May 26, 2009 Dallas Ray Goad, Superintendent City Of Bradford 308 B, W. Walnut St Bradford, AR 72020 AFIN: 73-00072 NPDES Permit No: AR0050911, Routine Compliance Inspection Dear Mr. Goad: On May 20, 2009, Gene Little, Enforcement Administrator and I performed a routine compliance inspection of the above referenced facility in response to a complaint. The complaint alleged that the pumping station at 415 Main Street had failed during the recent heavy rains resulting in wastewater being discharged from 3 manholes in the area. 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. The inspection revealed the following: 1. Manholes on Main Street had recently overflowed due to inflow and infiltration and a substandard wastewater pumping station. The discharge of the wastewater from these manholes is a violation of the Arkansas Water and Air Pollution Control Act (A.C.A. 8-4-217(b)(1)(C). In addition, the City of Bradford failed to notify the Department of the overflow within 24-hours as required by Part III, D.6 of the permit. Finally, the clean up of the wastewater spill was inadequate. Wastewater solids were noted on the ground adjacent to the pumping station and there was no evidence that the ground was disinfected. You will need to develop a formal clean-up response plan for collection system overflows. 2. The wastewater pumping station at 415 Main Street is substandard and requires upgrading. Specifically, the station does not have an adequate alarm system, the pumps are incapable of handling the anticipated range of flow, and the facility is not secure. I was able to access the pump station wet well without the assistance of City employees because the station is not fenced and the lids were not locked. This is a violation of Part III, B.1.a of the permit which requires the proper operations and maintenance of all systems of treatment and control at all times. 3. The lagoon levees and rock reed filters are overgrown and in need of maintenance. In addition, minor problems with erosion were noted on the plant grounds. This is a violation of Part III, B.1.a of the permit which requires the proper operations and maintenance of all systems of treatment and control at all times. It should be noted the City had a mower on site to begin cutting and the delay in cutting was due to excessive rainfall in the area the past few weeks. 4. The check of the Discharge Monitoring Report (DMR) for January 2008 reveals an unexplainable difference between what was reported on the DMR and what was calculated by the Department (see NPDES Pages 6 and 7). Please have your laboratory recheck the DMR calculations and if they believe the DMR was calculated properly, you must submit information that supports this position. Otherwise, a corrected DMR needs to be submitted. 5. The above reference permit in Part I, B contains a schedule for the evaluation of the levels of sludge in the treatment facility. This schedule required a plan on how the city will evaluate the sludge levels to be submitted within a 180 days of the effective date of the permit and that you must start executing the plan within one year of the effective date of the permit. The plan was due on January 28, 2009, however, I can find no record of where the plan was submitted and approved by the Department. Your response to this inspection should include the plan required by your permit and a statement has to whether or not you will meet the deadline for implementing the plan.
Dallas Ray Goad, Superintendent, City of Bradford May 20, 2009 Page 2 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 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 necessary documentation (i.e. pictures) is due by June 4, 2009. If I can be any assistance, please contact me at benson@adeq.state.ar.us or 501-683-0827. Sincerely, Dennis Benson District 9 Field Inspector Water Division cc: Water Division Enforcement Branch Water Division Permits Branch
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Washington, D.C. 20460 NPDES Compliance Inspection Report Section A: National Data System Coding Form Approved OMB No. 2040-0003 Approval Expires 7-31-85 Transaction Code NPDES Yr/Mo/Day Inspec. Type Inspector Fac. Type 1 N 2 5 3 A R 0 0 5 0 9 1 1 11 12 0 9 0 5 1 9 17 18 C 19 S 20 1 Remarks Inspection Work Days Facility Evaluation Rating BI QA -------------------------------Reserved------------------------------ 67 69 70 2 71 N 72 N 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For industrial users discharging to POTW, also include POTW name and NPDES permit number) Bradford, City Of Take Highway 67 north from NLR to the City of Bradford. Take the Highway 87 exit and go west. This is Main Street. The pumping station at 415 Main Street will be on the right. The wastewater plant is located off of SE Front road, which is a left turn off of Main Street. Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) Dallas Ray Goad, Superintendent, 501-344-2252 Entry Time/Date 10:20 am on 05/19/09 Exit Time/Date 2:00 pm on 05/19/09 Permit Effective Date 8/1/2008 Permit Expiration Date 7/31/2013 Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Dallas Ray Goad, Superintendent Bradford, City Of 308 B, W. Walnut St Bradford, AR 72020 (501) 344-2252 Contacted Yes No Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated) S Permit S Flow Measurement U Operations & Maintenance N Sampling U Records/Reports M Self-Monitoring Program N Sludge Handling/Disposal N Pollution Prevention U Facility Site Review U Compliance Schedules N Pretreatment N Multimedia S Effluent/Receiving Waters S Laboratory N Storm Water N Other: Section D: Summary of Findings/Comments (Attach additional sheets if necessary) See NPDES Page 8 for details. Name(s) and Signature(s) of Inspector(s) Dennis Benson Agency/Office/Telephone/Fax Date AR Dept. of Environmental Quality- 05/19/09 (501) 683-0827/(501) 682-0910 (Fax) Signature of Reviewer Agency/Office/Phone and Fax Numbers Date NPDES Page 1
SECTION A: PERMIT VERIFICATION PERMIT SATISFACTORILY ADDRESSES OBSERVATIONS 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 Unsure of how January 2008 DMR was calculated. 1. ANALYTICAL RESULTS CONSISTENT WITH DATA REPORTED ON DMRS: Y N NA NE 2. SAMPLING AND ANALYSES DATA ADEQUATE AND INCLUDE: 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: 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: 4. PLANT RECORDS INCLUDE SCHEDULES, DATES OF EQUIPMENT MAINTENANCE AND REPAIR: 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 1. TREATMENT UNITS PROPERLY OPERATED: 2. TREATMENT UNITS PROPERLY MAINTAINED: levees need mowing, city has been delayed due to excessive rainfall 3. STANDBY POWER OR OTHER EQUIVALENT PROVIDED: 4. ADEQUATE ALARM SYSTEM FOR POWER OR EQUIPMENT FAILURES AVAILABLE: 5. ALL NEEDED TREATMENT UNITS IN SERVICE: 6. ADEQUATE NUMBER OF QUALIFIED OPERATORS PROVIDED: City needs Class II, permit allows until 2010 to obtain 7. SPARE PARTS AND SUPPLIES INVENTORY MAINTAINED: 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: 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: Y N NA NE 13. HAS CORRECTIVE ACTION BEEN TAKEN TO PREVENT ADDITIONAL BYPASSES/OVERFLOWS: city plans upgrade with Clayton Engineering. 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 Page 2
SECTION D: SAMPLING PERMITTEE SAMPLING MEETS PERMIT REQUIREMENTS 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: 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 1. PRIMARY FLOW MEASUREMENT DEVICE PROPERLY INSTALLED AND MAINTAINED: TYPE OF DEVICE: 4 Parshall flume 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: Y N NA NE 4. CALIBRATION FREQUENCY ADEQUATE: 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: (no flow) 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 1. EPA APPROVED ANALYTICAL PROCEDURES USED (40 CFR 136.3 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: 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: Arkansas Testing b. LAB ADDRESS: 204 E. Lincoln, Searcy, AR 72143 c. PARAMETERS PERFORMED: CBOD, TSS, FCB, Cl, DO, ammonia 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 Page 3
SECTION G: EFFLUENT/RECEIVING WATERS OBSERVATIONS BASED ON VISUAL OBSERVATIONS ONLY OUTFALL #: OIL SHEEN GREASE TURBIDITY VISIBLE FOAM FLOATING SOLIDS COLOR OTHER 001 none none none none none none SECTION H: SLUDGE DISPOSAL SLUDGE DISPOSAL MEETS PERMIT REQUIREMENTS 1. SLUDGE MANAGEMENT ADEQUATE TO MAINTAIN EFFLUENT QUALITY: 2. SLUDGE RECORDS MAINTAINED AS REQUIRED BY 40 CFR 503: 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 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 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 Page 4
FLOW CALCULATION SHEET Not discharging when inspecting flume Date: 05/19/09 Time: 11:00 am Head in Inches: Feet: Type & Size of Primary Flow Measurement Device: 4 parshall flume Name & Model of Secondary Flow Measurement Device: Honeywell 10801 Recorded Flow at Date & Time Listed Above: (Facility Flow Meter) Calculated Flow at Date & Time Listed Above: (Flow is calculated using flow charts in: ISCO Open Channel Flow Measurement Handbook-5 th Edition) % Error = Recorded Value - Calculated Value Calculated Value X 100 - % Error = X 100 % Error = X 100 % Error = X 100 % Error = % Comments: NPDES Page 5
DMR Calculation Check DMR from old permit AR0022136 Reporting Period: From 08 01 01 To 08 01 31 Year Month Day Year Month Day Parameter Checked: TSS Loading Concentration Mass Monthly Mo. Avg. - lbs/day Mo. Avg. - mg/l 7-day Avg. - mg/l Reported Value: 3.4 3 8 Calculated Value: 3.1 3.7 8 Permit Value: 33 20 30 If calculated value does not equal reported value, explain: Unsure of reason for error. Permittee reported a flow on 1/29 of 86 gpm, however, chain of custody indicated a flow of 244 gpm when sample was collected on 1/29. I was unable to get a consistent answer using either flow or average of flow on that date. NPDES Page 6
DMR Calculation Check Reporting Period: From 08 01 01 To 08 01 31 Year Month Day Year Month Day Parameter Checked: Nitrogen, Ammonia Loading Concentration Mass Monthly Mo. Avg. - lbs/day Mo. Avg. - mg/l 7-day Avg. - mg/l Reported Value: 5.77 4.9 6.8 Calculated Value: 5.2 4.4 6.8 Permit Value: 20 12 18 If calculated value does not equal reported value, explain: Unsure of reason for error. Permittee reported a flow on 1/29 of 86 gpm, however, chain of custody indicated a flow of 244 gpm when sample was collected on 1/29. I was unable to get a consistent answer using either flow or average of flow on that date. NPDES Page 7
NPDES Compliance Inspection Report Further Explanation 1. Manholes on Main Street had recently overflowed due to inflow and infiltration and a substandard wastewater pumping station. The discharge of the wastewater from these manholes is a violation of the Arkansas Water and Air Pollution Control Act (A.C.A. 8-4-217(b)(1)(C). In addition, the City of Bradford failed to notify the Department of the overflow within 24-hours as required by Part III, D.6 of the permit. Finally, the clean up of the wastewater spill was inadequate. Wastewater solids were noted on the ground adjacent to the pumping station and there was no evidence that the ground was disinfected. You will need to develop a formal clean-up response plan for collection system overflows. 2. The wastewater pumping station at 415 Main Street is substandard and requires upgrading. Specifically, the station does not have an adequate alarm system, the pumps are incapable of handling the anticipated range of flow, and the facility is not secure. I was able to access the pump station wet well without the assistance of City employees because the station is not fenced and the lids were not locked. This is a violation of Part III, B.1.a of the permit which requires the proper operations and maintenance of all systems of treatment and control at all times. 3. The lagoon levees and rock reed filters are overgrown and in need of maintenance. In addition, minor problems with erosion were noted on the plant grounds. This is a violation of Part III, B.1.a of the permit which requires the proper operations and maintenance of all systems of treatment and control at all times. It should be noted the City had a mower on site to begin cutting and the delay in cutting was due to excessive rainfall in the area the past few weeks. 4. The check of the Discharge Monitoring Report (DMR) for January 2008 reveals an unexplainable difference between what was reported on the DMR and what was calculated by the Department (see NPDES Pages 6 and 7). Please have your laboratory recheck the DMR calculations and if they believe the DMR was calculated properly, you must submit information that supports this position. Otherwise, a corrected DMR needs to be submitted. 5. The above reference permit in Part I, B contains a schedule for the evaluation of the levels of sludge in the treatment facility. This schedule required a plan on how the city will evaluate the sludge levels to be submitted within a 180 days of the effective date of the permit and that you must start executing the plan within one year of the effective date of the permit. The plan was due on January 28, 2009, however, I can find no record of where the plan was submitted and approved by the Department. Your response to this inspection should include the plan required by your permit and a statement has to whether or not you will meet the deadline for implementing the plan. NPDES Page 8
Photographic Evidence Sheet Location: Bradford, City Of Photographer: Dennis Benson Witness: Gene Little Photo # 1 Of 6 Date: 05/19/09 Time: 10:18 am Description: Wastewater solids at the base of wastewater pumping station. Photographer: Dennis Benson Witness: Gene Little Photo # 2 Of 6 Date: 05/19/09 Time: 10:20 am Description: Pumping station is not secure, no alarm system. Photo Page 1
Photographic Evidence Sheet Location: Bradford, City Of Photographer: Dennis Benson Witness: Gene Little Photo # 3 Of 6 Date: 05/19/09 Time: 10:38 am Description: Overgrown rock reed filter system Photographer: Dennis Benson Witness: Gene Little Photo # 4 Of 6 Date: 05/19/09 Time: 10:43 am Description: Erosion problem on plant grounds Photo Page 2
Photographic Evidence Sheet Location: Bradford, City Of Photographer: Dennis Benson Witness: Gene Little Photo # 5 Of 6 Date: 05/19/09 Time: 11:08 am Description: Tall grass on levee. Photographer: Dennis Benson Witness: Gene Little Photo # 6 Of 6 Date: 05/19/09 Time: 10:39 am Description: Overgrown rock reed filter. Photo Page 3
June 22, 2009 Mr. Dallas R. Goad, Supt. City of Bradford 308 B, W. Walnut St. Bradford, AR 72020 RE: Wastewater Treatment Plant, Permit Number AR0050911, AFIN 73-00072 Inspection of May 20, 2009. Dear Mr. Goad: On May 20, 2009, a compliance inspection was conducted at the site located at S.E. Front Rd., Bradford, AR. A copy of the inspection report is included with this letter. Notice of the inspection was mailed to you on May 26, 2009. A response was requested by June 4, 2009. As of the date of this letter, a response has not been received. Please submit a response to the inspection findings, and any mitigating circumstances you wish the Department to consider prior to initiating formal enforcement actions, to the Department, by July 6, 2009. Thank you for your attention to this matter. Should you have any questions, feel free to contact me at 501-682-0636 or you may e-mail me at boycej@adeq.state.ar.us. Sincerely, James D. Boyce Enforcement Administrator Water Division Enforcement Section