Document LK8eoEZ52Nr2Okp3wd7g8gonQ

NPDES Compliance Inspection Report Darigold - Chehalis Facility Chehalis, Washington Permit #: WAR005575 Inspection Date: January 13, 2022 Prepared by: Raymond Andrews U.S. Environmental Protection Agency, Region 10 Enforcement & Compliance Assurance Division Water Enforcement & Field Branch Field, Data & Drinking Water Enforcement Section Signature/Date: RAYMOND ANDREWS Date: 2022.03.22 08:25:58 -07'00' Digitally signed by RAYMOND ANDREWS Supervisor Signature/Date: PETER CONTRERAS Date: 2022.03.22 09:32:44 -07'00' Digitally signed by PETER CONTRERAS Darigold - Chehalis NPDES #WAR005575 Contents I. Facility Information ............................................................................................................ 1 II. Inspection Information........................................................................................................ 2 III. Permit Information.............................................................................................................. 2 IV. Background ..................................................................................................................... 2 V. Inspection Chronology........................................................................................................ 2 VI. Opening Conference ........................................................................................................... 3 VII. Laboratory Inspection ......................................................................................................... 4 VIII. File Review ..................................................................................................................... 4 IX. Site Inspection..................................................................................................................... 4 X. Areas of Concern ................................................................................................................ 5 XI. Closing Conference............................................................................................................. 7 ATTACHMENT A - Aerial Images and Site Diagram ATTACHMENT B - Inspection Photographs and Photograph Log Darigold - Chehalis NPDES #WAR005575 (All details in this report were obtained through conversations with Mr. Brent Daniels, Plant Manager, Ms. Erin Avery, Senior Environmental Health and Safety Manager, and Mr. Bruce Reynolds, Environmental Health and Safety Manager, review of facility documents or observations made during the inspection.) I. Facility Information Facility Name: Darigold - Chehalis Facility Owner/Operator: Darigold Inc. Physical Address: 67 SW Chehalis Avenue Chehalis, Washington 98532 Lewis County Lat/Long: 46.65952, -122.97040 Mailing Address: 67 SW Chehalis Avenue Chehalis, Washington 98532 NAICS Code: 311514 (Dry, Condensed, and Evaporated Dairy Product Mfg) SIC Code: 2023 (Dry, condensed, & evaporated dairy product mfg) Facility Contacts: Brent Daniels Plant Manager Office Phone: 360-748-8826 x15 Email: brent.daniels@darigold.com Erin Avery Senior Environmental Health and Safety Manager Office Phone: 425-677-0798 Email: erin.avery@darigold.com Bruce Reynolds Environmental Health and Safety Manager Office Phone: 360-748-8826 x13 Email: bruce.reynolds@darigold.com Permit Number: WAR005575 Receiving Water: City Muncipal Stormwater System Dillenbaugh Creek Chehalis River Page 1 of 8 II. Inspection Information Inspection Date: January 13, 2022 Darigold - Chehalis NPDES #WAR005575 Inspectors: Raymond Andrews, Inspector EPA Region 10, ECAD /FDDWES Phone: 206-553-4252 CJ Langlois, Observer EPA Region 10, ECAD /FDDWES Phone: 206-553-2739 Arrival Time: 9:30 AM Departure Time: 3:40 PM Weather: Overcast, 45F Purpose: To determine facility compliance with the Washington Industrial Stormwater General Permit (ISGP) and the Clean Water Act. III. Permit Information Darigold - Chehalis is permitted under Washington Industrial Stormwater General Permit (ISGP) ("Permit") for Stormwater Discharges Associated with Industrial Activities. The facility's current permit, NPDES permit # WAR005575, became effective on January 1, 2020, and will expire on December 31, 2024. Table 3 of the ISGP indicates the facility has additional industry specific sampling requirements as a business that operates under the "Food and Kindred Products" industry. IV. Background Darigold - Chehalis ("Facility") located at 67 SW Chehalis Avenue Chehalis, Washington is owned and operated by Darigold Inc. In August 2019, the Washington Department of Ecology (WDOE) inspected the facility for compliance with its ISGP. On March 11, 2021, the facility was inspected by WDOE for compliance with its individual wastewater permit, NPDES Permit #WA0037478. The facility has not had any formal enforcement actions due to non-compliance with its permit. V. Inspection Chronology This was an announced inspection. On January 10, 2022, I emailed Mr. Brent Daniels, Plant Manager, and told him I would be conducting an industrial stormwater compliance of the Darigold - Chehalis facility in Chehalis, Washington on January 13th. Page 2 of 8 Darigold - Chehalis NPDES #WAR005575 I conducted an opening conference, which included an interview of Mr. Daniels, Ms. Erin Avery, Senior Environmental Health and Safety Manager, and Mr. Bruce Reynolds, Environmental Health and Safety Manager, followed by a records review, a site inspection, and a closing conference. VI. Opening Conference I arrived at the facility at 9:30 am. CJ Langlois accompanied me as an observer as part of his on-thejob (OJT) training to qualify for inspector credentialing. Once we arrived at the facility, we followed Darigold's COVID protocol which included electronically signing-in, filling out a COVID questionnaire, and having our temperature taken. Once cleared, we proceeded to the office. I presented my credentials to Mr. Daniels, Ms. Avery, and Mr. Reynolds; henceforth, collectively called "the Representatives." I explained the purpose of the inspection was to determine compliance with the Washington Industrial Stormwater General Permit (ISGP) and the Clean Water Act (CWA). The facility has been in operation at its current location since approximately 1974, and has approximately 40 full time employees. It operates 24-hours per day, 365-days per year with various shifts to meet production needs during different times of the year. The site is approximately 8.3-acres and is generally flat with enough grading to allow industrial stormwater to flow to one of the eight stormwater catch basins. The facility map shows a ninth catch basin but it collects water and sends it to the facility's wastewater treatment plant which is not part of the industrial stormwater management program so is not included in the Stormwater Pollution Prevention Plan (SWPPP.) According to usclimatedata.com, Chehalis, Washington, receives approximate average annual precipitation of 47.04 inches. November is the wettest month with approximate average precipitation of 7.88 inches, while July is the driest month with approximate average precipitation of 0.61 inches. As stated above, the facility has eight Catch Basins (CB) labeled CB-1 through CB-8. The facility only samples two of the basins, CB-5 and CB-7. Per the Representatives, only those two basins are sampled because CB 1 and CB 2 are "substantially identical" to CB-5 and CB-4, CB-6, and CB-8 are "substantially identical" to CB-7. CB-3 is not sampled because it is plugged. The facility's primary operation is the processing of fluid milk. The facility receives liquid dairy milk. The milk is pasteurized and processed into powdered dairy goods such as dried whey, nonfat milk, and buttermilk powders. All process activities are conducted indoors. No raw material or finished products are stored outside. No vehicle washing is conducted on-site. The facility has a contracted street sweeper that cleans all paved areas every two weeks. Page 3 of 8 VII. VIII. IX. Darigold - Chehalis NPDES #WAR005575 Laboratory Inspection The facility has statewide benchmark monitoring requirements applicable to all facilities, as well as industry-specific benchmark monitoring requirements. The statewide benchmarks are pH, turbidity, oil sheen, total copper (Cu), and total zinc (Zn). The oil sheen parameter is observational only. The industry-specific benchmarks for the facility's industry, Food and Kindred Products, are biological oxygen demand (BOD5), nitrate + nitrite nitrogen (N), and total phosphorus (P). Stormwater samples are collected by either Ms. Avery or Mr. Mike Donahue, Wastewater Supervisor. All samples are grab samples. The facility conducts pH sampling, using a pH meter and probe, and the oil sheen observation. All other parameters are analyzed by: ALS Environmental - Kelso Laboratory 1317 South 13th Avenue Kelso, Washington 98626 (360) 577-7222 File Review The Washington ISGP requires documentation be retained for a minimum of five years. I reviewed the following records and documents: Notice of Intent (NOI) - dated June 11, 2019 Permit Reissuance Letter - December 30, 2019 Stormwater Pollution Prevention Plan (SWPPP) - revised August 25, 2021 Monthly Facility Inspection Reports - January 2017 through December 2021 Discharge Monitoring Reports (DMRs) - 1Q 2017 through 4Q 2021 Chain of Custody Documents (CoCs) - 1Q 2017 through 4Q 2021 Annual Employee Training Records - January 2017 through December 2021 Level 1, 2, and 3 Corrective Action Forms - 1Q 2017 - 4Q 2021 Site Inspection Attachment A contains an aerial map, provided by Google Maps, and a site diagram map provided by the facility. Attachment B contains photos used in this inspection report and a complete photo log. Following the records review, the Representatives took me on a tour of the site. I told them since the scope of the inspection was the facility's industrial stormwater program, I would be focusing on those components during the Site Tour. As stated in Section VI of this report, the facility only monitors Catch Basins (CB) 5 and 7 because they are substantially identical to Catch Basins 1, 2, 4, 6, and 8. Catch Basin 3 has been plugged and directs stormwater drainage to the City of Chehalis' main storm sewer line that runs alongside Southwest Chehalis Avenue. Page 4 of 8 Darigold - Chehalis NPDES #WAR005575 We started the site tour by exiting the offices on the east side of the facility adjacent to Southwest Chehalis Avenue. We walked around the building to the south to CB-1. CB-1 is near the truck loading/unloading dock (Photo 1). Water that enters CB-1 flows to a sump pump which pumps the stormwater to the City's storm drain located in the street. We headed north back to the office to look at CB-5, which was past the office on Southwest Chehalis Avenue. CB-5 (Photo 2) is one of the facility's two sampling points. The facility collects a grab sample from the pipe that extends into the vault (Photo 3). The vault outlet (Photo 4) drains into the City's stormwater conveyance system. Stormwater collected by CB-5 comes from a strip drain inside the perimeter fence a short distance further to the west of the vault, which collects stormater from the facility's parking lot and drainage from building rooftops. Prior to water from the rooftops entering CB-5, it is collected and filtered by a passive filtration system (Photo 5). We continued heading north to the northern edge of the facility site to CB-7 (Photo 6). CB-7 lies outside the site's perimeter fence and is the second point that the facility samples. CB-7 collects stormwater from the north parking lot and the rooftops on the northern side of the site. Catch Basins 4 (Photo 7), 6 (Photo 8), and 8 (Photo 9) are all in relatively close proximity. Based on the locations of CB-4, CB-6 & CB-8, and the industrial activity at those locations, it is likely their discharges are substantially identical to CB-7 as claimed by the facility. We walked to the west side of facility to CB-3 (Photos 10 - 12). The Representatives said CB-3 is not sampled because it is plugged and stormwater drainage is directed to flow to the main stormwater conveyance that runs alongside Southwest Chehalis Avenue into the City's municipal storm sewer system which discharges into Dillenbaugh Creek, a tributary of the Chehalis River. We ended the industrial stormwater site inspection at CB-2 (Photo 13), which lies southwest of CB3 and is the final Catch Basin associated with industrial stormwater management. Based on the location of CB-2 and the industrial activity nearby, it is likely that its discharge is substantially identical to CB-5 as claimed by the facility. X. Areas of Concern At the time of inspection, I found the following areas of concern: A. SWPPP Sampling Plan S3.B.5 of the ISGP states the SWPPP shall include a Sampling Plan and the plan shall "b. Include documentation of why applicable parameters are not sampled at each discharge Point...The required documentation includes... i. Location of which discharge points the Permittee does not sample applicable parameters because the pollutant concentrations are substantially identical to a discharge point being sampled. vi. Reasons why the Permittee expects the discharge points to discharge substantially identical effluents." Page 5 of 8 Darigold - Chehalis NPDES #WAR005575 At the time of the inspection, I reviewed the facility's SWPPP. The SWPPP contained a Sampling Plan; however, the Sampling Plan did not include the discharge points not sampled because they were substantially identical to other points. The Sampling Plan did not contain additional documentation that supported the facility's claim the discharge points had substantially identical effluents. Due to the location of CB-1 at the truck loading/unloading dock, I'm concerned its effluent is not substantially identical to the discharge of CB-5 due to the potential for additional zinc and other pollutants to be deposited by truck tires. B. SWPPP Map S3.B.1 of the ISGP states " the SWPPP shall contain a site map...the site map shall identify...b. The size of the property in acres...f. Locations of all receiving water (including wetlands and drainage ditches) in the immediate vicinity of the facility...m. Locations of stormwater inlets and outfalls with a unique identification number for each sampling point and discharge point, indicating any that are identified as substantially identical, and identify, by name, any other party other than the Permittee that owns any stormwater drainage or discharge structures..." At the time of the inspection, I reviewed the facility site map. The map in the SWPPP is largely illegible. The map was missing the following items: 1. Size of the property in acres. 2. Locations of all receiving water in the immediate vicinity of the facility. 3. The locations of sampling points with unique identification numbers. 4. Discharge points that are identified as substantially identical. C. Laboratory Analysis S5, Tables 2 and 3 of the ISGP indicates the analytical methods authorized for each benchmark parameter. The ISGP indicates the analytical method of SM 5210B for BOD5, SM4500 NO3E/F/H for the parameter nitrate + nitrate nitrogen (N), and EPA 356.1 for phosphorus (P). S5, Footnote a. of Table 2 and 3 of the ISGP states, "The Permittee shall ensure laboratory results comply with the quantitation level (QL) specified in the table. However, if an alternate method from 40 CFR Part 136 is sufficient to produce measurable results in the sample, the Permittee may use that method for analysis. If the Permittee uses an alternative method, it must report the test method and QL on the discharge monitoring report. The permittee must also upload the QA/QC documentation from the lab on the QL development." At the time of inspection, I reviewed the facility SWPPP and laboratory documents and found the following issues: 1. The SWPPP indicates the lab may use analysis method EPA 405.1 or SM 5210B for BOD5. The ISGP does not authorize the use of analysis method EPA 405.1 for this parameter. 2. The SWPPP indicates the lab is to use analysis method EPA 365.1 for total phosphorus, which is the method indicated in the ISGP. However, lab reports show the lab was using analysis method EPA 365.3. I did not see QA/QC documentation from the lab on QL development. Page 6 of 8 Darigold - Chehalis NPDES #WAR005575 D. Monthly Inspection Reports S7.C.1 of the ISGP states, in part, "The Permittee shall ensure each inspection report documents the observations, verifications and assessments required...includes...a. Time and date of inspection...b. Locations inspected...e. Name, title, and signature of person conducting inspection..." Upon review of the facility's routine monthly inspection reports, I found the inspection reports did not include the time of inspection, the locations inspected, or the title of the person conducting the inspection. XI. Closing Conference On January 13, 2022, I held a closing conference with Mr. Daniels, Ms. Avery, and Mr. Reynolds. We discussed my observations, and I gave a brief overview of the post-inspection process. I thanked them for their time and assistance. Page 7 of 8 ATTACHMENT A Aerial Image of Site Provided by Google N Site Diagram Provided by Facility ATTACHMENT B Inspection Photographs and Photograph Log (Photographs taken by Ray Andrews on January 13, 2022, with a Panasonic DMC-FH25 camera) Photo 1 / P1010151 - Catch Basin 1 Photo 2 / P1010154 - Catch Basin 5 Vault, exterior Sampling Point Photo 3 / P1010153 - Catch Basin 5 Sample Point in Vault Outlet to City Stormwater Conveyance Photo 4 / P1010152 - Catch basin 5 Vault, interior Photo 5 / P1010155 - Filtration System Photo 6 / P1010157 - Catch Basin 7, sampling point Photo 7 / P1010160 - Catch Basin 4, facing north Photo 8 / P1010158 - Catch Basin 6, facing west Photo 9 / P1010159 - Catch Basin 8, facing west Photo 10 / P1010161 - Catch Basin 3, facing north Photo 11 / P1010163 - Catch Basin 3, facing west, close-up Photo 12 / P1010164 - Catch Basin 3, facing west, extended view Photo 13 / P1010165 - Catch Basin 2, facing north Complete list of photographs taken during the inspection: P1010147 - Letter to WDOE P1010148 - 2020 Annual Report, photo 1 P1010149 - 2020 Annual Report, photo 2 P1010150 - 2020 Annual Report, photo 3 P1010151 - Catch Basin 1 P1010152 - Catch basin 5 Vault, interior P1010153 - Catch Basin 5 Sample Point in Vault P1010154 - Catch Basin 5 Vault, exterior P1010155 - Filtration System P1010156 - Strip Drain P1010157 - Catch Basin 7, sampling point P1010158 - Catch Basin 6, facing west P1010159 - Catch Basin 8, facing west P1010160 - Catch Basin 4, facing north P1010161 - Catch Basin 3, facing north P1010162 - Catch Basin 3, facing East P1010163 - Catch Basin 3, facing west, close-up P1010164 - Catch Basin 3, facing west, extended view P1010165 - Catch Basin 2, facing north P1010166 - Catch Basin 9, photo 1 P1010167 - Catch Basin 9, photo 2 P1010168 - pH Calibration Log P1010169 - pH Probe & Monitor P1010170 - pH Buffer Solution