Document x1zGXzoDEjVGMve8k9YE3vm11

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 09/29/2022 Water NPDES 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 Tucumcari Tucumcari Wastewater Treatment Plant 1700 North Rock Island Street Tucumcari, New Mexico Post Office Box 1188 Tucumcari, New Mexico 87321 Quay 575-402-4542 Calvin Henson Wastewater Superintendent wastewater@cityoftucumcari.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110000762354 NM0020711 NA 221320 4952 Personnel participating in inspection: Calvin Henson City of Tucumcari David Esparza R6-ECDWM Wastewater Superintendent Environmental Engineer EPA Lead Inspector Signature/Date DAVID ESPARZA David Esparza Digitally signed by DAVID ESPARZA Date: 2022.11.21 13:34:59 -07'00' Date Supervisor Signature/Date ROBERTO BERNIER Date: 2022.11.22 08:14:37 -06'00' Digitally signed by ROBERTO BERNIER Roberto Bernier Date 6ENFORM-020-R8.2 (02/12/2020) 1 Section I - INTRODUCTION City of Tucumcari WWTP Permit No. NM0023396 Inspection Date 09/29/2022 PURPOSE OF THE INSPECTION EPA Region 6 inspector David Esparza, PE arrived at the City of Tucumcari Wastewater Treatment Plant (WWTP) (Tucumcari) at approximately 8:00 AM on September 29, 2022, for an unannounced inspection. I met with Mr. Calvin Henson, Wastewater Superintendent, presented my credentials and informed him that this was an EPA inspection to determine the Tucumcari WWTP's (Tucumcari) compliance under the Clean Water Act (CWA). This compliance evaluation inspection (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 Tucumcari representatives, observations made by the United States Environmental Protection Agency (US EPA) inspector, and records and reports maintained by the permittee (Tucumcari), and the US EPA. Before leaving the facility, an exit briefing was held at 11:30 AM with City of Tucumcari representative Mr. Calvin Henson to explain areas of concern noted at the time of the inspection. FACILITY DESCRIPTION The WWTP is a major discharger with a design flow capacity of 1.2 MGD (million gallons per day) and an average influent flow of 0.4 MGD. The facility is located at 1700 North Rock Island Street, Tucumcari, Quay County, New Mexico (depicted in Aerial Site Image #1 below). The WWTP also accepts approximately 3,500-gallons per day of septage from permitted waste haulers. The facility serves a population of approximately 5,000 residents and is operated by staff within the Public Works Department consisting of 5 full-time equivalent (FTE) positions, during the hours of 7:00 AM to 4:00 PM five (5) days during the regular work week and 1 FTE on weekends. On-call staff is available on an as needed basis. Aerial Site Image #1: Overall view of the City of Tucumcari Wastewater Treatment Plant The WWTP discharges its disinfected effluent through a closed conduit pipe to a point within Breen Pond located approximately 2-miles from the WWTP (located approximately at a point described as 2 City of Tucumcari WWTP Permit No. NM0023396 Inspection Date 09/29/2022 Latitude/Longitude 35 13' 09.18" N, 103 42' 16.69"W), overflow from the pond traverses to No Name Creek, thence travels approximately one-mile to Pajarito Creek, a tributary to the Canadian River. Construction of the new WWTP Medium Rate Activated Sludge facility (MRAS) was completed in 2011 and was a replacement for the original WWTP built in 1982. These upgrades included construction of a water reuse storage pond, pump station, and a pipeline for a water conservation and reuse projects. This upgraded system is a conventional activated sludge process that also incorporates biological nutrient removal. The previous improvements also included upgrades to the headworks, new splitter boxes, rehabilitation of the primary clarifiers, new MRAS basins, secondary clarifiers, two (2) banks of Trojan ultraviolet (UV) disinfection units, a blower/pump building, sludge drying and composting pads, and a new laboratory and administration building. Rehabilitation of the anaerobic and aerobic sludge digesters included replacement of the floating roof with a fixed roof over the anaerobic digester and reinforcement/repairs to the concrete structures. Currently the WWTP is at a 60% design phase of their wastewater Effluent Reuse Project. Upon completion the reuse project will include the installation of new effluent lift pumps to convey Class 1B effluent from the existing facility to two (2) onsite storage ponds, one (1) existing (3 million gallons) and one (1) new (4 million gallons) for a total combined storage of 7 million gallons. The Reuse project also includes installation of Reuse Booster Pumps that will draw from the pond storage and pump via closed conduit pipeline to irrigation pivots at the New Mexico State University (NMSU) property (an existing operation) and the Smith property (new). At the Smith property, three (3) new irrigation pivots will be installed to reuse the Class 1B effluent water the WWTP is producing. Additional electrical upgrades will be installed and power feeds for each irrigation pivot at the Smith property. The WWTP is a gravity flow system with ten (10) lift stations (LS) (Identified in Table 1 below). The lift stations are equipped with standby generators and automatic switchovers in the event of power loss. The generators are exercised monthly to verify system readiness. In the event of a local power outage, an emergency generator at the WWTP is available to operate most of the facility treatment processes except for the blowers. This enables the WWTP to continue the treatment process through gravity flow, unabated. Table 1: City of Tucumcari Lift Stations Lift Station Name 54 66 KOA Date Street Rock Island El Carro Ridge Crest JW Sherwood Tucumcari Truck Terminal (TTT) Comments/Status Operational Operational Operational- proposed to be upgraded in 2023 Operational Operational Operational Operational Operational Stand-by Stand-by 3 City of Tucumcari WWTP Permit No. NM0023396 Inspection Date 09/29/2022 The MRAS is a modified racetrack, having both aerobic and anoxic zones. Flow from the MRAS is sent to the reconditioned secondary clarifiers. The flow from the secondary clarifiers is combined and routed to the ultraviolet (UV) treatment building for disinfection. To address their sludge management, the WWTP has and/or maintains three (3) concrete sludge drying beds (located approximately at the southeast end of the facility) for composting into Class A sludge for land application and/or local agricultural purposes. These beds were originally constructed with underdrains to collect excess wastewater; thus, creating the ability to pump and/or return excess wastewater to the headworks. The one (1) previous industrial use (IU) discharger, Tucumcari Mountain Cheese Factory no longer discharges to the facility. It was indicated they currently discharge to a lined pond permitted by the New Mexico Environment Department (NMED) Ground Water Quality Bureau, but no discharge permit could be located. This previously permitted IU facility is in addition to the proximate motels, restaurants, gas stations, and laundromats. A Supervisory Control and Data Acquisition (SCADA) system provides around the clock monitoring of WWTP operations Additionally, Tucumcari has implemented written policies and procedures to address any potential sanitary sewer overflow events (SSOs), and standard operating procedures (SOPs) pertaining to facility operations and maintenance (O&M), inclusive of daily (morning and evening) visual checks of the WWTP treatment processes and lift stations. These SOPs also include protocols for new hires, inclusive of testing to ensure that they can perform each step properly before advancing on their own. It is not clear whether the city, has a written protocol or mechanism in place pertaining to a Fats, Oils and Grease (FOG) program. Section II - OBSERVATIONS I observed or the following was stated on September 29, 2022. Tucumcari has implemented written policies and procedures to address any potential sanitary sewer overflow events (SSOs), and standard operating procedures (SOPs) pertaining to facility operations and maintenance (O&M), inclusive of daily (morning and evening) visual checks of the WWTP treatment processes and lift stations. Written protocols or mechanisms are in-place for new hires, inclusive of testing to ensure they can perform each step properly before advancing on their own. A Supervisory Control and Data Acquisition (SCADA) system provides around the clock monitoring of WWTP operations. A review of facility record shows the permittee is conducting the sampling and monitoring on the effluent as required. Adequate staffing. The permittee currently maintains five (5) FTE operator positions The overall housekeeping of the WWTP of the grounds and ancillary appurtenances appeared to be well maintained and in operational order. The WWTP did have secure perimeter fencing and lighting; thus, limiting access. 4 City of Tucumcari WWTP Permit No. NM0023396 Inspection Date 09/29/2022 Section III - AREAS OF CONCERN A review of the ICIS database for the period from January 1, 2020, to August 31, 2022 (Appendix 2) indicates NPDES permit excursions. A review of the Integrated Compliance Information System (ICIS) indicates several NPDES permit single event violations (August and November 2020) and July 2021. I conducted a closing conference a closing conference at City of Tucumcari WWTP on September 29, 2022, for the inspection. Section IV - FOLLOW UP The following information was received by EPA on October 5, 2022, after exiting the Facility on September 29, 2022: Electronic copies of the 60% Plan Set drawings for the WWTP re-use lines to the New Mexico State University's Tucumcari Science Center Electronic copies of your WWTP's Standard Operating Procedures (SOP) or a Fats, Oils and Grease (FOG) program Names and/or addresses of any Industrial Users (IUs) discharging to the WWTP. Electronic copies of any applicable Service Agreements with respect to the above IUs. Status of your previously identified lift stations (i.e., operational, or on-standby) Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 4 photos taken 9/29/2022 Appendix 2 - Review of the Integrated Compliance Information System (ICIS) Database for the period from January 1, 2020, to September 19, 2022. 5 City of Tucumcari WWTP Permit No. NM0023396 Inspection Date 09/29/2022 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Tucumcari WWTP City: Tucumcari Photo No. 1 County/Parish: Quay State: New Mexico View of the WWTP's Headworks. The WWTP Supervisor stated that locating replacement parts for the existing facility equipment in general was getting extremely difficult. (DSCN2348) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Tucumcari WWTP City: Tucumcari Photo No. 2 County/Parish: Quay State: New Mexico View of the grit screen removal equipment. (DSCN2349) Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Tucumcari WWTP City: Tucumcari Photo No. 3 County/Parish: Quay State: New Mexico View of one (1) the three (3) sludge drying beds (located approximately at the southeast end of the facility) for composting into Class A sludge for land application and/or local agricultural purposes. These beds were originally constructed with underdrains to collect excess wastewater; thus, creating the ability to pump and/or return excess wastewater to the headworks. (DSCN2346) Photographed D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Tucumcari WWTP City: Tucumcari Photo No. 4 County/Parish: Quay State: New Mexico View of the two (2) banks of Trojan ultraviolet (UV) disinfection units included in the 2011 WWTP upgrades. (DSCN2350) Photographed by D. Esparza City of Tucumcari WWTP Permit No. NM0023396 Inspection Date 09/29/2022 Appendix 2 Review of the ICIS database for the period from January 1, 2020, to September 19, 2022 9/19/22, 9:14 AM FE&C NPDES AIR ICIS: Search Violation Results Admin Reports Help DESPARZA Logout Search Permits Related NPDES Violations ADD SINGLE EVENT VIOLATION List of Violations Related to the Permit Violation Type Single Event Violation Single Event Violation Single Event Violation Single Event Violation Violation Information Violation Violation Code Date RNC Detection Code-Date R013S Dry-weather SSO, no discharge to waters of the U.S., R013S that may endanger health or the environment 08/15/2020 D0017 Permit Violations - Violation Specified in Comment D0017 11/07/2020 R011S Wet-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment R011S 07/02/2021 R013S Dry-weather SSO, no discharge to waters of the U.S., R013S that may endanger health or the environment 07/03/2021 Record Numbers 1 to 4 RNC Resolution Code-Date Action Delete Delete Delete Delete Record Numbers 1 to 4 ICIS Home Reports Help Logout Technical issues? Contact user support Help Desk at (202) 564-7756 or via email at ICIS@epa.gov https://icis.epa.gov/icis/permit/SearchViolation.do?fromSearchCriteriaPage=true&compositeKey=3602358660@NPD&navActivityId=3602358660&nav... 1/2 9/19/22, 9:14 AM ICIS: Search Violation Results https://icis.epa.gov/icis/permit/SearchViolation.do?fromSearchCriteriaPage=true&compositeKey=3602358660@NPD&navActivityId=3602358660&nav... 2/2