Document VjXMGN1K7ommV6GLraKrzXbj4

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 05/18/2017 Water NPDES- Clean Water Act Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Northlake, Town of- Trinity River Authority (TRA) Member City Northlake Wastewater Collection System 1400 FM 407 Northlake, Texas 76247 1400 FM 407 Northlake, Texas 76247 Denton County Eric Tamayo I Public Works Director etamayo@town.northlake.tx.us FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110069996784 TXU011193 [and served by TRA Denton Creek Regional WWS (TX0104957)] N/A 22132 4952 Personnel participating in inspection: Eric Tamayo Town of Northlake Mike Tillman EPA Region 6 (6EN-WM) Mitty Mohon EPA Region 6 (6EN-WM) Public Works Director Environmental Scientist Environmental Scientist 940-242-5704 214-665-7531 214-665-6497 EPA Lead Inspector Signature/Date Supervisor Signature/Date ?L/_cU~ (Inspector name) Mike Tillman (#JU-t 1;1r;; {;J~ {Supervisor name} Carol Peters-Wagnon ct/J/;7 Date ct/i/17 Date 6ENFORM-019-R7 (2/15/2017) 1 Section I-INTRODUCTION Town of Northlake, Texas Inspection Date: 05/18/2017 PURPOSE OF THE INSPECTION The purpose of the inspection is to examine the Town of Northlake's (or Town) 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 and unpermitted discharges or SSOs. EPA Region 6 inspectors arrived at the Town of Northlake's Public Works Office at 8:50am on May 18, 2017 for an announced Compliance Evaluation Inspection (CEI). We met with the Town's Public Works Director 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 Town'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 Central Regional Wastewater System (CRWWS) National Pollutant Discharge Elimination System (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 Town's representatives, observations made by the U.S. EPA inspectors, records and reports maintained by the Town of Northlake, the State of Texas, and the U.S. EPA. TCEQ was notified of the inspection, but did not to participate. FACILITY DESCRIPTION The Town of Northlake's collection system is described as being fairly new with the oldest section being approximately 17 years old. The Public Works Department is located at the Town Hall, 1400 FM 407, Northlake, Texas 76247. The wastewater utility is comprised of a Director and a crew of five (5) licensed collection system operators. The Utility serves about 2,000 residents and approximately 15 commercial connections. The system covers roughly 17 square miles (Appendix 3) with operations in place 24 hours a day, seven days a week. The collection system consists of 10 miles of gravity flow lines and is 2 Town of Northlake, Texas Inspection Date: 05/18/2017 comprised of 100% polyvinyl chloride (PVC.) Northlake has no wastewater supervisory control and data acquisition (SCADA) system in place at this time, there are no force mains or lift stations within the collection system. Sanitary sewage is routed through the Town's wastewater collection system to multiple TRA trunk lines and metering stations for transportation to the TRA Denton Creek Regional Wastewater Treatment System (TX0104957) for contractual wastewater treatment services. The community currently has approximately 200 active septic systems within its jurisdiction. Septic systems that fail are required to correct any issues within 10-15 days of failure or if wastewater collection systems are available, failed systems are required to tie into the Town's wastewater collection system. Section II- OBSERVATIONS A) Based on the inspection discussions, data analysis, and observations at the time of the inspection: Sewer calls that come in during business hours are routed to the Utility Billing Office (Appendix 1; photo #2.) The call is then routed to the WW Crew Leader in the field, who checks out the problem. Additional staff is notified as required. Utility Billing fills out a work order for the call and the Public Works Director finalizes the work order once the call has been resolved, enters the information into the Town's automated work order system, and files appropriate reports. Northlake instituted an automated work order system in 2013. Sewer calls that come in after hours are routed to an after-hours number linked to the Public Works Director's cell phone. The Director dispatches the on-call crew to handle the sewer issue. The Director finalizes work orders and files appropriate reports using procedures established for normal business hours. During the inspection, it was determined that the Public Works Department is in need of additional administrative staff to assist with payroll, completion of work orders, spreadsheets, paperwork for backflow reporting and on-site sewage treatment systems, and other reporting requirements. Wastewater crews handle all sewer issues that occur in the Town's right of way. Any issues that occur from the residence to the right of way is considered to be on the private side and the responsibility of the home owner. The Town of Northlake has not experienced any SSOs in the last five (5) years, but should an overflow occur, the Texas Commission on Environmental Quality (TCEQ) will be notified within 24 hours as required by Texas law. Should an SSO occur, a response would include clean up with removal of solids followed by flushing with dechlorinated potable water and disinfection with lime if necessary. The Town's collection system remained relatively small until new development began to move into the area about three years ago. The Town has an engineering design manual with specifications for developers to follow when installing new collection system lines and manholes. All new infrastructure is inspected by staff and contractors are required to use closed circuit television (CCTV) before final acceptance. The Town had an inflow and infiltration (1/1) study performed by RPS group in 2015. The study identified wet weather issues within the study area. Recommendations from the study include the establishment of a Pipeline Condition Assessment Program (PACP) and a smoke 3 Town of Northlake, Texas Inspection DaW: 05/18/2017 testing program in the affected area. Wet weather issues have been identified near the intersection of I-35W and areas north and south of SH-114. Monthly reports indicate 1/1 with rain events. Systematic smoke testing with utilization of flow meters are being implemented to identify problems (Appendix 1; photo #5.) No specific problems have been identified to date. Northlake received funding in FY16-17 to acquire new equipment for line cleaning and flow monitoring to better identify 1/1 affected areas. The Town was able to purchase a new Jet-Vac truck in January of 2017 (Appendix 1; photo #3.) The Department is seeking funding to initiate a CCTV program to better inspect sewer lines and establish a PACP. Presently CCTV services are handled on a contractual basis or with limited assistance from the City of Roanoke. Once equipment purchases have been completed, Northlake's goal is to clean the entire collection system once a year. Visual inspections will be made throughout the year. Wastewater crews perform routine inspections of manholes and staff has been updating the Geographic Information System (GIS) as necessary when new residential or commercial developments are completed. It was determined during the inspection that the Town of Northlake does not have a sewer use ordinance, liquid wastehauler ordinance, and grease and oil program in place. Such authority is necessary to protect critical wastewater infrastructure as the community continues its growth and development. A third party health inspector (under contract) handles all restaurant inspections. Reports are sent to the Development Director. Hot spots are identified through routine maintenance and sewer calls. These locations are serviced on a monthly basis. The TRA metering station on Raceway Drive, is one such hot spot (Appendix 1; photos #6 & 7.) Management indicated concern with the costs being passed along to the Town for TRA to treat its wastewater. Treatment costs will continue to rise along with increasing wastewater flows (Appendices 5 & 6.) The Town of Northlake has not had any significant issues with its collection system to date and does not participate in the TCEQ's Sanitary Sewer Overflow Initiative (SSOi) at the present time. It was noted that the Town 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. All collection system workers are licensed by the State and are expected to complete annual recurrency training to maintain their licenses. The Town of Northlake performs some training in-house, but lacks expertise for training in some specialized areas. Additional funding is needed to keep up with safety and recurrency training, more specifically confined space entry, lock out and tag out, and manhole inspections. The Town of Northlake's current Capital Improvement Program (CIP) is primarily for roads and water distribution system. Wastewater is not a line item and has relied on existing revenue streams for funding. Currently Northlake has an annual operating budget of $5,000.00 for its wastewater operations (Appendix 4.) A line item is being added to the CIP to help fund coating and rehabilitation of leaking manholes that may be identified by the 1/1 study. Northlake does not have written standard operating procedures (SOPs) for critical components of its wastewater operations. Such operations include dispatch, preventive 4