Document 1gdqmjMzL8v5Dy1J8E0OLr6bX

EPA Inspection Report - Page 1 of 21 Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 04/11/2019 Water CWA - NPDES Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Cuba, Village of Village of Cuba Wastewater Treatment Plant Mile Marker 2 on NMSR 197 Cuba, NM 87013 P.O. Box 426 Cuba, NM 87013 Sandoval County Richard Velarde Mayor mayorvelarde@gmail.com FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110009831156 NM0024848 221320 4952 Personnel participating in inspection: Amy Andrews, P.E. USEPA/6EN-WMH Barbara Cooney NMED-GWQB Esther Herrera Cuba, Village of Levi Casaus Paul Chavez Cuba, Village of New Mexico Rural Water Association Environmental Engineer Environmental Specialist Clerk / Water & Sewer Department Supervisor Wastewater Operator Wastewater Operator 214-907-0638 505-827-0212 575-289-2020 575-289-2020 505-884-1031 EPA Lead Inspector Signature/Date Supervisor Signature/Date AMY ANDREWS Amy Andrews Digitally signed by AMY ANDREWS DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=AMY ANDREWS, 0.9.2342.19200300.100.1.1=68001003655888 Date: 2019.06.06 10:09:34 -06'00' Date CAROL PETERS-WAGNON Digitally signed by CAROL PETERS-WAGNON DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=CAROL PETERS-WAGNON, 0.9.2342.19200300.100.1.1=68001003652679 Date: 2019.06.06 17:04:02 -05'00' Carol Peters Date 6ENFORM-019-R7 (2/15/2017) 1 EPA Inspection Report - Page 2 of 21 Section I - INTRODUCTION Cuba, Village of, Wastewater Treatment Plant Inspection Date 4/11/2019 PURPOSE OF THE INSPECTION Environmental Protection Agency (EPA) Region 6 inspector Amy Andrews, and New Mexico Environment Department inspector, Barbara Cooney, arrived at the Village of Cuba Wastewater Treatment Plant at 10:25 am on April 11, 2019 for an unannounced inspection. We met with Esther Herrera, Village of Cuba Clerk/Water and Wastewater Department Supervisor; Levi Casaus, Village of Cuba Wastewater Operator; and Paul Chavez, New Mexico Rural Water Association Wastewater Operator. I presented my credentials to Ms. Herrera and informed her that this was an EPA inspection to determine compliance with the facility's National Pollutant Discharge Elimination System (NPDES) permit and the Clean Water Act (CWA). The inspection was conducted under the authority of the NPDES permit program, in accordance with the Federal CWA. This report is based on information supplied by Village of Cuba representatives (the permittee), observations made by the EPA inspector, and records and reports maintained by the permittee and the EPA. FACILITY DESCRIPTION The Village of Cuba WWTP is classified as a minor municipal discharger with a design flow of 0.144 million gallons per day (MGD). The wastewater discharge flows to the Rio Puerco in water quality Segment 20.6.4.131 NMAC. The designated uses for this segment of the river are warmwater aquatic life, irrigation, livestock watering, wildlife habitat and primary contact. Raw sewage enters the WWTP via an approximately 5-mile-long collection system. Flow is transported by gravity with one lift station. The Aero-Mod Extended treatment plant constructed in 2013 is an activated sludge process utilizing a sequential oxidation (SEQUOX) biological nutrient removal process. The plant consists of a bar screen, grit tank, two first and second stage aeration tanks A& B, two secondary clarifiers and ultraviolet (UV) disinfection. Influent enters the headworks and manual bar screen, flows through a flume and ultrasonic flow meter, and then enters the grit tank. Flow is then split into two trains of aeration basins (activation basins) where aerobic and anaerobic phases occur. After the activation basins, wastewater enters the secondary clarifiers and then passes through UV disinfection. Return Activated Sludge (RAS) is sent from the secondary clarifiers back to the aeration basins. Waste Activated Sludge (WAS) is sent to the solids thickeners then to the old plant's lagoon system for storage. Flow is measured with a flume and ultrasonic flow meter prior to discharge to the Rio Puerco. After the UV system, treated effluent enters a pipe, and then flows approximately 300 feet to an outlet. The effluent pipe outlet is approximately 370 feet west of the main channel of Rio Puerco. Section II - OBSERVATIONS After the Phase I construction of the WWTP in 2013, the Permittee has been under an enforcement action that would eliminate discharge from April 1 thru October 31 each year for past effluent violations. USEPA Docket No. CWA-06-2015-1732 dated March 16, 2015 states: 2 EPA Inspection Report - Page 3 of 21 Cuba, Village of, Wastewater Treatment Plant Inspection Date 4/11/2019 A. ...shall accomplish the following tasks and comply with the following schedule of activities: 1. Complete design of the Phase 2 construction project by July 31, 2015. The Phase 2 project will store and transfer effluent to a land application site where the Village will grow crops to utilize the water and nutrients in the WWTP effluent. The Phase 2 project will also enable the Village to discontinue flow to the Rio Puerco during the summer months. 2. Complete construction of the Phase 2 project by February 28, 2016. B. ...shall submit a Project Completion Report...by April 30, 2016. At this inspection, facility personnel stated that the construction for Phase 2 was nearly complete and that Startup would commence within the next week. Following the completion of Phase 2, treated wastewater will be stored in a newly constructed synthetically lined impoundment. Treated wastewater meeting Class 2 reuse standards (reclaimed wastewater) will be discharged to 13 individual fields within approximately 12 acres of reuse area. Wastewater not meeting Class 2 reuse standards will be discharged to a rehabilitated, concrete-lined, emergency discharge impoundment for disposal by evaporation or returned to the treatment plant headworks for further treatment. Waste activated sludge from the treatment plant will be stored in a rehabilitated, synthetically-lined, stabilization impoundment prior to being dried in newly constructed, concrete-lined, sludge drying beds with underdrains leading to the treatment plant headworks. Up to 2,700 cubic yards per year of dried sludge from the current treatment process will be land applied in the reuse area. Sludge that has accumulated at the plant since its construction in the 1970's will be consolidated in an existing impoundment and allowed to dry. As part of Phase 2, a new laboratory building has been built and is reportedly furnished will all new laboratory analysis equipment. This new laboratory building was not yet in service as of the date of this inspection. Section III - AREAS OF CONCERN Requirement 1 Administrative Order Docket Number CWA-06-2015-1732, Section 309(a)(3) Compliance Order states: Respondent shall accomplish the following tasks and comply with the following schedule of activities: 2. Complete construction of the Phase 2 project by February 28, 2016 (See Appendix 2). Concern 1 As of the date of this inspection (April 11, 2019) construction on Phase 2 was nearly finished, but not yet tested and implemented. Requirement 2 Administrative Order Docket Number CWA-06-2018-1799, dated May 18, 2018, states: 12. Part III.C.5 of the permit was violated in that Respondent did not have Standard Operating Procedures ("SOPs") available for review by the inspectors, and as such, the SOPs could not be reviewed for compliance with 40 CFR Part 136 requirements. The available documentation of bench sheets did not reference EPA approved methods, and also indicate the SOPs would not have met this requirement. Section 309(a)(3) Compliance Order states: A. Within thirty (30) days of the effective date of this Order, Respondent shall 3 EPA Inspection Report - Page 4 of 21 Cuba, Village of, Wastewater Treatment Plant Inspection Date 4/11/2019 provide written certification to EPA, Region 6 that the violations cited herein have been corrected and the facility is in compliance with the requirement of the permit (see Appendix 3). Concern 2 As of the date of this inspection (April 11, 2019) permittee did not have SOPs available for review, and bench sheets did not show test methods as approved in 40 CFR 136. Requirement 3 NPDES Permit NM0024848, Part I: Limitations and Monitoring Requirements, 1. Outfall 001 - Final Effluent Limits: During the period beginning the effective date of the permit [11/1/2015] and lasting through the expiration date of the permit [ (unless otherwise noted), the permittee is authorized to discharge treated domestic wastewater from Outfall 001 ... Discharges are Prohibited through months from April 1 through October 31 each year. Concern 3 Due to the unfinished nature of Phase 2, permittee has been unable to meet the no discharge requirement between April and October during the years of 2016, 2017, and 2018. The facility was also discharging on the date of this inspection (April 11, 2019). Requirement 4 NPDES Permit NM0024848, Part I: A.1. Outfall 001 - Final Effluent Limits - 0.144 MGD Design Flow Concern 4A Permittee has started using an Excel spreadsheet to calculate DMR values, however the spreadsheet is only as good as the data entered. Several typos were noted by the inspector upon review of the spreadsheet. Typos that resulted in incorrect values reported on DMRs need to be corrected - revised DMRs should be submitted to EPA. Concern 4B During the month of November 2018, permittee forgot to enter the flow from the last day of the previous month into the spreadsheet, resulting in a calculated (and reported) 7-day average flow of 4 EPA Inspection Report - Page 5 of 21 Cuba, Village of, Wastewater Treatment Plant Inspection Date 4/11/2019 30.264 MGD and a calculated (and reported) 30-day average of 7.623 MGD, is well above the permitted design flow of 0.144 MGD. Concern 4C Permittee is reporting Total Kjeldahl Nitrogen (TKN) for Ammonia, instead of Ammonia by test method SM 4500 NH3 (in accordance with 40 CFR 136). Concern 4D Permittee is using a zero value in DMR calculations when the laboratory report is below the detection limit. Guidance provided in the NPDES Reporting Requirements Handbook (EPA, 2004), Section XII, Question 9, states: "Unless otherwise stated in the permit, values below the detection limit are to be reported with a less than symbol ( < ) and the numeric value for the detection limit using the EPA approved method" (Please refer to the referenced document for additional information on this topic). During the month of November 2018, permittee reported a zero for the 30-day average and daily maximum for TSS instead of "<4" mg/l as shown on the laboratory report. Using a value of 4 mg/l to calculate the percent removal would result in a percent removal of 97% rather than the reported 100%. Concern 4E Permittee is not using monthly average effluent concentration in percent removal calculations as shown in footnote *2. Requirement 5 NPDES Permit NM0024848, Part I: Limitations and Monitoring Requirements, 1. Outfall 001 - Final Effluent Limits, Footnote *3: TRC (total residual chlorine) shall be measured during periods when chlorine is used as either backup bacteria control or when disinfection of plant treatment equipment is required. Concern 5 Facility personnel stated that plant is cleaned periodically with potable water which was sanitized with chlorine. TRC testing should be done whenever chlorine may have entered the treatment stream, including when potable water is used. Requirement 6 NPDES Permit NM0024848, Part III: Standard Conditions B.3. Proper Operation and Maintenance a. 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 permittee as efficiently as possible and in a manner which will minimize upsets and discharges of excessive pollutants and will achieve compliance with the conditions of this permit. Concern 6 An ongoing leak on the WAS line is present, as identified by the healthy stands of vegetation growing next to the access hatch (see photos in Appendix 1). Requirement 7 NPDES Permit NM0024848, Part III: Standard Conditions B.3. Proper Operation and Maintenance b. The permittee shall provide an adequate operating staff which is duly qualified to carry out operation, maintenance and testing functions required to insure compliance with the conditions of this permit. 5 EPA Inspection Report - Page 6 of 21 Cuba, Village of, Wastewater Treatment Plant Inspection Date 4/11/2019 Concern 7 At the time of the inspection, the facility had one full time operator with a Level 1 Wastewater certification, one full time operator who was not yet certified, and one operator with a Level 3 Wastewater certification who was contracted to visit the facility one day a week. In accordance with New Mexico Administrative Code (NMAC) 20.7.4, in order to "operate" this facility, a Level 3 Wastewater Certification is required. Operate is defined as "performing any activity or function or making any process control or system integrity decision regarding water quality or water quantity that has the potential to affect the proper functioning of ... a public wastewater facility or to affect human health, public welfare or the environment." Requirement 8 NPDES Permit NM0024848, Part III. C.4. Record Contents: Records of monitoring information shall include: a. The date, exact place, and time of sampling or measurements; b. The individual(s) who performed the sampling or measurements; c. The date(s) and time(s) analyses were performed; d. The individual(s) who performed the analyses; e. The analytical techniques or methods used; and f. The results of such analyses. Concern 8 pH bench sheets are missing the time of analysis, making it impossible to verify that analysis was completed within the 15-minute holding time. Requirement 9 NPDES Permit NM0024848, Part III. C.5.a. Monitoring must be conducted according to test procedures approved under 40 CFR Part 136, unless other test procedures have been specified in this permit or approved by the Regional Administrator. NPDES Permit NM0024848, Part III. C.5.b. The permittee shall calibrate and perform maintenance procedures on all monitoring and analytical instruments at intervals frequent enough to insure accuracy of measurements and shall maintain appropriate records of such activities Concern 9 There was no thermometer present in the refrigerator used to store the samples during compositing, and pH buffer solutions did not have received-on or opened-on dates written on the bottles. The manufacturer of these solutions, "USABlueBook" states that they must be used within 6 months after opening. Section IV - LIST OF APPENDICES Appendix 1 - Photo Log - 2 photos taken 4/11/2019 Appendix 2 - Administrative Order Docket No. CWA-06-2015-1732 Appendix 3 - Administrative Order Docket No. CWA-06-2018-1799 6 EPA Inspection Report - Page 7 of 21 Cuba, Village of, Wastewater Treatment Plant Inspection Date 4/11/2019 Appendix 1 Photograph Log EPA Inspection Report - Page 8 of 21 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Village of Cuba Wastewater Treatment Plant City: Cuba County/Parish: Sandoval County State: New Mexico Photo File Name: DSCN0881.JPG Date of Photo: 04/11/2019 Time of Photo: 2:16 PM Photographer: Amy Andrews Description: Ongoing leak on the WAS line, as identified by healthy stands of vegetation. EPA Inspection Report - Page 9 of 21 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Village of Cuba Wastewater Treatment Plant City: Cuba County/Parish: Sandoval County State: New Mexico Photo File Name: DSCN0882.JPG Date of Photo: 04/11/2019 Time of Photo: 2:17 PM Photographer: Amy Andrews Description: Ongoing leak on the WAS line, as identified by healthy stands of vegetation. EPA Inspection Report - Page 10 of 21 Cuba, Village of, Wastewater Treatment Plant Inspection Date 4/11/2019 Appendix 2 Administrative Order Docket No. CWA-06-2015-1732 EPA Inspection Report - Page 11 of 21 EPA Inspection Report - Page 12 of 21 EPA Inspection Report - Page 13 of 21 EPA Inspection Report - Page 14 of 21 EPA Inspection Report - Page 15 of 21 EPA Inspection Report - Page 16 of 21 EPA Inspection Report - Page 17 of 21 Cuba, Village of, Wastewater Treatment Plant Inspection Date 4/11/2019 Appendix 3 Administrative Order Docket No. CWA-06-2018-1799 EPA Inspection Report - Page 18 of 21 EPA Inspection Report - Page 19 of 21 EPA Inspection Report - Page 20 of 21 EPA Inspection Report - Page 21 of 21