Document 6R1v3QKbQx3DpZoeaE9yYOdyE

United States Environmental Protection Agency Region 4 Enforcement and Compliance Assurance Division Water Enforcement Branch 61 Forsyth Street, SW Atlanta, Georgia 30303 Wastewater Collection and Transmission System Compliance Evaluation Inspection Report City of Sevierville (McCroskey Island) STP NPDES Permit Number: TN0063959 Project No. SS-TN0063959-03072024 Facility Address: 2295 McCroskey Island Road, Sevierville, TN 37876 Inspection Date: March 7, 2024 Inspectors: Mel-Chilecee Taylor, EPA Region 4 Andrew Gunderson, EPA Region 4 Brad Ammons, EPA Region 4 Inspection Report Prepared by: Mel-Chilecee Taylor COMPLIANCE EVALUATION INSPECTION REPORT City of Sevierville, Project No. CS-TN0063959-03072024 Title and Approval Sheet Title: City of Sevierville (McCroskey Island) STP, Sevierville, Tennessee Compliance Evaluation Report Project No. SS- TN0063959-03072024 Approving Official: JAIRO Digitally signed by JAIRO CASTILLO Date: 2024.05.03 06:52:33 C__A_S__T_I_L_L_O________-0_4_'00_'____________ Jairo Castillo, P.E., Chief Wastewater Enforcement Section Water Enforcement Branch Enforcement Officer: _______________________________ Mel-Chilecee Taylor, Inspector Wastewater Enforcement Section Water Enforcement Branch Table of Contents 1. OVERVIEW ..........................................................................................................................................................1 2. OBJECTIVE...........................................................................................................................................................1 3. INVESTIGATION METHODS .................................................................................................................................1 4. REGULATORY SUMMARY....................................................................................................................................1 5. INSPECTION SUMMARY AND FINDINGS .............................................................................................................2 a. Analysis of SSOs ..............................................................................................................................................2 d. Site Inspections ...............................................................................................................................................3 6. RECOMMENDATIONS AND CONCLUSION ..........................................................................................................3 Enclosure 2 - Photographs....................................................................................................................................... 12 COMPLIANCE EVALUATION INSPECTION REPORT City of Sevierville, Project No. CS-TN0063959-03072024 1. OVERVIEW On March 7, 2024, the EPA conducted a Compliance Evaluation Inspection (CEI) of the City of Sevierville's sewer system. The purpose of this CEI was to evaluate compliance with the CWA and the City's National Pollutant Discharge Elimination System (NPDES) permit (permit # TN0063959) as it relates to the sanitary sewer wastewater collection and transmission system (WCTS) and to assess the City's Management, Operations, and Maintenance (MOM) programs. This inspection was conducted under the authority of Section 308 of the Clean Water Act (CWA), as amended. This report presents the results of the inspection. The City of Sevierville (City) Wastewater Treatment Department provides sanitary sewer services for residential, commercial, and industrial entities within the City of Sevierville, Tennessee. The city owns and operates one wastewater treatment plant, and 94 pump stations. The miles of gravity pipe owned by the city was not readily available. 2. OBJECTIVE The objective of this inspection was to evaluate the general condition of the WCTS and to evaluate the City's operations and maintenance practices. Additionally, the EPA was to ascertain the use of any MOM programs that may be implemented by the City and to offer compliance assistance as needed. Specific tasks included conducting an opening conference, interview City staff, conducting a site visit of selected portions of the WCTS, and a closing conference. 3. INVESTIGATION METHODS The investigation included: Review of the Integrated Compliance Information System database and the NPDES Permit; Interviews with the City's Wastewater Department personnel; and, Visual inspection. 4. REGULATORY SUMMARY The City NPDES permit was issued on May 1, 2020, and expires on April 30, 2025. NPDES permit requirements most applicable to the WCTS includes: i. Section 2.3.2 (Noncompliance Notification - Twenty-Four Hour Reporting) requires the City to report any non-compliance that may endanger health or the environment within 24 hours "from the time the permittee becomes aware of the circumstances." ii. Section 2.1.4 (Proper Operation, Maintenance, and Replacement) requires the City to properly operate, maintain, and replace parts and equipment for the wastewater treatment plant and the associated collection system, (i.e., the WCTS). The Clean Water Act (CWA) Section 301, 33 U.S.C. 1311, states that it is unlawful for any person 1 of 13 COMPLIANCE EVALUATION INSPECTION REPORT City of Sevierville, Project No. CS-TN0063959-03072024 to discharge any pollutant into waters of the United States without authorization under specific provisions of the CWA, including 402 (NPDES) or 404 (discharge of dredged or fill material). Section 402, 33 U.S. Code 1342, of the Clean Water Act requires that a discharge of any pollutant or combination of pollutants to surface waters that are deemed waters of the United States be regulated by a NPDES permit. Sanitary Sewer Overflows (SSOs) are discharges of untreated sewage from any part of the WCTS that is not identified in the NPDES permit as a permitted outfall. SSOs that reach waters of the U.S. are prohibited discharges based on Section 301 of the CWA. SSOs that discharge into storm water sewers, drainage ditches, and unnamed tributaries which reach waters of the U.S. are also prohibited. Section 2.3.2 of the NPDES permit requires the City to report SSOs to the Tennessee Department of Environment and Conservation (TDEC) within 24 hours of discovery. SSOs that do or do not reach waters of the U.S. could be indicative of improper operation and maintenance of the WCTS as required by Section 2.1.4 of the NPDES permit. 5. INSPECTION SUMMARY AND FINDINGS The EPA performed an inspection of the City where EPA personnel reviewed SSO reports that were provided by the City. This section will provide a summary of the inspection, including associated pre-and/or post-inspection activity, as well as any recommendations to the City to improve performance of the WCTS. a. Analysis of SSOs b. The City uses "Red Hot" for controlling roots in the sewers. The last few reported Sanitary Sewer Overflows (SSOs) were from the bypass pump at the 36" interceptor lining project at the river crossing. Chad Parton does all SSO reporting to TDEC. All citizen complaints go through City Hall during work hours and staff add them to the work order system. The City reported a total of 94 lift stations within the system. There are 84 that are on Supervisory Control and Data Acquisition (SCADA) and 10 are not on SCADA. In the mornings, the crews check SCADA for any anomalies and check those stations first. Single phase stations seem to have the most issues and they are moving to 3 phase (new control panels; about 4 of 13 pump stations currently contracted have been completed). One of the crew members is responsible of conducting grease trap inspections and another crew member assist him with also doing inventory of parts for the pump stations. None of the pump stations have on-site backup generators, but the City has 3 portable generators in case of power failure. Mr. Loveday stated there are 3 main influent feeds to the STP (Kodak; Seymour; Davis Lane (largest PS in system). Mr. Loveday also mentioned that they have about 1,500 single customer pumps ("E1" in their CMOM Reports on TDEC's website) and that E1 calls are done through an electronic work order system. The City also has 1 River crossing that was leaking (contractors working on it now). Have an annual budget of $250,000 for CMOM/Rehabilitation. 2 of 13 COMPLIANCE EVALUATION INSPECTION REPORT City of Sevierville, Project No. CS-TN0063959-03072024 c. Management, Operations and Maintenance Program. For the few lift stations that are not tied into SCADA, the operators keep a log of when each lift station is checked and then put into an annual Capacity, Management, Operations, and Maintenance (CMOM) report to TDEC. The CMOM report is reported to TDEC annually in October. Nine employees are on staff for the WCTS, that are broken up into three crews. These crews are placed in a service truck with three in each truck. Each team has assigned lift stations and they are to be inspected daily. They check control panels, manipulate high level pumps, check wet wells, look for any spills, etc. Each morning each team looks through SCADA at their assigned lift stations to see if there are any issues showing for a lift station. If an issue is identified at a lift station or complaint is called in, it is tagged by City Hall to a work order. That work order is relayed into SCADA which is sent out to the assigned team of that area/lift station. Any updates or resolution of the complaint is relayed back into SCADA and later also noted on any monthly reports. d. Site Inspections Refer to Enclosure 1 (Photographs) for pictures taken on March 7th. i. Photo 1 is the manhole next to the Stables Lift Station. Manholes are inspected with a camera on a weekly basis, where pictures are taken and uploaded in GIS. During the inspection, one of the service workers used an Insta 360 camera to demonstrate how manholes are inspected. ii. Photos 2 through 4 are lift stations (Stables Lift Station, Davis Lane Lift Station, and Kodak Lift Station, respectively) in Sevierville. a. Stables Lift Station: alarm system and both pumps were operational, no spills noted, station upgraded in 2020, has a flow meter (FLEXIM) which is determined based on time. Lift station was fenced and locked and signage displayed with City contact information. Minor grease and trash buildup in wet well, and station has a generator connect. b. Davis Lane Lift station: All new pumps (4 pumps: 3- 75 Horsepower and 1- 80 Horsepower pumps), no audible alarm but the lift station is on SCADA. Has a generator connected as well as an automatic generator transfer switch, no spills noted, lift station was fenced and locked and signage displayed with City contact information. Wet well was epoxy coated during recent rehabilitation. c. Kodak Lift station: a three-pump system (25 Hp, 15 Hp, and 10 Hp) also on SCADA. The lift station is connected to a generator, was observed fenced and locked, and signage displayed with City contact information. 6. RECOMMENDATIONS AND CONCLUSION The City should develop and implement a program for sewer assessment and rehabilitation to remove Inflow and Infiltration (I&I). The City can refer to EPA Region 4's Guide to Collection and 3 of 13 COMPLIANCE EVALUATION INSPECTION REPORT City of Sevierville, Project No. CS-TN0063959-03072024 Transmission System Management, Operation, and Maintenance Programs that can be found on EPA's website at https://www.epa.gov/enforcement/region-4-management-operations-andmaintenance-program-guidance-sanitary-sewer. Enclosure 1 - SSO Report 4 of 13 COMPLIANCE EVALUATION INSPECTION REPORT City of Sevierville, Project No. CS-TN0063959-03072024 5 of 13 COMPLIANCE EVALUATION INSPECTION REPORT City of Sevierville, Project No. CS-TN0063959-03072024 6 of 13 COMPLIANCE EVALUATION INSPECTION REPORT City of Sevierville, Project No. CS-TN0063959-03072024 7 of 13 COMPLIANCE EVALUATION INSPECTION REPORT City of Sevierville, Project No. CS-TN0063959-03072024 8 of 13 COMPLIANCE EVALUATION INSPECTION REPORT City of Sevierville, Project No. CS-TN0063959-03072024 9 of 13 COMPLIANCE EVALUATION INSPECTION REPORT City of Sevierville, Project No. CS-TN0063959-03072024 10 of 13 COMPLIANCE EVALUATION INSPECTION REPORT City of Sevierville, Project No. CS-TN0063959-03072024 11 of 13 COMPLIANCE EVALUATION INSPECTION REPORT City of Sevierville, Project No. CS-TN0063959-03072024 Enclosure 2 - Photographs Photo 1. Manhole located at Stables Lift Station. Photo 2. Stables Lift Station 12 of 13 COMPLIANCE EVALUATION INSPECTION REPORT City of Sevierville, Project No. CS-TN0063959-03072024 Photo 3. Davis Lane Lift Station (One of the three main lift stations discharging to the wastewater plant) Photo 4. Kodak Lane lift station END REPORT 13 of 13