Document rO3ELeB07jv3XEbX9JQVKEaq

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) Company Name: Facility Name: Facility Physical Location: 03/1/2023 Water SDWA-PWS D & M Water Supply Corporation (WSC) D & M WSC 111 Buck Alley (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Douglass, TX 75943 PO Box 9 Douglass, TX 75943 Nacogdoches County 936-559-9900 Robert Shumate rshumate.dmwsc@gmail.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: TX1740010 Personnel participating in inspection: Jessica Moore ECDWR Sami Doupnik ECDWR Robert Shumate D & M WSC Sherri Read D & M WSC Head Operator Lead Inspector Inspector Head Operator Office Manager EPA Lead Inspector Signature/Date Jessica Moore ll Date Supervisor Signature/Date CURRY JONES Digitally signed by CURRY JONES Date: 2023.04.17 22:46:29 -05'00' Curry Jones 4/17/2023 Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION D & M WSC / TX1740010 Inspection Date 03/01/2023 PURPOSE OF THE INSPECTION EPA Region 6 inspectors Jessica Moore and Sami Doupnik arrived at D & M WSC at 10:00 am on 03/01/2023 for an announced inspection. D & M agreed to participate in a training exercise conducted by the National Enforcement Investigation Center (NEIC) and EPA Region 6 for roughly 25 inspectors from Oklahoma, Texas, Louisiana, and EPA Region 6. We met with Robert Shumate, Lead Operator, and Sherri Read, Office Manager. I presented my credentials to Mr. Shumate and informed him that this was an EPA inspection to determine compliance with the Safe Drinking Water Act and train new state and federal inspectors. The scope of the inspection is to inspect the physical water plants and associated storage facilities. The inspection is not a full Sanitary Survey, nor does it take the place of the Texas Commission on Environmental Quality Comprehensive Compliance Investigations, performed triennially. The training specifically focused on evaluating Disinfection By-Product reduction for water systems. FACILITY DESCRIPTION D & M WSC purchases water from the City of Nacogdoches and provides water through groundwater wells. The water system provides treated, filtered surface water purchased from Nacogdoches to ten pressure planes, and groundwater to eight pressure planes through four drinking water wells. The inspection centered on the Douglass, Eden, and Alazan Plants. The Douglass Plant consists of Well No. 7, Well No. 6 (inactive), a 0.125 MG ground storage tank, three service pumps, one 0.010 MG pressure tank and a generator. The plant utilizes gas chlorine for disinfection. The Eden plant consists of Well No. 8, a 0.25 MG ground storage tank, three service pumps, and two 0.0054 MG pressure tanks. The Eden plant utilizes polyphosphate for sequestration and gas chlorination for disinfection. The Alazan Plant consists of Well No. 1, a 0.25 MG ground storage tank, two or three service pumps, a 0.010 MG pressure tank, and a generator. The Alazan Plant utilizes polyphosphate for sequestration, caustic soda for pH control, and gas chlorination for disinfection. The water system employees one Class A operator and 3-4 assistant operators. The head operator is retiring in the second quarter of 2023. His replacement was unknown at the time of the inspection. Section II - OBSERVATIONS The training group visited three of the groundwater plants for the purpose of the inspection. The observations are limited to the three groundwater plants and the Emergency Response and Risk and Resiliency plans EPA administers through America's Water Infrastructure Act (AWIA). Douglass Plant Observations x I observed an open hole where the electrical wire enters the well (Photo 2) x I observed open holes in the electrical conduit (Photo 3) x The well had some area of insulation removed to access well (Photo 4) 2 D & M WSC / TX1740010 Inspection Date 03/01/2023 x We observed a flap style cover on the storage tank overflow. Seal appeared airtight at time of inspection, however small amount of rust and corrosion was showing (Photo 5) x We observed a hole in the side of the insulation of the bottom of the ground storage tank. Unable to observe where hole led to (Photo 6) x We observed ammonia being stored in the chlorine room at the treatment plant (Photo 7) x We observed a pressure tank with a new air relief valve in the open position on the top of the storage tank (Photo 8 and 9) x We observed a diesel generator onsite for the well. We were informed that over the last freeze the water system maintained running water through the last two heavy freezes but did have pressure issues Eden Plant Observations x We were informed the well at this location was two years old and was drilled following a collapse x We observed a heavily insulated well and well pad that was consistent with recent construction (Photo 10) x We observed the chemical injection point marked by multiple large rocks and were informed rocks were to prevent mowing accidents (Photo 11) x We observed areas of the ground storage tank foundation being eroded (Photo 12) x We observed staining and erosion from supporting gravel and rock from the storage tank overflow (Photo 13) x We observed erosion of the foundation gravel around the bottom of the tank on all sides of the tank (Photo 14) x We observed ammonia in the chlorine room of the water plant at this location x We observed a polyphosphate tank in a secondary containment bin of unknown capacity (Photo 15) Alazan Plant Observations x We observed one well supplying the Alazan plant (Photo 16) x We observed an opening around the electrical conduit on the well (Photo 17) x We observed corrosion on the top part of the overflow of the ground storage tank where it met the pipe coming directly from the tank (Photos 18-20) x We observed a large amount of corrosion at the base of the overflow for the ground storage tank. There were also many dead bugs in the overflow indicating the seal is not air tight (Photos 21-24) x We observed the fan in the chlorine room pulling air into the chlorine room (Photo 25) x We observed operation and maintenance information written directly on pump (Photo 26) x We observed a double wall storage tank in the chemical storage room on an elevated platform (Photo 27) x We observed a large tank in secondary containment but volume of secondary containment unknown (Photo 29) x We observed a key in the door of the chemical storage room that had been painted and rusted into the lock (Photo 28) Emergency Response and Risk and Resiliency Plans 3 D & M WSC / TX1740010 Inspection Date 03/01/2023 x We observed the completed plans certified by the water system per the requirements of the American Water Infrastructure Act x We reviewed the plans against the small systems checklist published by EPA x We observed many of the elements to be complete x We observed the monitoring and sampling plan was absent from the document Section III - AREAS OF CONCERN Douglass Plant Areas of Concern (AOC) x The electrical conduit box had four holes on the back of the panel that were open to the air x The electrical conduit into the well was open which could be a potential path for contamination x We were unable to confirm where hole in insulation on the side of the ground storage tank led x Ammonia should not be stored inside of the chlorine room Eden Plant AOCs x Several areas around the base of the ground storage tank had areas where the gravel is eroding, at times under the tank at least the length of a pen x The ammonia was stored inside the chlorine room at the plant Alazan Plant AOCs x The electrical conduit into the well was open which could be a potential path for contamination x The overflow had significant corrosion throughout the pipe. Very significant corrosion was seen at the top of the pipe and at the outflow with numerous dead bugs in the pipe. The seal was not air/water tight since bugs were able to access the inside of the pipe. x The exhaust fan in the chlorine room was blowing air into the room instead of pushing air out as designed. This would not clear out a potential chlorine leak x Recording maintenance information directly onto a pump is easily lost through pump maintenance such as painting x We were unable to determine if the secondary containment of the single walled chemical tank was sufficient x The key in the door of the chemical room is a security concern since it has been left in the door long term Emergency Response and Risk and Resiliency Plans AOCs x The sampling plan was not present in the document, water system noted it would be added by reference EPA Region 6 inspectors Jessica Moore and the training group conducted a closing conference at D & M WSC at 15:00 on March 1, 2023, for the inspection. During the closing conference, Jessica Moore reviewed the 12 Areas of Concern noted during the inspection. Section IV - FOLLOW UP No additional information was received by EPA after exiting the Facility on March 1, 2023. 4 Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 29 photos taken 03/01/2023 Appendix 2 - Sign In Sheet From Inspection D & M WSC / TX1740010 Inspection Date 03/01/2023 5 D & M WSC / TX1740010 Inspection Date 03/01/2023 Appendix 1 Photographic Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 1 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1547 Date of Photo: 03/01/2023 Time of Photo: 10:42 Photographer: Sami Doupnik Description: Map of D & M WSC UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 2 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1548 Date of Photo: 03/01/2023 Time of Photo: 10:46 Photographer: Sami Doupnik Description: Hole in electrical conduit on well casing UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 3 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1549 Date of Photo: 03/01/2023 Time of Photo: 10:46 Photographer: Sami Doupnik Description: Holes in electrical box UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 4 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1550 Date of Photo: 03/01/2023 Time of Photo: 10:54 Photographer: Sami Doupnik Description: Douglass Well UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 5 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1551 Date of Photo: 03/01/2023 Time of Photo: 10:57 Photographer: Sami Doupnik Description: Seal at bottom of ground storage tank overflow UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 6 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1552 Date of Photo: 03/01/2023 Time of Photo: 10:58 Photographer: Sami Doupnik Description: Hole in insulation connected to the ground storage tank UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 7 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1553 Date of Photo: 03/01/2023 Time of Photo: 11:05 Photographer: Sami Doupnik Description: Ammonia in chlorine room at water plant UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 8 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1554 Date of Photo: 03/01/2023 Time of Photo: 11:13 Photographer: Sami Doupnik Description: Pressure relief valve at the top of the pressure tank UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 9 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1555 Date of Photo: 03/01/2023 Time of Photo: 11:13 Photographer: Sami Doupnik Description: Pressure tank at Douglass Plant UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 10 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1556 Date of Photo: 03/01/2023 Time of Photo: 13:53 Photographer: Sami Doupnik Description: New well at Eden Plant UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 11 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1557 Date of Photo: 03/01/2023 Time of Photo: 13:54 Photographer: Sami Doupnik Description: Chemical feed location at Eden Plant, rocks marking location UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 12 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1558 Date of Photo: 03/01/2023 Time of Photo: 13:56 Photographer: Sami Doupnik Description: Erosion at foundation of ground storage tank UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 13 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1559 Date of Photo: 03/01/2023 Time of Photo: 13:57 Photographer: Sami Doupnik Description: Discoloration from splashing from tank overflow UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 14 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1560 Date of Photo: 03/01/2023 Time of Photo: 14:00 Photographer: Sami Doupnik Description: Foundation erosion beneath storage tank UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 15 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1561 Date of Photo: 03/01/2023 Time of Photo: 14:05 Photographer: Sami Doupnik Description: Chemical storage tank in secondary containment UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 16 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1562 Date of Photo: 03/01/2023 Time of Photo: 14:24 Photographer: Sami Doupnik Description: Well at Alazan Treatment Plant UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 17 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1563 Date of Photo: 03/01/2023 Time of Photo: 14:25 Photographer: Sami Doupnik Description: Electrical conduit on well open to casing UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 18 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1564 Date of Photo: 03/01/2023 Time of Photo: 14:30 Photographer: Sami Doupnik Description: Corrosion at top of overflow pipe UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 19 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1565 Date of Photo: 03/01/2023 Time of Photo: 14:30 Photographer: Sami Doupnik Description: Corrosion of overflow pipe UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 20 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1566 Date of Photo: 03/01/2023 Time of Photo: 14:30 Photographer: Sami Doupnik Description: Zoomed in view of corrosion at top of overflow pipe UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 21 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1567 Date of Photo: 03/01/2023 Time of Photo: 14:31 Photographer: Sami Doupnik Description: Paint peeling, rust, and biological matter seen inside overflow pipe or ground storage tank UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 22 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1568 Date of Photo: 03/01/2023 Time of Photo: 14:31 Photographer: Sami Doupnik Description: Paint peeling, rust, and biological matter seen inside overflow pipe or ground storage tank UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 23 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1569 Date of Photo: 03/01/2023 Time of Photo: 14:33 Photographer: Sami Doupnik Description: Rust on lid of overflow on ground storage tank UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 24 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1570 Date of Photo: 03/01/2023 Time of Photo: 14:35 Photographer: Sami Doupnik Description: Hole seen on underside of overflow pipe on ground storage tank UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 25 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1571 Date of Photo: 03/01/2023 Time of Photo: 14:39 Photographer: Sami Doupnik Description: Exhaust fan in chlorine room UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 26 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1572 Date of Photo: 03/01/2023 Time of Photo: 14:41 Photographer: Sami Doupnik Description: Maintenance records on paint of pump UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 27 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1573 Date of Photo: 03/01/2023 Time of Photo: 14:51 Photographer: Sami Doupnik Description: Double walled storage tank UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 28 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1574 Date of Photo: 03/01/2023 Time of Photo: 14:54 Photographer: Sami Doupnik Description: Key permanently located in chemical storage room UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: D & M WSC TX1740010 City: Douglass Photo No. 29 County/Parish: Nacogdoches State: Texas Photo File Name: DSCN1575 Date of Photo: 03/01/2023 Time of Photo: 14:55 Photographer: Sami Doupnik Description: Secondary containment in chemical room