Document X7drGjkwy1M05Xo7gw28ErQg4

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 10/25/2023 12:39 PM (CT) Announced: Yes 10/25/2023 03:05 PM (CT) Access: Granted Overcast 59F (rained overnight) Water Clean Water Act, NPDES, Industrial Compliance Evaluation Inspection (CEI) Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County Facility GPS Coordinates Menominee Indian Tribe of Wisconsin Menominee Tribal Enterprises Sawmill Hwy 47 North, P.O. Box 10 Neopit, WI 54150 Menominee 44.982138, -88.82985 FRS ID 110010885453 Permit Number(s) (If Applicable) WI0046868 SIC and/or NAICS SIC 2421/NAICS 32113 Regulatory Representatives Participating in Inspection: Title Name Inspector Ray Cullen Organization EPA REGION 5 Lead Inspector: Dean Maraldo [Signature] DINO MARALDO Digitally signed by DINO MARALDO Date: 2023.11.15 17:17:10 -06'00' EPA REGION 5 Maraldo.Dean@epa.gov (312) 353-2098 Supervisor Review: Ryan Bahr [Signature] Digitally signed by RYAN RYAN BAHR Date: 2023.11.17 BAHR 17:14:28 -06'00' EPA REGION 5 bahr.ryan@epa.gov 1 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 SECTION I - INTRODUCTION Site Entry and Inspection Objectives I, EPA Region 5 Lead Inspector, Dean Maraldo, arrived at the Menominee Tribal Enterprises Sawmill (the "Facility" or "MTE"), located at Hwy 47 North, Neopit, WI 54150, at 12:39 PM (CT) on October 25, 2023, for an announced inspection. I was joined by EPA inspector Ray Cullen. We presented our EPA inspector credentials to Raymond Fish (Safety Coordinator) and informed them that this was an EPA inspection to determine compliance as authorized by Clean Water Act (CWA) Section 308 and implementing regulations. This report is based on information supplied by Facility representatives, direct observations made by the EPA inspectors, records and reports maintained by the Facility and other information including: photographs taken by EPA inspectors, physical evidence collected by the EPA inspectors, measurements taken by EPA inspectors, verbal or written statements made by Facility representatives during or subsequent to the on-site inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA inspectors by 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 and/or public records may be included in this report. Attendees Organization EPA Region 5 EPA Region 5 Menominee Tribal Enterprises Attendee Name Dean Maraldo Ray Cullen Raymond Fish Title Lead Inspector Inspector Safety Coordinator Present in Opening Conf. Yes Yes Yes Present in Closing Conf. Yes Yes Yes Facility/Site Description We began the opening conference in Raymond Fish's office and reviewed the Facility description provided in the Facility's NPDES Permit, as follows: The existing facility is a timber processing facility which produces rough sawn and planed lumber from logs harvested from the Menominee Indian Reservation. Processes include wet decking, mechanical barking, sawing, edging, planing, machining, and drying. The following outfalls are covered under this permit: 001- Boiler blowdown discharge to the West Branch of the Wolf River 002- Stormwater discharge to the West Branch of the Wolf River 003- Wet decking discharge to the Neopit Mill Pond Mr. Fish confirmed that the permit description and outfall receiving waters were accurate. 2 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 Facility/Site Information Next, I asked some background questions. Mr. Fish provided the responses in the table below. Industrial Sector/Sub-sector? Is the process discharge a batch, continuous or combination? Are you required to report flow? If yes, how is it measured? Have the principal products or production rates changed? Is property owned or leased? Number of employees? Shifts/Hours of Operations? Have there been or are there plans to make changes in the process(es) that will cause a new, different, or increased discharge? Do you self-monitor and keep monitoring records? Outfalls (and do the numbers and locations match the permit?) Size of Facility? What are the raw materials used? Type of Operation? What is the principal product generated? Responsible official verified Do you use in-house or contract out for laboratory analyses? Confirmed SIC code 2421 (Sawmills and Planing Mills, General) as included in NPDES permit application 001 (boiler blowdown): intermittent flow; 002 (stormwater) discharged this week with rain; 003 (wet decking): in warm weather (May-Sep) sprinkler on logs then water flows to river, not occurring now. Sprinklers help to preserve wood in warm in conditions. Yes, Outfalls 1/3: use pail method (permit allows for estimated flow measurement) No, Facility has been operating this way for "a hundred years" Owned by the Tribe. MTE President reports to the Chairperson About 90; another 100 in forestry department offsite 6am-2:30 pm M-F, weekends off Bureau of Indian Affairs will build a new dam; no changes to current water management Yes, keep records more than 3 years 3, and yes 40 acres Timber (make rough lumber) Sawmill (saw, grade, and dry til, then planing mill) Rough lumber Raymond Fish Use laboratory, Pace Analytical - Green Bay Inspection Focus Areas and Locations Location/Area/Sub-area Description Interview Records/Reporting Self Monitoring Safety Coordinator's Office Operations and Maintenance ("O&M") Minimize Exposure (Non-numeric Technology-based Effluent Limits) Good Housekeeping (Non-numeric Technology-based Effluent Limits) 3 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 Maintenance (Non-numeric Technology-based Effluent Limits) Spill Prevention (Non-numeric Technology-based Effluent Limits) Employee Training (Non-numeric Technology-based Effluent Limits) Stormwater Pollution Prevention Plan ("SWPPP") Stormwater Inspections and Monitoring Physical Inspection Close out Conference Outdoor areas throughout Facility Safety Coordinator's Office SECTION II - OBSERVATIONS The Facility was represented only by Raymond Fish, who provided all the responses to the interview questions below. Location: Interview/Records/Reporting Observation #: DM1-OB-001 Date: 10/25/2023 I asked Raymond Fish if records and reports were maintained for at least 3 years? He replied "Yes". I then showed Mr. Fish the list of recent NPDES permit effluent limit violations for pH (See Appendix 3 (Document Log). I asked specifically about the pH violation in April 2023, which appeared to be a reporting error (reported "<6", lower limit is "=6"). Mr. Fish said it was an issue with NetDMR. I recommended he contact NetDMR specialists at EPA to resolve the issue. I also asked why pH values are always exactly 6 or 9 for Outfall 003. Mr. Fish said this is due to another issue with NetDMR for this outfall. I provided Mr. Fish with the name of a NetDMR contact at EPA to help resolve this these issues. Location: Interview/Self Monitoring Observation #: DM1-OB-002 Date: 10/25/2023 I asked the following Records/Reporting-related questions and Raymond Fish provided the responses (in bold), below: For each outfall, where are effluent samples collected? 001: right at outfall, grab samples and measure pH the same time laboratory samples are collected 002: right at outfall 003: right at outfall For Outfall 002, you have special requirements for reporting in DMRs: Along with the results of your monitoring, you must provide in DMRs the date and duration (in hours) of the storm event(s) samples; rainfall measurements or estimates (in inches) of the storm event that generated the sampled runoff; the duration between the storm event samples and the end of the previous measurable (greater than 0.1 inch rainfall) storm event; and an estimate of the total volume (in gallons) of the discharge samples. 4 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 Is the above being done for Outfall 002? No, I collect samples whenever I get the lab bottles. How are samples collected at Outfall 003: Grab samples from outfall. Process for recording pH measurements from outfalls? Record pH right away directly from outfalls. pH instrument used? Oakton pH Tester 2 Is it calibrated before each use? Yes. Is there a written calibration record? No. Are all grab samples cooled with ice, gel packs or refrigerated to <6C from the time of collection until analysis including shipping time, if applicable? Yes. Do you maintain a written record of pH sample results and retain these records? No. Location: Interview/O&M Observation #: DM1-OB-003 Date: 10/25/2023 I asked the following O&M-related questions and Raymond Fish provided the responses (in bold), below: Any bypasses in last 12 months? Not really. Back in September there was breach in berm along river and "water shortcutted to the river." The breach was repaired. Does the facility have standby power for all treatment units? Not needed, all gravity. Location: Interview/Minimize Exposure (Non-numeric Technology-based Effluent Limits) Observation #: DM1-OB-004 Date: 10/25/2023 I asked the following "Minimizing Exposure" questions and Raymond Fish provided the responses (in bold), below: Are manufacturing, processing, and material storage areas exposed to rain, snow, snowmelt, and runoff located inside or protected with storm resistant coverings. Yes, all under cover or bermed. Are you implementing any of the following measures: Use grading, berming, or curbing to prevent runoff of contaminated flows and divert run-on away from these areas: Yes; Clean up spills and leaks promptly using dry methods (e.g., absorbents) to prevent the discharge of pollutants: Yes, we have procedures to use saw dust to absorb spills and leaks; Store leaky vehicles and equipment indoors or, if stored outdoors, use drip pans and absorbents: Most vehicles are stored inside. Outside machines do not use drip pans, we need to get back to doing that. Use spill/overflow protection equipment: Yes, we have waste oil kits (300-gallon drum) inside buildings. Perform all cleaning operations indoors, under cover, or in bermed areas that prevent runoff and run-on and also that capture any overspray. Yes, all inside. Wastewater drains to oil water separator and is disposed of offsite. 5 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 Location: Interview/Good Housekeeping & Maintenance (Non-numeric Technology-based Effluent Limits) Observation #: DM1-OB-005/6 Date: 10/25/2023 I asked the following "Good Housekeeping" questions and Raymond Fish provided the responses (in bold), below: Are all dumpsters with a lid closed when not in use. Most of the time dumpsters are kept closed. Are salt storage piles, used for deicing or other commercial or industrial purposes, covered or enclosed in order to minimize pollutant discharges. Salt is kept inside. Are baghouses maintained to prevent the escape of dust from the system and immediately removing any accumulated dust at the base of the exterior baghouse? We remove dust, once a year. Otherwise, the system is enclosed and not exposed to water. Location: Interview/Spill Prevention and Training (Non-numeric Technology-based Effluent Limits Observation #: DM1-OB-007/8 Date: 10/25/2023 I asked the following Spill Prevention and Training questions, and Raymond Fish provided the responses (in bold), below: Do you implement procedures for material storage and handling, including the use of secondary containment and barriers between material storage and traffic areas to prevent the discharge of pollutants from these areas? Yes, we place universal spill kits around the Facility and supervisors call me when incidents occur. Are staff trained on procedures for expeditiously stopping, containing, and cleaning up leaks, spills, and other releases? Yes, staff and supervisors are trained to conduct minor cleanups. For major cleanups, they use universal spill kits and call me. Universal spill kits around the plant, around 3-4 of them. Are personnel trained in conducting stormwater inspections? I am the only one responsible for implementing stormwater SWPPP. Location: Interview/SWPPP Observation #: DM1-OB-009 Date: 10/25/2023 I asked Raymond Fish if the SWPPP is reviewed and updated as needed and within 90 days of the effective date of this permit? He said no and provided the Facility Spill Prevention, Control, and Countermeasure (SPCC) Plan dated, August 17, 2010 (see Appendix 3 - Document Log). I asked if there were any documents, other than the SPCC plan, regarding stormwater management at the Facility. Raymond Fish said no. I asked when the SPCC plan was last updated. He said it hasn't been updated since August 17, 2010. The Facility was required to review and update as needed, the SWPPP within 90 days of the effective date of this permit then submit to EPA, with a courtesy copy to the Menominee Indian Tribe of Wisconsin Environmental Services Department, a report within 14 days of the completion of the SWPPP indicating, a) the date the SWPPP was updated, or b) that the updated of the SWPPP was not completed, the reason for noncompletion, and the anticipated completion date. Raymond Fish confirmed there is no SWPPP and thus no 6 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 report certifying completion of the SWPPP. I reviewed the SPCC Plan, dated August 17, 2010, to determine if the plan contained the elements required for coverage under the Permit (page I-23). Findings are provided in bold below: Stormwater pollution prevention team (see Part I.E.4.2.1); Not included in SPCC plan. Site description (see Part I.E.4.2.2); SPCC plan missing General location map including entire site and all receiving waters for stormwater discharges. Also missing a Site map showing entire property boundary, extent of impervious surfaces, direction of stormwater flow for entire site, location of stormwater controls, location of all pollution sources across the entire site, and the location of all activities exposed to precipitation. Summary of potential pollutant sources (see Part I.E.4.2.3); Lists of sources limited to only tanks and drums. Description of control measures (see Part I.E.4.2.4); Control measures limited to only tanks and drums. Location: Interview/Stormwater Inspections and Monitoring Observation #: DM1-OB-010 Date: 10/25/2023 I asked Raymond Fish if stormwater inspections are conducted at least quarterly and, if at least once each calendar year, a routine inspection is conducted during a period when a stormwater discharge is occurring (page I-33). Raymond Fish said stormwater inspections are conducted "sometimes, but there are no written reports." I asked if visual assessments are conducted and documented once each quarter and if he collects a stormwater sample from each discharge point (except as noted in Part I.E.6.4) and conduct a visual assessment of each of these samples. Raymond Fish said "yes, but there are no written reports." I asked if the Facility conducted benchmark monitoring for all parameters in Part I.E.9.2 of the permit for four quarters in your first year of permit coverage, beginning in your first full quarter of permit coverage. Raymond Fish said "no", and he was not aware of benchmark monitoring requirement. Location: Physical Inspection Observation #: DM1-OB-011 Date: 10/25/2023 Weather: Overcast 59F (rained overnight) The physical inspection of the sawmill started at 2:00 pm (CT) and concluded at 3 pm (CT). The physical inspection observations are documented in the Photo Log (Appendix 2). Observation locations are identified on the Observation Location Map (Appendix 1). Photo(s) 1. MTES0338 2. MTES0339 3. MTES0340 4. MTES0341 5. MTES0342 6. MTES0343 7. MTES0344 8. MTES0345 9. MTES0346 10. MTES0347 7 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 11. MTES0348 12. MTES0349 13. MTES0350 14. MTES0351 15. MTES0352 16. MTES0353 17. MTES0354 18. MTES0355 19. MTES0356 20. MTES0357 21. MTES0358 22. MTES0359 SECTION III - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted by EPA. SECTION IV - 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 #: DM1-OB-001 Location: Interview/Records/Reporting Regulation and/or Permit Requirement Permit Part I.B.1. Final Numeric Effluent Limitations AOC: Self-reported pH violation in April 2023, appears to be a reporting error (reported "<6", lower limit is "=6"). Mr. Fish said it an issue with NetDMR. I recommended he contact NetDMR specialists at EPA to resolve the issue; pH values are always exactly 6 or 9 for Outfall 003. Mr. Fish said this is due to another issue with NetDMR for this outfall. I provided Mr. Fish with the name of a NetDMR contact at EPA to help resolve this these issues. AOC Reference #: DM1-OB-002 Location: Interview/Self Monitoring Regulation and/or Permit Requirement Permit Part I.B.1.b. Final Numeric Effluent Limitations AOC: For Outfall 002, the Facility has special requirements for reporting in DMRs: Along with the results of your monitoring, you must provide in DMRs the date and duration (in hours) of the storm event(s) samples; rainfall measurements or estimates (in inches) of the storm event that generated the sampled runoff; the duration between the storm event samples and the end of the previous measurable (greater than 0.1 inch rainfall) storm event; and an estimate of the total volume (in gallons) of the discharge samples. However, for Outfall 002, the Facility does not collect samples pursuant to the above requirement. Instead, samples are collected whenever bottles are provided by the lab. 8 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: The Facility does not maintain a written calibration record for pH; The Facility does not maintain a written record of pH sample results. 10/25/2023 AOC Reference #: DM1-OB-004 Location: Interview/Minimize Exposure (Non-numeric Technologybased Effluent Limits Regulation and/or Permit Requirement Permit part I.B.2.1.d. Minimize Exposure - Store leaky vehicles and equipment indoors or, if stored outdoors, use drip pans and absorbents AOC: The Facility does not use drip pans for vehicles and machines stored outside. AOC Reference #: DM1-OB-008 Location: Interview/Employee Training (Non-numeric Technologybased Effluent Limits) Regulation and/or Permit Requirement Permit part I.B.2.8. Employee Training - You must train all employees who work in areas where industrial materials or activities are exposed to stormwater, or who are responsible for implementing activities necessary to meet the conditions of this permit (e.g., inspectors, maintenance personnel), including all members of your stormwater pollution prevention team. AOC: Only supervisors are aware of stormwater pollution prevention. Maintenance staff are not trained in stormwater pollution prevention; Raymond Fish is the only one person responsible for and implementing the stormwater SWPPP. AOC Reference #: DM1-OB-009 Location: Interview/SWPPP Regulation and/or Permit Requirement Permit part I.E.4. Stormwater Pollution Prevention Plan (SWPPP) - You must review and update as needed, your SWPPP for your facility within 90 days of the effective date of this permit. You shall submit to EPA, with a courtesy copy to the Menominee Indian Tribe of Wisconsin Environmental Services Department, P.O. Box 910, Keshena, Wisconsin 54135-0910, a report within 14 days of the completion of the SWPPP indicating, a) the date the SWPPP was updated, or b) that the updated of the SWPPP was not completed, the reason for non-completion, and the anticipated completion date. AOC: The Facility did not review and update the SWPPP within 90 days of the effective date of this permit. The Facility confirmed there is no SWPPP and thus no report certifying completion of the SWPPP; The Facility does not have a SWPPP, developed pursuant to Permit Part I.E.4. Instead, the Facility provided an SPCC plan, dated August 17, 2010. I reviewed the SPCC plan to determine if it met any SWPPP requirements. Review observations include: Stormwater pollution prevention team description requirement not included in SPCC plan (Permit Part 9 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 I.E.4.2.1); SPCC plan missing site description requirements, including a general location map showing the entire site and all receiving waters for stormwater discharges. Also missing a site map showing entire property boundary, extent of impervious surfaces, direction of stormwater flow for entire site, location of stormwater controls, location of all pollution sources across the entire site, and the location of all activities exposed to precipitation (Permit Part I.E.4.2.2); Summary of potential pollutant sources requirement limited only to tanks and drums (Permit Part I.E.4.2.3); Description of control measures requirement limited only to tanks and drums (Permit Part I.E.4.2.4). AOC Reference #: DM1-OB-010 Location: Interview/Stormwater Inspections and Monitoring Regulation and/or Permit Requirement Permit part I.E.5.1.4. Stormwater Inspection Frequency - Inspections must be conducted at least quarterly. At least once each calendar year, the routine inspection must be conducted during a period when a stormwater discharge is occurring. Permit part I.E.5.1.5. Routine Facility Inspection Documentation - You must document the findings of your facility inspections and maintain this report with your SWPPP. Permit part I.E.6. Quarterly Visual Assessment of Stormwater Discharges - Once each quarter for the entire permit term, you must collect a stormwater sample from each discharge point and conduct a visual assessment of each of these samples. Permit part I.E.9.1.2. Benchmark Monitoring Schedule - Benchmark monitoring of stormwater discharges is required quarterly in the first and fourth year of permit coverage. AOC: The Facility does not conduct routine stormwater inspections at least quarterly and, and does not, at least once each calendar year, conduct a routine inspection during a period when a stormwater discharge is occurring (Permit part I.E.5.1.4.); Raymond Fish said stormwater inspections are conducted "sometimes, but there are no written reports." (Permit part I.E.5.1.5); The Facility conducts visual assessments once each quarter. However, there are no written reports documenting the visual assessments (Permit part I.E.6.3.); The Facility did not conduct benchmark monitoring for all parameters in Part I.E.9.2 of the permit for four quarters in your first year of permit coverage, beginning in your first full quarter of permit coverage. The Facility was not aware of the benchmark monitoring requirement. 10 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 AOC Reference #: DM1-OB-011 Location: Physical Inspection Regulation and/or Permit Requirement Section 301 (a) of the Clean Water Act, 33 U.S.C. 1311(a) AOC: Observed several discharges to the West Branch of the Wolf River from conveyances not covered in the Facility's NPDES permit, including discharges in the following Observation Location Areas: Location 8 (see photo MTES0344) Location 14 (see photos MTES0352, MTES0353, MTES0354, and MTES0356) Location 16 (see photo MTES0358) Location 17 (see photo MTES0359) AOC Reference #: DM1-OB-011 Location: Physical Inspection Regulation and/or Permit Requirement Section 301 (a) of the Clean Water Act, 33 U.S.C. 1311(a) AOC: Observed fresh spill staining from drum with unknown dark contents. Spill staining led to a nearby floor drain in the boiler blowdown room (see photo MTES0338 in Appendix 2 - Photo Log). The Facility's NPDES permit only authorizes the discharge of boiler blowdown from Outfall 001. AOC Reference #: DM1-OB-011 Location: Physical Inspection Regulation and/or Permit Requirement Permit part I.B.2.3.a. Maintenance Activities - You must maintain all control measures that are used to achieve the effluent limits in this permit in effective operating condition, as well as all industrial equipment and systems, in order to minimize pollutant discharges. This includes: i. Performing inspections and preventive maintenance of stormwater drainage, source controls, treatment systems, and plant equipment and systems that could fail and result in contamination of stormwater; iv. Cleaning catch basins when the depth of debris reaches two-thirds (2/3) of the sump depth and keeping the debris surface at least six inches below the lowest outlet pipe. AOC: Stormwater control measures were not maintained to minimize pollutant discharges, including: Damage to stormwater catch basin inlet cage in Location 11 (see photo MTES0349 in Appendix 2 - Photo Log); Stormwater inlet grates partially filled and blocked by debris in Location 12 (see photo MTES0350 in Appendix 2 - Photo Log); Hay bales seperated or offset, allowing stormwater discharges to pass without treatment in Locations 14 and 15 (see photos MTES0355 and MTES0356 in Appendix 2 - Photo Log). 11 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 SECTION V - CLOSING CONFERENCE Closing Conference We held the closing conference with Raymond Fish in his office at 02:55 PM (CT) on October 25, 2023. During the closing conference, I discussed the observations and preliminary Areas of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. I also discussed the timing for completing the inspection report. Before concluding the inspection, I asked if there were any questions. Mr. Fish had no questions, and we departed the Facility at 3:05 pm (CT) on October 25, 2023. Communication Log No additional information was requested or received by EPA Region 5 after exiting the Facility on October 25, 2023. SECTION VI - LIST OF APPENDICES 1. Observation Location Map 2. Photo Log 3. Document Log 12 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: APPENDIX 2: OBSERVATION LOCATION MAP 10/25/2023 13 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: APPENDIX 2: PHOTO LOG 10/25/2023 Floor Drain in Boiler Blowdown Room. MTES0338.JPG 10/25/2023 02:03 PM No CBI No PII Photographer: Dean Maraldo Location 1 on Observation Location Map. 44.98189166, -88.83002666 Observed fresh spill staining from drum with unknown contents. 14 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 Bark staging area. 10/25/2023 02:05 PM No CBI Location 2 on Observation Location Map. Trucks pull up to this area to load bark. No PII MTES0339.JPG Photographer: Dean Maraldo 44.981808, -88.830282 Runoff from Bark Pile area. MTES0340.JPG 10/25/2023 02:05 PM No CBI No PII Photographer: Dean Maraldo Location 3 on Observation Location Map. 44.981555, -88.83021833 Observed runoff from Bark Pile area flowing toward parking lot. 15 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 Continuation of runoff from Bark Pile area. 10/25/2023 02:06 PM No CBI No PII Location 4 on Observation Location Map. Runoff from Bark Pile area flowing toward parking lot. MTES0341.JPG Photographer: Dean Maraldo 44.98149, -88.829943 Continuation of runoff from Bark Pile area into parking MTES0342.JPG lot. 10/25/2023 02:09 PM No CBI No PII Photographer: Dean Maraldo Location 5 on Observation Location Map. 44.98145, -88.82980666 Observed runoff from Bark Pile area flowing across parking lot. Observed turbid flow with sheen. I asked Mr. Fish if he could measure pH in the flow. He measured a pH of 8.2 SU. 16 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 Continuation of runoff from Bark Pile area from parking MTES0343.JPG lot toward the West Branch of the Wolf River. 10/25/2023 02:12 PM No CBI No PII Photographer: Dean Maraldo Location 6 on Observation Location Map. 44.981338, -88.829395 Observed runoff from Bark Pile area flowing toward bridge over the West Branch of the Wolf River. Runoff from Bark Pile area flowing onto a bridge and into the West Branch of the Wolf River. MTES0344.JPG 10/25/2023 02:13 PM No CBI No PII Photographer: Dean Maraldo Location 7 on Observation Location Map. 44.981201, -88.829184 Runoff from Bark Pile area flowing across the bridge and into the West Branch of the Wolf River. Note turbidity and sheen in the runoff. 17 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 Runoff from Bark Pile area flowing over the side of the MTES0345.JPG bridge and into the West Branch of the Wolf River. 10/25/2023 02:14 PM No CBI No PII Photographer: Dean Maraldo Location 8 on Observation Location Map. 44.981174, -88.829204 Runoff from Bark Pile area flowing over the bridge and into the West Branch of the Wolf River. Note turbidity and sheen in the runoff. Outfall 001 to the West Branch of the Wolf River. MTES0346.JPG 10/25/2023 02:15 PM No CBI No PII Photographer: Dean Maraldo Location 9 on Observation Location Map. 44.98112333, -88.82917666 Outfall 001 (red arrow) discharges boiler blowdown water immediately east of the bridge referenced in the photos above. River flows from right to left through the bridge culvert. 18 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 Outfall 002 to the West Branch of the Wolf River. MTES0347.JPG 10/25/2023 02:16 PM No CBI No PII Photographer: Dean Maraldo Location 10 on Observation Location Map. 44.98137833, -88.828845 Outfall 002 (red arrow) discharges stormwater into the West Branch of the Wolf River. River flows toward another bridge (top of image) east of the bridge referenced in the photos above. View of Log yard stormwater pond and caged inlet. MTES0348.JPG 10/25/2023 02:23 PM No CBI No PII Photographer: Dean Maraldo Location 11 on Observation Location Map. Log yard 44.983896, -88.831491 View of Log yard stormwater pond (through brush at top of photo) and caged stormwater inlet (bottom right of photo. 19 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 Caged stormwater inlet. 10/25/2023 02:23 PM No CBI No PII Location 11 on Observation Location Map. Log yard Note damage to catch basin inlet cage. MTES0349.JPG Photographer: Dean Maraldo 44.983896, -88.831491 Stormwater inlet. MTES0350.JPG 10/25/2023 02:26 PM No CBI No PII Photographer: Dean Maraldo Location 12 on Observation Location Map. Log yard, location approximate Note stormwater inlet grates (red arrow) partially filled and blocked by debris. 20 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 Log yard. 10/25/2023 02:30 PM No CBI Location 13 on Observation Location Map. No PII MTES0351.JPG Photographer: Dean Maraldo 44.983933, -88.83263 Runoff from log decking area. MTES0352.JPG 10/25/2023 02:35 PM No CBI No PII Photographer: Dean Maraldo Location 14 on Observation Location Map. 44.981078, -88.832287 Observed runoff from log decking/staging area. Note, turbid discharge. 21 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 Runoff from log decking/staging. MTES0353.JPG 10/25/2023 02:36 PM No CBI No PII Photographer: Dean Maraldo Location 14 on Observation Location Map. 44.981078, -88.832287 Observed runoff from log decking/staging area flowing through hay bales and into the West Branch of the Wolf River. View of runoff from log decking/staging flowing to the MTES0354.JPG West Branch of the Wolf River. 10/25/2023 02:38 PM No CBI No PII Photographer: Dean Maraldo Location 14 on Observation Location Map. 44.98107833, -88.83228666 The West Branch of the Wolf River is at the top of the photo and the runoff from log decking/staging can be seen at the bottom left of the photo until obscured by vegetation. Raymond Fish said this was a new stormwater discharge to the river and not Outfall 003. Mr. Fish measured the pH of the discharge (8.2 SU). 22 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 Outfall 003 discharge from wet decking area. MTES0355.JPG 10/25/2023 02:41 PM No CBI No PII Photographer: Dean Maraldo Location 15 on Observation Location Map. 44.98103333, -88.831695 Note, hay bales seperated, allowing discharge to pass without treatment. The West Branch of the Wolf River is visible in the upper part of the photo. Hay bale structure at Location 14. MTES0356.JPG 10/25/2023 02:42 PM No CBI No PII Photographer: Dean Maraldo Location 14 on Observation Location Map. 44.98108, -88.832095 I returned to the Location 14 (runoff from log decking/staging) to document the condition of the hay bales. Note, the hay bales are offset allowing water to flow past without treatment. Once past the bales, the discharge flows a short distance to the West Branch of the Wolf River (top of photo). 23 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 Runoff from wet decking area. MTES0357.JPG 10/25/2023 02:44 PM No CBI No PII Photographer: Dean Maraldo Location 15 on Observation Location Map. 44.98110, -88.83149 Observed runoff from wet decking area, flowing toward bottom of the photo and to Outfall 003 and the West Branch of the Wolf River (photo MTES0355.jpg, above). Another stormwater discharge to the West Branch of the Wolf River. MTES0358.JPG 10/25/2023 02:44 PM No CBI No PII Photographer: Dean Maraldo Location 16 on Observation Location Map. 44.98103333, -88.83142833 Observed stormwater flowing from the yard in Location 16 and discharging to the West Branch of the Wolf River. The discharge is not identified as an outfall in the current permit. 24 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 Another stormwater discharge to the West Branch of the Wolf River. MTES0359.JPG 10/25/2023 02:46 PM No CBI No PII Photographer: Dean Maraldo Location 17 on Observation Location Map. 44.98113666, -88.830815 Observed a stormwater flowing from the yard in Location 17 and discharging to the West Branch of the Wolf River. The discharge is not identified as an outfall in the current permit. 25 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 APPENDIX 3: DOCUMENT LOG Document Type Document Name Contains Date Received CBI or PII Pages Permit wi0046868-5-mte- No 2021.pdf 10/23/2023 59 (obtained by EPA) Detailed Facility Report source: EPA-ECHO Website MTE_Detailed Facility No Report _ ECHO _ US EPA.pdf 10/23/2023 7 (obtained by EPA) Facility SPCC Plan, dated August 17, 2010 WI0046868_MTE No Provided by 17 Sawmill_SPCC Raymond Fish on Plan_20100817 10/25/2023 Summary of self-reported effluent pH data_20231017.pdf No pH sampling April-July 2023 10/17/2023 1 (obtained by EPA) Attached to Report? No No Yes Yes 26 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 27 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 28 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 29 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 30 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 31 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 32 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 33 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 34 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 35 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 36 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 37 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 38 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 39 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 40 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 41 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 42 of 44 Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 43 of 44 perm_fea ture_nmb parameter_ limit_value_type_ r desc desc 1 pH Concentration1 1 pH Concentration3 1 pH Concentration1 1 pH Concentration3 3 pH Concentration3 3 pH Concentration1 3 pH Concentration3 3 pH Concentration1 3 pH Concentration3 3 pH Concentration1 3 pH Concentration1 3 pH Concentration3 3 pH Concentration3 3 pH Concentration1 3 pH Concentration3 3 pH Concentration1 limit_value _nmbr 6 9 6 9 9 6 9 6 9 6 6 9 9 6 9 6 limit_v statistical_ba alue_q monitoring_p limit_unit se_short_des ualifier eriod_end_da dmr_value _desc c _code te _nmbr SU MINIMUM >= 3/31/2023 8.2 SU MAXIMUM <= 3/31/2023 8.2 SU MINIMUM >= 6/30/2023 8.6 SU MAXIMUM <= 6/30/2023 8.6 SU DAILY MX <= 1/31/2023 9 SU DAILY MN >= 1/31/2023 6 SU DAILY MX <= 2/28/2023 6 SU DAILY MN >= 2/28/2023 6 SU DAILY MX <= 3/31/2023 9 SU DAILY MN >= 3/31/2023 6 SU DAILY MN >= 4/30/2023 6 SU DAILY MX <= 4/30/2023 9 SU DAILY MX <= 5/31/2023 9 SU DAILY MN >= 5/31/2023 6 SU DAILY MX <= 6/30/2023 9 SU DAILY MN >= 6/30/2023 6 dmr_valu e_qualifi value_received er_code _date days_late violation_severity = 4/5/2023 No Violation Identified = 4/5/2023 No Violation Identified = 7/26/2023 5 No Violation Identified = 7/26/2023 5 No Violation Identified = 4/6/2023 No Violation Identified < 4/6/2023 Non-Reportable Noncompliance Effluent Violation = 4/6/2023 No Violation Identified = 4/6/2023 No Violation Identified = 4/5/2023 No Violation Identified = 4/5/2023 No Violation Identified = 7/26/2023 5 No Violation Identified = 7/26/2023 5 No Violation Identified = 7/26/2023 5 No Violation Identified = 7/26/2023 5 No Violation Identified = 7/26/2023 5 No Violation Identified = 7/26/2023 5 No Violation Identified Menominee Tribal Enterprises Sawmill Inspection Date: 10/25/2023 44 of 44