Document jmbDr81k8pQd91941neZwE9R9

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 02/24/2025 - 02/25/2025 Drinking Water Safe Drinking Water Act (SDWA) System Owner System Name: System Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: City of Deming, NM Deming Municipal Water System 1275 E Pine St Deming, NM 88030 P.O. Box 706 Deming, NM 88031 Luna County (575) 694-5419 Joel Amaya Public Works Administrative Assistant and Water Operator jamaya@cityofdeming.org FRS Number: System Classification: PWS ID: 110013115681 Community Water System (CWS) NM3528616 Personnel participating in inspection: Chelo Hall EPA Region 6 Chris Padilla ERG Maura Harbaugh ERG Joel Amaya City of Deming Anthony Myers Cam L. Shult Windia Cassy Archie Heddleston City of Deming City of Deming City of Deming City of Deming Enforcement Officer Inspector Inspector Public Works Administrative Assistant and Water Operator Water Operator Senior System Analyst Public Works Administrative Assistant Water Superintendent EPA Lead Inspector Signature/Date Chris Padilla 3/26/25 Supervisor Signature/Date RUBEN ALAYON-GONZALEZ Date: 2025.04.25 08:48:35 -05'00' Digitally signed by RUBEN ALAYON-GONZALEZ {Supervisor name} Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I. - INTRODUCTION City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 PURPOSE OF THE INSPECTION On February 24, 2025, the United States Environmental Protection Agency (EPA) and EPA contract inspectors from Eastern Research Group, Inc. (ERG) (hereinafter, the EPA inspection team) conducted an announced Compliance Evaluation Inspection under Section 1445 of the Safe Drinking Water Act (SDWA), 42 U.S.C. 300j-4, of the Deming Municipal Water System (hereinafter, the System) (NM3528616). The inspection process began at approximately 8:00 AM on February 24, 2025 and finished at approximately 2:15 PM on February 25, 2025. Chris Padilla presented credentials to Joel Amaya, Public Works Administrative Assistant and Water Operator, as well as several other City of Deming personnel, including Anthony Meyers, Cam L. Shult, and Windia Cassy, during the opening conference. The EPA inspection team informed the System that this was an EPA inspection to determine compliance with the SDWA and other applicable federal and state regulations. The EPA inspection team also informed the System representative that they would be conducting a cybersecurity evaluation alongside the SDWA Section 1433 review of the System's Risk and Resilience Assessment (RRA) and Emergency Response Plan (ERP). To facilitate the inspection process, the EPA inspection team used a checklist outlining the requirements of SDWA Section 1433 during the document review. Refer to Appendix 2, Inspection Sign-in Sheet. SYSTEM DESCRIPTION The System is a groundwater system drawing from the Mimbres aquifer with disinfection utilizing calcium hypochlorite as the only treatment process. The System has a water right allowance of 6,363 acre-feet per year of water withdrawals and 2,892 acres of land with irrigation rights. The infrastructure consists of nine active wells equipped with centrifugal sand separators and calcium hypochlorite feed systems for disinfection, three storage tanks (one with a 3-million-gallon (MG) capacity and two with 0.5 MG capacity), and one booster pumping station. No consecutive systems or interconnections are connected to the System; however, the Columbus water system does pull from the same aquifer downgradient. The System has two inactive wells: Well #18 (Refer to Appendix 1, Photographs 1 and 2), that is fully capped with plans to be brought back into service Well #11 (Refer to Appendix 1, Photographs 3 and 4), that is not currently in service and not capped. According to System representatives, all well sites are included in a capital improvement project to install online chlorine residual analyzers. A Mayor-Council form of municipal government oversees the System with an appointed Public Works Director. The System creates annual budgets and presents to decision makers for approval, along with an updated 40-year capital improvement plan. 2 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Certified operators staff the system 24 hours per day, seven days per week. The System is staffed with one Level 1 water supply operator, two Level 3 water supply operators, and one Level 4 water supply operator. The Level 1 operator is currently working toward recertification, as their credentials had expired at the time of the inspection. The System serves a population of 16,236 with 6,127 service connections through a distribution system constructed primarily of polyvinyl chloride (PVC) pipe, with some asbestos cement, ductile iron, and steel pipe. It is a community water system as defined by 40 C.F.R., Part 141 Subpart A. The System has the following assets (Note: numbers shown in parentheses are the facility identification numbers assigned by the New Mexico Environment Department): Well #1 (001) - Well #1 pumps water to Treatment Plant #1 (015) for sand removal and disinfection. Well #1 is controlled by a local SCADA system that monitors the on-site Well #1 Tower (029) water level, an elevated tank with a 0.5 MG capacity that floats on the system. The treated water is then directed to the distribution system or stored in the Well #1 Tower. Well #2 (002) - Well #2, referred to as the North Zinc well, is manually operated and pumps water to Treatment Plant #2 (022) for sand removal and disinfection. The treated water is then directed to the distribution system. Well #5 (005) - Well #5, referred to as the Martin School well, is manually operated and pumps water to Treatment Plant #5 (021) for sand removal and disinfection. The treated water is then directed to the distribution system. Well #6 (006) - Well #6, referred to as the South Iron well, is manually operated and pumps water to Treatment Plant #6 (017) for sand removal and disinfection. The treated water is then directed to the distribution system. Well #7 (007) - Well #7, referred to as the Grand well, is manually operated and pumps water to Treatment Plant #7 (018) for sand removal and disinfection. The treated water is then directed to the distribution system. Well #9 (009) - Well #9, referred to as the Ash & Grand well, is manually operated and pumps water to Treatment Plant #9 (024) for sand removal and disinfection. The treated water is then directed to the distribution system. Well #10 (010) - Well #10, referred to as the Airbase well, is manually operated and pumps water to Treatment Plant #10 (020) for sand removal and disinfection. The treated water is then directed to the distribution system. Well #11 (011) - Well #11, referred to as the E. Florida well, is designed to pump water to Treatment Plant #11 (014) for sand removal and disinfection. Well #11 is currently inactive and was not in service 3 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 during the inspection. Well #11 is controlled by a local SCADA system that monitors the on-site Well #11 Tower (028) water level, an elevated tank with a 0.5 MG capacity that floats on the distribution system. The treated water is then directed to the distribution system or stored in the Well #11 Tower. Well #15 (027) - Well #15, referred to as the Peru Mill well, is SCADA-controlled and pumps water to Treatment Plant #15 (034) for sand removal and disinfection. The treated water is then directed to the distribution system. Well #17 (032) - Well #17, referred to as the Bilbo well, is SCADA-controlled and pumps water to Treatment Plant #17 (033) for sand removal and disinfection. The treated water is then directed to Storage Tank #3 (035), a 3-MG capacity reinforced wire-wound concrete tank, and then to the distribution network and the booster pump station. Section II. - INSPECTION ACTIVITY SUMMARY The EPA Inspection Team conducted an array of interviews and field activities to discuss and observe the System's operation and maintenance activities and to assess the condition of drinking water system assets. The physical inspection occurred over two days. The System provided some documents before the inspection. The information in this report is based on document review, conversations with system representatives, and observations made during this inspection. After the opening conference of the inspection, the EPA Inspection Team inquired about the technical, managerial, and financial capacity of the System, including a review of operator certifications, an overview of the water system, asset management, and source water protection. A review of programmatic topics followed, including a review of monitoring/reporting requirements and results associated with the Revised Total Coliform Rule (RTCR), Disinfection Byproducts (DBP) Rule, Lead and Copper Rule (LCR), LCR Revisions (LCRR), LCR Improvements (LCRI), per- and polyfluoroalkyl substance requirements, inorganics, volatile and semi-volatile organic chemicals, and radionuclides. The System representatives described their records' retention policy and the annual development of the Consumer Confidence Report. The EPA Inspection Team subsequently reviewed distribution system items with the System representatives, such as their Cross-Connection Control Program, tank inspections, hydrant flushing and valve exercising programs, water main break and customer complaint logs, mapping, metering, and water loss audits. The EPA inspection team also reviewed the System's Section 1433 RRA and ERP and the System's cybersecurity practices. 4 VIOLATIONS - LAST FIVE YEARS City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Table 1 provides a summary of the System's violations as identified in New Mexico Drinking Water Watch for the last five years. Table 1. SDWA Violations for Compliance Periods between January 2020 and January 2025 (data pulled on 3/19/2025) Determination Violation Date Type Violation Name Analyte Analyte Name Code 08-22-2024 3A MONITORING, ROUTINE, MINOR (RTCR) 3014 E. COLI 08-14-2024 27 MONITORING, ROUTINE (DBP), MAJOR 0999 CHLORINE FIELD ASSETS Field assets were inspected on February 25, 2025, day two of the inspection. Observations related to field assets are included in Section III - OBSERVATIONS. Well #1 Tower and Wellhouse Well #1 Tower and Wellhouse are located within the Water Utility Shop facility, a fenced yard with utility equipment and storage. The 0.5 MG elevated Well #1 Tower was last inspected in 2019 and is scheduled to be recoated in fiscal year 2026. The EPA Inspection Team observed that Well #1 Tower's overflow pipe (Refer to Appendix 1, Photographs 5 and 6) was not air-gapped and was plumbed directly to a buried pipe that was also connected to Well #1's de-sanding unit waste line. The line terminated north of the Shop facility grounds with no screen and a flapper valve that did not rest flush to the pipe, creating a gap for contaminant entry. The EPA Inspection Team also noted a threaded finished water sample tap in the wellhouse (Refer to Appendix 1, Photograph 7). The EPA inspection team observed that the calcium hypochlorite feed room had an open electrical box with exposed wiring, no ventilation (automatic or manual), a chemical container open to atmosphere, and no secondary containment for the chemical tank (Refer to Appendix 1, Photographs 8, 9, 10, and 11). The eyewash station was inoperable, according to System representatives. A portable generator was stored at the site and was available to be transported to well sites affected by power failures (Refer to Appendix 1, Photograph 12). Well #15 The EPA Inspection Team observed that the calcium hypochlorite feed room had no ventilation (automatic or manual), a chemical container open to room atmosphere, and no secondary containment 5 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 for the chemical tank (Refer to Appendix 1, Photograph 13). The EPA Inspection Team also noted a threaded finished water sample tap in the wellhouse. Well #5 The EPA Inspection Team observed that the calcium hypochlorite feed room had no ventilation (automatic or manual), a chemical container open to room atmosphere, and no secondary containment for the chemical tank (Refer to Appendix 1, Photograph 14). A lack of proper screening on the well air relief valve was noted by the EPA Inspection Team (Refer to Appendix 1, Photograph 15). The EPA Inspection Team observed threaded finished water sample taps with no vacuum breakers or smoothnosed style spigots (Refer to Appendix 1, Photograph 16). System representatives stated that the chlorine residual target at this well site was 0.4 milligrams per liter (mg/L). Well #2 Well #2 is a seasonal use well capable of producing 350 gallons per minute (gpm) when demand dictates. A permanently installed natural gas generator is on-site. The EPA Inspection Team observed that the calcium hypochlorite feed room had no ventilation (automatic or manual), a chemical container open to room atmosphere, and no secondary containment for the chemical tank (Refer to Appendix 1, Photographs 17 and 18). The well pump-to-waste discharge line was equipped with a coarse screen, and the well vent screen was torn (Refer to Appendix 1, Photographs 19 and 20). The EPA Inspection Team observed old hose connections attached to the well discharge line (Refer to Appendix 1, Photograph 21). The well discharge line had threaded finished water sample taps with no vacuum breakers or smoothnosed style spigots (Refer to Appendix 1, Photograph 22). The EPA Inspection Team also observed an uncapped opening on the well, which served as a sounding port according to the System representatives. Well #18 Well #18 was visited but not inspected as it was out of service at the time of the inspection (Refer to Appendix 1, Photographs 1 and 2). Well #11 and Tower Well #11 Tower and Wellhouse are located within the Water Utility Maintenance facility, a fenced yard with utility equipment and storage. Well #11 was out of service at the time of inspection, however planned to be back in operation in fiscal year 2026, according to the System representative. The 0.5 MG elevated Well #11 Tower was last inspected in 2019 and is scheduled to be re-coated in fiscal year 2026. The EPA Inspection Team observed that Well #11 Tower's overflow pipe was not air gapped and was plumbed directly to a buried pipe that was also connected to Well #11's de-sanding unit waste line. The EPA Inspection Team noted a threaded finished water sample tap in the wellhouse and an unsecured 6 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 bucket covering the opening where the well pump and motor would normally stand (Refer to Appendix 1, Photographs 3 and 4). The EPA Inspection Team observed that the calcium hypochlorite feed room had no ventilation (automatic or manual), a chemical container open to room atmosphere, and no secondary containment for the chemical tank (Refer to Appendix 1, Photograph 23). Well #17 The EPA Inspection Team observed that the calcium hypochlorite feed room had no ventilation (automatic or manual), a chemical container open to room atmosphere, and no secondary containment for the chemical tank (Refer to Appendix 1, Photograph 24). A lack of proper screening on the well discharge line was noted by the EPA Inspection Team. Inspectors observed threaded finished water sample taps with no vacuum breakers or smooth-nosed style spigots (Refer to Appendix 1, Photograph 25). Booster Station Five 550 gpm pumps were located in the booster station, which drew water from the 3 MG storage tank for delivery to the distribution system. The pumps utilize power from solar panels, while the grid powers the control systems. 3 MG Storage Tank The EPA Inspection Team noted minor cracks in the outer layers of the tank's coating system (Refer to Appendix 1, Photograph 26). According to System representatives, repairs to the coating system were included in the long-term capital plan. The EPA Inspection Team observed that the tank roof access ladder's first rung was less than 12 feet from ground level. Remaining Well Sites The remaining well sites were not inspected during this inspection. System representatives stated that the remaining sites were of identical construction to the visited well sites. Section III - OBSERVATIONS SDWA 1433(a), 42 U.S.C. 300i-2, Community Water System Risk and Resilience requires a CWS serving more than 3,300 persons to conduct an RRA of its system, including an assessment of: a. the risk to the system from malevolent acts and natural hazards; b. the resilience of the pipes and constructed conveyances, physical barriers, source water, water collection and intake, pretreatment, treatment, storage, and distribution facilities, electronic, 7 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 computer, or other automated systems (including the security of such systems) which are utilized by the system; c. the monitoring practices of the system; d. the financial infrastructure of the system; e. the use, storage, or handling of various chemicals by the system; and f. the operation and maintenance of the system. Observation 1. On February 12, 2025, EPA completed an inspection of the System under SDWA Section 1445, 42 U.S.C. 300j-4. EPA inspectors requested to review the System's RRA and observed the following: a. The document was available at the time of the inspection. b. The RRA was dated to show that it was completed before the date of the certification of completion. c. The RRA did not assess all required elements of Section 1433(a). d. The RRA did not include a complete assessment of the required elements. SDWA 1433(b), 42 U.S.C. 300i-2, Community Water System Risk and Resilience requires a CWS serving more than 3,300 persons to conduct an ERP of its system, including an assessment of: a. strategies and resources to improve the resilience of the system, including the physical security and cybersecurity of the system; b. plans and procedures that can be implemented, and identification of equipment that can be utilized, in the event of a malevolent act or natural hazard that threatens the ability of the CWS to deliver safe drinking water; c. actions, procedures, and equipment which can obviate or significantly lessen the impact ofa malevolent act or natural hazard on the public health and the safety and supply of drinking water provided to communities and individuals, including the development of alternative source water options, relocation of water intakes, and construction of flood protection barriers; and d. strategies that can be used to aid in the detection of malevolent acts or natural hazards that threaten the security or resilience of the system. Observation 2. During the inspection, EPA inspectors also reviewed the System's ERP and observed the following: a. The document was available at the time of the inspection. b. The ERP was dated to show that it was completed before the date of the certification of completion. c. The ERP did not complete all required elements of Section 1433(b). 40 CFR 141.853 General monitoring requirements for all public water systems, (a)(5), states, "Systems must identify repeat monitoring locations in the sample siting plan. Unless the provisions of paragraphs (a)(5)(i) or (a)(5)(ii) of this section are met, the system must collect at least one repeat sample from the sampling tap where the original total coliform-positive sample was taken, and at least one repeat sample at a tap within five service connections upstream and at least one repeat sample at a tap within five service connections downstream of the original sampling site...": 8 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Observation 3. The EPA Inspection Team observed that routine and repeat sampling locations were listed in the sample siting plan for the Revised Total Coliform Rule (RTCR); however, the sample siting plan did not link an upstream and downstream repeat sample sites for every routine sample site location. 40 CFR 141.63(e)(3), Maximum contaminant levels (MCLs) for microbiological contaminants, states, "Proper maintenance of the distribution system including appropriate pipe replacement and repair procedures, main flushing programs, proper operation and maintenance of storage tanks and reservoirs, cross connection control, and continual maintenance of positive water pressure in all parts of the distribution system." Observation 4. The EPA Inspection Team observed that the system had recently created a Hydrant Flushing Plan, which had not yet been implemented. Additionally, the System is unaware of the Fire Department's protocols and procedures for flushing hydrants and does not have communication with them regarding the frequency of flushing. Observation 5. The EPA Inspection Team observed that the system had recently created a valve exercising plan; however, it had not yet been implemented. 40 CFR 141.63(e)(3), Maximum contaminant levels (MCLs) for microbiological contaminants, states, "Proper maintenance of the distribution system including appropriate pipe replacement and repair procedures, main flushing programs, proper operation and maintenance of storage tanks and reservoirs, cross connection control, and continual maintenance of positive water pressure in all parts of the distribution system." Observation 6. The EPA Inspection Team observed that the system did not have a list of annual backflow prevention device testing, nor did it track annual testing or devices that had failed testing and required repair. Additionally, the team observed that although the system had a documented CCCP, the document did not indicate the backflow prevention device testing/inspection frequency. Observation 7. The EPA Inspection Team observed that sampling taps on the discharge side of the wellhouses' piping were threaded rather than smooth-nosed taps or not equipped with atmospheric vacuum breakers, presenting a potential cross-connection. This issue was noted at Wells #1, #15, #5, #2, #17, and #11 (Refer to Appendix 1, Photographs 7, 16, 22, and 25). Not all wellhouses were inspected due to time constraints, but system representatives stated that all wellhouses were constructed similarly. New Mexico Administrative Code 20.7.10.400.P , Cross-connection(s) present at the storage tank, states, "Cross-connections to a public water system or within a public water system shall be prohibited, unless the public water system is protected by a method acceptable to the department using either a device listed in the American society of sanitary engineering "prevention rather than cure" seal authorization booklet or a device acceptable to the department to prevent the back flow of water." 9 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Observation 8. The EPA Inspection Team observed that the overflow piping from both Well #1 Tower and Well #11 Tower were connected to the wellhouses' discharge from the de-sanding cleaning process, presenting a potential cross-connection. Recommended Standards for Water Works (2022 Edition), 2.5, Electrical Controls, states, "...All electrical work shall conform to the requirements of the National Electrical Code or to relevant state and/or local codes." Observation 9. The EPA Inspection Team observed an open electrical box with exposed wiring in the chlorine feed room at Well #1. Recommended Standards for Water Works (2022 Edition), 5.7.1, Ventilation, states, "Special provisions shall be made for ventilation of chlorine storage and feed rooms." Observation 10. The EPA Inspection Team observed that there was no room ventilation initiated by an automatic door switch or manual switch in the calcium hypochlorite feed rooms at all inspected well stations (Refer to Appendix 1, Photograph 18). Recommended Standards for Water Works (2022 Edition), 5.5.11, Day Tanks, states, "Day tanks shall be located in secondary containment areas or over the bulk storage tank secondary containment pallet." Observation 11. The EPA Inspection Team observed that there was no secondary containment for the chemical storage or feed systems in the calcium hypochlorite feed rooms at all inspected well stations (Refer to Appendix 1, Photographs 10, 13, 14, 17, 23, and 24). Recommended Standards for Water Works (2022 Edition), 5.8.4.2.a.2., Storage, states, "Storage containers or tanks shall be located out of the sunlight in a cool area and shall be vented to the outside of the building." Observation 12. The EPA Inspection Team observed chemical storage containers with openings and not vented outside of the building in the calcium hypochlorite feed rooms at all inspected well stations (Refer to Appendix 1, Photographs 10, 13, 14, 17, 23, and 24). New Mexico Administrative Code 20.7.10.400.C, Protection of a public water system well, states, "A ground water supply well serving a public water system shall have a sanitary seal installed at the wellhead to protect against entry of storm water and other non-potable fluids or foreign materials and against access by insects, rodents, birds or other vermin. All vents installed in the well casing shall be protected against entrance of foreign material and flooding. If the well is completed in a subsurface vault, the casing shall extend above the potential flooding height. All cracks, joints or other openings at the wellhead and all penetrations to the casing at or near the ground surface shall be tightly sealed with an impermeable material." Observation 13. The EPA Inspection Team noted that #24 gauge mesh was torn on Well #2 vent (Refer to Appendix 1, Photograph 20). 10 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Observation 14. At the time of the inspection, Well #11 was inactive but was intended to be brought back online. However, the cap temporarily covering the well was not secured and had gaps underneath (Refer to Appendix 1, Photographs 3 and 4). As a result, the cap could easily be lifted or moved, presenting a potential risk for contaminants to enter the well. Recommended Standards for Water Works (2022 Edition), 7.1.7.c, Overflow, states, "The overflow shall open downward and be screened with twenty-four mesh non-corrodible screen. The screen shall be installed within the overflow pipe at a location least susceptible to damage by vandalism. A meshfitted mechanical flap valve is acceptable provided the flapper is supplied with non-corroding and nonseizing hinges. The flap valve shall be spring loaded or counterweighted, so it closes and forms a tight seal after the overflow event." Observation 15. The EPA Inspection Team noted that #24-gauge mesh was not installed on the overflow for the 3MG Storage Tank (Refer to Appendix 1, Photograph 28). Recommended Standards for Water Works (2022 Edition), 5.7.4 (b), Operator Safety. Other protective equipment, states, "An appropriate deluge shower and eye washing device shall be installed where strong acids and alkalis are used or stored." New Mexico Environment Department Recommended Standards for Water Facilities, 5.1.13.j, Chemical Storage and Feed Equipment Housing, states, "Eye wash and deluge showers should be provided at convenient locations." Observation 16. The EPA Inspection Team noted non-functional eyewash stations at inspected wellhouses (#1, #15, #5, #11, and #2). System representatives stated that all wellhouses were of similar construction. Recommended Standards for Waterworks (2022 Edition) 7.1.12.a, Safety, states, "Ladders, ladder guards, balcony railings, and safely located entrance hatches shall be provided. Access to roof hatches and vents shall be provided. When a fixed ladder is used, the bottom shall be located at least 12 feet above ground to prevent the entrance of unauthorized personnel." Observation 17. The EPA Inspection Team noted that the height to the first ladder rung at the 3MG Storage Tank was less than 12 feet from ground level, and there was no locked hatch preventing unauthorized access. (Refer to Appendix 1, Photograph 29). EPA How to Conduct a Sanitary Survey of Drinking Water Systems (2019) 10.4.8, states, "Concrete foundations should be inspected to ensure that there is minimal spalling (ground level tanks) and no cracks (elevated tanks). Anchor bolts should not be rusted so much that their material strength has been compromised. Column shoes should be clean and painted, and grout under the shoes and riser plates should be in good condition. There should not be any pooled water, erosion, weeds, or shrubs around a tank's foundation." 11 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Observation 18. The EPA Inspection Team noted that the foundation of the Well #11 Tower was showing signs of cracking (Refer to Appendix 1, Photograph 30). Section IV - CLOSING CONFERENCE The EPA Inspection Team held a closing conference at 1:55 PM on February 25, 2025, at Deming City Hall. The EPA Inspection Team discussed preliminary observations identified during the field component of the inspection. The EPA inspection team reiterated to the System representatives that these preliminary observations were not compliance determinations. Preliminary observations shared during the closing conference are subject to further investigation by EPA upon the review of additional records and documentation. Therefore, this inspection report may include observations that were not identified at the time of the closing conference. Observations are described in Section III. The EPA inspection team shared observations related to cybersecurity practices with the System verbally. The inspection concluded at approximately 2:15 PM. Section V - FOLLOW UP The following information was requested by the EPA Inspection Team during the inspection and via email on March 5, 2025: Operation and Maintenance Plan - Electronic Copy Updated copies of operator certifications - Electronic Copy Letter from NMED indicating reduced monitoring frequency for DBPs - Electronic Copy Summary of scope of work performed by Electric Supply Source (ESS) - Electronic Copy The requested information was not received as of the writing of the inspection report. The following information was received electronically by the EPA Inspection Team after leaving the System on February 25, 2025: Drinking Water Distribution System Sampling Plan (DSSP) 2022.pdf WELLLayerToKML.kmz (Google Earth file) DigitizedwaterlinesLayerTo1.kmz (Google Earth file) CityWaterTankLayerToKML.kmx (Google Earth file) Section VI - LIST OF APPENDICES Appendix 1 - Photo Log - 30 photos taken 02/24/2025-2/25/2025 Appendix 2 - Inspection Sign-in sheet 12 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 APPENDIX 1 - PHOTO LOG Unless otherwise indicated herein, all photographs were taken by Maura Harbaugh of ERG during the inspection. The displayed date and time are the local time (MST unless otherwise noted). Photographs were not manipulated beyond minor cropping for sizing and adding labels or callouts to draw attention to the subject of the photograph. Not all photographs taken during the inspection are included in the Photograph Log. 13 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: NMSU Public Water System Deming County: Luna State: New Mexico Photograph 1. 02/25/2025 10:04 P2250344.JPG Description: Inactive Well #18. 14 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 2. 02/25/2025 10:04 P2250339.JPG Description: Inactive Well #18 severed discharge line. 15 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 3. 02/25/2025 10:16 P2250339.JPG Description: Inactive Well #11 with an unsecured bucket resting on top of the well opening. 16 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 4. 02/25/2025 09:43 P2250339.JPG Description: Opening to inactive Well #11; well lacks a secured cover. 17 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 5. 02/25/2025 08:34 P2250285.JPG Description: Overflow for Well #1 Tower and waste discharge of de-sanding unit at Well #1. 18 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 6. 02/25/2025 08:35 P2250286.JPG Description: Overflow for Well #1 Tower with a compromised gasket. 19 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 7. 02/25/2025 08:19 P2250267.JPG Description: Threaded sample tap on the Well #1 discharge piping. 20 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 8. 02/25/2025 08:26 P2250277.JPG Description: Chlorine room for Well #1. 21 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 9. 02/25/2025 08:27 P2250279.JPG Description: Chlorine room door for Well #1 with excessive corrosion. 22 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 10. 02/25/2025 08:27 P2250280.JPG Description: Chlorine feed for Well #1 without secondary containment and open to the room atmosphere. 23 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 11. 02/25/2025 08:28 P2250282.JPG Description: Calcium hypochlorite buckets for Well #1. 24 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 12. 02/25/2025 08:40 P2250291.JPG Description: Portable generator located at Well #1. 25 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 13. 02/25/2025 08:40 P2250291.JPG Description: Chlorine room for Well #15 with no secondary containment and with openings in the chemical tank. 26 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 14. 02/25/2025 09:27 P2250317.JPG Description: Chlorine room for Well #5 with no secondary containment and with openings in the chemical tank. 27 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 15. 02/25/2025 09:22 P2250321.JPG Description: Air relief at Well #5 with no mesh. 28 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 16. 02/25/2025 09:22 P2250309.JPG Description: Threaded sample tap on the discharge side of Well #5's piping. 29 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 17. 02/25/2025 09:43 P2250336.JPG Description: Chlorine room for Well #2 with opening in chemical drum and no secondary containment. 30 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 18. 02/25/2025 09:43 P2250339.JPG Description: Chlorine room non-functional automatic ventilation switch for Well #2. 31 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 19. 02/25/2025 09:45 P2250341.JPG Description: Well #2 pump-to-waste discharge line with coarse mesh. 32 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 20. 02/25/2025 09:36 P2250331.JPG Description: Well #2 vent screen with torn mesh. 33 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 21. 02/25/2025 09:39 P2250334.JPG Description: Well #2 with old hose connections. 34 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 22. 02/25/2025 09:39 P2250335.JPG Description: Well #2 discharge line with threaded sample tap with hose connection. 35 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 23. 02/25/2025 10:20 P2250363.JPG Description: Chlorine room for Well #11 with no secondary containment. 36 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 24. 02/25/2025 10:53 P2250387.JPG Description: Chlorine room for Well #17 with no secondary containment and liquid chemical tank open to atmosphere. 37 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 25. 02/25/2025 10:47 P2250383.JPG Description: Threaded sample tap on the Well #17 discharge piping. 38 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 26. 02/25/2025 10:58 P2250397.JPG Description: Minor cracking of 3-MG Storage Tank. 39 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 27. 02/25/2025 10:28 P2250370.JPG Description: Overflow for Well #11 Tower with coarse mesh; Well #11 de-sander waste discharge is connected to the overflow pipe. 40 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 28. 02/25/2025 11:01 P2250402.JPG Description: Overflow for 3MG Storage Tank; unsealed flap valve without a mesh screen. 41 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 29. 02/25/2025 10:58 P2250398.JPG Description: Ladder for 3-MG Storage Tank less than 12 feet from ground level and no locked hatch preventing unauthorized access. 42 City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 Photograph 30. 02/25/2025 10:25 P2250369.JPG Description: Cracking foundation of the Well #11 Tower. 43 APPENDIX 2 - SIGN-IN SHEET City of Deming - Deming Municipal Water System Inspection Dates - 02/24/2025-02/25/2025 44