Document qa0eRRgnKgMzwBLz71nyYz0yE

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 9-27-2018 Drinking Water SDWA Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Village of Fort Sumner Fort Sumner Municipal Water System Village of Fort Sumner, New Mexico Village of Fort Sumner, New Mexico, 88119 PO Box 180, Fort Sumner, NM-88119 Village of Fort Sumner, New Mexico, 88119 DeBaca county Jamie Wall Clerk fscityhalljw@plateautel.net - 575-355-2401 FRS ID PWS # NAICS: SIC: 110013119053 NM03527706 221310 4941 Personnel participating in inspection: Cathie Eisen Village of Fort Sumner Louis Gallegos Village of Fort Sumner David Esparza EPA R6 6EN-WM Rachel Matthews EPA R6 6EN-WM Ken Aubuchon EPA R6 6EN-WM Sandra Gabaldon NM Environment Dept. Contract Operator Mayor Inspector Inspector Inspector State Inspector 575-937-6321 575-355-2401 505-366-8402 214-665-8589 281-983-2151 505-827-1041 EPA Lead Inspector Signature/Date Supervisor Signature/Date Digitally signed by RACHEL MATTHEWS RACHEL MATTHEWS DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=RACHEL MATTHEWS, 0.9.2342.19200300.100.1.1=68001003655849 Date: 2018.10.26 10:40:06 -05'00' {Inspector name} CAROL PETERS-WAGNON Digitally signed by CAROL PETERS-WAGNON DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=CAROL PETERS-WAGNON, dnQualifier=0000009981 Date: 2018.10.26 13:43:33 -05'00' {Supervisor name} Date Date 1 Village of Fort Sumner Municipal Water System Inspection Date (09/27/2018) Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors David Esparza, Rachel Matthews, and Ken Aubuchon incorporated the Fort Sumner Municipal Water System inspection while already onsite for a separate inspection of the wastewater treatment plant. Original entry was made on 9-25-2018 at 0930, with an announced compliance evaluation inspection begun, and completed, on 9-27-2018. We met with Louis Gallegos, Village Mayor, Cathie Eisen, contract operator for both wastewater and drinking water, and Jamie Wall, Village Clerk, at the Opening Conference. David Esparza presented his credentials to the mayor and informed him that this was an EPA inspection to determine compliance with the facility's ability to provide safe and high-quality drinking water in accordance with the Ground Water Rule (GWR) and under the authority of the Safe Drinking Water Act. The GWR requires that all community Public Water Supply systems (PWSs) be surveyed every three years in order to identify significant deficiencies. A sanitary survey consists of a compliance evaluation inspection (CEI) of the following eight elements: 1. Sources 2. Pumps and pumping facilities 3. Water treatment 4. Distribution 5. Monitoring 6. Management & Operations 7. Operator certification 8. Water storage facilities It was also explained that Rachel Matthews would conduct the inspection under the credentials of David Esparza, working toward her credentials for inspecting PWSs. Following this inspection, the Village of Fort Sumner will be responsible for correcting any significant deficiencies observed and documented in this report. According to the GWR, the water system has 30 days from receipt of the sanitary survey report to consult with EPA regarding any appropriate corrective actions to address the deficiencies, and 120 days to complete the corrective actions or develop a schedule to complete them. FACILITY DESCRIPTION The drinking water system consists of: 3 wells, 2 of which are located on one site, o "McMillian (Mac) Well" - 350 GPM pumping capacity o "Grizzle Well" - 550 GPM pumping capacity o "Mares Well" - 400 GPM pumping capacity 2 treatment systems, using 12.5% sodium hypochlorite injection, located at the well/pumping sites 2 on-grade welded steel storage tanks, with a capacity of 500,000 gallons each o "Grizzle Tank" - supplied by the Grizzle and Mares wells o "McMillian (Mac) Tank" - supplied by the Mac well Distribution system o 2 pressure reducing valves (PRV) o Distribution piping consists of polyvinyl chloride (PVC), ductile iron, and asbestos concrete (AC) o Approximately 600 service connections (with a population of approximately 2,304 according to Drinking Water Watch) Sales to Valley Mutual Domestic Water Consumers Association - with a separate permit and distribution system (for approximately 480 customers according to Drinking Water Watch). 2 Village of Fort Sumner Municipal Water System Inspection Date (09/27/2018) Locations: McMillian well, treatment system, and tank are located at coordinates 34.528875 North, -104.202458 West, just north of County Road 3-12, off County Road 3-13. See aerial photo below: McMillian (Mac) location: aerial from Google Maps Mares and Grizzle wells, and their treatment systems, are located at coordinates 34.547588 North, 104.209161 West just northeast of County Road 3-11 and the corner of Truchas Creek Road, just off Truchas Creek Road. See aerial photo below: Mares and Grizzle Wells location: aerial from Google Maps 3 Village of Fort Sumner Municipal Water System Inspection Date (09/27/2018) The Grizzle Tank is located just southwest of County Road 3-11 corner turn, at Truchas Creek Road, at end of unmarked road at the coordinates 34.536355 North, -104.22825 West. See aerial photo below: Grizzle Tank location: aerial from Google Maps Other wells: A fourth well ("Truchas Well", # FS-20-X-2) is owned/operated by the village, but is non-potable bulk water point of diversion. This was not included in the inspection. Section II - OBSERVATIONS A. Sources a. The Mares and Grizzle wells are currently offline due to positive total coliform bacteria, violating the Revised Total Coliform Rule (RTCR), which the New Mexico Environment Department (NMED) addressed in two recent notification letters. See Appendix 3. b. Access to the Mares and Grizzle wells location required driving through multiple feedlot areas at a home site and gated area. See photo #5 in Appendix 1. c. A cattle feedlot is located next to the fenced area of Mares and Grizzle wells. See photo #6 and #7 in Appendix 1. d. The concrete pad surrounding the Mares and Grizzle wellheads is cracked at various locations. See photo #8 in Appendix 1. e. Rodent holes were observed next to concrete pads at the Mares and Grizzle wells. f. The screen on the air relief valve for Grizzle well is ineffective. See photo #10 in Appendix 1. g. There is a gap in the well plate at the Grizzle well. See photo #11 in Appendix 1. h. The first "customer" appears to be the cattle feedlot next to the Mares and Grizzle wells, with a frost-free hose bib. See photo # 13 in Appendix 1. 4 Village of Fort Sumner Municipal Water System Inspection Date (09/27/2018) B. Pumps and pumping facilities a. Flow meter no longer in operation at Mac well b. Overflow valve for Mac well house, not seating properly and vegetation not managed. See photo #1 in Appendix 1. c. The raw water sample port is in-line with the chlorine injection location at the Mares and Grizzle wells. See photo #9 in Appendix 1. d. The flush line directly to the Grizzle well has no gasket or other protection for the flapper valve and is possibly misaligned. See photo #12 in Appendix 1. C. Water treatment Both treatment systems have 12.5% sodium hypochlorite injection D. Distribution The system has two Pressure Reducing Valves (PRV) located below ground level. Both exhibit corrosion, are subject to flooding (not at minimum height) and do not have properly screened vents. At least one PRV has open electrical lines. See Photo #15 in Appendix 1. E. Monitoring a. Currently no dead-end chlorine residual monitoring exists b. Chlorine residuals currently being tested with a Hach colorimetric test kit, but manganese adjustments not being made. F. Management & Operations a. No Operations & Maintenance (O&M) or emergency contingency plan b. No spill control/protection for sodium hypochlorite (liquid chlorine containers) c. No audible/visual, or notification alarm system d. No lightening protection on any appurtenance or associated ancillary equipment G. Operator certification Currently under contract operator until December 2018. At this time, there is no permanently hired certified operator. H. Water storage facilities a. Grizzle Tank area overrun with vegetation, making it difficult (and potentially hazardous) to observe problems and perform maintenance. See photo #2 and #3 in Appendix 1. b. The Grizzle tank overflow valve splashpad is nonexistent. Currently using small area of rock under pipe, allowing vegetation overgrowth. See Photo #4 in Appendix 1. Section III - Areas of Concern 1. The Mares and Grizzle wells are currently offline due to positive total coliform bacteria. 2. There is a private well at the house, and inside a cattle lot. See Photo #14 in Appendix 1. Based on aerial measurements, the private well appears to be about 1,060 feet - or less than a quarter mile from the Mares and Grizzle wells. This may be potential for contamination of the groundwater within the vicinity of the public water supply wells. 3. The first "customer" appears to be the cattle feedlot close by the Mares and Grizzle wells, with a frost-free hose bib next to a barn and cattle lot. See photo # 13 in Appendix 1. This is a potential contamination to the public water supply if it is a customer and there is no backflow prevention. 5 Village of Fort Sumner Municipal Water System Inspection Date (09/27/2018) 4. The cattle feedlots next to the Mares and Grizzle wells may be a potential for contamination. 5. Possible manure pile at the north side of the Mares and Grizzle wells may be a potential for contamination. 6. There is currently no O&M or emergency contingency plan. This was also addressed in the 2016 Sanitary Survey Report from NMED, dated 1/26/2017. See report in Appendix 2. 7. Lack of O&M was evident at all locations during the inspection, including vegetation management around wells, tanks, buildings, overflow valves, etc. 8. Monitoring of dead-ends for chlorine residuals is not being completed. 9. Overflow valve for Mac well is not seating properly and therefore open to intrusion. 10. Manganese adjustments for the Hach instrument has not been done. This may be an issue with false chlorine residual readings. 11. The gap in the well plate at the Grizzle well is a potential conduit for contamination. 12. The raw water sample port is in-line with the chlorine injection location at the Mares and Grizzle wells. See photo #9 in Appendix 1. 13. The system has two Pressure Reducing Valves (PRV) located below ground level. Both exhibit corrosion, are subject to flooding (not at minimum height) and do not have properly screened vents. At least one PRV has open electrical lines. See Photo #15 in Appendix 1. Section V - FOLLOW UP The following information was requested by EPA via email on October 5, 2018: 1. Information on any easement (or other legal information) regarding entry to the well locations, if necessary. 2. Any agreement(s)/restrictions regarding how that same property receives drinking water for the home and the livestock, 3. Any map/schematic of the easement and/or property boundaries surrounding the Mares and Grizzle well locations. Information was submitted for a 1964 sales agreement for the well and its surrounding land, a 1996 Right of Way Easement (ROW) for a powerline, and a 1996 legal description (with plat) of the powerline easement. See Appendix 4. The ROW includes "in consideration of a water hook-up". It is unclear what this means. Information regarding a warranty deed in 1982 was also submitted. See Appendix 5. A follow-up statement from Village staff clarified that there is no public/county road access to this area, only private roads and gates. Section VI - LIST OF APPENDICES Appendix 1 - Photo Log Appendix 2 - 2016 Sanitary Survey Report Appendix 3 - Notification letters regarding Level 1 Assessment Appendix 4 -- Grizzle well purchase and ROW Easement Appendix 5 - 1982 Warranty Deed 6 Village of Fort Sumner Municipal Water System Inspection Date (09/27/2018) Appendix 1 - Photo Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Fort Sumner Municipal Water System Photographer: Rachel Matthews City: Village of Fort Sumner County: De Baca State: NM Photo 1: Overflow valve for Mac Well, not seating properly and vegetation not managed Photo 2. Grizzle Tank area overrun with vegetation, making it difficult (and potentially hazardous) to observe problems and perform maintenance UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Fort Sumner Municipal Water System Photographer: Rachel Matthews City: Village of Fort Sumner County: De Baca State: NM Photo 3. Grizzle Tank area overrun with vegetation, making it difficult (and potentially hazardous) to observe problems and perform maintenance Photo 4. Grizzle Tank overflow valve. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Fort Sumner Municipal Water System Photographer: Rachel Matthews City: Village of Fort Sumner County: De Baca State: NM Photo 5. Driving through cattle feedlot to get to the Grizzle and Mares wells location Photo 6. Cattle feedlot next to fenced area of Mares and Grizzle wells. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Fort Sumner Municipal Water System Photographer: Rachel Matthews City: Village of Fort Sumner County: De Baca State: NM Photo 7. Cattle feedlot next to fenced area of Mares and Grizzle wells. Photo 8. Concrete pad at Mares and Grizzle wells location UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Fort Sumner Municipal Water System Photographer: Rachel Matthews City: Village of Fort Sumner County: De Baca State: NM Photo #9. Raw water sample port in-line with the chlorine injection location. Photo #10. Screen on the air relief valve for Grizzle well. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Fort Sumner Municipal Water System Photographer: Rachel Matthews City: Village of Fort Sumner County: De Baca State: NM Photo #11. Gap in the well plate at the Grizzle well Photo #12. The flush line directly to the Grizzle well has no gasket or other protection for the flapper valve UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Fort Sumner Municipal Water System Photographer: Rachel Matthews City: Village of Fort Sumner County: De Baca State: NM Photo #13. Frost-free spigot (hose bib) at cattle feedlot next to Mares and Grizzle wells - first "customer" Photo #14. Private well located close to house, and inside cattle lot, next to the Mares and Grizzle wells. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Fort Sumner Municipal Water System Photographer: Rachel Matthews City: Village of Fort Sumner County: De Baca State: NM Photo #15. (1 of 2) Pressure Reducing Valves. Some corrosion, electrical open, subject to flooding, no vent. Village of Fort Sumner Municipal Water System Inspection Date (09/27/2018) Appendix 2 - 2016 Sanitary Survey Report Village of Fort Sumner Municipal Water System Inspection Date (09/27/2018) Appendix 3 - Notification letters regarding Level 1 Assessment Appendix 4 - Grizzle well purchase and ROW Easement Appendix 5 - 1982 Warranty Deed