Document LJDaZk2B120BwjoREqjbd2eOz

EPA Inspection Report - Page 1 of 21 Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 07/30/2018 Water CWA - NPDES Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: City of Elephant Butte Sierra County Regional Wastewater Treatment Plant 1001 Sunset Ridge Road Sierra County, NM 87935 PO Box 1080 Elephant Butte, NM 87935 Sierra County David DuVall City Manager citymanager@cityofelephantbutte.com FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110064634560 NM0030864 221320 4952 Personnel participating in inspection: Amy Andrews, P.E. USEPA/6EN-WM Marcus Ortega City of Elephant Butte Shawn Tillots City of Elephant Butte Environmental Engineer Wastewater Technician/Operator Wastewater Technician/Operator 214-907-0638 575-744-4892 575-744-4892 EPA Lead Inspector Signature/Date Supervisor Signature/Date Digitally signed by AMY ANDREWS AMY ANDREWS DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=AMY ANDREWS, dnQualifier=0000131170 Amy Andrews Date: 2018.09.25 10:22:01 -06'00' CAROL PETERS-WAGNON Carol Peters Digitally signed by CAROL PETERS-WAGNON DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=CAROL PETERS-WAGNON, dnQualifier=0000009981 Date: 2018.09.27 16:09:47 -05'00' Date Date 6ENFORM-019-R7 (2/15/2017) 1 EPA Inspection Report - Page 2 of 21 Section I - INTRODUCTION City of Elephant Butte, Sierra County Regional Wastewater Treatment Plant Inspection Date 7/30/2018 PURPOSE OF THE INSPECTION Environmental Protection Agency (EPA) Region 6 inspector, Amy Andrews, arrived at the City of Elephant Butte, Sierra County Regional Wastewater Treatment Plant (WWTP) at 10:15 am on July 30, 2018 for an unannounced Compliance Evaluation Inspection (CEI). I met with Marcus Ortega and Shawn Tillots, City of Elephant Butte Wastewater Treatment Operators, for the Opening Conference. I presented my credentials to Mr. Ortega and Mr. Tillots and explained 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 City of Elephant Butte representatives (the permittee), observations made by the EPA inspector, and records and reports maintained by the permittee and the EPA. FACILITY DESCRIPTION The City of Elephant Butte, Sierra County Regional WWTP is located at 1001 Sunset Ridge Road, Sierra County, New Mexico. The facility is classified as a minor municipal discharger, and is permitted for a design flow discharge of 0.6 million gallons per day (MGD), with actual average flow maintained around 0.06 MGD. Discharge is to receiving waters named Cuchillo Negro Creek, and thence to the Rio Grande. Raw sewage flows through a collection system via six (6) lift stations to the plant. The final station is approximately one quarter mile north of the plant. Influent flow is measured with a magnetic flow meter. An additional lift station is located at the treatment plant to direct decant from the digester and the drying beds back to the headworks. At the headworks, raw sewage passes through a manual bar screen and grit chamber. Screenings are sent down a chute to a container at ground level. The main treatment units for this facility are two sequencing batch reactor (SBR) basins and a digester which allow for aeration, mixing, anoxic and decanting of influent. Following the SBR treatment units, flow enters a flow equalization (EQ) basin before entering the disinfection unit. The EQ basin is covered to minimize algal growth in the effluent prior to discharge. This also increases the bulb life span in the Ultraviolet (UV) disinfection chamber. Effluent flows from the EQ basin past the UV disinfection into a 3" Parshall flume for flow measurement prior to being discharged to Cuchillo Negro Creek. Sludge produced at the plant is placed in two divided (four concrete cell) drying beds for dewatering. Screenings removed from the bar screen are also transported and disposed with the dried sewage sludge. Once the sludge passes a paint filter liquid test it is stockpiled on site for further drying and pathogen removal through natural processes. The facility uses a roll off for further storage to prevent moisture from rewetting the material. The dewatered sludge is transported to the Socorro Landfill by a registered waste hauler for final disposal. Mr. Ortega indicated that sludge had not been taken to the 2 EPA Inspection Report - Page 3 of 21 City of Elephant Butte, Sierra County Regional Wastewater Treatment Plant Inspection Date 7/30/2018 landfill during the five months that he had been working at the facility, and was not sure when it may have happened previous to his starting there. Section II - OBSERVATIONS Mr. Ortega and Mr. Tillots met me at the WWTP and gave me a tour of the facility. Pollutants that are sampled and analyzed for by the permittee include pH, E. coli bacteria, and flow rate. Samples of other pollutants are sent to Aqua Environmental Testing Lab, LLC in Las Cruces, NM. I was informed that their previous operator has resigned the previous Friday, therefore all documentation was locked in his office and unavailable as of the date of the inspection. As of the time of this inspection, the facility does not have a certified Operator. David DuVall, the City Manager of the City of Elephant Butte, emailed requested records and documents to me on 8/3/2018. Section III - AREAS OF CONCERN Requirement 1 NPDES Permit NM0030846, Part III.D.9 Standard Conditions: Where the permittee becomes aware that it failed to submit any relevant facts in a permit application, or submitted incorrect information in a permit application or in any report to the Director, it shall promptly submit such facts or information. Concern 1 The permittee's name (City of Elephant Butte) is not listed on the permit. The permittee was informed of this requirement previously, in an inspection conducted January 10, 2013, prior to the issuance of the current permit. Requirement 2 NPDES Permit NM0030846, B.3.a. Proper Operation and Maintenance: 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. Proper operation and maintenance also includes adequate laboratory controls and appropriate, quality assurance procedures. Concern 2 The permittee was unable to demonstrate that Standard Operating Procedures existed for either WWTP operations or laboratory procedures. During this inspection, solids were present at the effluent finger weir following the ultraviolet (UV) disinfection basin (see photo in Appendix 1) and the effluent appearance was turbid. It is unclear when the last time the facility may have wasted solids from the SBR basins. Visual observation of effluent quality does not appear to match the values shown on the DMRs. The permittee has reported E. coli as less than one (<1) colony forming units (cfu) per 100 milliliters on their DMRs for a majority of the reporting periods since this permit became effective October 1, 2013. 3 EPA Inspection Report - Page 4 of 21 City of Elephant Butte, Sierra County Regional Wastewater Treatment Plant Inspection Date 7/30/2018 Requirement 3 NPDES Permit NM0030846, Part I.A. Final Effluent Limits: Pollutant pH, measurement frequency of 5/Week Concern 3 pH was not measured at a frequency of 5/week during the months of April, May, or June 2018 (see bench sheets in Appendix 2). Measurement frequency was inconsistent, sometimes measuring pH every day for two weeks, and then missing 3 or 4 days in a week. Bench sheets did not clearly designate the start and end of each week, making it difficult to determine the number of samples collected in a week. However, regardless of when the weeks started, there were only a total of five pH samples collected between May 19 and May 31, 2018 as well as between June 16 and June 31, 2018. Requirement 4 NPDES Permit NM0030846, Part III. C.4. Record Contents: Records of monitoring information shall include: a. The date, exact place, and time of sampling or measurements; b. The individual(s) who performed the sampling or measurements; c. The date(s) and time(s) analyses were performed; d. The individual(s) who performed the analyses; e. The analytical techniques or methods used; and f. The results of such analyses. NPDES Permit NM0030846, Part III. C.5. Monitoring Procedures 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. 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. c. An adequate analytical quality control program, including the analyses of sufficient standards, spikes, and duplicate samples to insure the accuracy of all required analytical results shall be maintained by the permittee or designated commercial laboratory. Concern 4 Bench sheets for E. coli are missing basic information such as the person who did the analysis, time of analysis as well as any procedural techniques used before or during the analysis, such as holding time or temperature of the sample prior to analysis, or incubation time or temperature during the analysis. Many of the sheets have values scribbled out or what looks to be white-out with other text over the top of the white-out, with no initials of the person who made the changes or any indication of why the changes were necessary. Bench sheets for E. coli list the method as "22nd Edition Standard Method 9223-B." Standard Methods 22nd Edition was published in 2012. The approved Standard Method, as shown in 40 CFR Part 136.3, is from 2004. BOD and TSS chain of custody forms from samples sent to an external laboratory are missing proper custody information, including relinquished and received signatures, and the laboratory reports are missing the analysis time, making it difficult or impossible to verify compliance with holding times. The permittee was unable to show documentation demonstrating that monitoring and analytical instruments had been calibrated. Bench sheets do not show any indication that the facility has a quality control program, or that spikes and duplicates are part of that program. 4 EPA Inspection Report - Page 5 of 21 City of Elephant Butte, Sierra County Regional Wastewater Treatment Plant Inspection Date 7/30/2018 Requirement 5 NPDES Permit NM0030846, Part I.A. Footnote 4: TRC shall be measured during periods when chlorine is used as either backup bacteria control, when disinfection of plant treatment equipment is required or when used for filamentaceous algae control. For permit reporting, when chlorine is not used in the treatment system the permittee may report N/A on the DMR. The effluent limitation for TRC is the instantaneous maximum and cannot be averaged for reporting purposes. Concern 5 The permittee stated that they clean the ultraviolet (UV) disinfection bulbs on Monday of every week using chlorine, however permittee has reported "NODI-9" which is "Conditional Monitoring - Not Required This Period," on every DMR since the beginning of this permit cycle (10/1/2013). However, the permittee is required to sample for TRC when disinfection of plant treatment equipment is required. Requirement 6 NPDES Permit NM0030846, 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 6 pH buffer solutions did not have received-on or opened-on dates written on the bottles. The manufacturer of these solutions, "USABlueBook" states that they must be used within 6 months after opening. It was therefore impossible to confirm proper calibration of the pH instrument. Section IV - FOLLOW UP The following information was received by EPA after exiting the Facility on 7/30/2018: April, May, and June 2018 DMR data was emailed by the facility on 8/3/2018 Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 32 photos taken 7/30/2018 Appendix 2 - Selected Laboratory bench sheets for May, June, and July 2018 ... 5 EPA Inspection Report - Page 6 of 21 City of Elephant Butte, Sierra County Regional Wastewater Treatment Plant Inspection Date 7/30/2018 Appendix 1 Photograph Log EPA Inspection Report - Page 7 of 21 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: City of Elephant Butte, Sierra County Regional Wastewater Treatment Plant City: Elephant Butte County/Parish: Sierra County State: New Mexico Photo File Name: DSCN0434.JPG Date of Photo: 7/30/2018 Time of Photo: 10:23 AM Photographer: Amy Andrews Description: Sign outside of wastewater treatment plant identifying the facility as belonging to the City of Elephant Butte, rather than Sierra County, as identified on the permit. EPA Inspection Report - Page 8 of 21 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: City of Elephant Butte, Sierra County Regional Wastewater Treatment Plant City: Elephant Butte County/Parish: Sierra County State: New Mexico Photo File Name: DSCN0440.JPG Date of Photo: 7/30/2018 Time of Photo: 10:48 AM Photographer: Amy Andrews Description: Solids floating in finger weirs after the ultraviolet (UV) disinfection chamber (UV banks are to the right in the photo, effluent flows toward the left). EPA Inspection Report - Page 9 of 21 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: City of Elephant Butte, Sierra County Regional Wastewater Treatment Plant City: Elephant Butte County/Parish: Sierra County State: New Mexico Photo File Name: DSCN00443.JPG Date of Photo: 7/30/2018 Time of Photo: 11:09 AM Photographer: Amy Andrews Description: pH buffers showing no received-on or opened-on dates. EPA Inspection Report - Page 10 of 21 City of Elephant Butte, Sierra County Regional Wastewater Treatment Plant Inspection Date 7/30/2018 Appendix 2 Selected Laboratory bench sheets for May, June, and July 2018 EPA Inspection Report - Page 11 of 21 EPA Inspection Report - Page 12 of 21 EPA Inspection Report - Page 13 of 21 EPA Inspection Report - Page 14 of 21 EPA Inspection Report - Page 15 of 21 EPA Inspection Report - Page 16 of 21 EPA Inspection Report - Page 17 of 21 EPA Inspection Report - Page 18 of 21 EPA Inspection Report - Page 19 of 21 EPA Inspection Report - Page 20 of 21 EPA Inspection Report - Page 21 of 21