Document 5LGyE5X2ovqrEy6K7wow2xpJz

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 04/18/2016 Water SDWA Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Santa Socorro Trailer Park Santa Socorro Trailer Park 3149 Highway 47 Los Lunas, NM 87031 P.O. Box 537 Los Lunas, NM 87031 Valencia County Hilda Montano 505.865.9898 FRS Number: Identification/Permit Number: NAICS: SIC: 110064843193 NM3577532 N/A 4941 Personnel participating in inspection: Hilda Montano Santa Socorro Lorina Sandoval Santa Socorro Angela Restivo EPA/6WQ-SD Jenna Manheimer EPA/6EN-WR Owner Owner Manager Compliance Officer Enforcement Officer 505.865.9898 505.507.4313 214.665.7123 214.665.7318 EPA Lead Inspector Signature/Date Supervisor Signature/Date Jenna Manheimer WILLIE LANE Willie Lane, Jr. Digitally signed by WILLIE LANE DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=WILLIE LANE, dnQualifier=0000007235 Date: 2016.05.23 08:25:32 -05'00' 5/20/2016 Date Date 6ENFORM-019-R6 (10/6/14) 1 Santa Socorro Trailer Park (PWS ID: NM3577532) Inspection Date: 4/18/2016 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Jenna Manheimer and Angela Restivo arrived at the Santa Socorro Trailer Park at 9:25 am on April 18, 2016, for an announced inspection. We drove around the property to assess how many lots are connected to the well, and where the well(s) are located. We located three wells, though could not decipher which well belonged to which property. We met with Lorina Sandoval, Property Manager, at 9:30 am and Hilda Montano, Property Owner, at 9:40 am. I presented my credentials to Hilda Montano and informed her that this was an EPA inspection to determine compliance with the Safe Drinking Water Act (SDWA). The scope of the inspection was to determine progress in addressing the Environmental Protection Agency's (EPA) administrative order (AO), issued on September 21, 2015, for failure to collect routine and repeat total coliform (TC) samples, and failure to correct sanitary deficiencies identified by the New Mexico Environment Department (NMED) during a sanitary survey, conducted on June 19, 2014 (Appendix 2). The purpose of the inspection was also to confirm that Santa Socorro Trailer Park operates a public water system (PWS), and to discuss sampling requirements in detail. FACILITY DESCRIPTION Santa Socorro Trailer Park is located southeast of Los Lunas on Highway 47. The drinking water system consists of one active well, located just west of Lot C and north of the storage facility (Appendix 1, Photo 1), one abandoned well, located on lot Q, and four hydropneumatic storage/pressure tanks. The trailer park has one septic system for every two trailers. There was no certified operator or sampler to service the water system at the time of inspection, though at least one of Ms. Montano's family members is a plumber, and assists with water system maintenance. Santa Socorro Trailer Park has a history of positive coliform bacteria, both at the source and in distribution. In June and July of 2015, a total of five routine and repeat samples in distribution were positive for TC, while one sample at Well 1 was positive. The well was reportedly shut down for 24 hours while all storage tanks were drained and chlorine was poured down the wellhead. Following disinfection, all lines were flushed by the operator at that time, Matthew Maez, on July 14, 2015, about two weeks after the first positive TC was collected. Subsequent TC samples from distribution were negative through December 2015; Ms. Montano then ceased monitoring in January 2016, as she believed that Santa Socorro should not be regulated as a PWS. Section II - OBSERVATIONS Ms. Montano contests that Santa Socorro Trailer Park is a PWS, though according to a population count provided by her, there are just over 25 residents. A county law passed last year prohibits travel trailers from stationing on private property such as Santa Socorro, and as a result, five trailers were forced to move off of the property, leading to a loss of 10-15 residents. According to Ms. Montano, Santa Socorro 2 Santa Socorro Trailer Park (PWS ID: NM3577532) Inspection Date: 4/18/2016 has only 10 homes on 12 lots, three of which are empty, and a total of 27 residents, including a newborn baby. She provided us with a list of property lots and resident names (Appendix 3); however, several lots appear to be missing from the list. Ms. Montano stated that Lots N and R are not being used and could therefore be disconnected from the water supply, if it would allow her to avoid regulation as a PWS. Ms. Montano stated several times during the inspection that she does not want to operate a PWS. She anticipates that the trailer park will lose at least two residents in the near future, which would put her right at the threshold of a PWS, according to her population count. However, Ms. Montano and Ms. Sandoval mentioned at least two residents, whose names were not disclosed on the sheet provided, indicating that the total number of residents may be well over 25. At the time of inspection, EPA told Ms. Montano that Santa Socorro Trailer Park is a PWS due to both population and number of service connections, and that she must comply with the SDWA, namely sampling and certified operator requirements. NMED's 2014 sanitary survey cited a lack of site security at the well head. Well #1 is 120 feet deep and is protected by metal bars to prevent cars from running it over. Since the sanitary survey, the wellhead has been adequately protected with a heavy, sealed, locked metal covering (Appendix 1, Photo 2). Ms. Montano removes the covering, and well cap is sealed tightly, and well pad is intact with approximately 2.5 feet of concrete on each side. Screening underneath cap is loose and not 24 mesh (Appendix 1, Photo 3). Lot C, located about two hundred feet from Well 1, is available for camper parking, but was not being used at the time of inspection (Appendix 1, Photo 4). However, Lot C's service connection is a hose that was lying on the ground surrounded by debris (Appendix 1, Photo 5). The tap opened easily, but would not close completely. There were two Well-X-Trol hydropneumatic pressure tanks on Lot C, stored inside of a shed with insulation. The line connecting storage tanks to the rest of system was leaking (Appendix 1, Photo 6). We inspected two additional storage tanks, located inside a shed on Lot Q that also contains an inactive well (Appendix 1, Photos 7 & 8). Ms. Montano claimed that the abandoned well was in a different location nearby, but did not remember exactly where. She stated that her husband sealed it with a cap below ground over 10 years ago, though it could be rehabilitated if necessary. The well we observed inside the shed was unprotected - there was no well pad, and the ground surrounding well was uneven, cracked and full of debris (Appendix 1, Photo 8). The cap on well was loose, not sealed, and electrical connection entering wellhead appears intact and is unsealed. Section III - AREAS OF CONCERN There was no certified drinking water operator employed at Santa Socorro Trailer Park at the time of inspection. Screen on Well 1 should be 24 mesh, sealed tightly around wellhead. 3 Santa Socorro Trailer Park (PWS ID: NM3577532) Inspection Date: 4/18/2016 The service connection on Lot C was a cross connection and a potential source of contamination into distribution. Due to its proximity to Well 1 and tendency to leak, it is imperative to either disconnect the line, or retrofit it with a hose that is not subject to contamination from dirt and surrounding debris. Water lines on inlet/outlet of storage tanks on Lot C were leaking. The inactive well on Lot P presents a direct pathway of contamination into the aquifer and must be protected with a tight seal around cap and wellhead. The inactive well should have an intact, concrete pad, and electrical conduit should be disconnected and sealed. Alternatively, the inactive well on Lot P should be abandoned according to NMED standards. All contaminant sampling must commence at Santa Socorro Trailer Park, in accordance with the SDWA and sampling schedules set by NMED, including coliform monitoring. Due to past bacteriological contamination at the source and lack of disinfection, it is imperative to correct all sanitary defects, eliminate cross connections, and prevent potential pathways of contamination. Section IV - FOLLOW UP Following the conclusion of EPA's inspection, Aaron Beckworth from NMED assisted in locating a certified sampler and operator, and a coliform sample was collected in distribution on April 28, 2016. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 8 photos, taken 4/18/2016 Appendix 2 - NMED Sanitary Survey, conducted 6/19/2014 Appendix 3 - List of residents, provided by Ms. Montano 4/18/2016 4 Santa Socorro Trailer Park Water System (PWSID: NM3577532) Inspection Date: 4/18/2016 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Santa Socorro Trailer Park Water System City: Los Lunas County/Parish: Valencia County State: NM Photo File Name: 1-Well 1 Overview.JPG Date of Photo: 4/18/2016 Time of Photo: 11:58 Photographer: Angela Restivo Description: Well #1 located near Hwy 47, protected from cars with vertical metal bars. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Santa Socorro Trailer Park Water System City: Los Lunas County/Parish: Valencia County State: NM Photo File Name: 2-Well 1.JPG Date of Photo: 4/18/2016 Time of Photo: 11:59 Photographer: Angela Restivo Description: Metal case with lock added to Well #1 for wellhead protection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Santa Socorro Trailer Park Water System City: Los Lunas County/Parish: Valencia County State: NM Photo File Name: 4-Well 1 Mesh Seal.JPG Date of Photo: 4/18/2016 Time of Photo: 12:01 Photographer: Angela Restivo Description: Sealed cap on Well #1, but screen is loose and not 24 mesh. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Santa Socorro Trailer Park Water System City: Los Lunas County/Parish: Valencia County State: NM Photo File Name: 7-Lot C Overview.JPG Date of Photo: 4/18/2016 Time of Photo: 11:58 Photographer: Angela Restivo Description: Lot C overview with debris. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Santa Socorro Trailer Park Water System City: Los Lunas County/Parish: Valencia County State: NM Photo File Name: 5-Lot C Running Service Connection.JPG Date of Photo: 4/18/2016 Time of Photo: 11:56 Photographer: Angela Restivo Description: Lot C with exposed, active service connection subject to cross contamination. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Santa Socorro Trailer Park Water System City: Los Lunas County/Parish: Valencia County State: NM Photo File Name: 10-Connection to Lot C STs.JPG Date of Photo: 4/18/2016 Time of Photo: 12:11 Photographer: Angela Restivo Description: Hydropneumatic pressure tanks are stored inside shed on Lot C; water line flowing into/out of tanks is leaking. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Santa Socorro Trailer Park Water System City: Los Lunas County/Parish: Valencia County State: NM Photo File Name: 14-Lot P Shed with STs.JPG Date of Photo: 4/18/2016 Time of Photo: 12:19 Photographer: Angela Restivo Description: Hydropneumatic pressure tanks are stored inside shed on Lot P, covered with insulation. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Santa Socorro Trailer Park Water System City: Los Lunas County/Parish: Valencia County State: NM Photo File Name: 13-Lot P Older Well.JPG Date of Photo: 4/18/2016 Time of Photo: 12:20 Photographer: Angela Restivo Description: Inactive well inside shed on Lot P is not properly sealed or protected. Santa Socorro Trailer Park Water System (PWSID: NM3577532) Inspection Date: 4/18/2016 Appendix 2 New Mexico Environment Department Sanitary Survey Conducted June 19, 2014 Santa Socorro Trailer Park Water System (PWSID: NM3577532) Inspection Date: 4/18/2016 Appendix 3 List of Residents Provided by Hilda Montano April 18, 2016