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Town of Walls - Walls Wastewater Collection System Inspection Report Photograph Log
Appendix A Photograph Log
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Inspection Date: October 24, 2024
Town of Walls - Walls Wastewater Collection System Inspection Report Photograph Log
Photograph 1. Library lift station wet well. Note the rust and corrosion on the interior of the wet well and the float gauges. Also note evidence of high-water levels in the wet well, outlined in red.
Photograph 2. Library lift station. The pump control panel is outlined in red. Note the rust and corrosion on the wet well access.
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Town of Walls - Walls Wastewater Collection System Inspection Report Photograph Log
Photograph 3. Library lift station with erosion, outlined in red, by the wet well.
Photograph 4. Library lift station valve pit. Note evidence of flooding.
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Town of Walls - Walls Wastewater Collection System Inspection Report Photograph Log
Photograph 5. Interior of the Morningside manhole.
Photograph 6. Morningside lift station perimeter fencing.
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Town of Walls - Walls Wastewater Collection System Inspection Report Photograph Log
Photograph 7. Morningside lift station wet well.
Photograph 8. Morningside lift station pump control panel.
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Town of Walls - Walls Wastewater Collection System Inspection Report Photograph Log
Photograph 9. Morningside lift station valve pit at the.
Photograph 10. Trailer Park lift station.
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Town of Walls - Walls Wastewater Collection System Inspection Report Photograph Log
Photograph 11. Trailer Park lift station wet well.
Photograph 12. Trailer Park lift station valve pit.
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Town of Walls - Walls Wastewater Collection System Inspection Report Photograph Log
Photograph 13. Railroad lift station.
Photograph 14. Railroad lift station wet well. Note the grease accumulation in the wet well.
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Town of Walls - Walls Wastewater Collection System Inspection Report Photograph Log
Photograph 15. Railroad lift station pump control panel.
Photograph 16. Railroad lift station valve pit.
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Town of Walls - Walls Wastewater Collection System Inspection Report Photograph Log
Photograph 17. Exterior of the Railroad manhole. Note the gaps/cracks in the grout and concrete exterior of the manhole.
Photograph 18. Interior of the Railroad manhole.
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Town of Walls - Walls Wastewater Collection System Inspection Report Exhibit Log
Appendix B Exhibit Log
Inspection Date: October 24, 2024
Town of Walls - Walls Wastewater Collection System Inspection Report Exhibit Log
Exhibit 1 Lift Station Operational Logs (August 2024 to October 2024)
Inspection Date: October 24, 2024
Town of Walls - Walls Wastewater Collection System Inspection Report Exhibit Log
Inspection Date: October 24, 2024
Town of Walls - Walls Wastewater Collection System Inspection Report Exhibit Log
Inspection Date: October 24, 2024
Town of Walls - Walls Wastewater Collection System Inspection Report Exhibit Log
Inspection Date: October 24, 2024
Town of Walls - Walls Wastewater Collection System Inspection Report Exhibit Log
Inspection Date: October 24, 2024
Town of Walls - Walls Wastewater Collection System Inspection Report Exhibit Log
Exhibit 2 Town of Walls Sewer Flows (October 2023 to September 2024)
Inspection Date: October 24, 2024
Town of Walls - Walls Wastewater Collection System Inspection Report Exhibit Log
Inspection Date: October 24, 2024
U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 4
ENFORCEMENT AND COMPLIANCE ASSURANCE DIVISION CLEAN WATER ACT COMPLIANCE INSPECTION REPORT
for
Name of System: Walls Wastewater Collection System System Address: 9087 Nail Rd, Walls, MS 38680 Mailing Address: 9087 Nail Rd, Walls, MS 38680
Report Prepared on:
12/16/2024 By: Date
Report Final as of:
By: Date
Eastern Research Group, Inc Signature
Digitally signed by JAIRO
JAIRO CASTILLO CASTILLO Date: 2024.12.17 09:21:22 -05'00'
EPA Signature
General Information Type of Inspection: Owner: Operator: Receiving Treatment Plant:
Receiving Treatment Plant Address:
Wastewater Collection System CEI Town of Walls Clear Water Solutions (CWS) DeSoto County Regional Utility Authority (DCRUA) Johnson Creek WWTF 2665 Highway 61 North, Walls, MS 38680
On-Site System Inspection Overview
On October 24, 2024, representatives from the U.S. Environmental Protection Agency Region IV's (EPA's) contract inspector, Eastern Research Group (ERG), James Phillips and Mike Beck, conducted a compliance evaluation inspection of the Walls wastewater collection system, under EPA Region IV's Management, Operations, and Maintenance (MOM) Program for sanitary sewer collection systems. The Town of Walls is identified as the owner of the wastewater collection system.
Approximate Entry Time: 1300 (CDT)
Approximate Exit Time: 1600 (CDT)
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Town of Walls - Walls Wastewater Collection System Compliance Evaluation Inspection Report
TABLE OF CONTENTS
I. INTRODUCTION ................................................................................................................... 3
II. INSPECTION PROCESS.......................................................................................................... 3 Inspection Opening Conference.......................................................................................... 3 System Site Walk ................................................................................................................. 5 Records Review ................................................................................................................... 8 Summary of Observations................................................................................................... 8 Closing Conference ............................................................................................................. 8
APPENDIX LIST
Appendix A: Photograph Log Appendix B: Exhibit Log
o Exhibit 1 - Lift Station Operational Logs (August 2024 to October 2024) o Exhibit 2 - Town of Walls Sewer Flows (October 2023 to September 2024)
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Town of Walls - Walls Wastewater Collection System Compliance Evaluation Inspection Report
I. INTRODUCTION
On October 24, 2024, representatives from the U.S. Environmental Protection Agency Region IV's (EPA's) contract inspector, Eastern Research Group (ERG), James Phillips and Mike Beck (hereinafter, the inspectors), conducted a compliance evaluation inspection of the Walls wastewater collection system (the "system"). The Town of Walls owns the collection system and has a contractor, Clear Water Solutions (CWS), which operates the collection system.
The primary purpose of the inspection was to review the wastewater collection system, to evaluate the accuracy and reliability of the Town of Wall's self-monitoring and reporting program, and to obtain information that will assist EPA in assessing the Town of Wall's compliance with the requirements of the Clean Water Act. The Walls wastewater collection system services a population of approximately 1,400 people and discharges wastewater to the Johnson Creek WWTF which is owned and operated by the Desoto County Regional Utility Authority (DCRUA). The weather at the time of the inspection was hot, humid, and sunny.
II. INSPECTION PROCESS
Inspection Opening Conference
The inspectors arrived at Walls town hall at 1300 on October 24, 2024, for the inspection. James Phillips and Mike Beck of ERG displayed their Clean Water Act inspector credentials to Donde Baldwin of CWS at the outset of the inspection and explained the purpose of the inspection was to observe compliance with the Clean Water Act. Table 1 describes the individuals that participated in the inspection, hereinafter the "system representatives".
Name James Phillips Mike Beck
Donde Baldwin Nathan Bruce Kathy Gordon Keidron Henderson
Table 1. Inspection Attendee List
Affiliation
Position EPA inspectors
Email
ERG
Inspector
James.phillips@erg.com
ERG
Inspector
Mike.beck@erg.com
Facility Representatives
CWS
Manager
Donde.baldwin@clearwatersol.com
CWS
Operator
Nathan.bruce@clearwatersol.com
Town of Walls
Town Clerk
kgordon@townofwalls.com
Town of Walls
Mayor
mayorkhenderson@townofwalls.com
During the opening conference, the system representatives provided an overview of the staffing, operational procedures, and sanitary sewer overflow (SSO) reporting procedures of the Walls collection system. Table 2 provides an overview of the system, including the number of lift stations, manholes, miles of lines, industrial users, connections, and SSOs per year. CWS has six full-time staff that oversee multiple collection systems in northern Mississippi, including the
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Town of Walls - Walls Wastewater Collection System Compliance Evaluation Inspection Report
Walls collection system. Staff at CWS follow a typical schedule working from 0800 to 1700 Monday to Friday and are on-call during off hours. Nathan Bruce is the primary operator for the Walls collection system and carries a Class 4 wastewater operator license from Mississippi.
The system does not have a centralized Supervisory Control and Data Acquisition (SCADA) system, nor any digital alerts/alarms. Each lift station is equipped with visual alarms and the lift stations are checked two to three times a week by the CWS operators. CWS will usually receive calls from the public if any alarms go off at the lift stations or if there is any evidence of an SSO. CWS operators record the lift station checks in operational logs.
According to the system representatives, the system does not have any industrial dischargers. The wastewater received by the Walls collection system is 100% domestic wastewater.
The system representatives stated they do not typically have any issues with fats, oils, and greases (FOG) or flushable wipes. CWS has a sewer jet that is shared among the several collection systems they operate to clear out any buildups of FOG or wipes, if needed. The system representatives stated they have some infiltration and inflow (I/I) during rain events, but it rarely causes any issues. CWS reports any SSOs to the Mississippi Department of Environmental Quality (MDEQ) as soon as possible. The system representatives stated they have not had any SSOs in the last 5 years.
CWS has both a preventative maintenance and work order program. The operators record any preventative maintenance or work orders on the lift station operational logs. CWS also has written SOPs for the daily checks and weekly cleanings of the lift stations, and other operation activities. The system representatives stated they have not conducted any inspections of the Walls collection system in the past few years. The system representatives stated they follow confined space entry procedures during maintenance or other work throughout the collection system.
CWS maintains an up-to-date inventory of spare parts for the lift stations and pumps they have for the collection systems they operate, including Walls, in an asset management plan. CWS also has one portable backup generator that is shared between the systems they operate.
At the time of inspection, the inspectors requested that the system representatives provide more detailed SOPs for the lift station, along with the system's total number of manholes and the total miles of sewer lines as follow up after the inspection. No additional information was received from Walls or MWS prior to the development of the report.
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Town of Walls - Walls Wastewater Collection System Compliance Evaluation Inspection Report
Table 2. System Characteristics.
Total No. of Lift Stations Total No. of Manholes Total Miles of Lines Total No. of Significant Industrial Users Approximate Population Served Sewer Line Composition Approximate No. of SSOs per Year
7 Unknown Unknown 0 1,400 Mostly PVC, some concrete None in the past 5 years
System Site Walk
As part of the inspection process, the inspectors visually observed 4 lift stations and 2 manholes throughout the Walls collection system. A map of the lift stations and manholes that the inspectors visited is shown in Figure 1. Table 3 and Table 4 display the names, photograph numbers, locations, information, notes, and any observations that the inspectors had for the lift stations and manholes, respectively.
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Town of Walls - Walls Wastewater Collection System Compliance Evaluation Inspection Report
Figure 1. Map of the lift stations and manholes the inspectors visited during the inspection.
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Table 3. Lift Stations Visited by the Inspectors during the Inspection
Name
Library Lift Station
No. on Map
1
Photograph Numbers1
Photographs 1-4
Latitude
34.9655521
Longitude
-90.1381664
Line Size
4 in.
Type of Pump
Submersible
Perimeter
Fenced
Security
Pump access and wet well were locked
Alarms
Yes, visual only
# of Pumps
2 pumps, alternate
Observations
Erosion near the wet well; rust and corrosion inside the wet well and on the float gauges; evidence of high-water levels in the wet well
1 Refer to Appendix A, Photograph Log.
Morningside Lift Station 2 Photographs 6-9
34.9738705 -90.135916 4 in. Submersible Fenced Pump access and wet well were locked Yes, visual only 2 pumps, alternate None
Trailer Park Lift Station
3
Photographs 1012
34.9579865
-90.1497531
4 in.
Submersible
Fenced
Pump access and wet well were locked
Yes, visual only
2 pumps, alternate
None
Railroad Lift Station
4
Photographs 1316
34.9560727
-90.1532173
4 in.
Submersible
Fenced
Pump access and wet well were locked
Yes, visual only
2 pumps, alternate
Grease accumulation in the wet well
Table 4. Manholes Visited by the Inspectors During the Inspection
Name No. on Map Photograph Numbers1 Latitude Longitude Manhole Type Observations
Morningside 2 Photograph 5 34.9738705 -90.135916 Concrete None
1 Refer to Appendix A, Photograph Log.
Railroad 4 Photographs 17-18 34.9560727 -90.1532173 Concrete Gaps/cracks in the grout and concrete exterior of the manhole
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Town of Walls - Walls Wastewater Collection System Compliance Evaluation Inspection Report
Records Review
On October 24, 2024, the inspectors conducted a records review to evaluate the Town of Walls' compliance with the Clean Water Act. The inspectors reviewed the following documents onsite:
Lift station operational logs and SOPs from August 2024 to October 2024 (refer to Appendix B, Exhibit 1)
Total monthly sewer flows from October 2023 to September 2024 (refer to Appendix B, Exhibit 2)
Sewer rates for 2024 Operator certifications
Summary of Observations
The following section summarizes the inspectors' observations relative to the requirements of the Clean Water Act and operational best practices.
The inspectors requested documentation containing more detailed SOPs for the lift stations, along with the system's total number of manholes and the total miles of sewer lines for review after the inspection. The system was unable to provide these records. The inspectors observed grease accumulation in the Railroad Lift Station wet well (refer to Appendix A, Photograph 14). The inspectors observed gaps/cracks in the grout and concrete exterior of the Railroad manhole (refer to Appendix A, Photograph 17). The inspectors observed erosion near the Library Lift Station wet well (refer to Appendix A, Photograph 3). The inspectors also observed rust and corrosion inside the wet well and on the float gauges, in addition to evidence of highwater levels in the wet well (refer to Appendix A, Photograph 1).
Closing Conference
On October 24, 2024, the inspectors met with the system representatives for a closing conference and shared preliminary observations. The inspectors reiterated that all preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared were subject to further investigation by the inspectors upon the additional review of records and documentation. Additional observations may be contained in this inspection report that were not identified at the time of the closing conference after the additional review of materials following the inspection.
The inspection concluded on October 24, 2024, at approximately 1600.
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