August 3, 2010
Mayor Clayton Franklin
City of Gurdon
P.O. Box 126
Gurdon, Arkansas 71743
Re: AFIN No.: 10-00055
NPDES Permit No.: AR0022551
Dear: Mayor Franklin
On July 1, 2010, I performed a routine compliance inspection of the waste water treatment facility
and reconnaissance inspection of the waste water collection system 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 were in response to a citizen’s
complaint, alleging that a manhole had been overflowing for weeks and has contaminated Coffee
Creek. The inspections revealed the following violations:
1. There had been a significant overflow at a manhole on the line servicing the Gurdon High
School. This line has been overflowing for an undermined amount of time due to lack of
routine inspections.
2. Failure to notify the aforementioned overflow as required; this violates Part III Item 6 of the
permit. The permittee shall report all overflows with the Discharge Monitoring Report
(DMR) submittal. These reports shall be summarized and reported in tabular format. The
summaries shall include: the date, time, duration, location, estimated volume, and cause of
overflow; observed environmental impacts from the overflow; action taken to address the
overflow; and ultimate discharge location if not contained (e.g., storm sewer system, ditch,
tributary). All overflows which endanger health or the environment shall be orally reported
to this department (Enforcement Section of the Water Division), within 24 hours from the
time the permittee becomes aware of the circumstance. A written report of overflows which
endanger health or the environment shall be provided within 5 days of the time the permittee
becomes aware of the circumstance.
3. There are no operations and maintenance manuals, standard operating procedures, or
procedures for emergency treatment establish for this facility.
City of Gurdon
August 3, 2010
Page 2
4. Lack of routine maintenance and proper maintenance. Approximately 20% of the
wastewater lagoons are covered by Marsh Pennywort. The Rock Plant Filter overgrown
with various unapproved vegetation such as weeds and small trees; this violates Part II
Section B:1.a. of the permit. The permittee shall at all times properly operate and maintain
all facilities and systems of treatment and control (and related appurtenances) which are
installed or used by the permittee to achieve compliance with the conditions of this permit.
Proper operation and maintenance also includes adequate laboratory controls and
appropriate quality assurance procedures. This provision requires the operation of backup or
auxiliary facilities or similar systems which are installed by a permittee only when the
operation is necessary to achieve compliance with the conditions of the permit.
The above items require your immediate attention. Please submit a written response to these
findings to the Water Division Enforcement Section of this Department. This response should
contain documentation describing the course of action taken to correct the items noted. This
corrective action should be completed as soon as possible, and the written response is due by
August 13, 2010.
If I can be of any assistance, please contact me at 501-683-1546.
Sincerely,
Jim Mcswain
District 7 Field Inspector
Water Division
cc:
Water Division Enforcement Branch
Water Division Permits Branch
NPDES Report Page 2
ADEQ Water NPDES Inspection
AFIN: 10-00055
Permit #: AR0022551
Form Approved
OMB No. 2040-0003
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Washington, D.C. 20460
NPDES Compliance Inspection Report
Section A: National Data System Coding
Transaction Code
1
N
A 2
F 3
5
I A N R 1 0 0 0 ­ Inspection Work Days
67
2 NPDES
2 0 0 5 5 0 5 1 5 Yr/Mo/Day
12
Remarks
Facility Evaluation Rating
69
BI
1 70
1 11
71
N
0 0 7 0 1 C l a r k QA
72
Inspec. Type
17
N
18
C C o Inspector
Fac. Type
19
S
20
n t y u 1 -------------------------------Reserved-----------------------------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 Gurdon Wastewater Treatment System Entry Time/Date
9:50 A.M. 7/1/10 Permit Effective Date
10/01/08
Exit Time/Date
11:50 A.M. 7/1/10 Permit Expiration Date
9/30/2013
Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s)
Other Facility Data
James Cox – Utilities Manager – 870‐353‐2951 Name, Address of Responsible Official/Title/Phone and Fax Number
Mayor Clayton Franklin – 870‐353‐2951 P.O. Box 126
Gurdon, Arkansas 71743
Contacted
Yes
…
No
;
Section C: Areas Evaluated During Inspection
(S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated)
S
Permit
S
Records/Reports
U
U
Facility Site Review
N
N
Effluent/Receiving Waters
S
S
Flow Measurement
U
Self-Monitoring Program
N
Compliance Schedules
N
Operations & Maintenance
S
Sampling
Sludge Handling/Disposal
N
Pollution Prevention
Pretreatment
N
Multimedia
N
N
Laboratory
Storm Water
Section D: Summary of Findings/Comments (Attach additional sheets if necessary)
Other:
Inspection of this facility found it to be in a continued state of noncompliance, citing all of the violations that were documented in
the previous two inspections.
See Further Explanations, Page 8 of this report.
Name(s) and Signature(s) of Inspector(s)
Jim McSwain
Signature of Reviewer
Agency/Office/Telephone/Fax
AR Dept. of Environmental Quality – Hot Springs Field
Office – 501-520-0541 – Fax 501-520-5978
Date
Agency/Office/Phone and Fax Numbers
Date
7/28/10
NPDES Report Page 3
ADEQ Water NPDES Inspection
AFIN: 10-00055
Permit #: AR0022551
SECTION A: PERMIT VERIFICATION
PERMIT SATISFACTORILY ADDRESSES OBSERVATIONS
DETAILS:
1.
;S …M …U …NA …NE
;Y
;Y
;Y
;Y
CORRECT NAME AND MAILING ADDRESS OF PERMITTEE:
2.
NOTIFICATION GIVEN TO EPA/STATE OF NEW DIFFERENT OR INCREASED DISCHARGES:
3.
NUMBER AND LOCATION OF DISCHARGE POINTS AS DESCRIBED IN PERMIT:
4.
ALL DISCHARGES ARE PERMITTED:
…N
…N
…N
…N
…NA
…NA
…NA
…NA
…NE
…NE
…NE
…NE
SECTION B: RECORDKEEPING AND REPORTING EVALUATION
RECORDS AND REPORTS MAINTAINED AS REQUIRED BY PERMIT
DETAILS:
1.
ANALYTICAL RESULTS CONSISTENT WITH DATA REPORTED ON DMRS:
2.
SAMPLING AND ANALYSES DATA ADEQUATE AND INCLUDE:
a. DATES AND TIME(S) OF SAMPLING:
b. EXACT LOCATION(S) OF SAMPLING:
c. NAME OF INDIVIDUAL PERFORMING SAMPLING:
d. ANALYTICAL METHODS AND TECHNIQUES:
e. RESULTS OF CALIBRATIONS:
f. RESULTS OF ANALYSES:
g. DATES AND TIMES OF ANALYSES:
h. NAME OF PERSON(S) PERFORMING ANALYSES:
3.
LABORATORY EQUIPMENT CALIBRATION AND MAINTENANCE RECORDS ADEQUATE:
4.
PLANT RECORDS INCLUDE SCHEDULES, DATES OF EQUIPMENT MAINTENANCE AND REPAIR:
5.
EFFLUENT LOADINGS CALCULATED USING DAILY EFFLUENT FLOW AND DAILY ANALYTICAL DATA:
;S …M …U …NA …NE
;Y
; S …M
;Y
;Y
;Y
;Y
;Y
;Y
;Y
;Y
; S …M
; S …M
;Y
…N
…U
…N
…N
…N
…N
…N
…N
…N
…N
…U
…U
…N
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NE
…NE
…NE
…NE
…NE
…NE
…NE
…NE
…NE
…NE
…NE
…NE
…NE
SECTION C: OPERATIONS AND MAINTENANCE
TREATMENT FACILITY PROPERLY OPERATED AND MAINTAINED
DETAILS:
1.
TREATMENT UNITS PROPERLY OPERATED:
2.
TREATMENT UNITS PROPERLY MAINTAINED:
3.
STANDBY POWER OR OTHER EQUIVALENT PROVIDED:
4.
ADEQUATE ALARM SYSTEM FOR POWER OR EQUIPMENT FAILURES AVAILABLE:
5.
ALL NEEDED TREATMENT UNITS IN SERVICE:
6.
ADEQUATE NUMBER OF QUALIFIED OPERATORS PROVIDED:
7.
SPARE PARTS AND SUPPLIES INVENTORY MAINTAINED:
8.
OPERATION AND MAINTENANCE MANUAL AVAILABLE:
9.
STANDARD OPERATING PROCEDURES AND SCHEDULES ESTABLISHED:
10. PROCEDURES FOR EMERGENCY TREATMENT CONTROL ESTABLISHED:
11. HAVE BYPASSES/OVERFLOWS OCCURRED AT THE PLANT OR IN THE COLLECTION SYSTEM IN THE LAST YEAR:
12. IF SO, HAS THE REGULATORY AGENCY BEEN NOTIFIED:
13. HAS CORRECTIVE ACTION BEEN TAKEN TO PREVENT ADDITIONAL BYPASSES/OVERFLOWS:
14. HAVE ANY HYDRAULIC OVERLOADS OCCURRED AT THE TREATMENT PLANT:
15. IF SO, DID PERMIT VIOLATIONS OCCUR AS A RESULT:
…S …M ;U …NA …NE
…S
…S
…S
…S
;S
;S
…S
…M
…M
…M
;M
…M
…M
…M
…Y
…Y
…Y
;Y
…Y
…Y
…Y
…Y
;U
;U
…U
…U
…U
…U
…U
;N
;N
;N
…N
;N
;N
;N
…N
…NA
…NA
;NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
;NA
NPDES Report Page 4
…NE
…NE
…NE
…NE
…NE
…NE
;NE
…NE
…NE
…NE
…NE
…NE
…NE
…NE
…NE
ADEQ Water NPDES Inspection
AFIN: 10-00055
Permit #: AR0022551
SECTION D: SAMPLING
PERMITTEE SAMPLING MEETS PERMIT REQUIREMENTS
;S …M …U …NA …NE
DETAILS:
1.
SAMPLES TAKEN AT SITE(S) SPECIFIED IN PERMIT:
2.
LOCATIONS ADEQUATE FOR REPRESENTATIVE SAMPLES:
3.
FLOW PROPORTIONED SAMPLES OBTAINED WHEN REQUIRED BY PERMIT:
4.
SAMPLING AND ANALYSES COMPLETED ON PARAMETERS SPECIFIED IN PERMIT:
5.
SAMPLING AND ANALYSES PERFORMED AT FREQUENCY SPECIFIED IN PERMIT:
6.
SAMPLE COLLECTION PROCEDURES ADEQUATE:
a. SAMPLES REFRIGERATED DURING COMPOSITING:
b. PROPER PRESERVATION TECHNIQUES USED:
c. CONTAINERS AND SAMPLE HOLDING TIMES CONFORM TO 40 CFR 136:
7.
IF MONITORING IS PERFORMED MORE OFTEN THAN REQUIRED ARE RESULTS REPORTED ON THE DMR:
;Y
;Y
;Y
;Y
;Y
;Y
;Y
;Y
;Y
…Y
…N
…N
…N
…N
…N
…N
…N
…N
…N
;N
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NE
…NE
…NE
…NE
…NE
…NE
…NE
…NE
…NE
…NE
SECTION E: FLOW MEASUREMENT
PERMITTEE FLOW MEASUREMENT MEETS PERMIT REQUIREMENTS
DETAILS:
1.
PRIMARY FLOW MEASUREMENT DEVICE PROPERLY INSTALLED AND MAINTAINED: TYPE OF DEVICE: Parshal Flume
2.
FLOW MEASURED AT EACH OUTFALL AS REQUIRED:
3.
SECONDARY INSTRUMENTS (TOTALIZERS, RECORDERS, ETC.) PROPERLY OPERATED AND MAINTAINED:
4.
CALIBRATION FREQUENCY ADEQUATE:
5.
RECORDS MAINTAINED OF CALIBRATION PROCEDURES:
6.
CALIBRATION CHECKS DONE TO ASSURE CONTINUED COMPLIANCE:
7.
FLOW ENTERING DEVICE WELL DISTRIBUTED ACROSS THE CHANNEL AND FREE OF TURBULENCE:
8.
FLOW MEASUREMENT EQUIPMENT ADEQUATE TO HANDLE EXPECTED RANGE OF FLOW RATES:
9.
HEAD MEASURED AT PROPER LOCATION:
;S …M …U …NA …NE
;Y
;Y
;Y
;Y
;Y
;Y
;Y
;Y
;Y
…N
…N
…N
…N
…N
…N
…N
…N
…N
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NE
…NE
…NE
…NE
…NE
…NE
…NE
…NE
…NE
SECTION F: LABORATORY
PERMITTEE LABORATORY PROCEDURES MEET PERMIT REQUIREMENTS
DETAILS:
1.
EPA APPROVED ANALYTICAL PROCEDURES USED (40 CFR 136.3 FOR LIQUIDS, 503.8(B) FOR SLUDGES) :
2.
IF ALTERNATIVE ANALYTICAL PROCEDURES ARE USED, PROPER APPROVAL HAS BEEN OBTAINED:
3.
SATISFACTORY CALIBRATION AND MAINTENANCE OF INSTRUMENTS AND EQUIPMENT:
4.
QUALITY CONTROL PROCEDURES ADEQUATE:
5.
DUPLICATE SAMPLES ARE ANALYZED >10% OF THE TIME:
6.
SPIKED SAMPLES ARE ANALYZED >10% OF THE TIME:
7.
COMMERCIAL LABORATORY USED:
;S …M …U …NA …NE
;Y
…Y
;Y
;Y
;Y
;Y
;Y
…N
…N
…N
…N
…N
…N
…N
…NA
;NA
…NA
…NA
…NA
…NA
…NA
…NE
…NE
…NE
…NE
…NE
…NE
…NE
…Y
…Y
…Y
…Y
…Y
…N
…N
…N
…N
…N
…NA
…NA
…NA
…NA
…NA
;NE
;NE
;NE
;NE
;NE
a. LAB NAME: Sorrells Research
b. LAB ADDRESS: 8002 Statton Road, Little Rock, AR
c. PARAMETERS PERFORMED: pH, D.O. CBOD, TSS, Fecal, ammonia
8.
BIOMONITORING PROCEDURES ADEQUATE:
a. PROPER ORGANISMS USED:
b. PROPER DILUTION SERIES FOLLOWED:
c. PROPER TEST METHODS AND DURATION:
d. RETESTS AND/OR TRE PERFORMED AS REQUIRED:
NPDES Report Page 5
ADEQ Water NPDES Inspection
AFIN: 10-00055
Permit #: AR0022551
SECTION G: EFFLUENT/RECEIVING WATERS OBSERVATIONS
;S …M …U …NA …NE
BASED ON VISUAL OBSERVATIONS ONLY
DETAILS:
OUTFALL #:
OIL SHEEN
GREASE
TURBIDITY
VISIBLE FOAM
FLOATING SOLIDS
COLOR
OTHER
001 NO DISCHARGE SECTION H: SLUDGE DISPOSAL
SLUDGE DISPOSAL MEETS PERMIT REQUIREMENTS
DETAILS:
1.
SLUDGE MANAGEMENT ADEQUATE TO MAINTAIN EFFLUENT QUALITY:
2.
SLUDGE RECORDS MAINTAINED AS REQUIRED BY 40 CFR 503:
3.
FOR LAND APPLIED SLUDGE, TYPE OF LAND APPLIED TO: (E.G., FOREST, AGRICULTURAL, PUBLIC CONTACT SITE):
…S …M …U ;NA …NE
…S …M …U ;NA …NE
…S …M …U ;NA …NE
SECTION I: SAMPLING INSPECTION PROCEDURES
SAMPLE RESULTS WITHIN PERMIT REQUIREMENTS
DETAILS:
…Y …N …NA …NE
1.
SAMPLES OBTAINED THIS INSPECTION:
2.
TYPE OF SAMPLE:
3.
SAMPLES PRESERVED:
4.
FLOW PROPORTIONED SAMPLES OBTAINED:
5.
SAMPLE OBTAINED FROM FACILITY'S SAMPLING DEVICE:
6.
SAMPLE REPRESENTATIVE OF VOLUME AND NATURE OF DISCHARGE:
…GRAB:
…COMPOSITE:
…S …M …U …NA ;NE
METHOD:
7.
SAMPLE SPLIT WITH PERMITTEE:
8.
CHAIN-OF-CUSTODY PROCEDURES EMPLOYED:
9.
SAMPLES COLLECTED IN ACCORDANCE WITH PERMIT:
FREQUENCY:
…Y
…Y
…Y
…Y
…Y
…Y
…Y
…N
…N
…N
…N
…N
…N
…N
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NE
…NE
…NE
…NE
…NE
…NE
…NE
SECTION J: STORM WATER POLLUTION PREVENTION PLAN
STORM WATER MANAGEMENT MEETS PERMIT REQUIREMENTS
DETAILS:
1.
SWPPP UPDATED AS NEEDED:
DATE OF LAST UPDATE:
2.
SITE MAP INCLUDING ALL DISCHARGES AND SURFACE WATERS:
3.
POLLUTION PREVENTION TEAM IDENTIFIED:
4.
POLLUTION PREVENTION TEAM PROPERLY TRAINED:
5.
LIST OF POTENTIAL POLLUTANT SOURCES:
6.
LIST OF POTENTIAL SOURCES AND PAST SPILLS AND LEAKS:
7.
ALL NON-STORM WATER DISCHARGES ARE AUTHORIZED:
8.
LIST OF STRUCTURAL BMPS:
9.
LIST OF NON-STRUCTURAL BMPS:
10.
BMPS PROPERLY OPERATED AND MAINTAINED:
11.
INSPECTIONS CONDUCTED AS REQUIRED:
…S …M …U …NA ;NE
…Y
…Y
…Y
…Y
…Y
…Y
…Y
…Y
…Y
…Y
…Y
…N
…N
…N
…N
…N
…N
…N
…N
…N
…N
…N
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
…NA
NPDES Report Page 6
…NE
…NE
…NE
…NE
…NE
…NE
…NE
…NE
…NE
…NE
…NE
ADEQ Water NPDES Inspection
AFIN: 10-00055
Permit #: AR0022551
NPDES Compliance Inspection Report
Further Explanation
Section C, Items 1&2: Approximately 25% of the lagoons are covered with vegatation. Approximately 70% of the Rock Plant Filters is covered with unapproved vegetation such as grasses, weeds, and small trees. Section C, Items 8,9,10: There is not a O&M manual available. There are no SOP's developed for this facility, and there is not a documented procedure for emergency treatment control. Section C, Items 11&12: The SSO inspection revealed that there was a manhole overflow on the line coming from the Gurdon High School. This overflow had been occurring for an indeterminate period. However, it was significant. The overflow was in a low area behind the Baseball Fields along Coffee Creek. There were several thousand gallons visible on the ground at the site of the overflow. It appeared to be a blockage in the line. The pump station on this line appeared to be functioning properly. This exact manhole was documented overflowing on 4/12/06 and 9/17/07. During that inspection, Mr. Cox was instructed to implement routine inspections of the collection system in order to prevent such an overflow to occur for a significant amount of time such as the one documented. This obviously has not occurred. To date this overflow has not been reported to this agency as required. NPDES Report Page 7
ADEQ Water NPDES Inspection
AFIN: 10-00055
Permit #: AR0022551
Water Division NPDES Photographic Evidence Sheet
Location:
City of Gurdon’s wastewater ponds
Photographer:
Photo #
1
Jim McSwain
Of
4
Description:
Photo of the vegetation in the lagoon.
Photographer:
Jim McSwain
Photo #
Description:
2
Of
4
Witness:
Date:
7/1/10
Witness:
Date:
7/1/10
Photo of the vegetation in the lagoon.
NPDES Report Page 8
ADEQ Water NPDES Inspection
AFIN: 10-00055
Permit #: AR0022551
Water Division NPDES Photographic Evidence Sheet
Location:
City of Gurdon’s Rock Plant Filters
Photographer:
Photo #
3
Jim McSwain
Of
4
Witness:
Date:
7/1/10
Description:
Photo of the Rock Plant Filter – Completely covered with weeds.
Photographer:
Jim McSwain
Photo #
Description:
4
Of
4
Witness:
Date:
7/1/10
Photo of the Rock Plant Filter – Completely covered with weeds.
NPDES Report Page 9
ADEQ Water NPDES Inspection
AFIN: 10-00055
Permit #: AR0022551
Form Approved
OMB No. 2040-0003
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Washington, D.C. 20460
NPDES Compliance Inspection Report
Section A: National Data System Coding
Transaction Code
1
N
2
A F 5
I A 3
N R 0 0 2 1 0 ­ 0 Inspection Work Days
67
1
NPDES
Yr/Mo/Day
2 5 5 1 11
0 0 5 5 Facility Evaluation Rating
70
69
12
1 Remarks
BI
1 71
N
0 0 6 3 0 17
18
R C l a r k C o QA
72
Inspec. Type
N
Inspector
Fac. Type
19
S
20
n t y u 1 -------------------------------Reserved-----------------------------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 Gurdon Wastewater Collection System – SSO Inspection Entry Time/Date
12:20 P.M. 6/30/10 Permit Effective Date
10/1/08
Exit Time/Date
1:30 P.M. 6/30/10 Permit Expiration Date
9/30/13
Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s)
Other Facility Data
N/A Name, Address of Responsible Official/Title/Phone and Fax Number
Mayor Clayton Franklin – 870‐353‐2952 P.O. Box 126
Gurdon, Arkansas 71743
Contacted
Yes
…
No
;
Section C: Areas Evaluated During Inspection
(S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated)
N
Permit
N
Flow Measurement
U
Operations & Maintenance
N
Sampling
N
Records/Reports
N
Self-Monitoring Program
N
Sludge Handling/Disposal
N
Pollution Prevention
N
Facility Site Review
N
Compliance Schedules
N
Pretreatment
N
Multimedia
Effluent/Receiving Waters
N
U
Other: SSO
N
N
Laboratory
Storm Water
Section D: Summary of Findings/Comments (Attach additional sheets if necessary)
This SSO inspection revealed that there was a manhole overflow on the line coming from the Gurdon High School. This overflow had been occurring for an indeterminate period. However, it was significant. The overflow was in a low area behind the Baseball Fields along Coffee Creek. There were several thousand gallons visible on the ground at the site of the overflow. It appeared to be a blockage in the line. The pump station on this line appeared to be functioning properly. This exact manhole was documented overflowing on 4/12/06 and 9/17/07. During that inspection, Mr. Cox was instructed to implement routine inspections of the collection system in order to prevent such an overflow to occur for a significant amount of time such as the one documented. This obviously has not occurred. Name(s) and Signature(s) of Inspector(s)
Jim McSwain
Signature of Reviewer
Agency/Office/Telephone/Fax
AR Dept. of Environmental Quality – Hot Springs Field
Office – 501-520-0541 – Fax 501-520-5978
Date
Agency/Office/Phone and Fax Numbers
Date
7/28/10
NPDES Report Page 11
ADEQ Water NPDES Inspection
AFIN: 10-00055
Permit #: AR0022551
Water Division NPDES Photographic Evidence Sheet
Location:
City of Gurdon – Sewer Line servicing the high school. Location is behind the baseball fields.
Photographer:
Photo #
1
Jim McSwain
Of
2
Witness:
Date:
6/30/10
1240
Description:
Manhole overflow – Path is flooded for more than 200 feet. Eventually enters Coffee Creek.
Photographer:
Jim McSwain
Photo #
Description:
2
Of
2
Witness:
Date:
6/30/10
1229
Coffee Creek approximately ¼ mile downstream of the overflow.
NPDES Report Page 12
October 7, 2010
Honorable Clayton Franklin, Mayor
City of Gurdon
P.O. Box 126
Gurdon, AR 71743
RE: AFIN: 10-00055
Permit No.: AR0022551
Dear Mayor Franklin:
The Department has received your response to the July 1, 2010 inspection of your
facility by our District Field Inspector, Jim McSwain. Your letter appears to adequately
address the discrepancies identified during the visit. The Department assumes the
corrective actions taken will be maintained to ensure consistent compliance with the
requirements of the permit. Acceptance of this response by the Department does not
preclude any future enforcement action deemed necessary at this site or any other site.
The Department will keep the inspection and response on file. If future violations occur
that require enforcement action, the Department will consider the inspection and
response as required by the Pollution Control and Ecology Commission Regulation No.
7, Civil Penalties. This regulation requires the Department to consider the past history
of your site and how expeditiously the violations were addressed in determining any civil
penalty that may be necessary for any future violations.
If we need further information concerning this matter, we will contact you. Thank you for
your attention to this matter. Should you have any questions, feel free to contact me at
501-682-0633 or you may e-mail me at schluterman@adeq.state.ar.us.
Sincerely,
Amy Schluterman
Enforcement Analyst
Water Division Enforcement Branch
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