New Staff Needed to Address TCEQ Water Quality Violations

City Council will consider adding five positions to comply with TCEQ cross connection control standards.  The top part of the form is pictured above and reveals personnel costs of $310,600.  Text from the bottom portion is below:

Justification: Provide a brief summary of the need and purpose for this proposed position

The Water Quality division provides laboratory services to the City in the sampling, analyzing, evaluating, reporting and consulting on City water / wastewater quality and plant operational issues. The division is also responsible for preparing the annual Consumer Confidence Report and administering the city’s backflow prevention program and industrial waste program. With only 5 personnel in the division, this does not provide enough staff to perform the tasks of a robust backflow prevention program and maintain the regulatory compliance for both the water and wastewater systems. Following the events of February 2021, the TCEQ will be monitoring the City's efforts to enhancing the program.

The addition of a Water Protection Crew within the Water Quality division will allow for personnel to ensure Customer Service Inspections (CSI) are performed on new construction (as part of plumbing inspection); material improvement, corrections, or addition to existing plumbing; periodic inspections of commercial and industrial customers; or if there is a complaint or other suspicion for residential.

Note* = One FTE will replace the FTE that was utilized from Water Distribution that was used to create the Backflow Technician (Grade 21) currently employed. 

I received this information from a public information request asking city staff to answer Mayor Brenda Gunter's question during the last City Council meeting about not conducting inspections prior to toxic chemicals entering the public water supply:

The question is, because of the PaulAnn issue we had to do these inspections, but why weren't inspections done prior to contamination to have seen some of this a year ago, two years ago, six months before the contamination?--Mayor Brenda Gunter

Adding a Water Protection Crew was the only information provided regarding the city's failure to meet TCEQ requirements in place since August 2016.  The Texas Commission on Environmental Quality conducted an investigation which found a number of disturbing items.  TCEQ completed their investigation in early June.  It provides historical information, along the lines of the Mayor's request.

City staff received a Notice of Violations (NOV) Letter from TCEQ on Wednesday, June 9th.  TCEQ sent the Notice of Violations via certified mail to Mayor Gunter at City Hall and Water Utilities Director Allison Strube.  The city had ten days to appeal the notice.  TCEQ and city staff indicated the city chose not to appeal the findings 

The June 4, 2021 dated Notice of Violations listed four areas which comprise TCEQ's cross connection control program.  A March blog post noted those four areas.  City Council viewed the same four areas in their last meeting, held June 15th.

Three of the four violations must be corrected by early August, while the one involving city ordinances has an October 2021 due date. The city does not face fines from TCEQ if it addresses all identified issues within the specified time frame.

Council meets tomorrow to discuss budget priorities.  Complying with TCEQ requirements will be front and center.  Executive Director of Public Works Shane Kelton and Water Utilities Director Allison Strube will present on strategy #1-Infrastructure, which includes water/wastewater.

Update 6-23-21:  The Strategic Planning event was postponed from 6-22-21 to 6-28-21.  The city later added the Notice of Violations letter TCEQ sent to Mayor Gunter in response to the public information request..  

Update 7-22-21:  City Council will entertain water funds as part of the budget process.  It's not clear where staff put the $310,600 for new CSI staff to comply with TCEQ requirements.  To avoid future fines the City must comply with TCEQ standards that have been in place since 2016.  Council has not taken up the TCEQ investigative report in public session since the report was issued.

Update 7-27-21:  Mayor Gunter challenged the need for five people to do the work required to comply with TCEQ's Cross Connection Control Program in today's budget session.  Water Chief Allison Strube admitted the work should have been done years ago and staff added along the way.  No one said the city must comply with the TCEQ investigative report or face fines. Current water fund balance is $28.5 million.  Three of the cited failures have an August correction date, while the ordinance deficit must be completed by October 2021. I hope TCEQ staff watch today's City Council meeting.  They will learn how the City of San Angelo operates.