March 12, 2010 Mayor Carolyn McGee City of Dardanelle 116 N. 1st ...

March 12, 2010 

Mayor Carolyn McGee 

City of Dardanelle 

116 N. 1 st St. 

Dardanelle, AR 72834 

RE: Wastewater Treatment Plant Inspection 

AFIN: 75-00024 

NPDES Permit No.: AR0033421 

Dear Mayor McGee: 

On February 18, 2010, I performed a routine compliance inspection of the waste water treatment 

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. This inspection revealed 

the following violations: 

TSS and BOD5 grab samples are not being stored at < 6 C prior to compositing. This is a violation of Part 

III, Section C. 3 of the permit. The facility collects three grab samples, one each hour, for 3-hour composite 

sampling. Mr. Parks states that he was told by the inspector to store these samples in an incubator at 20 C 

during the previous inspection. Mr. Parks reported that Standard methods required cooling to < 4 C. I 

reported that 40 CFR Part 136 requires cooling to < 6 C. Mr. Parks reported that the facility would start 

storing samples at < 4 C. 

The above items require your immediate attention. Please submit a written response to these 

findings to the Water Division Enforcement Branch of this Department at the following address: 

Water Division Enforcement Section 

Arkansas Department of Environmental Quality 

5301 Northshore Drive 

North Little Rock, AR 72118-5317 

This response should contain detailed documentation describing the course of action taken to 

correct the items noted. This corrective action should be completed as soon as possible, and the 

written response is due by March 26, 2010. 

For additional information you may contact the enforcement branch by telephone at 501-682-0639 

or by fax at 501-682-0910.

Mayor Carolyn McGee, City of Dardanelle 

March 1, 2010 

Page 2 

If I can be of any assistance, please contact me at 479-968-7339 extension 14. 

Sincerely, 

Travis Harmon 

District 5 Field Inspector 

Water Division 

harmont@adeq.state.ar.us 

cc: 

Water Division Enforcement Branch 

Water Division Permits Branch 

NPDES R eport Page 2

ADEQ Water NPDES Inspection AFIN: 75-00024 Permit #: AR0033421 

Form Approved 

OMB No. 2040-0003 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Washington, D.C. 20460 

NPDES Compliance Inspection Report 

Section A: National Data System Coding 

Transaction Code NPDES Yr/Mo/Day Inspec. Type Inspector Fac. Type 

1 N 2 5 3 A R 0 0 3 3 4 2 1 11 12 1 0 0 2 1 8 17 18 C 19 S 20 1 

A F I N 7 5 --- 0 0 0 2 4 

Remarks 

Inspection Work Days Facility Evaluation Rating BI QA -------------------------------Reserved------------------------------ 

67 

0 0 

69 70 3 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) 

City of Dardanelle 

10532 Water Plant Rd 


Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) 

H. Dale Parks/ Chief Operator/ 479-229-4538 

Entry Time/Date 

09:30/ 2/18/2010 

Exit Time/Date 

1:30/ 2/18/2010 

Permit Effective Date 

10/1/2009 

Permit Expiration Date 

9/30/2014 

Other Facility Data 

Name, Address of Responsible Official/Title/Phone and Fax Number 

Carolyn McGee/ Mayor/ 479-229-3992 

116 N 1 st St 


Yesþ 

Contacted 

No¨ 

Section C: Areas Evaluated During Inspection 

(S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated) 

S Permit S Flow Measurement S Operations & Maintenance M Sampling 

S Records/Reports S Self-Monitoring Program S Sludge Handling/Disposal N Pollution Prevention 

S Facility Site Review N Compliance Schedules N Pretreatment N Multimedia 

N Effluent/Receiving Waters S Laboratory N Storm Water N Other: 

Section D: Summary of Findings/Comments (Attach additional sheets if necessary) 

1. TSS and BOD5 grab samples are not being stored at < 6 C prior to compositing. 

2. TSS monthly load rates were under-reported. by 5-9 lb/day in the DMRs. The under-reported values do not affect 

compliance status with TSS limits. The highest calculated monthly TSS load was 43 lb/day and the facility limit is 

245 lb/day. 

3. FCB monthly average was over-reported in 09/2009 due to rounding of log values up to 2. 

Name(s) and Signature(s) of Inspector(s) 

Travis Harmon 

Agency/Office/Telephone/Fax 

Arkansas Department of Environmental Quality / 

Russellville / 479-968-7339 x 14 / 479-968-7321 

Date 

3/2/2010 

Signature of Reviewer Agency/Office/Phone and Fax Numbers Date 



SECTION A: PERMIT VERIFICATION 

PERMIT SATISFACTORILY ADDRESSES OBSERVATIONS 

DETAILS: 

þS ¨M Ü ¨NA ¨NE 

1. CORRECT NAME AND MAILING ADDRESS OF PERMITTEE: þY ¨N ¨NA ¨NE 

2. NOTIFICATION GIVEN TO EPA/STATE OF NEW DIFFERENT OR INCREASED DISCHARGES: Ÿ ¨N þNA ¨NE 

3. NUMBER AND LOCATION OF DISCHARGE POINTS AS DESCRIBED IN PERMIT: þY ¨N ¨NA ¨NE 

4. ALL DISCHARGES ARE PERMITTED: þY ¨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: þY ¨N ¨NA ¨NE 

2. SAMPLING AND ANALYSES DATA ADEQUATE AND INCLUDE: ¨S ¨M Ü ¨NA ¨NE 

a. DATES AND TIME(S) OF SAMPLING: þY ¨N ¨NA ¨NE 

b. EXACT LOCATION(S) OF SAMPLING: þY ¨N ¨NA ¨NE 

c. NAME OF INDIVIDUAL PERFORMING SAMPLING: þY ¨N ¨NA ¨NE 

d. ANALYTICAL METHODS AND TECHNIQUES: þY ¨N ¨NA ¨NE 

e. RESULTS OF CALIBRATIONS: þY ¨N ¨NA ¨NE 

f. RESULTS OF ANALYSES: þY ¨N ¨NA ¨NE 

g. DATES AND TIMES OF ANALYSES: þY ¨N ¨NA ¨NE 

h. NAME OF PERSON(S) PERFORMING ANALYSES: þY ¨N ¨NA ¨NE 

3. LABORATORY EQUIPMENT CALIBRATION AND MAINTENANCE RECORDS ADEQUATE: þS ¨M Ü ¨NA ¨NE 

4. PLANT RECORDS INCLUDE SCHEDULES, DATES OF EQUIPMENT MAINTENANCE AND REPAIR: þS ¨M Ü ¨NA ¨NE 

5. EFFLUENT LOADINGS CALCULATED USING DAILY EFFLUENT FLOW AND DAILY ANALYTICAL DATA: þY ¨N ¨NA ¨NE 

SECTION C: OPERATIONS AND MAINTENANCE 

TREATMENT FACILITY PROPERLY OPERATED AND MAINTAINED 

DETAILS: 


1. TREATMENT UNITS PROPERLY OPERATED: þS ¨M Ü ¨NA ¨NE 

2. TREATMENT UNITS PROPERLY MAINTAINED: þS ¨M Ü ¨NA ¨NE 

3. STANDBY POW ER OR OTHER EQUIVALENT PROVIDED: Generator on-site. þS ¨M Ü ¨NA ¨NE 

4. ADEQUATE ALARM SYSTEM FOR POW ER OR EQUIPMENT FAILURES AVAILABLE: Guardtronic calls after 30 min power failure. þS ¨M Ü ¨NA ¨NE 

5. ALL NEEDED TREATMENT UNITS IN SERVICE: þS ¨M Ü ¨NA ¨NE 

6. ADEQUATE NUMBER OF QUALIFIED OPERATORS PROVIDED: Mr. Dale Parks (III) and Blake Robinson (I). þS ¨M Ü ¨NA ¨NE 

7. SPARE PARTS AND SUPPLIES INVENTORY MAINTAINED: þS ¨M Ü ¨NA ¨NE 

8. OPERATION AND MAINTENANCE MANUAL AVAILABLE: þY ¨N ¨NA ¨NE 

9. STANDARD OPERATING PROCEDURES AND SCHEDULES ESTABLISHED: þY ¨N ¨NA ¨NE 

10. PROCEDURES FOR EMERGENCY TREATMENT CONTROL ESTABLISHED: þY ¨N ¨NA ¨NE 

11. HAVE BYPASSES/OVERFLOWS OCCURRED AT THE PLANT OR IN THE COLLECTION SYSTEM IN THE LAST YEAR: Bar screen 

became clogged and overflowed. Some material on ground during inspection. Facility could not clean yet due to ice/snow cover. þY ¨N ¨NA ¨NE 

Facility now has written instructions in place for staff to check and/or clear bar screen. 

12. IF SO, HAS THE REGULATORY AGENCY BEEN NOTIFIED: Was contained at plant. Ÿ ¨N þNA ¨NE 

13. HAS CORRECTIVE ACTION BEEN TAKEN TO PREVENT ADDITIONAL BYPASSES/OVERFLOWS: þY ¨N ¨NA ¨NE 

14. HAVE ANY HYDRAULIC OVERLOADS OCCURRED AT THE TREATMENT PLANT: þY ¨N ¨NA ¨NE 

15. IF SO, DID PERMIT VIOLATIONS OCCUR AS A RESULT: Ÿ þN ¨NA ¨NE 



SECTION D: SAMPLING 

PERMITTEE SAMPLING MEETS PERMIT REQUIREMENTS 

DETAILS: 

¨S þM Ü ¨NA ¨NE 

1. SAMPLES TAKEN AT SITE(S) SPECIFIED IN PERMIT: þY ¨N ¨NA ¨NE 

2. LOCATIONS ADEQUATE FOR REPRESENTATIVE SAMPLES: þY ¨N ¨NA ¨NE 

3. FLOW PROPORTIONED SAMPLES OBTAINED W HEN REQUIRED BY PERMIT: Facility reads flow each hour during compositing 

sampling and includes a representative proportion of each hourly sample in the composite sample. 

þY ¨N ¨NA ¨NE 

4. SAMPLING AND ANALYSES COMPLETED ON PARAMETERS SPECIFIED IN PERMIT: þY ¨N ¨NA ¨NE 

5. SAMPLING AND ANALYSES PERFORMED AT FREQUENCY SPECIFIED IN PERMIT: þY ¨N ¨NA ¨NE 

6. SAMPLE COLLECTION PROCEDURES ADEQUATE: þY ¨N ¨NA ¨NE 

a. SAMPLES REFRIGERATED DURING COMPOSITING: 3 hr composite samples are placed in incubator at 20 C prior to compositing. 

Mr. Parks reports being told to store these samples at 20 C during the previous inspection and was doing so. 

Ÿ þN ¨NA ¨NE 

b. PROPER PRESERVATION TECHNIQUES USED: Samples are analyzed or processed on-site within 15 minutes of collection. 

Excludes 3 hr composite samples (BOD and TSS). 


c. CONTAINERS AND SAMPLE HOLDING TIMES CONFORM TO 40 CFR 136: þY ¨N ¨NA ¨NE 

7. IF MONITORING IS PERFORMED MORE OFTEN THAN REQUIRED ARE RESULTS REPORTED ON THE DMR: Ÿ ¨N þNA ¨NE 

SECTION E: FLOW MEASUREMENT 

PERMITTEE FLOW MEASUREMENT MEETS PERMIT REQUIREMENTS 

DETAILS: 


1. PRIMARY FLOW MEASUREMENT DEVICE PROPERLY INSTALLED AND MAINTAINED: TYPE OF DEVICE: 9 in Parshall flume þY ¨N ¨NA ¨NE 

2. FLOW MEASURED AT EACH OUTFALL AS REQUIRED: þY ¨N ¨NA ¨NE 

3. SECONDARY INSTRUMENTS (TOTALIZERS, RECORDERS, ETC.) PROPERLY OPERATED AND MAINTAINED: þY ¨N ¨NA ¨NE 

4. CALIBRATION FREQUENCY ADEQUATE: þY ¨N ¨NA ¨NE 

5. RECORDS MAINTAINED OF CALIBRATION PROCEDURES: þY ¨N ¨NA ¨NE 

6. CALIBRATION CHECKS DONE TO ASSURE CONTINUED COMPLIANCE: 2 or 3 times each year (not including annual calibration). þY ¨N ¨NA ¨NE 

7. FLOW ENTERING DEVICE WELL DISTRIBUTED ACROSS THE CHANN EL AND FREE OF TURBULENCE: þY ¨N ¨NA ¨NE 

8. FLOW MEASUREMENT EQUIPMENT ADEQUATE TO HANDLE EXPECTED RANGE OF FLOW RATES: þY ¨N ¨NA ¨NE 

9. HEAD MEASURED AT PROPER LOCATION: þY ¨N ¨NA ¨NE 

SECTION F: LABORATORY 

PERMITTEE LABORATORY PROCEDURES MEET PERMIT REQUIREMENTS 

DETAILS: 

1. EPA APPROVED ANALYTICAL PROCEDURES USED (40 CFR 136.3 FOR LIQUIDS, 503.8(B) FOR SLUDGES) : Using Standard 

methods. 



2. IF ALTERNATIVE ANALYTICAL PROCEDURES ARE USED, PROPER APPROVAL HAS BEEN OBTAINED: Ÿ ¨N þNA ¨NE 

3. SATISFACTORY CALIBRATION AND MAINTENANCE OF INSTRUMENTS AND EQUIPMENT: þY ¨N ¨NA ¨NE 

4. QUALITY CONTROL PROCEDURES ADEQUATE: þY ¨N ¨NA ¨NE 

5. DUPLICATE SAMPLES ARE ANALYZED >10% OF THE TIME: 100% of time. þY ¨N ¨NA ¨NE 

6. SPIKED SAMPLES ARE ANALYZED >10% OF THE TIME: Blanks analyzed. Ÿ þN ¨NA ¨NE 

7. COMMERCIAL LABORATORY USED: N/A Ÿ þN ¨NA ¨NE 

a. LAB NAME: 

b. LAB ADDRESS: 

c. PARAMETERS PERFORMED: 

8. BIOMONITORING PROCEDURES ADEQUATE: Ÿ ¨N þNA ¨NE 

a. PROPER ORGANISMS USED: Ÿ ¨N þNA ¨NE 

b. PROPER DILUTION SERIES FOLLOWED: Ÿ ¨N þNA ¨NE 

c. PROPER TEST METHODS AND DURAT ION: Ÿ ¨N þNA ¨NE 

d. RETESTS AND/OR TRE PERFORMED AS REQUIRED: Ÿ ¨N þNA ¨NE 



SECTION G: EFFLUENT/RECEIVING WATERS OBSERVATIONS 

BASED ON VISUAL OBSERVATIONS ONLY 

¨S ¨M Ü ¨NA þNE 

DETAILS: Arkansas River. Could not view effluent as outfall was submerged during the inspection. I did not view 

any foam, solids, or turbidity as effluent left the flume. 

OUTFALL #: OIL SHEEN GREASE TURBIDITY VISIBLE FOAM FLOATING SOLIDS COLOR OTHER 

001 

SECTION H: SLUDGE DISPOSAL 

SLUDGE DISPOSAL MEETS PERMIT REQUIREMENTS 


DETAILS: Dried in drying beds and disposed of at Yell Co. landfill. 

1. SLUDGE MANAGEMENT ADEQUATE TO MAINTAIN EFFLUENT QUALITY: þS ¨M Ü ¨NA ¨NE 

2. SLUDGE RECORDS MAINTAINED AS REQUIRED BY 40 CFR 503: ¨S ¨M Ü þNA ¨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 Ü þNA ¨NE 

DETAILS: No samples collected. 

1. SAMPLES OBTAINED THIS INSPECTION: Ÿ ¨N þNA ¨NE 

2. TYPE OF SAMPLE: ¨GRAB: ¨COMPOSITE: METHOD: FREQUENCY: 

3. SAMPLES PRESERVED: Ÿ ¨N þNA ¨NE 

4. FLOW PROPORTIONED SAMPLES OBTAINED: Ÿ ¨N þNA ¨NE 

5. SAMPLE OBTAINED FROM FACILITY'S SAMPLING DEVICE: Ÿ ¨N þNA ¨NE 

6. SAMPLE REPRESENTATIVE OF VOLUME AND NATURE OF DISCHARG E: Ÿ ¨N þNA ¨NE 

7. SAMPLE SPLIT WITH PERMITTEE: Ÿ ¨N þNA ¨NE 

8. CHAIN-OF-CUSTODY PROCEDURES EMPLOYED: Ÿ ¨N þNA ¨NE 

9. SAMPLES COLLECTED IN ACCORDANCE WITH PERMIT: Ÿ ¨N þNA ¨NE 

SECTION J: STORM WATER POLLUTION PREVENTION PLAN 

STORM WATER MANAGEMENT MEETS PERMIT REQUIREMENTS 

¨S ¨M Ü þNA ¨NE 

DETAILS: 

1. SWPPP UPDATED AS NEEDED: DATE OF LAST UPDATE: Ÿ ¨N þNA ¨NE 

2. SITE MAP INCLUDING ALL DISCHARGES AND SURFACE WATERS: Ÿ ¨N þNA ¨NE 

3. POLLUTION PREVENTION TEAM IDENTIFIED: Ÿ ¨N þNA ¨NE 

4. POLLUTION PREVENTION TEAM PROPERLY TRAINED: Ÿ ¨N þNA ¨NE 

5. LIST OF POTENTIAL POLLUTANT SOURCES: Ÿ ¨N þNA ¨NE 

6. LIST OF POTENTIAL SOURCES AND PAST SPILLS AND LEAKS: Ÿ ¨N þNA ¨NE 

7. ALL NON-STORM WATER DISCHARGES ARE AUTHORIZED: Ÿ ¨N þNA ¨NE 

8. LIST OF STRUCTURAL BMPS: Ÿ ¨N þNA ¨NE 

9. LIST OF NON-STRUCTURAL BMPS: Ÿ ¨N þNA ¨NE 

10. BMPS PROPERLY OPERATED AND MAINTAINED: Ÿ ¨N þNA ¨NE 

11. INSPECTIONS CONDUCT ED AS REQUIRED: Ÿ ¨N þNA ¨NE 



FLOW CALCULATION SHEET 

Date: 2/18/2010 Time: 11:35 

Head in Inches: 5 3/4 Feet: 0.4792 

Type & Size of Primary Flow Measurement Device: 

9 inch Parshall flume. 

Name & Model of Secondary Flow Measurement Device: 

Milltronics Hydroranger Totalizer. 

Date of last Calibration of Secondary Flow Device: 

1/8/2010. 

Recorded Flow at Date & Time Listed Above: 462 GPM (Facility Flow Meter) 

Calculated Flow at Date & Time Listed Above: 

448.3 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 

462 - 448.3 

448.3 

X 100 

X 100 

% Error = 

13.7 

448.3 

X 100 

% Error = 0.0305598929 X 100 

% Error = 3.05598929 % 3.1 % 

Comments: Within 10%. 



DMR Calculation Check 

Reporting Period: From 09 09 01 To 09 09 30 

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: 31 7.3 10 

Calculated Value: 36 7.3 10 

Permit Value: 245 30 45 

If calculated value does not equal reported value, explain: 

Results: (9/30/09, .552 MGD, 8 mg/l), (9/23/09, 0.632 MGD, 4 mg/l), (9/9/09, 0.608 MGD, 10 mg/l). 







TSS 

Loading 

Concentration 

Mass 

Monthly 


Reported Value: 37.5 9.3 10 

Calculated Value: 43 9.3 12* 



Results: (10/7/09, 0.552 MGD, 10 mg/l), (10/22/09, 0.560 MGD, 12 mg/l), (10/28/09, 0.592 MGD, 6 mg/l). 

*No more than one sample collected in a week. Results were 10 mg/l on 10/7, 12 mg/l on 10/22, and 6 mg/l on 

10/28. 







TSS 

Loading 

Concentration 

Mass 

Monthly 


Reported Value: 27 8 9 

Calculated Value: 36 8 10 



Results: (11/12/09, 0.536 MGD, 6 mg/l), (11/20/09, 0.560 MGD, 10 mg/l), (11/25/09, 0.544 MGD, 8 mg/l). 







FCB 

Loading 

Concentration 

Mass 

Monthly 


Reported Value: 100 100 

Calculated Value: 83* 98* 

Permit Value: 200 400 

If calculated value does not equal reported value, explain: Rounding of logs. 

Results (9/9/09 72, 121, 82, 130), (9/23/09 54, 91), (9/30/09 67, 103). 

* Facility is rounding log values to 2. For example, for 54 colonies, the log of 54 is 1.732. The 

facility rounds 1.732 to 2 and averages before taking the anti-log. 

2 + 2 = 4, average 2, and anti-log of 2 is 100 vs. 

1.732 + 1.959 = 3.691, average 1.845, and anti-log of 1.845 is 69.9. 



NPDES Compliance Inspection Report 

Further Explanation 

The facility collects three grab samples, one each hour, for a 3 hour composite sample. TSS and BOD5 grab samples 

are not being stored at < 6 C prior to compositing. Mr. Parks states that he was told by the inspector to store these 

samples in an incubator at 20 C during the previous inspection. 

I reviewed DMR and analysis data for 09/2009, 10/2009, and 11/2009. I identified some differences in the TSS monthly 

load rate reported in the DMRs and my calculated monthly TSS load rates. TSS monthly load rates were under-reported 

by 5-9 lb/day in the DMRs. The under-reported values do not affect compliance status with TSS limits. The highest calculated monthly 

TSS load was 43 lb/day and the facility limit is 245 lb/day. ADEQ inspector Amy Beck visited the facility with me on 

2/26/2010. We went through the process of calculating values for the DMR. Mr. Parks requested copies which show 

how monthly load rates should be calculated. 

FCB colonies monthly average appear to be over-reported on the 09/2009 DMR due to rounding. The facility is 

correctly calculating the monthly average; however, the log values were rounded to 2 prior to determining the average 

of the log values. For example (for 9/23) sampling the logs of 54 and 91 were both rounded to 2 with an average of 2 

instead of log of 54 = 1.7 + log of 91 = 1.9 = 3.6 then averaged to 1.8. The anti-log of 2 = 100 colonies while the antilog 

of 1.8 = 63 colonies. For the month of September 2009, I determined a monthly average of 83 colonies while a 

monthly average of 100 colonies was reported in the DMR. 

NPDES R eport Page 12


Location: 

Water Division NPDES Photographic Evidence Sheet 

Photos of records obtained from the facility. 

Photographer: Travis Harmon Witness: None 

Photo # 1 Of 3 Date: 2/26/2010 Time: 15:43 

Description: 

Flow and monthly load (TSS) calculations. 220 on the sheet is equivalent of 22,000 

gallons/hour as the totalizer reads gallons x 100. 



Description: 

Facility FCB geometric mean calculations. Shows log values rounded to 2 prior to 

averaging and calculating anti-log. 



Location: 

Water Division NPDES Photographic Evidence Sheet 

City of Dardanelle POTW. 



Description: 

Nocardia bacteria generating foam in clarifier. Has been an on-going issue at the facility 

but does not appear to be impacting the facilitys ability to meet effluent limits.

March 12, 2010 Mayor Carolyn McGee City of Dardanelle 116 N. 1st ...

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