Document MJ2D1xqrMQJawdyJ7LrdRne4M

ft EAUnited States Environmental Protection , ., Agency Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 05/21/2025 Water SDWA-PWS Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: EOLWater Supply Corporation EOLWSC 9645 Elk Road Axtell, TX, 76624 9645 Elk Road Axtell, TX, 76624 Mclennon (903) 457-3190 MR FRED KUBITZA fkubitza@yahoo.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: TX1550025 Personnel participating in inspection: Craig Young EPA-Region 6 ECAD-WR Ruben Alayon-Gonzalez EPA-Region 6 ECAD-WR Chelo Hall EPA-Region 6 ECAD-WR Daniel Kim EPA-Region 6 ECAD-WR Mariela Reyna EPA-Region 6 ECAD-WR Fatima Shaikh EPA-Region 6 ECAD-WR Janet Cherry ERG Maura Harbaugh ERG Elizabeth Luke TCEQ Robert Mathis EOL WSC Terri Lindsay EOL WSC II EOL LEAD OPERATOR Enforcement Coordinator ECAD Water Resources Supervisor Enforcement Coordinator Enforcement Coordinator Enforcement Coordinator Enforcement Coordinator Contract Inspector Contract Inspector Compliance Officer Operator Secretary EPA Lead Inspector Signature/Date CRAIG YOUNG {Inspector name} Digitally signed by CRAIG YOUNG Date: 2025.07.03 09:17:39 -05'00' Date Supervisor Signature/Date RUBEN ALAYON-GONZALEZ Date: 2025.07.09 10:58:53 -05'00' Digitally signed by RUBEN ALAYON-GONZALEZ {Supervisor name} Date 6ENFORM-020-R8.2 (02/12/2020) 1 EOLWSC 05/21/2025 2 Section I - INTRODUCTION EOLWSC 05/21/2025 PURPOSE OF THE INSPECTION The EPA inspection team arrived at EOL WSC at 9:00 am on May 21, 2025, for an announced inspection. The inspection team included EPA Region 6 employees Craig Young, Ruben Alayon-Gonzalez, Chelo Hall, Daniel Kim, Mariela Reyna and Fatima Shaikh; Eastern Research Group (ERG) contract inspectors Janet Cherry and Maura Harbaugh; and TCEQ compliance officer Elizabeth Luke. We met with Elk Oak Lake {EOL) operators Fred Kubitza and Robert Mathis as well EOL secretary Terri Lindsay. The inspection team presented our credentials to Mr. Kubitza and informed him that this was an EPA inspection to determine compliance with the Safe Drinking Water Act, and the EPA Administrative Order SDWA 06-2011-1342 for arsenic Maximum Contaminant Level {MCL) violations. FACILITY DESCRIPTION The EOL WSC is a community water system managed by four employees: three operators, and a secretary. The system obtains water from three wells and serves approximately 686 service connections. The system also supplies water to the Moores Water System {TX1550127) and serves as an emergency connection for Axtell WSC {TX1550016) and Prairie Hill (TX1470011). Wells No. 1 and No. 3 pump water to three interconnected ground storage tanks, with gaseous chlorine injected prior to storage. Water from the storage tanks circulates through a cooling tower to two service pumps that take suction from the ground storage tanks and pump to the distribution system, with a pressure tank floating on the system. Water from Well No. 2 is pumped through a cooling tower and then to two interconnected ground storage tanks, with gaseous chlorine injected prior to storage. Two service pumps take suction from the storage tanks and pump to the distribution system with a pressure tank floating on the system. Section II - OBSERVATIONS Opening Conference We discussed the purpose of the inspection, the timeline for the inspection report and expected follow-up actions from the inspection We discussed the system's sources, asset management, water demands and treatment processes We discussed technical and financial challenges faced by the facility as well as the system's efforts to return to compliance with the arsenic MCL violations We discussed the system's plan to receive a line extension from the city of Waco to blend and ensure compliance with the arsenic MCL We discussed the systems Technical Managerial and Financial {TMF) capacity including the system's organization, inter-system connections, history of funding, rate increases, current treatment techniques, anticipated treatment changes once connected to the city of Waco, as well as staffing, customer base and sampling requirements 3 EOLWSC 05/21/2025 We reviewed documents concerning the system's cross connections, tank inspections, sampling, and reporting Plant 2 We observed the system's emergency generator (Photo 2) We observed system's chlorine injection/pump room (Photos 3-4) We observed the system's chlorine storage (Photos 5-7) We observed the system's two 50k gallon storage tanks, and hydrostatic pressure tank (Photos 8-10) We observed the foundation for the system's 100k gallon mixing tank We observed the system's cooling tower We observed Well 2 Plant 3 We observed Well 3 (Photos 11-12, 20) We observed the system's emergency generator (Photo 11) Plant 1 We observed the system's chlorine injection/pump room (Photo 14) We observed the system's chlorine storage We observed the system's emergency generator We observed the system's two 50k and 100k gallon storage tanks, and hydrostatic pressure tank (Photo 15-18) We observed the foundation for the system's 100k gallon mixing tank We observed the system's cooling tower (Photo 19) We observed Well 1 Section Ill - AREAS OF CONCERN 1. The chlorine room at Plants 2 and 1 did not have a viewing window, crash bar, alarm, or chlorine sensor {Photos 6,14) 2. The chlorine room ventilation at Plants 2 and 1 was not tied to automatic switches 3. The entrance of Plants 2 and 1 did not contain signage warning of chlorine gas storage {Photos 1, 13) 4. Spent chlorine gas tanks were unchained at Plants 2 and 1 {Photos 5, 7,14) 5. Ground storage tanks at Plants 2 and 1 were missing adequate climb protection {Photos 9, 15, 18) 6. A ground storage tank at Plant 2 housed a wasp's nest in the overflow valve {Photo 10) 7. Well 3 at Plant 3 was missing a 24-mesh screen on the air relief valve {Photo 20) 8. There were exposed openings in the wellhead at Plant 3 {Photo 12) 9. A flapper valve at Plant 1 would not self-close once opened {Photo 16) 4 EOLWSC 05/21/2025 10. An overflow flapper valve contained painter's tape that prevented the valve from fully closing at Plant 1 (Photo 17) 11. There was a heavy leak at the cooling tower of Plant 1 (Photo 19) The EPA inspection team conducted a closing conference at the EOL office at 12:15 pm on May 21, 2025, following the inspection. During the closing conference, the inspection team reviewed the Areas of Concern noted during the inspection. Section IV - FOLLOW UP On July 1, 2025, representatives of EOL provided EPA documentation of the corrected areas of concern. Section V - LIST OF APPENDICES Appendix 1- Photo Log- 20 photos taken 5/21/25 Appendix 2- Opening and closing conference sign-in sheets Appendix 3- Process flow diagram Appendix 4- Corrective Actions 5 EOLWSC 05/21/2025 Appendix 1 Photograph Log 6 EOLWSC 05/21/2025 Unless otherwise indicated herein, all photographs were taken by Fatima Shaikh of EPA during the inspection. The displayed date and time are the local time (CST). 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. 7 Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. l I County: McClennan I State: Texas EOL WATER SUPPLY CORP. PLANT NO. 2 9219 Elk Photo File Name: DSCNS842 Description: Signage on entrance to Plant 2 with no warning of chlorine gas storage on site Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 I County: McClennan I State: Texas Photo File Name: DSCN5843 Description: Emergency generator located at Plant 2 Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 I County: McClennan I State: Texas Photo File Name: DSCN5846 Description: Chlorine injection and pump room Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 I County: McClennan I State: Texas Photo File Name: DSCN5847 Description: Chlorine injection and service pumps Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 I County: McClennan I State: Texas Photo File Name: DSCN5855 Description: Unchained spent chlorine gas cylinder Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 I County: McClennan I State: Texas 1-LJiiJ11 _g_ CHLORINE __Q_ -;.:; GAS ?S: lfr-n'1JI Photo File Name: DSCN5857 Description: Door of chlorine gas room missing viewing window Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 I County: McClennan I State: Texas r-.:> 0 r-.:> U1 0 r-.:> Photo File Name: DSCN5858 Description: Chlorine gas room missing alarm and chlorine gas sensor Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 I County: McClennan I State: Texas Photo File Name: DSCN5866 Description: Ground storage tanks and hydrostatic pressure tank at Plant 2 Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 I County: McClennan I State: Texas Photo File Name: DSCN5867 Description: Ground storage tank at Plant 2 missing adequate climb protection Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 I County: McClennan I State: Texas LO 0 Photo File Name: DSCN5868 Description: Wasp's nest discovered in ground storage tank overflow Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 I County: McClennan I State: Texas Photo File Name: DSCN5895 Description: Well 3 and accompanying emergency generator Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 I County: McClennan I State: Texas Photo File Name: DSCN5897 Description: Well head of Well 3 with openings for exposure Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 I County: McClennan I State: Texas Photo File Name: DSCN5899 Description: Signage on entrance to Plant 1 with no warning of chlorine gas storage on site Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 I County: McClennan I State: Texas Photo File Name: DSCN5900 Description: Door of chlorine gas room missing viewing window and unchained spent chlorine gas cylinder Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 I County: McClennan I State: Texas Photo File Name: DSCN5901 Description: Ground storage tank at Plant 1 missing adequate climb protection Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 I County: McClennan I State: Texas Photo File Name: DSCN5915 Description: Flapper on overflow valve of ground storage tank would not self-close once opened Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 I County: McClennan I State: Texas Photo File Name: DSCN5921 Description: Flapper on overflow valve of ground storage tank covered in painters tape preventing proper sealing Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 I County: McClennan I State: Texas r-..:, 0 r-..:, u, Photo File Name: DSCN5932 Description: Climb protection at ground storage tank at Plant 1 missing lock Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 I County: McClennan I State: Texas Photo File Name: DSCN5946 Description: Leak at the cooling tower at Plant 1 Location: EOL WSC City: Axtell UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 I County: McClennan I State: Texas Photo File Name: P1010572 Photographer: Maura Harbaugh Description: Air relief valve at Well 3 missing a 24-mesh screen EOLWSC 05/21/2025 Appendix 2 Opening and Closing Conference Sign-in Sheet 28 INSPECTION SIGN-IN SHEET Facility: .o. L oosc PWS ID No.: ,-X \2.'=, ---r--- Present for PreNnt for Name 11Ue Agency/Company Phone Emall Opening Cloalng Conf11n11ce? Co11feoce? r,'AIQ.UJO I- V1.. l'tr1rl1. PA c.e>ntrac.. ,r75vv d1) r P,{:;i Dqz'f-Z)1P-LJ57q ra 1-1a. I Y'-' l--{Cl)J. &i iv,m I ------+-----+------+------+-___.s;@C.O 6 tJ,/?..,Q/).;r7eJ/l. 0, rJd-vb,'rz:.-r .-- J --;::c-----,----=-----,-------,-----,----1-___::__._____:____-+-_....:___ef, (}1(U1a tJ -..l-----;- OL '-'--'-'--'-'-I Iur-- / V Cort\\ ;o.(\ce ,./ 1fl izo-be""" L<At __Q\ ,r - Oc..:....J~-+.EPP..----+-'-'-----+--'-----=------++:(I-J-..J." =( .,(,...?:J..I I. - i:.-..:.J.1. --- E\)f\ ,r-::.yec\t.,( ('Y\,... , \ '.\. 7 " v,.\ ,e c ne ro,. rc:;'7\\-Vn\ 1 J 1 'cC"'tn',C-\i ni:- L\l\- Ci,S- ,n1 I (e \'\C.. N'cn 1q,q.c:,11 (JJ #cut t ell) :......:'----l-t-P- I} -(-2.-,-'---+-"--f'l-t-- t',-- J.1'-I t,,c; ;..1tG h,ll.d.ef0)er. Vi PA i"sp;:ct-o, _,--1 . , . v1 c o r ,c,PA .214-C.GS-- 71"('0 Sl..,tJ.oo<J.qoJ /.1'.,Tl /y\C{ "'-0... iC...r...-.....__C_..--'--"_f\._la --+-'--- - - ---t-----0 -t------J 1-'-""""'->-.L..l::>-'li,V\ - 21- (/6-2+<o(" ti/A, o+, l.J.l'l,{i',v,er- J V v \...,/' J 5'{_1,0<10 ,"310-'6411 4 eol l - :oe.,-t. <Jtecq e..u.L EOLWSC 05/21/2025 Appendix 3 Process Flow Diagram 30 WellNo.1 175gpm WellNo.3 320 gpm WellNo. 2 300 gpm Elk Oak Lake Water Supply Corporation August 22, 2023 PWS ID No.: 1550025 Linettte Ly Plant 1 o.15MG Cooling Tower (closed loop) o.03MG Ground Storage Tanks o.otMG r, Pressure Tank Service pumps 2 x 500 GPM each To Distribution 447 connections Plant 2 o.otMG Cooling Tower (closed loop) Emergency Generator o.02MG Ground Storage Tanks Service pumps 2 x 400 GPM each To Distribution 239 connections Note: System sketch not to scale EOL WSC 05/21/2025 Appendix 4 Corrective Actions UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Corrective Actions Location: EOL WSC City: Axtell Photo No. 1 County: McClennan State: Texas Photo File Name: 20250623_133712 Description: Signage at Plant 1 warning of chlorine gas storage UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Corrective Actions Location: EOL WSC City: Axtell Photo No. 2 County: McClennan State: Texas Photo File Name: 20250623_133728 Description: Plant 1 Chlorine gas storage room with viewing window installed UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Corrective Actions Location: EOL WSC City: Axtell Photo No. 3 County: McClennan State: Texas Photo File Name: 20250623_133804 Description: Leak at Plant 1 cooling tower repaired UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Corrective Actions Location: EOL WSC City: Axtell Photo No. 4 County: McClennan State: Texas Photo File Name: 20250623_133951 Description: Climb protection installed on ground storage tank at Plant 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Corrective Actions Location: EOL WSC City: Axtell Photo No. 5 County: McClennan State: Texas Photo File Name: 20250623_133956 Description: Climb protection installed on ground storage tank at Plant 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Corrective Actions Location: EOL WSC City: Axtell Photo No. 6 County: McClennan State: Texas Photo File Name: 20250623_134355 Description: Openings in Well 3 repaired UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Corrective Actions Location: EOL WSC City: Axtell Photo No. 7 County: McClennan State: Texas Photo File Name: 20250623_135637 Description: Chlorine room at Plant 2 with viewing window installed UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Corrective Actions Location: EOL WSC City: Axtell Photo No. 8 County: McClennan State: Texas Photo File Name: 20250623_140041 Description: Signage at Plant 2 warning of chlorine gas storage UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Corrective Actions Location: EOL WSC City: Axtell Photo No. 9 County: McClennan State: Texas Photo File Name: 20250701_103431 Description: Climb protection installed on ground storage tank at Plant 2 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Corrective Actions Location: EOL WSC City: Axtell Photo No. 10 County: McClennan State: Texas Photo File Name: 20250701_110415 Description: 24-mesh screen installed UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Corrective Actions Location: EOL WSC City: Axtell Photo No. 11 County: McClennan State: Texas Photo File Name: 20250701_110427 Description: 24-mesh screen installed UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Corrective Actions Location: EOL WSC City: Axtell Photo No. 12 County: McClennan State: Texas Photo File Name: 20250701_110844 Description: Overflow valve on ground storage tank self closes UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Corrective Actions Location: EOL WSC City: Axtell Photo No. 13 County: McClennan State: Texas Photo File Name: 138209451818409238 Description: Lock installed on climb protection at Plant 2 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Corrective Actions Location: EOL WSC City: Axtell Photo No. 14 County: McClennan State: Texas Photo File Name: 227663563445070237 Description: Chlorine sensor installed Plant 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Corrective Actions Location: EOL WSC City: Axtell Photo No. 15 County: McClennan State: Texas Photo File Name: 1219669472642732727 Description: Chlorine sensor installed Plant 2 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Corrective Actions Location: EOL WSC City: Axtell Photo No. 16 County: McClennan State: Texas Photo File Name: -4665752508437909529 Description: Button installed for automatic ventilation of chlorine room Plant 2 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Corrective Actions Location: EOL WSC City: Axtell Photo No. 17 County: McClennan State: Texas Photo File Name: 6327594606417265017 Description: Switch installed for automatic ventilation of chlorine room Plant 2