City Submits Response to TCEQ Investigative Report

The City of San Angelo completed their initial followup report to the Texas Commission for Environmental Quality addressing three of the four deficiencies that caused toxic chemicals to enter the public water system in February.  

At the current time and until the Water Utilities department is able to become properly staffed, the value of these CSIs will be balanced with the currently identified facilities.

The 199 page response was remarkably light on planned customer service inspector staffing.  Two plumbing inspectors are CSI qualified, while a new full time CSI is in the Water Department.  That comprises the three CSIs City Council directed staff to propose for the coming budget year.  

A fourth person, the Assistant Water Utilities Director, is now CSI qualified but their time is dedicated to other duties. An excerpt from their 6-17-21 e-mail to TCEQ stated:

We are still trying to complete final CSIs for the customers in the PaulAnn/North Bell area identified in the February/March time period. We have also spent numerous hours in both formal training and department research for our cross‐connection control program. Although we currently have two TCEQ‐licensed CSI inspectors, I am one of them and only a small portion of my time can be dedicated in the field to customer service inspections due to my other responsibilities as Assistant Director. We are prioritizing the customers in the PaulAnn/North Bell area identified in February/March to conclude these concerns. We will be engaging City Council for additional CSI staff in the budgeting process for the next fiscal year. In addition, we have spent significant time researching and developing a customer service agreement (approved by Council this past Tuesday), a draft ordinance, and working with City staff in other departments and the development community to develop protocols for backflow prevention in the development services process. At this time, we feel that completing CSIs at the above listed facilities/locations is a lower priority than other cross‐connection control program needs based upon our understanding of your concerns.

Please also note that we understand that a CSI inspection at these facilities/location in the future is beneficial and will be completed as other prioritized tasks are completed and as we build our staff.

TCEQ remains clear that the city must do more than rely on third party vendor VEPO, as it has done for at least five years.  TCEQ's investigator wrote:

The VEPO information for backflow devices can be submitted electronically. However, be aware that additional documentation/information may be requested should the electronic VEPO information not show everything needed to determine compliance. This will be evaluated once information is submitted as until then I am unable to determine if it will be sufficient.

If a facility has backflow and that information is not in VEPO, then the backflow form will be required to be submitted that the City is maintaining. The form is required to be TCEQ -20700 or another form that has been approved by the TCEQ.

The City's response did not reveal staffing constraints imposed by City Council and the impact that may have on compliance with TCEQ's longstanding cross connection control program requirements.  

Former Executive Director of Public Works Ricky Dickson oversaw the city's lax cross connection control program.  City ordinances charged Dickson with identifying businesses that needed to have backflow preventers for health concerns.  A public information request failed to produce the names of any businesses Dickson required to have backflow preventers due to health hazards.

TCEQ's investigative report indicated nearly 1.4 million gallons of water flowed out of Lone Staff Beef into the public water supply from December 2020 to February 2021.  The public water system was connected to a well onsite at the meat processing plant.  That connection has been removed and the two systems separated.

The city's response also stated:

Although the City has not adopted a fully comprehensive plumbing ordinance, the 2015 International Plumbing Code (2015 IPC) has been adopted by resolution, as shown in Appendix H. This code does provide guidance on proper backflow prevention

The above plumbing code was adopted by City Council in October 2018.  That adoption did not prevent toxic chemicals from entering the water supply in February 2021.  

It's been nearly six months since the City allowed toxic chemical intrusion into the public water supply.  It needs to resolve all four deficiencies by early fall.  It's not clear that will happen.