September 4, 2013 Linda Mayhood, Interim General Manager Hot
Transcription
September 4, 2013 Linda Mayhood, Interim General Manager Hot
September 4, 2013 Linda Mayhood, Interim General Manager Hot Springs Village POA 895 DeSoto Blvd. Hot Springs Village, AR 71909 Re: Compliance Inspection (Garland & Saline Co) AFIN: 26-00105 NPDES Permit No.: AR0039284 63-00883 ARG640089 Dear Ms. Mayhood: On August 22, 2013 I performed a routine compliance inspection of the Cedar Creek wastewater treatment facility and the water treatment plant wastewater facility in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. This inspection revealed the following violations: AR0039284 1. The grit removal system including the paddle drive and motor and the bar screen rake is out of service due to excessive corrosion. These treatment units should be replaced or repaired as soon as possible. This is a violation of Part III, Section B, 1, A of the permit. 2. At the time of the inspection, one of the two aerators in one of the two digesters was out of service. This treatment unit should be replaced or repaired as soon as possible. This is a violation of Part III, Section B, 1, A of the permit. 3. Chloride, Sulfate and TDS are being collected as a composite. The permit requires that these samples be collected as a grab sample. This is a violation of Part 1A, Section A of the permit. 4. Sample preservation is not being documented in the facility’s records. Typically this is noted on the Chain of Custody (COC) forms. This is a violation of Part III, Section C, 3 of the permit. 5. The biomonitoring results indicate a dilution series of 32%, 42%, 56%, 80% and 100%. The permit requires 32%, 45%, 56%, 80% and 100%. This is a violation of Part II, 10.1.a of the permit. Hot Springs Village POA Page 2 ARG640089 1. The facility performs their own sampling and analysis of pH, TRC and Dissolved Aluminum. Missing from the onsite records are the sample date, sample time, name or initials of sampler, analyses date, analyses time, name or initials of analyst and the sample location. This is a violation of Part 6.8 of the permit. 2. Excessive sludge has accumulated in the treatment pond. No sludge storage capacity was available and sludge was observed being discharged to the receiving stream. Additionally, excessively tall vegetation, specifically trees, has grown up on the interior banks of the pond levees. This is a violation of Part 2.1 and 5.1 of the permit. 3. The facility is referencing HACH Method 8012 for analyzing Dissolved Aluminum. This is not an approved method. This is a violation of Part 6.3 of the permit. 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 below, or e-mailed to Water-Inspection-report@adeq.state.ar.us. 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 documentations (i.e. photos) is due by September 18, 2013. If I can be of any assistance, please contact me at 870 389-6970. Sincerely, Shan Lynch District 7 Field Inspector Water Division NPDES Report Page 2 ADEQ Water NPDES Inspection AFIN: 26-00105 Permit #: AR0039284 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 5 NPDES 3 A R 0 0 3 9 Yr/Mo/Day 2 8 4 11 1 12 3 0 8 Inspec. Type 2 2 17 18 Inspector C 19 S Fac. Type 20 1 Remarks Inspection Work Days 67 Facility Evaluation Rating 70 69 BI 3 71 QA N 72 N -------------------------------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) Hot Springs Village POA – Cedar Creek WWTP at 198 Cortez Road in Hot Springs Village Entry Time/Date 0917 / 8-22-2013 Permit Effective Date November 1, 2010 Exit Time/Date 1210 / 8-22-2013 Permit Expiration Date October 31, 2015 Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) Billy Graves / Water & Wastewater Superintendent / 501 922-5523 Charles Hicks / Chief Operator / 501 922-1620 Kurtis Richardson / Operator / 501 922-1620 Other Facility Data Minor mun. Name, Address of Responsible Official/Title/Phone and Fax Number PDS# 073342 Contacted Linda Mayhood / Interim General manager / 501 922-5531 895 DeSoto Blvd. Hot Springs Village, AR 71909 Yes No Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated) S Permit S Records/Reports S S Facility Site Review N S Effluent/Receiving Waters S Flow Measurement M Self-Monitoring Program S Compliance Schedules N Operations & Maintenance M Sampling Sludge Handling/Disposal N Pollution Prevention Pretreatment N Multimedia M N N Laboratory Storm Water Other: Section D: Summary of Findings/Comments (Attach additional sheets if necessary) Sec. C, 2 – The grit removal system including the paddle drive and motor and the bar screen rake is out of service due to excessive corrosion. These treatment units should be replaced or repaired as soon as possible. Sec. C, 2 – At the time of the inspection, one of the two aerators in one of the two digesters was out of service. This treatment unit should be replaced or repaired as soon as possible. Sec. D, 6 – Chloride, Sulfate and TDS is being collected as a composite. The permit requires that these samples be collected as a grab sample. Sec. C, 6, b – Sample preservation is not being noted on the COC forms. Sec. F, 8, b – The biomonitoring results indicate a dilution series of 32%, 42%, 56%, 80% and 100%. The permit requires 32%, 45%, 56%, 80% and 100%. Name(s) and Signature(s) of Inspector(s) Agency/Office/Telephone Date Shan Lynch ADEQ / Dist. 7 / (870) 389-6970 August 23, 2013 Signature of Reviewer Agency/Office/Phone and Fax Numbers ADEQ / NLR / 501-682-0642 Date September 4, 2013 Kerri McCabe NPDES Report Page 3 ADEQ Water NPDES Inspection AFIN: 26-00105 Permit #: AR0039284 SECTION A: PERMIT VERIFICATION PERMIT SATISFACTORILY ADDRESSES OBSERVATIONS DETAILS: S M U NA NE Y Y Y Y 1. 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: 26-00105 Permit #: AR0039284 SECTION D: SAMPLING S M U NA NE PERMITTEE SAMPLING MEETS PERMIT REQUIREMENTS 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: 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: TYPE OF DEVICE: weir 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: 8. S M U NA NE Y Y Y Y Y Y Y N N N N N N N a. LAB NAME: American Interplex Corp. b. LAB ADDRESS: 8600 Kanis Rd.; Little Rock, AR 72204 c. PARAMETERS PERFORMED: CBOD, TSS, NH3-N, FCB, Total Recoverable Copper, TP, NO3 + NO2 - N, Chloride, Sulfate, TDS, biomonitoring 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: Y Y Y Y Y N N N N N NA NA NA NA NA NA NA NE NE NE NE NE NE NE NA NA NA NA NA NE NE NE NE NE NPDES Report Page 5 ADEQ Water NPDES Inspection AFIN: 26-00105 Permit #: AR0039284 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 none none none none none clear NA 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: 26-00105 Permit #: AR0039284 FLOW CALCULATION SHEET Date: 8-22-2013 Head in Inches: Time: 1030 0.78 Feet: 0.8683 Type & Size of Primary Flow Measurement Device: 90o V-notch weir Name & Model of Secondary Flow Measurement Device: Siemens HydroRanger 200 Date of last Calibration of Secondary Flow Device: 8-9-2013 Recorded Flow at Date & Time Listed Above: Calculated Flow at Date & Time Listed Above: 0.89 MGD (Facility Flow Meter) 0.8683 MGD (Flow is calculated using flow charts in: ISCO Open Channel Flow Measurement Handbook-5th Edition) % Error = % Error = Recorded Value - Calculated Value Calculated Value 0.89 0.8683 % Error = 0.217 0.8683 X 100 % Error = 0.249 X 100 % Error = 2.49 % 0.8683 X 100 X 100 Comments: NPDES Report Page 7 ADEQ Water NPDES Inspection AFIN: 26-00105 Permit #: AR0039284 DMR Calculation Check Reporting Period: Parameter Checked: From 13 Year 05 Month 01 Day To 13 Year 05 Month 31 Day CBOD Loading Mass Mo. Avg. - lbs/day Concentration Monthly Mo. Avg. - mg/l 7-day Avg. - mg/l Reported Value: 7.7 2.0 2.0 Calculated Value: 7.7 2.0 2.0 Permit Value: 83.4 10.0 15.0 If calculated value does not equal reported value, explain: same NPDES Report Page 8 McCabe, Kerri From: Sent: To: Subject: McCabe, Kerri Thursday, September 19, 2013 8:06 AM McCabe, Kerri FW: Hot Springs Village - Compliance Inspection 8-22-13, AFIN: 26-00105 63-00883, ARG0039284 ARG640089 From: Jason Temple [mailto:jtemple@hsvpoa.org] Sent: Tuesday, September 17, 2013 7:50 PM To: Lynch, Shan Subject: Hot Springs Village - Compliance Inspection 8-22-13, AFIN: 26-00105 63-00883, ARG0039284 ARG640089 Mr. Lynch, The following are my interim responses to the reference Compliance Inspection report dated September 4, 2013. AR0039284 Response #1 – The grit removal system motor is being replaced and the gear box will be evaluated and replaced if needed to bring the unit on line. The bar screen rake is being rebuilt out of stainless steel. Response #2 – The digester aerator motor has shorted out and was sent to be rewound on 8‐12‐13. Response #3 – Grab samples per the permit will be taken for Chloride, Sulfate, and TDS beginning on the next round of sampling in October. Response #4 – Documentation of the sample preservation will be documented on the Chain of Custody form. Response #5 – The lab will use 45% dilution instead of 42% on the biomonitoring test beginning in October. 1 ARG640089 Response #1 – In house sampling records will include the sample date, time, name or initials of sampler, analyses date, analysis time, name or initials of analyst, and sample location on future in house testing. Response #2 – The clearing of the trees and vegetation around the sludge pond will be completed in September 2013. Evaluation of the existing sludge volumes for removal, dewatering, and disposal by land application of Water Treatment Residuals by General Permit No. 0000‐WG‐WR or to the Saline County land fill are currently being determined. Please note the receiving stream drains back to the reservoir for a closed system. None of the floating polymers you saw discharging leave the property and remain within the water treatment system. Response #3 – the testing for dissolved aluminum will be conducted by a licensed third party testing lab and in accordance with the permitted approved method. Upon completion of the repairs noted above, photos and further documentation will be sent. Thank you for assistance in bringing these deficiencies to our attention. Jason Charles Temple, PE Director of Public Works Hot Springs Village 895 DeSoto Blvd, HSV, AR 71909 (O) 501.922.5528, (F) 501.922.5017 Email: jtemple@hsvpoa.org Web: www.hsvpoa.org 2 September 27, 2013 Linda Mayhood, Interim General Manager Hot Springs Village POA 895 DeSoto Blvd. Hot Springs Village, AR 71909 Re: Response to Inspection (Garland and Saline Co) AFIN: 26-00105 NPDES Permit No.: AR0039284 63-00883 ARG640089 Dear Ms. Mayhood: I have reviewed the response pertaining to my August 22, 2013 inspections of the Hot Springs Village Cedar Creek wastewater treatment facility and the Hot Springs Village water treatment facility. The information provided sufficiently addresses the violations referenced in my inspection report. At this time, the Department has no further comment concerning this particular inspection. Acceptance of this response by the Department does not preclude any future enforcement action deemed necessary at this site or any other site. 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 870 389-6970 or you may e-mail me at lynch@adeq.state.ar.us. Sincerely, Shan Lynch District 7 Field Inspector Water Division McCabe, Kerri From: Sent: To: Subject: Attachments: Lynch, Shan Monday, September 30, 2013 9:37 AM McCabe, Kerri FW: Hot Springs Village - Compliance Inspection 8-22-13, AFIN: 26-00105 63-00883, ARG0039284 ARG640089 WP_20130925_004.jpg Here’s a photo you can attach to the HSV water plant inspection. ARG640089. Not sure of the water ID#. Also, since he’s having trouble with our e‐mail address, I told him that he can send any correspondence directly to me and that I’d forward it on to the main office. From: Jason Temple [mailto:jtemple@hsvpoa.org] Sent: Thursday, September 26, 2013 10:54 AM To: Lynch, Shan Cc: 'Billy Graves'; 'Linda Mayhood'; Water-Inspection-report@adeq.state.ar Subject: RE: Hot Springs Village - Compliance Inspection 8-22-13, AFIN: 26-00105 63-00883, ARG0039284 ARG640089 Shan, We are still in progress with the repairs. Started the clearing around the sludge pond at the water plant per the picture attached. The email address Water‐Inspection‐report@adeq.state.ar did not work. Should it all be lower case? Would you like me to use your email address or the other for future email correspondences. Thank you for the reply. Jason Charles Temple, PE Director of Public Works Hot Springs Village 895 DeSoto Blvd, HSV, AR 71909 (O) 501.922.5528, (F) 501.922.5017 1 Email: jtemple@hsvpoa.org Web: www.hsvpoa.org From: Lynch, Shan [mailto:LYNCH@adeq.state.ar.us] Sent: Thursday, September 26, 2013 9:33 AM To: 'Jason Temple' Subject: RE: Hot Springs Village - Compliance Inspection 8-22-13, AFIN: 26-00105 63-00883, ARG0039284 ARG640089 Mr. Temple, I will be sending an adequate response letter in regards to the inspections, but, will still want some correspondence when the repairs and corrections are finalized. Thanks, Shan Lynch From: Jason Temple [mailto:jtemple@hsvpoa.org] Sent: Tuesday, September 17, 2013 7:50 PM To: Lynch, Shan Subject: Hot Springs Village - Compliance Inspection 8-22-13, AFIN: 26-00105 63-00883, ARG0039284 ARG640089 Mr. Lynch, The following are my interim responses to the reference Compliance Inspection report dated September 4, 2013. AR0039284 Response #1 – The grit removal system motor is being replaced and the gear box will be evaluated and replaced if needed to bring the unit on line. The bar screen rake is being rebuilt out of stainless steel. Response #2 – The digester aerator motor has shorted out and was sent to be rewound on 8‐12‐13. Response #3 – Grab samples per the permit will be taken for Chloride, Sulfate, and TDS beginning on the next round of sampling in October. Response #4 – Documentation of the sample preservation will be documented on the Chain of Custody form. 2 Response #5 – The lab will use 45% dilution instead of 42% on the biomonitoring test beginning in October. ARG640089 Response #1 – In house sampling records will include the sample date, time, name or initials of sampler, analyses date, analysis time, name or initials of analyst, and sample location on future in house testing. Response #2 – The clearing of the trees and vegetation around the sludge pond will be completed in September 2013. Evaluation of the existing sludge volumes for removal, dewatering, and disposal by land application of Water Treatment Residuals by General Permit No. 0000‐WG‐WR or to the Saline County land fill are currently being determined. Please note the receiving stream drains back to the reservoir for a closed system. None of the floating polymers you saw discharging leave the property and remain within the water treatment system. Response #3 – the testing for dissolved aluminum will be conducted by a licensed third party testing lab and in accordance with the permitted approved method. Upon completion of the repairs noted above, photos and further documentation will be sent. Thank you for assistance in bringing these deficiencies to our attention. Jason Charles Temple, PE Director of Public Works Hot Springs Village 895 DeSoto Blvd, HSV, AR 71909 (O) 501.922.5528, (F) 501.922.5017 Email: jtemple@hsvpoa.org Web: www.hsvpoa.org 3