Document LoBQoO101ZRkV9NK3mnLyMRyb
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
06/25/2025 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 Roswell
Roswell Wastewater Treatment Plant
2306 E. College Road
Roswell, New Mexico
Post Office Drawer 1838
Roswell, New Mexico 88202-1838
Chavez
575-622-1449 x 3307
Naomi Steward
Wastewater Supervisor
n.steward@roswell-nm.gov
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
110039926925 NM0020311 N/A 221320 4952
Personnel participating in inspection:
Andrew Valadez
City of Roswell
Naomi Steward
City of Roswell
David Esparza
EPA-ECDWM
Utilities Director Wastewater Supervisor Environmental Engineer
EPA Lead Inspector Signature/Date
DAVID ESPARZA Date: 2025.08.25 11:34:59 -06'00' Digitally signed by DAVID ESPARZA
David Esparza
Date
Supervisor Signature/Date
ROBERTO BERNIER Date: 2025.08.26 08:24:10 -05'00' Digitally signed by ROBERTO BERNIER
Roberto Bernier
Date
6ENFORM-019-R9 (02/27/2025)
1
City of Roswell/Roswell WWTP Permit No. NM0020311
Inspection Date 06/25/2025
Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspector David Esparza, PE, arrived at the City of Roswell Wastewater Treatment Plant (WWTP) at approximately 8:30 AM on June 25, 2025, for an announced inspection. I met with Mr. Andrew Valadez, Utilities Director, 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 Ms. Naomi Steward, Wastewater Supervisor. 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 Roswell representatives, observations made by the United States Environmental Protection Agency (US EPA) inspector, and records and reports maintained by the permittee (Roswell), and the US EPA. Before leaving the facility on June 25, 2025, an exit briefing was held with Mr. Valadez and Ms. Naomi Steward, to explain areas of concern noted at the time of the inspection and discuss the Capacity Management Operations and Maintenance (CMOM) checklist forwarded via electronic mail (email) earlier in our discussion (Appendix 1 Capacity Management Operations and Maintenance Self-Assessment). Note: The City of Roswell's existing NPDES permit became effective on January 1, 2020, and had an expiration date of December 31, 2024. A permit renewal application was submitted on July 22, 2024. FACILITY DESCRIPTION The WWTP is a major discharger with a design flow of 7.0 million gallons per day (MGD) and average daily flow of approximately 3.1 MGD. The facility is located at 2306 E. College Road, Roswell, Chavez County, New Mexico (depicted in Aerial Image #1 below). The WWTP facility serves a population of approximately 48,000 residents. The WWTP is operated by staff within the Public Works Department and consists of 9 full-time equivalent (FTE) positions, exclusive of administrative support, during the hours of 7:00 AM to 3:30 PM during the regular work week and 7:00 AM to 9:00 AM on the weekends. On-call staff is available on an as needed basis.
2
City of Roswell/Roswell WWTP Permit No. NM0020311
Inspection Date 06/25/2025
Aerial Image #1: Overall view of the City of Roswell's Wastewater Treatment Plant. Aerial from Google Earth maps.
A Supervisory Control and Data Acquisition (SCADA) system provides around the clock monitoring of WWTP operations. The WWTP is a gravity flow system with four (4) lift stations (LS), (identified in Table 1 below). After entering the WWTP raw influent traverses through a pump station, thence through a bar screen and a grit chamber. It then enters one of two primary clarifiers, into a splitter box and then flows into aeration basins with fine bubble diffusers. It then flows into the final clarifiers. The facility staff monitors incoming registered septage haulers for pH and grease to determine compatibility with the WWTP for acceptance or rejection.
Table 1: City of Roswell Lift Stations
Lift Station Name Roswell
International Air Center (RIAC) Mistic Kids Care Mescalero
Location by Street Address 1211 E Hobson Rd
122 Will Rogers Rd. 3751 N Main
1000 E Mescalero
Comment Back-up power
Following the belt press, the sludge originating from the primary treatment process is placed in drying beds (underdrains return excess liquid to the headworks) for composting into Class A sludge for land application and/or local agricultural purposes.
It was stated the WWTP has not discharged to the Rio Hondo in approximately 2-years but utilizes the treated effluent to irrigate approximately 1,100-acres of cropland and 200-acres of golf course turf.
3
City of Roswell/Roswell WWTP Permit No. NM0020311
Inspection Date 06/25/2025
Additionally, the WWTP uses the water to irrigate the facility grounds, wash water on the fine screen bar screen and the gravity belt thickener. It should be noted the WWTP does not maintain a retention pond
for re-use water. All disinfected water not used for facility purposes is pumped directly to the area farmers.
If there is a discharge to Outfalls 001 and/or 002, samples are collected via an automatic sampler located after two (2) banks of ultraviolet (UV) disinfection. Routine weekly maintenance is performed on the UV system to ensure the proper disinfection of the effluent.
Currently the established Industrial Users (IU) includes Dean Baldwin Paint LLC., and Vestis (f.k.a. Aramark). The City of Roswell and the above identified entities entered into individual wastewater discharge agreements for the disposal of variable treated effluent amounts ranging from 1,500 gpd (gallons per day) to 44,000 gpd into the City's WWTP.
The WWTP maintains a backup diesel generator for power that is exercised weekly, typically every Friday.
Section II - OBSERVATIONS
I observed the following and/or the following information was provided or stated:
A review of the City of Roswell completed CMOM Self-Assessment: General Information (page 2)indicates an average daily flow of 3.1 MGD of the design capacity 7 MGD.
A review of the City of Roswell completed CMOM Self-Assessment: Collection System Information (page 3)- indicates 4 lift or pump stations (identified in Table 1 above), and an approximate service area of 30 square miles. Further discussion regarding the CMOM indicates that 20% of the total piping, equates to 26-years old and less than 50-years old and the remaining 80% approximately 75-years old. The CMOM further states 80% of the piping is constructed of vitrified clay pipe (VCP) and 20% of polyvinyl chloride pipe (PVC).
A review of the City of Roswell completed CMOM Self-Assessment: Budgeting (BUD) (page 10)- does not identify a percentage of the utility `s overall budget being allocated to maintenance of the collection system (BUD-06).
A review of the City of Roswell completed Self-Assessment: Training (TR) (page 12) indicates the utility does have a formal job knowledge, skills, and abilities (KSA) training program(TR-01), but indicates 100% of the training goals is on-the-job (TR-10).
A review of the City of Roswell completed CMOM Self-Assessment: Safety (SAF) (page 14) does not indicate the utility has a written safety policy in place (SAF-01).
A review of the City of Roswell completed CMOM Self-Assessment: Customer Service (CS) (page 17) does not indicate the utility has a customer service and public relations program (CS-01), or customer service evaluation program to obtain feedback from the community in place (CS-08).
A review of the City of Roswell completed CMOM Self-Assessment: Equipment & Collection System
4
City of Roswell/Roswell WWTP Permit No. NM0020311
Inspection Date 06/25/2025
Maintenance (ESM) (page 17 and page 18) indicates the utility does not maintain maintenance schedule records (ESM-02), there is not an established system for prioritizing equipment maintenance needs (ESM-04), and corrective repair work orders are not backlogged more than six months (ESM-06).
A review of the City of Roswell completed CMOM Self-Assessment: Equipment Parts Inventory (EPI) (page 18 and page 19) indicates the utility has not identified critical spare parts (EPI-01), adequate supplies are not on hand to allow for two-point repairs (EPI-02), the system does not have a parts standardization policy in place (EPI-03), does not maintain a stock of spare parts on its maintenance vehicles (EPI-05), and does not have a system in place to track and maintain an accurate inventory of spare parts (EPI-06).
A review of the City of Roswell completed CMOM Self-Assessment: Management Information System (MIS) (page 20) indicates there are not written instructions for managing and tracking scheduled system inventory, safety incidents, equipment/tools tracking or parts inventory (MIS-04). Additionally, it is not clear how often the management information system is updated (MIS-06).
A review of the City of Roswell completed CMOM Self-Assessment: System Mapping (MAP) (page 21 and page 22) indicates "as built" plans (record drawings) or maps are not available for use by field crews in the office and in the field (MAP-01), and there is not a procedure for field crews to record changes or inaccuracies in the maps and update the mapping system (MAP-02). Additionally, the System Mapping does not record the following scale, property lines, SSO occurrences, pipe material, installation date, flow meters, slope, manhole rim elevation, manhole coordinates, or manhole invert elevation (MAP-04). Note: the city states it does have a combined sewer. Furthermore, these additional manhole attributes shape, type (e.g., precast, cast in place, etc.) or age are not recorded (MAP-06).
A review of the City of Roswell completed CMOM Self-Assessment: Internal TV Inspection (TVI) (page 23) indicates the utility does not have a standardization pipeline condition assessment program (TVI01). It is not clear if a written operation procedures/guidelines for the internal TV inspection program exists (TVI-03), inclusive of records indicating pipe size, type, length, and joint spacing, distance recorded by internal TV, results of the internal TV inspection (including a structural rating), internal TV operator name, cleanliness of the line and location and identification of line being televised by manholes (TVI-04). Furthermore, a rating system is not used to determine the severity of the defects found during the inspection process (TVI-05), a code list is not used for internal TV inspection reporting (TVI-06), though the total defects determined by TV inspection, during the past 5, years are attributed to the following: debris/grease/roots, intruding tap/roots, surcharges, offset joint/grease, and line failure are not identified (TVI-07).
A review of the City of Roswell completed CMOM Self-Assessment: Sewer Cleaning (CLN) (page 25 and page 26) indicates there is not a program to identify sewer line segments, with chronic problems, that should be cleaned on a more frequent schedule (CLN-01), though it also states the entire system is cleaned weekly. It further states the city does not have a root control program (CLN-05), and it is not clear if stoppages are plotted on maps and correlated with other data such as pipe size and material or location (CLN-09).
5
City of Roswell/Roswell WWTP Permit No. NM0020311
Inspection Date 06/25/2025
A review of the City of Roswell completed CMOM Self-Assessment: Manhole Inspection and Assessment (MAN) (page 26 and page 27) indicates the city does not have routine manhole inspection and assessment program (MAN-01), does not have a goal for the number of manholes inspected annually (MAN-03), inflow from manhole covers, presence of infiltration, location, and estimated quantity, inflow from manhole covers (MAN-05), or a grouting program (MAN-06).
A review of the City of Roswell completed CMOM Self-Assessment: Pump Stations (PS) (page 28 and page 29) indicates the city does not have an emergency operating procedure for each pump station (PS-03), only 1 of the 4 pump stations are equipped with backup power sources (PS-05), and there is not a procedure for manipulating pump operations during wet weather to increase in-line storage of wet weather flows (PS-07). Additionally, records are not maintained for each inspection (PS-13) and 12% of the pump stations are equipped with permanent flow meters (PS-19).
A review of the City of Roswell completed CMOM Self-Assessment: Capacity Assessment (CA) (page 30) indicates that the city does not have a flow monitoring program (CA-01), a comprehensive capacity assessment and planning program (CA-02), or a tool (hydraulic model, spreadsheet, etc.) for assessing whether adequate capacity exists in the sewer system (CA-04).
A review of the City of Roswell completed CMOM Self-Assessment: Tracking SSOs (TRK) (page 32 and page 33) is not clear if the city, has reported any SSO event in the past 5 years (TRK-01).
A review of the City of Roswell completed CMOM Self-Assessment: Overflow Emergency Response (OERP) (page 35) indicates the city does not have a documented OERP available for utility staff to use (OERP-01). Additionally, it is not clear if specific responsibilities for personnel who respond to emergencies are detailed (OERP-03), if staff are continuously trained to respond to emergencies (OERP-04), or if work crews have immediate access to tools and equipment during emergencies (OERP-05). Furthermore, it is not clear if procedures to limit public contact with areas affected by SSOs (OERP-09), or containment techniques to protect storm systems exist (OERP-10).
A review of the City of Roswell completed CMOM Self-Assessment: Smoke & Dye Testing (SDT) (page 36 and page 37) indicates the city does not have a have a smoke testing program to identify sources of inflow and infiltration (SDT-01), a smoke testing program to identify sources of inflow and infiltration in illegal connectors (SDT-01A), or a smoke testing program to identify sources of inflow and infiltration in house laterals (private service laterals (SDT-01B).
A review of the City of Roswell completed CMOM Self-Assessment: Hydrogen Sulfide Monitoring and Control (HSMC) (page 38 and page 39) indicates the city does not have a have a program to rate the system vulnerability for hydrogen sulfide corrosion or any associated aspects (HSMC-01).
During the closing conference, David Esparza discussed the requested completion of the Capacity, Management, Operation and Maintenance (CMOM) Self-Assessment document.
Section III - AREAS OF CONCERN
A review of the of the CMOM self-assessment completed by the City of Roswell, and additional supporting information, indicates some of the following or could be beneficial:
6
City of Roswell/Roswell WWTP Permit No. NM0020311
Inspection Date 06/25/2025
A review of the City of Roswell completed CMOM Self-Assessment indicates it is not clear the city, has reported any SSO events in the past 5 years.
Preparation of an Overflow Emergency Response Plan (OERP) delineating specific utility staff responsibilities to responding emergencies, a public notification plan and procedures to limit public contact with areas affected by sanitary sewer overflow (SSO) events.
Preparation of an Internal TV Inspection (TVI), Sewer Cleaning (CLN), Manhole Inspection and Assessment (MAN) program.
Preparation/creation of supporting documentation to complement the tracking maintenance activities within the existing Management Information System (MIS).
Preparation of an Equipment & Collection System Maintenance (ESM) and Equipment Parts Inventory (EPI) program. Given the recent experiences of supply chain delays, it is paramount to dayto-day operations and permit compliance.
Preparation of a newsletter or notification procedure for regular communication/coordination with other municipal departments to facilitate Internal Communications (IC).
Preparation of a formal Training (TR) job knowledge, skills, and abilities (KSA) training program to assist and encourage safe work practices and potential position advancement.
EPA Region 6 inspector David Esparza, PE conducted a closing conference at the Roswell WWTP at approximately 1:00 PM on June 25, 2025, for the inspection. During the closing conference, David Esparza discussed the requested completion of the Capacity, Management, Operation and Maintenance (CMOM) Self-Assessment document.
ADDITIONAL AREAS of CONCERN:
A review of the submitted Integrated Compliance Information System (ICIS) Discharge Monitoring Reports (DMR) data for the period January 21, 2022, through March 31, 2025, indicates NPDES permit exceedances with respect to Oxygen, dissolved (DO) and Whole Effluent Toxicity (WET) (Appendix 2 ICIS E90 Effluent Violations).
A review of the submitted Integrated Compliance Information System (ICIS) Discharge Monitoring Reports (DMR) data for the period January 4, 2024, through May 8, 2025, indicates Roswell experienced 7 sanitary sewer overflow (SSO) events (Appendix 3 ICIS E80 Effluent Violations).
Section IV - FOLLOW UP
The following information and/or clarification was received by EPA after exiting on June 25, 2025:
Completed Capacity Management Operations and Maintenance Self-Assessment
7
Section V - LIST OF APPENDICES
City of Roswell/Roswell WWTP Permit No. NM0020311
Inspection Date 06/25/2025
Appendix 1 - Capacity Management Operations and Maintenance Self-Assessment Appendix 2 - Review of the ICIS E90 Effluent Violations Appendix 3 - Review of the ICIS E80 Effluent Violations
8
Appendix 1
Capacity Management Operations and
Maintenance Self-Assessment (CMOM)
1
CAPACITY, MANAGEMENT, OPERATION AND MAINTENANCE
(CMOM) Program Self-Assessment
Compiled By: Name: ___Naomi Steward_________________ Title: ___Superintendent__________________ Date: ___07/11/2025_____________________ Staffing list and Organization chart: Attach separate document as needed
2
General Information
Service area Annual precipitation
29.7
SQ. MILES
12.91 inches*
NUMBER
Service population
*Based off the link below 1/1893-6/2016
47,836
PEOPLE
*Find your annual New Mexico precipitation here: https://wrcc.dri.edu/summary/Climsmnm.html
# of Treatment Facilities
1
NUMBER
WWTP design capacity
Average Daily Flow Manholes
3.1
MGD
NUMBER
Average dry weather flow
Number of air vacuum relief valves
Service Area Characteristics Residential Industrial
Multi-Family
Total
X X X
NUMBER
Commercial Institutional
Other
NUMBER
Collection system service lateral responsibility (check one) At main line connection only From main line to property line or easement/cleanout Beyond property line/clean out Other: Comments:
7 MGD
MGD
3.1
MGD
NUMBER
X X
NUMBER
X
What percent of sewer system is served by combined sewers (i.e., sanitary sewage and storm water in the same pipe)?
2
PERCENT
Collection System Information
Conveyance & Pumping
Gravity Sewers
Pipes and pumps:
Length/quantity
MILES
Age of system: 0-25 years old
PERCENT
26-50 years old
PERCENT
51-75 years old
>75 years old
Number of Inverted siphons
PERCENT
70
PERCENT
3
Pump Stations
Stations Force Mains
4
NUMBER
MILES
Vacuum Stations
Stations Vacuum Lines
Force Mains
NUMBER
MILES
MILES
NUMBER PERCENT
NUMBER PERCENT
PERCENT
NUMBER PERCENT
NUMBER PERCENT
PERCENT
NUMBER PERCENT
NUMBER PERCENT
PERCENT
NUMBER PERCENT
NUMBER PERCENT
PERCENT
NUMBER
Pipe Diameter Information 8 inches or less
Gravity Sewers
Force Mains
Vacuum Lines
PERCENT
PERCENT
PERCENT
9 - 14 inches
PERCENT
PERCENT
PERCENT
15 - 36 inches
PERCENT
PERCENT
PERCENT
Comments:
> 36 inches
PERCENT
PERCENT
PERCENT
4
Pipe Material Information Prestressed concrete cylinder pipe (PCCP) High density polyethylene (HDPE) Reinforced concrete pipe (RCP) Polyvinyl Chloride (PVC) Vitrified Clay Pipe Cast Iron Pipe (CIP), Ductile Iron Pipe (DIP) Non-reinforced concrete pipe Asbestos cement pipe Brick Fiberglass Cured in Place Fold and Form
Comments:
Gravity Sewer
PERCENT
Force Mains
Vacuum Lines
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
20
PERCENT
80
PERCENT
PERCENT PERCENT PERCENT
PERCENT PERCENT PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
PERCENT
5
Engineering Design (ED)
ED-01
Checklist Item Is there a document which includes design criteria and standard construction details?
Comments:
ED-02
Is there a document that describes the procedures that the utility follows in construction design review?
Comments:
ED-03 ED-04 ED-05 ED-06
Are WWTP and O&M staff involved in the design review process? Comments:
Is there a procedure for testing and inspecting new or rehabilitated system elements both during and after the construction is completed? Comments:
Are construction sites supervised by qualified personnel (such as professional engineers) to ascertain the construction is in accordance with the agreed upon plans and specifications?
Comments:
Are new manholes tested for inflow and infiltration? Comments:
ED-07 ED-08
Are new gravity sewers checked using closed circuit TV inspection? Comments:
Does the utility have documentation on private service lateral design and inspection standards? Comments:
ED-09
Does the utility attempt to standardize equipment and sewer system components?
Comments:
Comments:
Yes No N/A X X X X
X X
X X X
6
Satellite Communities and Sewer Use Ordinance (SUO) Checklist Item
SUO-01 Does the utility receive flow from satellite communities? IF NO, GO TO NEXT SECTION
Comments:
Yes No N/A X
SUO-02 What is the total area from satellite communities that contribute flow to the collection system? (Acres or square miles) Comments:
SUO-03 Does the utility require satellite communities to enter into an
X
agreement? IF NO, GO TO QUESTION SUO-06
Comments:
SUO-04
Does the agreement include the requirements listed in the sewer use ordinance?
Comments:
SUO-05
Do the agreements have a date of termination and allow for renewal under different terms?
Comments:
SUO-06 Does the utility maintain a legal authority to control the
X
maximum flow introduced into the collection system from
satellite communities?
Comments:
SUO-07 Are standards, inspections, and approval for new
X
connections clearly documented in a SUO?
Comments:
SUO-08 Does the SUO require satellite communities to adopt the same
X
industrial and commercial regulatory discharge limits as the
utility?
Comments:
SUO-09 Does the SUO require satellite communities to adopt the same
X
inspection and sampling schedules as required by the
pretreatment ordinance?
Comments:
SUO-10 Does the SUO require satellite communities or the utility to
X
issue control permits for significant industrial users?
Comments:
7
Checklist Item
SUO-11 Does the SUO contain provisions for addressing overstrength wastewater from satellite communities? Comments:
SUO-12
Does the SUO contain procedures for the following? Inspection standards Pretreatment requirements Building/sewer permit issues Comments:
SUO-13 Does the SUO contain general prohibitions of the following materials?
Fire and explosion hazards Corrosive materials Obstructive materials Oils or petroleum Material which may cause interference at the wastewater treatment plant Comments:
SUO-14
Does the SUO contain procedures and enforcement actions for the following?
Fats, oils, and grease (FOG) Infiltration and inflow Building structures over the sewer lines Storm water connections to sanitary lines (downspouts) Defects in service laterals located on private property Sump pumps, air conditioner connections Comments:
Comments:
Yes No N/A X
X X X
X X X X X
X X X X X
X
8
Organizational Structure (OC) Checklist Item OC-01 Is an organizational chart available that shows the overall
personnel structure for the utility, including operation and maintenance staff? Comments:
Yes No N/A X
OC-02 Are up-to-date job descriptions available that delineate responsibilities and authority for each position? X Comments:
OC-03 Are the following items discussed in the job descriptions?
Nature of work to be performed
X
Minimum requirements for the position
X
Necessary special qualifications or certifications
X
Examples of the type of work
X
List of licenses required for the position
X
Performance measures or promotion potential
X
Comments:
OC-04 What percent of staff positions are currently vacant?
20%
Comments:
OC-05
On average how long do positions remain vacant? (months)
APPROX 1MO
Comments: POSITIONS ARE FILLED IMMEDIATELY BASED ON THE POOL OF
APPLICANTS
OC-06 What percent of utility work is contracted out?
10%
Comments:
Comments:
9
Internal Communications (IC) Checklist Item
IC-01 Which of the following methods are used to communicate with utility staff?
Regular meetings Bulletin boards E-mail Cell Phones Other (explain) Comments:
Yes No N/A
X X X X
IC-02 How often are the staff meetings held? (e.g., Daily, Weekly, Monthly, etc.)
Comments:
CASE TO CASE BASIS
IC-03 Are incentives offered to employees for performance improvements?
X
Comments: IC-04 Does the utility have an X
"Employee of the Month/Quarter/Year" program? Comments: UOCP NMED "OPERATOR OF THE YEAR"
IC-05 How often are performance reviews conducted? (e.g. Semi-annually, Annually, etc.)
Comments:
6 MONTHS PROBATIONARY PERIOD
IC-06 Does the utility regularly communicate/coordinate with other X municipal departments?
Comments: MONTHLY INFRASTRUCTURE MEETINGS @ CITY HALL
Comments:
10
Budgeting (BUD)
Checklist Item
Yes No N/A
BUD-01 What is the average annual fee for residential users? Avg. $5.84
Comments: B a s e d o f f i n f o r m a t i o n a v a i l a b l e 0 . 8 7 p e r 1,000gal
BUD-02 How often are user charges evaluated and adjusted? (e.g. annually, biannually. etc.)
Comments:
BUD-03 Are utility-generated funds used for non-utility programs?
X
Comments:
BUD-04 Are costs for collection system operation and maintenance (O&M) separated from other utility services such as water, storm water, X and treatment plants? IF NO, GO TO BUD-07
Comments:
BUD-05 What is your average annual (O&M) budget? Comments:
BUD-06 What percentage of the utility's overall budget is allocated to maintenance of the collection system? Comments:
BUD-07 Does the utility have a Capital Improvement Plan (CIP) that
provides for system repairs/replacements on a prioritized basis?
X
Comments:
BUD-08 What is your average annual CIP budget? Comments:
Comments:
11
Checklist Item BUD-09 What percentage of the maintenance budget is allotted
to the following maintenance? Predictive maintenance Preventive maintenance -
Corrective maintenance -
Emergency maintenance Comments:
BUD-10
Does the utility have a budgeted program for the replacement of under-capacity pipes?
Comments:
BUD-11
Does the utility have a budgeted program for the replacement of over-capacity pipes?
Comments:
Yes No N/A
Comments:
12
Training (TR)
Checklist Item
TR-01
Does the utility have a formal job knowledge, skills, and abilities (KSA) training program?
Comments:
Yes No N/A X
TR-02 Does the training program address the fundamental mission, X goals, and policies of the utility? Comments:
TR-03 Does the utility have mandatory training requirements X identified for key employees? Comments:
TR-04
What percentage of employees met or exceeded their annual training goals during the past year?
Comments:
TR-05 Does the utility provide training in the following areas?
Safety
X
Routine line maintenance
X
Confined space entry
X
Traffic control
X
Record keeping
X
Electrical and instrumentation
Pipe repair
X
Bursting / CIPP
Public relations
SSO/Emergency response
X
Pump station operations and maintenance
X
CCTV and trench/shoring
X
Other
Comments:
TR-06 Are operator and maintenance certification programs used? X IF NO GO TO TR-08 Comments:
13
TR-07 Are operator and maintenance certification programs X required? Comments: For appropriate personnel.
TR-08 Is on-the-job training progress and performance measured? Comments:
TR-09
Checklist Items
Yes No NA
Which of the following methods are used to assess the effectiveness of the training?
None Periodic testing Drills Demonstrations Comments:
TR-10 What percentage of the training offered by the utility is in the form of the following?
Manufacturer training On-the-job training 100 In-house classroom training Industry-wide training Comments:
Safety (SAF)
Checklist Item
Yes No N/A
SAF-01 Does the utility have a written safety policy?
Comments:
SAF-02 How often are safety procedures reviewed and revised? (Annually, quarterly, etc.)
Comments:
SAF-03 Does the utility have a safety committee?
X
Comments:
SAF-04 Are regular safety meetings held with the utility employees?
X
How often?
Comments:
SAF-05 Does the utility have a safety training program?
X
14 Comments:
SAF-06 Are records of employee safety training kept up to date?
X
Comments:
SAF-07
Checklist Item Does the utility have written procedures for the following? Lockout/tagout Material safety data sheets (MSDS) Chemical handling Confined spaces permit programs Trenching and excavations safety Biological hazards in wastewater Traffic control and work site safety Electrical and mechanical systems Pneumatic and hydraulic system safety Comments:
Yes No N/A
X X X X X X X X X
SAF-08 What is your agency's lost-time injury rate?
Comments:
SAF-09 Are the following equipment items available and in adequate supply?
Rubber/disposable gloves
X
Confined space ventilation equipment
X
Hard hats, safety glasses, rubber boots
X
Antibacterial soap and first aid kit
X
Tripods or non-entry rescue equipment
Fire extinguishers
X
Equipment to enter manholes
Portable crane/hoist
X
Atmospheric testing equipment and gas detectors
Oxygen sensors
H2S Monitors
X
Full body harness
X
Protective clothing
X
Traffic/public access control equipment
5-minute escape breathing devices
Life preservers for lagoons
N/A
Life preservers at activated sludge plants
X
Fiberglass or wooden ladders for electrical work
X
Respirators and/or self-contained breathing apparatus
Methane gas or optical vector (OVA) analyzer
Lower explosion limit (LEL) metering
15
Comments:
SAF-10 Are safety monitors clearly identified?
X
Comments:
Customer Service (CS)
Checklist Item
CS-01 Does the utility have a customer service and public relations program? IF NO GO TO CS-03
Comments:
Yes No N/A
CS-02 Does the customer service program include giving formal presentations on the wastewater field to the following?
Schools and universities Community gatherings Local officials Businesses Media Citizens Building Inspector(s) Public utility officials Comments:
CS-03 Are employees of the utility specifically trained in customer
X
service?
Comments:
CS-04 Are there sample correspondence, Q/A's, or "scripts" to help
X
guide staff through written or oral responses to customers?
Comments:
CS-05
What methods are used to notify the public of major construction or maintenance work?
Door hangers Public radio or T.V. announcements Newspaper Flyers
X X X
X
16
Signs
X
Other
X
None
Comments: A N N O U N C E M E N T S O N S O C I A L M E D I A P L A T F O R M S
CS-06
Checklist Item
Is a homeowner notified prior to construction that his/her property may be affected? Comments:
CS-07
Do you provide information to residents on cleanup and safety procedures following basement backups and overflows from manholes when they occur?
Comments:
Yes No N/A X
X
CS-08 Does the utility have a customer service evaluation program to
X
obtain feedback from the community?
Comments:
CS-09 Do customer service records include the following information?
Personnel who received the complaint or request
X
Nature of the complaint or request
X
To whom the follow-up action was assigned
X
Date of the complaint or request
X
Date the complaint or request was resolved
X
Total days to end the problem
X
Name, address, and telephone number of the customer
X
Location of the problem
X
Date the follow up action was assigned
X
Cause of the problem
Feedback to customer
X
Comments: Asset Essentials work order has the bulk of this information
CS-10 Does the utility have a goal for how quickly customer
x
complaints (or emergency calls) are resolved?
IF NO, GO TO NEXT SECTION
17 Comments:
CS-11 What percentage of customer complaints (or emergency calls) are resolved within the timeline goals? 99%
Comments:
Equipment & Collection System Maintenance (ESM)
Checklist Item
ESM-01
Is a maintenance card or record kept for each piece of mechanical equipment within the collection system? IF NO, GO TO ESM-03
Comments:
Yes No N/A X
ESM-02
Do equipment maintenance records include the following information?
Maintenance recommendations
X
Instructions on conducting the specific maintenance activity
X
Other observations on the equipment
X
Maintenance schedule
X
A record of maintenance on the equipment to date
X
Comments:
ESM-03 Are dated tags used to show out-of-service equipment?
X
Comments:
ESM-04 Is there an established system for prioritizing equipment X maintenance needs?
Comments:
ESM-05 What percent of repair funds are spent on emergency repairs?
25%
Comments:
ESM-06 Are corrective repair work orders backlogged more than six x months? Comments:
ESM-07 Do collection system personnel coordinate with state, county,
and local personnel on repairs, before the street is paved?
x
18 Comments:
Comments:
Equipment Parts Inventory (EPI)
EPI-01
Checklist Item Have critical spare parts been identified? Comments:
Yes No N/A x
EPI-02 Are adequate supplies on hand to allow for two-point repairs in
x
any part of the system?
Comments:
EPI-03 EPI-04
Is there a parts standardization policy in place? Comments: Does the utility have a central location for storing spare parts?
Comments:
x x
EPI-05 Does the utility maintain a stock of spare parts on its
x
maintenance vehicles?
Comments:
EPI-06 Does the utility have a system in place to track and maintain an
x
accurate inventory of spare parts?
Comments:
EPI-07 For those parts which are not kept in inventory, does the x utility have a readily available source or supplier? Comments:
19 Comments:
Management Information System (MIS) Checklist Item
MIS-01
Does the utility have a management information system (MIS) in place for tracking maintenance activities? (Either electronic or good paper files) IF NO, GO TO NEXT SECTION
Comments:
Yes No N/A x
MIS-02 Are the MIS records maintained for a period of at least three x years? Comments:
MIS-03 Is the MIS able to distinguish activities taken in response to x an overflow event? Comments:
MIS-04
Are there written instructions for managing and tracking the following information? (Check all that apply)
Complaint work orders x Schedule work orders x Customer Service X Scheduled preventive maintenance X Scheduled Inspections X
Scheduled system inventory
Safety incidents
Scheduled monitoring/sampling X
20
MIS-05
Compliance/overflow tracking X Equipment/tools tracking Parts inventory Do the written instructions for tracking procedures include the following information?
Accessing data and information Instructions for using the tracking system Updating the MIS Developing and printing reports Comments:
MIS-06
Checklist Item How often is the management information system updated?
Immediately Within one week of the "incident" Monthly Other: Comments:
Yes No N/A
Comments:
System Mapping (MAP)
Checklist Item
MAP-01 Are "as built" plans (record drawings) or maps available for use by field crews in the office and in the field?
Comments:
Yes No N/A x
21
MAP-02 Is there a procedure for field crews to record changes or
x
inaccuracies in the maps and update the mapping system?
Comments:
MAP-03 Do the maps show the date the map was drafted and the
x
date of the last revision?
Comments:
Comments:
MAP-04
Checklist Item Do the sewer line maps include the following? Scale North arrow Date the map was drafted Date of last revision Service area boundaries Property lines Other landmarks (Roads, water bodies, etc.) Manhole and other access points Location of building laterals Street names SSOs occurrences/CSOs outfalls Flow monitors Force mains Pump stations Lined sewers Main, trunk, and interceptor sewers Easement lines and dimensions Pipe material Pipe diameter Installation date Slope Manhole rim elevation Manhole coordinates Manhole invert elevation Distance between manholes
Yes No N/A
x X X X X
x X X X X
x x
X X
x X X X X x
22 Comments:
MAP-05 Are the following sewer attributes recorded? Size Shape Invert elevation Material Separate/combined sewer Installation date Comments:
MAP-06
Checklist Item Are the following manhole attributes recorded? Shape Type (e.g., precast, cast in place, etc.) Depth Age Material Comments:
Yes No N/A
x x x x x
MAP-07 Is there a systematic numbering and identification system to
x
identify manholes, sewer lines, pump station, etc.?
Comments:
Internal TV Inspection (TVI)
Checklist Item
Yes No N/A
TVI-01 Does the utility have a standardization pipeline condition assessment
x
program? If yes, explain
Comments:
TVI-02 Is internal TV inspection used to perform condition assessment? x IF NO, GO TO NEXT SECTION
23
TVI-03
Comments: Are there written operation procedures/guidelines for the internal TV inspection program?
Comments:
TVI-04 Do the internal TV record logs include the following?
Pipe size, type, length, and joint spacing
x
Distance recorded by internal TV
x
Results of the internal TV inspection (including a structural rating)
x
Internal TV operator name
x
Cleanliness of the line
x
Location and identification of line being televised by manholes
x
Comments:
TVI-05 Is a rating system used to determine the severity of the defects
x
found during the inspection process?
Comments:
TVI-06 Is there a code list used for internal TV inspection reporting?
x
Approximately what percent of the total defects determined by TV inspection, during the TVI-07 past 5, years were attributed to the following?
Debris
Debris/Grease
Debris/Roots
Grease
Grease/Roots
Intruding Tap
Intruding Tap/Roots
Surcharged
Offset Joint/Grease
Roots
Roots/Debris
Roots/Grease
Roots/Grease/Debris
Roots/Line Failure
Line Failure
24
Sag In Line Sag In Line/Debris Sag In Line/Grease Other: Other: Total Percentage Comments:
TVI-08 Are main line and lateral repairs checked by internal TV
x
inspection after the repair(s) have been made?
Comments:
Sewer Cleaning (CLN
Checklist Item
CLN-01
Is there a program to identify sewer line segments, with chronic
problems, that should be cleaned on a more frequent schedule?
Comments:
Yes No NA x
CLN-02 CLN-03
What is the entire system cleaning frequency? (e.g., every "X" years) Comments:
What is the utility's plan for system cleaning (% or frequency in years)? Comments:
Weekly 100 annually
CLN-04 CLN-05 CLN-06
What percent of the total cleaning was considered repeat and trouble spot cleaning during the past year? Comments:
Does the utility have a root control program? Comments:
Does the utility have a fats, oils, and grease (FOG) program? Comments: p r e t r e a t m e n t d e p a r t m e n t
x x
CLN-07 CLN-08 CLN-09
25
What is the average number of stoppages experienced per 100 miles of sewer pipe per year? Comments:
Has the number of stoppages increased, decreased, or stayed the same over the past 5 years? Comments:
Are stoppages plotted on maps and correlated with other data such as pipe size and material or location? Comments:
Comments:
CLN-10
Checklist Item
Yes No NA
Do the sewer cleaning records include the following information?
Date and time
X
Cause of stoppage
X
Method of cleaning
Location of stoppage or routine cleaning activity
X
Identity of cleaning crew
Further actions necessary/initiated
Comments:
CLN-11 If sewer cleaning is done by a contractor, are videos taken X before and after cleaning? Comments:
Manhole Inspection and Assessment (MAN)
Checklist Item
MAN-01
Does the utility have a routine manhole inspection and assessment program? IF NO, GO TO MAN-06
Yes No N/A x
26 Comments:
MAN-02
Are the results and observations from the routine manhole inspection recorded?
Comments:
MAN-03 MAN-04
Does the utility have a goal for the number of manholes inspected annually?
Comments: How many manholes were inspected during the past year? What is the percent of total manholes were inspected during the Comments:
Comments:
Checklist Item
Yes No N/A
MAN-05 Do the records for manholes/pipe inspection include the following?
Conditions of the frame and cover
x
Evidence of surcharge
Offsets or misalignments
Atmospheric hazards measurements (especially hydrogen sulfide)
Details on the root cause of cracks or breaks in the manhole or pipe including blockages
Recording conditions of (corbel, walls, bench, trough, and pipe seals)
Presence of corrosion
x
If repair is necessary
x
Manhole identifying number/location
x
Wastewater flow characteristics (flowing freely or backed x
up)
Accumulation of grease, debris, or grit
x
Presence of infiltration, location, and estimated quantity
x
Inflow from manhole covers
x
27 Comments:
MAN-06 Does the utility have a grouting program?
x
Comments:
Comments:
Pump Stations (PS) Checklist Item
PS-01 Are Standard Operating Procedures (SOPs) and Standard Maintenance Procedures (SMPs) used for each pump station?
Comments:
Yes No N/A x
PS-02 Are there enough trained personnel to properly inspect and x maintain all pump stations? Comments:
PS-03
Is there an emergency operating procedure for each pump station?
Comments:
PS-04 Is there an alarm system to notify personnel of pump station x failures and overflow?
28 Comments:
PS-05 Percent of pump stations with backup power sources
10%
Comments:
PS-06
Does the utility use the following methods when loss of power occurs?
On-site electrical generators
x
Portable electric generators
Vacuum trucks to bypass pump station
x
Alternate power source
Other
Comments:
PS-07
Is there a procedure for manipulating pump operations during wet weather to increase in-line storage of wet weather flows?
Comments:
Comments:
Checklist Item PS-08 Are wet well operating levels set to limit pump start/stops?
Comments:
PS-09 Are the lead, lag, and backup pumps rotated regularly? Comments:
PS-10 Are operation logs maintained for all pump stations? Comments:
PS-11 Are the manuals that contain the manufacturers recommended maintenance schedules for all pump station equipment available? Comments:
PS-12 On average, how often were pump stations inspected during the past year?
Yes No N/A x
x
100%
29
Comments: PS-13 Are records maintained for each inspection?
Comments:
PS-14 Average annual labor hours spent on pump station inspections Comments:
PS-15 Percent of pump stations with pump capacity redundancy Comments:
PS-16 Percent of pump stations with dry weather capacity limitations Comments:
PS-17 Percent of pump stations with wet weather capacity limitations Comments:
PS- Percent of pump stations calibrated annually 18 Comments:
PS- Percent of pump stations with permanent flow meters 19 Comments:
Capacity Assessment (CA) Checklist Item
CA-01 Does the utility have a flow monitoring program? Comments:
CA-02
Does the utility have a comprehensive capacity assessment and planning program?
Comments:
CA-03
Are flows measured prior to allowing new connections? Comments:
CA-04
Do you have a tool (hydraulic model, spreadsheet, etc.) for assessing whether adequate capacity exists in the sewer system? IF NO, GO TO CA-06.
Yes No N/A
30 Comments:
CA-05
Does your capacity assessment tool produce results consistent with conditions observed in the system?
Comments:
CA-06
What is the ratio of peak wet weather flow to average dry weather flow at the wastewater treatment plant?
Comments:
CA-07
How many permanent flow meters are currently in the system? (Include meters at pump stations and WWTPs)
Comments:
CA-08 CA-09
How frequently are the flow meters checked? Comments: Do the flow meter checks include the following? Independent water level Checking the desiccant Velocity reading Cleaning away debris Downloading data Battery condition Comments:
Checklist Item
Yes No N/A
CA-10 Are records maintained for each inspection? IF NO, GO TO CA-12
Comments:
CA-11
Do the flow monitoring records include the following? Descriptive location of flow meter Type of flow meter Frequency of flow meter inspection Frequency of flow meter calibration Comments:
CA-12 Does the utility maintain any rain gauges?
x
Comments:
31
CA-13
Does the utility have any wet weather capacity problems? Comments:
CA-14
Are low points or flood-plain areas monitored during rain events? Comments:
CA-15
Does the utility have any dry weather capacity problems? Comments:
CA-16
Is flow monitoring used for billing purposes, capacity analysis, and/or inflow and infiltration investigations?
Comments:
Comments:
x x
Tracking SSOs (TRK)
TRK-01
Checklist Item How many SSO events have been reported in the past 5 years?
Comments:
Yes No N/A
TRK-02
What % of SSOs were less than 1,000 gallons in the past 5 years? Comments:
TRK-03
Does the utility document and report all SSOs regardless of size? x
32 Comments:
TRK-04
Does the utility document basement backups?
x
Comments:
TRK-05
Are there areas that experience frequent street flooding?
x
Comments:
TRK-06
What % of SSO discharges were from each of the following in the last 5 years?
Manholes
65
Lift/Vacuum Systems (Revised term)
10
Main and trunk sewers
10
Lateral and branch sewers
15
Total
100
Comments:
TRK-07
Checklist Item
Yes No N/A
What % of SSO discharges were caused by each of the following in the last 5 years?
Construction
Cause Unknown
Debris
Debris/Grease
30
Debris/Roots
Equipment Failure
5
Grease
40
Sag In Line
Intruding Tap
Line Failure
Manhole/Surcharged
10
Offset Joint
Roots
Roots/Debris
33
Roots/Grease Roots/Intruding Tap Roots/Line Failure Surcharged Other(s): Grand Total
Comments:
TRK-07A
Checklist Item What percentage of SSOs were released to: Storm Sewer Arroyo/Ditch/Drain Street/ Parking lot Private Property River/Stream/Lake/Bayou/Ocean Other: Grand Total Comments:
TRK-07B
For surface water releases, what percent are to areas that could affect: Contact recreation (beaches, swimming areas) Drinking water sources Shellfish growing areas Fishing or spawning areas Comments:
TRK-08
Checklist Item How many chronic SSO locations are in the collection system?
Comments:
Yes No N/A
TRK-09 TRK-10
Are pipes with chronic SSOs being monitored for sufficient capacity and/or structural condition? Comments:
Prior to collapse, are structurally deteriorating pipelines being monitored for renewal or replacement?
34 Comments:
Comments:
Overflow Emergency Response (OERP) Checklist Item
OERP-01 Does the utility have a documented OERP available for utility staff to use? IF NO, GO TO OERP-04
Comments:
OERP-02
How often is the OERP reviewed and updated? (Annually, Biannually, etc.)
Comments:
OERP-03 OERP-04
Are specific responsibilities detailed in the OERP for personnel who respond to emergencies? Comments: Are staff continuously trained to respond to emergencies?
Comments:
OERP-05
Do work crews have immediate access to tools and equipment during emergencies?
Comments:
Yes No N/A x
OERP-06
Checklist Item
Yes No N/A
Does the utility have procedures for notifying state agencies, local health
departments, the NPDES authority, the public, and drinking water
x
authorities of significant overflow events?
Comments:
OERP-07 Does the procedure include a current list of the names, titles, phone
x
numbers, and responsibilities of all personnel involved?
35 Comments:
OERP-08 Does the utility have a public notification plan?
x
Comments:
OERP-09 Does the utility have procedures to limit public contact with areas
x
affected by SSOs? (can be delegated to another authority)
Comments:
OERP-10 Does the utility use containment techniques to protect storm systems?
x
Comments:
OERP-11 OERP-12
Do the overflow records include the following information?
Date and time Cause(s) Names of affected receiving water(s) Location How it was stopped Any remediation efforts Estimated flow/volume discharged Duration of overflow Comments: Does the utility have signage to keep public from affected area? Comments:
Smoke & Dye Testing (SDT) Checklist Item
SDT-01
Does the utility have a smoke testing program to identify sources of inflow and infiltration?
Comments:
Yes No N/A x
36
SDT-01A
Does the utility have a smoke testing program to identify sources of inflow and infiltration in illegal connectors?
Comments:
SDT-01B
Does the utility have a smoke testing program to identify sources of inflow and infiltration in house laterals (private service laterals)? Comments:
SDT-02
Are there written procedures for smoke testing? Comments:
x x
N/A
SDT-03
Is there a documented procedure for isolating line segments? Comments:
SDT-04
Is there a documented procedure for notifying residents that smoke testing will be conducted in their area?
Comments:
Comments:
SDT-05
Checklist Item What is the guideline for maximum amount of line to be tested at one time? (Feet or Miles)
Comments:
SDT-06 Are there guidelines for the weather conditions under which smoke testing should be conducted?
Yes No N/A
37
Comments: SDT-07 What is the goal for the % of the system smoke tested each year?
Comments:
SDT-08
What % of the system has been smoke tested in the past 5 years? Comments:
SDT-09
Do the written records contain location, address, and description of the smoking element that produced a positive result?
Comments:
SDT-10
Does the utility have a dye testing program? Comments:
SDT-11
Are there written procedures for dye testing? Comments:
SDT-12
Does the utility have a goal for the percent of the system dye tested each year?
Comments:
SDT-13
What percent of the main collection system had been dye tested over the past year?
Comments:
SDT-14
Does the utility share smoke and dye testing equipment with another utility?
Comments:
Comments:
Hydrogen Sulfide Monitoring and Control (HSMC)
Checklist Item
Yes No N/A
HSMC-01 How would you rate the system vulnerability for hydrogen sulfide corrosion?
Not a problem
Only in a few isolated areas
A major problem
38 Comments:
HSMC-02 Does the utility have a corrosion control program?
x
Comments:
HSMC-03 Does the utility take hydrogen sulfide corrosion into consideration x when designing new or replacement sewers?
Comments:
HSMC-04 Does the utility have procedures for application of chemicals? Comments:
HSMC-05 Are the chemical dosages, dates, and locations documented? Comments:
HSMC-06 Does the utility document where odor is a problem in the system? Comments:
HSMC-07 Does the utility have a program in place for renewing or
x
replacing severely corroded sewer lines to prevent collapse?
Comments:
Comments:
HSMC-08
Checklist Item
Yes No N/A
Are the following methods used for hydrogen sulfide control?
Aeration
Iron Salts
Enzymes
Activated charcoal canisters
39
Chlorine Sodium hydroxide Hydrogen peroxide Potassium permanganate Biofiltration Other Comments:
HSMC-09
Does the system contain air relief valves at the high points of the force main system?
Comments:
HSMC-10
How often are the valves maintained and inspected? (Weekly, Monthly, etc.)
Comments:
HSMC-11
Does the utility enforce pretreatment requirements? Comments:
Comments:
Infrastructure Security Although outside the scope of a CMOM program, municipal wastewater utilities should also consider security vulnerabilities. To reduce the threat of both intentional and natural disasters, the utility should take steps to implement appropriate countermeasures and develop or update emergency response plans.
40 Please summarize any program the utility has for infrastructure security. Comments:
Appendix 2
Review of the ICIS E90 Effluent Violations
NM0020311
ROSWELL, NEW MEXICO
Monitoring Period End Date 01/31/2022 01/31/2022 01/31/2022 01/31/2022 12/31/2022 12/31/2022 12/31/2022 12/31/2022 01/31/2023 01/31/2023 03/31/2025 03/31/2025 03/31/2025
Parameter Desc Oxygen, dissolved [DO] Oxygen, dissolved [DO] Oxygen, dissolved [DO] Oxygen, dissolved [DO] Oxygen, dissolved [DO] Oxygen, dissolved [DO] Oxygen, dissolved [DO] Oxygen, dissolved [DO] Oxygen, dissolved [DO] Oxygen, dissolved [DO] Whole Effluent Toxicity [WET] - C. dubia Whole Effluent Toxicity [WET] - C. dubia Whole Effluent Toxicity [WET] - C. dubia
Statistical Base Short Desc DAILY MN MO AV MN DAILY MN MO AV MN DAILY MN MO AV MN DAILY MN MO AV MN DAILY MN DAILY MN MN VALUE MN VALUE MN VALUE
Limit Unit Short Desc mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L % % %
Limit Value 4.1 4.1 4.1 4.1 4.1 4.1 4.1 4.1 4.1 4.1 90. 90. 90.
DMR Value Qualifi er Code
DMR Value
<
1.99
<
2.41
<=
1.99
>=
2.41
<
2.06
=
2.23
<=
2.06
<=
2.23
<=
1.94
<=
1.94
=
68.
=
68.
=
68.
Appendix 3
Review of the ICIS E80 Effluent Violations
5/21/25, 9:28 AM
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Violation Violation
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Date
RNC Detection Code-Date
Record Numbers 1 to 23 RNC Resolution Action Code-Date
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S
01/04/2024
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Single Event Violation
R011S Wet-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R011S
02/11/2024
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Single Event Violation
R011S Wet-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R011S
10/19/2024
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Single Event Violation
R010S Wet-weather SSO discharge to waters of the U.S. that may endanger health or the environment
R010S
10/20/2024
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Single Event Violation
R015S Wet-weather SSO, no discharge to waters of the U.S., not permit compliant, no endangerment
R015S
10/27/2024
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Single Event A0013 Effluent Violations - Failed Toxicity Test
Violation
A0013
02/04/2025
Delete
Single Event A0013 Effluent Violations - Failed Toxicity Test
Violation
A0013
02/13/2025
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S
04/06/2025
Delete
Single Event A0013 Effluent Violations - Failed Toxicity Test
Violation
A0013
04/15/2025
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S
05/08/2025
Delete
Effluent
001 A 00300 Oxygen, dissolved [DO] Effluent
E90
Violation
Gross Season ID:0 C1
01/31/2022
Effluent
001 A 00300 Oxygen, dissolved [DO] Effluent
E90
Violation
Gross Season ID:0 C2
01/31/2022
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