Document oeMv6vBQyJe2XrkLkwEEVZzpw

NPDES Inspection Report - Industrial User Name of industry and location: Control authority / Permit No. / Facility ID: Nature Soy, LLC 6123 Arapahoe Rd Boulder, CO 80303 Date of visit: City of Boulder Permit No. SIU 2024-1 NPDES ID: COPU00175 Inspection ID: 202412_COPU00175 NAICS Code: 311991 - Perishable Prepared Food Manufacturing Latitude: 40.0151145 N, Longitude: -105.210832W Time of visit: December 19, 2024 9:00 a.m. - 11:15 a.m. Name(s) / Affiliation of inspector(s): Jennifer Ferrando / U.S. Environmental Protection Agency, Region 8 (Lead) Monica Crosby / U.S. Environmental Protection Agency, Region 8 Stephanie Passarelli / U.S. Environmental Protection Agency, Region 8 Sheri Duren / Industrial Pretreatment Supervisor / City of Boulder James Werther / Water Quality Compliance Program Manager / City of Boulder Name / Title / Affiliation: Jorge Saenz / Facility Manager / Nature Soy, LLC Carl Gothmann / Corporate QA Manager / Nature Soy, LLC Report Review and Signature Drafter Name MONICA MONICA CROSBY Digitally signed by CROSBY 09:58:15 -07'00' Date: 2025.02.13 Monica Crosby Reviewer Name Jennifer Ferrando Supervisor Signature/Name EMILIO Digitally signed by EMILIO LLAMOZAS LLAMOZAS 10:26:29 -07'00' Date: 2025.02.13 Emilio Llamozas Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ECA-W-NW Denver, Colorado 80202 303-312-6196 Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ECA-W-NW Denver, Colorado 80202 303-312-6601 Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ECA-W-NW Denver, Colorado 80202 303-312-6407 Date 2/3/2025 Date 2/5/2025 Date 2/10/2025 Page 1 of 6 Inspection Description: On December 19, 2024, U.S. Environmental Protection Agency (EPA) inspectors Jennifer Ferrando, Monica Crosby, and Stephanie Passarelli (jointly referred to as EPA inspectors) and the City of Boulder (City) inspectors Sheri Duren and James Werther, conducted an industrial user inspection of Nature Soy, LLC, dba Keystone Natural Holdings ("Nature Soy" or "Facility"), in Boulder, Colorado, as part of a pretreatment compliance inspection (PCI) of the City. The City had identified Nature Soy as a Significant Industrial User (SIU) permitted to discharge to the City's sanitary sewer system under Permit Number 2024-01 (Permit). The inspection was unannounced. The inspection was conducted to evaluate the City's inspection procedures as part of the PCI. Mr. Werther was the facility lead for the walk-through inspection of the Facility, and the EPA inspectors observed and asked clarifying questions as necessary. Upon arriving to the Facility at approximately 9:00 a.m., the City introduced the inspectors to Nature Soy's Facility Manager, Jorge Saenz, as well as their Corporate QA Manager, Carl Gothmann. The EPA inspectors began the opening conference by presenting their credentials. The inspectors then explained the general purpose and procedures of the inspection. During the opening conference, Mr. Gothmann provided an overview of the Facility's operations, focusing on the processes that generate wastewater and the recent changes to the Facility's production. Following the opening conference, Mr. Gothmann and Mr. Saenz accompanied the group of inspectors on a facility walk-through, beginning with the outside storage areas for materials and used chemical containers and the Facility's mobile steam plant. The interior walkthrough focused on the processing of tempeh, plant-based tuna, and seitan products; chemical and waste storage areas; wastewater treatment; and the sampling point. To document and record the conversation and inspection observations, the inspectors took notes using bound checklists with questions applicable to the permitted industrial user. Photographs taken during the inspection are included in the attached photo log. The inspectors conducted a closing conference with Mr. Gothmann and Mr. Saenz and provided general observations and preliminary findings from the inspection. The EPA and City representatives left the Facility at approximately 11:15 a.m. 1. What does this industry produce? Nature Soy is a manufacturer and co-packer of vegan and vegetarian soy products, including tempeh, plantbased tuna, and seitan. The Facility used to manufacture tofu products, but recently stopped that production line. 2. How is the industry classified by the POTW? The City classified Nature Soy as an SIU because the Facility discharges an average of 25,000 gallons per day or more of process wastewater to the POTW, which is in accordance with 40 C.F.R. 403.3(v). 3. Have there been any significant changes in processes or flow? Within the past year, the Facility stopped their production of tofu and baked tofu products. The Facility recently added a plant-based tuna line, but this did not appear to create a significant change in process or flow. Page 2 of 6 4. What raw materials are used? The Facility uses the following materials: Soybeans Grains, wheat dough Flavorings (oils, garlic and onion powder, and soy sauce) Vinegar Flours (soy, wheat, garbanzo) Sanitation Chemicals 5. What processes are used to make the product(s)? Indicate any wastes generated and destination of wastes. Tempeh is made by culturing and controlling the fermentation process of soybeans. Soybeans are pressure cooked with spices and flavorings. Starter culture is then added and allowed to incubate for 24 hours. After that, the tempeh product is heated enough to kill growth and is sent to the Facility's packaging line. Seitan is a vegan meat substitute made entirely out of hydrated gluten. Various gluten doughs are used for this product and are mixed, marinated, steamed, and then packaged. The Facility had recently added the plant-based tuna line, and the EPA inspectors did not request details on this process. Wastewater is generated from soybean soaking, wasted soy whey, and cooling water. Any wastes generated from these processes are discharged to the floor drains which are plumbed to the Facility's wastewater treatment system. The third shift is dedicated to cleaning all process rooms, including all equipment. The sanitization chemicals are loaded onto a mobile cart. All wastewater is discharged to the floor drains which are plumbed to the wastewater treatment system. 6. Where is water used and what is the source of the water (city, well, river, etc.)? The Facility uses City water in its operations, specifically for soybean soaking, pressure cooking, wasted soy whey, and cooling water. Additionally, water is used daily for the cleaning of tanks and rinsing of equipment. 7. Describe the processes which discharge wastewater. Please refer to Sections 5 and 9 of the inspection report for a description of the processes that discharge wastewater. 8. Describe the sample location. Are the CA and industry using the same location? Nature Soy has one outfall, Outfall 01, that discharges to the City's collection system. This outfall receives Nature Soy's process wastewater which consists of all wastewaters generated through the manufacturing of vegan and vegetarian soy-based products. Facility staff use a time proportional sampler to collect composite samples from the Facility's pH neutralization tank ("Tank 3") (Photo 22). The City collects time proportional composite samples at the same sample location, using the City's sampling equipment. 9. Describe the treatment system in place. Floor drains in the production area capture all cleaning water and process wastewater and send it to a solids settling tank ("Tank 1") in the Facility's wastewater treatment room (Photos 9 and 21). Solids are transferred to a truck for disposal off-site. Supernatant from the solids settling tank is pumped into a decanting tank ("Tank 2"), where solids further settle out (Photo 19). Like Tank 1, any solids collected from Tank 2 are Page 3 of 6 Recommendation Ensure that practices are in place to prevent contaminated stormwater (from rinsing empty drums and buckets of cleaning supplies outside) from leaving the property or entering waterways. Finding 2 - Condensate entering stormwater drain The inspectors observed condensate from the mobile steam plant, located at the southeast corner of the building, dripping onto a metal plate below the steam plant before flowing northeast across the paved parking area and entering a storm drain (Photo 6). Permit Requirement Part C.1 of the Permit states, "No user or other person, shall discharge any sanitary sewage, industrial wastes, other polluted waters or other deleterious substance into or upon any public highway, street, sidewalk, alley, land, public or private property, stream, ditch or other watercourse or into any cesspool, stormwater sewer or private sewer or natural water outlet, within the city or in an area under the jurisdiction of the city, except where suitable treatment has been provided in accordance with provisions of applicable federal, state, and local laws." Recommendation To prevent stormwater contamination, it is recommended that the Facility evaluate the water quality of the mobile steam plant condensate that enters the storm drain or avoid discharging condensate to the storm drain. Finding 3 - Improper storage for hazardous materials At the time of the inspection, a battery was stored outside without cover or secondary containment (Photo 7). Permit Requirement Part C.1 of the Permit states, "No user or other person, shall discharge any sanitary sewage, industrial wastes, other polluted waters or other deleterious substance into or upon any public highway, street, sidewalk, alley, land, public or private property, stream, ditch or other watercourse or into any cesspool, stormwater sewer or private sewer or natural water outlet, within the city or in an area under the jurisdiction of the city, except where suitable treatment has been provided in accordance with provisions of applicable federal, state, and local laws." Recommendation To prevent stormwater contamination, it is recommended that all batteries stored outside be stored under cover. Finding 4- Inadequate spill protection At the time of the inspection, totes of soy sauce, and drums of and canola oil were observed to be without secondary containment (Photos 11, 12, 14, and 17-20). The drums of that were observed in the pretreatment room were near sewer drains (Photo 23). The totes of soy sauce and drums of canola oil that were in the production area were located near floor drains. Permit Requirement Part C.5 of the Permit requires the Facility to develop a Slug Discharge Control Plan that includes: a. Description of discharge practices, including nonroutine batch discharges b. Description of stored chemicals c. Procedures for immediately notifying the City of Boulder Industrial Pretreatment Program of slug discharges, including any discharge that would violate a prohibition under 40 CFR 403.5(b), with procedures for follow-up, written notification within five (5) days. d. Procedures to prevent adverse impact from accidental spills, including inspection and maintenance of Page 5 of 6 storage areas; handling and transfer of materials; loading and unloading operations; control of plant site runoff; worker training; building of containment structures or equipment; measures for containing toxic organic pollutants; and measures and equipment for emergency response. Corrective Action Ensure that the Facility's slug discharge control plan includes all chemicals and ingredients that are stored and handled at the Facility and that the City and Facility have determined what should have secondary containment to avoid contamination from spills and/or leaks. Page 6 of 6