Document XOLaR5d5ay6z5kJEX7X9Zqmzx

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 01/17/2024 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: City of Belen Belen Wastewater Treatment Plant 1300 Conservancy Rd Belen, NM 87002 100 South Main St Belen, NM 87002 Valencia County 505-966-2580 Robert Noblin, Jr. Robert Noblin, Jr. robert.noblin@belen-nm.gov FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110001934462 NM0020150 Water 221320, 541380 4952, 8734 Personnel participating in inspection: Name Affiliation/mailcode Amy Andrews, P.E. EPA/6ECD-WM Magda Vargas EPA/6ECD-WR Mariela Reyna EPA/6EN-WR Nafis Fuad NMED/SWQB James Andel NMED/SWQB Jeffrey Gatewood City of Belen Benjamin Morales City of Belen John Ivey City of Belen Title Engineer/Lead Inspector Inspector Inspector Inspector/Supervisor Inspector Wastewater Plant Superintendent Wastewater Plant Chief Operator Wastewater Laboratory Technician EPA Lead Inspector Signature/Date Amy Andrews Date Supervisor Signature/Date Roberto Bernier Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION City of Belen Wastewater Treatment Plant Inspection Date 1/17/2024 PURPOSE OF THE INSPECTION Environmental Protection Agency (EPA) Region 6 inspector Amy Andrews and New Mexico Environment Department (NMED) inspectors Nafis Fuad and James Andel arrived at the City of Belen Wastewater Treatment Plant (WWTP) at 8:05 AM on January 17, 2024, for an unannounced inspection. We met with Jeffrey Gatewood, Benjamin Morales, and John Ivey with the City of Belen. I explained to the facility we would be conducting a virtual inspection of their laboratory as part of the on-site inspection of the facility. EPA Region 6 inspectors Magda Vargas and Mariela Reyna were in attendance remotely via Microsoft Teams video call. I presented my credentials to Mr. Gatewood and informed him 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), with an emphasis on the laboratory. The inspection was conducted under the authority of the NPDES permit program, in accordance with the Federal CWA. The scope of the inspection is to evaluate the compliance of the facility's laboratory and sampling requirements as well as the WWTP general operation requirements as prescribed in the CWA and the NPDES Permit. This report is based on information supplied by City of Belen representatives (the permittee), observations made by the EPA inspectors, and records and reports maintained by the permittee and the EPA. FACILITY DESCRIPTION The City of Belen WWTP is classified as a major municipal discharger under the CWA, Section 402, of the NPDES permit program and is authorized to discharge up to 1.2 million gallons per day (MGD) based on design flow, with an actual average discharge maintained around 0.4 MGD. The population served is approximately 7,400 residents according to 2020 United States Census. Discharge is to receiving waters named Bosque Drain and thence to the Rio Grande in waterbody segment number 20.6.4.105 (NMAC, State of New Mexico Standards for Interstate and Intrastate Surface Waters) of the Rio Grande Basin. This segment includes the designated uses of irrigation, marginal warmwater aquatic life, livestock watering, public water supply, wildlife habitat and primary contact. LABORATORY DESCRIPTION The facility's laboratory is not accredited under national or private programs. There are eight (8) full time wastewater treatment operators, one (1) of which performs the majority of the laboratory analysis with occasional assistance from four (4) others. At the time of the inspection, the facility had three (3) certified operators licensed by the New Mexico Water Quality Control Commission (NMWQCC). The main laboratory technician holds a Wastewater Level 1 (WW1). Of the four (4) support technicians, two (2) do not hold certifications and two (2) hold Wastewater Level 4 (WW4), Wastewater Level 3 (WW3), and Wastewater Lab 2 (WWL2) certifications collectively. The laboratory performs sample analyses of the following parameters for compliance with their respective NPDES permit: Total Residual Chlorine (TRC), Total Suspended Solids (TSS), E. coli, pH, and 5-Day Biochemical Oxygen Demand (5-Day BOD). 2 City of Belen Wastewater Treatment Plant Inspection Date 1/17/2024 Analyses for nitrate and dichlorobromomethane as well as pollutant screening analyses are sent to Eurofins Environmental Testing South Central, LLC (previously Hall Environmental Laboratory), in Albuquerque, NM. Whole effluent testing is sent to Bio-Aquatic Testing, Inc. in Carrollton, TX. PLANT OPERATIONS DESCRIPTION The Belen WWTP is an activated sludge facility. The main plant lift station consists of a wet well and four submersible pumps, each rated for 880 gallons per minute. Entrance works include a bar screen and Parshall Flume. All flow from the entrance works goes to the grit tank, where high specific gravity solids are dropped out of the raw wastewater influent in the grit chamber. Slurry from the grit chamber is taken to the grit classifier and de-watered. The grit solids are disposed of in a landfill. The wastewater flow from the grit chamber is split between the two aeration basins, although either of the basins can handle the entire flow for maintenance, if necessary. Flow from the aeration basins is split between two secondary clarifiers. From the clarifier(s), all wastewater flow is treated with chlorine gas through the chlorine contact chamber, chlorine contact time is around 30-45 minutes, and then is dechlorinated using sulfur dioxide. Water is then discharged via a rectangular weir into the Bosque Drain. Sludge is drawn from the bottom of the secondary clarifiers and pumped to the sludge thickener unit. The sludge is decanted (thickened) in this unit prior to being pumped to the aerobic digesters. Supernatant from the sludge thickener is piped back to the influent wet well and re-introduced to the aeration basins. After digestion, sludge is taken to the sludge drying beds. Drainage from the beds is routed back to the wet well at the Main Plant Lift Station. After drying to approximately 50 percent total solids, the sludge is moved to a sludge composting pad for composting. The sludge is composted after drying without the use of amendment materials. After composting, the sludge is used as a soil conditioner on public and private property. Section II - OBSERVATIONS At the opening conference, introductions were made, and the inspection objectives were discussed. I provided a document request list and information to be reviewed as part of the inspection. Facility personnel provided a description of the operational processes of the facility and the laboratory analyses that are conducted on-site. After the opening meeting we toured the WWTP in-house laboratory, with EPA inspectors Magda Vargas and Mariela Reyna participating virtually. After the tour of the laboratory, a tour of the treatment train was conducted beginning with the flow from influent collection at the headworks to the effluent flowing to the Bosque Drain at the outfall. 3 LABORATORY OBSERVATIONS City of Belen Wastewater Treatment Plant Inspection Date 1/17/2024 During the review of laboratory documents and the laboratory review of the facility, the following observations were made. Records of Monitoring The following observations were made on the laboratory's records of monitoring. 1. The records of monitoring were not properly maintained, as detailed below. a) The records of monitoring had been photocopied several times and were barely legible. Some were photocopied sheets that had data erased using white out. It was difficult to determine whether current data had been erased using white out or not. Items on records of monitoring that need to be corrected must have a single line drawn through them and be initialed with the date and time. b) Uncontrolled documents in the form of Post It notes were observed posted on the walls of the laboratory. See Appendix 1, photo 1. c) The methods cited did not clearly cite an approved EPA method, as detailed below. i. The pH records of monitoring cite Standard Methods of the Treatment of Water and Wastewater (SM) 22nd Ed, Section 4500H, and does not clearly define which alphabetical section is used. ii. The E. coli records of monitoring cite "M E. coli Blue 24." This is an incomplete citation; it appears that the method used is m-ColiBlue24. d) For all records of monitoring, times are recorded at exactly the ten- and five-minute marks and are consistently at the exact same time every day, with few exceptions. Therefore, it appears that an approximate time is recorded, which is not an accurate representation of the data and analysis of the samples. e) For all records of monitoring, measurements are rounded to significant digits inconsistently and not following standard rounding protocol. These practices produce inaccurate results. f) On several instances no chain of custody was provided to the contract laboratory that performs the nitrate and dichlorobromomethane analysis for the facility. 2. At least one (1) instance was observed where the sample analysis and sample collection for two (2) separate methods were performed at the same time by the same technician. See Appendix 1, photos 2 & 3. 3. At least one (1) instance was observed in which the time and date of analysis as well as analyst signature were filled out in advance of the actual analysis by at least one (1) calendar day. See Appendix 1, photo 4. 4. At least one (1) instance was observed in which the technician had yet to record data for analysis that had been completed five (5) days previous based on their observed methods. See Appendix 1, photo 5. 4 City of Belen Wastewater Treatment Plant Inspection Date 1/17/2024 5. The temperature log does not accurately document the temperature, nor does it demonstrate that the equipment could maintain the required temperature for the duration of the analysis, as detailed below. a) Temperature is recorded on the log once a day. A minimum of two (2) recordings a day is required to ensure the equipment is sustaining the required temperature throughout the day. b) Temperature is recorded at exactly 7am every day. No variation in the day-to-day recorded time suggests that an approximate time is being used. Therefore, it appears that the actual time of the reading is not being recorded. c) The recorded temperatures are consistently the same and are the exact temperature needed for analysis. No variation in the recorded temperature suggests that an approximate temperature is being used. Therefore, it appears that the actual read temperature is not being recorded. i. The inspectors observed the E. coli incubator at 35.2C, different from the 35.1C that has been previously consistently recorded, see Appendix 1 photo 6. ii. The thermometer in the E. coli incubator was observed to be touching the bottom of a glass container in the incubator. iii. The inspectors observed the BOD incubator at 20.2C, different from the 20.1C that has been consistently reported, see Appendix 1 photo 7. 6. Records of monitoring for reliable documentation is insufficient for TSS. See Appendix 2 for representative examples. a) The unit of measurement labeled for the initial weight of the sample is grams (g), but the data recorded is in milligrams (mg). The exact time of sample collection is not recorded for individual samples composited. b) The record of temperature for the refrigerator and oven is autogenerated on the record of monitoring prior to analysis and is not an accurate representation of the temperature at the time of sample drying. c) Quality control samples are not included for each analysis. A duplicate is required for all analysis in batches less than or equal to 20 samples. Currently, quality control samples are performed twice a month. d) No variation in the recorded times as noted below suggest that an approximate time is recorded instead of actual time. i. The difference between sample analysis and drying time is the same and exactly five (5) minutes apart, with few exceptions. ii. The difference between the beginning and end of dry time is always exactly one (1) hour. e) There is no start or stop time recorded for the second drying time. f) In the TRC column of the records of monitoring, no value is recorded on the physical document. A value of zero (0) is entered in the electronic document. See Appendix 2 for representative examples. 5 City of Belen Wastewater Treatment Plant Inspection Date 1/17/2024 7. Records of monitoring for reliable documentation is insufficient for E. coli. See Appendix 2 for representative examples. a) No variation in the recorded time as noted below suggests that the time recorded is being rounded and is not an accurate representation of the analysis. i. The difference between the recorded time of sample collection and the recorded time of arrival is always five (5) minutes, with few exceptions. ii. On several instances, the difference between recorded time of sample collection and the recorded time of arrival is less than the usual five (5) minutes. iii. The difference between recorded time of arrival and the recorded time of analysis is always 15 minutes, with few exceptions. iv. The difference between the recorded time for start and end of incubation is always exactly 24 hours. b) The pH is recorded on the E. coli bench sheet with fewer significant figures than is measured on the instrumentation used. c) Data representation and recording is insufficient. i. Data is not labeled with enough information to distinguish individual samples. ii. Units of measurement are not included. iii. Cells are not properly labeled to represent data. iv. There is a significant amount of empty and unlabeled cells. v. Calculations are not clearly labeled. vi. Results are not written in the designated cell. vii. There is no designated area to record the presence or quantity of colonies that are a color other than blue. d) Measurements are being calculated erroneously. Per the standard method used, if the sample filtered does not produce any colonies, its volume should still be used in the calculation. 8. Records of monitoring for reliable documentation is insufficient for pH. See Appendix 2 for representative examples. a) The difference between recorded time of arrival and the recorded time of analysis is always 5 minutes, with few exceptions. Therefore, it appears that the time recorded is being rounded and is not an accurate representation of the analysis. b) Clarity monitoring as a reference for the quality of standards is autogenerated on the record of monitoring prior to analysis and not manually recorded for each calibration. c) Instantaneous flow is recorded with fewer significant figures than is measured on the instrumentation used and no unit of measurement is used. 9. Records of monitoring for reliable documentation is insufficient for BOD. See Appendix 2 for representative examples. a) The difference between the recorded time for beginning and end of incubation is always the same and exactly 5 days apart. Therefore, it appears that the time recorded is being rounded and is not an accurate representation of the analysis. 6 City of Belen Wastewater Treatment Plant Inspection Date 1/17/2024 b) The difference between the time of analysis for various sample sets is exactly ten minutes. No variation in the recorded time suggests that the time recorded is being rounded and is not an accurate representation of the analysis. c) The instantaneous flow is recorded with less significant figures than are measured on the instrumentation and no unit of measurement is used. d) The pH is recorded with less significant figures than are measured on the instrumentation used. e) The volume of standard and seed used is autogenerated on the record of monitoring prior to analysis and not an accurate representation of the actual volume. f) Quality control is insufficient to produce accurate and reliable results. i. The temperature of the samples is not recorded. It appears that it is not being measured and thus it cannot be assured that the samples are reaching 20 degrees Celsius before they are measured as is required by the standard method. ii. There is no record of the Dissolved Oxygen meter being calibrated before each measurement. It appears that calibration is not being performed. iii. There is no record of the influent flow being recorded. This data is necessary for the final calculation of BOD. iv. There is no record of the time nor temperature for the start and end of incubation. 10. Records of monitoring for reliable documentation is insufficient for TRC. See Appendix 2 for representative examples. a) The difference between sample collection and analysis is always the same, with few exceptions. No variation in the recorded time suggests that the time recorded is being rounded and is not an accurate representation of the analysis. Reagents, Standards, and Equipment The following observations were made on the laboratory's reagents, standards, and equipment. 11. Reagent bottles were not labeled to accurately represent their contents, such as solution/reagent name, open date, and expiration date. See Appendix 1, photos 8, 9, & 10. 12. As of March 14, 2024, the facility did not provide documentation of the National Institute of Standards and Technology (NIST) certified calibration for the following equipment and instrumentation. a) BOD Incubator b) Spectrophotometer c) E. coli incubator d) pH meter e) Do meter f) Thermometers g) An invoice was provided which listed yearly service and calibration services rendered to the following instrumentation and equipment. An invoice is not the equivalent of a 7 City of Belen Wastewater Treatment Plant Inspection Date 1/17/2024 calibration certification and therefore is not sufficient documentation of a NIST certified calibration. i. Incubator (unspecified) ii. Spectrophotometer iii. Fume hood iv. Balance 13. None of the temperature-controlled equipment had calibrated thermometers with correction factors with which to monitor the operating temperature. Temperature controlled equipment must have a NIST certified calibration a minimum of annually by a qualified third-party technician. a) The equipment used for TSS, BOD, and E. coli used built in thermometers, but these thermometers have no record of calibration or evidence that laboratory technicians are checking the thermometers for accuracy and precision. See Appendix 1, photos 6, 7, & 11. b) The E. coli incubator had a secondary thermometer which had an expired calibration from 2020. See Appendix 1, photos 12 & 13. c) The refrigerator had a thermometer that had no calibration or correction factor information associated with it. 14. Several reagents housed in the laboratory were expired per the manufacturer's expiration. See Appendix 1, photos 14 & 15. 15. Residue was seen on the bottom of plastic containers used for sample collection and testing. See Appendix 1, photos 16 & 17. 16. The balance is not routinely calibrated before being used for sample analysis. 17. The petri dishes used for analyses of E. coli are not sterile as they are stored in an open bag which allows for the possibility of contamination. Standard Operating Procedures and Supporting Documentation The following observations were made on the laboratory's standard operating procedures and supporting documentation. 18. The standard operating procedures (SOPs) provided by the facility are not properly maintained, as detailed below. a. None of the provided SOPs reference the approved EPA method used. b. There is no review date listed and the documents do not appear to be controlled documents as they do not seem to have been written or updated recently, and or copies of them may not be kept in a controlled location. 19. Data qualifiers and requirements for accurate testing are not included in the procedure for BOD analysis. a) No explanation is included on what to do if the initial DO of the dilution water is not at least 7.5 mg/L. b) No explanation is included on what to do if the residual DO is less than 1.0 mg/L and/or if DO depletion is less than 2.0 mg/L. 8 City of Belen Wastewater Treatment Plant Inspection Date 1/17/2024 c) There is no mention of the need to prevent air bubbles and head space in the bottles being filled with sample. d) Temperature and time requirements of incubation are not included. e) There is no written standard method on how to calibrate the DO meter, nor that the DO meter must be calibrated before sample analysis. f) There is no written standard detailing the volume of sample that is collected for analysis or description of where the sample is collected from. 20. Data qualifiers and requirements for accurate testing are not included in the procedure for TSS analysis. a) The required temperature of the oven is not provided. b) There is no explanation of how the results are calculated. c) There is no mention of the requirement to bring the sample to room temperature before measuring or that the temperature, time of incubation, and second weight must be recorded. d) The procedure for filter preparation is not included. e) There is no mention of the need to stir and pipet the sample for proper homogenization of the final composite solution. f) There is no written standard detailing the volume of sample that is collected for analysis. 21. Procedures to ensure accurate testing is missing in the E. coli SOP. a) The is no mention of how much sample to collect or the sample collection procedures. b) The location of sample collection is not mentioned. c) There is no mention of the requirement to rinse bottles three times. d) The alcohol solution concentration required for sterilization is not specified. e) There is no mention of what to do if the presence of colonies of any color other than blue is observed. f) There is no written standard detailing the volume of sample that is collected for analysis or description of where the sample is collected from. 22. Instructions for the measurement of TRC are insufficient to perform the procedure. a) There is no mention of how to conduct the analysis after the sample is placed in the instrument. b) The required wait time after addition of reagents is not specified. c) The instrument's program used for analysis is not specified. d) There is no written standard detailing the volume of sample that is collected for analysis or description of where the sample is collected from. 23. Instructions for the measurement of pH are insufficient to perform the procedure. a) There is no written standard detailing the volume of sample collected for analysis or description of where the sample is collected from. 24. There is no written standardized procedure for Biochemical Monitoring sample collection. 25. There is no written standardized procedure for the collection of samples used for nitrate and dichlorobromomethane analysis by contract laboratories. 9 City of Belen Wastewater Treatment Plant Inspection Date 1/17/2024 26. There is no written standardized procedure for the use of the Autoclave to ensure sterilization of items. No device is used to certify sterilization. 27. The facility does not track the internal or external training received by the operators. Observed Methods The following observations were made on the observed methods used by the laboratory during the inspection. 28. The method used for TRC differed from the EPA approved method as detailed below. a) The sample volume used in analysis is measured with a beaker and not a volumetric method. b) After the addition of the free chlorine reagent, technicians are waiting three (3) minutes to analyze the sample instead of the two (2) minutes as required by the method. c) Technicians are not adding the free chlorine reagent to the sample and sample cell used to blank the instrument, as required by method. 29. Dichlorobromomethane is a volatile organic compound, and the sample must be taken directly from the source into a volatile organics (VOA) glass sample bottle, see Appendix 1, photo 18, with zero headspace so that the sample doesn't volatilize into the air of the bottle. The permittee reported that they have been collecting the composite sample by hand and storing each aliquot in a small plastic bottle, with headspace in each aliquot, in the laboratory refrigerator. Once they have all the aliquots, they mix them together in a graduated cylinder and pour the sample into the VOA bottles (without headspace). This headspace and mixing allows the pollutant to volatilize into the air inside the bottle. Due to the extra time the samples are exposed to air and mixing, all samples collected to date have been under-reporting the actual amount of pollutant present in the sample. The only way to collect the sample as written in the permit, is for the permittee to collect each aliquot directly into the three (3) VOA bottles and have the contract laboratory composite the samples without headspace and mixing. The permittee is advised to contact their EPA permit writer to request a permit modification of this permit requirement. PLANT OPERATIONS OBSERVATIONS After the tour of the laboratory, a tour of the treatment train was conducted following the flow from influent collection at the headworks to the effluent flowing to the Bosque Drain at the outfall. Observations regarding plant observations and the treatment train include the following: 1. The grit removal system has been down for approximately six (6) months, allowing grit to pass into the treatment basin. The permittee reports that supply chain issues and budget constraints have hampered their ability to get the grit removal system back online. Failing to remove grit may cause significant equipment damage to aeration nozzles, pumps, piping, sludge thickening centrifuges, as well as to treatment basin and digester basin walls. This damage to the plant will cause the facility to incur additional costs to repair equipment. 10 City of Belen Wastewater Treatment Plant Inspection Date 1/17/2024 2. The influent flow primary flowmeter is a Parshall Flume, effluent flow primary flowmeter is a rectangular weir. Facility personnel stated that they verify the secondary flow meters against the primary flow meters daily, twice per day (morning and afternoon). Records of secondary flow meter logs were submitted as part of this inspection, however verification records comparing primary to secondary flow meters were not submitted. 3. The permittee has hired the services of an engineer to design plans for plant renovation. The plant was built originally in 1982, and no renovations to the plant have occurred in at least the last five (5) years. There are no major structural issues with any of the treatment basins, all cracks appear to be cosmetic in nature. Renovations are looking to expand capacity of the plant as well as treat the effluent for nitrate and dichlorobromomethane. 4. The plant has eight total operators, however five (5) of these operators are unlicensed. Unlicensed operators cannot run facility operations without oversight from a licensed operator and the permittee has struggled with getting these operators licensed. 5. Sewage sludge (biosolids) in the drying beds was not fully contained on concrete so as to prevent potential runoff to stormwater. See Appendix 1, photo 19. Section III - AREAS OF CONCERN Requirement 1 NPDES Permit NM0020150 Part I. A.1. Final Effluent Limits: *5. Monitoring to begin from the effective date and continue during initial three (3) years of the final permit. After initial three (3) years of monitoring, effluent limits shall be met. Concern 1 Sampling results for nitrate have been reported incorrectly since February 2022. The laboratory is reporting nitrate results in mg/L however the discharge monitoring report (DMR) form requires the results for nitrate to be converted and reported in g/L. Effluent limits shown in the table above went into effect July 1, 2023, which would result in DMR exceedances between the months of August 2023 and January 2024. All nitrate values since February 2022 on the DMRs must be corrected. DMR Date Currently Reported Values 7 DAY AVG DAILY MAX Values Corrected for Units* 7 DAY AVG DAILY MAX 08/31/2023 9 ug/L 14 ug/L 9,000 ug/L 14,000 ug/L 09/30/2023 11 ug/L 13 ug/L 11,000 ug/L 13,000 ug/L 10/31/2023 17 ug/L 20 ug/L 17,000 ug/L 20,000 ug/L 11/30/2023 26 ug/L 33 ug/L 26,000 ug/L 33,000 ug/L 12/31/2023 21 ug/L 28 ug/L 21,000 ug/L 28,000 ug/L 01/31/2024 29 ug/L 33 ug/L 29,000 ug/L 33,000 ug/L * Other corrections to reported values may be necessary, see AOC Requirement 12 below 11 Requirement 2 NPDES Permit NM0020150 Part I. A.1. Final Effluent Limits: City of Belen Wastewater Treatment Plant Inspection Date 1/17/2024 *5. Monitoring to begin from the effective date and continue during initial three (3) years of the final permit. After initial three (3) years of monitoring, effluent limits shall be met. Concern 2A As reported, the permittee has exceeded the 5.6 ug/L limit for Dichlorobromomethane. DMR Date Reported Values DAILY MAX 07/31/2023 15 ug/L 08/31/2023 8 ug/L 09/30/2023 7 ug/L 11/30/2023 9 ug/L 12/31/2023 7 ug/L 01/31/2024 8 ug/L Because dichlorobromomethane is a volatile organic compound, and the permittee is not sampling directly from the source into a VOA glass sample bottle, see Appendix 1, photo 18, with zero headspace, all samples collected to date have been under-reporting the actual amount of pollutant present in the sample. Concern 2B Permittee is reporting values incorrectly. Permittee must report values to the same number of significant digits as shown in the permit. For dichlorobromomethane, this would be two digits. Requirement 3 NPDES Permit NM0020150, Part I: B. Schedules of Compliance: The permittee shall submit a detailed plan to test for nitrate and dichlorobromomethane (bromodichloromethane) within two (2) months after the effective date of the permit to both EPA and NMED for approval. The plan must also include strategies to control effluent concentrations of dichlorobromomethane (bromodichloromethane) and nitrate in order to meet the NMQWS at the treatment facility. Once approved, the permittee must collect and analyze samples for nitrate and dichlorobromomethane (bromodichloromethane) three (3) times per week or more frequent during first (1), second (2) and third (3) year of the permit. The results of this study shall be attached to the DMR reports to EPA. At the end of third year, the treatment facility shall meet the effluent limitations for both pollutants. Concern 3 A detailed plan to test for nitrate and dichlorobromomethane was due September 1, 2020, and has not been received by EPA. Effluent limits went into effect on July 1, 2023; the treatment facility has not met the effluent limitations for both pollutants. 12 City of Belen Wastewater Treatment Plant Inspection Date 1/17/2024 Requirement 4 NPDES Permit NM0020150, Part II: C.2. The permittee shall require any indirect discharger to the treatment works to comply with the reporting requirements of Sections 204(b), 307, and 308 of the Act, including any requirements established under 40 CFR Part 403. 40 CFR 122.21(j)(6): Industrial discharges. Applicants must submit the following information about industrial discharges to the POTW: (i) Number of significant industrial users (SIUs) and non-significant categorical industrial users (NSCIUs), as defined at 40 CFR 403.3(v), including SIUs and NSCIUs that truck or haul waste, discharging to the POTW... Concern 4 Facility personnel stated that there are no indirect dischargers (also referred to as Industrial Users) within their collection system. However, when the inspector asked about specific commercial entities located within the Belen city limits, facility personnel stated that several of them likely do discharge to the Belen WWTP. It is possible that limit exceedances for nitrate and dichlorobromomethane are caused by passthrough or interference from Industrial Users. Permittee must conduct a full industrial user survey prior to next permit cycle and submit the list of Industrial Users found as part of the permit application. Requirement 5 NPDES Permit NM0020150, Part III: B.3.a. Proper Operation and Maintenance. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by permittee as efficiently as possible and in a manner which will minimize upsets and discharges of excessive pollutants and will achieve compliance with the conditions of this permit. Concern 5A The grit removal system must be brought back online as quickly as possible to minimize additional repair costs to the system. Concern 5B The sewage sludge (biosolids) must be kept entirely within (or moved into) the containment boundaries of the drying beds. Requirement 6 NPDES Permit NM0020150 Part III.B.3.b. Proper Operation and Maintenance. The permittee shall provide an adequate operating staff which is duly qualified to carry out operation, maintenance and testing functions required to insure compliance with the conditions of this permit. Concern 6 At the time of this inspection the facility employed three (3) licensed operators and five (5) unlicensed technicians who regularly perform laboratory analysis for regulated pollutants in addition to their plant operational duties. The main laboratory technician is not adequately licensed for the analysis performed in the laboratory. In accordance with NMAC 20.7.4, "operate" is defined as "performing any activity or function or making any process control or system integrity decision regarding water quality or water quantity that has the potential to affect the proper functioning of ... a public wastewater facility or to affect human health, public welfare or the environment." Facility personnel without any operator 13 City of Belen Wastewater Treatment Plant Inspection Date 1/17/2024 certification are not qualified to "operate" the facility nor perform any laboratory analysis including pH and dissolved oxygen without constant oversight from a certified operator. It is the responsibility of the permittee to offer operators a salary commensurate with the tasks of running the WWTP and the laboratory. Requirement 7 NPDES Permit NM0029351 Part III. C.4. Record Contents. Records of monitoring information shall include: a. The date, exact place, and time of sampling or measurements; b. The individual(s) who performed the sampling or measurements; c. The date(s) and time(s) analyses were performed; d. The individual(s) who performed the analyses; e. The analytical techniques or methods used; and f. The results of such analyses. Concern 7 Several records of monitoring were missing information as required per either the permit or the EPA methods cited or assumed used in the analysis of regulated pollutants. See Records of Monitoring section of Laboratory Observations. Requirement 8 NPDES Permit NM0029351 Part III.C.5.a. Monitoring Procedures. Monitoring must be conducted according to test procedures approved under 40 CFR Part 136, unless other test procedures have been specified in this permit or approved by the Regional Administrator. Concern 8A Several SOPs and observed methods used for the analysis of regulated pollutants deviated from the EPA approved methods that were either cited or assumed used. The facility does not have approval for the use of alternate methods or deviations from methods listed in 40 CFR Part 136 from the Regional Administrator. Concern 8B Facility personnel are rounding values obtained during analysis before the final calculation to determine the actual value of analysis for regulated pollutants. This is a deviation from the EPA approved methods and produces an inaccurate value to be reported on the facility's Discharge Monitoring Reports. Concern 8C The pH buffer bottles had a written `received-on' date, but not an `opened-on' date, see Appendix 1, photo 10. Depending on the manufacturer, many of these buffers should be used within six months and the pH 10 buffer should be used within three months of opening. Permittee must contact the manufacturer of the specific buffers they use to determine appropriate expiration dates. Several other laboratory reagents were also expired. Proper calibration of laboratory equipment cannot be confirmed, and therefore neither can we confirm proper analysis of the pollutant, if the buffers and reagents used for instrumentation calibration are expired. 14 City of Belen Wastewater Treatment Plant Inspection Date 1/17/2024 Requirement 9 NPDES Permit NM0029351 Part III.C.5.b. Monitoring Procedures. The permittee shall calibrate and perform maintenance procedures on all monitoring and analytical instruments at intervals frequent enough to insure accuracy of measurements and shall maintain appropriate records of such activities. Concern 9 The facility failed to provide adequate documentation to the NIST certified calibrations for instrumentation and equipment used in the analysis of regulated pollutants. Additionally, the facility failed to perform adequate temperature monitoring on temperature-controlled instrumentation and equipment used in the analysis of regulated pollutants. Requirement 10 NPDES Permit NM0029351 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 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 10 Facility personnel were unable to provide documentation proving that they have recorded the staff gauge water levels of the primary flow measurement devices, used the relevant conversion tables, and compared them to the secondary (electronic) flow measurement devices to ensure that the primary and secondary flow measurement devices are within 10% of each other. This comparison must be done monthly to ensure that secondary flow devices remain stable. Requirement 11 NPDES Permit NM0029351 Part III. D.8. Other Noncompliance. The permittee shall report all instances of noncompliance not reported under Parts III.D.4 and D.7 ... at the time monitoring reports are submitted. The reports shall contain the information listed at Part III.D.7. NPDES Permit NM0029351 Part III. D.7.a. Twenty-Four Hour Reporting. The permittee shall report any noncompliance which may endanger health or the environment. Notification shall be made to the EPA at the following e-mail address: R6_NPDES_Reporting@epa.gov, as soon as possible, but within 24 hours from the time the permittee becomes aware of the circumstance. Notification shall also be made to the New Mexico Environment Department at (505) 827-0187 or psrs.program.manager@env.nm.gov as soon as possible, but within 24 hours from the time the permittee becomes aware of the circumstance. A written submission shall be provided within 5 days of the time the permittee becomes aware of the circumstances. The report shall contain the following information: (1) A description of the noncompliance and its cause; (2) The period of noncompliance including exact dates and times, and if the noncompliance has not been corrected, the anticipated time it is expected to continue; and, (3) Steps being taken to reduce, eliminate, and prevent recurrence of the noncomplying discharge. 15 City of Belen Wastewater Treatment Plant Inspection Date 1/17/2024 Concern 11 Permittee has not been reporting excursions of dichlorobromomethane nor nitrate properly. DMR reporting must include the count of the number of individual samples that exceeded the permit limit during the reporting period; permittee has been reporting zero exceedances for dichlorobromomethane even though the value reported is above the permit limit. Permittee has not followed the Twenty-Four Hour Reporting regulations listed above for dichlorobromomethane nor for nitrate. Requirement 12 NPDES Permit NM0029351 Part III. F.22.a. 7-DAY AVERAGE or WEEKLY AVERAGE, other than for fecal coliform bacteria, is the arithmetic mean of the daily values for all effluent samples collected during a calendar week, calculated as the sum of all daily discharges measured during a calendar week divided by the number of daily discharges measured during that week. The 7-day average for fecal coliform bacteria is the geometric mean of the values for all effluent samples collected during a calendar week. Concern 12 Permittee is not reporting 7-day averages correctly for any pollutants. The 7-day average must be calculated for each week within a month, and the reported value would be the highest of these weekly averages. For example: Sample Date Laboratory-Reported Value (ug/L) 7 DAY AVG 7/4/2023 15 7/5/2023 8.5 11.2 This value would be reported for 7-day average 7/6/2023 10 7/11/2023 6 7/12/2023 6.4 6.4 7/13/2023 6.7 7/18/2023 5.9 7/19/2023 4.5 5.1 7/20/2023 5 7/25/2023 4.1 7/26/2023 4 4.1 7/27/2023 4.3 Section IV - CLOSING CONFERENCE EPA Region 6 Inspectors conducted a closing conference for the inspection at the Belen WWTP at 2:03 PM on January 17, 2024. During the closing conference, Inspectors reviewed the Areas of Concern (AOCs) noted during the inspection. Additional AOCs have been noted in this report that were not covered in the closing conferences because they were determined afterward. The inspection was concluded at 2:43 PM on January 17, 2024. 16 Section V - FOLLOW UP City of Belen Wastewater Treatment Plant Inspection Date 1/17/2024 The following document request was given to the permittee by EPA at the beginning of the inspection on January 17, 2024: For the dates January 2023 to December 2023, please provide the following documentation for the analysis of all regulated pollutants per your NPDES permit; (i.e., pH, BOD5, TSS, E. coli, Total Residual Chlorine, Total Ammonia, Dissolved Oxygen, Whole Effluent Toxicity Testing, and any additional pollutants not listed). o Chain of Custody documents for all incoming samples to the laboratory. o Bench sheets and all recorded data (records of monitoring). o All calibration reports for instrumentation used in analysis. Meters, mass balances, etc. o Temperature records for all equipment and instrumentation used in analysis. Incubators, refrigerators used for storage, ovens, etc. o Submitted and signed DMRs. All National Institute of Standards and Technology (NIST) calibration certificates for laboratory instrumentation used in the analysis of regulated pollutants. Influent and effluent flow measurements from January 2023 to December 2023. o Calibration records for influent and effluent flow meters Laboratory Quality Control and Quality Assurance records from January 2023 to December 2023. o Preliminary batch testing for disposable sampling and analysis equipment. For example, pre-weighed filters for TSS analysis, Colilert trays for E. coli testing. o Blank testing of glassware or other equipment and instrumentation to ensure proper preparation, for example cleaning or sterilization. Certifications and/or training documents for all technicians who perform analysis or sample preparation for regulated pollutants. All standard operating procedures for the analysis, sample gathering, sample preparation, sample disposal, equipment and instrument preparation, and calibration of equipment for the analysis of regulated pollutants. Excursion, Overflow or Bypass Summary Report(s). Latest Sludge DMR with metals, pathogens, and vector report. o Sludge sampling results. SPCC Plan (Spill Prevention, Control and Countermeasure Plan), required if aggregate capacity of above-ground oil storage containers greater than 1,320 gallons, or buried storage tanks greater than 42,000 gallons. Storm Water Permits (Construction, Multi-Sector, and/or General Baseline). Pollution Prevention Program documents, as required by your NPDES Permit. Requested documents were received from City of Belen representatives via GoAnywhere Managed File Transfer on January 24, 25, 29 and 31, and February 1, 2024. All requested documents were provided unless the document did not exist. 17 Section VI - LIST OF APPENDICES City of Belen Wastewater Treatment Plant Inspection Date 1/17/2024 Appendix 1 - Photograph Log - 19 photos taken January 17, 2024 Appendix 2 - Selected Bench Sheets Submitted by City of Belen Representatives 18 City of Belen Wastewater Treatment Plant Inspection Date 1/17/2024 Appendix 1 Photograph Log 19 photos taken January 17, 2024 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 1 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2218.JPG Date of Photo: 01/17/2024 Time of Photo: 8:47 AM Photographer: Amy Andrews Description: Uncontrolled documents in the form of post-it notes found in the laboratory UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 2 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2294.JPG Date of Photo: 01/17/2024 Time of Photo: 10:04 AM Photographer: Amy Andrews Description: Record of monitoring in which sample analysis and sample collection for two (2) separate methods were performed at the same time by the same technician, 1 of 2 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 3 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2287.JPG Date of Photo: 01/17/2024 Time of Photo: 9:45 AM Photographer: Amy Andrews Description: Record of monitoring in which sample analysis and sample collection for two (2) separate methods were performed at the same time by the same technician, 2 of 2 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 4 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2243.JPG Date of Photo: 01/17/2024 Time of Photo: 9:03 AM Photographer: Amy Andrews Description: Record of monitoring in which the time and date of analysis as well as analyst signature were filled out in advance of the actual analysis by at least one (1) calendar day. A BOD record of monitoring is filled out for January 18, 2024, analysis at the time of picture on January 17, 2024. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 5 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2318.JPG Date of Photo: 01/17/2024 Time of Photo: 10:19 AM Photographer: Amy Andrews Description: Record of monitoring in which the technician had yet to record data for analysis that had been completed five (5) days previous based on their observed methods. A TSS record of monitoring with sample collected on 1/11/2024 with no data recorded for the second dry weight, which should have happened on 1/12/2024 per the facility's method. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 6 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2213.JPG Date of Photo: 01/17/2024 Time of Photo: 8:46 AM Photographer: Amy Andrews Description: E. coli incubator at 35.2C, different from the 35.1C that has been previously consistently recorded on the temperature log. Laboratory equipment with built-in thermometers that did not have additional calibration, 1 of 3. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 7 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2321.JPG Date of Photo: 01/17/2024 Time of Photo: 10:24 AM Photographer: Amy Andrews Description: The BOD incubator at 20.2C, different from the 20.1C that has been consistently reported on the temperature log. Laboratory equipment with built-in thermometers that did not have additional calibration, 2 of 3 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 8 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2214.JPG Date of Photo: 01/17/2024 Time of Photo: 8:46 AM Photographer: Amy Andrews Description: Reagent bottles are not labeled with solution/reagent name, open date, and expiration date, 1 of 3. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 9 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2216.JPG Date of Photo: 01/17/2024 Time of Photo: 8:47 AM Photographer: Amy Andrews Description: Reagent bottles are not labeled with solution/reagent name, open date, and expiration date, 2 of 3. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 10 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2217.JPG Date of Photo: 01/17/2024 Time of Photo: 8:47 AM Photographer: Amy Andrews Description: Reagent bottles are not labeled with solution/reagent name, open date, and expiration date, 3 of 3. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 11 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2211.JPG Date of Photo: 01/17/2024 Time of Photo: 8:46 AM Photographer: Amy Andrews Description: Laboratory equipment with built-in thermometers that did not have additional calibration, 3 of 3. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 12 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2321.JPG Date of Photo: 01/17/2024 Time of Photo: 10:24 AM Photographer: Amy Andrews Description: The thermometer in the E. coli incubator was expired with an expiration year of 2020, 1 of 2. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 13 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2275.JPG Date of Photo: 01/17/2024 Time of Photo: 9:33 AM Photographer: Amy Andrews Description: The thermometer in the E. coli incubator was expired with an expiration year of 2020, 2 of 2. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 14 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2223.JPG Date of Photo: 01/17/2024 Time of Photo: 8:49 AM Photographer: Amy Andrews Description: Expired reagents, 1 of 2. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 15 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2399.JPG Date of Photo: 01/17/2024 Time of Photo: 1:53 PM Photographer: Amy Andrews Description: Expired reagents, 2 of 2. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 16 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2295.JPG Date of Photo: 01/17/2024 Time of Photo: 10:05 AM Photographer: Amy Andrews Description: Residue was seen on the bottom of plastic containers used for sample collection and testing, 1 of 2 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 17 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2280.JPG Date of Photo: 01/17/2024 Time of Photo: 9:41 AM Photographer: Amy Andrews Description: Residue was seen on the bottom of plastic containers used for sample collection and testing, 2 of 2 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 18 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2325.JPG Date of Photo: 01/17/2024 Time of Photo: 10:35 AM Photographer: Amy Andrews Description: Volatile organics (VOA) glass sample bottle used in the analysis of dichlorobromomethane. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1300 Conservancy Rd City: Belen Photo No. 19 County/Parish: Valencia County State: New Mexico Photo File Name: DSCN2379.JPG Date of Photo: 01/17/2024 Time of Photo: 1:14 PM Photographer: Amy Andrews Description: Sewage sludge in the drying beds is not fully contained on concrete so as to prevent potential runoff to stormwater Appendix 2 City of Belen Wastewater Treatment Plant Records of Monitoring Excerpts Hall Environmental Analysis Laboratory 4901 Hawkins NE Albuquerque, NM 87109 TEL: 505-345-3975 FAX: 505-345-4107 Website: www.hallenvironmental.com August 03, 2023 John Ivey City of Belen WWTP 100 South Main Belen, NM 87002 TEL: (505) 864-6081 FAX: (505) 864-0211 RE: Nitrate Bromodichloromethane OrderNo.: 2307A11 Dear John Ivey: Hall Environmental Analysis Laboratory received 2 sample(s) on 7/21/2023 for the analyses presented in the following report. These were analyzed according to EPA procedures or equivalent. To access our accredited tests please go to www.hallenvironmental.com or the state specific web sites. In order to properly interpret your results, it is imperative that you review this report in its entirety. See the sample checklist and/or the Chain of Custody for information regarding the sample receipt temperature and preservation. Data qualifiers or a narrative will be provided if the sample analysis or analytical quality control parameters require a flag. When necessary, data qualifiers are provided on both the sample analysis report and the QC summary report, both sections should be reviewed. All samples are reported, as received, unless otherwise indicated. Lab measurement of analytes considered field parameters that require analysis within 15 minutes of sampling such as pH and residual chlorine are qualified as being analyzed outside of the recommended holding time. Please don't hesitate to contact HEAL for any additional information or clarifications. ADHS Cert #AZ0682 -- NMED-DWB Cert #NM9425 -- NMED-Micro Cert #NM0901 Sincerely, Andy Freeman Laboratory Manager 4901 Hawkins NE Albuquerque, NM 87109 Hall Environmental Analysis Laboratory, Inc. Analytical Report Lab Order 2307A11 Date Reported: 8/3/2023 CLIENT: City of Belen WWTP Project: Nitrate Bromodichloromethane Lab ID: 2307A11-001 Matrix: AQUEOUS Client Sample ID: Nitrate / Bromodichloromethane Collection Date: 7/19/2023 3:01:00 PM Received Date: 7/21/2023 9:29:00 AM Analyses EPA METHOD 624.1 - VOCS Bromodichloromethane Surr: 1,2-Dichloroethane-d4 Surr: 4-Bromofluorobenzene Surr: Dibromofluoromethane Surr: Toluene-d8 EPA METHOD 300.0: ANIONS Nitrate+Nitrite as N Result 4.5 109 112 111 108 8.3 RL Qual Units DF Date Analyzed Batch 1.0 70-130 70-130 70-130 70-130 1.0 g/L %Rec %Rec %Rec %Rec mg/L Analyst: CCM 1 7/21/2023 8:19:00 PM W98398 1 7/21/2023 8:19:00 PM W98398 1 7/21/2023 8:19:00 PM W98398 1 7/21/2023 8:19:00 PM W98398 1 7/21/2023 8:19:00 PM W98398 Analyst: SNS 5 7/28/2023 1:38:06 PM R98598 Refer to the QC Summary report and sample login checklist for flagged QC data and preservation information. Qualifiers: * Value exceeds Maximum Contaminant Level. D Sample Diluted Due to Matrix H Holding times for preparation or analysis exceeded ND Not Detected at the Reporting Limit PQL Practical Quanitative Limit S % Recovery outside of standard limits. If undiluted results may be estimated. B Analyte detected in the associated Method Blank E Above Quantitation Range/Estimated Value J Analyte detected below quantitation limits P Sample pH Not In Range RL Reporting Limit Page 1 of 4 Hall Environmental Analysis Laboratory, Inc. Analytical Report Lab Order 2307A11 Date Reported: 8/3/2023 CLIENT: City of Belen WWTP Project: Nitrate Bromodichloromethane Lab ID: 2307A11-002 Matrix: AQUEOUS Client Sample ID: Nitrate / Bromodichloromethane Collection Date: 7/20/2023 3:01:00 PM Received Date: 7/21/2023 9:29:00 AM Analyses EPA METHOD 624.1 - VOCS Bromodichloromethane Surr: 1,2-Dichloroethane-d4 Surr: 4-Bromofluorobenzene Surr: Dibromofluoromethane Surr: Toluene-d8 EPA METHOD 300.0: ANIONS Nitrate+Nitrite as N Result 5.0 113 113 113 106 8.5 RL Qual Units DF Date Analyzed Batch 1.0 70-130 70-130 70-130 70-130 1.0 g/L %Rec %Rec %Rec %Rec mg/L Analyst: CCM 1 7/21/2023 8:44:00 PM W98398 1 7/21/2023 8:44:00 PM W98398 1 7/21/2023 8:44:00 PM W98398 1 7/21/2023 8:44:00 PM W98398 1 7/21/2023 8:44:00 PM W98398 Analyst: SNS 5 7/28/2023 1:50:26 PM R98598 Refer to the QC Summary report and sample login checklist for flagged QC data and preservation information. Qualifiers: * Value exceeds Maximum Contaminant Level. D Sample Diluted Due to Matrix H Holding times for preparation or analysis exceeded ND Not Detected at the Reporting Limit PQL Practical Quanitative Limit S % Recovery outside of standard limits. If undiluted results may be estimated. B Analyte detected in the associated Method Blank E Above Quantitation Range/Estimated Value J Analyte detected below quantitation limits P Sample pH Not In Range RL Reporting Limit Page 2 of 4 QC SUMMARY REPORT Hall Environmental Analysis Laboratory, Inc. WO#: 2307A11 03-Aug-23 Client: Project: City of Belen WWTP Nitrate Bromodichloromethane Sample ID: MB Client ID: PBW Prep Date: Analyte Nitrate+Nitrite as N Sample ID: LCS Client ID: LCSW Prep Date: Analyte Nitrate+Nitrite as N Sample ID: MB Client ID: PBW Prep Date: Analyte Nitrate+Nitrite as N Sample ID: LCS Client ID: LCSW Prep Date: Analyte Nitrate+Nitrite as N SampType: MBLK Batch ID: R98598 Analysis Date: 7/28/2023 TestCode: EPA Method 300.0: Anions RunNo: 98598 SeqNo: 3590685 Units: mg/L Result ND PQL SPK value SPK Ref Val %REC 0.20 LowLimit HighLimit %RPD RPDLimit SampType: LCS Batch ID: R98598 Analysis Date: 7/28/2023 TestCode: EPA Method 300.0: Anions RunNo: 98598 SeqNo: 3590686 Units: mg/L Result 3.5 PQL SPK value SPK Ref Val %REC 0.20 3.500 0 98.6 LowLimit 90 HighLimit 110 %RPD RPDLimit SampType: MBLK Batch ID: R98598 Analysis Date: 7/28/2023 TestCode: EPA Method 300.0: Anions RunNo: 98598 SeqNo: 3590736 Units: mg/L Result ND PQL SPK value SPK Ref Val %REC 0.20 LowLimit HighLimit %RPD RPDLimit SampType: LCS Batch ID: R98598 Analysis Date: 7/28/2023 TestCode: EPA Method 300.0: Anions RunNo: 98598 SeqNo: 3590737 Units: mg/L Result 3.4 PQL SPK value SPK Ref Val %REC 0.20 3.500 0 98.1 LowLimit 90 HighLimit 110 %RPD RPDLimit Qual Qual Qual Qual Qualifiers: * Value exceeds Maximum Contaminant Level. D Sample Diluted Due to Matrix H Holding times for preparation or analysis exceeded ND Not Detected at the Reporting Limit PQL Practical Quanitative Limit S % Recovery outside of standard limits. If undiluted results may be estimated. B Analyte detected in the associated Method Blank E Above Quantitation Range/Estimated Value J Analyte detected below quantitation limits P Sample pH Not In Range RL Reporting Limit Page 3 of 4 QC SUMMARY REPORT Hall Environmental Analysis Laboratory, Inc. WO#: 2307A11 03-Aug-23 Client: Project: City of Belen WWTP Nitrate Bromodichloromethane Sample ID: 100NG 624 LCS Client ID: LCSW Prep Date: Analyte Bromodichloromethane Surr: 1,2-Dichloroethane-d4 Surr: 4-Bromofluorobenzene Surr: Dibromofluoromethane Surr: Toluene-d8 Sample ID: mb Client ID: PBW Prep Date: Analyte Bromodichloromethane Surr: 1,2-Dichloroethane-d4 Surr: 4-Bromofluorobenzene Surr: Dibromofluoromethane Surr: Toluene-d8 SampType: LCS Batch ID: W98398 Analysis Date: 7/21/2023 TestCode: EPA Method 624.1 - VOCs RunNo: 98398 SeqNo: 3582007 Units: g/L Result 21 10 12 11 11 PQL 1.0 SPK value 20.00 10.00 10.00 10.00 10.00 SPK Ref Val 0 %REC 104 103 117 111 113 LowLimit 65 70 70 70 70 HighLimit 135 130 130 130 130 %RPD RPDLimit SampType: MBLK Batch ID: W98398 Analysis Date: 7/21/2023 TestCode: EPA Method 624.1 - VOCs RunNo: 98398 SeqNo: 3583497 Units: g/L Result ND 11 11 11 11 PQL 1.0 SPK value SPK Ref Val 10.00 10.00 10.00 10.00 %REC 111 112 115 107 LowLimit 70 70 70 70 HighLimit 130 130 130 130 %RPD RPDLimit Qual Qual Qualifiers: * Value exceeds Maximum Contaminant Level. D Sample Diluted Due to Matrix H Holding times for preparation or analysis exceeded ND Not Detected at the Reporting Limit PQL Practical Quanitative Limit S % Recovery outside of standard limits. If undiluted results may be estimated. B Analyte detected in the associated Method Blank E Above Quantitation Range/Estimated Value J Analyte detected below quantitation limits P Sample pH Not In Range RL Reporting Limit Page 4 of 4