Document 5y9oxOkMdEqoLO7dybRgBqBV

United States Environmental Protection Agency / Region 4 Risk Management Program Inspection Report Town Branch WWTP Lexington, Kentucky May 12, 2021 1.0 Introduction The U.S. Environmental Protection Agency's efforts to reduce the likelihood and severity of chemical accidents includes planning and legislative initiatives such as the National Contingency Plan, the Emergency Planning and Community Right-to-Know Act (EPCRA), and the Accidental Release Prevention requirements under Section 112(r) of the Clean Air Act (CAA), as amended in 1990. This report outlines an inspection of the Risk Management Program (RMP) as mandated by Section 112(r)(7) of the CAA. The focus of this inspection was to assess the RMP for the wastewater treatment process at the Town Branch Wastewater Treatment Plant (Town Branch) facility located in Lexington, Fayette County, Kentucky. This facility was selected for inspection because it hasn't been inspected within the last five years under the RMP. The inspection, which was conducted on May 12, 2021, consisted of an examination of program documentation as well as site reviews of various aspects of facility operations. Personnel from the facility participated throughout the inspection. Numerous documents were provided for review off-site. This report will provide a background of the facility and a listing of observations. 2.0 Background The Town Branch facility is located in Lexington, Kentucky. The facility uses chlorine and sulfur dioxide for wastewater treatment purposes. The process is regulated as program level 3. According to facility records, the facility has a maximum of 40,000 pounds of chlorine and 16,000 pounds of sulfur dioxide on site. The sewage treatment processes at the facility are subject to the RMP requirements of 40 C.F.R. Part 68 and EPCRA Section 302. The background specifics are summarized as follows in Table 1. TABLE 1: Inspection Information Summary Inspection Team Lead Inspector: Jordan Noles, EPA Inspector: Om Devkota, EPA Date of Facility Visit: May 12, 2021 Facility Identification Name: Town Branch WWTP Street Address: 301 Jimmy Campbell Drive City: Lexington County: Fayette EPA Facility ID No: 1000 0010 0623 State: Kentucky Zip: 40504 Dun & Bradstreet (D&B) No: 618239958 Latitude: 38.063796 Longitude: -084.533402 Name, address, and phone of corporate parent company: Owner/Operator: Lexington-Fayette Urban County Government Mailing Address: 301 Jimmy Campbell Drive City: Lexington State: Kentucky Zip: 40504 Phone: (859) 425-2413 Name, title, and email of person responsible for 40 C.F.R. Part 68 implementation: Name: Danny Hyatt Title: Plant Operations Supervisor Phone: (859) 425-2413 Email: dhyatt@lexingtonky.gov Name and title of emergency contact: Name: Danny Hyatt Title: Plant Operations Supervisor Day phone: (859) 425-2413 24-hour Phone: (859) 621-2722 Email: dhyatt@lexingtonky.gov Name and titles of stationary source personnel involved in site inspection (accompanied site tours, provided documents and explanations): Name: Robin Wright Title: Program Coordinator Phone: (859) 425-2419 Email: rwright@lexingtonky.gov Name: Danny Hyatt Title: Plant Operations Supervisor Phone: (859) 425-2413 Email: dhyatt@lexingtonky.gov Note: This is not a union facility. Date and Program Levels of Submitted Risk Management Plan Date of initial submission: November 20, 2006 Date of most recent submissions: December 30, 2016 Process: Chlorine Storage Process ID: 1000077018 Process: Sulfur Dioxide Storage Process ID: 1000095666 2 Program Level as reported in RMP: 3 NAICS code: 22132 (Sewage Treatment Facilities) 3.0 Observations The inspection of the Town Branch facility evaluated various sections of the RMP regulations (40 C.F.R. Part 68, Program Level 3) and the inspection checklist included in "Guidance for Conducting Risk Management Programs Inspections under Clean Air Act Section 112(r)." The inspection included discussions with the facility representatives regarding a myriad of issues related to the operation of its chemical process, the facility's RMP, a review of paperwork associated with the facility's most recent Risk Management Plan, and a tour of the facility. An inspection in-brief and out-brief were conducted. There were no findings of note as a result of the inspection. Inspection Report, Prepared by: ____________________________ Jordan Noles, Inspector North Air Enforcement Section Air Enforcement Branch U.S. EPA Region 4 _July 08, 2021_______ Date Approved by: JASON Digitally signed by JASON DRESSLER Date: 2021.07.08 08:26:56 _D__R_E__S_S_L__E_R_______-_04_'0_0_' ______ Jason Dressler, Chief North Air Enforcement Section Air Enforcement Branch U.S. EPA Region 4 _July 08, 2021_______ Date 3