Document xzw4gZezZONJ1oa31DGY3o0Ey
CWA FOCUSED COMPLIANCE INSPECTION REPORT U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 5
Purpose: Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process
Facility: Milwaukee Metro Sewerage District (MMSD), Jones Island Biosolids Dewatering and Drying Facility
NPDES Permit Number: WI-0036820-04
Date of Inspection: June 4, 2021
MMSD Representatives: Sid Arora, Contract Compliance Assistant Manager Patrick Obenauf, Contract Compliance Manager Steve Unger, Contract Administrator
EPA Inspector: Dean Maraldo, EPA Region 5 Inspector; (312) 353-2098; maraldo.dean@epa.gov
Wisconsin Department of Natural Resources Representatives: Frederick Hegeman, Wastewater Engineer Jacob Wedesky, Wastewater Engineer
Report Prepared by: Dean Maraldo, EPA Region 5
Maraldo,
Digitally signed by Maraldo, Dean
EPA Inspector Signature: _D__e_a_n__________D17_a:t1e_9:_:2301_2-_10.5_0'60_.00_'9__________
Approver Name & Title: Ryan Bahr, Chief, Section 2, Water Enforcement and Compliance Assurance Branch
Digitally signed by RYAN
RYAN
BAHR
BAHR Date: 2021.06.09
Approver Signature/Date _______________1_7:_25_:2_1_-0_5'_00_' ____________
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
[This page intentionally left blank]
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
TABLE OF CONTENTS
I.
Introduction .................................................................................................................................. 1
II. Background................................................................................................................................... 4
III. Inspection Activity summary........................................................................................................ 4
IV. Closing Conference ...................................................................................................................... 6
V. Documents Received .................................................................................................................... 6
LIST OF APPENDICES
Appendix A: Aerial Image of MMSD's Jones Island Facility Appendix B: Facility Presentation "503 Compliance Update" Appendix C: March 2021 Monthly Report Appendix D: Photo Log Appendix E: Documents Received
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
[This page intentionally left blank]
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
I.
INTRODUCTION
On March 14, 2017, I, along with scientists from EPA's Office of Research and Development (ORD), and inspectors from EPA Region 7, conducted a biosolids inspection at the Milwaukee Metro Sewerage District Combined's (MMSD), Jones Island EQ Biosolids Dewatering and Drying Facility ("D&D Facility"). The D&D Facility is owned and operated by MMSD. Veolia Water Milwaukee, LLC, provides operational management and support for the production of EQ biosolids at the D&D Facility (See Appendix A - Facility map). MMSD sells and distributes processed biosolids as EQ biosolids under the product name "Milorganite." Once biosolids meet EQ requirements, they generally are not subject to further regulation under 40 CFR 503. As a result, 40 CFR 503 regulations include monitoring requirements to ensure EQ biosolids are safe for distribution to the public.
EPA assessed MMSD's compliance with 40 CFR Part 503 and the National Pollutant Discharge Elimination System (NPDES) permit for the D&D Facility. During the March 14, 2017 inspection, EPA identified the following areas of concern:
Heat drying temperature monitoring issues. MMSD did not measure the temperature of the sewage sludge particles or the wet-bulb temperature of the gas in contact with sewage sludge, as required under 40 CFR Part 503 (Appendix B (B)(2). Instead, MMSD measured temperature approximately 19 feet away from dryer furnace outlet along dryer discharge screw chute.
Location of compliance sampling for fecal coliform and moisture content. Fecal coliform samples were collected from the process distribution pile, not at the point of bagging or at the time of load out into trains or trucks for offsite shipping. 40 CFR Part 503.32(a)(7) Class A-- Alternative 5 requires either the density of fecal coliform in the sewage sludge shall be less than 1000 Most Probable Number per gram of total solids (dry weight basis), or the density of Salmonella, sp. bacteria in the sewage sludge shall be less than three Most Probable Number per four grams of total solids (dry weight basis) at the time the sewage sludge is used or disposed, at the time the sewage sludge is prepared for sale or given away in a bag or other container for application to the land, or at the time the sewage sludge or material derived from sewage sludge is prepared to meet the requirements in 503.10(b), (c), (e), or (f).
Product moisture samples were collected after temporary storage in silos, not at the point of bagging. 40 CFR Part 503.33(3) requires one of the vector attraction reduction requirements in 503.33 (b)(1) through (b)(8) shall be met when sewage sludge is sold or given away in a bag or other container for application to the land.
Fecal coliform sample preservation and holding time issues. MMSD stored fecal coliform samples at room temperature until the end of the month, when all samples were analyzed. Fecal coliform samples were not refrigerated to <10C and not analyzed within the standard holding time of 8 hours.
The purpose of the announced June 4, 2021 inspection was to follow up on MMSD's actions to address the above areas of concern and assess MMSD's compliance with 40 CFR Part 503 and the NPDES permit for the D&D Facility.
MMSD raised some concerns regarding COVID-19 and the face-to-face time needed to conduct the mainly indoor inspection of the D&D Facility. To address these concerns and limit face-to-face inspection efforts to only the physical inspection of the D&D Facility, we agreed to hold a pre-inspection teleconference on June 3, 2021, to discuss MMSD's efforts to address the above-referenced areas of concern. MMSD also presented a summary of recent biosolids compliance monitoring information (See
1
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix B "503 Compliance Update"). During the teleconference, MMSD described its new fecal coliform preservation and holding time protocols to address concerns raised during the March 2017 inspection. MMSD now refrigerates samples and analyzes samples within required holding times for fecal coliform. MMSD also described its new temperature monitoring system, including new temperature probes in each dryer and recycling bin. MMSD now utilizes two compliance methods to demonstrate Class-A biosolids compliance at any given time, including 40 CFR Part 503 Dryer Discharge Temperature method (Primary) and Recycle Bin Discharge Temperature method (40 CFR Part 503 Time and Temperature method )(Secondary).
MMSD describes the Class-A biosolids system overview and compliance methodology as follows (March 2021 Monthly Report, Appendix C):
The drying system consists of twelve Dryers, three Recycle Bins and several product conveyors. The dryers are laid out in two groups - North Side Dryers (1-6) and South Side Dryers (7-8). A recycling bin is at the end of each group of six dryers. The third recycle bin acts as redundant and can serve either side of dryers. From the recycle bin, most pellets return to the dryers. The remaining pellets go to classification and product screening. Figure 1 (below) represents a typical day of biosolids processing with 8 dryers operating (4 Dryers on the North Side and 4 Dryers on the South Side) with Recycle Bins 1 and 2 routing dried product either back to the Dryers or allowing it to go to Classification and Screening through automatic slide gates. The dry mass values on Figure 1 represent annual averages as monitored over the years. Figure 1 also shows the approximate location of the temperature monitoring devices at the discharge end of each dryer and at the discharge end of the recycle bins.
[40 CFR Part 503] Alternative 5-503.32(a)(7) and Appendix B.B.2 (Heat Drying) is used as the Primary means to demonstrate compliance with 503 Regulation for Class A. In this method, dryer discharge product temperatures for all in-production dryers stay above 176F. Automatic controls in each dryer recycle all product leaving the dryer back to the inlet of the dryers if a discharge temperature falls below 180F. [40 CFR Part 503] Alternative 1-503.32(a)(3) (Time Temperature) is used as the secondary means to demonstrate compliance. This method is only used when the primary method does not demonstrate compliance. In this method, we continuously monitor the recycle bin discharge temperature and determine detention time of the product through the recycle bin. The District continuously calculates a required temperature by using 40 CFR Part 503(a)(3) Equation 2 for the current detention time. Comparison between the measured recycle bin discharge temperature and the required temperature determines compliance with this method. If a 15-minute dryer discharge product temperature is below 176F at any individual dryer discharge, then the District will use recycling bin time and temperature to demonstrate pathogen reduction. Use of time and temperature will continue until 40 minutes after all in-drum product temperatures are higher than the required temperature. 40 minutes is the worst-case product travel time from the dryer farthest from the recycling bin to the outlet of the recycling bin. If time and temperature does not show compliance, then the gates between the recycle bin and classification & screening will automatically CLOSE. In this configuration, all product will return to the dryers. These gates are reopened when time and temperature show compliance or Dryer discharge temperature show continuous compliance for at least 40 minutes. Figure 2 (below) shows overall compliance strategy to demonstrate compliance with 503 Class A.
2
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
3
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
According to MMSD, since implementing the new temperature monitoring system, dryer temperatures consistently meet the Dryer Discharge Temperature requirements. Before the pre-inspection teleconference, Wisconsin Department of Natural Resources ("WDNR") inspector Fred Hegeman provided monthly compliance reports for the D&D Facility for April 2020 thru March 2021. According to the reports, final biosolids product met temperature (40 CFR Part 503 (Appendix B (B)(2)), fecal coliform (40 CFR Part 503.32(a)(7)), and moisture content (40 CFR Part 503.33(3)) requirements.
II.
BACKGROUND
MMSD is authorized to discharge treated wastewater from the Jones Island Water Reclamation Facility to Lake Michigan, Milwaukee Harbor, and tributary streams in Milwaukee County under NPDES permit number WI-0036820-04 ("Permit"). The Permit also includes land application requirements for EQ biosolids produced at the D&D Facility. The Facility's Operations Department is responsible for operating the D&D Facility and for compliance with the Permit. MMSD is responsible for conducting monitoring activities and reporting monitoring results to the WDNR and EPA.
MMSD's Jones Island Water Reclamation Facility (JIWRF) began operating in 1925. MMSD began producing Milorganite at the JIWR Facility in 1926. The current sludge D&D Facility is located within
the JIWR Facility and began operation since 1994. The D&D Facility treats sludge from the JIWR Facility and MMSD's South Shore Water Reclamation Facility. Milorganite is produced at the D&D Facility from sludge collected at the two facilities. Milorganite is marketed as commercial fertilizer and
sold in bags at retail stores or shipped via rail and truck to commercial customers in the USA, Canada,
and elsewhere.
III. INSPECTION ACTIVITY SUMMARY
The June 4, 2021 inspection consisted of the following activities:
Inspection opening conference; Physical inspection of the D&D Facility; and Closing conference and area of concern review.
This report summarizes the results of the inspection. The list of attendees is included below. Note that numerous representatives attended on behalf of MMSD, and below I list only the MMSD representatives with key roles in leading the physical inspection or responding to questions:
MMSD:
Sid Arora, Contract Compliance Assistant Manager Patrick Obenauf, Contract Compliance Manager Steve Unger, Contract Administrator Tom Cox, Operator (Veolia Water Milwaukee) Zach Ream, Operator (Veolia Water Milwaukee)
EPA Region 5:
Dean Maraldo, Inspector/Enforcement Officer
WDNR:
Frederick Hegeman, Wastewater Engineer Jacob Wedesky, Wastewater Engineer
4
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
III. A. Opening Conference I arrived at the MMSD Jones Island Water Reclamation Facility Operations Building at 8:45 am on June 4, 2021. I met WDNR engineers Frederick Hegeman and Jacob Wedesky and the MMSD representatives listed above and began the inspection opening conference with introductions at 8:57 am. Due to COVID19 concerns, all participants wore face masks. I presented my EPA-issued Inspector credentials to Patrick Obenauf (MMSD). I discussed the intent and scope of the inspection. I mentioned my plans to take photographs during the inspection, focusing on the new temperature monitoring system and asked if there were any potential confidential business information concerns. Patrick Obenauf said they would have no concerns about taking photographs but asked to confirm before taking each photograph. I agreed, and no concerns were raised with any of the photographs taken during the inspection. Before starting the physical inspection, I asked the MMSD representatives if the new fecal coliform preservation and holding time protocols mentioned during the pre-inspection teleconference were available in written form, such as a standard operating procedure or memo. Sid Arora said they would relay the request to the laboratory manager.
III. B. Physical Facility Inspection - D&D Facility We started the physical inspection of the D&D Facility at 9:04 am. Photographs referenced below are included in the Photo Log (Appendix D). Sid Arora, Patrick Obenauf, and Steve Unger led portions of the tour. To minimize concerns regarding COVID-19, we agreed to focus the inspection on the new temperature monitoring system. We began with an overview of the south side dryers (Photograph MMSD0001), then stopped at the three recycle bins (30-ton capacity each) which collect treated material from the dryers and directs material either back to recycling or to classification and screening. The recycle bins are now equipped with temperature probes to monitor for the secondary means to demonstrate compliance (Time and Temperature) as described on page 3, above, and in Appendix C. Sid Arora mentioned that MMSD installed three temperature probes per bin for redundancy (Photograph MMSD0002).
Next, we stopped at the product samplers station. Steve Unger explained that the sampler collects an aliquot for every four tons of material over 24 hours. This sampling location is known as WPDES Permit Sampling Point (Outfall) 006 - Jones Island EQ Sludge - PRODUCTION.
We walked to the south side dryer area and observed Dryer #1S, which was out of service at the time of inspection. Since the dryer was out of service, we were able to look inside the dryer and observe one of two new temperature probes (Photograph MMSD0004). Patrick Obenauf mentioned that each dryer has two new temperature probes on opposites sides of the dryer to measure temperature and each probe has a unique control signal. Photograph MMSD0005 captures the same probe from outside of Dryer #1S. I asked for copies of the specifications for the new temperature probes. Steve Unger said they would pull together the probe specifications and follow up after the inspection.
On the way to the operation control center, we stopped at the former temperature compliance monitoring location, approximately 19 feet away from the dryer furnace outlet along the dryer discharge screw chute (Photograph MMSD0006). Patrick Obenauf confirmed that the location is no longer used for 40 CFR Part 503 compliance monitoring.
The last stop in the D&D Facility was the operations control center (Photograph MMSD0007). The center is where operators monitor the treatment and control process, including the temperature monitoring system. Photograph MMSD0009 captures a control screen that monitors the temperature and status of all 12 dryers. Fred Hegeman asked the two operations control center operators, Zach Ream and Tom Cox, how the new temperature monitoring system is working. The operators described how the system improved control over drum temperature. Referring to the new temperature monitoring system, operator Zach Ream added that "monitoring is easier now" and "it's awesome."
5
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
On the way out of the D&D Facility, I asked Sid Arora if they've experienced any compliance issues since implementing the new temperature monitoring system. Sid Arora said they've had no compliance issues.
At the request of Fred Hegeman, Steve Unger led the group past the silos to observe the silo load-out facility. On the second floor of the load-out facility, we observed the belt conveyer which transports Milorganite product from the silos to the load-out facility. Photograph MMSD0010 captures the belt conveyor and product autosampler. Steve Unger identified the product autosampler location as WPDES Permit Sampling Point (Outfall) 008 - Jones Island EQ Sludge - SHIPPING. Steve Unger added that all finished Milorganite material, except for some special orders, is now loaded out to two offsite bagging facilities on Jones Island at Kinder Morgan and Spring Valley facilities, where compliance samples are collected at WPDES Permit Sampling Points (Outfall) 009 - Jones Island EQ Sludge - BAGGING.
We completed the physical inspection at 10:14 am.
IV. CLOSING CONFERENCE
I began the closing conference at the Jones Island Water Reclamation Facility office at 10:20 am with the WDNR and MMSD representatives in attendance. I mentioned that I did not observe any preliminary areas of concern, and added that areas of concern may be identified after reviewing information collected as part of the inspection. I asked the group if they had any questions. There were no questions. However, Steve Unger mentioned that the new temperature monitoring system and strategy was "overall a good thing for us."
I asked if MMSD could provide the two items requested earlier in the inspection (fecal sampling procedures and temperature probe specifications) within one week. Patrick Obenauf agreed with the requested timeframe.
I provided the group with an estimated timeframe for completing the inspection report, and we concluded the closing conference at 10:25 am. I departed the Jones Island Water Reclamation Facility at 10:30 am on June 4, 2021.
V.
DOCUMENTS RECEIVED
Documents received after the inspection (included in Appendix E): MMSD LAB-031 Quantification of Fecal Coliform and Total Coliform Bacteria in Biosolids by MPN REV.0.4 (1/4/2021) Milorganite Fecal Coliform Chain of Custody Form Thermowell and Bosset Fitting Data Form Wireless Transmitter Equipment Data Form
Specific resource included by reference: Milwaukee Metropolitan Sewerage District Combined WPDES Permit# WI-0036820-04; issued by WDNR on March 27, 2019; expiration date March 31, 2024.
6
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix A: Aerial Image of MMSD Jones Island Facility
Google Earth aerial image of the Facility, dated June 18, 2015.
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
[This page intentionally left blank]
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix B: Facility Presentation "503 Compliance Update"
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
503 Compliance Update
EPA WDNR WDNR Visit June 2021
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 1
Presentation Outline
Overview of the drying system MMSD 503 Regulation Compliance Plan Dryer Discharge Temperature Mode- Controls Strategy Recycle Bin Temp Mode- Controls Strategy Construction Sequence Operations Summary 2019-Present
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 2
Recycle Feed to dryer in Dry Tons/Day (Typica Mass)
180 Recycle Product returning from Recycle Bin, Dry
Tons/Day (Typical Mass)
502
Sludge Cake Feed to dryer, Dry Tons/Day (Typical Mass)
18 180
Dryer7
Drying and Recycle System Schematic
18
18
18
180
180
Dryer8
Dryer9
Dryer10
Dryer11
Dryer12 574
502
Redundant
0
Recycle Bin and
Recycle Train
502
Temperature Monitoring
Device
Gate to Classification
RECYCLE BIN 1 RECYCLE BIN 3 RECYCLE BIN 2
72
To Classification
& Screening
of Milorganite
72
Dryer1
Dryer2
Dryer3
Dryer4
Clea1n8W0ater Act
June 4, 2021
Focused
18
Complia1n8c0e
Inspection
-
Milorganite1B8i0osolids 18
Process
18
180
18
Dryer5
Dryer6
South Dryers and recycle system are Mirror Image of
the North
Appendix B, page 3
Dryer Temps for all in-service dryers
per side
Biosolids 503 Reg Compliance Plan
IN Compliance
>176F
Time Temp Method
IN Compliance for > 40 Mins & Ave Dryer Temps for all
in service Dryers >176
IN Compliance
(Gate to classificatio
n stay OPEN)
TimeTemp
Condition
Met?
IN Compliance (OPEN Gate to classification)
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Close the gate to
Classification and Recycle all
material
Condition Met with Recycle mass <25
tons
Store In Day Tank
Landfill
Segregate Product
Available room in recycle System
Appendix B, page 4
503 Regulation Compliance Strategy
We can use any one of the compliance methods to demonstrate CLASS-A compliance in any given time:
Dryer Discharge Temperature (Primary Method)
Recycle Bin Discharge Temp (Time Temperature)(Secondary Method)
Helminth Ova & Virus Testing (Emergency Method)
Only Few States Including WI Allow this. Product Produced by this method will stay in WI
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 5
Primary Method- Dryer Temperature
WPDES Permit Requirements
Dryer Drum Product Temp for all dryers In-Production >176 on continuous basis
IN-Production: Dryer IN Service and NOT in ADDBACK
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Dryer Drum Product Temperature
Appendix B, page 6
DRYER Temperature MODE for North or South Side
This is the Primary Method to demonstrate compliance
This Mode is Active per Side (North or South) when:
Drum Temperatures > 176F for all Inservice Dryers which are not in Addback
If a Dryer is in Addback there is no product leaving the system, hence is not included to determine the Active Mode per side.
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Dryer Drum Temp
Appendix B, page 7
Auto Add Back Mode ACTIVE
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Drum Temp Monitoring
Discharge Screw Temp Monitoring
Appendix B, page 8
Product Mapping
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 9
Dryer Temperature Study Report
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Dry Bulb Air Temps are more conservative measurements as compared to Product Temps
Appendix B, page 10
Drum Temp Probes
Up
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 11
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 12
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 13
Primary (P) and Secondary (S) Temperature Sensors
During normal operation (P) is used for compliance demonstration and nothing is displayed next to drum temperature. Normal operation is defined as when the difference between temperatures measured from Primary and Secondary sensors ( T) is less than 10F. If T is greater than 10F, letters (P) and (S) will be displayed next to the drum temperature. Sensor being used will be highlighted Red and the other sensor will be Flashing Yellow highlight. For example, PS indicates that sensor (S) is being used and (P) needs repair. Hence operator should put in the work request for sensor (P).
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 14
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 15
Alarms and Warnings
Normal Operation
Warning Alarm
Add-Back Mode ACTIVE
ALARM
When Add-Back ACTIVE
Dryer Discharge Screw Starts IF
Dryer Drum Temperature
HMI Drum Temperature Data Display
Discharge Screw Temperature
180F 176F < T < 180F
Blue Text
Yellow
<180F "ACTIVE"
176F
180F for 5 min OR > 200F
FLASHING RED
Blue Text
> 220F
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 16
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 17
Secondary Means of Demonstrating Compliance with 503 Regulation
Alternative I: Time-temperature Regime Meet the Established relation between Detention Time and Product Temperature
Alternative 2: Biosolids Treated In A High Ph-high Temperature Process Alternative 3: Biosolids Treated In Other Processes Alternative 4: Biosolids Treated In Unknown Processes Alternative 5: Biosolids Treated In Processes To Further Reduce Pathogens Such As Heat
Drying Alternative 6: Biosolids Treated In A Process Equivalent To A PFRP
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 18
Evaluation of Time Temperature Method
3 Recycle Bins with capacity of 30 tons each
Product discharging the recycle bin approx. 160F
Retention time in each recycle bin approx. 20 minutes
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 19
TRACER Study
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 20
Recycle Bin-Time Temperature
3 Temp Probes Installed in each Recycle Bin Using Existing Parameters monitored in HMI
added calculation for Retention Time in Recycle Bin Used Safety Factor in Retention Time Calculation based on Continual evaluation of Tracer Study Automatic closure of discharge gate and recycle all material when time temperature requirements are not met Operator verify visually and document gate closed
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 21
Recycle Bin Display Data
Recycle Bin Tonnage and T (Required- Actual Bin Temperatures) display YELLOW, if minimum requirements for time-temperature are not being met.
Out of Service Bin Shown in Gray
Gate Requested Position Actual Gate Position Actual Bin Mass
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 22
Condition for Switching Compliance Mode - Dryer Temp to Recycle Bin Temp
1. In-service dryer Drum T 176 F and add-back fails to engage for that dryer for 15 seconds
2. If Operator MANUALLY takes in-service dryer out of add back mode (manually starts discharge screw) and drum T 176F
Dryers Getting too full Temperature Rising
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 23
Recycle Bin Temp MODE for North or South Side
This Mode is Active per Side (North or South) when any Drum Temperature <176F for all Inservice Dryers which are not in Addback
Permit Conditions:
Measured Recycle Bin Discharge Temperature should be > Required Temperature AND The detention time through the bin should be 20 minutes or greater.
"Required Temperature": Calculated based on the Detention Time in the Recycle bin. Higher the Detention Time in the Bin lower the required temperature and vice versa.
Recycle Bin Discharge Temp > Required Temperature then gate to Classification is OPEN (Auto) Recycle Bin Discharge Temp < Required Temperature then gate to Classification is CLOSED(Auto)
(OPERATORS VERIFY THAT GATES ARE CLOSED)
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 24
Alarms and Warnings
Normal Operation
ALARM & Gates to Warning Alarm
Classification Closes
Outlet Gate Reopens
HMI Data Blue Text
Yellow
FLASHING RED
Blue
Residence time
Bin Temp - Req Temp = Temp Delta ( T)
3F
1F T < 3F
20 min OR < 1 F
> 20 min AND 3F
* NOTE: OPERATOR MUST PHYSICALLY VERIFY AND DOCUMENT THAT GATES TO CLASSIFICATION ARE CLOSED
FOR THE NON-COMPLIANT BIN. Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process
Appendix B, page 25
June 4, 2021
Condition for Switching Compliance ModeRecycle Bin Temp to Dryer Temp
When in Recycle Bin Mode for North or South Side and the Dryer Drum Temperatures for all in-production dryers for that side become
greater than 176F, a countdown timer is displayed on HMI.
When the timer countdowns 40 minutes, the compliance mode is switched to Dryer Compliance Mode.
Why 40 minutes?
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 26
Construction Sequence
Activity
Completion Date
Dryer Drums
Tested Accutech wireless transmitter for continuous temperature monitoring
7/26/2018
Installed first thermowell and temperature sensor (RTD) with wireless transmitter 10/16/2018
Installed thermowells and RTD with wireless transmitters in all 12 dryer drums
2/28/2019
Installed and tested two redundant RTDs with wireless transmitter
7/9/2019
Completion adding a dedicated power supply for each RTD receiver radio
10/8/2019
Ready to test second RTD installed in Dryers 6 and 12
10/25/2019
Completed installation of redundant RTDs in all 12 dryers
11/19/2019
Recycle Bins
Installed and tested first hardwired RTD at a recycle bin
9/24/2018
Completed recycle bin tracer testing to establish residence time
10/22/2018
Installed and collecting data from two hardwired RTDs in each of three recycle bins 11/15/2018
Installed a third hardwired RTD in two active recycle bins
1/24/2019
Installed a third hardwired RTD in redundant recycle bin
4/5/2019
Completed rebuilding all 6 recycle bin outlet gates with SS material to ensure proper ope8r/a3ti1o/n2019
Installed and tested 6 inductive sensors to confirm recycle bin outlet gates "closed" 9/17/2019
Milorganite Temperature Monitoring and Compliance Programming
Completed initial PLC programming to control processes to ensure compliance
12/21/2018
Revised control program to use dryer drum temperature as primary compliance measure 3/1/2019
Completed and tested programming to record compliance and place data to historian 3/22/2019
Installed compliance monitor in operator control room (HMI Screen)
4/5/2019
Programmed automatic addback at each dryer to recycle product if temp. <176 F
4/26/2019
Implemented full operation of compliance program for Milorganite production
4/26/2019
Generated first monthly compliance report from Hach WIMS
5/3/2019
Added 20 min. minimum residence time to time-temperature compliance program
9/5/2019
Added 15 sec. delay when switching to time-temperature mode from dryer mode
9/20/2019
Completed programming for redundant RTDs at all 12 dryer drums
10/31/2019
Completed FATs for all compliance modes
2/14/2020
Training, O&M Manual and Spare Parts Completed initial operator and maintenance training on new system Completed operator training on revised compliance program Transferred first shipment of spare instrument parts to Veolia Anticipate completing second version of O&M manual
Clean Water Act FToracnusfeedrrCeodmfpinlialnscheipInmspeencttiofns-paMrieloirngsatnriutemeBnitopsoalritdsstPorVoceeoslsia June 4, 2021 Conducted second training session with Veolia operators, 2 days
11/28/2018 3/19/2019 5/30/2019 10/31/2019 12/10/2019 2/12/2020
Appendix B, page 27
Summary - April 2019 through Present
All stored and shipped product complied with Dryer Temp or Time Temp
Most of time complied with Dryer Temperature Mode Isolated events in Time Temp Mode
Example May 28, 2020
One event - had to send product from day tank back to drying system
May 31, 2021 Communication failure caused gate control issue
No events where we had to send product to landfill
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 28
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 29
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix B, page 30
Appendix C: March 2021 Monthly Report
Milorganite Fertilizer 503 Regulation Class A Compliance Monitoring Report
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Milorganite Fertilizer
503 Regulation Class A Compliance
Monitoring Report
March 2021
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendic C, page 1
Table of Contents
Section 1: Milorganite Solids and Fecal Coliform Results at Various Outfalls Section 2: Drying System Temperature Monitoring Dryer Recycle
2.1 System Overview and Compliance Methodology 2.2 Operations Notes for March 2021 2.3 Dryer Discharge Product Temperature Monitoring 2.4 Time Temperature Monitoring
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendic C, page 2
Section 1: Milorganite Solids and Fecal Coliform
Results at Various Outfalls
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendic C, page 3
March 2021 Results
Sample Collection Date
Outfall
3/9/21
009
3/9/21
009
3/9/21
008
3/2/21
006
3/9/21
006
3/16/21
006
3/23/21
006
3/30/21
006
Sample Location
BAGGING - Kinder Morgan BAGGING - Spring Valley
SHIPPING PRODUCTION PRODUCTION PRODUCTION PRODUCTION PRODUCTION
Fecal Coliform
Limit MPN/gTS
Sample Results MPN/gTS
<1000 <1000
<1000
<1000 <1000 <1000 <1000 <1000
< 0.19 < 0.19
< 0.19
< 0.19 < 0.19 < 0.19 < 0.19 < 0.19
Solids, Total
Limit % TS
Sample Results
% TS
90
95
90
95
90
95
90
96
90
94
90
96
90
96
90
94
Milorganite Production = 3,555 ton/month Milorganite to Kinder Morgan Bagging = 3,574 tons/month Milorganite to Spring Valley Bagging = 332 tons/month Milorganite Shipped = 3,959 tons/month Note:
- The results shown above are for grab samples collected at Outfalls 6, 8, 9 as defined in the WPDES Permit WI-0036820-04-0 - For all samples shown in the table above, fecal coliform analyses are started within 8 hrs. of collection, as per EPA Method 1680 - All Milorganite Produced in a month is not necessarily bagged or shipped the same month
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendic C, page 4
Section 2:
Drying System Temperature Monitoring
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendic C, page 5
Section 2.1: System Overview and Compliance Methodology
The drying system consists of twelve Dryers, three Recycle Bins and several product conveyors. The dryers are laid out in two groups - North Side Dryers (1-6) and South Side Dryers (7-8). A recycling bin is at the end of each group of six dryers. The third recycle bin acts is redundant can serve either side of dryers. From the recycle bin, most pellets return to the dryers. The remaining pellets go to classification and product screening. Figure 1 represents a typical day of biosolids processing with 8 dryers operating (4 Dryers on the North Side and 4 Dryers on the South Side) with Recycle Bins 1 and 2 routing dried product either back to the Dryers or allowing it to go to Classification and Screening through automatic slide gates. The dry mass values on Figure 1 represent annual averages as monitored over the years. Figure 1 also shows the approximate location of the temperature monitoring devices at the discharge end of each dryer and at the discharge end of the recycle bins.
Alternative 5-503.32(a)(7) and Appendix B.B.2 (Heat Drying) is used as the Primary means to demonstrate compliance with 503 Regulation for Class A. In this method, dryer discharge product temperatures for all in-production dryers stay above 176F. Automatic controls in each dryer recycle all product leaving the dryer back to the inlet of the dryers if a discharge temperature falls below 180F.
Alternative 1-503.32(a)(3) (Time Temperature) is used as the secondary means to demonstrate compliance. This method is only used when the primary method does not demonstrate compliance. In this method, we continuously monitor the recycle bin discharge temperature and determine detention time of the product through the recycle bin. The District continuously calculates a required temperature by using 40 CFR Part 503(a)(3) Equation 2 for the current detention time. Comparison between the measured recycle bin discharge temperature and the required temperature determines compliance with this method.
If a 15-minute dryer discharge product temperature is below 176F at any individual dryer discharge, then the District will use recycling bin time and temperature to demonstrate pathogen reduction. Use of time and temperature will continue until 40 minutes after all in-drum product temperatures are higher than the required temperature. 40 minutes is the worst-case product travel time from the dryer farthest from the recycling bin to the outlet of the recycling bin. If time and temperature does not show compliance, then the gates between the recycle bin and classification & screening will automatically CLOSE. In this configuration, all product will return
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendic C, page 6
to the dryers. These gates are reopened when time and temperature show compliance or Dryer discharge temperature show continuous compliance for at least 40 minutes. Figure 2 shows overall compliance strategy to demonstrate compliance with 503 Class A.
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendic C, page 7
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendic C, page 8
Section 2.2 Operations Notes- March 2021
Dryer discharge product temperatures for all in-production South Side Dryers (Dryers 1-6) were greater than 176F for the entire month, except on March 3, 2021 at 04:29 hours for Dryer 1, and on March 14, 2021 at 05:01 hours for Dryer 3.
Dryer discharge product temperatures for all in-production North Side Dryers (Dryers 7-12) were greater than 176F for the entire month.
DRYER 1 - March 3, 2021, 04:29 hours At 04:29 hours on March 3, 2021 Dryer 1 was in add back mode due to
product temperature less than 176F. The dryer was in add back mode for a prolonged time and eventually became too full. Hence the Operator manually took Dryer 1 out of add back mode. To take the dryer out of add back mode, the Operator manually turned on the discharge screw. At that time, the Dryer 1 discharge product temperature was below 176F, therefore the system controls for South Side Dryers immediately shifted to the Time Temperature mode for compliance demonstration. While in Time Temperature mode, the Recycle Bin discharge temperature and detention time did not meet the required conditions of Time Temperature. Hence the gates to classification and screening were automatically closed and all product was recycled back to the South Side Dryers. Additionally, Operators visually verified that no product was going to classification - the gates to classification were closed. About 1 hour later, Dryer 1 was in compliance and compliance strategy switched back to dryer discharge product temperature mode.
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendic C, page 9
DRYER 3 - March 14, 2021, 05:01 hours At 05:01 hours on March 14, 2021 Dryer 3 was in add back mode due to
product temperature less than 176F. It was in add back mode for a prolonged time and eventually became too full. Hence the Operator took Dryer 3 out of add back mode. To take the dryer out of add back mode, the Operator turned on the discharge screw. At that time, the Dryer 3 discharge product temperature was below 176F, therefore the system controls for South Side Dryers immediately shifted to the Time Temperature mode for compliance demonstration. When the south dryers first shifted to Time Temperature mode, the Recycle Bin discharge temperature and detention time did indeed meet the required conditions of Time Temperature. Hence the gates to classification and screening were initially left open as shown on Table #3. However, shortly after the shift to Time Temperature mode, the Recycle Bin temperature dropped and no longer met the required conditions of Time Temperature. Hence the gates to classification and screening automatically closed and all product was recycled back to the South Side Dryers. At this time, Operators visually verified that no product was going to classification while the gates to classification were closed. About 1 hour later, Dryer 3 was in compliance and compliance strategy switched back to dryer discharge temperature mode.
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendic C, page 10
Section 2.3. Dryer Discharge Product Temperature Monitoring
Graph 1: South Side Dryer Discharge Product Temperature Monitoring Graph 2: North Side Dryer Discharge Product Temperature Monitoring Table 1: South Side Dryers Daily Minimum Discharge Product Temperatures Table 2: North Side Dryers Daily Minimum Discharge Product Temperatures
Notes for Graphs 1 and 2 1. Temperature data is presented on these graphs as 15-minute average when the
dryer is in production. 2. Temperatures are measured at end of heated zone of each dryer by a resistance
temperature detector (RTD) thermometer located in a thermowell on the interior wall of dryer drum. 3. Dryer discharge temperatures are measured continuously and are recorded in reporting database as a 15-minute average. 4. If any dryer temperature drops below 176F, the system control shifts to time temperature control and the data is presented in the Time-Temperature Mode Table.
Notes for Tables 1 and 2 1. Data represents the daily minimum 15-minute average temperatures when the dryer
was in production. 2. Blank spaces represent that the dryer was out of service the entire day.
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendic C, page 11
Graph #1 - Dryer Discharge Temperature - South Dryers - March 2021
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendic C, page 12
Graph #2 - Dryer Discharge Temperature - North Dryers - March 2021
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendic C, page 13
Table #1 Daily Minimum Discharge Product Temperature - South Dryers - March 2021
Date 03/01/21 03/02/21 03/03/21 03/04/21 03/05/21 03/06/21 03/07/21 03/08/21 03/09/21 03/10/21 03/11/21 03/12/21 03/13/21 03/14/21 03/15/21 03/16/21 03/17/21 03/18/21 03/19/21 03/20/21 03/21/21 03/22/21 03/23/21 03/24/21 03/25/21 03/26/21 03/27/21 03/28/21 03/29/21 03/30/21 03/31/21
Dryer #1
168.90 205.39 202.98 203.68 190.54 191.99 217.11 204.96
201.10 208.39 203.92 186.87 193.59 185.60 194.37 193.61 217.72 180.99 183.51 193.74 199.48 198.37 194.98 197.37 189.45
Daily Minimum Discharge Product Temperature
Dryer #2
Dryer #3
Dryer #4
Dryer #5
227.30
205.62
205.93
213.85
185.81
192.83
181.85
193.44
190.54
201.82
191.42
202.30
198.77
199.01
203.72
187.11
202.87
205.25
198.87
200.32
210.28
210.35
187.70
214.09
206.36
198.58
205.29
199.70
199.50
214.73
196.69
198.92
182.23
191.58
187.54
184.97
190.89
187.93
183.90
192.99
170.78
184.93
195.55
190.09
204.95
186.15
192.32
210.03
217.58
201.37
190.67
187.00
199.93
195.16
206.05
187.87
196.46
186.34
197.69
184.24
193.40
190.38
187.45
181.09
187.67
192.35
194.49
191.67
195.09
203.81
186.87
181.25
206.66
183.12
189.70
189.27
203.23
198.23
194.63
183.07
191.03
193.17
204.81
182.29
195.66
191.94
203.40
194.51
189.56
190.62
195.81
183.71
193.25
191.05
208.92
199.67
199.28
185.61
197.43
202.53
185.21
183.85
209.19
185.05
209.14
198.21
182.77
203.68
187.71
182.05
190.88
Dryer #6 213.41 196.88 195.95 193.22 190.16 196.66 197.18 203.53
185.97 191.25 186.70 191.70 182.34
189.97 186.40 194.95 193.30 184.48 199.70 188.09 200.64 183.63 183.34
3693 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendic C, page 14
Table #2 Daily Minimum Discharge Product Temperature - North Dryers - March 2021
Daily Minimum Discharge Product Temperature
Date
Dryer #7
Dryer #8
Dryer #9
Dryer #10
Dryer #11
Dryer #12
3699
03/01/21
193.75
221.39
215.84
221.29
209.46
212.32
0.00
03/02/21
203.10
217.72
212.96
212.39
203.67
0.00
03/03/21
196.99
185.00
183.28
192.20
199.14
0.00
03/04/21
188.73
196.51
211.49
202.81
204.39
0.00
03/05/21
203.12
186.21
202.83
203.69
208.29
0.00
03/06/21
191.73
191.34
202.68
190.82
206.03
0.00
03/07/21
192.66
209.01
201.76
206.91
206.58
0.00
03/08/21
198.11
220.71
201.80
218.14
204.83
0.00
03/09/21
185.12
210.76
192.31
190.29
203.64
0.00
03/10/21
189.54
197.21
202.52
217.47
210.02
0.00
03/11/21
186.06
212.22
203.62
218.75
198.27
0.00
03/12/21
185.93
201.55
203.22
218.31
200.37
0.00
03/13/21
185.94
193.50
203.62
199.85
198.76
0.00
03/14/21
197.27
202.20
196.44
195.87
203.04
0.00
03/15/21
203.66
220.13
200.40
210.95
0.00
03/16/21
206.72
225.18
208.72
215.40
0.00
03/17/21
199.96
227.77
202.72
216.28
0.00
03/18/21
187.50
181.61
190.81
190.79
0.00
03/19/21
185.52
192.54
199.87
204.42
0.00
03/20/21
191.56
195.16
200.24
187.13
0.00
03/21/21
198.84
185.62
189.31
197.45
0.00
03/22/21
189.90
201.64
198.94
182.47
0.00
03/23/21
185.31
195.66
195.33
204.06
0.00
03/24/21
194.64
211.18
201.71
206.45
0.00
03/25/21
195.05
211.34
197.09
207.83
0.00
03/26/21
193.17
211.12
184.25
185.28
0.00
03/27/21
209.01
221.78
211.05
199.58
0.00
03/28/21
206.73
186.80
211.56
211.95
0.00
03/29/21
182.93
191.56
184.11
190.59
0.00
03/30/21
187.65
193.84
192.05
187.39
0.00
03/31/21
185.94
185.32
196.32
192.79
0.00
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendic C, page 15
Section 2.4 Time Temperature Monitoring
Table 3: South Side Time-Temperature Mode Temperatures Table 4: North Side Time-Temperature Mode Temperatures
Notes for Tables 3 and 4 1. Recycle bin discharge temperature is measured continuously and is reported on this table as a 15-minute average. 2. Time temperature control is active only if any dryer discharge temperature per side is less than 176F. 3. No values in the table (blank table) represents that the dryer recycle system never went to Time Temperate Mode for the month 4. Once the time temperature control is active, it stays active for a minimum of 40 minutes. 5. Recycle bin discharge temperature is measured using RTD probes located in a thermowell on the interior wall of each recycle bin. 6. The required temperature is calculated with 40 CFR 503(a)(3) Equation 2 7. If the recycle bin discharge temperature is less than the required temperature, then gates to classification close and all product is recycled back to the dryers. 8. If the recycle bin discharge temperature is greater than required temperature, then gates to classification stay open and some product goes to classification and the remaining product is recycled back to the dryers.
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendic C, page 16
Table #3
dd("D",3,A1, Date/Time
03/03/21 04:30
03/14/203/03/21 04:45 03/14/203/03/21 05:00
21 05:15 03/03/21 05:15 21 05:30 03/14/21 05:00 21 05:15 03/14/21 05:15
03/03/21 03/14/21 05:30 03/03/21 03/14/21 05:45 03/03/21 03/14/21 06:00 03/14/21 03/14/21 06:15
none
Time-Temperature Mode - South Dryers - March 2021
South Dryers (Recycle Bin #1 or Bin #3)
Required
Recycle Bin
Gates to
Temp. Discharge Temp Classifica#on
160.14
153..03
CLOSED
Recycle Bin Discharge To:
All Recycled to Dryers
159.67
152.46
CLOSED
All Recycled to Dryers
159.42
153.77
CLOSED
All Recycled to Dryers
159.13
157.67
CLOSED
All Recycled to Dryers
159.56
162.56
OPENED
Classifica#on & Recycled to Dryers
159.50
160.28
CLOSED
All Recycled to Dryers
159.15
156.78
CLOSED
All Recycled to Dryers
158.85
158.66
CLOSED
All Recycled to Dryers
158.69
158.42
CLOSED
All Recycled to Dryers
158.43
157.82
CLOSED
All Recycled to Dryers
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendic C, page 17
Table #4
Date/Time
none none none none none none
Time-Temperature Mode - North Dryers - March 2021
North Dryers (Recycle Bin #2 or Bin #3)
Required
Recycle Bin
Gates to
Recycle Bin
Temp. Discharge Temp Classifica#on
Discharge To:
.
x
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendic C, page 18
Appendix D: Photo Log
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Milwaukee Metro Sewerage District (MMSD) Jones Island Biosolids Dewatering and Drying Facility
EPA Inspection June 4, 2021 All photos taken by Dean Maraldo, Inspector, U.S. EPA
Camera: Ricoh WG-4
1: MMSD0001 Description: Overview of the south side dryers. Location: MMSD D&D Facility Camera Direction: 46 Date/Time: June 4, 2021; 09:06
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix D, page 1
2: MMSD0002 Description: new temperature probes (3) in recycling bin #3. Location: MMSD D&D Facility Camera Direction: 349 Date/Time: June 4, 2021; 09:13
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix D, page 2
3: MMSD0003 Description: Product composite sampler. Location: MMSD D&D Facility (WPDES Permit Sampling Point (Outfall) 006 - Jones Island EQ Sludge - PRODUCTION). Camera Direction: 70 Date/Time: June 4, 2021; 09:24
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix D, page 3
4: MMSD0004 Description: One of two new temperature probes installed within the Dryer #1S. Location: MMSD D&D Facility Camera Direction: 198 Date/Time: June 4, 2021; 09:32
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix D, page 4
5: MMSD0005 Description: The same probe shown in Photograph MMSD0004, viewed from outside of Dryer #1S. Location: MMSD D&D Facility Camera Direction: 105 Date/Time: June 4, 2021; 09:34
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix D, page 5
6: MMSD0006 Description: The former temperature compliance monitoring location (vicinity of steel plate on the screw chute), measured approximately 19 feet away from dryer furnace outlet along dryer discharge screw chute. Location: MMSD D&D Facility Camera Direction: 262 Date/Time: June 4, 2021; 09:40
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix D, page 6
7: MMSD0007 Description: D&D Facility operations control center. Location: MMSD D&D Facility Camera Direction: 240 Date/Time: June 4, 2021; 09:46
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix D, page 7
8: MMSD0009 Description: Close up view of dryer temperature control screen. Location: MMSD D&D Facility Camera Direction: 251 Date/Time: June 4, 2021; 09:47
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix D, page 8
9: MMSD0010 Description: Silo load out belt conveyor and product auto sampler. Location: MMSD Silo Load Out Facility Camera Direction: 232 Date/Time: June 4, 2021; 10:05
Clean Water Act Focused Compliance Inspection - Milorganite Biosolids Process June 4, 2021
Appendix D, page 9
Appendix E: Documents Received
MMSD LAB-031 Quantification of Fecal Coliform and Total Coliform Bacteria in Biosolids by MPN REV.0.4 (1/4/2021)
Thermowell and Bosset Fitting Data Form Wireless Transmitter Equipment Data Form
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 1
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 2
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 3
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 4
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 5
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 6
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 7
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 8
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 9
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 10
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 11
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 12
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 13
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 14
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 15
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 16
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 17
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 18
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 19
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 20
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 21
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 22
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 23
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 24
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 25
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 26
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 27
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 28
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 29
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 30
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 31
Fecal Coliform via EPA 1680 % Total Solids LIMS Placeholder Type (grab, comp) Preservative Preserved Time
Milorganite Fecal Coliform
VWM-MMSD Sample Chain of Custody Sample Location: Jones Island Milorganite Production, Shipping, and Bagging
Sample Date: ______________
Analyses Requested
Sample Time(s)
# of Bottles
Source Code
978/1
Sample ID *Milorganite Production
978/1 *Milorganite Production
978/5 *Milorganite Shipping
978/5 *Milorganite Shipping
978/4 *Miloragnite Bagging
978/4 *Milorganite Bagging
XX X
XX X
XX X
Grab Grab Grab Grab Grab Grab
(comp. only)
None None None None None None
Start Time End Time
*Microbiological samples must be collected after 4am and received by the lab no later than 9am* Remarks (any unusual conditions must be recorded here and supervisor informed):
VWM Sample Custody Relinquished by:
Date
Time
Received by:
For Laboratory Use Only
LIMS #
pH verified
Date
Time
Sample Courier Custody Received by:
*Microbiological samples must be refrigerated upon collection and transported on ice*
Date
Time
Relinquished by:
Date
Time On Ice?
Y / N
MMSD Lab Sample Custody Received by:
Date
Time On Ice?
Y / N
Relinquished by:
Date
Time
If not received on ice, sample temperature on receipt in lab: __________C
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Version 4; Revised 11/18/20 Appendix E, page 32
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 33
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 34
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 35
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 36
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 37
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 38
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 39
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 40
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 41
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 42
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 43
Clean Water Act Focused Compliance Inspection Milorganite Biosolids Process June 4, 2021
Appendix E, page 44
