Document 3JbwZdbdYnyBL73K98GX8QDzO

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 01/18/2024 Water CWA Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Village of Taos Ski Valley Taos Ski Valley WWTP 101 Ocean Boulevard Village of Taos Ski Valley, New Mexico 87525 Post Office Box 100 Taos Ski Valley, New Mexico 87525 Taos 575-776-8220 John Avila Village Administrator javila@vtsv.org FRS Number: 110002047197 Identification/Permit Number: Media Identifier Number: NAICS: SIC: NM0022101 NA 221320 4952 Personnel participating in inspection: Adam Romero Village of Taos Ski Valley Damean Crenen Village of Taos Ski Valley Josiah Griego Village of Taos Ski Valley John Avila Village of Taos Ski Valley Marlene Salazar Village of Taos Ski Valley Nafis Fuad James Andel Issac Martinez David Esparza NMED-PSRS NMED-SWQB NMED-SWQB EPA-R6/ECDWM WWTP Operator WWTP Operator WWTP Operator Village Administrator Village Public Works Administration Assistant Compliance/Enforcement Team Lead Industrial/Municipal Inspector Municipal/Industrial Specialist Environmental Engineer EPA Lead Inspector Signature/Date DAVID ESPARZA Date: 2024.03.01 16:03:26 -07'00' Digitally signed by DAVID ESPARZA David Esparza Date Supervisor Signature/Date ROBERTO BERNIER Date: 2024.03.12 13:31:23 -05'00' Digitally signed by ROBERTO BERNIER Roberto Bernier Date 6ENFORM-020-R8.2 (02/12/2020) 1 Village of Taos Ski Valley/Taos Ski Valley WWTP Permit No. NM0022101 Inspection Date 01/18/2024 Section I - INTRODUCTION PURPOSE OF THE INSPECTION United States Environmental Protection Agency (EPA) Region 6 inspector David Esparza, PE, Mr. Nafis Fuad, Mr. James Andel and Mr. Issac Martinez all from the New Mexico Environment Department (NMED) arrived at the Village of Taos Ski Valley (Taos Ski Valley) Wastewater Treatment Plant (WWTP) at approximately 8:45 AM on January 18, 2024, for an unannounced inspection. I presented my credentials to Mr. John Avila and Ms. Marlene Salazar of Taos Ski Valley and informed them that this was an EPA inspection to determine the facility's compliance under the Clean Water Act (CWA) and the requirements of the National Pollutant Discharge Elimination System (NPDES) permit program, in accordance with the CWA. The generation of this report is based on information supplied by Taos Ski Valley representatives, observations made by the EPA inspector, NMED, and records and reports maintained by the permittee (Taos Ski Valley), and the EPA. Before leaving the facility on January 18, 2024, an exit briefing was held with Ms. Salazar and Mr. Avila, to explain areas of concern noted at the time of the inspection. It should be noted the WWTP also maintains a discharge permit (DP-1383) issued by the New Mexico Environment Department (NMED), Groundwater Quality Bureau (GWQB) in conjunction with the sludge disposal. FACILITY DESCRIPTION The Village of Taos Ski Valley (VTSV) WWTP facility is classified as a minor discharger with a design capacity of 0.9 MGD serving a year-round population of approximately 500 people and a peak tourist population of approximately 5,000. The facility is located at 38 Ocean Boulevard Taos Ski Valley, Taos County New Mexico or approximately 0.36-miles west of the Village Administration Office, between New Mexico State Road (SR) 150 and Ocean Boulevard in Taos Ski Valley, Taos County, New Mexico (denoted in Aerial Image #1 below). Approximate coordinates to the VTSV WWTP facility are Latitude 3635'48.66" North, Longitude 10527'40.67" West. Site hours will consist of Monday through Friday 7am to 5pm. The existing WWTP is located inside a building to protect it from inclement weather during the winter months. The WWTP treatment process is comprised of a gravity collection system, one (1) lift station (identified in Table #1), headworks comprised of a grit removal system with a screw pump and bagging system. Flow from the headworks then traverses through a flow control box; thence to two (2) in-ground equalization (EQ) basins, i.e., an anoxic EQ basin with mixers and a steel EQ basin. The WWTP maintains the following basins which were retrofitted from the existing treatment facility. This includes one (1) Pre Anoxic Zone (PAX) basin of approximately 24K-gallons (existing tank) which flows into the one (1) Pre-Aeration Zone (PAI) basin of approximately 71K-gallons (existing tank). Flow is separated into two (2) parallel treatment trains. Each train consists of one (1) Pre-Aeration Zone tanks of approximately 30K-gallons (existing tanks) which flow into the following process zones. One (1) 2 Village of Taos Ski Valley/Taos Ski Valley WWTP Permit No. NM0022101 Inspection Date 01/18/2024 Post-Anoxic Zone (AXP) basin of 29K-gallons per train which flow into one (1) Membrane Zone (MBR) basin of approximately 21K-gallons. Solids from the MBR basin are returned to the Pre-Anoxic Zone basin. The permeate water thence traverse through two (2) ultraviolet (UV) disinfection units per train prior to discharge to the Rio Hondo a tributary of the Rio Grande. The WWTP utilizes an Alfa Laval centrifuge located within the dewatering building prior to discharging to the sludge pad. Final, disposal of the sludge is at the Taos County Regional Landfill or Rio Rancho Landfill. In June 2019 an improvement project included the placement of an Ovivo Membrane Bioreactor (MBR) system that provides primary treatment in the WWTP. This MBR system is comprised of two (2) treatment trains, an upgraded ultra-violet (UV) disinfection system, comprised of two (2) banks of three (3) modules for each treatment train and a Supervisory Control and Data Acquisition (SCADA) instrumentation. Aerial Image #1: Overall view of the Village of Taos Ski Valley's Wastewater Treatment Plant. Aerial from Google Earth maps. Table 1: Village of Taos Ski Valley Lift Stations Lift Station 1 Kachina 104 Kachina Road Address Taos Ski Valley does have written policies and procedures to address any potential sanitary sewer overflow events (SSOs), and standard operating procedures (SOPs) pertaining facility operations and 3 Village of Taos Ski Valley/Taos Ski Valley WWTP Permit No. NM0022101 Inspection Date 01/18/2024 maintenance (O&M) and a current Fats, Oils and Grease (FOG) program policy regarding existing and/or new FOG contributors. Additionally, their Asset Management Plan was updated in 2021. Currently, there are no Industrial Users (IU) or satellite communities contributing to the WWTP. Section II - OBSERVATIONS I observed the following and/or the following information was provided or stated on January 20, 2022. The June 2019 improvements included upgrades to the WWTP UV disinfection system, a Supervisory Control and Data Acquisition (SCADA) instrumentation and placement of an Ovivo Membrane Bioreactor (MBR) system. The WWTP maintains an on-site generator for back up that is routinely exercised every week. Overall maintenance and operation (O&M) of the WWTP appeared to be satisfactory. All equipment looked to be running properly. Section III - AREAS OF CONCERN A review of the submitted Integrated Compliance Information System (ICIS) Discharge Monitoring Reports (DMR) data for the period January 20, 2022, through January 31, 2023, indicates NPDES permit excursions with respect to Nitrogen as Ammonia, Total Nitrogen, Total Phosphorus, 5-day Biological Oxygen Demand (BOD5) and pH (Appendix 2 ICIS E90 Effluent Violations). EPA Region 6 inspector David Esparza conducted a closing conference at the Village of Taos Ski Valley's WWTP at approximately 11:30 AM on January 18, 2024, for the inspection. Section IV - FOLLOW UP The following information was received by EPA on January 30, 2024, after exiting the Facility on January 18, 2024: A copy of the current Asset Management Plan-revised in 2021 A summary of the quantity and locations of any lift station(s). Kachina Lift Station- 104 Kachina Road A sanitary sewer overflow (SSO) protocol, Fats, Oils and Grease (FOG) or Best Management Practices (BMP) summary of: VTSV Spill Reporting Policy 4 Village of Taos Ski Valley/Taos Ski Valley WWTP Permit No. NM0022101 Inspection Date 01/18/2024 Spill Spreadsheet Grease Trap Policy A copy of the current/updated Site Map/Plan VTSV Site and Building plan layout. Schematic of the process system equipment layout A copy of the Ovivo Membrane Bioreactor (MBR) Control Strategy MBR unit instruction manual Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 5 photos taken 1/18/2024. Appendix 2 - ICIS E90 Effluent Violations 5 Village of Taos Ski Valley/Taos Ski Valley WWTP Permit No. NM0022101 Inspection Date 01/18/2024 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Taos Ski Valley Wastewater Treatment Plant City: Village of Taos Ski County/Parish: Taos State: New Mexico View of one (1) of the WWTP two (2) pieces of process equipment associated with the headworks. (IMG_0216) (09:14 AM:01/18/2024). Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Taos Ski Valley Wastewater Treatment Plant City: Village of Taos Ski County/Parish: Taos State: New Mexico View of the grit bagging system within the headworks. (IMG_0217) (09:15 AM :01/18/2024). Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Taos Ski Valley Wastewater Treatment Plant City: Village of Taos Ski County/Parish: Taos State: New Mexico View of some of the Ovivo MBR membrane modules. (IMG_0218). (10:16 AM :01/18/2024). Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Taos Ski Valley Wastewater Treatment Plant City: Village of Taos Ski County/Parish: Taos State: New Mexico A view of the Alfa Laval centrifuge within the dewatering building. (IMG_0221). (10:43 AM:01/18/2024) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Taos Ski Valley Wastewater Treatment Plant City: Village of Taos Ski County/Parish: Taos State: New Mexico View of the WWTP's snow covered sludge pad. Note: Final, disposal of the sludge is at the Taos County Regional Landfill or Rio Rancho Landfill. (IMG_0222) (10:47 AM:01/18/2024) Photographed by D. Esparza Village of Taos Ski Valley/Taos Ski Valley WWTP Permit No. NM0022101 Inspection Date 01/18/2024 Appendix 2 Review of the ICIS E90 Effluent Violations E90 Effluent Violations From 01/01/2019 - Present NM0022101 TAOS SKI VALLEY, VILLAG Monitoring Period End Date 01/31/2022 01/31/2022 01/31/2022 02/28/2022 03/31/2022 03/31/2022 03/31/2022 03/31/2022 04/30/2022 05/31/2022 05/31/2022 01/31/2023 01/31/2023 01/31/2023 01/31/2023 01/31/2023 02/28/2023 02/28/2023 02/28/2023 02/28/2023 02/28/2023 03/31/2023 03/31/2023 03/31/2023 03/31/2023 03/31/2023 Perm Feature ID 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 Limit Set Designator A A A A A A A A A A A A A A A A A A A A A A A A A A Parameter Desc Statistical Base Short Desc Nitrogen, ammonia total [a 7 DA AVG Nitrogen, ammonia total [a 7 DA AVG Nitrogen, total [as N] 7 DA AVG Phosphorus, total [as P] 7 DA AVG Phosphorus, total [as P] 30DA AVG Phosphorus, total [as P] 30DA AVG Phosphorus, total [as P] 7 DA AVG Phosphorus, total [as P] 7 DA AVG Phosphorus, total [as P] 7 DA AVG BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, percent remo MO AV MN Nitrogen, ammonia total [a 30DA AVG Nitrogen, ammonia total [a 7 DA AVG Nitrogen, ammonia total [a 7 DA AVG Nitrogen, total [as N] 30DA AVG Nitrogen, total [as N] 7 DA AVG Nitrogen, ammonia total [a 30DA AVG Nitrogen, ammonia total [a 7 DA AVG Nitrogen, ammonia total [a 7 DA AVG Nitrogen, total [as N] 30DA AVG Nitrogen, total [as N] 7 DA AVG Nitrogen, ammonia total [a 30DA AVG Nitrogen, ammonia total [a 30DA AVG Nitrogen, ammonia total [a 7 DA AVG Nitrogen, ammonia total [a 7 DA AVG Nitrogen, total [as N] 30DA AVG Limit Unit Short Desc lb/d mg/L mg/L mg/L lb/d mg/L lb/d mg/L mg/L mg/L % mg/L lb/d mg/L mg/L mg/L mg/L lb/d mg/L mg/L mg/L lb/d mg/L lb/d mg/L lb/d Limit Value 5.34 3.2 12.3 .75 .8 .5 1.2 .75 .75 30 85 3.2 5.34 3.2 8.2 12.3 3.2 5.34 3.2 8.2 12.3 5.34 3.2 5.34 3.2 13.65 DMR Value Qualif ier Code = = = = = = = = = = = = = = = = = = = = = = = = = = DMR Value 6.41 11 17.3 .85 1.34 2.44 2.35 4.1 1.1 41 16.33 3.63 5.56 8.4 9.53 13.3 8.59 14.56 24 12.73 26.41 20.42 34.4 29.02 44 21.3 Monitoring Period End Date 03/31/2023 03/31/2023 03/31/2023 03/31/2023 03/31/2023 03/31/2023 04/30/2023 04/30/2023 04/30/2023 04/30/2023 04/30/2023 08/31/2023 08/31/2023 08/31/2023 08/31/2023 08/31/2023 08/31/2023 08/31/2023 08/31/2023 08/31/2023 09/30/2023 09/30/2023 09/30/2023 09/30/2023 09/30/2023 09/30/2023 09/30/2023 09/30/2023 09/30/2023 09/30/2023 10/31/2023 Perm Feature ID 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 Limit Set Designator A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A Parameter Desc Statistical Base Short Desc Nitrogen, total [as N] 30DA AVG Nitrogen, total [as N] 7 DA AVG Nitrogen, total [as N] 7 DA AVG Phosphorus, total [as P] 30DA AVG Phosphorus, total [as P] 7 DA AVG Phosphorus, total [as P] 7 DA AVG Nitrogen, ammonia total [a 30DA AVG Nitrogen, ammonia total [a 7 DA AVG Nitrogen, ammonia total [a 7 DA AVG Nitrogen, total [as N] 30DA AVG Nitrogen, total [as N] 7 DA AVG Nitrogen, ammonia total [a 30DA AVG Nitrogen, ammonia total [a 30DA AVG Nitrogen, ammonia total [a 7 DA AVG Nitrogen, ammonia total [a 7 DA AVG Nitrogen, total [as N] 30DA AVG Phosphorus, total [as P] 30DA AVG Phosphorus, total [as P] 30DA AVG Phosphorus, total [as P] 7 DA AVG Phosphorus, total [as P] 7 DA AVG Nitrogen, ammonia total [a 30DA AVG Nitrogen, ammonia total [a 30DA AVG Nitrogen, ammonia total [a 7 DA AVG Nitrogen, ammonia total [a 7 DA AVG Nitrogen, total [as N] 30DA AVG Nitrogen, total [as N] 7 DA AVG Phosphorus, total [as P] 30DA AVG Phosphorus, total [as P] 30DA AVG Phosphorus, total [as P] 7 DA AVG Phosphorus, total [as P] 7 DA AVG pH MINIMUM Limit Unit Short Desc mg/L lb/d mg/L mg/L lb/d mg/L mg/L lb/d mg/L mg/L mg/L lb/d mg/L lb/d mg/L mg/L lb/d mg/L lb/d mg/L lb/d mg/L lb/d mg/L mg/L mg/L lb/d mg/L lb/d mg/L SU Limit Value 8.2 20.5 12.3 .5 1.2 .75 3.2 5.34 3.2 8.2 12.3 5.34 3.2 5.34 3.2 16.6 1.2 1.5 1.8 2.25 5.34 3.2 5.34 3.2 12.7 19 .8 2.5 1.2 3.75 6.6 DMR Value Qualif ier Code = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = DMR Value 35.88 29.83 45.22 .95 1.25 1.9 5.5 7.12 21 8.92 24.13 6.56 18 6.56 18 19.16 3.02 8.3 3.02 8.3 13.98 33 13.98 33 34 34 6.36 15 6.36 15 6.42