Document zdx6aLzOq6gkMMM1pzvXg4mY0

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 03/27/2024 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: Los Alamos County White Rock WWTF 600 Overlook Road White Rock, New Mexico 87571 1000 Central Avenue Los Alamos, New Mexico 87544 Los Alamos 505-470-5606 Joshua Silva joshua.silva@lacnm.us Superintendent FRS Number: 110009831209 Identification/Permit Number: Media Identifier Number: NAICS: SIC: NM0020133 NA 221320 4952 Personnel participating in inspection: Jennifer Baca Los Alamos County Department of Public Utilities Marcos Ocanas Los Alamos County Department of Public Utilities SMA-Operations (Contract Operator) Joshua Silva Los Alamos County Department of Public Utilities James Martinez Los Alamos County Department of Public Utilities Nafis Fuad NMED-PSRS Shawnee Suazo NMED-SWQB David Esparza EPA-R6/ECDWM Engineering Associate WWTP Supervisor WWTP Superintendent WWTP Operator Compliance/Enforcement Team Lead Complex Facilities Inspector Environmental Engineer EPA Lead Inspector Signature/Date DAVID ESPARZA David Esparza Digitally signed by DAVID ESPARZA Date: 2024.04.24 12:02:12 -06'00' Date Supervisor Signature/Date ROBERTO BERNIER Roberto Bernier Digitally signed by ROBERTO BERNIER Date: 2024.04.25 10:01:16 -05'00' Date 6ENFORM-020-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Los Alamos County/White Rock WWTF Permit No. NM0020133 Inspection Date 03/27/2024 PURPOSE OF THE INSPECTION United States Environmental Protection Agency (EPA) Region 6 inspector David Esparza, PE, accompanied by Mr. Nafis Fuad, and Ms. Shawnee Suazo from the New Mexico Environment Department (NMED), arrived at the Los Alamos County-White Rock (White Rock) Wastewater Treatment Facility (WWTF) approximately 9:30 AM on March 27, 2024, for an unannounced inspection. I presented my credentials to Mr. Joshua Silva and Mr. Marcos Ocanas and informed them 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 Los Alamos County representatives, observations made by the EPA inspector, NMED, and records and reports maintained by the permittee (Los Alamos County), and the EPA. Before leaving the facility on March 27, 2024, an exit briefing was held with Ms. Baca, Mr. Silva, and Mr. Ocana, to explain areas of concern noted at the time of the inspection. It should be noted the WWTP also maintains a discharge permit (DP-907) issued by the New Mexico Environment Department (NMED), Groundwater Quality Bureau (GWQB) that allows a permitted discharge up to 0.8MGD. FACILITY DESCRIPTION The Los Alamos County White Rock Wastewater Treatment Facility (WWTF) was originally constructed circa 1966 with improvements completed in 1978. The WWTF has a design flow of 0.82 MGD with an average daily flow of 0.3 MGD serving a population of approximately 5,800 residents. The facility is located at 600 Overlook Road White Rock, Los Alamos County, New Mexico (denoted in Aerial Image #1 below). WWTP hours of operation are Monday through Friday 7 AM to 4:30 PM. The existing WWTF provides primary and secondary levels of treatment. The wastewater is treated with a trickling filter system. Currently the effluent is disinfected with chlorine, followed by dechlorination, thence discharged to Caada Del Buey, through a closed conduit pipe to the Rio Grande, via Outfall 001. Water designated for reuse under a ground water permit (DP-907) is drawn off before dechlorination and used for irrigation of nearby athletic fields and a park. Generated sewage sludge is transported and disposed of approximately 5-miles Northeast at the Los Alamos-Bayo WWTF (NM0020141) for further treatment. Construction of the new WWTF commenced in January 2022 with an estimated substantial completion date of August 2024. The planned construction would replace either by demolition or abandonment the existing headworks, clarifiers, and chorine contact chamber. The new WWTF proposes a design flow of 0.5 MGD or an approximate 40% decrease, while continuing to provide primary and secondary levels of treatment. The wastewater will be treated with an activated sludge system. Following treatment by primary and secondary clarifiers, the wastewater is processed through a tertiary filtration system consisting of disk filters. Under the new process scheme the effluent will traverse through two (2) channels of two (2) banks each of ultraviolet (UV) modules for disinfection, prior to being discharged to Caada Del Buey, thence to the Rio Grande via an outfall (Outfall 001). 2 Los Alamos County/White Rock WWTF Permit No. NM0020133 Inspection Date 03/27/2024 Aerial Image #1: Overall view of the Los Alamos-White Rock Wastewater Treatment Facility. Note: this Aerial Image is dated May 7, 2023, and illustrates the existing WWTF. Aerial from Google Earth maps. Table 1: White Rock Lift Stations Lift Station 1 Karen Circle 2 Kimberly 3 Rio Bravo 4 Potrillo 5 Estante Way Note: See Appendix 4 White Rock Lift Station Map White Rock does have written policies and procedures to address any potential sanitary sewer overflow events (SSOs), and standard operating procedures (SOPs) pertaining facility operations and maintenance (O&M). Currently, there is no Industrial Users (IU) contributing to the WWTF. Section II - OBSERVATIONS I observed the following and/or the following information was provided or stated on January 19, 2024. 3 Los Alamos County/White Rock WWTF Permit No. NM0020133 Inspection Date 03/27/2024 The collection systems (lift stations, etc.) and operation of the WWTF are maintained by different departments within the Los Alamos Public Utilities. The existing WWTF does not have Supervisory Control and Data Acquisition (SCADA) system, however, the current upgrades will provide monitoring of WWTF operations. All five (5) lift station are securely locked inclusive of the hatchways and electrical panels. The Public Utilities Department has an ongoing capital improvement project to implement SCADA and/or upgrades for all lift stations. Los Alamos County does not have a current Asset Management Plan. Los Alamos County does not have a Fats, Oils and Grease (FOG) or permitting program, though the Public Utility Department does preform grease trap inspections. The WWTF maintains a backup diesel generator for power that is routinely exercised. There are no satellite communities contributing to the WWTF. The WWTF had secure perimeter fencing; thus, limiting access. The overall WWTF's operations and maintenance (O&M), and general facility housekeeping appeared to be in good order. Section III - AREAS OF CONCERN A review of the submitted Integrated Compliance Information System (ICIS) Discharge Monitoring Reports (DMR) data for the period January 20, 2022, through October 31, 2023, indicates NPDES permit excursions with respect to Nitrogen (ammonia total), Total Suspended Solids (TSS), 5-day Biological Oxygen Demand (BOD5), Escherichia coli (E. coli), Total Chlorine Residual (TCR), Total Mercury (as Hg), fecal Coliform (general), and pH (Appendix 5 ICIS E90 Effluent Violations). EPA Region 6 inspector David Esparza conducted a closing conference at the Los Alamos -White Rock WWTF approximately at 11:30 AM on March 27, 2024, for the inspection. Section IV - FOLLOW UP Additional information or clarification was requested on April 1, 2024, via electronic mail (email) and by telephone. The Request for Information (RFI) included: A current copy of the WWTP Site Plan- Note: the previous/existing Plan can be notated (clearly) to reflect the rehabilitation/upgrades currently under construction. A project timeline of commissioning or substantial completion of the current construction 4 Los Alamos County/White Rock WWTF Permit No. NM0020133 Inspection Date 03/27/2024 A complete electronic copy of your Sanitary Sewer Overflow (SSO) protocol, inclusive of all SSO events and associated work orders/work sheets for the previous two (2) years. A complete electronic copy of your Standard Operating Procedures (SOPs) and clarification how often it is updated. Identification of the quantity, location, and names of any lift stations (LS), wet wells etc. Section V - LIST OF APPENDICES Appendix 1 - Photo Log 4 photographs taken 3/27/2024. Appendix 2 - Current Site Plan Appendix 3 - Process Flow Diagram Appendix 4 - White Rock Lift Station Map Appendix 5 - Integrated Compliance Information System (ICIS) Database E90 Exceedances 5 Los Alamos County/White Rock WWTF Permit No. NM0020133 Inspection Date 03/27/2024 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: White Rock Wastewater Treatment Facility City: White Rock County/Parish: Los Alamos State: New Mexico View of existing headworks looking approximately North. Note: this structure is identified in Appendix 2 Current White Rock Site Plan to be demolished or abandoned. (DSCN2688). Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: White Rock Wastewater Treatment Facility City: White Rock County/Parish: Los Alamos State: New Mexico View of existing grit removal located adjacent to the existing headworks looking approximately South. Note1: the concrete degradation and spalling. Note2: this structure is identified in Appendix 2 Current White Rock Site Plan to be demolished or abandoned. (DSCN2689). Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: White Rock Wastewater Treatment Facility City: White Rock County/Parish: Los Alamos State: New Mexico View of the existing chlorine contact chamber. Note1: this structure is identified in Appendix 2 Current White Rock Site Plan to be demolished or abandoned. This disinfection process will be replaced by two (2) channels of two (2) banks each of ultraviolet (UV) modules for disinfection, prior to being discharged to Caada Del Buey, thence to the Rio Grande via an outfall (Outfall 001). (DSCN2691). Photographed by D. Esparza UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: White Rock Wastewater Treatment Facility City: White Rock County/Parish: Los Alamos State: New Mexico View of the White Rock WWTP Outfall 001. Note: it was suggested debris be cleared from the discharge conduit and "riprap" or similar be placed to minimize/prevent back flow or conduit undermining. (DSCN2692). Photographed by D. Esparza Appendix 2 Los Alamos County/White Rock WWTF Permit No. NM0020133 Inspection Date 03/27/2024 Current White Rock WWTF Site Plan Site Layout Appendix 3 Los Alamos County/White Rock WWTF Permit No. NM0020133 Inspection Date 03/27/2024 White Rock WWTF Process Flow Diagram Process Flow Diagram Appendix 4 Los Alamos County/White Rock WWTF Permit No. NM0020133 Inspection Date 03/27/2024 White Rock WWTF Lift Station Map Appendix 5 Los Alamos County/White Rock WWTF Permit No. NM0020133 Inspection Date 03/27/2024 Integrated Compliance Information System (ICIS) Database E90 Exceedances E90 Effluent Violations From 01/01/2019 - Present NM0020133 LOS ALAMOS COUNTY (W Monitoring Period End Date 01/31/2022 01/31/2022 02/28/2022 02/28/2022 02/28/2022 03/31/2022 03/31/2022 04/30/2022 05/31/2022 06/30/2022 07/31/2022 08/31/2022 09/30/2022 10/31/2022 11/30/2022 12/31/2022 12/31/2022 12/31/2022 01/31/2023 01/31/2023 01/31/2023 02/28/2023 02/28/2023 03/31/2023 03/31/2023 04/30/2023 Perm Feature ID 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 Limit Set Designator A A A A A A A A A A A A A A A A A A A A A A A A A A Parameter Desc Statistical Base Short Desc BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, 20 deg. C 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 BOD, 5-day, 20 deg. C 30DA AVG Oxygen, dissolved [DO] MINIMUM Oxygen, dissolved [DO] MINIMUM Oxygen, dissolved [DO] MINIMUM Oxygen, dissolved [DO] MINIMUM Oxygen, dissolved [DO] MINIMUM Oxygen, dissolved [DO] MINIMUM Oxygen, dissolved [DO] MINIMUM Oxygen, dissolved [DO] MINIMUM Oxygen, dissolved [DO] MINIMUM BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, 20 deg. C 7 DA AVG Oxygen, dissolved [DO] MINIMUM BOD, 5-day, 20 deg. C 30DA AVG BOD, 5-day, 20 deg. C 7 DA AVG Oxygen, dissolved [DO] MINIMUM BOD, 5-day, 20 deg. C 30DA AVG Oxygen, dissolved [DO] MINIMUM BOD, 5-day, 20 deg. C 30DA AVG Oxygen, dissolved [DO] MINIMUM BOD, 5-day, 20 deg. C 30DA AVG Limit Unit Short Desc mg/L mg/L mg/L mg/L % mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L Limit Value 30 45 30 45 85 30 4.1 4.1 4.1 4.1 4.1 4.1 4.1 4.1 4.1 30 45 4.1 30 45 4.1 30 4.1 30 4.1 30 DMR Value Qualif ier Code = = = = = = = = = = = = = = = = = = = = = = = = = = DMR Value 42.23 47.26 46.46 52.87 83.9 33.18 3.25 3.03 3.49 3.43 3.62 3.56 3.64 3.64 3.72 39.47 45.18 3.73 40.95 46.53 3.85 40.26 3.85 31.38 3.98 35.67 Monitoring Period End Date 04/30/2023 05/31/2023 06/30/2023 07/31/2023 07/31/2023 08/31/2023 09/30/2023 10/31/2023 11/30/2023 12/31/2023 Perm Feature ID 001 001 001 001 001 001 001 001 001 001 Limit Set Designator A A A A A A A A A A Parameter Desc Oxygen, dissolved [DO] Oxygen, dissolved [DO] Oxygen, dissolved [DO] BOD, 5-day, 20 deg. C Oxygen, dissolved [DO] Oxygen, dissolved [DO] Oxygen, dissolved [DO] Oxygen, dissolved [DO] Oxygen, dissolved [DO] BOD, 5-day, 20 deg. C Statistical Base Short Desc MINIMUM MINIMUM MINIMUM 30DA AVG MINIMUM MINIMUM MINIMUM MINIMUM MINIMUM 30DA AVG Limit Unit Short Desc mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L Limit Value 4.1 4.1 4.1 30 4.1 4.1 4.1 4.1 4.1 30 DMR Value Qualif ier Code = = = = = = = = = = DMR Value 3.32 3.88 3.53 31.47 3.27 3.99 2.85 3.98 3.6 30.72