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1 EPA ft . .- . . . "' United States Envlronm&ntel Protecllon Agen~ Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT - Inspection Date(s): 06/12/2014 - Media: Water - Regulatory Program(s) CWA Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Harper Valley Home Owners Association Harper Valley HOA WWTP East side of Road 6070 Farmington, New Mexico 87401 #90 Road 6050, NBU #1001 Farmington, New Mexico 87401 San Juan County Larry Hathaway _I hatb_a'!Y..?Y.~ilsjco uclty. net I President o! HOA FRS Number: N/A Identification/Permit Number: N/A Media Number: NM0029025 - NAICS: 221320 SIC: 4952 Facility Representatives: EPA Inspectors: Larry Hathaway Daniel Flack, P.E. Juan Ibarra President of HOA Valley Water & Sanitation District I Consultant Env. Scientist/6EN-WR State lnspector(s): N/A Other lnspector(s): N/A 505-334-4550-~---- 505-598-5163 214-665-8493 Title: ro -"0ro -~uthor: ro <)) Subject: -2 --~--- Keywords: EPA Lead Inspector Signature/Date Supervisor Signature/Date - - Harper Valley Home Owners Association Harper Valley HOA WWTP Farmington San Juan County New Mexico US EPA Region 6 Compli~nce Assuran~e and EnforcementDivision Dallas TX -Inspection Report Clean Water Act CWA National Pollutant Discharge Elimination System NPDES Wastewater Treatment Facility WWTF - -?/ ic P//T//1 -~//.A.. / L {lnsb)e"ctor'n'amel ' .,_,, . I .. .!%~~ {Supervisor name} -----" 16~{~6/201____ I &/..2.; /;<? Date -~ - - "---~ 6ENFOHM019-R5 (2/3/14) 2 Harper Valley Home Owners Association I Harper Valley HOA WWTP Inspection Date 06/12/2014 Section I -INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspector Juan Ibarra arrived at the Harper Valley Home Owners Association (HOA)/Harper Valley HOA WWTP at 0920 on June 12, 2014 for an announced inspection. I met with Mr. Larry Hathaway/President of the Harper Valley HOA at the Opening Conference, and later met with Mr. Daniel Flack, P.E. to discuss a potential sewer line connection to the Valley Water and Sanitation District lift station which pumps wastewater to the City of Farmington POTW. I presented my credentials to Mr. Hathaway and informed him that this was an EPA inspection to determine compliance with the facility's EPA NPDES permit and the Clean Water Act (CWA). The scope of the inspection was to conduct a Compliance Evaluation Inspection (CEI), which included an evaluation of the facility's compliance with their permit discharge limits, operational management of the plant, process control, laboratory data and records management. FACILITY DESCRIPTION The Harper Valley HOA wastewater treatment plant (WWTP) is a 0.096 MGD (design capacity) minor activated sludge plant with an off-site neighborhood lift station that receives flow from a residential housing development of 135 homes. The lift station, which lacks protective fencing and locks on the wet well, has a visual alarm (light beacon) and about 10 hours of holding capacity should it experience an electrical or mechanical failure (depending on the time of day and flow rates). Otherwise, there is no back-up power at the WWTP or lift station. Wastewater enters the single aeration basin (equipped with a fixed mechanical aerator on timer, but no bar screen), and discharges thru an effluent weir and channel to the clarifier. The clarifier has a traveling bridge sludge removal system which operates in-place every two hours. The operator (Mr. Mike West, 505-801-1534-not present during the inspection) tends to the WWTP three times a week during evening hours, at which time he runs the traveling bridge back and forth. Effluent from the clarifier weirs enters the chlorine contact chamber, followed by the effluent weir box and outfall. Solids from the clarifier are either returned (Return Activated Sludge) to the aeration basin or wasted (Waste Activated Sludge) to the aerobic digester. Disinfection is accomplished by mixing HTH chlorine tablets in a drum, and feeding chlorine via a continuous drip dosing system, followed by sodium bi-sulfite tablets for de-chlorination prior discharge to the San Juan River Section II - OBSERVATIONS lift Station The lift station lacks protective fencing and locks on the wet well. Otherwise, the lift station appeared to be working normally, and did not show any signs of overflows. 2 3 Harper Valley Home Owners Association I Harper Valley HOA WWTP Inspection Date 06/12/2014 General WWTP Condition The WWTP, which was built in the late 1970's (according to Mr. Hathaway), is showing signs of metal deterioration such as worn weirs, a missing bar screen, and recently replaced clarifier Return Activated Sludge (RAS)/Waste Activated Sludge (WAS) line (due to metal deterioration which may indicate a similar condition of the bottom clarifier scrapper). As such, the facility is over 30 years old, and is reaching the end of its useful life unless funds are committed to a WWTP capital improvement project. Also, the plant no longer has a bar screen to keep debris from entering the WWTP. The clarifier sludge line was replaced in 11/2013. Operations Effluent solids have accumulated in the chlorine contact and effluent weir basins due to solids carry-over from the clarifier. The clarifier may be discharging excessive solids into the chlorine contact and effluent weir basins because the traveling bridge traverses the clarifier basin only when the operator arrives to maintain the facility for short periods of time (three days a week). Although the clarifier traveling bridge is operable, and runs in-place (without moving across the clarifier) every two hours, solids may be building up in the rest of the clarifier length, adversely affecting effluent quality. At the time of the inspection, pin floc and solids carry-over were observed significantly contributing to the facility's numerous and significant E. coli and fecal coliform violations. As such, more frequent removal of accumulated solids in the chlorine contact and effluent weir basins is required to eliminate the numerous bacterial effluent violations. Additionally, the facility needs to obtain a sludge judge to assess the amount of solids accumulation in the clarifier, in order to determine the effectiveness of their current solids removal procedures, and if required, make adjustments as to how often the traveling bridge solids removal system is operated. Excessive old sludge will bulk to the surface and increase solids carry-over to the chlorine contact basin, thus reducing disinfection potential and solids discharged to the outfall. Process Control Additional process control is required to determine the frequency of solids wasting, sludge age (or MCRT for solids inventory), and solids accumulation in the clarifier, chlorine contact and effluent weir basins. The plant operator currently estimates their solids management based on visual appearance of the RAS and WAS. Other process control testing would include, but not be limited to, 30-minute settleability, mixed liquor suspended solids (MLSS), clairifier sludge judge, DO, etc. Additionally, the operator must assess the chlorine residual after the 20-minute disinfection basin hold time. The residual after 20 minutes must be at least 1.0 mg/1, however, the facility does not currently know what the chlorine residual is after disinfection, prior to de-chlorination. Also, the facility lacked a sludge judge to evaluate its solids blanket levels in the clarifier. 3 4 Effluent Violations Harper Va lley Home Owners Association I Harper Val ley HOA WWTP Inspection Date 06/12/2014 The tables be low, for t he discharge period of 1/1/2011 to present, show that the facility has had numerous effluent violations. There are seven quarters (Q) of BOD violatio ns, ten Q of TSS violations, twe lve Q of E. coli vio lations, t hree Q of TDS violations, and seven Q of feca l coliform vio lations. 00310 BOD, 5-day, 20 deg. C I Location 1 1Season 0 I Base 00530 Solids, total suspended I Location 1 I Season 0 I Base 4 5 Harper Valley Home Owners Association I Harper Va lley HOA WWTP Inspection Date 06/12/2014 51040 E. coli I Location 1 I Season 0 I Base 70295 Solids, total dissolved I Location VI Season 0 I Base 5 6 Harper Valley Home Owners Association I Harper Valley HOA WWTP Inspection Date 06/12/2014 74055 Coliform, fecal general/ Location 1 I Season 0 I Base Solids Management Sludge has not been pumped out of the aerobic digester in about 18 months. Vacuumed so lids are sent to the City of Farmington WWTP for disposal. Records The facility failed to take the first Q WWTP effluent sample in 2014, and mistakenly reported the April 22, 2014 sample as the first Q sample on the DMR. A revised DMR must be subm itted for the first Q, indicating that no sample was taken. Additionally, EPA records indicate that no DMR was received for the fourth Q of 2011. Mr. Hathaway was informed to make this submission if he finds the paperwork. Also, the pH buffer bottles (4, 7, and 10) were not marked with an expiration date. Permit The WWTP is operating under its expired permit, wh ich has not been reissued by EPA. The permit (NM0029025) expired on 6/30/2011. EPA issued a Cease and Desist Adm inistrative Order on 2/5/2013 (CWA-06-2013-1757) for discharging treated effluent to the San Juan River without a permit. In response, the facility app lied for permit renewal. The application, which has been rece ived by EPA Permits Section (Tung Nguyen), was dated 3/6/2013. The proposed permit will go out for public comment on 6/28/2014. 6 7 Harper Valley Home Owners Association I Harper Valley HOA WWTP Inspection Date 06/12/2014 Plans for Future lift Station Connection to Farmington At this time, Mr. Hathaway states that the HOA is seeking State funding to construct a 6" force main sewer line connection to the Valley Water & Sanitation District lift station, located about 6675' from the current HOA lift station. The force main project is estimated to cost about $600,000, and a preliminary engineering report is being developed at this time. Therefore, the Harper Valley HOA will have to decide between the lift Station connection to the City of Farmington and decommissioning of the WWTP, or a rehabilitation of the current WWTP to achieve its permit limits. Section Ill- AREAS OF CONCERN The following areas of concern were observed during the inspection, and summarized during the exit interview with Mr. Hathaway. Operations and Maintenance concerns include the aging WWTP which appears to be approaching the end of its useful life unless a capital improvement project is initiated, or the HOA decides to connect to the City of Farmington WWTP. The WWTP is missing its bar screen, and has an unsecured lift station which lacks fencing and locks on the wet well door. The plant does not have a sludge judge to evaluate clarifier solids accumulation. A sludge judge is needed to help evaluate whether the operational strategy of only moving the traveling bridge three times a week is adequate to prevent excessive solids accumulation at the bottom of the clarifier, or if operation and process adjustments are required to properly manage RAS and WAS solids. The plant appears to have solids carry-over which is contributing to the numerous and significant bacterial permit exceedances. The facility does not have sufficient process control to optimize plant performance, including a lack of knowledge as to whether there is a chlorine residual at the end of the disinfection basin, sludge age, settleability, DO, etc. The WWTP has had numerous effluent violations for the evaluation period of 1/1/2011 to present. The facility has several DMR reporting violations. The facility failed to take the first Q WWWTP effluent sample in 2014, and mistakenly reported the April 22, 2014 sample as the first Q sample on the DMR. Additionally, EPA records indicate that no DMR was received for the fourth Q of 2011. Also, the pH buffer bottles were not labeled with the expiration dates. The WWTP is operating and discharging treated effluent to the San Juan River with an expired permit. Also, the plant operator does not hold any Wastewater Certifications from the State of New Mexico. 7 8 Harper Valley Home Owners Association I Harper Valley HOA WWTP Inspection Date 06/12/2014 Section IV- FOLLOW UP The inspection report will be forwarded to the Enforcement Officer to determine whether an enforcement action will be taken. Section V -LIST OF APPENDICES Appendix 1-3560 Cover Sheet 8 9 Harper Valley Home Owners Association I Harper Valley HOA WWTP Inspection Date 06/12/2014 Appendix 1 3560 Cover Sheet 9 10 EPA Transaction Code 1~ 2 l_sj United States Environmental Protection Agency Washington D.C. 20460 NPDES Compliance Inspection Report Section A: National Data System Coding NPDES 3 IN ll'j 0 I0 12191 0 1 21 51 11 yr/mo/day 12 11 I4 I0 16 I1 I2 I 17 . Inspection Type 18Lj Inspector 19~ 21 I s I I lc I lc lo ID I E I : I 4 19 I 5 12 I I I I I I I I 66 Fac Type 20 L~ Inspection Work Days 671 I I 169 Facility Evaluation Rating 70 L!J Ill 71 ~ QA 72~ ------------------------Reserved---------------------------------- 73 I I I 74 751 I I I I I I so Section B: Facility Data Name and Location of Facility Inspected Entry Time/Date Harper Valley Home Owners Association WWTP is located within the 0920 I 6112114 Harper Valley Subdivision, at the far east end of Road 6070, in Farmington, San Juan County, New Mexico. Exit Time/Date 1230 I 61121l4 Namc(s) of On-Site Representatives Tit!e(s) Larry Hathaway President of Harper Valley HOA Daniel Flack, P.E. Valley Water & Sanitation Dist.IConsultant Name, Address of Responsible OffiCial Title Larry Hathaway President of Harper Valley HOA Harper Valley Home Owners Association #90 Road 6050 NBU #1001 Phone Number 505-334-4550 I Contacted: Farmington, NM 87401 Section C: Areas Evaluated During Inspection u Permit u Records/Reports u Facility Site Review u Effluent/Receiving Waters s 1--M 1----- N 1--- N '------ (S = Satisfacto!y, M ""Mar ina!, U = Unsatisfactmy, N =Not Evaluated N Flow Measurement Storm Water s - N Self-Monitoring Program N N Compliance Schedules Laboratory M Sludge Handling/Disposal 1----- - Pretreatment 1--- - u Operations & Maintenance '------ - Section D: Summar' of Findinos/Commcnts (Attach additional sheets if necessary) Permit Effective Date -- 07101106 Pennit Expiration Date Phone 06130111 I 505-334-4550 I I 505-598-5163 YES X NO ----- -- CSO/SSO (Sewer Overflow) Pollution Prevention I Multimedia I The facility had numerous Areas of Concern which are detailed in the attached inspection report (page 7). I i Attachments: Inspection report Name(s) and Signaturc(s) of lnspector(s) Juan Ibarra Signature u1 Agency/Office/Telephone US EPAI6EN-WR/(214) 665-8493 Date 26 June 2014 I !ICC US EPA/6EN-WR -- Date - - - - .