Document QX36Gz433ME3Q7qeVO2z4BNZL

NPDES Compliance Inspection Report Darigold - Rainier Seattle, Washington Permit #: WAR000500 Inspection Date: January 18, 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 08:57:11 -07'00' Digitally signed by RAYMOND ANDREWS Supervisor Signature/Date: PETER CONTRERAS Date: 2022.03.22 09:31:17 -07'00' Digitally signed by PETER CONTRERAS Darigold - Rainier NPDES #WAR000500 Contents I. Facility Information ............................................................................................................ 1 II. Inspection Information........................................................................................................ 1 III. Permit Information.............................................................................................................. 2 IV. Background ..................................................................................................................... 2 V. Inspection Chronology........................................................................................................ 2 VI. Opening Conference ........................................................................................................... 3 VII. Laboratory Inspection ......................................................................................................... 3 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 - Rainier NPDES #WAR000500 (All details in this report were obtained through conversations with Mr. Ross Wilson, Environmental, Health and Safety Manager and Mr. Bruce Reynolds, Environmental Manager, review of facility documents or observations made during the inspection.) I. Facility Information Facility Name: Darigold - Rainier Facility Owner/Operator: Darigold Inc. Physical Address: 4058 Rainier Avenue S Seattle, Washington 98118 King County Lat/Long: 47.566513, -122.288238 Mailing Address: P.O. Box 18229 Seattle, Washington 98118 NAICS Code: 311511 (Fluid Milk Manufacturing) SIC Code: 2026 (Fluid Milk Production) Facility Contacts: Ross Wilson Environmental, Health and Safety Manager Office Phone: 206-722-2661 Email: ross.wilson@darigold.com Bruce Reynolds Environmental Manager Office Phone: 360-748-8826 x13 Email: bruce.reynolds@darigold.com Permit Number: WAR005000 Receiving Water: Washington River II. Inspection Information Inspection Date: January 18, 2022 Inspectors: Raymond Andrews, Inspector EPA Region 10, ECAD /FDDWES Phone: 206-553-4252 Page 1 of 7 Arrival Time: 9:00 AM Darigold - Rainier NPDES #WAR000500 Departure Time: 3:30 PM Weather: Light Rain, 45F Purpose: To determine facility compliance with the Washington Industrial Stormwater General Permit (ISGP) and the Clean Water Act. III. Permit Information Darigold - Rainier is permitted under Washington Industrial Stormwater General Permit (ISGP) ("Permit") for Stormwater Discharges Associated with Industrial Activities. The facility's current permit, NPDES permit # WAR000500, 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 - Rainier ("Facility") located at 4058 Rainier Avenue South, Seattle , Washington is owned and operated by Darigold Inc. On June 13, 2018, the facility was inspected be the Washington Department of Ecology (WDOE) for compliance with its ISGP. According to WDOE's inspection report, no potential violations of the ISGP were observed. The facility could not be found in EPA's Integrated Computer Information System (ICIS) under permit #WAR00500. Since the facility is not in ICIS, it is unlikely it has been previously inspected by EPA. In 2008, the facility was sued by Puget Soundkeeper Alliance and was put under a Consent Decree. V. Inspection Chronology This was an announced inspection. On January 10, 2022, I emailed Mr. Doug Pettinger, Senior Director of Environmental Compliance, and told him I would be conducting an industrial stormwater compliance inspection of the Darigold - Rainier facility in Seattle, Washington on January 18th. Mr. Pettinger contacted the facility to let them know to expect me. I conducted an opening conference, which included an interview of Mr. Ross Wilson, Environmental, Health and Safety Manager and Mr. Bruce Reynolds, Environmental Manager, followed by a records review, a site inspection, and a closing conference. Page 2 of 7 VI. VII. Opening Conference Darigold - Rainier NPDES #WAR000500 I arrived at the facility at 9:00 am. Upon arrival, I followed Darigold's COVID protocol which included electronically signing-in, filling out a COVID questionnaire, and having my temperature taken. Once cleared, I proceeded to the office. I presented my credentials to Mr. Wilson 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 1962, and has approximately 145 full time employees. It operates 24-hours per day, 365-days per year with two production shifts, 5:00am until 3:30pm and 3:00pm until 2:30am, and a cleaning shift. The site is approximately 4-acres and is generally flat with enough grading to allow industrial stormwater to flow into the stormwater catch basins located throughout the site. The facility is primarily covered with asphalt and buildings (75%). There is a green belt on the east side of the site that covers approximately an acre (25%). According to usclimatedata.com, Seattle, Washington, receives approximate average annual precipitation of 37.13 inches. November is the wettest month with average precipitation of 6.54 inches, while July is the driest month with average precipitation of 0.67 inches. All stormwater on the site is collected in catch basins and is filtered through an stormwateRxTM Aquip filtration system, and discharged via piping to Lake Washington. The only discharge point, Outfall #2, is from the filtration unit. The facility's primary operation is the processing of fluid milk. The facility receives raw milk. The cream is separated from the skim. The butterfat is then added back into the milk in the required percentages for various products, i.e., 1% milk, 2% milk, and whole milk. All process activities are conducted indoors. No raw material or finished products are stored outside. The facility does store both used and unused filtration media near the filtration unit. No vehicle washing is conducted on-site. The only outdoor operations are the fueling of refrigerated trucks. The facility does not have fuel storage tanks. The fueling is done by an outside vendor using a fueling truck. The facility has a contracted sweet sweeper that cleans all paved areas once a week. 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). Page 3 of 7 VIII. IX. Darigold - Rainier NPDES #WAR000500 Stormwater samples are collected by Mr. Wilson. All samples are grab samples. The facility conducts oil sheen observance and pH sampling. pH sampling is performed with a meter and probe. The pH buffers used to calibrate the pH meter were within their expiration dates. The facility had previously used pH test strips to conduct pH monitoring. All other parameters are analyzed by: Analytical Resources, Inc. 4611 South 134th Place Suite 100 Tukwila, Washington 98168 (206) 695-6200 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 25, 2019 Permit Reissuance Letter - dated December 30, 2019 Stormwater Pollution Prevention Plan (SWPPP) - last certified October 4, 2018 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 Annual Reports - 2017 - 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. At the time of the inspection, the site was clean and generally free of any unprotected potential pollutant sources. We started the tour in the northwestern side of the site where I observed a "catch basin line" (Photo 1). The facility has over 30 catch basins located around the site to collect stormwater. As can be seen in Photo 1, the ground is slightly graded to facilitate the flow of stormwater into the catch basins. The facility uses two types of catch basins, Type 1 (Photo 2) and Type 2 (Photo 3). The two catch basin types function similarly. Page 4 of 7 Darigold - Rainier NPDES #WAR000500 After observing several catch basins, I asked to see the filtration system. The facility uses a stormwateRxTM Aquip filtration system, which was installed in 2011. The filtration system is located on the northern end of the site. As we came upon the Aquip system, I noted there were two totes in front of the system (Photo 4). One of the Representatives said the totes contained clean filter media that would be used to replace media in the filtration unit as it becomes contaminated. All stormwater collected by the catch basins is pumped into the Aquip system. Stormwater enters the system on the southern end (Photo 5). The water enters a pre-treatment chamber then flows into the filtration chamber. The water infiltrates down through the media and is discharged through a pipe on the bottom of the northern end of the system (Photo 6). The water is sampled from a stopcock (Photo 7) prior to discharge through piping to Lake Washington which lies approximatelyone-half mile northeast of the facility. While observing the filtration system, I noted approximately ten 55-gallon unlabeled barrels lined up on the backside of the system (Photo 8). The barrel lids were in place but not secured. One of the Representatives said the barrels contained used filtration media. I asked him to the lift the lid of one of the barrels so I could view the contents (Photo 9). This was the last stop on the site tour, so we returned to the office for the closing conference. X. Areas of Concern At the time of inspection, I found the following areas of concern: A. Stormwater Pollution Control Plan (SWPPP) 1. S3.A.3.b of the ISGP states, "The Permittee shall modify the SWPPP whenever there is a change in design, construction, operation, or maintenance at the facility that significantly changes the nature of pollutants discharged in stormwater from the facility, or significantly increases the quantity of pollutants discharged." At the time of the inspection, I reviewed the facility's SWPPP and SWPPP map. The map shows multiple outfalls. Per the Representatives, those points identified as outfalls are not actual outfalls since the facility collects all stormwater and filters it before it is discharged from a single outfall at the filtration unit. The facility did not provide any additional information on when or how the unused outfalls were decommissioned. The only actual outfall the facility maintains is not identified as such on the SWPPP map. 2. S3.B.3 of the ISGP states, "The SWPPP shall identify specific individuals by name or by title within the organization (pollution prevention team) whose responsibilities include: SWPPP development, implementation, maintenance, and modification." During my review of the SWPPP, I found that the document showed Mr. Eric Palmer on the Pollution Prevention Team as the Senior Environmental Manager. Mr. Palmer is no longer in that position. That position is now filled by Mr. Wilson. 3. S3.B.7 of the ISGP states, in part, "The SWPPP shall include measures to identify and eliminate the discharge of process wastewater, domestic wastewater, noncontact Page 5 of 7 Darigold - Rainier NPDES #WAR000500 cooling water, and other illicit discharges, to stormwater sewers, or to surface waters and groundwaters of the State." During my review of the SWPPP, I found that the document did mention illicit discharges but did not have a section on "measures to identify and eliminate" the illicit discharges. 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... j. Locations of actual and potential pollutant sources..." At the time of the inspection, I reviewed the facility site map. The map in the SWPPP cannot be read with the naked eye in paper form. The map was missing the following items: a. Size of the property in acres. b. Locations of all receiving water in the immediate vicinity of the facility. c. The map did not show the locations of the used and unused filtration media stored by the filtration unit. 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: a. 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. b. The ISGP indicates the lab must use analysis method SM4500 NO3-E/F/H for the parameter nitrate + nitrate nitrogen (N). However, the SWPPP states analysis method 353.1 is to be used. I did not see QA/QC documentation from the lab on QL development. D. Monthly Inspection Reports 1. S7.A.1 of the ISGP states, "The Permittee shall conduct and document visual inspections of the site each month." Page 6 of 7 Darigold - Rainier NPDES #WAR000500 At the time of the inspection, I requested to review monthly inspection reports from January 2017 through December 2021. There were 17 inspection reports that were not available. The missing inspection reports were June - September 2018, May - December 2019, and February - June 2020. 2. 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..." Upon review of the facility's routine monthly inspection reports, I found most of the inspection reports did not include the time the inspection was conducted. Time was included on monthly inspection reports from October 2018 - January 2019. E. Discharge Monitoring Reports (DMRs) S9.B.1 of the ISGP states, in part, "The Permittee shall submit sampling data obtained during each reporting period on a Discharge Monitoring Report (DMR)..." At the time of the inspection, I reviewed facility DMRs from 1Q 2017 through 4Q 2021. I found the following issues: a. The 1Q 2019 DMR did not include an entry for the pH parameter. b. The 3Q 2021 DMR was unavailable. c. The 4Q 2020 DMR did not include entries for the copper, zinc, BOD, and phosphorus parameters. XI. Closing Conference On January 18, 2022, I held a closing conference with Mr. Wilson 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 7 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 18, 2022, with a Panasonic DMC-FH25 camera) Photo 1 / P1010174 - Catch Basin Line, facing east Photo 2 / P1010175 - Catch Basin, Type 1 Photo 3 / P1010176 - Catch Basin, Type 2, facing north Photo 4 / P1010181 - Filtration System with totes of clean filtration media Photo 5 / P1010182 - Filtration System, south end, influent Photo 6 / P1010179 - Filtration System, north end, effluent Sampling Point Photo 7 / P1010180 - Filtration System, sample collection point Photo 8 / P1010177 - Ten Barrels, contain used filtration media Photo 9 / P1010178 - Barrel, used filtration media, close-up Complete list of photographs taken during the inspection: P1010172 - pH Meter and Probe P1010173 - pH Meter Manual, calibration instructions P1010174 - Catch Basin Line, facing east P1010175 - Catch Basin, Type 1 P1010176 - Catch Basin, Type 2, facing north P1010177 - Ten Barrels, contain used filtration media P1010178 - Barrel, used filtration media, close-up P1010179 - Filtration System, north end, effluent P1010180 - Filtration System, sample collection point P1010181 - Filtration System with totes of clean filtration P1010182 - Filtration System, south end, influent media