Document RjNRQBdNXg7b1BBzO24grmg3v

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 06/29/2017 Water NPDES- Clean Water Act ----- ----- Company Name: t--F=a CIT1ty Name: Cedar Hill, City of- Trinity River Authority (TRA) MeiTlber City_ _.. - - -Cedar Hill Wastewater Collection System Facility Physical Location: 1554 South Clark Rd. (city, state, zip code) Mailing address: Cedar Hill, Texas 75104 - .----- 285 Uptown Blvd. - ---- (city, state, zip code) Cedar Hill, Texas 75104 County/Parish: Facility Contact: Dallas and Ellis Counties Elias Sassoon (Joe Komisarz) I Public Works Director .(lnteriJ,; PW Director) elias.sassoon@cedarhilltx.com (joe. kom isarz @ceda rh illtx .com) -- FRS Number: 110010934409 Identification/Permit Number: TXU000147 [and served by TRA- Central Regional (TX0022802), Ten Mile Media Number: f-------. . NAICS: SIC: - (TX0022811), and Red Oak (TX0104345) Wastewater Treatment Systems] - N/A 22132 4952 ------ -- - Personnel participating in inspection: .. Elias Sassoon City of Cedar Hill Adam Campbell City of Cedar Hill Mike Farr DuyVu City of Cedar Hill - -- City of Cedar Hill Public Works Director .i 972-291-5126 . Public Works Ops. Manager 972-291-5126- Public Works Utility Supervisor 972-291-5126 Public Works Environ. Mgr. 972-291-5126 Gregg Kidd City of Cedar Hill Public Works Environ. Canst. 972-291-5126 --------- Mike Tillman ------- Rachel Matthews Mgr. EPA Region 6 {6EN-WM) Environmental Scientist EPA Region 6 {6EN-WM) -~ife Scientist --------- 214-665-7531 214-665-8589 EPA Lead Inspector Signature/Date --- Supervisor Signature/Date 6ENFORM019-R7 (2/15/2017) ~2%/d/L.~ { nspector name} Mike Tillman --- - -- .. /i--- .. I( ~~.:;:jz)~ {Supervisor name) Carol Peters-Wagnon 1 - jtz/~ 7 Date 1 ?-/oro/;? Date ------ Section 1- INTRODUCTION City of Cedar Hill, Texas Inspection Date: 06/29/2017 PURPOSE OF THE INSPECTION The purpose of the inspection was to examine the City of Cedar Hill's (or City) sanitary sewer collection system as an element of the EPA's National Sanitary Sewer Overflow (SSO) Initiative to prevent raw sewage from entering streets, rivers, reservoirs, front yards, etc. For further SSO initiative information you may reference the web link: https://www.epa.gov/enforcement/water-enforcement. The scope of the inspection is to generally evaluate the municipalities that receive Trinity River Authority (TRA) wastewater treatment services in order to assist in stopping or mitigating unauthorized/unpermitted discharges or SSOs. EPA Region 6 inspectors arrived at the City of Cedar Hill's Public Works Office at approximately 9:00am on June 29, 2017 for an announced Compliance Evaluation Inspection (CEI). We met with the City's Public Works Director and other staff listed on the cover sheet above and illustrated by the inspection sign-in sheet (Appendix 2.) We presented our credentials and the purpose of the inspection was broadly explained as a collection system compliance evaluation of areas such as capacity, management, operations, and maintenance (CMOM) and associated SSO mitigation activities; as well as comprehensive SSO reporting according to Texas law. For further CMOM program guidance you may reference the web link: https://www3.epa.gov/npdes/pubs/cmom guide for collection systems.pdf. The inspection was conducted in accordance with the Clean Water Act (CWA). The City's collection system is regulated under the: Texas Water Code (TWC) Texas Administrative Code (TAC) Texas Health and Safety Code Clean Water Act (CWA) Code of Federal Regulations (CFR) Associated CRWWS NPDES General Permit Conditions Before leaving the facility, an exit briefing was conducted that explained observations, suggestions and areas of concern. This inspection report is based on information supplied by the City's representatives, observations made by the U.S. EPA inspectors, records and reports maintained by the City of Cedar Hill, the State of Texas, and the U.S. EPA. Greg Diehl and Sandy Van Cleave of the TCEQ were notified of the inspection, but did not to participate. FACILITY DESCRIPTION The City of Cedar Hill is approximately 36.0 square miles in size. The collection system consists of three (3) different basins which flow to three (3) different TRA wastewater treatment plants; Central Regional, Mountain Creek, and Red Oak for contractual wastewater treatment services (Appendix 3.) Most of the system (80%) has been constructed since the 1980's and consists of 213 miles of pipe comprised of 13.5% vitreous clay (VC), 1.3% ductile iron (DI), 83.8% polyvinyl chloride (PVC), and 1.3% other materials with 20 lift stations. The Utility serves approximately 49,500 residents and 714 commercial connections. Cedar Hill's wastewater supervisory control and data acquisition (SCADA) system is located at the Public 2 City of Cedar Hill, Texas Inspection Date: 06/29/2017 _ Works Department and is supported by a dedicated generator for emergency backup power (Appendix 1; photo# 1.) The water/wastewater utility has a total of fourteen (14) full time positions; one supervisor, four crew chiefs, seven utility maintenance workers, and two utility technicians. The City currently has 148 active aerobic on-site sewerage treatment systems within its jurisdiction. All septic systems with a leach field have been required to install an aerobic treatment system or tie into the City's collection system. Systems are constructed in accordance with State rules and require timely maintenance contracts. Section II- OBSERVATIONS A) Based on the inspection discussions, data analysis, and observations at the time of the inspection: According to staff, Cedar Hill's collection system does not experience any problems during dry weather. It was noted that the City of Cedar Hill received several 'historic' rain events (i.e. roughly greater than a 50-year flood event) in the months of June and July in 2015, but they did not have a significant impact on the collection system. Wet weather problems tend to occur near connections with the Trinity River Authority (TRA) system, 90% being in the Red Oak basin. Specifically, three (3) areas which include Brookside Drive, the Red Oak interceptor, and at the intersection of Cooper Street and Hastings Drive. The most recent inflow and infiltration (1/1) study was completed in the Red Oak basin in June 2016. Findings from 2013 and 2016 studies will help identify future capital improvement projects. Cedar Hill has four (4) wastewater maintenance crews available during normal business hours_ Each crew rotates one (1) week each month for after hours on-call duty. Sewer calls that come in during business hours are received by the receptionist at the Call Center (Appendix 1; photo# 2), who sets up a work order and notifies one of the four (4) crew chiefs. The crew chief taking the call directs his crew to respond. Upon job completion, crews complete the work orders by hand (logbooks) and turn them into the supervisor who is responsible for entering the information into the automated work order system- Cartegraph. Cedar Hill has no written standard operating procedure (SOP) for the Call Center. After hours sewer calls are handled by the City of Duncanville Call Center and forwarded to the Cedar Hill Duty Phone, which is manned 24 hours a day. All SSOs, regardless of size, are reported to the Texas Commission on Environmental Quality (TCEQ) as required by state law, except for those from private property. One exception is any private property overflow that enters a curb and gutter or street inlet, these are reported. Normally, private side overflows are brought to the attention of the customer, who is responsible for making necessary repairs_ If overflows are a repeat problem, the City will televise the line to help determine the problem. If the customer does not correct the problem, the matter is turned over to Code Enforcement, who can issue the customer a citation. Cedar Hill has 20 lift stations; two (2) have permanent on-site generators for backup power, four (4) are wired with quick connects and share the use of one (1) portable generator, and 14 have enough holding capacity to utilize a vac-truck to manually move wastewater to another 3 City of Cedar Hill, Texas Inspection Date: 06/29/2017 gravity flow line. The City has a vac-truck company on standby contract who can respond in an emergency within two (2) hours. Generators are tested weekly to verify operation and output. Lift stations are monitored via SCADA 24/7, are inspected weekly, and cleaned monthly. The City of Cedar Hill does not have written SOPs or checklists for lift station operation and maintenance (O&M) activities. The SCADA system is located at the Public Works Department on South Clark Road. The system monitors both drinking water and wastewater infrastructure, has back-up power supplied by a dedicated generator, and the capability of an alarm notification via cell phone App Mobile 911. Technicians can also log in remotely via laptop to check system status. The City is looking to eventually install a mirror SCADA system at City Hall. The City has no written SOP for SCADA operations. Cedar Hill has a geographical information mapping system (GIS) and is currently identifying and cataloging its wastewater infrastructure. Once up to date, the City will integrate the information with its asset management program for better tracking. Cedar Hill has been a participant in the TCEQ's Sanitary Sewer Overflow Initiative (SSOi) program since 2007. The initiative is set to expire in 2017, but the City has plans to renew its commitment to the program. The latest SSOi report to TCEQ, dated February 12, 2016 is attached (Appendix 4.) A fats, oils, and grease (FOG) program has been implemented to regulate the discharge of grease and oils to the collection system. Grease and oil are known to be a major contributor to SSOs in most municipalities. Components of the FOG program include public outreach, a public grease drop off location, a liquid wastehauler/grease trap program, and industrial pretreatment program. Restaurant/grease trap inspections are carried out by a 3'' party health inspector. Under the grease trap program, restaurants are required to pump their traps every 90 days. The pretreatment program is contracted out to the Trinity River Authority. Written SOPs are in place for SSO response and clean-up (Appendices 5 and 6.) An initial infiltration and inflow (1/1) analysis has been performed in some of the older sections of the city. The initial analysis has been followed up with closed circuit television (CCTV) and repairs. Repairs consist of pipe bursting and slip lining as needed. The primary target areas are the 10 mile and Red Oak basins. An assessment of ongoing work was performed in July 2016 to determine the effectiveness of repairs. The report is attached as Appendix 7 Hydro jet cleaning and CCTVing of lines is an ongoing process to identify trouble areas. Problem (hot spots) areas receive monthly preventative maintenance to help prevent SSOs. The City has not established any annual cleaning goals (pipe footage/year) for cleaning of the collection system. Staff have regular safety meetings and training. Training consists of protocol for confined space entry; SSO response, cleanup, documentation and reporting. Asset management is an ongoing process. As sections of the collection system are CCTV'd, pipe condition is being assessed and categorized. This information is being transferred into the City's GIS system and integrated into the asset management and work order software. Once lines are identified for replacement or rehab, they are submitted for inclusion in the Capital Improvement Plan (CIP.) System funding is provided through Enterprise and CIP funds. The Enterprise fund is based on utility rates, which are reviewed on a regular basis. The next rate study is to be completed by the end of 2017. The CIP is renewed on an annual basis and has line items included for 1/1 4