Document 3QvOOOQn8QLVGwB6Rx3Qq3x5y

EAlA ft Uoited States C)' I"\ ~~~~~~mental Ptot~cUon Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) April12, 2018 Municipal Wastewater NPDES Utility Name: Facility inspected: Facility Physical Location: (Town, state, zip code) Mailing address: (Town, state, zip code) County/Parish: Facility Contact: Westlake, Town of Wastewater Collection System Town of Westlake, 1500 Solana Boulevard, Building 7, Suite 7200 Westlake, TX 76262 1301 Solana Blvd. Westlake, TX, 76262 Denton and Tarrant Jarrod Greenwood I Public Works Director (817) 490-5717 (office) FRS Number: Identification/Permit Number: NAICS: SIC: 110069996042 TXU011194 22132 4952 Personnel participating in inspection: Jarrod Greenwood Town of Westlake Public Works Director 817-788-7159 l<ory Kittrell Damon McElroy Town of Westlake Region 6 EPA (6EN-WM) Water/Wastewater Operator 817-788-1030 Environmental Engineer & 214-665-7159 6EN-WM Enforcement Officer EPA Lead Inspector Signature/Date Supervisor Signature/Date ..... /)~u'- !1k V)_-- Damon McElroy l(l~ tt/1.1 / ,fn~v dV1:'"/1 Carol Peters-Wagnon sh IP.<No Date 5/'f/!'if Date 6ENFORM-019-R7 (2/15/2017) 1 Section I - INTRODUCTION Town of Westlake Collection System Inspection Date 04/12/2018 PURPOSE OF THE INSPECTION EPA Region 6 inspector Damon McElroy arrived at Westlake Town Hall at 8:55 am on April 12, 2018, for an announced Compliance Evaluation Inspection. I met with the Town's wastewater utility officials illustrated by the inspection sign-in sheet in Appendix 2. I presented my credentials to the group. 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 Sanitary Sewer Overflow (SSO) mitigation activities; as well as SSO reporting according to Federal and 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. Jeff Tate from TCEQ (DFW Region) was invited to participate via phone call at (817)-588-5800 on March 22, 2018. The inspection examined the Town of Westlake's (or Town) sanitary sewer collection system following EPA's National SSO Initiative, in CWA accordance. For further SSO initiative information you may reference the web link: https://www.epa.gov/npdes/sanitary-sewer-overflows-ssos. The inspection scope is to generally to evaluate the municipalities that receive Trinity River Authority (TRA) wastewater treatment contractual services in order to assist in stopping unauthorized / unpermitted discharges (or SSOs) and encourage sustainability. The Town'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 DCWWS 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 Town representatives, observations made by the U.S. EPA inspector, records and reports maintained by Westlake, the State of Texas, and the U.S. EPA. FACILITY DESCRIPTION Westlake's WW utility serves about 1,200 residents via about 270 residential service connections, 90 septic systems, and 76 commercial connections. The Town's collection system consists of about 20 miles of WW gravity and force mains, three lift stations, and concrete manholes. The sanitary sewer system was installed beginning in 1999. The WW mains are 100% PVC and up to about 19 years old. Westlake is a town in Denton and Tarrant Counties and is described as an upscale suburb of Fort Worth The Public Works Department employees two fulltime Town officials (one utility director and one operator) that split O&M activities between drinking water and Wastewater O&M activities. The Town's sanitary sewage is transmitted to the TRA Denton Creek Regional Wastewater System (DCRWWS - 2 Town of Westlake Collection System Inspection Date 04/12/2018 Permit No.: TX0104957) for contractual wastewater treatment. The Town's zoning code mandates at least a half-acre lot per home and one acre lots for every eight apartments. Section II - OBSERVATIONS Based on the inspection discussions, data analysis, and observations: The Town has adequate capacity during dry weather. The Town retained RJN, Inc. to conduct a I/I Study and Report, dated July 2016. The Westlake collection system analysis study included: 1. Smoke Testing 2. Dye Testing 3. CCTV condition assessment of pipelines. 4. Hydraulic analysis. The collection system experiences infiltration and inflow (I/I) during wet weather. I/I reportedly occur primarily from private service laterals and manholes. The Town's sanitary sewer overflow (SSO) or unauthorized discharge notification procedure adheres to the TCEQ's Office of Compliance and Enforcement RG-395 (regulatory guidance 395), revised September 2016. The RG-295 web-address is located here: https://www.tceq.texas.gov/assets/public/comm_exec/pubs/rg/rg-395.pdf Westlake reported the below to SSO Non-Compliance Reports in the past five years: Start Date Volume (Gallons) Location/Description Cause 10/21/2012 300 Manhole approximately 100 ft. west of Post Oak Rd. & Sabine Rd. Intersection. Discharged to concrete drainage channel. Equipment failure 10/17/2014 450 2600 Ottinger Rd. manhole overflowed to ground. Blockage Emergency LS power is provided by a Sunbelt Rental contract. The SCADA system has backup battery power that should last at least three days. The town has adequate spare parts including LS pumps. The three LSs (i.e. named Deloitte, Fidelity and Vaquero) are connected to SCADA that monitor low level, high level, run times, relevant high level alarm, etc. and are available via the web on offsite devices such as cell phones or personal computers (reference Photo 3 in Appendix 1). The Fidelity LS was observed to have a problem with grease and debris. The LS emergency notification and response is handled by the SCADA alarms that notify City officials. Lift stations are inspected each workday that include a visual inspection of site conditions. 3 Town of Westlake Collection System Inspection Date 04/12/2018 Customer inquiries are handled at the call center located at Westlake Town Hall, 1500 Solana Boulevard, Building 7, Suite 7200. LSs are reportedly cleaned contractually every six months. Public works operates 40 hours per week during "normal" working hours (i.e. Monday through Friday, at about 8:00 am to 5:00 pm). Phone inquiries and emergencies that occur after the 40-hour work week are routed to the Town's utility director and the utility operator. The Town does not participate in the TCEQ Sanitary Sewer Overflow Initiative (SSOi). O&M is funded by the adopted water and sewer budget. Town operator(s) are TCEQ certified and receive adequate training. The Town was observed to not implement a fat, oils and grease (FOG) program. The Town was observed to not have a root-control program. The Town does not have a formal program stop private or subscriber sewer overflows. There has no ordinance for authority to take appropriate action to stop private or subscriber sewer overflows or implement a FOG program (i.e. right of entry, enforcement, and inspection authority). The Town jet cleans known hot spots annually. The Town does not document, analyze or map repeat problem areas. The Town purchased a GIS system that is to be populated with WW utility assets in the future. The Town plans to install additional WW lines to unserved or underserved areas including to replace the existing septic systems with a gravity sanitary sewer system. The Town has not implemented a formal capacity, management, operation and maintenance (CMOM) program. The Town does not utilize a work order management system. Wastewater customer inquiries or work orders could not be obtained or compared to any nonreported SSOs. The Town does not implement an asset management plan. The Town indicated it has adequate capital improvement resources for wastewater utility O&M. The Town reported that it has adequate resources for condition assessment. The Town reported that it has adequate resources for emergency repairs. There are no categorical industries in the Town. Section III - AREAS OF CONCERN The Town of Westlake utility department will best serve Westlake's customers by addressing the following: 1. Updated SOPs need to be created and made available for utility staff including for each O&M and emergency activity. 2. The Town needs a FOG Program. 3. The Town needs a program to mitigate private (or subscriber) sewer overflows. 4 Town of Westlake Collection System Inspection Date 04/12/2018 4. The Town needs ordinance (i.e. right of entry, enforcement, and inspection authority) to implement a FOG program and a private sewer overflow mitigation program. 5. The Town needs to implement a Work Order Management System. 6. The Town needs to track and analyze WW relevant customer inquiries to prevent SSOs. 7. The Town further needs to document, analyze, and map repeat problem areas or hot spots, and confirm to clean more often than annually. 8. The Fidelity LS grease and debris needs to be removed. 9. The Town needs a formal collection system condition assessment program. 10. The Town needs a utility GIS map that is populated with assets. 11. Phone inquiries for WW emergencies including SSOs need to be confirmed to be routed to the Town's utility director and the utility operator "after hours" and on weekends; including a resulting SOP. Section IV - RECOMMENDATIONS AND SUGGESTIONS RECOMMENDATIONS 1. The Town needs a formal capacity, management, operation and maintenance (CMOM) program. 2. If a SSO reaches a waterway, the Town needs to notify and work with the: a. The Code enforcement group, b. The Texas Parks and Wildlife department, and c. Any Municipal Separate Storm Sewer System (MS4) permit program team as appropriate. 3. The Town needs a root-control program. 4. The Town should implement a formal asset management process. An active asset management plan will support the Town to manage and operate utility assets at a lowered cost as well as judiciously identify critical infrastructure rehabilitation or replacement projects. SUGGESTIONS The Town would benefit by participating in the TCEQ Sanitary Sewer Overflow Initiative (SSOi) (more SSOi information is available via the web-address: https://www.tceq.texas.gov/compliance/investigation/ssoinitiative) 5 Section V - FOLLOW UP Town of Westlake Collection System Inspection Date 04/12/2018 No information was received by EPA after exiting the Facility on April 12, 2018. Section VI - LIST OF APPENDICES Appendix 1 - Photographic Log -eight photos taken Appendix 2 - Opening Conference Sign-In Sheet. Appendix 3 -Westlake Maps (GIS & Zoning) 6 Town of Westlake Collection System Inspection Date 04/12/2018 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Town of Westlake Collection System Town: Westlake County: Denton and Tarrant State: Texas Date of Photo: 04/12/2018 Time of Photo: 11:26 a.m. Photographer: DLM Description: Deloitte LS outside view. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Town of Westlake Collection System Town: Westlake County: Denton and Tarrant State: Texas Date of Photo: 04/12/2018 Time of Photo: 11:29 a.m. Photographer: DLM Description: Deloitte LS inside view. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Town of Westlake Collection System Town: Westlake County: Denton and Tarrant State: Texas Date of Photo: 04/12/2018 Time of Photo: 11:30 a.m. Photographer: DLM Description: Example of remote (cell phone) SCADA access to LS data. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Town of Westlake Collection System Town: Westlake County: Denton and Tarrant State: Texas Date of Photo: 04/12/2018 Time of Photo: 11:32 a.m. Photographer: DLM Description: Deloitte LS outside view. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Town of Westlake Collection System Town: Westlake County: Denton and Tarrant State: Texas Date of Photo: 04/12/2018 Time of Photo: 11:46 a.m. Photographer: DLM Description: Fidelity LS inside view - grease issue observed. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Town of Westlake Collection System Town: Westlake County: Denton and Tarrant State: Texas Date of Photo: 04/12/2018 Time of Photo: 11:43 a.m. Photographer: DLM Description: Fidelity LS outside view. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Town of Westlake Collection System Town: Westlake County: Denton and Tarrant State: Texas Date of Photo: 04/12/2018 Time of Photo: 12:00 p.m. Photographer: DLM Description: Vaquero LS outside view. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Town of Westlake Collection System Town: Westlake County: Denton and Tarrant State: Texas Date of Photo: 04/12/2018 Time of Photo: 12:02 p.m. Photographer: DLM Description: Vaquero LS inside view. Appendix 2 Sign in Sheet United States Environmental Protection Agency Region 6 - Water Enforcement Branch 1445 Ross Avenue, Suite 1200 DATE: TIME: SUBJECT: April 12, 2018 8:55 am Town of Westlake Collection System and Wastewater Utility Compliance Evaluation Inspection MEETING ATTENDEES Appendix 3 Westlake Maps (GIS & Zoning)