Document 9J8Md5OQk5YG3kQ3z8dEqqqy5

Inspection Date: Time: Media: Statute(s)/Program(s): Type of inspection: Access: REGION 5 Enforcement and Compliance Assurance Division INSPECTION REPORT 03/01/2023 Announced: Yes Entry: 08:54 AM (ET) Exit: 12:49 PM (ET) Water Clean Water Act, NPDES, WWTP Focused Inspection - AO monitoring Granted Permittee Name: Facility or Site Name: Facility/Site Physical Address: (City, state, zip code) County/Parish: Facility GPS Coordinates: CITY OF KENDALLVILLE CITY OF KENDALLVILLE WASTEWATER TREATMENT PLANT 501 WEST WAYNE STREET KENDALLVILLE, IN 46755 NOBLE 41.446444, -85.273806 Facility/Site Identifier: Permit Number: 110005973900 IN0020656 Persons Participating in Inspection: Title Name Phone Lead Inspector Dean Maraldo 3123532098 Inspector Jake Berger (312) 353-8024 Inspector Lynn Raisor (317) 691-0099 Inspector Aaron Deeter (317) 691-1915 City Council Member Jim Dazey Superintendent Mark Schultz (260) 349-8598 Maint. and Collection Supervisor Pretreatment Coordinator WET Env. Eng Patrick Howell Trevor Hampshire (260) 347-1362 Wade Hale (260)410-4400 WET Env. Eng Karl Tanner WET Env. Eng Kyle Walters WET Env. Eng Dustin Wuis (260) 222-1560 Email Present at Opening Conf. maraldo.dean@epa.gov Yes berger.jake@epa.gov Yes LRAISOR@idem.IN.gov Yes ADEETER@idem.IN.gov Yes Yes mschultz@kendallville-in.org Yes Yes THampshire@kendallville-in.org Yes whale@wetenvironmental.com Yes ktanner@wetenvironmental.com Yes kwalters@wetenvironmental.com Yes dwuis@wetenvironmental.com Yes Present at Closing Conf. Yes Yes Yes Yes No Yes Yes Yes Yes Yes Yes Yes 1 of 22 KENDALLVILLE WWTP Inspection Date: Lead Inspector: Dean Maraldo Supervisor Review: Ryan Bahr 03/01/2023 [Signature] REGION 5 Digitally signed by DINO DINO MARALDO MARALDO Date: 2023.03.02 16:36:04 -06'00' Maraldo.Dean@epa.gov (312) 353-2098 [Signature] REGION 5 Ryan Bahr Digitally signed by Ryan Bahr Date: 2023.03.02 21:24:07 -06'00' bahr.ryan@epa.gov SECTION I - INTRODUCTION Site Entry and Inspection Objectives I, Region 5 Lead Inspector, Dean Maraldo, arrived at the KENDALLVILLE WWTP (the "Site" or "Facility"), located at 501 WEST WAYNE STREET, at 8:54 AM (all times in Eastern Time Zone) on 03/01/2023 for an announced inspection. REGION 5 inspector Jake Berger joined me for the inspection and we both presented our credentials to the Superintendent Mark Schultz and informed him that this was a REGION 5 inspection to determine compliance with the Clean Water Act (CWA) and the National Pollutant Discharge Elimination System (NPDES) permit program, and the recently issued administrative order on consent (dated January 9, 2023). The inspection was conducted under the authority of the Federal CWA (Section 308). The table above identifies the attendees that participated in the inspection. This report is based on information supplied by Facility representatives, observations made by the Region 5 inspectors, and records and reports maintained by the permittee and the Region 5 inspectors, including: direct observations made by the Region 5 inspectors, photographs taken by Region 5 inspectors, physical evidence collected by the Region 5 inspectors, verbal or written statements made by or information supplied by Facility representatives (the permittee) during or subsequent to the on-site inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the Region 5 inspectors by Facility representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the inspection from a review of U.S. EPA, State, and public records may be included in this report. After opening introductions, we went over the inspection plan for the day, including review of recent compliance with permit limits and the City's recently submitted Interim Compliance Plan. I asked if there were any questions. There were no questions. SECTION II - OBSERVATIONS Observations may not be in sequential order. Unit: Review of Recent Effluent Data Observation #: DM1-OB-001 Contains CBI: No Date: 03/01/2023 I asked the Facility representatives about recent compliance with NPDES permit limits. Mr. Hampshire presented recent influent and effluent data (see Appendix 2 - Inspection Documents). The data showed the facility is still struggling to meet effluent limits for nitrogen-ammonia, total suspended solids (TSS), phosphorus and biochemical oxygen demand (BOD). Mr. Schultz said that the ongoing effluent limit exceedances are due to highly variable BOD loading from Kraft Heinz. I asked about recent copper effluent limit exceedances. 2 of 22 KENDALLVILLE WWTP Inspection Date: 03/01/2023 Mr. Schultz said the copper issues are usually related to high TSS influent conditions. I asked if all treatment plant components were up and running at the time of inspection. Mr. Schultz confirmed all treatment plant components were up and running at the time of inspection. Unit: Review of City's Draft Interim Compliance Plan Observation #: DM1-OB-002 Contains CBI: No Date: 03/01/2023 I asked the City to review the key elements of their recently submitted Draft Interim Compliance Plan required under EPA's Administrative Order on Consent ("AOC"), dated January 9, 2023. The City submitted the Draft Interim Compliance Plan on February 7, 2023, and within the timeframe required by the AOC (paragraph 112(a)(i)). The City representatives walked through the planned interim measures and implementation schedule. I asked for clarification regarding the process of thermal bulking of secondary clarifiers, and the length of time proposed for chemical addition and redirection of pressate to digesters. Mr. Walters explained that currently a third of the mounding around clarifiers is complete, with a goal of adding bulk material to within 12-18" of the top of the clarifiers. Mr. Schultz added that the schedule for installing equipment related to chemical addition and redirection of pressate to digesters was due in part to funding procedures under the American Rescue Plan and contracting and installation scheduling. Mr. Schultz provided the list of equipment to be installed over the next several months (see Appendix 2 - Inspection Documents). Following the overview of the Draft Interim Compliance Plan, the City agreed to address some minor comments, including missing tables and figures, by March 6. Unit: Review of Kraft Heinz Draft Interim Compliance Plan Contains CBI: No Observation #: DM1-OB-003 Date: 03/01/2023 Representatives of Kraft Heinz arrived at 9:50 AM, including Scott Borger, Kenny Pankop, Eric Stanek (via phone), Rachel Burris (Ramboll, via phone), and Dan Wagner (Ramboll, via phone). They joined the meeting to go over the company's Draft Interim Compliance Plan required under EPA's Administrative Order on Consent ("AOC"), dated January 18, 2023. I asked the Kraft Heinz representatives to specifically describe items 17-24 (items initiated since November 2022) in the plan, summarized below: #17. Rented a 24-hour sampler to investigate elevated BOD discharges. #18. Daily Walk Through with Maintenance and Production Manager inspecting pumps or lines that for leaks. #19. End of production run remove excess product prior to sanitation. #20. Check pH every 4 hours and calibrate sensor every week. #21. When shutting down lines capture as much product as possible into Animal Feed totes to reduce wastewater loading. #22. Weekly Wednesday call with City and engineering group to discuss issues or actions. #23. Daily COD sampling to the City. #24. Continuous evaluation of process to identify additional measures to reduce BOD Loading. Mr. Borger described each of the above items. For item #17, Mr. Borger noted BOD spikes occurred at night due to sanitation and cleaning and flushing lines. I asked for clarification for item #19. Mr. Borger said that crews remove excess product from tanks and then scrape into hoppers, and reuse excess in other processes. 3 of 22 KENDALLVILLE WWTP Inspection Date: 03/01/2023 For item #20, Mr. Borger said that they now check pH every 4 hours, and added that "pH doing well, no violations over last couple months." Regarding item #21, Mr. Borger clarified that captured waste in marshmallow lines was used for animal feed. Lastly, for item#24, Mr. Borger provided a copy of his presentation describing continuous evaluation process to reduce BOD loading (see Kraft Heinz handout in Appendix 2 - Inspection Documents). After the presentation, I asked if they had any other interim items to mention. Mr. Borger added that they expect to have corporate help with ideas soon, and they were looking into working with third parties for solutions. Mr. Stanek added that Kraft Heinz plans to use a phased approach for interim actions. We agreed to set up a call with Kraft Heinz and EPA to discuss interim measures in more detail. Mr. Hampshire asked about BOD spikes in January. Mr. Pankop said January was bad month and weather caused a lot of problems in production and unplanned downtime (see Kraft Heinz handout in Appendix 2 - Inspection Documents). Mr. Tanner asked Dan Wagner (Ramboll) if they could share design criteria for BOD inflows. They agreed to set up a meeting to discuss. Mr. Schultz asked about Kraft Heinz plans to construct an equalization basin. Rachel Burris said Kraft is evaluating the option and will include it in the engineering report (due to EPA in April pursuant to the AOC). Mr. Schultz followed up with a question about developing an O&M manual. Kraft Heinz representatives confirmed that an O&M manual would be developed. With no additional questions, we concluded the meeting with Kraft Heinz, and their representatives departed the facility at 10:35 AM. After a break we reconvened and began the physical plant inspection. Unit: Physical Inspection Observation #: DM1-OB-004 Contains CBI: No Date: 03/01/2023 We began the physical plant inspection at 11:15 AM. The Superintendent led the tour. We started at headworks and grit basin where all flow enters the plant via gravity from the collection system, then followed the treatment train all the way to the final outfall. See the Photo Log for a summary of physical inspection observations. We concluded the physical inspection at 12:30 PM and returned to the main office for the closeout conference. SECTION III - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION IV - AREAS OF CONCERN Areas of Concern may not be in sequential order. The presentation of areas of concern does not constitute a formal compliance determination or violation. 4 of 22 KENDALLVILLE WWTP Inspection Date: 03/01/2023 Unit: Interview DM1-OB-001 Ongoing chronic effluent limit exceedances for CBOD, copper, E.coli, nitrogenammonia, phosphorus, and TSS. See summary of effluent limit exceedances from August 1, 2022 to December 31, 2023 (see Appendix 2 - Inspection Documents). Citations: Permit Part I.A DM1-OB-002 The City recently submitted a Draft Interim Compliance Plan required under EPA's AOC, dated January 9, 2023. Following the City's overview of the Draft Interim Compliance Plan, the City agreed to address some minor comments, including missing tables and figures, by March 6. Citations: AOC, paragraph 112(a)(i). Unit: Physical Inspection DM1-OB-004 The City reported a CSO discharge of 628,885 gallons on February 22, 2023, due to 15" of rainfall (see Bypass/Overflow Report in Appendix 2 - Inspection Documents). CSO Outfall #002 is located just upstream from Outfall 003, on the unnamed tributary that flows to Henderson Lake. Citations: Permit Attachment A. SECTION V - CLOSING CONFERENCE AND FOLLOW UP I began the inspection closing conference with facility personnel at 12:35 PM on 03/01/2023. During the closing conference, I discussed the preliminary observations and Areas of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. We also discussed follow-up on a recent citizen complaint about an alleged surface discharge that occurs during rain events on Pennsylvania Ave. The City agreed to follow-up on the issue and the IDEM representatives agreed to contact the citizen. I also reviewed the documents received from the City during the inspection, including: 1. Data Graphs (12/1/2022-2/28/2023) 2. Summary of American Rescue Plan-Fund Plan 3. Kraft Heinz Wastewater Presentation (received from Kraft Heinz representatives) Before concluding, I asked if anyone had any questions. With no other questions, I discussed EPA's inspection report timeframes, and we departed the facility at 12:49 PM, on March 1, 2023. Communication Log Type Email From Dustin Wuis To Date Dean Maraldo 3/2/2023 Description transmitting attachment Attachment(s) Electronic copy of data graphs 5 of 22 KENDALLVILLE WWTP Inspection Date: SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Inspection Documents APPENDIX 1. Photo Log Headworks - Grit Basin KVLL0198.JPG 03/01/2023 11:27 AM (ET) Dean Maraldo Physical Inspection/Headworks No CBI No PII Note influent pipe outlet. SCADA Display KVLL0199.JPG 03/01/2023 11:35 AM (ET) Dean Maraldo Physical Inspection/Control Room No CBI No PII SCADA system display in the Operations Building. 03/01/2023 6 of 22 KENDALLVILLE WWTP Inspection Date: Primary Clarifier KVLL0200.JPG 03/01/2023 11:49 AM (ET) Dean Maraldo Physical Inspection/Primary Clarification No CBI No PII Note the floating palm oil blobs on primary clarifier. System operates with three of six clarifiers under normal conditions. Aeration Tank #1 KVLL0201.JPG 03/01/2023 11:54 AM (ET) Dean Maraldo Physical Inspection/Aeration Tank #1 No CBI No PII Four aeration tanks in total and all operating. Aeration Tank #4 KVLL0202.JPG 03/01/2023 11:58 AM (ET) Dean Maraldo Physical Inspection/Aeration Tank #4 No CBI No PII Noted palm oil blobs on surface, but difficult to discern in image. 7 of 22 03/01/2023 KENDALLVILLE WWTP Inspection Date: Secondary Clarifier KVLL0203.JPG 03/01/2023 12:11 PM (ET) Dean Maraldo Physical Inspection/Secondary Clarification No CBI No PII Note skimmer capturing palm oil blobs on the surface of the secondary clarifier. Post-aeration Basin KVLL0204.JPG 03/01/2023 12:16 PM (ET) Dean Maraldo Physical Inspection/Disinfection & post-aeration No CBI No PII The UV system was out of service until recreation season begins April 1. Noted improvement in duckweed and growth since August 2022 inspection. Final Outfall #003 KVLL0205.JPG 03/01/2023 12:24 PM (ET) Dean Maraldo Physical Inspection/Final Outfall No CBI No PII Outfall #003 discharges to an unnamed tributary just upstream of Henderson Lake. Discharge appeared clear. 8 of 22 03/01/2023 KENDALLVILLE WWTP Inspection Date: CSO Outfall #002 KVLL0206.JPG 03/01/2023 12:25 PM (ET) Dean Maraldo Physical Inspection/CSO Outfall No CBI No PII CSO Outfall #002 is located just upstream from Outfall 003, on the unnamed tributary that flows to Henderson Lake. The CSO discharged 628,885 gallons on February 22, 2023, due to 15" of rainfall (see Bypass/Overflow Report in Appendix 2 - Inspection Documents) 03/01/2023 APPENDIX 2: INSPECTION DOCUMENTS Document Received Name Data Graphs (12/1/2022-2/28/2023) Summary of American Rescue Plan-Fund Plan Kraft Heinz Wastewater Presentation (received from Kraft Heinz representatives) CSO Notification Report Date Received 03/03/2023 03/01/2023 03/01/2023 Pages 6 1 4 Attached to report below? Yes Yes Yes 02/24/2023 1 Yes Reference Document Name Summary of effluent limit exceedances (August 1, 2022 to December 31, 2023) Attached to report Page(s) below? 1 Yes 9 of 22 Friday Tuesday Red Line = 2.9mg/L Daily Max Limit Green Dash = Mean Wednesday Wednesday Tuesday Wednesday Tuesday Kendallville WWTP Inspection Date: 3/1/2023 Appendix 2, page 10 of 22 TSS Limit = 18mg/L Weekly 12mg/L Monthly Phos Limit = 1.0mg/L Kendallville WWTP Inspection Date: 3/1/2023 Appendix 2, page 11 of 22 Red Line = Curve Trend Green Dash = Mean Kendallville WWTP Inspection Date: 3/1/2023 Appendix 2, page 12 of 22 Green Line = Curve Trend Red Line = Plant Design Raw 10,796lbs Purple Dash = Mean Kendallville WWTP Inspection Date: 3/1/2023 Appendix 2, page 13 of 22 Kendallville WWTP Inspection Date: 3/1/2023 Appendix 2, page 14 of 22 Kendallville WWTP Inspection Date: 3/1/2023 Appendix 2, page 15 of 22 Kendallville WWTP Inspection Date: 3/1/2023 Appendix 2, page 16 of 22 Kendallville WWTP Inspection Date: 3/1/2023 Appendix 2, page 17 of 22 Kendallville WWTP Inspection Date: 3/1/2023 Appendix 2, page 18 of 22 Kendallville WWTP Inspection Date: 3/1/2023 Appendix 2, page 19 of 22 Kendallville WWTP Inspection Date: 3/1/2023 Appendix 2, page 20 of 22 Kendallville WWTP Inspection Date: 3/1/2023 Appendix 2, page 21 of 22 Effluent Limit Exceedances Report IN0020656: KENDALLVILLE WWTP, KENDALLVILLE, IN 46755 Monitoring Period Date Range: 08/01/2022 to 12/31/2022 Exceedance Details Monitoring Period Date 8/31/2022 8/31/2022 8/31/2022 9/30/2022 9/30/2022 9/30/2022 9/30/2022 9/30/2022 9/30/2022 10/31/2022 10/31/2022 10/31/2022 10/31/2022 10/31/2022 10/31/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 12/31/2022 12/31/2022 12/31/2022 12/31/2022 12/31/2022 12/31/2022 12/31/2022 Parameter Description Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) E. coli, colony forming units (CFU) Oxygen, dissolved (DO) Solids, total suspended Solids, total suspended Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) E. coli, colony forming units (CFU) Oxygen, dissolved (DO) Solids, total suspended Solids, total suspended Solids, total suspended Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Oxygen, dissolved (DO) Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Phosphorus, total (as P) Copper, total recoverable Copper, total recoverable Copper, total recoverable Copper, total recoverable BOD, carbonaceous, 05 day, 20 C BOD, carbonaceous, 05 day, 20 C BOD, carbonaceous, 05 day, 20 C BOD, carbonaceous, 05 day, 20 C Phosphorus, total percent removal Solids, total suspended Solids, total suspended Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Copper, total recoverable Limit Type DAILY MX MO AVG DAILY MX DLYAVMIN MO AVG MX WK AV DAILY MX MO AVG DAILY MX DLYAVMIN MO AVG MX WK AV MO AVG DAILY MX MO AVG DLYAVMIN MX WK AV MX WK AV MO AVG MO AVG MO AVG DAILY MX MO AVG DAILY MX MO AVG DAILY MX MO AVG MO AVG DAILY MX MX WK AV MX WK AV MO AVG MO AVG MO AV MN MX WK AV MO AVG MO AVG MO AVG DAILY MX DAILY MX MO AVG DMR Value 8.68 1.9 533.5 5.68 14.9 26 13 1.86 960.6 5.45 420.27 36.4 112.4 7.58 1.54 1.42 4979.37 1179.4 2779.91 615.2 7.51 31.5 43.54 289.66 4.54 0.33 0.14 0.66 1.56 1331.70 299.4 394.10 87.2 10.06 28.8 21.8 36.54 7.73 93.20 20.7 0.032 dmr_valu e_qualifie DMR Value r Unit = mg/L = mg/L = CFU/100mL = mg/L = mg/L = mg/L = mg/L = mg/L = CFU/100mL = mg/L = kg/d = mg/L = mg/L = mg/L = mg/L = mg/L = kg/d = mg/L = kg/d = mg/L = mg/L = mg/L = kg/d = kg/d = mg/L = mg/L = mg/L = kg/d = kg/d = kg/d = mg/L = kg/d = mg/L = % = mg/L = mg/L = kg/d = mg/L = kg/d = mg/L = mg/L Limit Value 2.9 1.3 235 6 12 18 2.9 1.3 235 6 294.3311 18 12 2.9 1.3 6 441.2698 18 294.3311 12 1.3 2.9 31.88209 71.11111 1 0.047 0.023 0.231293 0.498866 367.8005 15 245.3515 10 70 18 12 31.88209 1.3 71.11111 2.9 0.023 Limit Value Qualifier <= <= <= >= <= <= <= <= <= >= <= <= <= <= <= >= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= >= <= <= <= <= <= <= <= % Exceedance 199 46 127 5 24 44 348 43 309 9 43 102 837 161 18 76 1028 6452 844 5027 478 986 37 307 354 604 496 186 212 262 1896 61 772 200 60 82 15 495 31 614 39 Kendallville WWTP Inspection Date: 3/1/2023 Appendix 2, page 22 of 22