Document X74OyK8o7qzR1gvKNV6R1dELg

ft E A ~ United States .,....., Environmental Protectior ,. Agency Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 2/24/2026 Water SDWA Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Patterson Water Group Denton Estates Mobile Home Park 1295 Cottonwood Ln Denton, TX, 76207 PO Box 910 Collinsville, TX, 76233-0910 Denton (903) 429-3008 Mike Colorado I I Compliance Manager Operations@pwg.services FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: TX0610016 TX0610016 - Personnel participating in inspection: Abigail Williams EPA Region 6 Fatima Shaikh EPA Region 6 Daniel Kim EPA Region 6 Mimi Phillips EPA Region 6 Mike Colorado Patterson Water Group Garrett Carter Patterson Water Group Dallas Slay Patterson Water Group Lead Inspector Inspector Inspector Inspector in Training Compliance Manager Operator Compliance Coordinator EPA Lead Inspector Signature/Date ABIGAIL WILLIAMS Date: 2026.04.01 09:17:27 -05'00' Digitally signed by ABIGAIL WILLIAMS {Inspector name} Date Supervisor Signature/Date RUBEN ALAYON-GONZALEZ Date: 2026.04.01 11:24:34 -05'00' Digitally signed by RUBEN ALAYON-GONZALEZ {Supervisor name} Date 1 Denton Estates Mobile Home Park 2/24/2026 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Abigail Williams, Fatima Shaikh, Daniel Kim and Mimi Phillips arrived at the Denton Estates Mobile Home Park at approximately 9:00 am on February 24th, 2026 for an announced Safe Drinking Water Act (SDWA) inspection of the Denton Estates Mobile Home Park, Public Water Supply (PWS) ID No. TX0610016. During the opening conference Abigail Williams presented her credentials to Mike Colorado and informed him that this was an EPA inspection to evaluate the System's compliance with the Safe Drinking Water Act (SDWA). The system representatives present at the opening conference are reflected on the sign-in sheet (Appendix 1). The scope of the inspection was to evaluate the drinking water system, including the ground water source, storage, treatment, pumps, distribution, operations and management, and to determine progress in addressing deficiencies cited in a sanitary survey by the Texas Commission on Environmental Quality (TCEQ), conducted on July 11, 2023. FACILITY DESCRIPTION Denton Estates Mobile Home Park Public Water System (PWS) is a community water system located in Denton, Denton County, Texas. The PWS is a groundwater system with 52 service connections and serves a population of 156 customers according to Texas Drinking Water Viewer database. Garrett Carter is the operator and visits the mobile home park once per week to collect water samples. The system has two wells; Well Number No.1 is active with a capacity of 30 gallons per minute (gpm) and Well No.2, appeared to be abandoned. Disinfection is provided via a sodium hypochlorite solution before entering a 1500 galloon ground storage tank. Water is pumped to distribution by one service pump with a two horsepower and pressure is maintained by a hydro-pneumatic tank. The system was previously operated by SRC Water Supply, Inc (SRC). SRC abandoned operations in February 2025 which resulted in the Public Utility Commission of Texas (PUCT) appointing Patterson Water Supply, LLC (Patterson) as temporary management in April 2025. Patterson is currently responsible for the PWS until the Commission orders otherwise (Appendix 4). Open Violations On the TCEQ Drinking Water Viewer, the system has received various violations in 2024 and 2025. The open violations are listed in Table 1 below. 2 Denton Estates Mobile Home Park 2/24/2026 Table 1 Violation ID 90065915 Compliance Status Unresolved Violation Begin Date 12/6/2025 Violation End Date - Violation Type 2C Violation Name CORRECTIVE/EXPEDITED ACTIONS (RTCR) 90065920 Unresolved 7/1/2025 12/31/2025 52 FOLLOW-UP OR ROUTINE TAP M/R (LCR) 90065917 Unresolved 7/1/2025 - 71 CCR REPORT 90065901 Unresolved 3/28/2025 4/4/2025 34 90065907 Unresolved 1/1/2025 6/30/2025 52 MONITOR GWR TRIGGERED/ ADDITIONAL, MAJOR FOLLOW-UP OR ROUTINE TAP M/R (LCR) 90065919 Unresolved 11/1/2024 11/30/2024 75 PUBLIC NOTICE RULE LINKED TO VIOLATION 90065903 Unresolved 10/17/2024 - 75 PUBLIC NOTICE RULE LINKED TO VIOLATION 90065863 Unresolved 10/17/2024 - 2E LSL INVENTORY-INITIAL 90065864 Unresolved 10/17/2024 - 4G LSL REPORTING-INITIAL 90065916 Unresolved 10/1/2024 10/31/2024 75 PUBLIC NOTICE RULE LINKED TO VIOLATION 90065913 Unresolved 9/1/2024 9/30/2024 75 PUBLIC NOTICE RULE LINKED TO VIOLATION 90065912 Unresolved 8/1/2024 8/31/2024 75 PUBLIC NOTICE RULE LINKED TO VIOLATION 90065850 Unresolved 7/2/2024 - 72 90065918 Unresolved 7/1/2024 9/30/2024 75 CCR ADEQUACY/AVAILABILITY/CONTENT PUBLIC NOTICE RULE LINKED TO VIOLATION 90065910 Unresolved 7/1/2024 7/31/2024 75 PUBLIC NOTICE RULE LINKED TO VIOLATION 90065862 Unresolved 7/1/2024 12/31/2024 52 FOLLOW-UP OR ROUTINE TAP M/R (LCR) Section II - INSPECTION ACTIVITY SUMMARY The EPA Inspection Team conducted interviews, and a field visit to understand the Water Treatment Plant (WTP) process and gather information regarding the system's operations. The TCEQ sanitary survey reports were provided prior to the inspection to help the inspection team get a general understanding of the PWS and compliance. The information in this report is based on the documents reviewed, conversations with the system representatives, and observations made during the inspection. The documents provided for review by the PWS during the inspection included: 3 Denton Estates Mobile Home Park 2/24/2026 x Customer Complaint logs for the last 12 months x Revised Total Coliform Rule (RTCR) Level 1 Assessment Form x Public Water System Monitoring Plan x Plant Operations Manual x Sample Siting Plan x Water Plant Schematic x Operator Licenses x SOP for sampling x SOP for Customer Service Inspections (CSI) Previous Sanitary Surveys The EPA inspection team reviewed the most recent sanitary surveys conducted by TCEQ, which took place in July 2023. From this survey two alleged violations remain unaddressed: Failure to provide a pressure tank capacity of at least 20 gallons per connection and failure to maintain the ground storage tank in accordance with 30 TAC 290.43(c). Both alleged violations were observed during the inspection. Section III - Observations Well No.1 x Well No.1 was located outdoors on a concrete well pad (Appendix 2, Photo 1). x The Well was equipped with 200 GPM pump and the pipe from the well was covered with insulation materials at the time of inspection (Appendix 2, Photo 2). x There was no lightning protection (grounding) for the well, appurtenances, or ancillary equipment. x The well was not equipped with a backflow prevention device. x The master meter is functional and in good repair (Appendix 2, Photo 3). x The raw water sample tap displayed signs of corrosion (Appendix 2, Photo 4). x The raw water sample tap was positioned horizontally instead of pointing down and the faucet appeared to be threaded (Appendix 2, Photo 4). x The air relief valve appeared to be properly screened and in good repair (Appendix 2, Photo 5). x System representatives stated that the Well produces 30 gpm. x Groundwater from Well #1 is disinfected with free chlorine before entering the ground storage tank (GST). Chlorine Injection x The injection valve was covered in insulation (Appendix 2, Photo 9). x The landscaping around the injection valve was overgrown and mostly covered the valve, making it not easily visible (Appendix 2, Photo 9). x The system representatives stated that there are no flow alarms to indicate changes in chemical treatment. 4 Denton Estates Mobile Home Park 2/24/2026 Ground Storage Tank (GST) x 1500-gallon tank capacity x The system uses a Polyvinyl chloride (PVC) tank. x The landscaping around the tank did not appear to be properly maintained (Appendix 2, Photo 12). However, the system representatives stated that landscaping duties are normally performed on a monthly schedule. x The tank did not have an overflow drainage pipe. x The system representatives stated that inside the GST they have a float switch. The float switch was replaced last year. x System representatives were unsure of when the tank had last been inspected. x The GST appeared to be experiencing foundation settlement. The bottom of the tank was not visible due to the overgrown grass and the tank settling into the ground maintained. The tank also appeared uneven (Appendix 2, Photo 13). Chemical Storage x The water is disinfected with liquid chlorine. x The system representatives stated that they purchase a chlorine solution from DPC industries. x The chlorine solution is stored inside the pump house. x The chlorine solution is kept in a white 50-gallon tank (Appendix 2, Photo 14). x The system representatives stated chlorine levels are monitored weekly during the operator's visits. x The system representatives stated that their target chlorine residual is 1.0 mg/L. x System representatives stated that the average chlorine residual is 0.77 mg/L. MORs submitted to TCEQ confirmed that. Well No.1 Pump House x An ownership sign with emergency contact information was posted on the door to the pump house (Appendix 2, Photo 10). x x The floor of the pump house was constructed of loose wooden panels (Appendix 2, Photo 12) x Various areas were covered in exposed insulation materials (Appendix 2, Photo 13). x Various loose wires were observed close to the ground on inside of the Pump House. (Appendix 2, Photo 13). x The inspection team identified small gaps in the back wall of the pump house. Hydro-pneumatic Tank x The hydro-pneumatic tank has a capacity of 990-gallons. x The pressure tank displayed signs of rust on the exterior (Appendix 2, Photo 14) x Two pressure gauges we observed in working conditions. x During the time of the inspection the pressure gauge monitoring the GST measured at 30 psi (Appendix 2, Photo 15). x During the time of the inspection the pressure gauge monitoring the water pressure being sent to distribution measured at approximately 42 psi. 5 Denton Estates Mobile Home Park 2/24/2026 Well No.2 x The system representatives stated that Well No.2 was abandoned and disconnected from the system, but the Well has not been plugged. x The Well is enclosed inside a well house on a concrete well pad (Appendix 2, Photo 16-17). x The well house is removable for easy access. x The roof of the Well House was rusty; there was a crack orginating from the bottom of the wall extending upwards and there was a noticeable gap in the seam. (Appendix 2, Photo 17). Section III - AREAS OF CONCERN Area of Concern 3. The landscaping around the water system has not been properly maintained. Area of Concern 4. The sample tap on Well No.1 displayed signs of corrosion. AWWA Manual: M27 External Corrosion Control for Infrastructure Sustainability, Chapter 1 states, "The health of water consumers may be threatened whenever extensive corrosion breaches the sanitary integrity of the water system. The ever-present danger of backflow of contaminated liquid into the drinking water system is further increased when water pressure is interrupted to facilitate repairs on corroded wells, pumps, treatment equipment, pipes, valves, and services." Area of Concern 5. The sample tap at Well No.1 lacked a backflow prevention device. AWWA Management Standard, G100-11 Water Treatment Plant Operation and Management, 4.3.2 states, "The plant shall have documentation of a cross-connection control and backflow prevention program or be part of a cross-connection control program run by another entity." Area of Concern 6. The ground storage tank has a maximum capacity of 1500-gallons. 6 Denton Estates Mobile Home Park 2/24/2026 30 TAC 290.45(b)(1)(C) For 50 to 250 connections, the system must meet the following requirements: 30 TAC 290,45(b)(1)(C)(ii) a total storage capacity of 200 gallons per connection. Area of Concern 7. The system representatives stated that they did not have records of the last tank inspection and were unaware of when a tank inspection had been conducted on the GST and the Hydropneumatic tank. 30 TAC 290.46(m)(1) Each of the system's ground, elevated, and pressure tanks shall be inspected annually by water system personnel or a contracted inspection service. Area of Concern 8. The ground storage tank lacked a foundation pad. Area of Concern 9. In the pump house various holes were observed along the back wall. Area of Concern 10. The wires in the pump house of Well No.1 were exposed and not properly secured. 30 TAC 290.46(v) Electrical wiring. All water system electrical wiring must be securely installed in compliance with a local or national electrical code. Area of Concern 11. The hydro-pneumatic tank at Well No.1 displayed signs of rust on the exterior. 30 TAC 290.46(m)(1)(B) Pressure tank inspections must determine that the pressure release device and pressure gauge are working properly, the air-water ratio is being maintained at the proper level, the exterior coating systems are continuing to provide adequate protection to all metal surfaces, and the tank remains in watertight condition. Pressure tanks provided with an inspection port must have the interior surface inspected every five years. Area of Concern 12. Well No.2 had not been properly plugged. 30 TAC 290-46(u) Abandoned public water supply wells owned by the system must be plugged with cement according to 16 TAC Chapter 76 (relating to Water Well Drillers and Water Well Pump Installers). Wells that are not in use and are non-deteriorated as defined in those rules must be tested every five years or as required by the executive director to prove that they are in a non-deteriorated condition. The test results shall be sent to the executive director for review and approval. Deteriorated wells must be either plugged with cement or repaired to a non-deteriorated condition. Area of Concern 13. The ground storage tank is made of Polyvinyl chloride material. 30 TAC 290.43(c) Design and construction of clear wells, standpipes, ground storage tanks, and elevated tanks. All facilities for potable water storage shall be covered and designed, fabricated, erected, tested, and disinfected in strict accordance with current American Water Works Association (AWWA) standards and shall be provided with the minimum number, size and type of roof vents, man ways, drains, sample connections, access ladders, overflows, liquid level indicators, and other appurtenances as specified in these rules. The roof of all tanks shall be designed and erected so that no water ponds at any point on the roof and, in addition, no area of the roof shall have a slope of less than 0.75 inch per foot. Area of Concern 14. The hydro-pneumatic tank has a 990-gallon capacity. 7 Denton Estates Mobile Home Park 2/24/2026 30 TAC 290-45(b)(1)(C) For 50 to 250 connections, the system must meet the following requirements: 30 TAC 290.45(b)(1)(C)(iv) an elevated storage capacity of 100 gallons per connection or a pressure tank capacity of 20 gallons per connection. Area of Concern 15. The well house had a crack along the wall and a gap in the seam. Section IV - Closing Conference EPA Region 6 inspectors Abigail Williams, Fatima Shaikh, Daniel Kim and Mimi Phillips conducted a closing conference with Mike Colorado, Dallas Slay, and Garrett Carter at Denton Estates Mobile Home Park at 10:08 am on February 24th, 2026. During the closing conference, Abigail Williams discussed the areas of concern identified during the field component of the inspection. The EPA inspection team reiterated to the system representatives that these areas of concern were not compliance determinations and that the inspection report may include observations that were not identified at the time of the closing conference. Section V - FOLLOW UP No additional information was received by EPA after exiting the Facility on February 24th, 2026. Section VI - LIST OF APPENDICES Appendix 1 - Sign-in sheet Appendix 2 - Photo Log - 16 photos taken 2/24/26 Appendix 3 - Process flow diagram Appendix 3 - Process flow diagram Appendix 4 - Public Utility Commission of Texas - Press release 4/4/24 8 Inspection Date: 02/24/2026 Appendix 1 Sign-in Sheet 9  ~~\~. ED . S1"-4~.s' ~ ~ ~ i0 w \ ~ ~ ~ .,,I': ,,._.s> '4 PRO~~c, United States Environmental Protection Agency Region 6 - Water Enforcement Branch 1201 Elm Street, Suite 500 Dallas, Texas 75270 Subject: Compliance Evaluation Inspection (CEI) Facility Name: Denton Estates Mobile Home Park Facility ID: TX0610016 Date: February 241\ 2026 Opening Meeting Name Title Phone Abigail Williams Inspector 410-459-3255 Fatima Shaikh Inspector 410-599-253 8 Mimi Phillips Inspector 858-239-8437 Daniel Kim Inspector 971-340-9880 rJ\,~ ~\0(0\~ \\c...7 )\~ i 4 u - ::I.ll Z. - -r3 s, l;~G-{_ 0,o<~ \~\orl ~7d- Sf7t - '{ti~ J_ J5 q"{c -- 90~ - 1q9 Email Williams.Abigail@epa.gov Shaikh.Fatima@epa.gov ' Phillips.Mimi@epa.gov Kim.Daniel @epa.gov . v->C\ . S-e..rv t-',_ ,7e.f'viUJ Page 1 of_1 Inspection Date: 02/24/2026 Appendix 2 Photograph Log 11 Photo No. 1 Facility/Location: Denton Estates Mobile Home Park City: Krum I County: Denton I State: Texas Photographer: Mimi Phillips I Witness Name: Abigail Williams Description: View of concrete well pad. 12 Photo No. 2 Facility/Location: Denton Estates Mobile Home Park City: Krum County: Denton State: Texas Photographer: Mimi Phillips Witness Name: Abigail Williams Description: View of Insulation materials. 13 Facility/Location: Denton Estates Mobile Home Park City: Krum Photographer: Mimi Phillips I County: Denton I State: Texas I Witness Name: Abigail Williams Description: View of master meter. 14 Facility/Location: Denton Estates Mobile Home Park City: Krum County: Denton State: Texas Photographer: Mimi Phillips Witness Name: Abigail Williams Description: View of Raw Water sample tap. Arrowing is pointing to corrasion on the sample tap. 15 Facility/Location: Denton Estates Mobile Home Park City: Krum Photographer: Mimi Phillips I County: Denton I State: Texas I Witness Name: Abigail Williams Description: View of screened air relief valve. 16 Facility/Location: Denton Estates Mobile Home Park City: Krum County: Denton State: Texas Photographer: Mimi Phillips Witness Name: Abigail Williams Description: View of Chlorine Injection. Landscaping appears overgrown. 17 Facility/Location: Denton Estates Mobile Home Park City: Krum County: Denton State: Texas Photographer: Mimi Phillips Witness Name: Abigail Williams Description: View of grass growing alongside GST. 18 Facility/Location: Denton Estates Mobile Home Park City: Krum County: Denton State: Texas Photographer: Mimi Phillips Witness Name: Abigail Williams Description: View of 50-gallon tank of chlorine solution in the pump house for well No.1 19 Facility/Location: Denton Estates Mobile Home Park City: Krum County: Denton State: Texas Photographer: Mimi Phillips Witness Name: Abigail Williams Denton Estates r~obileHome Par 0610016 Description: View of signage posted on the door to the pump house. 20 Facility/Location: Denton Estates Mobile Home Park City: Krum Photographer: Mimi Phillips I County: Denton I State: Texas I Witness Name: Abigail Williams Description: View of loose floorboards in the pump house. 21 Facility/Location: Denton Estates Mobile Home Park City: Krum Photographer: Mimi Phillips I County: Denton I State: Texas I Witness Name: Abigail Williams Description: View of loose wires in the pump house. 22 Facility/Location: Denton Estates Mobile Home Park City: Krum County: Denton State: Texas Photographer: Mimi Phillips Witness Name: Abigail Williams Description: View of rust on the Hydro-pneumatic Tank. 23 Facility/Location: Denton Estates Mobile Home Park City: Krum Photographer: Mimi Phillips I County: Denton I State: Texas I Witness Name: Abigail Williams Description: View of pressure gauge on the Hydro-pneumatic Tank. 24 Facility/Location: Denton Estates Mobile Home Park City: Krum County: Denton State: Texas Photographer: Mimi Phillips Witness Name: Abigail Williams Description: View of concrete well pad of well No.2 25 Facility/Location: Denton Estates Mobile Home Park City: Krum County: Denton State: Texas Photographer: Mimi Phillips Witness Name: Abigail Williams Description: View of well house. 26 Appendix 3 Water Plant Schematic 27 Denton Estates Water Plant Schematic 990 Gal HPT ' NO D"~ . [I]- - - - - - - -( w el l Intake Lin~- ~- --------------------- "------------- / Well 1 1500 gallon GST ll>'<J---------- Suction Line 2 HP Pump Pump Room L-------------, 1, ~~l~j~:!~~ :, I CL2 Storaqe Room Lt] Abandoned Well ' To Distribution (115 Connections) 28 Denton Estates Mobile Home Park PWS ID#: TX0610016 Inspection Date: 02/24/2026 Appendix 4 Public Utility Commission of Texas Press Release 29 Press Release April 4, 2025 Public Utility Commission of Texas 1701 N. Congress, P.O. Box 13326, Austin, TX 78701 Contact: Ellie Breed Media@PUC.Texas.Gov Public Utility Commission of Texas Appoints Temporary Manager for SRC Water Supply Manager to serve customers in Denton, Harris, Jim Wells, Limestone, McLennan, Shelby, Walker, Waller, and Wise Counties Austin, Texas - The Public Utility Commission of Texas (PUCT) has appointed a temporary manager for SRC Water Supply Inc. (SRC) to ensure continuous and safe water service for the water utility's customers. SRC operates, maintains, or controls 11 public water systems in Denton, Harris, Jim Wells, Limestone, McLennan, Shelby, Walker, Waller, and Wise counties and serves approximately 431 connections. In October 2024, the PUCT received complaints alleging low water pressure, lack of accessible customer service, and service outages from SRC customers in the Rolling Hills public water system service area. On Oct. 18, the PUCT's executive director issued an emergency order to compel SRC to provide adequate service to its customers in Rolling Hills. The Commission affirmed the emergency order in December 2024. The PUCT later found that SRC had not complied with the emergency order. Additionally, on Feb. 18, 2025, SRC informed the Texas Commission on Environmental Quality (TCEQ) of its intent to abandon all 11 of its public water systems. To ensure safe, reliable water service for all SRC customers, the PUCT has appointed Mark Patterson, through his company Patterson Water Supply, LLC (Patterson), as temporary manager for SRC. As the temporary manager, Patterson will be responsible for managing SRC. Patterson will respond to consumer complaints, read meters, bill customers, collect payments, and perform system maintenance. Patterson must comply with TCEQ and PUCT rules and employ a TCEQ-licensed operator for the duration of the appointment. (cont) 30 SRC customers will see a monthly $12.00 fee per connection per month on their bills to cover the cost of the temporary manager. Patterson will serve as temporary manager until the Commission orders otherwise. Consumer questions or complaints should be directed to the temporary manager by calling (936) 321-7721 or emailing heather@aggregatewater.com. If the temporary manager is unable to address the issue, consumers can contact the PUCT's Consumer Protection Division with billing and service questions by calling 888-782-8477 or by emailing consumer@puc.texas.gov. If the temporary manager is unable to respond to water quality questions or complaints, those should be directed to the specific TCEQ's Regional Office. Contact information for Regional Offices can be found at https://www.tceq.texas.gov/agency/directory/region. About the Public Utility Commission of Texas Our mission is to serve Texans by regulating the state's electric, telecommunication, and water and sewer utilities, implementing respective legislation, and offering customer assistance in resolving consumer complaints. Since its founding in 1975, the Commission has a long and proud history of service to Texas, protecting customers, fostering competition, and promoting high quality infrastructure. To learn more, please visit https://www.puc.texas.gov. 31