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Tri-County SUD Inspection Date 05/20/2025 Inspection Date(s): Media Program: Regulatory Program(s) 05/20/25 Water Safe Drinking Water Act (SDWA) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Tri-County Special Utility District - Public Water System Tri-County Special Utility District 5212 TX-7 Marlin, TX 76661 P.O. Box 976 Marlin, TX 76661 Falls County (254) 803-3553 Melissa Lloyd Tri-County SUD Office Manager tricountysud@ctwa.com FRS Number: System Classification: PWS ID: 110013278069 Community Water System (CWS) TX0730004 Personnel participating in inspection: Janet Cherry Eastern Research Group, Inc. (ERG)/ janet.cherry@erg.com Maura Harbaugh ERG/ maura.harbaugh@erg.com Melissa Lloyd Tri-County SUD/ tricountysud@ctwa.com Tim O'Neil Tri-County SUD/ trstc@msn.com Chris Trainer Elizabeth Luke Daniel Kim Fatima Shaikh Ruben Alayon-Gonzalez Chelo Hall Craig Young Tri-County SUD/ tri.countysud@gmail.com TCEQ/ elizabeth.luke@tceq.texas.gov EPA R6/ Kim.Daniel@epa.gov EPA R6/ Shaikh.Fatima@epa.gov EPA R6/ Alayon.Gonzalez@epa.gov EPA R6/ Hall.Chelo@epa.gov EPA R6/ Young.Craig@epa.gov Lead Inspector Support Inspector Office Manager President Board of Directors Operator and Outside Manager Compliance Officer EPA Inspector EPA Inspector EPA Inspector EPA Inspector EPA Inspector EPA Lead Inspector Signature/Date 6/27/2025 Supervisor Signature/Date Janet Cherry Date MARIELA REYNA Date: 2025.07.18 09:59:27 -05'00' Digitally signed by MARIELA REYNA On behalf of Ruben Alayon-Gonzalez Date 1 Tri-County SUD / Water Utility Inspection Date 05/20/2025 2 Tri-County SUD / Water Utility Inspection Date 05/20/2025 Section I - INTRODUCTION PURPOSE OF THE INSPECTION On May 20, 2025, at 0900, the EPA Inspection Team, consisting of Eastern Research Group, Inc. (ERG) contract inspectors Janet Cherry and Maura Harbaugh, EPA Region 6 inspectors Daniel Kim, Fatima Shaikh, Ruben Alayon-Gonzalez, Chelo Hall, and Craig Young, and Elizabeth Luke from the Texas Commission on Environmental Quality (TCEQ), arrived for an announced inspection at the Tri-County Special Utility District (System). The EPA Inspection Team met with Melissa Lloyd, Tim O'Neil, and Chris Trainer from the System at the opening conference at 5212 TX-7, Marlin, TX 76661. Refer to Appendix 1, Opening and Closing Conference Sign-in Sheet for a list of attendees. Janet Cherry, lead inspector, presented credentials to the System and informed them that this was an EPA inspection to determine the facility's compliance with the SDWA with a focus on the System's compliance status with the arsenic maximum contaminant level (MCL) of 0.010 milligrams per liter (mg/L). The EPA inspection team also informed the System representative that they would be conducting a cybersecurity evaluation alongside the SDWA Section 1433 review of the System's Risk and Resilience Assessment (RRA) and Emergency Response Plan (ERP). To facilitate the inspection process, the EPA inspection team used a checklist outlining the requirements of SDWA Section 1433 during the document review. SYSTEM DESCRIPTION The System is a Special Utility District (SUD), a type of local government entity in Texas established to provide water and other utility services within a designated geographic area. It operates independently of city or county governments and is governed by a board of five elected directors. The System generates revenue through a combination of fixed fees and usage-based charges for its residential and agricultural customers. These funds support daily operations, maintenance, infrastructure improvements, and long-term capital projects. The utility serves approximately 5,353 people through 1,807 service connections. According to representatives, average water demand ranges from 20 to 25 million gallons (MG) per month, with peak demand reaching 30 MG per month during the summer months. Currently, the system has reached its service capacity and is unable to sell additional meters. To address future demand, the utility has explored the option of constructing an interconnection with a nearby surface water system. This potential project could provide additional capacity to support approximately 600 to 700 new service connections. Certified operators staff the utility from 0800 to 1700 on weekdays, with on-call coverage during weekends. The water system staff includes two Class C groundwater operators and one maintenance 3 Tri-County SUD / Water Utility Inspection Date 05/20/2025 technician plus two office staff. In addition, a contractor is available on call to handle main breaks, part replacements, and other operations and maintenance tasks. The System is composed of two independent sections: Northern section: Wells 1, 4, 5, and 6. These wells pull water from the 2nd Trinity Aquifer at a depth of over 3,700 feet where raw water temperatures range from 147F to 153F. These wells exceed the arsenic MCL. Southern section: Wells 3R, 4R, and 7. These wells pull water from the Carrizo-Wilcox Aquifer recharge zone at a depth of 550 feet where raw water temperatures range from approximately 80F to 110F. These wells are low in arsenic and do not require treatment for arsenic removal. These areas are not interconnected and function separately. Spanning approximately 315 miles of pipeline and 13 treatment plants across four counties, the utility is supplied by these seven active water wells. The distribution network consists of nine pressure planes and includes bypass capabilities for all treatment plants, allowing minimum system pressure of 35 psi to be sustained even during treatment plant outages. Table 1 provides a summary of plants with wells serving Tri-County SUD. Tri-County SUD has other plants with storage tanks and booster pumps to serve the distribution system, but these facilities were not inspected. More details on arsenic treatment efforts are below. Plant Number 1 6 10 11 13 Table 1: Plants with Wells Serving Tri-County SUD Wells at Plant Flow per Well, gallons Treatment per minute (gpm) Well No. 1 278 Polyphosphate, cooling tower and gas chlorine. Well No. 4 320 Polyphosphate, cooling tower, gas chlorine, and arsenic treatment with ferric chloride and filtration. Water from Plant 13 also treated at Plant 6 for arsenic removal. Well No. 3R 258 Polyphosphate and gas chlorine. Well No. 4R 250 Well No. 7 Unknown Well No. 5 330 Polyphosphate, cooling tower and gas chlorine. Well No. 6 250 Polyphosphate, cooling tower and gas chlorine. Treated water is pumped to Plant 6 for arsenic removal treatment. Tri-County currently has one active interconnection with another public water system, City of Riesel (TX1550040), that City of Riesel can use in an emergency; the interconnection does not allow City of Riesel to serve Tri-County SUD. Recent infrastructure improvements include the installation of six diesel 4 Tri-County SUD / Water Utility Inspection Date 05/20/2025 emergency generators at Plants 3, 5, 8, and 10, as well as at Well 7R and the administrative office. Two mobile diesel emergency generators are also available to provide backup power where needed. Arsenic Treatment and Compliance Efforts The Northern Section wells have elevated arsenic levels, and the System has a number of arsenic MCL violations (Refer to Appendix 2, Tri-County SUD Violations). A review of documents indicated raw water quality data from Well 4 as: Arsenic: 0.014 mg/L Iron: 0.1 mg/L A review of documents indicated raw water quality data from Well 6 as: Arsenic: 0.023 mg/L Iron: 0.4 mg/L Elevated arsenic levels and warm water temperatures along with high iron concentrations in the Northern Wells have historically presented treatment challenges for the System. Plant 6 is the only arsenic treatment facility the System owns and operates; however other wells appear to exceed the arsenic MCL. The System has other wells where treatment includes polyphosphate, to address high iron, and chlorination. Site visits during this inspection were limited to Plants 6 and 11 given the arsenic MCL focus for the inspection. The System pilot tested iron and arsenic treatment for Wells 4 and 6. The pilot studies proved successful, and in 2014, the System received approval to implement a full-scale arsenic treatment system for Well 4 (Plant 6) (Refer to Appendix 3, Photograph 1). Polyphosphate is injected into the raw water to sequester high iron in the water and then flows through a cooling tower where gaseous chlorine is injected for disinfection. The cooling tower provides a 20F to 30F temperature reduction. Plant 6 also receives supplemental water from Plant 13 (not visited during the inspection), which draws from Well No. 6 pumping at 250 gpm. Plant 13 injects polyphosphate into the raw water and then routes water through a cooling tower where gaseous chlorine is injected into the basin before the water is transferred to Plant 6 for arsenic treatment. At Plant 6, the cooled and disinfected water from Wells 4 and 6 is pumped to a 60,000-gallon ground storage tank, then it is directed into the arsenic removal system. Ferric chloride is dosed ahead of filtration to aid coagulation. The water then passes through three IRS-84 filters in parallel containing Omni-SORB media designed for catalytic removal of both iron and arsenic. Following filtration, treated water is stored in an 80,000-gallon ground storage tank. From there, it could be distributed via two high- 5 Tri-County SUD / Water Utility Inspection Date 05/20/2025 service pumps to a 200,000-gallon elevated tank. The water sent to distribution from Plant 6 then blends with all the water in the Northern section of the System. A pressure tank sitting on the distribution line ensures stable pressure levels. The System uses a tank to capture filter backwash water, which is then returned to the treatment process. The sludge generated during treatment is treated with a solid's separator. The full-scale treatment process is unable to consistently reduce arsenic below the MCL. The System worked with consultants on treatment solutions and revising the treatment process, but has been unsuccessful with reducing arsenic concentrations below the MCL. As of 2023, the Plant 6 arsenic treatment system has been offline. The System is working on a blending option to address the arsenic MCL violations. Section II - INSPECTION ACTIVITY SUMMARY Opening Conference The EPA Inspection Team met with the System at the opening conference at the System's office, 5212 TX-7, Marlin, TX 76661, at 0900 on May 20, 2025. The EPA Inspection Team began by requesting a general overview of the System and discussing its overall operations, including the cybersecurity policies and procedures in place. The EPA Inspection Team proceeded to review the documentation provided by the System. Records Review All System documents requested by the EPA Inspection Team were readily available upon arrival. The following documents were reviewed on site during the opening conference: Tri-County Special Utility District Arsenic Treatment Project Update Tri-County Special Utility District - PWS ID No. 0730004 Arsenic and Iron Removal Pilot Study Report and Exception Request Omni-SORB As/Fe Removal - Pilot Test Report Tri-County Special Utility District Administrative Order Docket Number: SDWA-06-2011-1372 PWS ID Number: TX 0730004 Filtration Inspection Report Tri-County SUD Pilot Study Report Well #4 Plant #6 and Well #6 Plant #13 Tri-County SUD - Arsenic Removal System Plant No. 6 - Wells No. 4 & 6 - Daily Monitoring Form Texas Commission on Environmental Quality Lead/Copper Sample Site Pool Selection Form Water Sources Sources Treated for Arsenic Hydrant Flushing Records Revised Total Coliform Rule Site Sample Plan 6 Tri-County SUD / Water Utility Inspection Date 05/20/2025 Lead and Copper Site Sample Plan Disinfection Byproducts Site Sample Plan Storage Tank Inspection Reports Risk and Resilience Assessment Emergency Response Plan The System representatives stated they completed the lead service line inventory and submitted all information to TCEQ. The review of storage tank inspection reports revealed the tanks are professionally inspected annually and the System is currently rehabilitating a number of storage tanks. The System is negotiating an interconnection with a nearby water system and will use the additional water to blend with the System's wells high in arsenic. The additional water will also allow the System to add more connections. The System is currently planning the additional pipe, storage tanks, and pump stations for the interconnection. Field Activities Plant 6 At approximately 1340 local time, the EPA Inspection Team arrived at Plant 6. The entire site was fenced with a locked gate and properly signed. System personnel provided a comprehensive walkthrough, covering the former arsenic treatment process, the current treatment system, and the operational status of both active and offline assets. The inspection began at the Well No. 4 wellhead, where the team observed a gap around the electrical conduit entering the well casing that supplies power to the submersible turbine pump. The team then proceeded to the chemical storage and mixing room, which also housed the high service pumps responsible for moving water from the ground storage tanks to the elevated tower and into the distribution system. Within the chemical room, no secondary containment was present beneath the polyphosphate injection barrel, and the polyphosphate dry barrel lacked an NSF-60 certification label. Additionally, System staff reported that the room's door is routinely propped open during summer months to prevent overheating the equipment. The EPA Inspection Team then entered the gas chlorine room, where they observed that the door was not equipped with a crash bar and that there were no windows, gas sensors, or alarm systems present. Ventilation in the room was controlled by a manual switch, with no automatic activation or safety interlocks. Following the chlorine room, the team visited the cooling tower and noted that chlorine was injected at its base. The team inspected the three storage tanks at Plant 6. The 100,000-gallon ground storage tank exhibited vegetation growth around its foundation, and the ladder cage lacked a lock. 7 Tri-County SUD / Water Utility Inspection Date 05/20/2025 The three IRS-84 filters were observed as well as the backwash tank utilized when arsenic treatment was occurring. All arsenic related assets are offline and the System plans to remove all arsenic treatment equipment. Plant 11 At approximately 1435, the EPA Inspection Team visited Plant 11. The entire site is fenced with a locked gate and is signed. The inspection began at the Well No. 5 wellhead, where the team observed an opening around the purge line and another where the vent was intended to be installed. System personnel explained that the well pump had been recently replaced and that the observed issues were in the process of being addressed. The team then proceeded to the chemical room. As with Plant 6, the polyphosphate dry barrel lacked an NSF-60 certification label. System staff also noted that the door to the chemical room is routinely propped open during the summer months to prevent equipment from overheating. Next, the team inspected the gas chlorine room, where they found that the door lacked a crash bar and the room was not equipped with windows, gas sensors, or alarm systems. Ventilation was manually controlled, with no automated safety mechanisms or interlocks in place. Afterward, the team visited the cooling tower and observed that chlorine was injected at its base. The inspection activities concluded with a review of the Plant's ground storage tank and standpipe. Closing Conference The EPA Inspection Team conducted a closing conference at the System's office, 5212 TX-7, Marlin, TX 76661, at 1530 on May 20, 2025. During the closing conference, the EPA Inspection Team reviewed the observations noted during the inspection and stated that the observation list was not exhaustive, as other observations could follow from additional document and/or photograph review. The EPA Inspection Team left the System at 1630 local time on May 20, 2025. Section III - OBSERVATIONS SDWA Section 1433(a), states: SDWA Section 1433(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; 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. 8 Tri-County SUD / Water Utility Inspection Date 05/20/2025 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. Observation 1. On May 20, 2025, EPA completed an inspection of the System 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: The document was available at the time of the inspection. The RRA was dated to show that it was completed before the date of the certification of completion. The RRA does not address all required elements of 1433(a)(1)(A). It is missing a required element of SDWA Section 1433(a)(1)(A)(v) "the use, storage, or handling of various chemicals by the system." The RRA did not include a complete assessment of Section 1433 (a)(1)(A)(i) "an assessment of the risk to the system from malevolent acts and natural hazards" and SDWA Section 1433 (a)(1)(A)(iv) "the financial infrastructure of the system." 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 ofa 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. Observation 2. During the inspection, EPA inspectors also reviewed the Respondent's ERP and observed the following: The document was available at the time of the inspection. The ERP was dated to show that it was completed before the date of the certification of completion. The ERP included all required elements of Section 1433(b). The ERP contained incomplete sections covering the requirements in SDWA Section 1433 (b)(1) "strategies and resources to improve the resilience of the system, including the physical security and cybersecurity of the system," SDWA Section 1433 9 Tri-County SUD / Water Utility Inspection Date 05/20/2025 (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 community water system to deliver safe drinking water," and 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." Recommended Standards for Water Works (Ten States Standards), 2022 Edition, 5.8 (d) states: "Chlorine gas feed and storage rooms shall be enclosed and separated from other operating areas. Both the feed and storage rooms shall be designed and constructed to comply with the following requirements: 1. A shatter resistant inspection window shall be installed in an interior wall. 2. All openings between the rooms and the remainder of the building shall be sealed. 3. Doors shall open outward only to the building exterior and be equipped with panic hardware. 4. A ventilation system with a capacity large enough to provide one air change per minute when the room is occupied shall be provided. Where this is not appropriate due to the size of the room, a lesser ventilation rate may be considered. 5. The ventilation system suction shall be near the floor and as far as possible from the door and air inlet. The ventilation system's discharge shall be screened and above grade outside of the building away from air inlets to any rooms or structures and designated walkway areas. 6. Air inlets with corrosion resistant louvers shall be airtight and installed near the ceiling. 7. Separate switches for the ventilation system and for the lights shall be located outside and at the inspection window. Outside switches must be protected from vandalism. A signal light indicating ventilation system operation shall be provided at each entrance when the system can be controlled from more than one point. 8. Floor drains are discouraged. Where provided, the floor drains must discharge to the outside of the building and not be directly connected to other internal or external drainage systems. 9. Provisions must be made to chemically neutralize or contain chlorine gas in the event of any measured chlorine release (or other acceptable measures as approved by the reviewing authority) 10 Tri-County SUD / Water Utility Inspection Date 05/20/2025 where feed and/or storage is located near residential or developed areas. The chemical neutralizing equipment must be sized to treat the entire contents of the largest storage container in service. 10. Automatic shut-off devices on in-service chlorine cylinders should be installed when impacts of a chlorine leak to the surrounding area are possible. These devices quickly and effectively stop the flow of gas through the feed line by closing the container valve. These devices may be operated remotely, by the use of pressure-sensing switches, and/or chlorine gas detection systems. Installation of an automatic shut-off device should not significantly impede or inhibit manual closing of the container valve or require the use of any tools other than the standard gas cylinder wrench." Observation 3. Observation 4. The EPA Inspection Team observed the chlorine gas room door lacked panic hardware at Plant 6 (Refer to Appendix 3, Photograph 2) and Plant 11 (Refer to Appendix 3, Photograph 3). The EPA Inspection Team observed the chlorine gas room lacked a viewing window at Plant 6 (Refer to Appendix 3, Photograph 2) and Plant 11 (Refer to Appendix 3, Photograph 3). Recommended Standards for Water Works (Ten States Standards), 2022 Edition, Section 5.7.3 states: "...When pressurized chlorine gas is present, continuous chlorine leak detection equipment is required and shall be equipped with an audible alarm and a warning light." Observation 5. The EPA Inspection Team observed the chlorine gas room lacked gas detectors and alarms at Plant 6 (Refer to Appendix 3, Photograph 4) and Plant 11 (Refer to Appendix 3, Photograph 3). 30 Tex. Admin. Code 290.42(j) - Water Treatment, states: "Treatment chemicals and media. All chemicals and any additional or replacement process media used in treatment of water supplied by public water systems must conform to ANSI/NSF Standard 60 for Drinking Water Treatment Chemicals and ANSI/NSF Standard 61 for Drinking Water System Components. Conformance with these standards must be obtained by certification of the product by an organization accredited by ANSI." Observation 6. Plant 6 (Refer to Appendix 1, Photograph 5) and Plant 11 polyphosphate chemical barrel did not have an NSF-60 certification label. The Safety Data Sheet stated that the product could be used for food processing and several industries including water treatment (Refer to Appendix 3, Photograph 6). 30 Tex. Admin. Code 290.42(f)(1)(E)(ii) - Water Treatment, states: "Except as provided in this clause, adequate containment facilities shall be provided for all liquid chemical storage tanks." 11 Tri-County SUD / Water Utility Inspection Date 05/20/2025 Observation 7. The Plant 6 polyphosphate chemical feed barrel did not have secondary containment (Refer to Appendix 3, Photograph 7). 30 Tex. Admin. Code 290.46(m) - Minimum Acceptable Operating Practices for Public Drinking Water Systems, states: "Maintenance and housekeeping. The maintenance and housekeeping practices used by a public water system shall ensure the good working condition and general appearance of the system's facilities and equipment. The grounds and facilities shall be maintained in a manner so as to minimize the possibility of the harboring of rodents, insects, and other disease vectors, and in such a way as to prevent other conditions that might cause the contamination of the water." Observation 8. Observation 9. At Plant 6, vegetation was observed growing around the foundation of the 100,000-gallon ground storage tank and up the ladder (Refer to Appendix 3, Photograph 8). At Plant 6 and Plant 11, the building for both the polyphosphate dry and mixing barrels, as well as the booster pumps, was stated and observed to have its door propped open during the summer. Wasps were present inside the building, and the open door left the interior and its equipment exposed to outdoor elements, posing potential risks to both equipment integrity and operational safety. 30 Tex. Admin. Code 290.41(c)(3)(K) - Water Sources, states: "Wellheads and pump bases shall be sealed by a gasket or sealing compound and properly vented to prevent the possibility of contaminating the well water. A well casing vent shall be provided with an opening that is covered with 16-mesh or finer corrosion-resistant screen, facing downward, elevated and located so as to minimize the drawing of contaminants into the well. Wellheads and well vents shall be at least two feet above the highest known watermark or 100-year flood elevation, if available, or adequately protected from possible flood damage by levees." Observation 10. Observation 11. Observation 12. The EPA Inspection Team observed an unsealed opening in the wellhead for the submersible pump's electrical conduit at Plant 6, Well No. 4 (Refer to Appendix 3, Photograph 9). The vent on Well No. 4 also lacked a screen. The EPA Inspection Team observed an unsealed opening in the wellhead for the purge line at Plant 11, Well No. 5 (Refer to Appendix 3, Photograph 10). The EPA Inspection Team observed an opening in the wellhead where the vent was previously installed at Plant 11, Well No. 5. The wellhead lacked a screened vent (Refer to Appendix 3, Photograph 10). 12 Tri-County SUD / Water Utility Inspection Date 05/20/2025 Recommended Standards for Waterworks (Ten State Standards) (2022 Edition) 7.1.12.a, Safety, states: "Ladders, ladder guards, balcony railings, and safely located entrance hatches shall be provided. Access to roof hatches and vents shall be provided. When a fixed ladder is used, the bottom shall be located at least 12 feet above ground to prevent the entrance of unauthorized personnel." Observation 13. At Plant 6, the 100,000-gallon ground storage tank was equipped with a fixed ladder that extended to the ground and lacked a security barrier or lock (Refer to Appendix 3, Photograph 8). Section IV - FOLLOW UP A document titled 'NSF 60 Documentation for Tripolyphosphate' was provided to the EPA Inspection Team after the team had exited the System on May 20, 2025, as seen below. However, the information in the document does not correspond to the product observed on site. As a result, the EPA Inspection Team was unable to verify that the product used onsite is NSF-60 certified (Observation 6). The System also provided photos after the inspection to document actions taken to address observations and photos are presented below. In addition, the System provided an email and video to document actions taken to address ventilation at Plant 6 and Plant 11 chlorine gas room. The video demonstrates the ventilation turns on automatically when the door is opened. 13 Tri-County SUD / Water Utility Inspection Date 05/20/2025 Description: Documentation provided on chemical used at Plants 6 and 11 (Observation 6). 14 Tri-County SUD / Water Utility Inspection Date 05/20/2025 Description: Plant 6. Well No. 4 wellhead with conduit penetration sealed and vent screen installed (Observation 10). Photo received June 6, 2025. 15 Tri-County SUD / Water Utility Inspection Date 05/20/2025 Description: Plant 6. Vent with screen installed on Well No. 4 (Observation 10). Photo received June 6, 2025. 16 Tri-County SUD / Water Utility Inspection Date 05/20/2025 Description: Plant 11. Well No. 5 wellhead with screened vent and sealed opening for the purge line (Observations 11 and 12). Photo received June 20, 2025. 17 Tri-County SUD / Water Utility Inspection Date 05/20/2025 Description: Lock installed on Plant 11 chlorine gas room. Photo received June 20, 2025. 18 Tri-County SUD / Water Utility Inspection Date 05/20/2025 Description: Containment provided for polyphosphate feed barrel at Plant 6 (Observation 7). Photo received June 24, 2025. 19 Section V - LIST OF APPENDICES Appendix 1 - Opening and Closing Conference Sign-in Sheet Appendix 2 - Tri-County SUD Violations Appendix 3 - Photo Log Tri-County SUD / Water Utility Inspection Date 05/20/2025 20 Tri-County SUD / Water Utility Inspection Date 05/20/2025 Section VI - APPENDICES APPENDIX 1 - OPENING AND CLOSING CONFERENCE SIGN-IN SHEET 21 Tri-County SUD / Water Utility Inspection Date 05/20/2025 APPENDIX 2 - TRI-COUNTY SUD VIOLATIONS Table 2 indicates violations listed in Texas Drinking Water Watch (DWW). The last five years of violations have been included in this report. EP001 - Plant 1 EP002 - Plant 6 EP004 - Plant 11 Table 2. Tri-County SDWA Violations 2021-2025 (from TX DWW) Compliance Violation Name Facility ID Period Sample Result (mg/L) Running Annual Average (mg/L) Analyte Has the Has the Violation Violation been Addressed? been (On the Path to Resolved? Compliance) (Returned to Compliance) 01-01-2025- MCL, AVERAGE EP002 03-31-2025 0.0146 0.014 ARSENIC Yes - Informal No 01-01-2025- MCL, AVERAGE EP004 03-31-2025 0.0219 0.019 ARSENIC Yes - Informal No 01-01-2025- MCL, AVERAGE EP001 03-31-2025 0.021 0.021 ARSENIC Yes - Informal No 10-01-2024- MCL, AVERAGE EP002 12-31-2024 0.0134 0.014 ARSENIC Yes - Informal No 10-01-2024- MCL, AVERAGE EP004 12-31-2024 0.0198 0.020 ARSENIC Yes - Informal No 10-01-2024- MCL, AVERAGE EP001 12-31-2024 0.0234 0.020 ARSENIC Yes - Informal No FAILURE TO SUBMIT AN 03-01-2022- APPROVABLE N/A N/A N/A N/A OPEN EMERGENCY PREPAREDNESS PLAN Yes - Informal No 07-01-2024- MCL, AVERAGE EP004 09-30-2024 0.0197 0.019 ARSENIC Yes - Formal and No Informal 07-01-2024- MCL, AVERAGE EP002 09-30-2024 No Lab Result 0.014 ARSENIC Yes - Formal and No Informal 22 Tri-County SUD / Water Utility Inspection Date 05/20/2025 07-01-2024- MCL, AVERAGE EP001 09-30-2024 04-01-2024- MCL, AVERAGE EP004 06-30-2024 04-01-2024- MCL, AVERAGE EP002 06-30-2024 04-01-2024- MCL, AVERAGE EP001 06-30-2024 01-01-2024- MCL, AVERAGE EP002 03-31-2024 01-01-2024- MCL, AVERAGE EP004 03-31-2024 01-01-2024- MCL, AVERAGE EP001 03-31-2024 10-01-2023- MCL, AVERAGE EP002 12-31-2023 10-01-2023- MCL, AVERAGE EP001 12-31-2023 10-01-2023- MCL, AVERAGE EP004 12-31-2023 07-01-2023- MCL, AVERAGE EP004 09-30-2023 07-01-2023- MCL, AVERAGE EP001 09-30-2023 07-01-2023- MCL, AVERAGE EP002 09-30-2023 04-01-2023- MCL, AVERAGE EP002 06-30-2023 04-01-2023- MCL, AVERAGE EP004 06-30-2023 04-01-2023- MCL, AVERAGE EP001 06-30-2023 01-01-2023- MCL, AVERAGE EP002 03-31-2023 No Lab Result 0.0162 0.020 0.020 0.014 0.014 0.0217 0.021 0.0144 0.015 0.0231 0.021 0.0187 0.021 0.0141 0.015 0.0234 0.023 0.0172 0.020 0.0217 0.021 0.0216 0.022 0.0152 0.015 0.015 0.015 0.0219 0.021 0.0203 0.021 0.015 0.015 ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal 23 Tri-County SUD / Water Utility Inspection Date 05/20/2025 01-01-2023- MCL, AVERAGE EP001 03-31-2023 01-01-2023- MCL, AVERAGE EP004 03-31-2023 10-01-2022- MCL, AVERAGE EP002 12-31-2022 10-01-2022- MCL, AVERAGE EP004 12-31-2022 10-01-2022- MCL, AVERAGE EP001 12-31-2022 07-01-2022- MCL, AVERAGE EP001 09-30-2022 07-01-2022- MCL, AVERAGE EP004 09-30-2022 07-01-2022- MCL, AVERAGE EP002 09-30-2022 04-01-2022- MCL, AVERAGE EP001 06-30-2022 04-01-2022- MCL, AVERAGE EP002 06-30-2022 04-01-2022- MCL, AVERAGE EP004 06-30-2022 01-01-2022- MCL, AVERAGE EP004 03-31-2022 01-01-2022- MCL, AVERAGE EP001 03-31-2022 01-01-2022- MCL, AVERAGE EP002 03-31-2022 10-01-2021- MCL, AVERAGE EP004 12-31-2021 10-01-2021- MCL, AVERAGE EP002 12-31-2021 10-01-2021- MCL, AVERAGE EP001 12-31-2021 0.025 0.023 0.021 0.021 0.0135 0.015 0.0194 0.021 0.0194 0.022 0.0205 0.023 0.0216 0.022 0.0145 0.015 0.0261 0.023 0.0163 0.015 0.0229 0.021 0.0216 0.021 0.0229 0.022 0.0146 0.017 0.0212 0.020 0.0148 0.017 0.0212 0.022 ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal 24 Tri-County SUD / Water Utility Inspection Date 05/20/2025 07-01-2021- MCL, AVERAGE EP002 09-30-2021 07-01-2021- MCL, AVERAGE EP001 09-30-2021 07-01-2021- MCL, AVERAGE EP004 09-30-2021 04-01-2021- MCL, AVERAGE EP004 06-30-2021 04-01-2021- MCL, AVERAGE EP002 06-30-2021 04-01-2021- MCL, AVERAGE EP001 06-30-2021 01-01-2021- MCL, AVERAGE EP001 03-31-2021 01-01-2021- MCL, AVERAGE EP002 03-31-2021 01-01-2021- MCL, AVERAGE EP004 03-31-2021 10-01-2020- MCL, AVERAGE EP004 12-31-2020 10-01-2020- MCL, AVERAGE EP001 12-31-2020 10-01-2020- MCL, AVERAGE EP002 12-31-2020 07-01-2020- MCL, AVERAGE EP001 09-30-2020 07-01-2020- MCL, AVERAGE EP004 09-30-2020 07-01-2020- MCL, AVERAGE EP002 09-30-2020 04-01-2020- MCL, AVERAGE EP001 06-30-2020 04-01-2020- MCL, AVERAGE EP002 06-30-2020 0.0134 0.016 0.0214 0.022 0.0195 0.020 0.0221 0.021 0.025 0.017 0.0243 0.023 0.0219 0.021 0.0128 0.014 0.0188 0.021 0.0199 0.022 0.0221 0.021 0.014 0.015 0.0247 0.021 0.0219 0.022 0.0152 0.017 0.0145 0.022 0.0142 0.017 ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC ARSENIC Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal 25 Tri-County SUD / Water Utility Inspection Date 05/20/2025 04-01-2020- MCL, AVERAGE EP004 06-30-2020 01-01-2020- MCL, AVERAGE EP002 03-31-2020 01-01-2020- MCL, AVERAGE EP001 03-31-2020 01-01-2020- MCL, AVERAGE EP004 03-31-2020 0.0215 0.023 0.017 0.018 0.023 0.024 0.023 0.023 ARSENIC ARSENIC ARSENIC ARSENIC Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal Yes - Formal and No Informal 26 Tri-County SUD / Water Utility Inspection Date 05/20/2025 APPENDIX 3 - PHOTO LOG Unless otherwise indicated herein, all photographs were taken by Janet Cherry or Maura Harbaugh of ERG during the inspection. The displayed date and time are the local time (CST unless otherwise noted). Photographs were not manipulated beyond minor cropping for sizing and adding labels or callouts to draw attention to the subject of the photograph. Not all photographs taken during the inspection are included in the Photograph Log. 27 Tri-County SUD Inspection Date 05/20/2025 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Tri-County SUD Water System Tri-County SUD County: Falls State: Texas Backwash Tank Filters Photograph 1. 05/20/2025 01:57 P1010523.JPG Description: Filters containing media for arsenic removal and backwash tank. 28 Tri-County SUD / Water Utility Inspection Date 05/20/2025 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Tri-County SUD Water System Tri-County SUD County: Falls State: Texas Photograph 2. 05/20/2025 02:13 P1010534.JPG Description: Plant 6. Gas chlorine room with no crash bar or window. 29 Tri-County SUD / Water Utility Inspection Date 05/20/2025 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Tri-County SUD Water System Tri-County SUD County: Falls State: Texas Photograph 3. 05/20/2025 02:47 P1010543.JPG Description: Plant 11. Gas chlorine room with no crash bar, window, gas sensors, or alarms. 30 Tri-County SUD / Water Utility Inspection Date 05/20/2025 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Tri-County SUD Water System Tri-County SUD County: Falls State: Texas Photograph 4. 05/20/2025 02:13 P1010532.JPG Description: Plant 6. Chlorine room with no gas sensors or alarms. 31 Tri-County SUD / Water Utility Inspection Date 05/20/2025 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Tri-County SUD Water System Tri-County SUD County: Falls State: Texas Photograph 5. 05/20/2025 02:03 P1010524.JPG Description: Plant 6. Polyphosphate dry barrel lacks an NSF-60 label. This condition is also representative of what was observed at Plant 11. 32 Tri-County SUD / Water Utility Inspection Date 05/20/2025 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Tri-County SUD Water System Tri-County SUD County: Falls State: Texas Photograph 6. 05/20/2025 02:03 P1010524.JPG Description: Plant 11. Safety Data Sheet for polyphosphate dry barrel with no NSF-60 certification. 33 Tri-County SUD / Water Utility Inspection Date 05/20/2025 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Tri-County SUD Water System Tri-County SUD County: Falls State: Texas Photograph 7. 05/20/2025 02:03 P1010525.JPG Description: Plant 6. Polyphosphate chemical feed barrel without secondary containment. 34 Tri-County SUD / Water Utility Inspection Date 05/20/2025 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Tri-County SUD Water System Tri-County SUD County: Falls State: Texas Photograph 8. 05/20/2025 01:53 P1010521.JPG Description: Plant 6. Fixed ladder extending to the ground and lacking a lock on the 100,000-gallon ground storage tank. 35 Tri-County SUD / Water Utility Inspection Date 05/20/2025 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Tri-County SUD Water System Tri-County SUD County: Falls State: Texas Photograph 9. 05/20/2025 01:46 P1010519.JPG Description: Plant 6. Opening in the electrical conduit on the Well No. 4 wellhead. 36 Tri-County SUD / Water Utility Inspection Date 05/20/2025 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Tri-County SUD Water System Tri-County SUD County: Falls State: Texas Well vent opening Photograph 10. 05/20/2025 02:36 P1010538.JPG Description: Plant 11. Openings in the Well No. 5 wellhead around the purge line and lack of screen on the vent opening. 37