Document KG17O5eNkJp2ZjegEB9pO90q2
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5 77 WEST JACKSON BOULEVARD
CHICAGO, IL 60604-3590
REPLY TO ATTENTION OF ECW-15J
VIA ELECTRONIC MAIL
Paul Nicholson Village President 102 Passive Sun Drive Soldiers Grove, WI 54655 email: nicholson1949@gmail.com
Re: NPDES Inspection Report - Village of Soldiers Grove WWTF (NPDES #WI0022241)
Dear Mr. Nicholson:
On March 23, 2023, the U.S. Environmental Protection Agency conducted an NPDES Inspection at the Village of Soldiers Grove Wastewater Treatment Facility, in Soldiers Grove, Wisconsin. Pages 8-10 of the enclosed report summarize the preliminary areas of concern identified during the inspection.
If you have questions or concerns regarding the report or believe any part of the report is not accurate, please contact Dean Maraldo of my staff at (312) 353-2098 or maraldo.dean@epa.gov.
Sincerely,
MOLLY SMITH
Digitally signed by MOLLY SMITH Date: 2023.03.28 16:28:21 -05'00'
Molly Smith Supervisor, Section 1, Water Enforcement and Compliance Assurance Branch
Enclosure
cc: Brian Copus, Soldiers Grove [sgrove@mwt.net] Kaitlynn Ott, Soldiers Grove [sgrove@mwt.net] Amy Garbe, WDNR [Amy.Garbe@wisconsin.gov] Julia A. Stephenson, WDNR [Julia.Stephenson@wisconsin.gov]
EPA Region 5 Enforcement and Compliance Assurance Division INSPECTION REPORT
Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection
03/23/2023 09:00 AM (CT)
Announced: Yes
03/23/2023 01:45 PM (CT)
Access: Granted
Sunny, cool
Water
Clean Water Act, NPDES, WWTP
CEI - Compliance Evaluation Inspection
Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County/Borough/Parish Facility GPS Coordinates Mailing Address (If different) City, State, Zip Code
Village of Soldiers Grove Soldiers Grove Wastewater Treatment Facility 800 Cth C, Soldiers Grove, Wisconsin Soldiers Grove, WI 54655 Crawford 43.396306, -90.785806 P.O. Box 121
Soldiers Grove WI 54655-0121
FRS ID
WI0022241
Permit Number(s) (If Applicable) WI0022241-10
SIC and/or NAICS
4952
EPA Representatives Participating in Inspection:
Title
Name
Inspector
Valerie Dooling
Organization EPA Region 5
Lead Inspector: Dean Maraldo
Supervisor Review: Molly Smith
[Signature] EPA Region 5
DINO MARALDO
Digitally signed by DINO MARALDO Date: 2023.03.28 07:59:23 -05'00'
maraldo.dean@epa.gov
(312) 353-2098
[Signature] EPA Region 5
MOLLY SMITH
Digitally signed by MOLLY SMITH Date: 2023.03.28 16:28:42 -05'00'
smith.molly@epa.gov
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SECTION I - INTRODUCTION
Site Entry and Inspection Objectives
I, EPA Region 5 Lead Inspector Dean Maraldo, arrived at the Village of Soldiers Grove Clerks' Office at 102 Passive Sun Dr., in Soldiers Grove, Wisconsin, at 09:00 AM (CT) on March 23, 2023, for an announced inspection of the Soldiers Grove Wastewater Treatment Facility ("WWTF" or "Facility"), located at 800 Cth C, Soldiers Grove, Wisconsin. I was joined by EPA inspector Valerie Dooling. We presented EPA inspector credentials to Kaitlyn Ott and informed the Village representatives that this was an EPA Region 5 inspection to determine compliance as authorized by Clean Water Act (CWA) Section 308 and implementing regulations. Wisconsin Department of Natural Resources ("WDNR") representatives Amy Garbe and Julia Stephenson also joined us for the inspection. This report is based on information supplied by Soldiers Grove Wastewater Treatment Facility representatives, direct observations made by the EPA Region 5 inspectors, records and reports maintained by the permittee and other information including: photographs taken by EPA Region 5 inspectors, physical evidence collected by the EPA Region 5 inspectors, verbal or written statements made by Soldiers Grove Wastewater Treatment Facility representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA Region 5 inspectors by Soldiers Grove Wastewater Treatment 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 EPA, State, and/or public records may be included in this report.
We began the opening conference with introductions and a review of the purpose of the inspection. The complete list of attendees for the opening (and closing) conferences is included in the table below.
Attendees
Organization
EPA Region 5 EPA Region 5 WDNR Village of Soldiers Grove Village of Soldiers Grove Village of Soldiers Grove WDNR
Attendee Name
Dean Maraldo Valerie Dooling Julia A. Stephenson Paul Nicholson
Brian Copus
Kaitlynn Ott
Amy Garbe
Title
Lead Inspector Inspector Engineer Village President
Operator
Clerk/Treasurer
Engineer
Present in Opening Conf. Yes
Yes Yes Yes
Present in Closing Conf. Yes
Yes Yes Yes
Yes
Yes
Yes
Yes
Yes
Yes
Facility/Site Description
I went over the facility description provided in the permit (excerpt below) and the Village representatives confirmed that information was accurate.
The annual average design flow is 0.114 million gallons per day (MGD) and the actual annual average in 2018 was 0.047 MGD. The treatment facility is an extended aeration package plant. The WWTF has a bar screen, a secondary clarifier and activated sludge. The effluent is disinfected seasonally via chlorination/dechlorination prior to discharge to the Kickapoo River.
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Waste activated sludge was previously discharged to sludge drying beds and then land applied as cake sludge on WDNR-approved sites. However, it was determined that the sludge drying beds were not underlain by an impervious surface and did not meet current administrative code. Use of the sludge drying beds has been discontinued and during the new permit term aerobically digested liquid class B sludge will be hauled off site to another permitted facility for storage and/or treatment prior to being landspread on WDNR-approved agricultural fields.
Brian Copus ("Operator") added that they haul sludge twice a year and land apply on Village owned land.
Facility/Site Background Information
Next, I asked some background questions. Unless noted otherwise, the Operator provided the responses in the table below.
Background Question Any Confidential Business Information concerns? Have any bypasses or overflows happened at the plant or in the collection system in the last year? Are there any plans for renovation or additional equipment to allow for increased wastewater flow? Is there currently any portion of the treatment train that is nonoperational? Do you accept waste from septage haulers? Do you use contract out for laboratory analyses? Are the Discharge Monitoring Reports (DMRs) submitted on time? Responsible official? WWTP Average Daily Flow? WWTP Approx. # of residents served? Contributing (or shared) Jurisdictions? Operation schedule?
Village Response No No
Yes (Paul Nicholson responded)
No
No Yes, Davy Laboratories in LaCrosse Yes (due 21st of every month) Operator and Kaitlynn Ott 40,000-50,000 gallons per day 257 (Kaitlynn Ott responded) No 6:30-3pm, M-F, plus on-call weekends; (Paul Nicholson responded)
Inspection Focus Areas and Locations
Inspection Area Interview
Operations and Maintenance Effluent Limit Exceedance Review Permit Compliance Schedule Review Flow Monitoring Self Monitoring Sanitary Sewer Overflows ("SSOs") Pretreatment Physical Inspection
Location Village of Soldiers Grove Clerks' Office
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Manhole receiving wastewater flow from Solar Meats LLC
Soldiers Grove Wastewater Treatment Facility
Sanitary sewer manhole north of American Legion 800 Cth C, Soldiers Grove, Wisconsin.
SECTION II - OBSERVATIONS
Location: Interview at Village Clerks' office and manhole north of the American Legion /Operations and Maintenance
Observation #: DM1-OB-001
Date: 03/23/2023
I began by asking how the Facility was working, and if all treatment units were operable? The Operator said the "clarifier still has grease on top, and its been that way the whole year." No FOG (fats, oils, and grease) removal other than bar screen. No issue prior to last year. He mentioned problems with Solar Meats LLC, an industrial user ("IU"), and that Solar Meats LLC switched to two kill days per week last July. He added that another IU Driftless Brewing Company - worked with the Village to capture yeast in 2021. Paul Nicholson added that the bulk of the issues at the WWTF are due to Solar Meats LLC.
The Operator mentioned collecting wastewater samples from a sanitary sewer manhole just downstream of Solar Meats LLC. Some samples are red, indicating blood from Solar Meats LLC animal processing. He added that Solar Meats LLC tends to process meat in the morning. I asked if we could observe the manhole now and collect a sample for observation. The group drove a short distance to the manhole north of the American Legion and the Operator collected a sample of the wastewater. The wastewater was red in color (see photos SOLD0209.JPG and SOLD0211.JPG capturing wastewater sample, and photo SOLD0210 capturing the manhole in the Photo Log in Appendix 1).
We returned to the Village Clerks' office to continue the interview portion of the inspection.
I asked if the Village has an asset management program, like records of repairs, lists of extra parts, or written plans for operations and maintenance ("O&M"). The Operator said they don't record repairs or keep a list of extra parts and motors. Paul Nicholson added that they do not have written monthly plans for O&M, and they do not conduct scheduled routine and preventive maintenance pursuant to a written schedule.
The Operator is certified and properly graded for operation of the Facility. Operations staff Paul Kinserdahl has general wastewater and collection systems certification.
I asked about sludge management. The Operator said he keeps the air side 350-450 on 30-minute settling test weekly and tries to keep 2-3 feet of sludge in the clarifier (15' deep). They also conduct daily pH and weekly dissolved oxygen process monitoring.
I asked if the Facility has an alarm system for all essential equipment. The Operator confirmed they have no alarm system, but plan to upgrade SCADA by 2025 (referenced "2025 Plan" to upgrade the Facility). The lift stations have telephone alerts. I asked for a copy of the 2025 Plan [Kaitlynn Ott provided the 2025 Plan, also known as the Wastewater Facility Plan, dated December 6, 2022, via email during the inspection on March 23, 2023; see Appendix 2 - Inspection Documents]. According to Paul Nicholson, the Facility does not maintain written procedures for responding to emergencies such as power failures, floods, fires, and other natural disasters.
I asked if the Facility maintains a logbook which documents all plant activities on a daily basis. The Operator said they only maintain a logbook for pH measurements.
I followed up with a question about standby power for treatment units. The Operator said they have one backup generator on a trailer for lift stations and the Facility, and the water plant. They exercise the generator
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every Monday, and under load every 3-4 weeks.
I brought up the annual Compliance Maintenance Annual Report ("CMAR") requirement in the Permit (Part 5.1.5). Amy Garbe confirmed the Village submitted the 2021 on time (by June 30, 2022). Kaitlynn Ott provided a copy of the 2021 CMAR (see Appendix 2 - Inspection Documents).
Finally, I asked how many sanitary sewer lift stations, manholes and miles of conveyance the Village maintains. The Operator said they maintain four lift stations and 74 manholes. He did not know the number of miles of conveyance in the sewer system. He said he would follow-up and provide the information [note the 2021 CMAR reported 4 miles of sanitary sewer].
Location: Interview at Village Clerks' office/Effluent Limit Exceedance Review
Observation #: DM1-OB-002
Date: 03/23/2023
We reviewed the list of permit effluent limit exceedances. (See ECHO Report Appendix 2 - Inspection Documents). The Biochemical Oxygen Demand ("BOD"), Total Suspended Solids ("TSS"), and Phosphorus permit effluent limit exceedances since 2021 were attributed by the Facility representatives to two industrial users, the Driftless Brewing Company and Solar Meats LLC. Paul Nicholson said the brewery was cooperative and is in control now after making adjustments including catching solids and controlling release of bad batches, adding that they "made adjustments immediately".
I asked if all noncompliance which may endanger health or the environment, including all violations of daily limits, were orally reported within 24 hours. The Operator said they do not consistently report violations. I asked if they provided written follow up to WDNR within 5 days. The Operator said they did not consistently submit 5-day reports to WDNR.
Paul Nicholson added that they developed the 2025 Plan and involved an engineering firm to help come up with solutions for ongoing issues at the Facility.
Location: Interview at Village Clerks' office/Permit Compliance Schedule Review
Observation #: DM1-OB-003
Date: 03/23/2023
We reviewed Phosphorus and E.coli permit compliance schedule requirements (pages 9-11 of Permit). WDNR representatives confirmed that the Village has complied with Phosphorus compliance schedule requirements to date, including submission of Annual Phosphorus Progress Report #3, due on January 31, 2023. They also confirmed the Village has complied with E.coli compliance schedule requirements to date, including submittal of the Operational Evaluation Report (due October, 31, 2021) and the Facility Plan (due date extended to December 2022). The WDNR representatives also confirmed that the deadline for submittal of Final Plans and Specifications was extended to September 30, 2023.
Location: Interview at Village Clerks' office/Flow Monitoring
Observation #: DM1-OB-004
Date: 03/23/2023
I asked the following questions regarding flow monitoring (the Operator provided responses unless indicated otherwise):
What type of influent meter is used? "None." Influent flow monitoring is not required.
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What type of effluent meter is used? "V-notch ultrasonic."
Are flow measuring device(s) calibrated routinely? "Effluent flowmeter calibrated (by an outside consultant) once a year." The operator expressed concerns about the reliability of consultant's last two calibration efforts. What is the average daily flow? "40,000-50,000 gallons per day." Any seasonal variation? "No."
Location: Interview at Village Clerks' office/Self Monitoring
Observation #: DM1-OB-005
Date: 03/23/2023
I asked where influent and effluent samples are collected. "Influent samples are collected after the bar screen; effluent composite and grab samples collected after the V-notch."
I asked the Operator to describe the chlorine monitoring process. The Operator said chlorine is measured after 5 minutes of sampling. They use the Hach Pocket Colorimeter and the Total Chlorine calibration packet for wastewater. They test the Hach Pocket Colorimeter for accuracy with a four-standard check using Hach standards, monthly.
The Operator described the bacteria sampling procedure. The Operator did not realize there was an eight-hour holding time for E.coli samples (maximum transport time to the laboratory in 6 hours, and samples should be processed within 2 hours of receipt at the laboratory), and confirmed that not all samples are analyzed within holding time (see example copy of laboratory report for sample collected at 08:00 on May 18, 2022 and analyzed at 13:18 on May 19, 2022, in Appendix 2 - Inspection Documents).
The Operator said the pH meter is calibrated daily, using 7/10 buffers. Calibrations are recorded on log sheets.
We discussed the sample chain of custody process and learned from the Operator that the Facility does not retain copies of completed chain of custody forms after dropping off samples at the laboratory.
I asked the Operator if composite samples are cooled to <4C to properly preserve them during the compositing period. He said the composite samplers are refrigerated to 2-3 C. Thermometers are in the sampler coolers. He added that all grab samples are placed in coolers with ice.
Last, I asked about the status of Nitrogen Series Monitoring (required pursuant to Permit Part 2.2.1.4). Monitoring for Total Kjeldahl Nitrogen (TKN), Nitrite + Nitrate Nitrogen, and Total Nitrogen shall be conducted once each year in rotating quarters in order to collect seasonal information about the discharge. The Operator said they are up to date with the Nitrogen monitoring series.
Location: Interview at Village Clerks' office/SSOs
Observation #: DM1-OB-006
Date: 03/23/2023
I started the discussion by asking if there have been any backups or overflows in the sanitary sewer collection system, including pump stations, manholes and piping over the last year? The Operator said no. I followed up with a question about basement backup complaints. He said they get no basement backup complaints.
I asked of the Village has a CMOM? The Operator said Yes, and Kaitlynn Ott provided a copy (see Appendix 2 - Inspection Documents). The CMOM was dated July 27, 2016 and has not been updated since. [Note, Permit
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Part 5.3.2, requires at least annually conduct a self-audit of activities conducted under the permittee's CMOM program to ensure CMOM components are being implemented as necessary to meet the general standards of NR 210.23(3), Wis. Adm. Code. The CMOM is not up to date with changes to the treatment system, including removal of drying beds from the treatment process.]
The Operator confirmed that no portion of the Facility's sewage collection system is combined with the storm water collection system.
Location: Interview at Village Clerks' office/Pretreatment
Observation #: DM1-OB-007
Date: 03/21/2023
I asked how many industrial users contribute wastewater to the Facility. Paul Nicholson provided an annotated December 7, 2022 letter to the WDNR identifying the 15 current IUs (see Appendix 2 - Inspection Documents). Two are designated by the Village as "majors" including Driftless Brewing Company and Solar Meats LLC.
I asked if any IUs are contributing to interference or pass through at the Facility. Paul Nicholson identified Solar Meats LLC as a contributor to interference and pass through and pointed to the bottle of red-colored wastewater the Operator collected earlier in the inspection as evidence (see photos SOLD0209.JPG and SOLD0211.JPG in the Photo Log in Appendix 1). The Operator said he thinks the Soldiers Grove WWTF would meet permit limits if Solar Meats LLC wasn't discharging wastewater to the sewer system.
Location: Physical Inspection of the Soldiers Grove WWTF
Observation #: DM1-OB-008
Date: 03/23/2023
The interview portion of the inspection concluded at 11:30 AM. We agreed to meet back at Village Clerks' office after lunch at 12:30 PM, then head to the Soldiers Grove WWTF to conduct the physical inspection of the Facility. Physical inspection observations are summarized in the Photo Log in Appendix 1.
Photo(s) 1. SOLD0212.JPG 2. SOLD0213.JPG 3. SOLD0214.JPG 4. SOLD0215.JPG 5. SOLD0216.JPG 6. SOLD0217.JPG 7. SOLD0218.JPG 8. SOLD0219.JPG 9. SOLD0220.JPG
10. SOLD0221.JPG 11. SOLD0222.JPG 12. SOLD0223.JPG
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SECTION III - AREAS OF CONCERN
Area(s) of Concern may not be in sequential order. The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation.
AOC Reference #: DM1-OB-001
Location: Interview/Operations and Maintenance
Regulation and/or Permit Requirement
5.3.2 CMOM Program. CMOM Section 3.1 requires a management information system for operations and maintenance. Permit Part CMOM Section 3.7 requires condition assessments for wastewater assets, and CMOM Section 4.6 requires Village to maintain spare parts and equipment inventory.
AOC: Facility does not have written monthly plans for O&M, and they do not conduct scheduled routine and preventive maintenance pursuant to a written schedule.
Regulation and/or Permit Requirement Permit Part 5.3.2 CMOM Program. CMOM Section 6.0 requires Overflow Emergency Response Plan. AOC: The Facility does not maintain written procedures for responding to emergencies such as power failures, floods, fires, and other natural disasters.
Regulation and/or Permit Requirement Permit Part 5.3.2 CMOM Program. CMOM Section 4.2 requires records of visual inspections of the wastewater treatment facility.
AOC: The Facility does not maintain a logbook which documents all plant activities on a daily basis, with the exception of a pH measurement log.
AOC Reference #: DM1-OB-002
Location: Interview/Effluent Limit Exceedance Review
Regulation and/or Permit Requirement Permit Part 2.2 Monitoring Requirements and Effluent Limitations.
AOC: Chronic permit effluent limit exceedances and recent significant noncompliance for BOD, TSS, and Phosphorus. (See ECHO Report Appendix 2 - Inspection Documents).
Regulation and/or Permit Requirement Permit Part 5.2.1 Noncompliance Reporting
AOC: Facility does not consistently report violations within 24-hours and follow-up with 5-day reports to WDNR.
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AOC Reference #: DM1-OB-004
Location: Interview/Flow Monitoring
Regulation and/or Permit Requirement Permit Part 5.2.2 Flow Meters - Flow meters shall be calibrated annually, as per NR 218.06, Wis. Adm. Code.
AOC: Effluent flowmeter is calibrated (by an outside consultant) once a year. The operator expressed concerns about the reliability of consultant's last two calibration efforts.
AOC Reference #: DM1-OB-005
Location: Interview/Self Monitoring
Regulation and/or Permit Requirement Permit Part 2.1. Sampling Point(s), requires representative effluent samples shall be collected from the effluent channel before the V notch weir for composite samples.
AOC: Effluent composite samples are collected after the V-notch weir (see photo SOLD0216.JPG in the Photo Log in Appendix 1).
Regulation and/or Permit Requirement Permit Part 5.1.2 Sampling and Testing Procedures. 40 CFR Part 136 Guidelines Establishing Test Procedures for the Analysis of Pollutants.
AOC: The Operator did not realize there was an eight-hour holding time for E.coli samples (maximum transport time to the laboratory in 6 hours, and samples should be processed within 2 hours of receipt at the laboratory), and confirmed that not all samples are analyzed within holding time (see example copy of laboratory report for sample collected at 08:00 on May 18, 2022 and analyzed at 13:18 on May 19, 2022, in Appendix 2 - Inspection Documents).
Regulation and/or Permit Requirement Permit Part 5.1.3. Recording of Results; and Permit Part 5.2.10., Proper Operation and Maintenance includes adequate laboratory and process controls, including appropriate quality assurance procedures. 40 CFR 122.41(j).
AOC: Facility does not retain copies of completed chain of custody forms after dropping off samples at the laboratory.
AOC Reference #: DM1-OB-006
Location: Interview/SSOs
Regulation and/or Permit Requirement Permit Part 5.3.2 CMOM Program requires permittee to at least annually conduct a self-audit of activities conducted under the permittee's CMOM program to ensure CMOM components are being implemented as necessary to meet the general standards of NR 210.23(3), Wis. Adm. Code.
AOC: The CMOM was dated July 27, 2016, and has not been updated since. The CMOM is not up to date with changes to the treatment system, including removal of drying beds from the treatment process.
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AOC Reference #: DM1-OB-007
Location: Interview/Pretreatment
Regulation and/or Permit Requirement Permit Part 5.2.5. Prohibited Wastes, including prohibition against wastewaters at a flow rate or pollutant loading which are excessive over relatively short time periods so as to cause a loss of treatment efficiency; and changes in discharge volume or composition from contributing industries which overload the treatment works or cause a loss of treatment efficiency. 40 C.F.R. 403.3(p), "Pass Through" means, in pertinent part, discharge of a pollutant which exits a POTW into waters of the United States in quantities or concentrations which, alone or in conjunction with other sources, is a cause of a violation of any requirement of a POTW's NPDES permit. 40 C.F.R. 403.3(k), "Interference" means, in pertinent part, a discharge of pollutants which alone or in conjunction with other sources, inhibits or disrupts the treatment process or operation of a POTW, and which therefore is a cause of a violation of any requirement of a POTW's NPDES permit.
AOC: Facility representatives identified Solar Meats LLC as a contributor to interference and pass through and pointed to the bottle of red-colored wastewater the Operator collected earlier in the inspection from the sewer manhole just downstream of Solar Meats LLC as evidence (see photos SOLD0209.JPG and SOLD0211.JPG in the Photo Log in Appendix 1). The Operator said he thinks the Soldiers Grove WWTF would meet permit limits if Solar Meats LLC wasn't discharging wastewater to the sewer system.
AOC Reference #: DM1-OB-008
Location: Physical Inspection of the Soldiers Grove WWTF
Regulation and/or Permit Requirement Permit Part 5.2.10 Proper Operation and Maintenance. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control which are installed or used by the permittee to achieve compliance with the conditions of this permit.
AOC: Observed heavy grease on surface of aeration basin, clarifier, and clarifier effluent trough (see photos SOLD0214.JPG, SOLD0218.JPG, and SOLD0219.JPG in the Photo Log in Appendix 1).
Regulation and/or Permit Requirement Permit Part 5.2.2. Flow Meters - Calibration.
AOC: Observed effluent flow sensor was located outside of the V-notch weir and over turbulent water (see photo SOLD0217.JPG in the Photo Log in Appendix 1). The effluent flow meter should be located at a specific point over the V-notch weir to allow for proper calibration under non-turbulent flow.
Regulation and/or Permit Requirement Permit Part 5.1.3. Recording of Results, requires permittee to maintain records which provide the following information for each effluent measurement or sample taken: the date, exact place, method and time of sampling or measurements; the individual who performed the sampling or measurements; the date the analysis was performed; the individual who performed the analysis; the analytical techniques or methods used and the results of the analysis.
AOC: Laboratory logsheets lack columns for sample collection and analysis time, and name of person sampling and analyzing sample.
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SECTION IV - CLOSING CONFERENCE AND FOLLOW UP
Closing Conference
I began the inspection closing conference with Facility personnel and WDNR representatives at 01:40 PM (CT) on March 23, 2023. I reviewed the observations and preliminary Areas of Concern identified during the inspection. Observations and Area(s) of Concern have not yet been evaluated for a formal compliance determination. I also reviewed the copies of documents received from the Facility representatives during the inspection and the follow up item listed below. I provided an estimated timeframe for preparing the inspection report and concluded the inspection and exited the Facility at 1:45 PM (CT) on March 23, 2023.
Follow Up The following item was requested by the inspector at the time of the inspection.
Location: Interview
Area: Operations and Maintenance
DM1-OB-001
Confirm miles of sewer conveyance
Communication Log
Kaitlynn Ott provided the 2025 Plan, also known as the Wastewater Facility Plan, dated December 6, 2022, via email during the inspection on March 23, 2023 [see Appendix 2 - Inspection Documents]. No additional information received by EPA Region 5 after exiting the Facility on March 23, 2023.
SECTION V - LIST OF APPENDICES 1. Photo Log 2. Document Log
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APPENDIX 1: PHOTO LOG
03/23/2023
Sample bucket with red colored wastewater collected from manhole downstream of Solar Meats LLC
SOLD0209.JPG
03/23/2023 09:44 AM
Photographer: Dean Maraldo
Sanitary Sewer Manhole North of American Legion No CBI
No PII
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View into manhole north of American Legion and SOLD0210.JPG downstream of Solar Meats LLC
03/23/2023 09:44 AM
Photographer: Dean Maraldo
Sanitary Sewer Manhole North of American Legion No CBI
No PII
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Clear glass sample bottle with red colored wastewater collected from manhole downstream of Solar Meats LLC
SOLD0211.JPG
03/23/2023 09:49 AM
Photographer: Dean Maraldo
Sanitary Sewer Manhole North of American Legion No CBI
No PII
View of wastewater treatment building and drying SOLD0212.JPG beds (no longer in use)
03/23/2023 12:50 PM
Photographer: Dean Maraldo
Physical Inspection
No CBI
No PII
View of wastewater treatment building and drying beds (no longer in use)
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Influent bar screen
SOLD0213.JPG
03/23/2023 12:51 PM
Photographer: Dean Maraldo
Physical Inspection
No CBI
No PII
Influent bar screen. No influent flow was observed at the time of the photo.
Aeration basin and clarifier
SOLD0214.JPG
03/23/2023 12:53 PM
Photographer: Dean Maraldo
Physical Inspection
No CBI
No PII
Aeration basin is the outer treatment ring, clarifier is the inner ring. Note heavy grease on surface of aeration basin.
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Composite samplers (ISCO)
SOLD0215.JPG
03/23/2023 12:55 PM
Photographer: Dean Maraldo
Physical Inspection
No CBI
No PII
Effluent (right) and influent (left) composite samplers. The operator stated that composite sampler tubing is replaced bi-monthly.
V-neck weir and disinfection tank
SOLD0216.JPG
03/23/2023 01:00 PM
Photographer: Dean Maraldo
Physical Inspection
No CBI
No PII
Note that the effluent sample tube is located after the V-notch weir. Permit requires collection of effluent composite samples before the weir. The V-notch weir is the metalwalled structure beneath the ladder in the photo.
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V-neck weir and disinfection tank
SOLD0217.JPG
03/23/2023 01:06 PM
Photographer: Dean Maraldo
Physical Inspection
No CBI
No PII
Note that the effluent flow sensor is located outside of the V-notch weir (under ladder in the photo) and over turbulent water. The effluent flow meter should be located at a specific point over the V-notch weir to allow for proper calibration under non-turbulent flow.
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Clarifier
SOLD0218.JPG
03/23/2023 01:08 PM
Photographer: Dean Maraldo
Physical Inspection
No CBI
No PII
Note the heavy grease and scum on the surface of the clarifier. The operated said the clarifier has "looked like this for the last year."
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Clarifier
SOLD0219.JPG
03/23/2023 01:09 PM
Photographer: Dean Maraldo
Physical Inspection
No CBI
No PII
Note heavy grease and scum in clarifier effluent trough. The operator said they try to clean troughs daily but difficult to keep up with it.
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Influent flow channel after bar screen and before aeration tank. 03/23/2023 01:16 PM Physical Inspection Observed influent flow after bar screen.
SOLD0220.JPG
Photographer: Dean Maraldo
No CBI
No PII
Disinfection Room
SOLD0221.JPG
03/23/2023 01:18 PM
Photographer: Dean Maraldo
Physical Inspection
No CBI
No PII
Note lack of secondary containment for chemical tanks.
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Lab Room
SOLD0222.JPG
03/23/2023 01:19 PM
Photographer: Dean Maraldo
Physical Inspection
No CBI
No PII
Process control logsheet (image blurry). Noted logsheet lacks columns for sample collection and analysis time, and name of person sampling and analyzing.
Lift Station #1
SOLD0223.JPG
03/23/2023 01:27 PM
Photographer: Dean Maraldo
Physical Inspection
No CBI
No PII
Lat lift station before the wastewater treatment plant. All flow is forced to the plant. Lift station installed in 2021 and is 35' deep. The operator believes the lift station has 24-hour storage capacity.
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Soldiers Grove Wastewater Treatment Facility Inspection Date: APPENDIX 2: DOCUMENT LOG
Document Name
Soldiers Grove Facility Plan
2021 Compliance Maintenance Annual Report
Correspondence from Soldiers Grove Consultant to WDNR (2/21/2023)
Correspondence from Soldiers Grove Consultant to Solar Meats LLC (3/26/2023)
Correspondence from Soldiers Grove Consultant to WDNR (5/24/2022)
Correspondence from Soldiers Grove Consultant to WDNR (12/7/2022)
Correspondence (annotated by Village President during inspection) from Soldiers Grove Consultant to WDNR (5/24/2022)
Correspondence from Solar Meats LLC to Soldiers Grove Consultant (2/8/2023)
Correspondence from Soldiers Grove Consultant to Solar Meats LLC (2/9/2023)
Laboratory Analysis Reports from Davy Laboratories for Soldiers Grove WWTF (for samples collected May 18, 2022; November 1, 2022; November 8, 2022; November 10, 2022; November 15, 2022; and February 7, 2023
Soldiers Grove CMOM dated July 27, 2016
U.S. EPA ECHO Facility Summary dated March 21, 2023 (provided by U.S. EPA)
Contains
CBI or
PII
Date Received
No
3/23/2023
No
3/23/2023
No
3/23/2023
Pages 94 27 2
No
3/23/2023 2
No
3/23/2023 4
No
3/23/2023 1
No
3/23/2023 5
No
3/23/2023 1
No
3/23/2023 3
No
3/23/2023 10
No
3/23/2023 12
No
3/21/2023 3
03/23/2023
Attached to Report below? No Yes Yes Yes Yes Yes Yes
Yes Yes Yes
Yes Yes
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