Document B5a8Qk9xrGk477xjkRRKQV30k
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
02/24/2020 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:
City of Lovington
Lovington Wastewater Treatment Plant
920 East Avenue K
Lovington, New Mexico
Post Office Drawer 1269
Lovington, New Mexico 88260
Lea
575-622-1449
Miguel De la Cruz
Wastewater Superintendent
mdelacruz@lovington.org
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
3601182958 NMU001998 N/A 221320 4952
Personnel participating in inspection:
Wyatt Duncan
City of Lovington
Miguel De la Cruz
City of Lovington
David Esparza
USEPA
Public Works Director Wastewater Superintendent Environmental Engineer
EPA Lead Inspector Signature/Date
DAVID
David Esparza
ESPARZA Digitally signed by DAVID ESPARZA DN: c=US, o=U.S. Government, ou=Environmental Protection Agency,
cn=DAVID ESPARZA, 0.9.2342.19200300.100.1.1=68001003655879
Date: 2020.03.23 12:19:31 -06'00'
Date
Supervisor Signature/Date
CAROL PETERS-WAGNON
Carol Peters
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: 2020.04.02 16:50:41 -05'00'
Date
6ENFORM-020-R8.2 (02/12/2020)
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Section I - INTRODUCTION
City of Lovington/Lovington WWTP
Permit No. NMU001998
Inspection Date 02/24/2020
PURPOSE OF THE INSPECTION
EPA Region 6 inspectors David Esparza, PE, arrived at the City of Lovington Wastewater Treatment Plant (WWTP) (hereinafter referred to as WWTP) at approximately 11:30 AM on February 24, 2020 for an unannounced inspection. I met with Mr. Miguel De La Cruz, Wastewater Superintendent, presented my credentials and informed him that this was an EPA inspection to determine the WWTP's compliance under the Clean Water Act (CWA). We were later joined by Mr. Wyatt Duncan, Public Works Director. This compliance evaluation inspection (CEI) was conducted under the authority 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 Lovington representatives, observations made by the United States Environmental Protection Agency (US EPA) inspector, and records and reports maintained by Lovington, and the US EPA. Before leaving the facility, an exit briefing was held at approximately 4:00 PM with Mr. Duncan and Mr. De La Cruz to explain areas of concern noted at the time of the inspection and request representative photograph copies of the WWTPs records. It should be noted the WWTP is a non-discharging facility; thus, does not have a NPDES permit, but rather maintains a discharge permit (DP-87) issued by the New Mexico Environment Department (NMED), Groundwater Quality Bureau.
FACILITY DESCRIPTION
The WWTP is an SBR (Sequencing Batch Reactor) activated sludge plant. Phase 1 of the SBR came online in November 2006, while Phase 2 came online in February 2007. The existing WWTP has a design capacity of 2.5 MGD (Million Gallons per Day) and is currently treating approximately one-half of design capacity or 1.2 MGD. The facility is located at 920 East Avenue K, Lovington, Lea County, New Mexico (depicted in Aerial Image #1 below). The WWTP facility serves a population of approximately 11,400 (2016 US Census) residents. The WWTP is operated by staff within the Public Works Department and consists of seven (7) full-time equivalent (FTE) positions, exclusive of administrative support during the hours of 6:00 AM to 5:00 PM seven (7) days during the regular work week. On-call staff is available on an as needed basis.
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City of Lovington/Lovington WWTP
Permit No. NMU001998
Inspection Date 02/24/2020
Aerial Image #1: Overall view of the City of Lovington's Wastewater Treatment Plant and the two (2) disinfected effluent storage lagoons. Aerial from Google Earth maps.
A Supervisory Control and Data Acquisition (SCADA) system provides around the clock monitoring of WWTP operations. After entering the WWTP facility via a series of 23 lift stations (Identified in Table 1 below and depicted in Aerial Image #2 below) raw influent enters the headworks consisting of a mechanical bar screen and grit chamber (Appendix 1 Photograph #1 & Photograph #2). Thence two (2) SBR tanks receive the wastewater via four (4) influent pumps. After aeration, mixing, and settling within the SBR's the wastewater is pumped to the aerobic digesters for further breakdown and thickening. Thence the supernatant traverses to the chlorine contact chamber for disinfection (Appendix 1 Photograph #4). The disinfected effluent is then used to water non-food crops on the farm just east of the plant, and it is also used to supplement the watering of Chaparral Park (Lift Station #9) during irrigation season. The WWTP maintains two (2) disinfected effluent storage lagoons measuring 52M gallons and 45M gallons, respectively (depicted in Aerial Image #1 above and Appendix 1 Photograph #3).
Table 1- City of Lovington Lift Stations
City of Lovington Lift Stations
Lift Station Number 1
Lift Station Name 9th & Jefferson
2
Polk & 6th
3
North Love
3
City of Lovington Lift Stations
4
Marks
5
The Hill
6
Love & Avenue R (T-Bird's)
7
Lea County Electric COOP
8
Street Yard (Avenue H & Chaves)
9
Chaparral Park
10
Lea County Oil & Gas (Shamrock)
11
Simpson drive
12
Vet Clinic
13
Eddy
14
Harrison
15
Redman (Haarmeyer)
16
Reed Road #1 (3rd)
17
West Avenue K
18
Cheese Plant
19
USDA Building
20
Police Department
21
Reed Road #2 (3rd)
22
Madison & Chaves
23
Stone
City of Lovington/Lovington WWTP
Permit No. NMU001998
Inspection Date 02/24/2020
Following the aerobic digesters, the sludge traverses to the screw press in preparation for composting. During this process the sludge is mixed with wood chips, cooked for approximately 2-weeks at temperatures at or in excess of 130 F (Fahrenheit), thence allowed to cure and/or cool for approximately four (4) months prior to being sold as screened or unscreened compost (Appendix 1 Photograph #3).
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City of Lovington/Lovington WWTP
Permit No. NMU001998
Inspection Date 02/24/2020
The WWTP maintains a backup diesel generator for power that is exercised weekly, typically every Monday. Currently the only established Industrial User (IU) is the Holly Frontier (Navajo Refining Company, LLCLea Refinery) facility (Appendix 1 Photograph #5). The City of Lovington and the above identified entity entered into an individual wastewater discharge agreement for the disposal of an estimated average flow rate between 90 and 116 GPM (gallons per minute) and up to a maximum of 240 GPM on a 24 hour per day basis. The Navajo - Lea facility is used for "topping" (separating crude oil) in accordance with Petroleum Refining Effluent Guidelines and Standards (40 CFR Part 419). This process separates crude oil into hydrocarbon groups.
Aerial Image #2: Overall view of the City of Lovington's Lift Stations. Aerial from Google Earth maps. Section II - OBSERVATIONS I observed the following and the following information was provided and/or stated:
The drying beds are used for staging the composting sludge material (previously combined with wood chips) and have not been utilized as drying beds circa 2010.
Visual observation of the two (2) disinfected effluent storage lagoons indicated approximate 3feet of freeboard on each lagoon and the liner material good condition (Appendix 1 Photograph #3). The volume of disinfected effluent in these lagoons typically is less than observed, but irrigation has not commenced.
The Cheese Plant (Lift Station #18) is no longer in operation, but the station name remains. 5
City of Lovington/Lovington WWTP
Permit No. NMU001998
Inspection Date 02/24/2020
The WWTP on-site laboratory maintains and updates its written SOP's as necessary, inclusive of appropriate annual equipment certifications and/or calibrations.
The WWTP had secure perimeter fencing; thus, limiting access. The overall WWTP's operations and maintenance (O&M), and general facility housekeeping appeared to be in good order.
The discharge agreement with the IU (Navajo Refining Company) is dated January 17, 1992 for an effective period of 20-years (Appendix 2 Discharge Agreement). Computations of the daily average flow rate and the daily maximum flow rate from Navajo Refining Company- Lea facility information equate to 177.7 gpm and 218 gpm, respectively. Note: this data was for the period December 2018 thru May 2019.
Section III - AREAS OF CONCERN
I observed no areas of concern at the time of the inspection.
Section IV - RECOMMENDATIONS
The Discharge Agreement with the IU (Navajo Refining Company) should be updated (Appendix 2 Discharge Agreement) to minimally delineate a current agreement period, analytical parameters and reporting schedules from Navajo Refining to the City.
Preparation of a written Sanitary Sewer Overflow (SSO) protocol in the event of an SSO.
Section IV - FOLLOW UP
The following information was received by EPA on March 2, 2020, after exiting the Facility on February 26, 2020:
Electronic copy of the current City of Lovington Discharge Agreement with Holly Frontier (Navajo Refining Company) dated January 17, 1992.
A Google Earth aerial depiction of the lift stations.
Section V - LIST OF APPENDICES
Appendix 1 - Photo Log - 5 photos taken 2/24/2020 Appendix 2 - Discharge Agreement Appendix 3 - Navajo Refining-Lea & City of Lovington Spring 2019 Self-Monitoring Report
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City of Lovington/Lovington WWTP Permit No. NMU001998
Inspection Date 02/24/2020
Appendix 1 Photograph Log
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: City of Lovington Wastewater Treatment Plant
City: Lovington
County/Parish: Lea
State: New Mexico
Picture of the WWTP's headworks/bar screen combination used in the removal of rags and other various large debris items contained in the influent flow. February 24, 2020 3:30 PM (DSCN 1714). Photographed by D. Esparza.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: City of Lovington Wastewater Treatment Plant
City: Lovington
County/Parish: Lea
State: New Mexico
Picture of the WWTP's grit chamber adjacent to the headworks/bar screen. February 24, 2020 3:31 PM (DSCN 1715). Photographed by D. Esparza.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: City of Lovington Wastewater Treatment Plant
City: Lovington
County/Parish: Lea
State: New Mexico
Picture of the staged composted sludge along the east side of the WWTP. Note: the 2 disinfected effluent storage lagoons in the background. The lagoon pictured on the upper left is the 45M gallon lagoon and the lagoon pictured at the upper right is the 52M gallon lagoon. Additionally, it should be noted the standing water in the composted sludge is from a recent rain event. February 24, 2020 3:51 PM (DSCN 1719). Photographed by D. Esparza.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 4
Location: City of Lovington Wastewater Treatment Plant
City: Lovington
County/Parish: Lea
State: New Mexico
Picture of the chlorine chamber and the WWTP's automatic sampler. February 24, 2020 3:53 PM (DSCN 1721). Photographed by D. Esparza.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 5
Location: City of Lovington Wastewater Treatment Plant
City: Lovington
County/Parish: Lea
State: New Mexico
Picture of the signage of the WWTP's Industrial User. February 24, 2020 4:57 PM (DSCN 1723). Photographed by D. Esparza.
City of Lovington/Lovington WWTP Permit No. NMU001998
Inspection Date 02/24/2020
Appendix 2 City of Lovington Discharge Agreement
City of Lovington/Lovington WWTP Permit No. NMU001998
Inspection Date 02/24/2020
Appendix 3 Navajo Refining-Lea & City of Lovington Spring 2019
Self-Monitoring Report