Document NNKoXnw5X10wO3EzbevXJL2Jb

EPA Region 5 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Media Statute(s)/Program(s) Type of Inspection 11/06/2024 09:30 AM (ET) Announced: Yes 11/06/2024 02:15 PM (ET) Access: Granted Water Clean Water Act, NPDES, WWTP Compliance Evaluation Inspection (CEI) Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code Facility GPS Coordinates Kendallville WWTP Kendallville WWTP 501 West Wayne Street Kendallville, IN 46755 41.446444, -85.273806 FRS ID Permit Number(s) (If Applicable) SIC and/or NAICS 110005973900 IN0020656 4952 Persons Participating in Inspection: Title Name Organization Lead Inspector WWTP Superintendent Pretreatment Supervisor IDEM Inspector IDEM Inspector Valerie Dooling Pat Howell Trevor Hampshire Lynn Stackhouse Aaron Deeter US EPA Water Enforcement and Compliance Assurance Branch (WECAB) Kendallville WWTP Superintendent Kendallville WWTP Pretreatment Supervisor Indiana Department of Environmental Management (IDEM) Indiana Department of Environmental Management (IDEM) Lead Inspector: Valerie Dooling Supervisor Review: Ryan Bahr Section 2 Supervisor, WECAB VALERIE DOOLING EPA Region 5 Digitally signed by VALERIE DOOLING Date: 2025.01.21 10:13:46 -06'00' Dooling.Valerie@epa.gov Digitally signed by Ryan Ryan Bahr Date: 2025.01.21 Bahr 15:36:16 -06'00' EPA Region 5 bahr.ryan@epa.gov (312) 886-7167 1 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 SECTION I - INTRODUCTION Site Entry and Inspection Objectives EPA and IDEM Inspectors Lynn Stackhouse and Aaron Deeter arrived together at the site for concurrent inspections. EPA Region 5 Lead Inspector, Valerie Dooling, arrived at the Kendallville Wastewater Treatment Plant (the "Site" or "Facility"), located at 501 West Wayne Street, Kendallville, IN 46755, at 09:30 AM (ET) on 11/06/2024 for an announced inspection. EPA Region 5 Lead Inspector presented credentials to WWTP Superintendent, Pat Howell, and informed him that this was an EPA Region 5 inspection to determine compliance as authorized by Clean Water Act (CWA) Section 308 and implementing regulations. This report is based on information supplied by Kendallville WWTP representatives, direct observations made by the EPA Region 5 inspector, records and reports maintained by the permittee and other information including: photographs taken by EPA Region 5 inspector, physical evidence collected by the EPA Region 5 inspector, measurements taken by EPA Region 5 inspector, verbal or written statements made by information supplied by Kendallville WWWTP 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 inspector(s) by Kendallville WWTP 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. Facility/Site Description After the opening conference, I asked about the facility and the Superintendent confirmed the following information about the facility: The permittee operates a Class III, 2.68 million gallons per day (MGD) single-stage nitrification activated sludge plant consisting of grit removal, bar screening, primary clarification, aeration, secondary clarification, phosphorus removal, ultraviolet light disinfection, and post aeration. Sludge is treated by anaerobic and aerobic digesters and de-watered via a screw press. Final sludge will be landfilled. The collection system is composed of approximately 35 miles of separate storm sewers, 53 miles of separate sanitary sewers, and 4 miles of combined sanitary and storm sewers. Facility/Site Information Have any bypasses or overflows happened at the plant or in the collection system in the last year? Industrial Users Outfalls: The superintendent confirmed that one sanitary sewer overflow occurred in the last year due to broken pressure release valve in a forcemain which released sewage into a field. Two SIUs: Kraft Heinz Company and Creative Liquid Coatings Two Outfalls: CSO Outfall 002 and Effluent Outfall 003 2 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 WWTP Design Capacity & Average Daily Flow Average design flow of 2.68 MGD and peak flow of 6.48 MGD SECTION II - OBSERVATIONS Location: Review AOC Interim Compliance Plan Observation #: VD1-OB-001 Date: 11/06/2024 The WWTP Superintendent told me that he would like to take primary clarification offline and has submitted a request to IDEM to do so. It would be a temporary troubleshooting experiment to determine if putting all the CBOD into to the aeration tanks will help during periods of IU shutdown when CBOD is limited. Included in this request are TSS and CBOD monthly averages from raw wastewater entering the primary clarifiers, the primary clarifier effluent and the calculated percent removal that occurs in the primary clarification tanks. During May and June 2024, a negative 5% and 9% removal of CBOD occurred and during February 2024, a negative 152% removal of TSS occurred in the primary tanks. I asked the Superintendent what he thinks caused the negative removal efficiency and he did not know. He thinks that the WWTP flows and BOD loading have decreased and suspects that it might be related to the negative removals in the primary clarifiers. I asked how he sampled for the data and he told me that he took samples of the raw primary influent and the primary effluent at the same time in the early morning. The sample collection did not account for a hydraulic residence time of the water in the tank (i.e. both primary influent and effluent were collected at the same time). During the inspection, while the primary clarifiers were online, the sludge from the primary clarifiers is directed to an anaerobic digester then screw press and the pressate is currently routed back into the primary clarifiers. Location: Review AOC Interim Compliance Plan Observation #: VD1-OB-002 Date: 11/06/2024 The WWTP Superintendent told me that the sluice slide gates have been installed and the SCADA panel for those gates is already installed but currently not operational. Before it is operational it still needs an electrician to complete the project. The sluice gates are designed to automatically lower slide gates which is based off of incoming flow but it is not based on incoming pollutant concentration or loading. The WWTP Superintendent expects the gates to be operational before December 2024. 3 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 Location: Review AOC Interim Compliance Plan Observation #: VD1-OB-003 Date: 11/06/2024 The WWTP Superintendent told me that the thermal bulking of the secondary clarifiers is completed and was finalized around July 2024 (Photos 1-4). I took thermal images of Clarifier 1 (Photos 5-6, 11-14) and Clarifier 2 (Photos 7-10, 15-16) in morning and afternoon to identify temperature fluctuations of the wastewater). Location: Review AOC Interim Compliance Plan Observation #: VD1-OB-004 Date: 11/06/2024 The WWTP Superintendent told me that chemical additions, as part of the Administrative Order on Consent Compliance Plan that Kendallville has with US EPA, has been completed. However, the facility is currently not using most of the chemical additives that it had been in previous years. The only two additives that it uses are an orthophosphate drip at the start of the aeration basin which is regulated by ORP probes in each of the basins. The drip is turned on when ORP is below 1. The second additive is an alum-based chemical called FLOC4000. The facility is not feeding a supplement for low BOD periods or using any of the other chemicals that it had been in previous years. Location: Review AOC Interim Compliance Plan Observation #: VD1-OB-005 Date: 11/06/2024 The facility is testing for process control each day (seven per week) and will continue at this rate until January 2025, when the Superintendent expects Kraft's pretreatment system to begin operation. The WWTP is testing for TSS, Ammonia, Phosphorus, DO, pH, CBOD and COD in its raw, primary and final effluent and for MLSS, MLVSS in all four aeration tanks and also determining the primary predicted BOD, MLVSS. It is planning to add sludge blanket depth data. The superintendent wants data both while the plant is performing alright, at the time of the inspection, and also as Kraft begins a shutdown period for the holidays and how the WWTP performs while receiving lower incoming BOD levels which has historically been difficult for the plant. Microbiology tests are also taken periodically, approximately twice per year, and the Superintendent expects one test taken when the plant is okay and another taken during the time that that plant is receiving lower incoming BOD levels. 4 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 Location: Review AOC Interim Compliance Plan Observation #: VD1-OB-006 Date: 11/06/2024 As part of funding from American Rescue Plan, the facility has completed: 1. Enhanced pump feed system skid 2. Caustic feed pumps, containment equipment and SCADA interface 3. Pump SCADA interface and chemical tank 4. Pump feed skid and SCADA interface 5. Four raw sewage pumps with SCADA 6. TSS effluent meter and SCADA interface 7. Add on sanitary sewer reline project for 700S Main St. Location: Review AOC Interim Compliance Plan Observation #: VD1-OB-007 Date: 11/06/2024 The facility has not started any work on redirection of pressate to digesters. The Superintendent hopes that if he is able to permanently remove the primary clarifiers then that would eliminate the pressate, since it is from the primary sludge. He has seen the project to redirect pressate as a contingency project and that it would occur if he cannot permanently remove primary clarification and if the POTW is still having effluent exceedances once the IU's pretreatment facility loadings stabilize. Location: Review AOC Interim Compliance Plan Observation #: VD1-OB-008 Date: 11/06/2024 The project to improve the aeration system and provide more oxygen to the aeration basins is underway. All the supplies and parts have arrived at the facility and they have drained Aeration Tank 4. The Superintendent expects next week that they will add more diffusers to Aeration Tank 4. He expects that they can accomplish one tank per week. Once Tank 4 has been completed, then Aeration Tank 3 will be drained and Tank 4 put back in service. He expects that the construction on this project will be completed by December 31, 2024. Location: Review AOC Interim Compliance Plan Observation #: VD1-OB-009 Date: 11/06/2024 The Superintendent stated that the collection system improvements have been occurring regularly and he expects that it will continue. The project reduces I&I by relining approximately 3000 linear feet of pipes per year. 5 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 Location: Discussion Observation #: VD1-OB-010 Date: 11/06/2024 The pretreatment supervisor stated that revised industrial user permits have not been issued to Kendallville's Industrial users at the time of the inspection. He anticipates that new permits will be issued at the beginning of 2025 to each industrial user. Kendallville updated its sewer use ordinance to revise the local limits for mercury and a permit modification was issued to the industrial user, CLC. Kendallville also included new local limits in the sewer use ordinance that previously contained only surcharge thresholds, however, Kendallville had not modify their significant industrial user, Kraft's existing permit to reflect the newly established limits. Location: Discussion Observation #: VD1-OB-011 Date: 11/06/2024 There was one sanitary sewer overflow which had previously been reported to IDEM. This occurred when the pressure release valve on a force main rusted off and was released from the pipe into a field. The facility responded immediately and shut off the wastewater flow from the forcemain and then replaced all pressure release valves to prevent future issues. Location: Discussion Observation #: VD1-OB-012 Date: 11/06/2024 I asked the WWTP Superintendent whether the relationship between cBOD and BOD at the facility or from the Industrial User, Kraft, had either been established or calculated. He told me that they had not been. I noted that Kraft had been submitting total BOD (tBOD or BOD) sample results to Kendallville prior to the reissuance of its permit in October 2020 but had been submitting monitoring results for cBOD after that date. He told me that he believed the effluent monitoring requirement for their Industrial Users had changed from BOD to cBOD during that permit reissuance. I noted that the Kendallville Sewer Use Ordinance lists BOD and Chemical Oxygen Demand as local limits with concentration limits but it does not list cBOD as a local limit. The WWTP Superintendent told me that he was not aware that cBOD was not a local limit in Kendallville's Ordinance. Location: Physical Inspection Observation #: VD1-OB-013 Date: 11/06/2024 The WWTP Superintendent, WWTP Pretreatment Supervisor, IDEM Inspectors and I began the site walkthrough at 12:15 pm ET and concluded site walkthrough at 1:23 pm ET. At that time, we viewed the headworks, the sluice gates that were installed, and an unfinished electrical panel which was installed for the sluice gates. We viewed six primary clarifiers, and I observed that three were being used at the time. We viewed four aeration basins, and I observed that three were in use at the time and the fourth was emptied in preparation for aeration diffusers to be added. I noted that each tank had an ORP monitor reading between (-300) and (-500). We viewed the secondary clarifiers and the Superintendent stated that they had been cleaned within the last week and they were scheduled to be cleaned weekly. 6 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 We viewed the pumphouse where four pumps used for primary clarifiers were located. One pump was not in operation and the Superintendent explained that they were waiting for parts. IDEM Inspectors noted that the pump that was not operational was a backup and if an additional pump became out of service, then the treatment plant would not be able to reach its maximum peak flow. We viewed the chemical storage area and saw that only the FLOC 4000 tank was full and the other tanks were empty. We viewed the sludge press which was currently pressing anaerobic sludge. The WWTP Superintendent explained that the same press is used for both aerobic or anaerobic sludge and that it does need to switch chemical additives when pressing either aerobic or anaerobic. The Superintendent explained that the aerobic digester tank is designed to not have to waste sludge for over 30 days and the Superintendent explained that he is trying to run it without wasting as sludge as frequently, more in line with how it was designed. He stated that he runs one hour of aeration and then 23 hours for settling and has not had to press sludge for a while. I observed that the UV system was not in operation at the time of inspection since the NPDES permitted effluent limits for E. coli are seasonal and were not in effect at the time of the inspection. The Superintendent said the UV system had been removed from service at the end of October. Location: Physical Inspection Observation #: VD1-OB-014 Date: 11/06/2024 I observed that the treated effluent after clarification and just prior to gravity cascade has vegetation and a visible film floating on it (Photo 18). 7 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 SECTION III -CYBERSECURITY A cybersecurity inspection was performed as part of the US EPA inspection. SECTION IV -AREAS OF CONCERN 1. Kendallville issues Industrial User Permits to monitor for cBOD, and cBOD is limited in Kendallville's NPDES Permit but Kendallville does not have a cBOD local limit. 2. BOD is a local limit according to the Kendallville Sewer Use Ordinance but the permits issued to Kendallville's industrial users do not include BOD monitoring requirements or limits. Kendallville had not modified or reissued permits to its industrial users since changing BOD from a surcharge limit to a local limit. 3. I observed vegetation and a visible film on the treated effluent just prior to the gravity cascade. 4. The facility has not started any work on redirection of pressate to digesters. According to the City of Kendallville's Compliance plan this work was expected to be completed by May 2024. SECTION V - IDEM AREAS OF CONCERN IDEM inspection report is attached to the inspection as Appendix B. The following concerns were noted: 1. Preventative maintenance plan and historical documentation was missing or absent due to a severed contract with the facilities' electronic maintenance program 2. Electronic laboratory bench sheet program allows for editing benchsheet data and does not track who created, edited or deleted data. 3. Inputted data on DMR sheets identified the incorrect number of effluent violations. SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The EPA Region 5 Lead Inspector held a closing conference with Facility personnel at 02:15 PM (ET) on 11/07/2024 for the inspection. During the closing conference, EPA Region 5 Lead Inspector discussed the observations and Area(s) of Concern identified during the inspection. Observations and Area(s) of Concern have not yet been evaluated for a formal compliance determination. 8 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 SECTION VII - LIST OF APPENDICES 1. Photo Log 2. IDEM Inspection Report 9 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 APPENDIX 1: PHOTO LOG Kendallville WWTP EPA Inspection November 6, 2024 All photos taken by Val Dooling, Environmental Engineer, U.S. EPA Camera: FLIR T420 1: FLIR0826 Description: Location: Clarifier 1 Camera Direction: Southwest Date/Time: November 6, 2024, 11:57 AM 3: FLIR0828 Description: Location: Clarifier 1 Camera Direction: Southwest Date/Time: November 6, 2024, 11:57 AM 2: FLIR0827 Description: Visable light image of Photo 1. The thermal bulking project had been completed and the ground surrounding the clarifier has been raised to within a foot of the edge of the clarifier. Location: Clarifier 1 Camera Direction: Southwest Date/Time: November 6, 2024, 11:57 AM 4: FLIR0829 Description: Visible light image of Photo 3 Location: Clarifier 1 Camera Direction: Southwest Date/Time: November 6, 2024, 11:57 AM 10 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 5: FLIR0830 Description: Infrared image of wastewater in Clarifier 1. The center of the clarifier is registering around 66F and portions of clarifier is as low as 57F. Location: Clarifier 1 Camera Direction: East Date/Time: November 6, 2024, 11:58 AM 7: FLIR0838 Description: Infrared image of wastewater in Clarifier 1. The center of the clarifier is registering around 66F and no portions of the water in the clarifier is below 61F. Location: Clarifier 1 Camera Direction: East Date/Time: November 6, 2024, 2:58 PM 6: FLIR0831 Description: Visible light image of Photo 5 Location: Clarifier 1 Camera Direction: East Date/Time: November 6, 2024, 11:58 AM 8: FLIR0839 Description: Visible light image of Photo 13 Location: Clarifier 1 Camera Direction: East Date/Time: November 6, 2024, 2:58 PM 11 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 9: FLIR0836 Description: Infrared image of wastewater in Clarifier 1. Wastewater is reading at a similar temperature as the center of the clarifier around 67F. Location: Clarifier 1 Camera Direction: East Date/Time: November 6, 2024, 2:58 PM 11: FLIR0832 Description: Infrared image of wastewater in Clarifier 2. The center of the clarifier is registering around 60F. Location: Clarifier 2 Camera Direction: West Date/Time: November 6, 2024, 11:58 AM 10: FLIR0837 Description: Visible light image of Photo 11. Location: Clarifier 1 Camera Direction: East Date/Time: November 6, 2024, 2:58 PM 12: FLIR0833 Description: Visible light image of Photo 7 Location: Clarifier 2 Camera Direction: West Date/Time: November 6, 2024, 11:58 AM 12 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 13: FLIR0834 Description: Infrared image of wastewater in clarifier 2. The center of the clarifier is registering around 64F and portions of clarifier is as low as 58F. Location: Clarifier 2 Camera Direction: Date/Time: November 6, 2024, 11:59 AM 15: FLIR0840 Description: Infrared image of wastewater in Clarifier 2. The center of the clarifier is registering around 66F and no portions of the water in the clarifier is below 60F. Location: Clarifier 2 Camera Direction: Date/Time: November 6, 2024, 2:59 PM 14: FLIR0835 Description: Visible light image of Photo 9 Location: Clarifier 2 Camera Direction: West Date/Time: November 6, 2024, 11:59 AM 16: FLIR0841 Description: Visible light image of Photo 15. Location: Clarifier 2 Camera Direction: West Date/Time: November 6, 2024, 2:59 PM 13 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 17: FLIR0843 Description: Treated wastewater just prior to entering the final stage of treatment, the gravity cascade, and discharge to recieving waters. Location: Post Aeration Camera Direction: East Date/Time: November 6, 2024, 3:00 PM 14 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 APPENDIX 2: IDEM INSPECTION REPORT 15 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 16 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 17 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 18 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 19 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 20 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 21 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 22 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 23 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 24 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 25 of 26 Kendallville WWTP Inspection Date(s): 11/06/2024 26 of 26