City of Austin Wastewater Treatment Facility - Executive Summary

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EXECUTIVE SUMMARY 
 
The City of Austin Wastewater Treatment Facility (WWTF) has developed its Risk Management Program with the intention of preventing the releases of substances that can cause serious harm to the public and the environment from short-term exposures and to mitigate the severity of any releases that do occur.  As a responsible member of the local community, it is the City of Austin's desire to minimize the risks posed by the WWTF.  To this end, the City of Austin submits it's Risk Management Plan to communicate with the public and responders and to assist in the preservation of public safety and environmental protection. 
 
 
The Accidental Release Prevention and Emergency Response Policies at Our Facility: 
 
It is the policy of City of Austin WWTF to provide employees with a work place free of recognized health and safety hazards in an effort to conserve our human, physical and financial resources.  The health and well-being of all personnel is important.  It is our policy t 
hat everything within reason shall be done to maintain a safe and healthy workplace for all employees.   
 
Each employee has a place in our accident prevention program and is expected to cooperate fully in all measures taken in loss prevention.  The ultimate goal of the health and safety program is to prevent and reduce employee injuries and illnesses through the administration of an effective health and safety program.  Elements of this program are: 
 
    Maintenance of safe and healthful working conditions. 
    Ensuring employee adherence to proper operating practices and procedures designed to prevent injuries and illness. 
    Observing and applying Federal, State, and Local safety regulations. 
    Each employee is properly trained and instructed on job procedures prior to job     assignments. 
    Providing safety meetings for all employees as a means of obtaining new and updated information and training. 
    Conducting periodic safety and fire inspections to identify potential hazards in the work  
place. 
    Conducting accident investigations to determine the cause of accidents and the actions necessary to prevent future reoccurrences. 
 
When feasible, we will eliminate or reduce the exposure to hazards by applying engineering controls.  When engineering controls are infeasible or fail to completely control the hazards, administrative controls will be used to minimize employee exposure.  When these types of controls fail, appropriate Personal Protective Equipment will be issued and employees will be trained in its proper use and required to wear it. 
 
Employees are required to read all safety rules and to know and follow them. A copy of the safety rules is given to each employee.  New employees receive a copy upon hire. Employees are asked to sign an acknowledgment card which states that they have read the safety rules and understand them. This card is kept in the employee personnel file. 
 
Upon initial assignment to a job, employees will be trained in the chemical hazards of the wor 
k and appropriate safe work practices and personal protective measures to be employed as per the Minnesota Employee Right-to-Know act.  This initial training will be provided by the Program Coordinator.  The level of training is relevant to the employee's role and responsibilities and is directed at protecting the employee and the environment. 
 
 
Our  Facility and the Regulated Substances Handled: 
 
The City operates two separate treatment plants.  The City was awarded the Environmental Protection Agency's 1998 National Award of Excellence for outstanding operation and maintenance.  Clean water has always been a priority for the City of Austin.   
 
The City's sanitary sewer system dates back to 1904.  The Domestic plant was constructed in 1925 and has been through five upgrades.  The Industrial plant was constructed in 1958 and has been expanded twice.   
 
Two treatment plants serve the residents and businesses of Austin.  Over 100 miles of sanitary sewer lines and 20 lift stations convey  
the wastewater to the Domestic plant.  Beginning with primary treatment in the early 10s this plant has been upgraded five times to keep pace with the ever changing regulatory requirements and the increase growth in the City.  This facility is operating at better than 90% efficiency and is currently operating at 75% of design capacity. 
 
The industrial plant was constructed in 1958 to treat the industrial strength wastewater from the George A. Hormel & Company.  This facility uses a unique treatment process to remove the high amounts of ammonia, organic and solid matter in the wastewater.  This facility is operating a t better than 90% efficiency and is currently operating at 70% of design capacity.   
 
The industrial plant was constructed in 1958 to treat the industrial strength wastewater from the George A . Hormel & Company.  This facility uses a unique treatment process to remove the high amounts of ammonia, organic and soled matter in the wastewater.  This facility is operating at 
better than 90% efficiency and is currently operating at 70% of design capacity. 
 
Industrial Wastewater Treatment Plant 
Wastewater Processes 
 
Preliminary Treatment  
The wastewater form the George A. Hormel & Company goes through pretreatment tanks which are designed to remove fat, oil, grease, and grit.  A lift station pumps an average of 1.8 million gallons per day of wastewater to a flow equalization tank where the wastewater is stored. 
 
Anaerobic Contact Digestion 
 
Two million gallon digesters biologically reduce the organic and solids by means of high rate mixing and recirculating.  This process produces high volumes of methane gas which is used as fuel in the boiler to heat the digesters. 
 
90% of the organic matter and 80% of the solids are reduced in this process.  The treated wastewater flows to an aeration tank which strips the methane gas from the liquid prior to flowing into four solids separators.  The settled solids (sludge) are returned to the digesters for more treatment 

 
Nitrification (R.B.C.'s) 
Sixteen rotating biological contactors (R.B.C.'s) biologically remove ammonia nitrogen.  This process rotates plastic discs in the wastewater.  Ammonia specific bacteria remove the wastewater of ammonia before going to the final clarifiers for suspended solids removal.   
 
DOMESTIC TREATMENT PANT 
Wastewater Process 
 
Preliminary Treatment 
A main pump station pumps an average of 3.5 million gallons per day of wastewater t the aerated grit chamber.  Rags and grit are removed in this process area to improve treatability of the wastewater.  A flow equalization tank is utilized to store and distribute the wastewater evenly to the primary treatment process. 
 
Primary Treatment 
Three primary clarifiers remove over 65% of the suspended solids.  The solids settle and are pumped as "sludge" to the anaerobic digesters.  The sludge is biologically stabilized before being land applied on area farmland. 
 
Secondary Treatment (High Rate Filters) 
Four trickling filters biologic 
ally remove 85% of the organic matter present in wastewater.  The bacteria consume the organic matter in the wastewater as it trickles over 8 feet of rock media.  The treated wastewater flows to intermediate clarifiers for suspended solids removal. 
 
Secondary Treatment (Clarification) 
Two final clarifiers remove the remaining suspended solids.  These solids are recirculated to the primary treatment area.  The final"clarified" water flows to the chlorine contact tanks for disinfection. 
 
Nitrification (Low Rate Filters) 
This biological treatment process removes ammonia nitrogen.  This process consists of 800 nozzles that spray the wastewater on a 10 foot bed of rocks.  The treated wastewater flows to final clarifiers for more suspended solids removal. 
 
Disinfection 
The treated effluent from both plants combine prior to being disinfected.  The wastewater then enters the Chlorine Contact Tank where chlorination begins.  The chlorine utilized in the chlorination process is contained in one- 
ton pressurized cylinders which are stored in the Chlorination Building.  Here the chlorine is mixed as a solution and introduced to the wastewater at the "front-end" of the Chlorine Contact Tank.  The maximum quantity of chlorine on-site at any one time is five cylinders, or 10,000 pounds.   
 
The dechlorination occurs at the "back-end" of the Chlorine Contact Tank prior to the wastewater's discharge to the Cedar River.  The sulfur dioxide used in this process is also contained in one-ton pressurized cylinders which are stored in the Dechlorination Building.  Here the sulfur dioxide is mixed as a solution and then introduced to the Chlorine Contact Tank.  The maximum quantity of sulfur dioxide on-site at any one time is three cylinders, or 6,000 pounds.   
 
The effluent from the two treatment plants contribute to 35% of the flow in the Cedar River. 
 
 
The Worst-case Release Scenarios and the Alternative Release Scenario(s): 
 
Worst-case Release Scenarios 
The City of Austin WWTF utilizes c 
hlorine gas in a process known as chlorination for the purposes of effluent disinfection.  Here, one-ton pressurized cylinders contain the gas which is introduced into wastewater.  The worse-case release accounts for the release of the largest quantity of a regulated substance from a single vessel or process that results in the greatest distance to an endpoint.  In this case, the worse-case release accounts for the ten minute release from one chlorine one-ton cylinder.  Using the guidance of the EPA/CEPP manual entitled "Risk Management Program Guidance for Wastewater Treatment Plants", the worse-case release scenario has been estimated as 1.3 miles to endpoint.  This release would impact approximately 22,000 residents and include the public receptors of schools, hospitals, recreation areas, and major commercial or industrial areas. 
 
The dechlorination process utilizes sulfur dioxide contained in one-ton pressurized cylinders which is mixed into the effluent to effectively dechlorinate 
the waste water.  The worse-case release accounts for the ten minute release of one of these one-ton cylinders.  Using the EPA/CEPP guidance manual "Risk Management Program Guidance for Wastewater Treatment Plants", the worse-case release scenario has been estimated as 1.3 miles to endpoint.  This release would impact approximately 22,000 residents and include public receptors of schools, hospitals, recreation areas, and major commercial or industrial areas. 
 
Alternative Release Scenarios 
The more plausible scenario that would have a greater likelihood of occurrence would be failure, or break away, of the one-inch diameter valve body located near the center of the cylinder head.  This scenario is likely to occur for both for chlorine and sulfur dioxide since their containers and handling procedures are identical.  Since the chlorination and dechlorination (storage and handling) is conducted in two separate buildings, it is reasoned that this accident would most likely occur within the 
se enclosures.  As such, the release-rate-multiplicative factor of 55 percent has been factored in as a passive mitigation.   
 
Using the EPA/CEPP guidance manual "Risk Management Program Guidance for Wastewater Treatment Plants", the distance to endpoint for chlorine has been calculated as 0.6 miles.  This release would impact approximately 18,000 residents and include public receptors of schools, hospitals, recreation areas, and major commercial or industrial areas. 
 
Using the EPA/CEPP guidance manual "Risk Management Program Guidance for Wastewater Treatment Plants", the distance to endpoint for sulfur dioxide has been calculated as 0.5 miles.  This release would impact approximately 17,000 residents and include public receptors of schools, hospitals, recreation areas, and major commercial or industrial areas. 
 
 
The General Accidental Release Prevention Program and Chemical-specific Prevention Steps: 
 
City of Austin, Wastewater Treatment Facility has developed a Process Safety Manage 
ment of Highly Hazardous Chemicals Program with the intention of preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals.   
 
As a responsible member of the local, state, and Federal communities, it is our responsibility to take the steps described in this program.  The goal of this program is to protect the health and safety of our employees, as well as the community.  City of Austin, Wastewater Treatment Facility will comply with 29 CFR 1910.119 "Process Safety Management (PSM) of Highly Hazardous Chemicals". 
 
Application to PSM 
The following City of Austin Wastewater Treatment Facility process meets the 40 CFR 68.3 definition: Chlorination/Dechlorination Process.  This process is identified as the facility's sole process when considering the co-location of separate smaller vessels, as well as the determined potential that the regulated substances could be involved in a single event.  
 
Responsibilities 
The Operations Sup 
ervisor is the member of City of Austin, Wastewater Treatment Facility management directly responsible for safety.  The Operations Supervisor will authorize this program and provide the coordinators of specific programs with the authority to administer the programs.  The Operations Supervisor will ensure that materials required by these programs are available.  He/She will also ensure that disciplinary policies are applied to employees who do not comply with the programs' requirements.  
 
The Operations Supervisor is the program coordinator for City of Austin, Wastewater Treatment Facility's PSM Program.  The Operations Supervisor is responsible for the development and day to day administration of the program throughout the entire company.  The program coordinator carries out the duties and/or coordinates the delegation or contracting of duties outlined in this program. 
 
The Maintenance Foreman and Relief Operators are responsible for the day-to-day administration of this program in the 
areas they supervise.  They will work with the program coordinator to; ensure that employees are made available for training, facilitate work related to this program conducted in their areas, ensure the requirements of the program are enforced, and to discipline employees when requirements are not met. 
 
Employees will follow the requirements of this program.  This may include attending required training or meetings, using appropriate equipment and following established procedures.  When employees have suggestions related to this program and/or safety in general, they will report them to their Supervisor and/or the Program Coordinator.  
 
Process Safety Information 
The City of Austin, Wastewater Treatment Facility has completed a compilation of written process safety information before conducting any process hazard analysis.  The purpose of compiling written process safety information is to enable the City of Austin, Wastewater Treatment Facility employees involved in operating the proc 
ess to identify and understand the hazards posed by those processes involving highly hazardous chemicals.  
 
This process safety information includes information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.  Material Safety Data Sheets meeting the requirements of 29 CFR 1910.1200 have been acquired for every hazardous chemical used or created by the process. 
 
The City of Austin, Wastewater Treatment Facility will document that equipment complies with recognized and generally accepted good engineering practices.  For existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the City of Austin, Wastewater Treatment Facility has determined and documented that the equipment is designed, maintained, inspected, tested, and operating in a safe manner. 
 
Process H 
azard Analysis 
The City of Austin, Wastewater Treatment Facility has performed an initial process hazard analysis (hazard evaluation) on the process covered by this program.  The process hazard analysis will be appropriate to the complexity of the process and will identify, evaluate, and control the hazards involved in the process.   
 
The City of Austin, Wastewater Treatment Facility will determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process. 
 
The process hazard analysis will be performed by a team with expertise in engineering and process operations, and the team will include at least one employee who has experience and knowledge specific to the process being evaluated.  Also, one member of the team must be knowledgeable in the specific process hazard analysis methodology  
being used. 
 
The City of Austin, Wastewater Treatment Facility will promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions. 
 
Every five (5) years after the completion of the initial process hazard analysis, the process hazard analysis will be updated and revalidated by a team meeting the requirements described in 3.4, to assure that the process hazard analysis is consistent with the current process.   
 
Operating Procedures 
The City of Austin, Waste Water Treatment Facility* has developed and implemented written operating procedures that provide clear instructions for saf 
ely conducting activities involved in each covered process consistent with the process safety information and will address at least the elements outlined in the remainder of section 4 of this program. 
 
In addition to developing procedures related to operating process equipment (as described below) the City of Austin, Waste Water Treatment Facility* has developed and implemented safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel.  These safe work practices will apply to employees and contractor employees. 
 
Operating procedures will be readily accessible to employees who work in or maintain a process. 
 
Training 
Employees whose work involves operating, maintaining, repairing, or otherwise being exposed to the process will receive an appropriate degree of training.  Training w 
ill comply with the guidelines described below. 
 
Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, will be trained in an overview of the process and in the operating procedures as specified in section 4 of this section.  The training will include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks. 
 
Refresher training will be provided at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process.  The City of Austin, Waste Water Treatment Facility*, in consultation with the employees involved in operating the process, will determine the appropriate frequency of refresher training. 
 
Contractors 
The City of Austin, Wastewater Treatment Facility will approve 
contractors based on an evaluation of their safety performance and safety programs.  The goal of the contractor approval process is to determine whether or not the contractor is able to safely perform the task at hand.  Contractors who do not meet the requirements described in the this section will not be permitted to work on the process.   
 
Pre-startup Safety Review 
The City of Austin, Wastewater Treatment Facility will perform a pre-startup safety review for any new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information. 
 
Mechanical Integrity 
The City of Austin, Wastewater Treatment Facility has established and implemented a written Preventative Maintenance (PM) Program.  The criteria used in these inspections are be based on manufacturers's recommendations.  The Maintenance Foreman is responsible for maintained the PMP.  
 
Hot Work Permit 
Before any hot work is to commence, in, on, or near a covered pr 
ocess, the person conducting the work will complete a hot work permit form, and ensure that all appropriate precautions are taken. 
 
After the form is completed and initialed/signed by the employee, the Maintenance Foreman is responsible for reviewing the permit form and verifying that the precautions have indeed been taken, and that no other precautions are necessary. 
 
Management of Change 
The City of Austin, Wastewater Treatment Facility has established and implemented written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process. 
 
If a change is covered and results in a change in the process safety information, the PSM plan will be updated accordingly.  If a change is covered and results in a change in the operating procedures or practices, such procedures or practices will be updated accordingly. 
 
Employees involved in operating a process and maintenance a 
nd contract employees whose job tasks will be affected by a change in the process will be informed of, and trained in, the change prior to start-up of the process or affected part of the process. 
 
Incident Investigation 
The City of Austin, Wastewater Treatment Facility will investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace.  An incident investigation will be initiated as promptly as possible, but not later than 48 hours following the incident. 
 
All investigations will be conducted by a team consisting of the Maintenance Foreman and Relief Operator.  In addition to these individuals the team will include at least one person knowledgeable in the process involved, including a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident.  A report will be prepared at the conc 
lusion of the investigation which includes at a minimum: date of incident, date investigation began, a description of the incident, the factors that contributed to the incident, and any recommendations resulting from the investigation. 
 
Incident investigation reports will be retained for five years.  Investigations are filed in the Operations Supervisor Office. 
 
Compliance Audits 
The City of Austin, Wastewater Treatment Facility will certify that we have evaluated compliance with the provisions of this program every three years to verify that the procedures and practices developed under the standard are adequate and are being followed. 
 
The compliance audit will be conducted by a team consisting of the Operations Supervisor*, Maintenance Foreman, and Relief Operator, all of whom are knowledgeable about the process. 
 
A report of the findings of the audit will be developed.  The City of Austin, Wastewater Treatment Facility will promptly determine and document an appropriate response to  
each of the findings of the compliance audit, and document that deficiencies have been corrected.  The City of Austin, Wastewater Treatment Facility will retain the two most recent compliance audit reports. 
 
 
The Five-year Accident History: 
 
There were no reportable accidents in the last five years. 
 
 
The Emergency Response Program: 
 
The City of Austin, WWTF has established and implemented an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38(a).  In addition, the emergency action plan will include procedures for handling small releases.  
 
The program is available for employees and representative by contacting the Operations Supervisor, Emergency Action Program Coordinator.  
 
While specific actions are detailed in the plan, general actions for all emergencies involving a highly hazardous chemical incident on the treatment plant site include: 
 
    Evacuation of the immediate area 
    Employee head count 
    Notification of the Fire Department by cal 
ling 9-1-1 
    Providing emergency medical care for the injured 
 
For contact with chlorine and/or sulfur dioxide gas, affected body areas should be flushed with clean water and if there is difficulty breathing, breathing supported by artificial respiration until the person can be transported to an area hospital. 
 
 
Planned Changes to Improve Safety: 
 
At the present time, the City of Austin WWTF is not planning to install new mitigation or control equipment or technology.  Refresher training will be provided at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process.  The City of Austin, Wastewater Treatment Facility, in consultation with the employees involved in operating the process, will determine the appropriate frequency of refresher training
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