Document gD1g3D5w5LE5QLy8Nvj0m8Bz3

Inspection Date(s): Media Program: Regulatory Program(s) 11/07/2024 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 Odessa City of Odessa PWS 119 W Fourth St Odessa, TX 79760 PO Box 4593 Odessa, TX 79760 Ector County 432-335-4632 Alex Rowlett mrowlett@odessa-tx.gov I I Interim Director of Utilities System Classification PWS ID: Media Identifier Number: NAICS: SIC: Community Water System (CWS) TX0680002 N/A 221310 4941 Personnel participating in inspection: Daniel Kim EPA Region 6 Janet Cherry ERG Jack Fowler ERG Alex Rowlett City of Odessa Chastity Tijerina City of Odessa Wray Carpentar City of Odessa Justin Boroff City of Odessa Rip Halbaedier City of Odessa Nolberto Aguirre City of Odessa Saimon Karki City of Odessa Inspector Inspector Inspector Interim Director of Utilities Compliance Coordinator I&E Technician SCADA Specialist Plant Supervisor Cybersecurity Analyst IT Manager EPA Lead Inspector Signature/Date ,__cc ~b ~ 12/5/2024 Supervisor Signature/Date Janet Cherry Date RU BEN ALAYON-GONZALEZ Digitally signed by RUI EN ALAYON-GONZALEZ Date: 2024.12.13 10:21 l36-06'00' Ruben Alayon-Gonzalez Date 6ENFORM-019-R8.2 (02/12/2020) 1 City of Odessa (TX0680002) Inspection Date: November 7, 2024 Section I - INTRODUCTION PURPOSE OF INSPECTION On November 7, 2024, United States Environmental Protection Agency (EPA) and the EPA contract inspectors from Eastern Reach Group (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 City of Odessa Public Water System (referred to as the System or City of Odessa) (TX0680002). The inspection process began at approximately 8:00 a.m. on November 7, 2024 and finished at approximately 4:10 p.m. Daniel Kim of EPA Region 6 and Janet Cherry and Jack Fowler of ERG presented their SDWA inspector credentials to System representatives during the opening conference. The EPA inspection team informed the System representatives that this was an EPA inspection to determine compliance with SDWA Section 1433, which requires community water systems that serve more than 3,300 people to complete a Risk and Resilience Assessment (RRA) and develop an Emergency Response Plan (ERP). The EPA Inspection Team also informed System representatives that they would be conducting a cybersecurity evaluation alongside the Section 1433 review. 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 Conference Sign-in Sheet. SYSTEM DESCRIPTION According to Drinking Water Watch, the System is owned by the City of Odessa, serves a population of approximately 123,334 people, and has 55,910 service connections. The EPA inspection team reviewed the above information with the System during the inspection process via conversations, with the System stating the population was probably closer to 125,000 people. It is a community water system as defined by 40 C.F.R., Part 141 Subpart A. The System serves the City of Odessa plus four other consecutive systems: Ector County Utility District (TX0680235) Hanna Water Hauler (TX1540021), which sells water to two other systems: AHG Odessa (TX1650182) and Iron Horse Ranch Odessa Lodge (TX0680223) Northgate Mobile Home Park (TX0680013) Deweys Breakfast Shop (TX0680220) All raw water is purchased from Colorado River Municipal Water District (CRMWD) (TX0000001) through an agreement between City of Odessa and CRMWD. The raw water source is primarily surface water from Lake Ivie supplemented by the Ward Wellfield, but City of Odessa can also be served surface water from Spence Reservoir (also owned by CRMWD). Lake Ivie is open to the public for recreation and fishing. City of Odessa staff and CRMWD staff meet monthly to discuss planned infrastructure upgrades, review drought contingency plans, and other issues. CRMWD recently improved the dam at Lake Ivie. CRMWD engineering team also provides updates to City of Odessa council. 2 City of Odessa (TX0680002) Inspection Date: November 7, 2024 CRMWD pumps raw water approximately 150 miles via two 32-inch transmission lines from Lake Ivie to two 80 million gallon (MG) raw water reservoirs located across the street from the City of Odessa's water treatment plant (Appendix 2, Photograph 1). CRMWD's well water is also conveyed in the transmission lines from Lake Ivie. The City of Odessa owns the two raw water reservoirs, but CRMWD owns all preceding raw water conveyance infrastructure. The 80-MG reservoirs provide approximately 3 days of storage during peak summertime water use and approximately 7 days of storage during wintertime use in the event the CRMWD raw water supply experiences disruptions. All raw water from CRMWD is treated at the Odessa water treatment plant with coagulation, flocculation, filtration and disinfection before being pumped to the distribution system via seven finished water pumps. City of Odessa water treatment plant operators communicate daily with CRMWD operators on current conditions and flow demands. CRMWD does not provide water quality data to City of Odessa; all raw water is monitored as it enters City of Odessa's water treatment plant. City of Odessa operators monitor raw water turbidity, pH, and temperature and note any changes. As example, an algae bloom is noticed by an increase in pH along with visual observation of algae in the raw water. The water treatment plant operates continuously and is staffed 24 hours per day. The System is working on its valve exercise and replacement program. The current condition of distribution system isolation valves has resulted in the entire distribution system being shut down to allow water main repairs at certain locations. All valves are inventoried and a contractor is hired to commence isolation valve evaluations and replace valves deemed as inoperable. The valve replacement program will allow the System to better isolate sections of the water distribution system for main repairs and limit the need for future system-wide shut down events during main repairs. Section II- INSPECTION ACTIVITY SUMMARY Water Treatment Plant Site Visit The EPA inspection team walked through portions of the water treatment plant starting at 2:00 PM local time. Photographs taken during the water treatment plant visit are presented in Appendix 2, Photograph Log. At the time of the inspection, the System was undergoing major upgrades at the water treatment plant including rehabilitation of one of the clearwells, upgrade of the SCADA system, renovation of the treatment buildings, upgrade of the chemical feed systems, and construction of new sedimentation basins. The System anticipates that all upgrades will be completed by the end of 2025. These upgrades will allow the water treatment plant to produce 55 million gallons per day of treated water. The water treatment plant is fenced with a locked gate and video cameras. Water treatment plant operators can view the video feed inside the temporary SCADA room (refer to Appendix 2, Photograph 2). The water treatment plant is staffed 24 hours per day. Additionally, there are computer stations that authorized staff can access to make PLC changes with login credentials (refer to Appendix 2, Photograph 3). City of Odessa has approximately 30 days of chemical storage at the water treatment plant. All treated water is pumped to the distribution system. Seven finished water pumps are located in a separate building at the water treatment plant site. System representatives stated that 3 pumps are 3 City of Odessa (TX0680002) Inspection Date: November 7, 2024 typically operating at a time to meet demands and keep finished water reservoirs full. One of the finished water pumps was offline for repairs during the inspection. The water treatment plant is equipped with a generator sufficiently sized to run all water treatment plant equipment and finished water pumps (refer to Appendix 2, Photograph 4). The generator is equipped with a 2,000-gallon fuel tank, enough for the generator to operate 24 hours. City of Odessa staff conduct full-load tests of the generator monthly. The City of Odessa also has fueling stations and is in the process of building 5 additional remote fueling stations to improve resiliency. The generator allowed the water treatment plant to remain in service during the February 2021 snowstorm. The 80-MG raw water reservoirs reside across the street from the water treatment plant and are fenced with a locked gate. The City of Odessa has a laboratory adjacent to the water treatment plant accredited for coliform sample analysis along with wastewater parameter analyses. The lab can also provide total organic carbon, alkalinity, pH, chlorine residual, and UV254 analysis for the water system for process control purposes. City of Odessa staff stated that all water system buildings are equipped with intrusion alarms that notify the police immediately. In addition, water treatment plant staff monitor water system facilities equipped with video cameras that transmit video to the water treatment plant. City staff visit all pump stations, booster chlorination facilities, and storage facilities 2 to 3 times per week. Document Review The EPA inspection team reviewed the System's RRA and ERP onsite. According to EPA's Shared CROMERR Services (SCS) database, the System most recently certified completion of its RRA and ERP on March 27, 2020 and September 24, 2020, respectively. The System developed its RRA using the American Water Works Association J100 Standard and the EPA's Vulnerability Self-Assessment Tool (VSAT). The System developed a list of 33 critical asset threat-pairs. A separate cybersecurity assessment was also prepared. The System did not include CRMWD assets in the RRA as these assets are owned, operated, and maintained by CRMWD. The System will need to recertify the updated RRA to EPA by March 31, 2025. The System maintains hardcopies of its ERP. The ERP addressed responses to the 33 critical asset threatpairs identified in the RRA. Updated System contact information for the ERP was provided as separate documents. The ERP contained mutual aid agreements with nearby entities. The ERP was dated March 2020. The System will need to recertify the updated ERP to EPA by September 30, 2025. Section III - OBSERVATIONS Texas Administrative Code, Title 30, Part 1, 290.44 (d) (5) states: "The system shall be provided with sufficient valves and blowoffs so that necessary repairs can be made without undue interruption of service over any considerable area and for flushing the system when required. The engineering report shall establish criteria for this design." 4 City of Odessa (TX0680002) Inspection Date: November 7, 2024 AWWA Management Standard, G200-15 Distribution Systems Operation and Management, 4.2.5.1 states: "The utility shall have a valve-exercising program. This program shall follow AWWA Manual M44 and the manufacturer's recommended procedures" Observation 1. System representatives stated lack of operating isolation valves within the distribution system resulted in a system-wide shutdown to facilitate a recent water main repair. At the time of the inspection, the System was working on a valve assessment and replacement program to address this issue but did not have a formal valve exercising program. Section IV - CLOSING CONFERENCE The EPA inspection team held a closing conference with System personnel at 3:35 PM on November 7, 2024, at the water treatment plant conference room. The EPA inspection team discussed preliminary observations identified during the field component of the inspection. The EPA inspection team reiterated to the System representatives 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. Observations regarding the cybersecurity practices were shared with the System verbally. The inspection concluded at approximately 4:10 PM. Refer to Appendix 3, Closing Conference Sign-In Sheet. Section V - FOLLOW-UP No additional information was requested or received by EPA after leaving the System on November 7, 2024. Based on EPA Inspection Team's review of the 2020 RRA, the following are offered for System consideration for the next 5-year RRA certification cycle ending on March 31, 2025: Given the extensive water treatment plant and associated SCADA system improvements currently in progress, the updated RRA should include the operational technology (OT) assets and other assets installed as part of the upgrades. The System should work with CRMWD to better share source water monitoring data at Ivie Lake and the wells. The System should investigate the ability to have interconnections with City of Midland in the event CRMWD sources are off-line for an extended period. Based on EPA Inspection Team's review of the 2020 ERP, the following are offered for System consideration for the next 5-year RRA certification cycle ending on September 30, 2025: 5 City of Odessa (TX0680002) Inspection Date: November 7, 2024 The ERP did not have a specific response for main breaks but the System has a separate standard operating procedure (SOP) for main break responses. The SOP did not include procedures for a system-wide water service shutdown, which has been required recently for main breaks due to inoperable isolation valves. The ERP did not have a specific response for loss of a finished water storage tank. The ERP contact information requires updates to reflect current staff. Updated staffing lists were provided during the inspection in separate printouts, but specific response activities also need to have the most current staff listed. The ERP should be updated to reflect the water treatment plant and SCADA system upgrades once these improvements are completed. The System should train all new staff about the ERP and provide ongoing training for existing staff. Section VI- LIST OF APPENDICES Appendix 1: Opening Conference Sign-in Sheet Appendix 2: Photograph Log Appendix 3: Closing Conference Sign-in Sheet 6 City of Odessa (TX0680002) Inspection Date: November 7, 2024 Appendix 1: OOpening CCoonnference SSiiggn-in SShheeet City of Odessa, TX SOWA AW IA Focused Inspection Kickoff Meeting Name Affiliation, TIiie Email Address Date: 11/07/2 024 Phone Number L.fJl.- 335- '-11.Jl.... <-/JJ.. 335- 4CP33 ~~1 - JJ5 - '{{, t(~ 7 City of Odessa (TX0680002) Inspection Date: November 7, 2024 Appendix 2: P!Phhoottooggraph Log Unless otherwise indicated herein, all photographs were taken by Jack Fowler 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. 8 City of Odessa (TX0680002) Inspection Date: November 7, 2024 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Odessa Public Water System City of Odessa County: Ector State: Texas 80-MG Raw Water Reservoir Photograph 1. 11/7/2024 15:30 DSC05788.JPG Description: Water Treatment Plant. The 80 MG raw water reservoirs are located directly across the street from the treatment plant. 9 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Odessa Public Water System City of Odessa County: Ector State: Texas Photograph 2. 11/7/2024 14:49 DSC05773.JPG Description: Water Treatment Plant. The temporary SCADA control room is locked when not in use. Changes to the SCADA system require login credentials. 10 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Odessa Public Water System City of Odessa County: Ector State: Texas Photograph 3. 11/07/2024 14:49 (time displayed is EST) P1010139.JPG Description: Water Treatment Plant. A PLC access location. Changes to the PLC login require login credentials. 11 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: City of Odessa Public Water System City of Odessa County: Ector State: Texas Photograph 4. 11/7/2024 14:54 DSC05774.JPG Description: Water Treatment Plant. The treatment plant generator can operate the entire plant at full capacity. 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