AFIN: 30-00103 NPDES Permit No.: AR0048020

July 16, 2012 Honorable Mitchell D. Burnett Mayor, Town of Donaldson P.O. Box 127 Donaldson, AR 71941 AFIN: 30-00103 NPDES Permit No.: AR0048020

Dear Mayor Burnett: On June 27, 2012 and July 9, 2012; I performed a reconnaissance inspection of the waste water treatment facility. On July 9, 2012, Loretta Reiber, P.E, Engineer, NPDES Permits Branch, ADEQ Water Division was in attendance. The inspection was conducted in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. These inspections revealed the following violations:

1) The lack of a pond level (staff) gauge in the 6-acre lagoon does not meet the standards in the Recommended Standards for Wastewater Facilities (10-States Standards) which was adopted by the Arkansas Pollution Control and Ecology Commission in Minute Order 80-21. The Arkansas Water and Air Pollution Control Act (A.C.A § 8-4-217(a)(3)) makes it unlawful to violate any Order by the Commission.

2) Minimal vegetation was documented in the constructed wetlands portion of the

wastewater treatment facility. This is a violation of Part II.B.1.a of the permit. Please contact Loretta Reiber, P.E.; NPDES Permits Branch, ADEQ Water Division at 501-682-0612 regarding the permitting requirements associated with the design of the waste water treatment facility.

3) The Department does not have documentation that the operator of the waste water

treatment facility is licensed as a Class II by the State of Arkansas in accordance with Part III.1 of the permit.

4) Erosion was observed on the retention pond embankments. This is a violation of

Part II.B.1.A of the permit.

5) Flow measurement data requested at the time of inspection and subsequently submitted for May 2012 indicates that there was no discharge from the waste water treatment facility for May 2012 (see Page 7). Flow measurement documentation illustrating that instantaneous flow readings (5x per week) as required by Part I.A of the permit (effluent limitations and monitoring requirements) was not submitted.

ADEQ Water NPDES Inspection AFIN: 30-00103 Permit #: AR0048020

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Please be aware that instantaneous flow readings illustrating that flow (or lack of) is being documented at the frequency specified in the permit (5x per week) is required to be maintained.

The above items require your immediate attention. Please submit a written response to these findings to the Water Division Inspection Branch of this Department. This response should be mailed to the address at the bottom of the first page of the letter or e-mailed to [email protected]. This response should contain documentation describing the course of action taken to correct each item noted. This corrective action should be completed as soon as possible, and the written response with all necessary documentation (i.e. photos) is due by July 30, 2012. If I can be of any assistance, please contact me 501-682-0658 or [email protected]. Sincerely,

Risa Parker District 9 Inspector Water Division

mailto:[email protected]



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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Washington, D.C. 20460

NPDES Compliance Inspection Report

Form Approved

OMB No. 2040-0003

Section A: National Data System Coding

Transaction Code

NPDES

Yr/Mo/Day

Inspec. Type

Inspector

Fac. Type

1 N 2 5 3 A R 0 0 4 8 0 2 0 11 12 1 2 0 7 0 9 17 18 R 19 S 20 1

Remarks

A F I N 3 0 - 0 0 1 0 3

Inspection Work Days

Facility Evaluation Rating

BI

QA

-------------------------------Reserved------------------------------

67

69

70 N

71

N

72

N

73

74

75

80

Section B: Facility Data Name and Location of Facility Inspected (For industrial users discharging to POTW, also

include POTW name and NPDES permit number)

City of Donaldson-from NLR office travel on I-30 to Malvern; go west

on Hwy 67 to Donaldson; turn left on N. Division Street; travel on N.

Division under Hwy 67 bridge; facility is on both sides of the road past

residential area.

Entry Time/Date

9:30 am on 7/9/12

Permit Effective Date

September 1, 2007 Exit Time/Date

10:30 am on 7/9/12

Permit Expiration Date

August 31, 2012 Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s)

Mitchell D. Burnett, Mayor, Town of Donaldson

Other Facility Data

Inspected site on 6/27/2; arrived at

12:30 pm and exited at 1:30 pm.

PDS #066764

Name, Address of Responsible Official/Title/Phone and Fax Number

Honorable Mitchell D. Burnett

Mayor, Town of Donaldson

P.O. Box 127

Donaldson, AR 71941

Contacted

Yes No

Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated)

S Permit U

Flow Measurement U

Operations & Maintenance N

Sampling

U Records/Reports N

Self-Monitoring Program N

Sludge Handling/Disposal N

Pollution Prevention

U Facility Site Review N

Compliance Schedules N

Pretreatment N

Multimedia

N Effluent/Receiving Waters N

Laboratory N

Storm Water N

Other:

Section D: Summary of Findings/Comments (Attach additional sheets if necessary)

Please see Page 4 below for a summary of findings/comments.

Name(s) and Signature(s) of Inspector(s)

Risa Parker/

Agency/Office/Telephone/Fax

ADEQ Water Division/ 501-682-0658/501-682-0910

Date

July 12, 2012

Signature of Reviewer

Agency/Office/Phone and Fax Numbers

Date


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NPDES Compliance Inspection Report

Further Explanation

1) The lack of a pond level (staff) gauge in the 6-acre lagoon does not meet the standards in the Recommended Standards for Wastewater Facilities (10-States Standards) which was adopted by the Arkansas Pollution Control and Ecology Commission in Minute Order 80-21. The Arkansas Water and Air Pollution Control Act (A.C.A § 8-4-217(a)(3)) makes it unlawful to violate any Order by the Commission.

2) Minimal vegetation was documented in the constructed wetlands portion of the

wastewater treatment facility. This is a violation of Part II.B.1.a of the permit. Please contact Loretta Reiber, P.E.; NPDES Permits Branch, ADEQ Water Division at 501-682-0612 regarding the permitting requirements associated with the design of the waste water treatment facility.

3) The Department does not have documentation that the operator of the waste water

treatment facility is licensed as a Class II by the State of Arkansas in accordance with Part III.1 of the permit.

4) Erosion was observed on the retention pond embankments. This is a violation of

Part II.B.1.A of the permit.

5) Flow measurement data requested at the time of inspection and subsequently submitted for May 2012 indicates that there was no discharge from the waste water treatment facility for May 2012 (see Page 7). Flow measurement documentation illustrating that instantaneous flow readings (5x per week) as required by Part I.A of the permit (effluent limitations and monitoring requirements) was not submitted. Please be aware that instantaneous flow readings illustrating that flow (or lack of) is being documented at the frequency specified in the permit (5x per week) is required to be maintained.


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Water Division NPDES Photographic Evidence Sheet

Location: City of Donaldson WWTP

Photographer: Risa Parker, ADEQ Water Division Witness: None

Photo # 1 Of 4 Date: 6/27/12 Time: 12:39 pm

Description: Minimal vegetation in constructed wetlands portion of wastewater treatment facility.



Description: Minimal vegetation in constructed wetlands portion of wastewater treatment facility.


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Water Division NPDES Photographic Evidence Sheet

Location: City of Donaldson WWTP



Description: Evidence of erosion on the retention pond embankment.


Description: Evidence of erosion on the retention pond embankment.


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August 3, 2012 Honorable Mitchell D. Burnett Mayor, Town of Donaldson P.O. Box 127 Donaldson, AR 71941 AFIN: 30-00103; NPDES Permit No.: AR0048020 Dear Mayor Burnett: Thank you for your response to my July 9, 2012 inspection of the above-referenced facility. As we discussed via telephone on August 2, 2012; additional information is required to sufficiently address the violations referenced in my inspection report.

1) Facility Response: “We will obtain and install a pond level (staff) gauge as soon an as we can locate a supplier and make the necessary arrangements.

ADEQ Water Division-Inspection Branch Response: Please specify a date by which corrective action will be completed.

Facility Response: “We are awaiting assistance from our engineer regarding vegetation in the constructed wetlands portion of the wastewater treatment facility.”

ADEQ Water Division-Inspection Branch Response: The ADEQ Water Division Inspection Branch recognizes that the Town of Donaldson is currently in the process of determining the methodology which will be utilized to address the violation. Tim Lemons, P.E. (Lemons Engineering Consulting, Inc.) has contacted the ADEQ Water Division Permits Branch on behalf of the Town of Donaldson regarding the permit requirements associated with the constructed wetlands portion of the wastewater treatment facility. In your written response to this letter, please specify the methodology which will be utilized to address the violation; and, the date by which corrective action will be initiated and subsequently completed.

2) Facility Response: “We are seeking proposals from local contractors to

cover the eroded areas on the retention pond embankments with clay gravel.”

ADEQ Water Division-Inspection Branch Response: Please specify a date by which corrective action will be completed.

The above items require your immediate attention. Please submit a written response to these findings to the Water Division Inspection Branch of this Department. This response should be mailed to the address at the bottom of the first page of the letter or e-mailed to [email protected]. This response should contain documentation describing the course of action taken to correct each item noted. This corrective action should be completed as soon as possible, and the written response with all necessary documentation (i.e. photos) is due by August 17, 2012. If I can be of any assistance, please contact me 501-682-0658 or [email protected]. Sincerely,

Risa Parker District 9 Inspector Water Division



October 30, 2012 Honorable Mitchell D. Burnett, Mayor Town of Donaldson P.O. Box 127 Donaldson, AR 71941 RE: Response to Inspection

AFIN: 30-00103, NPDES Permit No.: AR0048020 Dear Mayor Burnett: I am in receipt of your inspection report response dated August 17, 2012. The information received does not sufficiently address the violations referenced in my inspection report. Specifically, Violation # 2 of my inspection report dated July 16, 2012, stated that minimal vegetation was documented in the constructed wetlands portion of the wastewater treatment facility, in violation of Part II.B.1.a of the permit.

In a meeting held on September 6, 2012, the Town of Donaldson, Lemons Engineering Consultants, Inc., and representatives of the ADEQ Water Division (Permits Branch, Inspection Branch, and Enforcement Branch) discussed the permit requirements associated with vegetation in the constructed wetlands portion of the wastewater treatment facility. As a result of the meeting, information pertaining to the operation of the wastewater treatment facility and the lack of wetland vegetation in the constructed wetlands portion of the wastewater treatment facility was to be submitted to the ADEQ Water Division Permits Branch by September 20, 2012. As of the date of this letter, the information has not been received. A deadline of November 8, 2012 has been established for submittal of the information requested by the ADEQ Water Division Permits Branch during the meeting. Additionally, this has been referred to the ADEQ Water Division Enforcement Branch for review. If I can be of any assistance, please contact me 501-682-0658 or [email protected]. Sincerely,

Risa Parker District 9 Inspector Water Division cc: Loretta Reiber, Engineer, ADEQ Water Division Permits Branch Michelle Bolenbaugh, Enforcement Analyst, ADEQ Water Division Enforcement Branch


Documents

AFIN: 30-00103 NPDES Permit No.: AR0048020