EPA inspected IN-AWC?s Ogden Dunes Water Treatment Plant at 84 Diana Road, Portage, Indiana (the Facility) on December 6 and 7, 2021 (the Inspection). During the Inspection, EPA reviewed several documents associated with the Risk Management Plan (RMP) developed by IN-AWC pursuant to the CAPP. EPA noted deficiencies in IN-AWC?s RMP in the following categories: process safety information, process hazard analysis, operating procedures, training, mechanical integrity, compliance audit, employee participation, and emergency response. A Finding of Violation was issued to IN-AWC on March 31, 2022 (March 2022 FOV), regarding the deficiencies noted during the Inspection. A consent agreement and final order is concurrently being issued to resolve the violations alleged in the March 2022 FOV.
The ACO addresses the violations set forth in the March 2022 FOV. In addition to assuring compliance with the CAPP, this ACO requires IN-AWC to convert the disinfection process at the facility from a chlorine gas disinfection process to a hypochlorite disinfection process. Since hypochlorite is not a regulated substance under the CAPP, the Facility will no longer need to comply with the CAPP after it eliminates chlorine at the Facility.