Document jN3YX6Vmj4xM8VYyGno32kjey

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Agency Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) December 6, 20 17 Water NPDES Company Name: Facility Name: Facility Physical Location: Mailing address: (city, state, zip code) County/Parish: Facility Contact: City of Nashville City of Nashville Wastewater Treatment Plant 33.919, -93.861 426 Nmth Main Nashville, AR 71852 Howard County Larry Dunway I Public Works Director larr~19211@gmail.com FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110000752855 AR0021776 none 221320 4952 Personnel participating in inspection: Magda Dallemagne US EPA, 6EN-WS Sarah Khomy Facility Representative Larry Dunway Facility Representative Greg Strawn Facility Representative Inspector Lab Technician Public Works Director Water & Wastewater Production Superintendent EPA Lead Inspector Signature/Date Magda Dallemagne (214) 665-7396 (870) 845-4522 (870) 845-1440 (870) 845-7797 Date Supervisor Signature/Date 6::,\-~sc-. ~d Robert Houston t4-~ Lj2--/zo I K Date 6ENFORM-019-R7 (2/15/2017) 1 Section I- INTRODUCTION City of Nashville WWTP December 6, 2017 PURPOSE OF THE INSPECTION EPA Region 6 inspector Magda Dallemagne arrived at the City of Nashville Wastewater Treatment Plant (WWTP) (the Facility) at 9:10am on December 6, 2017, for an unannounced inspection. I met with Sarah Khoury, Laboratory Technician, Larry Dunaway, Public Works Director, and Greg Strawn, Water and Wastewater Production Superintendent. I presented my credentials to Ms. Khoury and Mr. Dunaway informing them that this was an EPA inspection to determine compliance with the facility's National Pollution Discharge Elimination System (NPDES) permit, AR0021776. 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 supervising technician who is responsible for the training of one other technician, expected to replace him in the near future. The laboratory performs pH, dissolved oxygen (DO), 5 Day Carbonaceous Biochemical Oxygen Demand (CBODs), Total Suspended Solids (TSS), and Fecal Coliform (Fecal) testing under their NPDES operating permit. The remaining required testing is sampled on site and sent to a contract laboratory, Ana Laboratory, 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 tlu-ough the processes for testing and sampling as per the NPDES permit. The following observations were made. 1. Internal training is not formally tracked, and performance reviews are not documented. 2. Thermometers are not traceable to National Institute of Standards and Technology (NIST) certification. They also were not correctly labeled with calibration, expiration, and correction factors. There were no temperature logs maintained for the temperaturecontrolled instruments. 3. Several 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. pH and DO meters are not calibrated before each use, and are instead calibrated weekly. 5. The balance undergoes a yearly "Basic Test Confirmation," which is not a NIST ce1tified calibration. Additionally, the contracting company performing this test stated in its last repmi "This balance is obsolete and is no longer supported ... I would advise that the 2 City of Nashville WWTP December 6, 2017 customer consider replacing the balance." NIST cettified weights are not available to perform regular calibration checks of the balance in house. 6. The refrigerator used for chemical and sample storage is also used for food storage. Spaces used for storage in this manner can cause contamination of one or more of the samples, chemicals, and food. 7. Solutions and reagents are not properly labeled with open and expiration dates. Most reagents are stored within the same cabinet and presented several concerns, as listed below. a. Expired and out of use chemicals are stored with the working reagents b. Acids and bases are stored right next to each other c. The labels of some chemicals had worn off, or were otherwise illegible 8. The method used for measuring TSS is inconect. The technician is drying the samples in an oven only once before recording the weight of solid. It is required that TSS samples be dried two or more times, or until the difference in mass after each drying period is less than 0.005g. 9. During Fecal testing, the technician is not utilizing an acceptable method to sterilize the forceps used to transfer the filter papers. l 0. The oven used in the laboratory was placed on an unstable rolling table, and was stored within just a few feet of a bookcase filled with books. 11. Bench sheets have some instances of auto-populated date and time. All entries must be made at time-of, none can be auto-populated. The bench sheets also do not reference any EPA method or SOP. White out was used to conect mistakes instead of the cross out, initialing, and dating method. 12. There are no written Standard Operating Procedures (SOP) as required. All testing procedures are performed as read from the 2015 edition of Standard Methods or are an understood 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 3:33pm December 6, 2017. At that time, the inspector provided details of the inspection and reviewed areas of concern noted in the inspection that will require additional follow-up or correction. These areas of concern included: 1. Tracking of personnel training and performance reviews 2. Use of non-certified NIST balance and thermometers in testing procedures 3. Inadequate maintenance and/or operation of equipment and instruments 4. Inadequate storage and handling of chemicals, reagents and samples 5. Improper EPA methods used 6. Maintenance of SOPs and bench sheets 3 Section IV- FOLLOW UP City of Nashville WWTP December 6, 2017 As per the document request placed during the inspection, documents were received by EPA on December 15, 2017, after exiting the Facility on December 6, 2017. Additional information was received January 29,2018. A copy of this report will be sent to the facility. 4