Document mqqOVx4xGvkEL2LvvnQdv93jZ

'Aft EA~UnlledStates fnvlronmental Protettlon "'"' Agency Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 05/03/2017 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 Bedford Public Works Department 1813 Reliance Parkway Bedford, Texas 76021 1813 Reliance Parkway Bedford, Texas 76021 Tarrant Kenny Overstreet I Public Works Director Kenneth.Overstreet@bedfordtx.gov 817.952.2248 FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110037938916 TXU000145 NA 221320 4952 Personnel participating in inspection: David Long USEPA/6EN-WM Mike Tillman USEPA/6EN-WM Scott Tedford City of Bedford/Public Works Dan Mitchell City of Bedford/Public Works Jerry Laverty City of Bedford/Environmental Environmental Scientist Environmental Scientist Field Operations Manager Utility Manager Drainage Manager 214.665.7323 214.665.7531 817.952.2220 817.952.2223 817.952.2258 EPA Lead Inspector Signature/Date Supervisor Signature/Date ,!}~ {Inspector namet) ,. PM: C2ch"' J~--- {Supervisor name} I ,;_~c/~r? Date I -z/ c,.; I I Date . City of Bedford, Texas 05/03/2017 Section I- INTRODUCTION PURPOSE OF THE INSPECTION A U.S. Environmental Protection Agency (USEPA) program review inspection was conducted in the City of Bedford Public Works offices located at 1813 Reliance Parkway, Bedford, Texas 76021. 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 Bedford'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 oftheir collection system. An entry briefing was conducted by EPA-Region 6 inspectors David Long and Mike Tillman at 8:40 a.m. on May 3, 2017 at the City of Bedford Public Works' offices. The inspectors met with Kenny Overstreet, Public Works Director, Scott Tedford, Field Operations Manager, Dan Mitchell, Utility Manager, and Jerry Laverty, Drainage manager. An invitation to Greg Diehl, Inspector with the Texas Commission on Environmental Quality, had also been extended, but he chose not to attend. During the entJy 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. 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 rep01t. This rep01t is based on information supplied by the City representatives, observations made by the U.S. EPA inspectors, records and repotts maintained by the City, the State of Texas and the USEPA. PROGRAM DESCRIPTION The City of Bedford is approximately 10 square miles in size and includes an approximate population of 47,000 with 22,674 total residential and commercial water accounts which are provided wastewater services through approximately 158 miles of sewer lines. The wastewater collection is composed sewer pipes of varying sizes ranging from new to 60 years of age. The City of Bedford's collection system is comprised of mainly PVC with much smaller fi-actions of vitreous clay, concrete and iron pipe in the southern or older sections of town. The City of Bedford does not have any lift stations and, as a result, the city has not invested in a Supervisor Control and Data Acquisition (SCADA) system, otherwise, 20% of all manholes are physically inspected per year for operational capability. The City of Bedford collection system has experienced approximately 30 SSOs in the past five years. Problem areas of the collection system lines are jetted and cleaned evety 30 days with other "hot spots" monitored more often. The remainder of the system is jetted and cleaned every five years (20%/year). In addition, the City of Bedford has developed and regularly updates a Utility Master Plan to ensure that capacity and condition of the collection system is maintained. Finally, the City of Bedford expends approximately one million dollars per year on their Capital Improvement Plan (CIP) to cover capital improvements, manhole rehabilitation projects, and emergency and planned collection system line maintenance and replacement. To assist in line maintenance, the City of Bedford also utilizes CCTV of City of Bedford, Texas 05/03/2017 Program but does not use National Association of Sewer Service Companies (NASSCO) ce1tified reviewers to document functional condition of the collection system in each video. The City of Bedford is a subscriber to the TCEQ Sanitmy Sewer Overflow Initiative but has not developed a CMOM following the results of a utility/hydraulic study performed in 2008 which found the collection system to be adequate to handle flows and growth through 2018. The City of Bedford will determine prior to that date whether to continue its' membership in the SSO Initiative and/or develop a CMOM. Finally, the City of Bedford maintains an excellent public outreach and awareness program regarding SSOs and their prevention. Outreach activities include online and in-person events and fairs, door hangers, magazines and mobile grease collection activities after major holidays. Section II- OBSERVATIONS Following the review of their SSO Program, the EPA inspectors requested site tours of the City of Bedford's problem manholes and CCTV truck. A review of each of those sites revealed the following observations: 1. CCTV Mobile Units: The City of Bedford maintains one CCTV Mobile Unit with a crawler camera(s) capable of viewing sanitary pipes from six to 27 inches in diameter. The unit records well over the required 20% of their collection system each year (20,000 to 30,000 feet per year). Following review of the recorded video, a determination for maintenance or repair is developed and follow-up service is usually dispatched within two weeks. 2. Manholes: Manholes are physically visited on an as needed basis (problem areas are visited more often). However, several of the visited manholes were severely impacted by grease which will continue to cause SSO issues in their city until a better form of control or regulations are developed and/or put in place. Inspector's Note- Photos taken during this inspection were overexposed due to camera malfunction and no Photo Log will be generated. Section III- AREAS OF CONCERN At the conclusion of the inspection, the EPA inspectors met with the representatives from the City of Bedford for an exit interview at 12 noon on May 3, 201 7. At that time, the inspectors provided details of the inspection and reviewed issues noted in the inspection that might require additional follow-up or correction. These issues included: 1. During the field observations, city personnel had some difficulty in locating manholes which had been selected for review. It was suggested that their GIS Depmtment work with Public Works in developing more accurate maps with the manhole locations. 2. The City of Bedford has experienced some data loss over the past two years due to electronic failure of their data collection system and they should institute better data management techniques and systems to safeguard their collected information. Section IV- FOLLOW UP None required at this time Section V- LIST OF APPENDICES Appendix 1- City of Bedford 550 Inspection Checklist Appendix 2- City of Bedford Supplied Documents A. SSO Inspection Reports B. City of Bedford 2008 Sanitary Sewer Condition Assessment C. TCEQ SSO Reports 2014- 2017 City of Bedford, Texas 05/03/2017 City of Bedford, Texas 05/03/2017 Appendix 1 City of Bedford SSO Inspection Checklist EPA SSO Inspection Checklist Name of Municipality City of Bedford, Texas Collection System Description I. Describe the collection system. The Citv of Bedford has !58 miles of sanitary sewer mains varying in age and type of pipe. The system also includes 2.750 manholes. _______ --------- ___ -------------~--- 2. What is the population ofthe service area: Number of residents 49 151 3. How many miles of sanitary sewer mains are in the collection system? -----'1"-"5"'8_ _ _ _ _ _ _ _ __ 4. What is the age of collection system? ----"-O__,to"--"'60"--'-ye,ar,_s-"of'-''a,g,.,e'-----------~---- %VC"' %DI"' %PVC"' %Other"' Do not have this data. 5. Does the collection system experience problems during dry weather? _...N,_,o'---Describe or provide d o c u m e n t a t i o n : - - - - - - - - - - - - - - - - - - - - - - - - - - 6. Does the collection system experience problems during wet weather? _Y~es,___--:_ Describe or provide documentation: See attached wastewater flow versus precipitation showing increased flow during rain events. 7. What is your sanitary sewer overflow (SSO) notification pi'Ocedure? Reporting per TCEO regulations utilizing fonn TCE0-0050 I (Rev. 09-07-I 0) and an internal Sanitary Sewer Overflow reporting form. What is reported? See enclosed forms for report data. 8. Are all SSOs reported, regardless of size? Yes . If no, why not? - - - - - - - - - - - - - - - EPA SSO Inspection Checklist Lift/Pump Stations 1. How many lift stations are in the system? ___ , 0 ' - - - - - - - - - - - - - - - - - - - - How many have backup power s o u r c e s ? - - - - - - - - - - - - - - - - - - - - - - - - Describe=------------------------------------ 2. Describe how pump/lift stations are inspected and monitored? - - - - - - - - - - - - - - - - - - - 3. Is a SCADA system used? _ _ _If so, what parameters are monitored?------------ 4. What provisions have been made for e m e r g e n c i e s ? - - - - - - - - - - - - - - - - - - - - - - - Emergency Power?__________ --------- Critical P r o c e s s e s ? - - - - - - - - - - - - - - - - - - SCADA? ________________________________________________________ Other?________ 5. Describe any automated emergency notification/response process._________________ Satellite Systems I. Does the collection system receive flow from satellite systems? _Y_._,e,_s_____ If yes, continue with questions 2-4 2. Is flow from satellite systems monitored? No Ifyes, how? ----------- ---------.. 3. Describe any known problems with the satellite collection system (hydraulic flow, wastewater concentration, ordinances, etc.)? ___.!,N,8on J S e ' - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 4. Who is responsible for satellite systems, enforcement, and response? Citv of Hurst for their lines and Citv of Bedford for our lines. _ --------------------- Enforcement? City ofHurst for their lines and City of Bedford for our lines. Response? City of Hurst for their lines and City of Bedford for our Jines. EPA SSO Inspection Checldist Performance Indicators 1. Summarize the Capacity, Management, Operations, and Maintenance (CMOM) components utilized by the facility and satellite systems, if applicable:. ~N=/A " - - - - - - - - - - - - - - - - - - - - - 2. Does the utility participate in the TCEQ Sanitary Sewer Overflow Initiative (SSOi)?-'Y'-'e"'s'----- Ifyes, please provide the latest SSOi Annual Report. o ffno,whynot? _____________________________________________________ 3. What Standard Operational Procedures (SOP) are developed and used? ___SCADA? __Valve maintenance? ___K_Routine Inspections/Maintenance? ___K_Fleet Management? ___K_Root Control? __Lift!Pump Stations? __x_clean-up? __Other?_ _ _ _ _ _ _ _ _ __ 4. Has an infiltration & inflow (Ill) analyses or sanitary system evaluation survey been performed? Yes If yes, describe (and provide a copy of any associated reports) A full Wastewater System Evaluation was completed in 2008. An additional evaluation was completed on the 19.1 W basin in 2010. See enclosed re orts. _Smoke Testing?_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _Dye Testing?_:--::-:--:---::---c----c--------------------_x_ccTV? Completed in-house for evaluation. _x_Peaking Factors? Completed in both evaluations and in-house. If not, why not? _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ 5. Describe the sewer cleaning and inspection goals. Reduction in I & I, SSOi requirements. system maintenance andre air. _x_Hot Spots? Monthly cleaning of troubled lines. lAnnual Goals? Minimum requirement of 20% of system manholes inspected. Minimum requirement of cleaning 20% ofthe system. Minimum requirement ofvideo inspection of 14,000 feet ofthe system. 6. Describe any training for receiving, documenting, and responding to sewer calls. Discharge Estimates? In-house I on the job training. Safety/Confined Space? Confined space training by Texas Municipal League {TML) online in April2016 and a hands on course through TML on June 8. 2016. In-house training. Lockout/Tagout?_N=/A"--:--:-:--:--:----------------------------------- Reporting? In-house I on the job training. Treatment/Clean-up? In-house I on the job training. cnhe~------------------------------------------------------------------- EPA SSO Inspection Checklist 7. Describe any Asset Management process in place for the collection system. The City completed the development ofthe data and imagery for the City Geographic Information System (GIS) database in 2011. The GIS database is continually updated as information fiom field observances is reoorted. 8. Describe the funding status. -:--.,---,----,----,----c---c---,----,---.,.,-.,---,-------,--- Emergency Repairs: Budgeted annually in the base budget and also annually in a Utility Repair Fund. Operation & Maintenance: ~A=nn,.,u,..a"'l-"b"'u"'dg!>!e'-'t~.- - - - - - - - - - - - - - - - - - - - - Rehabilitation: Budget money in the Utility Repair Fund annually and also by the sAle of Bonds. Rates:____________________________________ Other? 9. Describe any formal approach to target areas for Capital Improvement Projects. After the collection system evaluation in 2008. it was noted that the 19.1W basin had substantial I & I and was in need ofrepair/rehab. It was d~.!~rmined at that time. by staff. that the lines in that basin were in need of repair and made it a priority. This area has received substantial rehabilitation. but still has areas of concerns. which staff continues to address. 10. Please provide any other relevant information. CERTIFICATION I certify undet penalty of law that I have examined and am familiar with the information provided and in any enclosed documents, including all attachments. Based on my inquiry of those individuals with primary responsibility for obtaining the information, I certifY that the statements and information are, to the best of my knowledge and belief, true, accurate, and complete. Date ilc.c:-1-cr City of Bedford, Texas 05/03/2017 Appendix 2A- City of Bedford Supplied Documents SSO Inspection Reports Water Quality Noncompliance Notification (X) Unauthorized Discharge IGeneral Information ( ) Reportable Effluent Violation () Other Entity Name: CITY OF BEDFORD Telephone No: (X) (817) 952-2224 (X) Permittee ()Subscriber TCEQ Region: 4 INoncompliance Summary County: TARRANT Permit Number*: W0-001 0303-01 Description of Noncompliance (include location, discharge route, and estimated volume If an unauthorized discharge): The manhole at 1609 Hospital Park way discharged for approximately 1.5 hour..Put out disinfect Flushed hydrant for 30 min. and odor control. 90 gallons of overflow discharge. This estimate is calculated from the time the crew received the call until the time it was resolved. Cause of Noncompliance: NATURAL CAUSES OF GREASE BUILD-UP & SAND & SEDIMENT Duration: Start Date and Time: 7/18/14 ................ 11:00 am End Date and Time: 7/18/14................. 12:00 pm Or Date Expected to be corrected: ......7/18/14 Potential Danger to Human Health and Safety or the Environment: NONE IActions Taken Monitoring Data: Data should be attached or submitted to TCEQ when available. ()Yes () No Field Measurements ()Yes () No laboratory Samples ()Yes () No Fish Kill If yes, estimated number killed: Actions Taken to Mitigate Adverse Effects: DISINFECTION BY FLUSHING HYDRANT, USING GRANULAR DEODORIZORS. Actions Taken to Correct the Problem and Prevent Recurrence: THE CREWS WILL ROUTINE CLEAN THE UP-STREAM AND DOWN-STREAM MANHLOES USING DEGREASERS. IF NECESSARY A TV INSPECTION WILL BE APPLIED. IVerification Information Information Reported By (Name/Title): Dannv Mitchell. Field Operations Manager Date Reported: 7/18/2014 M.Q!: If this form is being used for a 5-day written report, a copy of the for should be sent to the TCEQ Region Office, and the original to: TCEQ, Compliance Monitoring Team (MC224), Enforcement Division, P.O. Box 13087, Austin, TX 78711-3087. Water Quality Noncompliance Notification (X) Unauthorized Discharge IGeneral Information . ( ) Reportable Effluent Violation () Other Entity Name: CITY OF BEDFORD Telephone No: (X) (817) 952-2224 (X) Permittee () Subscriber TCEQ Region: 4 County: TARRANT Permit Number*: WQ-001 0303-01 \ Noncompliance Summary Description of Noncompliance (include location, discharge route, and estimated volume if an unauthorized discharge): The manhole at 1609 Hospital Park Way discharged for approximately 1 hour. .Put out disinfect Flushed hydrant for 30 min. and odor control. 30 gallons of overflow discharge. This estimate is calculated from the time the crew received the call until the time it was resolved. Cause of Noncompliance: NATURAL CAUSES OF GREASE BUILD-UP & SAND & SEDIMENT Duration: Start Date and Time: 7/16/14 ................ 11:00 am End Date and Time: 7/16/14................. 12:00 pm Or Date Expected to be corrected: ......7/16/14 Potential Danger to Human Health and Safety or the Environment: NONE IActions Taken Monitoring Data: Data should be attached or submitted to TCEQ when available. () Yes () No Field Measurements ( ) Yes ( ) No Laboratory Samples () Yes () No Fish Kill If yes, estimated number killed: ActionsTaken to Mitigate Adverse Effects: DISINFECTION BY FLUSHING HYDRANT. USING GRANULAR DEODORIZORS. Actions Taken to Correct the Problem and Prevent Recurrence: THE CREWS WILL ROUTINE CLEAN THE UP-STREAM AND DOWN-STREAM MANHLOES USING DEGREASERS. IF NECESSARY A TV INSPECTION WILL BE APPLIED. IVerification ln{p~mation Information Reported By (Name/Title): Danny Mitchell, Field Operations Manager o"'""'""'' '""""" ~a./~ ~: If this form is being used for a 5-day written report, a copy:tthef()Should be sent to the TCEQ Region Office, and ""'m"' the original to: TCEQ, Compliance Monitoring Team (MC224), Enforcement Division, P.O. Box 13087, Austin, TX 78711-3087. Water Quality Noncompliance Notification *See back of Form for Guidance for Completion* D Unauthorized Discharge xll Reportable Effluent Violation D Other Entity Name: City Of Bedford 952-2224 ~Permittee D Subscriber Telephone No: (817 J ) TCEQ Region: 4 County: Tarrant *Permit Number: WQ-0010303-01 Description of Noncompliance (include location, discharge route, and estimated volume of unauthorized discharge): The Manhole at 312 Gentry Way discharged for approximately 1 hour. Ran the main line and got it down and flowing. Approximately 40 gallons overflowed. This estimate is calculated from the time the crew received the call until the time it was resolved. Cause of Noncompliance: Discharge was caused by grease in the main. Main was not completely blocked still had flow down stream. Duration: Start Date and Time: 08-30-14 10:00am End Date and Time: 08-30-14 11:00am Corrected: 08-30-14 Potential Danger to Human Health and Safety or the Environment: none Or Date Expected to be Monitoring Data: Data should be attached or submitted to TCEQ when available. xli!.Yes D No ITves x~ No D Yes x ~No Field Measurements Laboratory Samples Fish Kill If yes, estimated number killed: Actions Taken to Mitigate Adverse Effects: Sucked up overflow and returned it to the system. Actions Taken to Correct the Problem and Prevent Recurrence: Cleaned the main at the time of repair. Will clean the line again and moniter. Information Reported By (Name/Title): Dan Mitchell Utility manager.