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States Environmental Protectior Agency
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
October 18, 2022 Water CWA
Company Name: Facility Name: Facility Physical Location:
(City, state, zip code) Mailing address:
(City, state, zip code) County: Facility Phone Number Facility Contact:
City of Watauga
Wastewater Utility Department
Public Works Office, 7800 Virgil Anthony Blvd.
Watauga, TX 76148
Public Works Office, 7800 Virgil Anthony Blvd.
Watauga, TX 76148
Tarrant
817-514-5806 Paul Hackleman PHackleman@cowtx.org
I I Public Works Director
FRS Number: Permit ID Number: NAICS: SIC:
110010927104 TXU001118 221320 4952
Personnel participating in inspection:
Taylor Alvarez
City of Watauga
Alan Vaughn
EPA Region 6
Damon McElroy
EPA Region 6
City Official (Utility Superintendent) EPA Enf. Officer and Inspector EPA Enf. Officer and Inspector
EPA Lead Inspector Signature/Date
Supervisor Signature/Date
ALAN VAUGHN Date: 2022.11.30 10:45:52 -06'00' Digitally signed by ALAN VAUGHN
Alan Vaughn
Date
ROBERTO BERNIER Date: 2022.11.30 16:20:06 -06'00' Digitally signed by ROBERTO BERNIER
Roberto Bernier
Date
6ENFORM-019-R8.2 (02/12/2020)
1
Section I - INTRODUCTION
City of Watauga Wastewater Utility Dept. Inspection Date: October 18, 2022
PURPOSE OF THE INSPECTION
EPA Region 6 inspectors Alan Vaughn and Damon McElroy arrived at the City of Watauga Public Works office at 9:00 am on October 18, 2022, for an announced inspection. We met with Tony Alvarez, the City of Watauga representative, indicated above and illustrated in the Appendix 1 Sign-In-Sheet. I presented my EPA Inspector Credentials informing Mr. Alvarez this was an EPA inspection to determine compliance with the Clean Water Act regarding sanitary sewer overflows from the wastewater collection system. The scope of the inspection is a compliance evaluation to determine if capacity, management, operations, and maintenance (CMOM) is sufficient to prevent sanitary sewer overflows (SSO).
FACILITY DESCRIPTION
The City of Watauga (City) serves approximately 23,677 residents (2020 census), with 8,247 residential and 615 commercial service connections. All areas that have sewer lines are connected and routed through the sanitary sewer collection system to the Village Creek wastewater treatment plant that is owned and operated by City of Fort Worth. The City's sanitary sewer collection system does not utilize any lift stations.
When an overflow occurs, TCEQ is notified by the City as required by the SOP (standard operational procedure) for managing and reporting SSOs. The sanitary sewer system infrastructure (i.e., gravity pipe and manholes) is up to 20 to 30 years old. There are about 81 miles (427,680 LF) of sewer pipes ranging in size from 4 to 12 inches in diameter. The wastewater gravity mains consist of about 51% vitrified clay with most of the remainder consisting of PVC and to a lesser amount cast iron, concrete, and polyethylene pipe. Five (5) SSOs were reported to TCEQ from May 2021 to September 2022, due to clogged main. The City puts these reported SSO locations on a monthly cleaning cycle.
Preventative maintenance to avoid stoppages and sewer backups and condition-responsive repair work represent a large part of the wastewater utility workload. The City has a goal of cleaning the entire system once per year. Contractor support is available for emergency remedial or repair work. There are currently three utility city staff openings. Public Works employees maintain current TCEQ licenses. Repair, maintenance, monitoring, and maintaining proper flow within the collection system are the City's responsibility. Wastewater maintenance falls under the City's Public Works (PW) department. Wastewater services are provided 24 hours per day. After-hour wastewater emergencies can be addressed via dispatch.
2
City of Watauga Wastewater Utility Dept. Inspection Date: October 18, 2022
Section II - OBSERVATIONS
The City has a Capacity Management Operations and Management Program (CMOM) to include the following:
x Targeted pipe and manhole cleaning and condition assessment. x Targeted manhole remediation (12.4% annually). x Routine inspection program for gravity pipes and manholes. x Routine gravity pipe and manhole remedial measures according to Capital Improvement
Projects (CIP) identified in the City's 5-year Capital Improvement Plan. x Public education about FOG and no-flush items. x SSO response plan. x Long-term routine sewer cleaning program. x Employee training. x City ordinances for wastewater utility operation (needed for FOG inspections and Private Service
Line Remediation program).
Staffing
x The City has three open positions for utility officials for the City to be considered fully staffed. Most projects and initiatives will be carried out with existing staff and contract support.
Section III - AREAS OF CONCERN
x With three (3) current utility staff openings, the City lacks sufficient wastewater staff to provide a CMOM program capable of preventing SSOs or to stop sewer backups.
Section IV -RECOMMENDATIONS
x The City should establish sufficient methods to obtain and hold on to sufficient wastewater officials.
Section V -SUGGESTIONS
1. The City should create comprehensive wastewater utility Standard Operational Procedures.
2. Reference the EPA "Guide for Evaluating Capacity, Management, Operation, and Maintenance (CMOM) Programs", January 2005, available on the web-address: https://www3.epa.gov/npdes/pubs/cmom_guide_for_collection_systems.pdf
3
City of Watauga Wastewater Utility Dept. Inspection Date: October 18, 2022
SECTION VI -REGULATORY INFORMATION: The City's collection system is regulated under the:
x Texas Water Code (TWC) x Texas Administrative Code (TAC) x Texas Health and Safety Code x Clean Water Act (CWA) x Code of Federal Regulations (CFR) x Associated CRWWS NPDES General Permit Conditions Below is a list of regulatory information pertinent to the Watauga's Wastewater utility program: A. Failure to prevent unauthorized/unpermitted discharges or Sanitary Sewer Overflows as
stipulated in TAC 305.125(9); TWC 26.121(a); Section 301of the CWA; and 40 CFR 122.1(b). B. Failure to report SSOs; as stipulated in Title 30 of the TAC 305.125(9), TWC 26.121, & 40 CFR
122.41(l)(6). C. Failure to implement proper O&M of the collection system as stipulated in Title 30 of the TAC
305.125(5) & 40 CFR 122.41(e). Section VII - FOLLOW UP Watauga SSO Reports and Work Orders were received by EPA after exiting the Facility on October 18, 2022. Section VIII - LIST OF APPENDICES
Appendix 1 - Opening conference Sign-In Sheet Appendix 2 - Reported SSOs from 5/2021 to 9/2022 Appendix 3 - TCEQ Regulatory Guidance
4
City of Watauga Wastewater Utility Dept. Inspection Date October 18, 2022
Appendix 1 Opening Conference Sign-In Sheet
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 6
1201 ELM STREET, SUITE 500 DALLAS, TEXAS 75270-2102
DATE: TIME: SUBJECT:
October 18, 2022
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City of Watauga, Texas
MEETING ATTENDEES
NAME
COMPANY PHONE NO.
EMAIL
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Page 1 of 1
City of Watauga Wastewater Utility Dept. Inspection Date October 18, 2022
Appendix 2 Watauga SSOs Reported to TCEQ
Water Qualify Noncompliance Notification
*See back of Form for Guidance for Completion*
l8l Unauthorized Discharge
D Reportable Effluent Violation
D Other
General Information
Entity Name: City Of Watauga
181 Permlttee
0 Subscriber
TCEQ Region: 4
County: Tarrant
Noncom Hance Summa
Telephone No: (817) 514-5846 *Permit Number: TX 2200328
Description of Noncompliance (Include location, discharge route, and estimated volume of unauthorized discharge):
Manhole overflowed at 6317 Saramac Or, closest two Intersecting streets are Deborah Ln and Karen Ln. Flowed 5 feet south into storm drain inlet at approximately SGPM from 6:00am to 10:00am Total of 1200 gallons
Cause of Noncompliance: Grease and posslble Debris in line
.
Duration:
Start Date and Time: 5/10/2021 6:00 AM
End Date and Time: 5/10/2021 10:00 Am
2[
Corrected:
Potential Danger to Human Health and Safety or the Environment: N/A
Date Expected to be
Actions Taken
Monitoring Data: Data should be attached or submitted to TCEQ when available.
0 Yes 181 No Field Measurements D Yes 181 No Laboratory Samples D Yes 181 No Fish Kill If yes, estimated number killed:
Actions Taken to Mitigate Adverse Effects: City crew unclogged main using Gap-vax sewer truck. Ran cleaning hose with jet nozzle from downstream manhole to upstream manhole.
Actions Taken to Correct the Problem and Prevent Recurrence: Camera main to make sure their Isn't a more severe issue, and continue to do routine cleaning.
Verification Information Information Reported By (Name/Title): Taylor Alvarez/Utjlity Supervisor Date Reported: 5/10/2021 Signature: ~ ~
~ : If this form is being used for a 5-day written report, a copy of the form 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.
* If the noncompliance Is an unauthorized discharge from a wastewater collection system, use the permit number of
the treatment plant to which the c:ollectlon system is tied. If you are uncertain of this permit number, you may call the TCEQ Regional Office for assistance.
TCEQ - 00501 (Rev. 09-07-10)
Page 1 of2
Water Quality Noncompliance Notification
*See back of Form for Guidance for Completion*
181 Unauthorized Discharge
0 Reportable Effluent Violation
0 Other
I General Information
., I"'',/,
I
Entity Name: City of Watauga
181 Permlttee
D Subscriber
Telephone No: (817) 514-5846
TCEQ Region: 4
I Noncompliance Summary
County: Tarrant
*Permit Number: TX 2200328
Description of Noncompliance (Include location, discharge route, and estimated volume of unauthorized discharge):
Manhole overflowed at 6612 Patsy ln Flowed 50 Feet North into Storm Drain inlet at approximately 20GPM from 8:00am to 10:00am Total of 2400 gallons.
Cause of Noncompliance: Grease in line
Duration:
Start Date and Time: 9/21/2021 8 :00AM End Date and Time: 9/21/2021 10:00AM
Qr Date Expected to be Corrected:
Potential Danger to Human Health and Safety or the Environment: N/A
! Actions Taken
..
a Monitoring Data: Data should be attached or submitted to TCEQ when available.
D Yes D Yes D Yes
No Field Measurements No Laboratory Samples
No Fish Kill If yes, estimated number killed:
Actions Taken to Mitigate Adverse Effects: City Crew unclogged main using Gap-Vax sewer cleaning truck. Ran Cleaning hose with jet nozzle from downstream manhole to upstream manhole that was overflowing.
Actions Taken to Correct the Problem and Prevent Recurrence: Continue to do routine cleaning in area to prevent future problems.
! Verification Information
Information Reported By (Name/Title): Taylor Alyarez/utmtv Supervisor
Date Reported: 9/21/2021 Signature: ~
~
.t!t.2m: If this form Is being used for a 5-day written report, a copy of the form 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.
* If the noncompliance Is an unauthorized discharge from a wastewater collectlon system, use the permit number of
the treatment plant to which the collection system Is tied, If you are uncertain of this permit number, you may call the TCEQ Regional Office for assistance.
TCEQ - 00501 (Rev. 09-07-10)
Page 1 of 2
Water Quality Noncompliance Notification
*See back of Form for Guidance for Completion*
181 Unauthorized Discharge
0 Reportable Effluent Violation
0 Other
I General Information
. I
Entity Name: City of Watauga
Telephone No: (817)514-5846
181 Permittee
0 Subscriber
TCEQ Region: 4
I Noncompliance Summary
County: Tarrant
*Permit Number: TX 2200328
7t1
Description of Noncompliance (Include location, discharge route, and estimated volume of unauthorized discharge): Manhole overflowed at 6328 Saramac Dr, closest two Intersecting streets are Deborah Ln a Karen Ln. Flowed 5 feet south into storm drain inlet at approximately 1GPM from 7:30pm to 9:30pm Total of 120gallons
Cause of Noncompliance: Grease and possible debris in line
Duration:
Start Date and Time: 12-24-2021 7:30pm End Date and Time: 12-24- 2021 9:30pm
.Qr Date Expected to be Corrected:
Potential Danger to Human Health and Safety or the Environment: N/A
l Actions Taken
i 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: N/A
Actions Taken to Mitigate Adverse Effects: City maintenance crew unclogged main using Gap-Vax truck. Ran high
pressure cleaning hose with jet nozzle from downstream manhole to upstream manhole.
Actions Taken to Correct the Problem and Prevent Recurrence: Put on a monthly preventive maintenance cleaning program.
Verification Information
!J.~... , # 4 _ Information Reported By (Name/Title): .i....~~~--Ui!~~l,.Ll:.I.IL--J~,l,IA,fl-L-1-1,f~'-'-----------
Date Reported:
6u,J'0 ~ Signature: cf
_ _;;;z;;c:
ftsWl: If this form Is being used for a 5-day written report, a copy of the form 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.
* If the noncompliance Is an unauthorized discharge from a wastewater collectlon system, use the permit number of
the treatment plant to which the collectlon system Is tied. If you are uncertain of this permit number, you may call the TCEQ Regional Office for assistance.
TCEQ 00501 {Rev, 09-07-10)
Page 1 of 2
Water Quality Noncompliance Notification
*See back of Form for Guidance for Completion*
[x Unauthorized Discharge
C Reportable Effluent Vlolatfon
7 Other
r::G=-e_n_e_r_a-=-1-=-1n""".f:-o-r_m_a_t-=io-- n - - - - - - - -,-\- -.~---.;-'{'""1'_1:i_1(- .-. -,,..,:.;.-r_,.,.._,.l.'.:.-~'.- 1-. ;<-1 .r.-,..,.,.,:,-\,,,-,.;_-n.H.,-- -,f,.._.,.c-.,.:,.:.,-.,- .,;~~ ~,.,~(~~1..~~,~,.--;=- - - - - - , ,
Entity Name: ICity Of Watauga
Telephone No(##########): IB17-514-5859
:::J Permittee TCEQRegion: j4
ICounty: !Tarrant
lPermitNumbenjRN101276822
xl Subscriber
,___ _ _ _____,
----------
Description and Cause of Noncompliance (include location, discharge route, and estimated volume ofunauthorized discharge):
DESCRIPTION: manhole overflowed at 6317 Saramac Dr, closest two intersecting streets are Deborah Ln & Karen Ln. Flowed 5' north into a storm drain inlet at approximately 4gpm from 8:30am to 9:45am; Total of 300 gallons. CAUSE: grease & possible debris in line.
Duration:
Start Date: j1~14-22
Time: p:30am
End Date: f-14-22
Time: F:45am
Or
Date Expected to be Corrected: _I_ _ _ _ _ _ __
Potential Dangerto Human Heahh and Safety orthe Environment:
Actions Taken
Monitoring Data: Data should be attached or submitted to TCEQ when available.
Field Measurements
Laboratory Samples
0 Yes 181 No
Yes 181 No
Actions Taken to Mitigate Adverse Effects:
Fish KHl(lf yes, estimated number killed):
D Yes ~ No
City maintenance crew unclogged main using Gap-vax truck. Ran high pressure hose with jet nozzle ~rom downstream manholes to upstream manholes.
Actions Taken to Correct the Problem and Prevent Recurrence:
Put on a minthly preventative maintenace cleaning program
Information Reported By (Name/Tide): IGreg Ronquillo III/Supervisor
I
Date Reported: [1-14-22
Sig....... I~~
I
Note: If thisform~s~Ing u~;( ;5-daywrltten Nport, a copyof theform should besentto theTCEQ Region Office,and theoriginal to:
TCEQ, Compliance Monitoring Team (MC224l, Enforcement Division, P.O. Box 13087, Austin, TX 78711-3087.
Ifthe noncompliance Is an unauthorized discharge from a wastewater collection system, usethe permit number of the treatment plant ta which the collection system is tied, Ifyou are uncertain ofthis permit number, you may calltheTCEQ Regional Officefor assistance.
TCE0-00S01 (Rev.04-27-12)
Page 1of2
Water Quality Noncompliance Notification
*See back of Form for Guidance for Completlon*
~ Unauthorized Discharge
0 Reportable Effluent Vlolatlon
D Other
I General Information
') d '
Entity Name: City of Watauga
Telephone No: ( 817 ) 51-4 - 5846
0 Permlttee
~ Subscriber
TCEQ Region: 4
I Noncompliance Summary
County:Tarrant
*Permit Number:TX 2200328
Description of Noncompllance (Include location, discharge route, and estimated volume of unauthorized discharge):
Manhole Overflowed behind srdewalk in intersection of Levitt Dr and Greenfield Dr. Flowed 200ft west into storm drain inlet at approximately 20GPM from 10:30am to 11 :00am. Total of600 gallons.
Cause of Noncompliance: Greese and possible debris in line
Duration:
Start Date and Time: 9/12/2022 10:30am End Date and Time: 9/12/2022 11 :00am
2[ Date Expected to be Corrected:
Potential Danger to Human Health and Safety or the Environment: N/A
I Actions Taken
C( f
I 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:
City crew unclogged main using Gap-Vax sewer trailer. Ran cleaning hose with jet nozzle from downstream manhole at !>413 Greenfield Ct to upstream manhole in intersection of Greenfield Dr and Greenfield Ct.
Actions Taken to Correct the Problem and Prevent Recurrence: Camera main to make sure their isn't a more severe issue, and continue to do routine clearning.
I Verification Information
. , ,. ,- athe tra
Information Reported By (Name/Tltle): Date Reported: __91_1_2_12_0_2_ 2 _ _ __
r1,, Taylor Alvarezl Utility Superintendent
Signature: /
A~
tuw:: If this form Is being used for a 5-day written report, a copy of the form should be sent to the TCEQ
Region Office, and the orlglnal to: TCEQ, Compliance Monitoring Team (MC224), Enforcement Division,
P.O. Box 13087, Austin, TX 78711-3087.
* If the noncompllance Is an unauthorized discharge from a wastewater collection system, use the permit number of
the treatment plant to which the collection system Is tied, If you are uncertain of this permit number, you may call the
TCEQ Regional Office for assistance.
TCEQ 00501 (Rev. 09-07-10)
Page 1 of 2
--------------------------------~---
City of Watauga Wastewater Utility Dept. Inspection Date October 18, 2022
Appendix 3 TCEQ Regulatory Guidance
TCEQ REGULATORY GUIDANCE Office of Compliance and Enforcement RG-395 Revised September 2016
Unauthorized Discharges and Sanitary Sewer Overflows
What does this document cover?
The Texas Commission on Environmental Quality is responsible for protecting the state's waters. Part of that responsibility involves monitoring for unauthorized discharges of wastewater, including municipal, industrial, recreational, and other waterborne wastes as defined in Texas Water Code Subsection 26.001(6) and, when necessary, pursuing enforcement action for noncompliance. The purpose of this publication is to clarify the TCEQ's requirements for reporting unauthorized discharges and overflows from sanitary sewers. Do not use or interpret this document as a substitute for the complete, official version of any state or federal law, rule, or regulation.
Who should read this document?
Managers, professionals, and operating personnel from permitted facilities and subscribers.
A permitted facility is the holder of a water quality permit issued by the TCEQ or the U.S. Environmental Protection Agency (EPA). A permitted facility may be a municipality, municipal water district, private individual, or company. The TCEQ issues several types of water quality permits. The most relevant permits to this document are those that regulate collection and treatment of wastewater.
A subscriber is any municipality, business, or organization acting as a waste contributor or customer of a permitted facility. Subscribers are owners of components of satellite collection systems, such as pipes, conduits, lift stations, force mains, or other devices used to transport wastewater directly to a permitted facility or to the collection system of a permitted facility operated by a different municipality, business, or other organization. Examples of subscribers include:
a city a stand-alone store that operates its own sewage lift station a school campus an apartment complex a shopping mall a mobile-home community
TEXAS COMMISSION ON ENVIRONMENTAL QUALITY PO BOX 13087 AUSTIN, TX 78711-3087
The TCEQ is an equal opportunity employer. The agency does not allow discrimination on the basis of race, color, religion, national origin, sex, disability, age, sexual orientation, or
veteran status. In compliance with the Americans with Disabilities Act, this document may be requested in alternate formats by contacting the TCEQ at 512-239-0028, fax 512-239-
4488, or 800-RELAY-TX (TDD), or by writing PO Box 13087, Austin TX 78711-3087. We authorize you to use or reproduce any original material contained in this publication--that
is, any material we did not obtain from other sources. Please acknowledge the TCEQ as your source.
www.tceq.texas.gov/publications/rg/rg-395.html
Printed on recycled paper.
How is our customer service? tceq.texas.gov/goto/customersurvey
Unauthorized Discharges and Sanitary Sewer Overflows
TCEQ publication RG-395
What is an unauthorized discharge? What is a sanitary sewer overflow?
An unauthorized discharge (UD) is any discharge of wastewater into or adjacent to any water in the state at a location not permitted as an outfall. [See Clean Water Act Subsection 301(a) or Texas Water Code Section 26.121. For ways to locate state laws and regulations, see "Where Can I Get More Information?" at the end of this document.] An unauthorized discharge may include a discharge of wastewater onto land (paved or otherwise) or a discharge into a pond, creek, canal, river, lake, wetland, or any other body of surface water or groundwater.
A sanitary sewer overflow (SSO) is a type of unauthorized discharge of untreated or partially treated wastewater from a collection system or its components (e.g., a manhole, lift station, or cleanout) before reaching a treatment facility. [See also Texas Water Code Paragraph 26.049(e)(4).]
Do I need to report a UD or an SSO?
Yes. A permitted facility's water quality permit includes a requirement to notify the TCEQ of UDs and SSOs. A subscriber is responsible for reporting unauthorized discharges from its collection system in accordance with Title 30, Texas Administrative Code (30 TAC), Section 327.32. In addition, you may be required to notify the public under certain criteria discussed later in this document.
Is there a minimum reportable volume?
No. Permitted facilities and subscribers must report all UDs and SSOs to the TCEQ regardless of volume, as federal and state regulations do not have a specified minimum reporting volume. In addition, you may be required to notify the public under certain criteria discussed later in this document.
When do I have to report? And to whom?
24-Hour Notification to the TCEQ
Permitted facilities and subscribers are required to report the date, location, volume, and contents of the UD or SSO to their TCEQ regional office as soon as possible but no later than 24 hours after becoming aware of the event. During our normal business hours--Monday through Friday, 8 a.m. to 5 p.m.--the 24-hour notice must be given orally or by fax to your local regional office. If the UD or SSO occurs after normal business hours, your local regional office must be notified by telephone. (Be sure to note the date and time of your call in your records.) The recorded messages at each regional office explain how to notify the TCEQ after business hours.
To locate your TCEQ regional office, visit <www.tceq.texas.gov/goto/region>. The same listings are available in print in TCEQ Areas, Regions, and Environmental Assistance
2
Revised September 2016
TCEQ publication RG-395
Unauthorized Discharges and Sanitary Sewer Overflows
Regional Staff (TCEQ publication GI-002). For ways to obtain publications and other information from the TCEQ, see "Where Can I Get More Information?" at the end of this document.
24-Hour Notification to the Public
For UDs and SSOs that meet the criteria listed below and occur at facilities owned or operated by a local government, the responsible individual of the local governmental authority must notify the public via media as soon as possible but no later than 24 hours after becoming aware of the event. A responsible individual is someone who is designated by the owner of a permitted facility or subscriber system to report noncompliances. Criteria for public and media notification, as found in 30 TAC Section 319.302:
a discharge that will adversely affect a public or private source of drinking water, or
a discharge with a volume of 50,000 gallons or more where one or more of the following conditions also exists--
the spill occurs within mile of a public or private source of drinking water;
the spill occurs within mile of a private drinking-water well located within mile of a well for public water supply;
the spill occurs within mile up-gradient of a surface water intake of a public or private source of drinking water;
the spill occurs in an active groundwater-recharge area; the spill occurs up-gradient and within mile of a karst terrain or shallow
alluvial well that is a source of drinking water; or
a discharge of 100,000 gallons or more.
If a UD or SSO meeting the requirements for public notification occurs outside of normal business hours, then the responsible individual must also notify the TCEQ Emergency Response Hotline (800-832-8224). Within 48 hours after notifying the public, the responsible individual must report to the regional office that public notice has been given. Complete information regarding the public notification requirements can be found in 30 TAC Sections 319.301-03.
Five-Day Written Notification to the TCEQ
In addition to the 24-hour notice, permitted facilities and subscribers are required to submit a written report to the TCEQ within five working days after facility personnel become aware of the event. Subscribers must submit the written report to their TCEQ regional office. Permitted facilities must submit the written report to their TCEQ regional office and to the TCEQ's Enforcement Division in Austin. The written report must include:
the nature of the UD or SSO (source, location, route, volume) and its specific cause;
Revised September 2016
3
Unauthorized Discharges and Sanitary Sewer Overflows
TCEQ publication RG-395
the potential danger to human health or safety, or the environment (including monitoring data, if collected);
the duration of the UD or SSO with exact dates and times; an estimate of how long the noncompliance is expected to continue (if the
noncompliance has not been corrected at the time of reporting) actions taken to mitigate adverse effects; and steps taken to reduce, eliminate, and prevent recurrence of the noncompliance.
Monthly Written Notification to the TCEQ
UDs and SSOs that meet the following criteria may be reported to the TCEQ as a monthly summary instead of via a 24-hour or five-day written notification. The monthly summary must be submitted to your TCEQ regional office by the 20th day of the following month. The UD or SSO must:
occur at a wastewater-treatment facility or collection system owned or operated by a local government;
be 1,000 gallons or less; not be associated with another simultaneous UD or SSO; be controlled or removed before entering water in the state or adversely
affecting a public or private source of drinking water; not endanger human health or safety, or the environment; and not be otherwise subject to local regulatory control and reporting
requirements.
The monthly summary must include the following information about the UD or SSO:
its location, volume and content; its description; its cause; the dates and duration; and steps taken to reduce or eliminate it and prevent its recurrence.
The responsible person must use one of the following methods for determining the volume of UDs and SSOs that will be submitted on the monthly summary by using one of the following methods.
Visual method: For small spills, use either a 55-gallon barrel or 5-gallon bucket for reference. Determine how many barrels or buckets would be used to contain the UD or SSO.
Measured volume: Measure the length, width, and depth of the UD or SSO and then multiply by 7.5 (the conversion factor between cubic feet and gallons).
Duration and flow rate: Multiply the duration by the flow rate. Other methods that are consistent with standard and accepted industry
practices, as long as they include procedures to identify the duration, flow rate, depth, affected area, and total quantity of each spill.
4
Revised September 2016
TCEQ publication RG-395
Unauthorized Discharges and Sanitary Sewer Overflows
Is there a form I can use to report a UD or SSO?
Yes. The TCEQ has a standardized form, Water Quality Noncompliance Notification (TCEQ-00501), that can be used for the 24-hour fax notice and the five-day written report; another standardized form, Accidental Discharge or Spill Monthly Summary Form (TCEQ-20756), can be used for the monthly summary report.
Alternatively, you may submit a written report in letter format. All noncompliance notifications must include the permit number of your wastewater-treatment facility. All noncompliance notifications from subscribers must include the Regulated Entity Number (RN) of the collection system.
You must keep a copy of any written report of UDs or SSOs at the facility site and the reports must be readily available for review by TCEQ representatives for three years.
After I've completed the notification requirements, then what do I do?
Each UD or SSO incident is unique and cleanup requirements should be based on individual circumstances. In preparation, each permitted facility or subscriber capable of experiencing a UD or SSO should have a contingency plan for spills and overflows. Your plan should:
stop or mitigate the flow as soon as possible; contain the spill whenever possible; return as much of the spilled wastewater to the collection system or treatment
facility as possible; remove and properly dispose of all solids; treat and disinfect the affected area as necessary (if using chemicals, be sure
to follow the manufacturer's guidelines); act quickly to reduce any threat to human health and the environment; and assess any impact to the environment by taking laboratory samples.
After a UD or SSO, you should evaluate the causes of the incident and identify possible methods to prevent a recurrence. Remember to send your written report within five working days of becoming aware of the noncompliance unless you meet the criteria for the monthly summary.
What are the main causes of UDs and SSOs?
During dry weather, the most frequent causes of UDs and SSOs are reduced capacity, blockages, malfunctioning lift stations, and vandalism. Grease entering the collection
Revised September 2016
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Unauthorized Discharges and Sanitary Sewer Overflows
TCEQ publication RG-395
system is also a common contributor to dry-weather UDs and SSOs. It is possible to minimize dry-weather UDs and SSOs by implementing an aggressive preventive maintenance program coupled with public education. Local enforcement of grease-trap ordinances and pretreatment ordinances is also effective in reducing UDs and SSOs.
For more information about grease traps, see Waste from Grease Traps, Grit Traps, and Septic Tanks: Questions and Answers, TCEQ publication RG-389.
During wet weather, the most frequent causes of UDs and SSOs are infiltration and inflow (I/I) into the collection system due to aging and deteriorating infrastructure. Infiltration is groundwater that enters the collection system through leaky pipes, faulty pipe joints, or defective manholes. Inflow is surface runoff that enters the collection system through missing or defective manhole covers, uncovered or damaged cleanouts, illegal stormwater connections, or defective pipes and manholes in streambeds or roadside borrow ditches. I/I can be confirmed by physical inspection of collection lines and manholes, smoke testing, and inspecting collection lines with cameras. Once problem areas are identified, a plan can be formulated to reduce I/I using systematic repair and replacement.
What is the TCEQ SSO Initiative?
The goals of the SSO Initiative are to reduce the number of SSOs that occur each year in Texas and to address SSOs before they harm human health or safety, or the environment and before they become enforcement issues. Participation in the SSO Initiative is entirely voluntary and requires that the participant submit an SSO corrective action plan.
Participation excludes the collection system from formal enforcement for SSOs that are addressed by the SSO corrective-action plan. However, under certain circumstances, the TCEQ does retain the right to take enforcement action or rescind a permitted facility's or subscriber's participation.
Additional information, including who can participate, how participation in the SSO Initiative can benefit your facility, what to expect if you agree (or elect) to participate, and requirements for your SSO corrective action plan can be found in Sanitary Sewer Overflow (SSO) Initiative: Information for Prospective Participants, TCEQ publication GI-389.
Where can I get more information?
Your TCEQ regional office or the TCEQ's Small Business and Local Government Assistance Section (800-447-2827) can help. To obtain copies of TCEQ rules, publications, and forms:
Visit <www.tceq.texas.gov> online; click on the link for "Rules," "Publications," or "Forms." Download and save a copy.
Fax your order to 512-239-4488 or order by phone at 512-239-0028. Write to TCEQ Publications, MC 195, PO Box 13087, Austin, TX 78711-3087.
Try to give the rule, publication, or form number as well as the title. The numerical designation will help the TCEQ get the correct item to you as quickly as possible.
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Revised September 2016