Document EvE00ZM91nXd8Ne6a750e55pN

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 06/25/2024 Water CWA - 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: Cuba, Village of Village of Cuba Wastewater Treatment Plant Mile Marker 2 on NMSR 197 Cuba, NM 87013 P.O. Box 426 Cuba, NM 87013 Sandoval County 575-289-2020 Denny Herrera Mayor Mayorherrera63@gmail.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110009831156 NM0024848 221320 4952 Personnel participating in inspection: Name Affiliation/mailcode Amy Andrews, P.E. USEPA/6-ECDWM Jason Martinez NMED-GWQB Angelo Aragon Cuba, Village of Vandora Casados Cuba, Village of Ester Hererra Cuba, Village of Title Engineer/ Lead Inspector Inspector Wastewater Operator Village Clerk Treasurer Village Water Clerk EPA Lead Inspector Signature/Date Supervisor Signature/Date AMY ANDREWS AMY ANDREWS c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=AMY ANDREWS, 0.9.2342.19200300.100.1.1=68001003655888 2024.08.20 11:13:28 -06'00' Amy Andrews Date ROBERTO BERNIER Date: 2024.08.20 12:44:53 -05'00' Digitally signed by ROBERTO BERNIER Roberto Bernier Date 6ENFORM-020-R8.2 (02/12/2020) 1 Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 Section I - INTRODUCTION PURPOSE OF THE INSPECTION Environmental Protection Agency (EPA) Region 6 inspector, Amy Andrews, and New Mexico Environment Department inspector, Jason Martinez, arrived at the Village of Cuba Office at 10:10 AM on 6/25/2024 for an unannounced inspection. We then proceeded to the Village of Cuba Wastewater Treatment Plant and met with Angelo Aragon, Village of Cuba Wastewater Operator. I presented my credentials to Mr. Aragon and informed him that this was an EPA inspection to determine compliance with the facility's National Pollutant Discharge Elimination System (NPDES) permit and the Clean Water Act (CWA). The inspection was conducted under the authority of the NPDES permit program, in accordance with the Federal CWA. This report is based on information supplied by Village of Cuba representatives (the permittee), observations made by the EPA inspector, and records and reports maintained by the permittee and the EPA. FACILITY DESCRIPTION The Village of Cuba Wastewater Treatment Plant (WWTP) is classified as a minor municipal discharger with a design flow of 0.144 million gallons per day (MGD). The wastewater discharge flows to the Rio Puerco in water quality Segment 20.6.4.131 NMAC from November 1 through March 31 of each year. Discharges are prohibited through months from April 1 through October 31 each year. The designated uses for this segment of the river are warmwater aquatic life, irrigation, livestock watering, wildlife habitat and primary contact. The Cuba WWTP is an Aero-Mod extended aeration plant with two trains. Raw sewage enters the WWTP via an approximately 5-mile-long collection system. Flow is transported by gravity with one lift station. The AeroMod Extended treatment plant constructed in 2013 is an activated sludge process utilizing a sequential oxidation (SEQUOX) biological nutrient removal process. Influent enters the headworks and manual bar screen, flows through a flume and ultrasonic flow meter, and then is then split into two trains of aeration (activation) basins (A and B) where aerobic and anaerobic phases occur. After the activation basins, wastewater enters the two secondary clarifiers and then passes through ultraviolet (UV) disinfection. Flow is measured with a flume and ultrasonic flow meter prior to discharge to either the Rio Puerco through Outfall 001, or to a reuse storage pond. After the UV system, treated effluent enters a pipe to a wet well without a high-level alarm. That wet well has two exit pipes, each of which with a valve, and the pipes go to either a lined Reuse Pond or to Outfall 001 at the river. The Outfall is approximately 370 feet west of the main channel of the Rio Puerco. Return Activated Sludge (RAS) is sent from the secondary clarifiers back to the aeration basins. Waste Activated Sludge (WAS) is sent to the solids thickeners then to the old plant's lagoon which now acts as a digester with two surface mixers. From the lagoon-digester the sludge is mixed with polymer inside the polymer building, and then sent to the drying beds, where it is windrowed and stockpiled. 2 Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 Section II - OBSERVATIONS The following observations were made during the inspection: 1. Headworks: The manual bar screen is cleaned out twice a day during the weekdays. Maintenance crews clean it at least once during weekends. Influent primary flow meter is trapezoidal, and no staff gauge is present. Calibration sticker is not present on secondary influent ultrasonic meter. 2. Aeration basins: Influent filter basket at aeration basin is a plastic milk crate that is replaced approximately every 2 weeks (see Photos 1 and 2). There is currently no grit removal system, which results in a significant amount of grit present in the aeration basins. Facility personnel stated that they skim the aeration basins manually with a net occasionally (see Photo 3). 3. Disinfection and Effluent Flow meter: The UV system has 4 banks of 4 bulbs each. Facility personnel clean bulb sleeves every 2 weeks. The effluent primary flow meter is a trapezoidal flow meter. The staff gauge on the effluent flow meter had come detached from the wall of the flow meter and cannot be used for flow rate verification (see Photo 4). The staff gauge should be repaired by a qualified flow meter technician. Facility personnel were not able to demonstrate that any flow meter verification against the staff gauge reading has been done since the flow meter was installed by an external contractor. 4. Compliance Sampling: Samples are collected immediately following the finger weirs after the UV system and prior to the valves that split the flow between the reuse pond and the outfall. Facility personnel stated that they collect compliance samples all year long, regardless of whether they are discharging to outfall or to reuse pond. 5. Wet Well and Valves to Reuse Pond and Outfall: The valve to the river outfall is next to a wet well with a second valve to the reuse pond. The valves are located underground and are opened and closed with a key on a long pole inserted into the valve cover at the ground level. At the time of the inspection, the key was in the valve to the river (see Photos 5 through 8). The potential exists that both valves (pond and outfall) could be closed at the same time, which would cause an overflow at the wet well with no alarm. There is no way to tell if the valves are open or closed without looking for water at end of pipe. The concrete skirt around the wet well is cracked and heaved; it is possible that the underground pipes are cracked. 6. Outfall: At the time of the inspection, effluent was flowing out of the outfall to the river (see Photos 9 and 10). Facility personnel stated that they turned the valve at the end of March to shut off the flow to the river, after collecting the WET test sample. They did not visit the river to observe whether there was effluent flow present or not. 7. Process Control: The SCADA system does not have call-out ability. Alarms are just flashing lights on the main panel inside the office. 8. Sampling and Laboratory: Sampling takes place at the finger weir after the UV system. Operators collect the compliance samples on a regular schedule regardless of whether the effluent is flowing to the outfall at the river or to the reuse pond. In-house analysis includes pH and process control 3 Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 samples. WET testing goes to SeaCrest Group in Louisville, CO, and all other compliance samples go to Eurofins in Albuquerque, NM (previously Hall Environmental). 9. Sampling and Laboratory: pH buffers were not labeled with opened-on dates, and lids on pH bottles were not screwed on tight to prevent oxidation of the buffer solutions (see Photos 11, 12 and 13). pH buffers 4 and 7 from USABluebook are only good for 6 months after the bottle is opened and pH buffer 10 from USABluebook is only good for 3 months, if the lids are closed tightly. Opened-on dates must be written on the bottles, and a revised expiration date, based on the earliest of the manufacturer's printed expiration date, or 3 or 6 months from the opened-on date, must be written on the bottle. 10. Sampling and Laboratory: The numbers shown on the pH probe prior to pressing the calibrate button are not within reasonable calibrations parameters, which may indicate the need for a new pH probe, or that pH buffers have oxidized from being exposed to air. Calibration slope should be recorded, as it demonstrates measurement drift and is an indicator of issues with buffer solutions or probes. Verify acceptable slope values with pH probe manufacturer and replace probe if necessary. For additional information about pH meter calibration, inspector recommends reading the documentation that came with the meter, or the methodology for pH in the Standard Methods 4500-H+ B. 11. Sampling and Laboratory: An operator from Rural Water comes by the plant once a week to oversee plant operations and sampling. The lead operator who is at the plant daily does not receive the compliance sample results, and therefore cannot use the information for process control. 12. Sludge Handling: The large lagoon near the lab is a sludge pond (digester) with two surface aerators. The green metal building is both the polymer building and the laboratory. Piping goes from sludge pond through the polymer building to the drying beds. The small tractor used for moving sludge in the drying beds is stored inside the laboratory/polymer building (see Photo 14). Biosolids have not been removed from the facility since this plant was constructed in 2013. Section III - RECORDS REVIEW The following records were requested at the end of the inspection, and again via email sent on 7/8/2024, with a request due date of Friday, 7/12/2024. Items with a checkmark in the box were received, items with an empty box were not received. Records Request: ~ Submitted and signed DMRs from __January 2024__ to __March 2024__ and all documentation directly related to the creation of these specific DMRs, including: ~ Laboratory Bench Sheets (handwritten &/or typed) used to construct DMRs from above. Only three (3) days of pH bench sheets were submitted from this time period. ~ Laboratory Sampling Reports used to construct DMRs (i.e., lab reports from external labs). ~ Excel (or other database) spreadsheets used to construct DMRs listed above. ~ Chain of Custody records (usually included as last page of Laboratory Report) ~ The latest WET Testing Laboratory report. 4 Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 Records Request: ~ Submitted and signed Sludge DMR with metals, pathogens and vector report from the last _1 year_. ~ Related sludge sampling Laboratory Reports ~ Flow meter logs showing daily flow rates from __January 2024__ to __March 2024__ ~ Calibration sheets for influent and effluent primary and secondary flow meters within the last _1 year_. ~ Calibration sheets for laboratory equipment (scales, thermometers, incubators, etc.) within the last _1 year_. ~ Excursion, Overflow or Bypass Summary Reports (if relevant) from the last _2 years_. ~ Pollution Prevention Program Documents as required by your NPDES permit (Part I.E.) Section IV - AREAS OF CONCERN Requirement 1 Federal Water Pollution Control Act (also known as the Clean Water Act), Section 301(a): Except as in compliance with this section and sections 302, 306, 307, 318, 402 and 404 of this Act, the discharge of any pollutant by any person shall be unlawful. Federal Water Pollution Control Act, Section 402 requires that a discharge of any pollutant or combination of pollutants from a point source to surface water that are deemed waters of the United States be regulated by and NPDES permit. NPDES Permit NM0024848, Part I: A. Limitations and Monitoring Requirements 1. OUTFALL 001 - FINAL Effluent Limits - 0.144 MGD Design Flow: During the period beginning the effective date of the permit and lasting through the expiration date of the permit (unless otherwise noted), the permittee is authorized to discharge treated domestic wastewater from Outfall 001 to the Rio Puerco, in Segment 20.6.4.131 of the Rio Grande River Basin. Discharges are prohibited through months from April 1 through October 31 each year. Concern 1 At the time of the inspection, during the month of June, effluent was flowing out of the outfall to the river, which is a prohibited and unpermitted discharge. Requirement 2 NPDES Permit NM0024848, Part I: A. Limitations and Monitoring Requirements 1. OUTFALL 001 - FINAL Effluent Limits - 0.144 MGD Design Flow NPDES Permit NM0024848, Part II: E. Whole Effluent Toxicity Testing (7-Day Chronic NOEC Freshwater) 1.a. The permittee shall test the effluent for toxicity in accordance with the provisions in this section. 5 Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 Concern 2 Sample dates for the WET Testing in 2024 occurred on 4/16/2024 and 4/17/2024 (see Appendix 2). The WET Test did pass the survivability criteria; however, these dates are during the time period when discharges at the outfall are prohibited, therefore there should be no "effluent" to sample. WET Test samples must be collected during times when the WWTP is authorized to discharge. Requirement 3 NPDES Permit NM0024848, Part I: C. Monitoring and Reporting 1. Reporting periods shall end on the last day of the months March, June, September, and December. 2. The permittee is required to submit regular reports as described above postmarked no later than the 28th day of the month following each reporting period. Concern 3 As of the writing of this inspection report, permittee has not submitted Discharge Monitoring Reports for the 11 months of April 2023, May 2023, June 2023, and November 2023, through June 2024. As Inspector did not receive requested copies of sampling results, it is not clear whether the required samples were collected. Requirement 4 NPDES Permit NM0024848, Part I: C. Monitoring and Reporting 3. No Discharge Reporting: If there is no discharge at Outfall 001 during the sampling month, place an "X" in the NO DISCHARGE box located in the upper right corner of the Discharge Monitoring Report. Concern 4 Discharge monitoring reports for April through October 2019, April through October 2020, April through October 2021, April through October 2022, and July through October 2023 appear to indicate that permittee has been discharging at Outfall 001. Permittee has never indicated "no discharge" on their DMRs. Requirement 5 NPDES Permit NM0024848, Part I: E. Pollution Prevention Requirements: The permittee shall institute a program within 12 months of the effective date of the permit (or continue an existing one) directed towards optimizing the efficiency and extending the useful life of the facility. The permittee shall consider the following items in the program: a. The influent loadings, flow and design capacity; b. The effluent quality and plant performance; c. The age and expected life of the wastewater treatment facility's equipment; d. Bypasses and overflows of the tributary sewerage system and treatment works; e. New developments at the facility; f. Operator certification and training plans and status; g. The financial status of the facility; h. Preventative maintenance programs and equipment conditions and; i. An overall evaluation of conditions at the facility. Concern 5 Permittee was unable to provide a Pollution Prevention Program. Requirement 6 NPDES Permit NM0024848, Part III: Standard Conditions A.7. Duty To Provide Information: The permittee shall furnish to the Director, within a reasonable time, any information which the Director may request to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to determine compliance with this permit. The permittee shall also furnish to the Director, upon request, copies of records required to be kept by this permit. 6 Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 NPDES Permit NM0024848, Part III: Standard Conditions C.1. Inspection And Entry: The permittee shall allow the Director, or an authorized representative, upon the presentation of credentials and other documents as may be required by the law to: b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit. Concern 6 The Permittee did not submit all documents requested (see Section III - Records Review). Requirement 7 NPDES Permit NM0024848, Part III: Standard Conditions B.2. Duty To Mitigate: The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this permit which has a reasonable likelihood of adversely affecting human health or the environment. Concern 7 After the valve to the Outfall is closed, permittee does not verify that flow to the river has stopped. There is no high-level alarm in the wet well prior to the valves to the Outfall and Reuse Pond (see Observations 5 and 6). If both valves were closed at the same time, the wet well would likely overflow, and effluent would unknowingly flow to the river. Requirement 8 NPDES Permit NM0024848, Part III: Standard Conditions B.3. Proper Operation and Maintenance a. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by permittee as efficiently as possible and in a manner which will minimize upsets and discharges of excessive pollutants and will achieve compliance with the conditions of this permit. Concern 8A Grit is not being removed properly at the headworks and is making it into the aeration basins where operators periodically remove the grit manually. Grit that is present in the treatment train causes excessive wear on piping and basin walls and may cause blowers and pumps to fail prematurely. Concern 8B Permittee is not properly operating the wet well and valves to ensure that flow has been redirected from the outfall to the reuse pond (see Observations 5 and 6) during the months when discharge is prohibited. Concern 8C Permittee is storing a small tractor in the laboratory that is used to move sludge in the drying beds. This could cause laboratory sample contamination. Requirement 9 NPDES Permit NM0024848, Part III: Standard Conditions B.3. Proper Operation and Maintenance b. The permittee shall provide an adequate operating staff which is duly qualified to carry out operation, maintenance and testing functions required to insure compliance with the conditions of this permit. In accordance with New Mexico Administrative Code (NMAC) 20.7.4, in order to "operate" this facility, a Level 3 Wastewater Certification is required. Operate is defined as "performing any activity or function or making any process control or system integrity decision regarding water quality or water quantity that has the 7 Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 potential to affect the proper functioning of ... a public wastewater facility or to affect human health, public welfare or the environment." Concern 9 At the time of the inspection, the facility had one full time operator with a Level 2 Wastewater certification and one operator with a Level 3 Wastewater certification who was contracted to visit the facility one day a week. Day to day operations require a qualified operator having full knowledge of the plant workings, including the quality of the effluent and whether or not effluent is being discharged to the river at the Outfall. Requirement 10 NPDES Permit NM0024848, Part III. C.4. Record Contents: Records of monitoring information shall include: a. The date, exact place, and time of sampling or measurements; c. The date(s) and time(s) analyses were performed; e. The analytical techniques or methods used; and f. The results of such analyses. Concern 10 pH bench sheets, which are labeled as "pH Meter Calibration" (see Appendix 3) are missing the sample collection dates, sample collection times, as well as the dates of analysis. Analysis within the 15-minute holding times could not be verified. Dates recorded for "Date of Calibration" are difficult to read or have been scratched out. The pH values do not always match those listed for that day on the "Aero-Mod Log," leading to questions regarding whether the dates or pH value were filled in correctly on one or both sheets. Requirement 11 NPDES Permit NM0024848, Part III. C.4. Record Contents: Records of monitoring information shall include: b. The individual(s) who performed the sampling or measurements; [and] d. The individual(s) who performed the analyses; Concern 11 Bench sheets must include separate locations for the recording of both the individual who collected the sample, and the individual who ran the analysis. The bench sheets include a single line for "tech initials" which appears to be the tech who performed the instrument calibration (see Appendix 3). The initials are often written in a different handwriting or color of ink pen than the rest of the form and these initials are not readily tied to the certified Operators as reported to the inspector. Initials noted on the bench sheets include "DM," "AA (Angelo Aragon)," and "AC" - it's not clear if DM and AC are certified operators. Requirement 12 NPDES Permit NM0024848, Part III. C.5.a. Monitoring must be conducted according to test procedures approved under 40 CFR Part 136, unless other test procedures have been specified in this permit or approved by the Regional Administrator. NPDES Permit NM0024848, Part III. C.5.b. The permittee shall calibrate and perform maintenance procedures on all monitoring and analytical instruments at intervals frequent enough to insure accuracy of measurements and shall maintain appropriate records of such activities Concern 12 Permittee was unable to provide documentation of proper daily calibration of the pH meter for the time period requested. It is unknown when the pH buffers were opened, so they may have been expired. Expired pH buffers were also stored in the laboratory, so it could not be verified if analysts used the correct, unexpired buffers for each analysis. Calibration order of the buffers is typed into the bench sheet in the order of, "First 8 Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 Buffer: 4:00; Second Buffer: 7:00; Third Buffer: 10:00" (see Appendix 2). This order would only be correct if the pH of the sample was expected to be less than pH 7 - pH measurements provided to the inspector from January 2024 through June 2024 show that all values were above pH 7. Calibration procedures that could change should not be pre-typed on bench sheets. Requirement 13 NPDES Permit NM0024848, Part III. C.6 Flow Measurements: Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The devices shall be installed, calibrated, and maintained to insure that the accuracy of the measurements is consistent with the accepted capability of that type of device. Devices selected shall be capable of measuring flows with a maximum deviation of less than 10% from true discharge rates throughout the range of expected discharge volumes. Concern 13 Permittee's effluent flow meter is located prior to the wet well and valves that direct flow to either the Outfall at the river or the Reuse Pond. Permittee has no way to measure and has no awareness of whether water is flowing to the river through the Outfall. Flow meter values recorded on "AERO-MOD" Worksheets (see Appendix 4) are total plant influent and effluent flow, not flow to the Outfall. Permittee does not regularly verify electronic flow measurements against primary flow meters. The influent flow meter is missing the staff gauge completely, and the effluent flow meter staff gauge is unusable. Flow meter staff gauges must be fixed by a qualified technician and should be used to verify accuracy of electronic flow meters to within 10% monthly. Section V - Closing Conference EPA Region 6 inspector, Amy Andrews conducted a closing conference regarding the Village of Cuba Wastewater Treatment Plant at the Village Office at 1:00 PM on 6/25/2024, for the inspection. During the closing conference, Inspectors reviewed the Areas of Concern that were noted during the inspection. Additional AOCs were determined after the conclusion of the inspection and were not included in the closing conference. Section VI - FOLLOW UP The following information was received by EPA after exiting the Facility: Received 07/09/2024 - SEACREST GROUP-Report for Chronic Biomonitoring Tests.pdf WET Test Laboratory Report dated 5/2/2024. Received 07/19/2024 - CUBA WWTP AERO-MOD Worksheets.pdf Worksheets from 1/1/2024 to 6/30/2024; data includes daily influent flow meter readings, pH, process control, and effluent flow meter readings. Received 07/19/2024 - CUBA WWTP Instrument & Loop Calibration Record.pdf Influent and effluent flow meter calibrations by Yukon & Associates LTD dated 12/13/2023. 9 Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 Received 07/19/2024 - Cuba WWTP PH & DO Calibration Worksheets.pdf Worksheets with the following dates: 2/27/2024, 3/4/2024, 3/27/2024, 6/26/2024, 6/27/2024, 6/28/2024, 6/29/2024, 6/30/2024, 7/1/2024, 7/2/2024, 7/3/2024, 7/4/2024, 7/5/2024, 7/6/2024, 7/7/2024, 7/8/2024, 7/9/2024, and 7/10/2024. Section VII - LIST OF APPENDICES Appendix 1 - Photograph Log - 14 photos taken 6/25/2024 Appendix 2 - WET Test Laboratory Report - dated 5/2/2024 (first few pages, full report available upon request) Appendix 3 - PH & DO Calibration Worksheets - Various dates February 2024 through July 2024 Appendix 4 - AERO-MOD Worksheets - dated January 2024 through June 2024 10 Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 Appendix 1 Photograph Log Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 Photo 1 IMG-202406251118491849135305.jpg 06/25/2024 11:18 AM (MT) No CBI No PII Photographer: Amy Andrews Aeration basins 35.99274825, -106.98413847 Influent filter basket at the aeration basin is a plastic milk crate. Photo 2 IMG-202406251121272127126640.jpg 06/25/2024 11:21 AM (MT) No CBI No PII Photographer: Amy Andrews Aeration basins 35.99274825, -106.98413847 Influent filter basket at the aeration basin is a plastic milk crate. 1 Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 Photo 3 IMG-202406251125172517153917.jpg 06/25/2024 11:25 AM (MT) No CBI No PII Photographer: Amy Andrews Aeration basins 35.99274825, -106.98413847 Signification amount of grit present in aeration basins. Facility personnel skim the grit out manually with a net occasionally. Photo 4 IMG-2024062511300730789306.jpg 06/25/2024 11:30 AM (MT) No CBI No PII Photographer: Amy Andrews Effluent Flow Meter 35.99273351, -106.98408711 The staff gauge on the effluent flow meter had come detached from the wall of the flow meter and cannot be used for flow rate verification. 2 Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 Photo 5 IMG-202406251145244524145747.jpg 06/25/2024 11:45 AM (MT) No CBI No PII Photographer: Amy Andrews Wet Well and Valves to Reuse Pond and Outfall 35.99270124, -106.98406263 Valve to Outfall with key present in valve. Wet well is shown at right of the photo. Photo 6 06/25/2024 11:45 AM (MT) No CBI No PII Wet Well and Valves to Reuse Pond and Outfall Valve to Outfall with key present in valve. IMG-202406251145354535198459.jpg Photographer: Amy Andrews 35.99270124, -106.98406263 3 Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 Photo 7 06/25/2024 11:46 AM (MT) No CBI No PII Wet Well and Valves to Reuse Pond and Outfall Valve to Outfall with key present in valve. IMG-202406251146144614163930.jpg Photographer: Amy Andrews 35.99273505, -106.98411703 Photo 8 06/25/2024 11:48 AM (MT) No CBI No PII Wet Well and Valves to Reuse Pond and Outfall Inside of wet well, with no high level alarm sensor. IMG-202406251148584858121635.jpg Photographer: Amy Andrews 35.99274824, -106.98413845 4 Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 Photo 9 06/25/2024 11:40 AM (MT) No CBI Outfall 001 Effluent is flowing out of the Outfall. No PII IMG-202406251140104010201854.jpg Photographer: Amy Andrews 35.99272503, -106.98405959 Photo 10 06/25/2024 11:40 AM (MT) No CBI Outfall 001 Effluent is flowing out of the Outfall. No PII IMG-202406251140314031200587.jpg Photographer: Amy Andrews 35.99272219, -106.98404994 5 Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 Photo 11 06/25/2024 11:17 AM No CBI Laboratory pH buffers without opened-on dates. No PII DSCN2416.JPG Photographer: Amy Andrews [Geographic Coordinates] Photo 12 06/25/2024 11:17 AM No CBI Laboratory Expired pH buffers present in laboratory. No PII DSCN2417.JPG Photographer: Amy Andrews [Geographic Coordinates] 6 Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 Photo 13 06/25/2024 11:18 AM No CBI Laboratory Expired pH buffers present in laboratory. No PII DSCN2418.JPG Photographer: Amy Andrews [Geographic Coordinates] Photo 14 DSCN2408.JPG 06/25/2024 11:07 AM No CBI No PII Photographer: Amy Andrews Laboratory [Geographic Coordinates] The small tractor used for moving sludge in the drying beds is stored inside the laboratory/polymer building where cross contamination of laboratory samples is possible. 7 Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 Appendix 2 WET Test Laboratory Report Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 Appendix 3 PH & DO Calibration Worksheets Village of Cuba Wastewater Treatment Plant Inspection Date 6/25/2024 Appendix 4 AERO-MOD Worksheets