Document 2K8X6JyRyop0Z7oNDw4jYDMR

COMPLIANCE EVALUATION INSPECTION REPORT U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 5 Purpose: NPDES Compliance Evaluation Inspection Facility: The Kraft Heinz Company 1701 West Bradley Avenue Champaign, Illinois 61821 Date of Inspection: August 21, 2023 EPA Inspectors: Val Dooling, Environmental Engineer, (312) 886-7167 Newton Ellens, Pretreatment Program Manager, (312) 353-5562 Illinois EPA Inspectors: Jeffery Holste, Environmental Protection Engineer Amelia Allen, Environmental Protection Engineer Kraft Heinz Representatives: Heather Conover, Operations Risk Manager William George, Site Lead Mickey Frantz, Lead Operations Risk Manager Urbana and Champaign Sanitary District Representatives: Rick Manner, Executive Director Wade Lagle, Director of Operations Trent Lyons, Laboratory Supervisor Report Prepared By: Val Dooling, Environmental Engineer EPA Inspector Signature and Date: VALERIE Digitally signed by VALERIE DOOLING Date: 2023.11.13 _D_O__O_L_I_N_G_____1_6:_44_:5_5 -_06_'0_0'_________________________ Approver Name and Title: Ryan J. Bahr, Section 2 Supervisor Water Enforcement and Compliance Assurance Branch Approver Signature and Date: Digitally signed by RYAN RYAN BAHR Date: 2023.11.16 BAHR _____________1_7:_04_:3_8 -_06_'0_0'_________________________ TABLE OF CONTENTS I. Introduction ................................................................................................................................. 1 II. Background ................................................................................................................................ 1 III. Opening Conference at UCSD.................................................................................................. 1 IV. Discussion at UCSD ................................................................................................................. 1 V. Opening Conference at Kraft Heinz........................................................................................... 4 VI. Discussion at Kraft Heinz ......................................................................................................... 4 VII. Kraft Heinz Site Visit .............................................................................................................. 6 VIII. Closing Conference................................................................................................................ 7 LIST OF APPENDICES Appendix A: Photo Log Appendix B: Aerial images of Kraft Heinz Appendix C: Kraft Heinz Significant Industrial Permit issued by UCSD Appendix D: Memoranda of activity by UCSD Representatives Appendix E: Email correspondence between UCSD and Kraft Heinz Appendix F: Influent Loading Measured at UCSD on August 4 - 7, 2023 Appendix G: Monthly Samples Collected at Kraft Effluent in 2023 Appendix H: Graph of Average Monthly Flow discharged by Kraft Heinz The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 I. INTRODUCTION The purpose of the report is to describe, evaluate and document the Kraft Heinz Company's compliance with the Clean Water Act (CWA) and Urbana Champaign Sanitary District's compliance with the CWA and its National Pollutant Discharge Elimination System (NPDES) permit. II. BACKGROUND On August 21, 2023, EPA conducted a Clean Water Act Compliance Evaluation Inspection at the Urbana Champaign Sanitary District (UCSD) Northeast Plant located at 1100 East University Avenue in Urbana Illinois 61802 and at The Kraft Heinz Company (Kraft Heinz) at 1701 West Bradley Avenue in Champaign, Illinois 61821, an industrial user of UCSD. UCSD holds NPDES Permit IL0031500 issued by Illinois Environmental Protection Agency (IEPA) effective October 1, 2020 and expires on September 30, 2025, which authorizes Pretreatment Program General Provision in Special Condition 12. UCSD has determined Kraft Foods is a significant Industrial User and has issued Wastewater Discharge Permit KHF-22-23 to Kraft Heinz. Permit KHF-22-23 states that the User shall comply with all applicable requirements of Sections 501 and 502 of the UCSD Ordinance 678. III. OPENING CONFERENCE AT UCSD Inspector Ellens and I arrived at UCSD at 10:00 am and met IEPA Inspectors Jeffrey Holste and Amelia Allen. We entered together and met with UCSD Representatives: Rick Manner, Executive Director; Wade Lagle, Director of Operations; and Trent Lyon, Laboratory Supervisor. Inspector Ellens and I showed our credentials to Mr. Manner. IV. DISCUSSION AT UCSD Mr. Lagle explained the following chain of events beginning with Friday August 4th in the afternoon when he noticed the influent at the Northeast Sewage Treatment Plant was darker than normal around 3:00 pm. The events are documented in the memoranda in Appendix D. The influent ammonia concentration began increasing at that time and throughout the evening (Appendix F). At that time the blowers were taken out of automatic and put into manual as well as changes made to the aeration basin to accommodate the higher demand of oxygen and an increase in flow split and recirculation rates. Mr. Lagle stated that due to the adjustments which were made at the plant, the effluent did not exceed NPDES permit limits. Mr. Lagle recalled that on Monday August 7th he received an email and phone call from the wastewater pretreatment operator at Kraft Heinz, Darin Colter. In that call, the operator stated that over the weekend of July 29th, Kraft's digester had tripped out and been offline causing the digester to go septic. By draining the digester contents into the aeration basin, a previously used hack that was not effective this time, it caused the aeration basin to go septic. Mr. Lagle explained that he 1 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 believed the increase in ammonia that the UCSD influent experienced influent was the result of Kraft's septic digester and aerobic lagoon. The following day, on Tuesday August 8th, Mr. Lagle spoke with Kraft's Operations and Risk Manager, Heather Conover, who confirmed the issues at Kraft Heinz's wastewater treatment plant and explained that Kraft Heinz was working to resolve low dissolved oxygen levels at the aeration basin. On Wednesday August 9th, Mr. Lagle stated that he drove southeast of the Kraft wastewater plant and did not notice any odor issues. The next week, on Tuesday August 15th, Mr. Lagle stated that he and Mr. Manner met with Kraft representatives and a consultant with whom Kraft Heinz was working to resolve its pretreatment issues, who provided an update on the pretreatment system. UCSD had received many private citizen odor complaints from the neighborhood south and east of the Kraft Heinz facility, so, prior to the meeting, UCSD drove through the neighborhood southeast of the Kraft wastewater plant and did notice odors. At that time, UCSD opened the first manhole downstream of Kraft's discharge and used a gas detector to determine that no residual hydrogen sulfide was detected in that manhole. On Thursday August 17, Mr. Lyons stated that he and other UCSD representatives met with Ms. Conover from Kraft to discuss the actions to return the pretreatment system to normal and Kraft's lack of reporting of its pretreatment malfunction. On Friday August 18, Mr. Lyons stated that UCSD met with Mr. George from Kraft Heinz to discuss the action taken to bring their wastewater pretreatment plant to normal operation and resolve the odor issues in the community. Mr. George stated that temporary foggers have been brought in to reduce odors and temporary aeration would also be brought in to help supply dissolved oxygen to the aeration basin. UCSD emphasized that Kraft needed to make more efforts to reduce loading to their system. At the time of the inspection, the effective significant industrial user permit for Kraft Heinz is KHF-22-23 issued by UCSD effective October 4, 2022 through October 10, 2023 (Appendix C). This permit states that wastewater discharged to the sewer from Kraft shall not exceed the following discharge limits for ammonia nitrogen. Pollutant Ammonia Nitrogen Monthly average (mg/L) 50 Daily maximum composite sample (mg/L) 100 Grab sample maximum (mg/L) 250 Minimum detection limit (mg/L) 0.1 The permit requires the user to sample and analyze the discharge for biochemical oxygen demand (BOD) and total suspended solids (TSS) on a daily basis and requires the user to semiannually sample and analyze the regulated discharge for all pollutants (including ammonia). 2 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 Kraft Heinz most recent semi-annual self-monitoring results were sampled and analyzed in March 2023 and its effluent was in compliance with its permit. In addition to semi-annual self-monitoring requirements, UCSD collects monthly splits of Kraft effluent; the results are listed in Appendix G. Samples collected 7/17/23, 8/1/23, 8/15/23 and 8/16/23 were in compliance with the discharge limits of its permit. Mr. Manner described the enforcement response that UCSD has had with Kraft. During the inspection, Mr. Manner told me that UCSD had given verbal notice to Kraft Heinz that an enforcement action a compliance plan or penalties, will be issued for this incident. An enforcement action was being prepared and penalties had been discussed with the UCSD legal department. Mr. Manner stated that UCSD wanted to resolve the odor issue affecting the community first rather than require Kraft to respond to the proposed violation from the incident. A mandatory compliance meeting with Kraft Heinz had taken plant between UCSD and Kraft on August 17, 2023. According to Mr. Lyons, during that meeting the following potential violations were discussed: UCSD noted that Kraft was still operating at or above an average flow of 1 MGD and the wastewater discharging from Kraft had not decreased. While Kraft Heinz's permit authorizes it to discharge an average of 765,000 gallons daily, its actual flow is expected to average 30 MGD in the last 30 days. UCSD stated that the large change in quantity of flow necessitated a notification according to Kraft's permit. At this meeting UCSD mentioned that Kraft's newest lines were added in 2023 and UCSD was not informed of the addition. Mr. Lyons stated that he then went to collect the split composite sample for total sulfides from Kraft's autosampler and noticed that the effluent sampler had stopped collecting samples for the day and had already collected 20 out of 20 aliquots by 3:00 pm. UCSD emailed Kraft to notify them that the effluent composite samples must be representative of the entire 24-hour sample day and the settings on the composite sampler need to be adjusted to be in compliance with its Permit. Mr. Manner stated that they are still analyzing additional effluent composite samples. All samples collected to date have not exceeded the effluent limits for any parameters. While COD and TSS has been elevated, neither of these exceed the permit. In the future, ammonia nitrogen will be added to Kraft Heinz daily monitoring by a compliance directive. UCSD has an industrial pretreatment program enforcement response plan, revised in 2013 and is reproduced here in part. Noncompliance Failure to notify of spill, slug load, bypass or pretreatment malfunction Minor violation of permit condition Failure to accurately report non-compliance, such as failure to report a violation discovered as a result of selfmonitoring. Circumstances No known interference or pass through No evidence of negligence or intent At any time Typical Range of Response Notice of Violation requiring report within 2 weeks. Phone notification, possible NOV Informal telephone calls, NOV requiring report within 2 weeks. 3 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 The Enforcement Response Plan specifies that phone notification should be completed by the pretreatment coordinator as soon as a violation is discovered, maximum of 1 week. A Notice of Violation should be mailed by the pretreatment coordinator as soon as possible, maximum of 1 week unless the industry has been informally informed of the violation, or other responses are under consideration. EPA and IEPA Inspectors left UCSD at 12:07 pm and proceeded to the neighborhood south and east of the Kraft Heinz facility. At a location two blocks from the facility, Inspectors did not notice wastewater odors. V. OPENING CONFERENCE AT KRAFT HEINZ EPA and IEPA Inspectors arrived at Kraft Heinz at 12:48 pm and met with Kraft Heinz representatives: Heather Conover, Operations Risk Manager and Environmental and Health and Safety and Security; William George, Site Lead; and Mickey Frantz, Lead Operation Risk Management of Business Unit TMA (Taste, Meals and Away from Home). Inspector Ellens and I showed our credentials to the three Kraft Heinz representatives. I explained the objectives of the inspection and asked whether anything is considered Confidential Business Information. VI. DISCUSSION AT KRAFT HEINZ Mr. George explained that at this facility, 34 lines produce sauces, including mayonnaise and ketchup, dinners and various salad dressing by over 800 employees. Five lines have been in ramp up in the last year with starting dates between May and July 2023. One organic line, which produces a variety of products, opened up three weeks ago. These lines were not additions but had been discontinued and remained vacant until they were recently converted. All the process lines produce some wastewater. Ms. Conover stated that the line additions had been communicated to UCSD over a year ago, which is the reason that the current permit issued to them from UCSD is for only one year until the changes to wastewater flow can be determined. Ms. Conover stated that there has been an increase in wastewater volume, and she would like to negotiate with UCSD a larger volume of flow into its permit. I asked about the clean in place (CIP) procedures on the lines and Kraft Heinz Representatives stated that lines can have full cleaning at different frequencies, from every night to once a week. If a line is changing products, such as the organic line frequently does, a full cleaning would happen between product changes. Also, prior to introducing the new lines, the equipment goes through a passivation cleaning process. While the CIP system is used for passivation, the chemicals used are different from those for routine CIP sanitization. Ms. Conover provided me with the safety data sheets for the chemical used for routine CIP sanitization, which contains 30 percent citric acid, and for the chemical used in passivation which contains 10 percent benzalkonium chloride and ethanol. 4 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 Ms. Conover explained that production is on 8 hours shifts and at least one division is running full shifts with a sanitation shift occuring on Friday and Saturday. Wastewater is produced during all shifts and flow may increase during the beginning and end of the week. During holidays there is a shutdown period and the wastewater microbiota are fed solids to remain alive. There are six pretreatment operators on three shifts. The shifts are rotating 12 hours shifts. The lead operator has a Class K certification. Process wastewater flows to the lift stations A1 and E prior to discharge into the pretreatment system. Once the process wastewater has gone through treatment it recombines with sanitary wastewater before being discharged into the municipal sewer system. The pretreatment system has a rotating drum screen, equalization (EQ) tank, dissolved air flotation (DAF) unit, aeration basin, and a clarifier and aerobic digester for sludge. Ms. Conover stated that the wastewater operator noticed the aerobic digester had turned septic at the end of July. This potentially was due to an electrical failure that caused the blowers to cease for about a day until it was noticed. The operator tried a solution that had previously worked to slowly bleed the contents of the aerobic digester into the aeration basin. At the time, the aerobic basin already had low dissolved oxygen and was not able to handle the ammonia load from the digester. It is possible that the aeration basin was less resilient due to the recent load of passivation chemicals on the new line. Dissolved oxygen (DO) in the aerobic basin went to zero parts per million (ppm), and became septic, and the clarifier contents also turned septic. Ms. Conover stated that she was made aware of the situation at the same time that UCSD received notice from the Kraft Operator on Monday August 7th. At that time a consultant who was already familiar with their pretreatment system, Nalco, was brought in to help repair the pretreatment system and began using a product called SulfX. By August 14, there had not been much improvement in the aeration basin and Kraft was made aware that UCSD was receiving odor complaints from the community. At that time, Kraft reached out to a different consultant, Ramboll, who brought in temporary aeration and at least two tanker loads, or 2600 gallons, of microbiological organisms from UCSD, to increase the healthy microbial population. At the time of the inspection, Ms. Conover stated that Kraft Heinz had started to see some progress, since the water in the aeration basin was now grey in color instead of black and DO reading had increased to 1.59 ppm. While the wastewater in the aeration basin and clarifier was black from August 4 through the time of the inspection, TSS, COD, BOD and pH were tested at the effluent sample testing point and were within the permit limitations. Kraft Heinz's permit does not require ammonia to be tested every day, so the amount of ammonia was not determined until UCSD requested ammonia testing on August 15th, 2023. All ammonia effluent tests results have been within the permit effluent limits. On Thursday, August 17th, Kraft Heinz added foggers on the south side of the aeration basin to mask the odors entering the community. According to Mr. Franz, prior to the inspection, in the morning of August 21st, Kraft Heinz had a third party perform air quantification testing for hydrogen sulfide, ammonia, nitric oxide, nitrogen dioxide and volatile organic compounds at the south fenceline of their facility. At the time of the inspection, the official air testing results had not been reported, but they had been made aware of the immediate results. According to Mr. George, 5 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 no hydrogen sulfide had been detected. Some nitrogen dioxide had been detected and was being investigated, but all other gasses had zero detects over three passes along the fenceline. VII. KRAFT HEINZ SITE VISIT EPA Inspectors, IEPA Inspectors and Kraft Representatives were present for all parts of the Kraft Heinz site visit beginning at 2:28 pm. In the production building called the "East Plant" we all viewed the new line which had received passivation in late July, and the corresponding CIP skid. Then we went to the wastewater pretreatment office, spoke with operators and then viewed each step of the wastewater process. In the East Plant, we viewed E2 Kitchen, where a food sauce is cooked, and the filling and packaging parts of the line. We viewed a cold kitchen, but Mr. George explained each line has duplicate cold and hot kitchens, to be used depending on whether the recipe requires heat. At this area, production is in eight hour shifts and cleaning begins in the second half of second shift. We viewed the CIP foamer in the kitchen area. During cleanup some wastewater is discharged to the floor drain (Photo 1), but the majority is returned in the CIP cycle and discharged through a pipe to the pretreatment system. The floor drains in the kitchen also discharge to the pretreatment system. Next, we viewed the CIP skid area outside of the production lines (Photo 2). Multiple kitchens in different lines will use the same CIP skid and the same sanitation chemicals. While near the CIP skid, I saw some older equipment that appeared to be not currently in use. There was an older pump that had white foam on it and appeared to be leaking in the direction of a floor drain (Photo 3). Facility employees stated that this as once used on the mac and cheese line. We then went to the pretreatment office and spoke with pretreatment employees: Darin Colter, Wastewater Coordinator; Andy Parker, Wastewater Operator; and Travis Howry, Licensed Plumber. Mr. Colter stated that the pretreatment plant was built in 1971. No upgrades have occurred on the pretreatment system since 1991. Mr. Colter stated that there are backup power generators at the lift stations, but not at the pretreatment system; however, the pretreatment system is all gravity fed after the EQ pump, so if the power went out the flow to the municipal sewer would cease. The EQ tank is usually kept half full during the week so there is some capacity and there is a high level alarm that would go off if it were to reach a maximum height. Internal process control samples for TSS, chemical oxygen demand (COD), pH, and flow are collected at the lift stations, primary influent, return wasting and digester. The permit compliance samples are collected at an autosampler after the process wastewater combines with sanitary. There is a stationary DO meter in the aerobic basin which normally reads around 2-6%, but could occasionally drop for a day or two, according to Mr. Colter. After the lift station, the first step is for the process wastewater to be collected at a pit with Hycor rotary drum screen (Photo 6), and then sent to the 600,000 gallon aerated EQ tank then to DAF. The EQ tank (Photo 5) was built in 1991 after the original pretreatment unit had already been constructed. Mr. Colter stated that the pace and length of treatment is determined by the pump on the EQ tank that pumps to the DAF unit and the rest of the process is gravity flow, so the length of treatment depends on the amount of treatment that DAF provides. The DAF unit is a circular 6 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 shape and has ferric chloride injection. I observed that the wastewater in DAF was an orangebrown color (Photo 7). Mr. Colter explained that the color was typical for the process wastewater due to tomatoes used in processing. All chemicals used in processing and sanitization are approved food grade, so the sludge from DAF goes through a belt filter press (Photo 11) and then can be sold as animal feed at a amount of one truck per day. After DAF the wastewater is sent to the aeration basin (Photo 12). The aeration basin is approximately 9 feet deep and has a DO probe a few feet down and was reading 0.23 ppm. I noted some vegetation on the banks of the basin and smelled a tomato-like odor. I did noticed a smell of wastewater but not at an overwhelming level. At the time of the inspection the aeration basin was heavily aerated and the surface was rolling, and Mr. Colter explained that it was operating significantly different than the normal operational settings. All seven blowers were running and during normal operation only three would run. There are 15 submersible flight pumps with jet nozzle diffusers and 10 were operating. Mr. Colter stated that 5 were down and had been for a while. One jet nozzle diffuser was lying outside the basin to be repaired (Photo 13). Mr. Colter stated that going forward there is an annual plan to keep up maintenance and he expects the 5 pumps to be repaired within a month, but in the meantime, they were getting rentals. Around the end of July Mr. Colter noted that the aeration basin went from grey to black, but noticed no changes to the influent or effluent sampler. Mr. Colter stated that the aeration basin did not start to " stink" until the week prior. Water from the aeration basin is discharged through gravity via a weir (Photo 15) to a clarifier. Two clarifiers are present, but one has not been used for decades (Photo 16). I asked whether there were any plans rehabilitate the unused clarifier, and Mr. Colter stated that were getting a company to look into that and that it could be beneficial to have a second clarifier since it could help to slow the flow. One clarifier was in use (Photo 17) and I observed that the water appeared grey and had some solids. Threre was a small flow coming into the clarifier (Photo 18). Mr. Colter stated that the clarifier water was used as a belt rinse and this was the flow getting returned to the clarifer. Sludge from the clarifier is treated in an aerobic digester which was not observed during the facility site visit. We observed a small sample hut with a flow meter which was used to determine the volume of process flow. The permit compliance samples were collected at a separate location after the treated process wastewater was combined with the sanitary flow. The compliance auto sampler display (Photo 19) indicated that the pump tubing needed to be changed and I observed some discoloration in the tubing. The facility tour ended at 4:44 pm. VIII. CLOSING CONFERENCE EPA began the closing conference at 4:54 pm and noted the following areas of concern: 1. Potential for passthrough or interference The effective significant industrial user permit for Kraft Heinz is KHF-22-23 states that the User shall comply with all applicable requirement of Section 501 and 502 of the District's Sewer User Ordinance Number 678. 7 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 Article V of the UCSD Sewer Use and Pretreatment Program Ordinance 678 lists Prohibitive Discharge Standards. Section 502 states that No User shall contribute or cause to be contributed, any wastewater which will interference with the operation or performance of the publicly owned treatment works (POTW) or pass through the POTW. Interference is defined in Section 141(b) as a discharge which causes a violation of any requirement of the UCSD's NPDES Permit. Similarly, Passthrough is defined in Section 147 as a discharge which exits UCSD into waters of the United States in quantities or concentration which alone or in conjunction is a cause of a violation of the POTW's NPDES permit. While UCSD Northeast Plant received an increase in influent ammonia, due to the adjustments which were made, the effluent did not exceed NPDES effluent permit limits. While Kraft Heinz's compliance samples collected 7/17/23, 8/1/23, 8/15/23 and 8/16/23 were in compliance with the discharge limits in its KHF-22-23 industrial user permit, but at the same time the aerobic basin and clarifier were septic. Therefore, it does not appear that the effluent limits in the KHF-22-23 permit are stringent enough to ensure proper operation of the wastewater pretreatment system. 2. Prohibition against discharge of malodorous substances The effective significant industrial user permit for Kraft Heinz is KHF-22-23 states that the User shall comply with all applicable requirement of Section 501 and 502 of the District's Sewer User Ordinance Number 678. Article V, Section 502(e) also prohibits a user from contributing the following substances to UCSD's publicly owned treatment works: Any noxious or malodorous liquids, gases or solids which either singularly or by interaction with other wastewater are sufficient to create a public nuisance or hazard to life or which results in the presence of toxic gases, vapors or fumes within the POTW in a quantity that may cause acute worker health and safety problems. From a period of August 14th through the time of the inspection, over 50 citizen complaints described noxious odors south and east of the Kraft Heinz facility. At the time the complaints were received, UCSD opened the first manhole downstream of Kraft's discharge used a gas detector to determine that no residual hydrogen sulfide was detected in that manhole. 3. Notification of potential slug discharge: Part IV: Reporting Requirements of KHF-22-23 requires Kraft Heinz, in the case of a discharge of compatible or incompatible pollutants which causes or may cause a violation of Kraft Heinz's Wastewater Discharge Permit or a violation of the regulatory requirement of Ordinance 678, it shall be the responsibility of Kraft Heinz to notify UCSD within 24 hours of becoming aware of the violation. Such discharges include accidental discharges, discharges of a non-routine, episodic nature, a non-customary batch discharge or a slug load. Similarly, the Permit also states that the User shall notify UCSD immediately of any changes at its facility affecting the potential for a slug discharge. 8 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 UCSD began noticing increasing ammonia in its influent on August 4th. Kraft Heinz operators noted that the aerobic digester had lost power on July 29th, causing it to turn septic. Kraft Heinz first notified UCSD of issues at its wastewater pretreatment facility on August 7th. 4. Notification concerning changes to wastewater: Part IV: Reporting Requirement of KHF-22-23 requires Kraft Heinz, in the event the type, quality, or volume of wastewater discharged by Kraft Heinz is expected to change materially and substantially, Kraft Heinz shall give a thirty-day notice in writing to UCSD. UCSD may require Kraft to make a new application to UCSD prior to said change. Kraft shall not materially and substantially change the type, quality, or volume of its wastewater beyond that allowed by this permit without prior approval of UCSD. Kraft Heinz had notified UCSD over a year in advance that five production lines would start in 2023, since the permit that UCSD issued to Kraft Heinz was only for one year, until the changes to flow had stabilized. According to UCSD, they had not been informed 30 days prior to the start of each of the five new production lines. 5. Increase in flow: Special Conditions of Permit KHF-22-23 states that Kraft Heinz Foods is hereby authorized to discharge an average of 765,000 gallons of wastewater daily to UCSD. Kraft has discharged average flow of above one million gallons per day for multiple years since 2013 (Appendix H). In the 30 days prior to the inspection, Kraft actual flow is expected to average one million gallons per day. 6. Representative Sampling: Part III.1 Monitoring Requirements of KHF-22-23 states that samples taken as a requirement of this permit shall be representative of daily operations. Samples shall be collected, preserved and analyzed in accordance with the requirements prescribed in 40 Code of Federal Regulations (CFR) Part 136 and amendments thereto. A. WCSD noticed that the split composite sample for total sulfides from Kraft's autosampler and noticed that the effluent sampler had stopped collecting samples for the day at 3:00 pm and had already collected and had already collected 20 out of 20 aliquots. B. The compliance auto sampler display (Photo 19) indicated that the pump tubing needed to be changed and I observed some discoloration in the tubing. EPA and IEPA Inspectors concluded the inspection at 5:10 pm and left the facility. 9 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 Documents received during the inspection from UCSD: Memo from Wade Lagle regarding high influent ammonia on Aug 4, 2023 Letter to USEPA regarding Notice of Potential Problems including slug loading on August 21, 2023 Letter to USEPA regarding Immediate Notification from Kraft Heinz on August 21, 2023 Letter to USEPA regarding Repeat sampling event results on August 21, 2023 Letter to USEPA regarding Enforcement Action, Compliance Plan, Penalties Issued on August 21, 2023 UCSD industrial user phone log on August 7, 2023 Memo from Wade Lagle regarding phone call on August 7, 2023 Email from Darin Colter regarding EXTERNAL: basin on August 7, 2023 UCSD industrial user phone log on August 8, 2023 Memo from Wade Lagle regarding phone call on August 8, 2023 Memo from Wade Lagle regarding Kraft Plant drive around on August 9, 2023 UCSD industrial user phone log on August 14, 2023 (2) Memo from Wade Lagle regarding phone call on August 14, 2023 Memo from Wade Lagle regarding Kraft Pretreatment onsite visit on August 15, 2023 Email from Heather Conover to Wade Lagle regarding Incident at Kraft Heinz on August 16, 2023 Memo and sign in sheet from Compliance review meeting on August 17, 2023 between UCSD and Kraft Memo from Wade Lagle regarding Kraft onsite sampling collection and effluent sampler from August 17, 2023 Email from Wage Lagle to Heather Conover regarding Kraft combined discharge sampler on August 17, 2023 Memo from Trent Lyons regarding Kraft Pretreatment - video call with William George on August 18, 2023 Chart of Kraft Monthly total flow from January 2017 - July 2023 Chart of Kraft Annual Monthly Average Flow from 2005 -2023 Readout from Station 1 Flow Meter Trend on August 4 - 7, 2023 Readout from Station GG2 - Ammonium Analyzed Level Trend from August 1 - 11, 2023 Readout from Ammonium Analyzed level Trend from August 4 - 7, 2023 Calculated Daily Average Ammonia from August 4 - 7, 2023 Kraft foods combined UCSD permit monthly reporting results for January - December 2022 Kraft foods combined UCSD permit monthly reporting results for January - July 2023 Kraft foods monthly sampling results from January -December 2022 Kraft foods monthly sampling results from January -December 2023 Kraft monthly effluent from January 2021 - August 2023 Kraft Heinz Foods December 2022 analyses local limits analysis Kraft semiannual reporting on March 6, 2023 10 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 Kraft semiannual reporting on August 16, 2022 Total suspended solids sampling from Kraft basin on Dates 215 - 218 UCSD Sewer Use and Pretreatment Program Ordinance 678 UCSD Annual Inspection of Kraft Heinz Foods on December 12, 2022 Permit KHF-22-23 issued to Kraft Heinz Foods on October 4, 2022 UCSD Industrial Pretreatment Program Enforcement Response Plan Industrial User Permit Application from Kraft Foods on September 15, 2022 Documents received during the inspection from Kraft Heinz: Safety Data Sheets for Liquid Citric Acid 50 Percent Cleaning Product Safety Data Sheets for Ster-Bac Sanitizer Spill Response Plan Facility Site Maps 11 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 Appendix A: Inspection Photo Log Kraft Heinz Company EPA Inspection August 21, 2023 All photos taken by Newton Ellens, Pretreatment Program Manager, U.S. EPA Camera: Canon PowerShot SX230 HS 1: IMG_0382 Description: E2 Kitchen floor drain. A CIP foam sanitizer system is present in each kitchen and during cleanup some wastewater is discharged to the floor drain. Location: East Plant Production Kitchen Date/Time: August 21, 2023 2:47 PM A1 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 2: IMG_0383 Description: Clean in Place (CIP) skid. This CIP is used for the E2 Kitchen in Photo 1 and for other kitchens. Conductivity meter on the skid determine reuse cycle. The passivation chemicals are in the 50 gallon barrels next to the CIP skid and are added during the passivation process. Location: East Plant Date/Time: August 21, 2023 2:52 PM A2 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 3: IMG_0384 Description: Pumps and equipment in storage near the CIP units. I saw a white foamlike dried residue which left a trail in the direction of the floor drain. Location: East Plant Date/Time: August 21, 2023 2:58 PM A3 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 4: IMG_0385 Description: Temporary foggers which are set up south of the aeration basin to help mitigate the odor complaints. I smelled a scented spray which was misted from the fogger at the time of the inspection. Ms. Conover stated that it was an apple cider vinegar product which is designed to mask the odor. Location: Pretreatment Aeration Basin Date/Time: August 21, 2023 3:46 PM A4 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 5: IMG_03876 Description: Aerated 600,000 gallon equilization tank was built in 1991 after the original pretreatment unit had already been constructed. Location: Wastewater Pretreatment Plant Camera Direction: Date/Time: August 21, 2023 3:56 PM A5 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 6: IMG_0387 Description: View inside of Pumphouse 4. The elevated white cube on right is wastewater pit with Hycor rotary drum screen. Location: Wastewater Pretreatment Plant Date/Time: August 21, 2023 3:56 PM A6 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 7: IMG_0388 Description: View inside the circular DAF unit with skimmer. I observed the DAF was an orange- brown color due to tomatoes used in processing. Location: Wastewater Pretreatment Plant Date/Time: August 21, 2023 4:00 PM A7 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 8: IMG_0389 Description: Two drains under the DAF unit are main and overflow pipes. Location: Wastewater pretreatment System Date/Time: August 21, 2023 4:03 PM A8 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 9: IMG_0390 Description: Small sampler attached to the DAF is desiged to collect in a constant overflow. The sampler does not work, but internal process samples are still collected at the DAF location. Location: Wastewater pretreatment Plant Date/Time: August 21, 2023 4:04 PM A9 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 10: IMG_0391 Description: Pipe leading to the belt filter press where the DAF sludge is thickened. There was small amount of liquid dripping under the pipe. Mr. Colter stated that it was from a constant flow on the pump seal. Location: Wastewater Pretreatment System Date/Time: August 21, 2023 4:04 PM A10 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 11: IMG_0392 Description: Thickened DAF solids travel to a tanker truck and are sent out as animal feed. The blue belt thickener is on middle right of the photo with orange-brown sludge solids. Location: Wastewater Pretreatment System Date/Time: August 21, 2023 4:07 PM A11 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 12: IMG_0393 Description: The aeration was fully aerated and I observed the surface of the water was rolling. I observed the basin had grey water with floatable solids at the time of the inspection. Location: Wastewater pretreatment system Date/Time: August 21, 2023 4:19 PM A12 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 13: IMG_0394 Description: Submersible jet diffuser sitting on the bank of the aeration basin. The diffuser had been removed from the aeration basin and taken out of service for repair. Location: Wastewater treatment plant Date/Time: August 21, 2023 4:20 PM A13 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 14: IMG_0395 Description: Stationary DO meter installed a few feet deep at the aeration basin. The DO meter was reading 0.23 ppm at the time of the inspection. Location: Wastewater pretreatment plant Date/Time: August 21, 2023 4:23 PM A14 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 15: IMG_0396 Description: Weir overflow at the aerobic basin which is gravity discharged to the clarifier. The manual valve is open in this photo. I observed some floatable solids and discolored foam at the point of discharge. Location: Wastewater pretreatment system Date/Time: August 21, 2023 4:25 PM A15 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 16: IMG_0397 Description: Unused clarifier with sitting water and green plant growth. Location: Wastewater pretreatment system Date/Time: August 21, 2023 4:29 PM A16 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 17: IMG_0398 Description: Clarifier full of wastewater which had been discharged from the aerobic basin. I observed the water in the clarifier was grey with floatable solids. Location: Wastewater ptreatment system Date/Time: August 21, 2023 4:330 PM A17 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 18: IMG_0399 Description: A small flow coming into the side of the clarifier. Mr. Colter stated that the clarifier water was used as a belt rinse and this was getting returned to the clarifer. Location: Wastewater pretreatment system Date/Time: August 21, 2023 4:33 PM A18 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 19: IMG_0400 Description: Autosampler for collecting compliance samples that consist of combined process and sanitary wastewater. Autosampler display stated to change the pump tube. The refridgeration temperature was reading 1C. Location: Wastewater pretreatment system Date/Time: August 21, 2023 4:42 PM A19 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 Appendix B: Aerial images of Kraft Heinz Note: Aerial images collected from Google Earth on October 13, 2023. Google Earth attributes the image collection as April, 6, 2023. Images do not represent conditions observed and are only to be used as reference. Aerial Image 1: Shows the wastewater pretreatment system at Kraft Heinz. B-1 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 Aerial Image 2: Shows Kraft Heinz facility and yellow areas which are rough approximations of the locations of at least 50 private citizen odor complaints sent to UCSD starting around August 14, 2023 through August 21, 2023. Most of the private citizen complaints are located within one mile radius to the south and east of the Kraft Heinz facility and bordered by Prospect Street on the east, Springfield Avenue on the South, Mattis Avenue on the west and Bradley Avenue in the north. B-2 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 Appendix C: Kraft Heinz Significant Industrial Permit issued by UCSD C-1 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 C-2 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 C-3 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 C-4 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 C-5 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 C-6 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 C-7 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 Appendix D: Memoranda of activity by UCSD Representatives D-1 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 D-2 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 D-3 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 D-4 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 D-5 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 D-6 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 D-7 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 D-8 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 D-9 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 D-10 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 Appendix E: Email correspondence between UCSD and Kraft Heinz Note: Email Addresses have been redacted for privacy G-1 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 G-2 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 G-3 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 Appendix F: Influent Loading Measured at UCSD on August 4 - 7, 2023 G-1 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 Appendix G: Monthly Samples Collected at Kraft Effluent in 2023 G-1 The Kraft Heinz Company Champaign, Illinois CEI Inspection - August 21, 2023 Appendix H: Graph of Average Monthly Flow discharged by Kraft Heinz in Million Gallons per Month H-1