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ft E P A United States .._.,.~ Environmental Protectior ,,,. Agency Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Dates: Media Program: Regulatory Program(s) 07/30/2025 and 07/31/2025 Drinking Water Safe Drinking Water Act (SDWA) System Owner: System Name: System Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County: System Phone Number System Contact: Southern Oklahoma Water Corporation Southern Oklahoma Water Corporation 1967 Sam Noble Pkwy Ardmore, OK 73401 1967 Sam Noble Pkwy Ardmore, OK 73401 Carter 580-223-8961 Roger Dethloff sowc@sowcwater.com I I General Manager FRS ID: System Classification PWS ID: 110013269523 Community Water System (CWS) OK1010830 Primary personnel participating in inspection: Kevin Sarmiento Eastern Research Group, Inc. (ERG, EPA Contractor)/ kevin.sarmiento@erg.com Brynn Goe ERG/ brynn.goe@erg.com Daniel Kim EPA Region 6/ kim.daniel@epa.gov Isaac Sparks State of Oklahoma Department of Environmental Quality (DEQ)/ isaac.sparks@deq.ok.gov Thomas Nguyen DEQ/ thomas.nguyen@deq.ok.gov Roger Dethloff Southern Oklahoma Water Corporation (SOWC)/ roger@sowcwater.com David Carroll SOWC/ david@sowcwater.com Inspector Inspector Inspector District Representative District Representative General Manager Assistant General Manager EPA Lead Inspector Signature/Date V JJ)I~ /v _C A t .. ....,X Kevin Sarmiento, ERG (EPA Contract Inspector) 9/24/2025 Date Supervisor Signature/Date RUBEN ALAYONGONZALEZ Digitally signed b) RUBEN ALAYONGONZALEZ Date: 2025.09.29 15:21 :29 -05'00' Ruben Alayon-Gonzalez, EPA Region 6, Enforcement and Date Compliance Assurance Division, Water Resources Section 6ENFORM-019-R8.2 (02/12/2020) 1 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Section I - INTRODUCTION PURPOSE OF THE INSPECTION From July 30, 2025 through July 31, 2025, the United States Environmental Protection Agency (EPA) and EPA contract inspectors from ERG (referred to as the EPA inspection team) conducted a Compliance Evaluation Inspection under Section 1445 of the Safe Drinking Water Act (SDWA), 42 U.S.C. 300j-4, of Southern Oklahoma Water Corporation Public Water System (PWS), PWS ID No. OK1010830 (System). The purpose of the inspection was to evaluate the System's compliance with the SDWA as well as other applicable regulations, including Title 252 of the Oklahoma Administrative Code (O.A.C.). The EPA notified Roger Dethloff of the System via email that an inspection would be conducted on July 30 and 31, 2025. Information regarding the reason and statutory authority for the inspection was discussed with System representatives during the inspection. This report is based on information supplied by the System representatives through interviews and written statements, observations made by the EPA inspection team, and records and reports maintained by the System. As part of the inspection process, the EPA inspection team made direct observations, took photographs, collected physical evidence, and reviewed relevant documents. Information gathered from EPA, state, and public records prior to, during, or after the onsite inspection are referenced in this report as applicable. A Consent Order between the System and the State of Oklahoma Department of Environmental Quality (DEQ) went into effect on April 11, 2025. The Consent Order was issued in response to non-compliance with a December 10, 2020 Consent Order between the System and DEQ for total trihalomethanes (TTHM) and haloacetic acids (HAA5) maximum contaminant level (MCL) violations, in addition to construction and operational violations cited by DEQ in two separate notices of violation (NOV) from December 29, 2022 and October 30, 2024. Refer to Appendix C for the April 11, 2025, Consent Order. The table below provides a summary of the System's individual violations prior to the inspection, as identified in the Oklahoma Drinking Water Watch (DWW) database: Table 1. DWW Individual Violations for Compliance Periods between July 1, 2020, and July 1, 2025 (data pulled on September 2, 2025) Analyte Name Carbon, Total Compliance Period Begin Date 06-01-2025 Compliance Period End Date 06-30-2025 Violation Category Treatment Technique Measurement/ Calculation (e.g., Locational Running Annual Average) 0.63 Units Ratio Turbidity 05-01-2025 05-31-2025 Treatment Technique Not Available - Total Trihalomethanes (TTHM) TTHM 04-01-2025 01-01-2025 06-30-2025 03-31-2025 Maximum Contaminant Level (MCL) MCL 0.109 0.105 mg/L mg/L TTHM 10-01-2024 12-31-2024 MCL 0.087 mg/L TTHM 10-01-2024 12-31-2024 MCL 0.102 mg/L TTHM 07-01-2024 09-30-2024 MCL 0.088 mg/L 2 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Table 1. DWW Individual Violations for Compliance Periods between July 1, 2020, and July 1, 2025 (data pulled on September 2, 2025) Analyte Name TTHM Compliance Period Begin Date 07-01-2024 Compliance Period End Date 09-30-2024 Violation Category MCL Measurement/ Calculation (e.g., Locational Running Annual Average) 0.098 Units mg/L TTHM 04-01-2024 06-30-2024 MCL 0.095 mg/L TTHM 01-01-2024 03-31-2024 MCL 0.096 mg/L TTHM 10-01-2023 12-31-2023 MCL 0.096 mg/L TTHM 07-01-2023 09-30-2023 MCL 0.099 mg/L TTHM 07-01-2023 09-30-2023 MCL 0.085 mg/L TTHM 04-01-2023 06-30-2023 MCL 0.082 mg/L TTHM 04-01-2023 06-30-2023 MCL 0.095 mg/L TTHM 01-01-2023 03-31-2023 MCL 0.088 mg/L TTHM 10-01-2022 12-31-2022 MCL 0.085 mg/L TTHM 07-01-2022 09-30-2022 MCL 0.090 mg/L Total Haloacetic Acids 04-01-2022 06-30-2022 MCL (HAA5) TTHM 04-01-2022 06-30-2022 MCL 0.062 0.100 mg/L mg/L HAA5 01-01-2022 03-31-2022 MCL 0.066 mg/L HAA5 01-01-2022 03-31-2022 MCL 0.061 mg/L TTHM 01-01-2022 03-31-2022 MCL 0.101 mg/L TTHM 01-01-2022 03-31-2022 MCL 0.082 mg/L HAA5 10-01-2021 12-31-2021 MCL 0.069 mg/L TTHM 10-01-2021 12-31-2021 MCL 0.104 mg/L Carbon, Total 09-01-2021 09-30-2021 Treatment Technique 0.62 Ratio TTHM 07-01-2021 09-30-2021 MCL 0.102 mg/L HAA5 07-01-2021 09-30-2021 MCL 0.066 mg/L TTHM 04-01-2021 06-30-2021 MCL 0.098 mg/L Carbon, Total 03-01-2021 03-31-2021 Treatment Technique 0.74 Ratio TTHM 01-01-2021 03-31-2021 MCL 0.109 mg/L TTHM 10-01-2020 12-31-2020 MCL 0.113 mg/L Turbidity 10-01-2020 10-31-2020 Treatment Technique Not Available - TTHM 07-01-2020 09-30-2020 MCL 0.104 mg/L 3 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 DBP VIOLATION HISTORY The System exceeded the maximum contaminant level (MCL) for total trihalomethanes (TTHM) during every compliance quarter from July 1, 2020, through July 1, 2025. Individual TTHM MCL violations date back as far as 2010. During the same period, the System also exceeded the MCL for haloacetic acids (HAA5) in four compliance quarters and failed to meet the total organic carbon (TOC) treatment technique requirements in three compliance quarters. The most recent TOC treatment technique violation period ended on June 30, 2025. SYSTEM DESCRIPTION According to DWW, the System is owned and operated by Southern Oklahoma Water Corporation, serves a population of approximately 11,250 people, and has 4,883 service connections. It is a community water system as defined by 40 C.F.R., Part 141, Subpart A. The State of Oklahoma maintains the DWW database which provides a record of the System's owner, operator, and size. The System uses both surface water and groundwater sources. It includes two surface water package plants--the 1.0 million gallon per day (MGD) Arbuckle Lake Water Treatment Plant (Arbuckle WTP), also known as Air Park WTP, and the 0.6 MGD Lake Murray Water Treatment Plant (Murray WTP)--as well as nine groundwater wells located throughout the service area. The System regularly operates eight of the nine wells and maintains the ninth in operable condition, though it is not typically used due to elevated hardness. The System produces an average of 0.6 MGD from its active groundwater wells. The distribution system includes one main pressure zone, seven finished water storage tanks, and five pressure booster stations. The System also has four emergency interconnections with the City of Ardmore, although their capacities are unknown. At the Arbuckle WTP, treatment includes raw water oxidation with chlorine dioxide, coagulation with aluminum sulfate and a proprietary polymer coagulant (WTM-4620B), flash mixing through a static mixer, and multi-stage treatment via three parallel package plants. Each package plant contains adsorption clarifiers with buoyant plastic media and a conventional multi-media filter. The System disinfects filtered water with chlorine gas before it enters two onsite clearwells operating in parallel. The Arbuckle WTP also has backwash storage and recycling capabilities. At the Murray WTP, treatment includes raw water oxidation with chlorine gas, coagulation with aluminum sulfate and WTM-4620B, and the same multi-stage package plant design used at the Arbuckle WTP. However, the Murray WTP does not include flash mixing. Filtered water is disinfected with chlorine gas before entering an onsite clearwell. Like the Arbuckle WTP, the Murray WTP has backwash storage and recycling capabilities. All groundwater wells are equipped with onsite sodium hypochlorite storage for raw water disinfection. Only one well, Banks Well #1, uses polyphosphate for iron control through sequestration. Section II - INSPECTION ACTIVITY SUMMARY The EPA inspection team conducted an array of interviews and field activities to discuss and observe the System operations and maintenance (O&M) activities and to assess the condition of the drinking water system assets. The physical inspection occurred over two days. The following subsections describe the inspection activities completed by the EPA inspection team. The System representatives provided 4 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 documents in response to a document request included in the EPA Region 6 inspection notification email. The information in this report is based on document review, conversations with System representatives, and observations made during this inspection. OPENING CONFERENCE The EPA inspection team arrived at the System, located at 1102 Waterplant Rd., Ardmore, OK 73401, at 08:30 CDT on July 30, 2025, for the inspection. The EPA inspection team was accompanied by Isaac Sparks and Thomas Nguyen from DEQ; refer to Appendix B for the opening conference sign-in sheet. Daniel Kim and Kevin Sarmiento presented credentials to Roger Dethloff and informed them that this was an EPA Region 6 inspection to determine compliance with the O.A.C. requirements and the SDWA. The EPA inspection team also informed the System representatives that they would be conducting a cybersecurity evaluation as part of the SDWA Section 1433 review of the System's Risk and Resilience Assessment (RRA) and Emergency Response Plan (ERP). The opening conference included a discussion of surface water sources and treatment, groundwater sources and treatment, and Supervisory Control and Data Acquisition (SCADA) systems. Additional conversations throughout the inspection included topics related to the technical, managerial, and financial capacity of the System, management strategy, staffing, monitoring and reporting requirements, cross-connection control plans, emergency response plans, and specific compliance topics including the Lead and Copper Rule (LCR) and modifications to it, Disinfection Byproduct Rule (DBPR), Revised Total Coliform Rule (RTCR), treatment techniques, and others discussed in more detail in the remainder of Section II. MANAGEMENT AND OPERATION The System is owned and operated by the non-profit Southern Oklahoma Water Corporation (SOWC), under the directive of SOWC's governing board. The System employs one Class B, four Class C, and seven Class D certified waterworks operators; three waterworks operators also have Class C waterworks lab certifications. The System is classified as a Class C water treatment system by DEQ. As a non-profit, the System cannot access typical funding sources such as the State Revolving Fund and instead relies on local loans for financing. The System does not have a short-term or long-term capital improvement plan. System representatives stated that their engineer identifies and presents the System's needs to the board for funding. At the time of the inspection, the System was actively constructing clarifiers, holding ponds, and a complete overhaul of the Murray WTP. System representatives stated that the project was 70 percent financed with funds from the American Rescue Plan Act of 2021 (ARPA) and 30 percent through local funds. The project aims to resolve violations 5.1, 5.11, 5.14, and 5.17 in the April 11, 2025, Consent Order. According to System representatives, the new Murray WTP is designed to improve the removal of total organic carbon (TOC), which is expected to reduce disinfection by-products (DBPs) in the distribution system. The Consent Order required the System to submit an approvable engineering report by June 1, 2025, detailing a schedule with actions and dates for the proposed Murray WTP. The System submitted the report on July 28, 2025, and DEQ accepted it without penalty. 5 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Violation 5.1 in the Consent Order stated that the System lacked a minimum of a 24-hour supply of water storage or standby means for providing electrical power. Additionally, violation 5.21 in the Consent Order stated that the Carter, Durwood, Lone Grove, Marietta, and South Booster Pump Stations were not equipped with standby power. The EPA inspection team observed newly installed transfer switches and generator camlocks at wells and booster stations, as well as a new but not yet operational natural gas generator at the Arbuckle WTP. System representatives stated that natural gas service for the generator had not yet been provided and that mobile generators still needed to be purchased for the distribution system. The System has four emergency interconnections with the City of Ardmore but lacks a written mutual aid agreement and does not know the maximum rate or volume of water it can draw from these connections. Additionally, the System does not have backup power capabilities at its treatment plants, wells, booster stations, or tanks. RECORDS REVIEW The System representatives provided documents for review at the time of the EPA inspection in response to a document request included in EPA Region 6's inspection notification email. The information in this report is based on documents reviewed onsite and provided after the onsite inspection. The System lacked documentation of cross connection control plans, hydrant flushing plans, valve exercising plans, compliance sampling plans for lead and copper, DBPs, and total coliform, customer complaints, and main break logs. The EPA inspection team reviewed the System's December 2023 Monthly Operating Report and observed three consecutive combined filter effluent (CFE) four-hour turbidity readings exceeding 0.30 nephelometric turbidity units (NTU) from December 17--18, 2023 (Photograph 1). System representatives stated that the treatment failure resulted from a tubing failure on the coagulant feed pump. Additionally, the EPA inspection team reviewed individual filter 15-minute turbidity data for the Arbuckle WTP from July 20 through August 16, 2025. The EPA inspection team observed consecutive instances of individual filter turbidities greater than 0.5 NTU and one instance where the turbidity for Filter 2 was greater than 2.0 NTU for two consecutive 15-minute measurements and greater than 1.0 for four consecutive 15-minute measurements between 20:38 and 20:53 on August 17, 2025. The EPA inspection team reviewed the System's November 16, 2022, tank inspection reports for all seven finished water storage tanks. Many of the recommendations related to the exterior condition of the tanks had not been addressed by the time of the inspection. The reports recommended sediment removal from the floors of all tanks and a full blast and recoat of the interior coating at all tanks except for Lone Grove Tank, where an interior power wash and spot repair were recommended. Violation 5.19 in the Consent Order stated that, due to a lack of documentation, such as maintenance records or inspection reports, the condition of all storage facility and clearwell hatches, vents, roofs, and interiors could not be verified. The EPA inspection team received inspection reports for all tanks except for the Arbuckle WTP North Clearwell, Arbuckle WTP South Clearwell, and Lake Murray WTP Clearwell Tank. Refer to Appendix D for all the System's 2022 tank inspection reports. 6 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 The EPA inspection team reviewed the System's Section 1433 Risk and Resilience Assessment and Emergency Response Plan and its cybersecurity practices. FACILITY WALKTHROUGH The EPA inspection team conducted an array of field activities to evaluate the drinking water system, including inspecting the Arbuckle WTP, Lake Murray WTP, groundwater wells, finished water storage tanks, and pressure booster stations. The physical inspection occurred over two days. The following descriptions are based on information provided to the EPA inspection team by the System and observations made during the inspection. Areas of concern and observations are described in Section III of this report. Arbuckle WTP The System conveys surface water from Arbuckle Lake through a 8.5 miles, 36-inch transmission line to the 1.0 MGD Arbuckle WTP. The Arbuckle Master Conservancy District manages and controls the lake intake. Operators pre-oxidized raw water with chlorine dioxide and dose it with aluminum sulfate and proprietary polymer before it enters the two-stage package plant. After chemical addition, raw water goes through a static mixer in a riser pipe before entering the multistage package plants. System representatives stated that they did not know of the condition of the static mixer. The Arbuckle WTP consists of three multi-stage package plants operating in parallel, with space available for a fourth unit. The first stage is an adsorption clarifier comprised of buoyant plastic media, and the second stage is a conventional multi-media filter. System representatives stated that the clarifiers do not perform well and that the barrier retaining the buoyant plastic media occasionally tears, releasing the media into the system. The System maintains large volumes of replacement buoyant plastic media onsite. System representatives stated that the plant struggled to meet effluent turbidity limits at raw water turbidities greater than 20 NTU thatraw water turbidity ZNTU. The Supervisory control and data acquisition (SCADA) system alarms operators when the CFE reaches 0.250 NTU but does not include an automatic shutoff for high finished water turbidity. Operators are instructed to contact the operator in responsible charge if CFE turbidity exceeds 1.0 NTU. However, the System does not have a defined CFE setpoint for shutting down the WTP and does not have a policy to shut down the surface plant regardless of finished water turbidity levels. System representatives stated that their priority is to maintain water flow in the distribution system. The System disinfects filtered water with chlorine gas before entering two onsite clearwells operating in parallel. Two high service pumps then push water from the clearwells into the distribution system, with a discharge pressure of 120 psi. Arbuckle WTP - Backwash Recycling and Residuals Management 7 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 The System's SCADA system automatically triggers a clarifier backwash every 200 minutes and a filter backwash every 810 minutes. Backwash water is stored in an outdoor residual lagoon adjacent to the Arbuckle, where residuals settle and the supernatant is recycled to the head of the treatment process. Violation 5.4 in the Consent Order stated that an unpermitted discharge occurred from the residual lagoon to the inactive residual lagoons of the abandoned WTP located approximately 300 feet north of the active lagoon. Although the EPA inspection team did not observe discharge into the abandoned lagoons, it did observe the active residual lagoon overflowing into the surrounding environment (Photograph 2). Additionally, violation 5.19 in the Consent Order stated that the residual lagoon did not have at least 3 feet of freeboard, which was also observed at the time of the EPA inspection. System representatives stated that it has not recycled water in over a year. The EPA inspection team observed the recycled water line lacking a flow meter (Photograph 3). Additionally, the recycled water injection point was located downstream of the raw water sample point for turbidity and other raw water quality monitoring (Photograph 3). Arbuckle WTP - Chemical Storage The EPA inspection team observed the following chemicals at the Arbuckle WTP: Two bulk tanks of aluminum sulfate used as the primary coagulant. One bulk tank and one 55-gallon barrel of polymer coagulant labeled as WTM-4620B, used as the secondary coagulant. 55-gallon plastic barrels of Aquacros HC-2075 blended phosphate and ProTex-M-2723 polyphosphate, used for iron sequestration at Banks Well #1. Two 330-gallon intermediate bulk containers (IBC) totes of 12.5 percent sodium hypochlorite solution used for disinfection at groundwater wells. One 330-gallon IBC of 25 percent sodium chlorite solution that was no longer used by the System. One 330-gallon IBC of chlorine dioxide solution used for raw water pre-oxidation. The EPA inspection team did not observe secondary containment around any chemical. All chemicals, except for the chlorine dioxide solution, were stored adjacent to one another (Photograph 4 and Photograph 5). All floor drains in the Arbuckle WTP discharge into the residual lagoon. Bulk chemical containers for aluminum sulfate and the proprietary coagulant had uncovered openings. Some openings were covered with temporary lids that were not fastened or secured in place (Photograph 6 and Photograph 7). None of the bulk chemical tanks had level indicators. Instead, operators measure chemical levels by inserting 6-foot-long metal rulers into the tanks and noting the marked level (Photograph 8). The System maintains approximately a three-week supply of aluminum sulfate and polymer coagulant onsite. System representatives stated that their supplier can deliver chemicals within one week. The EPA inspection team observed hose bibs with garden hoses connected to the facility's potable water supply without vacuum breakers (Photograph 8). Chlorine dioxide solution is prepared by dissolving brand-name TwinOxide Component A and Component B into an IBC tote filled with potable water. A garden hose without a backflow prevention device is used to fill the tote (Photograph 9). The WTP is the first service connection in the distribution system and does not have a backflow prevention device (Photograph 10). 8 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Arbuckle WTP - Chlorine Room Gaseous chlorine is used as the primary disinfectant and is metered in the chlorine room. However, the EPA inspection team observed full 150-pound chlorine cylinders stored in a safety cage inside the main WTP facility (Photograph 11). System representatives stated that operators normally change out the 150-pound chlorine cylinders by themselves every 3 days. The EPA inspection team observed four full cylinders in the safety cage and two cylinders in operation, with a total chlorine supply of about 18 days. The chlorine room has two scale-mounted 150-pound cylinders with automatic switchovers. The EPA inspection team observed that the WTP's potable water supply used as carrier water for the chlorinator did not have a backflow prevention device upstream of the chlorine injectors (Photograph 12). The EPA inspection team observed that the chlorine room was equipped with an exhaust fan at ground level that was not operational (Photograph 13), and a chlorine gas detector located 4 feet above the ground. Arbuckle WTP - North & South Clearwells Two 988,000-gallon ground-level steel tanks used as clearwells and operate in series. The EPA inspection team observed cracked and missing seal around the base of the North Clearwell (Photograph 14) and the South Clearwell (Photograph 15). Additionally, the access ladder on the South Clearwell extended to ground level and lacked a ladder guard to prevent unauthorized access (Photograph 16). System representatives stated that both clearwells were rehabilitated in 2021. They confirmed the presence of vent screens but were unaware of the screen mesh size. They also stated that the access hatches were missing gasket seals. Violation 5.24 in the Consent Order stated that the South Clearwell overflow was not equipped with a flex gate. The EPA inspection team observed that both tanks had internal overflows and drains that daylighted in separate concrete spillways, each equipped with flapper valves. However, the South Clearwell flapper valve was found in a partially open position (Photograph 17). Arbuckle WTP - Clearwell Booster Two booster pumps equipped with variable frequency drives (VFD) move finished water from the North Clearwell to the South Clearwell. These pumps are SCADA-controlled and maintain equal water levels in both tanks. The EPA inspection team observed the south pump leaking from the packing and noted corrosion around the pump head (Photograph 18). Lake Murray WTP The Lake Murray WTP is located 16.5 miles south of the Arbuckle WTP and draws up to 0.6 MGD of surface water from Lake Murray, located approximately 250 feet away. The intake is owned and managed by the System. Raw water is pre-oxidized with chlorine gas and dosed with aluminum sulfate and polymer before entering the two-stage package plant. The EPA inspection team observed the raw water pipe located in a below-grade pit submerged in several feet of standing water (Photograph 19). The recycle water injection point, coagulant injection, pre- 9 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 chlorine injection, polymer injection, and raw water flow meter were submerged. An exposed electrical box was a few inches above the water level in the raw water pit. The EPA inspection team also observed a sump pump in the pit. System representatives stated that they were unsure how long the sump pump had been non-operational and confirmed that it was connected to the sanitary sewer. After chemical addition, raw water flows directly to the multi-stage package plants. Violation 5.11 in the Consent Order stated that the Lake Murray WTP was not equipped with a rapid mix or in-line static mixer. System representatives stated that planned upgrades to the Lake Murray WTP include the addition of rapid mix units. The Lake Murray WTP consists of two multi-stage package plants, identical to those at the Arbuckle WTP, operating in parallel. The EPA inspection team observed anthracite filter media outside of the filter box along the top edges of the filters (Photograph 20). System representatives explained that an air blower is used during the backwash phases of both the clarifier and the filters and that media `blowout' occurred sometimes on backwash startup. The System disinfects filtered water with chlorine gas before it enters an onsite clearwell and is then pumped into the distribution system. Clarifier and filter backwash water is stored in a process water retaining tank located outside the facility. Decanted water is recycled to the head of the treatment process, and sludge is discharged into a sludge basin located directly below the holding tank and pumped to a sanitary sewer force main. System representatives stated that the facility has not recycled process water in over a year and currently discharges all process water to the sanitary sewer. Lake Murray WTP - Chemical Storage At the Lake Murray WTP, the System has two bulk tanks of aluminum sulfate, one bulk tank of WTM4620B, labeled as proprietary coagulant, and two 330-gallon IBC totes of 12.5 percent sodium hypochlorite solution. The EPA inspection team did not observe secondary containment around any chemicals. Two 330-gallon IBCs of sodium hypochlorite were located adjacent to the raw water pit (Photograph 21 and Photograph 22). Additionally, all floor drains in the Lake Murray WTP discharge into the backwash recycle decant tank. The EPA inspection team also observed empty and filled 55-gallon barrels of chemicals stored outside the facility without secondary containment (Photograph 23). Bulk chemical containers for aluminum sulfate and the proprietary coagulant had uncovered openings and no level indicators, consistent with the setup at the Arbuckle WTP (Photograph 24). Operators also used 6-foot-long metal rulers to measure chemical levels (Photograph 24). System representatives stated that they typically maintain a two-week supply of aluminum sulfate and coagulant onsite. The EPA inspection team observed hose bibs with garden hoses connected to the facility's potable water supply without vacuum breaker protection (Photograph 25). One garden hose was directly connected to the proprietary coagulant chemical tank without vacuum breaker protection (Photograph 26). The WTP's potable water supply does not have a backflow prevention device. Lake Murray WTP - Chlorine Room Gaseous chlorine is used as the primary disinfectant and is metered in a room adjacent to the WTP. The EPA inspection team did not observe chemical hazard labeling on the entryway to the chlorine room (Photograph 27). System representatives stated that operators typically change out the 150-pound 10 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 chlorine cylinders by themselves, carrying the full cylinders from the main WTP facility to the chlorine room. The EPA inspection team observed four full 150-pound cylinders stored inside the main Lake Murray WTP facility (Photograph 28), with a total chlorine supply of about 60 days. The chlorine room has two scale mounted 150-pound cylinders with automatic switchovers. The EPA inspection team observed that the potable water supply used as carrier water for the chlorinator lacked a backflow prevention device upstream of the chlorinators (Photograph 29). A double check valve was installed downstream of one of the two chlorinators (Photograph 29). System representatives stated that this line was for post-clearwell chlorination and was not currently connected. They also stated that the backflow prevention device was not tested on a predetermined schedule. Lake Murray WTP - Clearwell Tank The Lake Murray WTP uses one ground-level steel tank as a clearwell. The EPA inspection team observed cracked and missing sealant around the base of the tank (Photograph 30). The access ladder extended to ground level and lacked a ladder guard to prevent unauthorized access (Photograph 31). Lake Murray WTP - SCADA The Lake Murray WTP's SCADA system automatically controls daily operations, turning the plant on and off based on clearwell level. Although the plant is always active, it is not staffed 24 hours a day. Alarms are configured to alert key personnel in the event of emergencies. The SCADA system logs raw water, filtered water, and finished water quality parameters, including turbidity and residual chlorine. The EPA inspection team observed that turbidity and chlorine values were offset by a factor of 100 in SCADA. For example, a combined filter turbidity reading of 0.125 NTU on the turbidimeter was displayed as 12.5 NTU in SCADA. System representatives stated that they were aware of the offset and accounted for it during operations. Lake Murray WTP - Backwash Recycling and Residuals Management The SCADA system automatically triggers a clarifier backwash every 250 minutes and a filter backwash every 750 minutes. Violation 5.14 in the Consent Order stated that the backwash system was not equipped with a flow meter. The EPA inspection team did not observe a flow meter on the backwash water supply. A decant tank located adjacent to the plant stores backwash process water for recycling to the head of the treatment process. The EPA inspection team did not observe a flow meter on the backwash recycle line (Photograph 19). Lake Murray WTP - Decant Tank The decant tank receives clarifier and filter backwash process water, along with floor drain wastewater, from the Lake Murray WTP via gravity. A pump draws supernatant from the decant tank and returns it to the raw water inlet for recycling. However, recycling was not active at the time of the inspection. System representatives stated that a valve at the bottom of the decant tank opens when the water level reaches a predetermined height, allowing sediment and water to drain into a catch basin through an airgapped opening. A sump pump in the catch basin then pumps the sludge and water into a sanitary sewer force main. 11 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 The EPA inspection team observed water and sludge on the ground surrounding the decant tank (Photograph 32). System representatives stated that splashing occurs when the waste valve opens. A polyvinyl chloride (PVC) drain was located along the fence line perimeter, which System representatives stated discharged into the lake. The inspection team also observed a path of eroded soil between the decant tank and the lake, located approximately 60 feet away (Photograph 33). Violation 5.17 in the Consent Order stated that the System did not have a residuals management plan approved by DEQ. At the time of the inspection, no DEQ-approved residuals management plan was in place. System representatives stated that the entire WTP and residual recycling system, including the decant tank, would be upgraded as part of planned improvements to address Consent Order requirements. Lake Murray WTP - Raw Water Intake The raw water intake is located approximately 40 feet from the shore and at a depth of about 10 feet from the surface. The EPA inspection team observed no signage or protection of the area immediately around the intake structure (Photograph 34). General Observations at Wellheads The System's eight active groundwater wells have an average production capacity of 0.6 MGD. The EPA inspection team inspected the Newport #6 Well, Banks Well, Shiggin Well, McKinney #2 Well, and McKinney #1 Well. The EPA inspection team observed the following conditions: Sodium hypochlorite was stored without secondary containment, and the containers had uncovered openings (Photograph 35 through Photograph 38). Air relief valve discharge pipes lacked screens (Photograph 39 through Photograph 42). Entryways to sodium hypochlorite storage rooms did not display chemical hazard labels (Photograph 43 and Photograph 44). Chemical dosing was manually adjusted due to operational issues with flow-paced metering. Newport #6 Well The well is located inside a protected wellhouse and has a normal production rate between 150 and 220 gpm. The EPA inspection team observed the following conditions: Corrosion and metal loss were visible on the wellhead (Photograph 45). Electrical cables were exposed on the ground inside the wellhouse, creating safety hazards for operations (Photograph 46). A threaded hose bib was installed on the discharge pipe without a vacuum breaker (Photograph 47). 12 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Banks Well #1 The Banks Well #1 wellhouse is located inside private property. System representatives stated that they always have unrestricted access to the well site. The well has a maximum production capacity of 450 gpm and is the only well feeding polyphosphate for iron control via sequestration. The EPA inspection team observed the following conditions: A 55-gallon polyphosphate barrel was stored without secondary containment and placed in the same closet as sodium hypochlorite (Photograph 36). Erosion was observed beneath the wellhouse foundation near the blow-off and splash pad (Photograph 48). A frost-free hose bib with a threaded sample tap was used for compliance sampling (Photograph 49). Shiggin Well dZZ^dZZ^Z^ ZZZ ZdWZZZZ ZWZZ McKinney #2 Well The well is in a secured wellhouse and has a normal production between 70 and 120 gpm. The EPA inspection team observed the following conditions: The gasket between the corroded wellhead was hardened and cracked (Photograph 51). Corrosion and metal loss were present on the discharge pipe and appurtenances (Photograph 52). The blow-off line discharged away from the splash pad, which was located approximately two feet from the wellhouse and one foot from the blow-off (Photograph 53). A pond was located approximately 160 feet south of the wellhead, and the well depth was reported to be approximately 700 feet (Photograph 54). McKinney #1 Well The well was not running at the time of the EPA inspection. The well log showed that the well only ran for three days between June and July, at rate between 41 and 48 gpm. The EPA inspection team observed the following conditions: Corrosion and metal loss were observed around the wellhead, the discharge pipe, and appurtenances (Photograph 55 and Photograph 56). A threaded hose bib was installed without a vacuum breaker on the well discharge pipe (Photograph 57). 13 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 The splash pad was located three feet from the wellhouse and one foot from the blow-off line, but did not adequately prevent erosion (Photograph 58). A residential property was located approximately 120 feet southeast of the wellhead (Photograph 44). General Observations at Finished Water Storage Tanks The EPA inspection team observed overflow flapper valves that did not fully seal to prevent entry of insects at the Springer Tower (Photograph 59), Lone Grove Tower (Photograph 60), Shiggin Tower (Photograph 61), and Marietta Tower (Photograph 62). Additionally, the overflows were not equipped with screens beneath the flapper valves at the tanks. Springer Tower The Springer Tower is a 90-foot-tall standpipe with a capacity of 118,965 gallons built in 1969. The November 16, 2022 tank inspection report designated the exterior of the tank as in fair condition. The EPA inspection team observed no improvement to the tank's exterior condition from the last tank inspection. The EPA inspection team observed the following conditions: A leak from a weld in one of the tank's anchors caused pooling water around and underneath the tank (Photograph 63 and Photograph 64), as documented in the 2022 tank inspection. Cracked and missing sealant was observed around the tank foundation, along with vegetation growth between the tank base and concrete foundation (Photograph 63 and Photograph 64), as documented in the 2022 tank inspection. Corrosion was present around the tank anchors (Photograph 63), as documented in the 2022 tank inspection. No splash pad was installed beneath the overflow outlet to direct water away from the tank foundation (Photograph 65), as documented in the 2022 tank inspection. Erosion was visible around the concrete foundation of the tank (Photograph 65). The perimeter fencing and barbed wire were damaged (Photograph 66). Vegetation had grown along the perimeter fence (Photograph 67). The tank's exterior paint was thinning, and minor corrosion had begun to show (Photograph 65), as documented in the 2022 tank inspection. Lone Grove Tower The Lone Grove Tower is a 90-foot-tall standpipe with a capacity of 118,965 gallons built in 1969. The November 16, 2022, tank inspection report designated the exterior of the tank as in fair/bad condition. The EPA inspection team observed no improvement to the tank's exterior condition from the last tank inspection. System representatives stated that the tank was going to be replaced with a new tank at a nearby location. The EPA inspection team observed the following conditions: One anchor bolt was broken, and corrosion was present around several anchor bolts and nuts (Photograph 68), as documented in the 2022 tank inspection. 14 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Several anchor nuts were not fully engaged with the anchor chair (Photograph 69), as documented in the 2022 tank inspection. Sealant around the tank foundation was cracked or missing, and vegetation was growing between the tank base and the concrete foundation (Photograph 70), as documented in the 2022 tank inspection. The concrete surrounding the tank foundation was cracking and spalling (Photograph 71), as documented in the 2022 tank inspection. The splash pad beneath the overflow outlet was undersized and did not adequately direct water away from the foundation (Photograph 71), as documented in the 2022 tank inspection. Barbed wire on the perimeter fencing was damaged (Photograph 72). Shiggin Tower The Shiggin Tower is a 115-foot-tall standpipe with a capacity of 97,000 gallons, built in 1997. The November 16, 2022, tank inspection report designated the exterior of the tank as in good condition. The EPA inspection team observed no changes to the tank's exterior condition from the last tank inspection. Marietta Tower The Marietta Tower is a 120-foot-tall standpipe with a capacity of 45,000 gallons, built in 1969. The November 16, 2022, tank inspection report designated the exterior of the tank as in fair condition. The EPA inspection team observed improvements to the tank's exterior paint from the last tank inspection. System representatives stated that the tank was previously damaged by a tornado and was subsequently repaired. General Observations at Pressure Booster Stations The System operates five pressure booster stations. The EPA inspection team inspected three in service booster stations (Maridian, Lone Grove, and Marietta Boosters) and one out of service booster station (Shiggin Booster). Violation 5.22 in the Consent Order stated that the Carter, Durwood, and Meridian Boosters were not equipped with discharge measuring devices. The EPA inspection team observed standard pressure gauges installed on both the suction and discharge lines at all inspected booster stations. Maridian Booster A single VFD-controlled pump inside the Maridian Booster house pushes water from north to south along the distribution system's main trunkline. installed on both the suction and discharge lines at all inspected booster stations. (Photograph 73). Additionally, the electrical conduit was not secured to the pump motor, exposing the electrical wires. Lone Grove Booster The Lone Grove Booster is located inside a below-grade manhole within the Lone Grove Tower fence line. Violation 5.20 in the Consent Order stated that the Lone Grove and Cook Pumping Stations were not equipped with a minimum of two pumping units. The EPA inspection team observed only one pump at the booster station (Photograph 74). The pump motor sat on a stack of concrete cinderblocks without 15 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 any fastening to secure it during operations (Photograph 74). The EPA inspection team did not observe a flow meter in the booster station. Shiggin Booster The Shiggin Booster contains a single booster pump located on the ground inside the station (Photograph 75). System representatives stated that the booster station had been out of service for over five years, although water still flows through the pipeline. The EPA inspection team observed corrosion, metal loss, and longitudinal cracks along the entire length of the exposed active pipeline. (Photograph 76). Marietta Booster The Marietta Booster has one installed booster pump and a backup pump available for emergency use. The EPA inspection team observed the operating pump motor placed on a concrete slab without any fastening to prevent movement during operation (Photograph 77). The VFD motor was running at peak capacity, with the indicator displaying 59 Hz (Photograph 78). Pressure readings showed 45 psi on the suction side and 80 psi on the discharge side. The inspection team did not observe a flow meter at the booster station. (Photograph 77). CLOSING CONFERENCE The EPA inspection team held a closing conference with System personnel at 16:00 on July 31, 2025, at the Southern Oklahoma Water Corporation's main office. The EPA inspection team discussed preliminary observations identified during the field component of the inspection. The EPA inspection team reiterated to the System representatives that these preliminary observations were not compliance determinations. Preliminary observations shared during the closing conference are subject to further investigation by EPA upon the review of additional records and documentation. Therefore, this inspection report may include observations that were not identified at the time of the closing conference. Observations are described in Section III. Observations regarding the risk and resiliency assessment, emergency response plan, and cybersecurity practices were shared with the System verbally. The inspection concluded at approximately 16:30. A sign-in sheet for the closing conference is provided in Appendix B. Section III - AREAS OF CONCERN SDWA Section 1433(a): SDWA Section 1433(a)(1)(A) requires a CWS serving more than 3,300 persons to conduct a Risk and Resilience Assessment ("RRA") of its system, including an assessment of: i. the risk to the system from malevolent acts and natural hazards; ii. the resilience of the pipes and constructed conveyances, physical barriers, source water, water collection and intake, pretreatment, treatment, storage and distribution facilities, electronic, computer, or other automated systems (including the security of such systems) which are utilized by the system; iii. the monitoring practices of the system; 16 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 iv. the financial infrastructure of the system; v. the use, storage, or handling of various chemicals by the system; and vi. The operation and maintenance of the system. Section 1433(a)(3)(A) of the SDWA required a CWS serving greater than 3,300 but less than 50,000 persons to submit its certification to the EPA Administrator that it has conducted its RRA on or before June 30, 2021, and at least once every five years after the initial applicable deadline. Area of Concern 1. On July 31, 2025, EPA completed an inspection of the Southern Oklahoma Water Corporation under SDWA Section 1445, 42 U.S.C. 300j-4. EPA inspectors requested to review the system's RRA pursuant to SDWA Section 1433, and observed the following: a. The document was available at the time of the inspection. b. The RRA was dated to show that it was not completed before the date of the certification of completion. c. The RRA failed to assess all required elements of SDWA Section 1433(a). The RRA is missing the required elements: o Section 1433 (a)(1)(A)(iii) the monitoring practices of the system; o Section 1433 (a)(1)(A)(iv) the financial infrastructure of the system; o Section 1433 (a)(1)(A)(v) the use, storage, or handling of various chemicals by the system; and o Section 1433 (a)(1)(A)(vi) the operation and maintenance of the system. d. The RRA contained incomplete sections covering the requirements in: o Section 1433 (a)(1)(A)(i) the risk to the system from malevolent acts and natural hazards; o Section 1433 (a)(1)(A)(ii) the resilience of the pipes and constructed conveyances, physical barriers, source water, water collection and intake, pretreatment, treatment, storage and distribution facilities, electronic, computer, or other automated systems (including the security of such systems) which are utilized by the system; and SDWA Section 1433(b): Section 1433(b) of the SDWA requires a CWS serving a population greater than 3,300 to prepare or revise, where necessary, an emergency response plan ("ERP") that incorporates the findings of the RRA no later than six months after completion of its RRA. The ERP shall include: 1. strategies and resources to improve the resilience of the system, including the physical security and cybersecurity of the system; 2. plans and procedures that can be implemented, and identification of equipment that can be utilized, in the event of a malevolent act or natural hazard that threatens the ability of the CWS to deliver safe drinking water; 3. actions, procedures, and equipment which can obviate or significantly lessen the impact of a malevolent act or natural hazard on the public health and the safety and supply of drinking water provided to communities and individuals, including the development of alternative source water options, relocation of water intakes, and construction of flood protection barriers; and 4. Strategies that can be used to aid in the detection of malevolent acts or natural hazards that threaten the security or resilience of the system. 17 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Area of Concern 2. During the inspection, EPA inspectors also reviewed the System's ERP pursuant to SDWA Section 1433 and observed the following: a. The ERP was available at the time of the inspection. b. The ERP was dated to show that it was completed before the certification of completion. c. The ERP failed to assess all required elements of SDWA Section 1433(b). The ERP is missing the required elements: o SDWA Section 1433(b)(2) plans and procedures that can be implemented, and identification of equipment that can be utilized, in the event of a malevolent act or natural hazard that threatens the ability of the CWS to deliver safe drinking water; and o SDWA Section 1433(b)(4) strategies that can be used to aid in the detection of malevolent acts or natural hazards that threaten the security or resilience of the system. d. The ERP contained incomplete sections covering the requirements in: o SDWA Section 1433(b)(1) strategies and resources to improve the resilience of the system, including the physical security and cybersecurity of the system; and o SDWA Section 1433(b)(3) actions, procedures, and equipment which can obviate or significantly lessen the impact of a malevolent act or natural hazard on the public health and the safety and supply of drinking water provided to communities and individuals, including the development of alternative source water options, relocation of water intakes, and construction of flood protection barriers. Title 40 Code of Federal Regulations (CFR) 141.173(a)(1) "For systems using conventional filtration or direct filtration, the turbidity level of representative samples of a system's filtered water must be less than or equal to 0.3 NTU in at least 95 percent of the measurements taken each month..." Area of Concern 3. Area of Concern 4. Area of Concern 5. In the compliance period between May 1, 2025, and May 31, 2025, the System experienced a CFE turbidity violation at the Lake Murray WTP. In the compliance period between October 1, 2020, and October 31, 2020, the System experienced a CFE turbidity violation at the Arbuckle WTP. On December 17--18, 2023, the System experienced a CFE turbidity greater than 0.30 NTU, but less than 1.0 NTU, for three consecutive 4-hour monitoring periods (Photograph 1). The System's protocols were inadequate to identify a coagulant feed failure prior to it negatively impacting water quality. 40 CFR 141.175(b)(1) "For any individual filter that has a measured turbidity level of greater than 1.0 NTU in two consecutive measurements taken 15 minutes apart, the system must report the filter number, the turbidity measurement, and the date(s) on which the exceedance occurred. In addition, the system must either produce a filter profile for the filter within 7 days of the exceedance (if the system is not able to identify an obvious reason for the abnormal filter performance) and report that the profile has been produced or report the obvious reason for the exceedance." 40 CFR 141.175(b)(4) "For any individual filter that has a measured turbidity level of greater than 2.0 NTU in two consecutive measurements taken 15 minutes apart at any time in each of two consecutive months, the system must report the filter number, the turbidity measurement, and the date(s) on which the exceedance occurred. In addition, the system must arrange for the conduct of a comprehensive performance evaluation by the State or a third party approved by the State no later than 30 days following the exceedance and have the evaluation completed and submitted to the State no later than 90 days following the exceedance." 18 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Area of Concern 6. The EPA inspection team observed a filtered water turbidity for Filter 2 at the Arbuckle WTP greater than 2.0 NTU for two consecutive 15-minute measurements and a turbidity greater than 1.0 for four consecutive 15-minute measurements between 2038 and 2053 hours on August 17, 2025. The System has not made targeted changes to operations to address turbidity exceedances since at least 2000. Inadequate turbidity removal is associated with elevated TOC in treated water. However, instead, it is planning a 2026 capital improvement to the Lake Murray WTP to address DBP and TOC violations in the 2025 Consent Order. 40 CFR 141.86(a)(1) (July 1, 2020) "By the applicable date for commencement of monitoring under paragraph (d)(1) of this section, each water system shall complete a materials evaluation of its distribution system in order to identify a pool of targeted sampling sites that meets the requirements of this section, and which is sufficiently large to ensure that the water system can collect the number of lead and copper tap samples required in paragraph (c) of this section. All sites from which first draw samples are collected shall be selected from this pool of targeted sampling sites. Sampling sites may not include faucets that have point-of-use or point-of-entry treatment devices designed to remove inorganic contaminants." Area of Concern 7. The System did not have a written sampling plan for compliance sampling for the Lead and Copper Rule. System representatives stated that 60 sample locations were identified on billing details but that no tier designations have ever been assigned to the sites. 40 CFR 141.853(a)(1) "Systems must develop a written sample siting plan that identifies sampling sites and a sample collection schedule that are representative of water throughout the distribution system no later than March 31, 2016. These plans are subject to State review and revision. Systems must collect total coliform samples according to the written sample siting plan. Monitoring required by 141.854 through 141.858 may take place at a customer's premise, dedicated sampling station, or other designated compliance sampling location. Routine and repeat sample sites and any sampling points necessary to meet the requirements of subpart S must be reflected in the sampling plan." Area of Concern 8. Area of Concern 9. The System did not have a written sample siting plan for compliance sampling for the Revised Total Coliform Rule. System representatives stated that they have a spreadsheet with sampling locations. System representatives stated that they have not identified repeat sample locations in their spreadsheet. 40 CFR 141.132(f) Monitoring plans. "Each system required to monitor under this subpart must develop and implement a monitoring plan. The system must maintain the plan and make it available for inspection by the State and the general public no later than 30 days following the applicable compliance dates in 141.130(b). All Subpart H systems serving more than 3300 people must submit a copy of the monitoring plan to the State no later than the date of the first report required under 141.134. The State may also require the plan to be submitted by any other system. After review, the State may require changes in any plan elements. The plan must include at least the following elements. 19 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 (1) Specific locations and schedules for collecting samples for any parameters included in this subpart. (2) How the system will calculate compliance with MCLs, MRDLs, and treatment techniques." Area of Concern 10. The System did not have a monitoring plan for disinfectants, disinfection byproducts, or disinfection byproduct precursors as part of the Disinfectants and Disinfection Byproduct Rules. System representatives stated that they knew the five disinfection byproduct sampling locations by memory. 40 CFR 141.64(b)(2) states that the MCL for TTHM is 0.080 mg/L and the MCL for HAA5 is 0.060 mg/L. Area of Concern 11. Area of Concern 12. Area of Concern 13. The System has exceeded the TTHM MCL every compliance quarter between July 1, 2020, and July 1, 2025. The System's TTHM MCL violations extend as far back as 2010. The System is under a Consent Order from DEQ and is required to comply with the TTHM MCL by January 1, 2028. The System has exceeded the HAA5 MCL in four compliance quarters between July 1, 2020, and July 1, 2025. The System's HAA5 MCL violations extend as far back as 2010. The System has not made targeted changes to operations to address TTHM and HAA5 since at least 2010; instead, it is planning a 2026 capital improvement to the Lake Murray WTP to address TTHM violations in the 2025 Consent Order. 40 CFR, 141.135(c)(1)(v) states that 12-month TOC removal ratio averages must remain at 1.00 or greater. Area of Concern 14. The System has not met the TOC treatment technique requirements in three compliance quarters between July 1, 2020 and July 1, 2025, with the most recent violation period ending on June 30, 2025. The System has not made targeted changes to operations to address TOC treatment technique requirements since at least 2006; instead, it is planning a 2026 capital improvement to the Lake Murray WTP to address TOC treatment technique violations in the 2025 Consent Order. 40 CFR 141.626(a) "You have exceeded the operational evaluation level at any monitoring location where the sum of the two previous quarters' TTHM results plus twice the current quarter's TTHM result, divided by 4 to determine an average, exceeds 0.080 mg/L, or where the sum of the two previous quarters' HAA5 results plus twice the current quarter's HAA5 result, divided by 4 to determine an average, exceeds 0.060 mg/L." Area of Concern 15. The System exceeded the operational evaluation level of 0.080 mg/L every quarter between 1/1/2021 and 6/30/2025. 40 CFR 141.626(b)(1) "If you exceed the operational evaluation level, you must conduct an operational evaluation and submit a written report of the evaluation to the State no later than 90 days after being notified of the analytical result that causes you to exceed the operational evaluation level. The written report must be made available to the public upon request." 20 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Area of Concern 16. The System did not provide records of operational evaluations conducted as a result of exceeding the operational evaluation level for TTHM. 40 CFR 141.76(d) "the system must collect and retain on file recycle flow information specified in paragraphs (d)(1) through (6) of this section for review and evaluation by the State beginning June 8, 2004. (2) List of all recycle flows and the frequency with which they are returned. (3) Average and maximum backwash flow rate through the filters and the average and maximum duration of the filter backwash process in minutes." Oklahoma Administrative Code (OAC) Title 252, Chapter 626, Subchapter 13-4 (OAC 252:626-13-4(c)) states that surface water treatment wastewater handling shall be designed for "wastewater to be returned at an instantaneous rate of 10 percent or less of the raw water entering the plant. Total flow shall not exceed the WTP maximum design flow rate..." Area of Concern 17. Area of Concern 18. The System did not have flow meters installed on the recycle lines at the Arbuckle WTP (Photograph 3) or the Lake Murray WTP (Photograph 19). The System is unable to ensure that the instantaneous rate of process water return is 10 percent or less of the raw water entering the plant. The System did not have flow meters installed on the filter backwash supply at the Arbuckle WTP or the Lake Murray WTP. 40 CFR 141.76(a) "All subpart H systems that employ conventional filtration or direct filtration treatment and that recycle spent filter backwash water, thickener supernatant, or liquids from dewatering processes must meet the requirements in paragraphs (b) through (d) of this section." Area of Concern 19. Floor drains at the Arbuckle WTP discharge into the backwash recycle lagoon, while at the Lake Murray WTP floor drains discharge into the recycle decant tank. All liquids and wastes that go into the floor drains at both WTPs can be recycled with the process waste. OAC 252:626-13-4. (C)(4) "when wastewater is to be discharged, a plant outfall must be provided that is designed and constructed in accordance with OAC 252:656-9-3." OAC 252:626-13-5. Land application of decant water or residuals "A permit is required if WTP decant water or WTP residuals are to be land applied from a water treatment plant." OAC 252:626-13-1. (b) "Do not discharge wastewater to waters of the state without first obtaining an OPDES permit from the DEQ." Area of Concern 20. Area of Concern 21. The EPA inspection team observed process water from the Arbuckle WTP backwash lagoon overflowing into the surrounding environment without a dedicated outfall or land application permit (Photograph 2). The EPA inspection team observed process water from the Lake Murray WTP Decant Tank entering the surrounding environment and Lake Murray without a dedicated outfall or OPDES permit from DEQ (Photograph 32 and Photograph 33). 21 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Area of Concern 22. The EPA inspection team observed partially filled 55-gallon barrels of chemicals outside of the Lake Murray WTP without any secondary containment (Photograph 23). OAC 252:626-5-15. (a) "Avoid cross connections in the system." OAC 252:626-5-15. (a)(1) "Do not allow a physical connection between a line carrying a public drinking water supply and a line carrying water of unknown or questionable quality." Area of Concern 23. The System does not have a cross-connection control program and does not practice cross-connection control measures within its facilities or throughout the distribution system. System representatives stated there was an iron works facility, a cannabis farm, restaurants, and two schools connected to the System, but that they do not know if any backflow prevention devices were installed and tested. Recommended Practice for Backflow Prevention and Cross-Connection Control: AWWA M14, Fourth Edition, Page 87, incorporated by reference in OAC 252:626-5-15. (f) "The water supplier should apply to the water treatment plant the same containment requirements imposed on industrial customers. Table 6-3 lists the backflow-prevention measures used to prevent cross-connections that could occur between individual treatment processes within the treatment plant from contaminating the finished product." Table 6-3 states that industrial customers with high hazards need reduce-pressure principle devices for back-pressure protection and air gaps or reduce-pressure principle devices for backsiphonage protection. Area of Concern 24. The Arbuckle WTP and Lake Murray WTP did not have backflow prevention devices installed on the facility's potable water supply. The potable water supply to both facilities was provided through a service connection located a few feet downstream from the entry point to the distribution system (Photograph 10). OAC 252:626-5-15. (e)(1) "provide cross-connection control to assure that service water lines discharging to solution tanks or pots are protected from backflow. Provide a minimum 6-inch air gap between the end of the service water line and the spill line of the solution tank. An air gap of less than 6 inches in conjunction with an approved backflow preventer is acceptable[.]" Area of Concern 25. Area of Concern 26. The EPA inspection team observed a garden hose connected directly to the bulk WTM-4620B (proprietary chemical) tank without an air gap or a backflow prevention device at the Lake Murray WTP (Photograph 25 and Photograph 26). System representatives stated that all garden hoses in the facility were connected to the facility's potable water supply. The EPA inspection team observed a garden hose without a backflow prevention device tied to the chlorine dioxide IBC tote at the Arbuckle WTP (Photograph 9). System representatives stated that chlorine dioxide solution is made by mixing brand name TwinOxide Component A and Component B into the IBC tote and adding potable water from the garden hose. 22 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Recommended Practice for Backflow Prevention and Cross-Connection Control: AWWA M14, Fourth Edition, Table 6-6, incorporated by reference in OAC 252:626-5-15. (f) "hose connection vacuum breakers are the appropriate backflow prevention product for hose bibb connections." Area of Concern 27. Area of Concern 28. The EPA inspection team observed garden hoses connected to hose bibbs without vacuum breakers at the Arbuckle WTP (Photograph 8) and Lake Murray WTP (Photograph 25). The EPA inspection team observed the hose bibb connection on the discharge pipe of the Newport Well (Photograph 47), Shiggin Well (Photograph 50), and McKinney #1 Well (Photograph 57) without vacuum breakers. OAC 252:626-17-1. (k) "Make the roof and side walls of all structures watertight with no openings except properly constructed vents, manholes, overflows, risers, drains, pump mountings, control ports, and piping for inflow and outflow." Area of Concern 29. The System's 2022 tank inspection report for the Walker Tank identified a 3-to4-inch diameter opening on the roof of the tank, thought to be a rigging hole left uncovered by a previous contractor. OAC 252:626-17-1. (i)(3) states that finished water storage tank accesses must "be fitted with a solid watertight cover." Area of Concern 30. The System's 2022 tank inspection reports showed no gaskets on the access hatches at the Spring Tank and Walker Tank. The EPA inspection team did not inspect the roofs of any finished water storage tanks, and the inspection report did not mention or provide photographs showing the presence or absence of gaskets at the System's other tanks. OAC 252:626-17-1. (h)(3) "Equip the ends of the pipes with flex gates." Recommended Standards for Water Works, 2022 Edition, 7.1.7(c) "The overflow shall open downward and be screened with twenty-four mesh non-corrodible screen. The screen shall be installed within the overflow pipe at a location least susceptible to damage by vandalism. A mesh-fitted mechanical flap valve is acceptable provided the flapper is supplied with non-corroding and non-seizing hinges. The flap valve shall be spring loaded or counterweighted, so it closes and forms a tight seal after the overflow event." Recommended Standards for Water Works, 2022 Edition, 7.1.7(d) "When a solid flapper is used, a screen shall be provided inside the overflow. If a duckbill valve is used, a screen is not required. Provisions must be included to prevent the flapper or duckbill from freezing shut." Area of Concern 31. The EPA inspection team observed solid flappers on the overflows of all the finished water storage tanks. The solid flappers did not form a tight seal around the overflow pipe at the Springer Tower (Photograph 59), Lone Grove Tower (Photograph 60), Shiggin Tower (Photograph 61), or Marietta Tower (Photograph 62). None of the inspected finished water storage tanks had screens installed inside the overflow pipe. 23 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Area of Concern 32. The EPA inspection team observed a partially open solid flapper on the overflow of the Arbuckle WTP South Clearwell Tank (Photograph 17). American Water Works Association (AWWA) Steel Water Storage-Tanks Manual (M42-13), Chapter 8, Page 90 "The exterior of the water-bearing surfaces should be examined, and any leaks--or rust streaking that could have been caused by tank leaks--should be reported. (Corrosion products often seal leaks, leaving only rust streaks as evidence of the leak.) The tank should be inspected by a professional structural engineer familiar with water tank construction as soon as possible after the leak is discovered. Although some leaks may not cause structural problems, potential catastrophic tank failures can be avoided if the visible leaks are properly investigated and repaired." Area of Concern 33. The EPA inspection team observed a leak stemming from a weld on one of the Springer Tank's anchors (Photograph 63 and Photograph 64). Water was pooled around and beneath the tank. The 2022 tank inspection report identified the same leak at the same location. OAC 252:626-17-1. (j)(4) "Design of vents must be covered with a 24-mesh corrosion resistant screen installed at a location least susceptible to vandalism." Area of Concern 34. The System's 2022 tank inspection reports showed a coarse mesh screen larger than 24-mesh on the vent of the Marietta Tower. The EPA inspection team did not inspect the roofs of any finished water storage tanks, and the inspection report did not mention or provide photographs showing the presence or absence of 24-mesh screens on the System's other tanks. OAC 252:626-17-1. (q) "Provide proper protection to metal surfaces by paints or other protective coatings." Area of Concern 35. The System's 2022 tank inspection reports stated that the overall interior paint at the Shiggin Tower, Springer Tower, Walker Tower, and Woodford Tower was in bad condition, with moderate to severe rust and/or delamination present and recommended blasting and recoating the tank interiors. Additionally, the System's 2022 tank inspection reports stated that the overall interior paint at the Dickson North Tower, Lone Grove Tower, and Marietta Tower was in fair condition, with minor to moderate rust and/or delamination present and recommended blasting and recoating the tank interiors. The System had no maintenance records showing the completion of any of the recommendations. OAC 252:631-3-23. (b) "PWS systems shall provide protection for a reservoir or lake used as a source of water. Control the marginal shoreline land by purchase or ordinance. If control is through the use of an ordinance, the ordinance must describe the water district boundaries and enforcement rules which shall include: (1) regulating the public health aspects of the water supply, waste and sewage disposal and recreation activities; (2) regulating the building of structures within the control area; (3) regulating aquatic activities involving human body contact with the water, including restricting body contact with the water during recreational or other activities when the water quality or public health may be adversely affected; and 24 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 (4) regulating the removal of brush and trees to the high water elevation, regulating the protection from floods during construction within the control district, and regulating the plugging of wells which are inundated, in accordance with OWRB requirements." Area of Concern 36. The System does not have a source water protection program. The source water to the Arbuckle WTP is managed by the Arbuckle Master Conservancy District and not the System, while the source water at the Lake Murray WTP is managed directly by the System. The System does not control or monitoring of the source water at Lake Murray. The EPA inspection team observed no protection around the intake structure or signage for boats and people to stay away from the intake (Photograph 34). System representatives stated that the lake was used recreationally and that it had residential houses throughout the lake shore. OAC 252:626-7-4. (3)(C)(i) "Do not locate wells in a ravine where the well site may be flooded or within 300 feet horizontally from any existing or potential source of pollution including water bodies. If a wellhead delineation model has been performed for the site, the separation distance must conform to the model prediction for potential contamination." Area of Concern 37. The EPA inspection team observed a water body approximately 160 feet from the McKinney #2 Well (Photograph 54). OAC 252:626-7-4. (3)(C)(iii) "Do not locate wells within one hundred feet (100') of a private property line" Area of Concern 38. The EPA inspection team observed a private property line less than 100 feet from the McKinney #1 Well (Photograph 44). OAC 252:626-7-4. (8)(C) Upper terminal well construction "Seal the top of the casings with a sanitary well seal to properly protect against entrance of contamination into the well." Area of Concern 39. The EPA inspection team observed corrosion around the wellhead seal at the Newport Well #6 (Photograph 45) and McKinney #2 Well (Photograph 51). Additionally, the McKinney #2 Well had a hardened and cracked gasket around the well seal (Photograph 51). OAC 252:626-7-4. (8)(D)(iii) Upper terminal well construction "The discharge piping must be equipped with an air relief valve located upstream from the check valve. The exhaust/relief piping must terminate in a down-turned position at least 18 inches above the floor and covered with a 24-mesh corrosion resistant screen." Area of Concern 40. The EPA inspection team observed air relief valves without 24-mesh corrosionresistant screens at the Newport #6 Well (Photograph 39), Banks Well #1 (Photograph 40), Shiggin Well, McKinney #2 Well (Photograph 41), and McKinney #1 Well (Photograph 42). OAC 252:626-11-3. (b)(2) "Provide control equipment to keep feed rates proportional to the plant flow rate." 25 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Area of Concern 41. Area of Concern 42. The EPA inspection team observed that the aluminum sulfate pump, proprietary chemical pump, and chlorinators were manually set and not proportional to the plant flow rate at the Arbuckle WTP and Lake Murray WTP. The EPA inspection team observed that the sodium hypochlorite feed pumps were manually set and not proportional to the plant flow rate at the Newport #6 Well, Banks Well #1, Shiggin Well, McKinney #2 Well, and McKinney #1 Well. OAC 252:626-11-3. (g)(1) "Provide space for dry storage of at least a 30-day supply of chemicals." Area of Concern 43. System representatives stated that they typically keep about a 3-week supply of coagulant and polymer at the Arbuckle WTP and 2-week supply at the Lake Murray Plant at any given time. OAC 252:626-11-3. (g)(1) "Provide space for dry storage of at least a 30-day supply of chemicals." OAC 252:626-11-3. (g)(2) "Separate the chemical storage rooms from the feed machine room. Liquid chemicals may be stored in the feed machine rooms where containment for spills is provided." OAC 252:626-11-3. (g)(4)(B) "Provide liquid chemical storage tanks with an overflow and a receiving basin or drain capable of receiving accidental spills or overflows." Area of Concern 44. Area of Concern 45. Area of Concern 46. The EPA inspection team observed no spill containment provisions for chemicals in the Arbuckle WTP (Photograph 4 and Photograph 5) and the Lake Murray WTP (Photograph 21 and Photograph 22). The EPA inspection Team observed bulk aluminum sulfate and polymer tanks at the Arbuckle WTP (Photograph 4) and Lake Murray WTP (Photograph 24) without overflows. The EPA inspection team observed no spill containment provisions for sodium hypochlorite at the Newport #6 Well (Photograph 35), Banks Well #1 (Photograph 36), Shiggin Well, McKinney #2 Well (Photograph 37), and McKinney #1 Well (Photograph 38), where sodium hypochlorite was stored in the same room as the feed pumps. OAC 252:626-11-3. (g)(4)(A) "Provide liquid chemical storage tanks with a device to measure the liquid level in the tank." Area of Concern 47. The EPA inspection observed no level indicating device for the aluminum sulfate and proprietary coagulant bulk tanks at the Arbuckle WTP and the Lake Murray WTP. Instead, operators insert 6-foot-long metal rulers into the bulk chemical tanks and note the chemical level marked on the ruler (Photograph 8 and Photograph 24). 26 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Recommended Standards for Water Works, 2022 Edition, 5.5.9(c) "Chemicals shall be stored in covered or unopened shipping containers unless the chemical is transferred into an approved storage unit." Area of Concern 48. The EPA inspection observed uncovered openings on the aluminum sulfate and the proprietary coagulant tanks at the Arbuckle WTP (Photograph 6 and Photograph 7) and the Lake Murray WTP (Photograph 24). OAC 252:626-11-4. (a)(1)(E) "Provide a gas-tight room to separate gas chlorination equipment, chlorine cylinders and ozone generation equipment from other parts of the building, if the building is used for other purposes. Do not connect floor drains from the chlorine room to floor drains from other rooms. Doors to this room shall only open to the outside of the building, with panic hardware, at ground level and allow easy access to all equipment." Area of Concern 49. The EPA inspection team observed four full 150-pound chlorine gas cylinders located in the main facility, outside of a dedicated chlorine storage area, at the Arbuckle WTP (Photograph 11) and the Lake Murray WTP (Photograph 28). OAC 252:626-11-4. (a)(2)(A) "Provide each room with a ventilating fan with the capacity to provide one complete air change per minute." Area of Concern 50. The EPA inspection observed a ventilation fan installed in the Arbuckle WTP chlorine room that was not functioning at the time of the inspection (Photograph 13). OAC 252:626-9-11. (b)(7) "Design the chlorinator water supply piping to prevent contamination of the treated water supply by back-siphonage or cross connections with non-potable water. At all facilities treating surface water, pre-chlorination and post-chlorination systems must be independent to prevent possible siphoning of partially treated water into the clear well." Area of Concern 51. The EPA inspection observed that the carrier water for the chlorinators was not equipped with a backflow prevention device to prevent siphoning of partially treated water into the distribution system at the Arbuckle WTP (Photograph 12) and Lake Murray WTP (Photograph 29). OAC 252:626-17-1. (f)(3) "Cathodic protection shall be provided for all steel tanks to prevent under bottom corrosion." Area of Concern 52. The EPA inspection team observed no cathodic protection systems installed at any of the inspected finished water storage tanks. All the System's tanks are steel tanks. The System's 2022 tank inspection reports stated that none of the tanks had cathodic protection installed. 27 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 OAC 252:626-17-1. (h) "Provide all water storage structures with an overflow that terminates at an elevation between 12 and 24 inches above the ground surface, and release water over a drainage inlet structure or splash plate. Area of Concern 53. The EPA inspection team observed damaged or missing splash pad at the Spinger Tower (Photograph 65) and Lone Grove Tower (Photograph 71). AWWA M42-13, Chapter 2, Page 33, incorporated by reference in OAC 252:626-17-1. (a) "Exterior ladders, cages, and platforms designed to meet Occupational Safety and Health Administration (OSHA) standards are recommended (Figure 2-6). Either the ladder should terminate at least 8 ft (2.4 m) above grade or a solid locking door, provided to discourage unauthorized access to the tank, should be installed on the lower 8-20 ft (2.4-6.1 m) of the exterior ladder. Certain areas will require a locking door and anti-climb screening at the bottom of the ladder cage to discourage unauthorized access." Area of Concern 54. The EPA inspection team observed exterior ladders extending less than 8 feet above ground level without a locking door or ladder guard to prevent authorized access at the Arbuckle WTP South Clearwell (Photograph 16) and Lake Murray WTP Clearwell (Photograph 31). AWWA M42-13, Chapter 8, Page 92, "As water is held in the tank, suspended solids settle out of the water into the tank bottom. Without regular washouts, tanks may accumulate large amounts of sediment. Sediment and deposits on tank walls decrease the effectiveness of disinfectant use. In addition, proper inspections cannot be conducted if sediment covers the bottom of the tank. Tanks should be washed out and inspected at least once every 3 years, and where water supplies have sediment problems, annual washouts are recommended. These washouts can be performed by the tank owner's personnel or a maintenance company." Area of Concern 55. The 2022 tank inspection reports stated that there was accumulated sediment on the floor of every inspected tank and recommended cleaning all the tanks. OAC 252:626-17-1. (f)(2) "Provide fencing, locks on access manholes, and other necessary precautions to prevent vandalism, pilfering, trespassing, or sabotaging." Area of Concern 56. Area of Concern 57. The EPA inspection team observed damage to the fencing and barbed wiring at the Springer Tower (Photograph 66) and Lone Grove Tank (Photograph 72). The EPA inspection team observed vegetation growth around the perimeter security fencing at the Springer Tower (Photograph 67). AWWA M42-13, Chapter 8, Page 91, "Any exterior corrosion, especially where metal loss is apparent, should be evaluated by a professional engineer familiar with the construction of water-storage tanks. If the operator notices a change or severe worsening of the exterior corrosion patterns, he or she should bring this to the attention of the engineer. Special areas to observe are anchor bolts and nuts, rods, and rod pins and clevises." Area of Concern 58. The EPA inspection team observed a broken anchor bolt at the Lone Grove Tower (Photograph 68). The 2022 tank inspection report showed that the same anchor bolt was broken back in 2022. 28 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Area of Concern 59. Area of Concern 60. The EPA inspection team observed corrosion around most anchor bolts at the Springer Tower. The EPA inspection team observed loose anchor nuts that were not fully engaged on the anchor chairs of the Lone Grove Tower (Photograph 69). The 2022 tank inspection report also stated that anchor nuts were not fully engaged on the anchor chairs. EPA How to Conduct a Sanitary Survey of Drinking Water Systems (2022) Section 10.4.8 "Concrete foundations should be inspected to ensure that there is minimal spalling (ground level tanks) and no cracks (elevated tanks). Anchor bolts should not be rusted so much that their material strength has been compromised. Column shoes should be clean and painted, and grout under the shoes and riser plates should be in good condition. There should not be any pooled water, erosion, weeds, or shrubs around a tank's foundation." Area of Concern 61. Area of Concern 62. The EPA Inspection Team observed the designed seal between the tank sidewall and concrete foundation to be weathered, cracked, or missing at the Arbuckle WTP North Clearwell (Photograph 14), Arbuckle WTP South Clearwell (Photograph 15), Lake Murray WTP Clearwell (Photograph 30), Springer Tower (Photograph 64), and Lone Grove Tower (Photograph 70). The EPA Inspection Team observed vegetative growth between the steel tank and concrete foundation at the Springer Tower (Photograph 63). Recommended Standards for Water Works, 2022 Edition, 1.5 "(1) Filtered water turbidity~ 0.10 NTU, 95th percentile of maximum daily values recorded (2) Maximum filtered water turbidity~ 0.30 NTU The filter should be designed based on the capacity to achieve effluent turbidity of less than 0.1 NTU continuously to ensure the integrity of filtration as a viable barrier in the treatment scheme. Operation of filters to produce filtered water quality less than 0.1 NTU is attainable by proper design of filters, and provides greater confidence that pathogens, such as Cryptosporidium oocysts and Giardia cysts, are being removed prior to disinfection, the final treatment barrier." Area of Concern 63. Area of Concern 64. System representatives stated that the two-stage package plant's performance struggles at raw water turbidities greater than 20 NTU. The System's raw water turbidity regularly exceeds 20 NTU. The System's SCADA alarms operators when the combined filter effluent (CFE) reaches 0.250 NTU, but has no automatic shutoff programmed at high finished water turbidities. System representatives stated that the operators also do not have a target CFE cutoff and that they will go over a CFE of 1.0 NTU if they must, to keep water in the pipes. Recommended Standards for Water Works, 2022 Edition, 1.1 Minimum Data Monitoring Requirements "Individual basin settled water turbidity (frequency of data acquisition from continuous meters should be not less than every 15 minutes)" Area of Concern 65. The two-stage package plants at the Arbuckle WTP and Lake Murray WTP did not monitor for turbidity of the clarified water. 29 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 OAC 252:626-15-3. (a)(1) "All pumping stations shall have a minimum of two (2) pumping units. With any pump out of service, the remaining pump(s) shall be capable of providing the maximum pumping demand of the system." Area of Concern 66. The EPA inspection team observed one booster pump installed at the Maridian Booster (Photograph 73), Lone Grove Booster (Photograph 74), Shiggin Booster (Photograph 75), and the Marietta Booster (Photograph 77). The Marietta Booster had a second pump in the pump house that was not installed. OAC 252:626-15-3. (a)(2) "All pumping stations shall have ample capacity to supply the peak demand against the required distribution system pressure without dangerous overloading" Area of Concern 67. The EPA inspection team observed that the single VFD motor installed at the Marietta Booster was running at 59.4 Hz, near at its maximum capacity of 60 Hz (Photograph 78). OAC 252:626-15-3. (a)(6) "All pumping stations shall provide standby power to ensure the continuous service when the primary power has been interrupted. Such a standby power supply shall be provided from at least two (2) independent sources or a standby or an auxiliary source shall be provided." Area of Concern 68. The EPA inspection team observed no standby power installed at any of the booster pump stations. However, the EPA inspection team observed newly installed transfer switches and generator camlock connections at the booster stations. System representative stated that mobile generators still needed to be purchased. OAC 252:626-15-5. (d)(1)(E) "Equip each pump with the following: discharge measuring device." Area of Concern 69. The EPA inspection team observed no flow measuring devices at the Lone Grove Booster (Photograph 74) and the Marietta Booster (Photograph 77). AWWA Distribution Systems Operation and Management (G200-15) 4.2.10.1 Leaks/breaks. "The utility shall have a standardized system for recording and reporting pipeline leak or break information. At a minimum, the data collected on a leak or break report shall include pipe location, pipe material, pipe size, apparent type of leak or break, visual assessment of surrounding soil type (e.g., sand, clay, etc.), pipe's depth, and best assessment of saturation conditions of the soil prior to break or proximity to water table." Area of Concern 70. System representatives stated that they did not have a system to document main breaks in the distribution system and did not have a log of past main breaks. OAC 252:626-5-13. "Disinfect all wells, pipes, tanks, and equipment that can convey or store potable water in accordance with AWWA standard specifications prior to being placed into service. Plans or specifications must outline the procedure and include the disinfectant dosage, contact time, residual and method of testing." 30 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Area of Concern 71. System representatives stated that they did not have written procedures for disinfecting water mains after repairing or installing new pipes. System representatives stated that their verbal procedure was to disinfect lines with High Test Hypochlorite (HTH) powder mixed with water. They also stated that residual chlorine was tested after flushing but that no records are kept. AWWA G200-15, 4.2.10.2 Monitoring program. "Utilities shall have an external corrosion monitoring program. All utilities should perform, at a minimum, a visual inspection. The program shall include surveys of pipeline route before construction, including existing pipeline and metallic tanks not under cathodic protection, and existing pipeline and metallic tanks under cathodic protection. Corrosion surveys shall include potential measurements, line current measurements, soil resistivity, and soil chemical analysis. This data may be used to evaluate an infrastructure improvement program." AWWA G200-15, 4.3.3.1 Rehabilitation and replacement program. "The Utility shall have a program for evaluation and upgrading existing portions of the distribution system as required." Area of Concern 72. Area of Concern 73. The EPA inspection team observed corrosion, metal loss, and longitudinal cracks along the entire length of the exposed distribution pipe at the Shiggin Booster (Photograph 76). System representative stated that the Shiggin Booster had been out of service for over 5 years, but that water still flowed through the booster station's pipeline. The EPA inspection team observed corrosion and metal loss on the well discharge pipe and appurtenances at the McKinney #1 Well (Photograph 55 and Photograph 56) and the McKinney #2 Well (Photograph 52). OAC 252:626-15-1.(b) "The facility must be accessible at all times. Elevate the pump station at least three feet (3') above the 100-year flood plain. Provide grading to divert surface drainage away from the station site." Area of Concern 74. The EPA inspection team observed the Lone Grove booster pump in a manhole approximately six feet below ground level (Photograph 74). The manhole was equipped with a sump pump. AWWA G100-11, 4.2.1.2 Treatment plant capital improvement planning. "The plant shall have a current forward-looking assessment of the need for capital improvements consistent with master or facility plans. Master or facility planning should occur on a regular basis." Area of Concern 75. The System does not have a short-term or long-term capital improvement plan. OAC 252:626-7-4. (8)(D)(x) Upper terminal well construction "The discharge piping must provide a concrete splash pad outside the wellhouse where the blow-off valve discharges to protect the well house foundation from erosion." Area of Concern 76. Area of Concern 77. The EPA inspection team observed soil erosion from the well blow-off beside the wellhouse and beneath the splash pad outside the wellhouse at the Banks Well #1 (Photograph 48). The EPA inspection team observed a small splash pad about 2 feet away from the wellhouse building and 1 foot away from the well blowoff line at the 31 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Area of Concern 78. McKinney #2 Well that does not protect the wellhouse foundation from soil erosion during the operation of the blowoff (Photograph 53). The EPA inspection team observed a splash pad about three feet away from the wellhouse building and 1 foot away from the well blowoff line at the McKinney #1 Well that does not protect the wellhouse foundation from soil erosion during the operation of the blowoff (Photograph 58). AWWA G100-11, 4.2.4 Housekeeping procedures and cleanliness. "Areas of the plant shall be maintained in a neat and orderly condition. Operation and maintenance functions should be conducted in such a manner that plant site safety and water quality are not compromised." Area of Concern 79, The EPA inspection team observed the raw water pipe located in a below grade manhole submerged in several feet of standing water at the Lake Murray WTP (Photograph 19). The recycle water injection point, coagulant injection, prechlorine injection, polymer injection, and raw water flow meter were all submerged. An exposed electrical box was a few inches above the water level in the raw water manhole. The EPA inspection team observed a sump pump in the manhole and System representatives stated that they were not sure how long the sump pump had not been operating. 40 CFR 141.63(e)(3) Maximum contaminant levels (MCLs) for microbiological contaminants "proper maintenance of the distribution system including appropriate pipe replacement and repair procedures, main flushing programs, proper operation and maintenance of storage tanks and reservoirs, crossconnection control, and continual maintenance of positive water pressure in all parts of the distribution system." Area of Concern 80. The System does not have a hydrant flushing program. Recommended Standards for Water Works, 2022 Edition, 1.1.5 "For systems with a high percentage of unaccounted for water (generally > 20% of water production), a water audit may be required by the reviewing authority. Area of Concern 81. Area of Concern &2. System representatives stated that the System's last water loss assessment showed a 40 percent water loss. They stated that they have lowered the distribution system pressure to reduce their water loss. However, their system pressure is still generally around 100 psi to reach all parts of the system. Besides lowering pressure, the System does not actively implement key elements of a water loss program such as annual leak detection, supply and customer meter calibrations, or annual water supply audits. OAC 252:626-9-9. (10)(C) "Make provisions to avoid excessive loss of filter media during backwashing." Area of Concern 83. The EPA inspection team observed anthracite filter media outside of the filter box on the top of the filter walls at the Lake Murray WTP (Photograph 20). The System has not changed equipment or procedures to avoid the known issue of media blow out during backwash startup. 32 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 AWWA G200-15, 4.3.2.2 "The utility shall have written maintenance procedures for each pumping station (including emergency power generating equipment) describing frequency, procedures, and maintenance records. Area of Concern 84. The EPA inspection team observed a leak from the driveshaft seal on the south clearwell transfer pump at the Arbuckle WTP (Photograph 18). OAC 252:626-9-1. (h) "Safety requirements for PWS systems must meet applicable OSHA standards." OSHA, Hazard Communication Standard 29 CFR 1910.1200 (HCS), requires the use of labels to provide information to workers on the specific hazardous chemical. Area of Concern 85. The EPA inspection team observed a lack of chemical hazard labels on the entryway of the sodium hypochlorite storage room at the Newport #6 Well (Photograph 43), Banks Well, Shiggin Well, McKinney #2 Well, and McKinney #1 Well (Photograph 44). OAC 252:626-15-2. (a)(9) "All construction must be in accordance with state and local safety, building, electrical, plumbing, and sanitary codes." Area of Concern 86. The EPA inspection team observed unprotected electrical connections and wires on the floor of the Newport Well #6 wellhouse (Photograph 46). OAC 252:626-5-8. (4) "Provide for sample taps in the approvable plans that are the smooth-nosed type without interior or exterior threads, and do not have a screen, aerator, or other such equipment." Area of Concern 87. The EPA inspection team observed a frost-free hydrant with exterior threads used for compliance sampling at the Banks Well #1 (Photograph 49). Section IV - LIST OF APPENDICES Appendix A - Photograph Log Appendix B - Inspection Sign-in Sheets Appendix C - April 11, 2025, Consent Order Appendix D - November 16, 2022, Tank Inspection Report 33 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 APPENDIX A - PHOTO LOG Unless otherwise indicated herein, all photographs were taken by Brynn Goe and Kevin Sarmiento of ERG during the inspection. The displayed date and time are the local time. Photographs were not manipulated beyond minor cropping for sizing and labels or callouts to draw attention to the subject of the photograph. OIILAHOWI D!PMTIIBIT OF ENVIRONMENTAL QUALITY MONTHLV OPEJIATIONAI. REPORT (MOR) CONV! NTIONAL 011 DlflCT FILTIIATION (F-ChlorineJ 'il!!!ll!P-..,.=s.i:Wft!l!ll"eo,~eo'ft!!!:!!l!!l!!. .::..":"'-"'' ... ......... lul'lllcllfW'~1..... t:ftill:lr.. ~ ...... ,..Ultl IDIW_....,.. ........ ~IIU--p18'1fra1"'"""'9 wt1tOftf..,the Photograph 1. 7/31/2025 15:08 P7310717.JPG Arbuckle WTP Description: December 2023 Monthly Operating Report for the Arbuckle WTP showing three consecutive CFE 4-hour monitoring periods above 0.30 NTU. A-1 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 2. 7/30/2025 11:30 P7300207.JPG Arbuckle WTP Description: Residuals lagoon at the Arbuckle WTP overflowing into the surrounding environment and lacking freeboard. Note the heavy vegetation growth on the left, where the water from the lagoon is overflowing. Photograph 3. 7/30/2025 09:24 P7300012.JPG Arbuckle WTP Description: Backwash recycle injection line without a flow meter at the Arbuckle WTP, called out with red arrow on the left. Note the raw water sample line, called out with red arrow on the right, located upstream of the recycle injection point. A-2 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 4. 7/30/2025 09:37 P7300040.JPG Arbuckle WTP Description: Liquid storage tanks for aluminum sulfate and proprietary coagulant without overflows at the Arbuckle WTP. Tanks are located inside a small cutout in the floor with two drains that discharge into the backwash recycle lagoon. Note the lack of level indication on the chemical storage tanks. Photograph 5. 7/30/2025 09:52 P7300080.JPG Arbuckle WTP Description: 55-gallon plastic barrels of polyphosphate and proprietary coagulant, two 330-gallon IBC totes of 12.5 percent sodium hypochlorite solution, and one 330-gallon IBC of 25 percent sodium chlorite solution located in the Arbuckle WTP without secondary containment. A-3 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 6. 7/30/2025 09:38 P7300049.JPG Arbuckle WTP Description: Openings on the cover of the aluminum sulfate storage tanks at the Arbuckle WTP, called out with red arrows. Photograph 7. 7/30/2025 09:44 P7300062.JPG Arbuckle WTP Description: Unsecured lid over opening on the aluminum sulfate storage tank at the Arbuckle WTP. A-4 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 8. 7/30/2025 09:41 P7300052.JPG Arbuckle WTP Description: Metallic rulers used to measure chemical levels in the aluminum sulfate and proprietary chemical tanks at the Arbuckle WTP. Additionally, note the garden hose connected to facility water supply without a vacuum breaker. Photograph 9. 7/30/2025 09:47 7300072.JPG Arbuckle WTP Description: Garden hose connected to the Arbuckle WTP water supply without a vacuum breaker used to fill a 330-gallon tote with chlorine dioxide. A-5 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 10. 7/30/2025 10:43 P7300150.JPG Arbuckle WTP Description: The Arbuckle WTP water service connection at the entry point to the distribution system without a backflow prevention device. FULL CYLINDERS EMPTY CYLINDERS '!":.':::.~::.- Photograph 11. 7/30/2025 09:40 100_0067.JPG Arbuckle WTP Description: Full 150-pound chlorine cylinders in the main Arbuckle WTP building, not in a dedicated chlorine storage room. A-6 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 12. 7/30/2025 10:32 P7300126.JPG Arbuckle WTP Chlorine Room Description: Carrier water line upstream of the chlorinator at the Arbuckle WTP without backflow prevention device, called out with red arrow. Photograph 13. 7/30/2025 10:36 P7300133.JPG Arbuckle WTP Chlorine Room Description: Non-functional exhaust fan in the Arbuckle WTP Chlorine Room. A-7 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 14. 7/30/2025 11:14 P7300173.JPG Arbuckle WTP North Clearwell Description: Missing seal around the North Clearwell foundation at the Arbuckle WTP. Note the pen inside the opening beneath the tank, called out with red arrow. Photograph 15. 7/30/2025 11:21 P7300192.JPG Arbuckle WTP South Clearwell Description: Missing seal around the South Clearwell foundation at the Arbuckle WTP. A-8 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 16. 7/30/2025 11:21 P7300194.JPG Arbuckle WTP South Clearwell Description: South Clearwell access ladder at the Arbuckle WTP without protection against unauthorized entry. Photograph 17. 7/30/2025 11:19 P7300186.JPG Arbuckle WTP South Clearwell Description: Partially open flapper valve without screening on the South Clearwell overflow outlet at the Arbuckle WTP. A-9 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 18. 7/30/2025 11:27 P7300203.JPG Arbuckle WTP Clearwell Pump Station Description: Excessive water leak through seal of south clearwell transfer pump at the Arbuckle WTP. Photograph 19. 7/31/2025 08:23 P7310424.JPG Lake Murray WTP Description: The raw water line into the Lake Murray WTP and its appurtenances submerged in standing water in a below grade manhole. Backwash recycle injection line called out with red arrow. Note the absence of a flow meter on the backwash recycle line. A-10 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 20. 7/31/2025 08:49 P7310470.JPG Lake Murray WTP Description: Anthracite filter media on the exterior wall of the filter at the Lake Murray WTP, called out with red arrow. Photograph 21. 7/31/2025 08:33 P7310442.JPG Lake Murray WTP Description: Two aluminum sulfate tanks (larger tanks) and one proprietary coagulant tank (smaller tank) without overflows at the Lake Murray WTP. Tanks are located inside a small cutout in the floor with two drains that discharge into the backwash recycle lagoon. Note the lack of level indication on the tanks A-11 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 --- Photograph 22. 7/31/2025 08:30 P7310434.JPG Lake Murray WTP Description: Two 330-gallon sodium hypochlorite totes without spill containment located next to the raw water inlet pipe pit, called out with a red arrow. Photograph 23. 7/31/2025 09:53 P7310598.JPG Lake Murray WTP Description: 55-gallon barrels of unlabeled liquids stored outside of the Lake Murray WTP, without appropriate spill containment. A-12 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 24. 7/31/2025 08:38 P7310458.JPG Lake Murray WTP Description: Uncovered openings on the aluminum sulfate storage tank at the Lake Murray WTP, called out with red arrows. Metallic rulers used to measure chemical levels in the aluminum sulfate and proprietary chemical tanks at the Lake Murray WTP are also shown. Photograph 25. 7/31/2025 08:35 P7310452.JPG Lake Murray WTP Description: Garden hoses connected to the Lake Murray WTP water supply without vacuum breakers or other backflow prevention device. Note that the garden hose at the top, called out with red arrow, is connected directly to the proprietary coagulant storage tank. A-13 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 26. 7/31/2025 08:34 P7310444.JPG Lake Murray WTP Description: Garden hosed connected directly to the top of the proprietary coagulant storage tank without an air gap, vacuum breaker, or other backflow prevention device at the Lake Murray WTP. Photograph 27. 7/31/2025 09:26 P7310544.JPG Lake Murray WTP Description: Missing chemical labels on the chlorine room door of the Lake Murray WTP A-14 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 28. 7/31/2025 08:58 P7310496.JPG Lake Murray WTP Description: Four full 150-pound chlorine cylinders in the main Lake Murray WTP building. Photograph 29. 7/31/2025 09:27 P7310547.JPG Lake Murray WTP Clorine Room Description: Carrier water line upstream of the chlorinator at the Lake Murray WTP without backflow prevention device, called out with red arrow. A-15 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 30. 7/31/2025 09:36 P7310570.JPG Lake Murray WTP Clearwell Description: Broken seal around the clearwell foundation at the Lake Murray WTP, called out with red arrow. Photograph 31. 7/31/2025 09:34 P7310564.JPG Lake Murray WTP Clearwell Description: Clearwell access ladder at the Lake Murray WTP without protection against unauthorized entry. A-16 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 07/31/2025 09:50 Photograph 32. 7/31/2025 09:50 P7310595.JPG Lake Murray WTP Decant Tank Description: Water and sediment pooling adjacent to the decant tank at the Lake Murray WTP. The tank drain outlet, called out with the top left red callout arrow, is located above a manhole opening in the floor. Photograph 33. 7/31/2025 09:51 P7310596.JPG Lake Murray WTP Decant Tank Description: Perimeter of the decant tank at the Lake Murray WTP with pathway for process water and wastewater from the decant tank to enter Lake Murray, located 60 feet away. A drainpipe and erosion channel, called out with red arrows on the bottom, discharge into Lake Murray, called out with red arrow near the top of the photograph. A-17 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 34. 7/31/2025 09:56 P7310600.JPG Lake Murray WTP Intake Description: Lake Murray raw water intake at the Lake Murray WTP without signage or protection around the intake structure. Photograph 35. 7/30/2025 12:33 100_0147.JPG Newport Well #6 Description: Sodium hypochlorite storage at the Newport Well #6 without secondary containment. Additionally, the chemical feed pump is called out with a red arrow. A-18 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 36. 7/30/2025 14:31 P7300351.JPG Banks Well #1 Description: Sodium hypochlorite tanks and a 55-gallon barrel of polyphosphate in the storage closet at the Banks Well #1 without secondary containment.Z Z Photograph 37. 7/31/2025 10:58 P7310646.JPG McKinney #2 Well Description: Sodium hypochlorite storage at the McKinney #2 Well without secondary containment. Additionally, the chemical feed pump is called out with a red arrow. A-19 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 38. 7/31/2025 11:26 P7310709.JPG McKinney #1 Well Description: Sodium hypochlorite storage at the McKinney #1 Well without secondary containment. Additionally, the chemical feed pump is called out with a red arrow. Photograph 39. 7/30/2025 13:36 P7300289.JPG Newport Well #6 Description: Unscreened air relief valve on the Newport Well #6 discharge pipe. A-20 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 40. 7/30/2025 14:37 P7300368.JPG Banks Well #1 Description: Unscreened air relief valve on the Banks Well #1 discharge pipe. Photograph 41. 7/31/2025 11:02 P7310664.JPG McKinney #2 Well Description: Unscreened air relief valve on the McKinney #2 Well discharge pipe. A-21 - Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 42. 7/31/2025 11:20 P7310698.JPG McKinney #1 Well Description: Unscreened and not downturned air relief valve on the McKinney #1 Well discharge pipe. Photograph 43. 7/30/2025 13:34 P7300277.JPG Newport Well #6 Description: Sodium hypochlorite storage closet at the Newport Well #6 without chemical hazard labeling. A-22 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 44. 7/31/2025 11:27 P7310715.JPG McKinney #1 Well Description: Sodium hypochlorite storage closet at the McKinney #1 Well without chemical hazard labeling, door called out with red arrow. Note the proximity of the building in the background. Photograph 45. 7/30/2025 13:37 P7300292.JPG Newport Well #6 Description: Corrosion and metal loss on the Newport Well #6 wellhead. A-23 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 46. 7/30/2025 13:40 P7300304.JPG Newport Well #6 Description: Exposed electrical wires on the floor of the Newport Well #6. Photograph 47. 7/30/2025 13:43 P7300306.JPG Newport Well #6 Description: Threaded hose bib connected to the discharge pipe at the Newport Well #6. A-24 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 48. 7/30/2025 14:43 P7300382.JPG Banks Well #1 Description: Erosion beneath the Banks Well #1 blowoff splash pad, adjacent to the wellhouse. Photograph 49. 7/30/2025 14:42 P7300380.JPG Banks Well #1 Description: Frost-free hose bib with threaded tap at the Banks Well #1 used for compliance sampling. A-25 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 50. 7/30/2025 15:12 P7300401.JPG Shiggin Well Description: Threaded hose bib without vacuum breaker connected to the discharge pipe at the Shiggin Well. Photograph 51. 7/31/2025 11:05 P7310672.JPG McKinney #2 Well Description: Corrosion on wellhead pipe and hardened and cracked gasket between the joint at the McKinney #2 Well. A-26 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 52. 7/31/2025 11:02 P7310662.JPG McKinney #2 Well Description: Corrosion and metal loss on the McKinney #2 Well discharge pipe and its appurtenances. Photograph 53. 7/31/2025 11:09 P7310676.JPG McKinney #2 Well Description: Inappropriately sized and located splash pad for the McKinney #2 Well blowoff discharge located adjacent to the wellhouse. A-27 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 54. 7/31/2025 11:10 P7310678.JPG McKinney #2 Well Description: Pond located 160 feet south of the McKinney #2 Well. Photograph 55. 7/31/2025 11:18 P7310686.JPG McKinney #1 Well Description: Corrosion and longitudinal cracks along the McKinney #1 Well discharge pipe. A-28 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 56. 7/31/2025 11:19 P7310690.JPG McKinney #1 Well Description: Corrosion and metal loss on the McKinney #1 Well discharge pipe and its appurtenances. Photograph 57. 7/31/2025 11:21 P7310701.JPG McKinney #1 Well Description: Threaded hose bib without vacuum breaker connected to the McKinney #1 Well discharge pipe. A-29 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 58. 7/31/2025 11:23 P7310705.JPG McKinney #1 Well Description: Inappropriately sized and located splash pad for the McKinney #1 Well blowoff discharge located adjacent to the wellhouse. Photograph 59. 7/30/2025 11:51 P7300228.JPG Springer Tower Description: Overflow flapper without tight forming seal or screen at the Springer Tower. A-30 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 60. 7/30/2025 14:05 P7300328.JPG Lone Grove Tower Description: Overflow flapper without tight forming seal or screen at the Lone Grove Tower. Photograph 61. 7/30/2025 15:15 P7300407.JPG Shiggin Tower Description: Overflow flapper without tight forming seal or screen at the Shiggin Tower. A-31 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 62. 7/31/2025 10:32 P7310620.JPG Marietta Tower Description: Overflow flapper without tight forming seal or screen at the Marietta Tower. Photograph 63. 7/30/2025 11:57 P7300239.JPG Springer Tower Description: Leak on the weld of an anchor chair at the Springer Tower, called out with red callout arrow. Note the water on the concrete foundation and the vegetation growing beneath the tank. A-32 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 64. 7/30/2025 11:49 P7300220.JPG Springer Tower Description: Missing seal between the concrete pad and the tank at the Springer Tower. Note the water on the concrete foundation stemming from the leak on the opposite side of the tank. Photograph 65. 7/30/2025 11:52 P7300229.JPG Springer Tower Description: Missing splash pad beneath the overflow outlet of the Springer Tower, and erosion of the soil around the concrete foundation of the tank. Note the discoloration on the tank wall due to thinning exterior coating and corrosion. A-33 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 66. 7/30/2025 11:47 P7300215.JPG Springer Tower Description: Damage to the Springer Tower perimeter fencing and barbed wiring. Photograph 67. 7/30/2025 11:52 P7300230.JPG Springer Tower Description: Vegetation growth on the Springer Tower perimeter fence. A-34 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 68. 7/30/2025 14:10 P7300339.JPG Lone Grove Tower Description: A sheered anchor bolt at the Lone Grove Tower. Photograph 69. 7/30/2025 14:07 P7300333.JPG Lone Grove Tower Description: Anchor nut not fully engaged with the anchor chair at the Lone Grove Tower. A-35 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 70. 7/30/2025 14:08 P7300337.JPG Lone Grove Tower Description: Missing seal around the Lone Grove Tower foundation, called out with red arrow. Photograph 71. 7/30/2025 14:06 P7300330.JPG Lone Grove Tower Description: Spalling concrete on the Lone Grove Tower's foundation beneath the overflow outlet. A-36 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 72. 7/30/2025 14:12 P7300346.JPG Lone Grove Tank Description: Damaged barbed wiring on the Lone Grove Tank perimeter fencing. Photograph 73. 7/30/2025 13:14 P7300256.JPG Maridian Booster Description: The only pump in the Maridian Booster station on the ground, on top of a concrete slab, without any fastening. A-37 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 74. 7/30/2025 14:05 P7300322.JPG Lone Grove Booster Description: Lone Grove Booster located inside a below grade manhole pit with the only pump placed on top of concrete blocks without fastening, shown with red callout arrow. Photograph 75. 7/30/2025 15:19 P7300415.JPG Shiggin Booster Description: The Shiggin Booster with only one pump, located on the ground on top of a concrete slab and without any fastening. A-38 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 76. 7/30/2025 15:19 P7300417.JPG Shiggin Booster Description: Corrosion and cracking of the water transmission line passing through the Shiggin Booster. Photograph 77. 7/31/2025 10:36 P7310629.JPG Marietta Booster Description: One installed pump and an uninstalled backup pump inside the Marietta Booster. Note that the booster pumps are placed on the ground and are not fastened. A-39 31/07/2025 Southern Okla Water Corp, PWS ID: OK1010830 Inspection Dates: 07/30/2025 and 07/31/2025 Photograph 78. 7/31/2025 09:40 100_0120.JPG Marietta Booster Description: Drive unit at the Marietta Booster operating at 59.4 Hz. Readout called out with red arrow. A-40 APPENDIX B - INSPECTION SIGN-IN SHEETS SDWA PWSS Inspect ion Sign-In Sheet System Name : Southern Okla Water Corp PWSID: OK1010830 Date: July 30, 2025 Meeting: Opening Conference -- Name Affiliation, Title Email Address Phone Number Kevin Sarmient o ERG, Inspector Kevin.Sarmiento@e rg.com 703-633-1642 Brynn Goe ~ D.ei h. -- l ~)/) :--J /41-0 l~ r lsAtiL- SPARv..s I~ ~ J'l Dc-n~e, ~,....., ERG, Inspector 70K.- ~0rvv1c__ t>:-~+,-f;!d.,,"~,,c.5v<~"'n"",'v c>,_. OJ<.. 1:)f,D 1)'. ~ ' ~1 Brynn.Goe@erg.com 303- 51 9-2332 I ll/ ~04~.,,. (tv 5o ,- C tv, e-e.rr, ... ~~0-223-S'cr~j ,{)tJ,. (/ ~ ~ r- $ tpC,(/C... ~ t i ' , (__p'-,,,,f fi~O-&'JO- '~3 L{-o?..___ " L'.. \ 'iOCJC..St110-Vll<,@,, Je. q.ok .c, ov V Y.05- 7o 2- g\o 1 OK_ tQ D/sh-k,t ~/-llJ-l.e fhorr)os.fl'JM'fb')@Jei .ok..9-cN 4($ -7(J2_- '6"246 I EVA , ~ i-to-cor, e-""t ctf~CL\.-- ~-;,., . dw,e,\ au e- i7a. , q oV 21tf-6i r - 66,., J I i I I B-1 SOWA PWSS Inspection Sign-In Sheet Da te: July 31, 2025 ~System Name: Southern Okla Water Corp PWSID : OK1010830 - M eeting : Closing Conference Name evin Sarmiento >-- Affiliation, Title ERG, Inspector Email Address Kevin.Sarmiento@erg.com i_ Phone NumbJ 703-633-1642 __, Brynn Goe ERG, Inspector Brynn.Goe@erg.com 3 0 3 -519- 2332 PN-~e> ~11"1 I lsaM... S pa.rKs - E\7A 12-b I ~~F t"7"~. dQ.fl~e\ ~ epcJ.. r 90V ).bf:&) b,s-tv-,d e.tp~..,~,...f~11i. iSlit.I(.,. ">po-v- ,._ Se]., Jet(__' ok., 0 \.) 2. li+- - ;6 5- 66ri I I 1 vS"-1z -'2.. ic:, 3 i'1iomc5 N7-v..~;.e11. Ok t>E4,D:~Jr;d - rzepre:eril-iJ!v, fhef'1Ct<S.o/LJt-fleJ ei ,ok. 'cr-v 4 (.15-762 - <824~ ,,. f r_,._ De ft.Jo~ '71) w (' ~ I ~A~ ( / " ~ lfo,er {ti:) ~tvc Wp/ . Co-. ~ f~ -2.21-.f'9'-I & rJ,j 62 vt)tA.X:-w4U ,:Z..~wt I ,;t o- /4 - 3 0 d--. I I I I I I I I - I I I B-2 APPENDIX C - APRIL 11, 2025, CONSENT ORDER TAl'E OF OKLAHOMA T OF E lRO ME AL Q. ALITY ER Q ALJ DIVISIO IN TH MAIT R OF': Southern Oklahoma Wa:ter orporation Respondent, PWSID No. OKl010830 Problem: Tr IM I L, Construction, and Operational Violations ) ) ) ) Case o. 24-306 ) ) DE? or EN~lRcIEIITI\L OUIJ,ITY ) ) R The parties to this case, the State of Oklahoma ex rel. Department of Environmental Quality (' D Q") and outhem Oklahoma ~ alcr Corporation ("Respondent' ) agree to this Consent Ord r to resolve certain environmental compliance issues. his Consent Order supersedes and closes Consent Order, ase o. 16-280 da,ted February 2. 201 7, and Addendum A I.hereto dated December 12, 2020 1 otices of iolation (" OV") o. P-10 10830-22- l date,d December 29, 2022: and OV o. P-1010830-24-1 dated October 30, 2024. FINI)) G OF F CT I. Respondent owns and operates a publi \Ya(er supply (..P~ ' syslm in Cart r County, Oklahoma, where the source of water is groundwater and surface water, and is defined as a community system in Tille. 40 oflhe Code offed ral Regulations(" .F.R. ' 141.2, Oklahoma Administrative Code "OAC") 252:626~1-2. and OAC 252:631-1-2. 2. In order t demonstrate compliance ,..;th Total Trihalomethan (''TfHM'') maximum containment level CL") requirements. the a\erage of four (4) consecutive quarters at each monitoring location, i.e. the locational running annual average ('LRAA"), musl remain at or below Page I of 17 C-1 Southern Oklahoma Water Corporation PWSID No. OKJO10830 Consent Order, Case No. 24-306 the TTHM MCL of 0.080 mg/L. Samples submitted by Resp(mdent for analysis indicate the fol1owing concentrations above !he ITHM MCL: Monitorin2 Period Second Quarter 2020 to FirSt Quarter 2021 Thfrd Quancr 2020 to Second Quarter2021 Fourth Quarter 2020 to Third Quarter 202l First Quarter 2021 to Fourth Quarter 2021 Second Quarter 2021 to First Quarter 2022 Seco.nd Quarter 2021 to First Quarter 2022 Third Quarter 2021 to Second Quarter 2022 Fourth Quarter 2021 to Third Quarter 2022 First Quarter2022 to Fourth Quarter 2022 Second Quarter 2022 10 First Quarter 2023 Third Quarter 2022 to Second Quarter 2023 Third Quarter 2022 to Second Quarter 2023 Fourth Quarter 2022 to Third Quarter 2023 Fourth Quarter 2022 to Third Quarter 2023 Monitorin.2 Location DBP02 DBP02 D8.P02 DBP02 DBP02 DBP03 DBP02 DBP02 DBP02 DBP02 DBP02 DBP0!J DBP02 DBPOJ TI1IM LRAA <mrz!L) 0.109 0.098 0.102 0.104 0.101 0.082 0.100 0.0.90 0.085 0.088 0.095 0.082 0.099 0.08.5 Page2ofl7 C-2 Southern Oklahoma Water Corporation PWSIDNo. OK1010830 Consent Order, Case No. 24-306 Monitoriae: Period Fii;-st Quarter 2023 to Fourth Quarter 2023 Second Quarter 2023 to First Quarter 2024 Third Quarter 2023 to Second Quarter 2024 Fourth Quarter 2023 to Third Quarter 2024 Fourth Quarter 20:23 to Third Quarter 2024 Mooitorin.E Location DBP02 DBP02 DBP02 DBPOl DBP02 1THM LRAA (m!VL) I 0.096 I 0.096 0.095 0.088 - 0.098 3. On December 10, 2020, DEQ and Respondent agreed to Consent Order, Case No. l6-280A, to address TIHM MCL and HAA5 MCL violations in Respondent' s PWS system. The Consent Order included a schedule of tasks to bring Respondent's system into compliance with TI1lM MCL and HMS MCL requirements. As ofthe date ofthis Consent Order, compliance with TIHM MCL requirements has not been achieved. 4. On September 7 & 8, 2022, Seb Noori, DistrictRepresentative, and Oinger Sharkness, P.E.~ District Engineer for DEQ~performed a sanitary smvey inspection ofRespondent's PWS system. 5. On December 29, 2022, DEQ issued NOV No. P-1010830-22-1 to Respondent for the following violations identified during the inspection on September 7 & 8, 2022: 5.1 . OAC 252:62~5-The system.did not maintain either a sufficient volume of water to supply 24 homs of average demand to the distribation system or a standby means for providing electrical power to allow continued operations during a power failure. 5.2. OAC l52:626-7-4(c)(8)(C) and OAC 2S2:626-7-4(c)(8)(F) - The McKinney No. 2 Well was not equipped with a vent. Instead, the well bad an unprotected opening in the sanitary seal which represented a potential pathway for contamination. 5.3. OAC 252:631~3-l(a) - The flow rates through the online P1V IO00 Page3 of 17 C-3 Southern Oklahoma Water Corporation PWSID No. OKl010830 Consent Order, Case No. 24-306 turbidimeters at both the Air Parle and Lake Murray Plants were not within the manufacturer' s specified range. Toe manufacturer's specified range is 30 to 500 mLJmin; during the inspection, the observed flow rates exceeded 1300 mUmin. 5.4. OAC 252:621-S..1(4)-There was an unpemutted discharge from the Air Park plant residual lagoon lo the neighboring and inactive Ardmore water treatment plant lagoons. 5.5 . OAC 252:626-s..4(4) - The fences surrmmding each storage facility and the Air Park and Lake Mw:my Plants were not equipped w:ith "No Trespassing" signs at least every fifty (50) feet along lheir entire lengths. 5.6. OAC 252:626-54(5) - The Air Park Plant gas chlorination room door was not secured with a lock. 5. 7. OAC 252:626--5--4(5)- The Cook Pumping Facility was not properly secured with a lock. 5.8. OAC 251: 626-7-4(c)(8)(D)(ii1") - The Woodford Well No. 1, Woodford WeU No. 2, Newport WeU No. 1,.Newport Well No. 6, Banks Well, Willis WeU, McKinney WeU No. 1, McKinney Well No. 2 and Shiggin Well were not equipped with air relief valves. 5.9. OAC 25l:626-7--4(c)(8)(D)(ix)- The McKinney Well No. 2 blow ofdid not discharge over a splm pad. 5.10. OAC 252:626-7-4{c)(8)(F)-During the inspection, it was observed that the Shiggin Well did not have a vent Also, du_e to its being wrapped in insulation and thw; .not viewable to the iaspectors, it was unverifiable whether the Woodford Well No. 2 was equipped with a vent, and if it was, what its condition was. 5.11 . OAC 252:626-9---8(:aXl)(A)-The Lake Murray WfP was not equipped. with a rapid mix or in-line sratic mixer equivalent A mixing mechanism is need.ed to optimize coagulation to achieve optimal TOC removal in the treatment process. 5.12. OAC 252:626-9-9(bX2)- Thefiltezs at the AirPark Plant were not equipped with head loss gauges. 5.13. OAC 2S2:626-9-9(d)(3)(B)(liv) - Tue filters at the Air Park Plant were not equipped with flow meters. 5.14. OAC 2S2:62,6..9-9(d)(ll)(F) - The fiJter backwash systems at both the Air Parle and Lake Mmray Plant were not equipped with flow m.eters. 5.1 S. OAC 252:626-ll-4(a)(l)(A)-Tue Lake Murray Plant gas chlorination room did not have an i:.mpeetion window. 5.16. OAC 25l-:6l6-ll--4(a)(I0} - During the inspection. an emergency response plan for chlorine gas leaks was not provided for review (maintenance of an emergency response plan for chlorine gas leaks is a requirement). 5.17. OAC 252:626-13-l(a) - The Air Parle. and Lake Murray water treatment pl0Dts lacked a DEQ-approved residuals management plan. Page4of17 C-4 Southern. Oklahoma Water Corporation PWSID No. OKl010830 Consent Order, Case No. 24-306 5.18. OAC 252:.626-134(a)(l) and OAC 252:631-lJ..l(b)-The Air Parle water treatment plant did not have a minimum of two (2) residuals lagoons. 5.t 9. OAC 252:626-l3-4(a)(3)- The la,goon at the Air Parle Plant did not have at least three (3) feet offreeboard. 5.20. OAC 25l:626-1S-3(a)(1)- The Lone Grove and Cook Pumping Stations were not equipped with a minimum oftwo (2) pumping units. 5.21. OAC 252:626--15-3(a)(6)-The Carter, Durwood, Lone Grove, Marietta, and South Booster Pump Stations were not equipped with standby power. 5.22. OAC 252:626-15-S(d)(l)(E)- The Carter, Dmwood, and Meridian Booster Pump Stations were not equipped with disc:barge measuring devices. 5.23. OAC l52:626--17l(h)-The Walker storage facility overflow pipe did not terminate within 12 to 24 inches above the splash pad or drainage structure. 524. OAC 252:626-l7-1(h)(3) - The South Ait Parle Clearwell and the South Dickson Storage Facility overllow pipes were o.ot equipped with flex gates. 5.25. OAC 252:631-3-l(a) - Due to a lack ofdocumentation such as maintenance records or inspection reports, the condition ofall storage facility and clearwell hatches. vents, roofs, and interiors could not be verified. 5.26. OAC 252:63l-3H-Dead~nds in the distribution system were not flushed at least once every ninety (90) days or more frequently as necessary to maintain adequate chlorine residuals. 5.27. OAC 252:6ll-3-19(h)- Theresiduals in the backwash lagoon at the Air Park Plant were not kept two (2) feet below the maximum operating depth. Respondent received the NOV on December 30, 2022. The NOV required. Respondent to immediately correct the violation above numbered 5.1-5.3 and to provide documenlation of their correction to DEQ within thirty (30) days ofreceipt ofthe NOV. The NOV also required Respondent to submit to DEQ an approvable corrective action plan ("CAP"), with dates, for th.e violations numbered S.4-5.27 within. thirty (30) days of receipt of 1he NOV. If any violations requiring immediate correction could not be corrected within thirty (30) days. Respondent was required to provide the reasons why and to include lhe violations in the approvable CAP, with dates, 6. On February 23, 2023, DEQ received from Respondent a response for NOV No.. p.: 1010830-22-1 that proYided adequate docUDlentation of corrections for violations numbered 5.2, 5.3, 5.S-5.7, 5.10., and5.1S. In addition. Respondent provided an approvable CAP, with dates, for Page5 ofl7 C-5 Southem Oklahoma Water Corporation PWSID No. OKIOI0830 Consent Order, Case No. 24-306 the remaining violations. 7. On February 5, 2024, DEQ received from Respondent a submittal of plans and specifications for the construction of two clari.fier:s, two holding ponds, a flash mixer, a flow splitter, alift station, and all appu.rtenances at the Air Park WTP. On March l, 2024, DEQ approved the submittaJ and granted Respondent Construction Pennit No. Wf000010240103. 8. On April 17, 2024, Isaac Sparks, District Representative, and Xavie-r Branch, District Representative for DEQ, performed a follow-up inspection of Respondent's PWS system. During this inspection, Mr. Sparks and Mr. Branch confirmed that violations 5.8, 5.9, 5.11, 5.13, 5.16, 5.18, and 5.23 had been corrected. 9. On December 16, 2024, Mr. Sparks contacted Glen Jones, Chairman for Respondent. by telephone. Mr. Jones was notified that DEQ would be issuing Respo.ndent this Consent Order to establish a schedule to eliminate and preventTIHM MCL, oonstruction, and operational violations. Mr. Jones was notified ofboth the included penalty and Ute option to meet with DEQ for a resolution meeting to discuss the terms presented in this Consent Order. Mr. Jones indicated that be would prefer to have the Consent Order mailed to the Respondent and would notify Mt. Sparks if the Respondent desired a resolution meeting upon review. 10. On January 3, 2025, the Order was mail.ed to Respondent. On January 6, 2025, the Order was delivered to Respondent. Mr. Jones contacted Mr. Sparks on Janll8l)' 6, 2025, to request a meeting. On February 20, 2025, an early resolution meeting was held between DEQ and the Respondent. 1n attendance, representing DEQ,. was Afiya Wille.ins, Attorney for DEQ; and Mr. Sparks.. In attendance, representing Respondent, was Glen Jones, Chair for Respondent; Roger Page6of 17 C-6 Southern Oklahoma Water Corporation :PWSID No. OK1010830 Consent Order, Case No. 24-306 Dethloff, General Mana,ger for Respondent; and David Wyatt, Contract Engineer for Respondent During this meeting, the task due dates and associated penalties were agreed upon. 11 . The parties agcee that it is beneficial to resolve these matters promptly and by agreement 12. The parties waive the filing ofa petition or other pleading, and Respondent waives the right to a hearing. CONCLUSIONS OF LAW 13. DEQ has regulatory jurisdiction and authority in this matter, and Respondent is subject to the jurisdiction and authority ofDEQ Wlder 27A O.S. l-3-lOl(B) and the Oklahoma Water Supply Systems Act. 27A 0.8. 2-6-301 et seq., and th.e rules promulgated thereunder in the Oklahoma Administrative Code ("OAC") at OA:C 252:621, OAC 252:626. and OAC 252:631. 14. Respondent and DEQ are authorized by 75 0.$. 309(E) and 27A O.S. 2-3-506(B) to resolve this matter by agreement. 15. Respondent violated OAC 252:621-5-1(4). This provision states that "[n]o action shall be allowed to breach the walls, berms, dikes, or other structures causing or allowing the wastewater contained to escape, unless specifically allowed in a discharge pennit as an allowable discharge from a discharging pennit." 16. Respondent violated OAC 626-S-S. This provision states "(i]f 24 hours of elevated distribution storage based on average daily demand is not available,. provide all plants with portable or in-place internal combustion engine equipment which will gene.rate electric power to allow continue operations. at peak hourly demand., during a power failure." 17. Respondent violated OAC 252:626-9-B(a){l)(A}. This provision states "equip mixing Page? of 17 C-7 Southern Oklahoma Water Corp0ration PWSID No. OKI 010830 Consent Orde1, Case No. 24-306 basins with mechanical mixing devices capable of adjustment to compensate for variations in raw water quality and flow. C-0mmercial in-line static mixe.rs capable of producing results equal to basins containing mechanical mixers at all anticipated flows will be acceptable[.]" 18. Respondent violated OAC 252:626-9-9(d)(l l)(FJ. This provision states for backwashing filters, equip ..rate-of-flow indicator on main.washwater line, located so that it can be easily read by the operator during the bat.k-washing pro<:ess[.J" 19. Respondent violated OAC 252:626-13-2(a). This provision states that "(a]n approved Residuals Management Plan is required for storage, dispoSal or reuse of WTP residuals, including residuals from iron and manganese removal plants. When a permit is required, a residuals management plan shall be filed with the DEQ[.f' 20. Respondent violated OAC 252:626-l3-4(a)(3). This provision states that lagoons used for the treatment of WTP waste .shall have "a rninim.um of3 feet offreeboard[.]" 21. Respondent viol!ated OAC 252:626-15-l(a)(l). This provision states that "[a]U pumping stations shall have a minimum of two (2) pumping units.. With any pump out of service, the, remaining pump(s) shall be capable ofproviding the maximum pumping demand of the system." 22. Respondent violated OAC 252:626-153(a)(6). This provision states that "[a]ll pumping statio.ns shall provide standby power to ensure the continuous service when the primary power has been interrupted. Sllch a standby power supply shall be provided from at least two (2) independent sources or a standby or an auxiliary sources.hall be provided." 23. Respondent violated OAC 252:626-15-S(d)(l)(E). This provision states that a PWS system should equip each pump with a "discharge measuring device." Page 8 of 17 C-8 Southern Oklahoma Water Corporation_ PWSID No. OK1010830 Consent Order, Case No. 24-306 24. Respondent violated OAC 252:626-17-l(h)(3). This provision states that for all water storage structure with an overflow, "[e]quip lhe ends oflhe pipes with flex gates.." 25. Pursuant to OAC 252:631-l-3, ''The provisions .ofParts 141. 'National Primary Drinking Water Regulations,' and 143, 'National Seoondacy Drinking Water Regulations,' of Title 40 of lhe Code ofFederal Regulations [C.F.R.] as published on August 17, 2022, and the requirements contained therein are. unless otherwise specified, adopted and incorporated by reference." 26. Respondent violated OAC 252:631-3-l(a). This provision states, "All systems must properly operate, in accordance with [an] Operations and Maintenance manual as required by OAC 252:626-3-7. All systems must maintain each unit to provide treatment of the water in accordance wilh the DEQ approved plans and specifications, in accordance with the purpose for which the uni ts were designed and according to the tenns of their permits . . . Employees must be trained in the proper operation and maintenance of the system." 27. Pursuant to OkC 252:631-3-l(b), "PubJic water supply systems must comply with all applicable Primary Drinking Water Standards in 40 [C.F.R.] Part 141 ..." 28. Respondent violated OAC 252:63 t -3-16. This provision states that "PWS systems must avoid dead-ends in the distribution system. Where a dead-end main exists, it must be equipped with a valve or other arrangement for flushing. Flush until the water is clear or a chlorine residual is found. Flush ever ninety (90) days or more often where conditions require. 29. Respondent violated OAC 252:631-3-19(b). This provision states that ..[d]isposal of wa.stewa.ter and residuals from treatment units (filter backwash water, clarifier blow-off, etc.) must be according to OAC252:606 (Discharge Standards), OAC 252:621 (Non-Industrial Flow- Page 9 of 17 C-9 Southern Oklahoma Water Corporation PWSID No. OKI 010830 Consent Order, Case No. 2+306 through and Public Water Supply Impoundments, Including Land Application) and OAC 252:626 (PWS Construction). Each lagoon shall be cleaned when the depth of the residua1s is within two feet (2'} of the maximum operating depth." 30. Pursuant to 40 C.F.R. 14l .64(b)(2), the MCL for HAAS is 0..060 mg/L. 31 . Respondent violated 40 C.F.R. 14I .64(bX2). This provision states the MCL for 1THM is 0.080 mg/L. ORDER 32. Based on the above paragraphs, Respondent and DEQ agree, and itis ordered by the Executive Director as follows:: TASK DATE A. Respondent shall submit and begin implementation ofan approvable, interim CAP, with dates, to address violations 5.4. 5.19. 5.20. 5.21 . 5.22, 5.24, 5.25, 5.26, and 5.27. Completed B. Respondent shall submit an approvable engineering report proposing a schedule, with actions and dates, for the proposed Lake Murray Water Treatment Plant. This engineering report should address violations SJ , 5. 11, 5.14, and 5.17. C. Respondent shall submit appmvable plans and specifications and obtain a DEQ..issued, Permit-toConstruct for the proposed Lake Murray Water Trealment Plant The plans and specifications should address violations 5.1, 5.1 t, SJ4, aod 5.17. D. Respondent shall complete construction of the project in accordance with the DEQ-issued Pennit-to-Construct No. WT000010240103 referenced in Paragraph 7. June 1,2025 Jufy 1, 2025 July l, 2026 E. Respondent shall attain compliance with the TIHM January I. 2028 Page l0ofl 7 C-10 Southern Oklahoma Water Corporation PWSID No. OK!Ol 0830 Consent Order, Case No. 24-306 MCL or proceed to complete Task G. F. Respondent shall maintain compliance with the TillM MCL or proceed to complete Task 0. January 1, 2029 G. Respondent shall submit an approvable engineering report proposing a schedule, with actions and dates, for achieving and maintaining compliance. The approvable engineering report will be incorporated into an addendum to this Consent Order to ensure Respondent continues to make progress in addressing too cited violations. 180 days after receiving notification from DEQ that Task G is required. 33. The Oklahoma Environmental Quality Code, 27A O.S. 2-3-502(B) and (K), authorize DEQ to seek penalties ofup to Teo Thousand Dollars ($10,000.00) per day for each violation of the Code and the associated rules. Based on the facts and cirownstances ofthls case, DEQ assesses a total penalty ofTwenty-nine Thousand Two Hundred Twenty-foUT Dollars ($29,224.00}. Ofthis penalty amoun~ One Thousand Dollars ($1,000.00) is due within thirty (30) days of the effective date of this Consent Order. DEQ agrees to defer the remaining penalty amount, Twenty-eight Thousand Two Hundred Twenty-four Dollars ($28,224.00), pending compliance with the due dates set forth in Paragraph 32 in th.is Consent Order. IfRespondent fails to complete a task by the scheduled due date, the portion of the deferred penalty allocated in the table below becomes immediately due and payable. IfRespondent completes a task by its due date, DEQ agrees to waive the portion of the deferred penalty allocated to that task in the table below. TASK A B C D E F G AMOUNT DEFERRED $4,032.00 $4,032.00 $4,032.00 $4,032.00 $4,032.00 $4,032.00 $4,032.00 Page 11 of 17 C-11 Southern Oklahoma Water Corporation PWSID No. OK1010830 Consent Order, Case No. 24-306 Payment shall be by check or money order payable to the Oklahoma Department ofEnvironmental Quality (or ODEQ), showing the Case Number ofthis Coose-nt Orde-r, and delivered to: Accounts Receivable Financial and Hwnan Resow:ces ~emenl Oklahoma Department of Environmental Quality P.O. Box 2036 Oklahoma City, OK 73!Ql .2036 34. Respondent agrees that if Respondent fails to complete any of the task(s) by the specified due dates set forth in Paragraph 32 in this Consent Order, DEQ may assess stipulated penalties as follows : TASK A B C D E F G PENALTY PER DAY $140.00 $140.00 $70.00 $280.00 NIA NIA $1 40.00 Stipulated penalties begin to accrue on tlte day perfonnWlce is due, with the total amount of stipula.ted penalties not to exceed Seventy.five Thousand Dollars ($75,000.00). 3S. If Respondent fails to pay any penally, DEQ may bring a separate action for collection of the penalty in district court. An action by DEQ for the collection of a penalty does not affect Respondent's duty to complete the tasks required by thls Consent Order. GENERAL PROVISIONS 36. ~ndent agrees to perfonn the requirements ofthis Consent Order within the time frames specified unless performance is prevented or delayed by events whiob are a ..force majeure." For Page 12ofl7 C-12 Southern Oklahoma Water Corporation PWSID No. OKJ010830 Consent Order, Case No. 24-306 purposes of this Consent Order, a force majeUN event is defined as any event arising from causes beyond the reasonable control of Respondent or Respondent's contractors. subcontractors, or laboratories that delays or prevents the perfonnance of any obligation under this Consent Order. Examples are vandalism, fire, floo4 labor disputes or strikes. weather condi.tions that prevent or serious1y impair construction activities, civil disorder or unrest, and "acts of God.'' Force majeme events do not include increased costs ofpetfonnance of(he tasks agreed to !n this Consent Otder or changed economic circumsmnces. Respondent must notify DEQ in writing within fifteen (15) days after Respondent knows, or should have known, ofa foroe majeure event that is expected to cause a delay in achieving compliance with any requirement of this Consent Order. Failure to submit notification within fifteen (l 5) days waives the right to claim force majeure. 37. As used in this Consent Order, an "approvable" submission to DEQ shall be considered a final submission. That is,.a1 l preliminary discussions between DEQ and Respondent regarding the requirements of a submission must be concluded prior to the date the submission is due, so that the submission will be approvable as submitt.ed. lftbe submission is not submitted in an approvable form by its due date, then the submission will be considered delinquent, and Respondent will be subject to the monetary penalties described in this Consent Order. 38. Upon their approval by DEQ, any final reports, plans, specifications, schedules, and atta.chments required under this Consent Order are incorporated into it and enforceable under it. Failure of Respondent to respond within a reasonable time to any errors, deficiencies, or other regulatory requirements identified by DEQ is a violation ofthis Consent Order. Page 13 of17 C-13 Southern Oklahoma Water Corpor:ation PWSID No. OK1010830 Consent Order, Case No. 24-306 39. No infonnal advice, guidance. suggestio11S, or comments by employees of DEQ regarding reports, plans, specifications, schedules, and other writinw, affect Respondent's obligation to obtain written approval by DEQ when required by this Consent Order. 40. If Respondent is required to sample or test. Respondent agrees to give DE-0 reasonable notice ofthe sampling or testing date and time and allow DEQ to observe and/or split-sample. 41 . Unless otherwise specified, any report, notice, or other comm.unication ~uired under this Consent Order must be in writing and must be sent IO: For the Department ofEnvironmental Quality Isaac Sparks, District Representative Public Water Supply Engineering and Enforcement Section Water Quality Division Oklahoma Department of Environmental Quality P.O. Box 1677 Oklahoma City. OK 73101-l6n For Respondent Glen Jones, Chair Southern Oklahoma Water Corporation 1967 SamNoblePatkway Ardmore, OK 73401 42. This Consent Order is enforceable as afirnd order of the Executive DirectorofDEQ. DEQ retains jurisdiction of this matter for the purposes Of interpreting, implementing, and enforcing the terms and conditions of this Consent Order and for the purpose ofresolving disputes. 43. Nothing in this Consent Order limits DEQ's right to take enforcement action for violations discovered or occuning after the effective date of this C-0nsent Order. Page 14 of 17 C-14 Southem Oklahoma Water Corporation PWS1D No. OK1010830 Consent Order, Case No. 24-306 44. Nothing in this Consent Order excuses Respondent from its obligation to comply with all applicable federal. state, and local statutes. rules. and ordinances. Respondent and DEQ agree that the provisions of this Consent ,Order are considered seve.rable, and if a court of competent jurisdiction finds any provisions to be unenforceable because they are inconsistent with state or fedend law, the remaining provisions will remain in full effect 45. Respondent agrees to notify all potential purchasers ofthe property that the obligations under this Consent Order are binding on the purchaser. Within ten (l 0) days of the sale of the property, Respondent will aotify DEQ of the sale and provide the name and address oftbe purchaser to DEQ. 46. The provisions of this Consent Onkr apply to and bind Respondent and DEQ and their officers, directors, employees, agents, successors, and assigns. No change in the ownership or corporate status of Respondent will affect Respondent's responsibilities under this Consent Order. 47. Compliance with the terms and conditiom ofthis Consent Order fully satisfies Respondent's liability to DEQ foI all hems of noncompliance in this Consent Order. If Respondent satisfies the requirements of this Consent Order, DEQ will nol pursue any other remedy, sanction, or relief that might otherwise be available to address 1he ~ of noncompliance in this Consent Order. 48. This Consent Order is for the ptup0se of settlement Neither the fact that Respondent and DEQ have agreed to this Consent Omer, nor the Findings of Fact and Conclusions ofLaw in it, shall be used for any purpose in any proceeding except the eafo:rmment by Respondent and DEQ of this Consent Order and, if applicable, a future determination by DEQ of eligibility for licensing or permitting. As to othen. who are not parties to chis Consent Order, nothing contained in this Consent Order is an admission by Respondent oftheFmdings offact ,or Conclusions ofLaw, and this Consent Page l5of 17 C-15 Southern Oklahoma Water Corporation PWSIDNo. OK1010830 Consent Order, Case No. 24-306 Order is not an admission by Respondent of liability for conditions at or near the facility and is not a waiver of any right, cause ofaction, or defense Respondent otherwise has. 49. Respondent and DEQ agree that the venue of any action in district court for the purposes of interpreting, implementing, and enforcing this Consent Order will be Oklahoma County, Oklahoma. 50. The requirements of this Consent Order will be considered satisfied, and this Consent Order terminated, when Respondent receives written notice from DEQ that Respondent has demonstrated that all the terms of the Consent Order have been completed to the satisfaction of DEQ, and that any assessed penalty has been paid. 51 . Respondent and DEQ may amend this Consent Order by mutual consent Such amendments must be in writing and the effective date ofthe amendments will be the date on which they are filed by DEQ. 52. The individuals signing this Consent Order certify that they are authorized to sign it and to legally bind the parties they represent. Page 16 of 17 C-16 Southern Oklahoma \ acer Corpora1jon P\1 ID No. K1010830 onsenl OrdC'r. asc o. 24-306 53 . This CanscDl Order becomes effective on the dale of the later f the two signatu~ below. ORRE PO DENT: OKLAHOMADEPARTME T OF I lRO i'VIE TAL Q ALIT : Chair D a t e : ~ ~ / ~ co<O..:Zb l-- Executive Director Date: Ll-1\-15" Page 17 of 17 C-17 APPENDIX D - NOVEMBER 16, 2022, TANK INSPECTION REPORT ) ::,( L) ( ,,,....... l SLJP_ RI R " ' -e - v ,c=~'a ,i. u UP L"f' .._ ,~ ..,,,,,,,, w 'r In .p tlon f\ Cl n1: owe . Dlldoon N T n l wn St1r1d plp T, nk Olni,m,I n , -,:H' V ar Bull1 9H PO 1Bo~431 Must n~. o 7 (l 4 405-~90-344 - D-1 ,-... \..._.. _,. ~- ~.!QB Gooo No fff'NI 10 Rt.fl .. EXTERIOR: I :.>t, SfflKtd/ r...,.e 2 ~ l Fou.ncbUOn 8...,C.ulQI& s Splth Pt.,d 6 Ancho, Bolu 7 Or.alft 0t t>Rri Pli.,I 8 Milnway t g ~nwily 2 ID Overflow "-udder u S.fttv Climb u . st..a 14. Roof 15 AoolHmh 16 floofVent 17 S.ltty tllllldtoil 18 11<, Olf Potnt 19 Tan.k Gu:H 20 Ovual bltr;or h int 21 .....o 22. Valllt Vault Fo, Field Olht1 for Fitld 0th ~r fltld 00,,, for Held 0th for F-.eld Otho, Commenli/Note.1: J.,,. ConMdtr a,p1atlnc Soon &ads Compjetf ~dure Pru~ttr ... Yu ... v. . ... Yu Ye> Yes Ho Yts v. . Yu Yts v. . Yu Yu llo YH ... ... No No Condlrlon hi/ Good hit Bd S.d Good Good Good N/ A Falt Good Good Filf Folr h it hu H/ A Good NJA hit H/A N/A Nor, Tant lilt n kKtfd M)d ncvre link Siitt IPPHIS to dtJJft o,OMrty Mloo, um, J>nd/or spolkna N f f dJ , ~ ~ e d Sized ln<oKtly .Anchor bollJ/tho on lllce nd Og/lt =~ Omn w/ valve P<tl!llt Manw.y wJ/Of bolu >nd mgood c<iod,'tloo Secondary l'Nftway not ,present F1P?f1 Vltve present w/ NO mHh ween udder1s) ~ppear in good concfruon Safety dimb and able gr.1b ptHMt in good condltJOt'! Minor-nnt prn.f'"l on WU arwJ./o, weld sums MWK>f t1J1,l ptHe-ftt on roof 1NS/0t w.--el,d seams M.no.r ruR present M hatch Jnd/or wtid seams MM'\Of" ru.U prtW'.nt Otl vtnl INJ/Of weld 5HffU n. off oo,n1., rood cone!<,..., Tnlt 1-1:1,111 cw-u<t-nt lklt not 0Pf1'Jba. MinorMl p,~nl Ov~H condi1ton orTank u t ~ tS FA(R Overflow 1plas:h ~d to smd Stconcfi,y 30- manw1v not OfUenl 0vHflow fl.i:PPN doff not 'have mt'ffl "'"" p,et.cnt. E.de,10, coitin1 iyuem nur3n& end of ldt cvdt. loch Itch ll/16/)011 11/16/2011 PO Bo, 431 M u\.t.tn. OIC 7)064 40'i590l449 D-2 Good No N~d lo RtplillCt: INTERIOR: 1 Roof Pla1e 2 Root Aftort: 3, Vtnl 4 H1tc:h S. Ovrflow/Woir 6 ShII 7 lnlt1l Plc1n11 8 Otlel PID1n1 , . M lnwiy 1 10 M ilnww J 11 C;athodlc Prott<:tk>n u . Le-vel lndictot u Floor 14, Sed1men1 lS. ln.terlo{ Ladde.r 16. Mixl n,: System 11. A!!~tion System 18. o ,aln )9. Ove,rall lnttriot P.lint 20. Water Visibility Fo.r field Othtr For Field Other for field Other for Field Other for neld Other for Reid Othef Fo, Field Othu C.ommtnU./NOttr. I Prutltf Yf\ NO Ye, YH NO Yt> y., Yo, Y No No Yei Yn v.. No No No Ve; ... CoM/rio. r,1, G"o'"od Good N/A r.., F Fair Fait NI" N/A N/A N/A f.air II/A N/A. H/A Fair fJir Good NOi f MMt ,U11 .nd}or d~li1.m1nat1on p,e.,,,n Nlinor ru11 pruent on v nt tnd/or .N~1d 1"1m, M"'' run oru~t on hanh aM/o,, weld 1r.itrT11 Wtir box n.o1 Dttttnt ~ ruit ....cnnt Of\ sl\iicn an.d/or w,ld ,c11mi M.lnor r1.1:1t/tc1ft pruent Minot" run CKt11nt MinottUst and/01 debm!ntlon Su.ondarymanW1v not Drl!\1?1'11 Cathodic ptottctkN, not present lt'lflind:iQ.to, prtsent but not ooe.nble Unable: to ln:Spect tank. floor due to ;edlment Mod,nte sed',ment pre.sent bddetls) ind s.1fetw dltnb notpreunt Mixing syittm not present Aeration system not present Orai:n w/va.lve cce.seot Minor rust and/or de~m,natl:Qfl present Clear Ov~rflow wtJr bOx nol pre.tnt OvttI (OfWlll-ol Ian!< Int,-" FAIR Modtrlll t,edm'\tnl P,-tlC'n on l'lnk floor Minor ru1t/dt4.tm.1natlOI'\ Of IN"''O' (OJllnf: ptutftl Ted,: Te<h: OWi 6'1mO<e Swvroo1o ll/16/lOU 11/16/'HW pa9o..,.a11 Mumog. O~ 7)064 405-S90-W9 D-3 - Surnm.a1v/ I 2. l. 4, s. 6. 7, R~co11,r,,ttncfat I lol\' Tanll. bte,10, Ap11lv ha'>e c.-.vlk.ln& Install overflow spfil,\h nad flum.e Install tla11ae-d OVl!fflow Hnp~t, valve w/ removJbll" mr,;h s,-,e~fl lni.u,n sccondarv 30.. m11nway Power wnsh and ove,coat ektt tlot (Ptndln1t Adh~slan ffl:\t) S, 9. 10, link lnte, lor l l, Remove se.dlrn!nl from tan~ floo r 12, lnJliU oass1ve mhclnR svnem lnHill ovcr11ow w tih box 13 Blan and re-coat ta nk lntcirlo, 14 IS "17, 18. 19 20. Addltlonal Comment s: I Overall Tank Grade: C 1M 1k doe~ flC>t meet i omit o, 11m~t rcgulalo v (Cldt',, mlo<'lr ~nci mnjor bli: ml~hes found 11ml neud\ '1ltenllon Mt' l!ldlth, ,le;t. I ) ( - ;J.. 110 Uo11 4.il Mv>1oog, OK /30&4 '1()S,S1)U .M'11J D-4 Tower Inspection Report Clleol, SOWC lone G,ove Tank Type: Standpipe Tanic Cap;u:Jtv: ue.'65 Gallon, Tan 'II: Dime MAoru. U ' to PO Bo:. 43 1 Mustang, OK 73004 40S S90.349 D-5 Good No Nted to ~eplac:~ EXTERIOR: I. Slit" SClturcd/ Fence 2. Or.lh\aa, 3 founda1!00 4 Aase: C.lulld~ s Splash l'lad 6. Anchor 8olt, 1 Drain or Oroin Plu11: 8 Manway l 9.. Manway # 2 10 Overflow 11. Ladder 12 Safety Climb ll. Sholl 14, Roof IS. Roof Hatt h 16. Roof Vent 17. Sorety Handrail 18, nt Off Point 19, hnlt Gause 20, Overall Exterior Paint 2l , Lo10 22, Valve Vt1uh For Field Other For Field Other For Field Other For Field Ol her For Field Other Commctnts/Notes: Fair~ Comlder 'Replacing Soon Bad: Complete Fiilu,, Prtsenc Condition N ore YCI Good Tank 1ltt l1 lo,ked 1nd ~,ure ye, Good Tank site appears to d rain pfoperly Yes fair Moderntt crack.sand/or spamns Y Dad y. . Fair Needs reapphed Sized lnc.orrectly Yts Bad ,., Fair Anchor brok~ a1 chair Drain w/ valve present Ve , Falt M;inwv and/or bolts show minor rust No N/A Secondary manwav not presen t Ye , Good Flaoptr valve present w/ NO mesh screen Yes Fa!r t.a ddi!t{s} have c1bles/wlrln1 attached co hilnd holds Yes Good S~fety climb present no ublt! 1:rab Yts Fair RusVDh!fAlau present Yes hlr Run/Oirt present Yts Fair Minar run preseni on hatch and/or weld sHms Yes F1lr Minor run present on vM\ 1nd/or wt ld sum.s NO N/A Ys Good No N/A Yo, Fair Vos Falt YO> Good Fadlng/Chalkina ptuent l o10 5hows slans of fad1n1 Overall Condition of Tank Clil'.tt rlor h FAIR/BAD Founda\ion has moderate spalllng present~ Anchor boll Isbroke at the anchor chair and other anchor nuu ~re no1 fully enijaged. Secondary 30" manwav not pre1.ent, Overflow flapper w/ remov3blr mesh screen not pn~.se.nt 1 Tech. Tech . Ch~d Gllrr\01 e Sawyer Toole Oate: Date: ll/ 16/1012 11/16/2022 PO 8011 43 1 Mu~ta ng, Ok 73064 40S-.S90-J449 D-6 IN TERIOR: l . Roo[Plate 2 !l:ool A.i rter~ : 3. Vent ~ t1Mch s. 0\1erf1'0w/W~ir 6. Si'l!.'11 1 In1Ir t Plpl11e 8" Outlet Plpmill 9 M,mwl!ylll lit MillW~V#2 l.l , Cll:ll;odlc IProte:ciion u . lelll!I Indic:,1tor 13. f lcor 14. Sl'ldlmcn,t lS, lnttrlor Udder Iii, M1,ln11: S.vstem 17, .l\er111tlo,n Svstem 111. Dr,llln 19, Ov1m111 !rmirfor Palnt 20.' WMcr Vlslblll t\l For f l eh:I Other For fii: 111 Other fer 1F-Jcld Other For Field Clher For Flela Othrr For Flold Olher j:ar Field O~her Cornm 11ts/ Otll , I Pnsfnt Corfdltla" 'fp,5 F.i!r 'l'e! fair 'l'e-5 CiD-Qd ves ' GY'Odi ' Yet, 000:d Ve~ Fair Vts Fair Ve:1 Fair Vu Falr Na N/A No NIA ~o I N//J. Ye1 N/A 'l'CJ ,~1tr IND N/A N:o N/,A No NIA Vu S11d Vti F'1ir I Vt1 Good I Notfl Mlnorrust ~nd/or dclamlnol 1011 p re1e nt Mo.d!!rnl,1!1 ru~t ~nd/or delatnlna:tion pr!!:1.0111 Minor nJ1I IP1"!!i5-Bflt on ve11t ~1r1c/0r weld 1eam"1o Minor r1,1st pre~l!n.t on lutth ~rid/or w@ld sie11,ms Overrtow/W~ir box Ir, !lOOd c;0ntllt1-on Heavy srail'!ll'lg Minar r1.1~t/m11e11r,111,emt Mlnor rust oru1mt Mil'lor nal al'l~/or dcl11mfnwtl1:m S~coni:lru\l m1rnw1v 11ot present ~ tl'lodjc pro:tectlan not preit!l'lt Le-vc I lndJt,tor not prMl!nt IJn:able to in111 Bet I.ink 000, clue to Hd lment Modtrat~ 1edlment pruent udderb) ~nr.1 safew dlmb not r:irttei'lt Mll!(ln,11 wncm ,not ,mucnt Al!,r~tla ru.vs,tem ncu IUi!!i!nt Drain w/ 11a1IIH! 11rutin~ Mmor nm arul/at dtl~min.itli:m e1r,eu1nt a111r i'l l11e1rnn pr s. t h lJ 0'111 r ,II c4:mdltlon 10f 1 nk,hu rior 1 AIR out In r H vy 't lnir1 r, nt 'hf u ho l 11'1 II I 5 dim nt pr nt on t -n tlo r li1 Ulltl.ll Te h: Tildi : 11 d G1lrnor awv r fac1_ Dill : [Ll Ill /W l tl/16/l 2 po o 1 M !.U n&, OK 30 40 -5,9'0-3449 D-7 Su 1 Afll/ ~P<or m ncfatl . OiveraU Tank Grade :.B T me l!i manor - od f., m or bl n t:!') He ~rd ), I )--r .,., D-8 D-9 l m;~, JI .J EXTERIOR: PN!U!'1d i 511.c Se<:UFl?d/ Fl'fll:I' 2 0r..w1a11:i: ] Fo11nd~t1on 4 B,1~~ Cnu I~Ing 5 !iip1,uh Plild 6 AIIChar Bain, ? , IOr.ii,, 1Qr Orilln ?11.11 Ii M.inwav ll 1, !!II M.inway !'1 1 10 C11er!l 1:1w 1l ladder l2 5.1r,1:1tv c 1,m13_ l3 51H:ill M ~oof l' Roar 1-t11tch I l . ~oc,f v 11,u l ' . SilfDtv m1i,id,.ahl a T111 Otl flo lr,t Jill IT;)nk GllUIII 20 , IOvn r11H~uor Piailn:t ' 21 lOl!!:! 22 V!l!lve V_!l!!l_t i:,orJu:lrJ Oth~r I for Fnilcl Other f ,or Fil!'ld Other For J;i11ld Ottlllr For Fiitlcl Othe r 'l'eli 'j'i!j Ves Vcs '1'11~ l''ci Yu ~ No, v~, Vu Na 'l'u Yet . 'iH Vin _No '1'111 No 'l'il!, Yes r,u Condition Ia~e1 Fal, GtHtdl B~d Good Gcu:ii:I Gooi;t IGood N/A FAlr flljr N/A fair F11,1r Gooi:1 GIHl d NIA Gciod I NI/r.. F11 lr Good ll!!1lr Note Se.cLJrlty IF-l!'!'il!::@ In PDOI" c;o.ndi,1io11 Tan!t 1lt,e need~gradlnit t o drain propNly f01:.1ndation ,ai:,i;eatS, In good con.d11.ie1n Ne,e,r;h ireapplLecl Si:,luh p1d,performs irilend~d fung_ion - ~nc'hor b1:1lt~/chalr1, In olu.e ill'ld tlghl Dr~h, w/ Vi!lv.e i:,re.se ru M~nwalj ~!l'ld:/ar lu,lu i ticw minor run Sec;cmd11ry m11n,w11i!;' ncit jilrts~l'l\' Fla1>F)1?r v11!:ve P~_!i~nt w/ NO mj,l1,h 1cr1:tn J~dderlsl h111,111- c;i t>lesJwlri i,,g ~tti!Ched t1:1 hand hold1 S1fatv ellmb not ,prc1ent Run/mrt/Al.1111 e prn1e n1 Ru1f'/l)lf'!: present Mlrlllr run Pr-Utl'lj on 1,atcl'i 11r;d/or w11ld teams I M ino, m1t prr:iunt on vcint 11 nci'/or w,l dI11t11m1i f lt a,, llO Int In.11,ood COl'lt:IIUon Ml nor nJ~t ill f\Cii ll I'll lo.110 11ooi!.11r1 In 1i,c1od to n-clltlol'l s11,0 IPl! ~ln11 naca111I IUO'Uncl \4!i11J lt II I ni::eIi In pogr on Ihon. Sit 11 Qt hi!~ f - l'f d lmb 1'1' t 'id liar l>i !rA:ili , fm:>p - -- . Secnnd _ry m nw - no 1:w s.en ,blH hiind,r_ I t rior co tir; rU! rln1 d e, T h: Tech : t,, ~ GOmo S<1Wyer Toole Dat e O a t !!' ll/16/2022 11/16/2022 11 a .iin Musta.ng, a 7:10 4 40~-!i!li'.l-3449 D-10 ri!II tond IOQ O f on D U/1 2012 D 'I J IJ6/IIU D-11 ,,.-.. ,_,I SUP=RID' \ . .B A 11 T A Cl' I 'I C .9. l'i 20. D-12 D-13 "rF" [IS,d r R " th'I n Coru:OUon 00. 'Secondary :30" m,mw y net pres.ent , Cab 1, r, u lied o u, I dd l'la,ndrnil ~d rlrn,Dre S Iii/Ver TO Di -, Dal1: ; O;U 1/1.6/ion H/1 /2022 PO 'l'i g,1<4 M u: I'll!, OK 71064 405 -5,gO,.JcWl D-14 ,..... L. 'SUP=AID R ." 1./IC .a,N "', ~ Al I'll~ 111"1 11 bu Id u ,111'1 f r, ll011r D llJ fJ 0 D U / 16/2012 D-15 R ~ - SUP RI R I II A N:1 Ll'J"H:"l 1,.-~ 1- .;;;,,,,.,,- IHl'IM~ / !t c ni.,n: !\fl! 11 t I, t--- 1 : l ~ " ~ " ~ s Cl ~o 11 a, 13 l~ . Ui , 16, l ?, Ill. 19. 20. Tank f:11ter~or flf'l.il?IIIV b:.sa t o)L1lk1ri11 lnitan ~f(;lll1d ilr'I' 30" ffiilnWil' t ~rlnci1h1c<1,b,lin11 from l11dtl11r lrnnrJr.11 l'tiwer wc1s'1 del}nln11 1:1r u1,nk l!'iderlor T~nk lnt'llil'lor Ftemov;il of $edim~r,:t frt1111 ta rik lloor F\111 bl,UUnd rt!'Coat oOn.Hirlor (D,atil'lll,:J'f'lhlm I Overa1l'I Tank Gra de: C T ,;_ D $ not m t mm r 11 t r ,RIJ 1, m , cl maj0r blemi hu I umi "1,d 11 P llno I\ l Mu I Oft, 0 J-lo tl 405 -5!1()- 44!1 .,, I D-16 Tower IMJ>ect on R port Clint 50WC _prl'rlli!f f n.kiype : S,Hdpip1 Tan .Cap 'f 111,9615 Tan O m - M iDn1: 15' 90' '(ear lltillt'. "9'(!9 ,PO a~ ~lJ Mu si 111 o~ 73 110,5.590. 449' D-17 ,..,... ..._s.(,",~,.... - r D-18 01 rn I, h h CHJ'! nd ChJd llm r S ,wy1u Joo,lil i 1./I ,/2dl "l 11/16/ 0 l j()flo~ :n Musl3rl , . 7. 064 Mt!.-S.90 J44-9 D-19 ,-.,... ..__,.SU'P _ RIOR t: '-.t i N ~ r, t.,. , I ' I~ Pow Add,IIlol'ml CEJrnm 1mu : I Over,aU Tank Grade: c fi d POlloi;;<'I l 70 4 D-20 Tow r In ,pecUon R p rt c11 - t : SOWC - Walk r T nkWp -. tanclplp fan C ,paatv: 1111,.96!3' Gall1111:11 T nlc 01,m n'.S cu, 15 go Y ;ir Ii lit : 198,5 PO Oo!!4 l MY till1B, Qi( 73064 405-590-3449' D-21  u," 11, EXTERIOB: B cl= 1 cml)I 5P on 011 r II caiul: t m1o-f Tan b:ter'lorl ~ R. y o manwa" not p r Se,(1 1, 01;1 rfl1>w "iapp nt v doe I not i'i1v U! co tr,;,1; or I n rlg11 ng ola~11nwv rncl on ;inlr; roof. xl rlor coa~m11, n ble m ,h , 11 r ~1chH rln ,11 oflll CV le T h: -ad ll mu wy I lm1I Dal : l l ; r /I I 022 11 / l ih.ffl.2 P-OU,"UI Mwi.lilll , 0 730 111) ,.. <ltl- q~J D-22 nd/or r- D-23 AddiUlorml Com,ment-1 : I Overalll Tank Grade~ C nk ci t! 1 nat me1f -om , a, m01.1 ,n sul1 i.1rv code~, rnl ll , riC!I I r br- mlsh' fc,und nd n d ;numUon, !'0 DOM lli Mus;\, 11 , 0 'i:l 1105- 590 3449 D-24 Tow r 1lmp ctlon R-por lf11"C p dt : 76,000 Gc:111fan1 T n Typ : tandp lp T r k D111,en.$ ons 12' Ii !lO '(e- r u II: 2003 P !10.111131 Mustang, OK 7 064 405-5- - 449 D-25 ,,-,,,... l,, SUF::J . l::: F=l rV' I ' l \ N F, l.:J'.aIID1 R(l'' ,..,,;,., Gaod = N o Need R p i,11:e .EXTER.IOR: P~tr nr ondlel'on 1 Is1ui svt ur!-'d/ r""c" t'4 1l NIA , lorn mag~ v.-~ Gl!md 3 If o1md/IU i:>"' 'fi!5 Good " lease Cml~l"ll s ~1 l"Jh Pl,,d 6. ltmrha r I.\LllU '1' 1'5 ll::id V~s Grui d Vcu F~lr 7 0 ,.,111 ,or Dr~ ln PILII 8.IM;ll n11,111;v ll l 9i, f!,,fanw.i:11 ii!!' .2 I 10, Ove rnew 11 . ,L11nd.;r -u .f~.,fetv Climb 13, ls11.1: U 14, l!Qof ,,.15, lh.1of H.atch IReial Van, !.i' ,ri-lety H,md111 II 111. r,eOff r :olr1t l ! J ~ rUIIII! 20. Ovt r, t:cr1or P:alru u .lla110 2, , V:i l\.trt Vault Ve:,, Fi!lr V1u (i c,od 'I'~~ I GoCJd 'l'ias Goad Vet Go0d No NIA Ve 1 f 1ir Ve1 fal, '1'11 1 Good Yes Gol'ld Na, N7A Yc1 Goo~ No, N/11, I 'i'el Fair I Va1 flilr VH Good' Feit Field CUhu far Fleld - For i:iold f:or F11rlcl For Ftitld OH1l!lr 0 1.h or ,othcr Ot hi1,r :B d'- -complete Fa,hi re N'otf n m ~ 1lt11 ne ed:s ~f!cu.rltv fcnte lat ,k sl!e ij pp~ars to,drain ro.,e,lv Fe und~ Tlori 11p1:1 ear,;, illli ,11oodl co ntlltl i:m IN'e,ad r rm1pplmrJ Sn!,uh rJi d plirrorm5i,it1mded 'function Anch!lr bolu/dl air 1~111ve ru, r i,tesiml Orrun W/ plui;: 11resent M1111'1W!IV arid/or bti!tJ ""'"ure ii rid In il:OCld tol'!dUori M;i,nw11y 11nd/a r bolt, ,m ~u,r,e i! i'i tl in ,Rood tol'ldlti 0n Fla1rH1e,r ..,o1,lve w/ muh .~u een ct,,."-"rit li!dc!'1uhl ,11~.1u1.:i r in .11aad torid,,Uon 511,fot" c:l1mb llat 11rH!ft;r11' M l,nor n.t~t pre1M't on 1'hell,,.,,.rJ/or wr ld ...11,r,u Mine, ru1~ o,..u ent a111 r1:1cd i! ndl/c:ir w~ld Je<1ms T1mk h,1tch In,l!.ood ,UI ncfltrcm THi k v,cnt 11nd meis l'I scra-u 1.1n ilillld co nd1~lon Tl!! 0tr' CIDlnl 11'1 1100d cMdltJ1111 Min or NJll ,0rl!i.11ni Lo~o,slh 0 w 1 1l11:n1,at fil d i r:1111, n sit 1 cu r 'IV f - - w/ a v.-r,iill condl 10 t ri0 t pr ~ rit , 11 !:!' lilli'inl I ,i!fe: O:iitu: 11/16/20;? 2 11/ 16/2022: D-26 INTERIOR: Pn ,,u 1, 'Rool P,attl Ym ' Roof Rafter,: No 3, Vt!'l'\1, Yts 4, HaHll 'l'e.s s. o~crftowl\Vclr 'iH ,5, l!ihell Ves 7 ,niet Ploln11. Ye.$ II, Outlt!'t Plpm11 Yes 9, Manw;avU 't'ot! $ 1Cl. M~nw~ll2 'l'u U , Cathodic Prolectlon No 12, le\lel indlc_,nor '- No l3 Floor Yes 14 , Si!d:lrnel'lil v~s 15.li'lt~ri0f tacltler ND 16. Mlxin11 S.ystem Yes 17 . Aeration .system No 11!- oraln Yes, 19. OveraUInterio r Palnt - '(es ' 20. Wo!iter Visi blntv ! Yes. For f'leld Oth~1 'Faor-Fleld Other For Field o,iticr 1Fil r Fiel d other for fi eld ott\er 1Fo., ~leld Qt-her Fa,r Ffl!lld IOtlm Com1111 11/N t 1: I, _, - <:011'lllrlo.r1 F11lr N/ 11. fair ~air I G1md Fair F;i lt Flilt F;,lr F1lr N/!,. N/A N/A ' Fair N/A Fair N/ A F.-lr Bad Good I I I d" om "'I t j urt- Nor Mcul rratl! nnt ~mJ/or dt!lam1n~ t,on aru,n l Minar ru;t 1irimm1 on v~nt l!r)dkr w-=-ei d cm1m, MIn., r ru~ t l)rtlsan~ on h~,ch 1md/ot Wil!ld \l!am~ Ov~rfli:,w/Wcr bo~ iri Roorl condltlori 5e,v11r-1i nu t i,rl!senc or) Jhall 1nd/0f walrl ieam~ Moi:1 erat:e rucQl/ic:1111 1c re ;11i,l Modar11t1 run .areuml Mfnor n,it ,ilnd/or d,a l1minatlon Mi nor nu,t and/or ,d,e f1mlnat1an Catht:uf,c arotectton !'lot oruenc L,evel lndlc~tor not iitese."t U11a:ble to in5pl!ct tant.: floor di.I!! to sedo-nen t Modc1,1,te ~ec:l'irn efl'I pre~erit La dder{5} and s;,fl!t',' d lmb l')ot pre.sent -Mbci~I! sys.tern !)re:1::ent arid oi:il!rabf!!' Alintion $ystem riot prl!s_en:t ora,ln w/ prll\g present SevEmi rust anfJ/ot delamiria'l1on pre'!;ent Clea,r Mad r , Q,;, 1'111 on rl tlon or n lnnl r Ii FA:IA/BAO adlm nl pr - ta t r k 'II or, Int rlor roor, w I o, nd p ur n n mod t I tu t. iid . I In tlo ' how lsn 0 .U/1' /2022 11/1 /l.022 PO BeiK 4 1 M11!.I rg, 0 710 405-5 O-l449 D-27 !ii,y ,,., 1. 1, J, l / P'lecpn ITI!' dlat1rin : T,1mk lhtil!rlor lnr.ti!II ~~,;:unt,; rerice w/ gattl 11,, ~tallll,1dd-er Sa,rptuC!lmb1 !.11u1m 4. Ari~1v b~se 1:.111l litng s. Pc:iweir w,nh t;i nk c:i:~erlor ai,cl mue~s 6. 7 8. Tank lntl!"riior 9, A~m,ov~ m.edlment from t,rnk P10ur 10 . l!l;ut ind --ec:0.1t T,m!k lnti:rlor 11, 12 - 13 l-'1, ,15 16, l ?, 18 . 19 20, I Overall Tan k Grade: C , nlk does 11ot m ome 0, r os.t t cgY latotv codes. m,no, ., . cl , Jor b'll!n'li ~hi s ro~r1ti 1md nl!t!Cis tt t 01'1 . R,egards, p (] 4.31 M u t;ir1g, 0 7 06 405590- M'!:11 D-28