Document a1O4wL6qE7Yd8X3Gzk4vXmNrX

Inspection Date(s): Media Program: Regulatory Program(s) 2/13/2025 Drinking Water Safe Drinking Water Act (SDWA) System Owner: System Name: System Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: System Phone Number System Contact: City of Galena Park City of Galena Park 105 Main St Galena, TX 79760 PO Box 46 Galena Park, TX 77547-0046 Harris County 713-672-2556 Jarrod Jones jjones@cityofgalenapark-tx.gov I I Water Superintendent System Classification PWS ID: Media Identifier Number: NAICS: SIC: Community Water System TX1010009 N/A 221310 4941 Personnel participating in inspection: Mariela Reyna EPA Region 6 Janet Cherry ERG (EPA Contractor) Bridget Murphy ERG (EPA Contractor) Bryan Gunawan Texas Commission of Environmental Quality (TCEQ) Jarrod Jones City of Galena Park Inspector Inspector Inspector in Training Environmental Investigator Water Superintendent EPA Lead Inspector Signature/Date Mill 3/20/25 Janet Cherry Date Supervisor Signature/Date RUBEN ALAYON-GONZALEZ Date: 2025.04.25 13:32:29 -05'00' Digitally signed by RUBEN ALAYON-GONZALEZ Ruben Alayon-Gonzalez Date 1 City of Galena Park (TX1010009) Inspection Date: February 13, 2025 Section I - INTRODUCTION PURPOSE OF INSPECTION On February 13, 2025, the United States Environmental Protection Agency (EPA) and EPA contract inspectors from Eastern Research Group, Inc. (ERG) (hereinafter, the EPA inspection team) conducted an announced Compliance Evaluation Inspection under Section 1445 of the Safe Drinking Water Act (SDWA), 42 U.S.C. 300j-4, of the City of Galena Park Public Water System (hereinafter, the System or Galena Park) (TX1010009). The inspection process began at approximately 8:30 AM on February 13, 2025 and finished at approximately 3:40 PM on February 13, 2025. Mariela Reyna and Janet Cherry presented their SDWA inspector credentials to the System's water superintendent (hereinafter, the System representative) during the opening conference. The EPA inspection team informed the System representative that this was an EPA inspection to determine compliance with the SDWA and other applicable federal and state regulations. The EPA inspection team also informed the System representative that they would be conducting a cybersecurity evaluation alongside the SDWA Section 1433 review of the System's Risk and Resilience Assessment (RRA) and Emergency Response Plan (ERP). To facilitate the inspection process, the EPA inspection team used a checklist outlining the requirements of SDWA Section 1433 during the document review. Refer to Appendix 1, Opening and Closing Conference Sign-in Sheet for a list of attendees. SYSTEM DESCRIPTION According to Drinking Water Watch, the System is owned by the City of Galena Park, serves a population of approximately 10,293 people, and has 3,431 service connections. The EPA inspection team reviewed the above information with the System representative during the inspection process via conversations. It is a community water system as defined by 40 C.F.R., Part 141 Subpart A. Galena Park purchases treated water from City of Houston (TX1010013), with Galena Park being the first customer served by the Southeast Houston Filtration Plant. The water received from City of Houston is chloraminated and Galena Park monitors total chlorine, monochloramines, and free ammonia weekly using a Hach test kit. Galena Park has a 10-year contract with City of Houston, ending in 2027. The current contract limits Galena Park to 35 million gallons (MG) per month and a daily maximum of 1.5 million gallons per day (MGD). Galena Park's current summertime use is approximately 980,000 gallons per day, less than the contractually allowed maximum of 1.5 MGD. The System representative estimates that leaks account for 10 to 15 percent of the water purchased. City of Houston water enters the System at two locations, with water treatment facilities, storage tanks, booster pumps, and a well at each location (refer to Appendix 2, City of Galena Park Water System Schematic). The wells are available in the event water is not available from City of Houston. Each plant is designed with the ability to feed both chlorine gas and liquid ammonium sulfate if the wells are used. According to the System representative, the well water has not been sent to the distribution system for years. As such, the System was not feeding chlorine gas or liquid ammonium sulfate at the time of inspection. The operators exercise the wells and pump the well water to waste. Galena Park recently received grants to perform upgrades to the two water treatment facilities, booster pump stations, and finished water storage tanks; install a Supervisory Control and Data Acquisition (SCADA) system; and replace old water mains. 2 City of Galena Park (TX1010009) Inspect ion Date: February 13, 2025 Mr. Jarrod Jones is the System's water superintendent w ith a C Ground Water and C Surface Water license. Another operator under Mr. Jones has a C Ground Water license. Three other staff plus a dedicated meter reader are available to assist with overseeing the System. System staff test and flush hydrants, w ith some hydrants being flushed more frequently than others, according to the System's written hydrant flushing program (see Appendix 31 Photographs 1 and 2) . System staff flush dead ends once or twice per month until the total chlorine residual is 1.5 milligrams per liter (mg/L). System staff exercise valves as time allows, exercising critical valves each year and non-critical valves every five years. The EPA inspection team discussed current water rates assessed to customers. The water rate for a single-family home is $14.46 per month for the first 6,000 gallons used. After that, each addit ional 1,000 gallons costs $7.76. This same rate is also assessed for a single-family home for sewer. Table 1 lists the violations incurred by Galena Park w ithin the past five years. The inspection activities included a discussion regarding the cyanide maximum contaminant level (MCL) violation listed in Table 1 (see Section II- Inspection Activity Summary. Cyanide MCL Violation Discussion) . Table 1. City of Galena Park Water System violations listed in SDWIS, 2/13/2020 - 2/13/2025 Compliance Resolved Rule or Contaminant Period Violation Consumer Confidence 07-01-2024- Consumer Confidence Report Yes Ru l e 09-25-2024 Disinfection Byproduct 01-01-2024- Monitoring, Routine Major (DBP) Yes Ru l e/Ch l o rine 03-31-2024 Public Notification Rule 01-01-2024- Public Notification for Cyanide Yes 03-31-2024 MCL Cyan id e 01-01-2024- Cyanide MCL No 03-31-2024 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 activities and to assess the condition of drinking water system assets. The physica l inspection occurred over one day. Previous TCEQ sanitary survey reports and enforcement actions were provided to the EPA inspection team prior to the inspection . The information in this report is based on document review, conversations w ith the System representative, and observations made during this inspection. Chlorine, Chloramine, and Total Ammonia Monitoring Program The EPA inspection team reviewed the System's monitoring of chloraminated water. The System is required to have a Nitrification Action Plan (NAP) since it receives chloraminated water from City of Houston. The System does not have SCADA or online monitoring capabilities and all sampling is done through grab samples analyzed using an approved test kit (see Appendix 3 1 Photograph 3). The EPA inspection team reviewed daily log sheets and documentation that indicates the operator is taking daily total chlorine residual samples and weekly monochloramine and free ammonia samples at the two entry 3 City of Galena Park (TX1010009) Inspection Date: February 13, 2025 to distribution locations (see Appendix 3, Photographs 4 and 5). The operator also logs daily flowmeter readings at the two entry to distribution system locations. Operation, Maintenance, and Asset Management Programs The EPA inspection team discussed the System's operation, maintenance, and asset management programs and reviewed records provided by the System representative. A list of all critical assets (i.e., wells, booster pumps, treatment plants, storage tanks) is maintained along with dates of installation. All information is obtained and tracked on paper; Galena Park does not have a computerized maintenance management system. Water main leaks and repairs are tracked through individual work orders and the operator maintains a folder with all water main repair information (see Appendix 3, Photograph 6). The System maintains a map of the distribution system noting size and location of water mains. The System representative stated there is old asbestos-cement pipe that needs to be replaced. The System does not maintain records of routine operation and maintenance activities, such as greasing of pumps, valve exercising, or hydrant flushing. The System performs monthly finished water storage tank inspections and maintains records of these inspections (see Appendix 3, Photograph 7). Galena Park owns and maintains three finished water storage tanks; all three tanks were professionally inspected in June 2022 and again in July 2023. The tank inspection reports noted the need to repair ladders and coatings on the tanks. Rehabilitation of each tank is proposed as part of the grant funding to address concerns noted in the tank inspection reports. The inspection reports noted sediment in each tank, with 0.5 to 3 inches of sediment noted in the 1 MG storage tank at Plant #2. Wellhead Protection Plan The EPA inspection team reviewed the System's wellhead protection plan and the plan identifies potential sources of contamination near the well. A house was recently built near Well #3 (located at Plant #1) and the System representative documented concerns with the sewer service line serving the home being close to Well #3. Well #3 is approximately 30 feet from the western property line shared with the new home and approximately 70 feet from 3rd Street right-of-way. Customer Complaints The EPA inspection team discussed the System's customer complaint process with the System representative. The System logs all customer complaints. Customers call the Galena Park office and then relay information to the water superintendent. The water superintendent assigns an operator to follow up on the complaint and report back. The completed customer complaint log is returned to the city office. Operators will take samples if needed, such as coliform samples, to address a complaint. Cross Connection Control Plan The EPA inspection team reviewed the System's cross connection control plan. According to the System representative, all high health hazard connections have been identified and a reduced pressure backflow assembly installed at each. The water superintendent maintains records of testing and receives test results of installed backflow prevention assemblies annually. The cross connection control plan did not define high hazard connections and the required assembly for high hazard connections. The cross 4 City of Galena Park (TX1010009) Inspection Date: February 13, 2025 connection control plan also lacked an incident response plan for a backflow contamination event. The System representative stated that Galena Park has an ordinance that allows for termination of water service if annual backflow assembly test results are not received. The EPA inspection team requested a copy of the ordinance, but the System representative did not provide the ordinance. Lead and Copper Rule (LCR) and Lead Service Line (LSL) Review The EPA inspection team reviewed the System's LCR sampling plan and list of tiered sample sites. The System identified the correct number of sample locations (30) and has additional sites identified if needed. The tiering of sites indicates the System currently has 11 Tier 1 sites with known LSLs, one Tier 2 site, 17 Tier 3 sites, and one site noted as "N." The EPA inspection team could not verify what "N" indicates in the sample site plan. The System representative stated that the System completed the LSL inventory but was not able to submit it to TCEQ by the required date of October 16, 2024. The System representative stated that the electronic file created to summarize the inventory results was lost during a hard drive crash on the laptop and the water superintendent is in the process of recreating the file. The System representative stated approximately 25 LSLs were identified on the customer side and approximately 10 unknowns were identified. The System has not received a violation for missing the October 16, 2024 deadline. Disinfection Byproducts (DBP) Rule Review The EPA inspection team reviewed the System's DBP Site Sampling Plan. The plan was complete and adequately identified the required number of sample sites, associated sample site location, and frequency of sampling. Revised Total Coliform Rule (RTCR) Review The EPA inspection team reviewed the System's RTCR Site Sampling Plan. The plan identified the adequate number of routine and repeat sample sites with addresses for each location. The plan did not have a current map showing sample locations or the requirement to obtain a raw water sample from the well or wells in use when a coliform-positive sample result occurs. Cyanide MCL Violation Discussion The System samples quarterly for cyanide (regulated and analyzed as free cyanide) at the entry to distribution at Plant #2 (designated as EP002 in TCEQ's database). Cyanide sample results at EP002 since January 2022 are presented in Table 2. The System had a sample above the free cyanide MCL of 0.2 mg/L in December 2023 (see bold text in Table 2) and TCEQ issued a violation for a cyanide MCL in the first quarter of 2024. The System representative believes the cyanide is in City of Houston's water as the water sampled at EP002 was all City of Houston water and not well water. However, the System did not have corresponding raw well water samples and City of Houston samples to confirm this theory. Research of City of Houston's entry point sampling revealed a cyanide sample result at EP001 of 0.2 mg/L taken on October 24, 2024. TCEQ's Drinking Water Watch database did not list any cyanide MCL 5 City of Galena Park (TX1010009) Inspect ion Dat e: Febru ary 13, 2025 violations for City of Houston. The most recent cyanide sample results taken by Galena Park indicate the cyanide concentrations are below the MCL. Table 2. City of Galena Park Free Cyanide Sample Results from EP002 (Plant #2} Sample Date Result, mg/L 1/ 10/ 2022 <0.01 4/ 6/ 2022 < 0.01 8/ 19/ 2022 < 0.01 10/ 13/ 2022 < 0.01 3/ 27/ 2023 0.05 6/ 28/ 2023 0.19 9/ 8/ 2023 0.05 11/ 13/ 2023 0.22 12/4/2023 0.28 1/ 18/ 2024 0.22 4/ 24/ 2024 0.06 9/ 10/ 2024 0.05 10/ 25/ 2024 0.05 1/ 18/ 2025 0.15 Plant #1 Site Visit The EPA inspection team v isited Plant #1 (designated at EP00l in TCEQ's database) starting at 1:00 PM local t ime. The front door to the office was locked and equipped with an intrusion alarm. The entire site is fenced w ith a locked gate (see Appendix 3. Photograph 8). The office is equipped with Hach Colorimeter II benchtop test kit s for total chlorine, monochloramine, and free ammonia. The System takes daily total chlorine samples of the water prior to entry to distribution. The System takes weekly monochloramine and free ammonia samples . All sampling efforts are conducted manually and recorded on daily log sheets (see Appendix 3. Photograph 9). The free ammonia reagent was past it s expiration date of December 2024. The System representative discarded the reagent and replaced w ith new reagent w hile the EPA inspection team was onsite. The EPA inspection team did not observe the use of polyphosphate, chemical feed pumps for polyphosphate feed, or an injection point on the piping for polyphosphate during the inspection . The EPA inspection Team viewed the follow ing assets at Plant #1 (see Appendix 2. City of Galena Park Water System Schematic): Inlet pipe from City of Houston main. 180,000-gallon concrete ground-level storage tank. Water from Cit y of Houston discharges directly into thi s storage tank. The tank exterior exhibited numerous areas of spalling and the overflow pipes discharge near the top of the tank (see Appendix 3. Photograph 10). The access ladder w as missing a cage lock (see Appendix 3. Photograph 11). This storage tank is scheduled for replacement w ithin the next year. Booster pump station. Three parallel booster pumps pull water from the 180,000-gallon storage tank and pump into the System' s distribution system. The pumps are manually operated. The booster pump station building had a broken window (see Appendix 3. Photograph 12). One 6 City of Galena Park (TX1010009) Inspection Date: February 13, 2025 booster pump did not have a motor shaft guard (see Appendix 3, Photograph 13). The booster pump building and pumps are dilapidated and scheduled for replacement. The booster pump discharge line to distribution had an air release valve with a missing screen and a threaded sample tap (see Appendix 3, Photograph 14). x Well #3. Operators exercise this well and pump to waste; water from this well has not been placed into the distribution system for years. The well discharge piping had a threaded raw water sample tap (see Appendix 3, Photograph 15) and a missing well vent screen (see Appendix 3, Photograph 16). The well discharge piping is connected to the 180,000-gallon storage tank. A house is located near the property line (approximately 30 feet west of Well #3) and the System representative does not know where the sewer service line for the house is located (see Appendix 3, Photograph 17). 3rd Street is approximately 70 feet north of the well and a sewer main resides in 3rd Street. x Chlorine gas feed room. Chlorine gas is used if Well #3 is in use. Chlorine gas has not been used for years as Well #3 water is currently not discharged to distribution. The chlorine gas feed system was not in operation during the inspection. x Natural gas generator to operate the booster pumps and well. The EPA inspection team did not observe a liquid ammonium sulfate chemical feed system at the treatment plant site. However, there were injection points for both chlorine gas and liquid ammonium sulfate with associated sample taps on the well discharge line. Plant #2 Site Visit The EPA inspection team visited Plant #2 starting at 1:45 PM local time. The entire site is fenced with a locked gate (see Appendix 3, Photograph 18). The System takes daily total chlorine samples of the water prior to entry to distribution. The System takes weekly monochloramine and free ammonia samples . All sampling efforts are conducted manually and recorded on daily log sheets (see Appendix 3, Photograph 19). The EPA inspection Team viewed the following assets at Plant #2 (see Appendix 2, City of Galena Park Water System Schematic): x Inlet pipe from City of Houston main. x 1-MG welded steel ground-level storage tank. Water from City of Houston discharges directly into the bottom of this storage tank. The fence near the 1 MG storage tank had a tree near the fence and signs of vegetation on the fence (see Appendix 3, Photograph 20). This storage tank is scheduled for rehabilitation within the next year, including removing the inlet at the bottom of the tank and replacing with a new inlet discharging into the top of the tank to improve water circulation. x Booster pump station. Two parallel booster pumps pull water from the 1-MG storage tank and pump into the 0.5-MG elevated storage tank and the System's distribution system. The booster pumps are controlled by a pressure switch. The booster pump station sits below grade and is prone to flooding, with water standing on the floor (see Appendix 3, Photograph 21). The building is equipped with a sump pump to remove water. The booster pumps and building are scheduled to be replaced. 7 City of Galena Park (TX1010009) Inspection Date: February 13, 2025 x 0.5-MG elevated storage tank. The booster pumps feed the elevated storage tank. The storage tank drain line had a threaded sample tap with a hose connected at the time of the inspection. The System representative disconnected the hose during the inspection (see Appendix 3, Photograph 22). The hose allowed water to run constantly during the recent cold weather to prevent the pipe from freezing. The bolts on the support base of the tank were corroded (see Appendix 3, Photograph 23). The bolts are scheduled for replacement and cathodic protection is planned. The ladder cage was not locked and secured (see Appendix 3, Photograph 24). x Chlorine gas feed room. Chlorine gas is used if Well #5 is in use. The chlorine gas sensor did not have a visual alarm and the auto-dialer is disabled due to repeated false alarm call-outs. Minor repairs to the chlorine feed system are ongoing (see Appendix 3, Photographs 25 and 26). A chlorine gas cylinder is stored in the chlorine building but chlorine was not being fed at the time of the inspection since Well #5 is not in use. The chlorine gas room is scheduled for rehabilitation. x Natural gas generator to operate the booster pumps. x Well #5. Well #5 is about 100 yards from Plant #2. Operators exercise this well and pump to waste; water from this well has not been placed into the distribution system for years. The well is fenced with a locked gate, but the area is not signed to identify Galena Park as the owner and with contact information. The fence had a large gap (see Appendix 3, Photograph 27). The well discharge piping had a threaded raw water sample tap (see Appendix 3, Photograph 28). The well motor, base, and discharge piping had peeling paint and corrosion (see Appendix 3, Photographs 28 and 29). The discharge piping is scheduling for rehabilitation as part of water system upgrades. The EPA inspection team did not observe a liquid ammonium sulfate chemical feed system at the treatment plant site. RRA and ERP Document Review The EPA inspection team reviewed the System's Section 1433 RRA and ERP and the System's cybersecurity practices. Section III - OBSERVATIONS SDWA Section 1433(a), 42 U.S.C. 300i-2, Community Water System Risk and Resilience requires a CWS serving more than 3,300 persons to conduct an RRA of its system, including an assessment of: a. the risk to the system from malevolent acts and natural hazards; b. the resilience of the pipes and constructed conveyances, physical barriers, source water, water collection and intake, pretreatment, treatment, storage and distribution facilities, electronic, computer, or other automated systems (including the security of such systems) which are utilized by the system; c. the monitoring practices of the system; d. the financial infrastructure of the system; e. the use, storage, or handling of various chemicals by the system; and f. the operation and maintenance of the system. 8 City of Galena Park (TX1010009) Inspection Date: February 13, 2025 Observation 1. On February 13, 2025, the EPA inspection team completed an inspection of Respondent's System under SDWA Section 1445, 42 U.S.C. 300j-4. The EPA inspection team requested to review Respondent's RRA and observed the following: a. Document was available at the time of the inspection. b. The RRA was dated to show that it was completed before the date of the certification of completion. c. The RRA did assess all required elements of Section 1433(a). d. The RRA did not include a complete assessment of the required elements. SDWA Section 1433(b), 42 U.S.C. 300i-2, Community Water System Risk and Resilience requires a CWS serving more than 3,300 persons to conduct an ERP of its system, including an assessment of: a. strategies and resources to improve the resilience of the system, including the physical security and cybersecurity of the system; b. plans and procedures that can be implemented, and identification of equipment that can be utilized, in the event of a malevolent act or natural hazard that threatens the ability of the CWS to deliver safe drinking water; c. ZZZZZ malevolent act or natural hazard on the public health and the safety and supply of drinking water provided to communities and individuals, including the development of alternative source water options, relocation of water intakes, and construction of flood protection barriers; and d. strategies that can be used to aid in the detection of malevolent acts or natural hazards that threaten the security or resilience of the system. Observation 2. During the inspection, EPA inspectors also reviewed Respondent's ERP and observed the following: a. Document was available at the time of the inspection. b. The ERP was dated to show that it was completed before the date of the certification of completion. c. The ERP did complete all required elements of Section 1433(b). National Primary Drinking Water Regulations Title 40 CFR 141.90 (e)(1) states, "No later than October 16, 2024, the water system must submit to the State an inventory of service lines as required in 141.84(a)." Observation 3. The System representative stated that they inventoried service lines and identified approximately 25 lead service lines and 10 unknowns. The compiled information was not submitted to TCEQ by October 16, 2024 due to the loss of electronic data. National Primary Drinking Water Regulations Title 40 CFR 141.62(b) states (summarized from the table), "Cyanide (as free cyanide) MCL is 0.2 mg/L." Observation 4. The System had a cyanide MCL violation in December 2024 result of 0.28 mg/L. The System representative stated the water purchased from City of Houston is the source of the 9 City of Galena Park (TX1010009) Inspection Date: February 13, 2025 cyanide. The EPA inspection team does not have sufficient cyanide sample results from City of Houston or Galena Park well water to confirm or dispute this statement. Texas Administrative Code Title 30, Part 1, 290.41(c)(3)(K) states, "A well casing vent shall be provided with an opening that is covered with 16-mesh or finer corrosion resistant screen, facing downward, elevated and located so as to minimize the drawing of contaminants into the well." Observation 5. The EPA inspection team observed a missing screen on Well #3 vent (see Appendix 3, Photograph 16). Texas Administrative Code, Title 30, Part 1, 290.44 (c) (7) states, "Air release devices on treated waterlines shall be installed in such a manner as to preclude the possibility of submergence or possible entrance of contaminants. In this respect, all openings to the atmosphere shall be covered with 16-mesh or finer corrosion-resistant screening material or an equivalent acceptable to the executive director." Observation 6. The EPA inspection team observed a missing screen on the air release valve located on the discharge line to the distribution system at Plant #1 (see Appendix 3, Photograph 14). Texas Administrative Code, Title 30, Part 1, 290.41(c)(1)(A) states, "No well site which is within 50 feet of a tile or concrete sanitary sewer, sewerage appurtenance, septic tank, storm sewer, or cemetery; or which is within 150 feet of a septic tank perforated drainfield, areas irrigated by low dosage, low angle spray on-site sewage facilities, absorption bed, evapotranspiration bed, improperly constructed water well, or underground petroleum and chemical storage tank or liquid transmission pipeline will be acceptable for use as a public drinking water supply. Sanitary or storm sewers constructed of ductile iron or polyvinyl chloride (PVC) pipe meeting American Water Works Association (AWWA) standards, having a minimum working pressure of 150 pounds per square inch (psi) or greater, and equipped with pressure type joints may be located at distances of less than 50 feet from a proposed well site, but in no case shall the distance be less than ten feet." Observation 7. Well #3 is located approximately 30 feet east of the property line where a house resides. The sewer service line material and location for this house is unknown (see Appendix 3, Photograph 17). Texas Administrative Code Title 30, Part 1, 290.46(m) states, "Maintenance and housekeeping. The maintenance and housekeeping practices used by a public water system shall ensure the good working condition and general appearance of the system's facilities and equipment. The grounds and facilities shall be maintained in a manner so as to minimize the possibility of the harboring of rodents, insects, and other disease vectors, and in such a way as to prevent other conditions that might cause the contamination of the water." AWWA Manual, M27 External Corrosion Control for Infrastructure Sustainability, Chapter 1 states, "The health of water consumers may be threatened whenever extensive corrosion breaches the sanitary integrity of the water system. The ever-present danger of backflow of contaminated liquid into the 10 City of Galena Park (TX1010009) Inspection Date: February 13, 2025 drinking water system is further increased when water pressure is interrupted to facilitate repairs on corroded wells, pumps, treatment equipment, pipes, valves, and services." EPA How to Conduct a Sanitary Survey of Drinking Water Systems (2019) Section 10.4.8 states, "Concrete foundations should be inspected to ensure that there is minimal spalling (ground level tanks) and no cracks (elevated tanks). Anchor bolts should not be rusted so much that their material strength has been compromised. Column shoes should be clean and painted, and grout under the shoes and riser plates should be in good condition. There should not be any pooled water, erosion, weeds, or shrubs around a tank's foundation." Observation 8. The EPA inspection team observed excessive concrete spalling on the 180,000gallon storage tank at Plant #1 (see Appendix 3, Photograph 10). Observation 9. The EPA inspection team observed support base corrosion and corroded bolts on the 0.5-MG elevated storage tank at Plant #2 (see Appendix 3, Photograph 23). Observation 10. The EPA inspection team observed peeling paint and excessive corrosion on Well #5 motor, motor base, and discharge piping (see Appendix 3, Photographs 28 and 29). Recommended Standards for Waterworks (Ten State Standards) (2022 Edition), Section 6.0 states, "No pumping station shall be subject to flooding." EPA How to Conduct a Sanitary Survey of Drinking Water Systems (2019) Section 5.6.1 states, "The pumping station should be above the highest flood level, and surface runoff should drain away from it. Pumping stations should have adequate drains to protect the pumping equipment from flooding if a pipe breaks inside the facility. Water systems should have compartments that are below grade, such as wet wells and dry pits, properly sealed to prevent the entry of undesirable water, either through the walls or from surface runoff. Dry pits should include a sump and sump pump." Observation 11. The EPA inspection team observed standing water on the floor at Plant #2 booster pump station building (see Appendix 3, Photograph 21). AWWA Standard, G100-11 Water Treatment Plant Operation and Management, 4.2.4 states, "Areas of the plant shall be maintained in a neat and orderly condition. Operation and maintenance functions should be conducted in such a manner that plant site safety and water quality are not compromised." Observation 12. The EPA inspection team observed a missing motor shaft guard on the pump at the Plant #1 booster pump station (see Appendix 3, Photograph 13). AWWA Management Standard, G100-11 Water Treatment Plant Operation and Management, 4.3.2 states, "The plant shall have documentation of a cross-connection control and backflow prevention program or be part of a cross-connection control program run by another entity." 11 City of Galena Park (TX1010009) Inspection Date: February 13, 2025 Recommended Standards for Water Works (Ten States Standards) (2022 Edition), 3.2.7.3.5 states, "The discharge piping shall...be equipped with smooth nosed sampling tap..." Recommended Standards for Water Works (Ten States Standards) (2022 Edition), 8.10.1 states, "There shall be no connection between the distribution system and any pumps, pipes, hydrants, or tanks through which unsafe water or other contaminating materials may be present and could be drawn into the distribution system." EPA How to Conduct a Sanitary Survey of Drinking Water Systems (2019) Section 12.5.4.3 states, "Water treatment plants can have a variety of potential cross-connections. If they do exist, the water system should eliminate them with an air gap or, if that is not possible, the appropriate backflow prevention device or assembly. The surveyor should determine whether the following cross-connections exist:... hose bibs without vacuum breakers..." Observation 13. The EPA inspection team observed threaded sample taps on the booster pump discharge line at Plant #1 (see Appendix 3, Photograph 14), at Well #3 (see Appendix 3, Photograph 15), on the 0.5-MG elevated tank drain line with a hose attached (see Appendix 3, Photograph 22), and at Well #5 (see Appendix 3, Photograph 28). Recommended Standards for Water Works (Ten States Standards), 2022 Edition, Section 5.7.3 states, "...When pressurized chlorine gas is present, continuous chlorine leak detection equipment is required and shall be equipped with an audible alarm and a warning light." Observation 14. At the time of the inspection, the chlorine gas feed building and system were under repair (see Appendix 3, Photographs 25 and 26) and the chlorine gas sensor was only connected to an audible alarm, but there was no warning light. Recommended Standards for Water Works (Ten States Standards), 2022 Edition, Section 6.1.1.a states, "Pumping facilities shall be in fenced enclosures and/or in buildings that are secured." Observation 15. The EPA inspection team observed a broken window at the booster pump station at Plant #1 (see Appendix 3, Photograph 12). Recommended Standards for Water Works (Ten States Standards), 2022 Edition, Section 7.1.4 states, "Fencing, locks on access manholes, and other necessary precautions shall be provided to prevent trespassing, vandalism, and sabotage." Observation 16. The EPA inspection observed the access ladder cage on the 180,000-gallon storage tank at Plant #1 lacks a locking mechanism (see Appendix 3, Photograph 11) and the 0.5MG elevated storage tank at Plant #2 lacks a locked ladder cage (see Appendix 3, Photograph 24). Observation 17. The EPA inspection team observed a tree adjacent to the fence that could damage the fence or provide access over the fence at Plant #2 (see Appendix 3, Photograph 20). 12 City of Galena Park (TX1010009) Inspection Date: February 13, 2025 Texas Administrative Code Title 30, Part 1, 290.46 (t) states, "System ownership. All community water systems shall post a legible sign at each of its production, treatment, and storage facilities. The sign shall be located in plain view of the public and shall provide the name of the water supply and an emergency telephone number where a responsible official can be contacted." Observation 18. Well #5 lacks a sign with the name of the water supply and an emergency telephone number where a responsible official can be contacted (see Appendix 3, Photograph 27). National Primary Drinking Water Regulations Title 40 CFR 141.63 Maximum contaminant levels (MCLs) for microbiological contaminants(e)(3) states, "Proper maintenance of the distribution system including appropriate pipe replacement and repair procedures, main flushing programs, proper operation and maintenance of storage tanks and reservoirs, cross connection control, and continual maintenance of positive water pressure in all parts of the distribution system;" Texas Administrative Code Title 30, Part 1, 290.46(i) states, "Plumbing ordinance. Public water systems must adopt an adequate plumbing ordinance, regulations, or service agreement with provisions for proper enforcement to ensure that neither cross-connections nor other unacceptable plumbing practices are permitted (See 290.47(b) of this title (relating to Appendices))." Texas Administrative Code Title 30, Part 1, 290.44(h)(4) states, "All backflow prevention assemblies that are required according to this section and associated table located in 290.47(f) of this title shall be tested upon installation by a licensed backflow prevention assembly tester and certified to be operating within specifications. Backflow prevention assemblies which are installed to provide protection against health hazards must also be tested and certified to be operating within specifications at least annually by a licensed backflow prevention assembly tester." Texas Administrative Code Title 30, Part 1, 290.47(f): Table f is a description of premise, assessment of hazard, and required assembly. https://texreg.sos.state.tx.us/fids/201502634-6.html Observation 19. The cross connection control plan lacks a list of premises that create a health hazard and required assembly for each hazard in accordance with Texas Administrative Code Title 30, Chapter 1, 290.47(f). Observation 20. The System representative stated the City of Galena Park has an ordinance for terminating service if annual testing is not conducted, but the EPA inspection team was not provided a copy of the ordinance. AWWA Manual M14 Backflow Prevention and Cross Connection Control, Program Administration states, "Administration of a cross-connection control program should include the investigation of any water quality complaint that indicates possible backflow contamination. Quick response by personnel trained in cross-connection control and basic water quality is necessary for the success of any investigation of a backflow incident and prevention of further contamination. The water supplier should 13 City of Galena Park (TX1010009) Inspection Date: February 13, 2025 act in cooperation with other authorities or agencies to protect the consumers of water within the premises where a contaminant or pollutant has been detected." Observation 21. The cross connection control plan lacks an incident response protocol for a backflow event. Texas Administrative Code Title 30, Chapter 1, 290.46(m)(9) states, "All critical components as described in the table in 290.47(c) associated to the source, treatment, storage, or other facilities necessary for the continued operations and distribution of water to customers must be protected from adverse weather conditions. Weatherization methods must be maintained in good condition and replaced as needed to ensure adequate protection." Observation 22. The EPA inspection team observed a hose connected to the 0.5-MG elevated storage tank drain line to prevent freezing of the drain line (see Appendix 3, Photograph 22). Texas Administrative Code Title 30, Part 1, 290.121(b)(3) states, "...a public water system that is required to collect any associated raw groundwater source(s) compliance samples, as required by 290.109(d)(4) of this title, shall include the microbial raw groundwater well compliance sites in the public water system's Sample Siting Plan. The repeat sample sites, as required by 290.109(d)(3) of this title, shall be associated to their originating routine microbial sample sites. The Sample Siting Plan shall include all groundwater sources and any associated sampling points necessary to meet the requirements of 290.109(d) of this title." Observation 23. The System's Sample Siting Plan lacks the requirement to sample at the well if the well is in use when a coliform-positive sample occurs. Texas Administrative Code Title 30, Part 1, 290.109(d)(6)(C) states, "The Sample Siting Plan shall include a distribution system map or series of maps which identifies distribution system valves and mains as described in 290.46(n)(2) of this title. The distribution system map shall also include the location of all routine microbial sample sites, water main sizes, entry point source locations, water storage facilities, and any pressure plane boundaries." Observation 24. The System's Sample Siting Plan lacks a map showing the required information in Texas Administrative Code Title 30, Part 1, 290.109(d) (6). Texas Administrative Code Title 30, Part 1, 290.110 (c)(5)(D)(i) states, "Monochloramine and free ammonia (as nitrogen) must be monitored weekly at the same time as a compliance sample required under paragraph (4) of this subsection..." Observation 25. The EPA inspection observed the reagent used to measure free ammonia was expired. 14 City of Galena Park (TX1010009) Inspection Date: February 13, 2025 AWWA Standard: G200-15 Distribution Systems Operation and Management, 4.3.2.2 states, "The utility shall have written maintenance procedures for each pumping station (including emergency power generating equipment) describing frequency, procedures, and maintenance of records. Information shall include basic manufacturer operating requirements. Records shall document all inspections and any other service performed." AWWA Standard: G200-15 Distribution Systems Operation and Management, 4.2.5.1, Valve-exercising program states, "The utility shall have a valve-exercising program. This program shall follow AWWA Manual M44...and the manufacturer's recommended procedures and include at least the following elements: 1. A goal for the number of transmission valves to be exercised annually based on the percentage of the total valves in the system. 2. A goal for the number of distribution valves to be exercised annually. 3. Measures to verify that the goals are met and written procedures for action if the goals are not attained. 4. Critical valves in the distribution system shall be identified for exercising on a regular basis. Potential water quality and isolation concerns shall be recognized. The program shall track the annual results and set goals to reduce the percent of inoperable valves...." AWWA Manual M17 Fire Hydrants states: "To carry out a meaningful inspection and maintenance program, it is essential to record the location, make, type, size, and date of installation for each hydrant. Other information also may be recorded, depending on the nature of the recordkeeping system used. When a hydrant is inspected, the record should indicate the inspection date and the condition of the hydrant. If repair work is necessary, the nature of the work should be indicated. When repair work is completed, the nature of the repairs, date, and other relevant information should be recorded. Other information, such as testing, pumping, ease of operation, direction of open, and number of turns to open, is also important and should be carefully recorded. These data may be kept in hard copy or transferred to a database on a microcomputer. It is suggested the format of these records be altered to meet individual needs." Observation 26. The System lacks written procedures for routine operation and maintenance activities. The System does not keep records of activities such as pump maintenance, hydrant flushing results, and valve exercising results. Texas Administrative Code Title 30, Part 1, 290.41(C)(3)(o) states, "All completed well units shall be protected by intruder-resistant fences, the gates of which are provided with locks or shall be enclosed in locked, ventilated well houses to exclude possible contamination or damage to the facilities by trespassers. The gates or wellhouses shall be locked during periods of darkness and when the plant is unattended." Observation 27. Texas Administrative Code Title 30, Part 1, 290.46(m) states, "Maintenance and housekeeping. The maintenance and housekeeping practices used by a public water system shall ensure the good working condition and general appearance of the system's facilities and equipment. The grounds and facilities shall be maintained in a manner so as to minimize the possibility of the harboring of rodents, insects, 15 City of Galena Park (TX1010009) Inspection Date: February 13, 2025 and other disease vectors, and in such a way as to prevent other conditions that might cause the contamination of the water." AWWA Manual M5 Water Utility Management, Chapter 7 states, "Total revenue requirements are determined by assessing the costs that are necessary to operate and maintain the utility and to finance capital investments for system expansion, upgrades, and renewal as well as to maintain adequate liquidity in the event of unplanned expenses or revenue shortfall. Identifying the appropriate amount of revenue requirements is an important first step in establishing user charges." Observation 28. The System's current water rate for a single-family dwelling of $14.46 per month for the first 6,000 gallons used does not appear adequate to allow for proper operation and maintenance of the system. The EPA inspection team observed a number of assets in need of repair, upgrades, or replacement. See Observations 8, 9, 10, 14, and 15 as examples of assets in need of repair. Section IV - CLOSING CONFERENCE The EPA inspection team held a closing conference with the System representative at 3:15 PM on February 13, 2025, at the System's office located at 105 Main Street, Galena Park, TX. The EPA inspection team discussed preliminary observations identified during the field component of the inspection. The EPA inspection team reiterated to the System representative that these preliminary observations were not compliance determinations. Preliminary observations shared during the closing conference are subject to further investigation by EPA upon the review of additional records and documentation. Therefore, this inspection report may include observations that were not identified at the time of the closing conference. Observations are described in Section III. The EPA inspection team shared observations related to cybersecurity practices with the System verbally. The inspection concluded at approximately 3:40 PM. Refer to Appendix 1, Opening and Closing Conference Sign-In Sheet. Section V - FOLLOW-UP During the closing conference, the EPA inspection team requested a copy of City of Galena Park's ordinance granting termination of water service for customers that do not conduct annual testing of backflow devices. The EPA inspection team did not receive the requested ordinance after leaving the System on February 13, 2025. Section VI- LIST OF APPENDICES Appendix 1: Opening and Closing Conference Sign-in Sheet Appendix 2: City of Galena Park Water System Schematic Appendix 3: Photograph Log 16 Appendix 1: Opening and Closing Conference Sign-in Sheet City of Galena Park (TX1010009) Inspection Date: February 13, 2025 NOTE: The same individuals attended both the opening and closing conferences as shown below. SDWA PWSS Inspection Sign-In Sheet s stem Name: o\en~Y-~ Afflllatlon Title Phone Number 17 City of Galena Park (TX1010009) Inspection Date: February 13, 2025 Appendix 2: City of Galena Park Water System Schematic (from TCEQ March 2022 Comprehensive Compliance Investigation report) Open I/C with City of Houston PWS ID 1010013, Source o. PIOI0009A 450 kW natural gas generator that ruus the whole plant Plant 1 30.t Stem1rt St. ~ tPO, L4.S -...;_---._ _;_~ EP Sample Tap 0.18 MG We113 Gl010009C Ch GR 1360GPM VT/ On-Demand SPs 2 @ 700 gpm/each 1@500gpm Open I/C with City of Houston PWS ID 1010013, Source No. P1 010009A Plant 2 1900 K~ne St. EPOOl ----+ ~ Distribution Conmmnity Con: 3431 Pop: 10293 P04 LAS EP Sample Tap We11 5 Ch G1010009D GR 1600GPM VT/ On-Demand EL SPs 2 @ 800 gpmleach EP002 264 kW nanlfal gas generator that runs the booster pumps Based on observations during the February 13, 2025 inspection, polyphosphate is no longer fed and chlorine gas and liquid ammonium phosphate were not being fed at the time of the inspection. 18 City of Galena Park (TX1010009) Inspection Date: February 13, 2025 Appendix 3: Photograph Log Unless otherwise indicated herein, all photographs were taken by Janet Cherry of ERG during the inspection. The displayed date and time are the local time (CST unless otherwise noted). Photographs were not manipulated beyond minor cropping for sizing and adding labels or callouts to draw attention to the subject of the photograph. Not all photographs taken during the inspection are included in the Photograph Log. 19 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park I County: Harris I State: Texas - - - -- ........... 4& --~l'W9t~ wA Wl:lllr. . - - . . , . . ........-i,.,......aMnb,.,.,,.~ ,.._., Ullfllcl.alctGO<O ------ J f"'O'#t:, INll"-::oltlh,-,, ,n.-., 'Illa -J: , lu<.11StO,"tll!ICC~ IDadliarN ..,...,,,....... e..,r fl , t:' ,-r .t,1 tAa, <.r-c. ~,.c,1;,r tcit<w J "" M ii. ti.itU"IIOJodf.0111,t:ie,-,n1h'l'I". J - , rutJ::CHM!ll..~ Mae~r:t llf'\_j l!COIC ct,,o,,,.e r,r1ru,t9, '"1 1"1 !, tfl( Uttt..,w. . . ,-1- 1 . h<Jtl i.lll~i::a.,. t,:t,;i11t1 Photograph 1. 2/13/2025 11:24 am P1010238.JPG Description: Records review. Written hydrant flushing program maintained by the System representat i ve. 20 UNITED STATES ENVI RONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park I County: Harris I State: Texas ....,.........._....,... "'---...,..,...,_,_nc111u.....,._ ,.._,.....,Pll,.,.,llt.,. O'ldav-- .-... _ _ ,__ ....,.,,,,e a " ' ~ to l'QlulAro,y:aUlhCfltoneonur,. , ...._"""-w_u,.....,. "-""-"tl'i:upd.,~cpl1:ma,111r.:,.1U..,r...:.:11'!t'Juns.~11na,;~are1,1d~ c 1 , , . , ,. . . Ad1w.1rfl,nd"ln@sc:ttdult-s n:r:a rinvtn: e :u n Pti1"ulVT3 '"lt.1tro;,t IJl"NaW CIU<Wt)I Photograph 2. 2/ 13/ 2025 11:24 am P1010239.JPG Description: Records review. W ritten hydrant flu shing program maintained by the System representative. 21 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 3. 2/13/2025 1:12 pm P1010245.JPG Description: Plant #1. Chlorine, monochloramine, and free ammonia test kits. 22 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park I County: Harris I State: Texas Photograph 4. 2/13/2025 9:04 am P1010235.JPG Description: Records review. Daily log sheet kept by operators for Plant #2, January 2024. 23 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 5. 2/13/2025 9:04 am P1010234.JPG Description: Records review. Daily log sheet kept by operators for Plant #2, August 2024. 24 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas ..................... Photograph 6. 2/13/2025 9:08 am P1010236.JPG Description: Records review. Work orders for water main leaks and repairs. 25 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park I County: Harris ...... N14Al .,ntuA,(_,l..,,-1, ..........,.. I State: Texas -- - .............. ....... t-<---!--~-i==:.:,.... - - - - - - - ::.:::---.,.-.-_-____ 1-+-=1.-:.-=.t_~~:..:.:c=_=-=.=:::..,:=====------I ................................ Photograph 7. 2/13/2025 9:14 am P1010237.JPG Description : Records review. Monthly tank inspections performed by the operator. 26 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 8. 2/13/2025 1:00 pm P1010240.JPG Description: Plant #1. Office building and fence around facilities. 27 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 9. 2/13/2025 9:04 am P1010243.JPG Description: Plant #1. Daily log sheet kept by operators for Plant #1, February 2025. 28 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 10. 2/13/2025 1:29 pm P1010258.JPG Description: Plant #1. Overflow pipes and spalling concrete on 180,000-gallon storage tank. 29 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 11. 2/13/2025 1:39 pm P1010264.JPG Description: Plant #1. Missing lock on ladder cage on 180,000-gallon storage tank. 30 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park I County: Harris I State: Texas Photograph 12. 2/13/2025 1:28 pm P1010256.J PG Description: Plant #1. Booster pump station building w ith broken w indow. 31 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 13. 2/13/2025 1:26 pm P1010254.JPG Description: Plant #1. Booster pumps; red pump is missing the motor shaft shield. 32 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 14. 2/13/2025 1:25 pm P1010253.JPG Description: Plant #1. Booster pump discharge piping to distribution. Air release valve with missing screen and threaded sample tap. 33 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 15. 2/13/2025 1:24 pm P1010252.JPG Description: Plant #1. Well #3 with raw water threaded sample tap. 34 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park I County: Harris I State: Texas I , I PM 1:20 FEB/13/2025 Photograph 16. 2/13/2025 1:20 pm P1010251.JPG Description: Plant #1. Well #3 vent with missing screen. 35 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 17. 2/13/2025 1:20 pm P1010250.JPG Description: Plant #1. Well #3 and house to the west, approximately 30 feet between the well and fence that borders the house. Approximately 70 feet between the well and 3rd Street. 36 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 18. 2/13/2025 1:49 pm P1010266.JPG Description: Plant #2. Fenced area with locked gate at Plant #2. 37 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 19. 2/13/2025 1:00 pm P1010244.JPG Description: Plant #2. Daily log sheet kept by operators for Plant #2, located at the Plant #1 office. February 2025. 38 UNITED STATES ENVI RONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park I County: Harris I State: Texas Photograph 20. 2/ 13/ 2025 2:11 pm P1010286.JPG Description : Plant #2 . Segment of fence near 1-MG storage tank w ith a nearby tree and overgrow n vegetation. 39 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park I County: Harris I State: Texas 'i Standing water. Photograph 21. 2/13/2025 2 :01 pm P1010276.JPG Description: Plant #2. Booster pump station with standing water on the floor. 40 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 22. 2/13/2025 1:55 pm P1010270.JPG Description: Plant #2. 0.5-MG elevated tank drain line with threaded sample tap and hose (System representative disconnected hose during the inspection). 41 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 23. 2/13/2025 1:52 pm P1010268.JPG Description: Plant #2. Corroded bolts and base on 0.5-MG elevated storage tank. 42 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 24. 2/13/2025 2:00 pm P1010275.JPG Description: Plant #2. Ladder cage lock not secured on the elevated tank. 43 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park I County: Harris I State: Texas Photograph 25. 2/13/2025 2:07 pm P1010282.JPG Description: Plant #2. Chlorine gas room with ongoing repairs. 44 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 26. 2/13/2025 2:06 pm P1010281.JPG Description: Plant #2. Partially-full chlorine gas cylinder. 45 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 27. 2/13/2025 2:15 pm P1010286.JPG Description: 46 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 28. 2/13/2025 2:16 pm P1010291.JPG Description: Well #5. Threaded raw water sample tap and corrosion on motor, motor base, and discharge piping. 47 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Galena Park Public Water System City of Galena Park County: Harris State: Texas Photograph 29. 2/13/2025 2:16 pm P1010290.JPG Description: Well #5. Corroded and peeling paint on well discharge piping. 48