Document 8RLb0XRKBpezem1mGLyd7M1Yd

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): __ ,_ 03/20/2018-03/21/2018 Media: Air - Regulatory Progr~m(s) RMP Company Name: ------ North Texas Municipal Water District -- Facility Name: North Texas Municipal Water District Wylie Water Treatment Plant --- Facility Physical Location: 810 N. Highway 78 (city, state, zip code) Wylie, TX 75098 Mailing address: P.O. Box 2408 (city, state, zip code) County/Parish: Wylie, TX Collin County -~ Facility Contact: Joshua Hathaway jhathaway@ntmwd.com Environmental Compliance Manager - --- FRS Number: 110064214584 Identification/Permit Number: N/A Media Number: RMP 11100000154584 NAICS: 22132 SIC: .... - Personnel participating in inspection: Buford Green Wylie Water Treatment Plant Assistant Water Systems -972-442-5405 Patrick Chadwick Wylie Water Treatment Plant Manager Water Treatment --- 469-626-4406 Manager Jim Shirley Wylie Water Treatment Plant Chief Information Officer 469-626-4326 Cody Graham Billy George Joshua Hathaway Wylie Water Treatment Plant Wylie Water Treatment Plant Wylie Water Treatment Plant Michael Walker Wylie Water Treatment Plant r---- Samuel Tates Kayla Buchanan Environmental Protection Agency Environmental Protection Agency EPA Lead Inspector Signature/Date EPA Lead Inspector Signature/Date Cbj. ;:'~,J,S~~an(\d, 1jftA.p. J_ / Supervisor Signature/Date Supervisor Signature/Date Samuel Tates ,, /~lru-,-l 1_7t;<'*'':S Professional Engineer Assistant Deputy Director -Water System Environmental __Compliance Manager Senior Environmental Health & Safety Specialist Section Chief Inspector 469-626-440_'1___ 972-442-5405 214-223-6481--~ - 469-626-4645 214-665-2243 214-665-6480 Date sj!S /!J -- Date Y/II/ 2di8 6ENFORM-019-R7 (2/15/2017) 1 Section I - INTRODUCTION PURPOSE OF THE INSPECTION Samuel Tates, Chemical Accident Section Chief, and I, Environmental Protection Agency (EPA) Region 6 inspector Kayla Buchanan, arrived at the North Texas Municipal Water District's Wylie Water Treatment Plant (North Texas Wylie) at 9:30 AM on March 20, 2018, for an announced inspection. We met with several representatives of the North Texas Municipal Water District at the Opening Conference (see Appendix 1). I presented my credentials to all attendees of the opening conference and informed them that this was an EPA inspection to determine North Texas Wylie's compliance with Clean Air Act (CAA) Sections 112(r)(1) and 112(r)(7). The scope of the inspection was a partial compliance evaluation of the facility pursuant to 40 CFR Subpart 68 - Chemical Accident Prevention Provisions. The facility does not have union representation. FACILITY DESCRIPTION North Texas Wylie is an entity that treats raw water to create potable water for the North Texas area. It is located at 810 N. Highway 78, Wylie, TX 75098. The facility is owned and operated by the North Texas Municipal Water District (NTMWD) and employs 198 full time employees. Section II - OBSERVATIONS On Wednesday, March 21, 2018, I conducted a walk-through of the facility and was accompanied by North Texas Wylie representatives to observe the covered processes, equipment, operations, and emergency equipment. 40 C.F.R. Part 68 - CHEMICAL ACCIDENT PREVENTION PROVISIONS Subpart A - General 40 C.F.R. 68.10 Applicability - North Texas Wylie is a non-Title V stationary source that has more than a threshold quantity of chlorine and ammonia, both of which are regulated substances in its process streams; therefore, these regulations are applicable. North Texas Wylie re-submitted a Risk Management Plan (RMP) on March 16, 2016, that described the processes containing regulated chemicals held at more than a threshold quantity. This facility is not subject to the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) Standard (29 CFR 1910.119), categorizing them as a Program 2 facility. 40 C.F.R. 68.12 General requirements - I reviewed the March 16, 2016, re-submission of North Texas Wylie's RMP and it listed the toxic chemicals for its Program 2 process. 40 C.F.R. 68.15 Management - I reviewed North Texas Wylie's management system. The facility assigned a qualified person or position that has the overall responsibility for the development, implementation, and integration of the risk management program elements. 6ENFORM-019-R7 (2/15/2017) 2 {North Texas Municipal Water District} / {Wylie Water Treatment Plant} Inspection Date {3/20/2018-3/21/2018} Subpart B - Hazard Assessment 40 C.F.R. 68.20 Applicability - North Texas Wylie is a Program 2 stationary source subject to this subpart; therefore, it is required to prepare a worst-case release scenario analysis and complete the five-year accident history. 40 C.F.R. 68.22 Offsite Consequence Analysis (OCA) Parameters - North Texas Wylie utilizes EPA RMP*Comp TM software and the RMP Offsite Consequence Analysis Guidance to ensure the OCA parameters are met. I reviewed the facility's OCA documentation to ensure the data was accurate and up to date. 40 C.F.R. 68.25 Worse-case release scenario analysis - North Texas Wylie identified and analyzed at least one worst-case scenario for each regulated toxic substance held in a covered process using the parameters specified in the regulation 40 C.F.R. 68.28 Alternative Release Scenario Analysis - North Texas Wylie identified and analyzed at least one alternative release scenario for each regulated toxic substance held in a covered process using the parameters specified in the regulation. 40 C.F.R. 68.30 Defining offsite impacts- Population - North Texas Wylie estimated the population within a circle with its center at the point of the release and a radius determined by the distance to the endpoint; likewise, they used the most recent Census data to estimate the population potentially affected. 40 C.F.R. 68.33 Defining offsite impacts- Environment - North Texas Wylie listed in its RMP environmental receptors within a circle with its center at the point of the release and a radius determined by the distance to the endpoint as defined in 68.22(a) of this part; likewise, they relied on U.S. Geological Survey (U.S.G.S.) data to identify environmental receptors. 40 C.F.R. 68.36 Review and Update - North Texas Wylie reviews and updates its OCA once every five years. 40 C.F.R. 68.39 Documentation- North Texas Wylie maintains records on the offsite consequence analyses, as required by the rule. 40 C.F.R. 68.42 Five-year accident history- North Texas Wylie is required to include in its five-year accident history all accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. The facility identified and included four (4) incidents that met this qualification in its accident history. Each of the incidents resulted in an injury due to a release of chlorine. I queried the National Response Center (NRC) database to ensure additional releases from the facility that could possibly be included in the facility's five-year accident history were not omitted. The data required by the regulation for each accidental release was documented in a report. 3 {North Texas Municipal Water District} / {Wylie Water Treatment Plant} Inspection Date {3/20/2018-3/21/2018} Subpart C - Program 2 Prevention Program 40 C.F.R. 68.48 Safety Information - I reviewed North Texas Wylie's compiled safety information related to the regulated substances, processes, and equipment including: (1) Material Safety Data Sheets (MSDS); (2) Maximum intended inventory of equipment in which the regulated substances are stored and processed (3) Safe upper and lower temperatures, pressures, flows, and compositions; (4) Equipment specifications; and (5) Codes and standards used to design, build and, operate the process. All of the safety information was up to date and met the requirements of the regulations. North Texas Wylie utilizes the following codes and standards to ensure its process is designed in compliance with recognized and generally accepted good engineering practices: Uniform Fire Code (UFC) National Electrical Code (NEC) Chlorine Institute Standards (CIS) Compressed Gas Association (CGA) Standards American Society for Testing and Materials (ASTM) Standards American National Standards Institute (ANSI) Standards American Society of Mechanical Engineers (ASME) Standards North Texas Wylie's primary source for standards in the use and the handling of chlorine is the Chlorine Institute's publication, Chlorine Basics. 40 C.F.R. 68.5 Hazard Review - I reviewed North Texas Wylie's two most recent hazard reviews, which were conducted on April 28, 2017, and May 2, 2012. The hazard reviews identified the hazards associated with the process and regulated substances, opportunities for equipment malfunctions or human errors that could cause an accidental release, safeguards used/needed to control the hazards or prevent equipment malfunctions, and the steps used to detect/monitor releases. North Texas Wylie utilized the what/if checklist method to conduct its hazard review. The facility determined this method to be appropriate due to the availability of checklists and what/if questions from guidance documents. North Texas Wylie documented the results of the review and ensured that problems identified were resolved in a timely manner. The hazard review is updated at least every five years or whenever a major change occurs. 40 C.F.R. 68.52 Operating Procedures - This regulation requires North Texas Wylie to prepare written operating procedures that provide clear instructions or steps for safely conducting activities associated with each covered process consistent with the safety information for that process. I reviewed North Texas Wylie's operating procedures. The operating procedures addressed each of the following: (1) initial startup; (2) normal operations; (3) temporary operations; (4) emergency shutdown; (5) normal operations; (6) startup following shutdown; and (8) equipment malfunctions; however, the procedures failed to address consequences of deviation and the steps to correct or avoid the deviations (AOC # 1) (see Appendix 2). North Texas Wylie has developed an SOP template and all old written operating procedures will be converted to this format. I recommended that the facility review this template because it also failed to address consequences of deviation (see Appendix 3). 4 {North Texas Municipal Water District} / {Wylie Water Treatment Plant} Inspection Date {3/20/2018-3/21/2018} The regulation also requires North Texas Wylie to develop standard operating procedures for equipment checks. The facility has an equipment checklist for its chlorine and ammonia system inspections (see Appendix 4) however, the facility does not have any written procedures that instruct employees on how to complete these equipment checks. When I asked about this, I was told that a verbal lesson is provided to employees and no written procedures have been developed (AOC # 2). 40 C.F.R. 68.54 Training - This regulation requires refresher training to be provided to employees operating the process at least every three years, and more often if necessary, to ensure that the employee understands and adheres to the current operating procedures of the process. I reviewed training records for North Texas Wylie employees. The records reviewed showed that refresher training was not provided every three years in accordance with the regulation (AOC #3) (Appendix 5) * 40 C.F.R. 68.56 Maintenance - North Texas Wylie uses procedures and instructions provided by covered process equipment vendors and industry codes as the basis for stationary source maintenance procedures. The facility utilizes Maximo software to notify employees when preventative maintenance needs to be performed. The regulation requires North Texas Wylie to train its maintenance workers in the hazards of the process, in how to avoid or correct unsafe conditions, and in the procedures applicable to the employees job tasks. Training conducted under Federal or state regulations, under industry-specific standards or codes, or training conducted by covered process equipment vendors can be used to demonstrate compliance; however, three (3) maintenance workers are on staff at the facility and, only one has a Water Operations License from the Texas Commission on Environmental Quality. The two non-licensed maintenance workers only assist in maintenance activities. North Texas Wylie stated informal training for procedure's applicable to the employee's job tasks is provided to the maintenance staff by the manufacturers of the process equipment; however, the facility was unable to provide official training records (AOC #4). The regulation requires maintenance contractor companies doing work for North Texas Wyle to ensure that their contract maintenance employees are trained to perform the maintenance procedures. I reviewed the contactors' statements of work for the North Texas Wylie facility and each included language ensuring contract maintenance employees are trained. 40 C.F.R. 68.58 Compliance Audit - I reviewed the facility's two most recent compliance audits, which were conducted May 2, 2012, and May 5, 2015. North Texas Wylie uses a contractor, Municipal H2O to conduct its compliance audit. This same contractor is responsible for completing its RMP. The compliance audits evaluated the facility's compliance with the provisions of this subpart to verify that the procedures and practices developed under the rules are adequate and are being followed as required. 40 C.F.R. 68.60 Incident Investigations - The regulation requires facilities to investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release. I reviewed the incident investigation reports for each of the incidents included in the facility's five-year accident history. North Texas Wylie initiated the incident investigation within 48 hours following the incident. The facility prepared a report at the conclusion of the investigation, which included the date of the incident, the date the investigation began, a description of the incident, factors that contributed to the incident, and recommendations resulting from the investigation. North Texas Wylie promptly addressed and resolved the investigation's findings and recommendations and documented the corrective actions. North Texas 5 {North Texas Municipal Water District} / {Wylie Water Treatment Plant} Inspection Date {3/20/2018-3/21/2018} Wylie has developed a standard incident investigation report template to ensure the requirements of the regulation are being met. In addition to the incidents included in the facility's five-year accident history, I reviewed a July 2017 incident that involved an ongoing release of 16,472 pounds of ammonia to the atmosphere from a tank in Plant III (AOC #5). As a result, North Texas Wylie staff evacuated the immediate area of the ammonia tank, the Wylie Fire Department evacuated Plant III and temporarily closed Skyline Road, and the EPA deployed On-Scene Coordinators (OSCs) to conduct air monitoring. A gasket failure caused the release, and the lack of a drainage valve on the bottom of the tank prolonged mitigation. Gaskets on the remaining ammonia tanks at the plant have been visually inspected, but not replaced. Because of this incident, North Texas Wylie has hired an industry expert to complete a review of its ammonia storage and feed system. The industry expert had several findings stemming from its analysis, including both code and safety issues, as well as non-standard/operational issues (where the operability and maintainability could be improved by using industry standard designs and equipment). Recommendations from this review included several improvements to the ammonia system, including gasket replacement, instrument modification and replacement, piping modifications, and other miscellaneous improvements. North Texas Wylie has developed a scope of work to undertake these improvements and is waiting for approval from the North Texas Municipal Water District Board of directors to proceed. Subpart E- Emergency Response 40 C.F.R. 68.90 Applicability- North Texas Wylie employees do not serve as first responders to accidental releases of regulated substances when they occur. 40 C.F.R. 68.95 Emergency response program- As a non-responding entity, North Texas Wylie is not required to have an emergency response program; however, the facility is required to ensure it is included in its community emergency response plan developed under 42 U.S.C. 11003, coordinates response actions with the local fire department, and have appropriate mechanisms in place to notify emergency responders when there is a need for a response. North Texas Wylie maintains an emergency response plan that includes all of the aforementioned information, which meet the requirements of the regulation. Subpart G- Risk Management Plan 40 C.F.R. 68.190 Updates- The RMP for this facility was re-submitted on March 16, 2016. The next RMP submission is due by March 16, 2021. 40 C.F.R. 68.195 Required corrections- An update is required and subsequent updates are required every five years, if the facility has new accident history information, or has a change in emergency contact information. Per this requirement, North Texas Wylie has submitted several corrections to update both its emergency contact information and accident history. The most recent update was June 5, 2017. 6 Section III - AREAS OF CONCERN {North Texas Municipal Water District} / {Wylie Water Treatment Plant} Inspection Date {3/20/2018-3/21/2018} 1. 40 C.F.R. 68.52(a) requires the owner or operator shall prepare written operating procedures that provide clear instructions or steps for safely conducting activities associated with each covered process consistent with the safety information for that process. Operating procedures or instructions provided by equipment manufacturers or developed by persons or organizations knowledgeable about the process and equipment may be used as a basis for a stationary source's operating procedures. (b) The procedures shall address the following: (1) Initial startup; (2) Normal operations; (3) Temporary operations; (4) Emergency shutdown and operations; (5) Normal shutdown; (6) Startup following a normal or emergency shutdown or a major change that requires a hazard review; (7) Consequences of deviations and steps required to correct or avoid deviations; and (8) Equipment inspections. North Texas Wylie failed to address consequences of deviations and steps required to correct or avoid deviations in its standard operating procedures. 2. 40 C.F.R. 68.52(a) requires the owner or operator shall prepare written operating procedures that provide clear instructions or steps for safely conducting activities associated with each covered process consistent with the safety information for that process. Operating procedures or instructions provided by equipment manufacturers or developed by persons or organizations knowledgeable about the process and equipment may be used as a basis for a stationary source's operating procedures. (b) The procedures shall address the following: (1) Initial startup; (2) Normal operations; (3) Temporary operations; (4) Emergency shutdown and operations; (5) Normal shutdown; (6) Startup following a normal or emergency shutdown or a major change that requires a hazard review; (7) Consequences of deviations and steps required to correct or avoid deviations; and (8) Equipment inspections. North Texas Wylie failed to prepare written procedures for its equipment checks. 3. 40 C.F.R. 68.54(d) Refresher training shall be provided at least every three years, and more often if necessary, to each employee operating a process to ensure that the employee understands and adheres to the current operating procedures of the process. North Texas Wylie failed to provide refresher training at least every three years. 4. 40 C.F.R. 68.56(b) requires the owner or operator to train or cause to be trained each employee involved in maintaining the on-going mechanical integrity of the process. To ensure that the employee can perform the job tasks in a safe manner, each such employee shall be trained in the hazards of the process, in how to avoid or correct unsafe conditions, and in the procedures applicable to the employee's job tasks. North Texas Wylie failed to train its maintenance staff in the procedures applicable to the employee's job tasks. 5. 112(r)(7) (General Duty Clause) requires the owner or operator to identify hazards facility may present from accidental releases of hazardous substances, design and maintain a safe facility, and minimize the consequences of accidental releases which do occur. North Texas failed to minimize the consequences of the accidental release that occurred in July 2017. Section IV - FOLLOW UP North Texas Wylie provided an initial response to the areas of concerns to EPA on May 14, 2018. 7 {North Texas Municipal Water District} / {Wylie Water Treatment Plant} Inspection Date {3/20/2018-3/21/2018} Section V - LIST OF APPENDICES Appendix 1 - Opening conference sign-in sheet Appendix 2 - North Texas Wylie Standard Operating Procedure Examples Appendix 3 - North Texas Wylie Standard Operating Procedure Template Appendix 4 - North Texas Wylie Maintenance Checklist Appendix 5 - Training Records* *Due to the volume of records, and to preserve employee indemnity, this appendix will not be included in the online version of this report. 8 {North Texas Municipal Water District} / {Wylie Water Treatment Plant} Inspection Date {3/20/2018-3/21/2018} Appendix 1: Opening Conference Sign-In Sheet 9 {North Texas Municipal Water District} / {Wylie Water Treatment Plant} Inspection Date {3/20/2018-3/21/2018} Appendix 2: North Texas Wylie Standard Operating Procedure Examples 10 {North Texas Municipal Water District} / {Wylie Water Treatment Plant} Inspection Date {3/20/2018-3/21/2018} 11 {North Texas Municipal Water District} / {Wylie Water Treatment Plant} Inspection Date {3/20/2018-3/21/2018} 12 {North Texas Municipal Water District} / {Wylie Water Treatment Plant} Inspection Date {3/20/2018-3/21/2018} 13 {North Texas Municipal Water District} / {Wylie Water Treatment Plant} Inspection Date {3/20/2018-3/21/2018} 14 {North Texas Municipal Water District} / {Wylie Water Treatment Plant} Inspection Date {3/20/2018-3/21/2018} Appendix 3: North Texas Wylie Standard Operating Procedure Template 15 {North Texas Municipal Water District} / {Wylie Water Treatment Plant} Inspection Date {3/20/2018-3/21/2018} 16 {North Texas Municipal Water District} / {Wylie Water Treatment Plant} Inspection Date {3/20/2018-3/21/2018} 17 {North Texas Municipal Water District} / {Wylie Water Treatment Plant} Inspection Date {3/20/2018-3/21/2018} 18 {North Texas Municipal Water District} / {Wylie Water Treatment Plant} Inspection Date {3/20/2018-3/21/2018} Appendix 4 - North Texas Wylie Maintenance Checklist 19