Document OzyZvByyam26w45gZMvQLDgK1

Region 6 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 05/28/2019 FIFRA Section 12 Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: City of Dallas Bachman Water Treatment Plant 2605 Shorecrest Dr. Dallas, TX 75235 Dallas County Chaise Holmgren I Senior Program Manager chaise. hol mgren@da Ilascityha II .com FRS Number: N/A Identification/Permit Number: N/A Med ia Number: NAICS: SIC: Personnel participating in inspection: Chaise Holmgren Bachman Water Treatment Dennis Walker Bachman Water Treatment Lee McM illan EPA Region 6 - Pesticide Enforcement Chuck Ruple EPA Region 6 - Pesticide Enforcement Henry Krusekopf Texas Department of Agriculture Katherine Newton Texas Department of Agricu lture Senior Program Manager Maintenance Manager Environmenta l Engineer/ Inspector Environmental Protection Specialist/ Inspector Assistant Regional Director Inspector (214) 670-6628 (214) 670-6628 (214) 665-6404 (214) 665-6534 (214) 631-0265 (214) 631-0265 EPA Lead Inspector Signature/Date ,rt{YiJLJIUL 11,ie-v. McMilran ( 7/5/2019 Date Supervisor Signature/Date ~~ H. Tr4Jstuckeyl ) 7 lS \ <'.\ Date 6ENFORM-019-R7 {2/15/2017) 1 Section I - INTRODUCTION City of Dallas/Bachman Water Treatment Plant Inspection Date: 05/28/2019 PURPOSE OF THE INSPECTION EPA Region 6 inspectors, Lee McMillan and Chuck Ruple arrived at the City of Dallas Bachman Water Treatment Plant at 9:00 AM on May 28, 2019 for an announced joint inspection with Texas Department of Agriculture inspectors, Henry Krusekopf and Katherine Newton. We met with Chaise Holmgren, Senior Program Manager, and Dennis Walker, Maintenance Manager. I presented my credentials to Chaise Holmgren along with a Notice of Inspection and informed him that this was an EPA inspection to investigate a potential unregistered pesticide. The scope of the inspection was the evaluation of the facility's use of sodium permanganate to treat zebra mussels in the water treatment process. FACILITY DESCRIPTION Founded in 1881, the City of Dallas Water Utilities (CDWU) is a not-for-profit department of the City of Dallas providing water, wastewater and storm drainage services to about 2.5 million people in Dallas and 27 nearby communities. The CDWU services approximately 700 square miles with a capacity of 900 million gallons per day. Dallas currently obtains water from area reservoirs: Lake Ray Hubbard, Lake Lewisville, Lake Grapevine, Lake Ray Roberts and Lake Tawakoni. All of Dallas' water supply comes from surface water (water from reservoirs or rivers) although Dallas does sit atop an aquifer. Dallas has three water treatment plants East Side, Elm Fork, and Bachman. The Bachman Water Treatment Plant (BWTP) was built in 1929 and has a capacity of 160 million gallons per day and an average flow of 100 million gallons per day. Water for the BWTP is received from Lake Grapevine to Lake Lewisville down the Elm Fork Trinity River. The BWTP has three intakes. In September 2015, the City of Dallas completed a study to evaluate the threat of zebra mussels in which sodium permanganate was identified as a preferred recommendation and functions as an irritant to keep zebra mussels from adhering to the walls of the pipeline. In 2017, the Dallas BWTP found zebra mussels in the intake and implemented the use of sodium permanganate to treat its intake water for zebra mussels. The sodium permanganate functions as an irritant to keep the zebra mussels from adhering to the walls of the pipeline. When water is transferred to the interior of the plant the zebra mussels are killed in the other section of the process. Through the interior process water is treated to control taste, odor, and raw plant water is disinfected. Section II - OBSERVATIONS At approximately 9:49 am I began touring the following areas accompanied by Mr. Holmgren along with EPA and TDA inspectors: water system intakes and water treatment plant. At approximately 10:03 AM, I arrived at BWTP where Mr. Walker was waiting for us. We observed the intake area and the sodium permanganate facility. The treatment plant uses a 40% sodium permangate solution. At approximately 10:45 AM we returned to the BWTP to observe the ozone generators. The generators intake oxygen and 2 City of Dallas/Bachman Water Treatment Plant Inspection Date: 05/28/2019 produce a 10% ozone rich mixture. Each generator produces about 3000 lbs. per day. All solid waste from the treated water settles out in the ozone basin where it is disposed. Section III - AREAS OF CONCERN I observed the installation of a sodium permanganate injection system used by the Bachman Water Treatment Plant to control zebra mussels. The labeling did not have any indication of EPA pesticide registration. The sodium permanganate product was potentially sold and distributed in violation of FIFRA because at the time of the inspection and an unregistered pesticide. The inspection was concluded at approximately 11:00 AM and I exited the facility. Section IV - FOLLOW UP The following information was received by EPA after exiting the Facility on May 30, 2019: Sodium Permanganate Data 2017-2019 Sodium Permanganate 40% - Carus Corp SDS Sodium Permanganate 40% - F2 Industries SDS Arcadis Zebra Mussel Report Sodium Permanganate Invoices Texas Commission on Environmental Quality Zebra Mussel Letter date 10/10/17 Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 5 photos taken Appendix 2 - Notice of Inspection 3 City of Dallas/Bachman Water Treatment Plant Inspection Date: 05/28/2019 APPENDIX 1 PHOTOGRAPH LOG City of Dallas/Bachman Water Treatment Plant Inspection Date: 05/28/2019 APPENDIX 1 PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Dallas Bachman Water Treatment Plant City: Dallas County/Parish: Dallas State: Texas PHOTOGRAPH LOG Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\FY2019\2019-059 City of Dallas-two locations (Citizen)\Bachman Water Treament Plant\Inspection\Inspection Photos\ DSC_0010.JPG Date of Photo: May 28, 2019 Time of Photo: 10:09 AM Photographer: Chuck Ruple Description: sodium permanganate facility flow meters UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Dallas Bachman Water Treatment Plant City: Dallas County/Parish: Dallas State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\FY2019\2019-059 City of Dallas-two locations (Citizen)\Bachman Water Treament Plant\Inspection\Inspection Photos\ DSC_0011.JPG Date of Photo: May 28, 2019 Time of Photo: 10:09 AM Photographer: Chuck Ruple Description: 40% sodium permanganate tanks UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Dallas Bachman Water Treatment Plant City: Dallas County/Parish: Dallas State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\FY2019\2019-059 City of Dallas-two locations (Citizen)\Bachman Water Treament Plant\Inspection\Inspection Photos\ DSC_0013.JPG Date of Photo: May 28, 2019 Time of Photo: 10:09 AM Photographer: Chuck Ruple Description: 40% sodium permanganate tank label UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Dallas Bachman Water Treatment Plant City: Dallas County/Parish: Dallas State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\FY2019\2019-059 City of Dallas-two locations (Citizen)\Bachman Water Treament Plant\Inspection\Inspection Photos\ DSC_0014.JPG Date of Photo: May 28, 2019 Time of Photo: 10:10 AM Photographer: Chuck Ruple Description: 40% sodium permanganate tank label UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Dallas Bachman Water Treatment Plant City: Dallas County/Parish: Dallas State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\FY2019\2019-059 City of Dallas-two locations (Citizen)\Bachman Water Treament Plant\Inspection\Inspection Photos\ DSC_0016.JPG Date of Photo: May 28, 2019 Time of Photo: 10:11 AM Photographer: Chuck Ruple Description: 40% sodium permanganate tank label APPENDIX 2 NOTICE OF INSPECTION