Document YDmByXeR4QqO4aMpLvk8Ld9O0

ft E A ~ IJnitedStates .. ,. Environ mental Protei;tlon ,., Agoni:y Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regu latory Program(s) 06/04/2024 through 06/06/2024 Drinking Water Safe Drinking Water Act (SOWA) System Owner: System Name: System Physical Location: (city, state, zip code) Mai ling address: (city, state, zip code) County/Parish: System Phone Number System Contact: City of Stillwater City of Stillwater Public Water System (PWS) 1022 W Yost Road Sti llwater, OK 74075 P.O. Box 1449 Stillwater, OK 74076 Payne County 405-533-8452 James Driskel I I Water Utilities Director jdriskel@stillwater.org FRS Number: System Classification: PWSID: Media Identifier Number: NAICS : SIC: 110000753248 Community Water System (CWS) OK1021220 N/A N/A 4941 Personnel participating in inspection: Daniel Kim EPA Region 6 Mariela Reyna EPA Region 6 Danny O'Conne ll PG Environmental/ERG (EPA Contractor) Jake Okun PG Environmental/ERG (EPA Contractor) Freddy Pitts City of Stillwater Jason Tyler City of Sti llwater James Driskel City of Stillwater Kelley Hitch City of Stillwater Jackson Dozier City of Stillwater Ginger Sharkness Oklahoma DEQ Dawn Hoggard Oklahoma DEQ Prasuna Maskey Oklahoma DEQ Enforcement Officer Enforcement Officer Inspector Inspector WTP Supervisor Plant Manager Water Utilities Director Water Utilities Specialist Water Quality District Engineer District Engineer District Engineer EPA Lead Inspector: Signature/Date -~ 1- - - -~ - ~ - - ~ 7/17/2024 Supervisor Signature/Date Danny O'Conne ll (ERG) Date RUBEN ALAYON-GONZALEZ Dlgltally slgned by RUBEN ALAYON-GONZALEZ Date: 2024.07.25 16:03:1 8-05'00' 7/25/2024 Ruben Alayon-Gonzalez Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I INTRODUCTION City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Purpose Of The Inspection On June 4-6, 2024, U.S. Environmental Protection Agency (EPA) Region 6 and EPA contract inspectors from PG Environmental, a division of ERG (hereinafter the EPA Inspection Team) conducted an announced Safe Drinking Water Act (SDWA) compliance inspection of the City of Stillwater Public Water System (the System or City), ID No. OK1021220. The inspection began at approximately 8:30 a.m. on June 4, 2024 and finished at approximately 3:00 p.m. on June 6, 2024. The City of Stillwater owns and operates the System. Danny O'Connell and Jake Okun presented their SDWA inspector credentials to the System representatives during the opening conference. The EPA Inspection Team informed the System representatives that this was an EPA inspection to determine compliance with the SDWA and other applicable federal and state regulations. The EPA Inspection Team met with James Driskel, the City's Water Utilities Director, Freddy Pitts, the Water Treatment Plant (WTP) Supervisory, Jason Tyler, the Plant Manager director, as well as other System representatives (see the attendance table on Page 1) for the opening conference. Members of the Oklahoma Department of Environmental Quality (DEQ) also attended the inspection. This report summarizes observations made as part of the inspection, which consisted of the following major activities: Discussions with the City's water system personnel regarding the operation and maintenance of the PWS Site visits to the System's water treatment plant: o Stillwater Conventional Water Treatment Plant Raw Water Ground Storage Tank Solids Contact Units (3) Recarbonization Basins (2) Dual Media Filters (12) Ozone Basins (2) Onsite Ground Storage Tank/Clearwell Distribution Pump Station Recovered Water Lagoons (7) Site visits to the following sites: o Pump Stations North Perkins Pump Station Manning Pump Station (Offline) Third and Stallard Pump Station South Perkins Pump Station 32nd St. Pump Station 19th Ave Pump Station West Highway 51 Pump Station Washington and Liberty Pump Station Yost Pump Station Karsten Creek Pump Station 2 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 OSU Research Pump Station Hilltop Pump Station (Offline) o Water Storage Tanks North Perkins Water Tower Manning Water Tower (Offline) Third and Stallard Water Tower 56th St. Water Tower 44th St. Water Tower Range Water Tower Washington and Liberty Water Tower Yost Water Tower Ricebeck Water Tower (Offline) Tan-Tara Water Tower (Offline) Coyle Water Tower (Offline) Central Water Tower o Distribution System Flushing Locations S. Western Road Flushing Line Photos taken during the inspection are included in Appendix 1, Photograph Log. Sections of this inspection report have been redacted by EPA to maintain the security of the PWS. System Description The City of Stillwater Public Water System (System, City) is classified as a community water system. The System is a surface water system that sources its raw water from Kaw Reservoir, located approximately 36 miles from the WTP. Raw water is conveyed through a 36-inch pipe to the Facility. The System provides service to an estimated residential population of 53,000 individuals according to the Safe Drinking Water Information System (SDWIS) database. The System also sells water through 10 metered interconnections located in various areas. The 51 East and Payne Ct. Rural Water District 3 areas each have three interconnections (for a total of six) and Noble Ct., the Town of Morrison, Lone Chimney, and Otoe-Missouria each consist of one (for a total of 4). The City can also provide finished water to and receive finished water from the Oklahoma State University water system if needed. The City owns, operates, and maintains a conventional surface water treatment plant. The WTP is capable of producing 18 million gallons per day (MGD) of treated water and was producing approximately 6-7 MGD on average during the months prior to the inspection. According to a technical memorandum of the distribution system that was generated by the System's contract engineer, Black & Veatch, the distribution system has 19 pressure zones. Treated, finished water is sent to either the "low side" or the "high side" of the distribution system via the high service pump station at the WTP. There are pressure relief valves (PRVs) located throughout the distribution system to reduce pressure coming from higher pressure zones. There are 12 pump stations located throughout the distribution system with 2 being offline during the inspection, and 12 water storage tanks with 4 being offline during the inspection. System representatives stated that the water storage tanks that were offline were being kept offline to preserve water quality but were being kept available for potential future use. A process flow diagram of the WTP can be seen in Appendix 2, Exhibit 1, City of Stillwater WTP Process Flow Diagram. 3 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Staffing Information/Contract Operations The WTP is staffed in two 12-hour shifts, starting at 11:00 a.m. and 11:00 p.m., seven days per week (24/7). Shift change over occur at 10:30 a.m. or 10:30 p.m. During that time, operators that were on shift inform the operators arriving at the WTP of any events that occurred during the prior shift. The treatment plant operators and distribution staff are responsible for preventative maintenance (PM) activities and corrective maintenance (CM) activities (e.g., main breaks). Section II INSPECTION ACTIVITY SUMMARY The EPA Inspection Team conducted an array of interviews and field activities to discuss and observe System operation and maintenance (O&M) and to assess the condition of drinking water system assets. The physical inspection occurred over three days. Previous Oklahoma DEQ sanitary survey reports were provided prior to the inspection. The information in this report is based on document review, conversations with System representatives, and observations made during this inspection. Supervisory Control and Data Acquisition (SCADA) System The City uses a SCADA system to monitor and trend data at the WTP and some, but not all, of the water towers and pump stations in the distribution system. Multiple water towers did not have telemetry that would enable operators to observe tank levels remotely. Operators were able to monitor the status of the 12 filters, including runtime, turbidity, and level through SCADA during the inspection (refer to _ App_en_ dix_1, _ Pho_to_ gra_ phs_1 _ and_2). "Flow" for each of the 12 filters was reading 0 gallons per minute (GPM) on the SCADA screen, and System representatives stated that it was not being monitored. Alarms are programed into the SCADA system to alert operators of failures in the treatment system and low tank levels (refer to Appendix 1, Photograph 3). Operators stated that chemical feed pumps were connected to SCADA, and that operators had the ability to change chemical feed rates remotely. Asset Management/Computerized Management Maintenance System (CMMS) The City does not have an asset management system or CMMS. Assets are not inventoried or categorized using unique ID numbers, and predictive maintenance is not being conducted on treatment assets or distribution system assets. Preventative maintenance is being conducted but is not formally tracked/scheduled. The City has redundant equipment (e.g., pumps, filters, recarbonization basins, ozone basins) and backup equipment such as chemical injection pumps, but unique details for the equipment such as past maintenance activity, equipment age, run hours, and location are not formally tracked using an asset management system. Preventative and corrective maintenance activities are also not tracked at the WTP, but maintenance activities that occur in the distribution system are recorded on a Microsoft Excel spreadsheet. Call Log Sheets System representatives explained that calls received by customers in the distribution system were received at City Hall during regular working hours. Calls that are received after hours are taken at the WTP, and an "After Hours Call Log" is completed. When calls are received, information such as caller name, address, and phone number are written down informally on lined paper, followed by the issue that the customer is calling about and the date/time the call was received. The EPA Inspection Team received call log sheets from System representatives that range from December 1, 2023, through June 1, 2024. The log sheets lacked detail on the issue that the customer was calling about and did not contain 4 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 notes regarding the response or the resolution to the issue. Therefore, it was unclear to the Inspection Team which complaints were resolved. The majority of the calls during the reviewed timeframe were regarding water leaks, but other examples of complaints during the reviewed timeframe include low pressure, off-color/taste water, and water being shut off. The log sheets are not included in this report because they contain sensitive information such as customer names, addresses, and phone numbers. Lead and Copper Rule (LCR) Evaluation While onsite, the EPA Inspection Team discussed LCR monitoring activities, including customer notifications and the System's 2023 sampling event. The City provided results from the last round of sampling, conducted June-August 2023, to the EPA Inspection Team (refer to Appendix 3, 2023 Stillwater LCR Results). The EPA Inspection Team also reviewed the City's IILCR Sample Sites,, document during the onsite inspection (refer to Appendix 4, Stillwater LCR Sample Sites). The plan identifies the 55 sample sites, including their location, tier level, and customer service line material. Customer service line material was listed as "unknown" for every sample site. However, System representatives indicated that a contractor had recently conducted an Advanced Metering Infrastructure (AMI) project. During this project, System representatives asked the engineers to take inventory of service line material on both sides of the meter. Through this project, nearly every service line in the distribution system was evaluated. System representatives stated that there were approximately 100 connections left to evaluate. Of the service lines that were inventoried, there were no lead service lines. Hydrant Flushing The City lacks a formal hydrant flushing program. An inventory of all of the hydrants in the distribution system, as well as a list of dead-end mains was provided to the EPA Inspection Team, but there was no documentation provided to confirm the existence of a routine hydrant flushing program for water quality management. It appeared that the hydrant inventory pertained to the Fire Department's hydrant activities rather than maintenance/water quality activities. Previous Sanitary Surveys The EPA Inspection Team reviewed the most recent sanitary survey that was conducted by the Oklahoma DEQ on April 23-25, 2019. The sanitary survey identified several violations that required a schedule for correction. In addition to these violations, multiple deficiencies were identified that did not require a schedule for correction. The City initially responded to each of these items in a response dated January 29, 2020 (refer to Appendix 2, Exhibit 2, Stillwater Initial Non-Compliance Response January 29 2020). However, Oklahoma DEQ found the response inadequate, citing the following deficiencies as unresolved: The Range Road Tower vent configuration was deemed unacceptable because it was susceptible to rainwater intrusion. There was a lack of an air gap between the fluoride mixing tank and the finished water line which supplies it. There was a lack of differential pressure-cell devices to monitor head loss across the individual filter media beds. Level sensors were implemented, but this did not resolve the deficiency. The City did not have a current DEQ-approved residuals management plan. 5 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 LCR sample sites were not individually categorized by either Tier 1, Tier 2, or Non-Tier. Several deficiencies were identified with the steel clearwell. A summary of these deficiencies can be seen in Appendix 2, Exhibit 3, OK DEQ Inadequate Response Letter June 1, 2020. The City responded to the inadequate response letter on June 30, 2020, resolving most of the deficiencies that were cited by Oklahoma DEQ (refer to Appendix 2, Exhibit 4, Stillwater Final NonCompliance Response June 30, 2020). During the EPA inspection that occurred June 4-6, 2024, the deficiencies that were identified during the last sanitary survey were discussed with System representatives. Deficiencies associated with the individual filters (head loss sensors, flow meters, and rate-of-flow controllers) had not been corrected at the time of the inspection. System representatives indicated that engineers had evaluated the feasibility of adding the required equipment to the individual filters and deemed that it would not be possible without a complete rehabilitation of the filters. Previous Notices of Violation (NOVs) The City received NOVs on February 9, 2023 and July 12, 2023. The February 9, 2023 NOV was in regard to three Running Annual Average (RAA) Total Organic Carbon removal ratio values that were less than 1.00. In the first quarter of 2022, the RAA removal ratio was 0.94. In the third quarter of 2022, it was 0.96, and 0.98 in the fourth quarter. The July 12, 2023 NOV was in regard to total chlorine residuals of less than 2.0 mg/L at the point of entry (POE) or 1.0 mg/L at the most distant points in the distribution system. In February 2023, nine sample results were below 2.0 mg/L at the POE, and one sample result was below 1.0 mg/L at a distant point in the distribution system. Risk and Resiliency/Emergency Response The System used a contractor, Carollo, to complete its risk and resiliency and emergency response documents. The documents were signed and certified by City representatives on June 29, 2021. The EPA Inspection Team reviewed the documents and found they were complete, and fulfilled the requirements outlined in SDWA Sections 1433(a) and (b). Continuous Monitoring Equipment Readings Refer to Table 1 for the continuous monitoring equipment readings obtained during the inspection. The individual filter effluent (IFE) and combined filter effluent (CFE) readings were taken from SCADA on the first day of the inspection (June 4, 2024). All of the filters were in service during the inspection. 6 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Table 1. Continuous Monitoring Equipment Readings Parameter and Units Combined Filter Effluent Turbidity (CFE) Location Combined Header Downstream of Filters Filter A Filter B Filter C Filter D Filter E Individual Filter Effluent Turbidity (IFE) Filter F Filter G Filter H Filter AA Filter BB Filter CC Filter DD Reading 0.080 NTU 0.090 NTU 0.080 NTU 0.090 NTU 0.100 NTU 0.160 NTU 0.090 NTU 0.130NTU 0.090 NTU 0.140 NTU 0.090 NTU 0.230 NTU 0.170 NTU Time/Date 12:40 p.m. 6/4/2024 12:40 p.m. 6/4/2024 12:40 p.m. 6/4/2024 12:40 p.m. 6/4/2024 12:40 p.m. 6/4/2024 12:40 p.m. 6/4/2024 12:40 p.m. 6/4/2024 12:40 p.m. 6/4/2024 12:40 p.m. 6/4/2024 12:44 p.m. 6/4/2024 12:44 p.m. 6/4/2024 12:44 p.m. 6/4/2024 12:44 p.m. 6/4/2024 The City provided the EPA Inspection Team w ith instantaneous IFE and CFE turbidity readings from December 6, 2023 through June 6, 2024 (last 6 months' worth) taken at 15-minute intervals. The readings were entered into EPA's Surface Water Treatment Rule Data Ana lysis Tool, and the following table was generated (refer to Table 2). 7 Table 2. CFE Turbidity Data City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 t hrough 06/06/2024 Results for CFE 95th Percentile Month CFE Measurements <0.35 NTU Total CFE Measurements Percentage <0.35 NTU Exceeds 95th Percentile Limit? (Yes or No) Dec-23 Jan-24 Feb-24 Mar-24 Apr-24 May-24 Jun-24 2439 2976 2773 2970 2880 2975 538 2439 2976 2784 2972 2880 2976 538 100.0% N 100.0% N 99.6% N 99.9% N 100.0% N 100.0% N 100.0% N Onsite Laboratory A separ ate EPA laboratory audit was conducted on June 6, 2024, as a component of the inspection by members of EPA Region 6. The full report that was generated from the audit, including images and observations/areas of concern can be seen in Appendix 5. EPA Laboratory Aud it -June 6. 2024. FACILITY/SYSTEM WALKTHROUGH City of Stillwater Water Treatment Plant The walkthrough of the WTP began at the 4 million gallon (MG) raw water ground storage tank. System representatives indicated that water is pumped from the Kaw Lake Reservoir through a 36 mile, 36-inch stee l intake line. The City has one raw water source (Kaw Lake Reservoir) and is in the process of seeking funds to create another line to a lake that is closer to the WTP. System representatives stated that the intake structure at the second lake already exists, and water r ights have already been established. The 36 mile intake line has been repaired several times, including leak repairs ranging from pencil-sized to substantia lly large repairs. The EPA Inspection Team asked for information associated with leaks in the raw water line, and System representatives stated that there were approximately 20 repairs on the line in the previous 6 months leading up to the inspection, with the most recent repairs occurring in May 2024. The EPA Inspection Team reviewed an invoice dated May 28, 2024, relating to line repa irs (refer to Appendix 2, Exhibit 6, Raw Water Line Repair Invoice - May 28 2024). The invoice included line items such as "leak being larger than 1 inch in diameter," "severe pitting was observed in an exposed portion of the raw waterline near the leak," and "washout area fill." System representatives stated that they cou ld shut down the raw water intake for approximately 6 hours based on the capacity of the existing 8 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 raw water ground storage tank. If the second intake line was constructed, they would be able to shut down the Kaw Lake Reservoir intake for approximately one month. Next, a chemical injection line was observed inside of one of the three meter vaults. There were chemical injection ports for chlorine, ferric sulfate, polymer, and ammonia, but System representatives stated that only ferric sulfate and polymer were being injected into the raw water line. The ferric sulfate and polymer day tanks were observed, as well as the chemical feed pumps. There were spare chemical feed pumps on a shelf next to the tanks. The three solids contact units (SCUs) were observed next. System representatives explained that only the north and middle SCUs were operating during the inspection, w ith the south SCU in standby mode (refer to Appendix 1, Photographs 4, 6, and 7). There was water in the south SCU during the inspection, and System representatives indicated that a small amount of water was leaking from the SCUs into the next step in the treatment process due to a leaky valve. System representatives explained that lime was only injected into the middle SCU, and that the water from the SCUs blended in a common line prior to entering the recarbonization basins. Settled solids from the SCUs is sent to one of seven onsite recovered water lagoons. The two parallel recarbonization basins were observed next (refer to Appendix 1, Photograph 8), followed by the filters. There were 12 total dual media filters. Eight of the fi lters were old and lacked an air scour function but had a surface wash function. The four newer filters had an air scour function to assist with backwashing. System representatives stated that they were unable to verify the individual flow meters for each filter, and they were unable to control the flow going through the filters. Additionally, the filters lacked differential pressure head loss sensors. The fi lter pipe gallery where the IFE turbidity monitoring points were located was positioned near the filters. The pipe gallery was located in a vault below ground, and access was restricted because the area was a confined space. The EPA Inspection Team was unable to enter the vault because of the confined space restrictions. However, System representatives provided images of the inside of the vault, as well as IFE and CFE turbidimeter digital readings to the EPA Inspection Team following the conclusion of the inspection (refer to Appendix 1, Photograph 10). The images showed that the turbidity samp.le tubes had an air gap, resolving a deficiency that was discussed in the 2019 OK DEQ sanitary survey (refer to Appendix 1, Photograph 11). Because of the access restrictions, System representatives stated that a team member only entered the vault once per month. Following the filters, the two parallel ozone basins were observed (refer to Appendix 1, Photograph 12), followed by the fluoride storage and injection room. The fluoride injection system was offline for maintenance during the inspection. The chemical injection vault located upstream of the clearwell was observed (refer to Appendix 1, Photograph 13). The vault was filled with water and the chemical injection line was completely submerged. There was a strong ammonia smell in the area around the vault. The clearwell was observed, and System representatives provided the EPA Inspection Team with pictures of the clearwell roof that were taken after the inspection (refer to Appendix 1, Photograph 14). The clearwell has a total capacity of 4.0 MG. The total capacity of the clearwell is used for contact time considerations, and documented as the fillable level. The high service pump station was observed next. The pump station contained four pumps that deliver finished water to the "low" side of the distribution system and three pumps that deliver finished water to the "high" side of the distribution system. One of the four low side pumps was wrapped in plastic because of a small leak. System representatives stated that the pump was scheduled for replacement. 9 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 The low side pumps send flow to the Central Tower and the high side pumps send flow to the Perkins Tower. Two 250 horsepower (hp) backwash pumps were also present in the pump station. System representatives explained that backwashes occur based on time (approximately every 160 hours) or if turbidity levels get too high. Backwash water is sourced from the 4.0 MG clearwell. The POE total chlorine level was observed at the high service pump station, and it was 3.60 mg/L at 9:06 a.m. on June 5, 2024, the second day of the inspection (refer to Appendix 1, Photograph 16). Asset Walkthrough During the asset walkthrough component of the inspection, 12 pump stations and 12 water storage tanks were observed (see Section I INTRODUCTION of this report). Two of the pump stations were offline during the inspection, and four of the water towers were offline during the inspection. Although the pump stations and towers were offline, they were not physically disconnected from the system and therefore were still evaluated against the Oklahoma Administrative Code Title 252 chapters 626 and 631, as well as the SDWA. Areas of Concern pertaining to the pump stations and water towers can be seen in Section III AREAS OF CONCERN below. An above-ground flushing line extending off of a distribution system line running parallel to S. Western Road was observed in addition to the pump stations and water towers (refer to Appendix 1, Photographs 32 through 41). There were several flushing lines along S. Western Road. The flushing line that the EPA Inspection Team observed had a rubber hose attached to the end without backflow prevention. System representatives stated that the hose was used to prevent ground erosion around the base of the flushing line. The hose extended several feet into a corrugated pipe that had water running through it. The end of the hose was resting in the water, creating a potential cross connection. An inspection of the hose documented a flow of water being discharged at less than one gallon per minute rate. In addition to the potential cross connection concern, the valve box that controlled flushing activities had a lid that was not properly seated when the EPA Inspection Team arrived. After these observations were made to System representatives, the distribution team members severed the hoses, and an inspector verified that the hoses had been removed and there was no discharge from the flushing line (refer to Appendix 1, Photographs 42 through 44). The valve box lid was also placed on properly. Google Earth street view imagery from S. Western Road shows that the hose was attached to the flushing line when the image was taken in March 2022 (refer to Appendix 2, Exhibit 5, Flushing Line Photo March 2022). Additional detail regarding this observation is provided below in Section III AREAS OF CONCERN. In addition to the flushing line that was observed next to S Western Road, multiple air relief valves were observed that extended above ground throughout the distribution system (refer to Appendix 1, Photographs 45 and 46). Additionally, a second flushing line was observed that was capped and did not appear to be a cross connection (refer to Appendix 1, Photograph 47). Section III AREAS OF CONCERN Work Orders/Asset Management Title 252, Chapter 626, Section 3-7(2)(c)(6), Plans and specifications states "Specifications must provide for an Operation and Maintenance (O & M) Manual for the operation and maintenance of the public water supply system. The O & M Manual shall include at a minimum: 10 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 (A) System Treatment Requirements; (B) Description, Operation and Control of the Water Treatment Plant; (C) Control of Unit Processes; (D) Laboratory Testing; (E) Common Operating Problems; (F) Start-Up Testing and Procedures; (G) Standard Operating Procedures; (H) Alternative and Emergency Operations; (I) Emergency Shutdown Operations and Emergency Response; (J) Records Control and Retention; (K) Safety; (L) Public Water Supply System Maintenance Records; (M) Storeroom and Inventory System; and {N) Utilities." Area of Concern 1. The following observations were made in regard to the City's work order/asset management programs: a. Public Water Supply System maintenance records (including preventative and corrective maintenance) for the water treatment plant and the distribution system were not complete. Some maintenance activities that are completed in the distribution system are documented in a Microsoft Excel sheet, but pending maintenance activities are not documented. Service orders/customer complaints are recorded on hard copy sheets but are not complete with details describing the uniqueness of the issue, the actions taken, or dates completed. The EPA Inspection Team observed notes regarding maintenance that occurred on a variable frequency drive (VFD) pump inside of the Third and Stallard Pump Station (refer to Appendix 1, Photograph 25). According to the notes, a communication failure occurred with the pump in May 2024. The notes lack detail regarding specific maintenance that was conducted, and the maintenance activities are not recorded in a work order system. b. The City lacks an asset management/inventory system identifying equipment operational hours/useful life expectancy, maintenance history, equipment inventory, and anticipated replacement budget/plan. Cross Connection Control Title 252, Chapter 626, Section 5-15(a), Cross connections states "Avoid cross connections in the system. (1) Do not allow a physical connection between a line carrying a public drinking water supply and a line carrying water of unknown or questionable quality. (2) Do not allow connections from any PWS system to any device or system that poses a health threat unless it is equipped with an air gap of at least 6 inches or two pipe diameters, whichever is larger, above the overflow or drain pipe. The installation of a reduced pressure zone backflow prevention device will be considered in lieu of an air gap. To allow maintenance on the backflow prevention device, 11 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 the design shall include a diversion line with equal backflow prevention. Do not locate backflow prevention devices in a pit or vault where they can become submerged. A fire suppression system is not considered a hazardous water supply. (3) Do not allow a cross-connection between a public water system and any private water system. (4) Provide an air gap at all points where finished water is discharged to a drain." Area of .Concern 2. The City lacks a formal cross connection control program, and a potential cross connection was observed during the inspection. Specifically, there were multiple above-ground flushing lines extending off of a distribution system line running parallel to S. Western Road. One of the flushing lines had rubber hose attached without backflow prevention (refer to Appendix 1, Photograph 32). The hose extended several feet down into a corrugated pipe that had water running through it (refer to Appendix 1, Photographs 34 and 35). The end of the hose was resting in the water, and water was observed to be flowing out of the hose at a rate of less than one gallon per minute (refer to Appendix 1, Photographs 36 through 41). Google Earth street view imagery taken from S. Western Road shows that the hose was connected in March 2022 (refer to Appendix 2, Exhibit 5, Flushing Line Photo March 2022). Following the observation, distribution team members severed the hose from the flushing line, and an inspector verified that the hose had been removed (refer to Appendix 1, Photographs 42 and 44). Proper Operation and Maintenance Title 252, Chapter 631, Section 3-1(a), PWS criteria states "All systems must properly operate, in accordance with an Operations and Maintenance manual as required by OAC 252:626-3-7. All systems must maintain each unit to provide treatment of the water in accordance with the DEQ approved plans and specifications, in accordance with the purpose for which the units were designed and according to the terms of their permits. Permits may contain more stringent provisions than contained in the rules to meet the requirements of the provisions of 40 CFR adopted by reference in this chapter. Employees must be trained in the proper operation and maintenance of the system." Area .of .Concern 3. The following observations were made in regard to proper operation and maintenance at the City of Stillwater Water Treatment Plant: a. There was a strap supporting the motor in the center of the offline South SCU (refer to Appendix 1, Photograph 7). b. There were multiple cracks in the corner of the concrete recarbonization basin that appeared to be weeping (refer to Appendix 1, Photograph 8). Other cracks in the concrete structure had been filled in with sealant to prevent weeping. c. System representatives stated that the flow meters associated with each of the filters were unable to be verified/calibrated due to their positioning in an underground vault, making them difficult/impossible to access (refer to Appendix 1, Photograph 10). In addition, this area is classified as a confined space, and System representatives stated it is only entered once a month. 12 Area of Concern 4. City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 d. There were numerous cracks in the concrete roof of the ozone basin (refer to Appendix 1, Photograph 12). It appeared that the cracks had been filled at a point in time, but there were cracks in the caulking as well. e. The chemical injection vault where ammonia is injected into the produced water line (downstream of the ozonation process) was completely flooded, submerging the injection port (refer to Appendix 1, Photograph 13). There was a strong ammonia smell coming from the vault. The following observations were made in regard to proper operation and maintenance at the pump stations and finished water storage towers in the distribution system: a. One of the impellers associated with one of the pumps at the 32nd St. Pump Station was spinning in reverse when the EPA Inspection Team arrived onsite (refer to Appendix 1, Photograph 30). The SCADA system indicated that the pump was not running at the time. After the observation was made, operators found that the seal of the check valve on the pump discharge line had deteriorated and needed to be replaced. The pump and discharge line were taken offline while repairs were being made. A second check valve at the pump station was making a periodic clicking noise; it was unknown what was causing the noise. It appeared that the check valve was not seated properly. System representatives stated that operators were planning to take the pump and discharge line offline to evaluate the extent of the issue. b. The floor of the 19th Ave. Pump Station was cracked and appeared to be settling and separating from the wall due to ground settling. c. A drainpipe extending from the floor of the 44th St. Water Tower was filled with black insects (refer to Appendix 1, Photograph 49). It appeared that the flapper for the drain line had been wired open previously. When this observation was made, the wire was removed, and the flapper was seated tightly to the pipe. d. The meter vault outside of the 44th St. Water Tower had one inch of standing water inside of it and staining on the walls of the vault indicated past water level heights of 12-16 inches high (refer to Appendix 1, Photograph 50). It was unclear why the vault was flooding, since a sump pump was present inside of the vault. The high water marks inside of the vault were approximately 12 inches from an electrical outlet inside of the meter vault. e. There was a heavy buildup of moisture on the control panel inside of the 44th St. Water Tower base due to humidity within the base (refer to Appendix 1, Photograph 52). The EPA Inspection Team had the City representatives check the inside of the panel, which did not contain moisture. f. The structural bolts and nuts around the bases of the Yost Water Tower and Ricebeck Water Tower (offline) did not appear to be properly seated on the tank anchor (refer to Appendix 1, Photographs 64 and 69). 13 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 g. The bolts that were designed to anchor the base of the Coyle Water Tower (offline) to the concrete pad that it was positioned on were not torqued down (refer to Appendix 1, Photographs 74 through 76). System representatives did not know when/how the bolts became loosened. There was also some corrosion/paint cracks around the bolts. Additionally, some of the bolts appeared to be positioned in an area where the concrete foundation had failed. h. The meter vault adjacent to the Tan-Tara Water Tower (offline) was completely flooded during the inspection, submerging all of the assets inside of the vault (refer to Appendix 1, Photograph 71). i. The floor of the Karsten Creek pump station appeared to be failing due to heavy corrosion (refer to Appendix 1, Photograph 79). The pump station was an underground, vault station and appeared to be a metal "can" style station. j. There were voids in the concrete walls surrounding the pump line in the Hilltop pump station (offline) (refer to Appendix 1, Photograph 80). The voids created a possible entry point for water into the pump station vault, and the electric motors for the pumps were positioned near the base of the vault. Security Title 252, Chapter 626, Section 5-4 (4), Security protection states "Public water supply systems shall provide the following security measures to protect water treatment plants, finished water storage facilities (which include laboratories, chemical buildings, administration buildings and storage buildings): (1) Fencing at least six (6) feet high of galvanized steel chain link, number nine gauge with two inch or smaller diameter mesh, and posts not more than ten feet (10') separation center-to-center in post-holes at least thirty inches (30") deep, back-filled with concrete that extends two inches (2") above grade and crowned to shed water; (2) Three-strand barbed wire shall be installed atop the fence along its entire length; (3) Gates shall be constructed of similar material as the fence or stronger; (4) "No Trespassing" signs shall be installed at least at fifty foot (50') intervals along the entire length of the fence and at the location of all intake structures. The signs shall contain the following information: (A) "Tampering with a Public Water Supply is a federal crime", and (B) "If you see a problem contact the following: (i) Contact name, (ii) Contact address, (iii) Contact phone number"; and (5) Locks shall be installed on all gates, entry doors, manholes, other access points, water wells and pumping stations. Electric gates shall be considered equivalent to locked gates." Area of Concern S. The following observations were made regarding physical security at the WTP: a. "No Trespassing" signs were not posted around the perimeter fence at the WTP. b. 14 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Area of Concern 6. The following observations were made regarding perimeter fences surrounding water storage towers in the distribution system: a. b. The barbed wire at the top of the perimeter security fence surrounding the Ricebeck Water Tower (offline) was damaged (refer to Appendix 1, Photograph 68). c. The perimeter fence surrounding the Coyle Water Tower (offline) was damaged/missing in places due to construction activities occurring around the tower (refer to Appendix 1, Photograph 78). The distribution system pipes were exposed in open trenches. Title 252, Chapter 626, Section 17-1(f)(2), Protection, Protection from trespass states "Provide fencing, locks on access manholes, and other necessary precautions to prevent vandalism, pilfering, trespassing, or sabotaging " Are.a of Concern 7. The following observations were made regarding vegetation growing along perimeter fence lines at the WTP and field assets: a. There was vegetation growing around and against the perimeter security fence at the WTP in multiple places. b. There were golf balls and broken glass near the base of the Third and Stallard Water Tower (refer to Appendix 1, Photograph 24). System representatives stated that the residents of the house directly next to the tank would throw bottles over the fence against the side of the tank, and that people would hit golf balls toward the tank. System representatives also stated that the police had dealt with the security issues coming from the house next to the tank. There were also tree branches growing over the perimeter fence surrounding the Third and Stallard Tower and pump station (refer to Appendix 1, Photograph 21). c. There were trees/vegetation growing on and around the perimeter fence surrounding the Tan-Tara Water Tower (offline) (refer to Appendix 1, Photograph 70). Area .of .Concern 8. The following observations were made at the 56th St. Water Tower: a. b. 15 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Area of Concern 9. There was a ladder resting on the ground next to the Yost Water Tower (refer to Appendix 1, Photograph 65). The purpose of the ladder was unknown; however, it would grant access to the tank's ladder. Protection of Finished Water Title 252, Chapter 626, Section 17-1(f)(1), Protection, Cover of finished water storage states "Storage of treated water must have a watertight roof or cover, which will exclude birds, animals, insects and excessive dust. Locate the top of all finished water storage structures above possible flood elevations." Area of Concern 10. The hatchways to the wet well that was positioned at the effluent end of the filters at the WTP lacked watertight seals (refer to Appendix 1, Photograph 9). Additionally, there was water ponding around the hatchways. Area of Concern 11. The rubber gasket around the perimeter of the hatchway leading to the 4.0 MG clearwell at the WTP had fallen off in places. It was unclear whether a watertight seal could be created without the gasket (refer to Appendix 1, Photograph 14). Title 252, Chapter 626, Section 11-3(g)(2), Storage of chemicals states "Separate the chemical storage rooms from the feed machine room. Liquid chemicals may be stored in the feed machine rooms where containment for spills is provided." Area of .Concern 12. The following observations were made in regard to chemical storage at the WTP: a. There were 35-pound buckets of petroleum based gear oil sitting on decks of the North and South SCUs at the WTP (refer to Appendix 1, Photographs 5 and 7). b. There were multiple chemical barrels and containers being stored on the ground without secondary containment, inside of the high service pump station (refer to Appendix 1, Photograph 15). The chemical barrels appeared to be empty at the time of the inspection. Title 252, Chapter 626, Section 11-1, Chemical application states "Chemicals must be listed by NSF or UL as meeting ANSI/NSF Standards 60 and 61. All containers shall be labeled with the following information: chemical name, chemical purity, chemical concentration, supplier name and supplier address. Do not apply any chemical to drinking water unless specifically permitted by the DEQ." Area o.f Concern 13. The 35-pound barrel of gear oil (Phillips 66 80W-90) that was sitting on the deck of one of the solids contact units at the WTP is not listed as NSF certified (refer to Appendix 1, Photograph 5). Threaded Hose Taps 16 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Title 252, Chapter 626, Section 15-5(d)(1)(C), Gauges, meters and sampling cocks states "Equip each pump with the following: smooth nosed sampling cocks on suction line and discharge line of booster pumps." Area of Concern 14. The following observations were made regarding threaded hose taps seen in the distribution system: a. There was a threaded hose tap without backflow prevention extending off of one of the pump lines inside of the Manning pump station (offline; refer to Appendix 1, Photograph 19). b. There were multiple threaded hose taps without backflow prevention extending off of the pump lines inside of the Third and Stallard pump station (refer to Appendix 1, Photographs 26 and 27). One of the taps had a hose attached to it without backflow prevention. c. There was a threaded hose tap without backflow prevention extending off of one of the pump lines inside of the Washington and Liberty pump station (refer to Appendix 1, Photograph 55). d. There was a threaded hose tap without backflow prevention extending off of one of the lines inside of the 44th St. Water Tower (refer to Appendix 1, Photograph 51). e. There was a threaded hose tap without backflow prevention extending off of one of the pump lines inside of the Karsten Creek pump station (refer to Appendix 1, Photograph 79). f. There was a threaded hose tap without backflow prevention extending off of one of the lines at the Coyle Water Tower (offline) (refer to Appendix 1, Photograph 77). g. There was a threaded hose tap without backflow prevention extending off of one of the lines inside of the Central Water Tower (refer to Appendix 1, Photograph 81). Pressure Gauges Title 252, Chapter 626, Section 15-5(d)(1)(A) and (B), Gauges, meters and sampling cocks states "Equip each pump with the following: (A) standard pressure gauge on its discharge line, and (B) compound gauge on its suction line." Area of Concern 15. The following observations were made regarding pressure gauges on pump lines in the distribution system: a. The City lacked compound pressure gauges (measuring both positive and negative pressure) on all of the observed suction lines inside of their pump stations. b. One of the pump lines in the Third and Stallard Pump Station was missing a suction side pressure gauge (refer to Appendix 1, Photograph 28). 17 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 c. Both of the pumps in the Washington and Liberty Pump Station were missing both suction and discharge side pressure gauges (refer to Appendix 1, Photograph 54). d. One of the pressure gauges on the suction side of one of the West Highway 51 Pump Station pump lines was not functional (refer to Appendix 1, Photograph 53). An operator opened a sample tap on the line to verify that water was flowing through the discharge line, and it was confirmed that the line was pressurized even though the pressure gauge was reading <0 psi. Pump Capacity Title 252, Chapter 626, Section 15-3(a)(1), Pumps states "All pumping stations shall have a minimum of two (2) pumping units. With any pump out of service, the remaining pump(s) shall be capable of providing the maximum pumping demand of the system." Aera of Concern 16. There was only one functional pump present inside of the Manning Pump Station (offline; refer to Appendix 1, Photograph 20). Air Relief Ports Title 252, Chapter 626, Section 19-1(e), Air relief and blow-off valves states "Locate air relief valves at high points in lines where air can accumulate. Do not use automatic air-relief valves where flooding of the valve exhaust may occur. Locate sufficiently sized blow-offs at low points of large mains to effectively remove accumulated sediments. Extend the open end of the exhaust line from automatic valves to at least 1 foot above grade and terminate with a screened, downward-facing elbow. Do not connect air reliefs or blow-offs directly to any sewer." Area of Concern 17. The following observations were made regarding downturned exhaust lines extending off of air relief ports: a. The South Perkins Road Pump Station lacked downturned exhaust lines extending off of air relief ports (refer to Appendix 1, Photograph 29). b. The Yost Pump Station pump lines lacked air relief ports and downturned exhaust lines (refer to Appendix 1, Photograph 60). Title 252, Chapter 626, Section 15-2(a)(1), Pumping station building, General construction of building states "Locate pump station buildings on a concrete floor at least 6 inches above the surrounding surface and graded to prevent the entrance of water." Area of Concern 18. There was a hill slope behind the Yost pump station, and it appeared that water flowed down the slope toward the pump station during rain events (refer to Appendix 1, Photograph 62). The building foundation was not 6 inches above the surrounding surface and graded to prevent the entrance of water. There was erosion behind and next to the pump station. 18 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Distribution System Pressure Title 252, Chapter 626, Section 15-3(d), Booster pumps states "Locate and control booster pumps used to increase water pressure in the distribution system so that in normal operation they will not reduce pressure below 25 psi within the distribution system or below 20 psi at any pump suction. Provide automatic cutoff of the pump when the pressure drops below 20 psi. Equip pumps with controls to prevent excessive cycling. Capacity shall meet instantaneous peak demands with the largest pump out of service. Provide a diversion line and valves to permit removal of the pump without disrupting water service. Private booster pumps shall not be allowed for any individual residential service from the public water supply." Area of .Concern 19. The following observations were made regarding pressures lower than 25 psi seen in the distribution system: a. A pressure gauge on the wall of the Washington and Liberty pump station was reading 15.248 psi during the inspection (refer to Appendix 1, Photograph 56). System representatives could not confirm where the pressure reading was coming from, but it appeared that the pressure was being read from the suction line entering the pump station. b. The suction side pressure gauge at the Yost pump station was showing a pressure that appeared to be just below 25 psi (based on photographic imagery from outside the confined space of the vault) (refer to Appendix 1, Photograph 61). Ground Grading Water Storage Tanks Title 252, Chapter 626, Section 17-1(p), Grading states "Grade the area surrounding a ground level structure to prevent surface water from standing within 50 feet of the structure." Area of Concern 20. The following observations were made regarding the grading of the ground surrounding water storage tanks in the distribution system: a. There was water pooling on the concrete drainage pad next to the North Perkins Water Tower, and it appeared that the concrete had settled so that it was sloped toward the tank (refer to Appendix 1, Photograph 17). b. Ponding of water was occurring near the base of the Third and Stallard Water Tower (refer to Appendix 1, Photograph 22). Water was also pooling in the concrete drainage pad next to the tower (refer to Appendix 1, Photograph 23). c. Ponding water was observed near the base of the Yost Water Tower (refer to Appendix 1, Photograph 63). d. The ground surrounding the base of the Ricebeck Water Tower (offline) was sloped toward the tower (refer to Appendix 1, Photograph 69). e. The ground surrounding the base of the tower was sloped toward the Central Water Tower in areas (refer to Appendix 1, Photograph 83). 19 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Water Storage Tank Construction Title 252, Chapter 626, Section 17-1(h) (3), Overflow states "Provide all water storage structures with an overflow that terminates at an elevation between 12 and 24 inches above the ground surface, and release water over a drainage inlet structure or splash plate. Equip the ends of the pipes with flex gates.II Area of Concern 21. The following observations were made regarding overflow lines at water storage tanks in the distribution system: a. The flex gate covering the overflow line of the North Perkins Water Tower did not form a tight seal (refer to Appendix 1, Photograph 18). There was an approximately 0.5-inch gap between the end of the pipe and the flapper. b. The flex gate covering the overflow line of the Third and Stallard Water Tower did not form a tight seal (refer to Appendix 1, Photograph 23). There was an approximately 1-inch gap between the end of the pipe and the flapper. c. The overflow pipe at the 44th St. Water Tower was downturned and contained a mesh screen, but it was not equipped with a flex gate (refer to Appendix 1, Photograph 48). The mesh screen was ripped. d. The overflow pipe at the Range Water Tower was downturned and contained a mesh screen, but it was not equipped with a flex gate. e. The flex gate at the end of the overflow line of the Washington and Liberty Tank was not seated properly (refer to Appendix 1, Photograph 58). There was an approximately 1-inch wide gap between the flapper and the pipe. There were animal/insect nests inside of the overflow pipe (refer to Appendix 1, Photograph 59). It appeared the mesh screen that was covering the end of the overflow pipe had ripped and fallen off. f. The overflow pipe at the Central Water Tower was downturned and contained a mesh screen, but it was not equipped with a flex gate (refer to Appendix 1, Photograph 82). Area of Concern 22. The following observations were made regarding splash pads beneath the terminus of overflow lines at water storage tanks in the distribution system: a. The overflow pipe for the Washington and Liberty Water Tower terminated approximately 2 inches above the concrete splash pad (refer to Appendix 1, Photograph 58). b. There was no splash pad beneath the end of the overflow pipe at the Yost Water Tower (refer to Appendix 1, Photograph 66). Title 252, Chapter 626, Section 17-1(k), Roof and sidewall states "Make the roof and side walls of all structures watertight with no openings except properly constructed vents, manholes, overflows, risers, drains, pump mountings, control ports, and piping for inflow and outflow." 20 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Area of Concern 23. The following observations were made regarding the sidewalls and bases of water storage tanks in the distribution system: a. There was moisture accumulating at the metal base of the Yost Water Tower and the concrete pad that the tank was sitting on (refer to Appendix 1, Photographs 63 and 64). It appeared that the tank was leaking from the base, but this was unable to be verified. The base of the tank lacked caulking or a seal. b. The caulking surrounding the base of the Washington and Liberty Tank was worn away and had failed in places (refer to Appendix 1, Photograph 57). c. Caulking was missing from the joint between the metal base of the Ricebeck Water Tower (offline) and the concrete pad it was sitting on (refer to Appendix 1, Photograph 69). d. Caulking was missing from the joint between the metal base of the TanTara Water Tower (offline) and the concrete pad it was sitting on (refer to Appendix 1, Photograph 72). e. There was an open pipe at the base of the Tan-Tara Water Tower (offline) that provided direct access into the tank (refer to Appendix 1, Photograph 73). A broken casing and ball valve were sitting next to the open pipe. Insects were observed crawling around and into the pipe. f. Caulking was missing from the joint between the metal base of the Coyle Water Tower (offline) and the concrete pad it was sitting on (refer to Appendix 1, Photograph 74). Tank Telemetry/Level Indicators Title 252, Chapter 626, Section 17-4(2), Distribution Storage, Level Controls states "Provide adequate controls to maintain levels in distribution system storage structures. (A) Control pumps by sensing tank water levels and transmitting the signal by telemetering equipment when any appreciable head loss occurs in the distribution system between the pump and the storage structure. (B) Provide altitude valves or equivalent controls for a second and subsequent structures on the system based on the hydraulic profile. (C) Provide overflow and low-level warnings or alarms." Area of Concern 24. The following observations were made regarding telemetry and level indicators at water storage tanks seen in the distribution system: a. There was no level indicator at the Ricebeck Water Tower (offline), and there was no telemetry tied into SCADA associated with the tower (refer to Appendix 1, Photograph 68). System representatives stated that when the tower was online, the level of the tank had to be calculated using the level of other tanks in the distribution system. b. There was no level indicator at the Coyle Water Tower (offline), and there was no telemetry tied into SCADA associated with the tower. System representatives stated that when the tower was online, the level of the 21 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 tank had to be calculated using the level of other tanks in the distribution system. Closing Conference On June 6, 2024, the EPA Inspection Team met with James Driskel, the City of Stillwater's Water Utilities Director, Freddy Pitts, the WTP Supervisory, Jason Tyler, the Plant Manager director at approximately 2:45 p.m. The EPA Inspection Team reviewed observations with the System representatives and explained that the observations were preliminary and did not constitute any formal compliance determinations. Section IV FOLLOW UP Following the conclusion of the inspection, the EPA Inspection Team received six months' worth of customer call logs/complaints, images of the filter pipe gallery, and images of the clearwell roof. Section V LIST OF APPENDICES Appendix 1 Photograph Log 83 Photos Appendix 2 Exhibit Log Exhibit 1 - City of Stillwater WTP Process Flow Diagram Exhibit 2 - Stillwater Initial Non-Compliance Response January 29 2020 Exhibit 3 - OK DEQ Inadequate Response Letter June 1, 2020 Exhibit 4 - Stillwater Final Non-Compliance Response June 30, 2020 Exhibit 5 Flushing Line Photo March 2022 Exhibit 6 Raw Water Line Repair Invoice May 28 2024 Appendix 3 2023 Stillwater LCR Results Appendix 4 Stillwater LCR Sample Sites Appendix 5 EPA Laboratory Audit June 6, 2024 22 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne IState: Oklahoma O. CDffl. "t)4.-fOW l1' to, '.IF"' mu CEUN H 28 FT 3~6 FT Pf-=RKINS ROAD I 82 4 FT 103 .8 PSI P1 Vl'D 15.D P2 \/Fl) 15.0 l!64FJ 100:tPSr n,.n0~T'I"' Slrfr, ,._hT'lm1 e......,r.,, Photograph 1. 6/4/202412:40 PM DSCN0657.JPG WTP SCADA Screen View of the City's SCADA screen show ing the status of the eight o lder filters at the WTP. Turb idity, runtime, and level of the fi lters w as being mon itored, but flo w w as not monitored or r eco r ded. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location : City of Stillwater Public Water System City of Sti llwater I County: Payne I State: Oklahoma MIidiy Aullllwe Flow L~ TurlJllltyAlirms Are Enabled Photograph 2. 6/4/2024 12:44 PM DSCN0658.JPG WTP SCADA Screen View of the City1s SCADA screen showing the status of the four newer filters at the WTP. Turb idity, runtime, and level of the fi lters was being monitored, but flow was not monitored or reco r ded. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: City of Stillwater Public Water System City of Sti llwater I County: Payne IState: Oklahoma -- -- L i!B',n Ffi 6 fT MB:%& 3B FT 10,$ 5PSI Erif Pt \iAl 15 O Photograph 3. 6/4/2024 12:38 PM DSCN0655.JPG WTP SCADA Screen View of the City's SCADA screen showing an overview of operations at the WTP. The "Intrusion Alarm System" panel was highlighted with a red border, and the reason was unclear to the EPA Inspection Team. This photograph was taken prior to the EPA Inspection Team walking through the WTP. The SCADA screen showed that the fluoride feed system and ch lorine feed scrubber system were d isabled during the inspection. The South solids contact unit (SCU) was offl ine during the inspection, but the SCADA screen did not reflect that. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location : City of Stillwater Public Water System City of Sti llwater I County: Payne I State: Oklahoma Extra Motor Photograph 4. 6/4/2024 2:15 PM IMG_00Sl.JPG WTP, North SCU View of the deck in the m iddle of the North SCU. There was an extra motor positioned on the operational deck, and System representatives stated that the motor had been changed a few months before the date of the inspection. Following the inspection, System representatives stated via emai l that the pump motor had been removed from the deck. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: City of Stillwater Public Water System City of Stillwater I County: Payne I State: Oklahoma 1 GEAR OIL SAE Photograph 5. 6/4/2024 2:15 PM DSCN0717.JPG WTP, North SCU View of a bucket of gear oil that was positioned on the deck in the center of the North SCU. There was no NSF label on the gear oil, and a search of the NSF website showed that the oil was not listed as NSF certified. The label described the substance as an "automotive gear lubricant" used in cars and trucks. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: City of Stillwater Public Water System City of Stillwater I County: Payne IState: Oklahoma Photograph 6. 6/4/2024 2:04 PM IMG_0063.JPG WTP, South SCU View of one of the effluent troughs of the South SCU. The South SCU was offline during the inspection. A smal l volume of water was entering the unit due to a faulty valve. This water was not treated with lime and was blended with treated waters from the Northern and Central SCUs. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location : City of Stillwater Public Water System City of Sti llwater I County: Payne I State: Oklahoma Photograph 7. 6/4/2024 2:05 PM IMG_0064.JPG WTP, South SCU View of the operational deck in the m iddle of the offline South SCU . The motor for the rake arm appeared to be supported by a strap, and there was a bucket of gear oil sitting on the deck. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: City of Stillwater Public Water System City of Stillwater I County: Payne I State: Oklahoma Photograph 8. 6/4/2024 2:21 PM IMG_0069.JPG WTP, Recarbonization Basin View of water weeping through concrete cracks in the northwest corner of the recarbonization basin. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location : City of Stillwater Public Water System City of Sti llwater I County: Payne I State: Oklahoma Photograph 9. 6/4/2024 2:29 PM DSCN0722.JPG WTP, Filter Effluent Wet Well View of the effluent wet well that was positioned after the fi lters. The hatchways to the wet well lacked sanitary seals, and there was water ponding on the roof near the hatchways. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 10. 6/5/2024 5:21 PM 20240605_172110.JPG WTP, Filter Pipe Gallery Vault (Confined Space, photo taken by System representatives) View of the inside of filter pipe gallery vault. The IFE turbidimeters were positioned inside of the vault. The vault was unable to be entered by the EPA Inspection Team due to confined space requirements. System representatives stated that the vault was only entered once per month due to confined space conditions making the vault difficult to access. (Photo provided by System representatives following the inspection). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 11. 6/5/2024 5:33 PM 20240605_173323.JPG WTP, Filter Pipe Gallery Vault (Confined Space, photo taken by System representatives) View of one of the IFE turbidity meter sample hoses that had an air gap, resolving a deficiency identified in the 2019 OK DEQ sanitary survey. (Photo provided by System representatives following the inspection). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State: Oklahoma Photograph 12. 6/5/2024 8:16 AM IMG_0003.JPG WTP, Ozone Basin View of a crack on the concrete roof of the ozone basin at the WTP. There w ere mu ltiple cracks on the roof of the basin, and it appeared that the cracks had been fi lled in the past, but there w ere fai lures in the new cau lking as w ell. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 13. 6/5/2024 9:11 AM DSCN0779.JPG WTP, Final Chemical Injection Vault View of the final chemical injection vault where ammonia and chlorine are injected upstream of the onsite clearwell. There was a strong ammonia smell surrounding the vault, and the vault was full of water, leaving the injection lines completely submerged. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State : Oklahoma Photograph 14. 6/11/2024 2:07 PM 20240611_140751.JPG WTP, Clearwell View of a hatchw ay on the roof of the 4.0 MG clea rwel l. The hatchw ays w ere not " shoe box" design, rather they were uti lity vault entry type design. The rubber gasket around the outside of the hatchw ay had fa llen off in places, and it is unknow n if a watertight sea l exists. (Photo provided by System representatives follow ing the inspection). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State : Oklahoma ,(auuao aa, aA;1e1uas~daH swe!ll!M :L ~Jo:, a1111e~uas,udal1 ue6meH w1r .1011was vLOV. >fO ~aJSMll!~S q19 at.OJ. uo!l""'l"uo:, a 1a,::,uo:, uaunuu1>1 ;A :>ll'lJUO_o No Secondary Containment Photograph 15. 6/5/2024 9:01 AM DSCN0773.JPG WTP, High Service Pump Station View of multiple chem ical barrels in the high service pump station that were not being stored on secondary containment. The chemica l barrels appeared to be empty at the t ime of the inspection . UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: City of Stillwater Public Water System City of Stillwater I County: Payne I State: Oklahoma Photograph 16. 6/5/2024 9:05 AM DSCN0777.JPG WTP, High Service Pump Station View of the POE chlorine analyzer. The analyzer was reading 3.60 mg/L at 9:05 a.m. on the morning of June 5, 2024. There was a preventative maintenance sticker from Hach on the analyzer that showed that it was last serviced on April 10, 2024. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 17. 6/5/2024 9:55 AM IMG_0057.JPG North Perkins Water Tower View of the concrete splash pad next to the overflow at the North Perkins Water Tower. The pad was offset, and water appeared to be draining toward the foundation of the tank. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State: Oklahoma Photograph 18. 6/5/2024 9:56 AM IMG_0058.JPG North Perkins Water Tower View of t he end of the overflow pipe at the North Perkins Water Tower. The flex gate covering the overflow line of the North Perkins Wate r Tow er did not form a tight seal. There w as an approximately 0.5-inch gap betw een the end of the pipe and the flex gate. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 19. 6/5/2024 10:21 AM DSCN0804.JPG Manning Pump Station View of a threaded hose tap without backflow prevention extending on the pump line at the Manning Pump Station. The pump station was offline during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 20. 6/5/2024 10:20 AM DSCN0800.JPG Manning Pump Station View of the two pumps inside of the Manning Pump Station. The pump on the right side of the image was inoperable at the time of inspection, leaving only one functional pump in the pump station. The pump station was offline during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 21. 6/5/2024 10:33 AM IMG_0079.JPG.JPG Third and Stallard Water Tower/Pump Station View of the perimeter fence surrounding the Third and Stallard Water Tower and pump station. There was vegetation growing over/against the fence, creating a security threat. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State: Oklahoma Photograph 22. 6/5/202410:45 AM IMG_0094.JPG Third and Stallard Water Tower View of pond ing wate r next to the base of the Th ird and Sta llard Water Tower. The ground sloped tow ard t he tank foundation in places. Areas of the caulking between the tank bottom plate and foundation had failed. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State : Oklahoma Photograph 23. 6/5/2024 10:48 AM DSCN0828.JPG Third and Stallard Water Tower View of the concrete splash pad next to t he end of the overfl ow pipe at the Third and Sta llard Water Tower. The pad was offset, and w ater appeared to be dra ining towar d the foundation of the tank. Also visible in th is image is t he flex gate at the end of the overflow pipe. The flex gate did not form a tight seal, and ther e w as an approximately 1-inch gap betw een the end of the pipe and the flex gate. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 24 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 24. 6/4/2024 10:50 AM IMG_0098.JPG Third and Stallard Water Tower View of golf balls and broken glass next to the base of the Third and Stallard Water Tower. System representatives stated that the residents of the house directly next to the tank would throw bottles over the fence against the side of the tank, and that people would hit golf balls toward the tank. System representatives also stated that the police had dealt with the security issues coming from the house next to the tank. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 25 Location : City of Stillwater Public Water System City of Sti llwater I County: Payne I State : Oklahoma PSI lndu:ator flowMetl!f" v v t/ I/" V I/ Photograph 25. 6/5/202410:35 AM IMG_0082.JPG Third and Stallard Pump Station View of a "Pump Station Checks" sheet outlining a pump fa ilure that occu rred in May 2024. The correct ive ma intenance activities that were conducted on the pump are not maintained in a work order system, and the notes lack specific detail of the ma intenance that was actual ly conducted. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 26 Location : City of Stillwater Public Water System City of Sti llwater I County: Payne I State: Oklahoma Photograph 26. 6/5/2024 10:37 AM DSCN0819.JPG Third and Stallard Pump Station View of a threaded hose tap without backflow prevention that extended off of one of the pump lines inside of the Third and Stallard Pump Station. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 27 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 27. 6/5/2024 10:40 AM IMG_0089.JPG Third and Stallard Pump Station View of an additional threaded hose tap at the Third and Stallard Pump Station that had a hose attached to it. The hose did not have backflow prevention. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 28 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State: Oklahoma Photograph 28. 6/5/2024 10:38 AM DSCN0820.JPG Third and Stallard Pump Station View of one of the pump lines inside of the Third and Stallard pump station. A suction side pressure gauge w as missing from the li ne. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 29 Location : City of Stillwater Public Water System City of Sti llwater I County: Payne I State: Oklahoma Photograph 29. 6/5/2024 11:45 AM DSCN0838.JPG South Perkins Road Pump Station View of an air rel ief port that was missing a downturned exhaust line. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 30 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 30. 6/5/2024 12:14 PM DSCN0845.JPG 32nd St. Pump Station View of two of the pumps inside of the 32nd St. Pump Station. The impellers of the pump on the right were spinning in reverse when the EPA Inspection Team arrived, and it was discovered that there was a failure with the check valve on the pump discharge line. The check valve on the discharge pump line to the left of the image was making a periodic clicking noise, and the reason was unknown. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 31 Location : City of Stillwater Public Water System City of Sti llwater I County: Payne I State: Oklahoma UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 32 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 32. 6/5/2024 1:00 PM IMG_0146.JPG S Western Road Flushing Line View of an above ground flushing line that was positioned approximately 100 yards south of the intersection of S. Western Road and W. 32nd Avenue. System representatives stated that the line was attached to a finished water transmission line running parallel to the road. There was a rubber hose attached to the end of the PVC line. System representatives stated that the hose was being used to divert water away from the concrete platform to prevent erosion. The hose extended several feet through the woods and into a stream flowing through a plastic corrugated pipe that extended under the road. This image was taken on June 5, 2024, the second day of the inspection. Google Earth street view imagery from S. Western Road shows that the hose was attached to the flushing line when the image was taken in March 2022 (refer to Appendix 2, Exhibit 5, Flushing Line Photo - March 2022). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 33 Location: City of Stillwater Public Water System City of Sti llwater I County: Payne I State: Oklahoma Photograph 33. 6/5/20241:01 PM IMG_0147.JPG S Western Road Flushing Line View of the valve box associated with the flushing line next to S. Western Road. Note, the cover of the valve box was offset, and the valve was in the "open" position allowing water to flow through the flushing line. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 34 Location : City of Stillwater Public Water System City of Sti llwater I County: Payne I State: Oklahoma Photograph 34. 6/5/20241:02 PM IMG_0149.JPG S Western Road Flushing Line View of the rubber hose that was attached to the above ground PVC flushing line. The hose extended several feet t hrough the woods and terminated in a below ground plastic corrugated pipe that extended under the road and had water running through it. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 35 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State : Oklahoma Photograph 35. 6/5/20241:02 PM IMG_0150.JPG S Western Road Flushing Line View of the rubber hose that w as attached t o the PVC flush ing line next to S. Western Road extending into a below gr ound plastic corrugated pipe that extended under the road and had w ater running through it. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 36 Location : City of Stillwater Public Water System City of Sti llwater I County: Payne I State: Oklahoma Photograph 36. 6/5/20241:03 PM IMG_OlSl.JPG S Western Road Flushing Line View of the rubber hose that was attached to the PVC flushing line discharging approximately eight feet into the corrugated pipe into a stream . UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 37 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State: Oklahoma Photograph 37. 6/5/20241:05 PM IMG_0152.JPG S Western Road Flushing Line View of the quick connector at the end of the rubber hose that w as elevated above the stream by approximately ten inches. The hose was fi lled with w ater, and some water w as spi ll ing out of the end of the pipe. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 38 Location : City of Stillwater Public Water System City of Sti llwater I County: Payne I State: Oklahoma Photograph 38. 6/5/20241:05 PM IMG_0153.JPG S Western Road Flushing Line Additiona l view of the quick connector at the end of the rubber hose that was elevated above the stream by approximate ly ten inches. The hose was filled with water, and the water was overflowing from the hose into the stream. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 39 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State : Oklahoma Photograph 39. 6/5/20241:06 PM IMG_0154.JPG S Western Road Flushing Line Close-up view of water being released from the quick connector at the end of t he rubber hose. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 40 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 40. 6/5/2024 1:07 PM IMG_0155.JPG S Western Road Flushing Line View of water being released from the quick connector at the end of the rubber hose after the inspector had lifted the hose to see if water would collect in the hose, and then set the hose back down. The water being released had collected in the hose while the hose was being held up at approximately 10 inches above stream. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 41 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State : Oklahoma Photograph 41. 6/5/20241:08 PM IMG_0156.JPG S Western Road Flushing Line View from behind the hose of water being released from the quick connector at the end of the r ubber hose after the inspector had lifted the hose to see if w ater w ould co llect in the hose, and then set the hose back dow n. Agitation from the releasing w ater can be seen in t he receiving stream. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 42 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 42. 6/6/2024 12:17 PM IMG_0123.JPG S Western Road Flushing Line View of the above ground flushing line that was positioned next to S. Western Road, taken on June 6, 2024, the third day of the inspection. The image was taken after the observation regarding the hose/potential cross connection was made to System representatives. The plastic piping that had connected the PVC flushing line to the rubber hose had been broken off. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 43 Location : City of Stillwater Public Water System City of Sti llwater I County: Payne I State: Oklahoma Photograph 43. 6/6/202412:20 PM IMG_0124.JPG S Western Road Flushing Line View of the valve box associated with the flush ing line next to S. Western Road. This image was taken on June 61 2024, after the potential cross connection was observed. The lid of the valve box was properly closed. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 44 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 44. 6/6/2024 12:20 PM IMG_0125.JPG S Western Road Flushing Line View of the rubber hose that had been attached to the PVC flushing line the day prior to this image being taken (June 5, 2024). It appeared that distribution team members had cut the hose and left it in the woods after the potential cross connection had been observed. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 45 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 45. 6/6/2024 12:22 PM IMG_0126.JPG Air Relief Valve Release Pipe View of an air relief valve relief pipe that extended off the distribution system. The pipe was located approximately 50 yards from the S. Western Road flushing line with hose. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 46 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 46. 6/6/2024 12:26 PM IMG_0127.JPG Air Relief Valve Release Pipe View of the underground components associated with the air relief pipe seen in the above image. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 47 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State: Oklahoma Photograph 47. 6/6/202412 :30 PM IMG_0129.JPG Flushing Line View of an addit ional above ground flush ing line in the distribution system. Th is line had a secure cap over the open ing w hi le the line w as not in use . UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 48 Location : City of Stillwater Public Water System City of Sti llwater I County: Payne I State: Oklahoma Photograph 48. 6/5/20241:47 PM IMG_0167.JPG 44th St. Water Tower View of the end of the overflow pipe extending from the 44t h St. Water Tower. The pipe was m issing a flex gate and the mesh screen coveri ng the pipe was ripped. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 49 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 49. 6/5/2024 1:49 PM IMG_0171.JPG 44th St. Water Tower View of the drainpipe from the floor inside of the 44th St. Water Tower that extended outside of the water tower. The flex gate covering the drainpipe appeared to have been wired open in past, allowing black insects to enter the pipe. After this observation was made, the wire was removed, and the flex gate was seated tightly over the end of the drainpipe. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 50 Location: City of Stillwater Public Water System City of Sti llwater I County: Payne IState: Oklahoma Photograph 50. 6/5/2024 2:03 PM IMG_0176.JPG 44th St. Water Tower View inside of the meter vau lt next to the 44th St. Water Tower. The meter vau lt had one inch of standing water inside of it, but staining on the walls of the vau lt indicated past water level heights of 12-16 inches high. It was unclear why the vault was flooding, since a sump pump was present inside of the vault. The high water marks inside of the vault were approximate ly 12 inches from an electrica l out let inside of the meter vault. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 51 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State: Oklahoma Photograph 51. 6/5/20241:56 PM IMG_0181.JPG 44th St. Water Tower View of a th readed hose tap without backflow prevention on one of the lines inside the base of the 44th St. Water Tow er. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 52 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 52. 6/5/2024 1:58 PM IMG_0182.JPG 44th St. Water Tower View of a control panel inside of the base of the 44th St. Water Tower. The panel had heavy moisture due to the humidity inside of the base. The EPA Inspection Team had the City representatives open the control panel, and the inside was dry. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 53 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 53. 6/5/2024 3:06 PM DSCN0906.JPG West Highway 51 Pump Station View of one of the pressure gauges on the suction side of one of the pump lines was not functional. An operator opened both valves and a sample tap on the line to verify that water was flowing through the discharge line, and it was confirmed that the line was pressurized even though the pressure gauge was reading <0 psi. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 54 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma 15: 0 Photograph 54. 6/5/2024 3:40 PM DSCN0912.JPG Washington and Liberty Pump Station View of one of the pumps and pump lines inside of the Washington and Liberty Pump Station. The pump line was missing both suction and discharge side pressure gauges. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 55 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 55. 6/5/2024 3:41 PM DSCN0914.JPG Washington and Liberty Pump Station View of a threaded hose tap without backflow prevention on the pump line inside of the Washington and Liberty Pump Station. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 56 Location: City of Stillwater Public Water System City of Stillwater I County: Payne IState: Oklahoma 15.248 p 7 Photograph 56. 6/5/2024 3:46 PM DSCN0917.JPG Washington and Liberty Pump Station View of a pressure gauge on the wa ll inside of the Washington and Liberty Pump Station that was reading 15.248 psi at 3:46 p.m. on June 5, 2024. System representatives could not confirm where the pressure read ing was coming from, but it appeared that the pressure was being read from the suction line entering the pump station. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 57 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State: Oklahoma Photograph 57. 6/5/2024 3:54 PM DSCN0924.JPG Washington and Liberty Water Tower View of deteriorated caulking and mortar between the metal bottom plate of the Washington and Liberty Water Tow er and the concrete base. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 58 Location: City of Stillwater Public Water System City of Stillwater I County: Payne IState: Oklahoma Photograph 58. 6/5/2024 3:56 PM DCSN0928.JPG Washington and Liberty Water Tower View of the end of the overflow pipe for the Washington and Liberty Water Tower. The end of the pipe was approximately 2 inches above the concrete splash pad. Also visible in this image is the flex gate at the end of the overflow pipe that was not seated properly. There was an approximately 1-inch w ide gap between the flex gate and the pipe. There were animal/insect nests inside of the overflow pipe. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 59 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State: Oklahoma Photograph 59. 6/5/2024 3:56 PM DCSN0929.JPG Washington and Liberty Water Tower View of the inside of the overflow pipe at the Washington and Liberty Tower. There were insect/animal nests inside of the pipe, and it appeared that the mesh screen had ripped and fallen off. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 60 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 60. 6/6/2024 8:45 AM IMG_0008.JPG Yost Pump Station View inside of the Yost Pump Station vault. The pump lines lacked air relief ports and downturned exhaust lines. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 61 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 61. 6/6/2024 8:49 AM DSCN0934.JPG Yost Pump Station View of the suction side pressure gauge at the Yost Pump Station that was showing a pressure that appeared to be just below 25 psi (based on photographic imagery from outside the confined space of the vault). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 62 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 62. 6/6/2024 8:57 AM DSCN0937.JPG Yost Pump Station View of a hill slope behind the Yost Pump Station. It appeared that water flowed down the slope toward the pump station during rain events. There was erosion behind and next to the pump station. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 63 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State : Oklahoma Photograph 63. 6/6/2024 9:07 AM DSCN0942.JPG Yost Water Tower View of moisture that w as accumulating at the metal base of the Yost Water Tow er and the concrete pad that the tank was sitting on. It appeared that the tank was leaking from the base plate, but th is w as unable to be verified. The base of the tank lacked cau lking or a seal. Also visible in t his image is ponding that w as occurring around the tan k foundation. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 64 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State : Oklahoma Bolt and Nut Moisture Photograph 64. 6/6/2024 9:08 AM IMG_0032.JPG Yost Water Tower Close-up view of moisture that w as accumulating at the bottom plate of the Yost Water Tower. Also visible in th is image is a structura l bolt and nut that did not appear to be prope rly seated on the tank anchor. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 65 Location : City of Stillwater Public Water System City of Sti llwater I County: Payne I State: Oklahoma Photograph 65. 6/6/2024 9:10 AM IMG_0031.JPG Yost Water Tower View of a ladder that was sitting on the ground next to the base of the Yost Water Tower. It was unknown what the ladder was used for. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 66 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 66. 6/6/2024 9:10 AM DSCN0945.JPG Yost Water Tower View of the terminus of the overflow pipe of the Yost Water Tower. There was no splash pad beneath the pipe, but the top of a plastic barrel had been placed under the pipe to protect the tank's discharge valve from cow's scratching activities. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 67 Location : City of Stillwater Public Water System City of Sti llwater I County: Payne I State: Oklahoma UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 68 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 68. 6/6/2024 9:28 AM DSCN0950.JPG Ricebeck Water Tower View of the Ricebeck Water Tower and the perimeter fence that surrounded it. The tower lacked a local level indicator and was also not tied telemetrically to SCADA. The barbed wire at the top of the fence was damaged/missing in places. The water tower was offline during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 69 Location: City of Stillwater Public Water System City of Sti llwater I County: Payne IState: Oklahoma Photograph 69. 6/6/2024 9:30 AM IMG_0039.JPG Ricebeck Water Tower View of the base of Ricebeck Tower. The ground was sloping toward the concrete foundation of the tank, and the concrete was leve l with the ground in some areas. Multiple structura l bolts and nuts did not appear to be properly seated on the tank anchors. Cau lking and mortar was also missing in some areas between the bottom plate of the tank and the concrete foundation. The water tower was offline during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 70 Location: City of Stillwater Public Water System City of Stillwater I County: Payne I State: Oklahoma Photograph 70. 6/6/2024 10:03 AM DSCN0962.JPG Tan-Tara Water Tower View of the vegetation that was growing on/over the perimeter security fence at the Tan-Tara Water Tower. The water tower was offline during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 71 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 71. 6/6/2024 10:15 AM IMG_0049.JPG Tan-Tara Water Tower View of the meter vault that was positioned next to the Tan-Tara Water Tower. The vault was completely flooded during the inspection, submerging the assets inside of the vault. The water tower was offline during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 72 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State : Oklahoma Photograph 72. 6/6/2024 10:04 AM DSCN0966.JPG Tan-Tara Water Tower View of the meta l bottom plate of the Tan-Tara w ater tower. There w as caulking missing betw een the bottom plate of the tank and the concrete foundation . The w ater tow er w as offline during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 73 Location: City of Stillwater Public Water System City of Stillwater I County: Payne IState: Oklahoma Photograph 73. 6/6/2024 10:08 AM DSCN0968.JPG Tan-Tara Water Tower View of an open pipe that provided direct access into the water tower. A broken ball valve (three components) were sitting next to the open pipe. Insects were observed crawling around and into the pipe. The water tower was offline during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 74 Location: City of Stillwater Public Water System City of Stillwater I County: Payne IState: Oklahoma Bolt and Nut Photograph 74. 6/6/202410:36 AM IMG_0068.JPG Coyle Water Tower View of the Coyle Water Tower base. Multiple structural bolts and nuts did not appear to be properly seated on the tank anchors. Caulking and mortar was also missing in some areas between the bottom plate of the tank and the concrete foundation. The water tower was offl ine during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 75 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 75. 6/6/2024 10:36 AM DSCN0978.JPG Coyle Water Tower Close-up view of one of the structural bolts and nuts that did not appear to be properly torqued down. There was also some corrosion/chipping paint around the tank anchor. The water tower was offline during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No . 76 Location : City of Stillwater Public Water System City of Sti llwater I County: Payne I State: Oklahoma Bol and Nu olt a d Nut Photograph 76. 6/6/202410:37 AM IMG_0069.JPG Coyle Water Tower View of a temporary discharge pipe that was attached to the tank, as well as additional bolts and anchors that were not seated properly. The water tower was offline during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 77 Location: City of Stillwater Public Water System City of Stillwater I County: Payne IState: Oklahoma Photograph 77. 6/6/2024 10:38 AM IMG_0076.JPG Coyle Water Tower View of a threaded hose tap without backflow prevention that was present at the Coyle Water Tower. The water tower was offl ine during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 78 Location: City of Stillwater Public Water System City of Stillwater County: Payne State: Oklahoma Photograph 78. 6/6/2024 10:38 AM DSCN0979.JPG Coyle Water Tower View of the damaged/missing perimeter fence surrounding the Coyle Water Tower. Parts of the fence had been removed due to ongoing construction that was occurring at the Water Tower. The water tower was offline during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 79 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State : Oklahoma Photograph 79. 6/6/202410:53 AM IMG_0084.JPG Karsten Creek Pump Station View of a th readed hose tap w ithout backflow prevention that was present at the Karsten Creek pump station. Also visible in this image is heavy corrosion at t he base of the vau lt , causing the potential for structural fa il ures and flooding of equipment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 80 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State : Oklahoma Photograph 80. 6/6/2024 11:25 AM DSCN0992.JPG Hilltop Pump Station View of the inside of t he Hilltop Pump Station vau lt. There w ere voids in the concrete w alls sur round ing the pump line. The voids created a possible entry point for w ater into the pump station vau lt, and the electric motors for the pumps w ere posit ioned near the base of the vau lt. The pump station w as offli ne. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 81 Location : City of Stillwater Public Water System City of Sti llw ater I County: Payne I State: Oklahoma Photograph 81. 6/6/202411:57 AM DSCN1008.JPG Central Water Tower View of a threaded hose tap w ithout backflow preventi on inside of the Central Water Tower. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 82 Location: City of Stillwater Public Water System City of Stillwater I County: Payne I State: Oklahoma Photograph 82. 6/6/2024 11:44 AM DSCN0998.JPG Central Water Tower View of the end of the overflow pipe extending from the Central Water Tower. The pipe was downturned and contained a mesh screen but was missing a flex gate. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 83 Location: City of Stillwater Public Water System City of Stillwater I County: Payne IState: Oklahoma Photograph 83. 6/6/202411:45 AM DSCNl000.JPG Central Water Tower View of the ground at the base of the Central Water Tower. The ground sloped toward the concrete foundation of the tank in areas, and it appeared that ponding would occur in the area next to the concrete foundation. City of Stillwater PWS ID No. OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Appendix 2 Exhibit Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Exhibit Log Exhibit 1 City of Stillwater WTP Process Flow Diagram StlllwaterWatar Traabnent Plant PWSID# 1021220 Stillwater Oklahoma Recovered Water .. 4 MG Raw Watarj Ground Storaae : , Tank Sample I SIie 1 " ' ~ "- Meter Vault North 1 Solids Colltact Unlt ! I .L ..,.. VaUlt Middle 1 Solids Contact Uni _L ~ .. Meter ~ Vault ~ ,... South i. 1, l .. Solids I Contact unit I -e CO2 i 1~ Chlorine Alum PolYmer Ammonia Lime r.. Chlorine ,. Poll/mer (non-ionic) ... FIiter Filter Altar Filter Filter illter r... Cellt, CeD~2 Cell t3 Celll-4 Cellf 5 eente .. FIiter FIiter Filter FIiier Filer Fllt8r Cell#7 Cell#8 Cel1#9 Cellf 10 CeU#1 1 Cellt12 Ii Ozone Buln Ozone Baa11 ~ ;,. Ozone Kaw I.Ilka RNHvolr ,1, e--- , Recovenld Wlllr ' (7) La&oone ~- I - h I i f0 :, u: 8 \I, .J, ~ ~ n,::c.._ 3.5 MG Ground Stortge Tank I ' i "' - I, w Oialribution Pumps I Chlorine (post) 4 - I.OW~ 3-HIIJhSemc;e ., To Distribution Swte m UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Exhibit Log Exhibit 2 Stillwater Initial Non-Compliance Response - January 29 2020 Departmen t of W ater Utilities 723 S. Lewis Street/P.O Box 1449 Stillwater, OK 74076-1449 ?/f/Jr '4J// ,a,,,,, tt;~~? Office: 405.742.8325 Web: slillwater.org January 29, 2020 CERTIFIED M AIL, RETURN RECEIPT REQUESTED David Mercer, P.E., District Engineer Public Water Supply Engineering and Enforcement Section Water Quality Division Re: Sanitary Survey on April 23-25, 2019 - Final Report Response PWID No. OK1021220 Dear Mr. Mercer: "n)'~'ir-'Ni?\15i JJJ->-~~- ~_!, \o/. JAN ~ 1 l ~20 WATER QUALffY UiVISION This is the City of Stillwater Utilities Authority (Authority} response to the final report of the sanitary survey public water supply (PWS) system on April 23-25, 2019 and received December 30, 2019. The purpose of the sanitary survey was to Identify existing sanitary deficiencies, verify compliance with state and federal regulations, and benchmark system performance. The Sanitary Survey performed is a mandated component of the Safe Drinking Water Act and consisted of an evaluation of the following eight elements: Water source; Pumps, pumping facilities, and controls; Water treatment; Monitoring, reporting, and data verification Distribution system; Water system management and operation; and Finished water storage; Operator compliance wit h state requirements. DEFICIEN CIES The sanitary deficiencies identified by DEQ during the inspect ion are listed below in one of two categories: deficiencies requiring a schedule for correction and deficiencies not requiring a schedule for correction at t his time. As explained in the conclusion of the Final Report, deficiencies requiring a schedule for correction and labeled as significant have been given Immediate attention for remediation according to 40 CFR and/or OAC 252:626 and OAC 252:631. Deficiencies Requiring a Schedule for Correction The sanitary deficiencies which require a schedule for correction are as follows: Water Source - None Identified. Pag 2 of Wate r Treatment Deficiency Significant - The stalnles.~ steel hatches on top of th e ozonation basin were not atcrtight. Re ponse New Ml were ordered, received and mstallotion was completed on January 27, 2020. De fi ciency - l'h re was not an air gap between the turbidimeler effluent lines and the collection lateral into which theydrain . Response R pairs/adjustments ro establish on air gop were completed by staff on January 3, 2020. Deficiency There was not an air gap or backflow protection device between the nuoride mixing tank and the finished water line which supplies it. Response Bock/low prorecrion was added to the influent and effluent supply lines on January 09, 2020. Adjustments to the float votve were mode on January 23, 2020 ro establish an air gap berween the flu oride mixing tonk ondfinished water line. Monitoring of rhe air gap was added w regular maintenance checks ta assure the Olf gap is consisrent. Deficiency - The log inactivations of Giordio and viruses were not being calculated ro11tinely, as a part of process control, to know what adjustments should be made t-0 tile 01onacion process. Response The lag Inactivation calculation spreadsheet was updated lo include the ozonation process and is being colculoted routinely by staff. The updated version was sent to David Mercer via email on January 13, 2020. Deficiency - The water treatment plant (WTP) did not have adequate f locculation capacity (with a/J units in service, or one unit out or service) or sedimentation capacity (with one unit out of service) to supply the historical maximum daily demand of 12.1 million gallons per day (MGD). Response The north SCU was not ;n operation dur;ng the Survey, but is used during periods of higher demand (summer months). SUA believes that the SCUfacilities were constructed (and ore operated) in compliance with ODEQ regulations and the approved permits in the early 1980's and mid 1990's. Please let us know if the OOEQ comment refers ra some other issue. De ciency - The individual filter effluent flow meters were not operational Response The existing units are non-repairable and replacement in the existing location is impractical due to space, dimensional and canftgurolion issues of replacement units. The Authority is currently under corn race with Black and Veatch (8& VJ to evaluate ancJ design improvemencs Jar Che water Treatment Plant which includes on entirely newfilter complex. This contract and improvements ore expounded on ot the end of this response report, Deficiency - The individual filters were not equipped with differential pressure-tell devices to monitor headloss across the filter media beds. filters were only equipped with a single device per filter (some of the radar type and some of the pressure transducer type) which measure water depths in the filter box. WI ere the COLLEG atmosphere and COWBOY spirit make everything come AllVE. r Pag 3 of 6 Response level indicators were installed to measure the depth of water in the filter beds in mid-April of 2019. Deficiency The filters did not have individual rate-of-flow controllers. (Each bank of filters had a manually-controlled valve and each filter had an on/off (non -variable) automated valve.) Response The Authority is currently under contract with B& V to evaluate and design improvements for the Water Treatment Plant which includes anew filter camp/ex. Deficiency There were not day tanks for the cationic polymer, ferric sulfate, or fluoride. Response Polymer -A day tank was established on November 07, 2019 and is in use. Ferric Sulfate - Two (2} tanks are utilized and ore operated so that one serves as a day tonk. Fluoride - The existing sodium silicof/uoride dry-type feed system will be replaced with a hydrofluorosi/i'cic acid liquid-type feed system. The proposedfeed system will consist of a bulk tank, trans!er pumps, a day tank, and metering pumps with water supply in-line chemical injection. Deficiency - The residuals ponds did not have at least 3 feet of free board and at least 2 feet of water depth between the water surface and the accumulated residuals. Response The residual ponds all currently have 3 feet or greater offreeboard. Cleaning the residuals ponds is scheduled to begin as weather ond soil conditions permit. Deficiency - The residuals ponds were not being managed to prevent the growth of unwanted vegetation, such as cattails and trees . Response Vegetation removal has started and is on-going. Deficiency - The Authority did not have a current DEQ-approved residuals management plan. Response Stillwater Utility Authority believes we have been operating the WTP as permitted in approx;mately 1980. Please let us know when the regulation to hove a residuals management plan become effective, haw the regulation stipulated implementation for existing WTP, and whether we have on outdated pion, so that we con assess how to move forward. Distribution System Deficiency - The volume of elevated water storage was less than the average daily demand. (While backup power sources may be used as an alternative means to satisfy the elevated water storage requirement, the Authority did not have adequate backup power sources either.) Response The Authority added 2 MG of storage In the lost year through the Water 2040 program. One (1) mobne backup generator cvrrently exists with two (2) backup mobile generators an order, expected to be delivered, field tested and ready for use by the end of June 2020. This new total of three (3) mobile generators is capable of supporting 6 MG in ground storage The Authority also hos o stationary backup generator project in construction at the Water Treatment Plant that will add backup power ot the plant (completion expected in Foll 2020) Jar running the fin ished water pump station which odds 6 MG of storage co the dis tribution system. Wh re the COLLEG atmosphere nd COWBOY spirit make everything come ALIVE Page 4 of 6 Finished Water Storage Deficiency Significant- The stainless steel hatches for the concrete clearwell did not appear to be watertight. Response New seols were ordered, received and installation was completed an January 17, 2020. Deficiency Significant - The roof of the steel clearwel/ was not watertight. (The roof was compromised with small holes formed as the result localized corrosion.) Response The City has engaged Jacobs Engineering for design of a new Finished Water Pump Station and Cleorwe/1 Replacement Project. The project is ~2s% complete, and the Engineering Report will be submitted to ODEQ as soon as o final version is available. Deficiency Significant- The vent of the steel clearwell was not protected with 24-mesh and was not down-turned (was completely vertical.) Response The vent of the steel clearwe/1 is a non-downturned style roof vent system and is currently protected with 24-mesh. Deficiency - The steel clearwell hatch was not locked. Response A lock was installed on the clearwe/1 hatch January 7, 2020. Deficiency Significant - The Range Road Tower vent was not equipped with 24-mesh screen or down-turned. (Drone footage indicates expanded metal was used to cover the vent opening and was capable of keeping out birds but not insects.) Response The Range Rood vent is o non-downturned style roof vent system and is currently protected with 24mesh. Deficiency - The Stallard Tank vent was not equipped with 24-mesh screen. (Drone footage indicates expanded metal was used to cover the vent opening and is capable of keeping out birds but not insects.) Response The Stallard Tank vent is a McGuire 24" Fail/Safe Roaf Vent System that includes 24-mesh. It replaced an alder vent in 2012. Pumps, Pumping Facilities, and Controls Deficiency - The air-relief valve at the Highway 51 Pump Station was not equipped with 24-mesh screen. Response The 24-mesh screen was ordered, received, and installation was completed on January 15, 2020. Monitoring, Reporting, and Data Verification Where the COLLEGE atmosphere and COWBOY spirit make everything come ALIVE. Pages of G Oefi n V TI1e Lead and Copper Rule samrilesites were not Individually categorized as being Tierl, Tier2, or Non -tier i\e!>. Response Soi ip/mg and analyses far Lead and Copper records were found far 2003 to 2018 for numerous res lden tiol /oco tions. However, the locations in the ODEQ approved sampling plan, and on SDWIS, were not categorized into individual tiers . The Authority's ;nrentlon is to comply with the forthcoming leod and Copper Rule update. Water System Management and operation - None identified Operator Compliance with State Requirements - None identified Deficiencies Not Requiring a Schedule for Correction at this Time Although many deficiencies were identified as 'Not Requiring a Schedule for Correction at this Time', the Authority appreciates the input to achieve complete and full compliance with the Lead and Copper Rule and the Clean Water Act. Much consideration will be given to the5e identified deficiencies and recommendations. RAW WATER LINE INFORMATION REQUEST During the sanita['f survey, DEQ did not conduct a detailed assessment of the raw water transmission line; however, the line is one of the Authority's most critical assets. Following completion of the survey; DEQ would like to obtain information concerning the state of the line and its remaining useful life, procedures the Authority has for addressing line breaks and maintenance events while keeping the City supplied with water, and plans for future replacement. As part of the Authority's response to this letter, please include raw water line information which addresses the points mentioned in this paragraph. Response The raw wa ter conveyance system was constructed in approximately 1980. The Ci ty hired Jason Consultants who conducted on extensive evaluation of the condition of the raw water line in 2013. The row water line was found to be In good condition. Steel lines are capable of lasting 100 years if they ore cothodicolly protected and rhe City's row water line hos o cathodic protection system. Inspections of the cathodic protection system hove been conducted on the line in the post, with the next one scheduled for Calendar year 2022. An additional evaluation on the Raw Water Line condition is in the Authority's Capitol Pion, including phases-for rehabilitation or replacement, as necessary. Proposed WTP Improvements To expand on Improvements at the WTP: During 2019, B&V performed various pilot studies to determine the best path forward for water treatment process improvements. SUA staff and B&V have met with ODfQ staff ro keep them informed as ta aur progress and path forward, Those pilot studies are wrapping up and draft Technical Reports are expected fn the cami11g weeks. Once final, the results will be provided ro the OFQ Where t he COLLEGE atmosphere and COWBOY spirit make everything come ALIVE. Page 6 of 6 The Ciey ofStlllwoter has a droft wrp Focllities pion Report (includes olterndtlve lnyoutsfor new chemical buil<iing(s), new filter complex ond various otherfoci/ieies) which constitutes about 10% design for the overall improvements. A new Finished Woter Pump Station Is under design by Jacobs. It will replace the existing pump batteriesfor the Northeast and Central zones, and one of the clearwells. These improvements will address some of the items noted in the ODEQ Sanitary Survey letter The SUA ore now considering alternative project delivery methods os a way to accelerate the WTP construction schedule and are also considering funding and sequencing approaches for the estimated S60 Million in proposed WTP projects. If you have any questions or concerns please get in touch with me at your convenience. Since rely, z.- \ / //f'm -q, . 7 -- i l j / ,J,IC.Y{ - / James Driskel, Director Water Utilities Department City of Stillwater Cc: Travis Mensik, Regional Manager, ECLS, DEQ Amanda Steadman, Environmental Specialist, ECLS, Stillwater DEQ Office Where the COLLEGEat mosphere and COWBOY spirit make everything come ALIVE. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Exhibit Log Exhibit 3 OK DEQ Inadequate Response Letter - June 1, 2020 SCOTT A. lllOMPSON Exerutive Directo, DIA d&::V~ 0Kl~trOMA WUIM.lN! or(WVIIOHA\Clil gu, ~11 OKLAHOMA DEPARTMENT OF ENVIRONMENTAL OUAUTl KfVIN STITT Governor June l 1020 CERTIFIED MAU. - :RETURN IU:CnPT REQlJESTED James Driskel, Water Utilities Director Stillwa er Utilities Authority P.O. Box 1449 Stillwater, OK 74076 Re: Sanitary Survey on April 23-25, 2019 - lnadequate Response Received PWSID No. OK1021220 Dear .:Mr. Driskel: On December 30, 2019, the Department of Environmental Quality (DEQ) issued the final report for the sanitary survey conducted at the Stillwater Utilities Authority's (Authority) public water supply (PWS) system on April 23-25, 2019. In the report, DEQ identified deficier;ic:ies at the Authority' s PWS system which required corrective action. Within thirty (30) days of receipt the report, the Authority was required to provide DEQ a response inchJding a schedule ofcorrection. On January 31, 2020, DEQ received an inadequate response from the Authority. In the report, the Range Road Tower vent not beiDg down-turned was identified as a significant deficiency. In its response, the Authority indicated that the vent was protecterl from rainwater and did not need to be downtumcd. After review, DEQ maintains that the current vent configuration is not acceptable and may be suscept.Jble to rainwater intrusion. The vent must be replaced or a rain guard that covers the entire mesli portion of the vent must be installed. In the report, the lack of an air gap between the fluoride mixing tank and the finished water line which supplies it was identified as a deficiyncy. Based on infonnation provided in the Authority's response, it is unclear whether the solution provided by the Authority is adequate. An air gap must be at least 6 inches or two pipe diameters in size, whichever is larger. If preferred, however, the in$tallat1on of a reduced pressure zone, backflow preventer in lieu ofan air gap would be considered acceptable. In the repon, the lack of differential pressure-cell devices to monitor headless across the individual filter media beds was identified as a deficiency. Installation of leve1 indicators docs not solve this deficiency, and instrumentation to measure headloss must be installed. k noted in the report. the Authority did not have a current DEQ-approved residuals management plan. A plan is required whenever residuals are to be removed from the lagoons, regardless of wbene,er tb.e plant was permitted. Please work with your DEQ Municipal Wastewater Engineer, Toby Harden, E.I.. to develop such a plan. 707 NORTH ROBINSON, P.O.BOX 1677, OKLAHOMA CITY. OkWlOJM 73101-1677 llf1')_11!don~pape,'!flli ..r 0 Sti!Jwater Utilities Authority PWSJD No. OKlo021220 Sanitary Survey on April 23-25, 2019- (nadequate Response Received Page 2 of2 As noted in the repot, Lead and Copper Rule (LCR) sample sites were not individually categorized as being either Tier 1, Tier 2, or Non-Tier. Please work with your DEQ Compliance Coordinator, Jennifer Alig, to categorize your lead and copper sample sites into the appropriate tiers and to update your LCR sample plan as necessary. 1n the report, several significant deficiencies were identified with the steel clearwell. First, the roofwas not watertight as a result of localized corrosion. Second, the vent was neither protected by properlysized mesh nor was the vent downtumed. While mesh screening was added to the clearwell and the clearwell itself is slated to be replaced, the deficienc ies identified were not able to be adequately dealt with in a timely manner. It has been agreed between DEQ and the Authority to remove this clearwell from service and to utilize only the second clearwell. This is an acceptable solution to resolving these significant deficiencies, and no further action regard:ing these deficiencies is requ ired by the Authority at this time. In the report, the lack of adequate flocculation capacity (i.e., with all units in service) to supply the historical maximum daily demand of 12.1 million gallons per day (MGD) was cited as a deficiency requiring a schedule for correction. After review, DEQ has decided to reclassify this deficiency as one not requiring a schedule for correction at this time. No further action regarding this deficiency is required by the Authority. If at a later date, it is found tht a lack offlocculation capacity is the cause for non-compliance with drinking water standards_ , DEQ may reconsider this reclassification at that time. While in its response, the Authority provided dates for correction for some deficiencies, the Authority failed to include da_ tes for all deficiencies which required a schedule of correction. An updated response, including a schedule ofcorrection for these deficiencies, is now required. Within thirty (30) days of receipt of this letter, the Authority must submit an updated response including the requested schedule ofcorrection. Also in the response, please provide pictures confirmingtl:>.11-t 24 mesh screening was added to the Range Road Tower and the Stallard Tank vents. If the Authority fails to provide an updated response, or if the Authority's updated response is not adequate, DEQ may proceed with enforcement actions, including the assessment of monetary penalties, to ensureocompliance. If you have any questions, you may reach me at (405) 702-8244 or write to me at the letterhead address. Sincerely, ,,,u/4,;dc__;; =- Ger Sharkness, P.E., District Engineer Pubiic Water Supply Engineering and Enforcernent Section Water Quality Division GS:MS:TA:GC:rh MW:JA:TH c: Travis Mensik, Regional Manager, ECLS, D EQ Amanda Steadman, Environmental Specialist, ECLS, Stillwater DEQ Office UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Exhibit Log Exhibit 4 Stillwater Final Non-Compliance Response - June 30, 2020 Department of Water Resources 723 S. Lewis Street/P.O. Box 1449 Stillwater, OK 74076-1449 Office: 405.742 .8325 Web: stillwater.org June 30, 2020 CERTIFIED MAIL, RETURN RECEIPT REQUESTED Ginger Sharkness, P.E., District Engineer Public Water Supply Engineering and Enforcement Section Water Quality Division Re: Sanitary Survey Inadequate Response Letter June 1, 2020 PWID No. OK1021220 Dear Ms. Sharkness: RECEIVED 'JUL Oi2020 WATER QUAUTY DMSION i.;o _ ... . This is the City of Stillwater Utilities Authority updated response as requested in your letter of inadequate response received on June 3, 2020. RANGE ROAD TOWER OEFIOENCY The Range Road Tower vent not being down-turned was identified as a significant deficiency. In its response, the Authority indicated that the vent was protected from rainwater and did not need to be downturned. After review, DEQ maintains that the current vent configuration is not acceptable and may be susceptible to rainwater intrusion. The vent must be replaced or a rain guard that covers the entire mesh portion of the vent must be installed. Response The Range Road Tower vent was upgraded with a retrofit caver that completely covetS the mesh screening on May 29, 2020. Please see below pictures of the upgrade: Stillwater Utilities Authority PWSIO No. OK1021Z20 Sanitary Survey Updated Response Page 2 of 5 AIR GAP BElWEEN THE FLUORIDE MIXING TANK ANO THE FINISHED WATER LINE DEFICIENCY The lack of an air gap between the fluoride mixing tank and the finished water line which supplies it was identified as a deficiency. Based on information provided in the Authority's response, it is unclear whether the solution provided by the Authodty t,; adequate. An air gap must be at least 6 inches or two pipe diameters in size, whichever is larger. If preferred, however, the installation of a reduced pressure zone, backflow preventer in lieu of an air gap would be considered acceptable. Response Below is a picture ofinside of the fluoride mixing tonk. The water has been turned off to show the 611 gap between the end offinished plpe and the top of the water. The adjustment to the float valve was completedJanuary 23, 2020. LACK OF DIFFER.ENTIAL PRESSURE-CELL DEVICES TO MONITOR HEADLOSS ACROSS THE INDIVIDUAL FILTER MEDIA BEDS DEFICIENCY The lack of differentia I pressure-cell devices to monitor headloss across the indiv/dual filter media beds was identified as a deficiency. Installation of level indicators does not solve this deficiency, and instrumentation to measure headless must be installed. Response The Authority hos scheduled a representative from Cogent Automatic-Engineering to visit the water treatment plont on Wednesday July 1, 2020 to perform an evaluation for installation of the required differential pr~sure-cell devises. THE AUTHORITY DID NOT HAVE A CURRENT DEQ-APPROVED RESIOUAl5 MANAGEMENT PLAN DEflOENCV The Authority did not have a current DEQ-approved residuals management plan. A plan is required whenever residuals are to be removed from the lagoons, regardless ofwhenever the plant was Where the COLLEGE atmosphere and COWBOY spirit make evetythlng come ALIVE, , Stillwater Utilities Authority PWSIO No. OK1021220 Sanitary Survey Updated Response Pagel of 5 permitted. ?lease work with your DEQ Municipal wastewater Engineer, Toby Harden, E.I., to develop such a plan. Respon,se The Authority emailed Toby Harden, E.I., on June 25, 2020 with an attached contract ond task schedule between the City of Stillwater and Carollo Engineering for preparation of o residuals management plan. LEAD AND COPPER SAMPLE SITES NOT INDIVlOUALLY CATAGORIZEO DEFIOENCV Lead and Copper (LCR) sample sites were not individually categorized as being Tier 1. ner 2, or Non-Tier. Please work with your DEQ Compliance Coordinator, Jennifer Alig, to categorize your lead and copper sample sites into the appropriate tiers and to update your LCR sample plan as necessary. Response Compliance with the Lead and Copper Rule (LCR) is accomplished in two phases: Phase 1- The preparation of Qsurvey to go out through mail to the owners of properties on the 5DWIS existing house list is developed and under review by management. The suNeys will serve the Authorityto determine whether the properties ore Tier 1, Tier 2, or Non-Tier. Two operotor certified employees were tasked beginning in Februory 2020 to work with the County Assessor's office to determine the owner of the dwelling (since Stillwoter's demographics has a high percentage of rental property} and o year for which the house was built. Phase 2 - Once the information is gathered from the surveys and pr~Jiminory determinations of Tier categorization is in plate, the needfor testing wfll begin with sample collection and anafyzation for lead and copper. This phase should be accomplished by January 2021. The Authority is working with Jennifer Alig on this pfan. THE STALLARD TANK VENTS Please see the pictures below of tfie Stallard Tank vent's confirmation of 24-rnesh screen inside and below outer expanded metal screen: Where the COLLEGE atmosphere and COWBOY spirit make everything come ALIVE. Stillwater Utilities Authority PWSID No. OK1021220 Sanitary Survey Updated Response Page 4 of S Where the COLLEGE atmosphere and COWBOY spirit make everything come ALIVE. Stillwater Utilities Authority PWSI0 No. OK.1021_220 Sanitary Survey Updated Response Page Sof S Dotes requested for other deficiencies: Currently, staff are working on a cost evaluation far rehabbing and expanding the current water treatment plant ver:sus transitioning to onew water treatment plant at anew site. Staff intend to present this evaluation to Stillwater Utilities Authority during on October 2020 meeting. At that time, if the Authority is prepared to adopt a plan, staff will move iorward with establishing a selection process for o Con.stru~ion Manager at Risk (CMAR) and whether continuing with the current consultant(~) or seeking new proposals. A typical timeline for a.II phases (pla()n_ing, design, ~onstruetion, startun} of a large Gapital project ranges from three to five years. If the Autho;;ty deems it nece_ssqry to continue expanding the currentiacility all proposed plans will continue. The deficienrjes needing submitted dates to the DEQ thatfol/ into this category are: the individual filter effluentflow meter were not operational. The response given in the January 29, 2020 report was the controc:t with Block and Veatch for evaluation and design and replacement impractic;o{ity The filters did not hove individual rote-of-flow conttollers. The response given in ~e January 29, 2020 report was the contract with Black and Veatch to evaluate and design a new filter complex There were no day tanks for the cationic polymer, Jerri~ sulfate, orfluoride. The date of November 7, 2019 wqs given for the cationic polymer iii the previous response and theferric .sulfate doy tank was in operation prior to the April 2325, 2019 Sanitary Survey. The fluoride tank induction system is a day tarJk and is included in the ~lack and Veatch contract for evaluation and design and replacement. The residuals ponds did not have 3feet or greater offreeboard. The freebaard has maintained ot under 3feet and is monitored during each rain event. Cleaning of the pond is scheduled to begin the summer of 2020. The residur,ls ponds were not being managed to prevent the growth of unwanted vegetation. The maintenanc~ of cledri,ng the ponds of unwant~d vegetation began in February ~020 and is contined as w~ather per,riits the use of equipment. If you have any questions or concerns please get in touch with me at your convenience. Sincerely, L~.o!fj)~ City of Stillwijter Water Utilities Cc Travis Mensik, Regional Manager, ECLS, DEQ Amanda Steadman, Environmental Specialist, ECLS, Stillwater DEQ Office Where the COLLEGE atmosphere and COWBOY spirit make everything come ALIVE. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Exhibit Log Exhibit 5 Flushing Line Photo - March 2022 3269swestern Rd UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Exhibit Log Exhibit 6 Raw Water Line Repair Invoice - May 28 2024 Date of Issuance: _M_a~Y-~.8.-,.2..P._24_ _ _ _ _ _ _ _ _ __ Change Order No. 1 Effective Date: -i'""d11..l.a..-,i'-.un""'IKl~br"""Gl"!'"l"l'"er....,.11!""1'M1--r.--~'"'"{J,--- - Coillrar.: .JCOC C-620 AQn,ement Bel\ll'e8i'l o,.,,11r and C()nimctDr for Construction Co11tra.lli O;lle ofCootract: Janua~ 22, 2024 OGie orITTP: J1inilary 28, 202,4 The.contract oocuments _are mor;lifted as fQllows upon euwtton of tills Cn,mge Ord8f, Description:; This Cha~ge O~er NQ. 1 (001) iner-eases th~ ~tract Prk:e by .S30,5:1_5.41 arid.covers all m_aterlals, equipment_. li:ibor, profit and 'OV.~rhead niaeded for the below described work. 001 includ~~ (2) s~p~rate changes tQ varl_9lls feEltWres of work inolucflng the following: Line item Quantity Differences (Attad'iment 1)i The actual installed quanti~ies vat14;)d from the contrE\et bid quantities in ~ever.al lnstance.s. q~e Item 4 VIBS 11ot n~~sary due to th~ l~K Q~lt'!g larger than 1 inch in diameter. The constructed quantities for line Items 8, 10, 11 and 12 are incre~ed due to tt,.e washout along Lorig Branch Creek befng significantly larger be~w the water surface than oligl.nally estim~ted at the tiine of the bid. The .net changes due to these differences results in an Increase to fhe Contrect Price of $24,'779.10 B;epalr of Pitting In the Pipe (Attachment 2): During reP,air of-the lea_k, sev~~ pltting wa$ observed_In an eXposed portion of the rsw waterline near the leek. It was determil18d by City staff on site to have the contractor repair thls pitting while the line was exposed to avoid future re..excavatlon. The wori< involved additional Weldli1g1 steel patch materials, 6<.!Ulpment and labor. The increa3e.!n Contract Price for this additional won(I~ $,166.71 . UCDCN.i. C-D4t (.2002 F.dllio11} l'Fqlarcd lty tbr E"llglneers' Jo[nt.C'onll'tld lltlatme11t11 Cemmlitte and tndor.sed by th~ As:ioclakd C'>ffltral Contnldot'S of Amerira pJtd t'ltt-C.Om.h"IU:dmi sr~<ltieatio?Ji ln.\litutt. 1'11gcJ ofl CHANGE IN CONTRACT PRICE; Original Contract Price: $219.930_00 CHANGE IN CONTRACT TIMES: Original Contract Times: O Working days 0 Substantial completion (days): 28 calendar days Calendar days Ready for final paymenl (days): 48 calendar days {ffi6Fea5e) (Oeorease) from previously approved Change Orders No. NIA to No. NIA [IRSfe'aSe] [Oeareaae] from previously approved Change Orders No, NIA to No.._~N.,./A_____-' Substantial completion (days): ~ Reai:ly for final payment (days): NIA Contract Price prior to this Change Order. S219 930,00 Contract Times prior to this Change Order: Substantial completfon (days): 28 calendar days Ready for final payment (clavs ordate): 48 calendar days [Increase] [Oesroase] of this Change Order: $30,545.41 [ I ~ ] [DesreaseJ otthis Change Order: Substanllal Completion: NIA Final Completion: lli8 Contract Price incorporat1ng this Change OrcJer: Ii 250,475.41 Contract Times with all approved Change Orde.rs; Substantial compleUon: 28 calendar days Ready for final payment: 48 calendar days RECOMMENDED: By; _ _ _ _ _ _ _ _ _ _ _ __ Engineer: Date: _ _ __ _ __ _ _ _ __ ACCEPTED: ACCEPTED: B~~~ Contniclor; Sandra Matthews Oate: ---b=- -_ ~_-_ 2_- _....c.;~ / - - - Approved by Funding Agency (If apl)licable): _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Date.: _ _ _ _ _ _ _ _ _ _ _ __ _ EJCOC t o. C-941 (1002 Edition) Prcpurccl by lht Engineers' JoinI Conlrutt D01:umcnl5 Cornmltti:c and cndor.;cd by l11c oeiuled G~Hernl Contr1utors of m~rit11 !Ind the Condrnetion Specifiution.~ Institntl!. P:igc 2 of2 Attachment 1 Line Item Differences CONTRACTED BID ITEMS 1 Mobilization/DemobU,zatlon 2 Bonds and Insurance Leak Repair, leak is above spring line of 3 pipe, and average leak hole is 0.5 inches Average leak hole diamelor between 4 0.5 inch to 1Inch BID Q1V UNIT UNIT BID INSTALLED INSTALLED COST CHANGE FROM COST AMOUNT QTY AMOUNT BI D AMOUNT 1 LS $ 8 ,250.00 $ 8,250.00 l $ 8,2.50,00 $ - 1 lS s U,000.00 $ 11.000.00 l s 11.,000.00 $ 1 EA 5 120,600.00 s 120,600.00 1 $ ll0,600.00 $ - 1 EA $ 3,300.00 $ 3,300.00 D $ s 13,300.001 Average leak hole diameter 1 inch or 5 greater 1 EA $ 6,600.00 $ 6,600.00 1 $ 6,600.00 s Ctearlng and grubblng of irees greater than 6 l lnd'ie& al breast height 100 7 Oewatering/Stream Diversion 1 8 Excavation for leak side 250 9 Leak hole i:; belO'lol sprin~ tlne 1 10 Restoration SOD 11 Washout Area Fil 200 12 Type 1A Rip Rap 26 TOTALS SV $ EA s CY $ EA $ SY s CY $ TN s 77.00 $ 27,500.00 s 12.00 s 6,600.00 s 13.20 s 60.SO s 110.00 $ 7,700.00 27,500.00 5,500.00 6,600,00 7,920.00 12,100.00 2,860.00 s .-tl219,930.00 10 $ 770,00 $ 1 s 21,500,00 s 68.0 $ 14,960.00 s 1 .$ 6,600.llO s 711 s 9,385.20 s 525 $ 31,762.50 s 66.2 $ 7,282.00 $ $ (6,930.00) . 9,460.00 - 1.465.20 19,662,SO 4,422.00 24,779,70 Original _/ Contract Price Pr0J, e1 To~I contract Price lncludlhg Line Item Differences Attachment 2 to CO1 - 24WL02 Cost Itemization summary for Change Order Description of Work: Long Branch Creek Additional Scope for Repair of LoJlg Branen Creek Leak Labor Job Title Hourly Rate Hours Amount Eiiuiiiment ........-..... Item Welder $150.00 10.00 $1,500.00 Superintendent Skllled Laborer $75.00 $42.00 10.00 10.00 $750.00 $420,00 Truck & Tools 8" Water Pump Skilled Laborer $42.00 10.00 $420.00 ..........,,._ _ _ - - Hourly Cost $6S.OO day rate Hours 10.00 -- -, Amount $650.00 $1,048.67 Materials Items Flange Gasket Blind Bolts l' 30" and 6" Pipe Total Quantity 1.00 1.00 1.00 8.00 1.00 Suppiementai Costs & SpecJal Consultants Items Unit Quantity $ 3,090.00 Cost/ Unit $66.10 $6.71 $66.10 $4,51 $50.00 Total Cost/Unit -, Amount $66.10 $6.71 $66.10 $36.08 $SO.OD so.co $224,99 I fsubcontra'1s Company -- --- -Attachment Total f $ 1,698.67 I - - -1 Amount Total 1$' . Amount ~ ost tt.emlzatlon Summiirv ' category Cost Labor $3,090.00 Materials $Wl99 Equipment $1,698.67 Subcontractors $0.00 Supplemental & Special $0.00 Markup 15% 15% 15% 5% or. Amount $3.55.3.50 $258.74 $1,953.47 $0.00 $0.00 Total $ Total $5,765.71 ' City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Appendix 3 2023 Stillwater LCR Results 2023 STILLWATER LEAD RESULTS (OK1021220) l'!.:UII~" LC023 LC018 LCOlS LC017 LC013 LC030 LC012 LC007 LC025 LC004 LC031 LC021 LCOS6 LCOSO LC040 LC068 LC047 LC044 LC042 LC053 LC054 LC022 LCOOl LC070 LC019 LC005 LC046 LC034 LC009 LC027 LC020 LC069 LC057 90TH PERCENTILE NUMBER r~fIJil 1..J:i 4606 N. Greenvale Cir. 202 E. Mohowk 208 E. Mohawk 2801 N. Keller #52 Vellowbrlck 125 E. Marie #8 Windsor Ctr. 802 N. Dryden Cir. 1623 Berkshire 2802 N. Keller 104 Crestwood Ct 1008 S. Blueridge 1707 N. Briarwood 921 S. Greystone 1711 N. Lincoln 919 E. Moore 1015 S. Bluerldge 2807 S. Sangre 2018 karr 923 Sunnvbrook Ct. 1508 N. Denver Ct. 1207 S. Williamsfield 713 N. Dryden Or. 2800W. 32nd 1423 N. Denver Ct. 4602 N. Greenvale 128E. Marie 1013 E. Dell 1912 N. Grandview 106 E. Mohawk 606 E. Maple 1021 W, Moore 1010 E. l<ravfer JO r,r. <tl_--41 lll',I~~~ 06/13/23 06/14/23 06/13/23 06/B/23 06/13/23 06/14/23 06/12/23 06/15/23 06/18/23 06/21/23 06/13/23 06/30/23 07/17/23 07/15/23 07/18/23 07/17/23 07/18/23 07/19/23 07/24/23 07/20/23 08/04/2.3 08/18/23 06/23/23 07/19/23 07/31/23 06/21/23 07/31/23 07/31/23 07/10/23 06/14/23 07/28/23 08/03/23 08/11/23 !Lf',1"1~ 7T,!!. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 ,_,.1.1, -:i:~h ~io. BPQl BPOL BPQL BPQL BPQL BPQL BPQL BPQL 8PQL BPQL BPQL BPQL BPOl BPQL BPQL BPQL BPQJ. BPQL BPQL BPQL BPQL BPQL 0.0010 0.0011 0.0013 0.0017 0 .0017 0 .0023 0 .0028 0 .0031 0 .0034 0.0043 0 .006 7 2023 STILLWATER COPPER RESULTS (OK1021220) ,- lfili'1:1H.:.ii LC013 LC007 LC02S LCOS6 LC070 LC054 LC022 LC044 LC019 LC069 LC015 LC017 LC023 LC021 LC012 LC047 LC031 LC068 LC020 LC042 LC040 LC053 LC050 LCOOS LC027 LC046 LC004 LC009 LC030 LCOOl LC018 LCOS7 LC034 90TH PERCENTILE NUM8ER l hT, l ;;n-, #1S2 Vellowbrlck 802 N. Dryden Cir.. 1623 5. Berkshire 1707 N. Briarwood 2800W. 32nd 1508 N. Denver Ct. 1207 S, Williamsfield 2807 S. Sangre 1423 N. Denver Ct. 1021 W. Moore 208 E. Mohawk 2801 N. Keller 4606 N. Greenvale Or. 1008 s. Blueridge #8 Windsor Cir. 1015 S. Bluerldge 104 Crestwood Ct. 919 E. Moore 606 e. Maple 2018 Karr 1711 N. Lincoln 923 Sunnybrook Ct. 921 S. Grevstone 4602 N. Greenvale 106 E. Mohawk 128 E. Marie 2802 N. Keller 1912 N. Grandview 125 e. Marie 713 N. Dryden Or. 202 E. Mohawk 1010 E. Kravler 1013 E. Dell 30 1iY~,f.1.,.1,i 1 .11 06/13/23 06/15/23 06/18/23 07/17/23 07/19/23 08/04/23 08/18/23 07/19/23 07/31/23 08/03/23 06/13/23 06/ 13/23 06/13/23 06/30/23 06/12/23 07/18/23 06/13/23 07/17/23 07/28/23 07/24/23 07/18/23 07/20/23 07/15/23 06/21/23 06/14/23 07/31/23 06/21/23 07/10/23 06/14/23 06/23/23 06/14/23 08/11/23 07/31/23 r...1~:1.1: ,iit 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 ~::t:t !~11-i~ BPOl BPQL BPOl BPOL BPQL BPQl BPOl 0.0117 0.0131 0.0133 0.0155 0..0155 0..0158 0.0166 0.0169 0.0173 0.0177 0.0178 0.0178 0.0187 0..0195 0.0223 0.0233 0.0247 0.0272 0.0292 0.0350 0.0355 0.0364 0.0414 0.0465 0.. 1 1 2 0 0.1390 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Appendix 4 Stillwater LCR Sample Sites City of Stillwater LCR Sample Sites l CR Sile I LCDOl LC:002 1,C003/LC077 L_sQ04/L~4 LCOOS/LC07l Ull06/l~ lC:007 LCOO!I ~ LC010/l~3 _l.__00ll/LC038 LCll12 LC013 JfQ.l 4/lCOS9 LCOlS lCD16 LCO!,?/LC07S LC018/LC072 ~19 -- - - cozo LC02l LC024 co~~s2 LC026/lC063 LQ!_2!_(LC073 LC02S/ C04S LC029 LC030[!:C036 .!:_00.]_1/L~2 LC032/LC067 Lal33/LC064 LC034 LC035/LC060 LC037 l.C040/LC065 LC042 L0)44 A!ldr6 s 8 lid O n u ate er 713 N. DRVOENOR 1713 N. JEFHRSO 124 E MARIE DR 2802 _!EllEROR 4602 N GREENVALE QR 1983 1985 1982 1984 1985 4/0THER l 3 l!O~ OGE~DR 802 N DRYDEN CIR 1422 N HIGHTOWER ST ----- l~l2 N GRANOl/_lEW ST 2.23 STI MBERCREST CT 2700$ WESTERN RO 8 W WINDSOR CIR 198S 1978 1999 1984 1985 1985 1984 l 3 1 4/0THER 1 l S~ '/EU-.OW~B-RI~CK-O-R ..!_212~UNRISE__AVE - 208EM~ VE 2702 N MONROE ST -280-1 -KEil-.ER-OR 1984 ~ 83 1985 1983 1985 1 1 4/0THER l l 202 E MS,HAWK AV_! _ 14~.!:!..0ENVER CT 606 EMA.PU: AVE 100&5 l!LUERIDGE OR 19~ 1.983 1983 1985 1985 _ _4 /_~ 1 1 1 4/0THER 1007E DEUAVE 1623 SSERICSHIREOR 2.22 N DONALDSON ST 198J 1985 1984 1985 4/0f!:!_ER 4/0THE~ 1 l 106 E MOHAWK AVE 117 S Bl.AIR ST 204EMARJ!cOR l .ZS EMARIE OR 104 SCRESTWOOD CT_ _ 1983 1985 1982 1981 1984 4/0THER 1 3 3 4/0THER llOS BLAIR _ST 1985 2209 E CRE.SiWOOD DR 1984 1 1013 EOEU.AVE 1_2~ 1003 S GREVSTONE ST_ 1983 l 1901N WILDWOOD DR 1983 l 1711 NUNCOUI ST 2018 E KARR CT 280_1 SANGE.IIRD 128EMARIEOR 1015 SBlUERIOGE DR 1005 W MOOR.EAVE 402SWI~ 921 S GREYSTONE ST 1985 1985 1985 1982 1982 1985 1983 1990 4/0T~ R 4/0THER 1 3 3 .!: 1 Replaced Plurnblng/Fl.rtures NO YE:S YES (2Dl5) NO YES YES __ _!ES (T~~ l '/ES (FEW Yf;ARS AGO) _!_ES YES (2008,2013,2017) YE.S YES (~015) NO J..E5 (20) J.2020) YES (2015) YES ~AUCETS 2009) NO YES Y! (FAUCITSJ YES YES (2016 FAUCETS) YES (PREVlOUS OWNER) YES YES (2005 FAUCETS) Cu;tomer Leak1 NO YES YES NO NO 0 NO - YES YES(20151 YES YES NO YES NO YES (BROKEN_) NO NO NO NO YES NO NO YES NO Red/Green Stain; NO NO Aerator/Strain needs regulu tinning NO NO Water Sof1ntr/ln line filtu NO NO NO NO YES NO NO VS NO NO NO NO NO NO NO NO YES NO NO NO NO NO YES (REOOISH) NO NO NO NO NO NO NO NO YES flCEMAKER) NO NO YES (ICE MAKER) YES NO YE:S(ICEMAIIER) NO ~ES (ICE MAKER) VES NO YES YES NO NO NO NO NO NO NO NO NO NO NO NO NO YES NO NO YES NO NO NO NO YES (WATER SOF1) City of Stillwater LCR Sample Sites lCR Site# Add~ss Build 0.ite l0l01 LOXl2 LC003/LC077 LC004/ LC074 713 N. DRYDEN C1R 1713 N. JfFFERSON 1Z4 EMMIE OR 21.nl KFL LrR.M lC00S/lC071 LC006/LS:076 LC:007 LCOOS 4602 N GREENVALE OR llO E ROGERS DR 802 N DRYO!._N OR l422N HIGHTOWER ST LC009 1912 N Gf\NOV1EW ST LCOlOf LO?i3 123 STIMBERCREST CT LCOl.l/lC:038 2700S~ ESTERNRD ~cou_ _ _a ~ ~ SOROR LC013_ S2 YELLOW MICK DR LC014( L ~ 12-12 E SUNRISE AVE LQ)15 LC016 LC0l7/ LCO_?S_ LC018/LC072 LC019 208 E MOHAW~ AVE - 2702 MONROE ST - 280_1 !! ~LLER OR 20~ ~VE 1423 N DENVER CT LC020 606 E MAPI.E AVE ~C021_ ~ S8!:_UER_I_~ LC!l2_ 2 _ _U07 SW ~ AMSFlfLO DR LC023 LC024 '606 N GREENVAl.f OR 1007 E0EU AVE LCO~al52 1623S~ ~EOR l~26/l?163 222 N DONALDSON Sf LC027/ LC073 - LC028/LC045 LC029 LC030f LC036 106 E MOHAWKAVf 117 S81AIR ST - - 204 EMARlE OR 125 E MARIE OR LC03J/LC062 l04 SCRESTW0.9D CT LC032/LC067 110 SBlAlR ST LC033/LC064- 2209 ECRESTWOOD DR LC034 1013 E DELl AVE LC03S/l~ 1003 S GREVSTONE ST lC03 7 1901 N WILDWOOD DR 1983 1985 1982 1984 1985 198S 1978 1999 1984 1985 1985 1984 1984 1983 _!_985 1983 1985 _ _198S 1983 1983 1985 1985 1981 1985 1984 1985 !983 198S 1982 1981 198_4 1985 1984 1985 1983 1983 I.C040/LC065 l C042 t.c:044 LC046 LC047 LC048 LC049 LCOSO 17ll N UNCOlJI ST 1985 2018 EKARR CT 1985 2.807 S SANGER!ID 128 E MARIE DR ~98__;; 1982 _ 1.Q!_S S_!I ~ERIDGE~ 1005 W MOOREAVE 198~ 1985 402 SWIWSST _ _ _1-983 921 SGl!EYSTONEST 1990 Tier 4/0lliER Residence T e VP SINGLE FAMILY l SIN GLE FAMILY 3 SINGLE FAMILY 1 ~NGLE FAMILY 1 SINGLE FAMILY l SINGLE FAMILY 3 SINGLE FAMILY 1 4/0THER SINGL FAMILY SINGLE FAMILY 1 ~ GLE FAMILY 1 SINGLE FAMILY 1 SINGLE FAMILY 1 S!NGlf ! ~MILY _ 1 4/0THER SINGLE FAM~LY SINGlEFAMILY 1 ~ GLEFAMILY 1 4/0THER ~ G l E ~ AM ILY SINGLE FAMILY 1 _ _ _SIN_tE F_AMILY 1 SINGLE FAMILY 1 4/0THER SINGLE FAMILY SINGLE FAMILY 4/0lliE~ 4/0.!_HER SINGLE.A_MI LY SINGLE FAMILY 1 SINGLEF~LY 1 SINGLE FAMILY 4/0THER SINGLE FAM ILY l SINGLE FAMILY 3 SINGLE.AMILY 3 ~NGLE. FAMILY 4/0THE:R SINGLE FAMILY 1 SI NGLE FAMILY 1 SINGLE FAMILY l SINGLE FAMILY 1 SINGLE FAMILY l SINGLE FAMILY 4/0THER SINGLE FAMILY 4/0THER SINGLE FAMILY 1 SINGLE FAMILY 3 SIN GLE FAMILY 3 SINGLE FAMILY 1 SINGLE FAMI LY l SINGLE FAMILY 1 SINGIE FAMILY Water Main M;,1er111 O>VC ACP ACP ACP ACP ACP ACP ACP ACf UNKNOWN ACP ACP ACP ACP ACP ACP ACP ACP PVC ACP ACP ACP ACP ACP ACP CIP ACP ACP ACP AC!'_ UNKNOWN ACP UNKNOWN ACP ACP ACP ACP ACP ACP ACP AC~ ACP ACP ACP COS Servke line Milftrlill Cwtomer Serviu llne Mill~rlal UNl(NOWN UNK OWN UNKNOWN UNKNOWN UNKNOWN UNKNOWN UNKNOWN U KNOWN UNKNOWN UNKNOWN UNKNOWN UNKNOWN UNKNQ_WN UNKNOWN ~KNOWN UNKNOWN UNKN.Q_INN UNKNOWN UNKNOWN UNKNOWN __l!NKNOWN UNKNOWN UNKNOWN U KNOWN UNKNOWN U KNOWN UNKNOWN UNKNOWN UNKNOWN UNKNOWN UNKNOWN UNKNOWN UNKNOWN UNKNOWN UNKNOWN UNKNOWN UNKNOWN UNKNOWN UNK OWN UNKNOWN UNK OWN UNKNOWN UNKNOWN UNKNOWN Plumblnf Mall!rlal PLASTIC COPPER 0 REVIST BLANK SURVEY ' COPPER REVIST BLANK SURVEY' PLASTIC 'REVIST BLANK SURVEY" 'REVISTBLANK SURI/EV- COPP ER PLArnC COPPER COPPER PLASTIC 'REVISTBLANK SUR\/EY' COPP ER/PLASTIC PLASTIC PLASTIC PI.ASTIC COPPER PLASTIC COPPER/PLASTIC PLASTIC UNKNOWN COPPER/PLASTIC Rent/Own OWN OWN OWN ow, OWN OWN OW OWN OWN OWN OWN OWN RENT OWN ow OWN OWN OWPII ow CAST IRON/PLASTIC PLASTIC COPPER/PLASTIC UNKNOWN "UNKNOWN' ow ow OWN ow OWN City of Stillwater LCR Sample Sites LCR Site# UI!Sl LCOS3 L_g)S4 LCOSS LCOS6 LCOS7 LC061 LCD68 LC069 LC070 LCD78 LC:080 Addre 914 SGREYSIQ_EST 923 N SUNNYi!ROOKCT -- --- l.S08f!~ 1420 NDENVER CT 1707 BRIARWOOD ST 1010 E KRAYlER AVE l109 E CRESlWOOD OR 919 E MOORE AVE 102l W MOORE~ 2800 W32 OA\lf 1501 !:!_DENVER CT 1406 DENVER CT BuiIll Ote 1982 1982 1982 19&2 198.11 1983 1984 1979 1985 1983 1984 Tier Resldena, Type _3 SIN~LE FAM~Y 3 SINGLE FAMILY 3 SINGLE FAMILY 3 SINGLE FAM ILY 4/ 0TH ER_ SINGLE FAMILY 1 SINGLE FAMILY ------ 1 SINGLE FAMILY 4/0! HER SINGLE FAMILY l SINGLE FAMILY l SINGLE FAMILY .! SINGLE: FAMILY NO SUCH ADDRESS W~ter Main Material ACP ACJ> PVC PVC ACP ACP UNKNOWN ACP ACP ACP PVC COS Service line Material Customer ,ervlce Une M a t e ri al UNKNOWN UNKNOWN UNKNOWN UNKNOWN UNKNOWN UNKNOWN UNKNOWN UNKNOWN UNKNOWN UNKNOWN UNK NOWN Pfumbln1 M1terlaf UNKNOWN COPPER/PLASTIC PLASTIC COPPER/UAO/PLASTIC PLASTIC COPPER Rrnt/Own OWN OWN OWN ow RENT ow City of Stillwater LCR Sample Sites lCR Slte II Addres.s Build Date LC051 LCOS3 91~-~ GREYS!ONE ST 923 N SUNNYBROOK CT 1!!!12 1982 l~ 1508N OENVRCT - 1982 LCOS_s_ _ 1420 N OtNV(R CT lCOS6 1?01 N BRl!-RW OOO ST - -1982 19~ ~ lC061 LC068 1010 EKRAYLER AVE --- ----- - 2109EC~OD ~ 919EMOOREAVE ~ 983 1~ 1979 - J:CX>69 LC070 1~ 2l W ~ ORE A_vE 2800W 32NDAV _ _19~ 1983 lC:078 1S01 N DENVER CT 1984 lCXl80 1406 N DENVER CT Tier I 3 3 ) 3 Replaced I bl g/ I P um n fxtu,es _L ~-ESE~O) 4/0THER NO 1 YES (JU~UQ19) 1 4/0THER NOT SURE _1 1 YES (F~UCETS/PLUMBING) 1 Customer l eaks ? NO NO NO NO YES Red/Green Stains NO NO Aerator/Strain needs I ., . regu a, '""eantng NO YES Willer Softener/lnIIr1a Illter NO NO YES (REOOl~H) NO NO NO NO NO YES (GREENISH/WHITE) NO NO YES NO YES(ICEMAKER) City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Appendix 5 EPA Laboratory Audit - June 6, 2024 Section I - INTRODUCTION City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 PURPOSE OF THE INSPECTION EPA Inspector Mariela Reyna conducted a lab audit as part of the Safe Drinking Water Act (SDWA) inspection on June 6, 2024. The scope of this audit is to evaluate the compliance of the facility's laboratory and sampling requirements as prescribed in the SDWA. The opening conference was held in conjunction with the opening conference of the SDWA inspection. FACILITY DESCRIPTION The facility's laboratory is not accredited under national or private programs. There are eight (8) full time operators that perform laboratory analysis. The laboratory performs sample analyses of the following parameters: pH, Temperature, Free Chlorine, Total Chlorine, Free Ammonia, Total Ammonia, Turbidity, Hardness, Conductivity, Alkalinity, Fluoride, Ozone. Section II - OBSERVATIONS Reagents, standards, and equipment 1. Reagents were not labeled with the date they were opened (refer to Section V, Photographs 14). 2. One (1) bottle containing a clear reagent was not labeled with any identifying information (refer to Section V, Photograph 5). 3. Bottles used for chlorine blanks were not labeled with any identifying information (refer to Section V, Photograph 6). 4. Bottles that were refilled with reagents from original reagent bottles were not labeled with the expiration date of their contents (refer to Section V, Photograph 7). 5. The technician communicated that plastic sample bottles are re-used for sample collection. Samples are only labeled with the location for which they are to be collected. The date and time of collection is not labeled on the bottles nor is there any identification of technician that conducts the sampling. There is no written record of this information maintained (refer to Section V, Photograph 8). 6. The thermometer in the refrigerator was not NIST certified, and its initial date of operation was unknown. 7. The pH meter was last certified by the manufacture in 2020. 8. There is no written record of the frequency required for instrument calibrations. 9. Distilled water purchased from a grocery store or similar general store was used in place of reagent water and deionized water. There was no documentation available to demonstrate this water meets the requirements for reagent water nor that it is a substitute for deionized water (refer to Section V, Photograph 9). 10. Various types of oral medications were seen on the laboratory counter where procedures where being performed (refer to Section V, Photograph 10). 6ENFORM-019-R8.2 (02/12/2020) 1 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 11. There was no hand soap present in the lab nor in close proximity to the laboratory sink. (refer to Section V, Photograph 11). Standard operating procedures and supporting documentation 12. The SOPs provided by the facility were not properly maintained, as detailed below (refer to Section V, Photograph 12). a. They did not reference an approved EPA method. b. There was no creation or review date listed and the document itself does not appear to be a controlled document. c. They did not include sample storage or holding time information, sample preservation requirements, calibration or quality control procedures, equipment maintenance, or retesting requirements or procedures. d. The SOP did not include information for the making or preparation of reagents, nor does it say to use manufacturers reagents. e. Unauthorized changes were made to documents. 13. There was no master list or table of content sheet that listed all available SOPs. 14. There were no SOPs for the collection and submission of samples tested by contractors. 15. The Alkalinity SOP describes the addition of reagents measured in drops and not milliliters (mL) as stated in the approved EPA method, Standard Methods 2320 B. Alkalinity (refer to Section V, Photograph 12). 16. The technician communicated that samples are collected in plastic bottles and then used for the various daily analysis. Laboratory records suggest the use of the approved EPA standard method, Standard Method 4500-CL G. Colorimetric for analyses of Total Chlorine. Per this method, the samples much be collected in pre-treated glass containers. The technician communicated that Alconox is used to clean laboratory glassware. This is not an adequate chemical to pre-treat glassware for Total Chlorine testing per this method (refer to Section V, Photograph 13). 17. There is no written SOP for Conductivity. 18. There is no written record of employee SOP training. 19. There is no written description of the specific duties and required analysis to be conducted by laboratory technicians. Bench Sheets and supporting documentation 20. The bench sheets reviewed at the facility were not properly maintained, as detailed below (refer to Section V, Photograph 14). a. There are no references to approved EPA methods listed on the bench sheet. b. The bench sheets did not have a proper description of the abbreviations for sampling locations used. c. Units for the results of analyses were not used on any of the bench sheets reviewed. d. The time of sampling collection was autogenerated. Neither the actual time of sample collection nor sample analysis are recorded. e. There is no indication whether the same technician is both collecting the samples and performing the analysis. f. The bench sheets and their data are not reviewed and approved. 2 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 g. There is no designated location on the daily bench sheet to record the location of samples for Distribution Chlorine Residuals. 21. There is no record of quality control or assurance being conducted for Free and Total Chlorine. 22. The temperature of the refrigerator is not being properly monitored. 23. There are no bench sheets created or records for non-routine and repeat samples. 24. The Jar Test bench sheet does not include the necessary information, as detailed below (refer to Section V, Photograph 15). a. The time of sampling. b. The time analyses began and ended. c. The technician that performed the sampling and analyses. Section III - AREAS OF CONCERN 1. Reagents, standards, and equipment: Per the SDWA, all methods performed for the monitoring and analytical requirements for public water systems shall comply with EPA approved methods, listed in 40 CFR Part 141, or the alternative methods listed in appendix A to subpart C. Equipment used for measuring samples, reagents, reagent water, or standards must meet the minimum accuracy and precision levels per each EPA approved method; measurement grade glassware must be used for measuring liquids in lieu of glassware who's primary function is for storage or containment. All reagents, reagent water, standards, and equipment must meet the requirements per each EPA approved method. Reagents and standards must be clearly labeled with open and expirations dates, to ensure they are not used past expiration. Unless otherwise noted by the manufacturer, liquid reagents and standards have a shelf life of one (1) year after opening. Should the manufacturer expiration date occur before the one year, the manufacturer's expiration takes precedence. EPA approved methods may further specify the shelf life of reagents, standards, or solutions created in house for the purpose of analysis or calibration. Expired reagents and standards must not be used in analysis or calibration as they do not meet the quality assurance and quality control (QA/QC) requirements per the EPA approved methods. All reagents and standards used in analysis must be clearly labeled with contents and expiration date to ensure all QA/QC requirements are fulfilled. Personal safety risks can result from the ingestion and contamination of oral medications. Eating, taking medication, and storing medication in laboratories where hazardous materials are used is not a safe practice. In additon, these practices can contaminate reagents and affect the integrity of analyses being performed. Another concern is the absence of hand soap near the sink. It is vital that hands be properly washed before and after analyses to prevent contamination of the sample and reagents. It is also a concern since many of the reagents used are hazardous and can cause serious issues when there is prolonged skin contact. 2. Standard operating procedures and supporting documentation: Per the SDWA, all methods performed for the analysis of pollutants shall comply with EPA approved methods (40 CFR Part 141, Subpart C). Facilities must have written SOPs documenting the use of EPA approved methods and QA/QC measures to ensure compliance with the SDWA (40 CFR Part 141, Subpart C). To ensure compliance with these requirements, SOPs should be regularly reviewed, updated, and fully and correctly cite the EPA approved methods. The techniques and methods utilized in the laboratory for analysis must meet the method requirements as detailed in an EPA approved 3 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 method. SOPs and bench sheets must follow a referenced EPA approved method, any deviation may result in the subsequent data to be ruled invalid. a. Document control procedures set the framework for how controlled documents are approved updated, tracked, and distributed. A controlled document is a reference document which, through the course of its lifecycle, may be reviewed, modified, and distributed several times. The use of document control procedures and maintenance of controlled documents helps to ensure policies and procedures of the facility meet the requirements of applicable regulations, as set forth by a regulating entity. b. Proper training and adequate documentation of training records ensures that proper EPA approved methods are being followed, without deviations, by all technicians in the laboratory. 3. Bench sheets and supporting documentation: Bench sheets must record the data and information as required per the EPA approved methods used for analysis and the SDWA. The SDWA and EPA approved methods require the time of both sample collection and sample analysis. The SDWA requires the identification of both the person who collected the sample and the person responsible for performing analysis (40 CFR 141.33). Additionally, the SDWA requires a reference to the EPA approved method used for analysis as well as the results of the analysis, including all information gathered during sample analysis (40 CFR 141.33). a. The time for both sample collection and sample analysis are recorded to ensure analysis is performed within the hold time as required by the EPA approved method used for analysis. b. The data recorded on bench sheets should clearly demonstrate the methods used and be representative of everything the technician performed during analysis. Section IV - FOLLOW UP The closing conference was held in conjunction with the closing conference of the SDWA inspection, after the on-site audit. Additional information regarding SOPs, laboratory instrumentation, and personal records was received by EPA on June 13, 2024, after exciting the facility on June 6, 2024. Section V - Photograph Log Section V contains 15 photos that were taken during the EPA laboratory audit that was conducted on June 6, 2024. 4 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Photograph 1. Photo File Name: DSCN5414.JPG Date of Photo: 06/06/2024 Time of Photo: 9:49 AM Photographer: Mariela Reyna Description: Reagents in cabinet without date opened properly labeled. 5 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Photograph 2. Photo File Name: DSCN5416.JPG Date of Photo: 06/06/2024 Time of Photo: 9:49 AM Photographer: Mariela Reyna Description: Reagent on counter with only date received labeled and without date opened labeled. 6 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 solution de de Thiosulfate desodc-: M Photograph 3. Photo File Name: DSCN5418.JPG Date of Photo: 06/06/2024 Time of Photo: 9:50 AM Photographer: Mariela Reyna Description: Reagent in refrigerator with only date received labeled and without date opened labeled. 7 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 1000 ml Sin wM. lflMYcuaM;v nhft)khkl~d Company PO BolC 389 l ~ IJ H I Photograph 4. Photo File Name: DSCN5419.JPG Date of Photo: 06/06/2024 Time of Photo: 9:50 AM Photographer: Mariela Reyna Description: Reagent in refrigerator with only date received labeled and without date opened labeled. 8 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Photograph 5. Photo File Name: DSCN5477.JPG Date of Photo: 06/06/2024 Time of Photo: 10:03 AM Photographer: Mariela Reyna Description: Bottles on counter containing a clear reagent not labeled with any identifying information. 9 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Photograph 6. Photo File Name: DSCN5433.JPG Date of Photo: 06/06/2024 Time of Photo: 9:55 AM Photographer: Mariela Reyna Description: Bottles on counter used for chlorine blanks and chlorine testing without identifying labels. 10 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Photograph 7. Photo File Name: DSCN5433.JPG Date of Photo: 06/06/2024 Time of Photo: 9:55 AM Photographer: Mariela Reyna Description: Bottles on counter that were refilled with reagents from original reagent bottles not labeled with the expiration date of their contents. 11 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Photograph 8. Photo File Name: DSCN5446.JPG Date of Photo: 06/06/2024 Time of Photo: 9:57 AM Photographer: Mariela Reyna Description: Plastic bottles used for sample collection. 12 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Photograph 9. Photo File Name: DSCN5458.JPG Date of Photo: 06/06/2024 Time of Photo: 9:59 AM Photographer: Mariela Reyna Description: Commercial distilled water purchased from a grocery store or similar general store on laboratory counter. 13 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 F1r!.t Aid , Facility Services, Safety, and CPR Training 1-800-869-6970 Photograph 10. Photo File Name: DSCN5449.JPG Date of Photo: 06/06/2024 Time of Photo: 9:58 AM Photographer: Mariela Reyna Description: Various types of oral medications on laboratory counter. 14 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Photograph 11. Photo File Name: DSCN5444.JPG Date of Photo: 06/06/2024 Time of Photo: 9:57 AM Photographer: Mariela Reyna Description: Laboratory sink with no hand soap in immediate proximity. 15 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 ALKALINITY Titration Fill buret with .02N H2SO4 (Sulfuric Acid). Record this reading. Measure 100ml sample and place into an Erlenmeyer flask. lf sample contains chlorine residual, de-chlorinate with .lN Sodium Thiosulfate (2-3 drops). Add 2 or 3 drops of phenolphthalein indicator. If a pink color is present, titrate with .02N H2so4 until sample becomes colorless. Record buret reading. If no color is present, omit this titration and record 0 1 for P-alkalinity. To the same sample, add i ~O I drops of brom cresol green methyl red. Titrate with .02N H2so4 until lhe endpoint i s ~ - This goes from blue until you have pink. Record buret read1nq. Multiply the buret reading by 10 to get ppm. 00 not zero the buret between the P-alkalinity and the Total-alkalinity. Record each . NOTE: present ly we have c1 2 in all but the raw water. Photograph 12. Photo File Name: DSCN5343.JPG Date of Photo: 06/06/2024 Time of Photo: 8:44 AM Photographer: Mariela Reyna Description: Alkalinity SOP with unauthorized changes. Additional SOPs followed similar format. 16 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Alconox Pawdered Precision Cleaner ....................,._--.1111dllnsM.~ ..........~ - -........-.....,,.....c.-. @ . . . . . . . . . . . . . . . . . . . . lllicbllMlill.--- ..........tk. a-t-,f-it. A.Ill. ...... u a,u,.n. u Photograph 13. Photo File Name: DSCN5468.JPG Date of Photo: 06/06/2024 Time of Photo: 10:01 AM Photographer: Mariela Reyna Description: Alconox used to clean laboratory glassware. 17 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Photograph 14. Photo File Name: DSCN5407.JPG Date of Photo: 06/06/2024 Time of Photo: 9:48 AM Photographer: Mariela Reyna Description: Daily bench sheet that recorded results from analyses performed in the laboratory. 18 City of Stillwater PWS ID No. OK OK1021220 Inspection Date(s): 06/04/2024 through 06/06/2024 Photograph 15. Photo File Name: DSCN5397.JPG Date of Photo: 06/06/2024 Time of Photo: 9:02 AM Photographer: Mariela Reyna Description: Jar test bench sheet. 19