Document 4aVbJE91mdMdgr5oap36V45yN

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 04/21/2016 Water SDWA Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: El Rancho Mobile Home Park Santa Fe El Rancho Mobile Home Park Santa Fe 58A Evergreen Lane Santa Fe, NM 87506 58A Evergreen Lane Santa Fe, NM 87506 Santa Fe County Jack Shelburn Operator, Manager, Owner 505.455.7261 FRS Number: Identification/Permit Number: NAICS: SIC: 110013111202 NM3570426 N/A 4941 Personnel participating in inspection: Jack Shelburn El Rancho MHP Gus Vigil El Rancho MHP Angela Restivo Jenna Manheimer EPA/6WQ-SD EPA/6EN-WR Facility Manager, Operator, Landowner Landowner, Southern Property Compliance Officer Enforcement Officer 505.455.7261 214.665.7123 214.665.7318 EPA Lead Inspector Signature/Date Supervisor Signature/Date Jenna Manheimer MEHDI TAHERI Digitally signed by MEHDI TAHERI DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=MEHDI TAHERI, dnQualifier=0000012516 Date: 2016.06.09 08:41:14 -05'00' Mehdi Taheri, acting for Willie Lane, Jr. 6/7/2016 Date Date 6ENFORM-019-R6 (10/6/14) 1 El Rancho Mobile Home Park Santa Fe (PWS ID: NM3570426) Inspection Date: 4/21/2016 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Jenna Manheimer and Angela Restivo arrived at El Rancho Mobile Home Park (MHP) Santa Fe on April 21, 2016, for an announced inspection of the drinking water system. We met with Jack Shelburne, Operator, Manager and Landowner at El Rancho MHP, and Gus Vigil, Landowner. I presented my credentials to Mr. Shelburne, and informed him that this was an EPA inspection to assess progress in complying with the Safe Drinking Water Act (SDWA), specifically with the maximum contaminant level (MCL) for uranium and the Groundwater Rule (GWR). The scope of the inspection was to evaluate the drinking water system, including the groundwater source, storage, treatment, pumps, distribution, operations and management, and to determine progress in addressing violations cited in the EPA administrative order (AO), issued on May 20, 2014 (Appendix 2), and deficiencies cited in a sanitary survey by the New Mexico Environment Department (NMED), conducted on March 13, 2015 (Appendix 3). FACILITY DESCRIPTION El Rancho MHP is located west of Pojoaque, just north of highway 502. The drinking water system serves 38 residents, and consists of two active wells, each with a production capacity of 16 gallons per minute (gpm). Each well reaches a total depth of approximately 200 feet, with the intakes at 120 ft. Water was pumped alternatively from each well, with only one running at any given time. Each well feeds into the same distribution piping, running in series directly behind (east of) the property lots. El Rancho MHP has a history of uranium contamination at both Well 1 and Well 2; however, since April 2014, samples at Well 1 have, on average, been significantly lower in uranium than historical results, and below the MCL running annual average (RAA) of 30 g/L. Therefore, as of February 2016, Mr. Shelburn stopped using Well 2, and began pumping solely from Well 1. However, Well 2 was not disconnected from the water system, and can be utilized at any time. Although Well 1's uranium levels are within regulatory limits, there is concern that relying on this source will stress the pump and supply, making it an unsustainable long-term solution for El Rancho MHP. There was coliform contamination in 2014 at various sample sites in El Rancho MHP, both in distribution and at Well 1. Well 1 was flushed and batch chlorinated at that time, while one home suspected to be the source was disconnected from the main distribution line. Mr. Shelburn recently sold property to family members, including Well 2. Since both sides of the MHP property will continue to be operated as a single water system, serving 37 residents through 17 service connections and one distribution system, this property transfer does not alter the size or public water system (PWS) status of El Rancho MHP, confirmed on March 15, 2016, by NMED's Office of General Counsel. 2 El Rancho Mobile Home Park Santa Fe (PWS ID: NM3570426) Inspection Date: 4/21/2016 Section II - OBSERVATIONS Well 1 is located in the middle of a parking lot, inside an underground vault (Appendix 1, Photo 1). The well was protected by a bolted metal covering, but had no well pad, and was surrounded by dirt reaching approximately three inches from top of casing (Appendix 1, Photos 2 & 3). Water from Well 1 flows approximately 50 ft. into a control vault, where it is pressurized by a 120 gallon diaphragm tank. Inside the control vault, there is a flow meter and an abandoned well, which appeared well sealed but close to the floor (Appendix 1, Photo 4). There was also a Culligan filter that, according to Mr. Shelburn, is no longer operable. The corners of the vault have holes dug into the flooring, apparently to collect water, though there were no outlets or drains from these holes to the outside (Appendix 1, Photo 5). According to Mr. Shelburn and Mr. Vigil, the vault has never flooded. Water inside the vault T's, with one side going to a home and the other side leading to the rest of distribution. The valve to the home was closed following the coliform positives in 2014, as Mr. Shelburn suspected that the frost free tap on that house was the source of contamination. Well 2 is located just less than a of a mile from Well 1 in a vault, next to a frost free spigot (Appendix 1, Photo 6). Water from this spigot is used by NMED as a finished water entry point sample tap for compliance for both wells, according to Mr. Shelburn. This tap would represent Well 2 when this source is running, but could only represent Well 1 if Well 2 is off and water from Well 1 were allowed to flow through distribution and over to this spigot. Since use of Well 2 ceased, its power supply was turned off; however, the pressure gauge adjacent to well showed a reading of about 50 psi at the time of inspection (Appendix 1, Photo 7). Also, the flow meter down the line from Well 2 and pressure tank was moving, and the valve flowing into distribution along this same line was open (Appendix 1, Photo 8). Well 2's casing terminates close to the vault floor, and a sideways hose bib tap is connected to the top of wellhead (Appendix 1, Photo 7). Section III - AREAS OF CONCERN Uranium Uranium fluctuates at Well 1, and is consistently high at Well 2. Uranium levels at Well 1 could increase in the future. There is currently no adequate treatment plan proposed for either well, as funding is an issue. Without adequate backup, Well 1's pump or supply could be stressed. Well 1 One private consultant, Goodwater, has worked with El Rancho MHP in the past, but since the technology offered was never purchased, this company is no longer interested in doing business with Mr. Shelburn. Plans submitted to NMED in April 2014 for treatment with Metsorb media were incomplete, lacking proper data from field testing that demonstrated effective removal. Reverse osmosis (RO) is approved for uranium removal, while other patented media must be approved for use based on robust performance results. Needs a well pad around casing that extends 3 ft. in each direction to prevent contamination of aquifer. 3 El Rancho Mobile Home Park Santa Fe (PWS ID: NM3570426) Inspection Date: 4/21/2016 Wellhead must be raised 12-18 inches above grade. If left inside vault, it should be raised as high as possible to the top of vault chamber. Well 2 Casing must terminate 12-18 inches above grade. Since well is inside a vault, it should terminate at least 12-18 inches above the floor of vault. Hose bib taps do not provide adequate seals and must be removed from wellhead. If Well 2 will not be used as a primary source, it must be adequately disconnected from the distribution system (at a minimum, valves should be closed to ensure that water is not entering distribution). Operations NMED's 2015 sanitary survey cited deficiencies that remain unaddressed, including no emergency response plan and inadequate sampling plans (Appendix 3). Section IV - FOLLOW UP Collaborate with NMED to determine if current frost-free spigot next to Well 2 is an appropriate entry point sample site for finished water from both wells. On May 2, 2016, EPA called Goodwater Company to obtain history about El Rancho MHP and information on the proposed uranium removal technology. Nancy Prosser at Goodwater referred EPA to the manufacturer of Metsorb media, Graver Industries. Nichole Pennisi from Graver stated that Metsorb adsorption media works well to remove heavy metals, and on May 3, 2016, provided letters from Maricopa County in Arizona approving Metsorb for arsenic removal, after the completion of a 12 month pilot test. In order to approve Metsorb technology for uranium removal, NMED or any other regulatory agency would need pilot test data specifically demonstrating adequate reduction of uranium. This data was requested in a follow-up emails from EPA to Graver on May 3, 2016 and May 25, 2016, pending response. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 8 photos, taken 4/21/2016 Appendix 2 - Enforcement History Appendix 3 - NMED's Sanitary Survey, conducted March 13, 2015 4 El Rancho Mobile Home Park Santa Fe (PWS ID: NM3570426) Inspection Date: 4/21/2016 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: El Rancho Mobile Home Park Santa Fe Water System City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: 6-Well 1 Pad & Closed Vault.JPG Date of Photo: 4/21/2016 Time of Photo: 12:43 Photographer: Angela Restivo Description: Well 1 sealed with metal covering in the middle of parking lot. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: El Rancho Mobile Home Park Santa Fe Water System City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: 7B-Well 1 Vault.JPG Date of Photo: 4/21/2016 Time of Photo: 12:37 Photographer: Jenna Manheimer Description: Inside Well 1 - loose gravel around casing and no well pad. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: El Rancho Mobile Home Park Santa Fe Water System City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: 8-Well 1.JPG Date of Photo: 4/21/2016 Time of Photo: 12:38 Photographer: Jenna Manheimer Description: Inside Well 1 - loose dirt and gravel surrounded casing, reaching approximately 3 inches from top of wellhead. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: El Rancho Mobile Home Park Santa Fe Water System City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: 2-Well 1 Flow Meter & Abandoned Well.JPG Date of Photo: 4/21/2016 Time of Photo: 11:49 Photographer: Jenna Manheimer Description: Inside control vault for Well 1, there was a flow meter and abandoned well, which appeared well sealed, but close to the floor. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: El Rancho Mobile Home Park Santa Fe Water System City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: 4-Well 1 Pressure Tank, Filter & Pipes.JPG Date of Photo: 4/21/2016 Time of Photo: 11:57 Photographer: Jenna Manheimer Description: 120 gallon pressure tank and inoperable Culligan filter in control vault for Well 1, with holes dug out of corners and no outlet to the outside. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: El Rancho Mobile Home Park Santa Fe Water System City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: 9A-Well 2 Vault & Frost Free Spigot.JPG Date of Photo: 4/21/2016 Time of Photo: 12:45 Photographer: Angela Restivo Description: Well 2 is located in a vault, next to a frost free spigot. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: El Rancho Mobile Home Park Santa Fe Water System City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: 10A-Well 2.JPG Date of Photo: 4/21/2016 Time of Photo: 12:46 Photographer: Jenna Manheimer Description: Well 2 is capped with a hose bib tap, its casing terminates just above vault floor, and pressure gauge showed a reading of about 50 psi. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: El Rancho Mobile Home Park Santa Fe Water System City: Santa Fe County/Parish: Santa Fe State: NM Photo File Name: 11-Well 2 Vault, Tank, Pipes & Flow Meter.JPG Date of Photo: 4/21/2016 Time of Photo: 12:47 Photographer: Jenna Manheimer Description: Flow meter downstream from Well 2 and pressure tank was moving, and the valve along line into distribution was open. El Rancho Mobile Home Park Santa Fe (PWS ID: NM3570426) Inspection Date: 4/21/2016 Appendix 2 Enforcement History El Rancho Mobile Home Park Santa Fe (PWS ID: NM3570426) Inspection Date: 4/21/2016 Appendix 3 NMED Sanitary Survey Conducted March 13, 2015 SUSANA MARTINEZ Governor JOHN A. SANCHEZ Lieutenant Governor NEW MEXICO ENVIRONMENT DEPARTMENT 5500 San Antonio Dr NE Albuquerque, NM 87109 Tel. 505-222-9590 Fax 505-222-9510 Toll Free 1-877-654-8720 www.nmenv.state.nm.us 3/30/2015 Jack Shelburn El Rancho Mobile Home Park Santa Fe, NM3570426 58 A Evergreen Lane Santa Fe, NM 87506 RE: 2015 Sanitary Survey Report RYAN FLYNN Cabinet Secretary BUTCH TONGATE Deputy Secretary Dear Jack Shelburn: Enclosed is the Sanitary Survey Report for the El Rancho Mobile Home Park Santa Fe water system, conducted on 3/13/15 by Jeff Pompeo of the New Mexico Environment Department Drinking Water Bureau (DWB). During the survey three significant deficiencies were identified and no recommendation(s) were provided. El Rancho Mobile Home Park Santa Fe water system must consult with the DWB within 30 days and take corrective action on the three significant deficiencies no later than 120 days after receipt of this sanitary survey report, or be in compliance with a DWB-approved schedule and plan for correcting these deficiencies within the same 120 day period. Failure to correct any significant deficiency will result in a treatment technique violation of NMAC 20.7.10.100 incorporating 40 C.F.R. 141 Subpart S. If you have any questions or need to send additional information/documentation concerning this report please call 505-222-9590 or e-mail jeff.pompeo@state.nm.us. Respectfully, Jeff Pompeo, Compliance Officer Drinking Water Bureau Water Protection Division Enclosures: Sanitary Survey Report Cc: Region Supervisor (electronic) El Rancho Mobile Home Park Santa Fe water system Area Office file Magneto system file SANITARY SURVEY REPORT For El Rancho Mobile Home Park Santa Fe NM3570426 Este informe contiene informacin importante acerca de su agua potable. Haga que alguien lo traduzca para usted, o hable con alguien que lo entienda. Prepared by: Jeff Pompeo New Mexico Environment Department 1190 St. Francis PO Box 5469 Santa Fe, NM 87502-5469 505.476.8620 3/13/15 State of New Mexico Environment Department Environmental Health Division Drinking Water Bureau 5500 San Antonio Dr NE Albuquerque, NM 87109 RECORD OF INSPECTION This Sanitary Survey Report fulfills the requirements of New Mexico Administrative Code 20.7.10.100 incorporating 40 Code of Federal Regulations 141.21(d) (ii) (2) and 142.16(o)(2) for completing a State approved survey. The information and data was prepared by Jeff Pompeo Compliance Officer. NMED APPROVING AUTHORITY: ______________________________ Date: ________________ Jeff Pompeo Compliance Officer El Rancho Mobile Home Park Santa Fe Sanitary Survey Report 3/13/15 Page |3 Introduction A sanitary survey enables the NMED Drinking Water Bureau Water (DWB) to provide a comprehensive and accurate review of the components of a water system, to assess the operating condition and adequacy of the water system, and to determine if past recommendations have been implemented effectively. The purpose of the sanitary survey is to evaluate and document the capabilities of the water system's sources, treatment, storage, distribution network, operation and maintenance, and overall management to ensure the provision of safe water. As part of a sanitary survey the DWB conducted a site inspection of the El Rancho Mobile Home Park Santa Fe water system. The site inspection was conducted by Compliance Officer Jeff Pompeo, and accompanied by El Rancho Mobile Home Park Santa Fe water system operator, Jack Shelburn. In addition to the site inspection, DWB reviewed various operational, managerial, and financial documents submitted by the El Rancho Mobile Home Park Santa Fe water system and conducted a review of DWB compliance files for the water system. System Description The El Rancho Mobile Home Park Santa Fe water system has approximately 40 year round and is classified as a Community water system according to the New Mexico Drinking Water Regulations 20.7.10 NMAC. The water system consists of two wells, three pressure tanks, and distribution. The two wells can produce a total of 25 gallons per minute (GPM). The pressure tanks have a capacity of 60 gallons and 100 gallons respectively. The distribution network consists of all PVC piping. The El Rancho Mobile Home Park water system was issued an Administrative Order (AO) dated September 15, 2009 for exceeding the Uranium MCL at both wells. Survey Findings Sanitary surveys serve as a proactive public health measure and can provide important information on a water system's design and operations, can identify minor and significant deficiencies for correction before they become major problems, and can improve overall system compliance. The following significant and minor deficiencies were identified during the sanitary survey. Significant Deficiencies: A significant deficiency is defined as any deficiency that is causing or has the potential to cause a threat to public health [New Mexico Administrative Code (NMAC) 20.7.10.100 incorporating 40 Code of Federal Regulations (CFR) 141.403(a)(4)]. Water systems must consult with DWB within 30 days and take corrective action for any significant deficiencies found during the sanitary survey no later than 120 days after receiving written notification of such deficiencies, or be in compliance with a DWB-approved schedule and plan for correcting these deficiencies within the same 120 day period [NMAC 20.7.10.100 incorporating 40 CFR 141.403(a)(4) and 141.403(a)(5)(i)-(ii)]. Failure to remedy any significant deficiency will result in a treatment technique violation of NMAC 20.7.10.100 incorporating 40 CFR Part 141 Subpart S. A total of three significant deficiencies were identified at the El Rancho Mobile Home Park Santa Fe water system during the survey. 1. Deficiency: 001W. Lack of an Emergency Response Plan Regulatory Citation: 20.7.10.400.E NMAC El Rancho Mobile Home Park Santa Fe Sanitary Survey Report 3/13/15 Page |4 Concern/Description: Operation/Management. Lack of an adequate Emergency Plan could lead to extended delays in supplying safe potable drinking water during minor or major emergencies. Public Water Systems that assess their vulnerabilities and adopt thorough emergency response plans are minimizing the likelihood of major delays in supplying safe potable drinking water to their customers. Emergency plan is not functional. Corrective Action: Please submit a copy of an adequate Emergency Response Plan that is specific to El Rancho Mobile Home Park Santa Fe. 2. Deficiency: 003R. No or inadequate sampling plans and/or schedules for Total Coliform Rule, Lead and Copper Rule, collection of SOC, VOC, IOC, Radionuclide, and Nitrate-Nitrite samples Regulatory Citation: 40 CFR 141.33(f) Concern/Description: Confirmation/Monitoring. Lack of a sampling plan can result in a water system failing to collect samples or collecting them from the wrong location. If samples are not collected or collected from the wrong location the system will be unaware if they are exceeding the MCL. Exceeding the MCL can result in health issues. Corrective Action: Please submit a copy of an adequate sampling plan that is specific to the El Rancho Mobile Home Park Santa Fe. 3. Deficiency: 001L. Well head or spring box is not secured from the elements or intrusion or is susceptible to flooding Regulatory Citation: 20.7.10.400.C NMAC Concern/Description: Direct contamination. Properly protected well heads, spring boxes and casings prevent contaminated water, insects, vermin, or other potential contaminants from entering the well and/or aquifer. Facilities which are susceptible to flooding have an increased potential for contamination by surface water. Potential for cross contamination. Corrective Action: Access port on well that is no longer in use needs to be a sealed. Minor Deficiencies: The following are minor deficiencies which DWB recommends be corrected before the next sanitary survey to ensure the deficiencies do not become significant. 1. Deficiency: No minor deficiencies were found, therefore, there are no recommendations at this time. Conclusion The sanitary survey for the El Rancho Mobile Home Park Santa Fe water system was completed on 3/13/15. Based upon the onsite inspection and review of various operational and managerial documents and of DWB compliance files, three significant deficiencies were identified and no minor deficiencies El Rancho Mobile Home Park Santa Fe Sanitary Survey Report 3/13/15 Page |5 were identified. The El Rancho Mobile Home Park Santa Fe water system must comply with the following bullets in the correction of these deficiencies. Upon receipt of this report, the El Rancho Mobile Home Park Santa Fe water system must consult with the DWB within 30 days for all significant deficiencies (i.e., provide written documentation to DWB within 30 days of receipt of this report stating how and when each significant deficiency will be addressed). Failure to consult with DWB within 30 days on all significant deficiencies will result in a monitoring and reporting violation of NMAC 20.7.10.100 incorporating 40 CFR Par 141 Subpart S. The El Rancho Mobile Home Park Santa Fe water system must take corrective action on all significant deficiencies no later than 120 days after receiving written notification of such deficiencies, OR be in compliance with a DWB approved schedule and plan for correcting these deficiencies within 120 days. Failure to correct any significant deficiency in accordance with the previous bullet will result in a treatment technique violation of NMAC 20.7.10.100 incorporating 40 CFR Part 141 Subpart S. In addition, the El Rancho Mobile Home Park Santa Fe must provide written documentation to the DWB within 30 days of completing corrective action for each significant deficiency. Failure to submit documentation within 30 days will result in a monitoring and reporting violation of NMAC 20.7.10.100 incorporating 40 CFR Part 141 Subpart S. If you have any questions or need to send additional information/documentation concerning this report please call 505-222-9590 or e-mail jeff.pompeo@state.nm.us.