Please refer to the Summary of Findings section of the attached inspection report and provide a written response for each violation that was noted.

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1 May 5, 2014 The Honorable Jackie Crabtree Mayor, City of Pea Ridge P.O. Box 29 Pea Ridge, AR72751 RE: Reconnaissance Inspection AFIN: Permit No.: AR Dear Ms. Stahman: On April 14, 2014, Matt Holden, District 1 Field Inspector, and I performed a reconnaissance inspection in response to a complaint. The inspection was conducted in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. A copy of the inspection report is enclosed for your records. Please refer to the Summary of Findings section of the attached inspection report and provide a written response for each violation that was noted. This response should be mailed to the attention of the Water Division Inspection Branch at the address at the bottom of this letter or e- mailed to Water-Inspection-Report@adeq.state.ar.us. This response should contain documentation describing the course of action taken to correct each item noted. This corrective action should be completed as soon as possible, and the written response with all necessary documentation (i.e. photos) is due by May 19, If I can be of any assistance, please contact me at west@adeq.state.ar.us or , ext.-12. Sincerely, Alison West District 1 Field Inspector Water Division Page 1 of 11

2 FACILITY INFORMATION NAME: City of Pea Ridge POTW LOCATION: 2456 N. Clark Street CITY: Pea Ridge RESPONSIBLE OFFICIAL NAME: / TITLE The Honorable Jackie Crabtree / Mayor COMPANY: City of Pea Ridge MAILING ADDRESS: P.O. Box 29 ***** CITY, STATE, ZIP: Pea Ridge AR PHONE & EXT: / FAX: / WATER DIVISION INSPECTION REPORT AFIN: PERMIT #: AR DATE: 4/14/2014 COUNTY: 04 Benton PDS #: MEDIA: WN GPS LAT: N LONG: W LOCATION: General Area FACILITY TYPE: 1 - Municipal FACILITY EVALUATION RATING: *** INSPECTION INFORMATION INSPECTOR ID#: S - State DATE(S): ENTRY TIME: EXIT TIME: 4/14/ :00 FAYETTEVILLE SHALE RELATED: N INSPECTION TYPE: Reconnaissance PERMIT EFFECTIVE DATE: 11/1/2012 PERMIT EXPIRATION DATE: 10/31/2017 FAYETTEVILLE SHALE VIOLATIONS: N INSPECTION PARTICIPANTS NAME/TITLE/PHONE/FAX/ /ETC.: Ken Hayes/Pea Ridge Utilities Manager/ CONTACTED DURING INSPECTION: No AREA EVALUATIONS (S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Applicable/Evaluated) ** PERMIT ** FLOW MEASUREMENT ** STORMWATER ** RECORDS/REPORTS ** LABORATORY ** FACILITY SITE REVIEW ** OPERATION & MAINTENANCE ** EFFLUENT/RECEIVING WATER ** SELF-MONITORING PROGRAM ** SAMPLING ** SLUDGE HANDLING/DISPOSAL ** PRETREATMENT ** OTHER: SUMMARY OF FINDINGS The following violations were noted: 1. Slime formations were documented in the receiving stream. This is a violation of Part 1. A of the permit. 2. After reviewing the December 2013 and January-February 2014 Discharge Monitoring Reports (DMRs), it was revealed the facility experienced the following permit excursions: Three permit excursions for Ammonia Nitrogen during December During January 2014, the facility had three excursions for Total Suspended Solids and three excursions for Ammonia Nitrogen. During February 2014, the facility had three excursions for Ammonia Nitrogen. These violations were noted on the monthly DMRs and were also submitted to the Department on the Non-Compliance Reports. The excursions are a violation of Part I, Section A2 of the permit. 3. Facility was not maintaining an equipment maintenance log. Inspection Report Page 2 of 11

3 GENERAL COMMENTS On April 14, 2014, Matt Holden, District 1 Field Inspector, and I conducted a reconnaissance inspection in response to a complaint. The complainant alleged the treatment plant stinks like sewer, Otter Creek has moss/algae all over it, aeration not working, and concerned about cattle as complainant uses the water from the creek for her cattle. Mr. Hayes stated that there are 12 aerators is Lagoon 1; 8 aerators in Lagoon 2; 6 aerators in Lagoon 3; and, 4 aerators in Lagoon 4. The aerators in each lagoon were running at the time of the inspection. Algae/slime was observed in Otter Creek directly below Outfall 001. The algae/slime was observed downstream of Outfall 001. During the inspection, Mr. Holden and I reviewed the following Discharge Monitoring Reports: September 2013, November 2013, December 2013, January 2014, and February Permit excursions were noted during December 2013, January and February A non-compliance report was submitted to the Department for each permit excursion. During the inspection, Mr. Hayes stated that he was working with Triple Point Technologies, Contractor, in regards to the algae, permit excursions, and lagoon temperatures. The City of Pea Ridge will submit a report to the Department after Triple Point Technologies reviews data from the City of Pea Ridge. According to Mr. Hayes, the temperatures warmed up in mid-march. We were informed that the wastewater was much greener. He stated it looked like an algae bloom. Mr. Hayes said that the wastewater temperatures in the lagoons went up from 30 degrees F to mid-50 degrees F. In addition, we were informed that the plant was down sometime on April 9 to replace a backwash relay on April 10 and April 11. Mr. Hayes stated that the aerators were still running while the plant was down. The facility could only produce maintenance records for May 14, 2013 and December 27, INSPECTOR S SIGNATURE: -Alison West DATE: 5/2/2014 SUPERVISOR S SIGNATURE: Jason Bolenbaugh DATE: 5/5/2014 Inspection Report Page 3 of 11

4 Photographer: Alison West Date: Time: 11:15 Witness: Matt Holden Photo #: 1 DSCN2280. Outfall 001. Permitted discharge into Otter Creek. Slime on rocks where discharge from Outfall 001 enters into Otter Creek. Photographer: Alison West Date: Time: 11:08 Witness: Matt Holden Photo #: 2 DSCN2263. Effluent discharging through Outfall 001. Inspection Report Page 4 of 11

5 Photographer: Alison West Date: Time: 11:09 Witness: Matt Holden Photo #: 3 DSCN2266. Algae/slime in Otter Creek below Outfall 001. Photographer: Alison West Date: Time: 11:10 Witness: Matt Holden Photo #: 4 DSCN2268. Close-up of algae/slime in Otter Creek. Inspection Report Page 5 of 11

6 Photographer: Alison West Date: Time: 11:10 Witness: Matt Holden Photo #: 5 DSCN2269. Algae/slime in Otter Creek downstream of Outfall 001. Photographer: Alison West Date: Time: 11:11 Witness: Matt Holden Photo #: 6 DSCN2272. Algae/slime in Otter Creek downstream of Outfall 001. Inspection Report Page 6 of 11

7 Photographer: Alison West Date: Time: 11:13 Witness: Matt Holden Photo #: 7 DSCN2276. Looking upstream towards Outfall 001. Algae/slime in Otter Creek downstream of Outfall 001. Photographer: Alison West Date: Time: 11:13 Witness: Matt Holden Photo #: 8 DSCN2279. Algae/slime in Otter Creek downstream of Outfall 001. Inspection Report Page 7 of 11

8 Photographer: Alison West Date: Time: 11:26 Witness: Matt Holden Photo #: 9 DSCN2285. Three Ammonia Nitrogen excursions during the month of December Photographer: Alison West Date: Time: 11:26 Witness: Matt Holden Photo #: 10 DSCN2287. Non-compliance report for the three Ammonia Nitrogen excursions during December Inspection Report Page 8 of 11

9 Photographer: Alison West Date: Time: 11:29 Witness: Matt Holden Photo #: 11 DSCN2294. Three Ammonia Nitrogen and three Total Suspended Solids excursions during the month of January Photographer: Alison West Date: Time: 11:28 Witness: Matt Holden Photo #: 12 DSCN2291. Non-compliance report for the three Total Suspended Solids excursions during January Inspection Report Page 9 of 11

10 Photographer: Alison West Date: Time: 11:29 Witness: Matt Holden Photo #: 13 DSCN2292. Non-compliance report for the three Ammonia Nitrogen excursions during January Photographer: Alison West Date: Time: 11:30 Witness: Matt Holden Photo #: 14 DSCN2296. Three Ammonia Nitrogen excursions during the month of February Inspection Report Page 10 of 11

11 Photographer: Alison West Date: Time: 11:31 Witness: Matt Holden Photo #: 15 DSCN2300. Non-compliance report for the three Ammonia Nitrogen excursions during February Inspection Report Page 11 of 11

12 May 15, 2014 Ms. Joy Alison West Arkansas Department of Environmental Quality Water Division Inspection Branch 5301 Northshore Drive North Little Rock, AR RE: Reconnaissance Inspection AFIN: Permit Number: AR Dear Ms. West. This letter is The Utilities response to the Summary of Findings from a reconnaissance inspection that took place on April 14, 2014 at the Pea Ridge Wastewater Treatment facility. The unseasonably colder winter had a very negative impact on the Pea Ridge Treatment Facility. We experienced three separate occasions in which the temperature stayed below freezing for approximately a week. This condition drove our lagoon temperature to very near freezing. The chart below represents the temperature trends for ponds one thru four, for the months of February and March. In mid-march an algae bloom took place in ponds three and four. The water became very green color, our TSS increased, and we saw an increase in the CBOD. When samples were taken near the end of April our test results were back in compliance. I contacted the contractors that were responsible for our plant up-grade, that took place in 2013, on May 5 th (Triplepoint Water Technologies). I ed to them all of the SCADA information for the months of October thru May. They indicated that their engineers would review this data and get back with their best diagnosis and recommendation on a course of action. When this is done I will contact you and Alen Anderson with an action Plan.

13 Response to findings. 1. The algae growth at our outfall is related to the algae bloom mentioned above. 2. I would agree with the violation as stated. 3. The equipment maintenance log was in place but there were occasions that scheduled maintenance was not recorded. I have met with all employees regarding this matter and I can assure you that it will not happen again. The treatment facility In Pea Ridge does not run twenty four hours a day. We are currently running twenty one hour cycles. This will increase or decrease based on flow. Any maintenance is completed before the plant is started. The aeration runs twenty four hours a day seven days a week. We have three blowers in which two are run at all times. Preventative maintenance is completed on a blower when it is idle. If you have any further comments or questions please call me at Sincerely Ken Hayes Utility Manager Cc: Mayor Jackie Crabtree

14 November 10, 2014 The Honorable Jackie Crabtree Mayor, City of Pea Ridge P.O. Box 29 Pea Ridge, AR72751 RE: Response to Reconnaissance Inspection AFIN: Permit No.: AR Dear Mayor Crabtree: I have reviewed the response pertaining to my April 14, 2014 inspection of the City of Pea Ridge POTW. The information provided sufficiently addresses the violations referenced in my inspection report. At this time the Department has no further comment concerning this particular inspection. Acceptance of this response by the Department does not preclude any future enforcement action deemed necessary at this site or any other site. If we need further information concerning this matter, we will contact you. Thank you for your attention to this matter. Should you have any questions, feel free to contact me at , ext. 12 or you may me at west@adeq.state.ar.us. Sincerely, Alison West District 1 Inspector Water Division