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Inspection Report: USDA Forest Service-Cass WWTP, AFIN: 24-00040, Permit #: AR0020648

Inspection Report of 16

WATER DIVISION INSPECTION REPORT AFIN: 24-00040 PERMIT #: AR0020648 DATE: 10/13/2016

COUNTY: 24 Franklin PDS #: 093638 MEDIA: WN

GPS LAT: 35.686797 LONG: -93.817246 LOCATION: Entrance

FACILITY INFORMATION INSPECTION INFORMATION NAME:

USDA Forest Service-Cass WWTP LOCATION:

State Highway 23 North CITY:

Cass

FACILITY TYPE:

4 - Federal

INSPECTOR ID#:

71330 S - State

FACILITY EVALUATION RATING:

2 - Marginal

INSPECTION TYPE:

Compliance Evaluation

DATE(S): ENTRY TIME: EXIT TIME:

10/13/2016 10:15 13:00

PERMIT EFFECTIVE DATE:

6/1/2016

PERMIT EXPIRATION DATE:

10/31/2017

RESPONSIBLE OFFICIAL

NAME: / TITLE

Dan Crow / Center Director COMPANY: Cass Civilian Conservation Corp. MAILING ADDRESS:

21424 N. Highway 23 CITY, STATE, ZIP: Ozark AR 72949 PHONE & EXT: / FAX:

479-667-0321 / EMAIL:

[email protected]

FAYETTEVILLE SHALE RELATED: N

FAYETTEVILLE SHALE VIOLATIONS: N INSPECTION PARTICIPANTS

NAME/TITLE/PHONE/FAX/EMAIL/ETC.:

Charles McClain/Operator/479-667-0321/[email protected]

CONTACTED DURING INSPECTION: Yes

AREA EVALUATIONS (S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Applicable/Evaluated)

S PERMIT M FLOW MEASUREMENT ** STORMWATER M RECORDS/REPORTS S LABORATORY M FACILITY SITE REVIEW M OPERATION & MAINTENANCE S EFFLUENT/RECEIVING WATER M SELF-MONITORING PROGRAM S SAMPLING S SLUDGE HANDLING/DISPOSAL ** PRETREATMENT ** OTHER:

SUMMARY OF FINDINGS The following violations were noted during inspection:

1. The following are violations of Part III, Section B.1.A of the permit. Specifically, the following items must be addressed: a) The media in the sand filter beds is low (Photos 4-5). b) Cracks were observed in the walls of the sand filter beds (Photo 6). c) The facility does not have an Operations and Maintenance (O&M) manual for the treatment plant.

2. The facility does not have a staff gage installed nor any other means to conduct flow checks to ensure that the flowmeter is measuring flows within a standard deviation of +/-10% in accordance with permit requirements. This is a violation of Part III, Section C.2 of the permit.

3. The flowmeter is not being calibrated to verify results. Specifically, the flowmeter has not been calibrated by a licensed calibration technician since February of 2012. This is a violation of Part III, Section C.2 of the permit.

4. Analytical results are being incorrectly reported on DMRs. This is a violation of Part 1A and Part III, Section C.5 of the permit. Specifically, the following items must be addressed:



a) pH minimum values reported on DMRs were found to be an average pH recorded from process control samples collected at the activated sludge tank throughout the monitoring period. pH minimum/maximum values must be analyzed from results of samples collected at the effluent/outfall, and must reflect the lowest/highest single analysis results within the calendar month. No average calculation should be conducted to obtain the pH values. b) Loading is being incorrectly calculated. The contracted operator has been using the average flow for each three month quarter to calculate the load for the grab sample. Load must be calculated using the instantaneous and/or totalized daily flow measured during sample collection. Note: In addition to correctly reporting data and loading in the future, the facility will be required to submit corrected DMRs. The number of corrected DMRs to be submitted will be determined by ADEQ’s Enforcement Branch. Permittee must contact Sandra Farmer, ADEQ Enforcement Analyst, at (501) 682-7399 or [email protected] to determine DMR correction requirements.

5. DO meter calibration is not being documented. This is a violation of Part III, Section C.3 of the

permit.

6. pH analyses times are not being documented. Therefore, it must be assumed that pH is not being analyzed within the required holding times. This is a violation of Part III, Section C.8.C of the permit.

7. Sample collection location is not being documented on Chain of Custody (COC) forms. This is a violation of Part III, Section C.8.A of the permit.

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SECTION A: PERMIT VERIFICATION PERMIT SATISFACTORILY ADDRESSES OBSERVATIONS S M U NA NEDETAILS: 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 S M U NA NE

DETAILS: 1. ANALYTICAL RESULTS CONSISTENT WITH DATA REPORTED ON DMRS: Loading incorrectly calculated; loading

calculations are being conducted using a three month average flow as opposed to flow from the day of sampling. 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: Sample location is not being documented on COC. 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: Analysis time for pH is not being documented. 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 S M U NA NEDETAILS: 1. TREATMENT UNITS PROPERLY OPERATED: S M U NA NE 2. TREATMENT UNITS PROPERLY MAINTAINED: Sand filters are in disrepair; sand levels are low and containment walls are

cracked. S M U NA NE

3. STANDBY POWER OR OTHER EQUIVALENT PROVIDED: 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: 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: 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: 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



SECTION D: SAMPLING

PERMITTEE SAMPLING MEETS PERMIT REQUIREMENTS S M U NA NEDETAILS: 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 S M U NA NE

DETAILS: 1. PRIMARY FLOW MEASUREMENT DEVICE PROPERLY INSTALLED AND MAINTAINED: TYPE OF DEVICE: 90° V-notch weir 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: Last calibration 2/23/12; need staff gage for routine flow checks. Y N NA NE

5. RECORDS MAINTAINED OF CALIBRATION PROCEDURES: Y N NA NE 6. CALIBRATION CHECKS DONE TO ASSURE CONTINUED COMPLIANCE: No staff gage; operator is conducting calibration checks.

However, no device is present that is capable of measuring maximum deviation of less than +/-10%. 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: Head is not measured manually, but is instead measured with a static sonic head

attached to the meter. Operator will have a staff gage installed to properly identify location of manual head measurement. Y N NA NE

SECTION F: LABORATORY

PERMITTEE LABORATORY PROCEDURES MEET PERMIT REQUIREMENTS S M U NA NE

DETAILS: 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: Lab equipment has adequate

calibration. Flowmeter does not, but is addressed in the “Flow Measurement” section 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: Data Testing

b. LAB ADDRESS: Country Club, Fort Smith, Arkansas

c. PARAMETERS PERFORMED: O&G, FCB, NH3-N, CBOD, TSS

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



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

002 None None None None None clear --

SECTION H: SLUDGE DISPOSAL

SLUDGE DISPOSAL MEETS PERMIT REQUIREMENTS S M U NA NE

DETAILS: 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 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: 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



FLOW CALCULATION SHEET

Date: 10/13/2016 Time: 1111

Head in Inches: N/A Feet: N/A

Type & Size of Primary Flow Measurement Device: 90° V-Notch Weir

Name & Model of Secondary Flow Measurement Device: Hach sc200 Sonic Head Flowmeter

Date of last Calibration of Secondary Flow Device: 2/23/12

Recorded Flow at Date & Time Listed Above: 9 gpm (Facility Flow Meter)

Calculated Flow at Date & Time Listed Above: N/A (Flow is calculated using flow charts in: ISCO Open Channel Flow Measurement Handbook-5th Edition)

% Error = Recorded Value - Calculated Value

X 100

Calculated Value

% Error = N/A - N/A

X 100

N/A

% Error = N/A

X 100

N/A

% Error = N/A X 100

% Error = N/A %

Comments: Flow too low to conduct flow check during inspection. Also, no staff gage in place. Weir is constructed of concrete and is unique. It is likely 90°. However, a staff gage needs to be installed by a calibration specialist to ensure that it is installed in the correct location for this weir to read accurate head measurements.



DMR Calculation Check

Reporting Period: From 2016 04 01 To 2016 06 30

Year Month Day Year Month Day

Parameter Checked: BOD

Loading Concentration

Mass Monthly

Mo. Avg. - lbs/day Mo. Avg. - mg/l 7-day Avg. - mg/l

Reported Value: 0.125 <2 <2

Calculated Value: 0.14 <2 <2

Permit Value: 2.8 10 15

If calculated value does not equal reported value, explain: Sample collected on 6/10/2016

Contracted Operator is using the average flow for the three month quarter to calculate loading. As discussed during inspection, this is inaccurate. Load calculations should be conducted with flow from the date of sample collection. Sample for this DMR was collected on 6/10/2016. Recorded flow for 6/10/2016 was 6.0 gpm. Therefore, the calculated load for this DMR should have been as follows: 6.0gpm * 0.00144 = 0.00864 MGD (2.0 mg/l)(0.00864 MGD)(8.34) = 0.1441152 lbs/day = 0.14 lbs/day






Parameter Checked: pH


Mass Monthly

Mo. Avg. - lbs/day Monthly Minimum

S.U. Monthly Maximum

S.U.

Reported Value: N/A 7.07 7.41

Calculated Value: N/A 6.74 7.41

Permit Value: N/A 6.0 9.0

If calculated value does not equal reported value, explain: pH minimum value reported is the average pH recorded from process control sampling in the activated sludge tank. pH minimum/maximum reported must be the lowest/highest pH analyses results recorded at the effluent during the calendar month. pH minimum/maximum should not be an average result, but should be the lowest/highest analytical results of the sample set for the month.






Parameter Checked: NH3-N


Mass Monthly

Mo. Avg. - lbs/day Mo. Avg. - mg/l 7-day Avg. - mg/l

Reported Value: 0.0287 0.53 0.53

Calculated Value: 0.03 0.5 0.5

Permit Value: 1.4 5.0 7.5

If calculated value does not equal reported value, explain:

Contracted Operator is using the average flow for the three month quarter to calculate loading. As discussed during inspection, this is inaccurate. Load calculations should be conducted with flow from the date of sample collection. Sample for this DMR was collected on 3/18/2016. Recorded flow for 3/18/2016 was 5.0 gpm. Therefore, the calculated load for this DMR should have been as follows: 5.0gpm * 0.00144 = 0.0072 MGD (0.53 mg/l)(0.0072 MGD)(8.34) = 0.03182544 lbs/day = 0.03 lbs/day



Water Division Photographic Evidence Sheet

Location: USDA Forest Service-Cass WWTP Photographer: Dannielle Gray Date: 10/13/2016 Time: 1043 Witness: Charles McClain Photo #: 1 Description: Influent

Photographer: Dannielle Gray Date: 10/13/2016 Time: 1045 Witness: Charles McClain Photo #: 2 Description: Biological treatment (subsurface tank) with seven chambers.




Location: USDA Forest Service-Cass WWTP Photographer: Dannielle Gray Date: 10/13/2016 Time: 1050 Witness: Charles McClain Photo #: 3 Description: EQ holding tank

Photographer: Dannielle Gray Date: 10/13/2016 Time: 1051 Witness: Charles McClain Photo #: 4 Description: Overview of sand filter beds.




Location: USDA Forest Service-Cass WWTP Photographer: Dannielle Gray Date: 10/13/2016 Time: 1052 Witness: Charles McClain Photo #: 5 Description: Sand filter bed in use during inspection. Note sand levels are depleted in bed.

Photographer: Dannielle Gray Date: 10/13/2016 Time: 1113 Witness: Charles McClain Photo #: 6 Description: Example of cracks in filter bed walls.




Location: USDA Forest Service-Cass WWTP Photographer: Dannielle Gray Date: 10/13/2016 Time: 1111 Witness: Charles McClain Photo #: 7

Description: Effluent, sonic flowmeter head, and V-notch weir. Note no staff gage; weir is concrete construction.

Photographer: Dannielle Gray Date: 10/13/2016 Time: 1100 Witness: Charles McClain Photo #: 8 Description: Outfall 002 (35.686658, -93.815425).



Figure 1. Google Earth image dated March 4, 2016 showing facility overview with treatment components labeled and outfall location.

USDA, Forest Service Cass CCC Wastewater Plant 21424 N HWY 23 Ozark, AR 72949 NPDES Permit NO.: AR0020648 Operator: Charles McClain Phone: (479)667-0321 Email: [email protected]

RE: Response/action to the violations observed during a routine inspection that occurred on 10/13/2016.

1) A. The media in the sand filter beds is low.

Response/action: Sand was delivered and installed on 11/8/2016. See exhibit #1A.

B. Cracks were observed in the walls of the sand filter beds.

Response/action: The onsite carpentry instructor inspected the walls and found them to be structurally sound. The cracks were filled with a high performance polyurethane sealant to prevent further cracking and leakage. See exhibit #1B.

C. The facility does not have an operations and maintenance (O&M) manual.

Response/action: A written plan has been implemented. See exhibit #1C.

2) The facility does not have a staff gauge installed nor any other means to conduct flow checks to ensure that the flowmeter is measuring flows within a standard deviation of +/-10% in accordance with permit requirements.

Response/action: A staff gauge was installed by a licensed calibration technician, Dan Elser of Telemetry Services on 11/09/16. See exhibit #2.

3) The flowmeter is not being calibrated to verify results. Specifically, the flowmeter has not been calibrated by a licensed technician since February of 2012.

Response/action: The flowmeter was calibrated on 11/09/16 by a licensed calibration technician, Dan Elser of Telemetry Services. See exhibit #3

4) A. PH minimum values reported on DMRs were found to be an average pH recorded from a process control samples collected at the activated sludge tank throughout the monitoring period.

Response/action: The facility was using an outside contractor to prepare and sign DMRs while the onsite operator, Charles McClain obtained the required Class 3 license. The incorrect PH values reported was a communication error between the contractor and operator. The operator onsite has since obtained the class 3 and is now preparing and signing the DMRs. The problem has since been corrected.

B. Loading is being incorrectly calculated. The contracted operator has been using the average flow for each three month quarter to calculate the load for the grab sample. Load must be calculated using the instantaneous and/or totalized daily flow measured during the sample collection.

Response/action: The facility was using an outside contractor to prepare and sign DMRs while the onsite operator, Charles McClain obtained the required Class 3 license. The onsite operator has since obtained the class 3 and received signatory privileges for the facility. After discussing the error with inspector Dannielle Gray at the time of the inspection, the problem has since been corrected. Contact attempts have been made to Sandra Farmer- Enforcement Division to determine the DMR correction requirements for the facility. I am currently awaiting her response.

5) DO meter calibration is not being documented. This is a violation of part III, Section C.3 of the permit.

Response/action: A DO calibration log was drafted and the DO meter calibration is now being documented. See exhibit #5.

6) pH analyses times are not being documented. Therefore, it must be assumed that pH is not being analyzed within the required holding times.

Response/action: pH times are already being documented on the Chain of custody record used for the quarterly samples. pH times have also been added to the comment section of the facility’s daily data record. Exact time of pH measurement will now be documented every instance. See exhibit #6.

7) Sample collection location is not being documented on the Chain of Custody forms.

Response/action: The exact location (outfall 002, end of pipe into creek) will now be included on the facility’s Chain of Custody forms.

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