Document YodBxGgG2Z0KE617KDX7yNZD
REPORT OF COMPLIANCE SAMPLING INSPECTION (CSI)
AT Carroll Wastewater Treatment Facility (WWTF)
Carroll, IA 51002
NPDES NO: IA-0021377
May 15-18, 2023
BY U. S. ENVIRONMENTAL PROTECTION AGENCY
Region 7 Enforcement and Compliance Assurance Division (ECAD)
INTRODUCTION
I performed a Compliance Sampling Inspection (CSI) at the Carroll WWTF in Carroll, Iowa from July 17, 2023, through July 20, 2023. The inspection was authorized by Section 308(a) of the Federal Water Pollution Control Act, as amended. This narrative report presents the findings of the inspection.
PARTICIPANTS
Carroll WWTF Sean Kleespies, Wastewater Superintendent/Operator (712) 792-2560 Email: wastewater@cityofcarroll.com Paul Kersey, Operator
U. S. Environmental Protection Agency (EPA) Joe Heafner, Life Scientist (913) 551-7091 Email: heafner.joseph@epa.gov
PROCEDURES
On July 17, 2023, I arrived at the Carroll WWTF at 10:30 a.m. and introduced myself to Mr. Kleespies, presented my credentials, and explained the purpose and procedures of the inspection. These procedures included completing the Water Compliance Inspection Report (attachment 1), an EPA Region 7 Biosolids Checklist (attachment 2), a facility walk-through with photos (attachment 3), a check of the self-monitoring records, the collection of influent, effluent and biosolids samples, and an exit interview.
From July 17, 2023, through July 20, 2023, I used an ISCO model 3710 automatic composite sampler to collect a 24-hour composite sample of the influent after screening. I suspended a weighted length of new Tygon tubing into the influent channel before the screen, and I connected the other end to the sampler pump and programmed it to collect evenly spaced aliquots every 30 minutes into a clean Nalgene bottle, which was packed in ice. I returned each day to service the sampler. I removed the bottle, agitated its contents, and poured them into clean, pre-labeled containers for the analysis of Carbonaceous Biochemical Oxygen Demand (CBOD), NonFilterable Solids (NFS), Ammonia, Total Kjeldahl Nitrogen (TKN), Nitrate+Nitrite, Total Nitrogen (by calculation), Total Phosphorus (TP) and Metals. I measured the pH and temperature in a separate grab sample using a field meter.
From July 17, 2023, through July 20, 2023, I used an ISCO model 3710 automatic composite sampler to collect a 24-hour composite sample of the effluent after the Ultraviolet (UV) disinfection system before effluent discharges through Outfall 001. I suspended a weighted length of new Tygon tubing into the channel and connected the other end to the sampler pump and programmed it to collect evenly spaced aliquots every 30 minutes into a clean Nalgene bottle, which was packed in ice. I returned each day to service the sampler. I removed the collection bottle, agitated its contents, and poured them into clean, pre-labeled containers for the analysis of CBOD, NFS, Ammonia, TKN, Nitrate+Nitrite, Total Nitrogen (by calculation), TP and Metals. I measured the pH and temperature in a separate grab sample using a field meter.
On July 20, 2023, I took six grab samples at various locations from the biosolids storage lagoon mixed the samples together in a teflon lined bucket then then composited the into one 32-ounce glass jar. I shipped the sample of biosolids with the other collected samples on July 20, 2023. The biosolids were analyzed for Metals, percent solids, Total Phosphorus, and TKN.
On July 18, 2023 through July 19, 2023, I used an ISCO model 3710 automatic composite sampler to collect a 24-hour composite sample of the process wastewater from the Smithfield processing facility. I suspended a weighted length of new Tygon tubing into the wet well and connected the other end to the sampler pump and programmed it to collect evenly space aliquots every 15 minutes into a clean Nalgene bottle, which was packed in ice. I returned on July 19, 2023, to collect the sample. I removed the collection bottle, agitated its contents, and poured them into clean, pre-labeled containers for the analysis of CBOD, NFS, Ammonia, TKN, Nitrate+Nitrite, Total Nitrogen (by calculation), TP and Metals. I measured the pH and temperature in a separate grab sample using a field meter. I also collected a separate grab sample for analysis of Oil and Grease.
On July 19, 2023 through July 20, 2023, I used an ISCO model 3710 automatic composite sampler to collect a 24-hour composite sample of the process wastewater from the Carroll County Sanitary Landfill. I suspended a weighted length of new Tygon tubing into the wet well and connected the other end to the sampler pump and programmed it to collect evenly space aliquots every 15 minutes into a clean Nalgene bottle, which was packed in ice. I returned on July 20, 2023, to collect the sample. I removed the collection bottle, agitated its contents, and poured them into clean, pre-labeled containers for the analysis of CBOD, NFS, Ammonia, TKN,
2
Nitrate+Nitrite, Total Nitrogen (by calculation), TP and Metals. I measured the pH and temperature in a separate grab sample using a field meter.
On July 18, 2023, and July 19, 2023, I placed the samples I collected on ice in an ice chest, sealed the container and shipped it overnight to the EPA Region 7 Science and Technology Center (STC) for analysis. On July 20, 2023, I placed the samples I collected on ice in an ice chest sealed the container and hand delivered the samples to the EPA Region 7 STC for analysis. I followed Region 7 LSASD standard operating procedures in the collection, packaging, transportation, and handling of the samples. Field Sheets and Chain of Custody forms were electronically submitted each day following Region 7 procedures. Samples shipped on July 19, 2023, did not arrive to the STC until Monday, July 24, 2023, therefore CBOD was not analyzed.
FACILITY DESCRIPTION
The Carroll WWTF is owned and operated by the City of Carroll, Iowa. The legal description is the SW , NE , Section 30, Township 84 North, Range 34 West within Carroll County, Iowa. The physical address of the WWTF is 1400 E. Anthony Street, Carroll, IA 51401. The mailing address is 112 E. 5th Street, Carroll, IA 51401. The WWTF treats domestic wastewater from the city of Carroll. According to the NPDES permit there are two significant industrial users (Smithfield and the Carroll County Sanitary Landfill) that discharge to the WWTF. Final effluent from the WWTF is discharged to an unnamed tributary of the Middle Raccoon River.
The following are components of the WWTF. See attachment 4 for a layout map of the facility:
Headworks (which includes mechanical screening and grit removal) (2) primary clarifiers (1) trickling filter (not operational) (3) vertical loop reactor basins (activated sludge) (2) secondary clarifiers UV Disinfection (not in operation during the inspection) Peak Flow Equalization Basin
Biosolids are handled by the following sequence:
anaerobic Sludge Digestion (2) biosolids holding pond
According to Mr. Kleespies, the biosolids are land applied to agricultural ground by a contractor in the spring and fall of each year.
The facility has a designed average dry weather flow of 1.6 MGD with an actual flow average during the inspection of 0.762 MGD.
3
The WWTF's National Pollutant Discharge Elimination System (NPDES) Permit (IA-0021377) was issued on September 1, 2022 (attachment 5). The permit expires on August 31, 2027. The WWTF currently has four active compliance schedules contained in their NPDES permit. The first schedule is for the Iowa Nutrient Reduction Strategy. This is a report that evaluates the feasibility and reasonableness of reducing the amounts of total nitrogen and total phosphorus discharged into surface water. Progress reports are to be submitted annually on February 1st. Construction improvements should be completed by February 1, 2026, with optimization for nutrient reduction by August 1, 2026. The second schedule is for compliance with final effluent copper limits. Final compliance with limits is required by October 1, 2023. The third compliance schedule is for meeting final selenium and thallium limits. The compliance strategy must describe the steps the facility will take to comply with the selenium and thallium effluent limits no later than August 1, 2027. Finally, a compliance schedule with chloride limits. A Chloride Compliance Strategy shall be submitted by June 1, 2023, and must include the steps that will be taken to achieve compliance with effluent limits no later than August 1, 2027.
FINDINGS AND OBSERVATIONS
The following findings were noted during the plant and record review. A complete summary is given in the NPDES Compliance Inspection Report Checklist (attachment 1). These findings were discussed with Mr. Pedersen during the exit meeting.
Self-Monitoring Data Review:
I obtained a spreadsheet of the NetDMR data for the Carroll WWTF from January 2019, through March 2023, and reviewed the data. During the inspection, I also obtained an electronic copy of the facility's Discharge Monitoring Reports for the years 2019 - 2023.
Table 1A below represent the effluent violations noted during the review.
Table 1A: Effluent violations at Outfall 001 reported from January 2019 - July 2023
CARROLL EPA #:IA0021377
Outfall: 001
10/2020 2/2021 6/2021 7/2021 8/2021 9/2021 10/2021 11/2021
DO CU NH3-N NH3-N NH3-N NH3-N NH3-N TSS
AVERAGE - LBS/DAY
Limit
DMR
DAILY MAXIMUM -
LBS/DAY
Limit
DMR
7DAY - MG/L
Limit
DMR
52.1
56.0787788
192.7
198.8964900
45 79.0000000
AVERAGE - MG/L
Limit
DMR
DAILY MAXIMUM - MG/L DAILY MINIMUM - MG/L
Limit
DMR
Limit
DMR
AVERAGE - MGD
Limit
DMR
1.4 1.8613333 1.1 3.3011777
1 1.2859666 1.5 6.4431222 2.8 3.5918250
0.092 5
6.6
0.1530000 13.2000000 21.2500000
5 3.6200000
4
Sample Results
The analytical results from the sampling conducted during the inspection were received on June 15, 2022, from the Region 7 STC laboratory. This data was not discussed during the exit interview. The analytical results for BOD, NFS, TKN, Ammonia, Nitrates+Nitrites, Total Nitrogen, Total Phosphorus, metals, pH, and temperature of the samples I collected are presented in Tables 2 and 3 below. See attachment 6 for the analytical data packet for Activity JAH2317.
Table 2A: Analytical Results for Influent
Parameter
(July 18) 2300269-01
(July 19) 2300270-01
( July 20) 2300271-01
CBOD5 (mg/L)1
210
NA
202
NFS (mg/L)
172
252
243
TKN (mg/L)
36.7
40.0
29.0
Nitrate+Nitrate (mg/L)
0.118
0.0855
0.0660
Total Nitrogen
36.8
40.1
29.1
Ammonia (mg/L)
35.2
39.9
34.2
Total Phosphorus 6.34 7.57 6.58 (mg/L)
Copper (mg/L)
0.171
0.156
0.150
(C)2 Temperature 18.3 18.1 19.3
pH3
7.76
7.74
7.72
Flow
0.058
0.818
0.848
1mg/L = milligrams per liter 2 C = degrees Celsius, Temperature was measured in the field. 3 pH is not to be averaged; pH was measured in the field.
5
Table 2B: Analytical Results for Effluent Samples Collected During Inspection
Parameter
CBOD5 (mg/L)1 NFS (mg/L)
Ammonia (mg/L)
TKN (lbs/day) Nitrate+Nitrite
(mg/L) Total Nitrogen
(lbs/day) Total Phosphorus
(mg/L) Copper (mg/L) Temperature (C)2
pH2 Disolved Oxygen
(mg/L) Flow in MGD
(July 18) Sample # 2300269-02
ND4 ND4 ND4
8.12
16.6
17.8
0.657
0.012 19.2 7.72
6.41
0.779
(July 19) Sample 2300270-02
NA ND4 ND4
7.37
16.5
17.7
0.466
0.0115 19.8 7.64
6.02
0.752
(July 20) Sample 2300271-02
ND4 ND4 ND4
7.81
14.2
15.4
0.350
0.00984 20.2 7.68
6.14
0.756
Concentration Permit Limits3
40/25 45/30 For July 1.0/5.0 1940/3175
NA
NA
NA 0.092/0.076
NA 6.0-9.0 <5.0
NA
1mg/L = milligrams per liter. 2 oC = degrees Celsius, pH is not to be averaged, pH was measured in the field. 3Permit limits for CBOD and NFS are Monthly followed by 7-day Averages. Limits for Ammonia are
Daily Maximum followed by 30-day average. Copper limits are for Daily Maximum followed by Monthly
Average. 4ND= No Detection
As stated previously, samples shipped on July 19, 2023 (2300270-02), did not arrive to the STC for analysis on time, therefore, BOD5 was not analyzed. All other parameters were analyzed, and no violations of effluent limits were noted.
6
Table 2C:
Analytical Results for Biosolids Sample Collected During Inspection reported as
Milligrams per Kilograms (mg/kg)
Parameter
May 18 2300188-03
Aluminum
1820
Antimony
ND
Arsenic*
25.9
Barium
349
Beryllium
ND
Cadmium*
ND
Calcium
28800
Chromium
14.8
Cobalt
3.99
Copper*
407
Iron
7340
Lead*
8.74
Magnesium
5570
Manganese
4080
Molybdenum*
4.70
Nickel*
8.86
Potassium
3770
Selenium
16.9
Silver*
ND
Sodium
11400
Thallium
ND
Vanadium
ND
Zinc*
267
Mercury*
0.350
% Solids
2.67
*40 CFR Part 503 Metals
Results from sampling conducted during the inspection indicate that the facility was in compliance with effluent limits set in the NPDES permit for the sampling conducted during the inspection.
Biosolids (sludge)
As mentioned above, the facility utilizes two anerobic digesters and a storage basin to treat and store biosolids. Mr. Kleespies stated that they periodically dewater the storage pond. Water from the basin is pumped to the equalization basin then is fed back to the WWTF for treatment. Mr. Kleespies stated that biosolids are typically land applied in the spring and fall by a contractor.
7
During the inspection, I requested copies of the 2021 and 2022 annual biosolids reports. Mr. Kleespies provided the 2021 and 2022 reports which include sampling results and hauling records. I reviewed the sampling data, and it appears to meet the requirements of 40 CFR Part 503.
According to the 2021 and 2022 biosolids sampling results, the facility meets the Pathogen Reduction requirements for producing "Class B" biosolids anerobic digestion. Mr. Kleespies also stated that the vector attraction reduction (VAR) is met by reducing the voltile solids to at least 38%. The facility also meets VAR by injecting biosolids during land application. The 2021 biosolids report stated that approximately 381 dry tons of biosolids were land applied while 299 dry tons were land applied in 2022. In 2021, the land application rate equaled approximately 2.89 dry tons per acre and in 2022 the land application rate was 3.42 dry tons per acre.
Laboratory
The facility is certified (IA-Lab #187) by the IDNR for the analysis of BOD and TSS. During the inspection, I reviewed bench sheets for 2022 and 2023. During the review, I noted that the methods used for BOD and TSS appear to follow the methods required by 40 CFR Part 136. While reviewing laboratory procedures, I noted that the pH 7.0 buffer was expired and needed to be replaced. Mr. Kleespies also stated that all other regulatory analysis is conducted by a contract laboratory, Foundation Analytical Laboratory of Cherokee, Iowa. During the inspection, I requested the laboratory records to ensure that all analysis complied with requirements of 40 CFR part 136. My review indicated that all holding times were being met and that all analytical methods appeared to be in compliance with 40 CFR Part 136.
Collection System
During the inspection, I discussed the city's collection system with Mr. Kleespies. Mr. Kleespies estimated that the city has approximately 76 miles of sanitary sewer and includes several lift stations. Mr. Kleespies stated that the city cleans approximately 50 miles of sewer line per year with some "problem" areas cleaned more often.
Mr. Kersey and I observed four lift stations (photos 13-14) during the inspection. I observed the wet wells at the "Wal-Mart" and "Leachate" lift stations. I noted that all lift stations appear to be well maintained. I observed that each station is equipped with a SCADA communication system to alert the WWTF of issues at the station. I also noted that audible and or visual alarms were at each station.
Mr. Kleespies stated that the city does experience bypasses from the sanitary sewer system from time to time. He also stated that since it has been very dry the past few years, the bypasses have been very infrequent. Mr. Kleespies stated that the city response to each call and notes if it a private service line or the blockage is along the main.
8
Industrial Users
As mentioned above, the facility has two significant industrial users (Smithfield Foods and Carroll County Sanitary Landfill) that discharge process wastewater to the WWTF. Each industrial user has effluent limits for their respective process wastewater discharges that have been incorporated into the WWTF's NPDES permit. Below is a description of each industrial user and results of sampling that was conducted during the inspection.
Smithfield Foods
Smithfield Farmland is located at 401 N Grant Road, Carroll, Iowa. This facility processes pork into ham, for distribution. In addition to the domestic waste, process wastewater is sent to the Carroll wastewater treatment facility. A roto-screen is used to remove solids from the wastewater before being discharged into the sanitary sewer. The facility has experienced periodic exceedances of the limits. I received a violation report from IDNR that shows the effluent violations for Smithfield Foods since 2019.
Table 3A: Effluent violations at Smithfield reported from January 2019 - July 2023
SMITHFIELD FARMLAND CO RP. O utfall: 001
3/2019 4/2019 5/2019
7/2020 8/2020 10/2020 12/2020 5/2021
7/2021
9/2021 1/2022
3/2022 3/2023 7/2023
O &G O &G BO D5 FLO W TKN FLO W FLO W FLO W BO D5 FLO W TS S BO D5 TKN O &G BO D5 FLO W TKN O &G PH FLO W
AVERAGE -
LB S /DAY
Li m i t
DMR
DAILY MAXIMUM LB S /DAY
Limi DMR t
7DAY - MG/L
Li m i t
DMR
AVERAGE - MG/L
Li m i t
DMR
DAILY MAXIMUM MG/L
Limi DMR t
DAILY MINIMUM -
MG/L
Li m i t
DMR
AVERAGE - MGD
Li m i t
DMR
1500 4405.7884800 70 123.8927016
1500 2636.2323000
550 609.6723480
950 1536.5616000
1500 1605.4816920
70 71.1269394
1500 2853.6144000
70 119.0835240
500 1956.2000000 500 679.6400000
750 3884.4700000
500 564.0000000 500 524.0000000
0.13 0.1339548 0.13 14.0886419
9
Below is a table that represents the analysis of samples that were obtained during the inspection. See attachment 7 for the analytical data packet for Activity JAH23018.
Table 3B: Analytical Results for Samples Collected at Smithfield Foods During Inspection
Parameter
BOD5 (lbs/day) NFS (lbs/day) Oil and Grease
(mg/L) TKN (lbs/day)
pH Flow in MGD
(July 19) Sample # 2300271-02
NA 81.16
19.1
20.27 8.32 0.0998
Concentration Permit Limits3
1,000/1,500 550/950
500/750
55/70 6.0-10.5 0.13/0.195
As stated previously, samples shipped on July 19, 2023 (2300271-02) did not arrive to the STC for analysis on time, therefore, BOD5 was not analyzed. All other parameters were analyzed, and no violations of effluent limits were noted.
Carroll County Sanitary Landfill
The Carroll County Solid Waste Management Commission owns and operates the sanitary landfill located west of the city of Carroll, Iowa. The landfill discharges sanitary landfill leachate to the WWTF via a lift station located west of the landfill entrance. No treatment of the leachate occurs prior to discharging to the lift station. The facility has experienced periodic exceedances of the limits. I received a violation report from IDNR that shows the effluent violations for sanitary landfill since 2019.
10
Table 4A: Effluent violations at Carroll County Sanitary Landfill reported from January 2019 - July 2023
CARRO LL CO UNTY SO LID WASTE MANAGEMENT CO MMISSIO N O utfall: 001
1/2019 3/2019 4/2019 5/2019 6/2019 7/2019 9/2019 10/2019
2/2020 4/2020
9/2020 10/2020 1/2021
BO D5 BO D5 BO D5 BO D5 BO D5 BO D5 FLO W BO D5 FLO W BO D5 BO D5 FLO W BO D5 BO D5 BO D5
AVERAGE -
LB S /DAY
Li m i t
DMR
DAILY MAXIMUM LB S /DAY
Limi DMR t
7DAY - MG/L
Li m i t
DMR
AVERAGE - MG/L
Li m i t
DMR
DAILY MAXIMUM MG/L
Limi DMR t
DAILY MINIMUM -
MG/L
Li m i t
DMR
AVERAGE - MGD
Li m i t
DMR
50 78.9939780 50 64.4815440 50 51.6663000 50 53.8697280 50 116.7608340 50 119.2369800
50 78.9939780 50 128.9630880 50 51.6663000 50 53.8697280 50 116.7608340 50 119.2369800
50 108.9145620
50 108.9145620
50 107.6810760 50 1586.9435400
50 107.6810760 50 1586.9435400
50 131.3916960 50 55.8752200
50 233.0946600 50 72.2977920 50 165.1470120
0.025 0.0372033 0.025 0.0387516
Below is a table that represents the analysis of samples that were obtained during the inspection. See attachment 8 for the analytical data packet for Activity JAH2319
Table 4B: Analytical Results for Samples Collected at Carroll County Sanitary Landfill During Inspection
Parameter
BOD5 (lbs/day) NFS (lbs/day) Copper (ug/L) TKN (lbs/day)
pH Flow in MGD
(July 19) Sample # 2300271-02
14.4 23.8 20.4 1580 7.67 0.0025
Concentration Permit Limits3
50/50 NA NA NA 6.0-9.0 0.025/0.05
11
Operational Issues and Observations
1. I observed all areas of the WWTF during the inspection (photos 1-12). I noted that all units were operating and functional at the time of the inspection.
2. Federal regulations at 40 CFR 122.26(b)(14)(xi) requires that treatment works treating domestic sewage or any other sewage sludge or wastewater treatment device or system, used in the storage treatment, recycling, and reclamation of municipal or domestic sewage, including land dedicated to the disposal of sewage sludge that are located within the confines of the facility, with a design flow of 1.0 mgd or more to obtain a stormwater discharge permit to cover this type of industrial activity. As part of the stormwater permit, a facility is required to develop and implement a Stormwater Pollution Prevention Plan (SWPPP).
Summary
The facility has had previous effluent violations for Ammonia. Operational changes made by the facility, appeared to correct the effluent violations.
The facility needs to ensure that pH buffers used to calibrate laboratory equipment has not expired.
The facility must apply and receive an industrial stormwater permit in accordance with 40 CFR Part 122.26 (b)(14)(xi).
The facility has two significant industrial users that discharge to the sanitary sewer system. The facility must ensure that all industrial users comply with the effluent limitations set in the NPDES permit.
JOSEPH
Digitally signed by JOSEPH HEAFNER
Date: 2023.08.29
_H_E__A_F_N__E_R____1_7:_47_:4_1 _-05'00'
Joe Heafner
Life Scientist
NICOLE
Digitally signed by NICOLE MORAN
Date: 2023.08.30
M__O__R_A__N______0_8:2_1_:29_-05'00'
Nicole Moran
Section Chief
12
Attachments: 1. Water Compliance Inspection Report, Form 3560-3 (4 pages) 2. EPA Region 7 Biosolids Checklist (3 pages) 3. Digital Photographs with Photo Log (16 pages) 4. Facility Satellite Photos/Maps (1 page) 5. NPDES permit issued on September 1, 2022 (30 pages) 6. Laboratory Analytical Report for Activity JAH2317 (44 pages) 7. Laboratory Analytical Report for Activity JAH23018 (13 pages) 8. Laboratory Analytical Report for Activity JAH2319 ( 19 pages)
13