Document 5kYrnjqrn36297yagVyxkgrn8

REPORT OF THE PRETREATMENT COMPLIANCE INSPECTION AT City of Fort Dodge Municipal Building 819 1st Avenue South Fort Dodge, Iowa 50501 Operated by US Water Utility Group 1406 Central Avenue Fort Dodge, Iowa 50501 NPDES Permit No.: IA0044849 BY U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 7 ENFORCEMENT AND COMPLIANCE ASSURANCE DIVISION (ECAD) WATER BRANCH/DRINKING WATER & INSPECTIONS SECTION (WB/DWIS) ON MARCH 5, 6, AND 7, 2024 At the request of the Water Branch (WB), Enforcement and Compliance Assurance Division (ECAD), a Pretreatment Compliance Inspection of the Fort Dodge Approved Pretreatment Program was conducted on March 5, 6, and 7, 2024. To direct the inspection, a checklist was used that evaluates all important elements of the Pretreatment Program. A copy of the checklist is attached to this report (Attachment 1). The inspection consisted of a discussion and file review of the City's program and site visits to Nestle Purina Pet Care Co. and Elanco US Inc. In addition, I conducted brief file review of the City's Biosolids Management Program (Sludge). This narrative report presents the findings of the inspection. Participants US Water Utility Group Michelle Bemrich, IPP Coordinator Travis Pender, Project Manager U.S. Environmental Protection Agency (EPA), Region 7 Naji J. Ahmad, Environmental Engineer, ECAD/WB/DWIS mbemrich@uswatercorp.net tpender@uswatercorp.net ahmad.naji@epa.gov Facility Description and Program Overview The city of Fort Dodge, with an approximate population of 24,912 (2021 census estimate), owns a Vertical Loop Reactor (VLR) activated sludge Water Pollution Control Facility (WPCF) located in the southern portion of the city. The city has a contract with US Water Utilities Group (USW) to operate the WPCF and manage the Fort Dodge Industrial Pretreatment Program (IPP) that was originally approved on January 30, 1984. USW personnel initiate permit issuance and reissuance, conduct all compliance sampling for all regulated industries, annually inspect all regulated industries, determine compliance status, initiate enforcement, and generate and submit annual pretreatment report by March 1st of each year. The USW laboratory analyzes most conventional pollutants (BOD, TSS, pH, ammonia, E. coli). Samples for all other parameters are sent to a certified third-party laboratory. The USW laboratory is located at the WPCF. Permits and formal enforcement documentations are signed by the city representative (Manager). Treated effluent by the WPCF discharges into the Des Moines River that flows through the city from northwest to southeast. The VLR process consists of a primary clarifier splitter box that is designed to split flow to the two primary clarifiers. Flow from the primary clarifiers then travels by gravity to either of three, four-train activated sludge processes. Screenings and grit are removed, pressed, treated with lime, and disposed of at a landfill. Flow from the grit system flows into the VLR after it is measured in an 18-inch Parshall flume. After the VLRs, flow enters four, 100-foot final clarifiers. Clarifier effluent is measured in a 30-inch Parshall flume and disinfected in an ultraviolet (UV) disinfection chamber. The WPCF is regulated under the Iowa National Pollutant Discharge Elimination System Permit (NPDES) number IA0044849 that is set to expire on September 30, 2025. According to the NPDES permit, the WPCF has a design of an average dry weather (ADW) flow of 8.4 million gallons per day (mgd), an average wet weather (AWW) flow of 15.0 mgd, a maximum wet weather (MWW) flow of 21.6 mgd, a design 5-day biochemical oxygen demand (BOD5) load of 27,164 lbs/day, a design Total Kjeldahl Nitrogen (TKN) load of 6,526 lbs/day, and a design Total Suspended Solids (TSS) load of 21,621 lbs/day. The WPCF receives discharges from nine permitted Significant Industrial Users (SIUs) that make up fifty-four percent (54%) of its actual 2023 average influent of 8.95 mgd. Of those nine SIUs, three are currently located just outside the Fort Dodge city limits. The current NPDES permit1 required the city to continue implementing its approved IPP and submit to the Iowa Department of Natural Resources (IDNR) an annual report by March 1st each year describing the pretreatment program activities for the preceding calendar year. The permit also required the city to: (1) evaluate adequacy of its local limits to meet the general prohibition against interference and pass through listed in 40 CFR 403.5(a) and the specific prohibitions listed in 40 CFR 403.5(b) and submit a report by October 1, 2021, and to (2) evaluate the program with regards to the Streamlining Rule by October 1, 2021. The USW and the city of Fort Dodge finalized the Industrial Pretreatment Study (Attachment 2) which included both evaluations in September 2021. (1) https://programs.iowadnr.gov/wwpie/Admin/PermitDetails?permitID=6914 The study was submitted to the IDNR Field Office #2 on September 30, 2021, but did not receive an approval from the Iowa DNR because they did not submit it to Ben Hucka at the Iowa DNR Central Office. I recommended to the IPP personnel to send an email to Ben Hucka and include the study. On March 6, 2024, Michelle Bemrich, IPP Coordinator, sent two emails to Ben Hucka that included the IPP final study and the Sewer Use ordinance (SUO) evaluation (Attachment 3). Ben Hucka responded that he will be evaluating the study (local limits and SUO) as soon as possible. The city incorporated the 2021 calculated local limits, which were not formally approved by the Iowa DNR, into the current cycle of the industrial user permits. However, at the time of the inspection, the city was still waiting for the Iowa DNR approval to enact the revised SUO that included the Streamlining Rule provisions. I reminded the IPP personnel that as required by 40 CFR Part 403 and Rule 567 IAC 62.4(455B), all significant program modifications must be submitted to the Iowa DNR for review and approval before enacted on. Legal Authority and Local Limits As mentioned above, the city submitted the 2021 IPP and local limits evaluation to the IDNR as required by the NPDES permit. Records also indicates that the current approved program was evaluated and approved by the IDNR on June 19, 2013. The current city Ordinance 1863 - Chapter 13.24 (Pretreatment) and Chapter 13.12 (Fees) were approved by the Iowa DNR on June 19, 2013, and was adopted on November 12, 2013. The city's current ordinance gives the authority to implement and enforce its Pretreatment Program, such as issuing permits for a duration not to exceed five years; requiring the submittal of permit renewal applications 180 days prior to the expiration date; the right to inspect, sample, enforce, collect a civil penalty up to $1,000.00 for each violation; and includes a provision to address confidential business information. The 2021 IPP study evaluated and identified the following pollutants as pollutants of concerns. Of the 26 pollutants, the city adopted mass limits as daily maximum (pounds per day) for eleven pollutants. Table 1, The 2021 Local Limits Pollutant Daily Pollutant Max Daily Pollutant Max Daily Max Arsenic 0.47 Selenium 0.94 1,4-Dichlorobenzene DNA Cadmium 0.60 Silver 0.97 Bis (2-ethylhexyl) phthalate DNA Nickel 4.7 Zinc 41.53 4-methylphenol DNA Chloride 54,114 Copper DNA Beryllium DNA Cyanide 0.77 Acetone DNA Chromium DNA Lead 6.47 Toluene DNA Fluoride DNA Mercury 0.26 Xylenes DNA Phenol DNA Molybdenum 0.70 Barium DNA BOD DNA pH 5.0 SU - 9.5 SU TSS DNA DNA = Technical analysis was performed but the limit was not adopted. Industrial Waste Survey and Significant Industrial Users Michelle Bemrich explained that they conduct an industrial waste survey (IWS) survey once every five years. The most recent IWS was conducted from June 2017 through July 2019, and included 202 entities. The survey did not result in any new industries in addition to those twelve industries were already regulated by the city. The list of industries is maintained and updated almost continuously. Currently the city regulates nine industries by issuing permits. In February 2023, the IPP Coordinator and the city of Fort Dodge eliminated three noncategorical SIU's from the IPP due to their little to no impact at the WPCF. The three industries were monitored for their flow rate, and officially released of their discharge permits. The three industries are Advantech, Americold, and Josephson Manufacturing Co. Of those nine regulated industries, three are categorical industrial users (CIUs). Argenta Medical Labs- Riverside and Elanco US Inc. are manufacturers of animal health supplements and products and are subject to the Pharmaceutical Federal Categorical standard 40 CFR Part 439 and Cargill Fort Dodge is corn mill ethanol plant and is subject to the Corn Wet Milling standard 40 CFR, Part 406 Subpart A. The IPP also regulates BHJ-USA, Inc. a meat product processing facility used as an ingredient in pet food, one hospital, a land fill, and a prison. Cargill and CJ Bio America (amino acid) are the biggest contributors to the WPCF and are in the North Central Ag-Park outside the city limits. Elanco is also located outside the city limits west of highway 169 west of the Des Moines River. Those nine industries contributed 54 percent (54%) to the WPCF actual average daily flow in 2023. I compared the total permitted flow of all IUs to the WPCF design average dry weather (ADW), and the 2023 actual total average daily flows from all 9 industries to the 2023 average daily flow to the WPCF. x (Total permitted flows for all 9 industries) to (WPCF design ADW). (7.6302 mg) / (8.4 mg) = 90.8358% x (2023 total average daily flows from all 9 industries) to the (2023 WPCF average daily flow). (4.819 mg) / (8.95 mg) = 53.84% Permits Except for Cargill Fort Dodge, all industries have current permits. The city issued permits on January 1, 2021, with five-year durations (Attachment 4). Cargill's permit was issued on January 1, 2019, and the new permit is currently at the city offices and ready for signature by the city. Permits are well written and include the necessary elements needed in a control mechanism. Records indicate that industries submitted permit renewal applications at least 180 days prior to permit expiration as required by industrial permits. Permits include local limits and categorical limits if applicable. Permits also require industries to develop, submit, and implement a slug control plan (SCP). Elanco is the only industry that uses the Combined Wastestream Formula (CWF), therefore, the Elanco permit included limits based on the CWF calculations (Attachment 5). Because the IPP performs the required sampling and analysis in lieu of the IUs and collects all the information required for the report, including flow data, the IUs are not required to submit the periodic compliance reports including the compliance certification required under 403.12 paragraphs (b)(6) and (d) of 40 CFR 403.12(g)(1). In addition, the permit included a statement that reads, "Permittee shall not be responsible for any sampling, monitoring, or analysis". I pointed out, however, that if issues with the sampling equipment arise (loss of power, equipment failure, etc.) that prevent the IPP from performing the sampling, the city should make it clear to the IUs (in the permit) that the IUs are responsible for the self-monitoring requirement. Therefore, the city should remove the following statement from its industrial permits "Permittee shall not be responsible for any sampling, monitoring, or analysis". The permits, rather, should include statement that if the city is unable to conduct the required monitoring, the responsibility should fall upon the industry to complete the monitoring within the required frequency. Inspections, Self-Monitoring, and Reporting The IPP Coordinator conducted inspections of all regulated industries in the past 12 months. Inspection reports appeared adequate and comprehensive (Attachment 7). As mentioned above, SCPs are required by the permits. Therefore, the IPP Coordinator evaluates the industry's implementation of the SCP during the inspection and includes the determination in the inspection report. Self-monitoring frequency is described in detail in the industrial permits. The IPP personnel enters all monitoring data in the LIMS program, and it is uploaded into a shared database where each industry can access its own data. Waste Haulers The city continues to accept domestic waste and grease at an access point equipped with an automatic pH metering device just before the headworks. Special wastes cannot be accepted unless the hauler submits a laboratory analysis result of the hauled material with a chain-ofcustody. Each hauler must be formally approved by the city (Attachment 8) and then issued a card to activate the access point and the card will register the time and date of the entry. Hauler, then, will be able to select the type of waste being dumped. The city requires each hauler to complete a manifest as a controlling mechanism. Domestic waste haulers are randomly monitored monthly by the staff of WPCF. IPP records indicate that the 2023 approved haulers are: Al Price Septic Service, Doyle Construction, Gudmonson Services, Portable Pro, The Tile Pros, Weiss Septic Pumping & Hauling, Advanced Waste Solutions, Mid Iowa Septic Services, and Moores Pumping & Portable Toilets LLC. Records also indicate that: x In 2022 the WPCF received a total of 991 loads. Averaging 82 loads/month with an average 1,526 gal/load. The total volume was 1.512 million gallons. x In 2023 the WPCF received a total of 1266 loads. Averaging 105 loads/month with an average 2,154 gal/load. The total volume was 1.710 million gallons. Enforcement The Enforcement Response Plan (ERP) was originally developed and approved on February 22, 1994, then revised and approved on June 19, 2013. The IPP continues to attach the ERP with each industrial permit. The USW IPP personnel perform all technical aspects of the IPP except signing the notices of violation (NOV) and collecting penalties. IPP personnel indicated that they utilize the LIMS computer system to enter all monitoring data. The LIMS program calculates Significant Noncompliance (SNC) and the Technical Review Criteria (TRC), but it does not flag infrequent violations. Michell Bemrich mentioned that she reviews the LIMS data and flags infrequent violations and other types of violations manually. Utilizing the LIMS program allows Michell Bemrich to take enforcement accordingly. Although the NOVs are signed by the city's responsible official, records indicated that enforcement actions are taken within the 30-day time frame as required by the ERP. During the inspection we discussed the systematic procedures of initiating enforcement when an exceedance occurs. The ERP requires the NOV letter be sent within 30 days of becoming aware of the violation. IPP personnel indicated that, with the use of the LIMS, the letters are drafted after they have all the monthly data for each industry. I pointed out that this method is acceptable for the monthly average violations, but it may not work for the daily maximum violations especially if violations occur early in the month. I also added, that for those samples that are analyzed by the USW laboratory, the knowledge of violation (start of the 30-day) begins when the results are uploaded into the LIMS. But for those samples that sent off to a certified thirdparty laboratory, the 30-day starts when the IPP receive the laboratory report. Michell Bemrich appeared to have a good knowledge of EPA's SNC definition, and she appeared to take enforcement within 30 days when a violation is noted by issuing a written NOV (Attachment 7). In addition, the city issues compliance schedules to industries and administers them through industrial permits. During the past 12 months, Argenta Medical Labs (AML) was the only industry placed in SNC for failure to meet a compliance schedule deadline by August 31, 2023. All requirements of the compliance schedule were completed on December 19, 2023, and a compliance schedule completion letter was signed, and electronically delivered to AML on January 10, 2024. The IPP Coordinator, the City of Fort Dodge published the AML non-compliance on November 9, 2023. Records indicated that in 2023, the IPP Coordinator, the City of Fort Dodge issued 71 NOVs, and in 2022 issued 69 NOVs. Data Management Overall, industrial files have all the necessary documentation as recommended by the Agency checklist. Each file consisted of permit and permit renewal applications, inspection reports, monitoring reports, and correspondence between the IPP Coordinator and the industries. Records are well kept by the IPP Coordinator at the USW offices and maintained for more than three-year durations and are available for public review. Records are also kept electronically. Dental Amalgam Rule In compliance with the Dental Amalgam Rule 40 CFR 441 requirements, in 2019 the IPP identified 13 dental offices that discharge to the WPCF. All submitted the one-time compliance report to the city/IPP (Control Authority). Treatment devices were installed when required. Sludge Quality Primary solids at the WPCF are pumped from the primary clarifiers using three sludge pumps and one skimmings/grease pump to the two sixty-five-foot diameter anaerobic digesters with a total combined capacity of 936,410 gallons. The anaerobic digesters are operated in series. Stabilized sludge is removed from anaerobic digester number two and pumped to the sludge storage lagoons. Biosolids are removed from the final clarifiers using two sludge pumps to the four sixty-five-foot diameter aerobic digesters with a total capacity of 2,206,308 gallons. The sludge is processed and then allowed to settle out in the four aerobic digesters. The supernatant is decanted off the top of the digester and returned to the head of the treatment plant. The secondary sludge is pumped to the four aerobic digesters. The aerobic digesters are operated in a parallel mode. Stabilized sludge is then removed from the aerobic digesters to the sludge storage lagoons. There are two biosolids storage lagoons with a total capacity of 9.90 million gallons. Sludge's percent solids, from the digesters to the lagoons, averages between one percent and four percent (1 - 4%) from both the aerobic and anaerobic digesters. The lagoons are settled and decanted back to the head of the treatment plant. When the last digester in the process becomes full or nears capacity, sludge is transferred to the lagoons for storage until the sludge can be disposed of through land application. Sludge has been land applied once every year. The City of Fort Dodge operates under a 5-year agreement with seven landowners with a total of 1,289 acres of farm ground for sludge disposal. According to the city's 5-year sludge management plan (Attachment 9), the City of Fort Dodge contracts directly with a Certified Biosolids Land Application Contractor for the dewatering and Biosolids Removal of the on-site Sludge Lagoons. By using the total solids test results provided by the state certified contract laboratory and soil samples taken, a determination of approximate land use requirements is determined. The determination of needed land helps the city and the landowner determine where to apply the biosolids. It shall be noted that the biosolids are applied to both Corn fields and Beanfields, therefore agronomic uptake rates vary from year to year. During hauling, a sample is collected from each load and composited. Once per hour this composite sample is analyzed for total solids to determine any changes in the solids content during the hauling process and to adjust application rates in the field. These samples are averaged together for a final determination of required land need for disposal. The nutrients (nitrogen and potassium) contributed by sludge application during the crop year (October 1 - September 30), do not exceed the respective crop's net nutrient requirements. Nutrients added by other sources of fertilizer (commercial fertilizers, manure, etc.), and nutrients carried over from previous years' sludge application must be subtracted from the crop's total nutrient requirements to determine the crop's net nutrient requirements. Soil samples taken by the farmer are used to determine compliance with nutrient requirements. Phosphorus in the soil shall not exceed 1,000 lbs/acre. One function of the IPP is to protect the city's sludge from metals contamination. As part of this inspection, the 2022 and 2023 annual biosolids reports (Attachment 9) were reviewed to determine the IPP's effectiveness. In 2022 the city produced 797 dry metric tons (dmt) and applied 1,534 dmt, and in 2023, the city produced 873 dmt and land applied 924 dmt. Because the city land applied 1,534 dmt in 2022, they were required to sample once per 60 days (six times per year) as required by Table 1 of 503.16 of 40 CFR 503. However, the city only sampled fives time because the lagoon was frozen in January 2022. In 2023, however, they were required to sample quarterly which they did. Below are the 2022 and 2023 tables that compares the city's peak observed metals level against the statutory ceiling and the city's average level against the exceptional quality (EQ) sludge level specified by the 40 C.F.R. Part 503 Sludge regulations. Because the city only sampled its sludge six times in 2022 and quarterly in 2023, the monthly average is the maximum value observed. As shown in the tables below, the city's sludge is well below both the ceiling and EQ levels for all metals except for arsenic and selenium where it exceeded the EQ levels in 2023. However, during my review of laboratory report for metal analyses data I noticed that there are significant variations in the numerical result of the data. I explained to IPP personnel that although the data is within the 503 limits, the IPP Coordinator should be investigating the reason behind the variation/spikes. Table 2, 2022 Fort Dodge WPCF Sludge Quality (mg/kg) Pollutant Arsenic, As Cadmium, Cd Copper, Cu Lead, Pb Mercury, Hg Molybdenum , Mo Nickel, Ni Selenium, Se Zinc, Zn 503 Ceiling 503 EQ Max 75 41 8.18 85 39 5.66 4300 1500 641 840 300 50.2 57 17 2.62 75 ---- 60 420 420 34.8 100 36 26.7 7500 2800 889 Mo. Avg. 8.18 5.66 641 50.2 2.62 60 34.8 26.7 889 Max/Ceiling 10.91% 6.66% 14.91% 5.98% 4.60% 80.00% 8.29% 26.70% 11.85% Avg./EQ 19.95% 14.51% 42.73% 16.73% 15.41% 8.29% 74.17% 31.75% Table 3, 20203 Fort Dodge WPCF Sludge Quality (mg/kg) Pollutant Arsenic (As) Cadmium (Cd) Copper (Cu) Lead (Pb) Mercury (Hg) Molybdenum (Mo) Nickel (Ni) Selenium (Se) Zinc (Zn) 503 Ceiling 503 EQ Max 75 85 4,300 840 57 75 420 100 7,500 41 57.5 39 24 1,500 721 300 125 17 1.56 ---- 52.7 420 92.7 36 99.1 2,800 918 Mo. Avg. 57.5 24 721 24.4 1.56 52.7 92.7 99.1 918 Max/Ceiling 76.67% 28.24% 16.77% 14.88% 2.74% 70.27% 22.07% 99.10% 12.24% Avg./EQ 140.24% 61.54% 48.07% 8.13% 9.18% 22.07% 275.28% 32.79% Conclusion Overall, Michelle Bemrich and Travis Pender of the USW IPP are responsible for the implementation of the city's pretreatment program. They appeared to have an adequate knowledge and the necessary skills to implement the program and were familiar with EPA's Significant Noncompliance definition and appeared to be making adequate compliance determination. Michelle Bemrich maintains the LIMS database and a worksheet that includes the current and recent compliance status of all regulated industries. As required by 40 CFR Part 403 and Rule 567 IAC 62.4(455B), all significant program modifications must be submitted to the Iowa DNR for review and approval before enacted on. Even if the IPP personal conduct all monitoring for all industries, permits should include statement that if the city is unable to conduct the required monitoring, the responsibility should fall upon the industry to complete the monitoring within the required frequency. Because the IPP performs the required sampling and analysis in lieu of the Industrial User, the IUs are not required to submit the compliance certification required under 40 CFR 403.12(g)(1). However, when issues with sampling equipment arise (loss of power, equipment failure, etc.) the city should make it clear to all IUs that IUs are responsible for the self-monitoring requirement. Therefore, the city should remove the following statement from its industrial permits "Permittee shall not be responsible for any sampling, monitoring, or analysis." The city and the IPP should revisit the ERP and enforcement procedures to improve the timing of issuing notice of violation letters. The IPP Coordinator should review the biosolids laboratory reports for the concentration of metals and investigate the reason behind the variation/spikes in metal concentration in the sludge even if the concentration in compliance with the 40 CFR 503 ceiling limits. On March 20, 2024, I received an email from the IPP Coordinator indicating that the City Manager for Fort Dodge signed the Wastewater Discharge Permit for Cargill, and it has been forwarded to the Facility Manager for her signature and acknowledgement. NAJI AHMAD Digitally signed by NAJI AHMAD Date: 2024.03.21 15:38:32 -05'00' Naji J. Ahmad Environmental Engineer, WB/DWIS Attachments 1. Checklist 2. 2021 Industrial Pretreatment Study 3. Sewer Use ordinance (SUO) evaluation 4. Industrial permits 5. Elanco CWF calculations 6. Industrial Inspections 7. Enforcement examples 8. Waste hauler letter 9. Biosolid's supporting documents JODI BRUNO Digitally signed by JODI BRUNO Date: 2024.03.21 15:52:44 -05'00' _______________________ Jodi Bruno Manager, ECAD/WB PCI Approved Pretreatment Program Date(s): March 5, 6, and 7, 2024 FY 2024 POTW: Address: Contact: Title: Address CITY OF FORT DODGE, IA Municipal Building 819 1st Avenue South Fort Dodge, IA 50501 Michelle Bemrich Industrial Pretreatment Coordinator 1406 Central Avenue Fort Dodge, IA 50501 Tel: 515 227 8695 email mbemrich@uswatercorp.net Date of last PCI/Audit: May 4 and 25, 2022 (DNR) NPDES Permit No.: IA 0044849 State Permit No.: 94-33-0-03 Expiration Date: 9/30/2025 Participants POTW: US Water, Water and Wastewater Utility Michelle Bemrich, IPP Coordinator Travis Pender, Project Manager Inspectors: Naji J. Ahmad, Environmental Engineer, ECAD/WB/DWIS Period covered by this PCI/Audit: 2021-2023 POTW Information Total for ALL Treatment Plants (MGD) Design Daily Ave. 8.4 ADW 15 AWW Actual Daily Ave. 8.95 Design Peak: 21.6 MXWW % Industrial Flow: 53%* Number of Plants: 1 % Combined Sewers: NONE Type of Treatment at Principal Plant: Vertical Loop Reactor (VLR)/Activated Sludge Sludge Disposal Method: Land Application (Sludge Lagoon) Quantity (dry/met.tons/Y): 873: produced 924: land applied Total permitted flow for all 9 industries = 7.6302 mgd (Total permitted /WWTP ADW) = 7.6302 mgd /8.4 mgd = 90.8358% Receiving Stream: Des Moines River Total averge daily flows from all 9 industries in 2023 = 4.819 mgd (2023 AVG Daily industrial flow /WWTP actual AVG flow 2023) = 4.819 mgd /8.95 mgd = 53.84% PART I: PROGRAM BACKGROUND INFORMATION I.A. Approved Modifications to the Original Program 1. Date of last NPDES permit modification: 10/1/2020 Date of original Program approval: Date NPDES Permit originally modified to require implementation [PTIM]: 01/30/1984 01/01/1985 2. Approved Pretreatment Program modifications: REQUIRED MODIFICATIONS PIRT SUO Revisions List of SIUs [403.8(f)(6)] Enforcement Response Plan DSS SUO Revisions LOCAL LIMITS APPROVAL DATE 02/22/1994 03/01/1992 02/22/1994 02/22/1994 02/22/1994 OTHER APPROVED MODIFICATIONS DNR approved DNR approved DNR approved DNR approved DNR approved APPROVAL DATE 6/19/2013 6/19/2013 6/19/2013 6/19/2013 6/19/2013 3. Is the POTW presently working on any program modifications? NO. 4. Does the POTW have any program modifications currently being reviewed by the Approval Authority? YES. The city submitted the 2021 revision to comply with the current NPDES permit. The city submitted to the regional IDNR office not the Central Office. During the inspection, the city submitted the SUO revision and LL to Ben Hucka as EPA Instructed. I.B. Approved Program Contents 5. Authority to enforce Pretreatment Standards contained in: City Ordinance 1863. Chapter 13.24 (Pretreatment) and Chapter 13.12 (Fees). 6. Date enacted or adopted: September 1994 (original) 7. Approved Control Mechanism: Permits/Sewer Use Agreements Note: Italicized question numbers indicate that the question is data base supported. 8. What is the frequency required by the approved program/modifications for: Activity Non-categorical SIUs Categorical SIUs* POTW sampling of: 1/Y 1/Y POTW inspection of: 1/Y 1/y SIU self-monitoring: 2*/Y 2*/Y SIU reporting: 2*/Y 2*/Y * Not required since city conducts all monitoring. 9. What types of enforcement options are available through the approved program: 10. COMMENTS: Y Notice of Violation (NOV) Y Administrative Order (AO) Y Show Cause Hearing Y Establishment of Compliance Schedules Y Revocation of Permit Y Injunctive Relief Y Fines; Maximum $1000/day/violation Y Criminal Penalties Y Termination of Service PART II: INTERVIEW QUESTIONS II.A. Legal Authority and Jurisdiction 11. Have any Pretreatment modifications been made to the Sewer Use Ordinance since the last PCI/Audit that have not been approved by the Approval Authority. NO. The city completed the SUO revision and LL in 2021. Submitted to the IDNR but yet to be approved. 12. List by name and location any SIUs that discharge to the POTW from outlying jurisdictions. Elanco, CJ Bio America, and Cargill. Indicate which of the above are not covered by a contract/agreement requiring them to abide by the POTWs legal authority. NONE 13. Does the POTW have the authority to seek fines up to $1000 per day? [403.8(f)(1)(vi)] YES. In Section 13.24.350 14. If the POTW has not yet developed an Enforcement Response Plan when does the POTW feel it will complete this requirement? Original ERP was in 1994. A new ERP was approved by IDNR on June 19, 2013. 15. COMMENTS: The City attaches the ERP to all industrial users permits. II. B. Control Mechanism 16.General Information: Type: PERMITS Duration: 5 years & 1 year for haulers Issued to Noncategorical SIUs? [DSS: 403.8(f)(2)(i)] YES 17.Do all SIUs have current (unexpired) control mechanisms? {NOCM} YES. Except Cargill permit is waiting for City Signature. 18.List by name those that do not and indicate which ones have not had a current control mechanism for 180 days or more. {RNC/SNC} NA. II.C. Hauled Wastes 19. Does the POTW accept hauled waste? (If "no," go to question 25) YES. Domestic and industrial a. if so describe (include approx. no. of loads per month): x In 2022 the WPCF received a total of 991 loads. Averaging of 82 loads/month with an average 1,526 gal/load. The total volume was 1.512 MG. x In 2023 the WPCF received a total of 1266 loads. Averaging of 105 loads/month with an average 2,154 gal/load. The total volume was 1.710 MG. b. How does the POTW ensure that it does not accept hazardous waste? x Special waste haulers are required to show sampling analysis before dumping. x Domestic waste haulers are randomly monitored or sampled monthly by the WWTP. 20. Does the POTW have a control mechanism for regulating waste haulers, and if so describe. YES. Each hauler must complete manifest. 21. Does the POTW have a designated discharge point (or points) for waste haulers? [DSS: 403.5(b)(8)] Describe: Prior to head works. Access discharge point with automatic pH metering device. 22. Are all applicable Categorical standards and Local Limits applied to IUs whose wastes are hauled to the POTW? YES. 23. Describe the method used to apply local limits to hauled waste. Comparing sampling analysis to local or Categorical limits. 24. COMMENTS: 2023 Haulers List: Al Price Septic Service, Doyle Construction, Gudmonson Services, Portable Pro, The Tile Pros, Weiss Septic Pumping & Hauling, Advanced Waste Solutions, Mid Iowa Septic Services, and Moores Pumping & Portable Toilets LLC II.D. Industrial User Characterization 25. How often does the POTW update its Industrial Waste Survey (IWS) to identify new SIUs or changes to wastewater discharges? Every five Years. On going. a. When was the last formal update: March thru July in 2020. 26. What is the POTW's current industrial base? Current 3 6 9 Industrial User Type Categorical SIUs {CIUS} Non-Categorical SIUs Total all SIUs {SIUS} Last Reported 3 12 Three SIUs were removed from list in February 2023: Advantech Ltd, Americold Logistics, and Josephson Manufacturing Co. II.E. Local Limits 27. Does the POTW have numerical limits for metals in its NPDES permit? If so, list the metals and the limits (or attach list). NONE. 28. Have there been any numerical NPDES permit violations in the last 12 months? NO. a. Were any of the numerical NPDES violations, identified above, a result of interference or pass through? NA. 1. Was the interference traceable to an industrial user? 2. Was action taken that led to elimination within 90 days of the interference or pass through? {SNC} NA. 3. Was the responsible industry placed on an enforceable compliance schedule within 90 days of discovery? {SNC} If not, why? NA. 29. How many times per year does the POTW regularly sample its PRINCIPAL plant for the following? Parameter Influent Metals 12* Toxic Organics - Biomonitoring TCLP *Mercury and zinc, **zinc Effluent 12** 0 1 Sludge 6 - - 30. List below the numerical value for the local limits derived by technical analysis. If a technical analysis was performed but the limit not adopted enter DNA in the block. (Values assumed to be mg/l unless otherwise noted). {EVLL} {ADLL}. The following are based on the September 2021 study. The city incorporated the local limits in the Industrial Users permits. But the IDNR has yet to approve the LL study or the SUO revision. POLLUTANT Arsenic Cadmium Copper Chloride Cyanide Lead Mercury Molybdenum pH DAILY MAX (lb/day) 0.47 POLLUTANT Nickel DAILY MAX (lb/day) 4.7 0.60 Selenium 0.94 DNA Silver 0.97 54,114 Zinc 41.53 0.77 Acetone DNA 6.47 Toluene DNA 0.26 Xylenes, (T) DNA 0.70 Barium DNA 5.0 SU - 9.5 SU POLLUTANT 1,4-Dichlorobenzene Bis(2-ethylhexyl)phthalate 4-methylphenol Beryllium Chromium Fluoride Phenol BOD TSS DAILY MAX (lb/day) DNA DNA DNA DNA DNA DNA DNA DNA DNA 31. Are the POTW's BOD and TSS limits technically derived (ie. based on plant capacity)? YES. 32. Are BOD and TSS violations treated as violations of technically based local limits? YES. 33. If there is more than one treatment plant, were the local limits established specifically for each plant? NA 34. Has the POTW made any changes to its Local Limits which have not been approved, and if so provide details? [403.18] The September 2021 LL were incorporated in the Industrial Users permits. But the IDNR has yet to approve the LL study or the SUO revision. 35. Has the POTW granted any Net/Gross allowances under 403.15? NO 36. COMMENTS: The following are based on the September 2021 study. The city incorporated the local limits in the Industrial Users permits. But the IDNR has yet to approve the LL study or the SUO revision. II.F. Standards and Requirements for Industrial Users 37. Does the POTW compare local limits against federal Categorical standards and apply the most stringent standards to Categorical IUs? [403.4] YES. a. Are any IUs required to implement best management practices in lieu of monitoring for pollutants: NO. If yes, describe: 38. Has the POTW notified its IUs of possible RCRA obligations? [40 CFR 403.8(f)(2)] YES. 39. Does the POTW allow Categorical users to use Solvent Management Plans/certification or surrogate test procedures to meet TTO requirements? YES. Currently the city has no industry subject to TTO. II.G. POTW Compliance Monitoring and Inspections 40. What is the current frequency for: Activity POTW sampling of: POTW inspection of: SIU self-monitoring: SIU reporting: Non-categorical SIUs 2-4-2 week 1/Y 2-4-2 week **NA Categorical SIUs 1, 3, & 4 Week 1/Y 1, 3, & 4 Week **NA 41. List exceptions: City does all monitoring. ** Industrial permits included requirement for daily flow monitoring. The city has access to the flow data through SCADA system at lift station at all industries. All industries have access to their daily flow and all monitoring data. Therefore, IUs don't have to submit the data in a semiannual periodic monitoring reports with certification statement. 42. List those SIUs that were not sampled by the POTW within the last 12 months. [DSS: 403.8(f)(2)(v)] NONE 43. List those SIUs that were not inspected within the last 12 months. [DSS: 403.8(f)(2)(v)] NONE 44. How many industries were neither sampled nor inspected within the last 12 months. [DSS: 403.8(f)(2)(v)] {NOIN}{RN}. NONE. 45. Does the POTW sample its SIUs for all regulated pollutants at least once annually? [403.8(f)(2)(v)] YES 46. Sample/Analysis Procedures: Chain-of-Custody always used? YES Sampling method, metals: TIME COMPOSITE Ability to sample on short notice? YES Sampling method, CN: GRAB In-house analysis of toxic pollutants: NONE Sampling method, O&G: GRAB Do in-house analytical methods conform to 40 CFR part 136? YES 47. How does the POTW document its industrial user inspections? 7 or 8 page CHECKLIST 48. Does the POTW evaluate all SIUs at least every two years to determine the need for a slug discharge/spill control plan? [DSS: 403.8(f)(2)(v)] All industries are required by the permit to develop and submit a plan. a. Describe the method used by the POTW to evaluate the need for a slug control plan. NA II.H. IU Self Monitoring and Reporting 49. Are all Categorical IUs required to self-monitor for all pollutants regulated by the respective Categorical standard at least twice per year? [403.12(e)] NO. All samples are collected by the city. 50. Were any Baseline Monitoring Reports or 90 day Compliance Reports due within the past 12 months?. If so, from whom? Were the reports submitted? NONE 51. Are IUs required to report spills, slug discharges, etc. to the POTW? [403.12(f)] YES 52. Are IUs required to report violations within 24 hours of knowledge of the violation? [403.12(g)(2)] YES 53. Are IUs required to resample and submit results within 30 days following a violation as per 403.12(g)(2)? YES II.I. Data Management 54. Are files/records computerized? YES 55. Are all records maintained for at least 3 years? [403.12(o)] YES. Records are well organized and easily accessible. 56. Are program records available to the public as required by 40 CFR 403.14(b)? YES. 57. Does the POTW have provisions to address confidential business information? [403.14(a)] YES 58. How is compliance status calculated? Describe the procedure used in determining Significant Noncompliance (eg. are mo. avg. violations considered as well as daily max?). City logs all monitoring data in LIMS. The program then calculates and flags SNC and TRC. The IPP Coordinator will then determine compliance status based on LIMS. The program does not calculate Infrequent non compliance. II.J. Program Resources 59. What percent of the Pretreatment Coordinator's time is spent on pretreatment? PC 100%. Project Manager 25%. Field Tech 50%. Lab supervisor and 3 Lab Tech 40%-60%. City 10%. 60. What computer programs does the POTW use for: Wordprocessing: MS WORD Spreadsheet: EXCEL Database: Hach WIMS/LIMS 61. Does the POTW believe its annual budget adequate for implementation? YES. a. If not, is the level of money available for pretreatment less than that in the approved program or approved modification? II.K. Special Questions 62. Are there any issues that the POTW would like to discuss: NO. PART III: FILE AND RECORDS REVIEW Following is a table containing the POTW's Significant Industrial User inventory regulated by its Pretreatment Program. Please verify that all information in the table is correct and current. For those industries no longer regulated draw a line through the entry. Add all new industries and provide the information sought by the table. Below is a guide to the information sought by the table and suggested abbreviations. INDUSTRY: Provide the name of each industrial user regulated under the pretreatment program. CAT STND: Provide the categorical standard code number. For example, industries subject to the Metal Finishing regulation should be designated "433." For noncategorical industries indicate "NA" in this column. REG PROCESS: Indicate what process the industry performs to qualify for inclusion in the pretreatment program. For example, if an industry is subject to Metal Finishing regulations because it performs zinc and chromium plating indicate with "ZnCrPL" or a similar abbreviation. TMT: If the facility treats its wastestream(s) indicate "Y." If no treatment is provided indicate "N." TYPE: Indicate the type of pretreatment system (if applicable) the industry has. Suggested abbreviations: "precip" for precipitation/clarification; "precp/flt" for precipitation followed by filtration; "DAF" for dissolved air flotation; etc. REG FLOW: Provide the industry's average daily flow for its regulated processes in gallons per day. The abbreviation "K" stands for 1000. TOT FLOW: Provide the average daily total plant flow in gallons per day. CWF: Indicate if the industry uses the Combined Wastestream Formula to determine compliance with categorical standards. "Y" = yes, "N" = no. COMPLIANCE STATUS FOR THE 6 MO PERIOD ENDING: For the six month periods listed, indicate if the industry's compliance status. Use the following abbreviations: CIn compliance with all standards: no violations. IInfrequent noncompliance with discharge standards: the facility had some violations but not severe enough to be considered in significant noncompliance. SNC,SIn significant noncompliance with discharge standards. SNC,RIn significant noncompliance with reporting requirements: the industry failed by greater than 30 days to submit reports as required. SNC,MIn significant noncompliance with self monitoring requirements: the industry did not properly report its compliance status on its self monitoring report. SNC,C Failure to meet a compliance schedule milestone by 90 days. LAST INSPECTION: Date of the last inspection performed by the POTW. SECTION VII: SIGNIFICANT INDUSTRIAL USERS Compliance Status for Six Month Period Ending: Industry Name Argenta Medical Labs- Riverside(2) BHJ-USA, Inc. (3) Cargill Fort dodge Cat. Standard 439 NA T Reg. M Process T VETMEDCN N Cold Storage Y 406.15 (A) WetCornMill Y Type NA Rotary screen EQ Aeration Basin, MBR Reg.3 C JUNE DEC. JUNE DEC. Last Flow Total W (MGD) Flow F 2022 2022 2023 2023 Inspection .0142 0.02 N I-M I-M SNC SNC 9/27/2023 0.14 0.02 N I-M I-M I-M I-M 11/13/2023 3.5 2.439 N I-M I-M I-M I-M 10/20/2023 CJ Bio America NA Amino Acids Y 3 holding ponds w/ 2.533 1.47 N I-M I-M I-M I-M 12/13/2023 Aeration, pH Elanco US Inc. 439 VETMEDC Y pH, Hg Pre-Filter, 0.93 .41 YES C C C C 12/5/2023 Auto clave MBBR Fort Dodge Correctional Facility NA Prison Y Grease Trap, pH 0.24 .13 N I-M I-M I-M C 11/20/2023 North Central Regional Solid Waste Agency NA Munic.Landfill N NA 0.02 .21 N C C C I-M 11/2/2023 Nestle Purina Pet Care NA PetFood Y Rotary Screen, pH, 0.175 .09 N I-M I-M I-M I-M 12/20/2023 GEM Syst Unity Point Health-Trinity Regional MC NA Hospital N NA 0.08 .03 N I-M I-M I-M I-M 11/10/2023 Advantech Ltd (1) NA VETMED N 0.0003 N I-M C C NA 10/18/2022 Josephson Manufacturing Co.(1) NA Radiators Y 0.002 N C C C NA 9/13/2022 Americold Logistics(1) NA Cold Storage N (1) eliminated February 2023 (2) Failure to meet a Compliance Order/Schedule. (3) Permitted flows 0.01 N I-M I-M C NA 9/7/2022 III.B. Significant Industrial User Compliance Evaluation 63. From the above list of industries, how many are in Significant Noncompliance (SNC) with either discharge standards or reporting requirements based on the most recent six-month reporting period? {PSNC} Argenta Medical Labs- Riverside 64. List by name, those industries currently on a compliance schedule. Complete the table below. NONE. But in the past 12 months: Industry Name Date Schedule Issued Compliance Deadline How Administered* Argenta Medical Labs- Riverside January 1, 2021 December 31, 2023. Permit 65. List those industries last published in the newspaper for noncompliance and provide the date (or attach a copy of the public notice). Argenta Medical Labs- Riverside. 66. If an industry has been deleted from the list of Significant Industrial Users list by name below and provide the reason. Advantech, Americold, and Josephson Manufacturing Co. in Fort Dodge, Iowa. It was determined by the IPP Coordinator and the City of Fort Dodge to eliminate three Noncategorical SIU's from the Pretreatment Program due to their little to no impact at the WWTP. The 3 industries were monitored for their flow rate, solely, in January 2023, not inspected nor sampled, and officially released of their discharge permits in February 2023. 67. For those industries in SNC within the last 12 months complete the following table for all written enforcement actions. IU Name Violation Date of POTW knowledge Date of Action Enforcement ERP required Action action Argenta Medical Labs- Failure to meet January 31, August 31, Riverside. compliance schedule by 2023 2023 January 31, 2023 NOV NOV 68. Provide the total number of NOVs, Administrative actions, Judicial referrals, and criminal prosecutions that occurred in the last twelve months. {FENF} {JUDI} There were 71 NOVs issued in 2023. 69. Were all actions taken by the POTW within 30 days of knowledge of a violation? {RNC/SNC} YES 70. Did all industries in SNC either return to compliance within 90 days, receive escalated enforcement action by the POTW within 90 days, or become placed on an enforceable compliance schedule within 90 days (of knowledge by the POTW) of the violation? {RNC/SNC} YES. III.C. Control Mechanism Evaluation 71. Do the POTWs control mechanisms: REQUIRED [DSS: 403.8(f)(1)(iii)] Permittee: AML SUGGESTED PROVISIONS Specify duration (no > 5 yrs.): Y Cite the POTW's legal authority: Y Contain the correct discharge limits: Y Identify TTO alternatives, if applicable: Y Specify sample type for IU self monitoring: Y Require notification within 24 hrs of a violation: Y Adequately identify sampling location: Y Require resample/report in 30 days of violation: Y Specify sampling frequency: Y Specify right of entry: Y State applicability of civil or criminal penalties: Y Reserve right to revoke permit: Y Stipulate reporting frequency: NA Specify immediate slug load notification: Y Properly require records retention: Y Require submission of all sampling results* NA Specify limited transferability: Y *City conducts all monitoring for the industries and industries have access to all data. Result of this review from the last PCI/audit: Permits has clear formats, has all necessary elements needed and included the Enforcement Response Plan as an attachment. Because the City does all monitoring, permits should include statement that if the City is unable to conduct the required monitoring, the responsibility should fall upon the industry to complete the monitoring within the required frequency. III.D. Industrial Inspection Evaluation 72. Do the Industrial Inspection reports contain? Cargill -Fort Dodge Name of Company contact: Y Evaluation of IU's monitoring procedures* NA Date of inspection: Y Verification of wastewater flow rates: Y Time of inspection: Y Determination of applicability of the CWF: Y Description of manufacturing process: Y Description of the chemical storage area: Y Description of treatment process, if any: Y Identification of potential spill conditions: Y Evaluation of IU's monitoring methods* NA Y Verification of production rates that would affect production based standard: Y *City conducts all monitoring for the industries. III.E. Slug Discharge Control Procedures 73. If the POTW has required the submittal of a Slug Control Plan does it contain: [DSS: 403.8(f)(2)(v)] ___X___ A description of discharge practices including non-routine batch discharges ___X___ A description of stored chemicals __X____ Procedures for immediate notification of slug discharges with written follow-up notification ___X___ Procedures necessary to prevent adverse effects at the POTW's treatment plant: ___X___ inspection and maintenance of storage areas ___X___ handling and transfer of materials __X____ loading and unloading operations ___X___ control of plant site runoff __X____ worker training ___X__ building of containment structures ___X___ measures for the control of toxic organics ___X__ measures for emergency response 74. COMMENTS: All industries are required by the SUO and the permit to develop, submits and implement a Slug Discharge Control Plan. All industries did submit such plans. III.F. Industrial User File Review Checklists Following are worksheets to aid in the assessment of the nature of the oversight activities and compliance status of the POTW's Significant Industrial Users. When reviewing SIU files priority should be placed on Categorical industries that either have a history of violations or that appear to be in compliance but have not installed that prescribed BAT technology to consistently meet discharge limits. While only three pages are provided the reviewer is encouraged to copy and add additional review pages for larger POTWs. Industry Name: Cargill Fort Dodge Principal Pollutants: Flow, BOD, TSS, NH3,.pH Products: Wet Corn Milling 40 CFR 406.15 Subpart A No. of Employees: 150 A. Does the file system for the industrial user contain: Y Permit application Y Current Permit Y Correct limits in Permit Y Correspondence/meeting notes/phone log Y Most recent inspection report Y Evaluation for need for Slug control Y Compliance status determination Y POTW sampling results NA Self-monitoring reports Y Enforcement documentation NA Solvent Management Plan NA Correct application of the CWF Y Slug Control Plan Y Correspondence/ emails B. Did the industry discharge any slug loads or spills to the POTW in the past 12 months? [403.12(f)] NO. _____ Immediate notification by the IU _____ POTW response _____ Follow-up written notification _____ Effect on the plant C. In the last complete calendar year, how many times did the POTW: Sample the IU 5/ Week Inspect the IU 1/ Year D. Were all regulated pollutants analyzed by the POTW at least once in the most recent calendar year? YES. E. If the industry is subject to Categorical Standards did its self-monitoring reports contain analysis for all regulated pollutants at least once during every six-month period during the last full calendar year? YES. F. Frequency in the IU's control mechanism for: Self-monitoring: NA Reporting: NA G. Did the industry comply with the sampling and reporting frequency requirements of its Control Mechanism? NA. H. Did the POTW identify all IU violations from: IU Self-monitoring: NA POTW Compliance monitoring: YES. I. Was the IU's compliance status (i.e. SNC, Infrequent noncompliance, Consistent compliance) determined properly? J. Complete the following table for all violations in the last 12 months. (If this information has already been provided in Question 85, please indicate). Date of Date of ERP Date of POTW POTW Required POTW Violation Violation Knowledge Response Response Response Information correctly reported on the annual report. Industry Name: Elanco US Inc. Principal Pollutants: Flow, BOD, TSS, NH3, O&G, Metals (LL), chloride, and Organics. Products: Pet Food A. Does the file system for the industrial user contain: 40 CFR 439.16(c) No. of Employees: 550 Y Permit application Y Current Permit Y Correct limits in Permit Y Correspondence/meeting notes/phone log Y Most recent inspection report Y Evaluation for need for Slug control Y Compliance status determination Y POTW sampling results NA Self-monitoring reports Y Enforcement documentation Y Solvent Management Plan (SPCC) NA Correct application of the CWF Y Slug Control Plan 6/11/2020 Y Phone Log B. Did the industry discharge any slug loads or spills to the POTW in the past 12 months? [403.12(f)] NO. _____ Immediate notification by the IU _____ POTW response _____ Follow-up written notification _____ Effect on the plant C. In the last complete calendar year, how many times did the POTW: Sample the IU 3/ Week Inspect the IU 1/ Year D. Were all regulated pollutants analyzed by the POTW at least once in the most recent calendar year? YES. E. If the industry is subject to Categorical Standards did its self-monitoring reports contain analysis for all regulated pollutants at least once during every six-month period during the last full calendar year? YES. F. Frequency in the IU's control mechanism for: Self-monitoring: NA Reporting: NA G. Did the industry comply with the sampling and reporting frequency requirements of its Control Mechanism? NA. H. Did the POTW identify all IU violations from: IU Self-monitoring: NA POTW Compliance monitoring: YES. I. Was the IU's compliance status (i.e. SNC, Infrequent noncompliance, Consistent compliance) determined properly? J. Complete the following table for all violations in the last 12 months. (If this information has already been provided in Question 85, please indicate). Date of Date of ERP Date of POTW POTW Required POTW Violation Violation Knowledge Response Response Response NONE Industry Name: AML Riverside. Principal Pollutants: Flow, BOD, TSS, NH3, O&G, Metals (LL), chloride, and Organics. Products: Animal Health A. Does the file system for the industrial user contain: 40 CFR 439.2(a) No. of Employees: 90 Y Permit application Y Current Permit Y Correct limits in Permit Y Correspondence/meeting notes/phone log Y Most recent inspection report Y Evaluation for need for Slug control Y Compliance status determination Y POTW sampling results NA Self-monitoring reports Y Enforcement documentation Y Solvent Management Plan Y Correct application of the CWF Y Slug Control Plan B. Did the industry discharge any slug loads or spills to the POTW in the past 12 months? [403.12(f)] NO. _____ Immediate notification by the IU _____ POTW response _____ Follow-up written notification _____ Effect on the plant C. In the last complete calendar year, how many times did the POTW: Sample the IU 52 Inspect the IU 1/ Year D. Were all regulated pollutants analyzed by the POTW at least once in the most recent calendar year? YES. E. If the industry is subject to Categorical Standards did its self-monitoring reports contain analysis for all regulated pollutants at least once during every six-month period during the last full calendar year? YES. F. Frequency in the IU's control mechanism for: Self-monitoring: NA Reporting: NA G. Did the industry comply with the sampling and reporting frequency requirements of its Control Mechanism? NA. H. Did the POTW identify all IU violations from: IU Self-monitoring: NA POTW Compliance monitoring: YES. I. Was the IU's compliance status (i.e. SNC, Infrequent noncompliance, Consistent compliance) determined properly? J. Complete the following table for all violations in the last 12 months. (If this information has already been provided in Question 85, please indicate). Date of Date of ERP Date of POTW POTW Required POTW Violation Violation Knowledge Response Response Response SNC Information correctly reported on the annual report. Industry Name: Nestle Purina Principal Pollutants: Flow, BOD, TSS, NH3, FOG, Metals (LL0 Products: Cat Food A. Does the file system for the industrial user contain: No. of Employees: 280 Y Permit application Y Current Permit Y Correct limits in Permit Y Correspondence/meeting notes/phone log Y Most recent inspection report Y Evaluation for need for Slug control Y Compliance status determination Y POTW sampling results NA Self-monitoring reports Y Enforcement documentation Y Solvent Management Plan NA Correct application of the CWF Y Slug Control Plan Y Phone Log B. Did the industry discharge any slug loads or spills to the POTW in the past 12 months? [403.12(f)] NO. _____ Immediate notification by the IU _____ POTW response _____ Follow-up written notification _____ Effect on the plant C. In the last complete calendar year, how many times did the POTW: Sample the IU 52 Inspect the IU 1/ Year D. Were all regulated pollutants analyzed by the POTW at least once in the most recent calendar year? YES. E. If the industry is subject to Categorical Standards did its self-monitoring reports contain analysis for all regulated pollutants at least once during every six-month period during the last full calendar year? YES. F. Frequency in the IU's control mechanism for: Self-monitoring: 52 Reporting: NA G. Did the industry comply with the sampling and reporting frequency requirements of its Control Mechanism? NA. H. Did the POTW identify all IU violations from: IU Self-monitoring: NA POTW Compliance monitoring: YES. I. Was the IU's compliance status (i.e. SNC, Infrequent noncompliance, Consistent compliance) determined properly? J. Complete the following table for all violations in the last 12 months. (If this information has already been provided in Question 85, please indicate). Date of Date of ERP Date of POTW POTW Required POTW Violation Violation Knowledge Response Response Response I . Information correctly reported on the annual report.