Document gDDxao2ogjbOaQvbr3yXkx9eG

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Indiana American Water, Northwest, Ogden Dunes Vicky Mei, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Supervisor AECAB (IL/IN) File BASIC INFORMATION Facility Name: Indiana American Water, Northwest, Ogden Dunes Facility Location: 84 Diana Road, Portage, Indiana 46368 Date of Inspection: December 6-7, 2021 EPA Inspector(s): 1. Jason Schenandoah, Environmental Engineer 2. Vicky Mei, Environmental Engineer Other Attendees: 1. Holly True, Senior Operations Manager 2. Ryan Love, Production Supervisor 3. Kimberly Stesanich, Planning Engineer 4. Justin Rich, EHS Manager 5. Shawn Johnson, Plant Mechanic 6. Greg Boxwell, Plant Mechanic 7. Pete Harretos, Senior Support Operations Contact Email Address: Holly.True@amwater.com Purpose of Inspection: Compliance inspection for the Chemical Accident Prevention Provisions (CAPP) Facility Type: Drinking water treatment plant Regulations Central to Inspection: 40 C.F.R. Part 68 December 6, 2021: Arrival Time: 9:15 AM Departure Time: 5:00 PM December 7, 2021: Arrival Time: 9:15 AM Departure Time: 2:00 PM December 6, 2021 was a focused document review of the Gary, Indiana facility. The morning of December 7, 2021 was spent touring the Portage, Indiana facility followed by the Gary, Indiana facility tour. After the tours, document review for the Portage, Indiana facility was conducted. Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Not a small business Provided CBI warning to facility The following information was obtained verbally from Indiana American Water (IN-AWC) personnel unless otherwise noted. Process Description: IN-AWC in Portage, Indiana treats and chlorinates water and distributes treated potable water to nearby communities. The Facility has a capacity to store 36,000 pounds of chlorine. The Facility has 3 chlorine tanks in service and 3 chlorine tanks on standby. There are 4 chlorine sensors in chlorine room and the monitors for the sensors are in the observation room. Staff Interview: IN-AWC developed a single Program 3 Prevent Program to cover both the Portage, Indiana and Gary, Indiana facilities. The same employees work at both facilities. The facility has not had an incident in the past 5 years. If there is a leak, the sensor alarms will sound at 3 parts per million (ppm). If the leak exceeds 5 ppm, then the Facility calls 911. Page 2 of 7 TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: Some chlorine pipes in the process are not labeled to indicate the direction of flow and that they contain chlorine. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW The following is a list of documents that were provided by IN-AWC prior to the inspection and uploaded to Region 5's OneDrive storage. 1. "Process Safety Management / Risk Management Program" a. "Section 1: Management System" b. "Section 2: Employee Participation Plan" c. "Section 3: Process Safety Information" d. "Section 4: Process Hazard Analysis (PHA)" e. "Section 5: Operating Procedure" f. "Section 6: Training" g. "Section 7: Contractor Safety" h. "Section 8: Pre-startup Safety Review (PSSR)" i. "Section 9: Mechanical Integrity" j. "Section 10: Hot Work Permit" k. "Section 11: Management of Change (MOC)" l. "Section 12: Incident Investigation" m. "Section 13: Emergency Planning and Response" n. "Section 14: Compliance Audits" 2. "Northwest Operations: Chlorine Process Application" flow chart 3. "Borman Park Pumping Station: Chlorine Feed System Components" operating limits table 4. "Chlorination Schematic" 5. SDS for Chlorine - liquified gas under pressure 6. Borman Park and Ogden Dunes WTP Process Hazard Analysis", September 3, 2020 7. American Water "Welding" procedure, adopted August 2012 8. "Lock Out Tag Out Form" 9. "Service Report-2021", August 18 & 19, 2021 annual service order 10. "Chemical Inventory and Storage Locations" at Borman Park and Ogden Dunes 11. "Class I Chlorine Release Checklist" for minor releases 12. "Class II Chlorine Release Checklist" for minor releases 13. "Class II Chlorine Release Checklist" for outside releases 14. Indiana American Water "Consequences of Deviations" Page 3 of 7 15. "RMP Audit Action Plan" spreadsheet, July 12, 2017 16. "Siemens Water Technology Certification of Completion" 17. Indiana American Water entry form and safety review for Borman Park and Ogden Dunes 18. "INAW-PSM/RMP Audit Form-Corrective Action Plan" for Ogden Dunes, September 3, 2020 19. Draft Exercise Plan "Lake County LEPC-Indiana American Water: Full Scale Exercise", September 14, 2017 20. Overview of lock out, tag out work order and forms 21. "Lockout/Tagout Hazardous Energy Control Program" 22. "Program Level 3: Compliance Audit Checklist", July 7, 2017 23. "Borman Park and Ogden Dunes WTP Process Hazard Analysis", July 2, 2013 24. "Borman Park and Ogden Dunes WTP Process Hazard Analysis", September 4, 2013 25. "Ogden Dunes Shut Down Procedure" 26. Indiana American Water "Operating Procedures for Chlorine Process" 27. American Water "Practice Document" for PHA 28. Training records, 2018-2021 29. "Risk Management Plan Roster of Employee Participation" 30. "Program Management" Gary audit, September 3, 2020 31. "Location visitor Report BP and OD 32. Hard copy of training review and certification, June 29, 2018 33. Hard copy of service reports made 34. Hard copy of training certification through observation of work performance on chlorine process work safety for 7 employees 35. Hard copy of "PSM-RMP 2020 PPT" 36. Training Documentation 37. "2015_Chlorine Operating Procedures Review" 38. "2016 Chlorine safety" 39. "2016 CL2 Operating Review and Certification" 40. "2017 Operating Procedures Review" 41. "2018 CL2 Operating Procedures Review and certification" 42. "2018 RMP CL2 Operating Procedures Checkpoint" 43. "2021_1 Operating Procedures Review and Certification" 44. "2021_12 Chlorine Operations Review and RMP review" email of operating procedures to employees 45. "On the Job_Proficiency Training General Chemical_Safety&Process Knowledge" for an employee, September 21, 1993 46. "PSM/RMP Chlorination SOP-Skill/Knowledge Check" 47. RMP Review PPT pre and post tests 48. Equipment manuals 49. Borman Park and Ogden Dunes Hazard Assessment 2021 Page 4 of 7 The following observations were made during the records review process: Process Safety Information (PSI) Process Chemistry was not included as part of the PSI. The consequences of deviation did not consider any deviations of the safe upper and lower limits of the PSI. An overall PSI document was created that lists the requirements of the PSI and where each document is located to satisfy those requirements. The Electrical Classification, Relief system design and design basis, ventilation system design, design codes and standards employed, and safety systems could not be found or was not in the place where the overall summary document listed it. IN-AWC has not documented that the equipment complies with recognized and generally accepted good engineering practices. IN-AWC has not determined and documented that existing equipment, designed and constructed in accordance with codes, standards, or practices that are no longer in general use, is designed, maintained, inspected, tested, and operating in a safe manner. Process Hazard Analysis (PHA) Stationary source siting, human factors, and a qualitative evaluation of a range of the possible safety and health effects of failure of controls were not addressed in the PHA. IN-AWC did not document which employees on the PHA team had expertise and knowledge of the process being evaluated and which employee on the PHA team was knowledgeable in the specific process hazard analysis methodology. IN-AWC did not assure that the recommendations of the PHA were resolved in a timely manner and documented. IN-AWC did not complete the PHA actions as soon as possible. IN-AWC did not develop a written schedule of when the PHA actions were to be completed. IN-AWC did not communicate the actions to operating, maintenance, and other employees whose work assignments are in the process and who may be affected by the recommendations. The last two PHAs were conducted in September 2013 and September 2020. Therefore, the PHA was not updated and revalidated by a team within 5 years. Operating Procedures The "Chlorine Tank Change" operating procedures and SDS for chlorine are posted on the wall of the Chlorine Room. The operating procedures are contained in a binder at the IN-AWC, Northwest, Borman Park facility in Gary, Indiana. The operating procedures do not include control measures to be taken if physical contact or airborne exposure occurs, any special or unique hazards, or safety systems and their functions. Operating procedures need to provide the types of personal protective equipment specific to each operating procedure. Page 5 of 7 Training The Facility relayed to EPA that each employee involved in operating a process and before being involved in operating a newly assigned process has been initially trained. The Facility did not have documentation of the initial training, other than for one employee. The Facility relayed to EPA that refresher training has been provided annually. These documents are available for only one employee: record that the employee involved in operating a process has received and understood the training required; and record of the means used to verify that the employee understood the training. Mechanical Integrity The facility only provided work orders as part of the mechanical integrity program. One company employee conducts maintenance of all the Indiana AWC facilities and trains two Ogden Dunes plant mechanics to rebuild regulators. EPA requested follow up documentation, if available: the written procedures to maintain the on-going integrity of the process equipment and records of maintenance training. Compliance Audits The last two compliance audits were completed in July 2017 and September 2020. Therefore, IN-AWC did not evaluate compliance with the provisions of the prevention program at least every three years. No person knowledgeable in the process was in included in the compliance audit team. The 2017 audit documents corrective actions and timely implementation of those actions, the 2020 audit does not include corrective actions nor dates to complete those actions. Employee Participation The facility created a PowerPoint presentation for its employees on the CAPP program. The information has not been presented to the employees yet. The Facility relayed to EPA that the employees received an email on December 2, 2021, requesting that they confirm that they received the process safety management information and operating procedures. The PHA that was due in 2020 was not fully completed. Emergency Response IN-AWC was not aware if the facility is included in the community emergency response plan developed under 42 U.S.C. 11003. Therefore, IN-AWC has not coordinated response needs with local emergency planning and response organizations to determine how the facility is addressed in the community emergency response plan. The Facility has never performed an annual emergency response coordination activity under 40 C.F.R. 68.93. Page 6 of 7  IN-AWC has not coordinated with local emergency response officials to establish an appropriate frequency for field exercises. Risk Management Plan RMP IN-AWC did not include whether the Facility is included in the community emergency response plan into the RMP. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Operating procedures for steps required to correct or avoid deviation. Annual certification of the operating procedures. Initial PHA Maintenance procedures Spare parts inventory Concerns: Not all chlorine lines were labeled. The records review and the attached checklist outline additional concerns identified by EPA inspectors. DIGITAL SIGNATURES Digitally signed by VICKY VICKY MEI Date: 2022.02.23 MEI Report Author: _____________2_0:_26_:3_9 _-0_6'0_0'_____________ Section Supervisor: Frank, Digitally signed by Frank, Nathan Date: 2022.02.24 _N_a_t_h_a_n_______1_1:_49_:3_9 _-06_'0_0'______________ Page 7 of 7 APPENDICES AND ATTACHMENTS 1. Appendix A; Digital Image Log Facility Name: IN-AWC, Northwest, Ogden Dunes Facility Location: 84 Diana Road, Portage, Indiana 46368 Date of Inspection: December 6-7, 2021 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Jason Schenandoah 2. Archival Record Location: Region 5 Electronic Record Center File Name: Enf_IndianaAmericanWaterOgdenDunes_IL_21_Inspection Image Number 1 2 3 4 5 6 7 8 9 10 11 12 13 Description of Image Signage outside chlorine room Empty canisters with tag Full canisters with tag In service canisters with tag Halogen and scale readout Alarm sensor readouts and emergency shutdown in observation room Emergency kit Chlorinators Chlorinators Post chlorinator chlorine signs Post chlorinator chlorine signs Post chlorinator chlorine signs Post chlorinator chlorine signs Appendices Page 1 of 1 General: General: General: - - : : : . : . : : : : : : 55. 56 57 : 58 59 60 61 ] : 62 63 64 65 66