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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