Document K3z45k6eKVp0OJ8JEXOm9V0r

United States Environmental Protection Agency / Region 4 Risk Management Program Inspection Report Athens Water Treatment Plant Elkmont, Alabama August 22nd, 2024 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 ammonia refrigeration process at the Athens Water Treatment Plant facility located in Elkmont, Limestone County, Alabama. This facility was selected because it had never been inspected under the RMP. The inspection, which was conducted on August 22, 2024, 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. Requested program documents were provided for further review off-site. This report will provide a background of the facility and a listing of observations. 2.0 Background Athens Water Treatment Plant facility located in Elkmont, Limestone County, Alabama. The facility uses chlorine (gas liquified by pressure) for treatment of the municipal water supply and irrigation systems on site. The process is regulated as program level 2. According to facility records, the facility has a maximum of 20,000 pounds of chlorine on site. The water treatment process at the facility is 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-In-Training: Callie Sotolongo, EPA Inspector: Jordan Noles, EPA Date of Facility Visit: August 22, 2024 Facility Identification Name: Athens Water Treatment Plant Street Address: 15575 Section Line Road City: Elkmont County: Limestone EPA Facility ID No: 1000 0023 7996 Dun & Bradstreet (D&B) No: 26600134 Latitude: 34.880465 Longitude: -87.043093 State: Alabama Zip: 35620 Name, address and phone of corporate parent company: Owner/Operator: City of Athens Utilities Mailing Address: PO Box 1089 City: Athens State: Alabama Zip: 35612 Phone: (256) 232-1440 Name, title, and email of person responsible for 40 C.F.R. Part 68 implementation: Name: Brian Daniels Title: Superintendent Phone: (256)- 233-8773 Email: bdaniel@athens-utilities.com Name and title of emergency contact: Name: Brian Daniels Title: Superintendent Day phone: (256) 233-8773 24-hour Phone: (256) 497-7856 Email: bdaniel@athens-utilities.com Name and titles of stationary source personnel involved in site inspection (accompanied site tours, provided documents and explanations): Name: Brian Daniels Title: Superintendent Phone: (256) 233- 8773 Email: bdaniel@athens-utilities.com Name: Tim Norman Title: Facility Employee Phone: (256) 233- 8773 Email: tnorman@athens-utilities.com Note: This is not a union facility. Date and Program Levels of Submitted Risk Management Plan Date of initial submission: August 19, 2019 Date of most recent submissions: June 13th, 2024 Process: Water Treatment Plant Process ID: 1000143661 Page 2 of 4 Athens Water Treatment Plant, Elkmont, AL CAA 112 (r), Risk Management Program, Inspection Report Program Level as reported in RMP: 2 NAICS code: 22131 (Water Supply and Irrigation Systems) 3.0 Observations The inspection of the Athens Water Treatment Plant evaluated various sections of the RMP regulations (40 C.F.R. Part 68, Program Level 2) and the inspection checklist included in "Guidance for Conducting Risk Management Programs Inspections under Clean Air Act Section 112(r)." The inspection included an opening conference where EPA inspectors reviewed documents associated with the facility's Risk Management Plan. The discussion was followed by a tour of the facility's water treatment area. An inspection out-brief was conducted where EPA inspectors requested additional documents for review off-site and described their observations. Observations from the RMP inspection at the Athens Water Treatment Plant are discussed below: 1. 40 C.F.R. 68.58(a) requires the owner or operator to certify that they have evaluated compliance with the provisions of this subpart, at least every three years to verify that the procedures and practices developed under this subpart are adequate and are being followed. At the time of the inspection, the 2019 and 2022 compliance audits were identical, with no edits having been done between the two. This includes recommendations and actions to be taken based on the compliance audit findings. The 2022 compliance audit was not evaluated with the provisions of Subpart C and was not updated. 2. 40 C.F.R. 68.93(a) requires the owner or operator to coordinate annually with local emergency planning and response organizations to address changes: At the stationary source; in the stationary source's emergency response and/or emergency action plan; and/or in the community emergency response plan. At the time of the inspection, the facility did not coordinate annually with local emergency planning and response organizations for the previous five years. There were no records available at the time of the inspection to suggest otherwise. There were no records received after the inspection to show coordination with local emergency planning organizations. 3. 40 C.F.R. 68.71(c) requires the owner or operator to ascertain that each employee involved in operating a process has received and understood the training required by this paragraph. The owner or operator shall prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training. At the time of the inspection, the facility did not have adequate documentation of employee training to include annual and refresher courses for all personnel. There was no documentation to show annual refresher courses after the inspection was conducted and documents were reviewed. Page 3 of 4 Athens Water Treatment Plant, Elkmont, AL CAA 112 (r), Risk Management Program, Inspection Report Inspection Report, Prepared by: CALLIE Digitally signed by CALLIE SOTOLONGO SOTOLONGO Date: 2024.10.18 10:47:23 -04'00' ____________________________ Callie Sotolongo, Inspector-In-Training South Air Enforcement Section U.S. EPA Region 4 10/18/2024 Date Digitally signed by JORDAN JORDAN NOLES Date: 2024.10.18 12:51:10 NOLES _________________________-_0_4_'00' ______________ Jordan Noles, Inspector Date North Air Enforcement Section U.S. EPA Region 4 Approved by: Digitally signed by TODD TODD GROENDYKE GROENDYKE __________________________D__ate: 2024.10_.1_8_1_2_:2_6_:_58__-0_4_'0_0_' Todd Groendyke, Section Chief Date South Air Enforcement Section U.S. EPA Region 4 Page 4 of 4 Athens Water Treatment Plant, Elkmont, AL CAA 112 (r), Risk Management Program, Inspection Report