Document JN6mYprmBGJQZpygpMNGkapye

EAA 0A UnltedStaln 1"\~~~~~~mentol P101e~tion Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 08/30/2018 Wastewater NPDES Municipality Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: City of Fort Smith Massard WWTP (wastewater treatment plant) 1609 North 9th Street Barling, AR 72923 3900 Kelley Hwy Fort Smith, AR 72904 Sebastian County Lance A. McAvoy I Director of Operations lmcavoy@fortsm itha r.gov FRS Number: Permit Number: NAICS: SIC: 110064594899 AR0021750 221320 4952 Personnel participating in inspection: Lance McAvoy Fort Smith Steve Floyd Fort Smith David Shelly Fort Smith Ted Palit EPA R6 EN-WM Damon McElroy EPA R6 EN-WM Director of Operations Treatment Program Manager Wastewater Supervisor Environmental Engineer Environmental Engineer 479-494-3908 479-784-2331 479-788-4147 214-665-8061 214-665-7159 EPA Lead Inspector Signature/Date Supervisor Signature/Date ~ Ct/\/t"'-'"'- <Darn;1:'cEiroy Me{/{1__-- (lftspector name} L~r~~tA)g-.~ {Supervisor name} 1/P-o/)-ttt; Date c;~</~g/ Date 6ENFORM-019-R7 (2/15/2017) 1 Section I - INTRODUCTION City of Fort Smith / Massard WWTP Inspection Date: 08/30/2018 PURPOSE OF THE INSPECTION EPA Region 6 inspectors Ted Palit and Damon McElroy arrived at the Massard Wastewater Treatment Plant (Massard WWTP or WWTP) (NPDES Permit Number: AR0021750) at 9:00 am on August 30, 2018 for an announced Compliance Evaluation Inspection (CEI) with City of Fort Smith Utility Officials documented above. The City's P-Street WWTP (NPDES Permit Number: AR0033278) CEI Report is available in a separate document. We conducted an Opening Conference where the group was informed that this was an EPA inspection to determine agreement with the facility's National Pollutant Discharge and Elimination System (NPDES) Permit and to evaluate compliance with the City's current Consent Decree (Civil Action No. 2:14-cv-02266-PKH filed on April 2015) stipulations. The City and EPA also had a Closeout & Consent Decree (CD) Meeting documented in this report. The inspection was conducted under NPDES authority, in accordance with the CWA. This report is based on information supplied by the City of Fort Smith Wastewater Utility representatives (the permittee), observations made by the U.S. EPA inspector(s), and records and reports maintained by the permittee, the State of Arkansas, and the U.S. EPA. FACILITY DESCRIPTION The P-Street WWTP Physical address is: City of Fort Smith Massard WWTP 1609 North 9th Street Barling, AR 72923 The facility is authorized to discharge treated municipal wastewater from the facility (located at Latitude: 35 20' 25.65"; Longitude: 94 18' 19.92) to receiving waters named Arkansas River at Pool 13 approximately 800 feet west of Lock and Dam 13 in Segment 3 H of the Arkansas River Basin. Reference the Massard WWTP NPDES Permit Excerpt in Appendix 4 for further details including effluent limits. The facility's NPDES Permit effective date is February 1, 2011, and the expiration date is January 31, 2020. As illustrated in the Massard Schematic and Description in Appendix 1, the Massard WWTP receives raw sewage that is pumped from the Massard WWTP Influent Pump Station. Sewage enters this pump station through a 48-in gravity sewer main and passes through two mechanically cleaned 1/4-in opening fine screens and is then pumped through a 36-in force main to the grit removal facility. The sewage then flows by gravity to the primary clarifier distribution box then to two 90-ft diameter primary clarifiers. Sludge collected in the primary clarifiers is pumped to sludge thickeners. Secondary treatment consists of trickling filters, contact stabilization, clarification, and UV disinfection. Primary clarifier effluent is conveyed to the trickling filter distribution box through a 42-in pipe. Each trickling filter is 145-ft in diameter and contains rock media to an average depth of 5-ft. The trickling filter effluent is conveyed through a 42-in pipe to the contact stabilization basin where the flow is combined with aerated secondary sludge. The mixed liquor from the contact basin is distributed to three 2 City of Fort Smith / Massard WWTP Inspection Date: 08/30/2018 80-ft diameter secondary clarifiers. Effluent from the secondary clarifiers is directed to the UV disinfection unit prior to the plant outfall pipeline to the Arkansas River. The WWTP operates 24 hours per day. Massard WWTP unit processes include a combination of trickling filter and activated sludge treatment. The NPDES permit (or permit) requires spring & summertime nitrification. This became an issue with ammonia-nitrogen (NH3-N) violations a few years ago. The City correspondingly made an O&M adjustment by raising the temperature of the aeration basin to 86 by increasing blower aeration output. Achieving at least 86 enhances nitrification efficiency. The Fort Smith Consent Decree (CD) requires a WWTP process assessment and a subsequent proposal for enhanced NH3-N removal. About two years ago, the City submitted two NH3-N remediation design proposals to either 1) expand the plant facilities or 2) upgrade to an activated sludge plant (at the higher cost). EPA asked for a re-submittal with one alternative. The City contends that its enhanced nitrification and O&M adjustment, described above, addresses the NH3-N effluent compliance issues. The City consequentially proposes that capital improvement or new unit processes for NH3-N removal is not necessary. In Massard, with nitrification efficiency apparently addressed, there is still a concern about UV disinfection since the TSS permit limit is 30 mg/l. Typically, UV disinfection becomes ineffective when effluent TSS goes above 15 mg/l. The City is planning on an alternative disinfection process instead of UV. The City is studying the efficacy of PAA (peracetic acid or peroxyacetic) a peroxide of acetic acid to replace the UV process. Since WWTP effluent TSS is normally capable of maintaining TSS at less than 15 mg/l, and the WWTP does not have any recent violations, EPA recognizes no immediate concern. The Massard WWTP collection system includes two EQ basins (equalization basins). These include: 1) Sunny Mead 22 MGD earthen basin system, and 2) Zero Street two (2) five MGD GSTs (ground storage tanks) (or 10 MGD total) flow equalization system. Reference Massard EQ basin photos in Appendix 2, Photo Numbers 16 to 23. Solids that are removed in the various treatment processes are dewatered by belt filter press. The dewatered solids are transported to the City's sanitary landfill for final disposal. CLOSEOUT & CD MEETING The City has submitted CD compliance documents on time and of good quality, to date. The City reported the intention to continue to comply with the CD. EPA is now concurrence-reviewing the CY 2018 submittals, or Annual Report documentation (CD Section V, Paragraphs 90 to 96), received March 31, 2018, including: Sewer System Assessments (SSAs) - CD Section V, Article One; Section X, Paragraph 91; Condition Remedial Measures - CD Section V, Article Two; Section X, Paragraph 92; 3 City of Fort Smith / Massard WWTP Inspection Date: 08/30/2018 Pump Station and Force Main Evaluation Report - remedial measures component; CD Section V, Article Three; Capacity Assessment and Hydraulic Modeling - Section V, Article Four; Capacity Remedial Measures - Section V, Article Five and Section X, Paragraph 93, Appendixes E1 and E2; Capacity, Management, Operations, and Maintenance (CMOM) Activities - Section V, Article Seven; Section X, Paragraph 94. The City addressed its proposed NASSCO Grade 4 and Grade 5 remediation design approach. The City presented several CCTV snapshots of a specific 350 feet gravity main from MH (manhole) to MH and identified three distinct pipe defects. One was determined NASSCO Grade 5, one Grade 3, and one Grade 2. The City illustrated that according to NAASCO guidance, since one defect in this pipe segment is certified as Grade 5, remediation minimally needs to address that Grade 5 pipe joint or equivalent. The remaining two defects, graded less than "5", are proposed to optionally be addresses under CMOM. The City and its consultant Engineers (that are licensed by Arkansas, as PACP & MACP experienced, professional engineers) proposed that according to engineering judgment and remaining useful life determination, that in this example, the 350 feet pipe segment final remedial design is PVC replacement. This was indicated to be a conservative design. However, in specific future remediation designs, the City requests that EPA approve, or confirm, interpretation of Grade 4 or 5 "remediation" in accordance with NASCO specifications and guidance. This would allow the remedial design option, in this example, to replace the Grade 5 pipe joint and not necessarily replace the entire MH to MH gravity main. Section II - OBSERVATIONS The inspection team confirmed that the facility does not have outstanding NPDES Permit violations. In addition, the WWTP has not had any recorded effluent violations despite several historic storm water events since CY 2016. The major unit process was observed to be in good condition. The Lift Stations and EQ basins inspected were similarly observed to be in good condition and functional. Section III - AREAS OF CONCERN Requirement: NPDES Permit Section III, Section B (1), the permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Concern: The confirmed deteriorating or unsustainable collection system will continue to increase wetweather flow, due to an inflow and infiltration (I/I) rise, unless collection system (i.e., pipeline, manholes, lift stations, etc.) remediation continues to be achieved. Such infrastructure remediation is understood to achieve permanent and sustainable I/I control in accordance with CWA 301a. 4 City of Fort Smith / Massard WWTP Inspection Date: 08/30/2018 Section IV - FOLLOW UP Relevant information was received by EPA after exiting the Facility includes electronic copies of the following: 1. Massard WWTP Operational Handout 2. Closeout meeting Sign-in Sheet Appendix 1 - Massard WWTP Aerial Photo Schematic & WWTP Description, provided by Fort Smith Appendix 2 - Photographic Log - 23 photos shown Appendix 3 - Permit No. AR0021750 Selected Pages Appendix 4 - Closeout meeting Sign-in Sheet 5 City of Fort Smith / Massard WWTP Inspection Date: 08/30/2018 Appendix 1 Massard WWTP Aerial Photo Schematic and WWTP Description Provided by Fort Smith Massard WWTP Schematic City of Fort Smith / Massard WWTP Inspection Date: 08/30/2018 City of Fort Smith / Massard WWTP Inspection Date: 08/30/2018 Massard Wastewater Treatment Plant Description (provided by the City) The Massard Wastewater Treatment Plant (WWTP) was constructed in 1966. The original WWTP consisted of an influent pump station, two primary clarifiers which reduce the content of solids and pollutants embedded in those solids by allowing them to either float to the top or settle to the bottom of the tank, two trickling filters consisting of a fixed bed of rocks over which wastewater flows downward and pollutants are then removed by a layer of microbial slime growing on the rocks, two secondary clarifiers which remove solids consisting of biological growth, and chlorine disinfection which destroys and reduces disease causing microorganisms. At that time the discharge from the WWTP flowed directly into Massard Creek, which is how the WWTP was named. The WWTP received its first upgrade twenty years later. The WWTP operations building was constructed in 1986. This building held a small control room, small process control laboratory, locker room, break room, and offices. It also contained the solids handling equipment. During this upgrade, a third secondary clarifier was added while the original two secondary clarifiers underwent a complete rehabilitation. The last upgrade in 1986 moved the discharge point from Massard Creek to the Arkansas River. The forth secondary clarifier was added in 1998. A new biosolids handling building which is used to process waste solids from the treatment process and prepare them for disposal at the landfill was constructed, and some rudimentary odor control was added to WWTP. The Massard WWTP saw its last major upgrade in 2001. The influent pump station was upgraded with new pumps and a grit removal chamber was added. Two secondary clarifiers were replaced with larger clarifiers and one final clarifier was closed for possible future use. A post solid contact aeration basin and blower building were added to treat and remove ammonia and nitrogen from the waste stream. As a safety measure the WWTP was converted from chlorine disinfection to UV disinfection and a UV Control building was constructed. Lastly the main WWTP operations building was remodeled. The consent decree called for adding a redundant (back up) power source to ensure continued plant operation in case of a power outage. This work will be completed in 2017. City of Fort Smith / Massard WWTP Inspection Date: 08/30/2018 Appendix 2 Photographic Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Massard WWTP Operations Building Photographer: DLM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Massard WWTP Headworks - odor control Photographer: DLM (photo taken from previous 07/07/2016 inspection - photo date is 07/07/2016) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Influent Raw Water Intake, Grit Removal and Waste Bin Photographer: DLM (photo taken from previous inspection dated 07/07/2016) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Primary Clarifier (1 of 2) Photographer: DLM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Trash bin at raw water lift station. Photographer: DLM (photo taken from previous inspection dated 07/07/2016) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Trickiling Filter (1 of 2) Photographer: DLM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Return Activated Sludge Chamber Photographer: DLM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Closeup of Secondary Clarifier (1 of 2). Photographer: DLM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Abondoned Clarifier Photographer: DLM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Secondary Clarifyer Effluen Baffle and Weir Photographer: DLM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: PAA (peracetic acid or peroxyacetic) a peroxide of acetic acid, five-gallon disinfectant solution (8) for study to replace UV process. Photographer: DLM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Abandoned chlorine contact plug flow baffle process unit. Photographer: DLM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: UV Disinfection Chamber Photographer: DLM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Post-disinfection pre-flume box Photographer: DLM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: 24" Parshall flume at final effluent box. Photographer: DLM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Sunnymead EQ Basin and Pump Station (Massard WWTP EQ GSTs) Photographer: DLM Description: Twin 5MG Equalization Storage Tanks = 10 MGD Total. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Sunnymead EQ Basin Building. Photographer: DLM Description: this peak flow facility provides pumping, treatment, and temporary storage of peak sanitary sewer flows caused by wet-weather events. Calcium Nitrate is used for odor control (unit to left of building). Treated flow is temporarily stored in an earthen 22 MGD Capacity equalization basin until it is pumped to the Massard Wastewater Treatment Plant for final treatment and disposal. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Sunnymead EQ Basin odor control unit close-up view. Photographer: DLM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Sunnymead EQ Basin Building (2). Photographer: DLM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Sunnymead EQ Basin showing inch bar screen. Photographer: DLM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Sunnymead EQ Basin Building SCADA example (SCADA typical of all City EQ basins). Photographer: DLM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Sunnymead EQ Basin 22 MGD earthen basin (and concrete headwall). Photographer: DLM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 Location: Massard Waste Water Treatment Plant (WWTP) City: Fort Smith County: Sebastian State: Arkansas Photo File Name: Sunnymead EQ Basin concrete headwall close-up view. Photographer: DLM City of Fort Smith / Massard WWTP Inspection Date: 08/30/2018 Appendix 3 Permit No. AR0021750 Selected Pages City of Fort Smith / Massard WWTP Inspection Date: 08/30/2018 Appendix 4 Closeout Meeting Sign-in Sheet