Document DvG4aQBdy2E9OOJRYqKmBKXxO
Region 6 Compliance Assurance and Enforcement Division sMS4 PRE-ASSESSMENT REPORT
Inspection Date(s):
June 14, 2018
Media:
Water
Regulatory Pro~ram(s):
Clean Water Act
Company Name:
City of Waxahachie
Facility Name:
City of Waxahachie
Facility Physical Location:
401 S. Rogers
City, State, Zip Code:
Waxahachie, TX 75 165
Mailing Address:
Same as above
City, State, Zip Code:
Same as above
County/Parish:
Ellis
Facility Contact:
James Gae1tner, City Engineer, Phone: (469) 309-4293
j gaertner~waxahachie. com
FRS Number:
N/A
Identification/Permit Number: TXR040474
Media Number:
N/A
NAICS:
237 110-Water and Sewer Line and Related Structures Construction
SIC:
1623-Water, Sewer, Pipeline Communications and Power Line
Construction
EPA and or State Personnel Par ticipating in Pre-Assessment
Name
Office/Mail Code
Title
Phone
Thea Lomax
EPA (6EN-WS)
Lead Technical/Enforcement (2 14) 665-8098
Officer
Linda Smith
EPA (6EN-WS)
Enforcement Officer
(214) 665-6641
James Gaettner
City of Waxahachie City Engineer
(469) 309-4293
Jeff Chambers
City of Waxahachie Director ofPublic Works
(972) 309-4301
David Bail~~
City of Waxahachie Director of Utilities
(469) 309-4321
Tommy Ludwig
City of Waxahachie Executive Director of
(469) 309-4021
Developmental Services
Ryan Studdard
City of Waxahachie Director ofBuilding and
(469) 309-4038
Community Services
Macey Beazley
City of Waxahachie Engineering Technician
(806) 470-8602
Stephen Brigman
City of Waxahachie Environmental Program
(214) 399-8660
Manager
(469) 309-4347
Sam Robinson Pre-Assessment Lead Signature/Date
Supervisor Signature/Date
City of Waxahachie Chief, Public Works Inspector
/ _ / Thea Lomax
stgnature: 0//L~ ~~
Lr Robert Ho~
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Signature:
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(469) 309-4303 (214) 665-8098
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Date P7~'~ f'
o?/a~jzo;g
Date
6ENFORM-019-R7 (2/15/ 2017 )
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Waxahachie, City of(Public Works Yard and Sports Complex Yard) Pre-Assessment Date: June 14,2018
Section I- INTRODUCTION
PURPOSE OF THE PRE-ASSESSMENT
Environmental Protection Agency (EPA) Region 6 inspectors Thea Lomax-Lead Inspector and Linda Smith atTived at the City of Waxahachie (City) City Hall, 401 S. Rogers, Waxahachie, Texas, 75165 at 9:00am on June 14,2018, for an announced Pre-Assessment. The inspectors met with James Gaertner, City Engineer; Jeff Chambers, Director of Public Works; David Bailey, Director of Utilities; Tommy Ludwig, Executive Director of Developmental Services; Ryan Studdard, Director of Building and Community Services; Macey Beazley, Engineering Technician; Stephen Brigman, Environmental Program Manager; and Sam Robinson, Chief, Public Works Inspector. There were no attendees from the Texas Depatiment of Environmental Quality (TCEQ) present.
Representatives of the City were informed that this was an EPA Pre-Assessment to determine compliance with the Texas Pollutant Discharge Elimination System (TPDES) Small Municipal Separate Storm Sewer System (sMS4) Phase II Permit and the Clean Water Act. The City's stmm water discharges are regulated under the TCEQ sMS4 Permit TXR040000, in which they are authorized by Permit Number TPDES Pe1mit Number TXR040474 to discharge stmm water to their MS4 in compliance with the permit. The City has been permitted under this MS4 Permit almost 5 years (Effective December 1, 2014; Expiration Date: December 13, 2018).
The Pre-Assessment was conducted under the authority of the National Pollutant Discharge Elimination System (NPDES) permit program, in accordance with the Federal Clean Water Act. The year evaluated is from June 2017 to June 2018. The City is responsible for compliance with pe1mit conditions relating to discharges from pmiions of the MS4 for which it is the operator, and, development and implementation of a Storm Water Management Program (SWMP). The SWMP should describe a systematic, goal-oriented approach to implement these required six Minimum Control Measnres: 1) Public Education, Involvement and Outreach; 2) Illicit Discharge Detection and Elimination; 3) Construction Site Runoff Control; 4) Post-Construction Stmm Water Management in New Development and Re-Development Projects; 5) Pollution Prevention and Good Housekeeping for Municipal Operations; and, 6) Industrial Stmm Water Sonrces.
FACILITY DESCRIPTION
The City is a Phase II MS4, population 34, 345 (2016 Bnreau of the Census), located in Ellis County, that discharges to its MS4 and thence to the South Prong Creek and Waxahachie Creek. The classified water bodies that ultimately receive the discharge fiom the City are Lake Bardwell and Lake Waxahachie, which are surface waters of the United States.
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Waxahachie, City of(Public Works Yard and Spmis Complex Yard) Pre-Assessment Date: June 14, 2018
The City's Stotm Water contact person is Mr. James Gaertner, City Engineer who directs the implementation of a SWMP and checks the program for compliance with the pennit in reducing pollutants in storm water discharges to the Maximum Extent Practicable. Several City Depatiments have a significant responsibility in carrying out the SWMP which are Public Works/Utilities; Planning and Zoning Commission; Parks and Recreation; Keep Waxahachie Beautiful; and the GIS and Mapping Services.
The City does not operate a landfill. Contractors are hired to dispose waste associated with residential areas and street cleaning. The City has mapped 80% of its outfalls and expects to complete mapping the remaining 20% by December 2018. Currently 1,126 GPS points for stmm inlets have been mapped.
Section II- OBSERVATIONS
1. The City showed a power point presentation, highlighting its implementation of all six SWMP Minimum Control Measures. Following the presentation EPA Inspectors reviewed the City's SWMP and found that the Minimum Control Measures inconsistently included quantifiable results.
2. The City has developed and implemented a Public Education and Outreach program that targets all ages for storm water educational programs and events to participate in reducing pollutants in stmm water discharges. The outreach programs that have proven to be effective in reducing pollutants in stmm water are the: Fats Oil and Grease program, Keep Waxahachie Beautiful, Pet Waste Management, Recycling Program, and the Youth Educational Progratn. Residents and children are encouraged to take part in each event through public announcements, posters, school visits, tours, door tags, mail insetis and other methods of communication. The City has collected over 10,000 pounds of household hazardous waste this repmiing period.
3. The City has obtained the necessary ordinances for authorization to enforce the Minimum Control Measures as applicable.
4. The City makes available to residents an app called "My Waxahachie" convenient for repotiing environmental problems that need to be addressed.
5. The City requires all contractors to submit a copy of their storm water prevention plan, Notice of Intent and attend a meeting about storm water compliance prior to getting petmitted by them, to construct a project. The City inventoried 28 active construction projects this repmiing period of which, only 6 construction sites remain active. The City however, has not required contractors to show a Notice ofTetmination at the completion of a project.
6. The TCEQ permit categorizes the City a Level 2 permittee. Level 2 permittees are not required to identify industrial facilities and control pollutants in stmm water discharges from
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