Document LgVwqJ098300ebxo6ojmRYYYQ
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
01/19/2022 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:
Town of Red River Red River WWTP 2 Straight Creek Trail Red River, New Mexico 87558 Post Office Box 1020 Red River, New Mexico 87558 Taos 575-754-6671 Patrick Jaramillo awwtplant@gmail.com
FRS Number:
110002042110
Identification/Permit Number: Media Identifier Number: NAICS: SIC:
NM0024899 NA 221320 4952
Personnel participating in inspection:
Patrick Jaramillo
Town of Red River
Miguel De La Mata
Town of Red River
Plant Manager
Plant Manager Laboratory Analyst
Matthew Stewart David Esparza EPA Lead Inspector Signature/Date
Supervisor Signature/Date
Town of Red River EPA-R6/ECDWM
Wastewater Operator Environmental Engineer
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: 2022.02.23 11:44:09 -07'00'
Date
ROBERTO
Roberto Bernier
BERNIER
Digitally signed by ROBERTO BERNIER DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=ROBERTO BERNIER, 0.9.2342.19200300.100.1.1=68001003655586 Date: 2022.02.23 13:54:00 -06'00'
Date
6ENFORM-020-R8.2 (02/12/2020)
1
Town of Red River/Red River WWTP Permit No. NM0024899
Inspection Date 01/19/2022
Section I - INTRODUCTION
PURPOSE OF THE INSPECTION
United States Environmental Protection Agency (EPA) Region 6 inspector David Esparza, PE, arrived at the Town of Red River (Red River) Wastewater Treatment Plant (WWTP) approximately 10:00 AM on January 19, 2022, for an unannounced inspection. I presented my credentials to Mr. Patrick Jaramillo, Plant Manager and informed him that 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. The generation of this report is based on information supplied by Red River representatives, observations made by the EPA inspector, NMED, and records and reports maintained by the permittee (Red River), and the EPA. Before leaving the facility on January 19, 2022, an exit briefing was held with Mr. Jaramillo, to explain areas of concern noted at the time of the inspection. It should be noted the WWTP also maintains a discharge permit (DP-268) issued by the New Mexico Environment Department (NMED), Groundwater Quality Bureau (GWQB) in conjunction with the sludge drying beds
FACILITY DESCRIPTION
The WWTP was constructed in 1983 and is classified as a minor discharger with a design capacity of 0.9 MGD serving a year-round population of approximately 500 people and a peak tourist population of approximately 5,000. The facility is located at 2 Straight Creek Trail, Red River, Taos County, New Mexico (depicted in Aerial Image #1 below). The WWTP is operated by staff within the Public Works Department and consists of 7 full-time equivalent (FTE) positions, during the hours of 7:00 AM to 3:30 PM daily. Oncall staff is available on an as needed basis.
The WWTP is located inside a building to protect it from inclement weather during the winter months. The WWTP treatment process is comprised of a gravity collection system (Appendix 2 Piping Flow Diagram), two (2) lift station (identified in Table #1 and depicted in Appendix 3), headworks comprised of a bar screen/grit removal system (Appendix 1 Photograph #1, and Photograph #2), grit cyclone, screened fine mesh filter (Appendix 1 Photograph #3, and Photograph #4), three (3) trains of Rotating Biological Contactors (RBCs): one (1) for biological oxygen demand (BOD) removal and two (2) for ammonia removal (Appendix 1 Photograph #5 and Photograph #6), two (2) parallel final clarifiers, three (3) parallel ultraviolet (UV) disinfection banks (Appendix 1 Photograph #7), thence the disinfected effluent traverses over a stepped cascade structure prior to discharge to the Red River via a closed conduit pipe (Appendix 1 Photograph #8 and Appendix 4 Red River WWTP Hydraulic Profile).
Solids are wasted from the clarifiers and pumped to the seven (7) lined drying beds located east of the WWTP main building. The sludge enters the drying beds via a forced main from the WWTP. Decant water
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Town of Red River/Red River WWTP Permit No. NM0024899
Inspection Date 01/19/2022
is returned to the headworks by gravity flow lines. Following the approximate 3-year sludge detention time, solids are moved to a stockpile area near the WWTP and are blended with wood chips for compost.
Aerial Image #1: Overall view of the Town of Red River's Wastewater Treatment Plant. Aerial from Google Earth maps.
Table 1: Town of Red River Lift Stations
Lift Station
Address
1
High Street
461 East High Street
2
Rio Colorado
approximately at the end of Golden Treasure Trail
Septage and domestic (typically greywater) wastewater is screened before entering the headworks. According to WWTP records approximately two (2) septic dumps per week, averaging 1200 gallons each time is received.
Currently, there is no Industrial User (IU) contributing to the WWTP.
Section II - OBSERVATIONS
I observed the following and/or the following information was provided or stated on January 19, 2022.
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Town of Red River/Red River WWTP Permit No. NM0024899
Inspection Date 01/19/2022
It was stated Red River does not have existing written policies and procedures to address any potential sanitary sewer overflow events (SSOs), standard operating procedures (SOPs) pertaining facility operations and maintenance (O&M) and/or a Fats, Oils and Grease (FOG) program.
The WWTP does not have back-up for some of its aging treatment process equipment (Appendix 1 Photograph #3, and Photograph #4), i.e., if equipment or mechanical systems go off-line replacement parts are difficult to locate and often require specific manufacture reproduction.
The WWTP maintains an on-site generator for back up that is exercised every two (2) weeks.
An alarm system comprised of a series of monitors and a call out system notifies the operators by telephone of any WWTP process failures.
I was advised that in approximately mid-January 2021 electricity was lost to the compressors in the sludge pump room. These compressors are used to assist the four (4) sludge pumps that pump the sludge to the lagoons from the clarifiers. It was ultimately identified the sludge line force main to the lagoons was frozen.
It was stated the sludge has been staged on-site for at least the last 8-years.
Overall maintenance and operation of the WWTF appeared to be satisfactory. All equipment looked to be running properly.
An Administrative Order (AO) (Docket #CWA-06-2018-1781) was issued on April 5, 2018, regarding a bulk caustic soda spill on January 5, 2018.
A First Amended Administrative Complaint (Complaint) (Docket #CWA-06-2018-1786) was issued on July 10, 2018.
A Consent Agreement and Final Order (CAFO) (Docket #CWA-06-2018-1786) was issued on December 4, 2019, regarding the January 2018 bulk caustic soda spill and included provisions to Supplemental Environmental Project (SEP) parameters.
The current NPDES permit (NM0024899) is set to expire on April 30, 2022. A permit/application renewal has not been submitted. Note: The typical process suggests submittal 180-days prior to expiration.
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Town of Red River/Red River WWTP Permit No. NM0024899
Inspection Date 01/19/2022
Section III- RECOMMENDATIONS
Preparation and implementation of written policies and procedures to address any potential sanitary sewer overflow events (SSOs), standard operating procedures (SOPs) pertaining facility operations and maintenance (O&M) and/or a Fats, Oils and Grease (FOG) program.
Section IV - AREAS OF CONCERN
A review of the Integrated Compliance Information System (ICIS) database for the period from January 5, 2018, to January 19, 2022, indicates the following:
1. NPDES permit excursion- Suspended Solids (percent removal)- April 2019, January 2021, and June 2021
2. NPDES permit excursion- pH Gross Effluent- January 2018, February 2018, and June 2021 3. NPDES permit excursion- Biological Oxygen Demand-5 day (BOD5)- January 2019, February 2019,
March 2019, April 2019, January 2021, February 2021 4. NPDES permit excursion- Phosphorus Total [as P]- June 2021 5. NPDES permit excursion- Nitrogen Total [as N]- June 2021 6. NPDES permit excursion- Chlorine Total residual- June 2021 7. Non-receipt of Discharge Monitoring Reports (DMR)- June 2021 8. NPDES permit excursion- Escherichia coli (E coli)- November 2018, March 2019, May 2019, June
2019, and June 2021
Additional Areas of Concern
9. It was stated the sludge has been staged on-site for at least the last 8-years.
10. The current NPDES permit (NM0024899) is set to expire on April 30, 2022. A permit/application renewal has not been submitted. Note: The typical process suggests submittal 180-days prior to expiration.
EPA Region 6 inspector David Esparza conducted a closing conference at Town of Red River's WWTP approximately at 3:30 PM on January 19, 2022, for the inspection.
Section IV - FOLLOW UP
The following information was received by EPA on January 28, 2022, after exiting the Facility on January 18, 2022:
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Town of Red River/Red River WWTP Permit No. NM0024899
Inspection Date 01/19/2022
A summary of the quantity and locations of Red River's lift station(s), inclusive of an aerial image overlay.
An aerial image overlay of the WWTP of the gravity collection/discharge system Piping Flow Diagram.
A copy of the current WWTP hydraulic profile schematic. A summary of the approximate quantity of septage volumes. Section V - LIST OF APPENDICES
Appendix 1 - Photo Log - 8 photos taken 1/19/2022 Appendix 2 - Piping Flow Diagram Appendix 3 - Aerial Image of The Lift Station Locations Appendix 4 - Red River WWTP Hydraulic Profile Appendix 5 - A Review of the Integrated Compliance Information System (ICIS) Database for the
period from January 5, 2018, to January 18, 2022
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Town of Red River/Red River WWTP Permit No. NM0024899
Inspection Date 01/19/2022
Appendix 1
Photograph Log
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: Red River Wastewater Treatment Plant
City: Red River
County/Parish: Taos
State: New Mexico
View of the headworks comprised of a bar screen/grit removal system. (DSCN2098). Photographed by D. Esparza
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: Red River Wastewater Treatment Plant
City: Red River
County/Parish: Taos
State: New Mexico
Another view of the headworks comprised of a bar screen/grit removal system. (DSCN2099). Photographed by D. Esparza
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: Red River Wastewater Treatment Plant
City: Red River
County/Parish: Taos
State: New Mexico
View of the screened fine mesh filter. (DSCN2097). Note: one (1) mesh filter is currently off-line awaiting repair and/or maintenance. Photographed by D. Esparza
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 4
Location: Red River Wastewater Treatment Plant
City: Red River
County/Parish: Taos
State: New Mexico
Another view of the screened fine mesh filter. (DSCN2100). Note: one (1) mesh filter is currently off-line awaiting repair and/or maintenance. Photographed by D. Esparza
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 5
Location: Red River Wastewater Treatment Plant
City: Red River
County/Parish: Taos
State: New Mexico
View of the three (3) trains of Rotating Biological Contactors (RBCs): one (1) for biological oxygen demand (BOD) removal and two (2) for ammonia removal. (DSCN 2102). Photographed by D. Esparza
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 6
Location: Red River Wastewater Treatment Plant
City: Red River
County/Parish: Taos
State: New Mexico
Anther view of the Rotating Biological Contactors (RBCs): one (1) for biological oxygen demand (BOD) removal and two (2) for ammonia removal. (DSCN 2105). Photographed by D. Esparza
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 7
Location: Red River Wastewater Treatment Plant
City: Red River
County/Parish: Taos
State: New Mexico
View of the three (3) parallel ultraviolet (UV) disinfection banks. (DSCN 2107) Photographed by D. Esparza
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 8
Location: Red River Wastewater Treatment Plant
City: Red River
County/Parish: Taos
State: New Mexico
View of the disinfected effluent as it traverses over a stepped cascade structure prior to discharge to the Red River via a closed conduit pipe. (DSCN 2106) Photographed by D. Esparza
Town of Red River/Red River WWTP Permit No. NM0024899
Inspection Date 01/19/2022
Appendix 2 Piping Flow Diagram
Town of Red River/Red River WWTP Permit No. NM0024899
Inspection Date 01/19/2022
Appendix 3 Aerial Image of The Lift Station Locations
Town of Red River/Red River WWTP Permit No. NM0024899
Inspection Date 01/19/2022
Appendix 4 Red River WWTP Hydraulic Profile
Town of Red River/Red River WWTP Permit No. NM0024899
Inspection Date 01/19/2022
Appendix 5
A Review of the Integrated Compliance Information System (ICIS) Database for the period from
January 5, 2018, to January 18, 2022
2/16/22, 1:01 PM
FE&C
NPDES
AIR
ICIS: Search Violation Results
Admin
Reports Help
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Logout
Search Permits Related NPDES Violations
ADD SINGLE EVENT VIOLATION
List of Violations Related to the Permit
Violation Type
Schedule Violation
Schedule Violation
Schedule Violation
Schedule Violation
Schedule Violation
Effluent Violation
Effluent Violation
Effluent Violation
Effluent Violation
Effluent Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
Violation Information 1 A CS031 Achieve Final Compliance With All Obligations Under This order
1 A CS001 Pay Required Civil Penalty Amount
Violation Violation Code Date
Record Numbers 1 to 51
RNC Detection RNC Resolution Action
Code-Date
Code-Date
C40
05/07/2018 S-08/06/2018 5-08/06/2018
C10
08/10/2018
1 A CS001 Pay Required Civil Penalty Amount
C20
08/10/2018
1 A CS001 Pay Required Civil Penalty Amount
C30
08/10/2018 S-11/09/2018 4-12/23/2019
1 A CS001 Pay Required Civil Penalty Amount
C40
08/10/2018 S-11/09/2018 4-01/07/2020
001 A 00400 pH Effluent Gross Season ID:0 C3
E90
01/31/2018
001 A 00400 pH Effluent Gross Season ID:0 C1
E90
02/28/2018
001 A 51040 E. coli Effluent Gross Season ID:0 C3 E90 001 A 81010 BOD, 5-day, percent removal Effluent
E90 Gross Season ID:0 C1 001 A 81010 BOD, 5-day, percent removal Effluent
E90 Gross Season ID:0 C1 001 A 00310 BOD, 5-day, 20 deg. C Effluent Gross
D90 Season ID:0 Q1
11/30/2018 01/31/2019 02/28/2019 03/31/2019 N-05/16/2019 2-09/17/2019
001 A 00310 BOD, 5-day, 20 deg. C Effluent Gross D90
Season ID:0 Q2
03/31/2019 K-05/16/2019 2-09/17/2019
001 A 00310 BOD, 5-day, 20 deg. C Effluent Gross D90
Season ID:0 C2
03/31/2019 N-05/16/2019 2-09/17/2019
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2/16/22, 1:01 PM
Violation Type
DMR NonReceipt Violation
DMR NonReceipt Violation
Effluent Violation
DMR NonReceipt Violation
Effluent Violation
DMR NonReceipt Violation
Effluent Violation
Effluent Violation
Effluent Violation
Effluent Violation
Effluent Violation
Effluent Violation
Effluent Violation
Effluent Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
Violation Information
ICIS: Search Violation Results
Violation Violation Code Date
RNC Detection RNC Resolution Action
Code-Date
Code-Date
001 A 00310 BOD, 5-day, 20 deg. C Effluent Gross D90
Season ID:0 C3
03/31/2019 K-05/16/2019 9-05/16/2019
001 A 51040 E. coli Effluent Gross Season ID:0 C2 D90
03/31/2019 K-05/16/2019 2-09/17/2019
001 A 51040 E. coli Effluent Gross Season ID:0 C2 E90
03/31/2019
001 A 51040 E. coli Effluent Gross Season ID:0 C3 D90
03/31/2019 K-05/16/2019 2-09/17/2019
001 A 51040 E. coli Effluent Gross Season ID:0 C3 E90
001 A 81010 BOD, 5-day, percent removal Effluent D90
Gross Season ID:0 C1 001 A 81010 BOD, 5-day, percent removal Effluent
E90 Gross Season ID:0 C1 001 A 81011 Solids, suspended percent removal
E90 Effluent Gross Season ID:0 C1 001 A 51040 E. coli Effluent Gross Season ID:0 C2 E90
001 A 51040 E. coli Effluent Gross Season ID:0 C2 E90
001 A 51040 E. coli Effluent Gross Season ID:0 C3 E90 001 A 81010 BOD, 5-day, percent removal Effluent
E90 Gross Season ID:0 C1 001 A 81011 Solids, suspended percent removal
E90 Effluent Gross Season ID:0 C1 001 A 81010 BOD, 5-day, percent removal Effluent
E90 Gross Season ID:0 C1 001 A 00310 BOD, 5-day, 20 deg. C Effluent Gross
D90 Season ID:0 Q1
001 A 00310 BOD, 5-day, 20 deg. C Effluent Gross D90
Season ID:0 Q2
001 A 00310 BOD, 5-day, 20 deg. C Effluent Gross D90
Season ID:0 C2
001 A 00310 BOD, 5-day, 20 deg. C Effluent Gross D90
Season ID:0 C3
03/31/2019 03/31/2019 04/30/2019 04/30/2019 05/31/2019 06/30/2019 06/30/2019 01/31/2021 01/31/2021 04/30/2021 06/30/2021 N-08/15/2021 2-08/30/2021
06/30/2021 K-08/15/2021 2-08/30/2021
06/30/2021 N-08/15/2021 2-08/30/2021
06/30/2021 K-08/15/2021 2-08/30/2021
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2/16/22, 1:01 PM
Violation Type
DMR NonReceipt Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
Violation Information
ICIS: Search Violation Results
Violation Violation Code Date
RNC Detection RNC Resolution Action
Code-Date
Code-Date
001 A 00400 pH Effluent Gross Season ID:0 C1
D90
06/30/2021
001 A 00400 pH Effluent Gross Season ID:0 C3
D90
06/30/2021 K-08/15/2021 2-08/30/2021
001 A 00530 Solids, total suspended Effluent Gross D90
Season ID:0 Q1 001 A 00530 Solids, total suspended Effluent Gross
D90 Season ID:0 Q2 001 A 00530 Solids, total suspended Effluent Gross
D90 Season ID:0 C2 001 A 00530 Solids, total suspended Effluent Gross
D90 Season ID:0 C3 001 A 00600 Nitrogen, total [as N] Effluent Gross
D80 Season ID:0 C2 001 A 00600 Nitrogen, total [as N] Effluent Gross
D80 Season ID:0 C3 001 A 00665 Phosphorus, total [as P] Effluent
D80 Gross Season ID:0 C2 001 A 00665 Phosphorus, total [as P] Effluent
D80 Gross Season ID:0 C3 001 A 50050 Flow, in conduit or thru treatment plant
D80 Effluent Gross Season ID:0 C1 001 A 50050 Flow, in conduit or thru treatment plant
D80 Effluent Gross Season ID:0 C2 001 A 50050 Flow, in conduit or thru treatment plant
D80 Effluent Gross Season ID:0 C3 001 A 50060 Chlorine, total residual Disinfection,
D90 Process Complete Season ID:0 C3
06/30/2021 N-08/15/2021 2-08/30/2021 06/30/2021 K-08/15/2021 2-08/30/2021 06/30/2021 N-08/15/2021 2-08/30/2021 06/30/2021 K-08/15/2021 2-08/30/2021 06/30/2021 N-08/15/2021 2-08/30/2021 06/30/2021 K-08/15/2021 2-08/30/2021 06/30/2021 N-08/15/2021 2-08/30/2021 06/30/2021 K-08/15/2021 2-08/30/2021 06/30/2021 N-08/15/2021 2-08/30/2021 06/30/2021 K-08/15/2021 2-08/30/2021 06/30/2021 K-08/15/2021 2-08/30/2021 06/30/2021 K-08/15/2021 2-08/30/2021
001 A 51040 E. coli Effluent Gross Season ID:0 C2 D90
06/30/2021 N-08/15/2021 2-08/30/2021
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Violation Type
DMR NonReceipt Violation
DMR NonReceipt Violation
DMR NonReceipt Violation
Effluent Violation
Effluent Violation
Violation Information
ICIS: Search Violation Results
Violation Violation Code Date
RNC Detection RNC Resolution Action
Code-Date
Code-Date
001 A 51040 E. coli Effluent Gross Season ID:0 C3 D90
06/30/2021 K-08/15/2021 2-08/30/2021
001 A 81010 BOD, 5-day, percent removal Effluent D90
Gross Season ID:0 C1
001 A 81011 Solids, suspended percent removal D90
Effluent Gross Season ID:0 C1 001 A 81010 BOD, 5-day, percent removal Effluent
E90 Gross Season ID:0 C1 001 A 81011 Solids, suspended percent removal
E90 Effluent Gross Season ID:0 C1
06/30/2021 06/30/2021 10/31/2021 10/31/2021
Record Numbers 1 to 51
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