Document zzvK37nMm1xKgvLOyX69KM2yn

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 05/14/2015 Water SDWA Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: N/A Nambe Headstart Water System 189 State Road 503/Cundiyo Road Pojoaque, NM 87506 1574 State Road 502 Pojoaque, NM 87506 Santa Fe County Adan Delgado Administrative Contact 505.455.2282 FRS Number: Identification/Permit Number: NAICS: SIC: 110063218316 NM3598726 N/A 4941 Personnel participating in inspection: Terry Cummings Nambe Headstart Jim Corbin Corbin Consulting Stephen Wiman Good Water Company Maria Medina NMED Jenna Manheimer EPA/6EN-WR School Superintendent (Retired) Independent Consultant Geologist Enforcement Coordinator Enforcement Officer 505.819.2324 505.466.4605 505.471.9036 505.476.8629 214.665.7318 EPA Lead Inspector Signature/Date Supervisor Signature/Date JENNIFER MANHEIMER Jenna Manheimer Digitally signed by JENNIFER MANHEIMER DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=JENNIFER MANHEIMER, dnQualifier=0000054325 Date: 2015.06.22 17:22:20 -05'00' WILLIE LANE Willie Lane, Jr. Digitally signed by WILLIE LANE DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=WILLIE LANE, dnQualifier=0000007235 Date: 2015.06.23 10:09:08 -05'00' Date Date 6ENFORM-019-R6 (10/6/14) 1 Nambe Headstart (PWSID NM3598726) Inspection Date: 5/14/2015 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspector Jenna Manheimer, in conjunction with New Mexico Environment Department (NMED) Enforcement Coordinator Maria Medina, arrived at the Nambe Headstart school at 10:30 am on May 14, 2015, for a planned inspection of the drinking water system. We met with Terry Cummings, the School District Superintendent, Jim Corbin, an independent consultant and Stephen Wiman from Good Water. I presented my credentials to Terry Cummings, and informed her that this was a joint EPA/NMED inspection of the drinking water system to verify that adequate treatment for arsenic and selenium removal has been installed, and that appropriate follow-up and system maintenance will be carried out. FACILITY DESCRIPTION Nambe Headstart is an elementary school that serves approximately 40 non-transient people, mostly children from the Tribal community, during months when school is in session (September through May). The water source is a single well, drilled about 30 years ago to a depth between 50-100 feet, which produces 20 gallons per minute. Well #1 is located outside of the school building and adjacent to the parking lot (Appendix 1, Photos 1-2). Nambe Headstart has a history of exceeding the maximum contaminant level (MCL) for both arsenic and selenium, with violations for selenium in the Safe Drinking Water Information System (SDWIS) as far back as 1999. Since January 2012, Nambe Headstart has continuously exceeded the running annual average (RAA) for both arsenic and selenium each quarter. Since 2008, bottled water jugs have been available to all schoolchildren and employees at Nambe Headstart. However, sinks within the facility served untreated water. Some time passed before the appropriate responsible party/owner of the water system from the school district was aware of the water quality issues. By late 2011, the school's superintendent became involved in mitigating the contaminant, after which it took additional time to leverage funds for installing treatment (Terry Cummings advocated for the passage of Senate Bill 9, which financed the school's filtration system). In February 2013, an interim "bare-bone" treatment system was installed for cooking water only. Then on July 28, 2014, a Good Water 0.001 nanofiltration system (schematic below) was installed, designed to remove both arsenic and selenium, for a total cost of $40,000. Well #1 5 pre-filter 0.001 Nanofiltration Antiscalent (See Appendix 1, Photos 4-7). Repressurizer Distribution Calcite Re-mineralizer UV Carbon Filter 2 Nambe Headstart (PWSID NM3598726) Inspection Date: 5/14/2015 Section II - OBSERVATIONS Well #1 is located inside a vault adjacent to parking lot that slopes downward toward well (Appendix 1, Photo 2). The well pad is raised, but the well head itself is a few feet below grade (Appendix 1, Photo 3). Flooding from the parking lot is unlikely, but if the water level rose above well pad, it would present contamination to the source. Reject water from the filtration process is discarded into a drain (Appendix 1, Photo 8). Piping terminates below the upper rim of drain, which could back-siphon if the drain overflows. The chemical sampler from NMED was not collecting arsenic and selenium compliance samples at the correct sample tap, which should be the entry point to the water system. However, this facility is small (one building), and the entry point will be a sample tap inside the building, also accessible for drinking water. Therefore, any sample tap designated as the entry point, and all taps within the building must provide water that has passed through the nanofiltration system. Section III - AREAS OF CONCERN The treatment system is housed inside a small kitchen, including antiscalent and calcite. These chemicals are not particularly hazardous, but it is important that they are properly contained and that employees are cautious when stepping around them. During the inspection, each party present confirmed that all water flowing from Well #1 into any given sample tap passes through nanofiltration. This was also observed by EPA and NMED inspectors, to the extent possible. There is a community center across the street from Nambe Headstart that utilizes the same well as the school. This facility hosts meetings 2-3 times each month by an unknown number of people. The community center is possibly registered under a separate PWS. There is a water softener installed, but no other treatment. Section IV - FOLLOW UP Since installation of the nanofiltration system, sample results for both arsenic and selenium have dropped to non-detectable levels. Compliance is calculated based on the quarterly RAA, with the MCL for arsenic at 0.010 mg/L and 0.05 mg/L for selenium. As of 1/20/2015, the RAA for arsenic was 0.0098 mg/L and 0.0348 for selenium. As of 4/1/2015, the RAA for arsenic was 0.0044 and 0.0154 for selenium. o Return violations in SDWIS to compliance. o AO will remain open until PWS remains compliant for four consecutive quarters. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 8 photos taken 5/14/2015 3 Nambe Headstart Water System (PWSID NM3598726) Inspection Date: May 14, 2015 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Nambe Headstart Water System City: Pojoaque County/Parish: Santa Fe State: New Mexico Photo File Name: Well #1 Pad & Hatch Date of Photo: 5/14/2015 Time of Photo: 11:06 am Photographer: Jenna Manheimer Description: 30-year old well inside vault, with a depth between 50-100 feet. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Nambe Headstart Water System City: Pojoaque County/Parish: Santa Fe State: New Mexico Photo File Name: Area Around Well #1 Date of Photo: 5/14/2015 Time of Photo: 11:26 am Photographer: Jenna Manheimer Description: Located adjacent to the parking lot, which slopes downward toward the well vault. The well pad is adequately raised, though well head is a few feet below grade. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Nambe Headstart Water System City: Pojoaque County/Parish: Santa Fe State: New Mexico Photo File Name: Well #1 Vault Date of Photo: 5/14/2015 Time of Photo: 11:09 am Photographer: Jenna Manheimer Description: Well #1 is located inside a vault, with top of well head a few feet below grade. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Nambe Headstart Water System City: Pojoaque County/Parish: Santa Fe State: New Mexico Photo File Name: Treatment System Controls Date of Photo: 5/14/2015 Time of Photo: 10:45 am Photographer: Jenna Manheimer Description: Control panel and measurement gauges for nanofiltration system. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Nambe Headstart Water System City: Pojoaque County/Parish: Santa Fe State: New Mexico Photo File Name: Nanofiltration Units Date of Photo: 5/14/2015 Time of Photo: 10:51 am Photographer: Jenna Manheimer Description: Canisters containing nanofiltration membranes. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Nambe Headstart Water System City: Pojoaque County/Parish: Santa Fe State: New Mexico Photo File Name: Pressure Tank + Antiscalent Storage Date of Photo: 5/14/2015 Time of Photo: 10:54 am Photographer: Jenna Manheimer Description: Tank to repressurize system post-membrane filtration, and antiscalent, which is added premembrane filtration to aide in the dispersion of insoluble particles, all located in school's kitchen. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Nambe Headstart Water System City: Pojoaque County/Parish: Santa Fe State: New Mexico Photo File Name: UV + Carbon Filters Date of Photo: 5/14/2015 Time of Photo: 10:50 am Photographer: Jenna Manheimer Description: After filtration, water passes through UV unit, and is then "polished" by carbon filters before entering distribution. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Nambe Headstart Water System City: Pojoaque County/Parish: Santa Fe State: New Mexico Photo File Name: Waste Piping Date of Photo: 5/14/2015 Time of Photo: 10:49 am Photographer: Jenna Manheimer Description: Effluent reject water pipes into kitchen drain.