Navajo Tribal Utility Authority
Maintaining a Tribally-Owned and Operated Compliance Laboratory
The Navajo Tribal Utility Authority (NTUA) Environmental Compliance and
Laboratory Department offers laboratory services to drinking water and
wastewater systems throughout the Navajo Nation. The laboratory also
serves in a broader capacity carrying out many essential regulatory
compliance activities for NTUA systems. With a small staff serving over 90
systems across an area larger than West Virginia, the NTUA laboratory is a
notable example of improving utility sustainability by investing in the
development and growth of an internal laboratory department.
Benefits
The NTUA laboratory has a critical role in protecting public health
throughout the Navajo Nation by ensuring compliance for drinking water and wastewater systems. With
numerous NTUA systems, the laboratory's services result in significant cost savings for the utility and remove
the logistical burdens of transporting samples to laboratories outside of the Navajo Nation, it also adds the
benefit of reduced holding times for time-sensitive samples. In addition to performing sample analysis, the
laboratory provides comprehensive compliance assistance to NTUA systems. These additional services include:
determining compliance monitoring schedules, coordinating the preparation and delivery of Consumer
Confidence Reports, conducting training at district offices and providing on-site assistance to systems. The
laboratory also expanded its services to support organizations outside the NTUA such as the Hopi Tribe, the
Bureau of Indian Affairs and the Indian Health Service to help maintain and construct infrastructure to benefit
the Navajo and other tribal communities. The substantial analytical capacity that is maintained within the
laboratory ensures the availability of critical analyses during public health emergencies.
Background
The Navajo Nation covers over 27,000 square miles across Arizona,
New Mexico and Utah. The NTUA was established in 1959 as a
single small water utility in Shiprock, New Mexico. Today, NTUA is
the largest multi-utility enterprise owned and operated by an
American Indian tribe. The NTUA provides electric, solar energy,
water, wastewater, natural gas and communications services to
residents of the Navajo Nation. Today, the NTUA serves an
estimated 39,323 water customers via 94 water systems with a
total of 217 groundwater wells and two surface water systems.
They also have 10 National Pollutant Discharge Elimination System
(NPDES) permitted wastewater facilities. The NTUA laboratory
serves as the core of NTUA's drinking water and wastewater
compliance activities.
The NTUA includes a headquarters office in Ft. Defiance, Arizona
and eight district offices. Each district office has a drinking water
and wastewater department that oversees systems in their respective area. The districts conduct sampling for
their systems, as well as provide the systems operators.
"NTUA management
understands that to keep
systems in compliance we
need a functioning
laboratory at all times."
Raquel Whitehorse
Supervisor, NTUA Laboratory
Figure 1. The Geographic Area of the Navajo Nation and
Populated Communities.
NTUA Environmental Compliance and Laboratory Department
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The NTUA Laboratory
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Figure 2. NTUA Laboratory equipment Photo Credit: NTUA
The NTUA Environmental Compliance and Laboratory
Department is located at the NTUA headquarters office
in Ft. Defiance, Arizona. The NTUA laboratory began
operations in 1975 and was certified by the
Environmental Protection Agency (USEPA) in 1977. Prior
to starting the laboratory program, NTUA incurred
significant costs associated with coordinating sample
collection and transportation to the nearest laboratory
in Gallup, New Mexico. The distance to the Gallup
laboratory also affected the NTUA's ability to meet
holding times for some regulated contaminants. With
these concerns and the continued growth of the
communities they serve, the NTUA made the decision to
build and operate their own laboratory facility.
In 1977, the NTUA laboratory was certified to analyze
bacteriological samples and wastewater samples for
NPDES-permitted systems. In 1979, the laboratory was
certified for wet chemistry and basic metals, in 1987, the
laboratory acquired an atomic absorption spectro-
photometer to analyze for metals. In that timeframe, it
also acquired an ion chromatograph and began
conducting analyses for anions. Today, the laboratory is
certified to analyze biological and inorganic contaminants
for drinking water. Samples for radionuclides and organic
and other regulated contaminants are sent to a
contracted laboratory for analysis. Whether analyzed
internally or through a contracted laboratory, the NTUA
laboratory accounts for all samples and reporting to the
Navajo Nation EPA to ensure compliance with drinking
water regulations. For NPDES permit compliance, the
laboratory is certified to analyze for biological oxygen
demand (BOD), total dissolved solids (TDS), total
suspended solids (TSS) and Escherichia coli (E. coli).
The laboratory employs nine people, including chemists and laboratory technicians who are trained to analyze
samples and technical assistants who review and record the water quality data. To maintain laboratory certification,
proficiency is demonstrated annually for all analyzed parameters through third-party examiners. Laboratory staff
receive training through the Inter-Tribal Council of Arizona and the Arizona Department of Environmental Quality.
Figure 3. NTUA staff preparing samples. Photo Credit: NTUA
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Responsibilities of the NTUA Environmental Compliance and Laboratory
Department
Sampling Support
4 Coordinating annually with regulatory agencies to
determine the required sampling schedules.
* Ordering sample kits containing bottles, preservatives
and sampling paperwork for sample collection and
preparing and shipping these kits to district offices.
4 Verifying that requirements are met for samples
submitted by the district offices, such as ensuring the
chain of custody form is completed correctly, among
other tasks
4 Shipping the samples that are collected by the eight
district offices and that are not analyzed in-house to
the contracted laboratory.
4 Providing training and field support on the use of equi
reliance.
Figure 4. NTUA staff performing laboratory analysis. Photo Credit: NTUA
to ensure data quality and operator self-
NTUA LABORATORY
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NTUA CHAIN OF CUSTODY RECORD
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(928) 729-5721
~ Fax (928) 729-6249
Please Print Clearly
CLIENT INFORMATION
Client Name
Address
City
State
Zip
Phone
System Name
PWSIDS/NPDES#
Contact
Sites/Location
RDC*
Laboratory Analysis Options (Heavy Metals, Wet Chemistry and Wastewater)
WATER ANALYSIS
Heavy Metals : Sb, As, Ba, Be, Cd, Cr, Cu, Fe, Pb, Mn, Hg, Nl, Se, Tl, Zn
Wet Chemstry: Alkalinity, Ca, CI, Corroslvity, F, Total Hardness, Mg, N02, N03, pH, Phosphate, K, Na, S04, Total Dissolved Solids,
Turbidity, and Temperature
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Wastewater: BOD, TSS, TDS, pH, Temperature. Total Residual Chlorine and Settable Solids
Preservative
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Reporting and Compliance Activities
4 Data entry for analyses conducted by the NTUA laboratory into a
database and generating compliance reports.
4 Compliance reports review for both NTUA and contracted
laboratory results, and submission of the reports to the
regulatory authorities.
4 Set and adjust system monitoring schedules for individual
systems through coordination with the regulatory agencies.
4 Notify the water system of an MCL violation, conduct follow-up
sampling analysis, and adjust monitoring schedules to quarterly
(if required).
4 Consumer Confidence Report (CCR) reviews for the 86 NTUA Figures, ntua staff recording analysis results,
water systems in Navajo Nation EPA's jurisdiction and the 8 water Photo Credit: ntua
systems in USEPA Region 9's jurisdiction. Then coordinate with
the NTUA Public Relations Department and a vendor to print, package and distribute the final CCRs to
customers. Additional assistance is provided to small systems by posting their CCRs to the NTUA website
and communicating the availability of the CCRs to customers.
4 Sanitary survey participation, which are led by the primacy agency, and assist with system review and
mitigation of potential issues.
Training Activities
4 Biannual training for drinking water and wastewater operators in the eight district offices. The training
includes proper procedures for compliance sampling, calibration of fluoride and chlorine monitoring
instruments, and proper maintenance of laboratory records.
4 Ad hoc training for district offices, as requested, or when training is needed for new equipment or sampling
techniques.
4 Safety training for emergency response personnel related to chemical spills and other hazardous materials,
as well as emergency response training.
NTUA Environmental Compliance and Laboratory Department 4 | Page
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Additional Compliance Services
* The NTUA laboratory performs drinking water analyses for other clients. These services are performed for
a fee and are arranged through an annual purchase order with the laboratory or on an individual sample
basis. Other entities utilizing NTUA laboratory services include:
o Bureau of Indian Affairs' (BIA) school system and other public schools;
o Hopi Tribal Utilities;
o National Monument water systems;
o Indian Health Service Office of Environmental Health; and,
o Casinos.
4 The NTUA laboratory performs analyses for treated wastewater discharge for the BIA.
4 The laboratory manages a website which enables users to view and obtain drinking water and wastewater
sampling information online. Utility staff can review sample results online from the previous 90 days. The
website also reports the number of samples collected forthe month and the numberof remaining monthly
samples that are required (Figure 7).
I
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Navajo Tribal Utility Authority^
^IWHc • Water/Wastewater W^Netural Gas • Solar Energy
Providing Utilities to the Navajo Nation Since 1959
Display | 20
v Samples page
List all Samples
| List only Samples where | MonthPWSID location contains
and Sampling Point contains (leave blank for all)
and Sample Type contains J (leave blank for all)
| (leave blank for all)
Format to edit'create:
List all formats
Figure 7. Snapshot of NTUA Laboratory Website Where Systems Can Use to Check Sample Results.
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Looking to the Future
The NTUA laboratory plays a pivotal role in utility compliance and has enjoyed a great deal of stability due to
limited staff turnover. Still, the responsibilities of the laboratory and the number of NTUA systems have grown
steadily over the years while the number of laboratory staff (9) has remained unchanged since the early 1990s,
In an effort to improve efficiency, the laboratory recently purchased compliance monitoring software for
drinking water systems, which is expected to result in streamlined tracking and reporting. The laboratory is
also working on expanding their workforce so that they can continue to provide high quality services to their
existing and future customers. Raquel Whitehorse, Supervisor at the NTUA laboratory, notes that the
laboratory department started with the goal of providing routine sampling analyses but has grown
substantially over the years as additional monitoring and compliance support was needed. Ms. Whitehorse
recommends that other utilities looking to develop in-house laboratory capacity start small and add new
responsibilities slowly over time to build a sustainable program.
LAB0RAT0Rr
DEPARTMENT
Figure 8, NTUA Environmental Compliance and Laboratory Department Building. Photo Credit: NTUA
4% United States
Environmental Protection
^1 M^\ Agency
EPA S10-R-20-004
MARCH 2019
NTUA Environmental Compliance and Laboratory Department
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