Document nmLq22j9Z2xBvz2Y8vZ1JarmX

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 05/05/2025 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 Las Cruces Jacob Hands Memorial WWTF 2851 West Amador Las Cruces, New Mexico 88005 680 N. Motel Blvd. Las Cruces, New Mexico 88007 Dona Ana (575) 528-3256 Joaquin Murillo jmurillo@lascruces.gov FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110039926774 NM0023311 N/A 221320 4952 Personnel participating in inspection: Joaquin Murillo City of Las Cruces David Esparza EPA-R6/ECDWM Deputy Director Wastewater/Utilities Deputy Director Wastewater/Utilities Environmental Engineer EPA Lead Inspector Signature/Date Digitally signed by DAVID DAVID ESPARZA ESPARZA David Esparza Date: 2025.06.18 09:48:07 -06'00' Date Supervisor Signature/Date ROBERTO BERNIER Date: 2025.06.18 13:55:12 -05'00' Digitally signed by ROBERTO BERNIER Roberto Bernier Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION City of Las Cruces/ Jacob Hands Memorial WWTF Permit No. NM0023311 Inspection Date 05/05/2025 PURPOSE OF THE INSPECTION United States Environmental Protection Agency (EPA) Region 6 inspector David Esparza, PE, arrived at the City of Las Cruces Public Works Department at approximately 1:00 PM on May 5, 2025, for an unannounced inspection. I presented my credentials to Mr. Joaquin Murillo, City of Las Cruces' Deputy Director Wastewater/Utilities and informed him that this was an EPA inspection to determine the facility's compliance under the Clean Water Act (CWA) and the requirements of the National Pollutant Discharge Elimination System (NPDES) permit program, in accordance with the CWA. The generation of this report is based on information supplied by Las Cruces' representatives, observations made by the EPA inspector, records and reports maintained by the permittee (Las Cruces), and the EPA. Before leaving the facility on May 5, 2025, an exit briefing was held with Mr. Murillo, to explain areas of concern noted at the time of the inspection and discuss the Capacity Management Operations and Maintenance (CMOM) checklist forwarded via electronic mail (email) earlier in our discussion (Appendix 1 Capacity Management Operations and Maintenance Self-Assessment). FACILITY DESCRIPTION The City of Las Cruces-Jacob Hands Memorial Wastewater Treatment Facility (Jacob Hands) (WWTF) is classified as a major discharger with a design capacity of 13.5 million gallons per day (MGD) and an average daily flow of 9.7 MGD, serving a population of approximately 115,000. The facility is located at 2851 W. Amador Avenue, Las Cruces, Dona Ana County, New Mexico (denoted in Aerial Image #1 below). The WWTF treatment process is comprised of a gravity collection system, and 16 lift/pump stations (Identified in Table 1 below). The influent traverses through a mechanical bar screen where large debris is removed, thence to the grit washer and the aerated grit remover where further debris is removed from the influent. Biofilters were installed during the 2009 WWTF expansion for odor control. Influent then flows to the equalization basin, thence to the primary clarifiers. There are two primary clarifiers that rotate operational status every six months. From the primary clarifiers flow enters the roughing filters. There are two aeration basins after the roughing filters, the east and west basins. Final clarifiers are used prior to chlorination and dechlorination. Effluent is then released through a 24" Parshall flume to an unnamed ditch, thence the Rio Grande. The CDM (f.k.a. Camp Dresser and McKee) Master Plan cites the utility department also treats wastewater from areas receiving water service from Doa Ana Mutual Domestic Water Consumers Association (MDWCA), Moongate Water Company, Jornada Water Company, the Town of Mesilla, San Pablo, and New Mexico State University (NMSU). The Master Plan further states the existing collection system is comprised of approximately 500-miles of pipes, inclusive of 39-miles of interceptors with a diameter of 15-inches or greater. Except for the West Mesa Industrial Park wastewater system, these interceptors receive flow from throughout the service area and convey the flow to Jacob Hands. It should be noted the West Mesa Industrial Park Wastewater Treatment Facility (WMIP) is a separate system that receives flows from West Mesa Industrial Park tenants through one central interceptor. The Jacob Hands Waste Activated Sludge (WAS), a by-product of wastewater treatment, is moved to a gravity thickener to concentrate the solids and reduce the volume of sludge, thence to the primary and 2 City of Las Cruces/ Jacob Hands Memorial WWTF Permit No. NM0023311 Inspection Date 05/05/2025 secondary digesters. Bio-solids from the East Mesa WWTF (NM0030872) are also sent to the digester at Jacob Hands. Produced digester gases are sent to the co-generation (CoGen) System. The Jacob Hands processed bio-solid waste is small quantity distributed to the public with excess transported to the West Mesa WWTF for composting. Aerial Image #1: Overall view of the City of Las Cruces'- Jacob Hands Wastewater Treatment Plant. Aerial from Google Earth maps. Table 1: City of Las Cruces-Jacob Hands Memorial Lift Stations Lift Station Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Name Boutz. Brown Craver Chisolm Dove Crossing Frenger Inspiration Mesilla Park Sanctuary Sand Hill Shadow Run Tortugas University Holman Metro Verde 3 Street Address 1716 W. Boutz Road 1811 Brown Road 40125 Willow Glen 379 E Franey 3141 Karen Drive 1801 East Park 7805 Holman Road 201 W Union 4105 W Hwy 28 999 Parkhill 5000 Las Alturas 291 E Tortugas Drive 520 W University 14000 Holman Road 4501 Arroyo City of Las Cruces/ Jacob Hands Memorial WWTF Permit No. NM0023311 Inspection Date 05/05/2025 Lift Station Number 16 Name Jacob Hands Street Address 2851 W Amador Currently there are eight (8) established Industrial Users (IU) that currently discharge their effluent into the City's WWTF (identified in Table 2 below). Table 2: City of Las Cruces-Jacob Hands Industrial Users Name NASA New Mexico State University Memorial Medical Center Southern Root Nuts Company Olam American Linen Johnny's Septic Tank Company 7 Diamond Type of Discharge Industrial Service Education-school Hospital Pecan processing Chile processing Commercial Laundry Dewatered Fats, Oils, and Grease Dewatered Septic Tank Sludge SIC # 9661 8221 8062 5159 2099 7211 4953 562219 Additionally, Las Cruces has written policies and procedures to address land development and specific ordinances regarding the operation of their NPDES permitted facility. Section II - OBSERVATIONS I observed the following and/or the following information was provided or stated: A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment: General Information (page 2)- indicates an average daily flow of 9.7 MGD. A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment: Collection System Information (page 3)- indicates 16 lift or pump station (identified above), and approximately 500miles of gravity sewer lines. The CDM Master Plan indicates that approximately one-third (1/3) of the total piping, equate to or are greater than 10-inches in diameter, are less than 20-years old and that greater than three-fourths (3/4) are less than 30-years old. The Plan further states most of the piping is constructed of vitrified clay pipe (VCP) and polyvinyl chloride pipe (PVC) with the VCP being more common in sewers with diameters less than 15 inches in diameter. Other pipeline materials in this system include cast iron, ductile iron, and reinforced concrete. A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment: Engineering Design (ED) (page 5)- indicates their engineering group involves staff for any comments or concerns with design, surveys are completed prior to construction and taken into consideration during design and planning, and television camera reports are available for all new installation of gravity sewer lines. Additionally, the city is currently updating the locate, (i.e., as-builts) field reports information within the Wastewater line maintenance group (ED-03, ED-06, ED-07 and ED-08). 4 City of Las Cruces/ Jacob Hands Memorial WWTF Permit No. NM0023311 Inspection Date 05/05/2025 A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment: Satellite Communities and Sewer Use Ordinance (SUO) (page 6)- indicates the utility department also treats wastewater from areas receiving water service from Doa Ana Mutual Domestic Water Consumers Association (MDWCA), Moongate Water Company, Jornada Water Company, the Town of Mesilla, San Pablo, and New Mexico State University (NMSU) (SUO-01). A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment: Organizational Structure (OC) (page 8)- indicates 28% of the staff positions are currently vacant (OC-04) and the city is not offering co-op positions now. This number is including new and approved positions currently advertised for recruitment and 5% of the utility work is contracted out (OC-06). A review of the City of Las Cruces-Jacob Hands completed Self-Assessment: Internal Communications (IC) (page 9) indicates the utility does not regularly communicate/coordinate with other municipal departments? (IC-06). A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment: Budgeting (BUD) (page 10)- indicates approximately 8% of the utility `s overall budget is allocated to maintenance of the collection system (BUD-06). A review of the City of Las Cruces-Jacob Hands completed Self-Assessment: Training (TR) (page 12) indicates the utility does not have a formal job knowledge, skills, and abilities (KSA) training program(TR-01), but does have training goals for supervisors and non-supervisors that must be met annually (TR-04). A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment: Equipment & Collection System Maintenance (ESM) (page 17 and page 18 ) indicates the utility does not maintain maintenance schedule records (ESM-02), there is not an established system for prioritizing equipment maintenance needs (ESM-04), corrective repair work orders are not backlogged more than six months (ESM-06), and collection system personnel do not coordinate with state, county, and local personnel on repairs, before the street is paved (ESM-06). A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment: Equipment Parts Inventory (EPI) (page 19) indicates the utility does not have a parts standardization policy in place (EPI-03). A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment: Management Information System (MIS) (page 19 and page 20) indicates the utility is not able to distinguish activities taken in response to an overflow event (MIS-03), there are not written instructions for managing and tracking the complaint work orders, scheduled system inventory, or parts inventory (MIS-04). Additionally, the utility does not have written instructions for tracking procedures pertaining to the following: accessing data and information, instructions for using the tracking system, updating the MIS, or developing and printing reports, though it also states work orders/maintenance records/dates/material used/complaint work orders are maintained by our MIS group and is updated regularly (MIS-05). 5 City of Las Cruces/ Jacob Hands Memorial WWTF Permit No. NM0023311 Inspection Date 05/05/2025 A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment: System Mapping (MAP) (page 21 and page 22) indicates the sewer line maps do not include SSOs occurrences/CSOs outfalls (MAP-04), attributes related to invert elevations, separate/combined sewer or installation dates (MAP-05). Note: the city does not have a combined sewer. Additionally, the System Mapping does not record the following manhole attributes shape, type (e.g., precast, cast in place, etc.) or age (MAP-06). A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment: Internal TV Inspection (TVI) (page 23) indicates there are not written operation procedures/guidelines for the internal TV inspection program (TVI-03). A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment: Sewer Cleaning (CLN) (page 25 and page 26) indicates there is not a program to identify sewer line segments, with chronic problems, that should be cleaned on a more frequent schedule (CLN-01), though it also states the entire system is cleaned every 3-years. It further states the city does not have a root control program (CLN-05), and stoppages are not plotted on maps and correlated with other data such as pipe size and material or location (CLN-09). A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment: Manhole Inspection and Assessment (MAN) (page 26 and page 27) indicates the city does not have routine manhole inspection and assessment program (MAN-01) or a grouting program (MAN-06). A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment: Pump Stations (PS) (page 28 and page 29) indicates the city does not have Standard Operating Procedures (SOPs) and Standard Maintenance Procedures (SMPs) used for each pump station (PS-01), an emergency operating procedure for each pump station (PS-03), only 50% pump stations are equipped with backup power sources (PS-05), and there is not a procedure for manipulating pump operations during wet weather to increase in-line storage of wet weather flows (PS-07). Additionally, records are not maintained for each inspection (PS-13) and 12% of the pump stations are equipped with permanent flow meters (PS-19). A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment: Capacity Assessment (CA) (page 30) indicates that the city maintains some flow metering in specific locations, for specific functions and are calibrated on a routine basis, but flow meter checks do not include the following independent water level, a check of the desiccant, downloading data or a battery condition CA-09). Additionally, the CMOM indicates the flow monitoring records do not include the following: location description, flow meter type, or how often the flow meter is inspected or calibrated (CA11). A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment: Tracking SSOs (TRK) (page 32 and page 33) indicates the city, has reported one (1) SSO event in the past 5 years (TRK-01) and 100% of the reported SSOs was less than 1,000 gallons (TRK-02). Additionally, the city indicates the last overflow resulted from a Digester overflow (TRK-06). A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment: Overflow Emergency Response (OERP) (page 35) indicates the city does not have a documented OERP 6 City of Las Cruces/ Jacob Hands Memorial WWTF Permit No. NM0023311 Inspection Date 05/05/2025 available for utility staff to use (OERP-01), specific responsibilities for personnel who respond to emergencies are not detailed (OERP-03), staff are not continuously trained to respond to emergencies (OERP-04) and a public notification plan does not exist (OERP-08). A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment: Smoke & Dye Testing (SDT) (page 36 and page 37) indicates the city does not have a have a smoke testing program to identify sources of inflow and infiltration (SDT-01), a smoke testing program to identify sources of inflow and infiltration in illegal connectors (SDT-01A), a smoke testing program to identify sources of inflow and infiltration in house laterals (private service laterals (SDT-01B), written procedures for smoke testing (SDT-02), a documented procedure for isolating line segments (SDT-03), or a documented procedure for notifying residents that smoke testing will be conducted in their area (SDT-04). During the closing conference, David Esparza discussed the requested completion of the Capacity, Management, Operation and Maintenance (CMOM) Self-Assessment document. Section III - AREAS OF CONCERN/RECOMENDATIONS A review of the of the CMOM self-assessment completed by the City of Las Cruces-Jacob Hands, and additional supporting information, indicates some of the following or could be beneficial: A review of the City of Las Cruces-Jacob Hands completed CMOM Self-Assessment indicates the city, has reported one (1) SSO event in the past 5 years and 100% of the reported SSOs was less than 1,000 gallons. Additionally, the city indicates the last overflow resulted from a Digester overflow. Preparation of an Overflow Emergency Response Plan (OERP) delineating specific utility staff responsibilities to responding emergencies, a public notification plan and procedures to limit public contact with areas affected by sanitary sewer overflow (SSO) events. Preparation of an Internal TV Inspection (TVI), Sewer Cleaning (CLN), Manhole Inspection and Assessment (MAN) program. Preparation/creation of supporting documentation to complement the tracking maintenance activities within the existing Management Information System (MIS). Preparation of an Equipment & Collection System Maintenance (ESM) and Equipment Parts Inventory (EPI) program. Given the recent experiences of supply chain delays, it is paramount to dayto-day operations and permit compliance. Preparation of a newsletter or notification procedure for regular communication/coordination with other municipal departments to facilitate Internal Communications (IC). Preparation of a formal Training (TR) job knowledge, skills, and abilities (KSA) training program to assist and encourage safe work practices and potential position advancement. 7 ADDITIONAL AREAS of CONCERN: City of Las Cruces/ Jacob Hands Memorial WWTF Permit No. NM0023311 Inspection Date 05/05/2025 A review of the submitted Integrated Compliance Information System (ICIS) Discharge Monitoring Reports (DMR) data for the period January 21, 2022, through March 31, 2025, indicates NPDES permit exceedances with respect to Escherichia coli (E. coli), Total Suspended Solids (TSS), 5-day Biological Oxygen Demand (BOD5), Polychlorinated biphenyls and Whole Effluent Toxicity (WET) (Appendix 2 ICIS E90 Effluent Violations). Note: Administrative Order (AO) (Docket # CWA-06-2022-1710) was issued on March 31, 2022, regarding failure to meet permit effluent limitations and was closed on March 1, 2024. Section IV - FOLLOW UP The following information and/or clarification was received by EPA after exiting on May 5, 2025: Completed Capacity Management Operations and Maintenance Self-Assessment Section V - LIST OF APPENDICES Appendix 1 - Capacity Management Operations and Maintenance Self-Assessment Appendix 2 - Review of the ICIS E90 Effluent Violations 8 City of Las Cruces/Jacob Hands Wastewater Treatment Facility NPDES permit No. NM0023311 Inspection Date May 5, 2025 Appendix 1 City of Las Cruces-Jacob Hands Capacity Management Operations And Maintenance (CMOM) Self-Assessment 1 City of Las Cruces Permit No. NM0023311 CAPACITY, MANAGEMENT, OPERATION AND MAINTENANCE (CMOM) Program Self-Assessment Compiled By: Name: ___Joaquin Murillo___________________ Title: Jacob Hands Wastewater Treatment Facility Permit #0023311 Date: ___May 20, 2025___________________ Staffing list and Organization chart: Attach separate document as needed Please see attachment: General Information Service area SQ. MILES 2 Service population City of Las Cruces Permit No. NM0023311 115,000 PEOPLE Annual precipitation 6.28 inches* NUMBER *Find your annual New Mexico precipitation here: https://wrcc.dri.edu/summary/Climsmnm.html # of Treatment Facilities Average Daily Flow Manholes 1 WWTP design capacity NUMBER 9.7 Average dry weather flow MGD Please see Number of air vacuum relief 0 attachmen valves NUMBER 13.5 MGD 9.7 MGD NUMBER Service Area Characteristics Residential Industrial Multi-Family Total NUMBER Commercial Institutional Other NUMBER NUMBER Collection system service lateral responsibility (check one) At main line connection only From main line to property line or easement/cleanout x Beyond property line/clean out Other: Comments: What percent of sewer system is served by combined sewers (i.e., sanitary sewage and storm water in the same pipe)? 0% PERCENT Collection System Information Conveyance & Pumping Gravity Sewers Pipes and pumps: 522 Length/quantity MILES Age of system: 0-25 years old PERCENT 26-50 years old PERCENT 51-75 years old PERCENT >75 years old Number of Inverted siphons PERCENT 12 3 City of Las Cruces Permit No. NM0023311 Pump Stations Stations Force Mains 16 16 NUMBER MILES Vacuum Stations Stations Vacuum Lines Force Mains 0 NUMBER MILES MILES NUMBER PERCENT NUMBER PERCENT PERCENT NUMBER PERCENT NUMBER PERCENT PERCENT NUMBER PERCENT NUMBER PERCENT PERCENT NUMBER PERCENT NUMBER PERCENT PERCENT NUMBER Pipe Diameter Information 8 inches or less Gravity Sewers Force Mains Vacuum Lines PERCENT PERCENT PERCENT 9 - 14 inches PERCENT PERCENT PERCENT 15 - 36 inches PERCENT PERCENT PERCENT > 36 inches PERCENT PERCENT PERCENT 4 Comments: Please see attachment for conveyance & Pumping City of Las Cruces Permit No. NM0023311 Pipe Material Information Prestressed concrete cylinder pipe (PCCP) High density polyethylene (HDPE) Reinforced concrete pipe (RCP) Polyvinyl Chloride (PVC) Vitrified Clay Pipe Cast Iron Pipe (CIP), Ductile Iron Pipe (DIP) Non-reinforced concrete pipe Asbestos cement pipe Brick Fiberglass Cured in Place Fold and Form Gravity Sewer PERCENT Force Mains Vacuum Lines PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT PERCENT 5 Comments: Percentage not available at this time. City of Las Cruces Permit No. NM0023311 Engineering Design (ED) ED-01 Checklist Item Is there a document which includes design criteria and standard construction details? Comments: Yes No N/A x ED-02 Is there a document that describes the procedures that the utility follows in construction design review? x Comments: ED-03 ED-04 ED-05 ED-06 ED-07 ED-08 Are WWTP and O&M staff involved in the design review process? x Comments: Yes. Our engineering group involves staff for any comments or concerns with design. Is there a procedure for testing and inspecting new or rehabilitated system elements both during and after the x construction is completed? Comments: Are construction sites supervised by qualified personnel (such as professional engineers) to ascertain the construction is in accordance with the agreed upon plans and specifications? x Comments: Are new manholes tested for inflow and infiltration? Comments: Surveys are performed before construction and taken into consideration during design and planning. Are new gravity sewers checked using closed circuit TV inspection? x Comments: T.V. camera reports are available for all new installation of gravity sewer lines. Does the utility have documentation on private service lateral x design and inspection standards? 6 Comments: City of Las Cruces Permit No. NM0023311 ED-09 Does the utility attempt to standardize equipment and sewer system components? x Comments: We try to standardize wherever possible Comments: ED-08: We are currently updating our locate field reports information within the Wastewater line maintenance group. Satellite Communities and Sewer Use Ordinance (SUO) Checklist Item Yes No N/A SUO-01 Does the utility receive flow from satellite communities? IF NO, GO TO NEXT SECTION x Comments: The City of Las Cruces receives flow from the Town of Mesilla, and a section of Dona Ana SUO-02 What is the total area from satellite communities that contribute flow to the collection system? (Acres or square miles) Comments: Total Area in acres or square miles not available at this time. SUO-03 Does the utility require satellite communities to enter into an agreement? IF NO, GO TO QUESTION SUO-06 x Comments: SUO-04 Does the agreement include the requirements listed in the sewer use ordinance? x Comments: SUO-05 Do the agreements have a date of termination and allow for renewal under different terms? x Comments: SUO-06 Does the utility maintain a legal authority to control the maximum flow introduced into the collection system from x satellite communities? Comments: SUO-07 Are standards, inspections, and approval for new x connections clearly documented in a SUO? Comments: 7 SUO-08 Does the SUO require satellite communities to adopt the same industrial and commercial regulatory discharge limits as the utility? Comments: SUO-09 Does the SUO require satellite communities to adopt the same inspection and sampling schedules as required by the pretreatment ordinance? Comments: City of Las Cruces Permit No. NM0023311 x x SUO-10 Does the SUO require satellite communities or the utility to x issue control permits for significant industrial users? Comments: Checklist Item SUO-11 Does the SUO contain provisions for addressing overstrength wastewater from satellite communities? Comments: Yes No N/A x SUO-12 Does the SUO contain procedures for the following? Inspection standards x Pretreatment requirements x Building/sewer permit issues x Comments: SUO-13 Does the SUO contain general prohibitions of the following materials? Fire and explosion hazards Corrosive materials Obstructive materials Oils or petroleum Material which may cause interference at the wastewater treatment plant Comments: see attachment x x x x x SUO-14 Does the SUO contain procedures and enforcement actions for the following? Fats, oils, and grease (FOG) Infiltration and inflow Building structures over the sewer lines Storm water connections to sanitary lines (downspouts) Defects in service laterals located on private property x x x 8 Sump pumps, air conditioner connections Comments: Comments: City of Las Cruces Permit No. NM0023311 Organizational Structure (OC) Checklist Item OC-01 Is an organizational chart available that shows the overall personnel structure for the utility, including operation and maintenance staff? Comments: OC-02 See attachments Are up-to-date job descriptions available that delineate responsibilities and authority for each position? Comments: OC-03 Are the following items discussed in the job descriptions? Nature of work to be performed Minimum requirements for the position Necessary special qualifications or certifications Examples of the type of work List of licenses required for the position Performance measures or promotion potential Comments: Yes No N/A x x x x x x x x OC-04 OC-05 What percent of staff positions are currently vacant? 28% Comments: We are not offering co op positions at the moment. This number is including new and approved positions currently advertised for recruitment. On average how long do positions remain vacant? (months) 6 9 Comments: OC-06 What percent of utility work is contracted out? Comments: Comments: City of Las Cruces Permit No. NM0023311 5% Internal Communications (IC) Checklist Item IC-01 Which of the following methods are used to communicate with utility staff? Regular meetings Bulletin boards E-mail Cell Phones Other (explain) Comments: Yes No N/A x x x x IC-02 How often are the staff meetings held? (e.g., Daily, Weekly, Monthly, etc.) Comments: Meetings are held monthly IC-03 Are incentives offered to employees for performance improvements? IC-04 Comments: Does the utility have an "Employee of the Month/Quarter/Year" program? Comments: x x 10 IC-05 How often are performance reviews conducted? (e.g. Semi-annually, Annually, etc.) Comments: Performance reviews are conducted semi-annually IC-06 Does the utility regularly communicate/coordinate with other municipal departments? Comments: City of Las Cruces Permit No. NM0023311 x Comments: Budgeting (BUD) Checklist Item BUD-01 What is the average annual fee for residential users? Comments: $ 2 8 0 Yes No N/A BUD-02 How often are user charges evaluated and adjusted? (e.g. annually, biannually. etc.) Comments: u s e r c h a r g e s a r e e v a l u a t e d a n n u a l l y BUD-03 Are utility-generated funds used for non-utility programs? x Comments: BUD-04 Are costs for collection system operation and maintenance (O&M) x separated from other utility services such as water, storm water, and treatment plants? IF NO, GO TO BUD-07 Comments: BUD-05 What is your average annual (O&M) budget? Comments: BUD-06 What percentage of the utility's overall budget is allocated to maintenance of the collection system? About 8% of WW utility budget 11 Comments: City of Las Cruces Permit No. NM0023311 BUD-07 Does the utility have a Capital Improvement Plan (CIP) that provides for system repairs/replacements on a prioritized basis? x Comments: BUD-08 What is your average annual CIP budget? 19,687,415 Comments: Comments: Checklist Item BUD-09 What percentage of the maintenance budget is allotted to the following maintenance? Predictive maintenance -n/a Preventive maintenance - n/a Corrective maintenance - n/a Emergency maintenance -n/a Comments: BUD-10 Does the utility have a budgeted program for the replacement of under-capacity pipes? Yes No N/A x 12 Comments: BUD-11 Does the utility have a budgeted program for the replacement of over-capacity pipes? Comments: Comments: City of Las Cruces Permit No. NM0023311 x Training (TR) Checklist Item TR-01 Does the utility have a formal job knowledge, skills, and abilities (KSA) training program? Comments: Yes No N/A x TR-02 Does the training program address the fundamental mission, x goals, and policies of the utility? Comments: TR-03 Does the utility have mandatory training requirements x identified for key employees? Comments: TR-04 TR-05 What percentage of employees met or exceeded their annual training goals during the past year? Comments: T h e u t i l i t y h a s t r a i n i n g g o a l s f o r s u p e r v i s o r s and non-supervisors that must be met annually. Does the utility provide training in the following areas? 13 Safety Routine line maintenance Confined space entry Traffic control Record keeping Electrical and instrumentation Pipe repair Bursting / CIPP Public relations SSO/Emergency response Pump station operations and maintenance CCTV and trench/shoring Other Comments: City of Las Cruces Permit No. NM0023311 x x x x x x x x x x x x TR-06 Are operator and maintenance certification programs used? x IF NO GO TO TR-08 Comments: TR-07 Are operator and maintenance certification programs x required? Comments: For appropriate personnel. TR-08 Is on-the-job training progress and performance measured? x Comments: TR-09 Checklist Items Yes No NA Which of the following methods are used to assess the effectiveness of the training? None Periodic testing x Drills x Demonstrations Comments: TR-10 What percentage of the training offered by the utility is in the form of the following? Manufacturer training On-the-job training In-house classroom training Industry-wide training 14 Comments: City of Las Cruces Permit No. NM0023311 Safety (SAF) Checklist Item Yes No N/A SAF-01 Does the utility have a written safety policy? X Comments: SAF-02 How often are safety procedures reviewed and revised? (Annually, quarterly, etc.) Comments: A N N U A L L Y SAF-03 Does the utility have a safety committee? X Comments: SAF-04 Are regular safety meetings held with the utility employees? How often? Comments: X MONTHLY SAF-05 Does the utility have a safety training program? X Comments: SAF-06 Are records of employee safety training kept up to date? X Comments: SAF-07 Checklist Item Does the utility have written procedures for the following? Lockout/tagout Material safety data sheets (MSDS) Chemical handling Confined spaces permit programs Trenching and excavations safety Biological hazards in wastewater Traffic control and work site safety Electrical and mechanical systems Pneumatic and hydraulic system safety Comments: SAF-08 What is your agency's lost-time injury rate? Comments: MONITORED BY SAFETY TEAM Yes No N/A X X X X X X X X X 15 SAF-09 SAF-10 Are the following equipment items available and in adequate supply? Rubber/disposable gloves X Confined space ventilation equipment X Hard hats, safety glasses, rubber boots X Antibacterial soap and first aid kit X Tripods or non-entry rescue equipment X Fire extinguishers X Equipment to enter manholes X Portable crane/hoist X Atmospheric testing equipment and gas detectors X Oxygen sensors X H2S Monitors X Full body harness X Protective clothing X Traffic/public access control equipment X 5-minute escape breathing devices X Life preservers for lagoons Life preservers at activated sludge plants X Fiberglass or wooden ladders for electrical work X Respirators and/or self-contained breathing apparatus X Methane gas or optical vector (OVA) analyzer Lower explosion limit (LEL) metering X Comments: Are safety monitors clearly identified? Comments: City of Las Cruces Permit No. NM0023311 x X x Customer Service (CS) Checklist Item CS-01 Does the utility have a customer service and public relations program? IF NO GO TO CS-03 Comments: Yes No N/A x CS-02 Does the customer service program include giving formal presentations on the wastewater field to the following? Schools and universities x Community gatherings x Local officials x 16 Businesses Media Citizens Building Inspector(s) Public utility officials Comments: City of Las Cruces Permit No. NM0023311 x x x x x CS-03 CS-04 Are employees of the utility specifically trained in customer service? Comments: Are there sample correspondence, Q/A's, or "scripts" to help guide staff through written or oral responses to customers? Comments: x x CS-05 What methods are used to notify the public of major construction or maintenance work? Door hangers X Public radio or T.V. announcements X Newspaper X Flyers X Signs X Other None Comments: CS-06 Checklist Item Is a homeowner notified prior to construction that his/her property may be affected? Comments: CS-07 Do you provide information to residents on cleanup and safety procedures following basement backups and overflows from manholes when they occur? Comments: Yes No N/A X X 17 CS-08 Does the utility have a customer service evaluation program to obtain feedback from the community? Comments: City of Las Cruces Permit No. NM0023311 x CS-09 Do customer service records include the following information? Personnel who received the complaint or request x Nature of the complaint or request x To whom the follow-up action was assigned x Date of the complaint or request x Date the complaint or request was resolved x Total days to end the problem x Name, address, and telephone number of the customer x Location of the problem x Date the follow up action was assigned x Cause of the problem x Feedback to customer x Comments: CS-10 Does the utility have a goal for how quickly customer x complaints (or emergency calls) are resolved? IF NO, GO TO NEXT SECTION Comments: CS-11 What percentage of customer complaints (or emergency calls) are resolved within the timeline goals? Comments: Equipment & Collection System Maintenance (ESM) Checklist Item ESM-01 Is a maintenance card or record kept for each piece of mechanical equipment within the collection system? IF NO, GO TO ESM-03 Comments: Yes No N/A x ESM-02 Do equipment maintenance records include the following information? Maintenance recommendations x 18 Instructions on conducting the specific maintenance activity Other observations on the equipment Maintenance schedule A record of maintenance on the equipment to date Comments: ESM-03 Are dated tags used to show out-of-service equipment? Comments: ESM-04 ESM-05 Is there an established system for prioritizing equipment maintenance needs? Comments: What percent of repair funds are spent on emergency repairs? Comments: N / A City of Las Cruces Permit No. NM0023311 x x x x x x ESM-06 Are corrective repair work orders backlogged more than six x months? Comments: ESM-07 Do collection system personnel coordinate with state, county, x and local personnel on repairs, before the street is paved? Comments: Comments: Equipment Parts Inventory (EPI) EPI-01 Checklist Item Have critical spare parts been identified? Comments: Yes No N/A x EPI-02 Are adequate supplies on hand to allow for two-point repairs in x any part of the system? 19 Comments: EPI-03 EPI-04 Is there a parts standardization policy in place? Comments: Does the utility have a central location for storing spare parts? Comments: City of Las Cruces Permit No. NM0023311 x x EPI-05 Does the utility maintain a stock of spare parts on its x maintenance vehicles? Comments: EPI-06 Does the utility have a system in place to track and maintain an x accurate inventory of spare parts? Comments: EPI-07 For those parts which are not kept in inventory, does the x utility have a readily available source or supplier? Comments: Comments: Management Information System (MIS) Checklist Item MIS-01 Does the utility have a management information system (MIS) in place for tracking maintenance activities? (Either electronic or good paper files) IF NO, GO TO NEXT SECTION Yes No N/A x 20 Comments: City of Las Cruces Permit No. NM0023311 MIS-02 Are the MIS records maintained for a period of at least three x years? Comments: MIS-03 Is the MIS able to distinguish activities taken in response to x an overflow event? Comments: MIS-04 MIS-05 Are there written instructions for managing and tracking the following information? (Check all that apply) Complaint work orders x Schedule work orders x Customer Service x Scheduled preventive maintenance x Scheduled Inspections x Scheduled system inventory x Safety incidents x Scheduled monitoring/sampling x Compliance/overflow tracking x Equipment/tools tracking x Parts inventory x Do the written instructions for tracking procedures include the following information? Accessing data and information x Instructions for using the tracking system x Updating the MIS x Developing and printing reports x Comments: Developing and printing reports. MIS-06 Checklist Item How often is the management information system updated? Yes No N/A 21 Immediately City of Las Cruces Permit No. NM0023311 x Within one week of the "incident" x Monthly x Other: x Comments:The system we use to track work orders/maintenance records/dates/material used/complaint work orders is maintained by our MIS group and is updated regularly. Comments: System Mapping (MAP) Checklist Item MAP-01 Are "as built" plans (record drawings) or maps available for use by field crews in the office and in the field? Comments: MAP-02 Is there a procedure for field crews to record changes or inaccuracies in the maps and update the mapping system? Comments: Yes No N/A x x MAP-03 Do the maps show the date the map was drafted and the x date of the last revision? Comments: Comments: Checklist Item Yes No N/A 22 MAP-04 Do the sewer line maps include the following? Scale North arrow Date the map was drafted Date of last revision Service area boundaries Property lines Other landmarks (Roads, water bodies, etc.) Manhole and other access points Location of building laterals Street names SSOs occurrences/CSOs outfalls Flow monitors Force mains Pump stations Lined sewers Main, trunk, and interceptor sewers Easement lines and dimensions Pipe material Pipe diameter Installation date Slope Manhole rim elevation Manhole coordinates Manhole invert elevation Distance between manholes Comments: City of Las Cruces Permit No. NM0023311 x x x x x x x x x x x x x x x x x x x x x x x x x MAP-05 Are the following sewer attributes recorded? Size x Shape x Invert elevation x Material x Separate/combined sewer x Installation date x Comments:We do not have a combined sewer within the City of Las Cruces. 23 MAP-06 Checklist Item Are the following manhole attributes recorded? Shape Type (e.g., precast, cast in place, etc.) Depth Age Material Comments: City of Las Cruces Permit No. NM0023311 Yes No N/A x x x x x MAP-07 Is there a systematic numbering and identification system to x identify manholes, sewer lines, pump station, etc.? Comments: Internal TV Inspection (TVI) Checklist Item Yes No N/A TVI-01 Does the utility have a standardization pipeline condition assessment x program? If yes, explain Comments: Our Wastewater Line Maintenance does regular t.v. inspections to access the condition of lines. TVI-02 Is internal TV inspection used to perform condition assessment? x IF NO, GO TO NEXT SECTION Comments: TVI-03 Are there written operation procedures/guidelines for the internal TV x inspection program? Comments: TVI-04 Do the internal TV record logs include the following? Pipe size, type, length, and joint spacing x Distance recorded by internal TV x Results of the internal TV inspection (including a structural rating) x Internal TV operator name x Cleanliness of the line x Location and identification of line being televised by manholes x 24 Comments: City of Las Cruces Permit No. NM0023311 TVI-05 Is a rating system used to determine the severity of the defects x found during the inspection process? Comments: TVI-06 Is there a code list used for internal TV inspection reporting? x Approximately what percent of the total defects determined by TV inspection, during the TVI-07 past 5, years were attributed to the following? Debris na Debris/Grease na Debris/Roots na Grease na Grease/Roots na Intruding Tap na Intruding Tap/Roots na Surcharged na Offset Joint/Grease na Roots na Roots/Debris na Roots/Grease na Roots/Grease/Debris na Roots/Line Failure na Line Failure na Sag In Line na Sag In Line/Debris na Sag In Line/Grease na Other: Other: Total Percentage Comments: 25 TVI-08 Are main line and lateral repairs checked by internal TV Ciommeni ts: f h i ( )h b d? City of Las Cruces Permit No. NM0023311 x Sewer Cleaning (CLN Checklist Item CLN-01 Is there a program to identify sewer line segments, with chronic problems, that should be cleaned on a more frequent schedule? Comments: Yes No NA x CLN-02 CLN-03 What is the entire system cleaning frequency? (e.g., every "X" years) Comments: What is the utility's plan for system cleaning (% or frequency in years)? Comments: Once every 3 years Once every 3 years CLN-04 CLN-05 CLN-06 CLN-07 CLN-08 CLN-09 What percent of the total cleaning was considered na repeat and trouble spot cleaning during the past year? Comments: Does the utility have a root control program? x Comments: Does the utility have a fats, oils, and grease (FOG) program? x Comments: What is the average number of stoppages experienced per 100 na miles of sewer pipe per year? Comments: Has the number of stoppages increased, decreased, or stayed the same over the past 5 years? Comments:Decreased Are stoppages plotted on maps and correlated with other data such as pipe size and material or location? Comments: x Comments: 26 City of Las Cruces Permit No. NM0023311 CLN-10 Checklist Item Yes No NA Do the sewer cleaning records include the following information? Date and time x Cause of stoppage x Method of cleaning x Location of stoppage or routine cleaning activity x Identity of cleaning crew x Further actions necessary/initiated x Comments: CLN-11 If sewer cleaning is done by a contractor, are videos taken x before and after cleaning? Comments: Manhole Inspection and Assessment (MAN) Checklist Item MAN-01 Does the utility have a routine manhole inspection and assessment program? IF NO, GO TO MAN-06 Comments: Yes No N/A x MAN-02 Are the results and observations from the routine manhole inspection recorded? Comments: MAN-03 MAN-04 Does the utility have a goal for the number of manholes inspected annually? Comments: How many manholes were inspected during the past year? What is the percent of total manholes were inspected during the 27 Comments: Comments: City of Las Cruces Permit No. NM0023311 Checklist Item Yes No N/A MAN-05 Do the records for manholes/pipe inspection include the following? Conditions of the frame and cover Evidence of surcharge Offsets or misalignments Atmospheric hazards measurements (especially hydrogen sulfide) Details on the root cause of cracks or breaks in the manhole or pipe including blockages Recording conditions of (corbel, walls, bench, trough, and pipe seals) Presence of corrosion If repair is necessary Manhole identifying number/location Wastewater flow characteristics (flowing freely or backed up) Accumulation of grease, debris, or grit Presence of infiltration, location, and estimated quantity Inflow from manhole covers Comments: MAN-06 Does the utility have a grouting program? x Comments: Comments: 28 City of Las Cruces Permit No. NM0023311 Pump Stations (PS) Checklist Item PS-01 Are Standard Operating Procedures (SOPs) and Standard Maintenance Procedures (SMPs) used for each pump station? Comments: Yes No N/A x PS-02 Are there enough trained personnel to properly inspect and x maintain all pump stations? Comments: PS-03 Is there an emergency operating procedure for each pump x station? Comments: PS-04 Is there an alarm system to notify personnel of pump station x failures and overflow? Comments: PS-05 Percent of pump stations with backup power sources 50% Comments: PS-06 Does the utility use the following methods when loss of power occurs? On-site electrical generators x Portable electric generators x Vacuum trucks to bypass pump station x 29 PS-07 City of Las Cruces Permit No. NM0023311 Alternate power source x Other Comments: There is also back up power from another sub-station at our main on-site lift station. Is there a procedure for manipulating pump operations during x wet weather to increase in-line storage of wet weather flows? Comments: Comments: Checklist Item PS-08 Are wet well operating levels set to limit pump start/stops? Comments: PS-09 Are the lead, lag, and backup pumps rotated regularly? Comments: PS-10 Are operation logs maintained for all pump stations? Comments: PS-11 Are the manuals that contain the manufacturers recommended maintenance schedules for all pump station equipment available? Comments: PS-12 On average, how often were pump stations inspected during the past year? Comments: PS-13 Are records maintained for each inspection? Comments: PS-14 Average annual labor hours spent on pump station inspections Comments: information not available Yes No N/A x x x x Once a month x 30 PS-15 Percent of pump stations with pump capacity redundancy Comments: PS-16 Percent of pump stations with dry weather capacity limitations Comments: PS-17 Percent of pump stations with wet weather capacity limitations Comments: PS- Percent of pump stations calibrated annually 18 Comments: PS- Percent of pump stations with permanent flow meters 19 Comments: City of Las Cruces Permit No. NM0023311 100% 0 0 Not available 12% Capacity Assessment (CA) Checklist Item CA-01 Does the utility have a flow monitoring program? Comments: CA-02 Does the utility have a comprehensive capacity assessment and planning program? Comments: Yes No N/A x x CA-03 Are flows measured prior to allowing new connections? x Comments: CA-04 Do you have a tool (hydraulic model, spreadsheet, etc.) for assessing whether adequate capacity exists in the sewer x system? IF NO, GO TO CA-06. Comments: hydraulic models are ran during Master Plan finalization. CA-05 Does your capacity assessment tool produce results x consistent with conditions observed in the system? Comments: 31 CA-06 What is the ratio of peak wet weather flow to average dry weather flow at the wastewater treatment plant? Comments: City of Las Cruces Permit No. NM0023311 1.2:1 CA-07 How many permanent flow meters are currently in the system? 4 (Include meters at pump stations and WWTPs) Comments: CA-08 CA-09 How frequently are the flow meters checked? Comments:Flow meters at WWTP/monthly. Verified/calibr by SCADA group/2x year Do the flow meter checks include the following? Independent water level x Checking the desiccant x Velocity reading x Cleaning away debris x Downloading data x Battery condition x Comments: Checklist Item Yes No N/A CA-10 Are records maintained for each inspection? IF NO, GO TO CA-12 x Comments: CA-11 Do the flow monitoring records include the following? Descriptive location of flow meter x Type of flow meter x Frequency of flow meter inspection x Frequency of flow meter calibration x Comments:flow monitoring records are separate from flow meter inspections. CA-12 Does the utility maintain any rain gauges? x Comments: CA-13 Does the utility have any wet weather capacity problems? Comments: CA-14 Are low points or flood-plain areas monitored during rain events? x n/a 32 Comments: CA-15 Does the utility have any dry weather capacity problems? Comments: CA-16 Is flow monitoring used for billing purposes, capacity analysis, and/or inflow and infiltration investigations? Comments: Comments: City of Las Cruces Permit No. NM0023311 x x Tracking SSOs (TRK) TRK-01 Checklist Item How many SSO events have been reported in the past 5 years? Comments: Yes No N/A 1 TRK-02 What % of SSOs were less than 1,000 gallons in the past 5 years? 100% Comments: TRK-03 Does the utility document and report all SSOs regardless of size? x Comments: 33 TRK-04 Does the utility document basement backups? Comments: City of Las Cruces Permit No. NM0023311 X TRK-05 Are there areas that experience frequent street flooding? X Comments: TRK-06 What % of SSO discharges were from each of the following in the last 5 years? Manholes 0 Lift/Vacuum Systems (Revised term) 0 Main and trunk sewers 0 Lateral and branch sewers 0 Total 0 Comments: The last overflow reported was from an over flowed Digester. TRK-07 Checklist Item Yes No N/A What % of SSO discharges were caused by each of the following in the last 5 years? Construction 0 Cause Unknown 0 Debris 0 Debris/Grease 0 Debris/Roots 0 Equipment Failure 0 Grease 0 Sag In Line 0 Intruding Tap 0 Line Failure 0 Manhole/Surcharged 0 Offset Joint 0 Roots 0 Roots/Debris 0 Roots/Grease 0 Roots/Intruding Tap 0 Roots/Line Failure 0 34 Surcharged Other(s): Grand Total Comments: City of Las Cruces Permit No. NM0023311 0 0 0 TRK-07A Checklist Item What percentage of SSOs were released to: Storm Sewer Arroyo/Ditch/Drain Street/ Parking lot Private Property River/Stream/Lake/Bayou/Ocean Other: Grand Total Comments: 0 0 0 0 0 0 TRK-07B For surface water releases, what percent are to areas that could affect: Contact recreation (beaches, swimming areas) 0 Drinking water sources 0 Shellfish growing areas 0 Fishing or spawning areas 0 Comments: TRK-08 Checklist Item How many chronic SSO locations are in the collection system? Comments: Yes No N/A NA TRK-09 Are pipes with chronic SSOs being monitored for sufficient NA capacity and/or structural condition? Comments: TRK-10 Prior to collapse, are structurally deteriorating pipelines being X monitored for renewal or replacement? Comments: Comments: 35 City of Las Cruces Permit No. NM0023311 Overflow Emergency Response (OERP) Checklist Item OERP-01 Does the utility have a documented OERP available for utility staff to use? IF NO, GO TO OERP-04 Comments: OERP-02 How often is the OERP reviewed and updated? (Annually, Biannually, etc.) Comments: OERP-03 OERP-04 Are specific responsibilities detailed in the OERP for personnel who respond to emergencies? Comments: Are staff continuously trained to respond to emergencies? Comments: emergencies are responded to immediately OERP-05 Do work crews have immediate access to tools and equipment during emergencies? Comments: Yes No N/A X X x OERP-06 Checklist Item Yes No N/A Does the utility have procedures for notifying state agencies, local health departments, the NPDES authority, the public, and drinking water x authorities of significant overflow events? Comments: Procedures are followed as per NPDES permit OERP-07 Does the procedure include a current list of the names, titles, phone x numbers, and responsibilities of all personnel involved? Comments: OERP-08 Does the utility have a public notification plan? x 36 Comments: City of Las Cruces Permit No. NM0023311 OERP-09 Does the utility have procedures to limit public contact with areas x affected by SSOs? (can be delegated to another authority) Comments: OERP-10 Does the utility use containment techniques to protect storm systems? x Comments: OERP-11 Do the overflow records include the following information? Date and time x Cause(s) x Names of affected receiving water(s) x Location x How it was stopped x Any remediation efforts x Estimated flow/volume discharged x Duration of overflow x Comments: OERP-12 Does the utility have signage to keep public from affected area? x Comments: Affected areas are addressed and cleaned up immediately Smoke & Dye Testing (SDT) Checklist Item SDT-01 Does the utility have a smoke testing program to identify sources of inflow and infiltration? Comments: Yes No N/A x SDT-01A Does the utility have a smoke testing program to identify sources of x inflow and infiltration in illegal connectors? 37 Comments: City of Las Cruces Permit No. NM0023311 SDT-01B Does the utility have a smoke testing program to identify sources of x inflow and infiltration in house laterals (private service laterals)? Comments: SDT-02 Are there written procedures for smoke testing? x Comments: SDT-03 Is there a documented procedure for isolating line segments? x Comments: SDT-04 Is there a documented procedure for notifying residents that smoke x testing will be conducted in their area? Comments: Comments: SDT-05 Checklist Item What is the guideline for maximum amount of line to be tested at one time? (Feet or Miles) Comments: SDT-06 Are there guidelines for the weather conditions under which smoke testing should be conducted? Yes No N/A x x 38 Comments: SDT-07 What is the goal for the % of the system smoke tested each year? Comments: City of Las Cruces Permit No. NM0023311 x SDT-08 What % of the system has been smoke tested in the past 5 years? NA Comments: SDT-09 Do the written records contain location, address, and description of the smoking element that produced a positive result? NA Comments: SDT-10 Does the utility have a dye testing program? X Comments: SDT-11 Are there written procedures for dye testing? X Comments: SDT-12 Does the utility have a goal for the percent of the system dye X tested each year? Comments: SDT-13 What percent of the main collection system had been dye tested 0% over the past year? Comments: SDT-14 Does the utility share smoke and dye testing equipment with NA another utility? Comments: Comments: Hydrogen Sulfide Monitoring and Control (HSMC) Checklist Item Yes No N/A HSMC-01 How would you rate the system vulnerability for hydrogen sulfide corrosion? Not a problem 39 Only in a few isolated areas A major problem Comments: City of Las Cruces Permit No. NM0023311 X HSMC-02 Does the utility have a corrosion control program? X Comments: We monitor H2S levels at headworks HSMC-03 Does the utility take hydrogen sulfide corrosion into consideration when designing new or replacement sewers? x Comments: HSMC-04 Does the utility have procedures for application of chemicals? x Comments: HSMC-05 Are the chemical dosages, dates, and locations documented? x Comments: HSMC-06 Does the utility document where odor is a problem in the system? x Comments: HSMC-07 Does the utility have a program in place for renewing or x replacing severely corroded sewer lines to prevent collapse? Comments: Comments: HSMC-08 Checklist Item Yes No N/A Are the following methods used for hydrogen sulfide control? 40 Aeration Iron Salts Enzymes Activated charcoal canisters Chlorine Sodium hydroxide Hydrogen peroxide Potassium permanganate Biofiltration Other Comments: City of Las Cruces Permit No. NM0023311 x x x x x x x x x HSMC-09 Does the system contain air relief valves at the high points of x the force main system? Comments: HSMC-10 How often are the valves maintained and inspected? NA (Weekly, Monthly, etc.) Comments: HSMC-11 Does the utility enforce pretreatment requirements? X Comments: Comments: 41 City of Las Cruces Permit No. NM0023311 Infrastructure Security Although outside the scope of a CMOM program, municipal wastewater utilities should also consider security vulnerabilities. To reduce the threat of both intentional and natural disasters, the utility should take steps to implement appropriate countermeasures and develop or update emergency response plans. Please summarize any program the utility has for infrastructure security. Comments: Lift stations are monitored by a SCADA system for door entry into lift stations. Lift stations are also fenced and barb wired. Security guards are on-site 24/7 at the Jacob Hands Wastewater Treatment Facility. Emergency Response Plans have also been developed for the Utility as a whole. City of Las Cruces/Jacob Hands WWTF Permit No. NM0023311 Inspection Date 05/05/2025 Appendix 2 Review of the ICIS E90 Effluent Violations E90 Effluent Violations From 01/01/2019 - Present NM0023311 LAS CRUCES, CITY OF Monitoring Period End Date 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 02/28/2022 02/28/2022 02/28/2022 02/28/2022 Perm Feature ID 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 Parameter Desc Statistical Base Short Desc E. coli 30DAVGEO E. coli 30DAVGEO E. coli DAILY MX Solids, suspended percent MO AV MN Solids, total suspended 30DA AVG Solids, total suspended 30DA AVG Solids, total suspended 7 DA 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 7 DA AVG BOD, 5-day, 20 deg. C 7 DA AVG Limit Unit Short Desc Limit Value BCFU/d 42.5 CFU/100126 CFU/100410 % 85 lb/d 3379 mg/L 30 lb/d 5069 mg/L 45 lb/d 3379 mg/L 30 lb/d 5069 mg/L 45 DMR Value Qualif ier Code = = = = = = = = = = = = DMR Value 71.96 217.05 2419.6 77 4720.9 64.6 5233.9 71 5443.4 73.1 7749.4 102.9 Reported Number of Excursions 6 6 6 1 8 8 8 8 8 8 8 8 Monitoring Period End Date 02/28/2022 02/28/2022 02/28/2022 02/28/2022 02/28/2022 02/28/2022 02/28/2022 02/28/2022 02/28/2022 03/31/2022 03/31/2022 03/31/2022 03/31/2022 03/31/2022 03/31/2022 03/31/2022 03/31/2022 03/31/2022 03/31/2022 Perm Feature ID 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 Limit Set Designator A A A A A A A A A A A A A A A A A A A Parameter Desc Statistical Base Short Desc BOD, 5-day, percent remo MO AV MN E. coli 30DAVGEO E. coli 30DAVGEO E. coli DAILY MX Solids, suspended percent MO AV MN Solids, total suspended 30DA AVG Solids, total suspended 30DA AVG Solids, total suspended 7 DA AVG Solids, total suspended 7 DA AVG BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, 20 deg. C 7 DA AVG BOD, 5-day, percent remo MO AV MN E. coli 30DAVGEO E. coli 30DAVGEO E. coli DAILY MX Solids, suspended percent MO AV MN Solids, total suspended 30DA AVG Solids, total suspended 30DA AVG Solids, total suspended 7 DA AVG Limit Unit Short Desc Limit Value % 85 BCFU/d 42.5 CFU/100126 CFU/100410 % 85 lb/d 3379 mg/L 30 lb/d 5069 mg/L 45 mg/L 30 mg/L 45 % 85 BCFU/d 42.5 CFU/100126 CFU/100410 % 85 lb/d 3379 mg/L 30 lb/d 5069 DMR Value Qualif ier Code = = = > = = = = = = = = = = = = = = = DMR Value 68 206.31 609.87 2419.6 63 6456.8 87 7055.1 97.5 37.3 48.2 83 97.31 279.55 5419.6 66 5901.8 77 6991.2 Reported Number of Excursions 1 18 18 18 1 10 10 10 10 2 2 1 17 17 17 1 10 10 10 Monitoring Period End Date 03/31/2022 03/31/2022 03/31/2022 03/31/2022 03/31/2022 04/30/2022 04/30/2022 04/30/2022 04/30/2022 04/30/2022 04/30/2022 04/30/2022 04/30/2022 04/30/2022 04/30/2022 04/30/2022 04/30/2022 05/31/2022 05/31/2022 Perm Feature ID 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 Limit Set Designator A Q Q Q Q A A A A A A A A A A A A A A Parameter Desc Statistical Base Short Desc Solids, total suspended 7 DA AVG Polychlorinated biphenyls [ 30DA AVG Polychlorinated biphenyls [ 30DA AVG Polychlorinated biphenyls [ DAILY MX Polychlorinated biphenyls [ DAILY MX BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, 20 deg. C 7 DA AVG BOD, 5-day, percent remo MO AV MN E. coli 30DAVGEO E. coli 30DAVGEO E. coli DAILY MX Solids, suspended percent MO AV MN Solids, total suspended 30DA AVG Solids, total suspended 30DA AVG Solids, total suspended 7 DA AVG Solids, total suspended 7 DA AVG BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, percent remo MO AV MN Limit Unit Short Desc Limit Value DMR Value Qualif ier Code mg/L 45 = lb/d ###### = ug/L .00102 = lb/d ###### = ug/L .0011 = lb/d 3379 = mg/L 30 = mg/L 45 = % 85 = BCFU/d 42.5 = CFU/100126 = CFU/100410 = % 85 = lb/d 3379 = mg/L 30 = lb/d 5069 = mg/L 45 = mg/L 30 = % 85 = DMR Value Reported Number of Excursions 91 10 ###### 4 .00268 4 ###### 4 .00268 4 3641.3 4 49.3 4 65.8 4 71 1 64.96 9 192.74 9 853.7 9 59 1 6911.3 12 93 12 8976.4 12 120.9 12 38.1 1 76 1 Monitoring Period End Date 05/31/2022 05/31/2022 05/31/2022 05/31/2022 05/31/2022 05/31/2022 05/31/2022 05/31/2022 06/30/2022 06/30/2022 06/30/2022 06/30/2022 06/30/2022 06/30/2022 06/30/2022 06/30/2022 06/30/2022 06/30/2022 06/30/2022 Perm Feature ID 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 Limit Set Designator A A A A A A A A A A A A A A A A A A Q Parameter Desc Statistical Base Short Desc E. coli 30DAVGEO E. coli 30DAVGEO E. coli DAILY MX Solids, suspended percent MO AV MN Solids, total suspended 30DA AVG Solids, total suspended 30DA AVG Solids, total suspended 7 DA AVG Solids, total suspended 7 DA AVG BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, percent remo MO AV MN E. coli 30DAVGEO E. coli 30DAVGEO E. coli DAILY MX Solids, suspended percent MO AV MN Solids, total suspended 30DA AVG Solids, total suspended 30DA AVG Solids, total suspended 7 DA AVG Solids, total suspended 7 DA AVG Polychlorinated biphenyls [ 30DA AVG Limit Unit Short Desc Limit Value DMR Value Qualif ier Code BCFU/d 42.5 = CFU/100126 = CFU/100410 = % 85 = lb/d 3379 = mg/L 30 = lb/d 5069 = mg/L 45 = mg/L 30 = % 85 = BCFU/d 42.5 = CFU/100126 = CFU/100410 = % 85 = lb/d 3379 = mg/L 30 = lb/d 5069 = mg/L 45 = lb/d ###### = DMR Value Reported Number of Excursions 68.12 7 200.43 7 1161.6 7 66 1 5804.9 9 77.8 9 6414.3 9 88.3 9 30.7 1 80 1 59.58 8 166.41 8 2419.6 8 67 1 5039.7 8 63.9 8 5849 8 74.2 8 .000127 2 Monitoring Period End Date 06/30/2022 06/30/2022 06/30/2022 07/31/2022 07/31/2022 07/31/2022 07/31/2022 07/31/2022 07/31/2022 07/31/2022 07/31/2022 07/31/2022 07/31/2022 07/31/2022 07/31/2022 08/31/2022 08/31/2022 08/31/2022 08/31/2022 Perm Feature ID 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 Limit Set Designator Q Q Q A A A A A A A A A A A A A A A A Parameter Desc Statistical Base Short Desc Polychlorinated biphenyls [ 30DA AVG Polychlorinated biphenyls [ DAILY MX Polychlorinated biphenyls [ DAILY MX BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, 20 deg. C 7 DA AVG BOD, 5-day, percent remo MO AV MN E. coli 30DAVGEO E. coli 30DAVGEO E. coli DAILY MX Solids, suspended percent MO AV MN Solids, total suspended 30DA AVG Solids, total suspended 30DA AVG Solids, total suspended 7 DA AVG Solids, total suspended 7 DA AVG BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, percent remo MO AV MN E. coli 30DAVGEO E. coli 30DAVGEO Limit Unit Short Desc Limit Value DMR Value Qualif ier Code ug/L .00102 = lb/d ###### = ug/L .0011 = lb/d 3379 = mg/L 30 = mg/L 45 = % 85 = BCFU/d 42.5 = CFU/100126 = CFU/100410 = % 85 = lb/d 3379 = mg/L 30 = lb/d 5069 = mg/L 45 = mg/L 30 = % 85 = BCFU/d 42.5 = CFU/100126 = DMR Value Reported Number of Excursions .00157 2 .000127 2 .00157 2 3835.8 5 48.2 5 63.1 5 62 1 129.58 13 355.59 13 1643 13 56 1 6792.7 12 85 12 7350.6 12 94.9 12 35.9 1 78 1 118.31 10 316.96 10 Monitoring Period End Date 08/31/2022 08/31/2022 08/31/2022 08/31/2022 08/31/2022 08/31/2022 09/30/2022 09/30/2022 09/30/2022 09/30/2022 09/30/2022 09/30/2022 10/31/2022 10/31/2022 10/31/2022 10/31/2022 10/31/2022 10/31/2022 10/31/2022 Perm Feature ID 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 Limit Set Designator A A A A A A A A A A A A A A A A A A A Parameter Desc Statistical Base Short Desc E. coli DAILY MX Solids, suspended percent MO AV MN Solids, total suspended 30DA AVG Solids, total suspended 30DA AVG Solids, total suspended 7 DA AVG Solids, total suspended 7 DA AVG BOD, 5-day, percent remo MO AV MN Solids, suspended percent MO AV MN Solids, total suspended 30DA AVG Solids, total suspended 30DA AVG Solids, total suspended 7 DA AVG Solids, total suspended 7 DA AVG BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, 20 deg. C 7 DA AVG BOD, 5-day, percent remo MO AV MN E. coli 30DAVGEO E. coli 30DAVGEO E. coli DAILY MX Solids, suspended percent MO AV MN Limit Unit Short Desc Limit Value CFU/100410 % 85 lb/d 3379 mg/L 30 lb/d 5069 mg/L 45 % 85 % 85 lb/d 3379 mg/L 30 lb/d 5069 mg/L 45 mg/L 30 mg/L 45 % 85 BCFU/d 42.5 CFU/100126 CFU/100410 % 85 DMR Value Qualif ier Code > = = = = = = = = = = = = = = = = > = DMR Value 2419.6 68 5590.6 68.2 5879.2 70.2 82 79 3995.2 49 5120.4 62.6 41.6 47.9 83 51.33 138.77 2419.6 75 Reported Number of Excursions 10 1 10 10 10 10 1 1 6 6 6 6 3 3 1 8 8 8 1 Monitoring Period End Date 10/31/2022 10/31/2022 10/31/2022 10/31/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 12/31/2022 12/31/2022 12/31/2022 01/31/2023 Perm Feature ID 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 Limit Set Designator A A A A A A A A A A A A A A A A A A A Parameter Desc Statistical Base Short Desc Solids, total suspended 30DA AVG Solids, total suspended 30DA AVG Solids, total suspended 7 DA 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 7 DA AVG E. coli 30DAVGEO E. coli 30DAVGEO E. coli DAILY MX Solids, suspended percent MO AV MN Solids, total suspended 30DA AVG Solids, total suspended 30DA AVG Solids, total suspended 7 DA AVG Solids, total suspended 7 DA AVG BOD, 5-day, 20 deg. C 7 DA AVG E. coli DAILY MX Solids, total suspended 7 DA AVG BOD, 5-day, percent remo MO AV MN Limit Unit Short Desc Limit Value lb/d 3379 mg/L 30 lb/d 5069 mg/L 45 lb/d 3379 mg/L 30 mg/L 45 BCFU/d 42.5 CFU/100126 CFU/100410 % 85 lb/d 3379 mg/L 30 lb/d 5069 mg/L 45 mg/L 45 CFU/100410 mg/L 45 % 85 DMR Value Qualif ier Code = = = = = = = = = > = = = = = = = = = DMR Value 6366.6 77.8 6841.1 82.8 3700.1 47.1 55.1 62.87 176.26 2419.6 76 5885.5 75.1 7385.2 98.2 51.2 2084.3 49.8 84 Reported Number of Excursions 10 10 10 10 5 5 5 9 9 9 1 9 9 9 9 1 3 1 1 Monitoring Period End Date 02/28/2023 02/28/2023 02/28/2023 03/31/2023 03/31/2023 04/30/2023 04/30/2023 04/30/2023 04/30/2023 04/30/2023 04/30/2023 04/30/2023 04/30/2023 05/31/2023 05/31/2023 05/31/2023 05/31/2023 05/31/2023 07/31/2023 Perm Feature ID 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 Limit Set Designator A A A A A A A A A A A A A A A A A A A Parameter Desc Statistical Base Short Desc E. coli DAILY MX Solids, total suspended 30DA AVG Solids, total suspended 7 DA AVG BOD, 5-day, 20 deg. C 30DA AVG E. coli DAILY MX BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, 20 deg. C 7 DA AVG BOD, 5-day, 20 deg. C 7 DA AVG BOD, 5-day, percent remo MO AV MN 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 7 DA AVG BOD, 5-day, percent remo MO AV MN Solids, total suspended 30DA AVG Solids, total suspended 7 DA AVG E. coli DAILY MX Limit Unit Short Desc Limit Value CFU/100410 mg/L 30 mg/L 45 mg/L 30 CFU/100410 lb/d 3379 mg/L 30 lb/d 5069 mg/L 45 % 85 lb/d 3379 mg/L 30 mg/L 45 mg/L 30 mg/L 45 % 85 mg/L 30 mg/L 45 CFU/100410 DMR Value Qualif ier Code = = = = = = = = = = = = = = = = = = = DMR Value 796.7 32.2 53.8 31.9 1034.9 4538.7 58.1 5649.9 71.7 74 3408.7 43.6 57.4 40.3 55.8 80 39.3 52.9 898.4 Reported Number of Excursions 1 2 2 1 3 7 7 7 7 1 4 4 4 2 2 1 3 3 1 Monitoring Period End Date 08/31/2023 09/30/2023 09/30/2023 09/30/2023 09/30/2023 09/30/2023 09/30/2023 09/30/2023 09/30/2023 09/30/2023 09/30/2023 09/30/2023 09/30/2023 04/30/2024 07/31/2024 08/31/2024 08/31/2024 09/30/2024 09/30/2024 Perm Feature ID 001 001 001 001 001 001 001 001 001 001 001 001 001 001 TX1 001 TX1 TX1 TX1 Limit Set Designator A A A A A A A A A Q Q Q Q A A A A A Q Parameter Desc Statistical Base Short Desc E. coli DAILY MX BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, 20 deg. C 7 DA AVG BOD, 5-day, percent remo MO AV MN E. coli 30DAVGEO E. coli DAILY MX Solids, total suspended 30DA AVG Solids, total suspended 7 DA AVG Polychlorinated biphenyls [ 30DA AVG Polychlorinated biphenyls [ 30DA AVG Polychlorinated biphenyls [ DAILY MX Polychlorinated biphenyls [ DAILY MX E. coli DAILY MX Whole Effluent Toxicity [W MN VALUE E. coli DAILY MX Whole Effluent Toxicity [W MN VALUE Whole Effluent Toxicity [W MN VALUE Whole Effluent Toxicity [W MN VALUE Limit Unit Short Desc Limit Value DMR Value Qualif ier Code CFU/100410 = lb/d 3379 = mg/L 30 = mg/L 45 = % 85 = BCFU/d 42.5 = CFU/100410 = mg/L 30 = mg/L 45 = lb/d ###### = ug/L .00102 = lb/d ###### = ug/L .0011 = CFU/100410 = % 95 = CFU/100410 = % 95 = % 95 < % 95 < DMR Value Reported Number of Excursions 504.6 1 3396.7 4 39.8 4 51.2 4 80 1 47.11 3 923.4 3 39.6 3 57.7 3 ###### 6 .001769 6 ###### 6 .001769 6 2203 1 1 1 469.9 1 30 1 30 1 30 3 Monitoring Period End Date 10/31/2024 10/31/2024 10/31/2024 11/30/2024 12/31/2024 12/31/2024 12/31/2024 12/31/2024 01/31/2025 02/28/2025 03/31/2025 03/31/2025 Perm Feature ID 001 001 TX1 TX1 001 001 TX1 TX1 TX1 TX1 TX1 TX1 Limit Set Designator A A A A A S A Q A A A Q Parameter Desc Statistical Base Short Desc Polychlorinated biphenyls [ DAILY MX Polychlorinated biphenyls [ DAILY MX Whole Effluent Toxicity [W MN VALUE Whole Effluent Toxicity [W MN VALUE E. coli DAILY MX Polychlorinated biphenyls [ DAILY MX Whole Effluent Toxicity [W MN VALUE Whole Effluent Toxicity [W MN VALUE Whole Effluent Toxicity [W MN VALUE Whole Effluent Toxicity [W MN VALUE Whole Effluent Toxicity [W MN VALUE Whole Effluent Toxicity [W MN VALUE Limit Unit Short Desc Limit Value DMR Value Qualif ier Code lb/d ###### = ug/L ###### = % 95 < % 95 < CFU/100410 = ug/L ###### = % 95 = % 95 < % 95 < % 95 < % 95 < % 95 < DMR Value Reported Number of Excursions ###### 2 .00114 2 30 1 30 1 483.4 1 .001113 2 30 1 30 3 30 1 30 1 30 1 30 3