Document bBVae2B5gYK2XNq823ZpyN0dZ

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) O6/08/2023 Water NPDES Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Oshara Mutual Domestic Wastewater Association Oshara Village Water Reclamation Facility No. 2 Willow Back Road Santa Fe, New Mexico 87507 11 Craftsman Road Santa Fe, New Mexico 87507 Santa Fe 505-690-2002 Loren Allen Consultant Operator loren.allenenvironmental@gmail.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110064637601 NM0030813 NA 221320 4952 Personnel participating in inspection: David Esparza EPA/R6-ECDWM Environmental Engineer EPA Lead Inspector Signature/Date DAVID ESPARZA Date: 2023.08.24 06:47:39 -06'00' Digitally signed by DAVID ESPARZA David Esparza Date Supervisor Signature/Date ROBERTO BERNIER Date: 2023.08.24 08:34:06 -05'00' Digitally signed by ROBERTO BERNIER Roberto Bernier Date 6ENFORM-019-R8.2 (02/12/2020) 1 Oshara Mutual Domestic Wastewater Association / Oshara Village Water Reclamation Facility Permit No. NM0030813 Inspection Date 06/08/2023 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspector David Esparza, PE, arrived at Oshara Village Water Reclamation Facility (WRF) at 10:00 AM on June 8, 2023, for an unannounced inspection. The Facility was unoccupied, and no facility staff was available. I did speak to Mr. Loren Allen, the contract operator for the Facility be telephone (505690-2002) later the same afternoon. I discussed with Mr. Allen the purpose of my onsite visit and that it was an EPA inspection to determine Ohara's compliance under the Clean Water Act (CWA). The compliance evaluation inspection (CEI) was conducted under the authority of the National Pollutant Discharge Elimination System (NPDES) permit program, in accordance with the CWA. The generation of this report is based on information supplied by Oshara representatives, observations made by the United States Environmental Protection Agency (US EPA) inspector, and records and reports maintained by the permittee, and the US EPA. An exit briefing was not held due to the above stated reasons. FACILITY DESCRIPTION The Oshara Village WRF is a minor discharger with a design flow capacity of 0. 0.03 MGD (million gallons per day) and a current average flow of 0.012 MGD. The WRF facility is located at No. 2 Willow Back Road, adjacent to Richards Avenue and approximately 1,500-feet north of the Santa Fe Community College, Santa Fe County, New Mexico (depicted in Aerial Image #1 below). Aerial Image #1: Overall view of the Oshara Village Water Reclamation Facility location. Aerial from Google Earth Maps. 2 Oshara Mutual Domestic Wastewater Association / Oshara Village Water Reclamation Facility Permit No. NM0030813 Inspection Date 06/08/2023 The WRF is an advanced Sequencing Batch Reactor (SBR) treatment facility which has three (3) major tanks: anoxic equalization tank, SBR tank, and effluent equalization chlorine contact tank. Ancillary equipment includes one (1) lift station that conveys raw influent to the facility from dwelling units (DW) in Oshara Village. At the headworks, influent flows through a 12-inch-wide bar screen with 1-inch openings to catch rags and debris. A 4-inch magnetic flow meter measures the influent flow at the WRF. From the headworks, influent travels by gravity into the conditioning sludge storage tank, the first or initial tank in the system. Here, the solids and grit are allowed to settle, like a primary clarifier. This tank provides an area to concentrate the sludge. Thence, the influent travels to an anoxic equalization tank that is used to retain and equalize peak influent flows and provide denitrification. Within the anoxic basin, two (2) pumps transfer the wastewater to the SBR tank. The SBR tank has an aspirating jet aerator that delivers oxygen to the system. Each cycle of treatment consists of fill/react, interact/react, settle, and decant phases. The phases of treatment are controlled by a Programmable Logic Controller, or PLC, that the operator can adjust manually to provide optimum treatment in each phase. Disinfection of the wastewater is achieved through a chlorine contact tank. Sodium hypochloride is dosed into the decant pipe during the decant phase, then it is dechlorinated with sodium thiosulfate before entering the Arroyo Hondo through a 10-inch closed conduit with a rip rap area below the conduit to minimize erosion and provide velocity dissipation. The disinfected effluent is metered by an ultrasonic flow meter and Palmer Bowles Flume as well. Sludge is removed from the sludge tank with a vacuum truck and transported to the Santa Fe Wastewater Treatment Plant (NM0022292) for final disposal. Rags and debris from the bar screen are transported to the Ranchland Utility WWTP (NM0030368) in Rancho Viejo for disposal. The WWTP also maintains a groundwater discharge permit issued by the New Mexico Environment Department (NMED) Groundwater Quality Bureau under permit number (DP-1532). Section II - OBSERVATIONS I observed the following and/or the following information was provided and/or stated: No facility staff were onsite and the major components of the WWTP are located within a locked building or beneath locked hatchways. A Fluidyne manufactured and supplied PLC, which is connected to a Mission Communications unit that sends out emails for alarm conditions and other process controls. There are two (2) back-up generators onsite, but it is not clear which one (1) can operate the WRF and lift station as stated in the Request for Information (RFI) response. The WRF did have perimeter fencing, but not around the adjacent wet well or lift station. The overall housekeeping of the WWTP grounds and ancillary appurtenances exhibited considerable vegetative overgrowth. Oshara does have and did provide a copy of their written policies and procedures to address potential sanitary sewer overflow events (SSOs) and maintains minimal standard operating 3 Oshara Mutual Domestic Wastewater Association / Oshara Village Water Reclamation Facility Permit No. NM0030813 Inspection Date 06/08/2023 procedures (SOPs) pertaining to facility operations and maintenance (O&M), inclusive of daily visual checks of the WRF treatment processes and lift station. Effluent totalizing flow meter readings are recorded daily. The WRF clarified their hours of operation; their offices are open from 8:00am - 5:00pm, with 24/7 for emergencies, though they did not delineate current staffing levels. The WRF clarified the type of electronic monitoring utilized in operating the WWTP (i.e., SCADA, PLC, etc.) and how the operator is alerted to a WRF situation/event. There is a Fluidyne manufactured and supplied PLC, which is connected to a Mission Communications unit that sends out emails for alarm conditions and other process controls. Section III - AREAS OF CONCERN I observed the following and/or the following information was provided and/or stated: A review of the submitted Integrated Compliance Information System (ICIS) Discharge Monitoring Reports (DMR) data for the period October 31, 2019, through June 30, 2023, indicates numerous NPDES permit excursions with respect to Total Suspended Solids (TSS) and 5-day Biological Oxygen Demand (BOD5) (Appendix 2 ICIS E90 Effluent Violations). The following additional areas of concern (AOCs) were identified: Extensive vegetative overgrowth throughout the facility area was visible, which could potentially attract rodents and/or vermin; thus, causing undermining of the facility structures. There are two (2) back-up generator onsite, but their operational status is unknown. No facility personnel were onsite and locked doors prevented ready access. EPA Region 6 David Esparza did not conduct a closing conference at the Oshara Village Water Reclamation Facility as no facility staff were on-site. Section IV - FOLLOW UP The following information was received by EPA on June 16, 2023, in response to a Request for Information (RFI), after exiting the Facility on June 8, 2023: Electronic copy of Oshara's Sanitary Sewer Overflow (SSO) protocol and a statement regarding previous SSO events. Electronic copy of Oshara's Standard Operating Procedures (SOPs) Electronic copy of the facility Site Map delineating the total area footprint, locations/volumes of any on-site fuel storage tanks, delineation of processes (i.e., headworks, EQ basins, chlorination, etc.), all associated ancillary equipment and outfall(s). Identification of the quantity and location of any lift stations (LS), wet wells etc. Electronic copies of calibration and maintenance records for your ultrasonic flow meter, inclusive of serial numbers (S/N) for the previous three (3) years. Electronic copies of your flow measurement record for the previous 1-year period. Clarification of which of the two (2) generators observed are utilized for back-up power, 4 Oshara Mutual Domestic Wastewater Association / Oshara Village Water Reclamation Facility Permit No. NM0030813 Inspection Date 06/08/2023 and how often they (it) are exercised. Additionally, clarification if the back-up generator can operate the entire WWTP or only a portion of it. This is shown on the site plan. Yes, the generator can operate the entire WWTP including the lift station. Electronic copies of your analytical analysis reports for the previous two (2) years, both internal and external. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 6 photos taken 6/08/2023. Appendix 2 - ICIS E90 Effluent Violations Appendix 3 - Oshara Village WRF Site Plan Drawings 5 Oshara Mutual Domestic Wastewater Association/ Oshara Village Water Reclamation Facility Permit No. NM0030813 Inspection Date 06/08/2023 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Oshara Village Water Reclamation Facility City: Santa Fe County/Parish: Santa Fe State: New Mexico View of the Water Reclamation Facility treatment process equipment located in below ground locked hatchways along the approximate south side of the locked building. Note: the back-up generator, the extensive vegetative overgrowth and inside view of perimeter fencing. (DSCN2540) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Oshara Village Water Reclamation Facility City: Santa Fe County/Parish: Santa Fe State: New Mexico Note the additional back-up generator, the extensive vegetative overgrowth and outside view of perimeter fencing looking approximately Northeast. (DSCN2542) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Oshara Village Water Reclamation Facility City: Santa Fe County/Parish: Santa Fe State: New Mexico View of the Operators Building and electrical transformer looking approximately South and indicated on Frachetti Site Plan (Appendix 3 Oshara Village Site Plan). What is not defined or described is the polytank. (DSCN2546) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Oshara Village Water Reclamation Facility City: Santa Fe County/Parish: Santa Fe State: New Mexico View of the adjacent wet well located at the approximate Northwest corner of the Operators Building. Note: the lack of perimeter fencing and vegetative overgrowth. (DSCN2551) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Oshara Village Water Reclamation Facility City: Santa Fe County/Parish: Santa Fe State: New Mexico View of the Oshara Village WRF individual lift station located approximately 600-feet Northwest the WRF Facility. Note: the lack of perimeter fencing and the locked hatchway. (DSCN2552) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Oshara Village Water Reclamation Facility City: Santa Fe County/Parish: Santa Fe State: New Mexico View of the Oshara Village WRF individual lift station electrical box. Note: the exposed wiring (no conduit). (DSCN2556) Photographed by D. Esparza Oshara Mutual Domestic Wastewater Association/ Oshara Village Water Reclamation Facility Permit No. NM0030813 Inspection Date 06/08/2023 Appendix 2 Review of the ICIS E90 Effluent Violations E90 Effluent Violations NM0030813 OSHARA VILLAGE WRF Monitoring Period End Date 10/31/2019 02/29/2020 02/29/2020 02/29/2020 02/29/2020 03/31/2020 04/30/2020 04/30/2020 04/30/2020 04/30/2020 02/28/2021 08/31/2022 06/30/2023 Perm Feature ID 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 Parameter Desc Statistical Base Short Desc Solids, total suspended 30DA AVG BOD, 5-day, 20 deg. C 30DA AVG Solids, suspended percent rem MO AV MN Solids, total suspended 30DA AVG Solids, total suspended 7 DA AVG Solids, suspended percent rem MO AV MN Solids, suspended percent rem MO AV MN Solids, total suspended 30DA AVG Solids, total suspended 30DA AVG Solids, total suspended 7 DA AVG BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, 20 deg. C 30DA AVG Limit Unit Short Desc mg/L mg/L % mg/L mg/L % % lb/d mg/L mg/L mg/L mg/L mg/L Limit Value 30. 30. 85. 30. 45. 85. 85. 7.51 30. 45. 30. 30. 30. DMR Value Qualifi er Code DMR Value = 35. = 36. = 84. = 65. = 65. = 66. = 83. = 8.02 = 58. = 58. = 42. = 41. = 32.6 Reported Number of Excursions 1 1 1 1 1 1 1 1 1 1 1 1 1 Oshara Mutual Domestic Wastewater Association/ Oshara Village Water Reclamation Facility Permit No. NM0030813 Inspection Date 06/08/2023 Appendix 3 Oshara Village WRF Site Plan Drawings