No violations were noted at the time of the inspections. Please refer to each of the attached inspection reports for any comments.

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1 September 9, 2015 Steve Parke, Director of Utilities City of Fort Smith 3900 Kelley Hwy Fort Smith, AR RE: City of Fort Smith - "P" Street WWTP Inspections (Sebastian Co) AFIN: Permit No.: AR ARR AR C Dear Mr. Parke: On August 19 and September 3, 2015, I performed a Compliance Evaluation Inspection, Sanitary Sewer/Collection System Inspection, an Industrial Stormwater (No-Exposure) Inspection, and a State WWTP Construction Inspection of the above-referenced facility in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. Copies of the inspection reports are enclosed for your records. No violations were noted at the time of the inspections. Please refer to each of the attached inspection reports for any comments. I would like to thank Mr. Plank, Key, Cowan, Mahan, and Floyd for their assistance provided during the inspections. If I can be of any assistance, please contact me at mccabe@adeq.state.ar.us or (501) Sincerely, Kerri McCabe Inspector Supervisor Water Division Cc: Steve Parke, City of Fort Smith, Director of Utilities, sparke@fortsmithar.gov Gerald Plank, City of Fort Smith, Supervisor of WW Operations, gplank@fortsmithar.gov Page 1 of 23

2 FACILITY INFORMATION NAME: City of Fort Smith - "P" Street WWTP LOCATION: 13 North P Street CITY: Fort Smith, AR RESPONSIBLE OFFICIAL NAME: / TITLE Steve Parke / Director of Utilities COMPANY: City of Fort Smith MAILING ADDRESS: 3900 Kelley Hwy CITY, STATE, ZIP: Fort Smith AR PHONE & EXT: / FAX: / WATER DIVISION INSPECTION REPORT AFIN: PERMIT #: AR DATE: 8/19/2015 COUNTY: 66 Sebastian PDS #: MEDIA: WN GPS LAT: LONG: LOCATION: Entrance FACILITY TYPE: 1 - Municipal FACILITY EVALUATION RATING: 3 - Satisfactory INSPECTION INFORMATION INSPECTOR ID#: S - State DATE(S): ENTRY TIME: EXIT TIME: 8/19/ :00 14:30 9/3/ :00 11:30 FAYETTEVILLE SHALE RELATED: N INSPECTION TYPE: Compliance Evaluation PERMIT EFFECTIVE DATE: 3/1/2012 PERMIT EXPIRATION DATE: 2/28/2017 FAYETTEVILLE SHALE VIOLATIONS: N INSPECTION PARTICIPANTS NAME/TITLE/PHONE/FAX/ /ETC.: Gerald Plank/Supervisor of WW Operations (Lic# )/(479) /gplank@fortsmithar.gov Johnny Key/Chief Operator (Lic# ) Preston Cowan/Chief Operator (Lic# ) District 4 Water Inspector Alana Sullivan sparke@fortsmithar.gov CONTACTED DURING INSPECTION: Yes AREA EVALUATIONS (S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Applicable/Evaluated) S PERMIT S FLOW MEASUREMENT N STORMWATER S RECORDS/REPORTS N LABORATORY S FACILITY SITE REVIEW S OPERATION & MAINTENANCE S EFFLUENT/RECEIVING WATER S SELF-MONITORING PROGRAM S SAMPLING S SLUDGE HANDLING/DISPOSAL N PRETREATMENT ** OTHER: SUMMARY OF FINDINGS No violations were noted during the inspection. Please see General Comments for minor recordkeeping issues noted during the inspection (refer to Part III, Section C, 8.A F. of the permit). Permittee s certified lab did not supply COCs and bench sheets utilized to prepare DMRs; and therefore, Sections B and F below could not be fully evaluated. A complete records review of the permittee s lab will be conducted during the 2017 inspection. Inspection Report Page 2 of 23

3 GENERAL COMMENTS On Wed Aug 19, 2015 a compliance inspection was conducted with the above-mentioned participants. The inspection consisted of a site assessment and records review. Inspections of the facility s collection system, No-Exposure certification, and State-issued WWTP construction permit were also conducted (see separate reports for each inspection). Also, a facility tour was conducted on Thur Sept 3, The site assessment was made difficult due to weather-related issues (i.e., lightening); however, Mr. Plank was thorough with the explanation of all treatment components associated with the plant. As a result of past tornado damage, the plant is relatively new with numerous technologically-advanced upgrades. Treatment consists of enclosed preliminary (course screening at lift stations as well as fine screening at the plant and degritting), enclosed bio-scrubbers for odor control (hydrogen sulfide and ammonia removal), anoxic bioselectors (filamentous bacteria control), aerated activated sludge, secondary clarifiers (sedimentation), chlorine disinfection, dechlorination (sodium bisulfite), and post-aeration. There are three (3) primary clarifiers that have been converted to secondary clarifiers that can be used during wet-weather conditions and are typically used times a year. For wet-weather flows, an additional 38 MGD can be treated as the plant is capable of diverting influent to the Ballasted Flocculation Unit (BFU) for partial treatment before routing to a flow EQ basin for storage. This treatment process is similar to water treatment in that it removes suspended solids by chemical additions, which result in coagulation, flocculation, and sedimentation (non-biological). The dissolved solids still remain in the influent, but the odor-causing components have been removed. When influent flow recedes, the partially treated wastewater is routed back to the plant for biological treatment. Sludge is wasted to sludge belt presses, thickened, dewatered, and hauled to the City s Class I landfill (permit# 0267-S1-R1) as Class B sludge. Effluent was observed at the sample location, rectangular weirs, and at the outfall. Effluent was clear with no visible solids or foam of a persistent nature. Effluent is routed to Outfall 001 via gravity feed; however, during flood conditions of the Arkansas River, it is necessary to force effluent to the receiving stream via a pump station and alternate outfall. The gate and valve for the force main were closed and locked during the inspection. Next, a records review was conducted. Operators at the plant are responsible for flow, DO, ph, and TRC samples. The City of Fort Smith s certified lab analyzes the remaining effluent parameters: CBOD5, BOD5, TSS, NH3-N, FCB, NO3+NO2-N, and Total Phosphorus. The City uses Pace Analytical Services, Inc. for WET testing. Operators should review Part III, Section C, 8.A F. for all requirements for records (i.e., time on flow sheets, exact location for flow measurement, etc.). The Operators keep well-maintained and organized records. The City s lab did not include COCs or bench sheets utilized for preparing monthly DMRs; however, inspectors were provided in-house spreadsheets used to keep track of analytical data. A thorough review of the recordkeeping for the City s lab will be conducted during the 2017 inspections of the Massard and P Street WWTPs. INSPECTOR S SIGNATURE: Kerri McCabe DATE: 9/8/2015 SUPERVISOR S SIGNATURE: Jason Bolenbaugh DATE: 9/9/2015 Inspection Report Page 3 of 23

4 SECTION A: PERMIT VERIFICATION PERMIT SATISFACTORILY ADDRESSES OBSERVATIONS S M U NA NE DETAILS: 1. CORRECT NAME AND MAILING ADDRESS OF PERMITTEE: Y N NA NE 2. NOTIFICATION GIVEN TO EPA/STATE OF NEW DIFFERENT OR INCREASED DISCHARGES: Y N NA NE 3. NUMBER AND LOCATION OF DISCHARGE POINTS AS DESCRIBED IN PERMIT: Outfall 001 has gravity and force options due to Arkansas River level; discharge to same location. Y N NA NE 4. ALL DISCHARGES ARE PERMITTED: Y N NA NE SECTION B: RECORDKEEPING AND REPORTING EVALUATION RECORDS AND REPORTS MAINTAINED AS REQUIRED BY PERMIT S M U NA NE DETAILS: Lab did not supply COCs and bench sheets utilized for sample collection and analyses; evaluated Operators bench sheets for DO, flow, ph, and TRC. 1. ANALYTICAL RESULTS CONSISTENT WITH DATA REPORTED ON DMRS: See above; will conduct records review of lab during 2017 inspection. Y N NA NE 2. SAMPLING AND ANALYSES DATA ADEQUATE AND INCLUDE: S M U NA NE a. DATES AND TIME(S) OF SAMPLING: Need time on flow sheet. Y N NA NE b. EXACT LOCATION(S) OF SAMPLING: Need exact location on flow sheet (e.g., Chamber A, etc.). Y N NA NE c. NAME OF INDIVIDUAL PERFORMING SAMPLING: Y N NA NE d. ANALYTICAL METHODS AND TECHNIQUES: Y N NA NE e. RESULTS OF CALIBRATIONS: Y N NA NE f. RESULTS OF ANALYSES: Y N NA NE g. DATES AND TIMES OF ANALYSES: Y N NA NE h. NAME OF PERSON(S) PERFORMING ANALYSES: Y N NA NE 3. LABORATORY EQUIPMENT CALIBRATION AND MAINTENANCE RECORDS ADEQUATE: S M U NA NE 4. PLANT RECORDS INCLUDE SCHEDULES, DATES OF EQUIPMENT MAINTENANCE AND REPAIR: S M U NA NE 5. EFFLUENT LOADINGS CALCULATED USING DAILY EFFLUENT FLOW AND DAILY ANALYTICAL DATA: Y N NA NE SECTION C: OPERATIONS AND MAINTENANCE TREATMENT FACILITY PROPERLY OPERATED AND MAINTAINED DETAILS: S M U NA NE 1. TREATMENT UNITS PROPERLY OPERATED: S M U NA NE 2. TREATMENT UNITS PROPERLY MAINTAINED: S M U NA NE 3. STANDBY POWER OR OTHER EQUIVALENT PROVIDED: Divert to standby treatment and storage during wet-weather; redirect to full treatment when flows are low. S M U NA NE 4. ADEQUATE ALARM SYSTEM FOR POWER OR EQUIPMENT FAILURES AVAILABLE: S M U NA NE 5. ALL NEEDED TREATMENT UNITS IN SERVICE: Primary clarifiers converted to secondary clarifiers only used during wetweather events (15-20 times/year). S M U NA NE 6. ADEQUATE NUMBER OF QUALIFIED OPERATORS PROVIDED: Two (2) Chief Operators (both Class IV). S M U NA NE 7. SPARE PARTS AND SUPPLIES INVENTORY MAINTAINED: S M U NA NE 8. OPERATION AND MAINTENANCE MANUAL AVAILABLE: Y N NA NE 9. STANDARD OPERATING PROCEDURES AND SCHEDULES ESTABLISHED: Y N NA NE 10. PROCEDURES FOR EMERGENCY TREATMENT CONTROL ESTABLISHED: See #3 Y N NA NE 11. HAVE BYPASSES/OVERFLOWS OCCURRED AT THE PLANT OR IN THE COLLECTION SYSTEM IN THE LAST YEAR: Y N NA NE 12. IF SO, HAS THE REGULATORY AGENCY BEEN NOTIFIED: USEPA R6 enforcement authority; monthly SSO reports. Y N NA NE 13. HAS CORRECTIVE ACTION BEEN TAKEN TO PREVENT ADDITIONAL BYPASSES/OVERFLOWS: Current Consent Decree through USEPA R6. Y N NA NE 14. HAVE ANY HYDRAULIC OVERLOADS OCCURRED AT THE TREATMENT PLANT: Y N NA NE 15. IF SO, DID PERMIT VIOLATIONS OCCUR AS A RESULT: Y N NA NE Inspection Report Page 4 of 23

5 SECTION D: SAMPLING PERMITTEE SAMPLING MEETS PERMIT REQUIREMENTS S M U NA NE DETAILS: Operators at P Street WWTP sample/analyze DO, flow, ph, and TRC; Fort Smith Utility EQAL samples/analyzes other permit parameters. 1. SAMPLES TAKEN AT SITE(S) SPECIFIED IN PERMIT: Y N NA NE 2. LOCATIONS ADEQUATE FOR REPRESENTATIVE SAMPLES: Y N NA NE 3. FLOW PROPORTIONED SAMPLES OBTAINED WHEN REQUIRED BY PERMIT: Y N NA NE 4. SAMPLING AND ANALYSES COMPLETED ON PARAMETERS SPECIFIED IN PERMIT: Y N NA NE 5. SAMPLING AND ANALYSES PERFORMED AT FREQUENCY SPECIFIED IN PERMIT: Y N NA NE 6. SAMPLE COLLECTION PROCEDURES ADEQUATE: Y N NA NE a. SAMPLES REFRIGERATED DURING COMPOSITING: Only use composite sampler for WET; Operators collect grabs for required composite samples. Y N NA NE b. PROPER PRESERVATION TECHNIQUES USED: Y N NA NE c. CONTAINERS AND SAMPLE HOLDING TIMES CONFORM TO 40 CFR 136: Y N NA NE 7. IF MONITORING IS PERFORMED MORE OFTEN THAN REQUIRED ARE RESULTS REPORTED ON THE DMR: Numerous QA/QC sampling/analyses conducted by permittee s certified lab; results provided. Y N NA NE SECTION E: FLOW MEASUREMENT PERMITTEE FLOW MEASUREMENT MEETS PERMIT REQUIREMENTS DETAILS: 1. PRIMARY FLOW MEASUREMENT DEVICE PROPERLY INSTALLED AND MAINTAINED: YES TYPE OF DEVICE: Three (3) rectangular weirs with end contractions (Chamber A and B 14 and 3 rd chamber ). S M U NA NE Y N NA NE 2. FLOW MEASURED AT EACH OUTFALL AS REQUIRED: Y N NA NE 3. SECONDARY INSTRUMENTS (TOTALIZERS, RECORDERS, ETC.) PROPERLY OPERATED AND MAINTAINED: Two (2) totalizers; pressure transducer connected to SCADA. Y N NA NE 4. CALIBRATION FREQUENCY ADEQUATE: Once/year; last calibrated Aug 11, Y N NA NE 5. RECORDS MAINTAINED OF CALIBRATION PROCEDURES: Y N NA NE 6. CALIBRATION CHECKS DONE TO ASSURE CONTINUED COMPLIANCE: Once/week Y N NA NE 7. FLOW ENTERING DEVICE WELL DISTRIBUTED ACROSS THE CHANNEL AND FREE OF TURBULENCE: Y N NA NE 8. FLOW MEASUREMENT EQUIPMENT ADEQUATE TO HANDLE EXPECTED RANGE OF FLOW RATES: Y N NA NE 9. HEAD MEASURED AT PROPER LOCATION: Y N NA NE SECTION F: LABORATORY PERMITTEE LABORATORY PROCEDURES MEET PERMIT REQUIREMENTS S M U NA NE DETAILS: Fort Smith Utility EQAL (certification expires Oct 1, 2015) conducts the following permit parameters besides WET: CBOD5, BOD5, TSS, NH3-N, FCB, NO3+NO2-N, and Total Phosphorus. 1. EPA APPROVED ANALYTICAL PROCEDURES USED (40 CFR FOR LIQUIDS, 503.8(B) FOR SLUDGES) : Y N NA NE 2. IF ALTERNATIVE ANALYTICAL PROCEDURES ARE USED, PROPER APPROVAL HAS BEEN OBTAINED: Y N NA NE 3. SATISFACTORY CALIBRATION AND MAINTENANCE OF INSTRUMENTS AND EQUIPMENT: See Section B, 1. above. Y N NA NE 4. QUALITY CONTROL PROCEDURES ADEQUATE: Y N NA NE 5. DUPLICATE SAMPLES ARE ANALYZED >10% OF THE TIME: Y N NA NE 6. SPIKED SAMPLES ARE ANALYZED >10% OF THE TIME: Y N NA NE 7. COMMERCIAL LABORATORY USED: Y N NA NE a. LAB NAME: Pace Analytical Services, Inc. b. LAB ADDRESS: 9608 Loiret Blvd., Lenexa, KS c. PARAMETERS PERFORMED: WET 8. BIOMONITORING PROCEDURES ADEQUATE: Y N NA NE a. PROPER ORGANISMS USED: Y N NA NE b. PROPER DILUTION SERIES FOLLOWED: Y N NA NE c. PROPER TEST METHODS AND DURATION: Y N NA NE d. RETESTS AND/OR TRE PERFORMED AS REQUIRED: Y N NA NE Inspection Report Page 5 of 23

6 SECTION G: EFFLUENT/RECEIVING WATERS OBSERVATIONS BASED ON VISUAL OBSERVATIONS ONLY S M U NA NE DETAILS: Observed at sample location and at outfall; Outfall 001 has gravity and force options based on Arkansas River levels (force used during flood conditions); force gate closed/locked during inspection. OUTFALL #: OIL SHEEN GREASE TURBIDITY VISIBLE FOAM FLOATING SOLIDS COLOR OTHER 001 NO NO NO NO NO CLEAR N/A SECTION H: SLUDGE DISPOSAL SLUDGE DISPOSAL MEETS PERMIT REQUIREMENTS S M U NA NE DETAILS: Class B sludge disposed at City of Fort Smith Sanitary Landfill (Class I; permit# 0267-S1-R1). 1. SLUDGE MANAGEMENT ADEQUATE TO MAINTAIN EFFLUENT QUALITY: S M U NA NE 2. SLUDGE RECORDS MAINTAINED AS REQUIRED BY 40 CFR 503: See 2014 Biosolids Report S M U NA NE 3. FOR LAND APPLIED SLUDGE, TYPE OF LAND APPLIED TO: (E.G., FOREST, AGRICULTURAL, PUBLIC CONTACT SITE): N/A SECTION I: SAMPLING INSPECTION PROCEDURES SAMPLE RESULTS WITHIN PERMIT REQUIREMENTS S M U NA NE DETAILS: 1. SAMPLES OBTAINED THIS INSPECTION: Y N NA NE 2. TYPE OF SAMPLE: GRAB: COMPOSITE: METHOD: FREQUENCY: 3. SAMPLES PRESERVED: Y N NA NE 4. FLOW PROPORTIONED SAMPLES OBTAINED: Y N NA NE 5. SAMPLE OBTAINED FROM FACILITY'S SAMPLING DEVICE: Y N NA NE 6. SAMPLE REPRESENTATIVE OF VOLUME AND NATURE OF DISCHARGE: Y N NA NE 7. SAMPLE SPLIT WITH PERMITTEE: Y N NA NE 8. CHAIN-OF-CUSTODY PROCEDURES EMPLOYED: Y N NA NE 9. SAMPLES COLLECTED IN ACCORDANCE WITH PERMIT: Y N NA NE SECTION J: STORM WATER POLLUTION PREVENTION PLAN STORM WATER MANAGEMENT MEETS PERMIT REQUIREMENTS S M U NA NE DETAILS: Inspected under No-Exposure ARR SWPPP UPDATED AS NEEDED: DATE OF LAST UPDATE: Y N NA NE 2. SITE MAP INCLUDING ALL DISCHARGES AND SURFACE WATERS: Y N NA NE 3. POLLUTION PREVENTION TEAM IDENTIFIED: Y N NA NE 4. POLLUTION PREVENTION TEAM PROPERLY TRAINED: Y N NA NE 5. LIST OF POTENTIAL POLLUTANT SOURCES: Y N NA NE 6. LIST OF POTENTIAL SOURCES AND PAST SPILLS AND LEAKS: Y N NA NE 7. ALL NON-STORM WATER DISCHARGES ARE AUTHORIZED: Y N NA NE 8. LIST OF STRUCTURAL BMPS: Y N NA NE 9. LIST OF NON-STRUCTURAL BMPS: Y N NA NE 10. BMPS PROPERLY OPERATED AND MAINTAINED: Y N NA NE 11. INSPECTIONS CONDUCTED AS REQUIRED: Y N NA NE Inspection Report Page 6 of 23

7 Chamber A Inspection Report: City of Fort Smith - "P" Street WWTP, AFIN: , Permit #: AR Date: Aug 19, 2015 Time: 0929 FLOW CALCULATION SHEET Head in Inches: Feet: 0.44 Type & Size of Primary Flow Measurement Device: 14 rectangular weir with end contractions and staff gauge Name & Model of Secondary Flow Measurement Device: Mercoid Series PBLT2 Submersible Level Transducer connected to SCADA (totalizer) Date of last Calibration of Secondary Flow Device: Aug 11, 2015 Recorded Flow at Date & Time Listed Above: MGD (Facility Flow Meter) Calculated Flow at Date & Time Listed Above: MGD Francis Equation (Flow is calculated using flow charts in: ISCO Open Channel Flow Measurement Handbook-5 th Edition) % Error = % Error = Recorded Value - Calculated Value Calculated Value X 100 X 100 % Error = X 100 % Error = X 100 % Error = 1.24 % Comments: Acceptable; within +/- 10% range. Francis Equation provided by permittee; ISCO only goes to 10 for rectangular weirs. Inspection Report Page 7 of 23

8 DMR Calculation Check Reporting Period: From To Year Month Day Year Month Day Parameter Checked: NH3-N (May Oct) Loading Concentration Mass (lbs/day) (mg/l) Monthly Avg. Monthly Avg. 7-day Avg. Reported Value: Calculated Value: Permit Value: If calculated value does not equal reported value, explain: Mass Monthly Avg = /31 = ; Concentration Monthly Avg = 61.49/31 = 1.98; Concentration 7-day Avg = 18.43/7 = 2.6 (highest). Values are the same (used May 4-10, 11-17, 18-24, and for 7-day Avg). Inspection Report Page 8 of 23

9 DMR Calculation Check Reporting Period: From To Year Month Day Year Month Day Parameter Checked: CBOD5 (May - Oct) Loading Concentration Mass (lbs/day) (mg/l) Monthly Avg. Monthly Avg. 7-day Avg Reported Value: Calculated Value: Permit Value: If calculated value does not equal reported value, explain: Mass Monthly Avg = /31 = ; Concentration Monthly Avg = /31 = 3.51; Concentration 7-day Avg = 42.64/7 = 6.1 (highest). Values are the same on the spreadsheet provided, but wrong values were entered on tabular DMR (used May 4-10, 11-17, 18-24, and for 7-day Avg). Inspection Report Page 9 of 23

10 DMR Calculation Check Reporting Period: From To Year Month Day Year Month Day Parameter Checked: TSS Loading Concentration Mass (lbs/day) (mg/l) Monthly Avg. Monthly Avg. 7-day Avg. Reported Value: Calculated Value: Permit Value: If calculated value does not equal reported value, explain: Mass Monthly Avg = /30 = 326.8; Concentration Monthly Avg = 178/30 = 5.93; Concentration 7-day Avg = 53/7 = 7.8 (highest). Values are the same (used Nov 2-8, 9-15, 16-22, and for 7-day Avg). Inspection Report Page 10 of 23

11 Water Division Photographic Evidence Sheet Location: City of Fort Smith - "P" Street WWTP Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 0936 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 1 Description: Enclosed bio-scrubber for odor control. Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 0937 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 2 Description: Bar screens for P Street gravity-fed influent. Inspection Report Page 11 of 23

12 Water Division Photographic Evidence Sheet Location: City of Fort Smith - "P" Street WWTP Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 0943 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 3 Description: Bar screens for Mill Creek Station #5 forced influent. Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 0947 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 4 Description: Degritter after bar screens; combined influent. Inspection Report Page 12 of 23

13 Water Division Photographic Evidence Sheet Location: City of Fort Smith - "P" Street WWTP Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 0950 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 5 Description: Two (2) bio-selector basins; low DO for selecting desirable microbes. Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 0958 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 6 Description: Contact basins for activated sludge. Inspection Report Page 13 of 23

14 Water Division Photographic Evidence Sheet Location: City of Fort Smith - "P" Street WWTP Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 1000 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 7 Description: MLSS basins; RAS basin photo right. Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 1005 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 8 Description: Diversion basin for secondary clarifiers; two (2) sets of clarifiers. Inspection Report Page 14 of 23

15 Water Division Photographic Evidence Sheet Location: City of Fort Smith - "P" Street WWTP Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 1007 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 9 Description: Activated sludge at center of secondary clarifier; ran in parallel. Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 1008 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 10 Description: Baffle and weir at outer edge of secondary clarifier. Inspection Report Page 15 of 23

16 Water Division Photographic Evidence Sheet Location: City of Fort Smith - "P" Street WWTP Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 1016 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 11 Description: Effluent after chlorination; clarity demonstrated with submerged platform. Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 1022 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 12 Description: Chamber A with 14 rectangular weir with end contractions; some post-aeration. Inspection Report Page 16 of 23

17 Water Division Photographic Evidence Sheet Location: City of Fort Smith - "P" Street WWTP Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 1026 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 13 Description: Chamber A s 14 rectangular weir with end contractions; effluent clear. Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 1025 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 14 Description: Sampling point after final treatment. Inspection Report Page 17 of 23

18 Water Division Photographic Evidence Sheet Location: City of Fort Smith - "P" Street WWTP Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 1024 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 15 Description: Pump house for force main to alternate Outfall 001; used during flood conditions. Photographer: Kerri McCabe Date: Aug 19, 2015 Time: 0846 Witness: Gerald Plank, Johnny Key, and Preston Cowan Photo #: 16 Description: Outfall 001 (gravity fed) and alternate Outfall 001 (force); alternate closed. Inspection Report Page 18 of 23

19 Water Division Photographic Evidence Sheet Location: City of Fort Smith - "P" Street WWTP Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 1035 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 17 Description: Chlorine storage area. Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 1040 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 18 Description: Chlorine feed lines. Inspection Report Page 19 of 23

20 Water Division Photographic Evidence Sheet Location: City of Fort Smith - "P" Street WWTP Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 1041 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 19 Description: Chlorine injector. Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 1047 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 20 Description: Wasted sludge belt press. Inspection Report Page 20 of 23

21 Water Division Photographic Evidence Sheet Location: City of Fort Smith - "P" Street WWTP Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 1053 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 21 Description: Trucks to haul Class B sludge to City s Class I landfill. Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 1101 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 22 Description: Launders/weirs at BFU; wet-weather partial treatment. Inspection Report Page 21 of 23

22 Water Division Photographic Evidence Sheet Location: City of Fort Smith - "P" Street WWTP Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 1104 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 23 Description: Flow EQ basin for BFU unit; partially treated wastewater routed back to headworks. Photographer: Kerri McCabe Date: Sept 3, 2015 Time: 1105 Witness: Gerald Plank, Johnny Key, Preston Cowan, and Alana Sullivan Photo #: 24 Description: Septic tank hauler offload station. Inspection Report Page 22 of 23

23 Figure 1. Google Earth image dated Oct 5, 2013 of the P Street WWTP. Inspection Report Page 23 of 23

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