Document rB4JkbMjkNvmEzNpwOynNevjE

EPA Inspection Report - Page 1 of 65 Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 05/10/2017 Water Clean Water Act/ NPDES Company Name: Facility Name: Facility Physical location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Gadsden Independent School District (ISO) #16 1325 West Washington Street Dona Ana County, New Mexico P.O. Box Drawer70 Anthony, New Mexico Dona Ana County Susan Vturralde syturralde@gisd.k12.nm.us I Interim Superintendent FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110011027441 NM0028487 4952 Personnel participating in inspection: Amy Andrews USEPA/GEN-WMH Kenneth AuBuchon USEPA/GEN-WMH Jennifer Foote NMED Alfredo Holguin Gadsden ISO Jessica Herrera Gadsden ISO Mario Apodaca Gadsden ISO Environmental Engineer Environmental Engineer Municipal Inspector Interim Associate Superintendent Director of Physical Plant WWTP Operator 214-907-0638 281-983-2151 505 -827-0596 575-882-6949 575-882-6903 575-882-6200 EPA Lead Inspector Signature/Date Supervisor Signature/Date Digitally signed by AMY ANDREWS AMY ANDREWS DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=AMY ANDREWS, dnQualifier=0000131170 Amy Andrews Date: 2018.01.10 11:40:18 -07'00' ()~,]~(Alfa-- Carol Peters - Date I/1 jr7 Date 6ENFORM-Ol9-R7 (2/15/2017) 1 EPA Inspection Report - Page 2 of 65 Section I - INTRODUCTION Gadsden Independent School District #16 Inspection Date 5/10/2017 PURPOSE OF THE INSPECTION EPA Region 6 inspectors Amy Andrews and Kenneth AuBuchon and New Mexico Environment Department (NMED) inspector Jennifer Foote arrived at the Gadsden Independent School District (ISD) #16 at 9:00am on May 10, 2017 for an unannounced inspection. We met with Mr. Mario Apodaca/WWTP Operator at the high school, who then escorted us back to the middle school where we were joined by Mr. Alfredo Holguin/Interim Assistant Superintendent and Ms. Jessica Herrera/Director of Physical Plant for the Opening Conference. Mr. AuBuchon presented his credentials to Mr. Apodaca, Mr. Holguin and Ms. Herrera and informed them that this was an EPA inspection to determine the WWTP's compliance under the Clean Water Act (CWA). This CEI was conducted under the authority of the National Pollutant Discharge Elimination System (NPDES) permit program, in accordance with the CWA. The generation of this report is based on information supplied by Gadsden ISD representatives, observations made by the EPA inspectors, and records and reports maintained by the permittee (Gadsden ISD), and the EPA. FACILITY DESCRIPTION The Gadsden ISD WWTP facility consists of two separate treatment plants, one each at the middle school and the high school in Anthony, New Mexico, in Doa Ana County. The facility is a nonpretreatment facility classified as a minor non-municipal discharger, permitted for with a total flow capacity of 0.09 million gallons per day (MGD). The middle school maintains approximately 1000 students and faculty, and the high school maintains approximately 2000 students when school is insession. Wastewater from both schools includes the cafeteria, biology and chemistry laboratories, vehicle maintenance shop floor drains and vehicle wash bays. The plant at each school includes a grit removal screen, an aeration basin and a clarifier. Following the clarifier, return activated sludge is pumped back to the aeration basin. The effluent from each WWTP (Outfall 01A is the designated sampling location for the middle school, and Outfall 01B is the sampling location for the high school) flows through piping to a batch tank, where the two effluents mix before going through the ultraviolet (UV) disinfection bank and out to the Rio Grande through Outfall 001. Section II - OBSERVATIONS We began the inspection with a records review. Mr. Apodaca explained that samples are usually collected on Thursday of the first week of the month. Samples for Biochemical Oxygen Demand (BOD) and Total Suspended Solids (TSS) are collected after each of the WWTPs but before the batch tank to the UV disinfection bank, and samples for E. coli bacteria are collected after the UV disinfection. A tour of the WWTP was conducted after the records review. The WWTP at the middle school looked to be operating within normal parameters, however the high school WWTP appeared to have a denitrification issue in the clarifier, which was causing solids to float over the clarifier baffles. Mr 2 EPA Inspection Report - Page 3 of 65 Gadsden Independent School District #16 Inspection Date 5/10/2017 Apodaca pointed out that he had been collecting the BOD and TSS samples directly after the baffles of the clarifier, which is prior to a holding well at the high school batch plant. Mr. Apodaca stated that samples taken after the holding well were having issues meeting limits, but samples collected directly from the clarifier were within sample limits. Upon viewing the clarifier, floating solids were observed passing over the baffles, and it was noted that by collecting a sample from the clarifier it would be possible to visually ensure that the sample didn't include any of the floating solids. Additionally, since the holding well is an integral part of the batch plant circuit and considered another additional treatment stage, the sample was not collected at the end of the treatment process. Section III - AREAS OF CONCERN Requirement NPDES Permit NM0028487, Part IV: Minor - Sewage Sludge Requirements, Element 2 - Surface Disposal, Section I: Requirements Applying to All Sewage Sludge Surface Disposal, Item A.3.: In all cases, if the person (permit holder) who prepares the sewage sludge or supplies the sewage sludge to another person (owner or operator of a sewage sludge unit) for disposal in a surface disposal site, the permit holder shall provide all necessary information to the parties who receive the sludge to assure compliance with these regulations. Item A.4.: The permittee shall give prior notice to EPA (Chief, Permits Branch, Water Management Division, Mail Code 6WQ-P, EPA Region 6, 1445 Ross Avenue, Dallas, Texas 75202) of any planned changes in the sewage sludge disposal practice, in accordance with 40 CFR Park 122.41(I)(1)(iii). These changes may justify the application of permit conditions that are different from or absent in the existing permit. Change in the sludge use or disposal practice may be cause for modification of the permit in accordance with 40 CFR Part 122.62(a)(1). Concern Approximately three years prior to the inspection date, the permittee began contracting with HORVAC Environmental to haul sludge from the WWTPs and surface-dispose of the sludge; previously sludge was hauled to the Doa Ana County South Central WWTP. The permittee was unable to show documentation that notification was given to EPA or NMED of the change in sewage sludge disposal location or facility-type. The permittee was unable to show any sludge sampling or waste manifest records for sludge disposal activities other than a receipt for hauling. Requirement 40 CFR 503.7 Requirement for a person who prepares sewage sludge: Any person who prepares sewage sludge shall ensure the applicable requirements in this part are met when the sewage sludge is applied to the land, placed on a surface disposal site, or fired in a sewage sludge incinerator. ("Person" is defined as an individual, association, partnership, corporation, municipality, State or Federal agency, or an agent or employee thereof.) 503.27 Recordkeeping, (a) When sewage sludge (other than domestic septage) is placed on an active sewage sludge unit: (1) The person who prepares the sewage sludge shall develop the following information and shall retain the information for five years. 3 EPA Inspection Report - Page 4 of 65 Gadsden Independent School District #16 Inspection Date 5/10/2017 (i) The concentration of each pollutant listed in Table 1 of 503.23 in the sewage sludge when the pollutant concentrations in Table 1 of 503.23 are met. (ii) The following certification statement: I certify, under penalty of law, that the information that will be used to determine compliance with the pathogen requirements in (insert 503.32(a), 503.32(b)(2), 503.32(b)(3), or 503.32(b)(4) when one of those requirements is met) and the vector attraction reduction requirement in (insert one of the vector attraction reduction requirements in 503.33 (b)(1) through (b)(8) if one of those requirements is met) was prepared under my direction and supervision in accordance with the system designed to ensure that qualified personnel properly gather and evaluate this information. I am aware that there are significant penalties for false certification including the possibility of fine and imprisonment. (iii) A description of how the pathogen requirements in 503.32 (a), (b)(2), (b)(3), or (b)(4) are met when one of those requirements is met. (iv) A description of how one of the vector attraction reduction requirements in 503.33 (b)(1) through (b)(8) is met when one of those requirements is met. Concern The permittee was unable to demonstrate that any of the above-listed recordkeeping requirements were available. Requirement NPDES Permit NM0028487, Part III: Standard Conditions, B.3. Proper Operation and Maintenance, a. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by permittee as efficiently as possible and in a manner which will minimize upsets and discharges of excessive pollutants and will achieve compliance with the conditions of this permit. Concern The high school WWTP appears to have a denitrification issue in the clarifier, which is causing solids to float over the clarifier baffles. These solids are likely to be the source of TSS, BOD and e. coli sample limit exceedances. Requirement 40 CFR 122.41(j) Monitoring and records. (1) Samples and measurements taken for the purpose of monitoring shall be representative of the monitored activity. Concern The Sampling methodology used for sample collection at Outfall 01B (the internal outfall from the high school) may not result in representative samples of the effluent coming from the high school WWTP (see Observations Section above). Requirement NPDES Permit NM0028487, Part III: Standard Conditions, B. Bypass of Treatment Facilities: c. Prohibition of bypass, (1) Bypass was unavoidable to prevent loss of life, personal injury, or severe property damage; (b) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities, retention of untreated wastes, or maintenance during normal periods of equipment downtime. This 4 EPA Inspection Report - Page 5 of 65 Gadsden Independent School District #16 Inspection Date 5/10/2017 condition is not satisfied if adequate back-up equipment should have been installed in the exercise of reasonable engineering judgment to prevent a bypass which occurred during normal periods of equipment downtime or preventive maintenance, and, (c) The permittee submitted notices as require by Part III.B.4.b. Concern After the batch tank where effluent from the middle school WWTP and the High School WWTP mix, and before the UV station, there is bypass piping present which would allow all effluent to leave the facility without passing through the UV station. This bypass piping has a valve which is normally closed to prevent said bypass from occurring, however, there is no lock on the valve and no leak detection system on the valve. This presents the potential for unknown bypasses to occur, or for someone to accidentally or intentionally open the valve to allow a bypass without following any standard procedures or notifications. Section IV - FOLLOW UP No information was received by EPA after exiting the Facility on May 10, 2017. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 5 photos taken 5/10/2017 Appendix 2 - NPDES Permit No. NM0028487 dated 03/04/2014, selected pages Appendix 3 - Sludge Removal Tickets and Manifest for DP-1355 Discharge Site 5 EPA Inspection Report - Page 6 of 65 Gadsden Independent School District #16 Inspection Date 5/10/2017 Appendix 1 Photograph Log EPA Inspection Report - Page 7 of 65 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Gadsden Independent School District Waste Water Treatment Plant City: Anthony County/Parish: Doa Ana State: New Mexico Photo File Name: P5100077.JPG Date of Photo: 05/10/2017 Time of Photo: 11:30am Photographer: Kenneth AuBuchon Description: On the left is the batch tank in which effluent from 01A and 01B mix. The piping shown on the right goes to the UV disinfection banks which are off the edge of the picture to the right. The pipe shown on the left is a bypass pipe with an unlocked valve which would allow effluent to bypass the UV disinfection bank. EPA Inspection Report - Page 8 of 65 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Gadsden Independent School District Waste Water Treatment Plant City: Anthony County/Parish: Doa Ana State: New Mexico Photo File Name: Date of Photo: 05/10/2017 Time of Photo: 12:10pm Photographer: Kenneth AuBuchon Description: Solids floating in the clarifier at the high school WWTP. EPA Inspection Report - Page 9 of 65 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Gadsden Independent School District Waste Water Treatment Plant City: Anthony County/Parish: Doa Ana State: New Mexico Photo File Name: Date of Photo: 05/10/2017 Time of Photo: 12:17pm Photographer: Kenneth AuBuchon Description: Treated effluent in a holding well at the high school WWTP, after the clarifier and prior to mixing with the effluent from the middle school WWTP. EPA Inspection Report - Page 10 of 65 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Gadsden Independent School District Waste Water Treatment Plant City: Anthony County/Parish: Doa Ana State: New Mexico Photo File Name: Date of Photo: 05/10/2017 Time of Photo: 1:35pm Photographer: Kenneth AuBuchon Description: Outfall 001 EPA Inspection Report - Page 11 of 65 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Gadsden Independent School District Waste Water Treatment Plant City: Anthony County/Parish: Doa Ana State: New Mexico Photo File Name: Date of Photo: 05/10/2017 Time of Photo: 1:37pm Photographer: Kenneth AuBuchon Description: Outfall 001 at the confluence with the Rio Grande. EPA Inspection Report - Page 12 of 65 Gadsden Independent School District #16 Inspection Date 5/10/2017 Appendix 2 NPDES Permit No. NM0028487 dated 03/04/2014, selected pages EPA Inspection Report - Page 13 of 65 EPA Inspection Report - Page 14 of 65 EPA Inspection Report - Page 15 of 65 EPA Inspection Report - Page 16 of 65 EPA Inspection Report - Page 17 of 65 EPA Inspection Report - Page 18 of 65 EPA Inspection Report - Page 19 of 65 EPA Inspection Report - Page 20 of 65 EPA Inspection Report - Page 21 of 65 EPA Inspection Report - Page 22 of 65 EPA Inspection Report - Page 23 of 65 Gadsden Independent School District #16 Inspection Date 5/10/2017 Appendix 3 Sludge Removal Tickets and Manifest for DP-1355 Discharge Site EPA Inspection Report - Page 24 of 65 EPA Inspection Report - Page 25 of 65 EPA Inspection Report - Page 26 of 65 EPA Inspection Report - Page 27 of 65 EPA Inspection Report - Page 28 of 65 EPA Inspection Report - Page 29 of 65 EPA Inspection Report - Page 30 of 65 EPA Inspection Report - Page 31 of 65 EPA Inspection Report - Page 32 of 65 EPA Inspection Report - Page 33 of 65 EPA Inspection Report - Page 34 of 65 EPA Inspection Report - Page 35 of 65 EPA Inspection Report - Page 36 of 65 Gadsden Independent School District #16 Inspection Date 5/10/2017 Appendix 1 Photograph Log EPA Inspection Report - Page 37 of 65 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Gadsden Independent School District Waste Water Treatment Plant City: Anthony County/Parish: Doa Ana State: New Mexico Photo File Name: P5100077.JPG Date of Photo: 05/10/2017 Time of Photo: 11:30am Photographer: Kenneth AuBuchon Description: On the left is the batch tank in which effluent from 01A and 01B mix. The piping shown on the right goes to the UV disinfection banks which are off the edge of the picture to the right. The pipe shown on the left is a bypass pipe with an unlocked valve which would allow effluent to bypass the UV disinfection bank. EPA Inspection Report - Page 38 of 65 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Gadsden Independent School District Waste Water Treatment Plant City: Anthony County/Parish: Doa Ana State: New Mexico Photo File Name: Date of Photo: 05/10/2017 Time of Photo: 12:10pm Photographer: Kenneth AuBuchon Description: Solids floating in the clarifier at the high school WWTP. EPA Inspection Report - Page 39 of 65 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Gadsden Independent School District Waste Water Treatment Plant City: Anthony County/Parish: Doa Ana State: New Mexico Photo File Name: Date of Photo: 05/10/2017 Time of Photo: 12:17pm Photographer: Kenneth AuBuchon Description: Treated effluent in a holding well at the high school WWTP, after the clarifier and prior to mixing with the effluent from the middle school WWTP. EPA Inspection Report - Page 40 of 65 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Gadsden Independent School District Waste Water Treatment Plant City: Anthony County/Parish: Doa Ana State: New Mexico Photo File Name: Date of Photo: 05/10/2017 Time of Photo: 1:35pm Photographer: Kenneth AuBuchon Description: Outfall 001 EPA Inspection Report - Page 41 of 65 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Gadsden Independent School District Waste Water Treatment Plant City: Anthony County/Parish: Doa Ana State: New Mexico Photo File Name: Date of Photo: 05/10/2017 Time of Photo: 1:37pm Photographer: Kenneth AuBuchon Description: Outfall 001 at the confluence with the Rio Grande. EPA Inspection Report - Page 42 of 65 Gadsden Independent School District #16 Inspection Date 5/10/2017 Appendix 2 NPDES Permit No. NM0028487 dated 03/04/2014, selected pages EPA Inspection Report - Page 43 of 65 EPA Inspection Report - Page 44 of 65 EPA Inspection Report - Page 45 of 65 EPA Inspection Report - Page 46 of 65 EPA Inspection Report - Page 47 of 65 EPA Inspection Report - Page 48 of 65 EPA Inspection Report - Page 49 of 65 EPA Inspection Report - Page 50 of 65 EPA Inspection Report - Page 51 of 65 EPA Inspection Report - Page 52 of 65 EPA Inspection Report - Page 53 of 65 Gadsden Independent School District #16 Inspection Date 5/10/2017 Appendix 3 Sludge Removal Tickets and Manifest for DP-1355 Discharge Site EPA Inspection Report - Page 54 of 65 EPA Inspection Report - Page 55 of 65 EPA Inspection Report - Page 56 of 65 EPA Inspection Report - Page 57 of 65 EPA Inspection Report - Page 58 of 65 EPA Inspection Report - Page 59 of 65 EPA Inspection Report - Page 60 of 65 EPA Inspection Report - Page 61 of 65 EPA Inspection Report - Page 62 of 65 EPA Inspection Report - Page 63 of 65 EPA Inspection Report - Page 64 of 65 EPA Inspection Report - Page 65 of 65