1162-Evergreen Sweeteners, Inc.r ,
MAILING ADDRESS
CITY OF SANFORD
POST OFFICE BOX 1788
SANFORD, FLORIDA 32772 -1788
PHYSICAL ADDRESS
CITY HALL
300 NORTH PARK AVENUE
SANFORD, FLORIDA 32771 -12
TELEPHONE
407.330.5640
FACSIMILE
407.330.5646
WEBSITE
W W W.CI.SANFORD. FL.US
CITY COMMISSION
LINDA KUHN
MAYOR
CITY OF SANFORD, FLORIDA
UTILITIES DEPARTMENT
IN THE MATTER OF: )
EVERGREEN SWEETENERS, INC)
2200 COUNTRY CLUB ROAD )
SANFORD, FLORIDA 32771 )
)
Respondent.
PROCEEDING UNDER
ARTICLE IX, CHAPTER 102
CITY OF SANFORD CODE
Wastewater Discharge Permit No.
0002
CONSENT ORDER
I. NATURE OF THE ACTION
1. The City issued an Administrative Order to Evergreen Sweeteners, Inc.
(Facility) on July 31, 2006 pursuant to Sections 102 -313 of the Sanford City
Code. The Facility is a Florida corporation, with its principal place of business at
2200 Country Club Road, Sanford, Florida.
ART WOODRUFF 2. On January 16, 2007 a meeting took place between the City of Sanford,
DISTRICT 1 Florida ( "City "), and Evergreen Sweeteners, Inc. formally known as Sunlight
DR. VELMA H. WILLIAMS Foods Inc. at the City's Utility Department. Evergreen Sweeteners, Inc.
DISTRICT 2, VICE MAYOR management discussed their concerns about receiving high surcharges fees for the
RANDY JONES past month and not being able to decrease the Carbonaceous Biological Demand
DISTRICT 3 (cBOD) as low as expected. Further, they indicate that their facility has invested a
JACK T. BRIDGES substantial amount of money in additional improvements related to their
DISTRICT 4 pretreatment system not required by the previous Administrative Order.
CITY MANAGER 3. The City and Evergreen Sweetener management agreed to include a
ROBERT (SHERMAN) YEHL portion of the cost for the surcharges fees for October and November (which were
place on hold until the conclusion of this meeting) and December through March
31, 2007 into a Consent Order. The City stated that in order to proceed with the
consent Order the previous Administrate Order shall be properly terminated.
4. The prior Administrative Order contained remedial actions under Section
III (Order) that were required to be performed by the Facility within a period of
sixty (60) days from the effective date of the Order. A copy of the Administrative
Order is attached as Exhibit A.
1
?/te 9WW9W# ea#
5. The City performed an inspection on August 23, 2006 before the due date
at the request of Evergreen Sweetener's Inc. to verify compliance with the
requirements of the Administrative Order.
6. The requirements listed under items number 6 through 12 and number 14
through 21 were completed.
7. The requirements listed under item number 13 have not been completed as
confirmed during the follow -up inspection performed on February 13, 2007.
8. The Pretreatment system at this facility was required to be reconfigured to
help recycling the activated sludge from the clarifier back to the activated sludge.
9. The Pretreatment system at this facility was required to have all plumbing
connections related to the wastewater flow and air blower flow reconfigured to
insure proper operation of the pretreatment system so that adequate sludge can be
cast as wasted.
10. The Pretreatment system was required to have all flow directions
permanently for valving, check valves, strainers, union connections, bulk head
fitting for tanks, pipe supports, pipe hangers, instruct mounting of pipe and clean
outs.
11. The sampling box was required to have installed a down pipe at the
sampling location to prevent solids from entering the sanitary sewer system.
12. The pH monitoring system was required to be relocated to the sampling
point location including all related piping modifications.
13. The depth of the sampling box shall allow at least twelve inches (12 ")
from the floor of the tank (twenty four inches [24 "] recommended) to the outlet
pipe to provide for proper sampling of oil and grease wastewater collection.
14. An updated Chart Recorder and alarm system for out of range pH was
required to be installed at this facility. The system shall be equipped with a new
chart recording system to show when the pH system is calibrated and to prevent
any interruptions in continuous pH recording. Additionally, the pH monitoring
system shall be equipped with an alarm to alert the operator of any potential
discharge problems. The system shall be capable of recording dual readings;
flows vs. pH so compliance with pH limitation can be determined. Automatic
daily print out of dates and significant out of range events shall also be included
in the recording as well.
15. The Automatic pH control system at this facility was required to have an
automatic pH controller added to monitor the pH of the system in the RAS
2
pipeline and for automatic pH adjustment. The controller shall be set to operate
the caustic pump and maintain the pH in a set range between: 5.0 and 9.0 units or
a more stringent recommended window of 0.5 units was set up for lower and
upper levels (5.5 — 8.5). No discharge of pH outside of this range shall enter the
City's collection system. Valves are programmed to automatically shut -off when
pH is outside discharge permitted limits.
16. The facility was required to up -grade the blower system from I HP blower
to 15 HP to improve the efficiency of the pretreatment system.
17. The facility was required to have onsite, an additional 15 HP Blower for
back -up purposes.
18. The facility was required to install a Lamella, plate and frame clarifier to
settle the activated sludge and to prevent solids from passing over the weir.
19. The facility was required to install a central control panel equipped with
manual — off — automatic operations for the transfer pumps and motor starters for
the blowers at 15HP as well as float controls, level controls and flow monitoring
totalizer.
20. The Facility was required to upgrade the capacity of the equalization tanks
from one (1) 1,200 gallons to two (2) 5,000 gallons to condition the wastewater
prior to treatment.
21. The facility was required to modify the boiler steam lines by adding steam
traps to return the condensate to the boiler. To eliminate condensate discharge
from several designated areas in the plant.
II. PRELIMINARY STATEMENTS
22. The City issued to this facility an Industrial Wastewater Discharge Permit
No. 0002, Effective April 1, 2005 and to expire March 31, 2008.
23. Evergreen Sweetener Inc, is Classified as Class three "Significant
Commercial User" as defined in Section 102 -396, City of Sanford Code.
24. Evergreen Sweeteners, Inc. is the owner of a transfer and blending facility
for food grade sweetening products located at 2200 Country Club Road, Sanford,
Florida.
25. Evergreen Sweeteners, Inc. has been served with one (1) Administrative
Order, dated July 31, 2006, four (4) Notices of Violation all dated June 30, 2006,
and one (SNC) dated February 2, 2006.
26. The Evergreen Sweetener Inc. certifies that as of the date of its execution
of this Order, it is in material compliance with the applicable provisions of Article
IX, Chapter 102, C'itt• of Sagforcl (' XIe.
III. PARTIES BOUND
27. This Order shall apply to and be binding upon Evergreen Sweeteners, Inc.
and its successors and assigns and the City and shall be recorded in the
Official Public Records of Seminole County and any other jurisdiction in
which the Facility owns property.
28. This Order and all obligations and responsibilities thereunder shall be
binding on the successors and assigns of Evergreen Sweeteners, Inc
without limitations. No change in ownership, partnership, corporate or
legal status relating to the Facility will in any way alter Evergreen
Sweeteners, Inc. obligations and responsibilities under this Order.
IV. REMEDIAL ACTIONS
29. Evergreen Sweeteners, Inc. was advised that January 30, 2007 was the due
date for submission to the City of copies of all invoices for the improvements
done to the pretreatment system. The City requested that such invoices shall
correspond to work performed on the Facility pretreatment system during the
months of October, November and December 2006 and that such invoices shall
not be related to any items previously mentioned in the Administrative Order
entered on July 31, 2006. The City will review and approve only those invoices
that meet the requirements stated herein. The City indicated that up to sixty five
percent (65 %) of the total monthly amount of these invoices will be deducted
from the respective monthly surcharges. On February 12, 2007 the City contacted
Evergreen Sweeteners, Inc. consultant to inquire as to the status of the invoices.
Upon petition of the consultant, the City extended the due date for compliance
until Thursday February 15, 2007 at 2:00 pm. Evergreens Sweeteners, Inc. was
advised that if this information was not provided as require, surcharges for
October, November and December, 2006 will be charged in full.
30. Evergreen Sweeteners, Inc. is required to provide the City with invoices
meeting the conditions in item 29 above for the months of January, February and
March 2007. The City will review and approve only those invoices corresponding
to the remedial actions described in article IV items number 30 through 40. The
City will consider up to sixty five percent (65 %) of the total monthly amount of
said invoices for deduction from the respective monthly surcharges.
31. The current location of the sampling point only represents wastewater
coming from the processing area. Federal and State regulations require this
sampling point be representative of the total wastewater discharge by the entire
facility. Evergreen Sweeteners, Inc. is required to relocate the current sampling
M
point to a location where processed water and sanitary waste are combined. The
previous Administrative Order requirements will be considered to be in
compliance upon the completion of this requirement. This modification shall be
completed by March 31, 2007. The Engineering plans showing the proposed
relocation and sampling structure installation shall be provided to the City within
fourteen (14) days of the issuance of this Order.
32. Evergreen Sweetener, Inc. is required to relocate the final pH/flow meter
to the new approved location as indicated in item 30 above. This modification
shall be completed by March 31, 2007.
33. Evergreen Sweeteners, Inc. is required to modify the existing equalization
system by converting one (1) of the two (2) 5,000 gallons tanks into an activated
sludge tank and adding five (5) additional 10,000 gallons tanks. Three (3) of these
tanks will be used for flow equalization and two (2) will be used for aeration
tanks. This modification shall be completed by March 31, 2007.
34. The proposed five 10,000 gallons tanks shall be double wall tanks or a
proper containment area shall be constructed to contain any spill that may occur
in this area. Evergreen Sweeteners, Inc shall specify to the City which spill
containment choice will be used for this area. Manufacturer specifications of the
tanks or Engineering plans showing the build -in containment area shall be
provided to the City within fourteen (14) days of the issuance of this Order. City
approval is required before proceeding with either installation.
35. Evergreen Sweetener, Inc. is required to provide the City with a complete
set of plans showing propose changes to include all the plumbing connections
from the existing pretreatment system to the system to the proposed pretreatment
system addition. The plans submitted on February 5, 2007, are not acceptable
since they are omitting must of the plumbing lay -out for the new system. The
Engineering plans for this area shall be provided to the City within fourteen (14)
days of the issuance of this Order. In addition, the new plans shall indicate the
wastewater flow direction.
36. Evergreen Sweetener, Inc. is proposing to reduce the concentration of
sugar entering into the pretreatment system by modifying the existing plumbing
configuration of the truck loading area. Evergreen Sweeteners, Inc. is required to
provide the City with plans detailing the existing plumbing configuration of the
truck loading area and the propose changes for City approval. This modification
shall be completed by March 31, 2007. The Engineering plans for this area shall
be provided to the City within fourteen (14) days of the issuance of this Order.
37. Evergreen Sweetener, Inc. is required to modify the plumbing connections
from the sugar loading process by adding a closed loop sugar melt system to
recycle the non - complaint product. Evergreen Sweeteners, Inc. is required to
provide the City with plans the propose changes for City approval. The
5
Engineering plans for this area shall be provided to the City within fourteen (14)
days of the issuance of this Order.
38. Evergreen Sweeteners, Inc. is required to add a filtration system to the
final flow holding tank prior to the discharge. This modification shall be
completed by March 31, 2007. The manufacturer specifications for the propose
filtration system shall be provide to the City within fourteen (14) days of the
issuance of this Order.
39. All flow directions for the items included in Article IV "Remedial
Actions" shall be permanently indicated by labels through the wastewater
treatment system.
40. Evergreen Sweetener, Inc. is required to provide the City with new
Standard Operating Procedures manual by April 29, 2007.
41. The City issued to this facility an Industrial Wastewater Discharge Permit
No. 0002, Effective April 1, 2005, to expire March 31, 2008 (which is required to
be renew every three years or before if determinate by the City to address
significant changes related with the facility or governing laws. A Renewal Permit
will be issued to this facility after all improvements and requirements have been
fulfilled. Evergreen Sweetener, Inc. is required to provide its updated General
application by March 31, 2007 (Refer to Exhibit B for a copy of this application).
VI. ADMINISTRATIVE COSTS
42. The City has incurred administrative costs including, but not limited to,
attorneys' fees and costs, in the amount of $10,000 in connection with this proceeding.
Evergreen Sweetener Inc shall pay the full amount of the administrative costs to City
within ten (10) days of the effective date of this Consent Order.
VIII. RESERVATION OF RIGHTS
43. The City reserves the right to take enforcement action, as othenvise
provided by law, against Evergreen Sweetener Inc for any future violations of the City of
Sanford Code or the requirements or pollutant limitations of the Revised Renewal Permit
and to enforce the terms and conditions of this Order. Evergreen Sweetener Inc reserves
the right to assert appropriate defenses in any such action.
44. This Order may be amended or modified only by written agreement
executed by both City and Evergreen Sweetener Inc.
0
IX. EFFECTIVE DATE
45. The effective date of this Order shall be the date on which it is signed by
City, provided, however, that should Evergreen Sweetener Inc fail to notify the City as
required in this Order or fail to pay to the City all sums set forth herein, the City shall
proceed with such enforcement actions as it deems appropriate.
DATED this a g day of March, 2007
Evergreen Sweetener, Inc
Wit ess raig Green, President
L '
Witness
CITY OF SANFORD, a municipality
organized under the laws of the State of
Florida
By:
Robert (Sherman) 1, City Manager
Attest:
Janet ug
Copies provided to:
Mr. Craig Green
President
Evergreen Sweetener, Inc.
2200 Country Club Road
Sanford, Florida 32771
Mr. Paul Moore
Utility Director
300 North Park Avenue
Sanford, Florida 32772 -1778
VA
: v
CITY OF SANFORD
Utility Department
P.O. Box 1788
Sanford, Florida 32772 -1788
Telephone (407) 302 -1084
t
IN THE MATTER OF
*
SUNLIGHT FOODS, INC. ADA07VISTRA77M ORDER
2200 COUBTRYCLUB ROAD.
SANFORD, FLORIDA 32771
PART L LEGAL AUTHORITY
The following findings are made and this Order is issued pursuant to the authority vested in the Utility
Director of the City of Sanford (hereafter, "City ") under Section 28 -95, City of Sanford Code. This
Order is based on findings of violation of the conditions of the wastewater discharge permit issued
under the City of Sanford Code and Wastewater Discharge Permit No.0002
PART II. FINDINGS
1. Sunlight Foods, Inc. discharges non - domestic wastewater containing pollutants into the sanitay
sewer system of the City.
2. Sunlight Foods, Inc. is identified as a Class Three Significant Commercial User under Sections
28 -82 and 28 -123, City of Sanford Code.
3. Sunlight Foods, Inc. was issued a wastewater discharge permit on April 1, 2005, which contains
prohibitions, restrictions, and other limitations on the quality of the wastewater it discharges to
the sanitary sewer.
4. Pursuant to the City of Sanford Code and the above- eferenced permmit, data is routinely
collected or submitted on the compliance status of Sunlight Foods.
5. This data shows that Sunlight Foods, Inc. has violated its wastewater discharge permit and City
of Sanford Code in the following manner as found during the City inspection performed on May
19, 2()06 in, at a minimum, the following manners all of which violations represent significant
violation as set forth in Section 28-82 (192), City of Sanford Code:
a. Exceeding permitted limits for pH levels. Evaluation of the pH recording charts vs. flow
chart recording showed below range pH discharges for April 18, 19 and 21 of 2006 (see
Notice Of Violation (NOV) 002,14OV003 and NOV004 attached hereto).
b. Being below the range pH levels (43 units) was measured during the City sampling event
performed on April 22, 2006 (see NOV005 attached).
C . Unsatisfactory pH data was recorded on the pH charts in that, at a minimum, charts were
missing the starting and ending dates; calibration information (spikes representing buffer
concentration for the calibration); and operator's initial-
d. Output signal recording problems associated with delays and concentration measurements.
e. Lack of record keeping in that copies of the manifest forms demonstrating the maintenance
frequency for pump-outs of Iffie sludge tanks could not be produced at the time of the
inspecti
L Exceeding by signific the e limitations for Chemical Biological Oxidant Demand
(CBOD) stated in the permit (ICBOD ranging fivin 13,400 to 34,000 mg/L).
g. Steam lines fiom the boiler ;�em tie fotmd to be dieing from t= of the railcars
onto the side of the farm play
PART IIL ORDER
TMREFORE, BASED ON THE ABO VE FINDINGS, SUNLIGHT FOOA% INS IS HEREBY
ORDERED TO: 1
1. Comply with the following pre- rent modifications referred on the CES (Sunlight Foods
Engineer consulting company) d4cument dated Am 1, 2006 as modified below:'
a. pgyj= � SYSTEM plimG MODmcA,, nom — The system shall be re to help
the recycling the activated fiom the clarifier to back to the activated sludge. The
complete piping of the WaAmater flow and air blower flow shall be piped to assure
complete flexi'bflity for the p enot system so that adequate sludge can be
wasted. All flow directions be poly indicated by labels through the pipes
system Piping shall include tie proper color (as per industry standards landbook� valving,
check valves, strainers, mum. connections, bulk head fitting for tanks, pipe supports, Pipe
hangem instruct mounting of j*e and clean outs.
b. Swr►rCMQ Box Pyre Installation of down pipe at sampling location to
prevent solids from enuring the sanitary sewer system and relocation of the pH Monitoring
system to the sarupling point location is included m the piping modifications. The depth of
the sampling box shall allow at least twelve in dws (12") fiom the floor of the tank (twenty
four inches (24') to the outlet pipe to provide for proper sampling of oil and
grease wad collection. I
C. NEW (CHART RECORDER. OUT OF BANGS ALARM SYS!'M - Thu system shall be
equipped with a new chart system to shiow whm the pH system is c alibuted and
to Prevent any int,�rnions�oi sous pH recording. Additionally, the pH monitoring
system shall be equipped wth an alarm to alert the operator of nay potential. d ischarge
problems. System shall be � of record dual reading; flows vs. pH so compliance with
pH limitation can be dete�nete. Automatic daily print out of dates and significant out of
range events shall be inc in the recording as well Sunlight needs to provide the City
with mmm ffi w ftffff spedfl - for the proposed equipment for vaL
d. AUTwum PH CO NMWL RM - Currudy the pH is adjusted based on the operation of
the influent pump. This is rat recommended for continuous disobwee dwr an
additional pH controller wM be ad&d
and for maomatic pH a vsWjeM The controller needs to be set W operate the caustic pump
and maintain the pH m a sO range between: 5.0 -9.0 or more stringent a reoonnmended
window of 0.5 units is recommended for lower.and upper levels (5.5 — 8.5). No discharge of
2
pH outside of this range slaA enter the City's collection system Valve shall autornaticauy
shut- off wknm pH is outside d vcharge permitted limits.
e. I'.a►uaZ9[ox of Lit BLOyyA2Im S - The City is approving CBS proposal of up
grading the blowox system fiOrn l HP bkower to 15 HP an additional 15 BP Blower for
back- up to improve the poph P� tn�ot system
n, :.+.i . wst�r►�+ox (:r. —The City is approving CES prop
to install a Luella, plate ano frame clarifier to settle the activated sludge and to prevent
solids from passing over the. �eir. llow+aver, sludge tanks must be completely pumped out
on a quarterly basis=&9chmW m form shall be received by the City within 72 hrs of
the service. A new _ permit will be issue after the completion of all the
ma I* ffli ins listed in this Ch dea.
g. - The ir r zi lb st system does not have a oral control panel
to operate the trrntmicak sys. Pumps and blowers arcs on individual controls and cannot be
wed f o m a cwtral loon. (MS proposal to install a ca tad control panel will be
equipped with manual -- off- operations for fire trwafer pumps and motors' -I - P 0 q
fete file blovars at 15M as well as float controls, level controls and flow monhoriog totalizer
h. EOIIALLZATION TANKS i CummO the equalization tank is undersized to handle spi7ce
influent flow. CES is proposal to upgrade the current size- of 1200 gallons this tank to two
5000 gallons tanks to c ti* the wastewater prior to treaxnnert is approved
CorMswTZ C ONTRO L he boiler steam lines do not have steam traps to return the
comae to the boiler: To E�liimmate condensate discluurge from several areas in the plant,
repairing and installation of st wan traps, new pipang and control valves for the boiler system.
2. Sunlight Foods, Inc. is ordered to pay the fines as imposed on the City of Sanford Code related
with the exxeedance of the pH li�iit�ons. Refer to NOV002, NOV003, NOV004 and NOV005
( . The total cline for *w fines is 1,5{!000. This smount.wM be added to your next
Utility bill.
3. The calculated CBOD's much w* for the morrths of March, April, May and June, 2006 add to
the total amount of $84, 127. Sigigbt Foods shall pay the full amount of the surcharges within
thirty (30) days of the effective dire of this Order.
a. However, because of Sunlight Foods, Inc. willingness to assist the City with the proper
management and control of pollutants of concern, surcharges fees for violating the Cfty of
Sanford Code can be recoverod by Sunlight Foods by submitting invoices detmft the type
of work; dates of work and cOmpan name that performed the work at this facility. Invoices
shall be signed and dated by IA& Mark Gilden or his Supervisor in a manner acceptab to
the City. I
b. The. wiN a0 w 8096 sum fees for the month of July 2006 fa be recovered
by Sunlight Foods, Inc r0i — to the cor>dition stated an this Order. The remaining 20
will be added to the next u*y bill. A separated letter will be sent to Sunlight Foods, Inc.
once the calculations are made.
c. Invoices shall be directly related to the items listed on item 1111 (44) ofthis Order.
d. All submitted invoices shall �e subject to approval by the City's Utdity Director before any
ref nid is made. #
e. Tire tout amount of the inA*w shall not exceed the emomat listed in 1113.
4. An admirristrative cos% for the Jamouat of $10,000 firm the urges fees calculated on
section 111 (3) of this order will not be reffimdable to Sunlight Foods, tic ..
5. Stimclarge fees for the preceding month shalt be included in the respective utility bills.
6. Sunli ght Foods, Ine. shall comp.' the imp�covements listed in III 1(a 0 of this Order section
within sixty days (60) days of theeffective date of this Order.
6. All reports and notices required 1* this order shall be sent, in writing, to the following address:
Pent Coordinator-
City of Sanford
[Utility D eparbuen t
i P.O. Box 1788
Sanford, Florida 32772 -1788
7. This Order does not constihrte a �Wv+er of the wastewater discdmge- pexmiy which remains in
full fierce and effect. The Cityr�Mves the right to seek any and all remedies available to it
under flan provisions of tine City q(Sanford Corte as well as conhvEbg State and Fedmal fear any
violation cited by this Order. a
8. Far'h= to cornpiy with the req of this order stall comae a further violation of the
City of Samford Code and may sul jest sunlight Foods to civil or criminal pies or such other
appropriate caforeemea t r etas nary be app -
DATED this / sday of 3uty ! 2006, and effective immediately.
Pmd Wore, utilit n;er
[A
of Sanford Fj
C; "C
id
d
P.O. Box 1788.32772 -1788
Telephone (407) 330 -5640
Mr. Mark Gilden (electronic copy) CERTIFIED MAIL NUMBER
Director of Operation 7006 0810 0003 7671 0093
Sunlight Foods
2200 Country Club Rd
Sanford, FL 32779
Mr. Michael D . Cammisa, P.E. (electronic copy) CERTIFIED MAIL NUMBER
Principal Engineer
7006 0810 0003 7671 0109
CES Engineering, Inc.
4421 Northrop Terrace
Tampa FL 33624
SUBJECT: I N . B A TTED N OTICE OF
a 2200 CO UNTRRy CLUB S
ROAD,SAN OR FL
I
32773.
Dear Mr. Gilden and Mr. Cammisa:
A Notice of Violation has been included with this letter for failure to maintain the
wastewater effluent pH levels within the required limits as established in your
permit
A a result of the violations of the pH limit on April 18, 19, 21 and May 22, 2006,
the City of Sanford's Code of Ordinance and Wastewater Discharge Permit
assesses a penalty for this viol as follows:
INDUSTRIAL PRETREATMENT PENALTY TABLE FOR PIS
Low H Violation H Violation Penal Amount*
5.00
9.01 to 9.99
$ 125
10.00 to 10.49
$250
4.50 to 4.99
10.50 to 10.99
$375
4.00 -4.49
11.00 to 11.49
$500
3.50
-3.99
11.50 to 11.99
$625
3.00 to 3.49
12.00 to 12.49
$750
2.50 to 2.99
12.50 to 12.99
$875
2.00 to 2.49
The table above lists penalty amounts for exc:eedanoes of pH limit enforce by the
City's Ordinance to the extent permitted by Federal or Stage law. The penalty
shown for each level is applicable to each individuall pollutan Hin� case
pH) limit that has been exceeded. The apps, you water bill.
4.3 units is $375.00 this amount will be included in you
"The Friendly City"
In addition, your facility is required to manually adjust and monitor the pH of the
wastewater pretreatment system until the new (automatic) pH proposed system
is Installed -and final approval is giving by the City. unscheduled site inspections
may be performed by the City to assure oompihums with these requirements.
The penalty flee associated with
The City is presently evaluating the additional modifications proposed to reduce
the discharge of high CBOD levels into the City sewer system and will reply to
your request in a separate letter.
Please give this matter your attention and feel free to contact Alma R.
Echevarria, Pretreatment Coordinator @ (407) 302 -1086 if questions should
arise.
Si ,
R. Echevarria
Prefirealment Coordinator
CC: Paul Moose, LWdy Director
Charlie Turner, Utility Plant Manager
Migdaiia Hernandez, Water Resources Engineer
File copy, Permit No 0002 — 2
NOTICE OF VIOLATION
IN THE MATTER OF
Sunlight Foods, Inc.
2200 Country Club Road
Sanford, FL 32773
*
LEGAL AUTHORITY
The following firidings are made and notice issued pursuant to the authority Wanted under
Section 28.81 thru 28-136 of the Citys ortsronce. This order is based on f x&W of violation
of the condidons of the industrial wadewaW doge permit #0002 issued under Section 28-
124 of the Sanford City Code.
FINDINGS
1. The City of SardDrd is dtarged with cwdrudiw, wxI oMM of the sewer
system and treabnerrt works.
2. To prated the sewer system and treabnent work, the City of Sanford administers a
pretreatrrier� program.
3. Under this went pro the City of Sanford has issued a discharge permit.
4. The d�arge permit issued d#g Foods, Inc. contained numerical grits on the
qua of po w , Sr
hi
, which N FOod4, Inc. could age and Self- rlOnitonng
5. During the Giy Annual inspection perForrred on May 19, 2006. Evaluation of the pH
recording darts vs. flow chart recording showed below range pH discharges far April
19, 2006. The dWdwge permit issued to Sur*W Foods Inc requires compliance with
pH ranges between 5.0 and 9.0. This cormihles violation of the pretreattnent effluent
limit for pH.
THEREFORE, BASED ON THE ABOVE FINDINGS, SUNLIGHT FOODS, INC. IS HEREBY
NOTIFIED THAT:
1. It is in nonoomplimm with its kukmt ai WwWwatw Pis 00002 and the
sewer use ordnance of the City of SarW.
• • • • _.• _ r e • • • ♦� ti c r� • r • • _�
sw
Chart Turner m
LWY PM AbnW
DakK
NOV003 0 amt vwwm)
NOTICE OF VIOLATION
IN THE MATTER OF
Sunlight Foods, Inc.
2200 Country Club Road
Sanford, FL 32773
F7
LEGAL AUTHORITY
The following findings are made and notice issued pursuant to the authority granted under
Section 2"1 ttuv 28-136 of the City's Ordinaroe. This osier is based on findings of violation
of the moons of the indusWai wastewater discharge permit #0002 issued under Section 28-
124 of the Sanford City Code.
FINDINGS
1. The City of Sanford is charged with construction, maintenance, and conad of the sewer
systern and treadment worics.
2. To -protect the sewer system and trestrnent work, the City of Sanford adminsters a
pretreabnetrt program.
3. Under this preltr+ea trM t program, the City of Sanford has issued a cbeharge permit.
4. The discharge permit issued to Sunlrgfit Foods,- Inc. contained numerical limits on the
query of pollutants. which Su'JW Foods Inc. could discharge and self- monitoring
requirernerft-
5. During the City Annual inspection performed on May 19, 2006- Evaluation of the pH
moording charts vs. flow chart recording showed below range pH dbdwges for April
18, 2006. The discharge permit issued to SudW Foods Inm requires compliance with
pH ranges between 5.0 and 9.0. This corgis violation of the -prebealmot t effluent
limit for pH.
NOTICE
THEREFORE, BASED ON THE ABOVE FINDINGS, SUNLIGHT FOODS, INC. IS HEREBY
NOTIFIED THAT:
1. It is in noncompliance with its krxlusbw wastewater dsdwge permit #0002 and the
sewer use ordinance of the City of Sanford.
2 Sunlight Foods Inc is advised that progressive enfornwents acWm including fines will
be used against repeated or unresolved violations.
Si
4�- -4-�:
s
Charve Turner 111
UIIUty Plant manager
lam:
I
NOV002 (Em m t vwwmin
NOTICE OF VIOLATION
IN THE MATTER OF i
SunIWA Foods, Inc.
2200 Country Club Road
Samford, FL 32773
LEGAL AUTHORITY
The following findings are made and notice issued purivant to the authority granted under
Section 28-81 fhnu 28 -136 of the City's Ordinance.; This order is based on findings of vitiation
of the conditions of the kxkssMW wastewater 'dis� permit #0002 issued under Section 28-
124 of the Sanford City Code.
FINDI
I. The City d Sanford is durgot! with c;cxabupdM I i densim, and cor*ol of dw sewer
system • trestrnent wo rks.
2. To proWd the sewer system and work the City of Sardbrd administers a
• eb : = =t progr
4. The discharge permit issued 10 Sw%W Foods, Inc. contained nuinedcal kift on ft
quardy of pollutants, which Sunfight Foocip, Inc. could discharge and salf-rvxwdtoring
- • s:
5. During the City Annual inspection performed on May 19, 2006. Evaluation of the pH
recording charts vs flow dvut recording showed below range PH discharges fbr April
21, 2006. The dschaW piermit issued to $Wxight Foods Inc. feqt*w compliance with
pH ranges beb~ &0 and 9.0- This coraftles violation of the imehealment effluent
firrift •
NOTICE
THEREFORE, BASED ON THE ABOVE FINDINroS, SUNLIGHT FOODS, INC. IS HEREBY
NOTIFIED THAT:
ftned
Date:_
Charge Tuner III
MY Plant Manager
NOV004 (Ekw* vmom)
NOTICE OF VIOLATION
IN THE MATTER OF
Sunlight Foods, Inc
2200 C=ft Club Road
Sanford, FL 32773
LEGAL AUTHORITY
The following findings are made and notice issued pursuant to the authority granted under
Section 2"1 ttwu 28-136 of the City's Ordinance. This order is based on findings of violation
of the conditions of the industrial wasfewafer discharge permit #0002 issued under Section 28-
124 of the Sanford City Code.
FINDINGS
1. The City of Sanford is diarged with c ortshtK&rt, maintertaltce, and control of the sewer
system and ttwt mer t works.
2. To Muted the sewer system and treatment work, the City of Sanford administers a
Pretreatment program.
3. Under this pretreatmerrt program, the City of SWd& d has issued a age permit
4. The discharge pemat issued to Sunlght Foods, Inc coed numertculll limits on the
quality of poltcrtants, which Sunlight Foods /nc. Could discharge and self -monit ming
5. During the City sampling event performed on - MOY 22, 2006. The Qty recorded pH
measurements of 4.3 units. The urge Permit issued to 'ht Foods Inc s
corrvkrtoe with pH ranges between 5.0 and 9.0. This consftaes violation of the
pretreatment efluant limit for pH.
NOTIC
THEREFORE. BASED ON THE ABOVE FINDINGS, SUNLIGHT" FOODS, INC. IS HEREBY
NOTIFIED THAT.
SWIed
Charge Tuffier fit
Uft Pkut Manager
Datel �x;
NOVOW (Emmt vuawn)
EXHIBIT B
CITY OF SANFORD
UTILITY DEPARTMENT
46NORAt PR67ROA7M6N1 APP00A7J0N/$AS60N6 MON370R9NO R6POR7
PLEASE READ INSTRUCTIONS LOCATED ON PAGES 8-11 BEFORE COMPLETING THIS APPLICATION
1. A. COMPANY NAME:
ADDRESS:
B. FACILITY NAME: (If different than listed above)
2. A. NUMBER OF EMPLOYEES:
B. NUMBER OF SHIFTS:
3. A. Fully Describe Manufacturing or Service Activities and processes Conducted
and the Final products. Use additional sheets to elaborate, if necessary
B. SUMMARIZE EACH COMPONENT PROCESS:
NATURE OF OPERATION
PRODUCTION
R
A
T
E
SUBPART
SIC CODE
C. LIST ALL ENVIRONMENTAL PERMITS HELD
D. RAW MATERIALS USED: INCLUDE AVERAGE & MAXIMUM USED PER DAY:
(ATTACH ALL MSDS TO THIS APPLICATION)
E. CHEMICALS USED: INCLUDE AVERAGE & MAXIMUM USED PER DAY:
(ATTACH ALL MSDS TO THIS APPLICATION)
2
4. WASTEWATER FLOWS:
A. TOTAL PLANT FLOW AVERAGE
MAXIMUM
� y
TYPE OF DISCHARGE BATCH
CONTINUOUS
B. INDIVIDUAL FLOWS (gaoorwday)
AVERAGE
MAXIMUM TYPE OF
NAME OF PROCESS LINE (regulated) FLOW
FLOW DISCHARGE
(non - regulated)
TOTAL COOLING WATER
TOTAL SANITARY WASTE
LIST ANY DAILY, MONTHLY AND /OR SEASONAL VARIATIONS IN FLOW IF ANY
D. PROVIDE ON A SEPARATE SHEET(S):
3
1) Schematic drawing or flow chart of each regulated process
2) Schematic drawing showing all wastewater flows (regulated and unregulated),
location of any treatment system and sampling locations.
3) Water balance indicating amount of intake water, discharges to sewer, losses,
and water retained in products.
4) Site plans, floor plans, mechanical and plumbing plans and details to show all
sewers, sewer connections, and appurtenances by the size, location and
elevation.
2
6. NATURE OF WASTEWATERS DISCHARGED
[Report in concentrations (mgA) or mass (lbs.)]
Attach additional sheets if necessary. If you are reporting adjusted limits, submit all
appropriate calculations and flow data on additional sheets.
REGULATED PROCESS LINE (e.g., L1)
Pollutant:
Maximum:
Average:
Sample Type (explain):
Number of Samples Collected (explain):
REGULATED PROCESS LINE (e.g., 1-2)
Pollutant:
Maximum:
Average:
Sample Type (explain):
Number of Samples Collected (explain):
REGULATED PROCESS LINE (e.g., 1-3)
Pollutant:
Maximum:
Average:
Sample Type (explain):
Number of Samples Collected (explain):
E
7. FULLY DESCRIBE ANY AND ALL PRETREATMENT UTILIZED (SHOW
TREATMENT SYSTEM LOCATION IN RELATION TO PROCESS FLOWS ON
SCHEMATIC DRAWING REQUIRED BY QUESTION 3.13)
8. DOES YOUR FACILITY HAVE A SPILL PREVENTION COUNTERMEASURE
CONTROL (SPCC) PLAN ?
YES NO
9. BRIEFLY DESCRIBE DISPOSAL OF HAZARDOUS WASTE (CHEMICAL BY-
PRODUCTS) TO INCLUDE PRETREATMENT SLUDGES:
10. DESCRIBE LOCATION OF SAMPLING MANHOLE/POINT:
N
11. DESCRIBE LOCATION OF ENTRY OF PROCESS WASTESTREAMS TO
SANITARY SEWERS:
12. CERTIFIED STATEMENT
PRETREATMENT STANDARDS ARE ARE NOT
BEING MET ON A CONSISTENT BASIS. ADDITIONAL OPERATION AND
MAINTENANCE UNDER CONSIDERATION FOR COMPLIANCE IS AS
FOLLOWS:
ADDITIONAL PRETREATMENT UNDER CONSIDERATION TO MEET
STANDARDS IS AS FOLLOWS:
7
13. ESTIMATED SCHEDULE OF COMPLIANCE (Attach on additional sheet)
[See 128/81 FEDERAL REGISTER SEC. 403.12(b)(7) & (c)].
14. LIST ANY ENVIRONMENTAL CONTROL PERMITS HELD BY THE FACILITY.
"7 certify under penalty of law that 1 have personally examined and 1 am familiar with the
information in this application and all attachments and that, based on my inquiry of those
persons immediately responsible for obtaining the information contained in the application,
I believe that the information is true, accurate and complete. I am aware that there are
significant penalties for submitting false information, including the possibility of fine and
imprisonment" (See 1128181 Federal Register, Section 403.12(k) for information on
signatory.)
"Additionally, I certify that the sampling and analysis conducted is representative of
normal work cycles and expected pollutant discharges to the POTW ".
OFFICIAL TITLE
NAME PRINTED OR TYPED
SIGNATURE
TELEPHONE NUMBER
DATE
F
EXHIBIT B
BASELINE MONITORING REPORT INSTRUCTIONS
This form shall be completed and returned to:
PRETREATMENT COORDINATOR
CITY OF SANFORD
UTILITY PLANT
P.O. BOX 1788
SANFORD, FL 32772 -1788
ITEM 1. A. GIVE THE NAME, AS IT IS LEGALLY REFERRED TO, OF THE PERSON,
FIRM, PUBLIC ORGANIZATION, OR ANY OTHER ENTITY WHICH
OWNS OR IS DIRECTLY RESPONSIBLE FOR THE FACILITY OR
ACTIVITY DESCRIBED IN THIS FORM. THIS MAY OR MAY NOT BE
THE SAME NAME AS THE FACILITY OR ACTIVITY PRODUCING THE
DISCHARGE. DO NOT USE COLLOQUIAL NAMES OR A SUBSTITUTE
FOR THE OFFICIAL NAME. GIVE THE COMPLETE MAILING ADDRESS
OF INDUSTRIAL USERS` MAIN OFFICE. THIS OFTEN WILL NOT BE
THE SAME ADDRESS USED TO DESIGNATE THE LOCATION OF
FACILITY OR ACTIVITY.
B. GIVE THE COMPLETE NAME AND ADDRESS OF FACILITY
PRODUCING THE DISCHARGE. IF SAME AS A, SO STATE.
ITEM 2. A & B SELF-EXPLANATORY
ITEM 3. A. STATE THE NATURE OF BUSINESS OR SERVICE, PRODUCTION
RATES, APPLICABLE SUBPARTS, AND APPROPRIATE STANDARD
INDUSTRIAL CLASSIFICATION (SIC) CODES. THE DISCHARGER
MUST BE SPECIFIC IN IDENTIFYING EACH PROCESS, ALONG WITH
THE AMOUNTS OF PRODUCTS PRODUCED USUALLY GIVEN AS AN
ANNUAL AVERAGE PRODUCTION OR MONTHLY AVERAGE. (E.G.,
M3 OF FEEDSTOCK - PETROLEUM INDUSTRY, LBS. OF PRODUCT
PRODUCED - IRON AND STEEL; LBS. OF PRODUCT PRODUCED -
INORGANIC; M3 OF PRODUCT - TIMBER PRODUCTS (WOOD
PRESERVING UNITS). IN ADDITION, IF OTHER MANUFACTURING
PROCESSES NOT RELATED TO ANY OF THE SUBCATEGORIES
9
EXISTS, THE DISCHARGER MUST PROVIDE A GENERAL
DESCRIPTION OF THE OTHER MANUFACTURING OPERATIONS
(USE ADDITIONAL SHEETS IF NECESSARY.)
B & C SELF EXPLANATORY
D. PROVIDE INFORMATION ON RAW MATERIALS UTILIZED. (USE
ADDITIONAL SHEETS IF NECESSARY).
E. PROVIDE INFORMATION ON CHEMICALS UTILIZED, INCLUDING
SOLVENTS. IF TRADE NAMES GIVEN, PROVIDE INFORMATION ON
ACTIVE INGREDIENT, IF KNOWN.
ITEM 4. A. PROVIDE TOTAL PLANT FLOW (AVERAGE AND MAXIMUM) TO
SANITARY SEWER (IF ACCURATE FLOW MEASUREMENTS ARE
LACKING, PROVIDE BEST ESTIMATE). THE TOTAL PLANT FLOW
SHOULD INCLUDE DOMESTIC WASTEWATERS, REGULATED
PROCESS WASTEWATERS, COOLING WATER PLUS ANY OTHER
MANUFACTURING WASTEWATERS. INDICATE WHETHER
CONTINUOUS OR BATCH DISCHARGING IS OCCURRING.
$. PROVIDE AVERAGE AND MAXIMUM FLOWS FROM REGULATED
PROCESSES. IN COME CASES THESE WASTEWATERS ARE
COMBINED. IF SO, PLEASE INDICATE THAT VOLUMES REPORTED
ARE SUMMATION OF ANY REGULATED PROCESSES. INDICATE
WHETHER DISCHARGES ARE CONTINUOUS OR BATCH. ALSO
INCLUDE NON - REGULATED PROCESSES, COOLING WATER AND
SANITARY WASTEWATER FLOWS.
ITEM 5. IN ORDER TO PROVIDE THE REVIEWING AGENCY WITH A FIRM
UNDERSTANDING OF PROCESSES /RELATED FLOWS/ AND
PRETREATMENT FACILITIES, THE DISCHARGER IS REQUIRED TO
SUBMIT A "SCHEMATIC OF EACH PROCESS AND ASSOCIATED
FLOWS AND PRETREATMENT SYSTEM ALL DRAWINGS SHOULD
BE ON MATERIAL SUITABLE FOR REPRODUCTION. IT SHOULD BE
SIMPLE, BUT COMPLETE. FLOWS CAN BE ESTIMATED. INDICATE
ON SCHEMATIC WHERE SAMPLES FOR ITEM 6 WERE TAKEN.
ITEM 6. A. EACH INDUSTRIAL USER WILL SAMPLE, ANALYZE AND REPORT ON
ALL POLLUTANTS REGULATED SPECIFIC TO EACH PROCESS
(REFER TO APPROPRIATE SUBCATEGORY IN REGULATIONS FOR
REGULATED POLLUTANTS). WHERE MASS LIMITS EXIST, THE
FACILITY WILL HAVE TO REPORT RESULTS IN MASS LIMITS
(CONCENTRATION X REGULATED PROCESS FLOW (MILLION
GALLONS /DAY) X 8.34).
- THE BAT PRETREATMENT STANDARDS ARE PROCESS - RELATED.
10
THAT IS, A FACILITY MUST COMPLY WITH THE STANDARD AT THE
END-OF-EACH REGULATED PROCESS. HOWEVER, EPA
RECOGNIZES THAT MANY FACILITIES COMBINE THEIR
WASTEWATER PROCESS LINES, COOLING H2O, AND SANITARY
PRIOR TO TREATMENT OR DISCHARGE TO MUNICIPAL SEWERS.
HENCE, A FACILITY CAN SAMPLE AT A COMBINED POINT, BUT WILL
NEED TO ADJUST THE CATEGORICAL LIMITS IT MUST MEET BY (I. E.
CALCULATED ADJUSTED LIMITS) EMPLOYING THE COMBINED
WASTESTREAM FORMULA WHICH IS CONTAINED IN SECTION
403.6(E) OF THE GENERAL PRETREATMENT REGULATIONS
(FEDERAL REGISTER JANUARY 28, 198 1). IF THIS IS THE CASE
WITH YOUR FACILITY, YOU MUST EMPLOY THE FORMULA AND
PROVIDE ADDITIONAL DATA FOR CALCULATIONS. SEE
ATTACHMENT 2 FOR FURTHER EXPLANATION.
- INDICATE TYPES OF SAMPLES (I.E. GRAB, FLOW PROPORTIONED
COMPOSITE, ETC.), ANALYTICAL METHODS AND NUMBER OF
SAMPLES TAKEN. INDICATE WHETHER SAMPLES WERE TAKEN OF
COMBINED WASTESTREAMS. THE INDUSTRIAL USER MUST
ASCERTAIN WHETHER IT CAN MEET THE 30-DAY AVERAGE,
CALCULATED AVERAGE, DAILY MAXIMUM OR CALCULATED
MAXIMUM LIMIT. THE TYPE OF DISCHARGE, I.E., BATCH,
CONTINUOUS, ROUTINE HISTORICAL INFORMATION (E.G. EXISTING
DATA POLLUTANT DISCHARGE), ETC., IS A FACTOR THAT SHOULD
GUIDE THE INDUSTRIAL USER REGARDING THE NUMBER OF
SAMPLES TO BE TAKEN TO ASCERTAIN COMPLIANCE. WHERE
FEASIBLE, SAMPLES SHOULD BE FLOW-PROPORTIONAL
COMPOSITES. ADDITIONALLY, THE TIME, DATE OF SAMPLING, AND
METHODS OF ANALYSIS MUST BE REPORTED. IT IS IMPORTANT
THAT THE SAMPLES BE REPRESENTATIVE AND TAKEN DURING
FULL PRODUCTION. MINIMUM SAMPLING REQUIREMENTS ARE:
PROCESS FLOWS < 250,000 GPD -- 3 SAMPLES WITHIN 2 WEEK
PERIOD.
PROCESS FLOWS > 250,000 GPD -- 6 SAMPLES WITHIN 2 WEEK
PERIOD.
PLEASE INDICATE ON SCHEMATIC FOR ITEM 5 WHERE SAMPLES WERE
TAKEN. "TRACE" OR "0.0 MG/L' IS NOT A VALID ANALYTICAL RESULT.
IF POLLUTANTS ARE NOT DETECTED, REPORT DETECTION LEVEL.
I TEM 7. DESCRIBE PRETREATMENT SYSTEM (INCLUDE EXPLANATION OF WHICH
PROCESS FLOWS ARE TREATED). IT IS DESIRABLE TO REFER TO
SCHEMATIC REQUIRED UNDER ITEM 5.
ITEM 8, 9, 1 0. 1 1 , 14 -SELF-EXPLANATORY.
11
ITEM 12. IN ORDER TO DETERMINE COMPLIANCE WITH PUBLISHED OR
CALCULATED MASS-BASED CATEGORICAL STANDARDS, A FACILITY WILL
NEED TO COMPARE ITS ALLOWABLE MASS LIMIT
PB = .00261 X 200,000 LBs. OF STEEL = 422 LBS.
LBS.
1000
LBS.
AGAINST THE ACTUAL MASS LOADING DERIVED FROM SAMPLING (I.E.,
CONC. X REGULATED PROCESS FLOWS X 8.34 - LBS. DISCHARGED). IF
CATEGORICAL STANDARDS ARE PUBLISHED IN CONCENTRATION, THEN A
FACILITY ONLY NEEDS TO COMPARE THE CONCENTRATION OF ITS
EFFLUENT AGAINST THE REGULATED STANDARDS FOR THE PARTICULAR
POLLUTANT.
ITEM 13. SELF- EXPLANATORY (SEE JANUARY 26, 1 981 , FEDERAL REGISTER
SECTION 403.12(B)(7) AND (C), P. 9452 - 9453).
12