Document V33Vo4kye4Rr87Ep2ko0G7w7K

EPA Region 5 Enforcement and Compliance Assurance Division INSPECTION REPORT Contains Confidential Business Information Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 12/02/2022 08:20 AM (ET) Announced: Yes 12/02/2022 10:57 AM (ET) Access: Granted Day 1 - Cloudy and 48oF Water Clean Water Act, National Pollutant Discharge Elimination System (NPDES) CAFO - Concentrated Animal Feeding Operation 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 Trillium Farm Holdings LLC, Layer Site 1 Trillium Farm Holdings LLC, Layer Site 1 11995 Croton Road Croton, OH Licking County 40.214559, -82.685305 10513 Croton Road Croton, Ohio 43013 FRS ID Layer1 Permit Number(s) (If Applicable) OH0131121 SIC and/or NAICS 5144 Regulatory Representatives Participating in Inspection: Title Name Inspector Megan Zale Organization EPA Region 5 Lead Inspector: Andi Hodaj Supervisor Review: Molly Smith Digitally signed by ANDI ANDI HODAJ HODAJ Date: 2023.02.03 16:32:23 -06'00' EPA Region 5 hodaj.andi@epa.gov MOLLY SMITH EPA Region 5 Digitally signed by MOLLY SMITH Date: 2023.02.06 09:27:01 -06'00' Smith.Molly@epa.gov (312) 353-4645 1 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 SECTION I - INTRODUCTION Site Entry and Inspection Objectives EPA Region 5 Lead Inspector, Andi Hodaj, arrived at the Trillium Farm Holdings Layer Site 1 (the "Site" or "Facility"), located at 11995 Croton Road, Croton, OH, at 08:20 AM (ET) on 12/02/2022 for an announced inspection. EPA Region 5 Lead Inspector presented credentials to Kayla Ferrendelli and Marcus Beer and informed them 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 Trillium Farm Holdings Layer Site 1 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, measurements taken by EPA Region 5 inspectors, verbal or written statements made by information supplied by Trillium Farm Holdings Layer Site 1 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 Trillium Farm Holdings Layer Site 1 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. Attendees Organization Attendee Name EPA Region 5 EPA Region 5 Trillium Farm Holdings LLC Trillium Farm Holdings LLC Andi Hodaj Megan Zale Kayla Ferrendelli Marcus Beer Facility/Site Description Title Lead Inspector Inspector Farm Compliance Manager General Manager (Layer Sites) Present in Opening Conf. Yes Yes Yes Present in Closing Conf. Yes Yes Yes Yes Yes EPA Region 5 lead inspector confirmed the following facility information: Facility representatives made a Confidential Business Information (CBI) claim on all information that was provided to EPA during the inspection. The Facility houses layer chickens in 14 Belt Battery style barns, and washes and packages eggs produced by the chickens. At the time of the inspection, the site was currently housing 2.087 million layer chickens and had a maximum capacity of 2.4 million layer chickens. Each barn is split into two levels with four rows of cages on the upper level and three rows on the lower level. There are 45 full-time employees on-site. The Facility operates seven days per week and it has one night shift. According to the Facility representatives, the Facility has two Manure Storage Barns (MSB) with a storage capacity of 629,000 cubic feet each. Manure is conveyed from each belt battery barn to the two MSB via a conveyor belt, where it is stored in two piles. The manure piles in the MSB are inspected weekly for height and temperature. Manure is removed from the MSB twice per year on average and hauled for land application by a third party, pursuant to a Manure Management Plan (MMP). The last time manure was hauled from the manure barns was November 10, 2022, and amount hauled was approximately 990 tons of manure. The Facility generates approximately 26,000 tons of manure per year. 2 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 The Facility also has an egg-wash and an egg-packaging operation. Eggs go through sprayers and the egg-wash water is discharged every five hours via floor drains into a two-celled lagoon. From there water is hauled via a center-pivot for land application on a field next to the Facility. According to Facility representatives, a contractor is also used when there is more egg-wash water than they can apply on the field next to the Facility. The Facility draws approximately 10,000 gallons of water from a well on-site for the egg-wash operation. No other equipment washing takes place on site, according to Facility representatives. The Facility operates under NPDES Permit No. OH0131121 (NPDES permit) with expiration date of August 31, 2023. The NPDES permit allows discharges from a stormwater pond that drains an area of 40.23 acres, with a storage capacity of 3.5 million gallons. The stormwater pond discharges to an Enhanced Treatment System (ETS) for further treatment of the wastewater before discharging through outfall 001, into an unnamed tributary of Otter Fork. The Facility's September 2018 - December 2022 certified DMRs to the Ohio Environmental Protection Agency (Ohio EPA) showed 18 instances of effluent limit exceedances for Total Phosphorus (TP), Ammonia-Nitrogen (NH3) and Total Suspended Solids (TSS). All, except one, the effluent limit exceedances start in June 2021 and continued through November 2022. The headwaters (or tributaries) of the Otter Fork are listed in EPA's CWA Section 303(d) List as impaired due to E.coli, nitrogen, phosphorus, and sediments. The Facility operates wells that provide drinking water for the chickens. Water from the wells is treated prior to being fed to the chickens. Bathroom water and water from the biosecurity showers goes to a septic tank and from there to the stormwater pond. Facility/Site Information Do you have any additional biosecurity concerns or issues at this site How many and types of animals are confined Do you have a permit and/or a Nutrient Management Plan (NMP) Who can tour the site with us in a facility vehicle or walk How do you land apply manure and wastewater No 2.087 million Layer chickens Yes, both Kayla Ferrendelli and Marcus Beer Egg-wash wastewater is land-applied to a crop field next to the facility via a center pivot. Location(s) Location/Area/Sub-area Chicken barns Description There are a total of 16 layer chicken belt battery style barns at this Facility. Two of the barns are decommissioned and do not house any chickens currently. The chicken barns are set in two rows. The north row has eight barns numbered from west to east 1, 3, 48, 5, 7, 9, 11, 13 and 13A (which is one of the decommissioned barns). The south row has eight barns numbered from west to east 2, 4, 6, 8, 10, 12, 14 and 14A (which is the decommissioned one). See map in Appendix 1. 3 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 Egg washing and packaging barn Manure Storage Barns Outfall 001 Wastewater storage structures The egg washing and packaging barn is located just west of the chicken barns and east of Croton Road. It also houses office space and restrooms. See map in Appendix 1. There are two Manure Storage Barns (MSB) on-site (south and north), at the east end of the chicken barns, where manure is stored in piles before being hauled off site. See map in Appendix 1. Outfall 001 is located north of the Facility and just north of Barns 5 and 7. Outfall 001 discharges into the unnamed tributary of the Otter Fork. East of the manure barns, there is an egg-wash lagoon divided into two cells, a stormwater pond and the ETS. The Facility discharges into the unnamed tributary of the Otter Fork that flows north on the north side of the property, through outfall 001. See map in Appendix 1. SECTION II - OBSERVATIONS Location: Egg washing and packaging barn Observation #: AH2-OB-001 Date: 12/02/2022 Weather: Cloudy and 48oF EPA observed the egg-washing and packaging process that took place in the same area. Water from the egg washing and egg parts from broken eggs were collected via floor drains and sent to the egg-wash lagoon. Photos 1. DSCN0356.JPG 2. DSCN0385.JPG Location: Chicken barns Observation #: AH2-OB-002 Date: 12/02/2022 Weather: Cloudy and 48oF EPA observed 16 chicken barns at the Facility split into two groups, south and north and numbered from 1 to 14 west to east, with the north group of barns being assigned the odd numbers and the south group of barns the even numbers. See map in Appendix 1. The chicken barns did not have roof gutters. EPA observed a concrete driveway between the two group of barns with several stormwater catch basins in it that drain to the stormwater pond, according to Facility representatives. Each chicken barn has 20 electric fans on either side of it. Photos DSCN0359.JPG and DSCN0383.JPG. When in operation, the electric fans emit a creamy dust and feathers on the area outside the barns. On either side of the chicken barns, there is a grass area that is sloped away from the barns and forms a channel that conveys stormwater east for the east barns and west for the west barns. Photo 359 in photolog. Some of the barns have a 3-foot gravel layer on each side of the barn. Photo DSCN0357.JPG. The grassed channels on the north side group of barns drain north via culverts to catch basins north of the north driveway. These catch basins drained into the north-side lift station. EPA observed accumulated sludge in the catch basin west of Barn 1. Photo DSCN0358.JPG. The lift station pumps water into the stormwater pond. At the time of the inspection, EPA observed 3 pipes flowing in it, from southwest, east and west. Photo DSCN0362.JPG. EPA observed parts of the concrete tunnel that house the manure conveying belts were cracked and needed repair. 4 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 Photos 1. DSCN0357.JPG 2. DSCN0358.JPG 3. DSCN0359.JPG 4. DSCN0360.JPG 5. DSCN0361.JPG 6. DSCN0362.JPG 7. DSCN0366.JPG 8. DSCN0382.JPG 9. DSCN0383.JPG Location: Manure Storage Barns Observation #: AH2-OB-003 Date: 12/02/2022 Weather: Cloudy and 48oF EPA observed a catch basin in the grassed area east of each of the Manure Barns. The catch basins routed water east across the east driveway and into other catch basins located next to the Egg-Wash Lagoon. These catch basins routed water north and into the unnamed tributary of the Otter Fork via a catch basin located at the northeast end of the Facility. Photo DSCN0368.JPG. EPA could not observe the outlet pipe from the catch basin because according to Mr. Beer, the pipe goes underground and outlets into the unnamed tributary on a private cropland north of the Facility. Photos 1. DSCN0363.JPG 2. DSCN0365.JPG 3. DSCN0364.JPG 4. DSCN0367.JPG 5. DSCN0368.JPG 6. DSCN0378.JPG 7. DSCN0379.JPG 8. DSCN0380.JPG 9. DSCN0381.JPG Location: Outfall 001 Observation #: AH2-OB-004 Date: 12/02/2022 Weather: Cloudy and 48oF EPA observed two pipes discharging at outfall 001, a big one from which the samples are taken and a smaller one that Facility representatives were unaware of its function. Photo DSCN0369.JPG. Photos 5 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 1. DSCN0369.JPG 2. DSCN0370.JPG 3. DSCN0371.JPG 12/02/2022 - 12/02/2022 Location: Wastewater storage structures Observation #: AH2-OB-005 Date: 12/02/2022 Weather: Cloudy and 48oF EPA observed a series of stormwater catch basins around the egg-wash lagoon and the stormwater pond that would route water towards the unnamed tributary of Otter Fork, north of the Facility. Location: Wastewater storage structures Observation #: AH2-OB-006 Date: 12/02/2022 Weather: Cloudy and 48oF EPA observed the Egg-Wash Lagoon that was split into two cells, north and south cell. The north cell had very little water in it. Photos DSCN0372.JPG and DSCN0374.JPG. EPA also observed the stormwater pond and the ETS. The stormwater pond had depth markers in it and there was no pooling water in the ETS, even though the stormwater pond was discharging to the ETS at the time. Photos DSCN0374.JPG - DSCN0377.JPG. Photos 1. DSCN0372.JPG 2. DSCN0373.JPG 3. DSCN0374.JPG 4. DSCN0375.JPG 5. DSCN0376.JPG 6. DSCN0377.JPG Location: Manure Storage Barns Observation #: AH2-OB-007 Date: 12/02/2022 Weather: Cloudy and 48oF EPA observed the incline room, where the manure conveying belt slopes upwards towards the top of the manure barn and observed accumulated manure dust on the ground below the conveyor belt. Facility representatives stated that when water accumulates in the manure conveying tunnel or the incline room, it gets pumped and hauled off-site. EPA observed the two Manure Storage Barns where the north had one pile of manure in it and south one two smaller piles. Photos DSCN0380.JPG and DSCN0381.JPG. The concrete driveway in front of the two MSB and driveway between the two rows of chicken barns had several stormwater catch basins that drained to the stormwater pond, according to Facility representatives. SECTION III - RECORDS REVIEW Records may not be in sequential order. Record: DMR Reports Ref #: AH2-RR-006 Reviewed By: Andi Hodaj 6 of 26 AOC: Yes Reviewed Date: 02/02/2023 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 EPA reviewed DMR reports for the months of August, September and October of 2022. EPA noted that there were 3 Ammonia effluent limit violations during the months of August, September and October 2022. A review of historical data from ECHO, showed a total of 18 effluent limit exceedances from outfall 001. All but one, of the effluent limit exceedances occurred during years 2021 and 2022. Record: Other - Chain of Custody Forms Ref #: AH2-RR-005 Reviewed By: Andi Hodaj AOC: Yes Reviewed Date: 02/02/2023 EPA reviewed copies of Chain of Custody (CoC) forms for samples collected from eight sites, including Layer 1, during the period of October 2021 through September 2022. The October 2021 CoC was missing signatures and the sample collection times. All CoC forms were missing signatures. Record: Other - Weather data Ref #: AH2-RR-004 Reviewed By: Andi Hodaj AOC: No Reviewed Date: 02/02/2023 EPA reviewed copies of local climatological data spreadsheets for the period November 2021 through November 2022. The weather station located is located at geographic coordinates Lat: 40.2046 Long: -82.6923, per the spreadsheets. Record: Manifests Ref #: AH2-RR-003 Reviewed By: Andi Hodaj AOC: No Reviewed Date: 02/02/2023 EPA reviewed manure hauling manifests for the period June 2020 through September 2022 for the Croton Pullet 3 Site. EPA had requested manifests for Layer 1. Record: Personnel Training Ref #: AH2-RR-002 Reviewed By: Andi Hodaj AOC: Yes Reviewed Date: 02/02/2023 EPA reviewed copies of Certified Livestock Manager certificates for Emily Hookway and Megan Combs with expiration dates of December 31, 2022 and issued by Ohio EPA September 9, 2019. NPDES Permit OH0131121, Part II, G states, "The permittee (or employee(s) appointed by the owner/operator) shall attend a manure management and water quality protection training and/or seminar at least once per year. The copies of the training records provided by Trillium did not include training records for 2020, 2021 and 2022. EPA could not verify that annual training had occurred in this year as required by the NPDES permit. Record: Other - Annual Reports to Ohio Department of Agriculture Ref #: AH2-RR-001 Reviewed By: Andi Hodaj AOC: Yes Reviewed Date: 02/02/2023 EPA reviewed copies of Annual Reports submitted to the Ohio Department of Agriculture (ODA) for years 2019, 2020 and 2021. EPA had asked the Facility to submit Annual Reports submitted to Ohio EPA as required Part II, K. of the NPDES permit. EPA reviewed an Emergency Spill Report Form that was submitted to ODA for a spill of approximately 50,000 gallons of egg-wash water into the unnamed tributary of the Otter Fork via a tile, on November 19, 2020. The report states that "the newly discovered tile will be checked going forward during drag-lining application." No more information is provided about the tile and the manner that the egg-wash water entered the tile and reached the unnamed tributary of the Otter Fork. 7 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION V - AREA OF CONCERN Areas of Concern may not be in sequential order. The presentation of Areas of Concern does not constitute a formal compliance determination or violation. AOC Reference #: AH2-OB-002 AOC: Location: Chicken barns EPA observed parts of the concrete tunnel that house the manure conveying belts were cracked and needed repair. AOC Reference #: AH2-OB-004 AOC: Location: Outfall 001 EPA observed two pipes discharging at outfall 001, a big one from which the samples are taken and a smaller one that Facility representatives were unaware of its function or what it was that was discharging. AOC Reference #: AH2-OB-005 AOC: Location: Wastewater storage structures EPA observed a series of stormwater catch basins around the egg-wash lagoon and the stormwater pond that would route water towards the unnamed tributary of Otter Fork, north of the Facility. AOC Reference #: AH2-RR-001 AOC: Records Review: Other - Annual Reports to Ohio Department of Agriculture EPA reviewed copies of Annual Reports submitted to the ODA for years 2019, 2020 and 2021. EPA had asked the Facility to submit Annual Reports submitted to Ohio EPA as required Part II,K. of the NPDES permit. EPA reviewed an Emergency Spill Report Form that was submitted to ODA for a spill of approximately 50,000 gallons of egg-wash water into the unnamed tributary of the Otter Fork via a tile, on November 19, 2020. The report states that "the newly discovered tile will be checked going forward during drag-lining application." No more information is provided about the tile and the manner that the egg-wash water entered the tile and reached the unnamed tributary of the Otter Fork. AOC Reference #: AH2-RR-002 AOC: Records Review: Personnel Training EPA reviewed copies of Certified Livestock Manager certificates for Emily Hookway and Megan Combs with expiration dates of December 31, 2022 and issued by Ohio EPA September 9, 2019. NPDES Permit OH0131121, Part II, G states, "The permittee (or employee(s) appointed by the owner/operator) shall attend a manure management and water quality protection training and/or seminar at least once per year. The copies of the 8 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 training records provided by Trillium did not include training records for 2020, 2021 and 2022. EPA could not verify that annual training had occurred in this year as required by the NPDES permit. AOC Reference #: AH2-RR-005 AOC: Records Review: Other - Chain of Custody Forms EPA reviewed copies of CoC forms for samples collected from eight sites, including Layer 1, during the period of October 2021 through September 2022. The October 2021 CoC was missing signatures and the sample collection times. All CoC forms were missing signatures. AOC Reference #: AH2-RR-006 AOC: Records Review: DMR Reports EPA reviewed DMR reports for the months of August, September and October of 2022. EPA noted that there were 3 Ammonia effluent limit violations during the months of August, September and October 2022. A review of historical data from ECHO, showed a total of 18 effluent limit exceedances from outfall 001. All but one, of the effluent limit exceedances occurred during years 2021 and 2022. SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The EPA Region 5 Lead Inspector held a closing conference with Facility personnel at 10:40 AM (ET) on 12/02/2022 for the inspection. During the closing conference, EPA Region 5 Lead Inspector discussed the observations and Areas of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. During the closing conference EPA discussed some preliminary areas of concern with the Facility representatives including: Discharges from the Facility that did not go through the wastewater treatment system; and The need to identify pipes and sources of discharge that drain into the lift stations and stormwater catch basins throughout the Facility. Follow Up EPA had requested copies of manure hauling manifests for Layer 1. However, Facility sent manure manifests for Croton Pullet 3. SECTION VII - LIST OF APPENDICES 1. Map of Facility 2. Photo Log 3. List of Effluent Limit Exceedances 9 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: APPENDIX 1. MAP OF FACILITY 12/02/2022 - 12/02/2022 10 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: APPENDIX 2: PHOTO LOG 12/02/2022 - 12/02/2022 Egg Wash DSCN0356.JPG 12/02/2022 08:52 AM (ET) Photographer: Andi Hodaj Egg washing and packaging barn CBI No PII Egg wash and packaging operation inside the egg-wash and packaging barn. Camera looking east. Grassed channel west of Barn 1 12/02/2022 09:00 AM (ET) Chicken barns Grassed channel west of Barn 1, facing north. DSCN0357.JPG Photographer: Andi Hodaj CBI No PII 11 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 Catch Basin west of Barn 1 DSCN0358.JPG 12/02/2022 09:03 AM (ET) Photographer: Andi Hodaj Chicken barns CBI No PII Catch basin that drains the grassed area west of Barn 1. Grassed area between Barns 1 and 3 DSCN0359.JPG 12/02/2022 09:08 AM (ET) Photographer: Andi Hodaj Chicken barns CBI No PII Grassed area between Barns 1 and 3, facing south. 12 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 Storm Sewer DSCN0360.JPG 12/02/2022 09:11 AM (ET) Photographer: Andi Hodaj Chicken barns CBI No PII Storm sewer grate in the north driveway of the facility between Barns 5 and 7. Grassed area between Barns 5 and 7 DSCN0361.JPG 12/02/2022 09:12 AM (ET) Photographer: Andi Hodaj Chicken barns CBI No PII Grassed area between Barns 5 and 7, facing south. 13 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 Lift Station 12/02/2022 09:14 AM (ET) Chicken barns Lift station north of Barn 7. DSCN0362.JPG Photographer: Andi Hodaj CBI No PII Belt from Incline Room to MSB DSCN0363.JPG 12/02/2022 09:21 AM (ET) Photographer: Andi Hodaj Manure Storage Barns CBI No PII Belt going from incline room to Manure Storage Barn. Camera looking east. 14 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 Inside Manure Incline Room DSCN0365.JPG 12/02/2022 09:22 AM (ET) Photographer: Andi Hodaj Manure Storage Barns CBI No PII Inside manure incline room. Camera facing southwest. Manure Incline Room DSCN0364.JPG 12/02/2022 09:22 AM (ET) Photographer: Andi Hodaj Manure Storage Barns CBI No PII Inside the manure incline room. Camera looking east. 15 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 Diversion Structure DSCN0366.JPG 12/02/2022 09:24 AM (ET) Photographer: Andi Hodaj Chicken barns CBI No PII Location of the diversion structure (y-shaped pipe) discovered at Layer 1 in June 2021. Camera facing west. Catch basin DSCN0367.JPG 12/02/2022 09:28 AM (ET) Photographer: Andi Hodaj Manure Storage Barns CBI No PII Catch basin at the northwest corner of the Egg-Wash Lagoon. There are two pipes flowing in it from east and southwest and a pipe that flows out and northwest towards the unnamed tributary of Otter Fork. 16 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 Catch Basin DSCN0368.JPG 12/02/2022 09:29 AM (ET) Photographer: Andi Hodaj Manure Storage Barns CBI No PII Catch basin at the northwest corner of the Egg-Wash Lagoon. There are two pipes flowing in it from east and southwest and a pipe that flows out and northwest towards the unnamed tributary of Otter Fork. Outfall 001 DSCN0369.JPG 12/02/2022 09:33 AM (ET) Photographer: Andi Hodaj Outfall 001 CBI No PII Two pipes discharging in the unnamed tributary of Otter Fork. The big pipe in the photo is where Facility takes its samples for outfall 001. Camera looking south. 17 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 Unnamed tributary of Otter Fork DSCN0370.JPG 12/02/2022 09:34 AM (ET) Photographer: Andi Hodaj Outfall 001 CBI No PII Unnamed tributary of Otter Fork just west of outfall 001. Camera looking west. Outfall 001 Sign 12/02/2022 09:35 AM (ET) Outfall 001 Outfall 001 sign, facing north. DSCN0371.JPG Photographer: Andi Hodaj CBI No PII 18 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 Egg-Wash Lagoon North Cell DSCN0372.JPG 12/02/2022 09:43 AM (ET) Photographer: Andi Hodaj Wastewater storage structures CBI No PII The north cell of the Egg-Wash Lagoon, facing south. Egg-Wash Lagoon South Cell 12/02/2022 09:47 AM (ET) Wastewater storage structures South cell of the Egg-Wash Lagoon, facing south. DSCN0373.JPG Photographer: Andi Hodaj CBI No PII 19 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 ETS 12/02/2022 09:49 AM (ET) Wastewater storage structures ETS, facing east. DSCN0374.JPG Photographer: Andi Hodaj CBI No PII ETS Influent DSCN0375.JPG 12/02/2022 09:52 AM (ET) Photographer: Andi Hodaj Wastewater storage structures CBI No PII ETS influent from stormwater pond. Camera looking south. 20 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 Stormwater Pond DSCN0376.JPG 12/02/2022 09:54 AM (ET) Photographer: Andi Hodaj Wastewater storage structures CBI No PII Stormwater pond from northeast corner. Camera facing southwest. Stormwater Pond Level Indicators DSCN0377.JPG 12/02/2022 10:04 AM (ET) Photographer: Andi Hodaj Wastewater storage structures CBI No PII Stormwater pond level indicators, west side of pond, facing south. 21 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 Drainage Structure DSCN0378.JPG 12/02/2022 10:09 AM (ET) Photographer: Andi Hodaj Manure Storage Barns CBI No PII Drainage structure (concrete catch basin) between the south MSB and Barn 14A. It has one inflowing pipe from north and an outflowing pipe towards south. Drainage Structure DSCN0379.JPG 12/02/2022 10:09 AM (ET) Photographer: Andi Hodaj Manure Storage Barns CBI No PII Drainage structure (concrete catch basin) between the south MSB and Barn 14A. It has one inflowing pipe from north and an outflowing pipe towards south. 22 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 South Manure Storage Barn 12/02/2022 10:13 AM (ET) Manure Storage Barns South manure storage barn, facing south. DSCN0380.JPG Photographer: Andi Hodaj CBI No PII North Manure Storage Barn 12/02/2022 10:14 AM (ET) Manure Storage Barns North manure storage barn, facing north. DSCN0381.JPG Photographer: Andi Hodaj CBI No PII 23 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 Driveway between the two barn rows DSCN0382.JPG 12/02/2022 10:16 AM (ET) Photographer: Andi Hodaj Chicken barns CBI No PII The driveway between the two chicken barn rows has several stormwater catch basins in it. Camera looking west. Grassed area between Barns 6 and 8 DSCN0383.JPG 12/02/2022 10:26 AM (ET) Photographer: Andi Hodaj Chicken barns CBI No PII Grassed area between Barns 6 and 8, facing north. 24 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: 12/02/2022 - 12/02/2022 Egg-Wash Lift Station DSCN0384.JPG 12/02/2022 10:36 AM (ET) Photographer: Andi Hodaj [Location/Area] CBI No PII Egg-Wash water lift station west of chicken barns, facing north. Egg Wash Lift Station 12/02/2022 10:38 AM (ET) Egg washing and packaging barn Egg wash lift station, facing south/southeast. DSCN0385.JPG Photographer: Andi Hodaj CBI No PII 25 of 26 Trillium Farm Holdings Layer Site 1 - Contains CBI Inspection Date: APPENDIX 3: List of Effluent Limit Exceedances Effluent Limit Exceedances Report OH0131121: TRILLIUM FARM HOLDINGS LLC - LAYER SITE 1, CROTON, OH 43013 Monitoring Period Date Range: 09/01/2018 to 01/31/2023 12/02/2022 - 12/02/2022 Exceedance Details Monitoring Period Date 10/31/2018 6/30/2021 7/31/2021 7/31/2021 8/31/2021 Outfall Parameter Description 1 Nitrogen, ammonia total (as N) 1 Nitrogen, ammonia total (as N) 1 Nitrogen, ammonia total (as N) 1 Nitrogen, ammonia total (as N) 1 Solids, total suspended 8/31/2021 8/31/2021 8/31/2021 1 Nitrogen, ammonia total (as N) 1 Nitrogen, ammonia total (as N) 1 Phosphorus, total (as P) 9/30/2021 9/30/2021 10/31/2021 10/31/2021 6/30/2022 7/31/2022 7/31/2022 8/31/2022 9/30/2022 10/31/2022 1 Nitrogen, ammonia total (as N) 1 Nitrogen, ammonia total (as N) 1 Nitrogen, ammonia total (as N) 1 Nitrogen, ammonia total (as N) 1 Nitrogen, ammonia total (as N) 1 Nitrogen, ammonia total (as N) 1 Nitrogen, ammonia total (as N) 1 Nitrogen, ammonia total (as N) 1 Nitrogen, ammonia total (as N) 1 Nitrogen, ammonia total (as N) Limit Type MO AVG MO AVG MO AVG MO AVG MO AVG MO AVG MO AVG DAILY MX MO AVG MO AVG MO AVG MO AVG MO AVG MO AVG MO AVG MO AVG MO AVG MO AVG DMR Value 1.34 1.04 1.42 0.649 9 0.96 0.86 0.26 1.2 0.7 0.339 2.37 1.19 1.17 0.253 0.92 1.16 0.99 Limit Value 0.9 0.9 0.9 0.22 7.2 0.9 0.22 0.24 0.9 0.22 0.22 0.9 0.9 0.9 0.22 0.9 0.9 0.9 Unit mg/L mg/L mg/L kg/d kg/d mg/L kg/d kg/d mg/L kg/d kg/d mg/L mg/L mg/L kg/d mg/L mg/L mg/L % Exceedance 49 16 58 195 25 7 291 8 33 218 54 163 32 30 15 2 29 10 26 of 26