Document 2jxLk5E6QVoryr0OnO95xryN5

Region 6 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 08/21/2019 FIFRA Section 12 Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: City of Corpus Christi O. N. Steven Water Treatment Plant 13101 Leopard Street Corpus Christi, TX 78410 Nueces County Kevin Norton, P.E. KevinN@cctexas.com Director of Water Utilities FRS Number: N/A Identification/Permit N/A Number: Media Number: NAICS: SIC: Personnel participating in inspection: Kevin Norton, P.E. City of Corpus Christi Utilities Department Gabriel Ramirez City of Corpus Christi Utilities Department William Creech City of Corpus Christi Utilities Department Rafael Martinez City of Corpus Christi Utilities Department Crystal Ybanez City of Corpus Christi Utilities Department Rebecca Pezzi City of Corpus Christi Utilities Department Lee McMillan EPA Region 6 - Pesticide Enforcement Perry Cervantes Texas Department of Agriculture Ernest Hernandez Texas Department of Agriculture Director of Water Utilities Assistant Director of Water Quality & Treatment Utilities System Manager (361) 826-1874 (361) 826-1202 (361) 826-1954 Water Plant Manager (361) 826-1218 Water Quality Manager Environmental Programs Specialist-Safety Inspector/Environmental Engineer Coordinator for Pesticide Certification and Compliance Inspector/Regional Training Specialist (361) 826-1289 (361) 826-1871 (214) 665-6404 (512) 463-7692 (956) 787-8866 EPA Lead Inspector Signature/Date Supervisor Signature/Date Lee V. McMillan H STUCKEY H. Troy Stuckey Digitally signed by H STUCKEY DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=H STUCKEY, 0.9.2342.19200300.100.1.1=68001003655434 Date: 2019.10.22 15:38:22 -05'00' 10/21/19 Date 10/22/19 Date 6ENFORM-019-R7 (2/15/2017) 1 Section I - INTRODUCTION City of Corpus Christi/O.N. Stevens Water Treatment Plant Inspection Date: 08/21/2019 PURPOSE OF THE INSPECTION EPA Region 6 inspector, Lee McMillan arrived at the City of Corpus Christi O. N. Stevents Water Treatment Plant at 8:53 AM on August 21, 2019 for an announced joint inspection with Texas Department of Agriculture inspectors (TDA), Perry Cervantes and Ernest Hernandez. I presented my credentials to Kevin Norton along with a Notice of Inspection and informed him that this was an EPA inspection to investigate a potential unregistered pesticide. The scope of the inspection was the evaluation of the facility's use of sodium permanganate to treat pests in the water treatment process. At 9:05 AM introductions were made. We met with Kevin Norton, Director of Water Utilities, Gabriel Ramirez, Assistant Director of Water Quality & Treatment, William Creech, Utilities System Manager, Rafael Martinez, Water Plant Manager, Crystal Ybanez, Water Quality Manager, and Rebecca Pezzi, Environmental Programs Specialist-Safety. FACILITY DESCRIPTION The City of Corpus Christi Water Department serves nearly 500,000 citizens of Corpus Christi and the Coastal Bend. The Department supplies water for municipal and industrial use in a seven-county service area covering 140 square miles. Water is drawn from the Lake Corpus Christi and Choke Canyon Reservoir System, both within the Nueces River Basin, and from Lake Texana via the Mary Rhodes Pipeline. Approximately 50% of the water delivered to homes in Corpus Christi comes from Lake Texana. Lake Corpus Christi, which stores 242,241 acre-feet of water and Choke Canyon Reservoir stores 695,271 acre-feet of water. The City of Corpus Christi also purchases 41,840 acre-feet of water per year from the Lavaca-Navidad River Authority. Approximately 28 billion gallons of water are treated each year. Water infrastructure has a rated capacity of 167 million gallons per day, which is well above the peak summer demand of as much as 110 million gallons per day. The department operates five pumping stations, four elevated storage tanks and maintains 1,600 miles of pipeline. The Water Department repairs and replaces water infrastructure and maintains a water testing laboratory. The City diverts raw water from the Nueces River and Lake Texana into the plant to be treated and turned into drinking water. Water is drawn from the Nueces River where it passes through screens to remove the large floating objects such as leaves, branches, fish, etc. The water is pumped from the Nueces River to the treatment plant to the junction box where the water is blended with Lake Texana water. From there, the water is piped to a receiving unit where coagulants are added to the water to "destabilize" colloidal suspensions. The coagulation process works to remove any colloidal suspended particles present in the raw water. Disinfectant chemicals are also injected into the water to kill bacteria and viruses. The water is then piped into settling basins where the coagulation process continues until it is completed. After that, water enters the filtration system for the final removal of particles. Additional disinfectant chemicals are added to the water before the water is stored in clear wells. Large master pumps help to distribute water into the city where water is stored in storage tanks. 2 Section II - OBSERVATIONS City of Corpus Christi/O.N. Stevens Water Treatment Plant Inspection Date: 08/21/2019 During the inspection we discussed the facility's processes and systems. All the plant's processes are self-contained within the facility. I was made aware that this facility currently uses sodium permanganate to treat its surface water. The facility had used potassium permanganate 10 years prior. At approximately 10:05 AM I began touring the following areas accompanied by the facility staff along with TDA inspectors: Raw Water Intake Area, Sodium Permanganate Station, Pre-sedimentation Basin, Recycle Pond, Coagulation Area, Flocculation Area including Settlement Areas, Filtration Area, and the Pumping station. I learned that chlorine dioxide is used to control taste and odor after raw water settlement. The sodium permanganate is introduced into the system at a rate of 5 mg/L per 8 million gallons. On average 70 - 80 mg/L are used in treatment. Anthracite Coal/Clay is the only filter media used in the filter area. The water treatment facility has the ability to store approximately 14 million gallons and on average provides about 80 million gallon per day to its citizen. Section III - AREAS OF CONCERN I observed the installation of a sodium permanganate injection system used by O. N. Stevens Water Treatment Plant to control taste and odor caused by algae. The labeling did not have any indication of EPA pesticide registration. The sodium permanganate product was potentially sold and distributed in violation of FIFRA because at the time of the inspection the pesticide was unregistered. At 11:30 AM a closing was conducted with the facility staff. During the inspection documents were requested regarding the plant's use of sodium permanganate to be sent at a later date. The inspection was concluded at approximately 11:40 AM and I exited the facility. Section IV - FOLLOW UP The following information was received by EPA after exiting the Facility on August 21, 2019: Submitted Bid Proposals to the City of Corpus Christi Bid Invitation Letter from the City of Corpus Christi Bid Submission Instructions Sample Bid Forms from the City of Corpus Christi. City of Corpus Christi Disclosure of Interest Technical Data Sheets for Sodium Permanganate SDS for Sodium Permanganate and Sodium Permanganate Purchase Invoices to the City of Corpus Christi Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 25 photos taken Appendix 2 - Notice of Inspection 3 City of Corpus Christi/O.N. Stevens Water Treatment Plant Inspection Date: 08/21/2019 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\DSCN0039.JPG Date of Photo: August 21, 2019 Time of Photo: 10:13 AM Photographer: Ernest Hernandez Description: Raw Water Junction Box Station UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0041.JPG Date of Photo: August 21, 2019 Time of Photo: 10:17 AM Photographer: Ernest Hernandez Description: Raw Water Junction Box Station UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0044.JPG Date of Photo: August 21, 2019 Time of Photo: 10:19 AM Photographer: Ernest Hernandez Description: Sodium Permanganate Pumping Station UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0048.JPG Date of Photo: August 21, 2019 Time of Photo: 10:22 AM Photographer: Ernest Hernandez Description: Raw Water Intake Pumps UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0049.JPG Date of Photo: August 21, 2019 Time of Photo: 10:24 AM Photographer: Ernest Hernandez Description: Sodium Permanganate Pumping Station UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0050.JPG Date of Photo: August 21, 2019 Time of Photo: 10:25 AM Photographer: Ernest Hernandez Description: Sodium Permanganate Storage UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0051.JPG Date of Photo: August 21, 2019 Time of Photo: 10:25 AM Photographer: Ernest Hernandez Description: Sodium Permanganate Tote UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0052.JPG Date of Photo: August 21, 2019 Time of Photo: 10:25 AM Photographer: Ernest Hernandez Description: Sodium Permanganate Label UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0054.JPG Date of Photo: August 21, 2019 Time of Photo: 10:26 AM Photographer: Ernest Hernandez Description: Sodium Permanganate Labeling UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0056.JPG Date of Photo: August 21, 2019 Time of Photo: 10:27 AM Photographer: Ernest Hernandez Description: Sodium Permanganate Injection Point UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0057.JPG Date of Photo: August 21, 2019 Time of Photo: 10:27 AM Photographer: Ernest Hernandez Description: Sodium Permanganate Injection Point UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0058.JPG Date of Photo: August 21, 2019 Time of Photo: 10:27 AM Photographer: Ernest Hernandez Description: Sodium Permanganate Injection Point at Pre-sedimentation Basin UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0059.JPG Date of Photo: August 21, 2019 Time of Photo: 10:27 AM Photographer: Ernest Hernandez Description: Sodium Permanganate Flow Meter UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0060.JPG Date of Photo: August 21, 2019 Time of Photo: 10:34 AM Photographer: Ernest Hernandez Description: Pre-sedimentation Basin UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0061.JPG Date of Photo: August 21, 2019 Time of Photo: 10:34 AM Photographer: Ernest Hernandez Description: Pre-sedimentation Basin UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0062.JPG Date of Photo: August 21, 2019 Time of Photo: 10:35 AM Photographer: Ernest Hernandez Description: Recycle Water Pond UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0064.JPG Date of Photo: August 21, 2019 Time of Photo: 10:36 AM Photographer: Ernest Hernandez Description: Pre-sedimentation Basin Sodium Permanganate Inlet UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0065.JPG Date of Photo: August 21, 2019 Time of Photo: 10:48 AM Photographer: Ernest Hernandez Description: Recycle Water Pond UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0066.JPG Date of Photo: August 21, 2019 Time of Photo: 10:48 AM Photographer: Ernest Hernandez Description: Recycle Water Pond UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0069.JPG Date of Photo: August 21, 2019 Time of Photo: 10:53 AM Photographer: Ernest Hernandez Description: Sodium Permanganate Station at Recycle Pond UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0070.JPG Date of Photo: August 21, 2019 Time of Photo: 10:54 AM Photographer: Ernest Hernandez Description: Sodium Permanganate Label at Recycle Pond UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0071.JPG Date of Photo: August 21, 2019 Time of Photo: 10:54 AM Photographer: Ernest Hernandez Description: Sodium Permanganate Station at Recycle Pond UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0072.JPG Date of Photo: August 21, 2019 Time of Photo: 10:54 AM Photographer: Ernest Hernandez Description: Sodium Permanganate Station Control at Recycle Pond UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 24 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0073.JPG Date of Photo: August 21, 2019 Time of Photo: 10:59 AM Photographer: Ernest Hernandez Description: Coagulation Area UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 25 Location: O. N. Stevens Water Treatment Plant City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\ FY2019\2019-061 City of Corpus Christy (Citizen)\Inspection\Photos\ DSCN0074.JPG Date of Photo: August 21, 2019 Time of Photo: 11:40 AM Photographer: Ernest Hernandez Description: Facility Arial Photo APPENDIX 2 NOTICE OF INSPECTION U. S. ENVI RO N""'ENTAL PROTECTION AGENCY NOTICE OF INSPECTION ~N FOR INSPE TITLE 11v/Y"oYI me //f !&. I~ /;,,(?fJ ~ 0 FOR T HE P URPOSE O F INSPECTI NG A NO OBTAI N ING SAMPLES O F ANY PESTICID E S O R DE V IC E S PACKAGE D , LA BELED, AN O RELEASED FOR SH IP M E N T, ANO SAMP L ES OF ANY CON T A I NERS OR LABELI NG FOR SUCH PE STIC I DES OR DEVICES, I N P L ACES WHERE PES TI C I DES OF> DE VI CES ARE H ELO FO R DISTR I B UTI ON OR S A LE ( Se c . 9 ( o) o nd 12 ( n )(2) (B) ) . 1'J'FOR TH E PU RPOSE" OF I NSPECTING AND OBTA IN I NG COP I ES O F THOSE RECORDS SPECI F I E D I N SECT IO N 8 ANO 40 CFR PART 7"-is9. ( Sec . 8 and 12(a)(2)(8 )) . VIO L ATION SU SPE C T ED: :f\e ;; ew i'/ ! rof'e 18 If-'5'7 6 "/-eJ i<J ;IA /WtWJMde Ifl k}~ tel ~fUtevi..f .. r?'f c,. ,_,,_pr c)L r/r7 ---7 tj/f.4_ ~...;. "' /.A 1V...,t ~ . Sec t i on 8 , 9 (a) and 1 2( a )(2)( B ) o f the F e d e ra l In se c ticide , Fung icide, a nd R ode nt icid e A c t , as ame nded ( 7 U.S.C . 136 e l seq. ) are qu ote d on the r ever se o f t hi s f or m. EPA Form 35402 (Rev. 377) P RE VIOUS EDI T I O N M AY BE USEC UNT I L SUPP L Y I S EXHAUS T E D Original ESTABLISHM ENT COPY 1 SAMP LE RECORD COPY 2 REG ION COPY 3 INSPECTOR'S COPY