Gallup issued administrative order for Clean Water Act violations

Copyright © 2008
Gallup Independent
By Kathy Helms
Diné Bureau

GALLUP — Gallup Wastewater Treatment Plant has been cited by U.S. Environmental Protection Agency with violations of the Clean Water Act following a July 15 inspection of the wastewater treatment plant.

EPA Region 6 in Dallas issued an administrative order Dec. 4 stating that violations include failure to meet effluent limits at outfall 001A and failure to submit required discharge monitoring reports.

Dave Bary of Region 6 said the order does not assess a monetary penalty at this time. The city of Gallup received the order Dec. 18 and has 30 days to meet the first compliance deadline.

“We’re working on the response on it,” Mayor Henry Mendoza said Tuesday and referred questions to Gallup Joint Utilities Executive Director Lance Allgood.

Portions of the permit require GWTP to sample and test its effluent and monitor its compliance with permit conditions. It also is required to file with EPA certified discharge monitoring reports detailing results, and noncompliance reports when appropriate.

The permit places certain limitations on the quality and quantity of effluent discharged to the receiving stream, in this case the waters of the Rio Puerco in the Lower Colorado River Basin. Certified discharge monitoring reports show the facility exceeded permitted effluent limits for fecal coliform, E. Coli bacteria, total residual chlorine, and biochemical oxygen demand.

The seven-day and 30-day averages for fecal coliform in August 2006 as well as this past June and July was “too numerous to count,” as was the seven-day and 30-day average for E. Coli in July. On June 24, GWTP’s lab technician noticed power out to parts of the plant and sewage backing up. About 1,800 gallons of raw sewage went into the Rio Puerco.

Allgood said the effluent hadn’t received proper disinfection and exceeded the permit requirements for bacteria.

According to EPA, within 30 days of receipt of the order, GWTP is required to submit a written report detailing specific actions taken to correct the violations; replace two inoperable aeration brushes in the oxidation ditch; repair the weirs and skimmer arms in the clarifiers to ensure they are even and the worn rubbers in the skimmer arms replaced; and submit to EPA all quarterly progress reports for copper from the effective date of the permit to the effective date of the order.

New Mexico Environment Department inspectors who conducted the July inspection found that GWTP violated its National Pollutant Discharge Elimination System permit by failing to submit progress reports for total copper compliance since the permit became effective July 1, 2006.

GWTP also has the option of arranging a meeting with EPA within 45 days of the effective date to discuss allegations contained in the order.

“Likely the way we will proceed is we will submit a report the first or second week in January and after they receive the report, give them a call and see if there’s anything we really need to discuss with them,” Allgood said.

“The order doesn’t have any penalties associated with it, which we didn’t expect. We have been expecting the order since the inspection. I’m assuming the reason they didn’t issue an order on all the violations is that they have been receiving our updates and our reports.” He said he doesn’t see a problem in obtaining compliance with the order within the time frame.

Regarding replacing two inoperable aeration brushes in the oxidation ditch, Allgood said one of those was replaced quite a while back. “The other one, the bearings were replaced and they’re just waiting to get the motor back in.

I don’t know the exact schedule but it will certainly be within 30 days.”

He said he believes there was some confusion in the original inspection regarding the clarifiers. “The inspection in this order refers to the primary clarifiers. We’re pretty sure they intended to say the secondary, because all the mechanisms and what not in the primaries were taken care of and rehabbed during the plant upgrade, so all the rubbers were new and the weirs were all leveled.

“A weir is like a V-notch and it goes around the exterior of the circular basin and maintains the water flow across and through that basin equally. They have to be level otherwise you get more water flow on one side of the basin than the other, which can cause some short-circuiting.

“In other words, the whole purpose of the clarifier is to slow the water down and allow the solids to settle. If you get increased velocities on one side of the clarifier because the weirs are unlevel, you could possibly have some short-circuiting. We’ve never really seen that; they’re not that out of level. But either way, by the 30-day date, all the weirs will have been releveled. The rubbers were replaced a long time ago.”

Allgood said they have been in communication with EPA and have been sending them progress updates on all the violations listed ever since the inspection.

Quarterly progress reports for copper have been submitted, according to Allgood. “I don’t know if within their organization it hasn’t gotten to the right place, but we’ve already resubmitted all that stuff. We’ll, of course, resubmit it again with our response to the order, with possibly the exception of the one that’s at the lab being tested now. We don’t know if we’ll have the results back from the lab within that time frame.”

He said the copper is from naturally occurring groundwater, GWTP’s water source. “We’ve never exceeded the copper limits, but the issue was they didn’t have the reports we had submitted. I think we found one report we thought we had submitted that we didn’t. We have since submitted all that stuff. The testing was done, they just didn’t have them on file.”