Document a1LRXXeL27VMGo5wnx1waJYYR

f t EA~Unite<IStatas ~ Environmental Protection "'IIII" Agency Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) November 27- 28, 2017 Water NPDES Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: City of Hot Springs City of Hot Springs Wastewater Treatment Plant 798 Adams St Hot Springs, AR 71901 798 Adams St Hot Springs, AR 71901 Garland Harold Mauldin I Lab Manager HMauldin @cit'{hs. net FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110000517254 AR0033880 None 221320 4952 Personnel pmticipating in inspection: Magda Dallemagne US EPA, 6EN-WS Harold Mauldin Facility Representative Gordon Yales Facility Representative Amanda Cates Facility Representative Inspector Lab Manager Plant Supervisor Lab Technician EPA Lead Inspector Signature/Date Supervisor Signature/Date ~~"'L a/./_. Magda Dallemagne 1 fl I If t''WlI/11' /Tiiiif\. Robett Il ouston ...-.._./- - .___ - (214) 665-7396 (501) 262-1881 (50 I) 262-1881 (501) 262-1125 I -2&- 2.4>/1( Date Vft//)D) b Date 6ENFORM019-R7 (2/15/2017) 1 Section I- INTRODUCTION City of Hot Springs WWTP November 27-28, 2017 PURPOSE OF THE INSPECTION EPA Region 6 inspector Magda Dallemagne arrived at the City of Hot Springs Wastewater Treatment Plant (WWTP) (the Facility) at 9:10am on November 27,2017, for an unannounced inspection. I met with Gordon Yates, Plant Supervisor, and Amanda Cates, Lab Technician. I presented my credentials to Mr. Yates informing him that this was an EPA inspection to determine compliance with the facility's National Pollution Discharge Elimination System (NPDES) permit, AR0033880. The scope of the inspection is to evaluate the compliance of the facility's laboratory and sampling with it's NPDES operating permit. FACILITY DESCRIPTION The Facility laboratory is not accredited under State, National, or Private programs. There is one Lab Manager and two Lab Technicians. The laboratory performs pH, dissolved oxygen (DO), 5 Day Carbonaceous Biochemical Oxygen Demand (CBODs), Total Suspended Solids (TSS), Ammonia, and Fecal Coliform (Fecal) testing under their NPDES operating permit. The remaining required testing is sampled on site and sent to a contract laboratory, NSI Laboratory Solutions, to satisfy the permit requirements. Section II- OBSERVATIONS The inspector discussed the operations and management of the laboratory and observed as the technician walked them through the processes for testing and sampling as per the NPDES permit. ' The following issues were discovered. 1. The expiration and open dates on the reagents and standards were not clearly labeled, and did not meet the general one year after opening, or as per manufacturer's expiration, rule. The received dates were recorded clearly. 2. Internal training is not formally tracked, and no regular performance reviews are conducted on the technicians. 3. Some thermometers were not held suspended in containers such that the thermometers were touching the inside surface of its container. Temperature readings can be affected if the thermometer is touching surfaces such as glass or metal, and so must be suspended. 4. The technicians were recording the time for grab samples after retuming to the lab, subtracting 3-5 minutes from the current time they read. The data collected for grab samples, including time of grab, must be collected at the time and place of the sampling. The data was also recorded in a loose notebook, considered an un-controlled document, and was recorded using pencil instead of pen. 5. The weights used for balance calibration are not National Institute of Standards and Technology (NIST) ce1tified and the balance is unplugged regularly due to power surges 2 City of Hot Springs WWTP November 27-28, 2017 in the laboratory. This could affect the balance's yearly NIST certified calibration, it was suggested the Facility consult the manufacturer for proper precautions. 6. The adjustable pipets used in the lab do not undergo regular calibrations or checks to ensure an accurate dispensing of volume. 7. The NIST certified thermometers had not been calibrated since 2004, most calibration ce1tifications last one year, a maximum of 5 years. The thermometers therefore are no longer NIST certified, and the working thermometers checked by the certified thermometers are no longer NIST traceable. 8. Standard Operating Procedures (SOP) are not regularly updated and do not reference the appropriate EPA or Standard Method. 9. Bench sheets did not clearly label units for all data entries and did not reference the appropriate EPA method. Section III- AREAS OF CONCERN At the conclusion of the inspection, the EPA inspector met with the representatives from the Facility for an exit interview at 2:50pm November 28, 2017. At that time, the inspector provided details of the inspection and reviewed issues noted in the inspection that will require additional follow-up or correction. These issues included: 1. Handling of reagents and standards 2. Tracking of training 3. Maintenance of equipment and instruments 4. Maintenance of SOPs and bench sheets Section IV- FOLLOW UP As per the document request placed during the inspection, documents were last received by EPA on December 1, 2017, after exiting the Facility on November 28, 2017. A copy of this repmt will be sent to the facility. 3