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Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 01/20/2022 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 Taos Taos WWTP 182 Los Cordovas Drive Ranchos de Taos, New Mexico 87571 400 Camino de la Placita Taos, New Mexico 87571 Taos 757-751-2047 Francisco Espinoza Public Works Director fespinoza@taosgov.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110022681267 NM0024066 NA 221320 4952 Personnel participating in inspection: Gerald Salazar SMA-Operations (Contract Operator) Jerome Salazar SMA-Operations (Contract Operator) Jose Apodaca SMA-Operations (Contract Operator) Celsa Vigil David Esparza SMA-Operations (Contract Operator) EPA-R6/ECDWM Wastewater Operator III Wastewater Operator III Wastewater Operator III, Water Operator II and Laboratory Tech. I Laboratory Technician Environmental Engineer EPA Lead Inspector Signature/Date 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: 2022.03.07 09:19:36 -07'00' Date Supervisor Signature/Date ROBERTO 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: 2022.03.07 10:30:40 -06'00' Roberto Bernier Date 6ENFORM-020-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Town of Taos/Taos WWTP Permit No. NM0024066 Inspection Date 01/20/2022 PURPOSE OF THE INSPECTION United States Environmental Protection Agency (EPA) Region 6 inspector David Esparza, PE, arrived at the Town of Taos (Taos) Wastewater Treatment and Reclamation Facility (WWTP) approximately 12:00 AM on January 20, 2022, for an unannounced inspection. I presented my credentials to Mr. Gerald Salazar, on-site Contract Supervisor 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 Taos' representatives, observations made by the EPA inspector, NMED, and records and reports maintained by the permittee (Taos), and the EPA. Before leaving the facility on January 20, 2022, an exit briefing was held with Mr. Salazar, to explain areas of concern noted at the time of the inspection. It should be noted the WWTP also maintains a discharge permit (DP-232) issued by the New Mexico Environment Department (NMED), Groundwater Quality Bureau (GWQB) that allows a permitted discharge up to 2MGD. FACILITY DESCRIPTION The Town of Taos (Taos) WWTP facility is classified as a major discharger with a design capacity of 2.0 MGD and an average daily flow of 1.2 MGD, serving a population of approximately 11,000 that includes the Town of Taos, Taos Pueblo, El Prado, and communities within the Valle de Los Ranchos area as well as individual residences in the proximate area. The facility is located at 182 Los Cordovas Drive, Rancho de Taos, Taos County, New Mexico (denoted in Aerial Image #1 and further detailed in Aerial Image #2 below). The WWTP has been operated and managed under a contract agreement with SMA Operations, LLC. since 1991. WWTP hours of operation are Monday through Friday 8 AM to 5 PM. The WWTP treatment process is comprised of a gravity collection system, and one (1) lift station (identified in Table #1). The influent then traverses through a splitter box that sends the flow to either the East or West aeration basins. These two (2) basins from the old WWTP have been configured such that half of each has a series of fine bubble diffusers to create an aerated zone, and the other half has mixers only that constitute the anoxic zone. Thence the partially treated wastewater enters the MBR system, consisting of four (4) parallel basins with filters, aerators, and mixers operating simultaneously. Return Activated Sludge (RAS) is returned to the splitter box past the grit removal basin, where the Waste Activated Sludge (WAS) is pulled from the return line. After the sludge is dewatered from the belt press, the solids are deposited into roll-off bins for transport and landfill disposal. The processed water or Permeate Water is continuously sent through two (2) banks of Ultraviolet Disinfection (UV) system lights prior to discharge into an unnamed arroyo that flows for approximately - mile thence into the Rio Pueblo de Taos a tributary to the Rio Grande. Approximately 500k-gallons of disinfected effluent water, is sold to the Taos Country Club for maintenance of their golf course greens. 2 Town of Taos/Taos WWTP Permit No. NM0024066 Inspection Date 01/20/2022 Septage and domestic (typically greywater) wastewater is received at the head works. According to WWTP records an average of approximately 140K-gallons of septage is received on a weekly basis (2021 Taos records). The facility staff monitors incoming registered septage haulers for pH and grease to determine compatibility with the WWTP for acceptance or rejection. This policy was adopted under Town of Taos Resolution 14-62 on November 25, 2014. Aerial Image #1: Overall view of the Town of Taos' Wastewater Treatment and Reclamation Facility. Aerial from Google Earth maps. 3 Town of Taos/Taos WWTP Permit No. NM0024066 Inspection Date 01/20/2022 Aerial Image #2: Detailed overall view of the Town of Taos' Wastewater Treatment and Reclamation Facility. Aerial from Google Earth maps and provided by SMA Operations, LLC. Table 1: Town of Taos Lift Stations Lift Station Address 1 Town Hall 400 Camino de la Placita Taos Taos does have 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 a current Fats, Oils and Grease (FOG) program policy with respect to existing and/or new FOG contributors. Additionally, their current Asset Management Schedule (Utility Improvement Fund) for 2021-2022 has been drafted and is awaiting legal approval for advertising. Currently, there is no Industrial Users (IU) contributing to the WWTP. Section II - OBSERVATIONS I observed the following and/or the following information was provided or stated on January 20, 2022. 4 Town of Taos/Taos WWTP Permit No. NM0024066 Inspection Date 01/20/2022 The WWTP and all ancillary services are contract operated/managed by SMA Operations, LLC. and have been since 1991. The WWTP maintains a backup diesel generator for power that is exercised weekly. A Supervisory Control and Data Acquisition (SCADA) system provides around the clock monitoring of WWTP operations and is manned during normal working hours with alarm notifications in the off hours. No visible sheen, stressed vegetation or aromatics were observed at the WWTP outfall. The WWTP had secure perimeter fencing; thus, limiting access. The overall WWTP's operations and maintenance (O&M), and general facility housekeeping appeared to be in good order. Section III - AREAS OF CONCERN A review of the Integrated Compliance Information System (ICIS) database for the period from January 1, 2019, to January 20, 2022, indicates the following: 1. NPDES permit excursion- DMR non-receipt (Lethal Survival Static Renewal 7 Day Chronic Ceriodaphnia dubia)- March 2019 2. NPDES permit excursion- DMR non-receipt (Lethal Survival Static Renewal 7 Day Chronic Pimephales promelas)- March 2019 3. NPDES permit excursion- DMR non-receipt (Sub-Lethal Reproduction Static Renewal 7 Day Chronic Ceriodaphnia dubia)- March 2019 4. NPDES permit excursion- DMR non-receipt (Sub-Lethal Reproduction Static Renewal 7 Day Chronic Pimephales promelas)- March 2019 5. NPDES permit excursion- Nitrogen Ammonia Total [as N]- December 2020, January 2021, and February 2021 6. NPDES permit excursion- Mercury, total [as Hg] - August March 2021, and September 2021 EPA Region 6 inspector David Esparza conducted a closing conference at the Town of Taos' WWTP approximately at 3:00 PM on January 20, 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 20, 2022: Town of Taos - FOG policy - section taken from the Town Code title 13 Section 13.12.100 5 Town of Taos/Taos WWTP Permit No. NM0024066 Inspection Date 01/20/2022 The location of Taos' one (1) lift station- at Town Hall 400 Camino de la Placita Taos- serviced quarterly A form that the operators use in the event of a sanitary sewer overflow (SSO) protocol or Best Management Practices (BMP). A current/updated Site Map/Plan. A summary of the approximate quantity of septage volumes for calendar year 2021. SCADA - A snapshot of SCADA system. Section V - LIST OF APPENDICES Appendix 1 - A Review of the Integrated Compliance Information System (ICIS) Database for the period from January 1, 2019, to January 20, 2022 6 Town of Taos/Taos WWTP Permit No. NM0024066 Inspection Date 01/20/2022 Appendix 1 A Review of the Integrated Compliance Information System (ICIS) Database for the period from January 1, 2019, to January 20, 2022 3/2/22, 11:14 AM FE&C NPDES AIR ICIS: Search Violation Results Admin Reports Help DESPARZA Logout Search Permits Related NPDES Violations ADD SINGLE EVENT VIOLATION List of Violations Related to the Permit Violation Type DMR NonReceipt Violation DMR NonReceipt Violation DMR NonReceipt Violation DMR NonReceipt Violation Effluent Violation Effluent Violation Effluent Violation Effluent Violation Effluent Violation Effluent Violation Effluent Violation Effluent Violation Violation Information TX1 Q TXP3B LOEC Lethal Survival Static Renewal 7 Day Chronic Ceriodaphnia dubia Effluent Gross Season ID:0 C3 Violation Violation Code Date Record Numbers 1 to 15 RNC RNC Detection Resolution Action Code-Date Code-Date K- 2- D80 03/31/2019 05/16/2019 05/22/2019 TX1 Q TXP6C LOEC Lethal Survival Static Renewal 7 Day D80 Chronic Pimephales promelas Effluent Gross Season ID:0 C3 K- 2- 03/31/2019 05/16/2019 05/22/2019 TX1 Q TYP3B LOEC Sub-Lethal Reproduction Static Renewal 7 D80 Day Chronic Ceriodaphnia dubia Effluent Gross Season ID:0 C3 TX1 Q TYP6C LOEC Sub-Lethal Reproduction Static Renewal 7 Day Chronic Pimephales promelas Effluent Gross Season ID:0 D80 C3 001 A 00610 Nitrogen, ammonia total [as N] Effluent Gross E90 Season ID:0 Q1 001 A 00610 Nitrogen, ammonia total [as N] Effluent Gross E90 Season ID:0 Q2 001 A 00610 Nitrogen, ammonia total [as N] Effluent Gross E90 Season ID:0 C2 001 A 00610 Nitrogen, ammonia total [as N] Effluent Gross E90 Season ID:0 C3 001 A 00610 Nitrogen, ammonia total [as N] Effluent Gross E90 Season ID:0 C2 001 A 00610 Nitrogen, ammonia total [as N] Effluent Gross E90 Season ID:0 C3 001 A 00610 Nitrogen, ammonia total [as N] Effluent Gross E90 Season ID:0 C3 001 A 71900 Mercury, total [as Hg] Effluent Gross Season ID:0 E90 C2 K- 2- 03/31/2019 05/16/2019 05/22/2019 K- 2- 03/31/2019 05/16/2019 05/22/2019 12/31/2020 R- 2- 12/31/2020 01/31/2021 05/31/2021 12/31/2020 R- 2- 12/31/2020 01/31/2021 05/31/2021 01/31/2021 R- 2- 01/31/2021 01/31/2021 05/31/2021 02/28/2021 08/31/2021 https://icis.epa.gov/icis/permit/SearchViolation.do?fromSearchCriteriaPage=true&compositeKey=3601439535@NPD&navActivityId=3601439535&nav... 1/2 3/2/22, 11:14 AM ICIS: Search Violation Results Violation Type Violation Information Violation Violation Code Date RNC RNC Detection Resolution Action Code-Date Code-Date Effluent Violation 001 A 71900 Mercury, total [as Hg] Effluent Gross Season ID:0 E90 Q2 09/30/2021 Effluent Violation 001 A 71900 Mercury, total [as Hg] Effluent Gross Season ID:0 E90 C2 09/30/2021 Effluent Violation 001 A 71900 Mercury, total [as Hg] Effluent Gross Season ID:0 E90 C3 09/30/2021 Record Numbers 1 to 15 ICIS Home Reports Help Logout Technical issues? Contact user support Help Desk at (202) 564-7756 or via email at ICIS@epa.gov https://icis.epa.gov/icis/permit/SearchViolation.do?fromSearchCriteriaPage=true&compositeKey=3601439535@NPD&navActivityId=3601439535&nav... 2/2