Document ydV8apymdK1G1BEk9MGzmVVX
Region 6 Compliance Assurance and Enforcement Division
INSPECTION REPORT
Inspection Date(s): Media: Regulatory Program(s)
10/12/2017 Water SDWA
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Contact:
Lama Escondida Water Association
Loma Escondida Water Association
Agua Fria Road & Cuarto Vientos
Belen, New Mexico 87002
Post Office Box 6995 (10147 2nd Street SW)
Albuquerque, NM 87107 {Albuquerque, NM 87119)
Valencia County John DaCamara
I Facility Manager
505-350-8765 Jrd @z-scapesinc.com
FRS Number: Identification/Permit Number: Media Number: NAICS: SIC:
110064569122 NM3500432 N/A N/A 4941
Personnel participating in inspection:
John DaCamara
Z-Management {Z-Scapes,
Inc.)
David A Esparza
EPA/6EN-WM
Amy Andrews
EPA/6EN-WM
EPA Lead Inspector Signature/Date
Supervisor Signature/Date
~<Wid (L up=
{Inspector name}
I( ' . //;,____ t-L
I {Supervisor name}
Facility Manager
Environmental Engineer Environmental Engineer
505-350-8765
505-366-8402 214-907-0638
11/03/2017 Date
3(:>-o(,'i-'
Date
6ENFORM-019-R6 (10/6/14)
1
Inspection Report Peer Review Form
1
no comments.
Reviewed with comments, re-submittal not requested.
Returned, comments should be addressed, re-submittal requested to verify corrections.
Comments were not fully addressed
Comments were
addressed.
Technical Reviewer:
comments: no comments.
Reviewed with comments, re-submittal not requested. Returned, comments should be addressed, re-submittal requested to verify corrections.
Comments were not fully addressed I
6ENFORM-015-R2 (11/4/2013)
Page 4 of 4
Loma Escondida Water Association / (PWS ID: NM3500432)
Inspection Date 10/12/2017
Section I - INTRODUCTION
PURPOSE OF THE INSPECTION
EPA Region 6 inspectors David Esparza and Amy Andrews arrived at the Loma Escondida Water Association (herein after referred to as Loma Escondida) at 10:00 AM (Mountain Standard Time (MST)) on October 12, 2017 for an announced inspection. We met with John DaCamara, Facility Manager and owner of Z-Management (aka Z-Scapes, Inc.) at the Opening Conference. I presented my credentials to Mr. DaCamara, and informed him that this was an EPA inspection to ascertain the facilities progress towards compliance with the Safe Drinking Water Act (SDWA), specifically with respect to the maximum contaminant level (MCL) for arsenic, the Groundwater Rule (GWR), monitoring and reporting under the Disinfection Byproduct (DBP) Rule, and the Consumer Confidence Rule (CCR). The scope of the inspection was to evaluate the drinking water system, its ancillary equipment, inclusive of the groundwater source (well), storage tank, treatment system, pumps, distribution piping, operations and management, and to determine facility progress in addressing violations cited in the EPA's administrative orders (AOs), issued on May 2, 2014 and August 14, 2015 (Appendix 2).
FACILITY DESCRIPTION
Loma Escondida is located north of Belen, between Highway 314 and I-25, just off of Cuarto Vientos and Agua Fria Road (see map below). Mr. DaCamara stated the drinking water system serves approximately 23-25 service connections, and consists of one active production well, which pumps approximately 120,000 gallons per quarter, the disinfection system equipment and one 15,000-gallon storage tank situated at land surface. DaCamara also stated all of the existing customers have totalizing water meters installed, though some are inaccessible and approximately four (4) water users pay their water bill. The existing system is in continuous operation throughout the year and is staffed and/or maintained by Mr. Tom Jourdan on an as-needed basis. Mr. Jourdan was not available during the inspection. DaCamara, further stated he had assumed operation of the system approximately 1-year ago after the previous owner had walked away and abandoned its contract due to complications with operations and treatment protocols. The original water well was drilled in November 1996 in the name of Scott Patrick & Loma Escondida Water Cooperative (Point of Contact (POC) Mr. John Clark- 505-880-1100); on land owned by Mesa Development Corporation under New Mexico Office of the State Engineer (NMOSE) permit number RG-64110. It should be noted no conveyance document from Scott Patrick & Loma Escondida Water Cooperative to Loma Escondida Water Cooperative could be located. The NMOSE Well Record lists the total depth (TD) of the well at 241 feet below land surface (BLS) and the static water level (SWL) at 30-feet BLS upon completion (Appendix 3). The well has been exceeding the running annual average (RAA) MCL for arsenic for numerous years, and did not have any removal treatment equipment installed at the time of inspection. Mr. DaCamara a Level I certified drinking water operator, sat for the Level II certification exam in May 2016, but did not achieve a passing score. Finally, DaCamara stated the arsenic system design is too expensive and he could not afford it at this time.
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Loma Escondida Water Association / (PWS ID: NM3500432)
Inspection Date 10/12/2017
Section II - OBSERVATIONS At this juncture it should be noted at the onset of the original inspection arrival time 10:00 AM MST, Mr. DaCamara was unable to access (unlock) the pump house door necessitating contact with a locksmith to gain entry. Mr. DaCamara requested we return around 1:30 PM MST which in fact we did and Mr. DaCamara did not (return). I will delineate my Observations into system sections:
1. Water well As previously stated the well had a TD of 241-feet BLS and a SWL of 30-feet BLS, respectfully at
completion (Appendix 3). There was no lightning protection (grounding) for the well, appurtenances, or ancillary
equipment. The concrete pad surrounding the well casing is not sloped away from the wellhead and exhibits
significant degradation due to concrete spalling or sloughing; thus potentially contributing to surface erosion and/or groundwater intrusion (Appendix 1 Photo #1, #2, #3 and #4). The goose-necked casing vent does face downwards, but sizing of the vent screen cannot be ascertained (Appendix 1 Photo #1 and #4). No pressure gauge was observed at the well. A locked metal chain link type perimeter fence surrounds the wellhead, though it does not have barbed wire (aka barb wire) attached to the top for added security as recommended in the New Mexico Environment Department's (NMED) 2013 sanitary survey (Appendix 1 Photo #5). 2. Pump House-
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Loma Escondida Water Association / (PWS ID: NM3500432)
Inspection Date 10/12/2017
The unlocked metal chain link type perimeter fence surrounding the pump house, does not have barbed wire (aka barb wire) attached to the top for added security as recommended in the New Mexico Environment Department's (NMED) 2013 sanitary survey (Appendix 1 Photo #14, #16, #18, and #19). The likelihood of vandalism or theft is exacerbated by this fact and is visually evident by the painted over graffiti on the exterior concrete masonry unit (CMU) wall face.
A liquid chlorine type treatment system has been installed with the dosage adjusted as appropriate and the previously used calcium hypochlorite pellet system removed (Appendix 1 Photo #6).
Two (2) of the three (3) booster pumps are not anchored to their concrete pedestals (Appendix 1 Photo #9 and #12), and all Three (3) pedestals exhibit significant concrete spalling, sloughing or degradation.
The makeshift finished water tap noted in the EPA 2016 Inspection Report (Appendix 1 Photo #7) appears to be the only device in existence.
All finished piping and distribution exhibited extensive corrosion (Appendix 1 Photo #8, #10 and #13).
Pump house exterior piping had been re-plumbed and the open excavation remained (Appendix 1 Photo #15 and #16).
The pump house is utilized as a storage facility/location for chemical storage and did not exhibit proper ventilation with respect to chemical use and potential comingling of non-compatible constituents (Appendix 1 Photo #8 and #11).
The pump house lacks proper signage.
3. Storage Tank-
Mr. DaCamara stated the water storage tank had a capacity of 15,000 gallons of finished water, which differs from the EPA 2016 Inspection Report of 25,000 gallons.
The storage tank valves had recently been serviced and the open excavation remained, however it is unclear how often the valves are exercised (Appendix 1 Photo #17 and #18).
The storage tank does not have a roof access ladder; therefore, we were not able to ascertain if the issues identified in previous inspection reports or sanitary surveys' have been addressed.
The storage tank drain line is located approximately 50 feet outside of security fence, and was properly screened.
The likelihood of vandalism or theft is visually evident by the painted over graffiti on the storage tank walls (Appendix 1 Photo #15, #16 and #17).
Section III - AREAS OF CONCERN
The overall housekeeping and/or maintenance of the system appurtenances and surrounding environs need to be addressed. As previously stated the concrete spalling or sloughing around the wellhead and earthen erosion potentially contributes to groundwater intrusion. The degradation of the booster pump pedestals or outright lack of anchoring (securing) of the booster pumps raises potential safety issues or system piping failure due to vibration. Any unaddressed system or piping vibration could result in breakage of treatment/distribution piping joints or connections due the visible corrosion. The open excavations and extensive overgrowth of invasive vegetation could invite vermin and reptiles (Appendix 1 Photo #15, #16, #17, #18, #21 and #23).
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Loma Escondida Water Association / (PWS ID: NM3500432)
Inspection Date 10/12/2017
A closing conference could not be held as Mr. DaCamara did not return to the system site after the locksmith gained access. Additionally, Mr. DaCamara did not respond to telephone calls, electronic mail (email) information requests (Appendix 4) or text messages, though he had contacted me by telephone (505-350-8765), and confirmed his email address by text message from this telephone number.
What was discussed with Mr. DaCamara and requested via email dated October 16, 2017 (Appendix 4) was the following:
Confirmation of the date he assumed operational control and/or ownership of the water system.
A summary of the number of dwelling units (DU's) and users on the system. A signed copy of the recently completed Consumer Confidence Report (CCR). Analytical results for the previous three (3) months, inclusive of chain of custody (CoC) forms,
and laboratory check-in sheets. Analytical results of his coliform monitoring. Analytical results with respect to your lead and copper sampling. Analytical results with respect to your disinfection by-products (DBP). A detailed piping, system and treatment diagram (map), delineating sampling points,
distribution lines and storage facilities. Preferably, current as-built drawings. A time estimate (schedule) pertaining to system rehabilitation and/or repairs/updates. Verification of storage tank capacity. Chlorine dosage/residual log sheets Status of Level II operator certification. A copy of Mr. Jourdan's operator certification.
To date there has been no response from Mr. DaCamara regarding my information requests by telephone (voicemail message), email and text message.
Section IV - FOLLOW UP
No information was received by EPA after exiting the Facility on [last day].
Section V - LIST OF APPENDICES
Appendix 1 - Photo Log - 23 photos taken 10/12/17 Appendix 2 - Enforcement History Appendix 3 - Loma Escondida NMOSE Well Permit and Well Completion Log Appendix 4 - Email Information Request
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Loma Escondida Water association / (PWS ID: NM35000432 Inspection Date 10/12/2017
Appendix 1 Photograph Log
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Wellhead land surface concrete pad. Note the concrete spalling in lower center of picture. October 12, 2017, 1:23 PM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Wellhead land surface concrete pad. Note the concrete deterioration in upper right of picture. October 12, 2017, 1:23 PM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Wellhead. Note the concrete sloughing and erosion at land surface around the pad. October 12, 2017, 1:25 PM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 4
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Wellhead. Note the deteriorated condition of the concrete pad surrounding the wellhead. October 12, 2017, 1:27 PM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 5
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Well. Note the approximate height of the perimeter fencing and lack of barbed wire on top. The fenced enclosure is locked. October 12, 2017, 1:29 PM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 6
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Pump House. Note the newly installed chlorination unit in center of picture. October 12, 2017, 1:32 PM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 7
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Pump House with the newly installed PVC piping, presumed "raw water" tap (left side of picture with tag), chlorination port and make shift finished water tap (lower right corner of picture). October 12, 2017, 1:32 PM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 8
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Pump House general picture of the chlorination unit, system piping and two (2) of the three (3) booster pumps. Note the storage of chemicals (chlorine, oxidizer, water and debris). October 12, 2017, 1:47 PM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 9
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Pump House general picture of the chlorination unit, system piping and all three (3) booster pumps. Note the storage of chemicals (chlorine, oxidizer, water and debris). October 12, 2017, 1:40 PM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 10
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Pump House representative picture of the corrosion along the pipe connections or joints. This is located at the middle booster pump. October 12, 2017, 1:33 PM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 11
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Pump House general picture of the middle or second booster pump without visible evidence of pump anchoring to concrete pedestal. Note the storage of chemicals (chlorine, oxidizer, water and debris). October 12, 2017, 1:39 PM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 12
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Pump House general picture of the first booster pump and lack of anchoring into concrete pedestal, a common issue with all three (3) of the booster pumps. October 12, 2017, 1:35 PM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 13
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Pump House general picture of the corrosion of valves and pipe unions. This valve is located at the second booster pump along the finished water line. October 12, 2017, 1:37 PM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 14
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Pump House. The likelihood of vandalism or theft is exacerbated by this fact and is visually evident by the painted over graffiti on the exterior concrete masonry unit (CMU) wall face. October 12, 2017, 1:49 PM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 15
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Pump House newly installed exterior piping and open excavation. October 12, 2017, 10:03 AM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 16
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Pump House newly installed exterior piping and open excavation. October 12, 2017, 10:05 AM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 17
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Storage Tank newly serviced valves and open excavation. It is not clear how often these or any valves are exercised. October 12, 2017, 10:07 AM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 18
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Storage Tank newly serviced valves and open excavation. It is not clear how often these or any valves are exercised. October 12, 2017, 10:08 AM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 19
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Storage Tank general picture of the exterior of the tank. Note the extensive overgrowth of invasive vegetation and painted over graffiti on the storage tank. October 12, 2017, 1:47 PM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 20
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Storage Tank general picture of the storage tank and the low perimeter fencing without barbed wire for security. October 12, 2017, 1:47 PM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 21
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Storage Tank general picture of the tank and the extensive overgrowth of invasive vegetation and painted over graffiti. October 12, 2017, 1:47 PM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 22
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association Facilities. The storage tank, pump house and wellhead (located to the left center of the picture). October 12, 2017, 1:47 PM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 23
Location: Loma Escondida Water Association
City: Belen
County/Parish: Valencia
State: New Mexico
Loma Escondida Water Association pump house and storage tank unlocked enclosure gate. October 12, 2017, 1:47 PM
Loma Escondida Water Association / (PWS ID: NM3500432)
Inspection Date 10/12/2017
Appendix 2 Enforcement History
Loma Escondida Water Association / (PWS ID: NM3500432)
Inspection Date 10/12/2017
Appendix 3 Loma Escondida NMOSE Well Permit and Well Completion Log
Loma Escondida Water Association / (PWS ID: NM3500432)
Inspection Date 10/12/2017
Appendix 4 Email Information Request
Esparza, David
From: Sent: To: Cc: Subject:
Esparza, David Friday, October 27, 2017 1:21 PM Pijawka, John, NMENV Esparza, David; Andrews, Amy FW: Loma Escondida
As we discussed. Please let me know if you require anything else.
From: Esparza, David Sent: Tuesday, October 24, 2017 12:22 PM To: Maria.Medina@state.nm.us Cc: Esparza, David <esparza.david@epa.gov> Subject: FW: Loma Escondida
As discussed
From: Esparza, David Sent: Monday, October 16, 2017 8:41 AM To: 'Jrd@z-scapesinc.com' <Jrd@z-scapesinc.com> Cc: Peters, Carol <Peters.Carol@epa.gov>; Saunders, Jerry <Saunders.Jerry@epa.gov>; Esparza, David <esparza.david@epa.gov>; Andrews, Amy <andrews.amy@epa.gov>; Hall, Chelo <Hall.Chelo@epa.gov> Subject: Loma Escondida
Mr. DaCamara
This is to reiterate my understanding of our morning discussion on October 12, 2017. The locksmith, as you advised did permit access to the treatment system. As you were not available upon our return in the afternoon. I will list my understanding as follows:
1. You only recently acquired operational control of the system and all ancillary equipment and pay for its operation and maintenance (O&M) out of your own pocket.
2. Only 2-3 users pay their monthly bill. 3. You recently completed a Consumer Confidence Report (CCR). 4. You have not completed or installed an arsenic treatment system. 5. Appropriate water samples are collected and submitted for analysis. 6. You are currently in the process of re-plumbing piping and/or rehabilitating equipment. 7. The system is operated by a Mr. Tom Jourdan.
Therefore, at this juncture I request the following information as soon as possible, but no later than close of business on October 20, 2017.
The date you assumed operational control and/or ownership the water distribution system and its appurtenances.
A summary (quantity) of the number of homes and users (persons) on the system. Water use derived from your totalizing meter.
A signed copy of your recently completed CCR, inclusive of results and any/all previous that are available. Analytical results for the previous three (3) months, inclusive of chain of custody (CoC) forms, and laboratory
check-in sheets. Analytical results of your coliform monitoring.
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Analytical results with respect to your lead and copper sampling. Analytical results with respect to your disinfection by-products (DBP). A detailed piping, system and treatment diagram (map), delineating sampling points, distribution lines and
storage facilities. Preferably, current as-built drawings. A time estimate (schedule) pertaining to system rehabilitation and/or repairs/updates. Verification of storage tank capacity. Chlorine dosage/residual log sheets Status of Level II operator certification. A copy of Mr. Jourdan's operator certification. Please let me know if you have any questions.
David A. Esparza, P.E. Environmental Engineer NPDES Water Enforcement U.S. Environmental Protection Agency 1445 Ross Avenue, Suite 1200 (6EN-WM) Dallas, Texas 75202-2733 (505) 366-8402 (Office) eMail: esparza.david@epa.gov
Confidentiality Notice: This email may contain material that is confidential, privileged and/or attorney work product and is for the sole use of the intended recipient. Any review, reliance or distribution by others or forwarding without express permission is strictly prohibited. If you are not the intended recipient, please contact the sender and delete all copies.
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