Document G8zyadRn35NJXZ5gNObaoY1x

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 06/04/2025 Water Clean Water Act Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: City of Cibolo, TX City of Cibolo, TX 108 Cibolo Dr. Cibolo, TX 78108 Same Bexar & Guadalupe Counties 210-619-0069 Chris Hubbard chubbard@cibolotx.gov Utilities Supervisor FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110071951747 TXU009131 NA 221320 4952 Personnel participating in inspection: Jeremy Trimm City of Cibolo Nicholas Guel City of Cibolo Chris Hubbard City of Cibolo Julio Gomez City of Cibolo Shannan Hall City of Cibolo Rachel Matthews Environmental Protection Agency Utilities Foreman Utilities Crew Leader Utilities Supervisor Public Works Director Executive Assistant Life Scientist EPA Lead Inspector Signature/Date Supervisor Signature/Date RACHEL MATTHEWS Rachel Matthews Digitally signed by RACHEL MATTHEWS Date: 2025.06.25 09:56:44 -05'00' Date ROBERTO BERNIER Date: 2025.06.25 14:13:03 -05'00' Digitally signed by ROBERTO BERNIER Roberto Bernier Date 6ENFORM-019-R9 (02/27/2025) 1 Section I - INTRODUCTION City of Cibolo, Texas Sanitary Sewer Overflow Initiative - 6-4-2025 PURPOSE OF THE INSPECTION EPA Region 6 inspector Rachel Matthews arrived at the City of Cibolo Public Works office, at 8:56 am on June 4, 2025, for an announced inspection. I met with Mr. Chris Hubbard, Utilities Superintendent, Mr. Julio Gomez, Public Works Director, and other city utilities staff. I presented my credentials to Mr. Hubbard and the others informing them this was an EPA inspection to determine compliance with the Clean Water Act regarding sanitary sewer collection system. The scope of the inspection is a compliance evaluation. FACILITY DESCRIPTION The City of Cibolo serves an approximately 34,000 residents, with 250 commercial connections and 11,306 residential connections. The city's sanitary sewer collection system consists of approximately 115.6 miles of pipe with five (5) lift stations. The lift stations are connected to Supervisory Control and Data Acquisition (SCADA) and have back-up generators as well as audible/visual alarm system. In addition, the city has two (2) vactor trucks available. The oldest sewer pipe (50+ years) is 4% vitreous clay, located in "old town" and the rest of the pipe is polyvinyl chloride (PVC) (new since 2020). All sewer lines are connected and routed through the collection system to a wastewater treatment plant (WWTP) owned and operated by Cibolo Creek Municipal Authority (CCMA). There are no septic systems outside of the piped service areas of the city. There is one (1) industrial area that is being added, but negotiations were ongoing at the time of the inspection. The surrounding San Antonio metropolitan area is greatly expanding. According to Public Works, Cibilo is rapidly expanding and has another five (5) square miles to full build-out. Section II - OBSERVATIONS/INTERVIEWS Department of Public Works personnel include 15 fulltime staff. According to the city, this is currently adequate, but they will need an additional crew (4 staff) with the expected expansion within the next five (5) years. The city expects the population to increase to 50,000 + residents in about 10 years. During the inspection, a review of the Sanitary Sewer of Overflow (SSO) reports (paper copies) showed the city reported only seven (7) SSOs since 2001. Most issues are at the lift stations and stem from inflow/infiltration (I/I) during heavy rain events if the pumps cannot keep up. The city has been using two (2) crews for annual cleaning, and follow-up closed circuit television (CCTV) inspection, all pipes and manholes throughout the system. Staff commented that dye and smoke testing is occasionally completed as well. Any root intrusion to the system in a right of way will add a concrete encasement for protection so as not to remove the tree. There is no formal I/I study however, and therefore unknown how much I/I there is. The city has a pretreatment ordinance for Fats, Oils, and Grease (FOG). Code Enforcement manages the grease traps for food establishments. And, while the apartment complexes (new in the last 5 years) schools, and other institutions with kitchens, grease and other blockages have not been a problem. The city also incorporates educational programs (including part of a parade) and fliers for the community. There is one "hot spot" jetted on a weekly basis. 2 City of Cibolo, Texas Sanitary Sewer Overflow Initiative - 6-4-2025 When asked about any manholes located in flood plains (and/or bolted down to prevent overflows), or creek crossings of pipes, the city said the line running through Schlater Park, through Schertz and Cibolo - is in a low area and all manholes are bolted down. City personnel inspect the lift stations every day. While there is a spreadsheet for pump run times tracked, there is no written checklist or Standard Operating Procedure (SOP) for daily inspections. All lift stations have a generator connected to SCADA. The generator is auto-tested once a week and runs for 30 minutes, which shows on SCADA. Of the five (5) lift stations, 2 smaller ones will be removed and replaced with one new lift station. Enzymes are used at lift stations to address FOG and (primarily) odor monthly. The onsite inspection of two (2) lift stations (Venado and Kaylee) included a high-water alarm check. The Kaylee lift station, located directly behind a home, did not trip the audio/visual alarm when the high-water alarm was tested. It did send a text warning through SCADA. The access road at the Kaylee lift station has active construction to rebuild the retaining wall between the homeowner's yard and the access road. The following are some of the procedures the city affirmed to have based on a pre-inspection questionnaire: SCADA Routine Inspections/Maintenance Privately owned SSO mitigation Lift/Pump Stations Infiltration/Inflow Abatement Condition Assessment Pipeline Cleaning Program Valve maintenance SSO Clean-up Hot Spot Maintenance or mitigation The city has ongoing training that includes On-The-Job and orientation for new staff whereby they change crews after a month to work with multiple people. The TCEQ required training for licensing and online training are also included, along with a monthly safety training. The city staff explained they use the "OpenGov" software platform for work orders. According to the website, the platform "delivers a unified experience across asset management, permitting, procurement, budgeting..." The city is currently getting "Cartegragh Asset Management", which works in conjunction with OpenGov. The city already has their sanitary sewer collection system mapped in GIS, with some work orders connected. The city is in the midst of developing a more comprehensive management system. Currently preventative maintenance is tracked in the GIS mapping system, but not through the work order system. The only work orders currently generated are from complaints that are taken through the billing department. These are conveyed to a customer services representative who investigates to verify legitimacy and then transfers the problem to public works for resolution. During the inspection, I requested to review complaints, and the associated work orders with details, which indicated they were not seamless. It took multiple tries to get a "complete picture" of one complaint. The city expects this to be uniform once the comprehensive system is fully up and running. According to the city, a rate study is in process - for the current Master Plan - to look at the projected expansion and updates. The annual budget is used to fund Operation & Maintenance, emergency 3 City of Cibolo, Texas Sanitary Sewer Overflow Initiative - 6-4-2025 repairs, as well as some rehabilitation. There is a 5-year Capital Improvement Plan for 2019-2024, which includes a 2024 comprehensive plan for the future, according to city staff. Regarding cyber security protocols and protections, I discussed some recent issues as well as training programs that are available. The city has an information technology (IT) department and said they have some protocols set for protections. Staff commented that phishing email tests are sent out occasionally. However, they do not have a written emergency response plan (ERP) for wastewater, nor does staff attend specific training. Section III - AREAS OF CONCERN There were no major areas of concern on the date of inspection. CLOSING CONFERENCE EPA Region 6 inspector Rachel Matthews conducted a closing conference. During the closing conference I reviewed Areas of Concern and recommendations Section IV - FOLLOW UP There was no information requested or received by EPA after I exited the Facility on June 4, 2025. RECOMMENDATIONS: The following recommendations were discussed during the closing conference: 1. Develop and maintain up-to-date written SOPs, including an inspection checklist and alarm test for the lift station, ensuring current and new employees understand necessary job functions. 2. Continue developing the new work order system to ensure accurate and efficient tracking system for all complaints, planned and unplanned work, and potential trend analysis. 3. Review regulations regarding private laterals and their associated maintenance requirements. Develop and institute a code if necessary. 4. Develop an ERP where necessary and ensure staff training. Section V - LIST OF APPENDICES There are no appendices in this report 4