Document O1jM2XwqBNDE6G8BgY1V6rLJK
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
01/19/2024 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:
Celsa Vigil
SMA-Operations (Contract Operator)
Celina Apodaca
SMA-Operations (Contract Operator)
Nafis Fuad
NMED-PSRS
James Andel
NMED-SWQB
Issac Martinez
NMED-SWQB
David Esparza
EPA-R6/ECDWM
Laboratory Technician Laboratory Technician Compliance/Enforcement Team Lead Industrial/Municipal Inspector Municipal/Industrial Specialist Environmental Engineer
EPA Lead Inspector Signature/Date
DAVID ESPARZA Date: 2024.03.06 10:01:12 -07'00' Digitally signed by DAVID ESPARZA
David Esparza
Date
Supervisor Signature/Date
ROBERTO BERNIER Date: 2024.03.12 14:07:07 -05'00' Digitally signed by ROBERTO BERNIER
Roberto Bernier
Date
6ENFORM-020-R8.2 (02/12/2020)
1
Section I - INTRODUCTION
Town of Taos/Taos WWTP Permit No. NM0024066
Inspection Date 01/19/2024
PURPOSE OF THE INSPECTION
United States Environmental Protection Agency (EPA) Region 6 inspector David Esparza, PE, accompanied by Mr. Nafis Fuad, Mr. James Andel, and Mr. Issac Martinez from the New Mexico Environment Department (NMED), arrived at the Town of Taos (Taos) Wastewater Treatment and Reclamation Facility (WWTP) approximately 12:00 PM on January 19, 2024, for an unannounced inspection. I presented my credentials to Ms. Celsa Vigil and Ms. Celina Apodaca, on-site SMA-Operations (Contract Operator) and informed them 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 19, 2024, an exit briefing was held with Ms. Vigil and Ms. Apodaca, 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. 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 membrane bioreactor (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 rolloff 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 greens.
2
Town of Taos/Taos WWTP Permit No. NM0024066
Inspection Date 01/19/2024 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 01/19/2024
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.
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 19, 2024.
The WWTP and all ancillary services are contract operated/managed by SMA Operations, LLC. and have been since 1991.
4
Town of Taos/Taos WWTP Permit No. NM0024066
Inspection Date 01/19/2024
It was stated the Town's Public Works Department maintains the collection system aspect of the Town while the WWTP is contactor operated by SMA Operations, LLC.
It was also stated the WWTP receives waste stream contributions from Taos Pueblo, El Prado, and communities within the Valle de Los Ranchos area as well as individual residences in the proximate area.
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.
It was previously stated their current Asset Management Schedule (Utility Improvement Fund) had been drafted and was awaiting legal approval for advertising. The status of this document is not known.
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 submitted Integrated Compliance Information System (ICIS) Discharge Monitoring Reports (DMR) data for the period January 20, 2022, through October 31, 2023, indicates NPDES permit excursions with respect to Nitrogen (ammonia total), Total Suspended Solids (TSS), 5-day Biological Oxygen Demand (BOD5), Escherichia coli (E. coli), Total Chlorine Residual (TCR), Total Mercury (as Hg), fecal Coliform (general), and pH (Appendix 2 ICIS E90 Effluent Violations).
EPA Region 6 inspector David Esparza conducted a closing conference at the Town of Taos' WWTP approximately at 4:30 PM on January 19, 2024, for the inspection.
Section IV - FOLLOW UP
Additional information or clarification was requested on January 23, 2024, and February 13, 2024, via electronic mail (email) and by telephone. No additional information was received (copies of email Request for Information (RFI) attached.
Section V - LIST OF APPENDICES
Appendix 1 - Photo Log 4 photographs taken 1/19/2024. Appendix 2 - Integrated Compliance Information System (ICIS) Database E90 Exceedances Appendix 3 - Request for Information (RFI)
5
Town of Taos/Taos WWTP Permit No. NM0024066
Inspection Date 01/19/2024
Appendix 1
Photograph Log
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: Taos Wastewater Treatment Plant
City: Town of Taos
County/Parish: Taos
State: New Mexico
View of "spaghetti" type membranes awaiting cleaning. These membranes physically separate water from the microorganisms and suspended solids. (IMG_0223). Photographed by D. Esparza
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: Taos Wastewater Treatment Plant
City: Town of Taos
County/Parish: Taos
State: New Mexico
View of the sodium hypochlorite injection system and peristaltic pumps. Sodium hypochlorite is utilized as an efficient oxidizing agent, proven to eliminate bacteria, viruses, and harmful pathogens. (IMG_0225). Photographed by D. Esparza
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: Taos Wastewater Treatment Plant
City: Town of Taos
County/Parish: Taos
State: New Mexico
View of the citric acid injection system and peristaltic pumps. Citric acid is utilized as a cleaning solution for membrane filters. Additionally, citric acid acts as a chelating agent, binding metals. (IMG_0227). Photographed by D. Esparza
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 4
Location: Taos Wastewater Treatment Plant
City: Town of Taos
County/Parish: Taos
State: New Mexico
Note the corrosivity of the sodium hypochlorite and citric acid on piping and metals supports. (IMG_0224). Photographed by D. Esparza
Appendix 2
Town of Taos/Taos WWTP Permit No. NM0024066
Inspection Date 01/19/2024
Integrated Compliance Information System (ICIS) Database E90 Exceedances
E90 Effluent Violations From 01/01/2019 - Present
NM0024066
TAOS, TOWN OF
Monitoring Period End Date 12/31/2022 12/31/2022 12/31/2022 12/31/2022 01/31/2023 01/31/2023 01/31/2023 01/31/2023 01/31/2023 01/31/2023 01/31/2023 01/31/2023 01/31/2023 01/31/2023 01/31/2023 01/31/2023 02/28/2023 02/28/2023 02/28/2023 04/30/2023 04/30/2023 04/30/2023 04/30/2023 04/30/2023 05/31/2023 05/31/2023
Perm Feature ID 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001
Limit Set Designator A A A A A A A A A A A A A A A A A A A A A A A A A A
Parameter Desc
Statistical Base Short Desc
BOD, 5-day, 20 deg. C 7 DA AVG
E. coli
30DAVGEO
E. coli
DAILY MX
Solids, suspended percent MO AV MN
BOD, 5-day, 20 deg. C 30DA AVG
BOD, 5-day, 20 deg. C 7 DA AVG
BOD, 5-day, 20 deg. C 7 DA AVG
BOD, 5-day, percent remo MO AV MN
Chlorine, total residual INST MAX
Coliform, fecal general 30DAVGEO
E. coli
30DAVGEO
E. coli
DAILY MX
Mercury, total [as Hg]
30DA AVG
Solids, suspended percent MO AV MN
Solids, total suspended 30DA AVG
Solids, total suspended 7 DA AVG
Chlorine, total residual INST MAX
E. coli
30DAVGEO
E. coli
DAILY MX
E. coli
DAILY MX
Nitrogen, ammonia total [a 30DA AVG
Nitrogen, ammonia total [a 30DA AVG
Nitrogen, ammonia total [a DAILY MX
Nitrogen, ammonia total [a DAILY MX
Nitrogen, ammonia total [a 30DA AVG
Nitrogen, ammonia total [a 30DA AVG
Limit Unit Short Desc
Limit Value
mg/L 21
CFU/100126
CFU/100235
%
85
mg/L 17
lb/d 350.49
mg/L 21
%
85
ug/L 11
CFU/100200
CFU/100126
CFU/100235
ug/L .027
%
85
mg/L 30
mg/L 45
ug/L 11
CFU/100126
CFU/100235
CFU/100235
lb/d 63
mg/L 3.75
lb/d 94
mg/L 5.62
lb/d 63
mg/L 3.75
DMR Value Qualif ier Code = = = = = = = = = = = = = = = = = = = = = = = = = =
DMR Value 22 141 276 71 27 373 48 64 12 244 263 440 .035 41 55 77 12 153 320 274 154 20 166 20 96 10
Monitoring Period End Date 05/31/2023 05/31/2023 09/30/2023 10/31/2023 10/31/2023 10/31/2023
Perm Feature ID 001 001 001 001 001 001
Limit Set Designator A A A A A A
Parameter Desc
Statistical Base Short Desc
Nitrogen, ammonia total [a DAILY MX
Nitrogen, ammonia total [a DAILY MX
E. coli
DAILY MX
BOD, 5-day, 20 deg. C 7 DA AVG
Solids, suspended percent MO AV MN
Solids, total suspended 7 DA AVG
Limit Unit Short Desc
Limit Value
lb/d 94
mg/L 5.62
CFU/100235
mg/L 21
%
85
mg/L 45
DMR Value Qualif ier Code
=
=
=
=
=
=
DMR Value 105 10 370 30 82 52
Town of Taos/Taos WWTP Permit No. NM0024066
Inspection Date 01/19/2024
Appendix 3
Request for Information (RFI)
Esparza, David
From: Sent: To: Cc: Subject:
Tracking:
Esparza, David Tuesday, January 23, 2024 12:27 PM fespinoza@taosgov.com Matthews, Rachel; Esparza, David Town of Taos WWTP (NM0024066)
Recipient fespinoza@taosgov.com Matthews, Rachel Esparza, David
Delivery
Delivered: 1/23/2024 12:27 PM Delivered: 1/23/2024 12:27 PM
Read
Read: 1/23/2024 2:03 PM Read: 1/23/2024 12:40 PM
Mr. Espinoza:
It is my understanding the Town's Public Works Department maintains the collection system aspect of the Taos NPDES permit, while the WWTP is contactor operated by SMA Operations, LLC. The following information is requested to make a complete and accurate assessment of the applicable parameters associated with the permit. Additional information might be requested after my review of the received information. The specific request for information (RFI) will be delineated below. Therefore, please forward by email the requested information as soon as possible, but no later than close of business January 30, 2024.
A complete electronic copy of your Sanitary Sewer Overflow (SSO) protocol, inclusive of all SSO events and associated work orders/work sheets for the previous two (2) years.
A complete electronic copy of your Standard Operating Procedures (SOPs) and clarification how often it is updated.
A current copy of your Asset Management plan. A current copy of your Fats, Oils and Grease (FOG) policy. Electronic copies of applicable service agreements with respect to satellite communities or other entities
contributing to the WWTP. Current copy of your septage policy. Identification of the quantity, location, and names of any lift stations (LS), wet wells etc.
David A. Esparza, P.E. Environmental Engineer U.S. Environmental Protection Agency Water Enforcement Branch-Municipal/Industrial Section Mail Code: 6-ECDWM 1201 Elm Street, Suite 500 Dallas, Texas 75270 (505) 366-8402 eMail: esparza.david@epa.gov
1
Esparza, David
From: Sent: To: Cc: Subject:
Tracking:
Esparza, David Tuesday, February 13, 2024 11:57 AM fespinoza@taosgov.com Esparza, David; Matthews, Rachel; Bernier, Roberto Town of Taos WWTP (NM0024066)
Recipient fespinoza@taosgov.com Esparza, David Matthews, Rachel Bernier, Roberto
Delivery
Delivered: 2/13/2024 11:57 AM Delivered: 2/13/2024 11:57 AM Delivered: 2/13/2024 11:57 AM
Read
Read: 2/13/2024 11:57 AM Read: 2/13/2024 12:03 PM
Mr. Espinoza:
This is a follow-up to my voicemail message (VM) from this morning (February 13, 2024). I had previously requested clarification regarding my understanding the Town's Public Works Department maintains the collection system aspect of the Taos NPDES permit, while the WWTP is contactor operated by SMA Operations, LLC. This information was requested to make a complete and accurate assessment of the applicable parameters associated with the permit. I had also stated additional information might be requested after my review of the received information. Receipt of the information was originally requested no later than the close of business January 30. 2024. As of this date I have not received any response. A further review of the Town's file indicates I had previously received some of the requested information. Therefore, please forward by email the requested information delineated below as soon as possible, but no later than close of business February 20, 2024.
A complete electronic copy of your Standard Operating Procedures (SOPs) and clarification how often it is updated.
A current copy of your Asset Management plan. It was previously stated the Asset Management Schedule (Utility Improvement Fund) had been drafted and was awaiting approval.
Electronic copies of applicable service agreements with respect to satellite communities or other entities, inclusive of their respective points of contact (POC) contributing to the WWTP.
David A. Esparza, P.E. Environmental Engineer U.S. Environmental Protection Agency Water Enforcement Branch-Municipal/Industrial Section Mail Code: 6-ECDWM 1201 Elm Street, Suite 500 Dallas, Texas 75270 (505) 366-8402 eMail: esparza.david@epa.gov
1