Document 6R0gaVyw2n8yz52Rnxjy1ymXm

ELECTRONIC MAIL CONFIRMATION OF EMAIL RECEIPT REQUESTED Marco Goings Mayor Town of Crenshaw 600 Broad Street Crenshaw, Mississippi 38621 townofcrenshaw@gmail.com Dear Marco Goings: The U.S. Environmental Protection Agency, Region 4 conducted a Compliance Evaluation Inspection (CEI) on the Town of Crenshaw Publicly Owned Treatment Works (POTW) on August 13, 2024. The objective of the CEI was to assess the Town's compliance with the Clean Water Act and the National Pollutant Discharge Elimination System (NPDES) permit, and to evaluate the general conditions of the POTW. The inspection results have been summarized in the enclosed CEI Report. If you have specific questions about the inspection report, please contact Mr. Brad Ammons via email at ammons.brad@epa.gov or 404.562.9769. Please verify receipt of this letter and report by emailing Mr. Ammons at the email address provided. Sincerely, JAIRO Digitally signed by JAIRO CASTILLO CASTILLO Date: 2024.10.03 16:49:29 -04'00' Jairo Castillo, P.E., Chief Wastewater Enforcement Section Water Enforcement Branch ENCLOSURES 1. Crenshaw MS POTW CEI Report cc: James Gammill Mississippi Department of Environmental Quality jgammill@mdeq.ms.gov Tracey Rosebud Manager Partner of Mr. Quinn West Town of Crenshaw traceyrosebud@yahoo.com United States Environmental Protection Agency Region 4 Enforcement and Compliance Assurance Division Water Enforcement Branch 61 Forsyth Street, SW Atlanta, Georgia 30303 Compliance Evaluation Inspection Report Crenshaw POTW Goodwin Street, Crenshaw, MS 38621 NPDES Permit Number: MS0026930 Project No. CV-MS0026930-08132024 Date of Inspection: August 13, 2024 Inspectors: Brad Ammons, EPA Region 4 Mel-chilecee Taylor, EPA Region 4 Inspection Report Prepared by: Brad Ammons Title and Approval Sheet Title: Crenshaw POTW CEI Report CV-MS0026930-08132024 Approving Official: JAIRO Digitally signed by JAIRO CASTILLO Date: 2024.10.03 C__A_S__T_I_L_L_O____1_6:_48_:5_6 -_04_'0_0'____________ Jairo Castillo, P.E., Chief Wastewater Enforcement Section Water Enforcement Branch Enforcement Officer: Digitally signed by MICHAEL AMMONS Date: 2024.10.02 MICHAEL AMMONS _____________1_6:_21_:1_8 _-0_4'0_0'____________ Brad Ammons, Environmental Engineer Wastewater Enforcement Section Water Enforcement Branch COMPLIANCE EVALUATION INSPECTION REPORT Crenshaw MS POTW, Project # CV-MS0026930-08132024 Table of Contents 1. Introduction.................................................................................................................................................. 1 2. Participants..................................................................................................................................................1 3. Facility Description ...................................................................................................................................... 1 4. Inspection Procedures.................................................................................................................................1 5. Findings & Conclusions................................................................................................................................2 A. Permit Review ...................................................................................................................................... 2 B. Records and Reports ............................................................................................................................... 2 C. Flow Measurement ................................................................................................................................. 3 D. Sampling/Laboratory .............................................................................................................................. 3 F. Sludge Handling ........................................................................................................................................ 3 G. Effluent/Receiving Water ........................................................................................................................ 3 6. Discussion .................................................................................................................................................... 3 1. Introduction COMPLIANCE EVALUATION INSPECTION REPORT Crenshaw MS POTW, Project # CV-MS0026930-08132024 On August 13, 2024, representatives of the United States Environmental Protection Agency Region 4, and the Mississippi Department of Environmental Quality (MDEQ) conducted a Compliance Evaluation Inspection (CEI) on the Town of Crenshaw Publicly Owned Treatment Works (POTW), owned by the Town of Crenshaw, Mississippi (The Town) and operated by Tracey Rosebud. The inspection was conducted under the authority of Section 308 of the Clean Water Act (CWA), as amended. This report provides a summary of the inspection. 2. Participants Name Brad Ammons Melchilecee Taylor James Gammill Tracey Rosebud Marco Goings Organization EPA Region 4 EPA Region 4 MDEQ Town Contractor Mayor Contact Information Ammons.brad@epa.gov Taylor.melchilecee@epa.gov jgammill@mdeq.ms.gov traceyrosebud@yahoo.com Townofcrenshaw@gmail.com 3. Facility Description The Crenshaw POTW is a single-cell lagoon publicly owned treatment works located on Missouri Avenue in Crenshaw, MS. The facility is currently permitted under National Pollutant Discharge Elimination System (NPDES) permit number MS0026930 to discharge 0.21 million gallons per day (MGD) from Outfall 001 into a ditch then to David Bayou. The POTW consists of a single-cell lagoon with no aeration (facultative lagoon). The effluent passes through a chlorine contact chamber which uses chlorine tablets for disinfection. The treated effluent is injected with SO2 gas for de-chlorination prior to discharge. The effluent passes over a weir prior to discharge to the pipe leading to the receiving stream/ditch. The facility's current wastewater plant staff are as follows: One contract Mississippi Wastewater Treatment Class 4 Operator. 4. Inspection Procedures The overall objective of this CEI was to evaluate the condition and operational performance of the POTW and Crenshaw's self-monitoring program and to offer compliance assistance as needed. Specific tasks included conducting an opening conference, interviewing POTW staff, reviewing laboratory and Discharge Monitoring Report (DMR) records, conducting a POTW walkthrough, and a closing conference. 1 COMPLIANCE EVALUATION INSPECTION REPORT Crenshaw MS POTW, Project # CV-MS0026930-08132024 Figure 1. Aerial View of Facility 5. Findings & Conclusions A. Permit Review Crenshaw's NPDES permit MS0026930 has an effective date of January 6, 2021, and expires on December 31, 2025. The NPDES permit lists Effluent Limitations and Monitoring Requirements for Outfall 001 (Treated Domestic Wastewater) that discharges into a ditch then to David Bayou. B. Records and Reports The EPA's Enforcement Compliance History Online (ECHO) shows that the Town failed to submit the Discharge Monitoring Report (DMR) for 2021-2024. Recent DMRs and analytical results from Sledge's contract laboratory (Waypoint Analytical in Memphis, TN) were reviewed onsite, which the Town was able to reproduce for most of the required quarterly sampling for 2021-2023. The Town had a copy of their NPDES permit and during the inspection some of the analytical results, chain of custody, and DMRs were present which met permit required retention times and were well organized. Mr. Rosebud stated that he kept all the Town's maintenance logs, but that they were ruined in a flood in his home, so none 2 COMPLIANCE EVALUATION INSPECTION REPORT Crenshaw MS POTW, Project # CV-MS0026930-08132024 were produced. EPA and MDEQ suggested that he re-create the operational logs (weekly Residual Chlorine and Flow readings) digitally. C. Flow Measurement Mr. Rosebud uses a yardstick at the v-notch weir to measure flow and allegedly records the depth in his notebook (see note above about no operational records produced). D. Sampling/Laboratory Mr. Rosebud samples and analyzes the Residual Chlorine and Flow parameters weekly for the Town. The Town contracts with Waypoint Analytical in Memphis, TN to analyze pH, Dissolved Oxygen (DO), Biochemical Oxygen Demand, 5-day (BOD5), Total Nitrogen, E. Coli, Total Phosphorus and Total Suspended Solids (TSS). E. Site Visit (Operation and Maintenance) The following components were observed: Chlorine tablets are used at the head of the chlorine contact chamber (Photo 1) and SO2 is injected at the end of the chlorine contact chamber for dechlorination (Photo 2). The lagoon was completely covered in algae and the berm was covered in woody plants (Photo 3). F. Sludge Handling Sludge was not evaluated during the inspection as this is a lagoon. No record of lagoon dredging was available. G. Effluent/Receiving Water The effluent being discharged through Outfall 001 into the ditch was not evaluated during the inspection due to restricted access (overgrown vegetation). Effluent was being discharged at the time of the inspection. 6. Discussion The facility DMR non-receipt SNC violations are due to not reporting laboratory analytical results into NetDMR. Most of the analytical results from Waypoint Analytical laboratory were produced, but Mr. Rosebud has not yet emailed three years of quarterly records as requested. Crenshaw should enter the sampling results into NetDMR immediately. Algae are a naturally occurring and necessary part of facultative wastewater lagoons. Conventional green algae are a sign of a healthy lagoon. The oxygen they produce is necessary for bacteria to stabilize waste (and thus remove BOD) in the pond. However, too much algae in the 3 COMPLIANCE EVALUATION INSPECTION REPORT Crenshaw MS POTW, Project # CV-MS0026930-08132024 effluent can lead to TSS, BOD, and pH violations. Blue-green algae are filamentous and block sunlight, and some blue-green algae produce toxic and odorous byproducts. When algae in the effluent die, settle out, and decay, they exert some oxygen demand on the receiving stream (Compliance Tips for Small Wastewater Treatment Lagoons with Clean Water Act Discharge Permit, EPA Document # 305F22002, March 2022). Crenshaw should control algal growth in their lagoon to support adequate wastewater treatment. END OF REPORT 4 Attachment 1, Photographs. Crenshaw, MS POTW, Project # CV-MS0026930-08132024 Appendix 1: Photographic Log Photo 1: Chlorine tablet injection point. Photo 2: Sulfur Dioxide injection point. High algae effluent observed Photo 3: Crenshaw lagoon and berm. 5