Document 2q8wDD6MqBjR92nY8BGb79DMp

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 06/08/2017 Water NPDES- Clean Water Act Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Farmers Branch, City of- Trinity River Authority (TRA) Member City Farmers Branch Wastewater Collection System 13000 William Dodson Parkway Farmers Branch, Texas 75234 13000 William Dodson Parkway Farmers Branch, Texas 75234 Dallas County Craig Hahn I Utilities Superintendent era ig. hahn @fa rmersb ra nchtx.gov FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110010934445 TXU000151 [and served by TRA Central Regional WWS (TX0022802)] N/A 22132 4952 Personnel participating in inspection: Craig Hahn City of Farmers Branch Ryan Sartor City of Farmers Branch Katy Evans City of Farmers Branch Louise Maranzana City of Farmers Branch Shane Davis City of Farmers Branch Mike Tillman EPA Region 6 {6EN-WM) Damon McElroy EPA Region 6 {6EN-WM) Utilities Superintendent Operations Mgr., Utilities Div. Environmental Health Mgr. Environmental Health Spclst. Env. Svcs. and Solid Waste Mgr. Environmental Scientist Environmental Engineer 972-919-2612 972-919-8782 972-919-2537 972-919-2536 972-919-2614 214-665-7531 214-665-7159 EPA Lead Inspector Signature/Date Supervisor Signature/Date ?U(\:1/LN {rnspector name} Mike Tillman ~ t~ ~;:~)0_,___ {Supervisor name} Carol Peters-Wagnon 6ENFORM-019-R7 (2/15/2017) 1 11/ls,/; 7 Date II 1/,f//7 Date Section I - INTRODUCTION City of Farmers Branch, Texas Inspection Date: 06/08/2017 PURPOSE OF THE INSPECTION The purpose of the inspection was to examine the City of Farmers Branch's (or City) sanitary sewer collection system as an element of the EPA's National Sanitary Sewer Overflow (SSO) Initiative to prevent raw sewage from entering streets, rivers, reservoirs, front yards, etc. For further SSO initiative information you may reference the web link: https://www.epa.gov/enforcement/nationalenforcement-initiative-keeping-raw-sewage-and-contaminated-stormwater-out-our. The scope of the inspection is to generally evaluate the municipalities that receive Trinity River Authority (TRA) wastewater treatment services in order to assist in stopping or mitigating unauthorized and unpermitted discharges or SSOs. EPA Region 6 inspectors arrived at the City of Farmers Branch's Public Works Office at 8:50am on June 8, 2017 for an announced Compliance Evaluation Inspection (CEI). We met with the City's Utilities Superintendent listed on the cover sheet above and illustrated by the inspection sign-in sheet (Appendix 2.) We presented our credentials and the purpose of the inspection was broadly explained as a collection system compliance evaluation of areas such as capacity, management, operations, and maintenance (CMOM) and associated SSO mitigation activities; as well as comprehensive SSO reporting according to Texas law. For further CMOM program guidance you may reference the web link: https://www3.epa.gov/npdes/pubs/cmom guide for collection systems.pdf. The inspection was conducted in accordance with the Clean Water Act (CWA). The City's collection system is regulated under the: Texas Water Code (TWC) Texas Administrative Code (TAC) Texas Health and Safety Code Clean Water Act (CWA) Code of Federal Regulations (CFR) Associated Central Regional Wastewater System (CRWWS) National Pollutant Discharge Elimination System (NPDES) General Permit Conditions Before leaving the facility, an exit briefing was conducted that explained observations, suggestions and areas of concern. This inspection report is based on information supplied by the City's representatives, observations made by the U.S. EPA inspectors, records and reports maintained by the City of Farmers Branch, the State ofTexas, and the U.S. EPA. TCEQ was notified ofthe inspection, but did not to participate. FACILITY DESCRIPTION The City of Farmers Branch's collection system is approximately 67 years old. The Public Works Department is located at City Hall, 13000 William Dodson Parkway, Farmers Branch, Texas, 75234. The wastewater utility is comprised of a Utility Superintendent, Utility Operations Manager, Pump Station Supervisor, two (2) Pump Station Operators, four (4) Field Crew Leaders, two (2) Heavy Equipment Operators, and nine (9) Maintenance Crew members. The system covers roughly 13.7 square miles, 2 City of Farmers Branch, Texas Inspection Date: 06/08/2017 serves approximately 30,530 residential and 1,838 commercial connections, and maintains operations 24 hours a day, seven days a week. The collection system consists of five (5) lift stations, 2,057 manholes, and 172 miles of sewer main which is comprised of 60% vitrified clay (VC), .02% ductile iron (DI), 21.6% polyvinyl chloride (PVC), .23% cast iron (CI), 6.33% high density polyethylene (HDPE), 5% reinforced concrete cylinder pipe (RCCP), and 7% reinforced concrete pipe (RCP.) Farmers Branch has a supervisory control and data acquisition (SCADA) system to monitor all lift station activity (Appendix 1; photo# 1) and each lift station has a generator available for emergency backup power. Backup generators are tested once a month. Sanitary sewage is routed through the City's wastewater collection system to TRA trunk lines and metering stations for transportation to the TRA Central Regional Wastewater Treatment System (TX0022802) for contractual wastewater treatment services. Management indicated there are no septic systems within the community. Section II- OBSERVATIONS A) Based on the inspection discussions, data analysis, and observations at the time of the inspection: Sewer calls that come in during business hours are received at the Customer Service Desk in the Utility Office (Appendix 1; photo# 2.) The call is then routed to a wastewater crew in the field and the Operations Manager for follow up. Customers determined as having problems on the private side are advised to contact a plumber. Sewer calls that come in after hours are routed through a Unified Dispatch located in Houston, Texas. Unified Dispatch notifies the on-call wastewater crew, who in turn notifies the Operations Manager. Otherwise calls are handled in a similar fashion to that of daytime hours. Any problematic overflows associated with private side lateral lines can be handled through the City's Environmental Health Division. The City of Farmers Branch has the legal authority to enforce provisions of its stormwater ordinance to rectify any ongoing problems. City crews investigate initial SSO reports, resolve active stoppages, estimate the overflow quantity for reporting to TCEQ, and investigates the cause to determine if other actions are needed. All overflows from City cleanouts, mains, manholes and lift stations are promptly reported to the Texas Commission on Environmental Quality (TCEQ) as required by Texas law. SSOs are disinfected by removal of remaining solids and standing water followed by application of chlorine and flushing with dechlorinated water from a fire hydrant. All customer calls are tracked in "My Gov", a work order tracking system. Management indicated the current system is inadequate to meet desired capabilities and is looking to upgrade to a more robust work order system. The City of Farmers Branch indicated in a questionnaire that some manholes overflow during severe rain events. The City has not performed any recent inflow and infiltration (1/1) studies and at this time, there are no future plans to do so. The City recently purchased a new closed circuit television (CCTV) van and jet-vac truck which allows for in house evaluations of the sanitary sewer collection system. Available funds have been focused on televising and lining large trunk mains as well as rehabbing and building new lift stations, manhole rehabilitation, and pipe bursting. 3 City of Farmers Branch, Texas Inspection Date: 06/08/2017 The City has a goal to CCTV a minimum of 75,000' and clean 120,000' of sanitary sewer every 2 (two) years. Hot spots are identified through review of work orders and the CCTV program. The City tries to clean hot spots in areas known to have heavy grease loading on a monthly basis. The City does not map out known hot spots. Farmers Branch implements a sewer use ordinance, a fats oil and grease (FOG) program, and a liquid wastehaulers program which are designed to help regulate discharges to the city's collection system. A major component of the FOG program is a city wide public education program. Additionally, the Environmental Services Division inspects grease traps (primarily restaurants) 2-3 times per year. Under the liquid wastehauler program, generators are required to use a permitted wastehauler to service its grease traps. The City inspects and permits liquid wastehaulers on a yearly basis. Discussions indicated that there is no inter-departmental communication strategy to facilitate the sharing of information between the Utilities and Environmental Health Divisions with regard to identifying causes, responding to, and prevention of SSOs. For example, the holding of regular inter-departmental SSO mitigation meetings. All lift stations are inspected weekly. Inspections are documented on a lift station inspection form. All lift stations are monitored by SCADA. The SCADA system monitors for Intruders, high wet well, low wet well, generator status, pump HOA status, pump run time, pump daily starts, pump load amps and wet well levels. City personnel respond to every SCADA alarm. SCADA alarms are texted and/or emailed to key personnel. Emergency cards are kept at each lift station with a list of vendors and contractors for emergency situations. Two (2) field workers and one (1) Pump Station/Lift Station worker are on call 24 hours a day, seven (7) days a week. If the SCADA system should go down, sites are actively monitored by personnel. The frequency of monitoring will depend on the normal pump run times of each station, weather, etc. The City has been participating in the TCEQ's Sanitary Sewer Overflow Initiative (SSOi) since 2007. The most recent annual report to the TCEQ is dated December 13, 2016 (Appendix 3.) It was noted that the City of Farmers Branch received several 'historic' rain events (i.e. roughly greater than a 50-year flood event) in the months of June and July in 2015, but they did not have a significant impact on the collection system. Any problems caused by such heavy rainfall events are usually associated with the TRA system trunk lines backing up the City's system at the point at which the two systems are tied together. SSO related training is handled in-house (Appendix 4) while safety training such as confined space and lockout-tagout is handled by an outside source such as United Rentals. Farmers Branch does not have written standard operating procedures (SOPs) for critical components of its wastewater operations. Such operations include dispatch, preventive maintenance of lines and manholes, manhole inspection and SSO response clean up and disinfection to name few. The City of Farmers Branch has a seven (7) year capital improvement plan (CIP.) The plan directs budgeting for maintenance, rehabilitation and reconstruction of sanitary sewer infrastructure. Discussions with management indicated current funding for wastewater operations, resources, and staffing is adequate. The current annual budget is $323,000/year with an increase to $2.1 million for FY18-19 to help recover from a recent TRA funding shortfall. There is no standing 'Emergency Fund', repairs are funded as needed. O&M and 4