Document NeedGEravBQKr23yYxmR6J18

EPA Inspection Report - Page 1 of 8 Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 9/13/2018 Water CWA - NPDES Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Mora Independent School District Mora High School - Athletic Field Project Highway 518 and Ranger Drive Mora, NM 87732 P.O. Box 179 Mora, NM 87732 Mora County Ella Arellano Superintendent earellano@mora.k12.nm.us FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110064609927 NM0031097 8211 Personnel participating in inspection: Amy Andrews, P.E. USEPA/6EN-WMH Eugene Abeyta Mora Independent School District Beverly Montoya Mora Independent School District Environmental Engineer Facilities Maintenance and Transportation Supervisor Special Projects Coordinator 214-907-0638 575-387-3108 575-387-3146 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: 2018.10.11 09:44:08 -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: 2018.10.11 12:25:48 -05'00' Date Date 6ENFORM-019-R7 (2/15/2017) 1 EPA Inspection Report - Page 2 of 8 Section I - INTRODUCTION Mora Independent School District - Athletic Field Project Inspection Date 9/13/2018 PURPOSE OF THE INSPECTION Environmental Protection Agency (EPA) Region 6 inspector Amy Andrews arrived at the Mora Independent School District / Mora High School Athletic Field Project at 9:00 AM on September 13, 2018 for an unannounced inspection. I met with Mr. Eugene Abeyta, the Facilities Maintenance and Transportation Coordinator, and Ms. Beverly Montoya. I presented my credentials to Mr. Abeyta and Ms. Montoya and informed them 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 Mora Independent School District representatives (the permittee), observations made by the EPA inspector, and records and reports maintained by the permittee and the EPA. FACILITY DESCRIPTION The Mora Independent School District Athletic Field Project is classified as a minor industrial discharger with an intermittent design flow (the system is only used when the ground water table is high) which would discharge to the Mora River in the Canadian Basin in Segment 20.6.4.309 according to the State of New Mexico Standards for Interstate and Intrastate Surface Waters, 20.6.4 NMAC. This segment includes the designated uses of domestic water supply, irrigation, high quality coldwater aquatic life, livestock watering, wildlife habitat, primary contact, and public water supply. Section II - OBSERVATIONS The Mora High School athletic field is located in an area where the ground water table is typically high during the spring runoff season. Historically, this would cause issues with standing water in the field. In 2012, the Athletic Field Project was implemented to resolve the standing water issue. Three groundwater extraction wells were installed around the athletic field to remove water from the subsurface when the groundwater reached a depth of 21 feet below ground level. Each of the wells contains an inline flow meter. After the water is pumped out of the wells it goes to one of two unlined reservoirs (with an unknown capacity) prior to being discharged to the river. Section III - AREAS OF CONCERN Requirement 1 NPDES Permit NM0031097, Part I: A.1. Final Effluent Limits - Intermittent Flow: Flow is to be reported in million gallons per day (MGD) with a measurement frequency of daily. NPDES Permit NM0031097, Part III: C.6. Flow Measurements: Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The devices shall be 2 EPA Inspection Report - Page 3 of 8 Mora Independent School District - Athletic Field Project Inspection Date 9/13/2018 installed, calibrated, and maintained to insure that the accuracy of the measurements is consistent with the accepted capability of that type of device. Devices selected shall be capable of measuring flows with a maximum deviation of less than 10% from true discharge rates throughout the range of expected discharge volumes. Concern 1 There is no flow meter on the discharge amount that flows through Outfall 001. Although each individual flow meter on each of the groundwater extraction wells qualifies as an appropriate flow measurement device in accordance with the above requirement, the summation of the flows recorded by the three well flow meters is not equal to the amount of water that is actually discharged to the Mora River, due to the presence of the reservoirs located between the wells and the discharge. Total flow amounts are recorded once a month from the groundwater wells. The original NPDES permit was issued September 2012, and the permittee has not reported on their DMRs that they have ever had a discharge (there are, however, a significant number of DMRs that were not received). Flow pumped out of the groundwater wells between 7/5/2017 and 8/4/2017 was recorded at 49,000 gallons total, however the permittee reported "NODI-4" on their DMRs, which stands for "no discharge, Discharge to Lagoon/Groundwater." Permittee verbally stated that the water was pumped out of the wells and into the reservoirs, but a once per day visual check confirmed that no water was discharged to the river out of Outfall 001. Flow pumped out of the groundwater wells between 8/4/2017 and 9/6/2017 was recorded at 19,000 gallons, and "NODI-C" was reported on the DMRs, which would mean that there was no discharge at all. Requirement 2 NPDES Permit NM0031097, Part I: C. Monitoring and reporting (Minor Dischargers): All DMRs shall be electronically reported ... 1. Reporting periods shall end on the last day of the months March, June, September, and December. 2. The permittee is required to submit regular quarterly reports no later than the 28th day of the month following each reporting period. NPDES Permit NM0031097, Part III: A.2. Duty to Comply: The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of the Act and its grounds for enforcement action; for permit termination; revocation and reissuance, or modification; or for denial of a permittee renewal application. Concern 2 DMRs were not received for the periods between September 2012 and December 2013 or October 2014 and October 2016. Even though the reporting period is over, the permittee needs to go back and report overdue data. Requirement 3 NPDES Permit NM0031097, Part I: A.1. Final Effluent Limitations: During the period beginning the effective date of the permit and lasting through the expiration date of the permit (unless otherwise noted), the permittee is authorized to discharge groundwater to the Mora River, in Segment Number 3 EPA Inspection Report - Page 4 of 8 Mora Independent School District - Athletic Field Project Inspection Date 9/13/2018 20.6.4.309, from Outfall 001. Such discharges shall be limited and monitored by the permittee as specified below: Concern 3 The permittee has Limitations and Monitoring Requirements in the permit. The permittee is not prepared to take samples or have analyses done. There is no alarm on either the discharge point or the well pumps to warn the permittee that a discharge will or has occurred, and the only way to know if discharge to the river has occurred is for someone to by physically standing by the outfall when it happens. If a discharge does occur, the permittee is responsible for monitoring the discharge. It is necessary for the permittee to find a laboratory, contract the laboratory, and prepare for any discharge that may occur. This is a repeat finding from previous inspection reports dated 7/2/2013, 3/6/2014, and 4/27/2016 conducted by the New Mexico State Environment Department (NMED), on the behalf of the EPA. Section IV - FOLLOW UP No information was received by EPA after exiting the Facility on 9/13/2018. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 3 photos taken 9/13/2018. 4 EPA Inspection Report - Page 5 of 8 Mora Independent School District - Athletic Field Project Inspection Date 9/13/2018 Appendix 1 Photograph Log EPA Inspection Report - Page 6 of 8 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Mora Independent School District - Athletic Field Project City: Mora County/Parish: Mora County State: New Mexico Photo File Name: DSCN0665.JPG Date of Photo: 9/13/2018 Time of Photo: 9:39 AM Photographer: Amy Andrews Description: Groundwater extraction well, with pump and flow meter, located at the Athletic Field. EPA Inspection Report - Page 7 of 8 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Mora Independent School District - Athletic Field Project City: Mora County/Parish: Mora County State: New Mexico Photo File Name: DSCN0668.JPG Date of Photo: 9/13/2018 Time of Photo: 9:41 AM Photographer: Amy Andrews Description: Unlined reservoir where the groundwater is stored prior to being discharged to the river through Outfall 001. EPA Inspection Report - Page 8 of 8 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Mora Independent School District - Athletic Field Project City: Mora County/Parish: Mora County State: New Mexico Photo File Name: DSCN0669.JPG Date of Photo: 9/13/2018 Time of Photo: 9:47 AM Photographer: Amy Andrews Description: Outfall 001, which discharges to the Mora River.