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CWA COMPLIANCE EVALUATION INSPECTION REPORT U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 5 Purpose: Compliance Evaluation Inspection Facility: Quality Dairy, LLC N 5232 BK Line Road Luxemburg, Wisconsin 54217 Kewaunee County 44.513856937943395, -87.764180364316 NPDES Permit Number: WI-0059579 Date of Inspection: 06/05/2024 EPA Representatives: Benjamin Atkinson, Agronomist atkinson.ben@epa.gov 312-353-8243 Joan Rogers, Environmental Scientist rogers.joan@epa.gov 312-886-2785 State Representatives: James Salscheider, Wastewater Specialist james.salscheider@wisconsin.gov 920-367-3007 Joe Baeten, NR Basin Supervisor Joseph.Baeten@wisconsin.gov 920-366-2072 Facility Representatives: Glen Dufek, Owner/Operator gdufek@gmail.com 920-371-3682 Report Prepared by: Benjamin Atkinson, Agronomist Inspector Signature: _B_E__N__J_A__M__I_N__A__T_K__I_N_S__O__N___Da_t_e:_2_0_24_.0_8_.0_5_0_6:_4_4:_04_-_0_5'_00_'______ Digitally signed by BENJAMIN ATKINSON Approver Name and Title: Ryan Bahr, Section 2 Supervisor, Water Enforcement and Compliance Assurance Branch Approver Signature: _R__y_a__n__B__a__h__r_____________D__at_e_: 2_0_2_4_.0_8_.0_5_0_9_:_50_:_20__-0_5_'0_0_' ___ Digitally signed by Ryan Bahr 1 Quality Dairy, LLC June 5, 2024 1. BACKGROUND The purpose of this report is to describe, evaluate and document Quality Dairy, LLC's compliance with the Clean Water Act (CWA) and its WPDES Permit at its Luxemburg, Wisconsin facility (Facility) on June 5, 2024. This inspection was performed pursuant to Section 308(a) of the Federal Water Pollution Control Act, as amended. The Facility is a large dairy Concentrated Animal Feeding Operation. The Facility confines approximately 1900 mature (dry and milking) dairy cows. The Facility was purchased in 2022 and was previously De-Ran Dairy. Surface water at the facility is either collected by a series of storm water drains which outlet to a grassed waterway in an adjacent agricultural field or surface flows to the adjacent agricultural fields. The grassed waterway flows northeast approximately 3 miles to School Creek. School Creek flows to the Kewaunee River which is a Traditionally Navigable Waterway. The Facility has coverage under WPDES Permit WI-0059579. The permit was issued August 31, 2022. It has an effective date of September 1, 2022 and expiration date of August 31, 2027. 2. SITE INSPECTION Table 1: Site Entry and Opening Conference Arrival Time: 8:47 AM Temperature: 67 F Precipitation: Light Rain Presented credentials? Yes Credentials presented to whom and at what Presented credentials to Glen Dufek time? - the Operator Was an opening conference held? With Yes, Dan Davister, Glen Dufek, whom? Larry (last name unknown) If photographs or documents were taken, does the facility consider any to No be Confidential Business Information (CBI)? EPA vehicle parked in approved location? Yes Location where EPA vehicle was parked? Next to Milking Parlor Disposable boots worn? Yes Other bio-security measures taken (state vet Yes, state vet contacted, vehicle contacted, etc.): washed after inspection. 2.1 Records Review (The following Records Review tables reflect information provided before the walk-through of the facility, unless otherwise noted.) 2 Quality Dairy, LLC June 5, 2024 Table 2: Documents Checklist(s) Used R5 CAFO Inspection Checklist Table 3: Facility Description Type of Animal Number of Capacity Animals Dairy Cows, 1,900 1,900 Mature (milking and dry) Minimum Number of Animals in previous 5 years: Maximum Number of Animals in previous 5 years: Number of Animals that are stabled/confined and/or fed/maintained for 45 days or more in previous 12 months: Amount of Liquid Manure Generated per year: Amount of Solid Manure Generated per year: Does the facility have an NPDES Permit? SIC or NAICS code: Do animals have direct access to WOUS? Are crops, vegetation, forage growth, or post harvest residues not sustained in the normal growing season over any portion of the lot or facility where animals are kept? What is the area (acres) of the production area? What is the area (acres) of the pasture? How many employees (not counting family members)? Other facilities under common ownership (name and address): Type of Confinement Total 1,900 1,900 1,900 Approximately 32 million gallons Approximately 250 tons Yes 0241 No Yes Approximately 20 Acres 0 15 None Table 4: Livestock Waste Storage Type of Storage Type of Depth Storage Capacity Liner Markers Present Pond ~20 M Clay Yes Gallons Pond ~ 1 M Concrete No Gallons Records at site of storage structure design? Last Time Waste was Removed May 2024 Days of Storage 264 Total May 2024 Yes- kept electronically 3 Is manure stored for the short term? If yes, describe where it is stored, how it is drained and where it drains to. Are records kept of the level of manure in the storage structures? When was the last time a storage structure was emptied, either partially or completely? What amount of manure or process wastewater was removed the last time the storage structure was emptied, either partially or completely? Do the facility personnel inspect and keep records of all diversion devices? Do the facility personnel inspect and keep records of all impoundments? Do the facility personnel inspect and keep records of all the water lines? Do the facility personnel perform routine visual inspections and keep records of the production area? Does the waste storage system have a managed outfall or discharge point? If yes, provide a description of the outfall and a description of the area receiving the discharge. Has the facility had any documented discharges of livestock waste to surface water in the past year? Are there safety devices installed around any manure storage ponds? (Barriers at the end of manure push off platforms, fences around pond, signage.) Quality Dairy, LLC June 5, 2024 No Yes May 2024 Not known at time of inspection Yes Yes Yes Yes No No No 4 Quality Dairy, LLC June 5, 2024 Table 5: Livestock Waste Management Describe the way manure is collected and disposed of at the facility: Manure from Barns 1, 2, and 3 is automatically scraped and pumped to Manure Storage 2. Manure from the Dry Cow Barn is pumped to Manure Storage 1. Describe the way used bedding is collected and disposed of at the facility: Composted manure solids are used as bedding. Used bedding is collected and disposed of with manure. Are mortality records kept? Yes Describe the way mortalities are managed at the facility: Mortalities are placed in a collection area and picked up daily by a mink farm. What type of method is used to provide drinking water for the animals? (Drinkers with float system? Nipple waters? If nipple waters, is backflow prevention installed?) Drinking water is provided in tanks with floats. Spilled water is collected and disposed of with manure. Describe the way mist cooling water is collected and disposed of at the facility: Collected and dispose of with manure. Describe how chemicals are stored and how used or spilled chemicals are collected and disposed of at the facility: Chemicals are stored in a storage room in the Milking Parlor. Any spills would flow to a floor drain and to Manure Storage 2. Describe the way water that has been used to wash/flush barns is collected and disposed of at the facility: No barn flush water is used. Describe the way feed is contained and how runoff from feed is collected and disposed of at the facility: Feed is stored on an asphalt and concrete pad with full collection of all runoff. If a dairy, describe how process wastewater from the plate cooler water is collected and disposed of at the facility: 5 Plate cooler water is used to water cows. Quality Dairy, LLC June 5, 2024 If a dairy, describe how process wastewater from the cleaning of the milking parlor is collected and disposed of at the facility: Parlor wash water is collected and disposed of with manure. If a dairy, describe how process wastewater from the cleaning of the milk tanks is disposed of at the facility: Milk tankers are used. If a dairy, how many times per day are Cows are milked three times a day. The cows milked? Operator pointed out that the number of times a day a facility milks is a poor determiner of the volume of water used and pointed out that they had taken steps to substantially reduce the amount of wash water generated at the facility beyond what other facilities that milk twice a day produce. Table 6: Land Application and Disposal of Manure and Process Wastewater Does the facility perform and keep records of the Yes manure testing? When was the last time a sample was taken of the May 2024 manure and/or process wastewater? Describe the process to take the manure and/or Manure samples are collected process wastewater sample. when manure pumped following agitation. Number of acres available for land application: Are land application records kept? Who applies the manure and process wastewater to the fields? Are weather conditions at time of application kept? (24 before - 24 after) Does the facility perform and keep records of the soil testing? Is manure transferred off-site to another party? Do facility personnel perform periodic inspection of land application equipment? Approximately 4,000 acres. Yes The Facility Yes Yes No Yes 6 Quality Dairy, LLC June 5, 2024 Table 7: Receiving Surface Waters Describe the surface flow pathways: Surface water at the facility is either collected by a series of storm water drains which outlet to a grassed waterway in an adjacent agricultural field or surface flows to the adjacent agricultural fields. The grassed waterway flows northeast approximately 3 miles to School Creek. School Creek flows to the Kewaunee River which is a Traditionally Navigable Waterway. How many months out of the year is there flow in the nearest surface water pathway: Are there any storm water pathways entering the facility? Are there any clean water ponds on site? What is the name of the first waterway that is identified as a Traditional Navigable Water (TNW) for surface flow from the facility? Is the surface water pathway nearest to the facility considered to be ephemeral, intermittent or perennial? Has the surface water pathway nearest to the facility been assessed for water quality? The Operator stated that the grassed waterways only flow in response to precipitation. There are two grassed waterways that flow into a culvert under the Facility from the south and outlet on the northeast side of the Facility. No Kewaunee River Ephemeral No Table 8: Nutrient Management Plan NMP on site? Electronically Date NMP Submitted: 2022 Planner Name/Company: United Coop Date that the NMP was last March 2024 updated: Storage Description: Table 9: NPDES Permit Type of permit (General, individual) Is a copy of the permit on site? Date that the permit was issued: Date that the permit will expire: Does the permit contain a compliance schedule? If yes, provide a detailed description of the requirements and the status. Individual Electronically 08/31/2022 08/31/2027 The permit requires an engineering evaluation of Waste Storage 2. 7 Have there been any changes made to No the production area since the permit was issued? If yes, provide a detailed description. Quality Dairy, LLC June 5, 2024 2.2 Walkthrough of the Facility Ben Atkinson and Joan Rogers of the US EPA (the Inspectors) arrived onsite at 8:47 AM. James Salscheider and Joe Baeten of WDNR (WDNR) arrived concurrently. The Inspectors donned their biosecurity boots and made contact with the Operator by phone. The Operator agreed to come meet them at the Facility. Following the Operator's arrival, EPA presented their credentials, explained the purpose of the Inspection, and confirmed that they were parked in an appropriate location. The Inspectors and the Operator then went into an office and conducted the opening conference and interview portion of the inspection. Following the interview, the Inspectors, WDNR, the Operator and his representatives began the walkthrough of the Facility. The walkthrough began on the south side of the Milking Parlor. The Inspectors walked east in the grassed area north of Barn three and observed a storm water drain inlet near the east end of the grassed area (photo 1). The Inspectors then walked west along the north side of Barn 3 and across west end (photos 2 and 3). The Inspectors observed a bunker on the west end of Barn 3 with a pipe through the concrete at ground level. There were some organic solids around the west side of the bunker. No surface water flow paths were observed from the area. The Inspectors walked east along the south side of Barn 3 and observed the two grassed waterways flowing into the culvert under the Facility from the South (photos 4-6). The Inspectors continued walking east and arrived at Manure Storage 2. The Inspectors observed an animal burrow on the berm of Manure Storage 2 and pointed it out as an area of concern to the Operator. The Inspectors walked south along west side of Manure Storage 2 and observed an additional animal burrow (photo 8). The Inspectors walked south, around the southern end of Manure Storage 2 and then walked north along the east side (photos 9-11). The Inspectors observed indentions left in the pit's berm by the agitator being lowered in (photo 12). WDNR advised that the indentions could lead to erosion and compromising of the clay liner and recommended addressing the indentions. Additionally, WDNR pointed out that the concrete pad in the northwest corner of Manure Storage 2 had been undercut by erosion and should be addressed. The Inspectors walked west along the north side Manure Storage 2 and observed the depth marker for Manure Storage 2 (photo 13). The Inspectors then walked northeast to the outlet of the culvert observed previously on the south side of the Facility (photos 14-16). The Inspectors then walked north and observed Manure Storage 1 (photos 17 - 19). The Inspectors did not observe a depth marker present in Manure Storage 1. The Inspectors 8 Quality Dairy, LLC June 5, 2024 did observe a pipe coming through the wall of the Dry Cow Barn (photo 20). The Inspectors observed an erosional pathway from the area around the pipe down to Manure Storage 1. The Operator stated that this pipe connected to a hand washing sink located in the maternity area. The Inspectors then walked back southwest to the east end of Barn 3. The Inspectors observed a stormwater drain surface inlet in the gravel area (Photo 21). The Inspectors then walked west in the grassed area between Barn 3 and Barn 2. The Inspectors observed a stormwater drain surface inlet near the west end of the grassed area (photo 22). The Inspectors then walked east and observed the mortality staging area located at the southeast corner of Barn 2 (photos 23 and 24). The Inspectors observed and noted to the Operator that, while no runoff was observed, it appeared that there was the possibility for runoff from the mortality staging area to flow to the grassed area between Barn 2 and Barn 3 and then to the stormwater drain. The Operator stated that he would look into using a covered shed at the northeast corner of Barn 2 as a mortality staging area (photo 25). The Inspectors then walked west to the west end of the grassed area between Barn 2 and Barn 1. The Inspectors observed a stormwater drain surface inlet (photos 26 and 27). The Inspectors then walked east to the east end of Barn 1 and observed series of stormwater drain surface inlets located between the Dry Cow Barn and the Commodity Building (photos 28-31). The Inspectors walked south to the southern end of the Commodity Building and then north between the east side of the feed pad and the west side of the Commodity Building (photos 32 and 33). The Inspectors continued walking north and observed a pipe under the access road that could convey stormwater from the north end of the grassed area between the Commodity Building and the feed pad to the roadside ditch south of Luxemburg Road (photos 34 and 35). The Inspectors then walked west across the north end of the feed pad and observed a pipe outletting on the north side of Luxemburg Road north of the northwest corner of the feed pad (photo 38). The Inspectors then walked south along the west side of the feed pad and observed two stormwater drain surface inlets in the grass between the feed pad and BK Line Road (photos 39 and 41). The Inspectors also observed an area where it appeared wind had blown feed over the berm of the feed pad (photo 40). The Inspectors then walked south to the southwest corner of the feed pad and then east. The Inspectors observed the runoff collection drain that collects the runoff from the feed pad (photo 42). The Inspectors then walked west around the west end of Barn 1 and then east to the east end of the grassed area between Barn 1 and the Milking Parlor. The Inspectors observed a stormwater drain surface inlet (photo 46). Inside the stormwater drain, the Inspectors observed a white pipe with trace wire entering the drain from the southwest (photo 45). The Inspectors walked southwest to the plate cooler tank and behind the tank they 9 Quality Dairy, LLC June 5, 2024 observed a white pipe coming out of the wall of the animal walkway to the Milking Parlor (photo 47). The Inspectors observed that there was manure around the base of the pipe and on the wall around where the pipe penetrated the wall. The Operator stated that he believed the pipe was coming from a groundwater sump in the basement below the Milking Parlor and that the manure was being pushed around the pipe from the animal walkway but not entering or flowing through the pipe. The Inspectors then walked west and observed a surface drain near the milk tanker parking area (photo 48). The Operator stated that this drain was not connected to the rest of the storm water drains. This drain is collected and sent to storage. He stated that WDNR had required that this drain collect any milk tank wash water. The inspectors then walked south and observed a stormwater drain surface inlet near the northwest corner of the Milking Parlor (photo 49). This concluded the walkthrough of the Facility. The Inspectors and the Facility personnel then returned to office for the closing conference. 2.3 Closing Conference and Post-Inspection Table 10: Post Walk-Through Was a closing conference held? With Yes, the Operator whom? Were specific Areas of Concern discussed with facility personnel? Yes Who were the Areas of Concern The Operator discussed with? Were any deficiencies or areas of No concern addressed or fixed during the inspection? If so, list what was done. Exit Time: Disposable Boots Left at Facility? Vehicle Washed after leaving facility? 12:15 PM Yes Yes 3. AREAS OF CONCERN EPA observed these areas of concern: 1. Lack of containment around the bunker at the southwest corner of Barn 3. 2. Animal burrows in the berm along Manure Storage 2. 3. Agitator wheel ruts in Manure Storage 2 creating the potential for liner erosion. 4. The concrete pad in Manure Storage 2 being undercut. 5. Lack of containment around the mortality staging area. 6. Feed outside the berm on the west side of the feed pad. 10 Quality Dairy, LLC June 5, 2024 7. The PVC pipe entering the stormwater drain between Barn 1 and the Milking Parlor 4. LIST OF ATTACHMENTS A) Aerial photograph of Quality Dairy, LLC with buildings, waterways and discharge pathways labeled. B) Photo Log 11 Attachment A - Aerial Photo Legend !@ Surface Drain Grassed Waterways Feed Pad Runoff Collection Attachment B - Photo Log Quality Dairy, LLC EPA Inspection June 5, 2024 All photos taken by Joan Rogers, Environmental Scientist, U.S. EPA Camera: Olympus TG-4 1: P6050658 Description: Storm water drain located between Barn 3 and the parlor walkway. Location: Grassed area on the south side of the parlor walkway. Camera Direction: West Date/Time: June 5, 2024 9:49 AM 2: P6050659 Description: Looking east along the south side of Barn 3. Note the drain at the bottom of the temporary bunker. Location: Southwest corner of Barn 3. Camera Direction: East Date/Time: June 5, 2024 9:51 AM Page 1 Quality Dairy LLC June 5, 2024 3: P6050660 Description: Looking southeast into the temporary bunker located at the southwest corner of Barn 3. Location: Southwest corner of Barn 3. Camera Direction: Southeast Date/Time: June 5, 2024 9:52 AM 4: P6050661 Description: Looking southwest along grassed waterway that flows into culvert under the Facility. Location: Centrally south of service road along the south side of Barn 3. Camera Direction: Southwest Date/Time: June 5, 2024 9:55 AM Page 2 Quality Dairy LLC June 5, 2024 5: P6050662 Description: Looking southeast along additional grassed waterway which flows into culvert under the Facility. Location: Centrally south of service road along the south side of Barn 3. Camera Direction: Southeast Date/Time: June 5, 2024 9:55 AM 6: P6050663 Description: Looking down at the confluance of the two grassed waterways as they enter the culvert under the Facility. Location: Centrally south of service road along the south side of Barn 3. Camera Direction: Down Date/Time: June 5, 2024 9:56 AM Page 3 Quality Dairy LLC June 5, 2024 7: P6050664 Description: Animal burrow in the west bank of Manure Storage 2. Location: Centrally located on the west side of Manure Storage 2. Camera Direction: East Date/Time: June 5, 2024 10:02 AM 8: P6050665 Description: Additional animal burrow on the side of Manure Storage 2 near the southwest corner. Location: Southwest corner of Manure Storage 2. Camera Direction: East Date/Time: June 5, 2024 10:04 AM Page 4 Quality Dairy LLC June 5, 2024 9: P6050666 Description: Looking northwest from the southeast corner of Manure Storage 2. Location: Southwest corner of Manure Storage 2. Camera Direction: Northwest Date/Time: June 5, 2024 10:07 AM 10: P6050667 Description: Looking northwest from the east side of Manure Storage 2. Note that the concrete pad built to protect the storage structures bank has been undercut and there is erosion on the internal walls of the pond. Location: Cerntrally on the east side of Manure Storage 2. Camera Direction: Northwest Date/Time: June 5, 2024 10:11 AM Page 5 Quality Dairy LLC June 5, 2024 11: P6050668 Description: Looking South along the east side of Manure Storage 2. Location: Northeast corner of Manure Storage 2. Camera Direction: South Date/Time: June 5, 2024 10:14 AM 12: P6050669 Description: Erosion in wheel ruts from where equipment was lowered into Manure Storage 2 on the north side. Location: North side of Manure Storage 2. Camera Direction: Down Date/Time: June 5, 2024 10:15 AM Page 6 Quality Dairy LLC June 5, 2024 13: P6050670 Description: Depth marker for Manure Storage 2 (red arrow). Location: Northwest corner of Manure Storage 2. Camera Direction: Down Date/Time: June 5, 2024 10:16 AM 14: P6050671 Description: Outlet of culvert under the Facility from the south side. Location: East side of the Facility, south of Manure Storage 1. Camera Direction: Southwest Date/Time: June 5, 2024 10:20 AM Page 7 Quality Dairy LLC June 5, 2024 15: P6050672 Description: Outlet of culvert under the Facility from the south side. Location: East side of the Facility, south of Manure Storage 1. Camera Direction: Southwest Date/Time: June 5, 2024 10:20 AM 16: P6050673 Description: Downstream along waterway flowing out of culvert under the Facility. Location: East side of the Facility, south of Manure Storage 1. Camera Direction: Northeast Date/Time: June 5, 2024 10:20 AM Page 8 Quality Dairy LLC June 5, 2024 17: P6050674 Description: Looking northwest from the south side of Manure Storage 1. The pier in Manure Storage 1 is left over from a previous manure handling system. Location: South side of Manure Stroage 1. Camera Direction: Northwest Date/Time: June 5, 2024 10:22 AM 18: P6050675 Description: Looking north at Manure Storage 1. Location: South side of Manure Storage 1. Camera Direction: North Date/Time: June 5, 2024 10:22 AM Page 9 Quality Dairy LLC June 5, 2024 19: P6050676 Description: Looking east from the west side of the southwest corner of Manure Storage 1. Note the outlet of the manure pipe from the Dry Cow Barn (red arrow). Location: West side of the southwest corner of Manure Storage 1. Camera Direction: East Date/Time: June 5, 2024 10:30 AM 20: P6050677 Description: Pipe in the wall on the east side of the Dry Cow Barn. Operator stated that his pipe connected to a sink in the maternity pin. The eroded flow to the left led down toward Manure Storage 1. Location: East side of the Dry Cow Barn. Camera Direction: Down Date/Time: June 5, 2024 10:32 AM Page 10 Quality Dairy LLC June 5, 2024 21: P6050678 Description: Stormwater drain inlet located at the east end of Barn 3. Location: Gravel area east of Barn 3. Camera Direction: South Date/Time: June 5, 2024 10:36 AM 22: P6050679 Description: Stormwater drain inlet located centrally between Barn 2 and Barn 3 west of the walkway. Location: Centrally between Barn 2 and Barn 3 west of the walkway Camera Direction: North Date/Time: June 5, 2024 10:40 AM Page 11 Quality Dairy LLC June 5, 2024 23: P6050680 Description: Mortality holding area located at the east end of Barn 2. Note potential flow path from the mortality holding area to the south toward the grassed area between Barn 2 and Barn 3 (blue arrow). Location: Southeast corner of Barn 2. Camera Direction: North Date/Time: June 5, 2024 10:42 AM 24: P6050681 Description: Mortality holding area located at the east end of Barn 2. Note potential flow path from the mortality holding area to the south toward the grassed area between Barn 2 and Barn 3 (blue arrow). Location: Southeast corner of Barn 2. Camera Direction: South Date/Time: June 5, 2024 10:43 AM Page 12 Quality Dairy LLC June 5, 2024 25: P6050682 Description: Covered shed (left) to which the Operator proposed moving the mortality holding area and hydrated lime storage container (right). Location: Northeast corner of Barn 2. Camera Direction: North Date/Time: June 5, 2024 10:44 AM 26: P6050683 Description: Looking east along the north side of Barn 2. Location: Northwest corner of Barn 2. Camera Direction: East Date/Time: June 5, 2024 10:47 AM Page 13 Quality Dairy LLC June 5, 2024 27: P6050684 Description: Looking east across grassed area between Barn 2 (right) and Barn 1 (left). Note stormwater surface drain inlet (blue arrow). Location: West end of the grassed area between Barn 2 and Barn 3. Camera Direction: East Date/Time: June 5, 2024 10:48 AM 28: P6050685 Description: Stormwater surface drain inlet located in access road northeast of Barn 1. Location: Northeast corner of Barn 1. Camera Direction: East Date/Time: June 5, 2024 10:52 AM Page 14 Quality Dairy LLC June 5, 2024 29: P6050686 Description: Stormwater surface drain inlet (blue arrow) west of dry cown barn and east of Commodity Barn. Location: Between Dry Cown Barn and Commodity Barn. Camera Direction: South Date/Time: June 5, 2024 10:54 AM 30: P6050687 Description: Looking north toward stormwater sufrace drain inlet (blue arrow) north of drain seen in photo 29. Location: Between Dry Cown Barn and Commodity Barn. Camera Direction: North Date/Time: June 5, 2024 10:55 AM Page 15 Quality Dairy LLC June 5, 2024 31: P6050688 Description: Additional stormwater surface drain inlet (blue arrow) east of the east end of the Commodity Barn. Location: East of the Commodity Barn. Camera Direction: North Date/Time: June 5, 2024 10:55 AM 32: P6050689 Description: Looking north into the south end of the Commodity Barn where they store bedding. Location: South end of the Commodity Barn. Camera Direction: North Date/Time: June 5, 2024 10:58 AM Page 16 Quality Dairy LLC June 5, 2024 33: P6050690 Description: Looking south between bunker (right) and west side of the Commodity Barn (left). Location: Between bunker and Commodity Barn. Camera Direction: South Date/Time: June 5, 2024 11:01 AM 34: P6050691 Description: Inlet for stormwater culvert (blue arrow) under access road. Location: Northwst corner of the Commodity Barn. Camera Direction: Northeast Date/Time: June 5, 2024 11:02 AM Page 17 Quality Dairy LLC June 5, 2024 35: P6050692 Description: Outlet of stormwater culvert under access road to roadside ditch on the south side of Luxemburg Road. Location: South of Luxemburg Road and north of the northwest corner of the Commodity Barn. Camera Direction: Northeast Date/Time: June 5, 2024 11:02 AM 36: P6050693 Description: Looking west along the north side of the feed pad. Location: Northeast corner of the feed pad. Camera Direction: West Date/Time: June 5, 2024 11:03 AM Page 18 Quality Dairy LLC June 5, 2024 37: P6050694 Description: Looking south at a mound of feed not yet covered. Location: Centrally on the north side of the feed pad. Camera Direction: South Date/Time: June 5, 2024 11:05 AM 38: P6050695 Description: Looking north downstream along the waterway on the north side of Luxemburg Road Location: Northwest of the Facility, north of Luxemburg Road. Camera Direction: North Date/Time: June 5, 2024 11:06 AM Page 19 Quality Dairy LLC June 5, 2024 39: P6050696 Description: Looking south along the west side of the feed pad east of County Line Road. Note stormwater surface drain inlet (blue arrow). Location: West side of feed pad. Camera Direction: South Date/Time: June 5, 2024 11:10 AM 40: P6050697 Description: Feed observed beyond outside of the berm on the west side of the feed pad. Location: West side of the feed pad. Camera Direction: Southeast Date/Time: June 5, 2024 11:10 AM Page 20 Quality Dairy LLC June 5, 2024 41: P6050698 Description: Stormwater drain surface inlet (blue arrow) in grass area west of the southwest corner of the feed pad. Location: West of the southwest corner of the feed pad. Camera Direction: West Date/Time: June 5, 2024 11:14 AM 42: P6050699 Description: Feed pad leachate collection inlet (blue arrow) on the south side of the feed pad. Location: Centrally on the south side of the feed pad. Camera Direction: Northwest Date/Time: June 5, 2024 11:19 AM Page 21 Quality Dairy LLC June 5, 2024 43: P6050700 Description: Looking southwest at the plate cooler water tank. Location: grassed area south of Barn 1 and west of animal walkway. Camera Direction: Southwest Date/Time: June 5, 2024 11:28 AM 44: P6050701 Description: Looking down into interior of the stormwater drain at the east end of the grassed area between Barn 1 and the milking Parlor. Location: East end of the grassed area between Barn 1 and the milking Parlor. Camera Direction: Down Date/Time: June 5, 2024 11:29 AM Page 22 Quality Dairy LLC June 5, 2024 45: P6050702 Description: Looking down into interior of the stormwater drain at the east end of the grassed area between Barn 1 and the milking Parlor. Note white PVC pipe entering stormwater drain from the southwest with locator wire. Location: East end of the grassed area between Barn 1 and the milking Parlor. Camera Direction: Down Date/Time: June 5, 2024 11:30 AM 46: P6050703 Description: Looking southwest toward the plate cooler water tank (red arrow). Stormwater drain surface inlet in forground (blue arrow). Location: grassed area south of Barn 1 and west of animal walkway. Camera Direction: Southwest Date/Time: June 5, 2024 11:31 AM Page 23 Quality Dairy LLC June 5, 2024 47: P6050704 Description: White PVC pipe with locator wire protruding the side of the animal walkway. Note manure around PVC pipe and on ground. The operator suspected that the white pipe is from a groundwater sump pump in the basement and that the area around the pipe was not well sealed allowing manure from the animal walkway to escape but he believed that no manure or process wastewater was in the pipe. Location: Northeast corner of the Milking Parlor. Camera Direction: Southeast Date/Time: June 5, 2024 11:34 AM 48: P6050705 Description: Stormwater collection inlet at milk tanker parking. The Operator stated that stormwater collected by this drain was sent to storage. Location: North of the northwest corner of the Milking Parlor. Camera Direction: South Date/Time: June 5, 2024 11:39 AM Page 24 Quality Dairy LLC June 5, 2024 49: P6050706 Description: Looking east at storwater surface drain inlet west of the northwest corner of the Milking Parlor. Location: Northwest of the Milking Parlor. Camera Direction: East Date/Time: June 5, 2024 11:41 AM Page 25 Quality Dairy LLC June 5, 2024