2. Patrick Manor Pump Station a. 1 pump had no metal guard around the belt drive.

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1 February 25, 2011 Mr. William Daniel, Manager Water and Sewer City of Pocahontas rd Street Pocahontas, AR RE: Sanitary Sewer Overflow Inspection AFIN: NPDES Permit No.: AR Dear Mr. Daniel: On January 19, 2011, I performed an inspection of the waste water collection system in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. This inspection revealed the following violations: 1. Waterloo Pump Station a. Wiring for both pumps was uncovered. 2. Patrick Manor Pump Station a. 1 pump had no metal guard around the belt drive. 3. KPOC Pump Station a. Slight accumulation of grease in the wet well. This did not interfere with the operation of the pumps. Only 7 pump stations out of 21 total pump stations had provisions for generators or emergency transfer pumps in case of emergencies. All of the items stated above are violations of Part III, Section B, Item 1, a, of the permit. The above items require your immediate attention. Please submit a written response to these findings to Cindy Garner, Water Division Enforcement Branch Manager, of this Department. This response should be mailed to the address below. 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 documentation (i.e. pictures) is due by March 7, For additional information you may contact the Enforcement Branch by telephone at or by fax at

2 William Daniel, Manager Water and Sewer City of Pocahontas February 25, 2011 Page 2 If I can be of any assistance, please contact me at Sincerely, Mike Kennedy District 11 Field Inspector Water Division cc: Water Division Enforcement Branch Water Division Permits Branch NPDES Report Page 2

3 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 V 19 S 20 1 A F I N Inspection Work Days Remarks Facility Evaluation Rating BI QA Reserved N 71 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) Pocahontas Wastewater Treatment Plant 2 miles down Swan Cove Road off Highway #67 (Randolph County) Entry Time/Date 1300 / Exit Time/Date 1600 / Permit Effective Date April 1, 2009 Permit Expiration Date March 31, 2014 Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) William Daniel / Manager Water & Sewer / Office Cell Name, Address of Responsible Official/Title/Phone and Fax Number William Daniel / Manager Water & Sewer / Office Cell Highway #67 South Pocahontas, AR Yes Contacted No Other Facility Data N36º15 31 W-90º58 17 Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated) N Permit N Flow Measurement U Operations & Maintenance N Sampling N Records/Reports N Self-Monitoring Program N Sludge Handling/Disposal N Pollution Prevention N Facility Site Review N Compliance Schedules N Pretreatment N Multimedia N Effluent/Receiving Waters N Laboratory N Storm Water N Other: Section D: Summary of Findings/Comments (Attach additional sheets if necessary) Some violations were noted during the inspection. Refer to attached letter and inspection report for a listing and explanation of findings. Name(s) and Signature(s) of Inspector(s) Mike Kennedy Agency/Office/Telephone/Fax AR Dept. of Environmental Quality-Batesville office / Fax Date January 31, 2011 Signature of Reviewer Agency/Office/Phone and Fax Numbers Date NPDES Report Page 3

4 ADEQ Water NPDES Inspection AFIN: Permit #: AR COLLECTION SYSTEM INSPECTION AND OVERALL RATING PROVIDE A BRIEF DESCRIPTION OF THE COLLECTION SYSTEM: Pocahontas WWTP has gravity collection systems with a series of lift stations and force mains pumping to gravity lines finally to settlement ponds. Pocahontas has 240,464 feet of gravity sewer line (6 to 24 inch lines) and approx. 66,760 feet of force main lines (4 to 10 inches in diameter). POPULATION SERVED/NUMBER OF RESIDENTIAL AND COMMERCIAL CONNECTIONS: Approx. 6,500 people Approx. 3,100 Residential connections and Approx. 446 Commercial connections. FEET OF SEWER SYSTEM: Approx. 240,464 feet of gravity sewer and Approx. 66,760 feet of force mains AGE OF SYSTEM: From Approx. 100 years old to newer DOES THE SYSTEM EXPERIENCE PROBLEMS DURING DRY OR WET WEATHER (EXPLAIN): Inflow and Infiltration IS THERE A SYSTEM IN PLACE FOR REPORTING SSOS TO ADEQ (DESCRIBE): All staff report SSOs to supervisor who reports SSOs to ADEQ within 24 hours or each occurrence. ARE ALL SSOs REPORTED REGARDLESS OF SIZE: HAVE SSOs REACHED WATERS OF THE STATE (LIST DATE AND LOCATION OF EACH): Not in the previous 12 months PUMP STATIONS NUMBER OF PUMP STATIONS IN SYSTEM: 21 NUMBER WITH BACKUP POWER: 7 HOW OFTEN ARE PUMP STATIONS INSPECTED/MONITORED: All pump stations are inspected daily. ARE MAINTENANCE RECORDS AND/OR OPERATOR LOGS KEPT: Minimal records ADEQUATE INVENTORY OF SPARE PARTS: Yes TYPE OF REMOTE ELECTRONIC MONITORING USED (I.E. SCADA OR AUTO DIALERS): None BRIEF SUMMARY OF EMERGENCY PROCEDURES: Inventory of spare parts kept in case of breakdowns. Pocahontas WWTP has 2 Backup Generators in case of power outage. The facility has 21 pump stations, but only 7 of the stations have provisions for generators or emergency transfer pumps in case of emergencies. NUMBER OF PUMP STATIONS VISITED DURING INSPECTION (SEE ATTACHED CHECKLISTS FOR EACH): 3 SATELLITE SYSTEMS DOES THE COLLECTION SYSTEM RECEIVE FLOW FROM SATELLITE SYSTEMS: No TYPE(S) OF WASTE WATER RECEIVED: RESIDENTIAL COMMERCIAL INDUSTRIAL OTHER: N/A BRIEFLY DESCRIBE THE SATELLITE SYSTEM: N/A ANY KNOWN PROBLEMS WITH SATELLITE SYSTEM: N/A NAME, ADDRESS AND PHONE NUMBER OF PERSON RESPONSIBLE FOR SATELLITE SYSTEM: N/A NPDES Report Page 4

5 ADEQ Water NPDES Inspection AFIN: Permit #: AR PUMP STATION VISIT (COMPLETE A SEPARATE CHECKLIST FOR EACH PUMP STATION VISITED) GENERAL INFORMATION AND OVERALL EVALUATION NAME AND/OR LOCATION OF PUMP STATION: Waterloo Pump Station #1 located at Waterloo Street and Highway #304 TYPE(S) OF WASTE WATER RECEIVED: RESIDENTIAL COMMERCIAL INDUSTRIAL OTHER: NUMBER OF PUMPS: 2 NUMBER OPERATIONAL: 2 NUMBER AND SIZE OF PUMPS APPEARS ADEQUATE: EVIDENCE OF RECENT OVERFLOWS OR HIGH LEVELS: GENERAL OPERATION AND MAINTENANCE CLEAN AND WELL MAINTAINED WITH MINIMAL STORAGE OF UNRELATED EQUIPMENT: GATES/DOORS/HATCHES/LIDS/ETC. LOCKED TO PREVENT UNAUTHORIZED ACCESS AND/OR TAMPERING: WET WELLS, SUMPS AND PITS ADEQUATELY COVERED, GRATED OR OTHERWISE PROTECTED: ELECTRICAL CONTROLS COVERS CONDUIT AND EQUIPMENT PROPERLY INSTALLED AND MAINTAINED: Wiring for both pumps not covered with cover boxes on each pump. This did not interfere with the operation of the pump station. GUARDS AND SHIELDS IN PLACE AROUND MOVING EQUIPMENT (BELTS, PULLEYS, DRIVESHAFTS, ETC.): ADEQUATE VENTILATION TO PREVENT EXCESSIVE CONDENSATION AND/OR GASES AND FUMES: ADEQUATE LIGHTING FOR ROUTINE INSPECTION/MAINTENANCE: SEALS, VALVES AND PACKING ADEQUATELY MAINTAINED TO PREVENT LEAKS: MINIMAL ACCUMULATION OF GREASE AND SOLIDS IN WET WELLS: BACKUP POWER AND ALARMS PROVISIONS FOR GENERATOR AND/OR EMERGENCY TRANSFER PUMP: Yes Emergency Generators on hand for emergencies AUDIBLE/VISUAL ALARM WITH EMERGENCY CONTACT INFORMATION POSTED: SCADA SYSTEM (LIST PARAMETERS MONITORED): NPDES Report Page 5

6 ADEQ Water NPDES Inspection AFIN: Permit #: AR PUMP STATION VISIT (COMPLETE A SEPARATE CHECKLIST FOR EACH PUMP STATION VISITED) GENERAL INFORMATION AND OVERALL EVALUATION NAME AND/OR LOCATION OF PUMP STATION: Patrick Manor Pump Station #2 located on Pace Road TYPE(S) OF WASTE WATER RECEIVED: RESIDENTIAL COMMERCIAL INDUSTRIAL OTHER: NUMBER OF PUMPS: 2 NUMBER OPERATIONAL: 2 NUMBER AND SIZE OF PUMPS APPEARS ADEQUATE: EVIDENCE OF RECENT OVERFLOWS OR HIGH LEVELS: GENERAL OPERATION AND MAINTENANCE CLEAN AND WELL MAINTAINED WITH MINIMAL STORAGE OF UNRELATED EQUIPMENT: GATES/DOORS/HATCHES/LIDS/ETC. LOCKED TO PREVENT UNAUTHORIZED ACCESS AND/OR TAMPERING: WET WELLS, SUMPS AND PITS ADEQUATELY COVERED, GRATED OR OTHERWISE PROTECTED: ELECTRICAL CONTROLS COVERS CONDUIT AND EQUIPMENT PROPERLY INSTALLED AND MAINTAINED: GUARDS AND SHIELDS IN PLACE AROUND MOVING EQUIPMENT (BELTS, PULLEYS, DRIVESHAFTS, ETC.) : 1 pump did not have a metal guard around the belt. ADEQUATE VENTILATION TO PREVENT EXCESSIVE CONDENSATION AND/OR GASES AND FUMES: ADEQUATE LIGHTING FOR ROUTINE INSPECTION/MAINTENANCE: SEALS, VALVES AND PACKING ADEQUATELY MAINTAINED TO PREVENT LEAKS: MINIMAL ACCUMULATION OF GREASE AND SOLIDS IN WET WELLS: BACKUP POWER AND ALARMS PROVISIONS FOR GENERATOR AND/OR EMERGENCY TRANSFER PUMP: No Emergency Generators on hand for emergencies AUDIBLE/VISUAL ALARM WITH EMERGENCY CONTACT INFORMATION POSTED: SCADA SYSTEM (LIST PARAMETERS MONITORED): NPDES Report Page 6

7 ADEQ Water NPDES Inspection AFIN: Permit #: AR PUMP STATION VISIT (COMPLETE A SEPARATE CHECKLIST FOR EACH PUMP STATION VISITED) GENERAL INFORMATION AND OVERALL EVALUATION NAME AND/OR LOCATION OF PUMP STATION: KPOC Pump Station #3 located on Highway #67 across highway from KPOC radio station TYPE(S) OF WASTE WATER RECEIVED: RESIDENTIAL COMMERCIAL INDUSTRIAL OTHER: NUMBER OF PUMPS: 2 NUMBER AND SIZE OF PUMPS APPEARS ADEQUATE: EVIDENCE OF RECENT OVERFLOWS OR HIGH LEVELS: NUMBER OPERATIONAL: 2 (Submersible) GENERAL OPERATION AND MAINTENANCE CLEAN AND WELL MAINTAINED WITH MINIMAL STORAGE OF UNRELATED EQUIPMENT: GATES/DOORS/HATCHES/LIDS/ETC. LOCKED TO PREVENT UNAUTHORIZED ACCESS AND/OR TAMPERING: WET WELLS, SUMPS AND PITS ADEQUATELY COVERED, GRATED OR OTHERWISE PROTECTED: ELECTRICAL CONTROLS COVERS CONDUIT AND EQUIPMENT PROPERLY INSTALLED AND MAINTAINED: GUARDS AND SHIELDS IN PLACE AROUND MOVING EQUIPMENT (BELTS, PULLEYS, DRIVESHAFTS, ETC.) : Submersible pumps No guards needed ADEQUATE VENTILATION TO PREVENT EXCESSIVE CONDENSATION AND/OR GASES AND FUMES: ADEQUATE LIGHTING FOR ROUTINE INSPECTION/MAINTENANCE: SEALS, VALVES AND PACKING ADEQUATELY MAINTAINED TO PREVENT LEAKS: MINIMAL ACCUMULATION OF GREASE AND SOLIDS IN WET WELLS: Slight accumulation of grease in wet well. Clean out of the wet well is part of periodic maintenance. This did not interfere with the operation of the pumps. BACKUP POWER AND ALARMS PROVISIONS FOR GENERATOR AND/OR EMERGENCY TRANSFER PUMP: Yes Emergency Generators on hand for emergencies AUDIBLE/VISUAL ALARM WITH EMERGENCY CONTACT INFORMATION POSTED: SCADA SYSTEM (LIST PARAMETERS MONITORED): NPDES Report Page 7

8 ADEQ Water NPDES Inspection AFIN: Permit #: AR Water Division NPDES Photographic Evidence Sheet Location: Waterloo Pump Station on Highway #304 in Pocahontas. (Randolph County) Photographer: Mike Kennedy Witness: William Daniel Photo # 1 Of 4 Date: Time: 1420 Description: A view of top of Waterloo Pump Station. Photographer: Mike Kennedy Witness: William Daniel Photo # 2 Of 4 Date: Time: 1429 A view inside of the Pump Station. Note exposed wires on one of 2 pumps at the station. Both Description: pumps had exposed wires. (Randolph County) NPDES Report Page 8

9 ADEQ Water NPDES Inspection AFIN: Permit #: AR Water Division NPDES Photographic Evidence Sheet Location: Patrick Manor Pump Station on Race Road in Pocahontas. Photographer: Mike Kennedy Witness: William Daniel Photo # 3 Of 4 Date: Time: 1436 Description: Patrick Manor Pump Station on Pace Road in Pocahontas. (Randolph County) Photographer: Mike Kennedy Witness: William Daniel Photo # 4 Of 4 Date: Time: 1455 Description: KPOC Pump Station on Highway #67 in Pocahontas. (Randolph County) NPDES Report Page 9

10 August 8, 2011 Certified: Honorable Frank Bigger City of Pocahontas P.O. Box 896 Pocahontas, AR Re: NPDES Permit No.: AR , AFIN: , Failure to Respond Dear Mayor Bigger: Two letters dated February 25, 2011 were sent to the City of Pocahontas. The letters outlined the findings of a January 18, 2011 investigation alleging that raw sewage had overflowed from a manhole, and a January 19, 2011 inspection of the city s wastewater collection system. Both letters requested that a written response be submitted to the Department by March 7, To date, no response has been received at the Department. Please submit a response by August 22, Copies of the inspection reports have been included for your convenience. Please be advised that the findings of the above referenced inspections are of an extremely serious nature and have prompted the Department to consider enforcement action in the form of a Consent Administrative Order which would include a civil penalty. Once submitted, the response will be reviewed in order to determine if the Department will proceed with the enforcement action. Thank you for your attention to this matter. Should you have any questions, feel free to contact me at or you may me at anderson@adeq.state.ar.us. Sincerely, Alan Anderson Enforcement Analyst Water Division Enforcement Branch

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