2. According to Jerry Spillers, Operator, and Donnie Tedford, Operator, the plant overflows and plant flooding are due to the following conditions:

Transcription

1 June 14, 2010 Honorable Jan Throgmorton City of West Fork P.O. Box 339 West Fork, Arkansas RE: West Fork Wastewater Treatment Plant Inspections AFIN: NPDES Permit No.: AR Dear Mayor Throgmorton: On April 28, 2010, I conducted a compliance sampling inspection at the wastewater treatment plant, and on May 3, 2010, I performed a routine permit compliance evaluation inspection of the facility. These inspections were 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. These inspections revealed the following: Permit Compliance Evaluation Inspection: 1. Numerous overflows from the package plant and flooding of the individual treatment units have occurred as a result of equipment malfunction, equipment failure and lack of maintenance. Inherent in its construction design, overflows from the plant occur each time the plant floods. Review of plant log records revealed that at least 17 plant floods have occurred at the treatment facility since April, Note that only the last 12 months of plant log records were reviewed. According to these records, treatment plant flooding and plant overflows occurred on April 9, 2009, April 10, 2009, May 1, 2009, June 27, 2009, July 25, 2009, September 17, 2009, November 21, 2009, November 27, 2009, January 2, 2010, February 12, 2010, February 17, 2010, March 15, 2010, April 1, 2010, April 3, 2010, April 17, 2010, April 21, 2010 and April 22, These overflows were not reported to the Department. This is in violation of Part II.D.6 and Part III.5 of your permit. 2. According to Jerry Spillers, Operator, and Donnie Tedford, Operator, the plant overflows and plant flooding are due to the following conditions: a. Long-term influent flow control problems. The automatic 3-way valve located at the flow splitter box before the headworks has not worked automatically for many years. Influent can be directed from this valve to either the package plant during low flow conditions or to the equalization/holding (EQ) pond as necessary during high flow conditions. In order to prevent hydraulic overloads, plant overflows and flooding of the plant, the valve system is designed to automatically redirect some or

2 Mayor Throgmorton, City of West Fork POTW June 14, 2010 Page 2 all influent flow to the EQ pond when the primary aeration unit at the package plant nears capacity. Though according to your operators, the floats and switch at the primary aeration unit and the motor that served to actuate the 3-way valve have been inoperable for at least 15 years. Since the time these components became inoperable, the 3-way valve has been controlled manually; however, this method of operation has proven unsuccessful in preventing plant flooding and plant overflows. In addition, your operators stated that when the valve is manually throttled to allow for simultaneous flow to the plant and the EQ pond, the valve will in time reposition itself and cause increased proportional flow to the plant, resulting in plant flooding and overflows. According to your operators, the City has failed to repair or replace the floats, switch and motor that functioned to automatically control the 3 way valve. This is in violation of Part II.B.1.a of your permit, which states that the permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the terms of the permit. The floats, switch and motor are essential for proper operation and must be repaired or replaced so that the 3-way valve system operates automatically as designed. b. The pump and the mercury switch that triggers the pump located at the chlorine contact chamber wet well had malfunctioned or failed. It appears that the necessary repairs have been made. However, it is recommended that a backup or alternate pump be installed. Should the one existing pump or pump switch malfunction, plant flooding and plant overflows will recur. 3. Waste solids from plant overflows were present on the ground surrounding the package plant. These solids must be removed from the ground surface and properly disposed. 4. Bypass of the preliminary treatment units. Your permit requires that all flow from the EQ pond must run through the preliminary treatment units before entering the primary aeration unit. However, because an essential pump is out-of-service, influent from the EQ pond is diverted to the primary aeration unit without first flowing through the grit chamber, bar screen, and comminutor. This is in violation Part II.B.4.a of the permit. According to your permit, the permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but only if it also is for essential maintenance to assure efficient operation. According to Mr. Tedford, because the 3-way valve before the headworks no longer operates automatically (as described in Item 2.a above), approximately 90% of total influent flow is first directed to the EQ basin. 5. Failure to notify the Department of the bypass described in Item 4 above. This is in violation of Part II.B.4.b.1 of your permit. 6. The EQ pond holding capacity has been greatly reduced due to accumulation of solids. Solids must be removed from the basin to restore the basin to its original holding capacity. Receipts for the solids disposal must be submitted to the Department. NPDES Report Page 2

3 Mayor Throgmorton, City of West Fork POTW June 14, 2010 Page 3 7. Part IV.11 of your permit defines grab sample as an individual sample collected in less than 15 minutes in conjunction with an instantaneous flow measurement. Instantaneous flow is not being measured at the time that effluent grab samples are taken. 8. Instantaneous flow measurements must be used in effluent parameter loading calculations, and must be used to report monthly and 7-day flow averages. Currently, the totalizing meter is being used for loading calculations and flow reporting. This is in violation of Part 1.A of your permit. 9. Violations of Part II.C.2 of your permit: a. Although effluent samples are collected after final treatment at the dechlorination pond discharge point as required, flow is measured before the pond after the chlorine contact chamber. This is a repeat violation. As the flow rate into the pond can differ from the flow rate from the pond, monthly mass loading determinations may not reflect the actual loading on the receiving stream. Your permit requires that your flow measurement devices be installed at the monitoring point of the discharge. A letter addressed to you from the Water Division Enforcement Branch dated March 20, 2009, stated that the Department had determined that a primary flow measurement device must be constructed at the dechlorination pond discharge point, and that an engineer must be hired to supervise its installation. Mr. Robert White, Vice President, McClelland Consulting Engineers, Inc., stated in a letter to the Enforcement Branch dated April 7, 2009, that he had visited the plant and that his firm would be developing plans for the installation of an effluent flow meter on the dechlorination pond. To date, neither the primary flow measurement device nor the flow meter has been installed as required. b. Absence of a properly located head measuring point in the existing primary flow measurement device. This is a repeat violation. This must be installed upstream from the weir crest at a distance of three to four times the maximum head expected over the weir. Currently, head is being measured at the 60 degree v-notch from the base of the notch to the liquid level directly above the notch. Because drawdown occurs at this point, flow rate determination is inaccurate. In Mr. Bartholomew s inspection response letter to the Department dated January 7, 2009, he stated that this issue would be addressed. 10. The chain-of-custody records for your treated effluent samples do not indicate that ice was used for ammonia-nitrogen and total phosphorus preservation. Sulphuric acid was the only preservation method indicated for these parameters. This is a violation of Part II.C.8 of your permit. 11. Records for ph meter and dissolved oxygen meter calibrations are incomplete. Only the date and time of the calibrations and the name of the person performing the calibrations are documented. The results of the calibrations are not recorded. This is in violation of Part II.C.3 of your permit. NPDES Report Page 3

4 Mayor Throgmorton, City of West Fork POTW June 14, 2010 Page Five-day carbonaceous biochemical oxygen demand was reported on the November and December 2009 discharge monitoring report rather than five-day biochemical oxygen demand. Compliance Sampling Inspection: The analytical results for the effluent samples collected during the inspection revealed that fecal coliform bacteria were present at a concentration of 273 cfu/100 ml. This concentration exceeds the monthly average limit of 200 cfu/100 ml. Your permit requires a sampling frequency of once/month for this parameter. The sample analytical results are attached. The above items require your immediate attention. Please submit a written response to these findings to Cindy Garner, Water Division Enforcement Branch Manager. This response should be mailed to the address provided at the bottom of page 1 of this letter. This response should contain documentation describing the course of action taken to correct each item noted. Color photographs documenting your corrective action must be included with your response where applicable. This corrective action should be completed as soon as possible, and the written response is due by June 24, For additional information you may contact the enforcement branch by telephone at or by fax at Sincerely, John Fazio District 1 Inspector Water Division cc: Water Division Enforcement Branch Water Division Permits Branch NPDES Report Page 4

5 ADEQ Water NPDES Inspection AFIN: Permit #: AR Form Approved OMB No UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Washington, D.C NPDES Compliance Inspection Report Section A: National Data System Coding Transaction Code NPDES Yr/Mo/Day Inspec. Type Inspector Fac. Type 1 N A R S 19 S 20 1 Remarks Inspection Work Days Facility Evaluation Rating BI QA Reserved N 72 N Section B: Facility Data Name and Location of Facility Inspected (For industrial users discharging to POTW, also include POTW name and NPDES permit number) City of West Fork POTW 323 Northwood Ave. West Fork, Arkansas Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) Donnie Tedford, Operator, , Jerry Spillers, Operator, Name, Address of Responsible Official/Title/Phone and Fax Number Jan Throgmorton, Mayor City of West Fork P.O. Box 339 West Fork, Arkansas S M Permit Records/Reports U M Entry Time/Date 0905 / / Exit Time/Date 1025 / / Yes Contacted No Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated) Flow Measurement Self-Monitoring Program U S Operations & Maintenance Sludge Handling/Disposal S N Permit Effective Date 05/01/07 Permit Expiration Date 04/30/12 Other Facility Data WWTP: , Outfall 001: , Sampling Pollution Prevention U N N N Facility Site Review Compliance Schedules Pretreatment Multimedia S M N Effluent/Receiving Waters Laboratory Storm Water Other: Section D: Summary of Findings/Comments (Attach additional sheets if necessary) A compliance sampling inspection and a permit compliance evaluation inspection were performed on 04/28/10 and 05/03/10, respectively. Discharge Monitoring Reports were reviewed for November 2009 March No excursions of the permit limits were reported for those months. Numerous violations were noted during the inspections. See Pages 12 & 13 below for details. Name(s) and Signature(s) of Inspector(s) John Fazio Agency/Office/Telephone/Fax Date AR Dept. of Environmental Quality-Fayetteville June 8, , ext. 16; (fax) Signature of Reviewer Agency/Office/Phone and Fax Numbers Date NPDES Report Page 5

6 ADEQ Water NPDES Inspection AFIN: Permit #: AR SECTION A: PERMIT VERIFICATION PERMIT SATISFACTORILY ADDRESSES OBSERVATIONS DETAILS: S M U NA NE 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: 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 DETAILS: 1. ANALYTICAL RESULTS CONSISTENT WITH DATA REPORTED ON DMRS: Reported CBOD5 results rather than BOD5 results in 11/2009 and 12/2009. S M U NA NE Y N NA NE 2. SAMPLING AND ANALYSES DATA ADEQUATE AND INCLUDE: S M U NA NE a. DATES AND TIME(S) OF SAMPLING: Y N NA NE b. EXACT LOCATION(S) OF SAMPLING: 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: D.O. & ph calibration results not recorded. 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: D.O. & ph calibration results not recorded. 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: However, instantaneous flow not used in loading calculations and flow not measured after final treatment as required. Y N NA NE SECTION C: OPERATIONS AND MAINTENANCE TREATMENT FACILITY PROPERLY OPERATED AND MAINTAINED DETAILS: 1. TREATMENT UNITS PROPERLY OPERATED: Flow equalization issues are causing flooding of the plant and overflows at the plant. 2. TREATMENT UNITS PROPERLY MAINTAINED: Failure to repair/replace automatic 3-way valve components resulting in flooding of the plant and overflows at the plant. S M U NA NE S M U NA NE S M U NA NE 3. STANDBY POWER OR OTHER EQUIVALENT PROVIDED: Equalization/holding pond only S M U NA NE 4. ADEQUATE ALARM SYSTEM FOR POWER OR EQUIPMENT FAILURES AVAILABLE: RACO Chatterbox S M U NA NE 5. ALL NEEDED TREATMENT UNITS IN SERVICE: However, essential related appurtenances need repair/replacement. S M U NA NE 6. ADEQUATE NUMBER OF QUALIFIED OPERATORS PROVIDED: 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: Needs updating. Y N NA NE 10. PROCEDURES FOR EMERGENCY TREATMENT CONTROL ESTABLISHED: Y N NA NE 11. HAVE BYPASSES/OVERFLOWS OCCURRED AT THE PLANT OR IN THE COLLECTION SYSTEM IN THE LAST YEAR: Bypasses and overflows have occurred at the plant & overflows have occurred in the collection system Y N NA NE 12. IF SO, HAS THE REGULATORY AGENCY BEEN NOTIFIED: Agency notified of collection system overflows only Y N NA NE 13. HAS CORRECTIVE ACTION BEEN TAKEN TO PREVENT ADDITIONAL BYPASSES/OVERFLOWS: Corrective action for collection system overflows only 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 NPDES Report Page 6

7 ADEQ Water NPDES Inspection AFIN: Permit #: AR SECTION D: SAMPLING PERMITTEE SAMPLING MEETS PERMIT REQUIREMENTS DETAILS: S M U NA NE 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: Y N NA NE b. PROPER PRESERVATION TECHNIQUES USED: However, documentation needs improvement. 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: Y N NA NE SECTION E: FLOW MEASUREMENT PERMITTEE FLOW MEASUREMENT MEETS PERMIT REQUIREMENTS DETAILS: S M U NA NE 1. PRIMARY FLOW MEASUREMENT DEVICE PROPERLY INSTALLED AND MAINTAINED: TYPE OF DEVICE: 60 degree v-notch weir Y N NA NE 2. FLOW MEASURED AT EACH OUTFALL AS REQUIRED: Measured before dechlorination pond. Y N NA NE 3. SECONDARY INSTRUMENTS (TOTALIZERS, RECORDERS, ETC.) PROPERLY OPERATED AND MAINTAINED: Not properly Y N NA NE located for proper operation. 4. CALIBRATION FREQUENCY ADEQUATE:: 08/27/09 Y N NA NE 5. RECORDS MAINTAINED OF CALIBRATION PROCEDURES: Y N NA NE 6. CALIBRATION CHECKS DONE TO ASSURE CONTINUED COMPLIANCE: 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: Measuring staff placed directly into v-notch to measure head. Y N NA NE SECTION F: LABORATORY PERMITTEE LABORATORY PROCEDURES MEET PERMIT REQUIREMENTS DETAILS: S M U NA NE 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: D.O. & ph calibration data not documented. 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: Environmental Testing Group, Inc. b. LAB ADDRESS: 1702 E. Central Ave., Bentonville, AR c. PARAMETERS PERFORMED: CBOD5, BOD5, TSS, NH3-N, TP, FCB 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 NPDES Report Page 7

8 ADEQ Water NPDES Inspection AFIN: Permit #: AR SECTION G: EFFLUENT/RECEIVING WATERS OBSERVATIONS BASED ON VISUAL OBSERVATIONS ONLY S M U NA NE DETAILS: OUTFALL #: OIL SHEEN GREASE TURBIDITY VISIBLE FOAM FLOATING SOLIDS COLOR OTHER 001 None None None None None Light Green Algae SECTION H: SLUDGE DISPOSAL SLUDGE DISPOSAL MEETS PERMIT REQUIREMENTS DETAILS: S M U NA NE 1. SLUDGE MANAGEMENT ADEQUATE TO MAINTAIN EFFLUENT QUALITY: S M U NA NE 2. SLUDGE RECORDS MAINTAINED AS REQUIRED BY 40 CFR 503: S M U NA NE 3. FOR LAND APPLIED SLUDGE, TYPE OF LAND APPLIED TO: (E.G., FOREST, AGRICULTURAL, PUBLIC CONTACT SITE): SECTION I: SAMPLING INSPECTION PROCEDURES SAMPLE RESULTS WITHIN PERMIT REQUIREMENTS DETAILS: S M U NA NE 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: Bailed at outfall. Y N NA NE 6. SAMPLE REPRESENTATIVE OF VOLUME AND NATURE OF DISCHARGE: But no means to measure flow at outfall as required. 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: STORMWATER POLLUTION PREVENTION PLAN STORMWATER MANAGEMENT MEETS PERMIT REQUIREMENTS S M U NA NE DETAILS: 1. 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 NPDES Report Page 8

9 ADEQ Water NPDES Inspection AFIN: Permit #: AR FLOW CALCULATION SHEET Date: April 28, 2010 Time: 0955 Head in Inches: 6.9 Feet: 0.58 Type & Size of Primary Flow Measurement Device: 60 degree V-Notch Weir Name & Model of Secondary Flow Measurement Device: Inventron 9140 Date of last Calibration of Secondary Flow Device: 08/27/09 Recorded Flow at Date & Time Listed Above: gpm (Facility Flow Meter) Calculated Flow at Date & Time Listed Above: gpm (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 = 3.3 % Comments: NPDES Report Page 9

10 ADEQ Water NPDES Inspection AFIN: Permit #: AR DMR Calculation Check Reporting Period: From To Year Month Day Year Month Day Parameter Checked: BOD5 Loading Concentration Mass Monthly Mo. Avg. - lbs/day Mo. Avg. - mg/l 7-day Avg. - mg/l Reported Value: Calculated Value: Permit Value: If calculated value does not equal reported value, explain: than BOD5. City reported CBOD5 rather NPDES Report Page 10

11 ADEQ Water NPDES Inspection AFIN: Permit #: AR DMR Calculation Check Reporting Period: From To Year Month Day Year Month Day Parameter Checked: TP Loading Concentration Mass Monthly Mo. Avg. - lbs/day Mo. Avg. - mg/l 7-day Avg. - mg/l Reported Value: Calculated Value: Permit Value: Report Report Report If calculated value does not equal reported value, explain: NPDES Report Page 11

12 ADEQ Water NPDES Inspection AFIN: Permit #: AR NPDES Compliance Inspection Report Further Explanation * * From the letter issued to the City of West Fork by the ADEQ: Permit Compliance Evaluation Inspection: 1. Numerous overflows from the package plant and flooding of the individual treatment units have occurred as a result of equipment malfunction, equipment failure and lack of maintenance. Inherent in its construction design, overflows from the plant occur each time the plant floods. Review of plant log records revealed that at least 17 plant floods have occurred at the treatment facility since April, Note that only the last 12 months of plant log records were reviewed. According to these records, treatment plant flooding and plant overflows occurred on April 9, 2009, April 10, 2009, May 1, 2009, June 27, 2009, July 25, 2009, September 17, 2009, November 21, 2009, November 27, 2009, January 2, 2010, February 12, 2010, February 17, 2010, March 15, 2010, April 1, 2010, April 3, 2010, April 17, 2010, April 21, 2010 and April 22, These overflows were not reported to the Department. This is in violation of Part II.D.6 and Part III.5 of your permit. 2. According to Jerry Spillers, Operator, and Donnie Tedford, Operator, the plant overflows and plant flooding are due to the following conditions: a. Long-term influent flow control problems. The automatic 3-way valve located at the flow splitter box before the headworks has not worked automatically for many years. Influent can be directed from this valve to either the package plant during low flow conditions or to the equalization/holding (EQ) pond as necessary during high flow conditions. In order to prevent hydraulic overloads, plant overflows and flooding of the plant, the valve system is designed to automatically redirect some or all influent flow to the EQ pond when the primary aeration unit at the package plant nears capacity. Though according to your operators, the floats and switch at the primary aeration unit and the motor that served to actuate the 3-way valve have been inoperable for at least 15 years. Since the time these components became inoperable, the 3-way valve has been controlled manually; however, this method of operation has proven unsuccessful in preventing plant flooding and plant overflows. In addition, your operators stated that when the valve is manually throttled to allow for simultaneous flow to the plant and the EQ pond, the valve will in time reposition itself and cause increased proportional flow to the plant, resulting in plant flooding and overflows. According to your operators, the City has failed to repair or replace the floats, switch and motor that functioned to automatically control the 3 way valve. This is in violation of Part II.B.1.a of your permit, which states that the permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the terms of the permit. The floats, switch and motor are essential for proper operation and must be repaired or replaced so that the 3-way valve system operates automatically as designed. b. The pump and the mercury switch that triggers the pump located at the chlorine contact chamber wet well had malfunctioned or failed. It appears that the necessary repairs have been made. However, it is recommended that a backup or alternate pump be installed. Should the one existing pump or pump switch malfunction, plant flooding and plant overflows will recur. 3. Waste solids from plant overflows were present on the ground surrounding the package plant. These solids must be removed from the ground surface and properly disposed. 4. Bypass of the preliminary treatment units. Your permit requires that all flow from the EQ pond must run through the preliminary treatment units before entering the primary aeration unit. However, because an essential pump is out-of-service, influent from the EQ pond is diverted to the primary aeration unit without first flowing through the grit chamber, bar screen, and comminutor. This is in violation Part II.B.4.a of the permit. According to your permit, the permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but only if it also is for essential maintenance to assure efficient operation. According to Mr. Tedford, because the 3-way valve before the headworks no longer operates automatically (as described in Item 2.a above), approximately 90% of total influent flow is first directed to the EQ basin. NPDES Report Page 12

13 ADEQ Water NPDES Inspection AFIN: Permit #: AR Failure to notify the Department of the bypass described in Item 4 above. This is in violation of Part II.B.4.b.1 of your permit. 6. The EQ pond holding capacity has been greatly reduced due to accumulation of solids. Solids must be removed from the basin to restore the basin to its original holding capacity. Receipts for the solids disposal must be submitted to the Department. 7. Part IV.11 of your permit defines grab sample as an individual sample collected in less than 15 minutes in conjunction with an instantaneous flow measurement. Instantaneous flow is not being measured at the time that effluent grab samples are taken. 8. Instantaneous flow measurements must be used in effluent parameter loading calculations, and must be used to report monthly and 7-day flow averages. Currently, the totalizing meter is being used for loading calculations and flow reporting. This is in violation of Part 1.A of your permit. 9. Violations of Part II.C.2 of your permit: a. Although effluent samples are collected after final treatment at the dechlorination pond discharge point as required, flow is measured before the pond after the chlorine contact chamber. This is a repeat violation. As the flow rate into the pond can differ from the flow rate from the pond, monthly mass loading determinations may not reflect the actual loading on the receiving stream. Your permit requires that your flow measurement devices be installed at the monitoring point of the discharge. A letter addressed to you from the Water Division Enforcement Branch dated March 20, 2009, stated that the Department had determined that a primary flow measurement device must be constructed at the dechlorination pond discharge point, and that an engineer must be hired to supervise its installation. Mr. Robert White, Vice President, McClelland Consulting Engineers, Inc., stated in a letter to the Enforcement Branch dated April 7, 2009, that he had visited the plant and that his firm would be developing plans for the installation of an effluent flow meter on the dechlorination pond. To date, neither the primary flow measurement device nor the flow meter has been installed as required. b. Absence of a properly located head measuring point in the existing primary flow measurement device. This is a repeat violation. This must be installed upstream from the weir crest at a distance of three to four times the maximum head expected over the weir. Currently, head is being measured at the 60 degree v-notch from the base of the notch to the liquid level directly above the notch. Because drawdown occurs at this point, flow rate determination is inaccurate. In Mr. Bartholomew s inspection response letter to the Department dated January 7, 2009, he stated that this issue would be addressed. 10. The chain-of-custody records for your treated effluent samples do not indicate that ice was used for ammonianitrogen and total phosphorus preservation. Sulphuric acid was the only preservation method indicated for these parameters. This is a violation of Part II.C.8 of your permit. 11. Records for ph meter and dissolved oxygen meter calibrations are incomplete. Only the date and time of the calibrations and the name of the person performing the calibrations are documented. The results of the calibrations are not recorded. This is in violation of Part II.C.3 of your permit. 12. Five-day carbonaceous biochemical oxygen demand was reported on the November and December 2009 discharge monitoring report rather than five-day biochemical oxygen demand. Compliance Sampling Inspection: The analytical results for the effluent samples collected during the inspection revealed that fecal coliform bacteria were present at a concentration of 273 cfu/100 ml. This concentration exceeds the monthly average limit of 200 cfu/100 ml. Your permit requires a sampling frequency of once/month for this parameter. The sample analytical results are attached. NPDES Report Page 13

14 ADEQ Water NPDES Inspection AFIN: Permit #: AR Location: Photographer: Photo # West Fork WWTP John Fazio Water Division NPDES Photographic Evidence Sheet Witness: None 1 Of 17 Date: 04/28/10 Time: 0929 Description: Plant log documenting 8 plant floods/plant overflows. Log period: 02/10 to 04/10. Photographer: John Fazio Witness: Photo # 2 Of 17 Date: 04/28/10 Time: 0929 Description: None Plant log documenting 3 plant floods/plant overflows. Log period: 10/09 02/10. NPDES Report Page 14

15 ADEQ Water NPDES Inspection AFIN: Permit #: AR Location: Photographer: Photo # West Fork WWTP John Fazio Water Division NPDES Photographic Evidence Sheet Witness: None 3 Of 17 Date: 04/28/10 Time: 0929 Description: Plant log documenting 1 plant flood/plant overflow. Log period: 08/09 10/ 09. Photographer: John Fazio Witness: Photo # 4 Of 17 Date: 04/28/10 Time: 0929 Description: Plant log. Log period: 07/09 09/09. None NPDES Report Page 15

16 ADEQ Water NPDES Inspection AFIN: Permit #: AR Location: Photographer: Photo # West Fork WWTP John Fazio Water Division NPDES Photographic Evidence Sheet Witness: None 5 Of 17 Date: 04/28/10 Time: 0929 Description: Plant log documenting plant 2 floods/plant overflows. Log period: 06/09 07/09. Photographer: John Fazio Witness: Photo # 6 Of 17 Date: 04/28/10 Time: 0930 Description: None Plant log documenting 3 plant floods/plant overflows. Log period: 04/09 05/09. NPDES Report Page 16

17 ADEQ Water NPDES Inspection AFIN: Permit #: AR Location: Photographer: Photo # Description: West Fork WWTP John Fazio Water Division NPDES Photographic Evidence Sheet Witness: None 7 Of 17 Date: 04/28/10 Time: 0937 Flow splitter box with 3-way valve (foreground), and package plant (background). Grit channel in between. All influent flow directed to EQ pond (left of photo) at time of inspection. Photographer: John Fazio Witness: Photo # 8 Of 17 Date: 04/28/10 Time: 0937 Description: EQ/holding pond. None NPDES Report Page 17

18 ADEQ Water NPDES Inspection AFIN: Permit #: AR Location: Photographer: Photo # Description: West Fork WWTP John Fazio Water Division NPDES Photographic Evidence Sheet Witness: None 9 Of 17 Date: 04/28/10 Time: 0937 T-bar used to manually operate/throttle 3-way valve at splitter box. Valve no longer works automatically. Photographer: John Fazio Witness: Photo # 10 Of 17 Date: 04/28/10 Time: 0940 Description: None Waste solids from plant overflow on ground surrounding package plant. NPDES Report Page 18

19 ADEQ Water NPDES Inspection AFIN: Permit #: AR Location: Photographer: Photo # Description: West Fork WWTP John Fazio Water Division NPDES Photographic Evidence Sheet Witness: None 11 Of 17 Date: 04/28/10 Time: 0954 All flow from 3-way valve first to EQ pond at time of inspection. Flow from pond bypassing grit chamber (silver lid at upper right), bar screen & comminutor (red). Photographer: John Fazio Witness: Photo # 12 Of 17 Date: 04/28/10 Time: 0940 Description: None Flow from EQ pond entering aeration unit at top left, bypassing preliminary treatment units (left center and bottom right). NPDES Report Page 19

20 ADEQ Water NPDES Inspection AFIN: Permit #: AR Location: Photographer: Photo # Description: West Fork WWTP John Fazio Water Division NPDES Photographic Evidence Sheet Witness: None 13 Of 17 Date: 04/28/10 Time: 0948 Flow from EQ pond bypasses preliminary treatment units located on west side of aeration unit (left of photo) & enters aeration unit through valve on east side of unit. Flow rate controlled by T-bar. Photographer: John Fazio Witness: Photo # 14 Of 17 Date: 04/28/10 Time: 0955 Description: None Switch (foreground) and float system (not visible) that are to control automatic 3-way valve (photos 7 & 9) are inoperable. NPDES Report Page 20

21 ADEQ Water NPDES Inspection AFIN: Permit #: AR Location: Photographer: Photo # Description: West Fork WWTP John Fazio Water Division NPDES Photographic Evidence Sheet Witness: None 15 Of 17 Date: 04/28/10 Time: 0929 Overflow solids surrounding plant, grit channel and flow splitter box. Photographer: John Fazio Witness: Photo # 16 Of 17 Date: 04/28/10 Time: 0935 Description: None V-notch weir and secondary flow measurement device located at chlorine contact chamber rather than at Outfall 001. Also, there is no properly located head measuring point for primary device. NPDES Report Page 21

22 ADEQ Water NPDES Inspection AFIN: Permit #: AR Location: Photographer: Photo # Description: West Fork WWTP John Fazio Water Division NPDES Photographic Evidence Sheet Witness: None 17 Of 17 Date: 04/28/10 Time: 1003 Outfall 001 at dechlorination pond. No flow measurement devices. EQ basin and plant building in background. Photographer: Witness: Photo # Of Date: Time: Description: NPDES Report Page 22

23 ADEQ Water NPDES Inspection AFIN: Permit #: AR Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, AR CERTIFICATE OF ANALYSIS - Our Lab#: Sample ID: West Fork - Outfall 001 Sample Collect Date: 4/28/2010 Sample C Report Date: 5/17/2010 Type: Test Group Test Result Units Analysis Date MDL RDL BOD5 FC-MF FIELD NH3/PO4/NO3 TKN/TKP TSS/TDS 5-day biochemical oxygen demand mg/l 4/28/ Fecal coliform 273 cfu/100 4/28/ ml Dissolved oxygen 20.1 mg/l 4/28/2010 Field ph 8.57 SU 4/28/2010 Water temperature 14.8 C 4/28/2010 Orthophosphate as phosphorus 1.80 mg/l 4/28/ Nitrite+Nitrate-N mg/l 4/28/ Ammonia as nitrogen 11.3 mg/l 4/28/ Total Kjeldahl nitrogen as nitrogen 15.0 mg/l 4/29/ Total phosphorus as phosphorus 2.82 mg/l 4/29/ Total suspended solids 26.5 mg/l 4/28/ NPDES Report Page 23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38 December 14, 2010 Michael Bartholomew City of West Fork P.O. Box 339 West Fork, Arkansas RE: NPDES Permit No.: AR AFIN: Letter dated November 1, 2010 from Mr. Bartholomew to Ms. Garner Dear Mr. Bartholomew: This letter is to confirm the receipt of the letter dated November 1, 2010 concerning the corrective actions needed at the West Fork Wastewater Treatment Plant. The Department appreciates your proactive approach and cooperation by sending in the required information. Please continue to work with the Department and your engineering company, McClelland Engineering until the all corrective actions have been met. Thank you for your attention to this matter. Should you have any questions, feel free to contact me at or you may me at Sincerely, Cindy Garner Enforcement Branch Manager Water Division Enforcement Branch