Document O3RrYYNp53GjNjzYM7n1zXxv1

ELECTRONIC MAIL CONFIRMATION OF EMAIL RECEIPT REQUESTED Willie Readus Mayor Town of Sledge 400 Main Street Sledge, MS 38670 townofsledge@comcast.net Dear Willie Readus: The U.S. Environmental Protection Agency, Region 4 conducted a Compliance Evaluation Inspection (CEI) on the Town of Sledge (Town) 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 or at 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 16:46:45 -04'00' Jairo Castillo, P.E., Chief Wastewater Enforcement Section Water Enforcement Branch ENCLOSURES 1. Sledge MS POTW CEI Report cc: James Gammill Mississippi Department of Environmental Quality jgammill@mdeq.ms.gov William Q. West Contract Operator, Town of Sledge qmwest104@gmail.com Tracey Rosebud Manager Partner of Mr. West, Town of Sledge 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 Sledge POTW Lagoon Road, Sledge, MS 38670 NPDES Permit Number: MS0021016 Project No. CV-MS0021016-08132024 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: Sledge MS POTW CEI Report CV-MS0021016-08132024 Approving Official: JAIRO Digitally signed by JAIRO CASTILLO Date: 2024.10.03 _C_A_S__T_I_L_L_O____1_6:_44_:5_9 _-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_:24_:3_1_-0_4'0_0_' ___________ Brad Ammons, Environmental Engineer Wastewater Enforcement Section Water Enforcement Branch COMPLIANCE EVALUATION INSPECTION REPORT Sledge MS POTW, Project # CV-MS0021016-08132024 Table of Contents 1. Introduction ................................................................................................................................... 3 2. Participants ................................................................................................................................... 3 3. Facility Description ........................................................................................................................ 3 4. Inspection Procedures .................................................................................................................. 3 5. Findings & Conclusions ................................................................................................................. 4 A. Permit Review ......................................................................................................................... 4 B. Records and Reports ................................................................................................................. 4 C. Flow Measurement ................................................................................................................... 4 D. Sampling/Laboratory ................................................................................................................ 5 F. Sludge Handling .......................................................................................................................... 5 G. Effluent/Receiving Water .......................................................................................................... 5 6. Discussion...................................................................................................................................... 5 1. Introduction Attachment 1, Photographs. Sledge, MS POTW, Project # CV-MS0021016-08132024 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 Sledge Publicly Owned Treatment Works (POTW), owned by the Town of Sledge, Mississippi (The Town) and operated by William Q. West. 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 Mel-chilecee Taylor James Gammill William Q. West Willie Readus 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 Qmwest104@gmail.com Townofsledge@comcast.net 3. Facility Description The Sledge POTW is a three-cell lagoon treatment system located on Lagoon Road in Sledge, MS. The facility is currently permitted under the National Pollutant Discharge Elimination System (NPDES) permit number MS0021016 to discharge 0.22 million gallons per day (MGD) from Outfall 001 into an unnamed creek then to David Bayou. The POTW consists of a three-cell lagoon with aeration in the first cell and a rotating contactor in the third cell. The treated effluent passes through a chlorine contact chamber which uses gaseous chlorine for disinfection. The effluent is injected with SO2 gas for de-chlorination prior to discharge. The effluent passes over a weir plate (primary flow measurement device) prior to discharge to the pipe leading to the receiving stream. 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 Sledge'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. 3 Attachment 1, Photographs. Sledge, MS POTW, Project # CV-MS0021016-08132024 Figure 1. Aerial View of Facility 5. Findings & Conclusions A. Permit Review Sledge's NPDES permit MS0021016 has an effective date of December 20, 2019, and expires on November 30, 2024. The NPDES permit lists Effluent Limitations and Monitoring Requirements for Outfall 001 (Treated Domestic Wastewater) that discharges into an unnamed creek 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 Reports (DMR) for 2022 and 2024 and reported effluent limitation exceedances for E. coli and Ammonia in 4th quarters of calendar years 2021 and 2022. 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. West agreed to email three years of quarterly records. EPA hasn't received the records. Finally, Mr. West stated that he kept all the Town's maintenance logs since September 2023, when he was hired, and he produced his weekly Flow and Residual Chlorine sample records. C. Flow Measurement Mr. West uses a yardstick at the v-notch weir to determine flow and records the depth in his notebook. 4 Attachment 1, Photographs. Sledge, MS POTW, Project # CV-MS0021016-08132024 D. Sampling/Laboratory Mr. West samples and analyzes the Residual Chlorine and Flow parameters weekly for the Town. The Town contracts with Waypoint Analytical in Memphis, TN to analyze Biochemical Oxygen Demand, 5-day (BOD5), Ammonia-Nitrogen, Total Nitrogen, E. coli, Total Phosphorus and Total Suspended Solids, pH, and Dissolved Oxygen. E. Site Visit (Operation and Maintenance) The following components were observed: Chlorine is injected 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). A spontaneous check for residual chlorine showed below detection limit (0.02 mg/L) for the handheld colorimeter Mr. West uses (Photo 3). Cell 1's two aerators were out of service (Photo 4) and the lagoon was completely covered in algae. Cell 2 was completely covered in algae (Photo 5). Cell 3's rotating contactor was out of service and the area of the berm there was covered in woody plants (Photo 6). 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 unnamed creek 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 Significant Non-Compliance (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. West has not yet emailed to EPA three years of quarterly records as requested. Sledge should repair the two non-functioning aerators in Cell 1 and the non-functional rotating contactor in Cell 3. Algal blooms in a wastewater lagoon, especially an aerated lagoon, affects the treatment process and effluent quality. Algae create oxygen during the day and consume it at night, leaving less oxygen available for BODconsuming bacteria to use. High algae can also create high TSS and BOD5 effluent concentrations that will generate a high oxygen demand in the receiving water. Sledge should control algal blooms in their lagoon to support adequate wastewater treatment. END OF REPORT 5 Attachment 1, Photographs. Sledge, MS POTW, Project # CV-MS0021016-08132024 Appendix 1: Photographic Log Photo 1: Chlorine injection point. Photo 2: Sulfur Dioxide injection point. Photo 3: Residual Chlorine reading of 0.02 mg/L. Photo 4: Cell 1 (location of non-functional aerators) 6 Attachment 1, Photographs. Sledge, MS POTW, Project # CV-MS0021016-08132024 Photo 5: View of Cell 2 full of algae. Photo 6: Lagoon- Cell 3 (non-functional rotating contactor and woody vegetation in berm). 7