Document rB6XE25nO6rn5aGOa1Ejpryka

US EPA Region 5 Pretreatment Compliance Inspection Kishwaukee Water Reclamation District, DeKalb, Illinois Control Authority Name and Address Kishwaukee Water Reclamation District 1301 Sycamore Rd DeKalb, IL 60115 Responsible Official Mark Eddington, Executive Director Inspection Participants Kishwaukee Water Reclamation District Mark Eddington, Executive Director Jason Robbins, Operations Manager Allison Yates, Laboratory Supervisor U.S. Environmental Protection Agency Valerie Dooling, Environmental Engineer/Scientist Eric Small, Physical Scientist Inspector: Eric Small, Physical Scientist, Water Enforcement and Compliance Assurance Branch Section 2 Small, Eric Digitally signed by Small, Eric Date: 2024.12.04 17:41:18 -06'00' Inspector Signature: __________________________________ Approver Name & Title: Ryan Bahr, Section Supervisor, Water Enforcement and Compliance Assurance Branch Section 2 Ryan Bahr Digitally signed by Ryan Bahr Date: 2024.12.04 18:30:26 -06'00' Approver Signature and Date:_______________________________________ IL0023027 Contents Kishwaukee Water Reclamation District September 2024 SECTION 1.0: INTRODUCTION ......................................................................................................... 3 SECTION 2.0: SITE BACKGROUND AND PRELIMINARY REVIEW ........................................ 3 SECTION 3.0: SUPPLEMENTAL DATA REVIEW/INTERVIEW ................................................. 4 A.Pretreatment Program Modification: ......................................................................................... 4 B. Industrial User (IU) Characterization: ..................................................................................... 4 C. Hauled Waste............................................................................................................................... 5 D. Application of Pretreatment Standards and Requirements ................................................... 6 E. Compliance Monitoring:............................................................................................................. 6 F. Enforcement:................................................................................................................................ 7 G. Other ............................................................................................................................................ 7 SECTION 4.0: FILE REVIEWS ............................................................................................................ 8 4.1 IU Identification................................................................................................................................ 8 4.2 Facility Information .......................................................................................................................... 8 4.3 IU Evaluation .................................................................................................................................. 10 A. Issuance of IU Control Mechanism ......................................................................................... 10 B. Application of IU Pretreatment Standards: ........................................................................... 12 C. CA Compliance Monitoring ..................................................................................................... 13 D. CA Enforcement Activities....................................................................................................... 14 E. IU Compliance Status ............................................................................................................... 14 SECTION 5.0: INDUSTRIAL USER SITE VISITS .......................................................................... 15 SECTION 6.0: POST-INSPECTION ACTIVITY ............................................................................. 19 SECTION 7.0: SUMMARY OF FINDINGS........................................................................................ 20 A. Areas of Concern ........................................................................................................................ 20 ATTACHMENT I: PHOTO LOG ATTACHMENT II: LIST OF DOCUMENTS RECEIVED FROM INSPECTION 2 IL0023027 Kishwaukee Water Reclamation District September 2024 SECTION 1.0: INTRODUCTION The U.S. Environmental Protection Agency (U.S. EPA) conducted a Federal Pretreatment Compliance Inspection (PCI) of the Kishwaukee Water Reclamation District (KWRD, the District, Facility, or POTW) on September 23rd, 24th, and 26th, 2024. The purpose of this inspection was to evaluate the procedures and implementation of KWRD's pretreatment program. KWRD has an National Pollutant Discharge Elimination System (NPDES) Permit issued by the Illinois Environmental Protection Agency on September 19, 2019 (Permit IL0023027). Special Condition 9 of the Permit outlines that KWRD shall implement an industrial pretreatment program and any subsequent modifications shall be approved by U.S. EPA Region 5. U.S. EPA's inspection consisted of: 1. Review of requested submittals prior to onsite inspection; 2. Interview and discussion with Kishwaukee Water Reclamation District staff; 3. Industrial User (IU) file reviews; and 4. Site visits at two IUs: Conex Cable, LLC. and DeKalb Plating Company, Inc. On September 23rd at 9:35 A.M., inspectors Eric Small and Valerie Dooling (EPA Inspection Team) arrived at the Kishwaukee Water Reclamation District, located at 1301 Sycamore Road in DeKalb, Illinois. The EPA Inspection Team met with Kishwaukee Water Reclamation District staff - Mark Eddington (Executive Director), Jason Robbins (Operations Manager), and Allison Yates (Laboratory Supervisor) - and escorted Mr. Small and Ms. Dooling into a large boardroom. EPA inspectors presented their credentials and began the inspection. EPA opened the inspection asking the District if there were any claims of Confidential Business Information, which the District indicated would likely not arise during the inspection. SECTION 2.0: SITE BACKGROUND AND PRELIMINARY REVIEW KWRD has one wastewater treatment plant, located to the north and west of the District's office building where the PCI was conducted. Based on information submitted to the EPA Inspection Team prior to inspection, the treatment plant wastewater flow is designed for 8.63 MGD and has an actual flow of 5.44 MGD. The facility does not have a collection system with a combined sewer. The wastewater treatment plant primary treatment process consists of screening and primary clarifiers, followed by secondary treatment using aeration tanks, and subsequently, prior to discharge to the South Branch of the Kishwaukee River, tertiary treatment via final clarifiers. Information indicates that Kishwaukee Water Reclamation District typically operates from 7:00 A.M. until 3:30 P.M. Mr. Eddington added that a major renovation of the POTW occurred in 2017, whereby a series of homes within the adjacent neighborhood were purchased to expand the operational capacity and storage of the Facility. The District maintains a service population of around 43,000primarily consisting of the City of DeKalb and recently added Kishwaukee Community College and the Village of Malta. Amounting to approximately 200,000 gallons per day, the Village of Malta began sending flow to the Facility on August 22, 2023, and Kishwaukee Community College began to send flow on August 31, 2023. The District is also exploring the potential for supplying services to 3 IL0023027 Kishwaukee Water Reclamation District September 2024 additional communities within DeKalb County in the future, though no formal agreements have been made at the time of the inspection. KWRD estimates that the full-time equivalent for personnel implementing the program is two, primarily consisting of two laboratory personnel, and estimates that the annual operating budget for the Control Authority's program is approximately $5,000. SECTION 3.0: SUPPLEMENTAL DATA REVIEW/INTERVIEW Kishwaukee Water Reclamation District staff submitted or stated the following during an initial interview: A. Pretreatment Program Modification: A local limits proposal was submitted to U.S. EPA Region 5 for review on September 27, 2021. The District has yet to hear whether this reevaluation has been approved. The preexisting local limits had been approved in 2014. KWRD added a contributing jurisdiction to the Facility's sewershed since the last Pretreatment Compliance Inspection, the Village of Malta, in addition to Kishwaukee Community College, located in unincorporated DeKalb County. In the agreement with the Village of Malta, KWRD and the Village agreed to the following language: "Malta agrees that it will comply with all KWRD ordinances and policies in effect on the date of this Agreement or as the same may be amended from time to time." B. Industrial User (IU) Characterization: The District collects sanitary waste from Northern Illinois University, which KWRD staff described as almost entirely domestic waste. The University's student population has declined in recent years and has thus reduced the amount of flow from this section of the collection system. KWRD utilizes Synagro to facilitate land application. Information indicates that sludge is dried onsite and subsequently applied onto agricultural fields. The District sends reports biannually to U.S. EPA describing the characteristics of the sludge. The District has evaluated facilities identified on the Toxic Release Inventory including Nehring Electrical Works Company, Unified Wire and Cable Inc., and Forge Group DeKalb LLC and made determinations that they are not categorical industrial users nor significant industrial users. KWRD does not have an Industrial Waste Survey scheduled and last conducted one in 2009. The District keeps abreast of industries within the sewershed by working with various departments within the City of DeKalb associated with zoning and new construction. New entities within the District's boundaries that could potentially qualify as significant industrial users are sent a pretreatment survey form to fill out and submit to the District for further evaluation. Conex Cable is in process of building another facility within DeKalb that the District is currently evaluating for potential pretreatment applicability. 4 IL0023027 Kishwaukee Water Reclamation District September 2024 C. Hauled Waste: Landfill leachate, septic, and grease hauler waste is accepted as a form of hauled waste at the Facility. The waste hauling program has helped the District remove phosphorus from their process by increasing the amount of carbon in the POTW's wastestream. The waste hauling program has been in practice at KWRD for approximately 10 years. Prior to utilizing the Facility's treatment system, the Facility requires that the truck driver provide their license, insurance, and that the truck is registered with the Illinois Department of Transportation. Landfill leachate is provided from the local DeKalb County landfill, which is operated by Waste Management. District staff indicated that Waste Management has its own NPDES permit that it has to abide by, detailing what can be discharged to KWRD. Landfill leachate from this process was formerly considered to be hazardous waste, but information indicates that leachate is no longer subject to hazardous waste regulations. During the interview, KWRD personnel delineated three processes for when hauled waste is accepted: (1) restaurant fat, oil, and grease is directed into anaerobic digestors and has its own dumping spot within the Facility, (2) high carbon loading and lower solids waste is directed into the Facility's side streams to reduce the nutrient load on the main treatment process, and (3) hauled septic waste is directed into a designated location within the Facility prior to being tested. The District has a fermenter that constantly operates to accommodate higher strength waste received by the Facility. The fermenter helps break down this waste to help form the Facility's primary sludge. As a prerequisite to accepting hauled waste, the Facility requires that a sample be collected and analyzed prior to it being considered. If possible, testing for this process is conducted at KWRD. Once approved to utilize KWRD's facility for hauled waste, haulers are directed to a particular location for each load brought into KWRD. Haulers utilizing KWRD's facility must provide manifests for each load to KWRD that include the following information: o Company information o Site hauled from o Gallons being hauled o Driver information and signature o Time and date of load pickup and drop off Restaurant grease that is accepted via hauled shipment to the Facility is codigested in the KWRD's anaerobic digestors. Septic waste received at the Facility is typically from nearby rural areas who are not connected to a collection system. High strength food processing waste is accepted by KWRD, typically consisting of out of specification products related to the production of pop, ice cream, candy, etc. Facility personnel indicated that Ferrara Candy - one of the waste haulers frequently utilizing the KWRD's facility - had hauled and discharged a load containing red dye into KWRD, which subsequently turned the South Branch of the Kishwaukee River red. This event took place approximately one year ago, per KWRD staff, and was the result of Ferrara Candy's 5 IL0023027 Kishwaukee Water Reclamation District September 2024 pretreatment system malfunctioning. The District paused acceptance of Ferrara Candy's hauled waste until the facility could prove to the District that their pretreatment system was operational and communicated a verbal warning to the facility. Information indicates that Ferrara Candy is located in Itasca, Illinois, and hauls waste between 2,500-5,000 gallons to the District approximately three times a week. KWRD maintains a small collection box at the front of its facility, whereby residents can discard fat, oil, and grease. Kishwaukee Water Reclamation District provided the following names of grease and septic haulers who provide hauled waste to the facility: All Around, A & P, B & L, Big John, Black Gold, G & L, Hallman, M & C Rentals, Mr. Outhouse, Tierra, United, Warfel's, Watson, Charles Environmental, Frinks, Hopkins, Premier, Van Wagoner, Bytec, Waste Management, Watson, and Meadowvale. D. Application of Pretreatment Standards and Requirements: KWRD defines an SIU as any of the following: o A facility subject to categorical pretreatment standards o A facility that discharges 25,000 gallons or more of process water per day o A facility that has the potential to cause an upset at the plant o A facility that contributes 5% or more of dry weather plant capacity. Information indicates that the District has adopted provisions related to the NPDES Pretreatment Streamlining Rule and incorporated them into the District's pretreatment ordinance. Kishwaukee Water Reclamation District has local limits for the following pollutants: cadmium, copper, lead, mercury, molybdenum, nickel, biochemical oxygen demand, total suspended solids, ammonia, and phosphorus. Information submitted indicates that these pollutants were identified from a previous local limits study. E. Compliance Monitoring: Historically, KWRD sampled more than once a year; however, due to minimal issues being identified from increased sampling events, a decision was made by the Control Authority to reduce KWRD sampling of IUs to yearly. KWRD sampled and inspected each of the District's three significant industrial users during the 2023 inspection year. Facility sampling conducted at the KWRD's lab consists of ammonia, pH, biochemical oxygen demand, phosphorus, and total suspended solids. KWRD has metals, cyanide, and organic media analyzed by Teklab, based out of Downers Grove, Illinois, and who maintains a full-service lab in Collinsville, Illinois. KWRD has used Teklab for approximately the last 1.5 years. All three significant industrial users within KWRD's domain have slug discharge control plans. KWRD generally conducts inspections at each of its significant industrial users every August or September (3rd Quarter) of each year. 6 IL0023027 Kishwaukee Water Reclamation District September 2024 F. Enforcement: KWRD defines Significant Noncompliance (SNC) as meeting one or more of the following criteria: o Chronic violations of wastewater discharge limits, defined here as those in which sixtysix percent (66%) or more of all the measurements taken for the same pollutant parameter taken during a six (6) month period exceed (by any magnitude) a numeric Pretreatment Standard or Requirement, including Instantaneous Limits as defined by this Ordinance; o Technical Review Criteria (TRC) violations, defined here as those in which thirty-three percent (33%) or more of wastewater measurements taken for each pollutant parameter during a six (6) month period equals or exceeds the product of the numeric Pretreatment Standard or Requirement including Instantaneous Limits, as defined by this Ordinance multiplied by the applicable criteria (1.4 for BOD, TSS, fats, oils and grease, and 1.2 for all other pollutants except pH); o Any other violation of a Pretreatment Standard or Requirement (Daily Maximum, longterm average, Instantaneous Limit, or narrative standard) that the District determines has caused, alone or in combination with other discharges, Interference or Pass Through, including endangering the health of POTW personnel or the general public; o Any discharge of a pollutant that has caused imminent endangerment to the public or to the environment, or has resulted in the Manager's exercise of its emergency authority to halt or prevent such a discharge; o Failure to meet, within ninety (90) days of the scheduled date, a compliance schedule milestone contained in an individual wastewater discharge permit or a general permit or enforcement order for starting construction, completing construction, or attaining final compliance. o Failure to provide within forty-five (45) days after the due date, any required reports, including baseline monitoring reports, reports on compliance with categorical Pretreatment Standard deadlines, periodic self-monitoring reports, and reports on compliance with compliance schedules; o Failure to accurately report noncompliance; or o Any other violation(s), which may include a violation of Best Management Practices, which the District determines will adversely affect the operation or implementation of the local pretreatment program. Facility personnel stated that there has not been any facilities in SNC within the last five years. KWRD has not issued a notice of violation in over a year to any of the three significant industrial users within its universe. G. Other KWRD is considering expanding, which could involve the construction of an additional facility on the southeast side of DeKalb to accommodate the increasing business interest and development along Interstate 88. The District does not maintain a combined sewer system. 7 IL0023027 Kishwaukee Water Reclamation District September 2024 Pretreatment records are retained by the District in excess of 15 years. Between 2019 and 2020, the Facility entered into a Compliance Commitment Agreement with Illinois Environmental Protection Agency to address ammonia nitrogen violations and newly introduced phosphorus limits. SECTION 4.0: FILE REVIEWS 4.1 IU Identification In this table, the IU Permit IU Name IU Number Type 185 Conex CIU Cable 110 DeKalb CIU Plating Company, Inc. 120 CST CIU Storage 4.2 Facility Information Avg total flow (gpd) Batch discharge of 500 gallons every 4-6 weeks. Second discharge of 32 gallons is in permit, but is actually nondischarging. 190 Avg process flow (gpd) 100 Visited During Audit? Yes Yes 40,535 12,798 No Reviewer Categorical Pretreatment Standard Valerie Dooling 40 C.F.R. Part 433 Metal Finishing Point Source Category and 40 C.F.R. Part 467 Aluminum Forming Point Source Category Eric Small 40 C.F.R. Part 413 Electroplating Point Source Category Valerie Dooling and Eric Small 40 C.F.R. Part 433 Metal Finishing Point Source Category Conex Cable 816 East Locust Street DeKalb, Illinois 60115 8 IL0023027 Kishwaukee Water Reclamation District September 2024 There are two lines at the facility: an Aluminum Clad Wire Line and a Magnetohydrodyamics (MHD) line. The first line entails the extrusion of aluminum wire onto steel wire. On this line, steel wire passes through an alkaline solution bath, rinse, and a heated borax bath before ultimately going through extruder die. At this point in the process, an aluminum rod is cleaned in a caustic bath and rinse before making contact with steel in extruder die within an extrusion machine. The aluminum clad steel (AS) wire is formed via this process, as water is cooled. Product wire is 10% aluminum and 90% steel and then respooled through a process. Wastestream A is steel wire alkaline rinse water that is recirculated through a particle filter, and the recirculation water is batch discharged to city sewer once per month. The steel alkaline bath is pumped to a holding tank and discharged by a contractor (Crystal Clean). Wastestream C is the aluminum caustic bath following pH neutralization. There has been no discharge of this wastestream to date, and information indicates that it is usually recirculated and returned to the system. Wastestream B is the aluminum rinse water, it is usually recycled to the bath, but it can be discharged to the city sewer following pH treatment. Wastestream D is contact cooling water from the AS extrusion process, and blowdown water from this process is usually recirculated. However, if necessary, it can be collected, evaluated for its pH, and discharged to the sewer. The second of the two lines, the MHD line, clads uncoiled steel - applying induction and coating to assist with zinc application during the process - prior to being steel being cooled and recoiled. Process water is also used in a closed loop refrigeration system within the facility. The refrigeration system is used to cool quench water and heat exchange return as it is stored in the pit. There is no discharge from the refrigeration system line. DeKalb Plating Company, Inc. 221 Grove Street DeKalb, Illinois 60115 DeKalb Plating Company operates a series of three plating lines comprised of zinc, copper, and brass. Chemicals utilized for the Facility include zinc, brass, copper, and trivalent chromium, as well as a series of miscellaneous acids, cyanides, and alkaline products. The discharge is continuous in nature and not subject to seasonal variation. Stagnant rinses are used throughout the process, as well as counterflow rinses for the purpose of reclaiming or concentrating the "dragout" from their plating tanks to replace evaporation and drag. Electrolytic recovery is also used in this process to recover metal ions in the water and atmospheric evaporation of plating solutions. Pretreatment of the facility's wastewater involves chlorination, which is employed on a daily or weekly basis for cyanide destruction. The facility also has pH adjustment. Wastewater from the facility should be comprised of the following constituents: cyanide, cadmium, chromium, and zinc. The facility has one process outfall in the permit, noted as Outfall 001, which is located at the end of the plating process near the south wall of the facility. 9 IL0023027 Kishwaukee Water Reclamation District September 2024 CST Storage 345 Harvestore Drive DeKalb, Illinois 60115 CST is a manufacturer of factory coated metal storage tanks, aluminum domes and specialty covers. There are three SIC codes associated with the processes: Porcelain Enamel on Steel, Fabricated Agricultural Feed Handling System, and Fabricated Metal Products. Outfall 001 coincides with process 1, which is a metal finishing line. Outfall 002 is Process 2 and entails a porcelain enameling line. Outfall 003 is the end of pipe on the south side of the facility. The enameling process water goes to a clarifier and is dewatered through a filter press. Process wastewater flow is generally between 6 A.M. and 5 P.M. Monday through Friday. The enamel sludge is disposed of by a waste management company. 4.3 IU Evaluation A. Issuance of IU Control Mechanism Applicable effluent limits Conex Cable - According to the facility's permit application, it discharges one wastestream (cleaning and etching rinse) and its production is 3000-5000 lbs/day, ultimately discharging one batch of 500 gallons every 4-6 weeks. Using these values, the categorical pollutant loadings limits would calculate to the following: Cr: 0.37 mg/L (daily [d]), 0.15 mg/L (monthly [m]); Cn: 0.20 mg/L (d), 0.07 mg/L (m); Zn: 1.02 mg/L (d), 0.42 mg/l (m); TTO:0.69 mg/L (d); O&G: 1.0mg/L (d&m). DeKalb Plating Company, Inc. - The average daily values for four consecutive monitoring days for lead and cyanide are noted in the permit under the monthly average column. Additionally, the permit does not include the 40 CFR 413 requirement that the facility monitor for and report a cadmium average daily value over a four consecutive day period. CST Storage - The Facility uses a metal finishing line as 433.15 Pretreatment Standards for Existing Sources (PSES). The limitation for nickel should be 3.98 mg/L, and there is a typo in the permit listing the limit as 3.96 mg/L. The permit file does not clearly state whether the facility is subject to PSES or PSNS standards for 40 CFR 466 Subpart A. The production data is not present for the porcelain enameling line and the effluent limits are mass-based. The local limits and metal finishing line values are consistent and the pollutants are all consistent. 10 IL0023027 Kishwaukee Water Reclamation District September 2024 Identification of pollutants to be monitored Conex Cable - The permit is written for two outfalls. Outfall 001 is Wastestream A and discharges. It requires sampling of local limits and not of categorical limits. Outfall 002 is considered the categorical wastestream and consists of the aluminum rinse, which had not been discharging. Outfall 002 requires sampling for the categorical limits, and it does not require sampling for local limits in addition to categorical. Process for seeking a waiver for pollutant not present or expected to be present Conex Cable - This language is in the Pretreatment Ordinance but not in the IU Permit. DeKalb Plating Company, Inc. - During review of the permit, the inspector did not identify language concerning this waiver requirement. This requirement, however, can be found in the pretreatment ordinance. CST Storage - This language is not observed in the permit but can be found in the Industrial Pretreatment Ordinance. Notification of significant change in discharge Conex Cable - There is a requirement to notify of accidental release and a reopener clause in case of significant changes to the wastewater but does not include the requirement to notify if there is a significant change. DeKalb Plating Company, Inc. - The permit does not include the requirement to notify the POTW for any change in character of the discharge. CST Storage - The permit does not explicitly state that it must notify the CA in event of significant change in discharge but does state that the permit may be modified in the event of a significant change in discharge. General Comments CST Storage - 40 CFR 466.01(b) is not applicable for industrial users that prepare or coat less than 1600 m2/day and which introduce less than 60,000 1/day of wastewater into a publicly owned treatment works. The facility has a max of 40,000 gpd, and it is not clear how much product is 11 IL0023027 Kishwaukee Water Reclamation District September 2024 enamel coated. Based on this information, it is not possible to determine whether the facility would be exempt from this category. B. Application of IU Pretreatment Standards: Calculation and application of categorical standards Conex Cable - If the facility discharges from the steel rinse line only (which they currently do), there are no discharges that would subject it to the aluminum forming category. DeKalb Plating Company, Inc. - The permit does not include the 40 CFR 413 requirement that the facility monitor for and report a cadmium average daily value over a four consecutive day period. CST Storage - There are two categorical lines. The metal finishing line has the correct calculation and application of its standards. There is not enough information in the file regarding the enamel coating production and whether 40 CFR 466.01(b) is applicable nor enough information to make a loading calculation for the enamel line. The local limits have been applied correctly. Classification by category/subcategory x Conex Cable - If the facility discharges from the steel rinse line only (which they currently do), it does not belong to the aluminum forming category. CST Storage - There is not enough information regarding enamel coating production and whether 40 CFR 466.01(b) is applicable. Application of limits for all regulated pollutants DeKalb Plating Company, Inc. - There does not seem to be a cadmium average daily value for four straight days as part of the permit's limitations. Calculation and application of production-based standards Conex Cable - According to the latest IU permit app, the IU production is 3000-5000 lbs/day multiplied by 5-6 production days/week; however, the permit limits are calculated based on 400,000 lbs/month (2650 lbs/day multiplied by 21 production days/month). This range is within the range given in the application, but it does not make the most stringent limits. If the facility only discharges 12 IL0023027 Kishwaukee Water Reclamation District September 2024 from the steel rinse - which they currently do - they are not categorical and do not need to apply production based effluent limits. CST Storage - There is not enough information regarding enamel coating production and whether the wastewater discharge is from metal preparation or coating to make a calculation for the enamel line. Application of most stringent limit Conex Cable - According to the latest IU permit app, the IU production is 3000-5000 lbs/day multiplied by 5-6 production days/week; however, the permit limits are calculated based on 400,000 lbs/month (2650 lbs/day multiplied by 21 production days/month). This range is within the range given in the application, but it does not make the most stringent limits. If the facility only discharges from the steel rinse - which they currently do - they are not categorical and do not need to apply production based effluent limits. General Comments CST Storage - The permit requires monitoring the facility's two lines at end of process and requires monitoring its local limits at end of pipe, all consistent with the requirement. C. CA Compliance Monitoring Sampling DeKalb Plating Company, Inc. - pH sampling was not observed for the 2022 and 2023 sampling reports. Sampling at frequency specified in approved program DeKalb Plating Company, Inc. - pH sampling was not observed for the 2022 and 2023 sampling reports. Analysis for all regulated parameters DeKalb Plating Company, Inc. - pH sampling was not observed for the 2022 and 2023 sampling reports. CST Storage - Monitoring for Metal Finishing from Outfall 001 is for all parameters, and monitoring for Outfall 002 - the porcelain line - is for all parameters and also additional ones (Cd, Cu, Ag). There 13 IL0023027 Kishwaukee Water Reclamation District September 2024 is no local limits monitoring conducted at Outfall 003 (Cd, Cu, Pb, Hg, Mb, Ni). pH is taken four times over the sample period, but it is not clear if pH taken is from Outfall 003. General Comments Conex Cable - In the last three years, the CA did not sample for TTOs, but results do have all the other local limits and categorical limits. EPA recommends that the city sample at least one permit term every 5 years. The facility does maintain a Toxic Organic Management Plan and TTO waiver. D. CA Enforcement Activities Identification of discharge violations CST Storage - The CA's monitoring of the IU showed a nickel effluent exceedance on the porcelain line. The nickel result was 1.57 mg/L on sample date of August 12, 2021, and the permit limit was 1.41 mg/L. All other violations in the IU's semiannual report were identified by the CA. Identification of monitoring/reporting violations Conex Cable - The pH holding time was not identified. CST Storage - Phosphorus, BOD, TSS, and ammonia are not observed as being sampled for semiannual reports from 2021, 2022, and June 27, 2023. Starting in January 2024, all but phosphorus of the aforementioned constituents was being sampled. By the latest report, July 2, 2024, all constituents including phosphorus were being sampled. A pH sample was also missing from the January 7, 2022 semi-annual report, which the facility noted on February 17, 2022 in a letter to the KWRD. E. IU Compliance Status Analysis by IU of all required pollutants in accordance with appropriate sampling techniques and analytical methods Conex Cable - The IU samples for its local limits (Cd, Cu, Pb, Ni, Hg, Mb and pH) semi-annually from Outfall 001 (the steel wire rinse, Wastestream A). It does not consider the steel wire rinse as categorical. It does not sample for the categorical limits and assumes that categorical limits should only apply to the aluminum rod rinse, which does not discharge. It does not sample for the categorical limits (Cr, CN, Zn or O&G) semi-annually; however, this is a requirement according to its permit. The IU sample for February 11, 2021 tested its pH at the laboratory after 2 hours and it had exceeded its hold time. The other pH samples were tested onsite and are within hold time. Note 14 IL0023027 Kishwaukee Water Reclamation District September 2024 that IUs that do not discharge a categorical wastestream are not considered categorical nor do they need to be required to test for categorical limits if they are not discharging. Reporting by IU on all required pollutantsCST Storage - Phosphorus, biochemical oxygen demand, total suspended solids, and ammonia are not observed as being sampled for semi-annual reports from 2021, 2022, and June 27, 2023. Starting in January 2024, all but phosphorus of the aforementioned constituents was being sampled. By the latest report, dated July 2, 2024, all constituents including phosphorus were being sampled. A pH sample was also missing from the January 7, 2022 semi-annual report, which the facility noted on February 17, 2022 in a letter to the KWRD. Resampling/reporting by IU within 30 days of knowledge of violation CST Storage - The inspector could not locate Notice of Violation-based resampling for Zinc in the December 19, 2022 results. There is a lack of clarity as to whether or not the IU self-reported this violation as well as the violations from December 2021 (nickel at Outfall #002). SECTION 5.0: INDUSTRIAL USER SITE VISITS DeKalb Plating Date of site visit: September 26, 2024 Inspection Participants: DeKalb Plating Bruce Miller, President EPA Region 5 Valerie Dooling, Environmental Engineer/Scientist Eric Small, Physical Scientist Kishwaukee Water Reclamation District Allison Yates, Laboratory Supervisor EPA Region 5 and KWRD personnel arrived at DeKalb Plating ("Facility") at 10:10 A.M. for an announced inspection and were greeted by Mr. Bruce Miller, President of the Facility. EPA staff showed Mr. Miller their credentials and proceeded to have Ms. Yates lead the inspection, which commenced with a Facility tour and ended with questions surrounding requisite industrial user documentation. The following inspection information was provided to EPA Region 5 staff and Ms. Yates: 15 IL0023027 Kishwaukee Water Reclamation District September 2024 General Plant Information: o The Facility generates a variety of plated products, specializing in lug production for U-Haul and door hinges for Raynor. Customers provide DeKalb Plating parts - typically comprising metal stampings with bare steel - which are subsequently plated and returned to the customer. o On occasion, the Facility subcontracts out larger plating jobs. o The Facility's SIC code is 3471: Electroplating, Plating, Polishing, Anodizing, and Coloring. o DeKalb Plating has two drains not plugged that are not located in the plating production area; inspection information indicates that all other drains are plugged. o Product out of specification - which Mr. Miller indicated rarely occurs - is collected by Republic Services. o The Facility is interested in becoming a non-significant categorical industrial user and believes it may qualify under KWRD's Pretreatment Ordinance No. 591. o The Facility has a singular outfall - identified as Outfall 001 - that is located along the southern wall adjacent to the water meter. Manufacturing Information: o The Facility is a Very Small Quantity Generator (VSQG) of hazardous waste, producing less than 220 pounds of hazardous waste per month. o Zinc is the primary element that customers ask DeKalb Plating to either plate or strip from their products; historically, the Facility also conducted plating activities with cadmium, though Mr. Miller indicated that practice had recently ended. o Tank bottoms from the zinc plating line contain residual sediment from the plating process, which is collected by Republic Services. o Sanitary waste is composed of bathrooms and sinks, which are non-process discharge. o The Facility's sampling point is located to the south of the copper/brass and zinc plating lines. o DeKalb Plating has a Slug Discharge Control Plan submitted to the Kishwaukee Water Reclamation District. o The Facility stores acid and cyanide in the northwestern portion of the Facility under lock and key. o Maintenance operations entail pump inspections to ensure they are operational as well as sweeping; Mr. Miller indicated that these operations occur as necessary. Pretreatment Information: o DeKalb Plating maintains two large tanks (1,500 and 3,000 gallon, respectively) within its operation that Facility staff use for pH adjustment. o Sampling for the plating line is conducted by Scientific Control Laboratories, Inc., based out of Chicago, Illinois. o The Facility conducts material reclamation operations on stagnant and counterflow rinses to help concentrate dragout from the Facility's plating tanks. 16 IL0023027 Kishwaukee Water Reclamation District September 2024 o Acid rinse water is reused when possible for alkaline rinsing to help achieve neutralization. o Cyanide Amenable to Chlorination and pH are the two wastewater characteristics analyzed for discharge to the KWRD. o Caustic soda is the primary treatment agent to help neutralize pH in the two buffering tanks. o Mr. Miller stated that holding tanks are inspected prior to being drained and discharged. o Rinse water from the zinc plating line currently in operation enters a chlorination tank prior to being pumped into the two buffering tanks. o Mr. Miller indicated that the pretreatment tanks could be drained every couple of days if very busy, but the tanks never reach capacity. o A sump pit is located next to the pH buffering tanks; once this water flows to the discharge point, a composite grab sample is taken. Conex Cable, LLC. Inspection Participants: Conex Cable Ariana Garcia, Environmental Engineer Brian Storr, Production Manager Abdus Mohammed, Production Supervisor EPA Region 5 Valerie Dooling, Environmental Engineer/Scientist Eric Small, Physical Scientist Kishwaukee Water Reclamation District Allison Yates, Laboratory Supervisor EPA Region 5 and KWRD personnel arrived at Conex Cable, LLC. ("Conex Cable" or "Facility") at 11:07 A.M. for an announced inspection and were greeted by two Facility representatives: Ms. Ariana Garcia (Environmental Engineer) and Mr. Brian Storr (Production Manager). EPA staff showed Ms. Garcia and Mr. Storr their credentials and proceeded to walk around the Facility with Ms. Yates. The EPA Inspection Team proceeded to observe Ms. Yates conduct the pretreatment inspection at the Facility after brief introductions between all parties. The following information was provided to EPA and KWRD by Facility staff: General Plant Information: o Conex Cable generates aluminum-clad steel wire and cable products, used by a variety of electric utilities and cable manufacturers. Mr. Storr stated that some of the company's most popular products are used as overhead aluminum-conductor 17 IL0023027 Kishwaukee Water Reclamation District September 2024 steel-reinforced cable lines for overhead power, transmission lines, and telecommunications. o Production for Conex Cable, LLC. is highly dependent on disasters; when disasters strike or are anticipated to occur (e.g., hurricane, fires), production at the Facility increases. o Mr. Storr stated that the process used to generate aluminum-clad steel wire and cable was developed in a California production facility around 1998. o Conex Cable is enhancing their operation within the greater DeKalb area, installing a new operation for galvanized steel wire at 1330 Locust Street. Inspection information indicates that Conex Cable will now have five buildings comprising their operations. o The Facility's SIC code is 3496: Miscellaneous Fabricated Wire Products. o Conex Cable operates three, eight-hour shifts per day and operates five-to-six days per week, depending on demand. o The Facility has a magnetohydrodynamics line that operates within a closed loop system. Manufacturing Information: o The Facility utilizes an ultrasonic cleaning process for processes above the Facility floor. o Material that is out of specification is sent to a supplier. o The aluminum-clad wire extrusion line consists of a series of wire cleaning steps before being extruded and cooled. o Prior to the extrusion process, steel wire is unwound and passed through an abrasive cleaning system. o Aluminum rod was formerly cleaned and washed at this Facility, but Mr. Stoff indicated that this process no longer occurs. o The extrusion process consists of drawing and stranding, followed by fouling. o The aluminum-clad steel wire operation is a continuous process while the Facility is open. o Mr. Storr estimated that the Facility generates between 20,000-30,000 lbs of wire per day. Pretreatment Information: o Floor scrubbing occurs weekly using a combination of water and Simple Green cleaning product. o The Facility has one holding tank that batch discharges every four-to-six weeks. o Mr. Storr said that there is a lead wastewater treatment operator for every shift. o First Environmental Laboratories, Inc., based out of Naperville, Illinois, conducts compliance sampling for the Facility. o Mr. Storr indicated that multiple samples are collected every two minutes via a glass beaker, with the assumption that flow is constant. Samples are subsequently refrigerated until shipped out via UPS. 18 IL0023027 Kishwaukee Water Reclamation District September 2024 o The Facility has a Slug Control Plan and a notification mechanism to alert the POTW if a slug does occur. o Rinse water from the steel wire cleaning process is changed out through production standards. o Mr. Storr stated that the pretreatment operation is checked daily to ensure it is working effectively. o The Facility has a 500-gallon filter tank where a flocculant is added prior to a filter paper and being pressed. o Two floor drains located within the aluminum-clad wire cleaning system direct wastewater to the pretreatment system. SECTION 6.0: POST-INSPECTION ACTIVITY Aside from materials submitted prior to the pretreatment compliance inspection, Ms. Yates emailed the following documents to Mr. Small after the inspection (with corresponding dates of receipt): Conex Cable, LLC. Permit Application (September 9, 2024) CST Storage Permit Application (September 9, 2024) DeKalb Plating Company Permit Application (September 9, 2024) Kishwaukee Water Reclamation District Notice of Violation to CST Storage issued on February 7, 2022 (September 30, 2024) Kishwaukee Water Reclamation District Notice of Violation to CST Storage issued on January 13, 2023 (September 30, 2024) Kishwaukee Water Reclamation District Notice of Violation to CST Storage issued on February 25, 2021 (September 30, 2024) DeKalb Plating SIU Inspection Form (November 25, 2024) Conex Cable SIU Inspection Form (November 25, 2024) 19 IL0023027 Kishwaukee Water Reclamation District September 2024 SECTION 7.0: SUMMARY OF FINDINGS A. Areas of Concern # 40 C.F.R. Part Site Background & Inspection Observations Report Section 1 40 C.F.R. During the visit to Conex Cable, Mr. Storr 403.8(f)(1)(iii)(B)(4) indicated that sampling is conducted every two minutes, assuming a constant flow. Unless flow can be determined as constant, this method 5 would suggest a time-proportional sampling. Information indicates that Conex Cable does not currently have a waiver to conduct time- proportional sampling. 2 NPDES Permit IL0023027 Information from the inspection and review of Special Condition 9.A.1 the District's intergovernmental agreement with Malta points to the following language concerning KWRD's ability to operate in Malta: "Malta agrees that it will comply with all KWRD ordinances and policies in effect on the date of 3 this Agreement or as the same may be amended from time to time." Based on this information, it is unclear whether KWRD has the proper legal authority to enforce the pretreatment program at industrial users in Malta. 40 C.F.R. Part File Reviews Report Section 3 40 C.F.R. 403.8(f)(1)(iii)(B)(3) Conex Cable - According to the facility's permit application, it discharges one wastestream (cleaning and etching rinse) and its production is 3000-5000 lbs/day, ultimately discharging one batch of 500 gallons every 4-6 weeks. Using these values, the categorical pollutant loadings limits would calculate to the following: Cr: 0.37 mg/L (daily [d]), 0.15 mg/L (monthly [m]); Cn: 0.20 mg/L (d), 0.07 mg/L (m); Zn: 1.02 mg/L (d), 0.42 mg/l (m); TTO:0.69 mg/L (d); O&G: 1.0mg/L (d&m). While this information aligned with KWRD's calculations, flow data used was a static value that did not reflect changing conditions at the facility. 4.3 A. 20 IL0023027 Kishwaukee Water Reclamation District September 2024 4 40 C.F.R. 403.8(f)(1)(iii)(B)(3) & DeKalb Plating Company, Inc. - The facility's permit lists four days of daily monitoring results for lead and cyanide in the monthly average column instead of in a four-day average column. The permit is also missing the four-day average cadmium value. 5 40 C.F.R. 403.8(f)(1)(ii) CST Storage - The permit file does not clearly state whether the facility is subject to PSES or PSNS standards for 40 CFR 466 Subpart A. 6 40 C.F.R. 433.16 & 40 CST Storage - The limitation for nickel should be C.F.R. 3.98 mg/L, and there is a typo in the permit 403.8(f)(1)(iii)(B)(3) listing the limit as 3.96 mg/L. 7 40 C.F.R. 403.8(f)(1)(ii) CST Storage - The production data is not & 40 CFR present for the porcelain enameling line and 403.8(f)(1)(iii)(B)(3) the effluent limits are mass-based. 8 40 C.F.R. 403.8(f)(1)(iii)(B)(4) Conex Cable, DeKalb Plating Company, Inc., and CST Storage - Language regarding the process for seeking a waiver for a pollutant not present or expected to not be present is in the Pretreatment Ordinance but is not in the IU Permit. 9 40 C.F.R. 403.12(j) and Conex Cable - The permit includes the 40 C.F.R. requirement to notify of accidental release 403.8(f)(1)(iii)(B)(4) and a reopener clause in case of significant changes to the wastewater but does not include the requirement to notify if there is a significant change. 10 40 C.F.R. 403.12(j) and DeKalb Plating Company, Inc. - The permit 40 C.F.R. does not include the requirement to notify the 403.8(f)(1)(iii)(B)(4) POTW for any change in character of the discharge. 11 40 C.F.R. 403.12(j) and CST Storage - The permit does not explicitly 40 C.F.R. state that it must notify the CA in event of 403.8(f)(1)(iii)(B)(4) significant change in discharge but does state that the permit may be modified in the event of a significant change in discharge. 12 40 C.F.R. 403.8(f)(1)(ii) Conex Cable - If the facility discharges from the steel rinse line only (which they currently do), there are no discharges that would subject it to the aluminum forming category. 4.3 A. 4.3 A. 4.3 A. 4.3 A. 4.3 A. 4.3 A. 4.3 A. 4.3 A. 4.3 B. 21 IL0023027 Kishwaukee Water Reclamation District September 2024 13 40 C.F.R. 403.8(f)(1)(ii) CST Storage - There is not enough information in the file regarding the enamel coating production and whether 40 CFR 466.01(b) is applicable nor enough information to make a loading calculation for the enamel line. 14 40 C.F.R. 403.8(f)(1)(ii) Conex Cable - According to the latest IU permit and 40 C.F.R. 403.6(c) app, the IU production is 3000-5000 lbs/day multiplied by 5-6 production days/week; however, the permit limits are calculated based on 400,000 lbs/month (2650 lbs/day multiplied by 21 production days/month). This range is within the range given in the application, but it does not make the most stringent limits. If the facility only discharges from the steel rinse - which they currently do - they are not categorical and do not need to apply production based effluent limits. 15 40 C.F.R. 403.8(f)(2)(v) DeKalb Plating Company, Inc. - pH sampling was not observed for the 2022 and 2023 sampling reports. 16 40 C.F.R. 403.8(f)(2)(v) CST Storage - Monitoring for Metal Finishing from Outfall 001 is for all parameters, and monitoring for Outfall 002 - the porcelain line - is for all parameters and also additional ones (Cd, Cu, Ag). There is no local limits monitoring conducted at Outfall 003 (Cd, Cu, Pb, Hg, Mb, Ni). pH is taken four times over the sample period, but it is not clear if pH taken is from Outfall 003. 17 40 C.F.R. 403.8(f)(2)(vii) CST Storage - The CA's monitoring of the IU showed a nickel effluent exceedance on the porcelain line. The nickel result was 1.57 mg/L on sample date of August 12, 2021, and the permit limit was 1.41 mg/L. All other violations in the IU's semiannual report were identified by the CA. 18 40 C.F.R. 403.8(f)(2)(vii) Conex Cable - The pH holding time was not identified in IU sampling reports reviewed. 19 40 C.F.R. 403.12(e)(1) Conex Cable - The IU samples for its local limits and 40 C.F.R. (Cd, Cu, Pb, Ni, Hg, Mb and pH) semi-annually 403.8(f)(2)(iv) from Outfall 001 (the steel wire rinse, Wastestream A). It does not consider the steel 22 4.3 B. 4.3 B. 4.3 C. 4.3 C. 4.3 D. 4.3 D. 4.3 E. IL0023027 Kishwaukee Water Reclamation District September 2024 wire rinse as categorical. It does not sample for the categorical limits and assumes that categorical limits should only apply to the aluminum rod rinse, which does not discharge. It does not sample for the categorical limits (Cr, CN, Zn or O&G) semi-annually; however, this is a requirement according to its permit. The IU sample for February 11, 2021 tested its pH at the laboratory after 2 hours and it had exceeded its hold time. The other pH samples were tested onsite and are within hold time. Note that IUs that do not discharge a categorical wastestream are not considered categorical nor do they need to be required to test for categorical limits if they are not discharging. 20 40 C.F.R. 403.12(e)(1), CST Storage - Phosphorus, biochemical oxygen 40 C.F.R. 403.8(f)(2)(iv), demand, total suspended solids, and ammonia and 40 C.F.R. are not observed as being sampled for semi- 403.8(f)(2)(vii) annual reports from 2021, 2022, and June 27, 2023. Starting in January 2024, all but phosphorus of the aforementioned 4.3 D. and E. constituents was being sampled. A pH sample was also missing from the January 7, 2022 semi-annual report, which the facility noted on February 17, 2022 in a letter to the KWRD. 21 40 C.F.R. 403.8(f)(5) and 40 C.F.R. 403.12(g)(2) CST Storage - The inspector could not locate Notice of Violation-based resampling for Zinc in the December 19, 2022 results. There is a lack of clarity as to whether or not the IU selfreported this violation as well as the violations from December 2021 (nickel at Outfall #002). 4.3 E. 23 IL0023027 Kishwaukee Water Reclamation District September 2024 Attachment I: Photo Log Kishwaukee Water Reclamation District Industrial User Inspections EPA Inspection Date: 09/26/2024 All photos taken by Eric Small, Physical Scientist, U.S. EPA Region 5 Camera: Pentax WG-1 GPS 1: IMGP0001.JPG Description: Discharge point for DeKalb Plating Company Location: Southern wall of DeKalb Plating Company Date/Time: September 26, 2024, 11:27 A.M. 24 IL0023027 Kishwaukee Water Reclamation District September 2024 2: IMGP0002.JPG Description: Filter press used as part of Conex Cable, LLC. wastewater setup Location: Southeastern corner of Conex Cable, LLC. Date/Time: September 26, 2024, 12:37 P.M. 3: IMGP0003.JPG Description: Discharge point for Conex Cable, LLC. Location: Southeastern corner of Conex Cable, LLC. Date/Time: September 26, 2024, 12:38 P.M. 25 IL0023027 Kishwaukee Water Reclamation District September 2024 4: IMGP0004.JPG Description: Closed loop process tank (foreground) and process water holding tank (background) Location: Southeastern corner of Conex Cable, LLC. Date/Time: September 26, 2024, 12:38 P.M. 26 IL0023027 Kishwaukee Water Reclamation District September 2024 Attachment II: List of Documents Received from Inspection A. 2006 USEPA Audit Checklist Attachment A - Pretreatment Program Profile (September 16, 2024) B. 2006 USEPA Audit Checklist Attachment B - Pretreatment Program Status Update (September 16, 2024) C. 2006 USEPA Audit Pages 13-27 Supplemental Data Review/Interview (September 17, 2024) D. Intergovernmental Cooperation Agreement Between the Kishwaukee Water Reclamation District and the Village of Malta (May 22, 2020) E. Kishwaukee Water Reclamation District Industrial User Discharge Permit No. 185 for Conex Cable, LLC. (Issued on January 8, 2020) F. Kishwaukee Water Reclamation District Industrial User Discharge Permit No. 110 for DeKalb Plating Company, Inc. (Issued on September 10, 2019) G. Kishwaukee Water Reclamation District Industrial User Discharge Permit No. 120 for CST Storage (Issued on October 19, 2021) H. Kishwaukee Water Reclamation District Hauled Waste Procedures (Date Unknown) I. Kishwaukee Water Reclamation District Industrial Pretreatment Enforcement Response Plan (Date Unknown) J. Kishwaukee Water Reclamation District Industrial Pretreatment Ordinance No. 591 (April 15, 2020) K. Illinois EPA NPDES Permit for Kishwaukee Water Reclamation District (Issued on September 19, 2019) L. Kishwaukee Water Reclamation District Ordinance No. 606 (March 15, 2023) M. Semi-Annual Compliance Report for Conex Cable, LLC (June 15, 2023) N. Semi-Annual Compliance Report for Conex Cable, LLC. (December 7, 2023) O. Ferrara Manifest from May 14, 2021 P. DeKalb Plating Company Permit Application (August 21, 2024) Q. Conex Cable, LLC. Permit Application (October 8, 2019) R. CST Storage Permit Application (August 27, 2021) S. Kishwaukee Water Reclamation District Notice of Violation to CST Storage issued on February 7, 2022 (September 30, 2024) T. Kishwaukee Water Reclamation District Notice of Violation to CST Storage issued on January 13, 2023 (September 30, 2024) U. Kishwaukee Water Reclamation District Notice of Violation to CST Storage issued on February 25, 2021 (September 30, 2024) V. DeKalb Plating SIU Inspection Form (September 17, 2024) W. Conex Cable SIU Inspection Form (September 20, 2024) 27 PRETREATMENT PROGRAM STATUS UPDATE INSTRUCTIONS: This attachment is intended to serve as an update of program status. It should be updated prior to each PCI based on information obtained from the most recent PCI and/ or audit and the last pretreatment program performance report. A. CA INFORMATION 1. CA name - Kishwaukee Water Reclamation District 2. a. Pretreatment contact b. Mailing address Allison Yates 1301 Sycamore Rd., DeKalb, Ill 60115 c. Title - Laboratory Supervisor d. Telephone number 815-758-3513 3. Date of last CA report to Approval Authority 2-13-24 Annual Pretreatment Report 4. Is the CA currently operating under any pretreatment-related consent decree, Administrative Order, compliance schedule, or other enforcement action? 5. Effluent and sludge quality a. List the NPDES effluent and sludge limits violated and the suspected cause(s). Parameters Violated Cause(s) none Yes No X b. Has the treatment plant sludge violated these tests? EP toxicity TCLP B. PRETREATMENT PROGRAM STATUS 1. Indicate components that were identified as deficient. Last PCI Date: a. Program modification b. Legal authority c. Local limits d. IU characterization e. Control mechanism f. Application of pretreatment standards g. Compliance monitoring h. Enforcement program i. Data management j. Program resources k. Other (specify) A-1 Yes No X Last Audit Date: Program Report Date: ATTACHMENT A: UPDATE PRETREATMENT PROGRAM STATUS UPDATE B. PRETREATMENT PROGRAM STATUS (Continued) 2. Is the CA presently in RNC for any of these violations? Data Source Yes No a. Failure to enforce against pass through and/or interference [RNC- X I][SNC] b. Failure to submit required reports within 30 days [RNC-I][SNC] X c. Failure to meet compliance schedule milestones within X 90 days [RNC-I][SNC] d. Failure to issue/reissue control mechanisms to 90 percent X of SIUs within 6 months [RNC-II] e. Failure to inspect or sample 80 percent of SIUs within X the last 12 months [RNC-II] f. Failure to enforce standards and reporting requirements [RNC-II] X g. Other (specify) [RNC-II] 3. List SIUs in SNC identified in the last pretreatment program performance report, PCI, or audit (whichever is most recent). Name of SIU in SNC Compliance Status Source none 4. Indicate the number and percent of SIUs that were identified as being in SNC* with the following requirements from the CA's last pretreatment program performance report. If the CA's report does not provide this information, obtain the information for the most recent four full quarters during the PCI. SNC Evaluation Period 0% Applicable pretreatment standards and reporting requirements *SNC defined by: 0% Self-monitoring requirements POTW 0% Pretreatment compliance schedules EPA 5. Describe any problems the CA has experienced in implementing or enforcing its pretreatment program. None ATTACHMENT A COMPLETED BY: TITLE: ATTACHMENT A: UPDATE A-2 DATE: TELEPHONE: PRETREATMENT PROGRAM STATUS UPDATE A-3 ATTACHMENT A: UPDATE PRETREATMENT PROGRAM PROFILE INSTRUCTIONS: This attachment is intended to serve as a summary of program information. This background information should be obtained from the original, approved pretreatment program submission and modifications and the NPDES permit. The profile should be updated, as appropriate, in response to approved modifications and revised NPDES permit requirements. A. CA INFORMATION 1. CA name - Kishwaukee Water Reclamation District 2. Original pretreatment program submission approval date 3. Required frequency of reporting to Approval Authority - 1x/year 4. Specify the following CA information. unsure Treatment Plant Name NPDES Permit Number Effective Date Expiration Date Kishwaukee Water Reclamation District IL0023027 10-1-19 9-30-24 Yes No 5. Does the CA hold a sludge permit or has the NPDES permit been modified to include sludge use and disposal requirements? X If yes, provide the following information. POTW Name Kishwaukee Water Reclamation District Issuing Authority IEPA Issuance Date 8-31-20 Expiration Date 7-31-25 Regulated Pollutants Land applied biosolids B. PRETREATMENT PROGRAM MODIFICATIONS 1. When was the CA's NPDES permit first modified to require pretreatment implementation? [WENDB-PTIM] unsure 2. Identify any substantial modifications the CA made in its pretreatment program since the approved pretreatment program submission. [403.18] Date Approved Nature of Modification Date Incorporated in NPDES Permit B-1 ATTACHMENT B: PROFILE PRETREATMENT PROGRAM PROFILE ATTACHMENT B: PROFILE B-2 PRETREATMENT PROGRAM PROFILE (Continued) C. TREATMENT PLANT INFORMATION INSTRUCTIONS: Complete this section for each treatment plant operated under an NPDES permit issued to the CA. 1. Treatment plant name 2. Location address Kishwaukee Water Reclamation District 1301 Sycamore Rd.-DeKalb, Ill 60115 3. a. NPDES permit number IL0023027 b. Expiration date 9-30-24 4. Treatment plant wastewater flows Desig 8.63 Actual 5.44 n MGD 5. Sewer system a. Separate 100% b. Combined 0% c. Number of CSOs - 0 6. a. Industrial Contribution (MGD) b. Number of SIUs Discharging to plant c. Percent industrial flow to plant 0.04 3 <1% 7. Level of treatment Type of Process(es) a. Primary Screening/ Primary clarifiers b. Secondary Aeration tanks c. Tertiary Final clarifiers 8. Indicate required monitoring frequencies for pollutants identified in NPDES permit. a. Metals b. Organics Influent (Times/Year) 4 1 Effluent (Times/Year) 4 1 Sludge (Times/Year) 4 1 Receiving Stream (Times/Year) 0 0 c. Toxicity testing 0 4x during 0 4x during permit cycle permit cycle d. EP toxicity e. TCLP 1 9. Effluent Discharge a. Receiving stream name b. Receiving stream classification c. Receiving stream use Kishwaukee River d. If effluent is discharged to any location other than the receiving stream, indicate where. N/A 10. 301(h) Waiver (ocean discharge) Yes No a. Applied for c. Date of application b. Granted d. Date approved or denied 11. Did the CA submit results of whole effluent biological toxicity testing as part of its NPDES permit application(s)? [122.21(j)(1) and (2)] N/A a. If yes, did the CA use EPA-approved methods? [122.21(j)(3)] b. Has there been a pattern of toxicity demonstrated? 12. Indicate methods of sludge disposal. Quantity of sludge Quantity of sludge a. Land application 2158 dry tons/year e. Public distribution b. Incineration dry tons/year f. Lagoon storage c. Monofill dry tons/year g. Other (specify) Yes No X X X dry tons/year dry tons/year dry tons/year B-3 ATTACHMENT B: PROFILE d. MSW landfill PRETREATMENT PROGRAM PROFILE (Continued) dry tons/year D. LEGAL AUTHORITY 1. a. Indicate where the authority to implement and enforce pretreatment standards and requirements is contained (cite legal authority). Permit and Pretreatment Ordinance b. Date enacted/adopted c. Date of most recent revision 2. Does the CA's legal authority enable it to do the following? [403.8(f)(1)(i-vii)] Yes No a. Deny or condition pollutant dischargers [403.8(f)(1)(i)] b. Require compliance with standards [403.8(f)(1)(ii)] X c. Control discharges through permit or similar means [403.8(f)(1)(iii)] X d. Require compliance schedules and IU reports [403.8(f)(1)(iv)] X e. Carry out inspection and monitoring activities [403.8(f)(1)(v)] X f. Obtain remedies for noncompliance [403.8(f)(1)(vi)] X g. Comply with confidentiality requirements [403.8(f)(1)(vii)] 3. a. Are all IUs located within the jurisdictional boundaries of the CA? X If no, list the name of contributing jurisdictions and the number of SIUs in those jurisdictions. Jurisdiction Name Number of CIUs Number of Other SIUs b. Has the CA negotiated all legal agreements necessary to ensure that pretreatment standards will be enforced in contributing jurisdictions? Yes No c. If yes, describe the legal agreements (e.g., intergovernmental contract, agreement, IU contracts, etc.). 4. If relying on contributing jurisdictions, indicate which activities those jurisdictions perform. a. IWS update b. Permit issuance c. Inspection and sampling d. Enforcement e. Notification of IUs f. Receipt and review of IU reports g. Analysis of samples h. Other (specify) ATTACHMENT B: PROFILE B-4 PRETREATMENT PROGRAM PROFILE (Continued) B-5 ATTACHMENT B: PROFILE PRETREATMENT PROGRAM PROFILE (Continued) E. IU CHARACTERIZATION 1. a. Does the CA have procedures to update its IWS to identify new IUs or changes in wastewater discharges at existing IUs? [403.8(f)(2)(i)] Yes No X b. Indicate which methods are to be used to update the IWS. Review of newspaper/phone book Onsite inspections X Review of water billing records X Permit application requirements X Review of plumbing/building permits Citizen involvement Other (specify) Self Reporting c. How often is the IWS to be updated? Yes No 2. Is the CA's definition of "significant industrial user" consistent within the language in the X Federal regulations? [403.3(t)(1)] If no, provide the CA's definition of "significant industrial user." F. CONTROL MECHANISM 1. a. Identify the CA's approved control mechanism (e.g., permit, etc.). b. What is the maximum term of the control mechanism? 2. Does the approved control mechanism include the following? [403.8(f)(1)(iii)] a. Statement of duration b. Statement of nontransferability c. Effluent limits d. Self-monitoring requirements Identification of pollutants to be monitored Sampling location Sample type Sampling frequency Reporting requirements Notification requirements Record-keeping requirements e. Statement of applicable civil and criminal penalties f. Applicable compliance schedule 3. Does the CA have a control mechanism for regulating IUs whose wastes are trucked to the treatment plant? 4. Does the program identify designated discharge point(s) for trucked or hauled wastes? [403.5(b)(8)] If yes, describe the discharge point(s) (including security procedures). permit 5 years Yes No X X X X X X X X X X X N/A Yes No X X ATTACHMENT B: PROFILE B-6 PRETREATMENT PROGRAM PROFILE (Continued) G. APPLICATION OF STANDARDS 1. Does the CA have procedures to notify all IUs of applicable pretreatment standards and any applicable requirements under the CWA and RCRA? [403.8(f)(2)(iii)] N/A specifically for each plant? 2. If there is more than one treatment plant, were local limits established X 3. Has the CA technically evaluated the need for local limits for all pollutants listed below? [WENDB-EVLL] [403.5(c)(1); 403.8(f)(4)] Partial technical evaluation (not all 10 pollutants evaluated)? Headworks Analysis Completed? Technically Evaluated? Local Limits Adopted? a. Arsenic (As) b. Cadmium (Cd) c. Chromium (Cr) d. Copper (Cu) e. Cyanide (CN) f. Lead (Pb) g. Mercury (Hg) h. Nickel (Ni) i. Silver (Ag) j. Zinc (Zn) Yes No Yes No Yes No X X X X X X X X X X X X X X X X X X X X k. Other (specify) Yes No X Yes No Local Limit (Numeric) H. COMPLIANCE MONITORING 1. Indicate compliance monitoring and inspection frequency requirements. Program Aspect Approved Program Requirement NPDES Permit Requirement State Requirement a. Inspections CIUs Other SIUs 1 x year 1 x year b. Sampling by POTW CIUs Other SIUs 1 x year 1 x year c. Self-Monitoring CIUs Other SIUs 2 x year 2 x year d. Reporting by IU CIUs 2 x year B-7 Minimum Federal Requirement ATTACHMENT B: PROFILE  Other SIUs PRETREATMENT PROGRAM PROFILE (Continued) I. ENFORCEMENT 1. Does the CA's program define "significant noncompliance?" If yes, is the CA's definition of "significant noncompliance" consistent with EPA's? [403.8(f)(2)(vii)] If no, provide the CA's definition of "significant noncompliance." Yes No X X Yes No 2. Does the CA have an approved, written ERP? [403.8(f)(5)] X 3. Indicate the compliance/enforcement options that are available to the POTW in the event of IU noncompliance. [403.8(f)(1)(vi)] a. Notice or letter of violation X f. Administrative Order X b. Compliance schedule X g. Revocation of permit X c. Injunctive relief h. Fines (maximum amount) X d. Imprisonment e. Termination of service Civil X Criminal Administrative J. DATA MANAGEMENT/PUBLIC PARTICIPATION 1. Does the approved program describe how the POTW will manage its files and data? Yes No Are files/records X computerized? X hard copy? both? 2. Are program records available to the public? 3. Does the POTW have provisions to address claims of confidentiality? [403.8(f)(2)(vii)] K. RESOURCES 1. What are the resource allocations for the following pretreatment program components? a. Legal assistance b. Permitting c. Inspections d. Sample collection e. Sample analysis f. Date analysis, review, and response g. Enforcement h. Administration Yes No X FTEs ATTACHMENT B: PROFILE B-8 TOTAL PRETREATMENT PROGRAM PROFILE (Continued) K. RESOURCES (Continued) 2. Identify the sources of funding for the pretreatment program. [403.8(f)(3)] a. POTW general operating fund b. IU permit fees c. Industry surcharges d. Monitoring charges e. Other (specify) L. ADDITIONAL INFORMATION ATTACHMENT B COMPLETED BY: TITLE: B-9 DATE: TELEPHONE: ATTACHMENT B: PROFILE THIS PAGE LEFT INTENTIONALLY BLANK SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW INSTRUCTIONS: Complete this section during the onsite visit based on CA activities since the last PCI or audit. Attach documentation where appropriate. Specific data may be required in some cases. A. CA PRETREATMENT PROGRAM MODIFICATION [403.18] Yes No 1. Did the CA make substantial changes to the pretreatment program that were not approved by X the Approval Authority (e.g., definitions, limits)? If yes, describe. 2. Is the CA in the process of modifying any approved pretreatment program component (including legal authority, local limits, DSS requirements, etc.)? If yes, describe. Submitted Local Limits proposal on 9-27-21 Yes No X 13 SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued) B. LEGAL AUTHORITY [403.8(f)(1)] 1. Are there any contributing jurisdictions discharging wastewater to the POTW? If yes, explain how the legal authority addresses the contributing jurisdictions. See Malta agreement 2. a. Has the CA updated its legal authority (e.g.,SUO) to reflect changes in the General Pretreatment Regulations? SUO updated March 2023 b. Did all contributing jurisdictions update their SUOs in a consistent manner? Explain Section 7 of Malta Agreement states: `Malta agrees that it will comply with all KWRD ordinances and policies in effect on the date of this Agreement or as the same may be amended from time to time.' 3. Does the CA experience difficulty in implementing its legal authority [i.e., SUO, interjurisdictional agreement (e.g., permit challenged, entry refused, penalty appealed)]? No If yes, explain. 14 SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued) C. IU CHARATERIZATION [403.8(f)(2)(i)&(ii)] 1. How does the CA define SIU? (Is it the same in contributing jurisdictions?) -Subject to categorical standards -Discharges 25,000 gallons or more of process water/day -Has a potential to cause an upset at the plant Or -Contributes 5% or more of dry weather plant capacity 2. How are SIUs identified and categorized (including those in contributing jurisdictions)? Discuss any problems. 40CFR 3. a) How and when does the CA update its IWS to identify new IUs (including those in contributing jurisdictions)? No current schedule-was last done in 2009 b. How and when does the CA identify changes in wastewater discharges at existing IUs (including contributing jurisdictions)? They are sampled and inspected every year. 4. How many IUs are currently identified by the CA in each of the following groups? ___ SIUs (as defined by the CA) [WENDB-SIUS] CIUs [WENDB-CIUS] - 3 Noncategorical SIUs ____ Other regulated noncategorical IUs (specify) _____ TOTAL D. CONTROL MECHANISM EVALUATION [403.8(f)(2)(i)&(ii)] 1. a. How many and what percent of the total SIUs are NOT covered by an existing, unexpired permit, or other individual control mechanism? [WENDB-NOCM] [RNC-II] 0 % b. How many control mechanisms were not issued within 180 days of the expiration date of the previous control mechanism? 15 [RNC-II] 0 SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued) 2. a. Do any UST, CERCLA, RCRA corrective action sites and/or other contaminated groundwater sites discharge wastewater to the CA? No b. How are control mechanisms (specifically limits) developed for these facilities? 3. a. Does the CA accept any waste by truck, rail, or dedicated pipe? Yes b. Is any of the waste hazardous as defined by RCRA? No If a. or b. above is yes, explain. Landfill leachate, septic and grease haulers. c. Describe the CA's program to control hauled wastes including a designated discharge point (e.g. number of points, control/security procedures). See "Hauled Waste Description and Procedures" form attached. E. APPLICATION OF PRETREATMENT STANDARDS AND REQUIREMENTS 1. What limits (categorical, local, other) does the CA apply to wastes that are hauled to the POTW (directly to the treatment plant or within the collection system, including contributing jurisdictions)? [403.1(b)(1)] 16 SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued) 2. How does the CA keep abreast of current regulations to ensure proper implementation of standards? [403.8(f)(2)(iii)] Meetings and talking to other wastewater people. 3. Local limits evaluation: [403.8(f)(4); 122.21(j)] a. For what pollutants have local limits been set? Cd,Cu,Pb,Hg,Mo,Ni, pH, BOD, TSS, Ammonia, and phosphorus. b. How were these pollutants decided upon? Local limits study c. What was the most prevalent/most stringent criteria for the limits? d. Which allocation method(s) were used? e. Has the CA identified any pollutants of concern beyond those in its local limits? No If yes, how has this been addressed? 17 SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued) E. APPLICATION OF PRETREATMENT STANDARDS AND REQUIREMENTS (Continued) 4. What problems, if any, were encountered during local limits development and/or implementation? Still waiting on a response from 2021 submission. F. COMPLIANCE MONITORING 1. a. How does the CA determine adequate IU monitoring (sampling, inspecting, and reporting) frequencies? [403.8(f)(2)(ii)&(v)] We used to sample more but over time it was the same results with almost no issues so dropped down to yearly. b. Is the frequency established above more, less, or the same as required? Same 2. In the past 12 months, how many and what percentage of SIUs were: [403.8(f)(2)(v)][RNC-II] Define the 12 month period 1-1-23 to 12-31-23 . a. Not sampled or not inspected at least once [WENDB-NOIN] 0% b. Not sampled at least once 0% c. Not inspected at least once (all parameters)? 0% If any, explain. Indicate how percentage was determined 3. Indicate the number and percent of SIUs that were identified as being in SNC* with the following requirements from the CA's last pretreatment program performance report. SNC Evaluation Period: 0% Applicable pretreatment standards and reporting requirements 0% Self-monitoring requirements 0% Pretreatment compliance schedules *SNC defined by POTW and USEPA 18 SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued) F. COMPLIANCE MONITORING (Continued) 4. What does the CA's basic inspection include? (Process areas, pretreatment facilities, chemical and hazardous waste storage areas, chemical spill prevention areas, hazardous waste handling procedures, sampling procedures, laboratory procedures, and monitoring records.) [403.8(f)(2)(v)&(vi)] All of the above. 5. Who performs CA's compliance monitoring analysis? -Metals Teklab -Cyanide Teklab . -Organics Teklab . -Other (specify) We do ammonia, pH, BOD, P and TSS in house. 6. What QA/QC techniques does the CA use for sampling and analysis (e.g., splits, blanks, spikes), including verification of contract laboratory procedures and appropriate analytical methods? [403.8(f)(2)(vi)] Blanks and standards 7. Discuss any problems encountered in identification of sample location, collection, and analysis. N/A 8. Did any IUs notify the CA of a hazardous waste discharge? No F. COMPLIANCE MONITORING 9. a. How and when does the CA evaluate/reevaluate SIUs for the need for a slug control plan? [403.8(f)(2)(v)] All currently have a slug control plan. 19 SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued) b. How many SIUs were not evaluated for the need to develop slug discharge control plans in the last two years? 0 20 SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued) G. ENFORCEMENT 1. What is the CA's definition of SNC? [403.8(f)(2)(vii)] A. Significant Noncompliance. An industrial user is in significant noncompliance if its violation meets one or more of the following criteria 1. Chronic violations of wastewater discharge limits, defined here as those in which sixty-six percent (66%) or more of all the measurements taken for the same pollutant parameter taken during a six (6) month period exceed (by any magnitude) a numeric Pretreatment Standard or Requirement, including Instantaneous Limits as defined by this Ordinance; 2. Technical Review Criteria (TRC) violations, defined here as those in which thirty-three percent (33%) or more of wastewater measurements taken for each pollutant parameter during a six (6) month period equals or exceeds the product of the numeric Pretreatment Standard or Requirement including Instantaneous Limits, as defined by this Ordinance multiplied by the applicable criteria (1.4 for BOD, TSS, fats, oils and grease, and 1.2 for all other pollutants except pH); 3. Any other violation of a Pretreatment Standard or Requirement (Daily Maximum, long-term average, Instantaneous Limit, or narrative standard) that the District determines has caused, alone or in combination with other discharges, Interference or Pass Through, including endangering the health of POTW personnel or the general public; 4. Any discharge of a pollutant that has caused imminent endangerment to the public or to the environment, or has resulted in the Manager's exercise of its emergency authority to halt or prevent such a discharge; 5. Failure to meet, within ninety (90) days of the scheduled date, a compliance schedule milestone contained in an individual wastewater discharge permit or a general permit or enforcement order for starting construction, completing construction, or attaining final compliance. 6. Failure to provide within forty-five (45) days after the due date, any required reports, including baseline monitoring reports, reports on compliance with categorical Pretreatment Standard deadlines, periodic self-monitoring reports, and reports on compliance with compliance schedules; 7. Failure to accurately report noncompliance; or Any other violation(s), which may include a violation of Best Management Practices, which the District determines will adversely affect the operation or implementation of the local pretreatment program 2. RP implementation: [403.8(f)(5)] Not sure on date a. Status b. Problems with implementation. none c. Is the ERP effective and does it lead to compliance in a timely manner? Provide examples if any are available. Yes. Rarely any issues but when there are the industries resample in a timely manner and report their results and possible cause of the permit violation. 21 SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued) 3. a. Does the CA use compliance schedules? [403.8(f)(1)(iv)(A)] b. If yes, are they appropriate? Provide examples. 4. Did the CA publish all SIUs in SNC in the largest daily newspaper in the previous year? [403.8(f)(2)(vii)] If yes, attach a copy. If no, explain. There were none to report. 5. How many SIUs are in SNC with self monitoring requirements and were not inspected and/or sampled (in the four most recent quarters? [WENDB] None 6. a. Has the CA experienced any problems since the last inspection (interference, pass through, collection system problems, illicit dumping of hauled wastes, or worker halth and safety problems) caused by industrial discharges? No H. DATA MANAGEMENT/PUBLIC PARTICIPATION 1. How is confidential information handled by the CA? [403.14] 2. How are requests by the public to review files handled? H. DATA MANAGEMENT/PUBLIC PARTICIPATION 3. Describe whether the CA's data management system is effective in supporting pretreatment implementation and enforcement activities. 22 SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued) 4. How does the CA ensure public participation during revisions to the SUO and/or local limits? [403.5(c)(3)] 5. Explain any public or community issues impacting the CA's pretreatment program. 6. How long are records maintained? 15 plus years I. RESOURCES [403.8(f)(3)] 1. Estimate the number of personnel (in FTEs) available for implementing the program. [Consider: legal assistance, permitting, IU inspections, sample collection, sample analysis, data analysis, review and response, enforcement, and administration (including record keeping and data management)]. There are 2 of us in the lab for this. We only have 3 CIU's who have been around for a very long time. They have a long record of compliance so this is not terribly time consuming. 23 SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued) I. RESOURCES (Continued) 2. Does the CA have adequate access to monitoring equipment? (Consider: sampling, flow measurement, safety, transportation, and analytical equipment.) Yes 3. a. Estimate the annual operating budget for the CA's program. $5000 b. Is funding expected to: stay the same, increase, decrease (note time frame; e.g., following year, next 3 years, etc.)? Discuss any changes in funding. Stay the same 4. None Discuss any problems in program implementation which appear to be related to inadequate resources. 5. a. How does the CA ensure personnel are qualified and up-to-date with current program requirements? Go to seminars and keep in touch with other pretreatment people. b. Does the CA have adequate reference material to implement its program? Yes J. ENVIRONMENTAL EFFECTIVENESS/POLLUTION PREVENTION 1. a. How many times were the following monitored by the CA during the past year? NPDES Influent Metals 4 Priority Pollutants 1 Biomonitoring 0 TCLP 1 EP toxicity Other (specify) Actual (+ or - compared to NPDES) Metals 4 Priority Pollutants 1 Biomonitoring 0 TCLP 1 EP toxicity Effluent 4 1 4 1 4 1 4 1 Sludge 4 1 0 1 4 1 0 1 24 Ambient (Receiving Water) 4 4 SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued) Other (specify) Explain any differences between when the CA is monitoring and what the NPDES permit requires. N/A 2. a. Has the CA evaluated historical and current data to determine the effectiveness of pretreatment controls on: -Improvements in POTW operations - Loadings to and from the POTW - NPDES permit compliance - Sludge Quality b. Has the CA documented these findings? d. If they have been documented, what form does the documentation take? Explain. (Attach a copy if appropriate) 3. If the CA has historical data compiled concerning influent, effluent, and sludge sampling for the POTW, what trends have been seen? (Increases in pollutant loadings over the years? Decreases? No change?) There doesn't seem to be a lot of change in our influent and effluent. Some of our sludge numbers have decreased. Nothing appears to be increasing. Most results are BDL and always have been 4. Has the CA investigated the sources contributing to current pollutant loadings to the POTW (i.e. the relative contributions of toxics from industrial, commercial, and domestic sources)? If yes, what was found? They are sampled yearly and industrial flow is very minimal. 5. a. Has the CA attempted to implement any kind of public education program? 25 SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued) We have had an open house and tours are given throughout the year to classes or anyone who would like one. b. Are there any plans to initiate such a program to educate users about pollution prevention? Explain. 6. What efforts have been taken to incorporate pollution prevention into the CA's pretreatment program (e.g., waste minimization at IUs, household hazardous waste programs)? We have a grease collection box for people to drop off in so they do not pour it down the drain. 7. Does the CA have any documentation concerning successful pollution prevention programs being implemented by IUs (e.g. case studies, sampling data demonstrating pollutant reductions)? Explain. 26 SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued) 27 SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued) G. ADDITIONAL EVALUATIONS INSTRUCTIONS: Attach additional sheets as needed. SECTION II COMPLETED BY: Allison Yates TITLE: Lab Supervisor POTW REPRESENTATIVE PROVIDING RESPONSES: DATE: 9-17-24 TELEPHONE: DATE: TELEPHONE: 28 KISHWAUKEE WATER RECLAMATION DISTRICT INDUSTRIAL PRETREATEMENT ENFORCEMENT RESPONSE PLAN 1. Purpose of Enforcement Response Plan. The purpose of the Kishwaukee Water Reclamation District's (District) Industrial Pretreatment Enforcement Response Plan is to establish a uniform enforcement response by the District, in the event of noncompliance with the terms and conditions of a District Industrial User Wastewater Discharge Permit by an area industry. This document describes the official District's policy and procedure for: (i) Obtaining and evaluating information concerning compliance by Significant Industrial Users (SIU) with their Wastewater Discharge Permits; (ii) Identifying cases of non-compliance; (iii) Selecting and prosecuting appropriate enforcement action; and (iv) Otherwise rectifying non-compliance in a timely, fair and consistent manner. 2. Key to Acronyms and Abbreviations. AO - Administrative Order A - Attorney BT - Board of Trustees Civil Action - A civil lawsuit brought by District against an Industrial User, seeking equitable relief, monetary penalties and/or actual damages. Criminal - Pursuing punitive measures against an individual and/or Prosecution organization through a court of law DM - District Manager Fine - A monetary penalty assessed by the Control Authority (Kishwaukee Water Reclamation District). IU - Industrial User. NOV -Notice of Violation. Meeting - Informal compliance meeting with an IU to resolve recurring non- significant non-compliance. PC - Pretreatment Coordinator Show Cause - A formal meeting requiring the IU to appear and demonstrate Hearing why the Control Authority should not take proposed enforcement action against the IU. The meeting also may serve as a forum to discuss corrective actions and compliance schedules. SNC - Significant non-compliance as defined by 40 CFR 403 Definition: Significant Industrial User (SIU) (1) An Industrial User subject to categorical Pretreatment Standards; or (2) An Industrial User that: (a) Discharges an average of twenty-five thousand (25,000) gpd or more of process wastewater to the POTW (excluding sanitary, noncontact cooling and boiler blowdown wastewater); (b) Contributes a process wastestream which makes up five (5) percent or more of the average dry weather hydraulic or organic capacity of the POTW treatment plant; or (c) Is designated as such by the District on the basis that it has a reasonable potential for adversely affecting the POTW's operation or for violating any Pretreatment Standard or Requirement. 3. Enforcement Response Plan Personnel. a. District Manager. Duties: To oversee the program, to update the pretreatment ordinance and Wastewater Discharge Permits, and to initiate escalated enforcement action. b. Pretreatment Coordinator. Duties: To screen compliance data, to initiate enforcement action, to conduct Industrial User inspections, to schedule compliance monitoring and to notify an Industrial User of any violations. c. Control Authority Attorney. Duties: To initiate and prosecute civil and criminal enforcement litigation. 4. Compliance Monitoring Procedure. Any Discharger subject to a Pretreatment standard or requirement shall submit to the District self-monitoring reports as required by the District's Industrial Pretreatment Ordinance No. 591 (the "Ordinance"). Reports by permittees shall contain the full results of all sampling and analysis of the permittee's discharge, including flow, the nature and concentration thereof, and its production and mass as required by the Ordinance or by the District. The frequency of monitoring by the Discharger shall comply with applicable Categorical Pretreatment Standards. Where such standards fail to specify the frequency of monitoring, the Discharger shall perform the required monitoring as specified in the District's Pretreatment Discharge Permit. All analyses shall be performed in accordance with federal regulation 40 CFR Part 136 and amendments thereto unless specified otherwise. All reports submitted to the District shall be accompanied by a chain of custody for any laboratory data reported, and shall be signed by an authorized representative of the Discharger. An Industrial User shall timely notify the District of any effluent limit violation or slug discharge. Effluent sampling must be repeated within 24 hours, and the analysis must be reported within 30 days for any parameter which is found to be in violation. The Control Authority (Kishwaukee Water Reclamation District) shall conduct a facility inspection of each industrial user under permit, at least annually. A pretreatment industrial user inspection checklist shall be completed for each inspection. Facility inspections shall be prescheduled but may be unscheduled at the discretion of the District. The control authority shall conduct sampling and flow monitoring of Industrial Users. Frequency of sampling shall be determined by the District. Control Authority sampling and flow monitoring will not be prescheduled with the Industrial User. 5. Compliance Screening. The compliance screening process shall involve a review by the District of all available information in order to detect non-complying dischargers and to bring appropriate enforcement action. This review process shall assess, as appropriate, compliance with schedules, and with reporting requirements and applicable pretreatment standards. The screening process shall verify that all required reports: a. Have been timely submitted; b. Cover the appropriate time periods; c. Include all required information; and d. Are properly signed and certified. The Kishwaukee Water Reclamation District (Control Authority) shall utilize a calendar of events to record and track reporting due dates. All monitoring data shall be entered into a computer software program for tracking purposes. The program will automatically "flag" permit limit exceedances. Nondischarge violations (late report submittal, etc.) shall be noted by pretreatment personnel and recorded manually on the computer. All data shall be reviewed as received. All monitoring data and any correspondence with an industry shall be maintained in a master file by the District. 6. Significant Non-Compliance (SNC) Any violation of pretreatment requirements (effluent limits, sampling analysis, reporting and meeting compliance schedules, and regulatory deadlines) is noncompliance for which a user is liable for enforcement, including penalties. If an industrial user is found in SNC as defined by the EPA below, the POTW must report it to the Approval Authority (EPA), and publish the industrial user in the newspaper. The EPA has defined instances of SNC as one or more of the following: A. Chronic violations of wastewater discharge limits, defined here as those in which sixty-six percent (66%) or more of all the measurements taken for the same pollutant parameter taken during a six- (6-) month period exceed (by any magnitude) a numeric Pretreatment Standard or Requirement, including Instantaneous Limits as defined in Section 2; B. Technical Review Criteria (TRC) violations, defined here as those in which thirtythree percent (33%) or more of wastewater measurements taken for each pollutant parameter during a six- (6-) month period equals or exceeds the product of the numeric Pretreatment Standard or Requirement including Instantaneous Limits, as defined by Section 2 multiplied by the applicable criteria (1.4 for BOD, TSS, fats, oils and grease, and 1.2 for all other pollutants except pH); C. Any other violation of a Pretreatment Standard or Requirement as defined by Section 2 (Daily Maximum, long-term average, Instantaneous Limit, or narrative standard) that the District determines has caused, alone or in combination with other discharges, Interference or Pass Through, including endangering the health of POTW personnel or the general public; D. Any discharge of a pollutant that has caused imminent endangerment to the public or to the environment, or has resulted in the District's exercise of its emergency authority to halt or prevent such a discharge; E. Failure to meet, within ninety (90) days of the scheduled date, a compliance schedule milestone contained in an individual wastewater discharge permit or a general permit or enforcement order for starting construction, completing construction, or attaining final compliance; F. Failure to provide within forty-five (45) days after the due date, any required reports, including baseline monitoring reports, reports on compliance with categorical Pretreatment Standard deadlines, periodic self-monitoring reports, and reports on compliance with compliance schedules; G. Failure to accurately report noncompliance; or H. Any other violation(s), which may include a violation of Best Management Practices, which the District determines will adversely affect the operation or implementation of the local pretreatment program. 7. Kishwaukee Water Reclamation District Enforcement Mechanisms. a. Informal notice to Industrial User for non-significant non-compliance (telephone call) all enforcement telephone calls to IUs will be documented with a form created for this purpose. b. Informal meeting with industrial User (for recurring non-significant noncompliance issues.) c. Notice of Violation (NOV) (example attached). d. Administrative Orders. 1. Cease and Desist Order (example attached) 2. Consent Order (example attached) 3. Compliance Schedules (example attached) 4. Notice of Order to Show Cause (example attached) e. Fines. f. Civil Action. g. Criminal Action. h. Criminal Prosecution. i. Termination of Services (revocation of discharge permit). Cease and Desist Order. Directs a non-compliant user to immediately cease illegal or unauthorized discharges or to terminate discharges all together. It is issued when the discharge could cause interference or pass-through. This order may be issued immediately upon discovery of a problem. In an emergency, the order to cease and desist may be given by telephone. In non-emergency situations, the order may be used to suspend or permanently revoke the user's discharge permit. Consent Order. This order combines the force of an AO with the flexibility of a negotiated settlement. This may be used when the user assumes responsibility for a noncompliance and is willing (in good faith) to correct the cause(s). Compliance Orders and Compliance Schedules. An Administrative Order may be issued by the EPA, pursuant to Section 309(a) of the Clean Water Act, without notice or opportunity for prior hearing, requiring compliance with standards or other requirements developed under authority of the Act. The District, under its legal authority, may also issue similar orders. Such an order may be used to place an Industrial User on an enforcement schedule to comply with pretreatment standards. Order to Show Cause. An Industrial User may be ordered by the District to show cause before the District at a formal hearing why formal action should not be taken and/or sewer service discontinued. At the hearing the District shall present those facts which it believes constitute non-compliance by the IU with the Industrial User Pretreatment Ordinance and the IU shall be required to "show cause" why the District should not initiate formal action and/or discontinue sewer service. Fines. The District may impose a fine to enforce its pretreatment program, ranging from $100 to $50,000 for each day of non-compliance by an Industrial User. Civil Actions. The District may file a civil suit seeking injunctive relief against an alleged violator of the pretreatment Ordinance. Such suit would seek a judication prohibiting the defendant-discharger from continuing a specific type of volume or discharge. Criminal Prosecution. Criminal investigation may be initiated by an appropriate county or state agency, upon request of the District, leading to criminal prosecution and punishment of any person who willfully or negligently violates pretreatment standards, or of any who knowingly makes a false statement regarding any report. Termination of Service. The District has the authority to halt, immediately, an actual or threatened discharge to its treatment facility which may represent an endangerment to the public health, the environment, the POTW personnel, or the POTW. 8. Enforcement Tracking When any enforcement action is necessary, the Kishwaukee Water Reclamation District will track the initial action and any escalated actions taken. A form has been created for this purpose the "Enforcement Tracking Log" (example attached.) Example: Notice of Violation August 25, 2008 Mr. Steve Smith ABC Company 101 Happy Road DeKalb, IL 60115 RE: Wastewater Discharge Permit 133 Dear Mr. Smith: As part of the Industrial Pretreatment Program, the Kishwaukee Water Reclamation District (District) is obligated to perform compliance monitoring of wastewater from selected industries on an occasional basis. Section 7.1 Inspection and Sampling of the District's Industrial Pretreatment Ordinance 591 provides the authority for the District to carry-out such compliance monitoring. A 24-hour composite sample was taken at ABC Company on 7/28-29/08. The sample was obtained by representatives of the District who are performing the required compliance monitoring analysis of your wastewater. The results of our analysis are enclosed. Based on the analysis, there is one VIOLATION of your permit limitations: Permit Limit Results Cyanide 2.7 mg/l 3.5 mg/l The Kishwaukee Water Reclamation District will be re-testing your facility for cyanide. If you have any questions or comments on your test results, please contact either Jane Smith or myself at (815) 758-3513. Sincerely, Kishwaukee Water Reclamation District Jim Smith Project Manager Example: Cease and Desist Order In the Matter of Administrative Cease and Desist Order Name and Address Of Industry Legal Authority The following findings are made and order issued pursuant to the authority vested in the Kishwaukee Water Reclamation District (District), under Section 10.5 of the District Industrial Pretreatment Ordinance. This order is based on findings of violation of the conditions of the wastewater discharge permit under Section ___ of the District's Industrial Pretreatment Ordinance. Findings 1. [Industry] discharges nondomestic wastewater containing pollutants into the sanitary sewer system of the Kishwaukee Water Reclamation District. 2. [Industry] is a "significant industrial user" as defined by 1.3 of the District Industrial Pretreatment Ordinance. 3. [Industry] was issued a wastewater discharge permit on June 15, 2006 which contains prohibitions, restrictions, and other limitations on the quality of the wastewater it discharges to the sanitary sewer. 4. Pursuant to the District Industrial Pretreatment Ordinance and the above-referred permit, data routinely collected or submitted on the compliance status of [Industry]. 5. This data shows that [Industry] has violated the District Industrial Pretreatment Ordinance in the following manner: a. [Industry] has continuously violated its permit limits for copper and zinc in each sample collected between January, 2007 and December, 2008. b. [Industry] has also failed comply with an administrative compliance order requiring the installation of a pretreatment system and the achievement of compliance with its permit by July 1, 2008. c. [Industry] has failed to appear at a show cause hearing pursuant to an order requiring said attendance. Order THERFORE, BASED ON THE ABOVE FINDINGS, [INDUSTRY] IS HEREBY ORDERED TO: 1. Within 24 hours of receiving this order, cease all nondomestic discharges into the District's sanitary sewer. Such discharges shall not recommence until such time as [Industry] is able to demonstrate that it will comply with its current permit limits. 2. Failure to comply with this order may subject [Industry] to having its connection to the sanitary sewer sealed by the District, and assessed the costs thereof. 3. Failure to comply with this order shall also constitute a further violation of the District Industrial Pretreatment Ordinance and may subject [Industry] to civil or criminal penalties or such other enforcement responses as may be appropriate. 4. This order, entered this 12th day of January, 2009, shall be effective upon receipt by [Industry]. Signed: _________________________ [Name] General Manager Kishwaukee Water Reclamation District 1301 Sycamore Rd. DeKalb, IL 60115 Example: Show Cause Order In the Matter of Administrative Show Cause Order Name and Address Of Industry Legal Authority The following findings are made and order issued pursuant to the authority vested in the Kishwaukee Water Reclamation District (District) Manager, under Section 10.3 of the District Industrial Pretreatment Ordinance. This order is based on findings of violation of the conditions of the wastewater discharge permit under Section ___ of the District Industrial Pretreatment Ordinance. Findings 1. [Industry] discharges nondomestic wastewater containing pollutants into the sanitary sewer system of the Kishwaukee Water Reclamation District. 2. [Industry] is a "significant industrial user" as defined by 1.3 of the District Industrial Pretreatment Ordinance. 3. [Industry] was issued a wastewater discharge permit on June 15, 2006 which contains prohibitions, restrictions, and other limitations on the quality of the wastewater it discharges to the sanitary sewer. 4. Pursuant to the District Industrial Pretreatment Ordinance and the above-referred permit, data routinely collected or submitted on the compliance status of [Industry]. 5. This data shows that [Industry] has violated the District Industrial Pretreatment Ordinance in the following manner: a. [Industry] has continuously violated its permit limits for copper and zinc in each sample collected between January, 2007 and December, 2008 for a total of 8 separate violations of the permit. b. [Industry] has failed to submit a periodic compliance report due July 1, 2008. c. All of these violations satisfy the District's definition of significant violation. Order THERFORE, BASED ON THE ABOVE FINDINGS, [INDUSTRY] IS HEREBY ORDERED TO: 1. Appear at a meeting with the General Manager of the Kishwaukee Water Reclamation District to be held on January 29, 2009, at 2:00 pm at the WWTP, 303 Hollister Avenue. 2. At this meeting, [Industry] must demonstrate why the District should not pursue a judicial enforcement action against [Industry] at this time. 3. This meeting will be closed to the public. 4. Representatives of [Industry] may be accompanied by legal counsel if they choose. 5. Failure to comply with this order shall also constitute a further violation of the District's Industrial Pretreatment Ordinance and may subject [Industry] to civil or criminal penalties or such other enforcement responses as may be appropriate. 6. This order, entered this 12th day of January, 2009, shall be effective upon receipt by [Industry]. Signed: _________________________ [Name] General Manager Kishwaukee Water Reclamation District 1301 Sycamore Rd. DeKalb, IL 60115 Example: Compliance Order In the Matter of Administrative Compliance Order Name and Address Of Industry Legal Authority The following findings are made and order issued pursuant to the authority vested in the Kishwaukee Water Reclamation District (District) District Manager, under Section 10.4 of the District Industrial Pretreatment Ordinance. This order is based on findings of violation of the conditions of the wastewater discharge permit under Section 5 of the District Industrial Pretreatment Ordinance. Findings 1. [Industry] discharges nondomestic wastewater containing pollutants into the sanitary sewer system of the Kishwaukee Water Reclamation District. 2. [Industry] is a "significant industrial user" as defined by 1.3 of the District Industrial Pretreatment Ordinance. 3. [Industry] was issued a wastewater discharge permit on June 15, 2006 which contains prohibitions, restrictions, and other limitations on the quality of the wastewater it discharges to the sanitary sewer. 4. Pursuant to the District Industrial Pretreatment Ordinance and the above-referred permit, data routinely collected or submitted on the compliance status of [Industry]. 5. This data shows that [Industry] has violated the District Industrial Pretreatment Ordinance in the following manner: a. [Industry] has violated its permit limits for copper and zinc in each sample collected between January, 2007 and December, 2008. b. [Industry] has failed to submit all periodic compliance reports due by June 30, 2008. c. All of these violations satisfy the District's definition of significant violation. Order THERFORE, BASED ON THE ABOVE FINDINGS, [INDUSTRY] IS HEREBY ORDERED TO: 1. Within 180 days, of receiving this order, install pretreatment technology which adequately treat [Industry]'s wastewater to a level which will comply with its wastewater discharge permits. 2. Within 5 days, submit all periodic compliance reports due since June 30, 2008. 3. Within 10 days, pay to the cashier's office of the District, a fine of $5,000.00 for the above- described violations in accordance with section _____ of the District Industrial Pretreatment Ordinance. 4. This order, entered this 12th day of January, 2009, shall be effective upon receipt by [Industry]. Signed: _________________________ [Name] General Manager Kishwaukee Water Reclamation District 1301 Sycamore Rd. DeKalb, IL 60115 Example: Consent Order In the Matter of Administrative Consent Order Name and Address Of Industry Consent Order WHEREAS, The Kishwaukee Water Reclamation District (District) pursuant to the powers, duties and responsibilities vested in and imposed upon the District Manager by provisions of the District's Industrial Pretreatment Ordinance, have conducted an ongoing investigation of [Industry] and have determined that:. 1. The District owns and operates a wastewater treatment plant which is adversely impacted by discharges from industrial users, including [Industry], and has implemented a pretreatment program to control such discharges. 2. [Industry] has consistently violated the pollutant limits in its wastewater discharge permit as set forth in Exhibit 1, attached hereto. 3. Therefore, to ensure that [Industry] is brought into compliance with its permit limits at the earliest possible date, IT IS HEREBY AGREED AND ORDERED, BETWEEN THE [INDUSTRY] AND THE GENERAL MANAGER OF THE DISTRICT, that [Industry] shall: a. By July 15, 2008, obtain the services of a licensed professional engineer specializing in wastewater treatment for the purpose of designing a pretreatment system which will bring [Industry] into compliance with its wastewater discharge permit. b. By September 30, 2008, submit plans and specifications for the proposed pretreatment system to the District for review. c. By December 31, 2008, install the pretreatment system in accordance with the plans and specifications submitted in item b above. d. By January 15, 2009, achieve compliance with the limits set forth in Exhibit 1. e. [Industry] shall pay $1,000 per day for each day it fails to comply with the schedule set out in items a-d above. The $1,000 per day penalty shall be paid to the accountant at the District within 5 days of being demanded by the District. 4. In the event [Industry] fails to comply with any of the deadlines set forth, [Industry] shall, within one (1) working day after expiration of the deadline, notify the District in writing. This notice shall describe the reasons for [Industry]'s failure to comply, the additional amount of time needed to complete the remaining work, and the steps to be taken to avoid future delays. This notification in no way excuses [Industry] from its responsibility to meet any later milestones required by this Consent Order. 5. Compliance with the terms and conditions of this Consent Order shall not be construed to relieve [Industry] of its obligation to comply with its wastewater discharge permit which remains in full force and effect. The District reserves the right to seek any and all remedies available to it under Section 10 of the District Industrial Pretreatment Ordinance for any violation cited by this order. 6. Violation of this Consent Order shall constitute a further violation of the District's Industrial Pretreatment Ordinance and subjects [Industry] to all penalties described by section 10 of the District Industrial Pretreatment Ordinance. 7. Nothing in this Consent Order shall be construed to limit any authority of the District to issue any other orders or take any other action which deems necessary to protect the wastewater treatment plant, the environment or the public health and safety. SIGNATORIES FOR [INDUSTRY] ___________________ (Date) ____________________________ Name Representative of [Industry] FOR KISHWAUKEE WATER RECLAMATION DISTRICT ___________________ (Date) ________________________________________ Name-General Manager Kishwaukee Water Reclamation District Pretreatment Program Telephone Documentation Pretreatment Staff initiating telephone call: _______________________________________ Industry name and Contact person: _____________________________________________ Date and Time of Call: _______________________________________________________ Reason for telephone call: ____________________________________________________ Synopsis of conversation: _____________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ____________________________________________________________________________ Date and Time issue was resolved Enforcement Tracking Log Name of Industry: _________________________ Nature of Violation: ________________________ Date of Violation: _________________________ Initial Enforcement Action Taken: ____________________________ Date of Enforcement Action: __________________________________ Date IU back in Compliance: __________________________________ OR Escalated Enforcement Action/Date of Action: ______________________ Comments: Hauled Waste Procedures The following description/procedures are relevant only to those haulers that: have provided all required documentation to KWRD have been given expressed written permission by the Operations Manager or Executive Director granting them approval to access the facility have been given expressed written permission by the Operations Manager or Executive Director granting them approval to haul in specific (approved only) hauled waste loads All haulers that have met the above conditions are to follow these guidelines/procedures for dumping at KWRD for each load: All haulers will be provided with a specific dump location (septic station, sidestream, fog station) for each approved load brought into KWRD All haulers are required to provide a manifest for each load hauled into KWRD and must include: o Company information o Site hauled from o Gallons being hauled o Driver information and signature o Time and Date of load pickup and drop off o Manifest drop off locations are the grey hut at FOG station and Headworks next to septic station All haulers are required to provide a sample for each load hauled into KWRD o All sample bottles and labels are provided by the District o A sample must be provided for each load o All samples must include a label that matches the information provided on the manifest o Sample drop off locations are the grey hut at FOG station and Headworks next to septic station o KWRD will pickup all hauler samples each day for testing All haulers must clean up/wash area after unloading o If any spillage occurs, haulers must immediately notify the District and clean up all materials o All screens (FOG station only) must be hand racked, debris removed from screens placed into dumpster (provided by District), and washed after each load KISHWAUKEE WATER RECLAMATION DISTRICT INDUSTRIAL PRETREATEMENT ENFORCEMENT RESPONSE PLAN 1. Purpose of Enforcement Response Plan. The purpose of the Kishwaukee Water Reclamation District's (District) Industrial Pretreatment Enforcement Response Plan is to establish a uniform enforcement response by the District, in the event of noncompliance with the terms and conditions of a District Industrial User Wastewater Discharge Permit by an area industry. This document describes the official District's policy and procedure for: (i) Obtaining and evaluating information concerning compliance by Significant Industrial Users (SIU) with their Wastewater Discharge Permits; (ii) Identifying cases of non-compliance; (iii) Selecting and prosecuting appropriate enforcement action; and (iv) Otherwise rectifying non-compliance in a timely, fair and consistent manner. 2. Key to Acronyms and Abbreviations. AO - Administrative Order A - Attorney BT - Board of Trustees Civil Action - A civil lawsuit brought by District against an Industrial User, seeking equitable relief, monetary penalties and/or actual damages. Criminal - Pursuing punitive measures against an individual and/or Prosecution organization through a court of law DM - District Manager Fine - A monetary penalty assessed by the Control Authority (Kishwaukee Water Reclamation District). IU - Industrial User. NOV -Notice of Violation. Meeting - Informal compliance meeting with an IU to resolve recurring non- significant non-compliance. PC - Pretreatment Coordinator Show Cause - A formal meeting requiring the IU to appear and demonstrate Hearing why the Control Authority should not take proposed enforcement action against the IU. The meeting also may serve as a forum to discuss corrective actions and compliance schedules. SNC - Significant non-compliance as defined by 40 CFR 403 Definition: Significant Industrial User (SIU) (1) An Industrial User subject to categorical Pretreatment Standards; or (2) An Industrial User that: (a) Discharges an average of twenty-five thousand (25,000) gpd or more of process wastewater to the POTW (excluding sanitary, noncontact cooling and boiler blowdown wastewater); (b) Contributes a process wastestream which makes up five (5) percent or more of the average dry weather hydraulic or organic capacity of the POTW treatment plant; or (c) Is designated as such by the District on the basis that it has a reasonable potential for adversely affecting the POTW's operation or for violating any Pretreatment Standard or Requirement. 3. Enforcement Response Plan Personnel. a. District Manager. Duties: To oversee the program, to update the pretreatment ordinance and Wastewater Discharge Permits, and to initiate escalated enforcement action. b. Pretreatment Coordinator. Duties: To screen compliance data, to initiate enforcement action, to conduct Industrial User inspections, to schedule compliance monitoring and to notify an Industrial User of any violations. c. Control Authority Attorney. Duties: To initiate and prosecute civil and criminal enforcement litigation. 4. Compliance Monitoring Procedure. Any Discharger subject to a Pretreatment standard or requirement shall submit to the District self-monitoring reports as required by the District's Industrial Pretreatment Ordinance No. 591 (the "Ordinance"). Reports by permittees shall contain the full results of all sampling and analysis of the permittee's discharge, including flow, the nature and concentration thereof, and its production and mass as required by the Ordinance or by the District. The frequency of monitoring by the Discharger shall comply with applicable Categorical Pretreatment Standards. Where such standards fail to specify the frequency of monitoring, the Discharger shall perform the required monitoring as specified in the District's Pretreatment Discharge Permit. All analyses shall be performed in accordance with federal regulation 40 CFR Part 136 and amendments thereto unless specified otherwise. All reports submitted to the District shall be accompanied by a chain of custody for any laboratory data reported, and shall be signed by an authorized representative of the Discharger. An Industrial User shall timely notify the District of any effluent limit violation or slug discharge. Effluent sampling must be repeated within 24 hours, and the analysis must be reported within 30 days for any parameter which is found to be in violation. The Control Authority (Kishwaukee Water Reclamation District) shall conduct a facility inspection of each industrial user under permit, at least annually. A pretreatment industrial user inspection checklist shall be completed for each inspection. Facility inspections shall be prescheduled but may be unscheduled at the discretion of the District. The control authority shall conduct sampling and flow monitoring of Industrial Users. Frequency of sampling shall be determined by the District. Control Authority sampling and flow monitoring will not be prescheduled with the Industrial User. 5. Compliance Screening. The compliance screening process shall involve a review by the District of all available information in order to detect non-complying dischargers and to bring appropriate enforcement action. This review process shall assess, as appropriate, compliance with schedules, and with reporting requirements and applicable pretreatment standards. The screening process shall verify that all required reports: a. Have been timely submitted; b. Cover the appropriate time periods; c. Include all required information; and d. Are properly signed and certified. The Kishwaukee Water Reclamation District (Control Authority) shall utilize a calendar of events to record and track reporting due dates. All monitoring data shall be entered into a computer software program for tracking purposes. The program will automatically "flag" permit limit exceedances. Nondischarge violations (late report submittal, etc.) shall be noted by pretreatment personnel and recorded manually on the computer. All data shall be reviewed as received. All monitoring data and any correspondence with an industry shall be maintained in a master file by the District. 6. Significant Non-Compliance (SNC) Any violation of pretreatment requirements (effluent limits, sampling analysis, reporting and meeting compliance schedules, and regulatory deadlines) is noncompliance for which a user is liable for enforcement, including penalties. If an industrial user is found in SNC as defined by the EPA below, the POTW must report it to the Approval Authority (EPA), and publish the industrial user in the newspaper. The EPA has defined instances of SNC as one or more of the following: A. Chronic violations of wastewater discharge limits, defined here as those in which sixty-six percent (66%) or more of all the measurements taken for the same pollutant parameter taken during a six- (6-) month period exceed (by any magnitude) a numeric Pretreatment Standard or Requirement, including Instantaneous Limits as defined in Section 2; B. Technical Review Criteria (TRC) violations, defined here as those in which thirtythree percent (33%) or more of wastewater measurements taken for each pollutant parameter during a six- (6-) month period equals or exceeds the product of the numeric Pretreatment Standard or Requirement including Instantaneous Limits, as defined by Section 2 multiplied by the applicable criteria (1.4 for BOD, TSS, fats, oils and grease, and 1.2 for all other pollutants except pH); C. Any other violation of a Pretreatment Standard or Requirement as defined by Section 2 (Daily Maximum, long-term average, Instantaneous Limit, or narrative standard) that the District determines has caused, alone or in combination with other discharges, Interference or Pass Through, including endangering the health of POTW personnel or the general public; D. Any discharge of a pollutant that has caused imminent endangerment to the public or to the environment, or has resulted in the District's exercise of its emergency authority to halt or prevent such a discharge; E. Failure to meet, within ninety (90) days of the scheduled date, a compliance schedule milestone contained in an individual wastewater discharge permit or a general permit or enforcement order for starting construction, completing construction, or attaining final compliance; F. Failure to provide within forty-five (45) days after the due date, any required reports, including baseline monitoring reports, reports on compliance with categorical Pretreatment Standard deadlines, periodic self-monitoring reports, and reports on compliance with compliance schedules; G. Failure to accurately report noncompliance; or H. Any other violation(s), which may include a violation of Best Management Practices, which the District determines will adversely affect the operation or implementation of the local pretreatment program. 7. Kishwaukee Water Reclamation District Enforcement Mechanisms. a. Informal notice to Industrial User for non-significant non-compliance (telephone call) all enforcement telephone calls to IUs will be documented with a form created for this purpose. b. Informal meeting with industrial User (for recurring non-significant noncompliance issues.) c. Notice of Violation (NOV) (example attached). d. Administrative Orders. 1. Cease and Desist Order (example attached) 2. Consent Order (example attached) 3. Compliance Schedules (example attached) 4. Notice of Order to Show Cause (example attached) e. Fines. f. Civil Action. g. Criminal Action. h. Criminal Prosecution. i. Termination of Services (revocation of discharge permit). Cease and Desist Order. Directs a non-compliant user to immediately cease illegal or unauthorized discharges or to terminate discharges all together. It is issued when the discharge could cause interference or pass-through. This order may be issued immediately upon discovery of a problem. In an emergency, the order to cease and desist may be given by telephone. In non-emergency situations, the order may be used to suspend or permanently revoke the user's discharge permit. Consent Order. This order combines the force of an AO with the flexibility of a negotiated settlement. This may be used when the user assumes responsibility for a noncompliance and is willing (in good faith) to correct the cause(s). Compliance Orders and Compliance Schedules. An Administrative Order may be issued by the EPA, pursuant to Section 309(a) of the Clean Water Act, without notice or opportunity for prior hearing, requiring compliance with standards or other requirements developed under authority of the Act. The District, under its legal authority, may also issue similar orders. Such an order may be used to place an Industrial User on an enforcement schedule to comply with pretreatment standards. Order to Show Cause. An Industrial User may be ordered by the District to show cause before the District at a formal hearing why formal action should not be taken and/or sewer service discontinued. At the hearing the District shall present those facts which it believes constitute non-compliance by the IU with the Industrial User Pretreatment Ordinance and the IU shall be required to "show cause" why the District should not initiate formal action and/or discontinue sewer service. Fines. The District may impose a fine to enforce its pretreatment program, ranging from $100 to $50,000 for each day of non-compliance by an Industrial User. Civil Actions. The District may file a civil suit seeking injunctive relief against an alleged violator of the pretreatment Ordinance. Such suit would seek a judication prohibiting the defendant-discharger from continuing a specific type of volume or discharge. Criminal Prosecution. Criminal investigation may be initiated by an appropriate county or state agency, upon request of the District, leading to criminal prosecution and punishment of any person who willfully or negligently violates pretreatment standards, or of any who knowingly makes a false statement regarding any report. Termination of Service. The District has the authority to halt, immediately, an actual or threatened discharge to its treatment facility which may represent an endangerment to the public health, the environment, the POTW personnel, or the POTW. 8. Enforcement Tracking When any enforcement action is necessary, the Kishwaukee Water Reclamation District will track the initial action and any escalated actions taken. A form has been created for this purpose the "Enforcement Tracking Log" (example attached.) Example: Notice of Violation August 25, 2008 Mr. Steve Smith ABC Company 101 Happy Road DeKalb, IL 60115 RE: Wastewater Discharge Permit 133 Dear Mr. Smith: As part of the Industrial Pretreatment Program, the Kishwaukee Water Reclamation District (District) is obligated to perform compliance monitoring of wastewater from selected industries on an occasional basis. Section 7.1 Inspection and Sampling of the District's Industrial Pretreatment Ordinance 591 provides the authority for the District to carry-out such compliance monitoring. A 24-hour composite sample was taken at ABC Company on 7/28-29/08. The sample was obtained by representatives of the District who are performing the required compliance monitoring analysis of your wastewater. The results of our analysis are enclosed. Based on the analysis, there is one VIOLATION of your permit limitations: Permit Limit Results Cyanide 2.7 mg/l 3.5 mg/l The Kishwaukee Water Reclamation District will be re-testing your facility for cyanide. If you have any questions or comments on your test results, please contact either Jane Smith or myself at (815) 758-3513. Sincerely, Kishwaukee Water Reclamation District Jim Smith Project Manager Example: Cease and Desist Order In the Matter of Administrative Cease and Desist Order Name and Address Of Industry Legal Authority The following findings are made and order issued pursuant to the authority vested in the Kishwaukee Water Reclamation District (District), under Section 10.5 of the District Industrial Pretreatment Ordinance. This order is based on findings of violation of the conditions of the wastewater discharge permit under Section ___ of the District's Industrial Pretreatment Ordinance. Findings 1. [Industry] discharges nondomestic wastewater containing pollutants into the sanitary sewer system of the Kishwaukee Water Reclamation District. 2. [Industry] is a "significant industrial user" as defined by 1.3 of the District Industrial Pretreatment Ordinance. 3. [Industry] was issued a wastewater discharge permit on June 15, 2006 which contains prohibitions, restrictions, and other limitations on the quality of the wastewater it discharges to the sanitary sewer. 4. Pursuant to the District Industrial Pretreatment Ordinance and the above-referred permit, data routinely collected or submitted on the compliance status of [Industry]. 5. This data shows that [Industry] has violated the District Industrial Pretreatment Ordinance in the following manner: a. [Industry] has continuously violated its permit limits for copper and zinc in each sample collected between January, 2007 and December, 2008. b. [Industry] has also failed comply with an administrative compliance order requiring the installation of a pretreatment system and the achievement of compliance with its permit by July 1, 2008. c. [Industry] has failed to appear at a show cause hearing pursuant to an order requiring said attendance. Order THERFORE, BASED ON THE ABOVE FINDINGS, [INDUSTRY] IS HEREBY ORDERED TO: 1. Within 24 hours of receiving this order, cease all nondomestic discharges into the District's sanitary sewer. Such discharges shall not recommence until such time as [Industry] is able to demonstrate that it will comply with its current permit limits. 2. Failure to comply with this order may subject [Industry] to having its connection to the sanitary sewer sealed by the District, and assessed the costs thereof. 3. Failure to comply with this order shall also constitute a further violation of the District Industrial Pretreatment Ordinance and may subject [Industry] to civil or criminal penalties or such other enforcement responses as may be appropriate. 4. This order, entered this 12th day of January, 2009, shall be effective upon receipt by [Industry]. Signed: _________________________ [Name] General Manager Kishwaukee Water Reclamation District 1301 Sycamore Rd. DeKalb, IL 60115 Example: Show Cause Order In the Matter of Administrative Show Cause Order Name and Address Of Industry Legal Authority The following findings are made and order issued pursuant to the authority vested in the Kishwaukee Water Reclamation District (District) Manager, under Section 10.3 of the District Industrial Pretreatment Ordinance. This order is based on findings of violation of the conditions of the wastewater discharge permit under Section ___ of the District Industrial Pretreatment Ordinance. Findings 1. [Industry] discharges nondomestic wastewater containing pollutants into the sanitary sewer system of the Kishwaukee Water Reclamation District. 2. [Industry] is a "significant industrial user" as defined by 1.3 of the District Industrial Pretreatment Ordinance. 3. [Industry] was issued a wastewater discharge permit on June 15, 2006 which contains prohibitions, restrictions, and other limitations on the quality of the wastewater it discharges to the sanitary sewer. 4. Pursuant to the District Industrial Pretreatment Ordinance and the above-referred permit, data routinely collected or submitted on the compliance status of [Industry]. 5. This data shows that [Industry] has violated the District Industrial Pretreatment Ordinance in the following manner: a. [Industry] has continuously violated its permit limits for copper and zinc in each sample collected between January, 2007 and December, 2008 for a total of 8 separate violations of the permit. b. [Industry] has failed to submit a periodic compliance report due July 1, 2008. c. All of these violations satisfy the District's definition of significant violation. Order THERFORE, BASED ON THE ABOVE FINDINGS, [INDUSTRY] IS HEREBY ORDERED TO: 1. Appear at a meeting with the General Manager of the Kishwaukee Water Reclamation District to be held on January 29, 2009, at 2:00 pm at the WWTP, 303 Hollister Avenue. 2. At this meeting, [Industry] must demonstrate why the District should not pursue a judicial enforcement action against [Industry] at this time. 3. This meeting will be closed to the public. 4. Representatives of [Industry] may be accompanied by legal counsel if they choose. 5. Failure to comply with this order shall also constitute a further violation of the District's Industrial Pretreatment Ordinance and may subject [Industry] to civil or criminal penalties or such other enforcement responses as may be appropriate. 6. This order, entered this 12th day of January, 2009, shall be effective upon receipt by [Industry]. Signed: _________________________ [Name] General Manager Kishwaukee Water Reclamation District 1301 Sycamore Rd. DeKalb, IL 60115 Example: Compliance Order In the Matter of Administrative Compliance Order Name and Address Of Industry Legal Authority The following findings are made and order issued pursuant to the authority vested in the Kishwaukee Water Reclamation District (District) District Manager, under Section 10.4 of the District Industrial Pretreatment Ordinance. This order is based on findings of violation of the conditions of the wastewater discharge permit under Section 5 of the District Industrial Pretreatment Ordinance. Findings 1. [Industry] discharges nondomestic wastewater containing pollutants into the sanitary sewer system of the Kishwaukee Water Reclamation District. 2. [Industry] is a "significant industrial user" as defined by 1.3 of the District Industrial Pretreatment Ordinance. 3. [Industry] was issued a wastewater discharge permit on June 15, 2006 which contains prohibitions, restrictions, and other limitations on the quality of the wastewater it discharges to the sanitary sewer. 4. Pursuant to the District Industrial Pretreatment Ordinance and the above-referred permit, data routinely collected or submitted on the compliance status of [Industry]. 5. This data shows that [Industry] has violated the District Industrial Pretreatment Ordinance in the following manner: a. [Industry] has violated its permit limits for copper and zinc in each sample collected between January, 2007 and December, 2008. b. [Industry] has failed to submit all periodic compliance reports due by June 30, 2008. c. All of these violations satisfy the District's definition of significant violation. Order THERFORE, BASED ON THE ABOVE FINDINGS, [INDUSTRY] IS HEREBY ORDERED TO: 1. Within 180 days, of receiving this order, install pretreatment technology which adequately treat [Industry]'s wastewater to a level which will comply with its wastewater discharge permits. 2. Within 5 days, submit all periodic compliance reports due since June 30, 2008. 3. Within 10 days, pay to the cashier's office of the District, a fine of $5,000.00 for the above- described violations in accordance with section _____ of the District Industrial Pretreatment Ordinance. 4. This order, entered this 12th day of January, 2009, shall be effective upon receipt by [Industry]. Signed: _________________________ [Name] General Manager Kishwaukee Water Reclamation District 1301 Sycamore Rd. DeKalb, IL 60115 Example: Consent Order In the Matter of Administrative Consent Order Name and Address Of Industry Consent Order WHEREAS, The Kishwaukee Water Reclamation District (District) pursuant to the powers, duties and responsibilities vested in and imposed upon the District Manager by provisions of the District's Industrial Pretreatment Ordinance, have conducted an ongoing investigation of [Industry] and have determined that:. 1. The District owns and operates a wastewater treatment plant which is adversely impacted by discharges from industrial users, including [Industry], and has implemented a pretreatment program to control such discharges. 2. [Industry] has consistently violated the pollutant limits in its wastewater discharge permit as set forth in Exhibit 1, attached hereto. 3. Therefore, to ensure that [Industry] is brought into compliance with its permit limits at the earliest possible date, IT IS HEREBY AGREED AND ORDERED, BETWEEN THE [INDUSTRY] AND THE GENERAL MANAGER OF THE DISTRICT, that [Industry] shall: a. By July 15, 2008, obtain the services of a licensed professional engineer specializing in wastewater treatment for the purpose of designing a pretreatment system which will bring [Industry] into compliance with its wastewater discharge permit. b. By September 30, 2008, submit plans and specifications for the proposed pretreatment system to the District for review. c. By December 31, 2008, install the pretreatment system in accordance with the plans and specifications submitted in item b above. d. By January 15, 2009, achieve compliance with the limits set forth in Exhibit 1. e. [Industry] shall pay $1,000 per day for each day it fails to comply with the schedule set out in items a-d above. The $1,000 per day penalty shall be paid to the accountant at the District within 5 days of being demanded by the District. 4. In the event [Industry] fails to comply with any of the deadlines set forth, [Industry] shall, within one (1) working day after expiration of the deadline, notify the District in writing. This notice shall describe the reasons for [Industry]'s failure to comply, the additional amount of time needed to complete the remaining work, and the steps to be taken to avoid future delays. This notification in no way excuses [Industry] from its responsibility to meet any later milestones required by this Consent Order. 5. Compliance with the terms and conditions of this Consent Order shall not be construed to relieve [Industry] of its obligation to comply with its wastewater discharge permit which remains in full force and effect. The District reserves the right to seek any and all remedies available to it under Section 10 of the District Industrial Pretreatment Ordinance for any violation cited by this order. 6. Violation of this Consent Order shall constitute a further violation of the District's Industrial Pretreatment Ordinance and subjects [Industry] to all penalties described by section 10 of the District Industrial Pretreatment Ordinance. 7. Nothing in this Consent Order shall be construed to limit any authority of the District to issue any other orders or take any other action which deems necessary to protect the wastewater treatment plant, the environment or the public health and safety. SIGNATORIES FOR [INDUSTRY] ___________________ (Date) ____________________________ Name Representative of [Industry] FOR KISHWAUKEE WATER RECLAMATION DISTRICT ___________________ (Date) ________________________________________ Name-General Manager Kishwaukee Water Reclamation District Pretreatment Program Telephone Documentation Pretreatment Staff initiating telephone call: _______________________________________ Industry name and Contact person: _____________________________________________ Date and Time of Call: _______________________________________________________ Reason for telephone call: ____________________________________________________ Synopsis of conversation: _____________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ____________________________________________________________________________ Date and Time issue was resolved Enforcement Tracking Log Name of Industry: _________________________ Nature of Violation: ________________________ Date of Violation: _________________________ Initial Enforcement Action Taken: ____________________________ Date of Enforcement Action: __________________________________ Date IU back in Compliance: __________________________________ OR Escalated Enforcement Action/Date of Action: ______________________ Comments: Ist Half 2023 Month January February March April May June* Total Days/Period* Average Production Month January February March April May June* Total * Estimated Conex - Semi Annual Compliance Report - June 2023 Clad-Net (lb/mo) 343,815 442,778 513,059 368,082 345,555 402,658 2,415,947 Scrap Clad (lb/mo) 38,983 84,321 39,846 78,750 119,692 80,609 442,201 Production Scrap Al Flash (lb/mo) 7,989 5,688 6,297 15,991 27,753 23,186 86,904 Summary Heat Treat (lb/mo) 285,815 125 2,982 lb/day AL Clean (gal/mo) 0 0 0 0 0 0 0 AL Rinse (gal/mo) 0 0 0 0 0 0 0 AL Rinse pH N/A N/A N/A N/A N/A N/A Heat Treat (gal/mo) 0 0 0 0 0 0 0 AL Clean (lb/mo) AL Rinse (lb/mo) 372,719 372,719 Steel Clean (gal/mo) 500 500 500 500 500 500 3,000 Steel Clean pH 8.3 8.3 8.3 8.3 8.3 8.3 1 Conex - Semi Annual Compliance Report - June 2023 Al Extrusion Compliance Summary - Outfall 002 Aluminum Extrusion Pollutant Cr CN Zn O&G TTO AL Production Basis AL Flow Basis Units mg/L mg/L mg/L mg/L mg/L lb/d gal/day 2,982 0 Daily Max 14.4 7.7 39.4 385 26.68 NS is No Sample Collected, No Regulated Flow During Period Monthly Average 5.9 3.1 16.31 385 --- Notes: (1) Oil & Grease used as surrogate; TTO Certification Attached Outfall 002 Result NS NS NS NS NA Status O.K. O.K. O.K. O.K. O.K. 2 Conex - Semi Annual Compliance Report - June 2023 Local Limit Compliance Summary - Outfall 001 Outfall 001 Local Limits Allowable Measured Pollutant (mg/L) (mg/L) Cadmium 0.885 <0.005 Copper 11.7 0.009 Lead 3.52 <0.005 Nickel 2.71 0.012 Mercury 0.076 <0.0005 Molybdnenum 2.14 <0.01 pH* 5.5 - 10.5 8.4 * Measured onsite Outfall 001 Status O.K. O.K. O.K. O.K. O.K. O.K. O.K. 3 First Environmental Laboratories, Inc IL ELAP / NELAC Certification # 100292 1600 Shore Road Naperville, Illinois 60563 Phone (630) 778-1200 FirstEnv.com June 06, 2023 Mr. Charles Dobbel CONEX CABLE 816 East Locust Street Dekalb, IL 60115 Project ID: STEEL RINSE First Environmental File ID: 23-4482 Date Received: May 31, 2023 Dear Mr. Charles Dobbel: The above referenced project was analyzed as directed on the enclosed chain of custody record. All Quality Control criteria as outlined in the methods and current IL ELAP/NELAP have been met unless otherwise noted. QA/QC documentation and raw data will remain on file for future reference. Our accreditation number is 100292 and our current certificate is number: 1002922023-10: effective 03/07/2023 through 02/28/2024. All analyses were performed in accordance with the currently amended 40 CFR Part 136. I thank you for the opportunity to be of service to you and look forward to working with you again in the future. Should you have any questions regarding any of the enclosed analytical data or need additional information, please contact me at (630) 778-1200 or neal@firstenv.com. Sincerely, Joy Geraci Project Manager Page 1 of 5 First Environmental Laboratories, Inc IL ELAP / NELAC Certification # 100292 1600 Shore Road Naperville, Illinois 60563 Phone (630) 778-1200 FirstEnv.com Case Narrative CONEX CABLE Project ID: STEEL RINSE Lab File ID: 23-4482 Date Received: May 31, 2023 All quality control criteria, as outlined in the methods, have been met except as noted below or on the following analytical report. The results in this report apply to the samples in the following table: Laboratory Sample ID 23-4482-001 Client Sample Identifier STEEL RINSE Date/Time Collected 5/26/2023 Sample Batch Comments: Time of sample collection was not provided. Page 2 of 5 First Environmental Laboratories, Inc IL ELAP / NELAC Certification # 100292 1600 Shore Road Naperville, Illinois 60563 Phone (630) 778-1200 FirstEnv.com Case Narrative CONEX CABLE Project ID: STEEL RINSE Lab File ID: 23-4482 Date Received: May 31, 2023 All quality control criteria, as outlined in the methods, have been met except as noted below or on the following analytical report. The following is a definition of flags that may be used in this report: Flag Description Flag Description A Method holding time is 15 minutes from collection. Lab analysis was performed as soon as possible. B Analyte was found in the method blank. L LCS recovery outside control limits. < Analyte not detected at or above the reporting limit. M MS recovery outside control limits; LCS acceptable. C Sample received in an improper container for this test. P Chemical preservation pH adjusted in lab. D Surrogates diluted out; recovery not available. Q Result was determined by a GC/MS database search. E Estimated result; concentration exceeds calibration range. S Analysis was subcontracted to another laboratory. G Surrogate recovery outside control limits. T Result is less than three times the MDL value. H Analysis or extraction holding time exceeded. W Reporting limit elevated due to sample matrix. I ICVS % rec outside 95-105% but within 90-110% J Estimated result; concentration is less than routine RL but N Analyte is not part of our NELAC accreditation or greater than MDL. accreditation may not be available for this parameter. Routine Reporting Limit (Lowest amount that can be RL detected when routine weights/volumes are used without dilution.) Analyte was not detected using a library search routine; ND No calibration standard was analyzed. Page 3 of 5 First Environmental Laboratories, Inc IL ELAP / NELAC Certification # 100292 1600 Shore Road Naperville, Illinois 60563 Phone (630) 778-1200 FirstEnv.com Client: Project ID: Sample ID: Sample No: CONEX CABLE STEEL RINSE STEEL RINSE 23-4482-001 Analyte Total Metals Analysis Date: 06/02/23 Analyzed By: KJM Cadmium Copper Lead Molybdenum Nickel Total Mercury Analysis Date: 06/06/23 Analyzed By: SLO Mercury Analytical Report Date Collected: Time Collected: Date Received: Date Reported: 05/26/23 05/31/23 06/06/23 Method: 200.7R4.4 Result < 0.005 0.009 < 0.005 < 0.01 0.012 Method: 245.1R3.0 R.L. Units Flags Preparation Method 200.7W Preparation Date: 06/02/23 Prepped By: KJM 0.005 mg/L 0.005 mg/L 0.005 mg/L 0.01 mg/L 0.005 mg/L < 0.0005 0.0005 mg/L Page 4 of 5 Page 5 of 5 Conex - Semi Annual Compliance Report - Jul - Dec 2023 2nd half 2023 Month July August September October November December* Total Clad-Net (lb/mo) 298,868 366,025 445,994 450,377 443,405 400,934 2,405,603 Scrap Clad (lb/mo) 41,229 75,053 82,758 25,070 110,937 67,009 402,056 Production Summary Scrap Al Flash Heat Treat (lb/mo) (lb/mo) 10,059 9,870 7,867 515 16,244 8,911 53,466 280,766 AL Clean (lb/mo) AL Rinse (lb/mo) 334,232 334,232 Days/Period* 125 Average Production 2,674 lb/day Month July August September October November December Total AL Clean AL Rinse (gal/mo) (gal/mo) 0 0 0 0 0 0 0 0 0 0 0 0 0 0 AL Rinse pH 0 0 0 0 0 0 0 Heat Treat (gal/mo) Steel Clean (gal/mo) 0 500 0 500 0 500 0 500 0 500 0 0 0 2500 Steel Clean pH 8.30 8.30 8.30 8.30 8.30 * Estimated 1 Conex - Semi Annual Compliance Report - Jul - Dec 2023 Al Extrusion Compliance Summary - Outfall 002 Aluminum Extrusion Pollutant Cr CN Zn O&G TTO AL Production Basis AL Flow Basis Units mg/L mg/L mg/L mg/L mg/L lb/d gal/day 2,674 0 Daily Max 14.4 7.7 39.4 385 26.68 NS is No Sample Collected, No Regulated Flow During Period Monthly Average 5.9 3.1 16.31 385 --- Notes: (1) Oil & Grease used as surrogate; TTO Certification Attached Outfall 002 Result NS NS NS NS NA Status O.K. O.K. O.K. O.K. O.K. 2 Conex - Semi Annual Compliance Report - Jul - Dec 2023 Local Limit Compliance Summary - Outfall 001 Outfall 001 Local Limits Allowable Measured Pollutant (mg/L) (mg/L) Cadmium 0.885 <0.005 Copper 11.7 0.007 Lead 3.52 <0.005 Nickel 2.71 0,012 Mercury 0.076 <0.0005 Molybdnenum 2.14 <0.01 pH* 5.5 - 10.5 7.9 * Measured onsite Outfall 001 Status O.K. O.K. O.K. O.K. O.K. O.K. O.K. 3 First Environmental Laboratories, Inc IL ELAP / NELAC Certification # 100292 1600 Shore Road Naperville, Illinois 60563 Phone (630) 778-1200 FirstEnv.com December 05, 2023 Mr. Charles Dobbel CONEX CABLE 816 East Locust Street Dekalb, IL 60115 Project ID: Steel Rinse First Environmental File ID: 23-10625 Date Received: November 30, 2023 Dear Mr. Charles Dobbel: The above referenced project was analyzed as directed on the enclosed chain of custody record. All Quality Control criteria as outlined in the methods and current IL ELAP/NELAP have been met unless otherwise noted. QA/QC documentation and raw data will remain on file for future reference. Our accreditation number is 100292 and our current certificate is number: 1002922023-11: effective 08/29/2023 through 02/28/2024. All analyses were performed in accordance with the currently amended 40 CFR Part 136. I thank you for the opportunity to be of service to you and look forward to working with you again in the future. Should you have any questions regarding any of the enclosed analytical data or need additional information, please contact me at (630) 778-1200 or neal@firstenv.com. Sincerely, Joy Geraci Project Manager Page 1 of 5 First Environmental Laboratories, Inc IL ELAP / NELAC Certification # 100292 1600 Shore Road Naperville, Illinois 60563 Phone (630) 778-1200 FirstEnv.com Case Narrative CONEX CABLE Project ID: Steel Rinse Lab File ID: 23-10625 Date Received: November 30, 2023 All quality control criteria, as outlined in the methods, have been met except as noted below or on the following analytical report. The results in this report apply to the samples in the following table: Laboratory Sample ID 23-10625-001 Client Sample Identifier Steel Rinse Date/Time Collected 11/29/2023 10:00 Sample Batch Comments: Sample acceptance criteria were met. Page 2 of 5 First Environmental Laboratories, Inc IL ELAP / NELAC Certification # 100292 1600 Shore Road Naperville, Illinois 60563 Phone (630) 778-1200 FirstEnv.com Case Narrative CONEX CABLE Project ID: Steel Rinse Lab File ID: 23-10625 Date Received: November 30, 2023 All quality control criteria, as outlined in the methods, have been met except as noted below or on the following analytical report. The following is a definition of flags that may be used in this report: Flag Description Flag Description A Method holding time is 15 minutes from collection. Lab analysis was performed as soon as possible. B Analyte was found in the method blank. L LCS recovery outside control limits. < Analyte not detected at or above the reporting limit. M MS recovery outside control limits; LCS acceptable. C Sample received in an improper container for this test. P Chemical preservation pH adjusted in lab. D Surrogates diluted out; recovery not available. Q Result was determined by a GC/MS database search. E Estimated result; concentration exceeds calibration range. S Analysis was subcontracted to another laboratory. G Surrogate recovery outside control limits. T Result is less than three times the MDL value. H Analysis or extraction holding time exceeded. W Reporting limit elevated due to sample matrix. I ICVS % rec outside 95-105% but within 90-110% J Estimated result; concentration is less than routine RL but N Analyte is not part of our NELAC accreditation or greater than MDL. accreditation may not be available for this parameter. Routine Reporting Limit (Lowest amount that can be RL detected when routine weights/volumes are used without dilution.) Analyte was not detected using a library search routine; ND No calibration standard was analyzed. Page 3 of 5 First Environmental Laboratories, Inc IL ELAP / NELAC Certification # 100292 1600 Shore Road Naperville, Illinois 60563 Phone (630) 778-1200 FirstEnv.com Client: Project ID: Sample ID: Sample No: CONEX CABLE Steel Rinse Steel Rinse 23-10625-001 Analyte Total Metals Analysis Date: 12/04/23 Analyzed By: KJM Cadmium Copper Lead Molybdenum Nickel Total Mercury Analysis Date: 12/05/23 Analyzed By: SLO Mercury Analytical Report Date Collected: Time Collected: Date Received: Date Reported: 11/29/23 10:00 11/30/23 12/05/23 Method: 200.7R4.4 Result < 0.005 0.007 < 0.005 < 0.01 0.012 Method: 245.1R3.0 R.L. Units Flags Preparation Method 200.7W Preparation Date: 12/04/23 Prepped By: KJM 0.005 mg/L 0.005 mg/L 0.005 mg/L 0.01 mg/L 0.005 mg/L < 0.0005 0.0005 mg/L Page 4 of 5 Page 5 of 5 BOARD OF TRUSTEES DENNIS J. COLLINS PRESIDENT TIMOTHY A. STRUTHERS VICE PRESIDENT CAROL B. ZAR CLERK OFFICERS KEITH FOSTER ATTORNEY STEVE PARKER TREASURER February 25, 2021 1301 Sycamore Road, DeKalb, Illinois 60115-0624 Telephone:(815) 758-3513 Email: mail@kishwrd.com ADMINISTRATION MARK EDDINGTON, P.E. DISTRICT MANAGER STEVE OLSEN OPERATIONS MANAGER MIKE HOLLAND, P.E. DISTRICT ENGINEER / ASST. DISTRICT MGR. TRACY ZENKNER ADMINISTRATIVE ASSISTANT Ms. Monica Ebert CST Storage 345 Harvestore Drive DeKalb, IL 60115 Dear Ms. Ebert: This letter constitutes a "NOTICE OF VIOLATION" of your discharge permit with the Kishwaukee Water Reclamation District. Per your permit there are several items that need to be included in your semi-annual report. As of today it is still missing the flow data. Please respond within 10 days as to the reason for this violation and your intended actions to preclude excursions of this nature in the future. As always, should any questions arise, feel free to call. Sincerely, Allison Yates Pretreatment Coordinator