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Agency
Region 6 Compliance Assurance and Enforcement Division
INSPECTION REPORT
Inspection Date(s): Media: Regulatory Program(s)
06/22/2017 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 DeSoto City of DeSoto 211 East Pleasant Run Road DeSoto, Texas 75115 620 North Westmoreland Road DeSoto, Texas 75115 Dallas lsom Cameron icameron@desototexas.gov
I Director of Public Utilities
FRS Number:
110010934506
Identification/Permit Number: TXU00157
Media Number:
NA
NAICS:
221320
SIC: 4952 .
Personnel participating in inspection:
David Long
USEPA/6EN-WM
Rachel Matthews
USEPA/6EN-WM
Crystal Owens
City of DeSoto
Alan McDonald
City of DeSoto
Environmental Scientist Environmental Scientist City Engineer Manager of Utilities
214.665.7323 214.665.8589 972.230.9672 972.230.5725
EPA Lead Inspector Signature/Date
Supervisor Signature/Date
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6ENFORM-019-R7 (2/15/2017)
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Section I-INTRODUCTION PURPOSE OF THE INSPECTION
City of DeSoto
06/22/2017
A U.S. Environmental Protection Agency (USEPA) program review inspection was conducted in the City of DeSoto offices located at 211 East Pleasant Run Road, DeSoto, Texas 75115. The inspection was conducted under the guidelines established by the USEPA 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 DeSoto'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 Rachel Matthews at 9:00a.m. on June 22, 2017 at the City of DeSoto offices. The inspectors met with lsom Cameron, Director of Public Utilities, Allan McDonald, Manager of Utilities, and Crystal Owens, City Engineer. During the entry briefing, the EPA inspectors provided credentials and explained the purpose of the inspection, as well as set the time line 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 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 ofTexas and the USEPA.
FACILITY DESCRIPTION
The City of DeSoto is approximately 21.6 square miles in size and includes a population of approximately 52,000 residents which are provided wastewater services through approximately 220 miles of sewer lines which includes no lift stations. Approximately 49 percent of the collection system is composed of PVC pipe. Fifty percent of the collection system is composed of vitrified clay and the remaining percentage is composed of ductile iron. The City of DeSoto does have a Supervisor Control and Data Acquisition (SCADA) system, but it only monitors the City's drinking water distribution system.
The City of DeSoto collection system has reported only two SSOs in the past three years to the TCEQ, however, while the City of DeSoto does maintain records of all SSOs originating from either private lateral or city owned lines, they do not report any of those overflows to the TCEQ unless the overflow reaches the Water of the U.S. or Waters of the State. Mr. McDonald indicated that the City of DeSoto responds to over 500 private lateral SSO complaints each year. Problem areas ofthe collection system, where SSOs occur more frequently, are placed on either a weekly or monthly preventative maintenance schedule and cleaned to reduce overflows. The consulting company, Grantham and Associates, performs the city's ongoing collection system basin studies which include basin capacity, 1&1, smoke testing, flow monitoring, line and manhole repairs and CCTV to evaluate line condition. The study is
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