to ensure the cross-section of the pipe is liquid-filled.
Less than a full pipe at the measurement location may be affecting the reading
of the flow meter.
MC3-OB-008 Outfalls 001, 002, 006, 007, 008, and 009 had markers on the stream banks.
No
The markers for the spray field outfalls are installed in May and taken down
before winter.
MC3-OB-009 Temperature, conductivity, and dissolved oxygen can be continuously
No
recorded at Outfalls 006, 007, 008, and 009. Probes had not yet been installed
for the season.
MC3-OB-010 Flow is measured and totalized with 36-inch rectangular weirs and
No
Endress+Hauser Prosonic S FMU90 ultrasonic transducers and recorders at
Outfalls 006, 007, 008, and 009. Ultrasonic transducers had not yet been
installed and connect for the season at Outfalls 007, 008, and 009.
MC3-OB-011 Each spray field is hayed off and the grass is removed by a farmer prior to
No
discharging to a field for the growing season. The first discharge to a field for
the 2021 season was on May 29 to the field that discharges at Outfall 006. The
Facility planned to have the remaining fields available for wastewater
treatment by July 4.
MC3-OB-012 Primary dissolved air flotation tank #1 (DAF #1) had been out of service since
Yes
October 2020. It was also out of service for some of the summer months in
2020.
MC3-OB-013 The plastic media in the secondary roughing tower is breaking down. The
Yes
Facility has a tentative plan to rebuild it in 2022.
MC3-OB-014 Beverage plant wastewater discharge volume and solids concentration
No
increase from August through mid-October when processing "V7" vegetables.
Page 4 of 12
CAMPBELL SOUP SUPPLY COMPANY Inspection Date(s):
6/15/2021 - 6/16/2021
No. MC3-OB-015
Observation The Facility states that spray fields result in better wastewater treatment than the wastewater treatment plant, so it tries to maximize flow to sprays fields during that period. The wastewater treatment plant is shut down for about 16 hours once each year around Memorial Day to perform electrical maintenance. This may have a temporary negative impact on biological media in treatment units.
Area of Concern?
No
SECTION III - RECORDS REVIEW Records may not be in sequential order.
No. MC3-RR-001
Record The permit fact sheet describes how compliance with effluent guideline limitations (EGLs) at 40 CFR 465.43, Subpart D - Canmaking Subcategory are verified. The fact sheet does not describe how compliance is verified when some, or all, wastewater is treated in spray fields, though it implies it is the same.
Area of Concern?
Yes
Compliance with the EGLs are verified by multiplying pollutant concentrations
in untreated canmaking wastewater by one minus the removal efficiency for
the pollutant by the wastewater treatment plant. Removal efficiencies were
determined from wastewater treatment plant influent and effluent sampling.
The removal efficiencies determined for zinc and aluminum were 27.5% and
14.9% respectively. The removal efficiency for chromium was determined to
be 77.4%, which was based on two sample results above detection. Canmaking
is the only source of chromium. Canmaking wastewater is diluted 50-fold
entering the wastewater treatment plant. Most chromium samples taken for
removal efficiency determination were below detection, which may be
partially attributed to dilution. The wastewater treatment plant is a biological
plant, so 77.4% removal for a metal may not be achieved. A chromium
removal efficiency similar to the other metals (zinc and aluminum) may be
more appropriate.
MC3-RR-002 Mr. Shafer is a Class IV wastewater treatment plant operator. The permit
No
requires a Class IV wastewater treatment plant operator be in charge of the
wastewater treatment works and sewerage system.
MC3-RR-003 The laboratory used by the Facility to analyze free cyanide uses method OIA
Yes
1677-09.
MC3-RR-004 The Lead Inspector requested calibration records and meter information for
Yes
the flow meter at Internal Monitoring Station 605 during the records review
and close-out. The Facility has not provided the information.
Page 5 of 12
CAMPBELL SOUP SUPPLY COMPANY Inspection Date(s):
6/15/2021 - 6/16/2021
No. MC3-RR-005 MC3-RR-006
MC3-RR-007 MC3-RR-008 MC3-RR-009
Record The Facility could not recall having requested permission for the chiller and boiler treatment additives they use. They did not have a record(s) of written permission from the director of the Ohio EPA for additives prior to their use. There were several issues with chain of custody records. The 5/7/2020 upstream/downstream sample was marked as received at the lab before it was sampled by Industrial Fluid Management (IFM). Some nitrate + nitrite samples collected by IFM and sent to BoJhun Environmental Services (BoJhun) for analysis were not marked whether they were preserved with sulfuric acid. An IFM form for samples sent to BoJhun that was collected on 2/26/2021 was not marked whether samples were iced. Several forms for samples sent to MASI Environmental Laboratories were not marked whether samples were place on ice, and they lacked date and time the samples were relinquished. An IFM form for the upstream sample sent to BoJhun was marked as collected on 12/8/2021, but the correct date was 1/28/2021. Noncompliance reports for violations of daily maximum discharge limits were not submitted for violations that were discovered prior to October 2020. There were 2 times (September/October 2020 and March/April 2021) when samples were not measured at the required monitoring frequency of 2 times per week at Outfall 001. The Facility stated their contract lab only samples the first 4 weeks of the month. Some pairs of months have nine weeks, in which case there may be a week when monitoring is not done. Routine stormwater inspections and stormwater visual assessments were documented for the prior four quarters. One visual assessment was during snowmelt discharge. All visual assessments stated there was no color, oil sheen, or any other characteristic.
Area of Concern?
Yes Yes
Yes Yes
No
Stormwater discharges that never have color, solids or floatable material is not
typical.
MC3-RR-010 Compliance with categorical limits at 40 CFR 465.43 is calculated from
Yes
measured concentrations of untreated wastewater at Internal Monitoring
Station 605 and then multiplying by one minus the removal efficiency of the
pollutant at the wastewater treatment plant. Results are reported as Station
099 measurements. The permit includes removal efficiencies to use in the
calculation. Calculation errors were found when making a random check of
discharge monitoring report (DMR) records. Examples are shown below.
Date 5/13/2020 5/20/2020 6/04/2020 6/17/2020 6/17/2020
DMR Value 0.021 mg/L fluoride 11.07 ug/L aluminum 8.59 ug/L aluminum 26.82 ug/L zinc 37 ug/L aluminum
Correct Value 0.2 mg/L 7.3 ug/L 5.67 ug/L 54.2 ug/L 37.8 ug/L
Page 6 of 12
CAMPBELL SOUP SUPPLY COMPANY Inspection Date(s):
6/15/2021 - 6/16/2021
No.
MC3-RR-011 MC3-RR-012 MC3-RR-013
Record
7/08/2020 0.29 ug/L phosphorus
0.21 ug/L
7/08/2020 8.81 ug/L aluminum
5.81 ug/L
8/05/2020 8.81 ug/L aluminum
5.81 ug/L
8/19/2020 8.81 ug/L aluminum
5.81 ug/L
8/19/2020 7.4 mg/L total suspended solids 98.3 mg/L
Samples for fluoride, chromium, zinc and aluminum are collected on Mondays
or Wednesdays at Outfall 001. Samples for fluoride, chromium, zinc and
aluminum are collected on Tuesdays and Thursdays at Internal Monitoring
Station 605.
Bromine compounds are not used for disinfection. The permit does not
require total residual oxidants monitoring when bromine compounds are not
used.
Based on the most recent quarter of data (01/01/2021 - 03/31/2021), the
Facility was in significant non-compliance with carbonaceous biochemical
oxygen demand (CBOD5) and total suspended solids limitations at Outfall 001.
An ECHO Effluent Exceedance Report for the five years through 05/31/2021 is
included as Appendix 2.
Area of Concern?
Yes No Yes
SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted.
SECTION V - AREAS OF CONCERN
Areas of Concern may not be in sequential order.
The presentation of areas of concern does not constitute a formal compliance determination or violation.
No. MC3-OB-001
Area of Concern The Facility measures dissolved oxygen at Outfall 001 twice per shift. There was not a functioning continuous analyzer at the outfall.
MC3-OB-003
Permit Part I.A.: continuously monitor dissolved oxygen at Outfall 001 Flow at Outfall 001 is measured with an 18-inch Parshall flume and Endress+Hauser Prosonic S FMU90 ultrasonic transducer and recorder. Flow through the flume was turbulent with waves and surface boils (see Photos 11 and 12). The flow rate was spotchecked against the staff gauge. The gauge measurement was about 1.7 feet, which corresponds to 6,090 gallons per minute. The meter readout was 5,700 gallons per minute.
Permit Part I.A.: continuously measure flow rate at Outfall 001
Page 7 of 12
CAMPBELL SOUP SUPPLY COMPANY Inspection Date(s):
6/15/2021 - 6/16/2021
No. MC3-OB-004
Area of Concern Permit Part II.5.: the permittee shall periodically calibrate and perform maintenance procedures on all monitoring and analytical instrumentation at intervals to ensure accuracy of measurements Samples at Internal Monitoring Station 605 are collected from the overflow of a holding pit. Wastewater is pumped out of one end of the overflow trough to the wastewater treatment plant. Return flow from two pipes discharges into the end of the trough that is pumped (see Photo 19). The sampling location is at the end of the trough that is opposite of where it is pumped out. The set up may not allow for adequate mixing and a representative sample.
MC3-OB-005
Permit Part II.I.: samples shall be collected at such times and locations, and in such a fashion, as to be representative of the facility's overall performance Samples at Internal Monitoring Station 605 are collected as time-composite samples. An aliquot is collected every 15 minutes.
MC3-OB-006
Permit Part II.I.: composite samples shall be comprised of a series of grab samples collected over a 24-hour period and proportionate in volume to the wastewater flow rate at the time of sampling Composite samples at Internal Monitoring Station 605 are not cooled during collection.
MC3-OB-007
40 CFR 136.3(e): total suspended solids and phosphorus samples must be preserved at 6 C The readout on the flow meter recording device at Internal Monitoring Station 605 was erratic. The instantaneous readout varied between 12 and 45 gallons per minute over a period of about a minute. Wastewater is pumped with a fixed speed pump (see Photo 15) through an inline, horizontally-mounted meter (see Photo 16).
The meter appeared to be a magnetic flow meter. Magnetic flow meters are often mounted vertically to ensure the cross-section of the pipe is liquid-filled. Less than a full pipe at the measurement location may be affecting the reading of the flow meter.
MC3-OB-012
Permit Part I.A.: measure 24-hour total flow at Internal Monitoring Station 605 Permit Part II.5.: the permittee shall periodically calibrate and perform maintenance procedures on all monitoring and analytical instrumentation at intervals to ensure accuracy of measurements Primary dissolved air flotation tank #1 (DAF #1) had been out of service since October 2020. It was also out of service for some of the summer months in 2020.
Permit Part III.3.A.: at 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
Page 8 of 12
CAMPBELL SOUP SUPPLY COMPANY Inspection Date(s):
6/15/2021 - 6/16/2021
No. MC3-OB-013
Area of Concern The plastic media in the secondary roughing tower is breaking down. The Facility has a tentative plan to rebuild it in 2022.
MC3-RR-001
Permit Part III.3.A.: at 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 The permit fact sheet describes how compliance with effluent guideline limitations (EGLs) at 40 CFR 465.43, Subpart D - Canmaking Subcategory are verified. The fact sheet does not describe how compliance is verified when some, or all, wastewater is treated in spray fields, though it implies it is the same.
Compliance with the EGLs are verified by multiplying pollutant concentrations in untreated canmaking wastewater by one minus the removal efficiency for the pollutant by the wastewater treatment plant. Removal efficiencies were determined from wastewater treatment plant influent and effluent sampling. The removal efficiencies determined for zinc and aluminum were 27.5% and 14.9% respectively. The removal efficiency for chromium was determined to be 77.4%, which was based on two sample results above detection. Canmaking is the only source of chromium. Canmaking wastewater is diluted 50-fold entering the wastewater treatment plant. Most chromium samples taken for removal efficiency determination were below detection, which may be partially attributed to dilution. The wastewater treatment plant is a biological plant, so 77.4% removal for a metal may not be achieved. A chromium removal efficiency similar to the other metals (zinc and aluminum) may be more appropriate.
MC3-RR-003
40 CFR 465.43: maximum for any 1 day and maximum for monthly average The laboratory used by the Facility to analyze free cyanide uses method OIA 1677-09.
MC3-RR-004
Permit Part III.5.: test procedures for the analysis of pollutants shall conform to regulation 40 CFR 136 unless procedures have been specified in this permit Permit Part II.T.: the permittee shall utilize method 4500-CN I for analysis of free cyanide 40 CFR 136.3: Standard Methods 4500-CN I is not currently an approved test procedure. Method OIA 1677-09 is currently an approved test procedure. The Lead Inspector requested calibration records and meter information for the flow meter at Internal Monitoring Station 605 during the records review and close-out. The Facility has not provided the information.
Permit Part II.5.: the permittee shall periodically calibrate and perform maintenance procedures on all monitoring and analytical instrumentation at intervals to ensure accuracy of measurements.
Page 9 of 12
CAMPBELL SOUP SUPPLY COMPANY Inspection Date(s):
6/15/2021 - 6/16/2021
No. MC3-RR-005
Area of Concern The Facility could not recall having requested permission for the chiller and boiler treatment additives they use. They did not have a record(s) of written permission from the director of the Ohio EPA for additives prior to their use.
MC3-RR-006
Permit Part II.BB.: in the event that the permittee's operation requires the use of cooling or boiler water treatment additives that are discharged to surface waters of the state, written permission must be obtained from the director of the Ohio EPA prior to use There were several issues with chain of custody records. The 5/7/2020 upstream/downstream sample was marked as received at the lab before it was sampled by Industrial Fluid Management (IFM). Some nitrate + nitrite samples collected by IFM and sent to BoJhun Environmental Services (BoJhun) for analysis were not marked whether they were preserved with sulfuric acid. An IFM form for samples sent to BoJhun that was collected on 2/26/2021 was not marked whether samples were iced. Several forms for samples sent to MASI Environmental Laboratories were not marked whether samples were place on ice, and they lacked date and time the samples were relinquished. An IFM form for the upstream sample sent to BoJhun was marked as collected on 12/8/2021, but the correct date was 1/28/2021.
MC3-RR-007
40 CFR 136.3(e): total suspended solids, ammonia, nitrate + nitrate, CBOD 5-day, phosphorus, oil and grease, dissolved hexavalent chromium, cyanide, and total dissolved solids samples must be preserved at 6 C. E. coli samples must be preserved at 10 C. Nitrate + nitrite samples must be preserved with sulfuric acid to pH <2 Noncompliance reports for violations of daily maximum discharge limits were not submitted for violations that were discovered prior to October 2020.
MC3-RR-008
Part III.12.A.: the permittee shall report noncompliance that is the result of any violation of a daily maximum discharge limit for any of the pollutants listed by the Director in the permit by e-mail or telephone within twenty-four (24) hours of discovery There were 2 times (September/October 2020 and March/April 2021) when samples were not measured at the required monitoring frequency of 2 times per week at Outfall 001. The Facility stated their contract lab only samples the first 4 weeks of the month. Some pairs of months have nine weeks, in which case there may be a week when monitoring is not done.
MC3-RR-010
Permit Part I.A.1.: monitoring frequency for total suspended solids, ammonia-nitrogen, and total phosphorus is two times per week Compliance with categorical limits at 40 CFR 465.43 is calculated from measured concentrations of untreated wastewater at Internal Monitoring Station 605 and then multiplying by one minus the removal efficiency of the pollutant at the wastewater treatment plant. Results are reported as Station 099 measurements. The permit includes removal efficiencies to use in the calculation. Calculation errors were found when making a random check of discharge monitoring report (DMR) records. Examples are shown below.
Page 10 of 12
CAMPBELL SOUP SUPPLY COMPANY Inspection Date(s):
No.
Area of Concern
Date
5/13/2020
5/20/2020
6/04/2020
6/17/2020
6/17/2020
7/08/2020
7/08/2020
8/05/2020
8/19/2020
8/19/2020
DMR Value 0.021 mg/L fluoride 11.07 ug/L aluminum 8.59 ug/L aluminum 26.82 ug/L zinc 37 ug/L aluminum 0.29 ug/L phosphorus 8.81 ug/L aluminum 8.81 ug/L aluminum 8.81 ug/L aluminum 7.4 mg/L total suspended solids
6/15/2021 - 6/16/2021
Correct Value 0.2 mg/L 7.3 ug/L 5.67 ug/L 54.2 ug/L 37.8 ug/L 0.21 ug/L 5.81 ug/L 5.81 ug/L 5.81 ug/L 98.3 mg/L
MC3-RR-011
Permit Part I.A.1.: final effluent limitations and monitoring requirements for Station 099 Samples for fluoride, chromium, zinc and aluminum are collected on Mondays or Wednesdays at Outfall 001. Samples for fluoride, chromium, zinc and aluminum are collected on Tuesdays and Thursdays at Internal Monitoring Station 605.
MC3-RR-013
Permit Part I.A. and Part II.II.: sampling for fluoride, chromium, zinc and aluminum at stations 2IH00021001, 2IH00021601, 2IH00021604 and 2IH00021605 shall occur the same day Based on the most recent quarter of data (01/01/2021 - 03/31/2021), the Facility was in significant non-compliance with carbonaceous biochemical oxygen demand (CBOD5) and total suspended solids limitations at Outfall 001. An ECHO Effluent Exceedance Report for the five years through 05/31/2021 is included as Appendix 2.
40 CFR 123.45 and Permit Part I.A.
SECTION VI - CLOSING CONFERENCE AND FOLLOW UP
Closing Conference
The Lead Inspector held a closing conference with Facility personnel on 06/16/2021 for the inspection. During the closing conference, the Lead Inspector discussed the observations and Areas of Concern identified during the inspection. Observations and Areas 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.
No. MC3-RR-004
Follow Up Item The Lead Inspector requested calibration records and meter information for the flow meter at Internal Monitoring Station 605 during the records review and closing conference.
Page 11 of 12
CAMPBELL SOUP SUPPLY COMPANY Inspection Date(s):
6/15/2021 - 6/16/2021
Communication Log
No additional information received by the Lead inspector after exiting the Facility on 06/16/2021.
SECTION VII - LIST OF APPENDICES
Appendix 1 - Photo Log Appendix 2 - ECHO Effluent Exceedance Report
Page 12 of 12
Facility Name & Location: Campbell Soup Supply Corporation, LLC 12-773 State Route 110, Napoleon, Ohio
Date Photograph Was Taken: 6/15/2021
Photo No.: 1
Time: 8:57 AM
Direction Photo Taken: down
Photo Description: This is the 36-inch rectangular weir and ultrasonic transducer for measuring flow rate at Outfall 006.
Photographer: Mark Conti
Camera: Canon PowerShot SD1400 IS (S/N 212065043406)
File: Campbell IMG_0001
APPENDIX 1, Page 1 of 16
Facility Name & Location: Campbell Soup Supply Corporation, LLC 12-773 State Route 110, Napoleon, Ohio
Date Photograph Was Taken: 6/15/2021
Photo No.: 2
Time: 8:59 AM
Direction Photo Taken: --
Photo Description: This is the Endress+Hauser Prosonic S FMU90 flow recorder at Outfall 006.
Photographer: Mark Conti
Camera: Canon PowerShot SD1400 IS (S/N 212065043406)
File: Campbell IMG_0002
APPENDIX 1, Page 2 of 16
Facility Name & Location: Campbell Soup Supply Corporation, LLC 12-773 State Route 110, Napoleon, Ohio
Date Photograph Was Taken: 6/15/2021
Photo No.: 4
Time: 9:13 AM
Direction Photo Taken: north
Photo Description: This is the 36-inch rectangular weir and ultrasonic transducer for measuring flow rate at Outfall 007.
Photographer: Mark Conti
Camera: Canon PowerShot SD1400 IS (S/N 212065043406)
File: Campbell IMG_0004
APPENDIX 1, Page 3 of 16
Facility Name & Location: Campbell Soup Supply Corporation, LLC 12-773 State Route 110, Napoleon, Ohio
Date Photograph Was Taken: 6/15/2021
Photo No.: 6
Time: 9:26 AM
Direction Photo Taken: down
Photo Description: This is the 36-inch rectangular weir and ultrasonic transducer for measuring flow rate at Outfall 009.
Photographer: Mark Conti
Camera: Canon PowerShot SD1400 IS (S/N 212065043406)
File: Campbell IMG_0006
APPENDIX 1, Page 4 of 16
Facility Name & Location: Campbell Soup Supply Corporation, LLC 12-773 State Route 110, Napoleon, Ohio
Date Photograph Was Taken: 6/15/2021
Photo No.: 8
Time: 9:36 AM
Direction Photo Taken: southeast
Photo Description: This is the 36-inch rectangular weir and ultrasonic transducer for measuring flow rate at Outfall 008.
Photographer: Mark Conti
Camera: Canon PowerShot SD1400 IS (S/N 212065043406)
File: Campbell IMG_0008
APPENDIX 1, Page 5 of 16
Facility Name & Location: Campbell Soup Supply Corporation, LLC 12-773 State Route 110, Napoleon, Ohio
Date Photograph Was Taken: 6/15/2021
Photo No.: 9
Time: 10:34 AM
Direction Photo Taken: --
Photo Description: A Hach AS950 sampler is used to collect 24-hour flowproportional composite samples at Outfall 001. Samples are collected in a 2.5gallon polyethylene bottle. The bottle thermometer in the refrigerator indicated samples were cooled to 4 C.
File: Campbell IMG_0009
Photographer: Mark Conti
Camera: Canon PowerShot SD1400 IS (S/N 212065043406)
APPENDIX 1, Page 6 of 16
Facility Name & Location: Campbell Soup Supply Corporation, LLC 12-773 State Route 110, Napoleon, Ohio
Date Photograph Was Taken: 6/15/2021
Photo No.: 10
Time: 10:35 AM
Direction Photo Taken: --
Photo Description: This is the controller for the Hach AS950 sampler used to collect 24-hour flowproportional composite samples at Outfall 001. The display showed the program was running, 7 aliquots had been collected, aliquot collection was flowbased, and the cabinet was at 3.4 C.
File: Campbell IMG_0010
Photographer: Mark Conti
Camera: Canon PowerShot SD1400 IS (S/N 212065043406)
APPENDIX 1, Page 7 of 16
Facility Name & Location: Campbell Soup Supply Corporation, LLC 12-773 State Route 110, Napoleon, Ohio
Date Photograph Was Taken: 6/15/2021
Photo No.: 11
Time: 10:36 AM
Direction Photo Taken: southeast
Photo Description: This is the 18-inch Parshall flume and Endress+Hauser Prosonic S FMU90 ultrasonic transducer for measuring final discharge flow rate at Outfall 001.
Photographer: Mark Conti
File: Campbell IMG_0011
Camera: Canon PowerShot SD1400 IS (S/N 212065043406)
APPENDIX 1, Page 8 of 16
Facility Name & Location: Campbell Soup Supply Corporation, LLC 12-773 State Route 110, Napoleon, Ohio
Date Photograph Was Taken: 6/15/2021
Photo No.: 12
Time: 10:37 AM
Direction Photo Taken: down
Photo Description: This is the 18-inch Parshall flume and Endress+Hauser Prosonic S FMU90 ultrasonic transducer for measuring final discharge flow rate at Outfall 001. There is also a staff gauge at the measurement location, which was mostly obscured with algae.
File: Campbell IMG_0012
Photographer: Mark Conti
Camera: Canon PowerShot SD1400 IS (S/N 212065043406)
APPENDIX 1, Page 9 of 16
Facility Name & Location: Campbell Soup Supply Corporation, LLC 12-773 State Route 110, Napoleon, Ohio
Date Photograph Was Taken: 6/15/2021
Photo No.: 13
Time: 10:37 AM
Direction Photo Taken: --
Photo Description: An Endress+Hauser Prosonic S FMU90 ultrasonic transducer and recorder measures flow rate at Outfall 001.
Photographer: Mark Conti
Camera: Canon PowerShot SD1400 IS (S/N 212065043406)
File: Campbell IMG_0013
APPENDIX 1, Page 10 of 16
Facility Name & Location: Campbell Soup Supply Corporation, LLC 12-773 State Route 110, Napoleon, Ohio
Date Photograph Was Taken: 6/15/2021
Photo No.: 14
Time: 10:37 AM
Direction Photo Taken: --
Photo Description: The Endress+Hauser Prosonic S FMU90 flow recorder at Outfall 001 was calibrated on 10/6/2020.
Photographer: Mark Conti
Camera: Canon PowerShot SD1400 IS (S/N 212065043406)
File: Campbell IMG_0014
APPENDIX 1, Page 11 of 16
Facility Name & Location: Campbell Soup Supply Corporation, LLC 12-773 State Route 110, Napoleon, Ohio
Date Photograph Was Taken: 6/15/2021
Photo No.: 15
Time: 1:55 PM
Direction Photo Taken: indoors
Photo Description: Samples for Internal Monitoring Station 605 are collected from the trough under this grate. Silgan Containers pumps their canmaking wastewater to Campbell's wastewater treatment plant.
File: Campbell IMG_0015
Photographer: Mark Conti
Camera: Canon PowerShot SD1400 IS (S/N 212065043406)
APPENDIX 1, Page 12 of 16
Facility Name & Location: Campbell Soup Supply Corporation, LLC 12-773 State Route 110, Napoleon, Ohio
Date Photograph Was Taken: 6/15/2021
Photo No.: 16
Time: 1:55 PM
Direction Photo Taken: up
Photo Description: This is the device for measuring the flow rate of wastewater pumped from Silgan Containers to Campbell's wastewater treatment plant.
Photographer: Mark Conti
File: Campbell IMG_0016
Camera: Canon PowerShot SD1400 IS (S/N 212065043406)
APPENDIX 1, Page 13 of 16
Facility Name & Location: Campbell Soup Supply Corporation, LLC 12-773 State Route 110, Napoleon, Ohio
Date Photograph Was Taken: 6/15/2021
Photo No.: 17
Time: 1:56 PM
Direction Photo Taken: indoors
Photo Description: This is the flow recorder for recording flow rate and totalizing 24-hour flow of wastewater pumped from Silgan Containers to Campbell's wastewater treatment plant.
File: Campbell IMG_0017
Photographer: Mark Conti
Camera: Canon PowerShot SD1400 IS (S/N 212065043406)
APPENDIX 1, Page 14 of 16
Facility Name & Location: Campbell Soup Supply Corporation, LLC 12-773 State Route 110, Napoleon, Ohio
Date Photograph Was Taken: 6/15/2021
Photo No.: 18
Time: 1:56 PM
Direction Photo Taken: indoors
Photo Description: This is the ISCO automatic sampler used by Silgan Containers for collecting composite samples at Internal Monitoring Station 605.
Photographer: Mark Conti
File: Campbell IMG_0018
Camera: Canon PowerShot SD1400 IS (S/N 212065043406)
APPENDIX 1, Page 15 of 16
Facility Name & Location: Campbell Soup Supply Corporation, LLC 12-773 State Route 110, Napoleon, Ohio
Date Photograph Was Taken: 6/15/2021
Photo No.: 19
Time: 1:58 PM
Direction Photo Taken: down
Photo Description: This is looking down into a trough that receives rinse water from canmaking. Silgan Containers pumps the wastewater to Campbell's wastewater treatment plant through the black corrugated plastic pipe behind the ladder.
File: Campbell IMG_0019
Photographer: Mark Conti
Camera: Canon PowerShot SD1400 IS (S/N 212065043406)
APPENDIX 1, Page 16 of 16
ECHO Effluent Exceedances Report Monitoring Period Date Range: 06/01/2016 to 05/31/2021
Monitoring Period
6/30/2016 7/31/2016 7/31/2016 7/31/2016 7/31/2016 7/31/2016 7/31/2016 7/31/2016 7/31/2016 7/31/2016 7/31/2016 8/31/2016 9/30/2016 9/30/2016 3/31/2017 3/31/2017 4/30/2017 6/30/2017 7/31/2017 7/31/2017 7/31/2017 7/31/2017 7/31/2017 7/31/2017 7/31/2017 8/31/2017 8/31/2017 8/31/2017 8/31/2017 8/31/2017 8/31/2017
Outfall 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001
Parameter Description BOD, carbonaceous, 5-day Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Phosphorus, total (as P) Phosphorus, total (as P) Phosphorus, total (as P) Phosphorus, total (as P) E. coli, MTEC-MF BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day Phosphorus, total (as P) Phosphorus, total (as P) BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day Oxygen, dissolved (DO) E. coli, MTEC-MF Solids, total suspended Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day Phosphorus, total (as P) Phosphorus, total (as P) BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day
Limit Type DAILY MX DAILY MX MO AVG DAILY MX MO AVG MO AVG DAILY MX DAILY MX WK GEOMN MO AVG DAILY MX DAILY MX DAILY MX MO AVG DAILY MX MO AVG DAILY MN WK GEOMN DAILY MX DAILY MX DAILY MX DAILY MX MO AVG MO AVG DAILY MX MO AVG DAILY MX DAILY MX MO AVG MO AVG DAILY MX
DMR DMR Value Value Unit
45 mg/L 10 mg/L
3 mg/L 190 kg/d
3 mg/L 54 kg/d 203 kg/d 10 mg/L 3,450 MPN/100mL 34 mg/L 67 mg/L 59 mg/L
2 mg/L 1 mg/L 55 mg/L 30 mg/L 4 mg/L 24,200 MPN/100mL 50 mg/L 4 mg/L 120 kg/d 2,300 kg/d 45 mg/L 1,300 kg/d 83 mg/L 1 mg/L 2 mg/L 1,800 kg/d 1,100 kg/d 37 mg/L 64 mg/L
APPENDIX 2, Page 1 of 7
Limit Value
40 3.5 1.6 90.9
1 37.9 56.8
1.5 284
25 40 40 1.5
1 40 25
5 284
45 3.5 90.9 1520 25 947 40
1 1.5 1520 947 25 40
Limit Value Limit Value Qualifier Unit
<= mg/L <= mg/L <= mg/L <= kg/d <= mg/L <= kg/d <= kg/d <= mg/L <= MPN/100mL <= mg/L <= mg/L <= mg/L <= mg/L <= mg/L <= mg/L <= mg/L >= mg/L <= MPN/100mL <= mg/L <= mg/L <= kg/d <= kg/d <= mg/L <= kg/d <= mg/L <= mg/L <= mg/L <= kg/d <= kg/d <= mg/L <= mg/L
% Exceedance
13 171
63 109 168
43 257 562 1,115
36 68 48 17 24 38 20 18 8,421 11 11 32 51 80 37 108 30 25 18 16 48 60
ECHO Effluent Exceedances Report Monitoring Period Date Range: 06/01/2016 to 05/31/2021
Monitoring Period
9/30/2017 9/30/2017 9/30/2017 10/31/2017 10/31/2017 10/31/2017 10/31/2017 10/31/2017 10/31/2017 11/30/2017 12/31/2017 12/31/2017 2/28/2018 3/31/2018 3/31/2018 6/30/2018 6/30/2018 7/31/2018 7/31/2018 7/31/2018 8/31/2018 8/31/2018 8/31/2018 8/31/2018 8/31/2018 8/31/2018 8/31/2018 8/31/2018 9/30/2018 9/30/2018 9/30/2018
Outfall 001 001 001 001 001 001 001 099 099 001 001 001 001 001 001 001 099 001 006 006 001 001 001 006 008 008 009 009 001 001 001
Parameter Description Phosphorus, total (as P) Phosphorus, total (as P) BOD, carbonaceous, 5-day Phosphorus, total (as P) Phosphorus, total (as P) BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day Oil and grease (soxhlet extr.) tot. Oil and grease (soxhlet extr.) tot. BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day E. coli, MTEC-MF Oil and grease (soxhlet extr.) tot. E. coli, MTEC-MF Oxygen, dissolved (DO) pH, minimum Solids, total suspended BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day pH, maximum Oxygen, dissolved (DO) pH, minimum Oxygen, dissolved (DO) pH, minimum Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N)
Limit Type DAILY MX MO AVG DAILY MX DAILY MX MO AVG DAILY MX MO AVG MO AVG DAILY MX DAILY MX DAILY MX MO AVG MO AVG DAILY MX MO AVG WK GEOMN MO AVG WK GEOMN DAILY MN DAILY MN DAILY MX DAILY MX DAILY MX DAILY MX DAILY MN DAILY MN DAILY MN DAILY MN DAILY MX DAILY MX MO AVG
DMR DMR Value Value Unit
2 mg/L 1 mg/L 46 mg/L 2 mg/L 1 mg/L 50 mg/L 32 mg/L 4 kg/d 6 kg/d 50 mg/L 42 mg/L 27 mg/L 29 mg/L 47 mg/L 26 mg/L 910 MPN/100mL 3 kg/d 5,470 MPN/100mL 3 mg/L 5 SU 50 mg/L 57 mg/L 1,900 kg/d 11 SU 3 mg/L 6 SU 5 mg/L 4 SU 12 mg/L 343 kg/d 3 mg/L
APPENDIX 2, Page 2 of 7
Limit Value
1.5 1
40 1.5
1 40 25 3.08 5.13 40 40 25 25 40 25 284 3.08 284
5 6.5 45 40 1520
9 5 6.5 5 6.5 3.5 90.9 1.6
Limit Value Limit Value Qualifier Unit
<= mg/L <= mg/L <= mg/L <= mg/L <= mg/L <= mg/L <= mg/L <= kg/d <= kg/d <= mg/L <= mg/L <= mg/L <= mg/L <= mg/L <= mg/L <= MPN/100mL <= kg/d <= MPN/100mL >= mg/L >= SU <= mg/L <= mg/L <= kg/d <= SU >= mg/L >= SU >= mg/L >= SU <= mg/L <= kg/d <= mg/L
% Exceedance
11 16 15 15 22 25 28 17 18 25
5 8 16 18 4 220 10 1,826 48
11 43 25
46
6
254 277
76
ECHO Effluent Exceedances Report Monitoring Period Date Range: 06/01/2016 to 05/31/2021
Monitoring Period
9/30/2018 9/30/2018 9/30/2018 9/30/2018 9/30/2018 9/30/2018 10/31/2018 10/31/2018 10/31/2018 10/31/2018 10/31/2018 11/30/2018 1/31/2019 4/30/2019 5/31/2019 5/31/2019 6/30/2019 6/30/2019 7/31/2019 7/31/2019 7/31/2019 7/31/2019 7/31/2019 7/31/2019 7/31/2019 7/31/2019 8/31/2019 8/31/2019 8/31/2019 8/31/2019 8/31/2019
Outfall 001 001 001 006 006 009 001 001 001 001 006 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 006 008
Parameter Description Nitrogen, ammonia total (as N) Phosphorus, total (as P) E. coli, MTEC-MF pH, maximum pH, minimum Oxygen, dissolved (DO) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Phosphorus, total (as P) Phosphorus, total (as P) pH, maximum pH, maximum pH, minimum Solids, total suspended Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Phosphorus, total (as P) Phosphorus, total (as P) Solids, total suspended Solids, total suspended Phosphorus, total (as P) Phosphorus, total (as P) E. coli, MTEC-MF BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day E. coli, MTEC-MF BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day Phosphorus, total (as P) Oxygen, dissolved (DO)
Limit Type MO AVG MO AVG WK GEOMN DAILY MX DAILY MN DAILY MN MO AVG DAILY MX MO AVG DAILY MX DAILY MX DAILY MX DAILY MN DAILY MX DAILY MX DAILY MX MO AVG DAILY MX MO AVG DAILY MX MO AVG DAILY MX WK GEOMN DAILY MX MO AVG DAILY MX WK GEOMN MO AVG DAILY MX MO AVG DAILY MN
DMR DMR Value Value Unit
80 kg/d 1 mg/L
285 MPN/100mL 10 SU 6 SU 4 mg/L 2 mg/L 93 kg/d 1 mg/L 2 mg/L 9 SU 10 SU 6 SU 52 mg/L 10 mg/L
240 kg/d 1 mg/L 2 mg/L
36 mg/L 47 mg/L
1 mg/L 2 mg/L 650 MPN/100mL 60 mg/L 34 mg/L 1,700 kg/d 537 MPN/100mL 28 mg/L 61 mg/L 1 mg/L 4 mg/L
APPENDIX 2, Page 3 of 7
Limit Value
60.6 1
284 9
6.5 5
1.6 90.9
1 1.5
9 9 6.5 45 3.5 90.9 1 1.5 30 45 1 1.5 284 40 25 1520 284 25 40 1 5
Limit Value Limit Value Qualifier Unit
<= kg/d <= mg/L <= MPN/100mL <= SU >= SU >= mg/L <= mg/L <= kg/d <= mg/L <= mg/L <= SU <= SU >= SU <= mg/L <= mg/L <= kg/d <= mg/L <= mg/L <= mg/L <= mg/L <= mg/L <= mg/L <= MPN/100mL <= mg/L <= mg/L <= kg/d <= MPN/100mL <= mg/L <= mg/L <= mg/L >= mg/L
% Exceedance
32 10 -
14 19
2 10
7
16 174 164 10 20 20
4 30
7 129
50 36 12 89 12 53 10 18
ECHO Effluent Exceedances Report Monitoring Period Date Range: 06/01/2016 to 05/31/2021
Monitoring Period
9/30/2019 9/30/2019 9/30/2019 9/30/2019 9/30/2019 9/30/2019 9/30/2019 9/30/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 11/30/2019 12/31/2019 12/31/2019 12/31/2019 5/31/2020 5/31/2020 5/31/2020 5/31/2020 5/31/2020 5/31/2020
Outfall 001 001 001 001 006 007 008 009 001 001 001 001 001 001 001 006 007 099 099 099 099 009 001 001 001 001 001 001 001 001 001
Parameter Description Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Phosphorus, total (as P) Phosphorus, total (as P) Oxygen, dissolved (DO) pH, maximum Application rate area sprayed Application rate area sprayed Solids, total suspended Solids, total suspended Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Phosphorus, total (as P) Phosphorus, total (as P) BOD, carbonaceous, 5-day Oxygen, dissolved (DO) Phosphorus, total (as P) Solids, total suspended Solids, total suspended Oil and grease (soxhlet extr.) tot. Oil and grease (soxhlet extr.) tot. Solids, total suspended Chlorine, total residual Chlorine, total residual pH, minimum Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Phosphorus, total (as P) Phosphorus, total (as P) Phosphorus, total (as P)
Limit Type DAILY MX DAILY MX MO AVG DAILY MX DAILY MN DAILY MX DAILY MX DAILY MX MO AVG DAILY MX DAILY MX MO AVG DAILY MX MO AVG DAILY MX DAILY MN MO AVG DAILY MX MO AVG DAILY MX MO AVG MO AVG DAILY MX DAILY MX DAILY MN MO AVG DAILY MX DAILY MX DAILY MX MO AVG DAILY MX
DMR DMR Value Value Unit
5 mg/L 130 kg/d
1 mg/L 2 mg/L 4 mg/L 10 SU 1 in/d 1 in/d 31 mg/L 56 mg/L 4 mg/L 2 mg/L 2 mg/L 1 mg/L 58 mg/L 5 mg/L 1 mg/L 41 kg/d 40 kg/d 17 kg/d 11 kg/d 43 mg/L 0 mg/L 2 kg/d 6 SU 2 mg/L 140 kg/d 5 mg/L 3 mg/L 1 mg/L 83 kg/d
APPENDIX 2, Page 4 of 7
Limit Value
3.5 90.9
1 1.5
5 9 0.75 0.75 30 45 3.5 1.6 1.5 1 40 5 1 10.51 5 5.13 3.08 30 0.038 1.44 6.5 1.6 90.9 3.5 1.5 1 56.8
Limit Value Limit Value Qualifier Unit
<= mg/L <= kg/d <= mg/L <= mg/L >= mg/L <= SU <= in/d <= in/d <= mg/L <= mg/L <= mg/L <= mg/L <= mg/L <= mg/L <= mg/L >= mg/L <= mg/L <= kg/d <= kg/d <= kg/d <= kg/d <= mg/L <= mg/L <= kg/d >= SU <= mg/L <= kg/d <= mg/L <= mg/L <= mg/L <= kg/d
% Exceedance
40 43 28 20 30
7 20
3 24 11 38 27 40 45
4 20 285 692 231 257 43 84 32
25 54 40 102 24 45
ECHO Effluent Exceedances Report Monitoring Period Date Range: 06/01/2016 to 05/31/2021
Monitoring Period
5/31/2020 5/31/2020 6/30/2020 6/30/2020 6/30/2020 6/30/2020 6/30/2020 6/30/2020 6/30/2020 6/30/2020 6/30/2020 6/30/2020 6/30/2020 7/31/2020 7/31/2020 7/31/2020 8/31/2020 8/31/2020 8/31/2020 8/31/2020 8/31/2020 9/30/2020 9/30/2020 9/30/2020 9/30/2020 9/30/2020 10/31/2020 10/31/2020 10/31/2020 10/31/2020 10/31/2020
Outfall 001 001 001 001 001 001 001 001 001 001 001 001 001 001 006 008 001 001 001 001 007 001 001 001 001 008 001 001 001 001 001
Parameter Description Chlorine, total residual Chlorine, total residual Solids, total suspended Solids, total suspended Solids, total suspended Phosphorus, total (as P) Phosphorus, total (as P) Phosphorus, total (as P) Phosphorus, total (as P) BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day E. coli, MTEC-MF Phosphorus, total (as P) Phosphorus, total (as P) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) E. coli, MTEC-MF Application rate area sprayed Phosphorus, total (as P) Phosphorus, total (as P) BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day Phosphorus, total (as P) Phosphorus, total (as P) Phosphorus, total (as P) E. coli, MTEC-MF BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day
Limit Type DAILY MX DAILY MX DAILY MX DAILY MX MO AVG DAILY MX MO AVG MO AVG DAILY MX DAILY MX MO AVG DAILY MX MO AVG WK GEOMN MO AVG MO AVG DAILY MX MO AVG DAILY MX WK GEOMN DAILY MX DAILY MX MO AVG MO AVG DAILY MX MO AVG DAILY MX MO AVG WK GEOMN MO AVG DAILY MX
DMR DMR Value Value Unit
0 mg/L 11 kg/d 1,800 kg/d 63 mg/L 36 mg/L 61 kg/d 44 kg/d
1 mg/L 2 mg/L 2,000 kg/d 1,100 kg/d 63 mg/L 35 mg/L 960 MPN/100mL 1 mg/L 1 mg/L 9 mg/L 2 mg/L 220 kg/d 2,720 MPN/100mL 1 in/d 2 mg/L 1 mg/L 26 mg/L 57 mg/L 1 mg/L 2 mg/L 1 mg/L 8,160 MPN/100mL 31 mg/L 47 mg/L
APPENDIX 2, Page 5 of 7
Limit Value 0.038
1.44 1710
45 30 56.8 37.9
1 1.5 1520 947 40 25 284
1 1 3.5 1.6 90.9 284 0.75 1.5 1 25 40 1 1.5 1 284 25 40
Limit Value Limit Value Qualifier Unit
<= mg/L <= kg/d <= kg/d <= mg/L <= mg/L <= kg/d <= kg/d <= mg/L <= mg/L <= kg/d <= kg/d <= mg/L <= mg/L <= MPN/100mL <= mg/L <= mg/L <= mg/L <= mg/L <= kg/d <= MPN/100mL <= in/d <= mg/L <= mg/L <= mg/L <= mg/L <= mg/L <= mg/L <= mg/L <= MPN/100mL <= mg/L <= mg/L
% Exceedance
953 664
5 40 20
7 16 45 25 32 16 58 40 238 17
2 151
19 142 858
1 23 40
4 43
6 14 26 2,773 24 18
ECHO Effluent Exceedances Report Monitoring Period Date Range: 06/01/2016 to 05/31/2021
Monitoring Period
10/31/2020 10/31/2020 12/31/2020 12/31/2020 12/31/2020 12/31/2020 12/31/2020
1/31/2021 1/31/2021 1/31/2021 1/31/2021 1/31/2021 1/31/2021 1/31/2021 2/28/2021 2/28/2021 2/28/2021 2/28/2021 2/28/2021 2/28/2021 2/28/2021 2/28/2021 2/28/2021 2/28/2021 2/28/2021 3/31/2021 3/31/2021 3/31/2021 3/31/2021 3/31/2021 3/31/2021
Outfall 008 009 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 099 001 001 001 001 001 001
Parameter Description Phosphorus, total (as P) BOD, carbonaceous, 5-day Solids, total suspended Solids, total suspended BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Phosphorus, total (as P) Phosphorus, total (as P) BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Phosphorus, total (as P) BOD, carbonaceous, 5-day
Limit Type MO AVG DAILY MX DAILY MX MO AVG DAILY MX MO AVG DAILY MX MO AVG DAILY MX MO AVG DAILY MX MO AVG DAILY MX DAILY MX DAILY MX MO AVG MO AVG DAILY MX DAILY MX MO AVG MO AVG DAILY MX MO AVG DAILY MX MO AVG MO AVG DAILY MX MO AVG DAILY MX MO AVG MO AVG
DMR DMR Value Value Unit
1 mg/L 42 mg/L 68 mg/L 34 mg/L 81 mg/L 36 mg/L 1,600 kg/d 1,200 kg/d 88 mg/L 46 mg/L 2,200 kg/d 35 mg/L 1,900 kg/d 71 mg/L 132 mg/L 2,050 kg/d 83 mg/L 2,950 kg/d
2 mg/L 1 mg/L 2,240 kg/d 3,040 kg/d 90 mg/L 120 mg/L 5 kg/d 62 mg/L 84 mg/L 1,600 kg/d 2,200 kg/d 1 mg/L 1,500 kg/d
APPENDIX 2, Page 6 of 7
Limit Value
1 40 45 30 40 25 1520 1140 45 30 1710 25 1520 40 45 1140 30 1710 1.5
1 947 1520
25 40
5 30 45 1140 1710
1 947
Limit Value Limit Value Qualifier Unit
<= mg/L <= mg/L <= mg/L <= mg/L <= mg/L <= mg/L <= kg/d <= kg/d <= mg/L <= mg/L <= kg/d <= mg/L <= kg/d <= mg/L <= mg/L <= kg/d <= mg/L <= kg/d <= mg/L <= mg/L <= kg/d <= kg/d <= mg/L <= mg/L <= kg/d <= mg/L <= mg/L <= kg/d <= kg/d <= mg/L <= kg/d
% Exceedance
47 5
51 13 103 44
5 5 96 53 29 40 25 78 193 80 176 73 23 35 137 100 260 200 2 107 87 40 29 10 58
ECHO Effluent Exceedances Report Monitoring Period Date Range: 06/01/2016 to 05/31/2021
Monitoring Period
3/31/2021 3/31/2021 3/31/2021 4/30/2021 4/30/2021 4/30/2021 4/30/2021 4/30/2021 5/31/2021 5/31/2021 5/31/2021 5/31/2021 5/31/2021 5/31/2021 5/31/2021
Outfall 001 001 001 001 001 001 001 099 001 001 001 001 001 001 001
Parameter Description BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day Solids, total suspended Solids, total suspended BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day Oil and grease (soxhlet extr.) tot. Solids, total suspended Solids, total suspended Solids, total suspended E. coli, MTEC-MF E. coli, MTEC-MF BOD, carbonaceous, 5-day BOD, carbonaceous, 5-day
Limit Type DAILY MX DAILY MX MO AVG MO AVG DAILY MX MO AVG DAILY MX MO AVG DAILY MX DAILY MX MO AVG WK GEOMN MO GEOMN DAILY MX DAILY MX
DMR DMR Value Value Unit 2,600 kg/d
99 mg/L 58 mg/L 39 mg/L 52 mg/L 27 mg/L 47 mg/L
4 kg/d 68 mg/L 2,200 kg/d 32 mg/L 7,700 MPN/100mL 1,405 MPN/100mL 1,700 kg/d 52 mg/L
Limit Value 1520
40 25 30 45 25 40 3.08 45 1710 30 284 126 1520 40
Limit Value Limit Value Qualifier Unit
<= kg/d <= mg/L <= mg/L <= mg/L <= mg/L <= mg/L <= mg/L <= kg/d <= mg/L <= kg/d <= mg/L <= MPN/100mL <= MPN/100mL <= kg/d <= mg/L
% Exceedance
71 148 132
30 16
8 18 20 51 29
7 2,611 1,015
12 30
APPENDIX 2, Page 7 of 7
