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EPA Inspection Report - Page 1 of 17 Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 9/12/2018 Water CWA - NPDES Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Village of Cimarron Cimarron Wastewater Treatment Plant Off Highway 58 approximately one-mile southeast of the Village of Cimarron Cimarron, NM 87714 P.O. Box 654 Cimarron, NM 87714 Colfax County Leo Martinez Mayor villageadmin@villageofcimarron.net FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110064621137 NM0031038 221320 4952 Personnel participating in inspection: Amy Andrews, P.E. USEPA/6EN-WMH Shawn Jeffrey Village of Cimarron Damian Casias Village of Cimarron Environmental Engineer Clerk Administrator Public Works Supervisor 214-907-0638 575-376-2232 575-643-5735 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: 2018.11.13 13:37:04 -07'00' 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: 2018.11.19 17:25:47 -06'00' Carol Peters Date Date 6ENFORM-019-R7 (2/15/2017) 1 EPA Inspection Report - Page 2 of 17 Section I - INTRODUCTION Village of Cimarron Wastewater Treatment Plant Inspection Date 9/12/2018 PURPOSE OF THE INSPECTION Environmental Protection Agency (EPA) Region 6 Inspector, Amy Andrews, arrived at the Village of Cimarron Village Hall at 11:20 AM on September 12, 2018 for an unannounced inspection of the Village of Cimarron Wastewater Treatment Plant (WWTP). I met with Ms. Shawn Jeffrey, the Village of Cimarron Clerk Administrator, and Mr. Damian Casias, the Village of Cimarron Public Works Supervisor. I presented my credentials to Ms. Jeffrey and Mr. Casias and informed them 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 Cimarron 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 Cimarron WWTP is classified as a minor municipal discharge with a design flow of 0.0083 MGD. The discharge for the WWTP enters French Lake, a tributary to the Cimarron River in water quality segment 20.6.4.306 NMAC, at Latitude 36 30' 28" North, Longitude 104 53' 45" West. The Designated Uses for this segment of the river are: irrigation, warmwater aquatic life, livestock watering, wildlife habitat and primary contact. The Village of Cimarron has a population of approximately 950 people, however two subdivisions are not served by the WWTP and it is estimated that 540 hook-ups are served by the drinking water distribution system. Raw sewage flows by gravity through the collection system. One lift station is located on the south side of town. The raw sewage enters the WWTP through a 4" to 6" Parshall Flume where a wooden stick is used as the staff gauge to measure influent flow. The staff gauge affixed to the wall is coated with debris and is unreadable. The raw sewage is split between two lagoons. Both lagoons have a small "Solar Bee" mixing unit anchored in the center. The Solar Bees do not provide any aeration; they simply mix a small section of the solids and water in the lagoons. Each lagoon is roughly 2 acres in size followed by 2 small sand filters designated for each lagoon then through a 6-inch Parshall Flume to the outfall at French Lake. French Lake is currently owned by the Vermejo Ranch for irrigating cropland seeded with alfalfa. The Vermejo Ranch no longer approves of the Village discharging onto their land. Approximately three feet of free board was observed in both lagoons. Stains show a highwater mark on the sidewalls is less than two feet from the top of the cement liners in the lagoons. During the winter months the evaporation rate is low, and the lagoons tend to fill. In the spring high winds and warmer temperatures lower the pond levels. Extremely high levels of solids are present in both lagoons. Around the edges, solids are so thick that plants have taken root and are growing in the lagoons. Facility personnel stated that solids have never been wasted. There are no sludge drying beds at the site. Facility personnel indicated they have been discussing using the solids to amend ranch land in the area. The 2 EPA Inspection Report - Page 3 of 17 Village of Cimarron Wastewater Treatment Plant Inspection Date 9/12/2018 wastewater system does not have a disinfection system in place. The Village has completed the technical design and bid proposals to upgrade WWTP by dredging, adding a third pond. The goal of the project is to upgrade the facility to produce reuse quality effluent. They are currently seeking funding from New Mexico state sources. Section II - OBSERVATIONS The WWTP does not discharge regularly but is controlled manually by facility personnel based on the levels in the lagoons. The only discharge that has occurred since this permit went into effect on November 1, 2015 was on December 14 and 28, 2016. Facility personnel stated that when they do discharge, they initiate discharge by opening the manual gate valve (see photo 4 in Appendix 1), typically for 5 to 6 hours the first day and 5 to 6 hours a second day (not necessarily consecutive days). Samples are collected every hour and analyzed for pH and total residual chlorine (TRC). A grab sample is collected at the beginning of the day on every day of discharge and sent to Hall Environmental Laboratory in Albuquerque via UPS for analysis of 5-day biochemical oxygen demand (BOD5), total suspended solids (TSS), and Escherichia coli (E. coli). Whole effluent toxicity (WET) testing is sampled by grab sample at the end of the discharge, usually around 11:00 AM. Dilution water is collected for the WET testing from the receiving water on the day of the discharge as well as the day after the discharge. Facility personnel indicated that during and after the lagoon renovation they intend to remove sludge from the lagoons, dry the sludge onsite, and give away dried biosolids to local ranchers as compost. This would be a change in the sewage sludge disposal method, and the permittee is required to give prior notice to the EPA of this change, in accordance with NPDES Permit NM0031038, Part IV, Element 1, Section I.A.4. and 40 CFR Part 122.41(l)(l)(iii). Change in the sludge use or disposal practice may be cause for modification of the permit in accordance with 40 CFR Part 122.62(a)(l). Additionally, permittee must comply with all testing and monitoring requirements, pathogen control, vector attraction reduction requirements, and must have a certification statement as described in NPDES Permit NM0031038, Part IV, Element 1. Requirements for Land Application and Section 405 of the CWA. Section III - AREAS OF CONCERN Requirement 1 NPDES Permit NM0031038, 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 1 The lagoon liner and the lagoon freeboard concrete are cracking and visually appear to be failing in several locations (see Photos 2 and 3 in Appendix 1) with weeds growing out of the cracks. There is an abundance of algae in the lagoons, sludge wasting has never occurred, and due to the constant mixing of the SolarBees, there is a high likelihood of solids flowing out the outfall during discharge events. 3 EPA Inspection Report - Page 4 of 17 Village of Cimarron Wastewater Treatment Plant Inspection Date 9/12/2018 Requirement 2 NPDES Permit NM0031038, Part I: C. Monitoring and reporting (Minor Dischargers): Monitoring results must be reported to EPA... 1. Reporting periods shall end on the last day of the months March, June, September, and December. 2. The permittee is required to submit regular quarterly reports as described above postmarked no later than the 15th day of the month following each reporting period. NPDES Permit NM0031038, Part III: A.2. Duty to Comply: The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of the Act and its grounds for enforcement action; for permit termination; revocation and reissuance, or modification; or for denial of a permittee renewal application. Concern 2 Discharge Monitoring Reports (DMRs) were not received for the periods below: 11/30/2015 7/31/2016 to 9/30/2017 - this includes the month of 12/31/2016, in which the only discharge occurred 11/30/2017 to 1/31/2018 Even though the reporting period is over, the permittee needs to go back and report overdue data. Requirement 3 NPDES Permit NM0031038, Part I, Section A.1. Effluent Limits, Table 1: BOD5, TSS and E. coli.: Concern 3A Effluent measurement frequency is required at once per week, when discharging. During the discharge on 12/13/2016 and on 12/28/2016, two grab samples were collected from the effluent and sent to Hall Environmental for BOD5, TSS, and E. Coli. Copies of these laboratory reports were received during the inspection. Results and inspector's calculations from the laboratory reports are shown as follows: 4 EPA Inspection Report - Page 5 of 17 Village of Cimarron Wastewater Treatment Plant Inspection Date 9/12/2018 Sample Date 12/13/2016 12/28/2016 BOD5 E. coli TSS 65 24196* 48 70 5794* 74 30-day average Result Discharge Limit 67.5 11,840* 61 30 126 90 Daily Max Result Discharge Limit NR 24,196* NR NR 410 NR Result 70 7-day average Discharge Limit 45 NR 74 NR 135 NR = not required *Samples analyzed outside of required holding time. Discharge permit limits have been exceeded for the 30-day average and 7-day average BOD5, as well as the 30-day average and daily max for E. coli. Please note that 7-day and 30-day averages are averages of samples collected, and cannot be averaged with no-discharge days; BOD5 and TSS are arithmetic averages and E. coli is a geometric average. Copies of flow records were not received during the inspection, therefore loading rates could not be checked. Concern 3B Permittee stated that samples of the influent have never been collected, thereby making it impossible to calculate percent removal for BOD5 and TSS. Concern 3C The holding time for E. coli is 8 hours from time of sample collection to the start of sample preparation for analysis. Shipping samples to a laboratory via overnight UPS is not appropriate for the analysis of this pollutant. Requirement 4 NPDES Permit NM0031038, Part I, Section A.1. Effluent Limits, Table 2: NPDES Permit NM0031038, Part III, D.5. Additional Monitoring by the Permittee: If the permittee monitors any pollutant more frequently than required by this permit, using test procedures approved under 40 CFR Part 136 or as specified in this permit, the results of this monitoring shall be included in the calculation and reporting of the data submitted in the Discharge Monitoring Report (DMR). Such increased monitoring frequency shall also be indicated on the DMR. Concern 4 pH bench sheets were not available at the time of inspection, and were not received by the inspector at a later date, however, water testing done during maintenance of the SolarBees (see Appendix 2) suggests that the pH of the water/slurry in the lagoons ranged from 8.92 to 9.89 on 11/8/2016, just 5 EPA Inspection Report - Page 6 of 17 Village of Cimarron Wastewater Treatment Plant Inspection Date 9/12/2018 prior to the manually-initiated discharge on 12/14/2016. It should be noted that facility personnel stated that samples for pH and total residual chlorine (TRC) are analyzed every hour while discharging, and all results obtained from these analyses must be used to calculate DMR values. Requirement 5 NPDES Permit NM0031038, Part III, C.5. Monitoring Procedures: a. Monitoring must be conducted according to test procedures approved under 40 CFR Part 13 6, unless other test procedures have been specified in this permit or approved by the Regional Administrator. 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. c. An adequate analytical quality control program, including the analyses of sufficient standards, spikes, and duplicate samples to insure the accuracy of all required analytical results shall be maintained by the permittee or designated commercial laboratory. Concern 5 Permittee's pH monitor (see photo 1 in Appendix 1) does not meet the requirements of the method stated in 40 CFR 136.3. Facility personnel were not familiar with calibration of instrument, and instrument must be able to be calibrated and maintain said calibration for the duration of testing. No evidence was presented to show the existence of a quality control program for the analyses run by the permittee (pH and TRC). Requirement 6 NPDES Permit NM0031038, Part I, Section A.1. Effluent Limits, Table 3: NPDES Permit NM0031038, Part II, 2.d. Samples and Composites: i. The permittee shall collect two flow-weighted composite samples from the outfall [001]. ii. The permittee shall collect a second composite sample for use during the 24-hour renewal of each dilution concentration for both tests. The permittee must collect the composite samples so that the maximum holding time for any effluent sample shall not exceed 36 hours. The permittee must have initiated the toxicity test within 36 hours after the collection of the last portion of the first composite sample. Samples shall be chilled to 6 degrees Centigrade during collection, shipping, and/or storage. iii. The permittee must collect the composite samples such that the effluent samples are representative of any periodic episode of chlorination, biocide usage or other potentially toxic substance discharged on an intermittent basis. iv. If the flow from the outfall(s) being tested ceases during the collection of effluent samples, the requirements for the minimum number of effluent samples the minimum number of effluent portions 6 EPA Inspection Report - Page 7 of 17 Village of Cimarron Wastewater Treatment Plant Inspection Date 9/12/2018 and the sample holding time are waived during that sampling period. However, the permittee must collect an effluent composite sample volume during the period of discharge that is sufficient to complete the required toxicity tests with daily renewal of effluent. When possible, the effluent samples used forthe toxicity tests shall be collected on separate days. The effluent composite sample collection duration and the static renewal protocol associated with the abbreviated sample collection must be documented in the full report required in Item 3 of this section. Concern 6 Facility personnel stated that the whole effluent toxicity (WET) sample is collected as a grab sample, right before the end of discharge, usually around 11:00 AM. A grab sample of the receiving water is also collected on the day of the discharge as well as the day following discharge. The chain of custody which was sent with the samples states that the "sample time" was from 0500 AM to 1100 AM, which facility personnel said was actually the time of discharge, not the time of sample, since the sample was a onetime grab. The sample is required to be collected as a 24-hour flow-weighted composite sample, meaning that a portion of the sample should be collected every hour as the facility is discharging, up to 24 hours. This is intended to be repeated on a second consecutive day of discharge and sent to the lab in a second shipment, in order to maintain holding times while the laboratory is running the test. Facility personnel stated that the sample collected on the second day is from the receiving water, after discharge (so the collected water is a mixture of receiving water and discharged water), which is not appropriate for use as the dilution water nor the effluent water in the 24-hour renewal of the WET testing. There is no documentation in the laboratory report about how the dilutions were created for the 24-hour renewal, and there is no mention of the minimum number of effluent samples, the minimum number of effluent portions, and the sample holding time being waived because the flow from the outfall ceased. Requirement 7 NPDES Permit NM0031038, Part III C.6. Flow Measurements: Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The devices shall be installed, calibrated, and maintained to insure that the accuracy of the measurements is consistent with the accepted capability of that type of device. Devices selected shall be capable of measuring flow with a maximum deviation of less than 10% from true discharge rates throughout the range of expected discharge volumes. Concern 7 The effluent flow meter (6-inch Parshall Flume) was not accessible during the inspection due to vegetation overgrowth. Facility personnel stated that the Flume has a staff gauge and that they use a conversion sheet to determine flow rates, however they also state that the Flume has never been calibrated. The influent Parshall Flume and staff gauge were heavily coated with dried debris. The staff gauge was unreadable. Operators indicated that a wooden stick is used to estimate the depth of the influent flow. 7 EPA Inspection Report - Page 8 of 17 Section IV - FOLLOW UP Village of Cimarron Wastewater Treatment Plant Inspection Date 9/12/2018 No information was received by EPA after exiting the Facility on 9/12/2018. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 4 photos taken 9/12/2018 Appendix 2 - SolarBee Service Report from 11/8/2016 8 EPA Inspection Report - Page 9 of 17 Village of Cimarron Wastewater Treatment Plant Inspection Date 9/12/2018 Appendix 1 Photograph Log EPA Inspection Report - Page 10 of 17 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Village of Cimarron Wastewater Treatment Plant City: Cimarron County/Parish: Colfax State: New Mexico Photo File Name: DSCN0649.JPG Date of Photo: 9/12/2018 Time of Photo: 1:14 PM Photographer: Amy Andrews Description: pH meter EPA Inspection Report - Page 11 of 17 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Village of Cimarron Wastewater Treatment Plant City: Cimarron County/Parish: Colfax State: New Mexico Photo File Name: DSCN0659.JPG Date of Photo: 9/12/2018 Time of Photo: 1:36 PM Photographer: Amy Andrews Description: View of algae and lagoon freeboard concrete cracking with weeds growing out of cracks. EPA Inspection Report - Page 12 of 17 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Village of Cimarron Wastewater Treatment Plant City: Cimarron County/Parish: Colfax State: New Mexico Photo File Name: DSCN0660.JPG Date of Photo: 9/12/2018 Time of Photo: 1:39 PM Photographer: Amy Andrews Description: Second view of algae and lagoon freeboard concrete cracking with weeds growing out of cracks. EPA Inspection Report - Page 13 of 17 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Village of Cimarron Wastewater Treatment Plant City: Cimarron County/Parish: Colfax State: New Mexico Photo File Name: DSCN0664.JPG Date of Photo: 9/12/2018 Time of Photo: 1:52 PM Photographer: Amy Andrews Description: Manual gate valve used to initiate discharge. EPA Inspection Report - Page 14 of 17 Village of Cimarron Wastewater Treatment Plant Inspection Date 9/12/2018 Appendix 2 SolarBee Service Report from 11/8/2016 EPA Inspection Report - Page 15 of 17 EPA Inspection Report - Page 16 of 17 EPA Inspection Report - Page 17 of 17