The Texas Commission for Environmental Quality completed their investigation into the February 2021 PaulAnn toxic water contamination in the City of San Angelo (COSA) public water supply. City records show the Notice of Violations letter was sent to Mayor Brenda Gunter and Water Utilities Director Allison Strube. The Mayor's letter arrived in City Hall on June 10, 2021.
The letter specified four violation areas in the city's compliance with TCEQ's cross connection control program requirements which have been in place since 2016. The slide below (without the yellow text) was presented to City Council on June 15th. I added the highlighted information and below the image is text from the TCEQ investigation.
1. Failure to conduct customer service inspections (CSIs) prior to providing continuous water service to new construction, on any existing service either when the water purveyor has reason to believe that cross-connections or other potential contaminant hazards exist, or after any material improvement, correction, or addition to the private water distribution facilities.
2. Failure to adopt an adequate plumbing ordinance, regulations, or service agreement with provisions for proper enforcement to ensure neither cross-connections nor other unacceptable plumbing practices are permitted.
3. Failure to record the date, location, and nature of water quality, pressure, or outage complaints received by the system and the results of any subSeL1Uent complaint investigation.
4. Failure to ensure that all backflow prevention assemblies which are installed to provide protection against health hazards are tested and certified at least annually by a licensed backflow prevention assembly tester.
The city had ten days to appeal the findings but chose not to appeal.
Page 9 of the investigative report revealed significant backflow from a meat processing plant over a 71 day period. The plant was not the source of the February chemical contamination but is a disturbing revelation regarding the city's "near zero" cross connection control program.
On February 10, 2021, the City's Customer Service Department identified a meter, associated to Lone Star Beef, as showing a reverse flow (Attachment #6). A meter technician was immediately dispatched by the City to shut off the meter. A combination meter, that is read as two separate meters, also associated to Lone Star Beef, were reviewed, and indicated reverse flow at one of the two readings (Attachment #6). The combination meter is a single unit; however, two meters are read, one meter for high flow and one for low flow. The City decided to lock out both meters, bringing the total to three meters shut off. City staff visited the facility to determine if any additional meters and/or City service water lines were connected to the facility. Multiple days were indicated to have reverse flow across the meters.
The meter consumption spreadsheets provided by the City, and that the City used to determine that reverse flow was occurring include both total daily consumptions, as well as a breakdown of hourly consumption rates as water flows through the meter. Mr. Louder was informed that the data supplied by the meter accurately reflected the total amount of flow per day. However, when the meter encounters an error reporting hourly values, it will take the total consumption amount for that day, and place that average amount over 24 hours into the periods it had errors reporting. [I.E. the total value divided by 24 = X which is used for hourly periods where a meter read error occurred]
The 3-meter accounts between December 1, 2020 and February 10, 2021, showed an estimated eighty (80) single hour events, instances with a negative consumption amount, totaling approximately -1,372,838.2 gallons of reverse flow. The account records showed forty-five days of zero ( o) readings as the total daily consumption, and six (6) "No Reading" listed as the total daily consumption.
It should be noted that multiple Customer Service Inspections (CSis) have been conducted at the facility since February 10, 2021, as well as investigations conducted by the TCEQ Region Office. The CSI records indicated deficiencies regarding internal cross-connections. However, at no time were any of the chemicals identified in the water found at the facility.
The city had not conducted annual backflow testing at a number of locations required for health reasons. The report cited on page 13.
By rule, backflow devices installed as a protection against a health hazard are required to be inspected annually by a licensed backflow prevention assembly tester (BPAT).
These facilities that have a backflow prevention assembly in response to a health hazard include but are not limited to facilities with graywater and irrigation with chemical feed initially tested/installed on July 13, 2015, May 2, 2016, June 16, 2016, December 13. 2016, February 15, 2017, March 22, 2017, March 31, 2017, as well as Medical/Dental/Laboratory/Mortuary facilities with initial installation/testing dates of June 25, 2019, December 17, 2019. Additionally, a wash bay with an initial installation/testing dates of November 29, 2019 requires annual testing.
TCEQ's investigator Jarrett Louder had a number of challenges working with city staff.
Additionally, Mr. Louder again requested complaint records for the City. Mr. Louder noted that a news article posted on March 3, 2021, included references to complaint logs that the TCEQ had not received during the previous February request.
On March 8, 2021, Mr. Louder emailed Mrs. Strube inquiring if additional out of town Customer Service Inspectors were assisting the City. Mrs. Strube replied informing Mr. Louder that at that time, the City did not have any out of town inspectors assisting the City. She also indicated the City was working on contracting with a 3rd party to perform inspections until they had their program up and running.
On March 16, 2021, the City provided an update on the water contamination issue at a city council meeting. The update included that "the chemical volume that caused the contamination could have been less than a gallon". Additionally, the City posted a press release with the update information as well as a "Frequently Asked Questions" (FAQ) document on their website regarding the water contamination (Attachment #3).
Mr. Louder followed up with Mrs. Strube at a later date to inquire how the City had determined that amount that could have caused the contamination event. Mr. Louder was informed that the City and their consulting engineer determined the amount based on flow models and distribution maps, based on the properties of the chemicals of interest. It is noted that Mr. Louder had previously requested from the City an estimated amount that they believed could have caused the event, and no information had been provided in response to that request.
Water Utilities Director Allison Strube expressed concern about sizeable fines. Louder said those do not come into play if the city complies with the recommendations within TCEQ's time frame. Three of the cited failures have an August correction data, while one must be completed by October 2021. Being five years late in complying with regulatory standards for a public water utility is far less than excellence.
TCEQ Searchable Investigation Report 1705422 by alan_prest on Scribd
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