Document B1onEoMpgvxaG39Bok5a9Erm

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 07/10/2024 Water NPDES Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: U.S. Bureau of Reclamation Cutter Treatment Plant Lateral (CTPL) CR 7575, 3 miles east of Highway 550/CR 7575 (Huerfano Turnout) Farmington, NM 87401 1235 La Plata HWY Farmington, New Mexico 87401 San Juan 505-729-6277 Kyle Burns Site Superintendent kyleburns@jacobs.com FRS Number: Identification/Permit Number: NAICS: SIC: 110070249835 NM0031194 221310 4941 Personnel participating in inspection: Kyle Burns Jacobs-Contract Operator David Esparza EPA/R6-ECDWM Site Superintendent Environmental Engineer EPA Lead Inspector Signature/Date DAVID ESPARZA Date: 2024.09.10 10:06:39 -06'00' Digitally signed by DAVID ESPARZA David Esparza Date Supervisor Signature/Date ROBERTO BERNIER Roberto Bernier Digitally signed by ROBERTO BERNIER Date: 2024.09.10 11:48:39 -05'00' Date 6ENFORM-019-R8.2 (02/12/2020) 1 U.S. Bureau of Reclamation/Cutter TPL Permit No: NM0031194 Inspection Date 07/10/2024 Section I - INTRODUCTION PURPOSE OF THE INSPECTION United States Environmental Protection Agency (EPA) Region 6 inspector David Esparza, PE, arrived at the U.S. Bureau of Reclamation/Cutter Treatment Plant Lateral (CTPL) at approximately 11:45 AM on July 10, 2024, for an unannounced inspection. I presented my credentials to Mr. Kyle Burns, Site Superintendent, Jacobs-contract operator and informed him 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. It should also be noted CTPL maintains a discharge permit (DP-1892) issued by the New Mexico Environment Department (NMED), Groundwater Quality Bureau (GWQB) that allows a permitted discharge to an evaporative lagoon of up to 0.37MGD. The generation of this report is based on information supplied by CTPL representatives, observations made by the EPA inspector, and records and reports maintained by the permittee (CTPL), and the EPA. Before leaving the facility on July 10, 2024, an exit briefing was held with Mr. Burns, to explain areas of concern noted at the time of the inspection. FACILITY DESCRIPTION The CTPL has design flow of 3.0 MGD in 2020 (Phase 1). Currently, the plant is producing 10% of Phase 1 design flow and is located approximately 2.75-miles Northwest of the Dzilth-Na-O-Dith-Hle Boarding School (aka DZ School) along County Road 7575 at Huerfano Turnout, San Juan County, New Mexico (denoted in Aerial Image #1 below). CTPL hours of operation are Monday through Friday 8:00 AM to 5:00 PM and consists of a staff of 4 full-time equivalent (FTE) positions. 2 U.S. Bureau of Reclamation/Cutter TPL Permit No: NM0031194 Inspection Date 07/10/2024 Aerial Image #1: Overall view of the U.S. Bureau of Reclamation-Cutter Treatment Plant Facility. Note: this Aerial Image is dated April 4, 2024, and illustrates the existing Treatment Plant. Aerial from Google Earth maps. The CTPL, is part of the Navajo Gallup Water Supply Project (NGWSP), a major infrastructure project that once constructed, will convey a reliable municipal water supply from the Cutter Reservoir to the eastern section of the Navajo Nation and the southwestern portion of the Jicarilla Apache Nation; and from the San Juan River to the western portion of the project to the Navajo Nation Chapters along US 491, the City of Gallup, New Mexico, Window Rock, Arizona, Crownpoint, New Mexico and others via about 280 miles of pipeline. The CTPL process includes coagulation, flocculation, and filtration processes with added granular activated carbon (GAC) absorption during startup and low flow influent flow rates. The decant flow stream to NPDES discharge is comprised of two flow streams - the backwash waste/off spec ponds and the solids drying beds decant flows. The decant from the backwash waste/off spec ponds and the sludge drying ponds is sent to the decant pump station, which then pumps to the NPDES discharge point passing through a storm water detention pond/evaporative lagoon to Outfall 001. The discharge is to Blanco Wash, a tributary of Canon Largo, thence to San Juan River. Sludge is transported to a landfill for disposal. Flow metering and sampling occurs prior to entering the storm water detention pond. The storm water drained to the pond is not regulated in this permit because the facility is not required coverage under a Municipal Separate Storm Sewer System (MS4) or multi-sector general permit, and the storm water detention pond is not part of the water treatment process. The plant has been designed with the ability to recycle the backwash waste/off spec ponds and solids drying beds decant flows to the head of the plant. Additionally, CTPL has implemented written policies and procedures to address any potential sanitary sewer overflow events (SSOs), and standard operating procedures (SOPs) pertaining facility operations and maintenance (O&M). Furthermore, a Supervisory Control and Data Acquisition (SCADA) system provides around the clock monitoring of CTPL operations. Section II - OBSERVATIONS I observed the following and/or the following information was provided or stated on July 10, 2024. The U.S. Bureau of Reclamation (BoR) was the original owner and NPDES permittee of the Cutter Treatment Plant Lateral (CTPL), circa 2018. In January 2024 a new NPDES permit was issued to the facility in the name of the Navajo Tribal Utility Authority (NTUA). Currently the CTPL is in the process of commissioning and will be operated by the NTUA. The CTPL is currently operating at approximately 0.3 MGD or about 10% of the anticipated 3.5 million gallons per day design flow volume and could potentially discharge an average flow of 0.12 MGD. The facility receives raw water from Pumping Plant No. 2 located approximately 1-mile Northeast along Reach 22B of the overall project. 3 U.S. Bureau of Reclamation/Cutter TPL Permit No: NM0031194 Inspection Date 07/10/2024 The CTPL is monitored and controlled with a supervisory control and data acquisition (SCADA) and call-out system. The on-site laboratory analytical analysis consists of alkalinity and pH. All additional samples are forwarded to Hall Laboratory (Eurofins) for analysis. Note: the pH-8 and pH-10 buffers were both expired (March 2024). Additionally, a review of the "bench sheet data" appears to indicate the recorded pH values (June 24, 2024) are outside the permitted ranges of 6.43 to 7.21 (S.U.) for the previous NPDES permit (expired in 2023), but within the ranges 6.6 to 9.0 (S.U) in the new permit (issued in January 2024) in some analysis. Note: the recorded values for the sedimentation basins effluent #1 and #2, and the flocculation/sedimentation basins (top) #1 and #2 are outside the ranges for either the old or new NPDES permit. Furthermore a review of the Integrated Computer Information System (ICIS) database indicates no evidence of submission of the required discharge monitoring reports since the 1st quarter of 2021. The changes from the previous permit that expired on December 29, 2023, include: Mass limitation for Total Suspended Solids (TSS) has been removed. Limits for copper have been added. Monitoring for hardness has been added. Monitoring frequency for TSS has been changed to "Daily" from "Weekly". The CTPL maintains a backup diesel generator for power that is routinely exercised. However, delivery of raw water relies of Pumping Plant No. 2 located approximately 1-mile Northeast along Reach 22B of the overall project. CTPL had secure perimeter fencing; thus, limiting access. The overall operations and maintenance (O&M), and general facility housekeeping appeared to be in good order. Section III - AREAS OF CONCERN The following Areas of Concern (AOCs) were identified: 1. The on-site laboratory analytical analysis consists of alkalinity and pH. All additional samples are forwarded to Hall Laboratory (Eurofins). Note: the pH-8 and pH-10 were both expired (March 2024). Additionally, a review of the "bench sheet data" appears to indicate the recorded pH values (June 24, 2024) are outside the permitted ranges of 6.43 to 7.21 (S.U.) for the previous NPDES permit (expired in 2023), but within the ranges 6.6 to 9.0 (S.U) in the new permit (issued in January 2024) in some analysis. Note: the recorded values for the sedimentation basins effluent #1 and #2, and the flocculation/sedimentation basins (top) #1 and #2 are outside the ranges for either the old or new NPDES permit. EPA Region 6 inspector David Esparza conducted a closing conference at the Cutter Treatment Plant Lateral at 2:30 PM on July 10, 2024, for the inspection. During the closing conference, David Esparza reviewed the Areas of Concern noted during the inspection. 4 U.S. Bureau of Reclamation/Cutter TPL Permit No: NM0031194 Inspection Date 07/10/2024 Section IV - FOLLOW UP The following information was received by EPA on July 18, 2024, after exiting the Facility on July 10, 2024: A current copy of the CTLP Site Plan- denoting each of the treatment processes. An electronic copy of the flow path commencing with the influent flow to discharge point. An electronic copy of the onsite CTLP laboratory bench sheet. A summary of the facility points of contact (POC) (telephone numbers, email addresses and company name). Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 13 photos taken 7/10/2024. Appendix 2 - Cutter Treatment Plant Lateral Process Flow Diagram Appendix 3 - Cutter Treatment Plant Lateral On-site Laboratory Bench Sheet 5 U.S. Bureau of Reclamation/Cutter TPL Permit No: NM0031194 Inspection Date 07/10/2024 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BoR-Cutter Lateral City: Bloomfield Photo No. 1 County/Parish: San Juan State: New Mexico Entrance sign to Cutter Lateral Water Treatment Plant. (IMG_0058) (July 10, 2024: 3:40 PM) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BoR-Cutter Lateral City: Bloomfield Photo No. 2 County/Parish: San Juan State: New Mexico View of the raw water influent lines delivered from Pumping Plant #2 prior to the Rapid Mix process. (IMG_0013) (July 10, 2024: 1:51 PM) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BoR-Cutter Lateral City: Bloomfield Photo No. 3 County/Parish: San Juan State: New Mexico View looking approximately Southwest of the Flocculation/Sedimentation basin after the addition of the polymer. (IMG_0018) (July 10, 2024: 1:55 PM) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BoR-Cutter Lateral City: Bloomfield Photo No. 4 County/Parish: San Juan State: New Mexico View of some of the process sampling equipment. (IMG_0018) (July 10, 2024: 2:01 PM) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BoR-Cutter Lateral City: Bloomfield Photo No. 5 County/Parish: San Juan State: New Mexico View of the location for future expansion adjacent to the existing flocculation/sedimentation basins. Looking approximately West. (IMG_0023) (July 10, 2024: 2:04 PM) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BoR-Cutter Lateral City: Bloomfield Photo No. 6 County/Parish: San Juan State: New Mexico View of the filtration basin inside the CTPL facility. (IMG_0029) (July 10, 2024: 2:09 PM) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BoR-Cutter Lateral City: Bloomfield Photo No. 7 County/Parish: San Juan State: New Mexico View of the granular activated carbon (GAC) filter system inside the CTPL facility. (IMG_0030) (July 10, 2024: 2:12 PM) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BoR-Cutter Lateral City: Bloomfield Photo No. 8 County/Parish: San Juan State: New Mexico View of a portion of the process piping located inside the CTPL facility. (IMG_0031) (July 10, 2024: 2:17 PM) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BoR-Cutter Lateral City: Bloomfield Photo No. 9 County/Parish: San Juan State: New Mexico View of the backwash waste piping from the GAC tanks. (IMG_0036) (July 10, 2024: 2:25 PM) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BoR-Cutter Lateral City: Bloomfield Photo No. 10 County/Parish: San Juan State: New Mexico View of the Hallet ultraviolet (UV) disinfection system. (IMG_0039) (July 10, 2024: 2:30 PM) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BoR-Cutter Lateral City: Bloomfield Photo No. 11 County/Parish: San Juan State: New Mexico View of the solids drying beds. Note: The dried sludge material is transported and disposed at a landfill. (IMG_0046) (July 10, 2024: 2:40 PM) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BoR-Cutter Lateral City: Bloomfield Photo No. 12 County/Parish: San Juan State: New Mexico View of the ph10 and pH8 buffer solutions. Note: Both had expired in March 2024. (IMG_0007) (July 10, 2024: 1:30 PM) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BoR-Cutter Lateral City: Bloomfield Photo No. 13 County/Parish: San Juan State: New Mexico View of the CTPL discharge conduit. Note: It was recommended the vagrant debris be removed. (IMG_0056) (July 10, 2024: 2:57 PM) Photographed by D. Esparza U.S. Bureau of Reclamation/Cutter TPL Permit No: NM0031194 Inspection Date 07/10/2024 Appendix 2 Cutter Treatment Plant Lateral Process Flow Diagram U.S. Bureau of Reclamation/Cutter TPL Permit No: NM0031194 Inspection Date 07/10/2024 Appendix 3 Cutter Treatment Plant Lateral On-site Laboratory Bench Sheet