Document YrR81XEQbQDwbo54MbawpJw0V

EAA 0ft Unitad States J-\1;~~mental Protection Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 06/06/2017 Water CWA 308[A][B] Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: City of Keller City of Keller Public Works Department 1100 Bear Creek Parkway Keller, Texas 76244 1-100 Bear Creek Parkway, P.O. Box 770 Keller, Texas 76244 Tarrant County Alonzo Linan alinan@cityofkeller.com I Director FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110010935621 TXU000059 NA 221320 4952 Personnel participating in inspection: David Long USEPA/6EN-WM Mike Tillman USEPA/6EN-WM Larry Jones City of Keller Robert Carrales City of Keller Environmental Scientist Environmental Scientist Water/Wastewater Supervisor Water/ Wastewater Foreman 214.665.7323 214.665.7531 817.743.4216 817 ..743.4217 EPA Lead Inspector Signature/Date Supervisor Signature/Date ~;Jh {Inspector name() ca~(J~J~ {Supervisor name} !J../~'fho,t7 D~te 1 '2-1~!('1 Date 6ENFORM -019-R7 (2/ 15/2017) 1 Section I- INTRODUCTION PURPOSE OF THE INSPECTION City of Keller 06/06/2017 A U.S. Environmental Protection Agency (USEPA) program review inspection was conducted in the City of Keller Public Works offices located at 1100 Bear Creek Parkway, Keller, Texas 76244. The inspection was conducted under the guidelines established by the US EPA under the National Pollutant Discharge Elimination System (NPDES) for wastewater collection systems. The purpose of this inspection was to inspect and review the City of Keller's current Sanitary Sewer Overflow (SSO) response protocols and their application of a Capacity, Management, Operations and Maintenance (CMOM) program and how the program is used to insure proper operation and maintenance of their collection system. An entry briefing was conducted by EPA-Region 6 inspectors David Long and Mike Tillman at 9:00a.m. on June 6, 2017 at the City of Keller Public Works offices. The inspectors met with Alonzo Linan, Public Works Director, and Larry Jones, Water/Wastewater Superintendent. Additional City of Keller personnel were also present and are listed in Appendix 1. During the entry briefing, the EPA inspectors provided credentials and explained the purpose of the inspection, as well as set the timeline for the day and verified the availability of documents that had been requested the week before. Notification of the inspection had been provided to Lead Inspector Greg Diehl with the Texas Commission on Environmental Quality, but he was not present for any part of the inspection. At the conclusion of the inspection, an exit briefing was conducted that explained the suggestions and areas of concerns noted during the inspection that are detailed in this report. This report is based on information supplied by the City representatives, observations made by the U.S. EPA inspectors, records and reports maintained by the City, the State of Texas and the USEPA. FACILITY DESCRIPTION The City of Keller is approximately 18.4 square miles in size and includes a population of 44,050 residents which are provided wastewater services through approximately 202 miles of sewer lines with seven lift stations. Approximately 92 percent of the collection system is composed of PVC pipe mostly installed since 1975. The remaining system includes approximately six percent vitrified clay and smaller percentages each of ductile iron and polyethylene pipe. A Supervisor Control and Data Acquisition (SCADA) continuously monitors the City's seven lift stations, otherwise, all lift stations are physically visited at least twice per week. While all lift stations are monitored, only two stations have dedicated emergency generators in the event of an electric grid failure. However, the remaining lift stations are all equipped with quick connect lines for electric power supplied by portable generators if needed. The City of Keller collection system has experienced seven SSOs since 2012. Problem areas of the collection system, where SSOs occur more frequently, are placed on either a 30 or 90-day preventative maintenance schedule and cleaned to reduce overflows. In addition, Keller has performed a Sanitary Sewer Evaluation Study to ensure capacity and condition of the collection system is maintained. The next evaluation has been funded ($200,000) and is expected to commence in late 2017 or early 2018 2