Document EdEKLbDbYnqm7yaDxYgJ6Yp8n

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) August 28, 2023 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 Aztec Aztec Water Treatment plant New Mexico State Highway (NM) 173 (Navajo Dam Drive) Aztec, New Mexico 87410 201 W. Chaco Aztec, New Mexico 87410 San Juan 505-334-7660 Ruben Salcido Public Works Director rsalcido@aztecnm.gov FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110017849649 NM0028762 N/A 221320 4952 Personnel participating in inspection: William Mazzeo City of Aztec Anthony Garcia City of Aztec David Esparza, P.E. USEPA/R6-ECDWM Water Plant Operation Supervisor Wastewater Operations Supervisor Environmental Engineer EPA Lead Inspector Signature/Date DAVID ESPARZA David Esparza Digitally signed by DAVID ESPARZA Date: 2023.10.17 15:42:44 -06'00' Date Supervisor Signature/Date ROBERTO BERNIER Date: 2023.10.23 16:48:37 -05'00' Digitally signed by ROBERTO BERNIER Roberto Bernier Date 6ENFORM-020-R8.2 (02/12/2020) 1 City of Aztec/Aztec Water Treatment Plant NPDES permit No. NM0028762 Inspection Date August 28, 2023 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspector David Esparza, PE, arrived at the City of Aztec Water Treatment Plant (WTP) at approximately 1:00 PM on August 28, 2023, for an unannounced inspection. I met with William Mazzeo, Water Plant Operation Supervisor, and Mr. Lorenzo Anthony Garcia, Chief Wastewater Operator, presented my credentials, and informed them that this was an EPA inspection to determine the WWTP's compliance under the Clean Water Act (CWA) and the requirements of the National Pollutant Discharge Elimination System (NPDES) permit program. The generation of this report is based on information supplied by Aztec representatives, observations made by the United States Environmental Protection Agency (EPA) inspector, and records and reports maintained by the permittee (Aztec) and the EPA. Before leaving the facility, an exit briefing was held with Mr. Mazzeo, and the above-mentioned staff, to explain areas of concern noted at the time of the inspection. FACILITY DESCRIPTION City of Aztec operates four (4) water treatment trains using a combination of coagulation, flocculation, and various media filters, including anthracite coal, plastic pellets, and garnet and silica sand. The oldest treatment train (#1), constructed during the 1940s, consists of solids contact clarifier and two (2) conventional rapid sand filters with a conventional backwash mechanism. Train #2, constructed during the 1950s, is a newer design and consists, of solids contact clarifier with a rapid sand filter that utilizes a travelling bridge backwash system. This allows the plant to continue treatment while backwashing. Trains #3 & #4, both constructed in the 1990s, are the newest treatment of the process treatment trains and are comprised of two (2) Trident TR-840A package plants. The Animas River provides intake water for these trains. The source water is treated with aluminum sulfate and a non-ionic polyacrylamide polymer for coagulation and/or flocculation depending upon the plant, clarification, and filtering prior to disinfection and then distribution. Trains #3 and #4 undergo a flush cycle using raw water approximately every four (4) to five (5) hours. Filter backwash using potable water occurs from once per day to once every three (3) to four (4) a day's depending on the plant and the time of year. Backwash and system flush traverses through the WTP's sump system to an on-site settling pond (called "backwash pond" by the plant operators), with an outlet to an open ditch, thence to culvert, thence to a closed conduit pipe, into an open channel in the Lower Animas Ditch. Aqueous samples are collected prior to discharge at the entrance to the closed conduit pipe leading to the Lower Animas Ditch. It is located at New Mexico State Highway 173 (NM-173) or Navajo Dam Drive, San Juan County, New Mexico (depicted in Aerial Image #1 below). Schematics provided by the City of Aztec of the Water Treatment Plant, the Water Plant Pump House and Flow are indicated in images #1, #2 and #3, respectively below. 2 City of Aztec/Aztec Water Treatment Plant NPDES permit No. NM0028762 Inspection Date August 28, 2023 Aerial Image #1 Overall view of the City of Aztec's Water Treatment Plant. Aerial from Google Earth. 3 City of Aztec/Aztec Water Treatment Plant NPDES permit No. NM0028762 Inspection Date August 28, 2023 Image #1 Water Plant 4 City of Aztec/Aztec Water Treatment Plant NPDES permit No. NM0028762 Inspection Date August 28, 2023 Image #2 Water Plant Pump House 5 City of Aztec/Aztec Water Treatment Plant NPDES permit No. NM0028762 Inspection Date August 28, 2023 Image #3 Water Treatment Plant Flow The WTP maintains three (3) storage reservoirs with #1 (currently undergoing rehabilitation and having a capacity of 10 MG (million gallons), #2 having a 10-MG capacity and #3 (aka "Tiger Pond") constructed circa 2010 having a capacity of 58-MG (Appendix 2 City of Aztec Water Treatment Plant and Reservoirs). Additionally, the WTP can supply water to the City of Bloomfield (#NM3510124) (emergency), Northstar Mutual Domestic Water Consumer Association (MDWCA) (#NM3520024) (emergency), Flora Vista MDWCA (#NM3510024) (approximately 10%), and Southside MDWCA #NM3509924 (approximately 75%). The WTP currently is budgeted for 3 FTE (full-time equivalent) positions and operates 7-days per week from 7:00 AM to 5:00 PM. Furthermore, the WTP maintains written standard operating procedures (SOPs) pertaining to facility operations and maintenance (O&M) and utilizes a Supervisory Control and Data Acquisition (SCADA) system to monitor operations. Section II - OBSERVATIONS I observed the following and/or the following information was provided or stated by WTP Staff. 6 City of Aztec/Aztec Water Treatment Plant NPDES permit No. NM0028762 Inspection Date August 28, 2023 The WTP maintains three (3) storage reservoirs with #1 (currently undergoing rehabilitation and having a capacity of 10 MG (million gallons), #2 having a 10-MG capacity and #3 (aka "Tiger Pond") constructed circa 2010 having a capacity of 58-MG. Backwash and system flush traverses through the WTP's sump system to an on-site settling pond (called "backwash pond" by the plant operators). The backwash pond lacks secure perimeter fencing, signage and is located downgradient and adjacent to residential housing. Effluent flow at the open channel in the Lower Animas Ditch appeared to be clear. No foam, aromatics, discoloration, or stressed vegetation was observed. The WTP does not have emergency generators either fixed or mobile to continue operations of their treatment processes or booster stations in the event of a local power outage. The WTP facility itself except for the backwash pond had secure perimeter fencing; thus, limiting access. The overall WTP's operations and maintenance, and general facility housekeeping appeared to be in good order. Section III - AREAS OF CONCERN A review of the submitted Integrated Compliance Information System (ICIS) Discharge Monitoring Reports (DMR) data for the period March 31, 2019, through May 31, 2023, indicates numerous NPDES permit excursions with respect to Chlorine, Total Residual (TCR), and Solids, Total Suspended (TSS) (Appendix 4 ICIS E90 Effluent Violations). Additional AOCs The backwash pond lacks secure perimeter fencing and signage and is located downgradient and adjacent to residential housing. The WTP does not have emergency generators either fixed or mobile to continue operations of their treatment processes or booster stations in the event of a local power outage. Section IV - LIST OF APPENDICES Appendix 1 - Photo Log - 9 photos taken 8/28/2023. Appendix 2 - City of Aztec Water Treatment Plant and Reservoirs Appendix 3 - City of Aztec Water System Inventory Appendix 4 - ICIS E90 Effluent Violations 7 City of Aztec/Aztec Water Treatment Plant NPDES permit No. NM0028762 Inspection Date August 28, 2023 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Aztec WWTP City: Aztec Photo No. 1 County/Parish: San Juan State: New Mexico View of the Plant #1 clarifier and filters #1 and #2. (DSCN2605). Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Aztec WWTP City: Aztec Photo No. 2 County/Parish: San Juan State: New Mexico View looking towards Plant #2 clarifier. (DSCN2606). Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Aztec WWTP City: Aztec Photo No. 3 County/Parish: San Juan State: New Mexico View of Plant #2 Supervisory Control and Data Acquisition (SCADA) data display. (DSCN2609). Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Aztec WWTP City: Aztec Photo No. 4 County/Parish: San Juan State: New Mexico View looking towards Plants #3 and #4. (DSCN2610). Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Aztec WWTP City: Aztec Photo No. 5 County/Parish: San Juan State: New Mexico View of Plants #3 and #4 Supervisory Control and Data Acquisition (SCADA) data display. (DSCN2611). Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Aztec WWTP City: Aztec Photo No. 6 County/Parish: San Juan State: New Mexico View of a portion of the treatment processes of Plant #3 and #4. (DSCN2612). Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Aztec WWTP City: Aztec Photo No. 7 County/Parish: San Juan State: New Mexico View of the discharge into the open channel, thence into a closed conduit and ultimately into the Lower Animas Ditch. (DSCN2613). Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Aztec WWTP City: Aztec Photo No. 8 County/Parish: San Juan State: New Mexico View looking approximately Northwest towards the on-site settling pond (called "backwash pond" by the plant operators). The backwash pond lacks secure perimeter fencing, signage and is located downgradient and adjacent to residential housing. (DSCN2615). Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Aztec WWTP City: Aztec Photo No. 9 County/Parish: San Juan State: New Mexico Another view looking towards the on-site settling pond (called "backwash pond" by the plant operators). Note: the backwash pond lacks secure perimeter fencing, signage and is located downgradient and adjacent to residential housing. (DSCN2616). Photographed by D. Esparza City of Aztec/Aztec Water Treatment Plant NPDES permit No. NM0028762 Inspection Date August 28, 2023 Appendix 2 City of Aztec Water Treatment Plant and Reservoirs 6 2 66 2 6 14 " 6 6 16 12 6 Backwash Pond Outfall Location 14 2 City of Aztec Water Treatment Plant 12 14 12 8 8 6 16 ROAD 2960 63 2 Reservoir #1 AZTEC 20 12 NA VAJ 16 2 O DA M 30 E 16 12 2 12 Reservoir #2 12" Waterline to Reservoir #3 16" Waterline from Reservoir #3 " 16 10 City of Aztec Water Treatment Plant (NM0028762) E Legend WaterLines FUNCTION Abandoned Drain Hydrant Tap Irrigation Main Moratorium_Area Raw Service AztecRoads AztecBuildings2017 Reservoirs CityParcels2018 6 6 12 OLD SPANISH 16 12 6 0 12 6 12 2 2 0 12" Waterline to Reservoir #3 8 " 16 16" Waterline from Reservoir #3 " E Reservoir #3 FORK 12 12 City of Aztec Water Treatment Plant (NM0028762) E Legend WaterLines FUNCTION Abandoned Drain Hydrant Tap Irrigation Main Moratorium_Area Raw Service AztecRoads AztecBuildings2017 Reservoirs CityParcels2018 City of Aztec/Aztec Water Treatment Plant NPDES permit No. NM0028762 Inspection Date August 28, 2023 Appendix 3 City of Aztec Water System Inventory (Pumps and Storage) City of Aztec Aztec Domestic Water System Pump Stations Name Location Size HP Airport Pump Station 730 Airport Dr 6 25 Bladder Tank Pump Station 1030 S Main Ave 4/5 75 Upper East Pump Station 1011 Navajo Dam Rd 4 75 Oliver Lift Station 701 Airport Dr 6 30 Navajo Pump Station (Raw Water Pumps) 201 Navajo Dam Rd 12 100 Navajo Pump Station 201 Navajo Dam Rd 12 75 GPM 450 900 500 900 2000 400 Pumps 2 2 2 2 2 2 Longitude -108.029 -107.998 -107.969 -108.022 -107.977 -107.977 Latitude 36.83468 36.80346 36.82803 36.83479 36.83573 36.83573 City of Aztec Aztec Domestic Water System Pump Inventory Name Airport Fire Pump Airport Charging Pump Back Wash Pump Animas River Pump Lower Animas Ditch Pump Navajo Raw Water #1 Pump Navajo Raw Water #2 Pump Bladder Tank Pump #1 Bladder Tank Pump #2 Upper East Aztec Pump #1 Upper East Aztec Pump #2 Lower East Pump #1 Lower East Pump #2 Oliver Pump #1 Oliver Pump #2 Water Plant #1 Water Plant #2 Water Plant #3 Water Plant #4 Water Plant #5 Location 730 Airport Dr 730 Airport Dr 201 Navajo Dam Rd CR 2980 CR 2978 201 Navajo Dam Rd Make Pacific (PACO) Pacific (PACO) FloWay KSB Gorman Rupp Aurora 201 Navajo Dam Rd Aurora 1030 S Main Ave 1030 S Main Ave NM 173 NM 173 1011 Navajo Dam Rd 1011 Navajo Dam Rd 701 Airport Dr 701 Airport Dr Berkeley Berkeley Grundfos Grundfos Aurora Aurora Aurora Aurora 201 Navajo Dam Rd Aurora 201 Navajo Dam Rd Flow Serv 201 Navajo Dam Rd Flow Serv 201 Navajo Dam Rd Aurora 201 Navajo Dam Rd FloWay Type Centrifugal Centrifugal Vertical Turbine 4 stage Centrifugal Submersible Vertical split case, single stage Vertical split case, single stage Centrifugal Centrifugal Centrifugal Centrifugal Centrifugal Centrifugal Centrifugal Centrifugal Vertical Turbine 3 stage Vertical Turbine 3 stage Vertical Turbine 3 stage Vertical Turbine 3 stage Vertical Turbine 3 stage HP Max Inlet Outlet GPM Diam. Diam. 25 450 3 20 125 5720 200 2800 12 8 75 1200 6 6 100 2000 8 6 100 2000 8 6 75 900 5 4 75 900 5 4 75 500 4 4 75 500 4 4 75 400 5 4 75 400 5 4 30 900 6 6 30 900 6 6 100 1500 14 10 40 750 6 40 750 6 100 1500 14 8 125 1500 14 8 Elev. (Ft) 5868 5868 5704 5623 5670 Year Inst. Next Serv. 2002 2000 5721 5721 5792 5792 2002 2002 2020 2020 5762 5762 5704 5704 5704 5704 5704 2010 2010 1997 1950 1950 2010 2010 City of Aztec Aztec Domestic Water System Pump Inventory Name Location Make Type HP Surface Wash Pump Plant #1 Surface Wash Pump Plants 3 & 4 Booster Pump #1 Plants 3 & 4 201 Navajo Dam Rd 201 Navajo Dam Rd 201 Navajo Dam Rd Aurora G&L Goulds Pump Cornell Centrifugal Centrifugal Centrifugal Booster Pump #2 Plants 3 & 4 201 Navajo Dam Rd Cornell Centrifugal Back Wash Pump Plant #2 201 Navajo Dam Rd Back Wash Suction Pump Plant #2 201 Navajo Dam Rd Alum Pump #1 201 Navajo Dam Rd Prominent Diaphragm Alum Pump #2 201 Navajo Dam Rd Prominent Diaphragm Alum Pump #3 201 Navajo Dam Rd Prominent Diaphragm Alum Pump #4 201 Navajo Dam Rd Prominent Diaphragm Polymer Pump #1 201 Navajo Dam Rd Prominent Diaphragm Polymer Pump #2 201 Navajo Dam Rd Prominent Diaphragm Polymer Pump #3 201 Navajo Dam Rd Prominent Diaphragm Polymer Pump #4 201 Navajo Dam Rd Prominent Diaphragm Polymer Pump 201 Navajo Dam Rd Prominent Diaphragm Bleach Pump #1 201 Navajo Dam Rd Prominent Diaphragm Bleach Pump #2 201 Navajo Dam Rd Prominent Diaphragm Max GPM Inlet Diam. Outlet Diam. Elev. (Ft) Year Inst. Next Serv. 8.4 gph 11.9 gph 35.9 gph 35.9 gph 3.83 gph 3.83 gph 3.83 gph 3.83 gph 30 gpd 8.4 gph 8.4 gph City of Aztec Aztec Domestic Water System Water Storage Inventory Name Airport Tank Airport Tank Bladder Tank Blanco Tank Lower East Aztec Tank Upper East Aztec Tank West Tank Location 730 Airport Dr 730 Airport Dr 2000 S Main Ave 901 Blanco St Hwy 173 #330 UT Road 2550 #42 UT 201 McWilliams Rd City of Aztec Aztec Domestic Water System Raw Water Storage Inventory Material Steel Concrete Polyester Steel Steel Steel Steel Capacity 250,000 500,000 2,000,000 2,000,000 250,000 50,000 1,000,000 Telemetry Yes Yes Yes Yes No No Yes Elev (Ft) 5867 5867 5998 5812 6191 6480 5793 Year 2013 2002 1958 1959 Name Reservoir #1 Reservoir #2 Reservoir #s Location Material Capacity 10M 10M 58M Telemetry Elev (Ft) Year City of Aztec/Aztec Water Treatment Plant NPDES permit No. NM0028762 Inspection Date August 28, 2023 Appendix 4 Review of the ICIS E90 Effluent Violations Aztec WTP.E90 Effluent Violations.xlsx City of Aztec Water Treament Plant (NM0028762) E90 Effluent Violations Monitoring Period End Date Parameter Description DMR Value Limit Value 03/31/19 Chlorine, total residual 34 19 11/30/19 Chlorine, total residual 61 19 01/31/20 Chlorine, total residual 38 19 10/31/20 Chlorine, total residual 21 19 12/31/20 Chlorine, total residual 21 19 06/30/21 Solids, total suspended 74 30 06/30/21 Solids, total suspended 27 20 09/30/21 Solids, total suspended 32 30 09/30/21 Chlorine, total residual 22 19 02/28/23 Chlorine, total residual 13 11 05/31/23 Solids, total suspended 39 30 Unit mg/L ug/L ug/L ug/L ug/L mg/L mg/L mg/L ug/L ug/L mg/L