The Top 5 Performance Tips for a Healthy Secondary Clarifier

The secondary clarifier is a vital part of every wastewater treatment plant. Its health is determined by upstream variables and the mechanical integrity of the clarifier components. Some wastewater facilities do not have a filtration system to capture total suspended solids that are discharged from the unit. This can cause the treatment system to be in a violation state or inhibit the operations of a disinfection system such as Ultraviolet treatment units. This article will focus on the top 5 performance tips to achieve or maintain a healthy secondary clarifier.


  1. Monitor the Upstream Biological System Very Closely

No matter if the process is a trickling filter, rotating biological contactor (RBC), pure oxygen aeration, or extended aeration the clarifier performance is married to the upstream biological system. Poor settling solids is a condition of the biological process. Here are some process control check for the operator:

  • Maintain an optimal dissolved oxygen level for you treatment train. If possible automate the blower control to appropriately react to the changing conditions of the hydraulic or organic loadings.
  • Check plant operations and maintenance (O&M) manual to compare design criteria with current operations. The O & M provides guidance as to the engineering capabilities of the biological system, therefore deviations can be detrimental to the system.
  • Extended Aeration Plants: Monitor key parameters such as alkalinity, temperature, and nitrification. As the plant nitrifies the potential for rising sludge will increase, because of the denitrification that happens in the clarifier. Alkalinity and nitrifying bacteria must be present, in the right ratio, to achieve complete nitrification.
  • Do microscopic examinations of the aeration basin daily to monitor filamentous growth and take prompt corrective action if any abnormal condition is observed.

Photo Credit: Loxahatchee River District taken by Sheldon Primus


  1. Uniform the Sampling Locations

Choosing the right sampling location for sludge sampling and clarifier core testing (commonly called sludge judge testing) is important for assessing the health of the clarifier. If operators do not have a uniformed location and speed in which to conduct the “sludge judge” test, then it becomes difficult to trust the data that is collected from shift to shift. A review of sampling procedures, location labeling, and operator techniques should be made semi-annually. Also a written sampling standard operating procedure (SOP) will erase arbitrary actions by individual operators.

  1. Use Trending Data to Predict Conditions

Trending data on Supervisory Control and Data Acquisition (SCADA) terminals is a wonderful way to help identify positive and negative plant trends on a given intervals. Here are some tips to maximize the use of the plant’s SCADA data (every plant does not monitor the same parameters, but one listed below are common):

  • Check the available flow data (Raw flow, recycled flows, return activated sludge (RAS) flow, etc.) in conjunction with the D.O. concentration. This will give you a correlation to the impact of hydraulic loading to the D.O. usage
  • Monitor the mixed liquor suspended solids (MLSS) concentration in the aeration basin and plant effluent total suspended solids (TSS) to the temperature in the aeration basin. This will give a connection to see how higher or lower temperatures affect settling. (Note: Settling can also be effected by concentration alone. Lighter flock settles slower)
  • Trend the plant pounds of solids in the aerbay, waste activated sludge (WAS), and effluent TSS to give you the necessary information to determine the plant Sludge Retention Time (SRT). Targeting flow may give you an incomplete picture of the process characteristics.
  1. Take Quick Action to Correct Poor Trends or Conditions

Gathering data is only a small portion of what is required for top performance. Once you analyze the data, then you must make prompt corrective action to avoid catastrophes. Corrective actions should be made strategically and incrementally to the process. Each major change (i.e. lower concentration of MLSS through wasting more, the addition or subtraction of a process train, or switching the aeration pattern of the aerbay) should be given 1 full SRT cycle. Then verify the expected changes has meet the expectations of the actual plant performance.

  1. Be Prepared for Seasonal Weather Conditions or Process Conditions

Seasonal weather or process changes can throw the proverbial monkey wrench in any well working treatment system. Being aware of the latest weather trends will help the plant superintendent to decide if a preemptive strike such as raising the plant solids loading will be necessary. Remember, the secondary clarifier will react to concentration changes, filamentous bacteria, and organic or hydraulic loadings. The more predictable the seasonal condition the better prepared the operator should be to protect the clarifier and aeration operations.

The secondary clarifier is dependent on the upstream process, but the clarifier performance can be optimized through following these simple tips. An important tip that didn’t make the top five is to have a quality preventative maintenance program that monitors the mechanical integrity of the system. Through a concerted effort of the plant maintenance and operations staff the secondary clarifier can reach peak performance.

The Top 5 Fall Protection Hazards Overlooked by Utilities

Fall hazards are the number one killers in the construction field according to the Occupational Safety & Health Administration (OSHA). In 2010, fatalities from falls to lower levels was 255 out of 264 recorded fall deaths ( However, other industries and sectors are also affected by fall hazard in day to day task. Utilities have several exposure points for fall hazards. This article will only highlight the top 5 fall protection hazards overlooked by utilities and way to mitigate this hazard.

  1. Ladder Safety

Photo Credit: Utility Compliance Inc.

The man seen here is on the top rung of a metal ladder operating a chainsaw without adequate fall protection. In the Occupational Safety and Health Administration (OSHA) general industry standard of 1910, there is no specific wording on fall protection for working on a metal ladder (29 CFR 1910.26) which becomes the working surface. Utilities have varies needs for using a ladder throughout the plant and in the field. 20 feet step ladders are sometime times used to change light bulbs or gain access to other areas of the plant.

Ladder use and care are very important to prevent fall hazards from occurring at the utility. It is common for the utility staff routinely do limp cutting, put up shutters on upper levels, and travel up and down ladders for tank entries and roof access. These tips will keep the workers safe and help with state OSHA compliance:

  • Read the manufacturers recommendations on the ladder care and use
  • Remove broken ladders from service
  • Instruct workers on the proper use of ladders
  • Be aware of the ladder duty and weight guidelines.


2. Scaffolding and Articulated Boom Truck

Photo Credit:


Falls from scaffolding and articulated booms can be fatal, due to the heights related to the nature of the work. Many operators have to use scaffolding for accessing elevated work surfaces of the plant for maintenance work and some construction. As a point of clarification, there must be an understanding of what is classified as construction and what is classified as maintenance. OSHA, in a 2003 letter of interpretation, explains construction under these considerations:

  • The physical condition of the equipment/structure being worked on by the worker (does this item need to be removed completely)
  • Was the replacement material for prevention of a state of failure or to supplant deteriorated sections
  • What are the physical characteristics (height, weight, width, and material) of the equipment or structure
  • Is work being performed by a contractor other than employees
  • Is this work done during an annual scheduling

Maintenance is described in a 1999 letter of interpretation as:

  • Efforts to keep equipment or structures in proper condition through “routine, scheduled or anticipated measure without having to significantly alter the structure or equipment in the process (OSHA, 1999)”

If the nature of the job is construction, then the utility should follow the 29 CFR 1926. 450 (Subpart L) rules and guidance on Scaffolding and 1926.500 (Subpart M) Fall Protection. If the task is deemed to be maintenance, then follow the 29 CFR 1910.28-.29 requirements for scaffolding.

Tips for compliance and hazard mitigation are:

  • Have the scaffolding constructed and broken down by a competent person
  • Inspect the elements of the scaffold and articulated boom for any damage
  • Instruct workers to stay within the rails of the protective system
  • Use fall arrest systems when appropriate and “tie off” on the approved anchor points per the manufacturers recommendation


3.   Floor Holes

Photo Credit: Utility Compliance Inc.

A floor openings are all over treatment plants and collections/distribution systems. Anything that is 12″ or more is considered a floor opening under 29 CFR 1910.21 and works must be protected from falling to a lower level. Many places in the treatment plant has Hydrogen Sulfide and other gases that are corrosive in nature. Workers must walk on grates, covers, and lids often in their day to day duties. If any of the brackets or track that hold the covers are compromised, then the worker can sustain injuries. Here are some steps to protect from floor opening hazards.

  • Put checks of the floor opening on the checklists used in daily operations. The worker should be checking the integrity of the cover, tracks, and any hardware.
  • Replace corroding hardware with stainless steel or other hard to corrode hardware
  • Use agents that will reduce sulfides in lift stations where at all possible
  • Use engineering controls to protect workers from exposures during entries or maintenance to the covered structure.

4.  Tank Maintenance

Photo Credit:


Clarifier, digester, holding tank cleanings are always a challenge for the operator, due to the heights and being over water. In some cases, the work area has not been engineered for proper cleaning at every location of the tank. Therefore, the worker has to adapt to the work environment in order to get the work accomplished. In the above picture, the worker is prepared for the event that he may fall into the tank, by wearing a life preserver. However, if he loses his balance and were to fall backwards he would suffer injury from the fall. Employers have a duty to protect their workers from known hazards and to provide a safe work condition under the Occupational Safety and Health Act General Duty Clause 5(a)(1). The workers can be protected by the following steps:

  • Perform a Job Hazard Analysis prior to performing the work.
    • List the step of the task one by one
    • Identify the hazards related to each step
    • Identify a control (Engineering, Administrative, and/or PPE) for each step listed.
  • Engineer a walkway with a railing system as a capital budget item issue when possible.
  • Provide a fall protection system
    • Safety Net
    • Fall Arrest System
    • Fall restraint system


5.   Vehicles

Photo Credit:


Falls from vehicles and heavy equipment is also a concern for the utility sector. In order to maintain or check critical components on an elevated vehicle, the workers are exposed to a fall hazard. Even short checks on the top of a tanker, truck, or trailer can prove to be a major hazard with debilitating consequences. Again, it’s up to the employer to provide a workplace free of known or suspected hazards in the work environment. Here are some tips to keeping the workers safe from falls off of vehicles:

  • Use a portable anchoring system with a retractable lifeline (as pictured above)
  • Use a platform to access the truck top
  • Wear the proper foot PPE to protect from slippery walking surfaces

In conclusion, each treatment plant has several fall hazards present, but though the hazard exist the worker can be protected by reduced exposure, engineering, administrative, or PPE controls. It is up to the utility to provide a work environment free from any known or suspected hazard.





Utility Safety Workshop | OSHA Regulatory Compliance : Compliance Training Webinar (Online Seminar) –

Utility Safety Workshop | OSHA Regulatory Compliance : Compliance Training Webinar (Online Seminar) –

Why Should You Attend:

Utilities have a myriad of hazards that must be mitigated on a continuous basis. There are physical, chemical, biological, and in some instance terrorist hazards and threats. Several utilities have dedicated safety personnel who take a leadership role in the organization’s safety and health program, but that is not always the case.

The liquid utility sector is a specialized group with a high level of exposure to hazardous environments and life threatening tasks. Wastewater and drinking water personnel have not been given the occupational safety training to the same degree as their private sector counterparts. However, the municipalities with state OSHA regulations must meet the same standards of 29 CFR 1910 and 29 CFR 1926 as the privately own companies.

This webinar will explain hazards related to each treatment process including water, wastewater and stormwater treatment. It will also provide attendees’ tools that they need to protect themselves on a day to day basis.

Areas Covered in the Webinar:

  1. Basics of water treatment, wastewater treatment, and stormwater treatment
  2. Hazards related to each process of a water treatment facility
    1. PPE for drinking water and wastewater sector
    2. Screening facilities
    3. Physical processes
    4. Chemical process
    5. Disinfection
      1. Gas chlorine
      2. Bleach
      3. UV
      4. Ozone
      5. Fluoridation
    6. Maintenance/Electrical (Both water and wastewater)
      1. Lockout/Tagout
      2. Welding
      3. Materials handling
      4. Machine guarding
    7. Process safety management (both water and wastewater)
    8. Walking and working surfaces (both water and wastewater)
  3. Hazards related to each process of a wastewater treatment facility
    1. Biological waste
    2. Nuclear waste
    3. Industrial waste
    4. Screenings
    5. Ergonomics
  4. Hazards related to collections and distribution systems
    1. Working in hot environments
    2. Emergency action plan
    3. Distracted driver
    4. Defensive driver
  5. Hazards related to construction in utilities
    1. Fall
    2. Caught-in between
    3. Electrocution
    4. Struck-by
    5. Silica dust
    6. Asbestos
    7. Trenching
  6. Hazards related to water and wastewater laboratories
    1. Hazard communication
    2. Bloodborne pathogens
    3. SDS Transition
  7. Basic understanding of homeland security concerns related to utilities
    1. Terrorism
      1. Domestic
      2. International
  8. Basic understanding of EPA risk management programs for utilities
    1. Risk management program compliance for handling highly hazardous chemicals

Who Will Benefit:

  • Utility Directors
  • Public Sector Underwriters and Insures
  • Public Works Personnel
  • Construction Foremen
  • Laboratory Personnel
  • Compliance and Safety Officers
  • Regulatory Affair Personnel

Instructor Profile:

Sheldon Primus, is a Certified Occupational Safety Specialist with a Masters of Public Administration with a concentration in Environmental Policy. He has been in the environmental field since 1994 as an “A” licensed Wastewater Operator, Plant Superintendent of Operations and Maintenance, Industrial Pretreatment Coordinator, Compliance and Safety Officer for a Special District of the State of Florida, and is an adjunct instructor for Florida Gateway College in the Environmental Science department. Additionally, he is a trainer for the Certified Occupational Safety Specialist program of the Alliance Safety Council-Baton Rouge, LA.

Additionally, Sheldon is an authorized OSHA General Industry and Construction trainer for the 10 and 30 hour Outreach program. He has created Spill Control Plans, Risk Management Plans for Chlorine gas, and has conducted numerous training for water, wastewater, industrial pretreatment, and distribution system operators and engineers.

Currently, Sheldon is the owner/CEO of Utility Compliance Inc. and its subsidiary OSHA Compliance Help a safety consulting, operator training, and a regulatory agency compliance assistance company based in Port St. Lucie, Florida. In this capacity, he creates Hazard Communication Plans, OSHA Compliance Mock Audits, Water and Wastewater Plant Operations and Maintenance training courses, and many other safety and training services. Sheldon is also part of the Water Environmental Federation (WEF) Water Sector Safety Committee and the US Department of Environmental Protection Agency (USEPA) taskforce on All Hazards Communication training for the Water and Wastewater Sector. Sheldon is currently under contract with Elsevier Publishing to write a wastewater math resource book, set for a Fall 2015 release.

Topic Background:

Workers in the liquid utility field have been plagued with amputations, struck-by, and caught-in between injuries. State OSHA programs has recorded 367 inspections of drinking water plant (SIC code 4941) through planned, follow-up, referral, and complaint inspections in a one year period. While wastewater plants (SIC code 4952) had 233 inspections in the same time period. Drinking Water Plants have been cited a total sum of $94,478 from the period of October 2012 to September 2013 ( Wastewater Plant has been cited a total sum of $29,728 in the same period(

However, the citations are only a small portion of the “cost” of an accident. Utilizing OSHA’s Safety Pays online calculator just one amputation at a 3% profit margin would cost the utility $133,074 in direct and indirect costs. The utility would have to generate $4,435,800 million to offset that total cost ( Those funds come from the local community in the form of their utility rate.



National Certification: What Would it Mean for Wastewater Treatment Operators? | TPO – Treatment Plant Operator Magazine

In North America, water, wastewater, and distribution and collections systems do not have a national certification program. In some industries — including teaching, nursing, therapy disciplines and interpreting — a national certification has been the norm for years. 



National Certification: What Would it Mean for Wastewater Treatment Operators? | TPO – Treatment Plant Operator Magazine.

Let’s Talk About National Certifications

A national certification program for water, wastewater, distribution and collections systems is not currently available in North America. There are some industries where a national certification is the “norm” and has been for years. Industries such as teaching, nursing, therapy disciplines, and interpreting. There should be a way for the liquid utilities to standardize and formalize, under a federal requirement, treatments for drinking water, wastewater, and the related services. This article will explore how it may be possible to have a national certification program and why it may serve the greater good of the field in the future.

Photo Credit:

The Current Certification System


In the current system for certification, all states are responsible for creating their own criteria to maintain compliance with FRL-6230-8 found in the Federal Register Volume 64 No. 24 February 5, 1999. The federal register is a publication that give the general public notification of all final rules for the federal government. The ruling is specific to drinking water operator certification, but wastewater certification has been adopted under this ruling. States were given control over items such as:

  • The type of exam that should be given, oral or written
  • The type of operator training
    • EPA is responsible for evaluating the state program on an annual basis
  • They must have a fixed cycle of renewal not to exceed 3 years
  • They must establish training requirements for certification renewal
  • They must follow the operator certification guidelines as outlined by Section II Operator Certification Guideline.

Reciprocation is another issue that goes hand in hand with a national certification program. Reciprocation is where a state will allow an operator that holds a valid license from another state to get credit for that established license. Therefore, the operator will only have to apply for reciprocity with the new state. States like Indiana and Kentucky currently reciprocate with other states. However, some states like Florida do not reciprocate with any other state. An operator that wants to move to Florida and operate a facility must meet all of the state’s requirements as a new operator. Though the experience will still be credited to the operator, he/she must meet the training and testing requirements before they can receive a valid Florida license.

Why Do We Need a National Certification Program?


A national certification program would give the liquid utility a much needed image boost and add professional credentialing to a highly technical industry. In an August, 2013 article in the Opflow
magazine, the authors declared “operators also enjoyed comparatively less earning power than other professions, largely due to the fact that the cost of their services are priced much lower then they’re worth”(Copeland, A. & Moore, G., 2013). The article on went on further to introduce a Professional Operator (PO) designation much like an engineer has a Professional Engineering (PE) designation behind their name (Copeland, A. & Moore, G., 2013).

In addition to a PO designation, the liquid utility field can shed the system of reciprocity of one state to the next with a national certification. This certification should not be mandated, but only an option for the operator that may want to keep their options open. In this day and age there are many reasons for a family to have to move states in order to keep two incomes. Operators that must move can have assurance that they will be able to apply for a job in any state without having to take a drastic pay cut while they get a new license.

Lastly, a national certification program will have a uniformed training criteria as developed by the Environmental Protection Agency (EPA), a national operator association, or other entities such as the Association Boards of Certification (ABC). ABC, has an established voluntary, international, operator certification program and has developed a model standards of operator certification that provides a framework and benchmarks for operator evaluation (ABC, 2014). There may be another entity that is developing a national or international certification model, but I’m unaware of any other besides ABC.

How Can We Create a National Certification Program?


The creation of a national certification program will have to come from the inside out. Meaning the driver must come from the operators, municipalities that are struggling to hire qualified operators, and the States that are willing to divide the piece of the certification fee, “pie”. The industry has widely established the Sacramento State Course as a standard for drinking water and wastewater certification. Therefore, the course training for the utility sector doesn’t have to change from the established curriculum. However, in addition to these courses, a criteria should be set to determine the perspective operator’s knowledge on specialized systems. Imagine having a national certification with a concentration or endorsement for UV Disinfection, Advance Waste Treatment, or Biological Nutrient Removal. With the endorsement addition to a national certification, then the hiring municipality can be assured that the candidate is qualified to operate “their” system.

States can administer the test or use an online program as most states have currently. CEU requirements will be consistent of the law, not more than 3 years, but that training will be as its current framework within the states. A PO would have to meet the requirements of the ABC program, but each state would have to formally recognize the Professional Operator designation. The future of operations in the States would change forever with a national certification program. Who know, it may lead to an international program where the global Water and Wastewater communities can share talent.

7 Tips For Risk Management Program Compliance

Program Overview

The Risk Management Program (RMP) is an Environmental Protection Agency (EPA) initiative that tracks, audits, and regulates facilities with extremely hazardous substances (EHSs), Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), and toxic chemicals over a certain quantity. Congress enacted the Emergency Planning and Community Right-to-Know Act (EPCRA) in 1986 as a reaction from the 1984 Bhopal, India accident where Union Carbide chemical plant had a release of methyl isocyanate.

This incident cause thousands to die and many injuries in India, but 6 months later a chemical release in West Virginia (EPA, 2012). Therefore, Congress moved under the Code of Federal Regulations (CFR), the protection of environment is Title 40 to create ways of protecting the American public. The RMP can be found 40 CFR Part 68 in the Clean Air Programs section. You can find specific chemicals on “The List of List” for regulated chemicals.

Photo Credit:

Each owner/operator has a duty to be responsible for the safe handling, storage, and use of regulated hazardous substances under The General Duty Clause (GDC) Section 112 (r)(1). This GDC covers “any stationary source producing, processing, handling, or storing regulated substances or other extremely hazardous substances” (EPA, 2009). The RMP sets a framework for an accident prevention program, reporting system for releases, establishing program levels, and compliance structuring (EPA, 2009).

Having an all-inclusive policy for all facilities is not a practical way of having a RMP on a national level. Therefore, the EPA has divided systems in to programs levels to better “match their size and the risks they pose” (EPA, 2009). The Program Level are as follows:

Program Level 1:

A facility that on its very worst day would not affect the public (as noted in a worst-case scenario modeling) and did not have an accident within the past 5 years

Program Level 2:

A facility not eligible for Program 1 or Program 2 is put into program level 2 status. These facilities have additional hazard assessment, emergency response, and management requirements (EPA, 2009).

Program Level 3:

Program that does not meet level 1 requirements, has to comply with the Occupational Safety and Health Administration (OSHA) Process Safety Management Standard (PSM), or is one of ten specified industry codes from the North American Industrial Classification System (NAICS). Level 3 programs must follow OSHA PSM standards because the RMP incorporates the PSM into its standard.

Photo Credit:

  1. Know Your Deadlines

Drinking Water and Wastewater Facilities have potential to have several substances regulated by the RMP and even OSHA PSM programs. Drinking water facilities (NAICS 22131) have 2,289 total facilities under the RMP, 108 accidents, 90 injuries, and $3,653,153 in property damage in the past 5 years (RTKNET, 2014). Wastewater facilities have 1,514 RMP facilities, 92 accidents, 70 injuries, and $5,179,500 in property damages in the past five years (RTKNET, 2014).

In 2009, the RMP system was updated by EPA in which all current facilities under the program had to resubmit their programs for approval. This program revision and resubmittal must be done every 5 years or if changes in the quantity stored, processes, handling, or any aspect of the program have been made within six (6) months of that change to maintain compliance of 40 CFR 68.36.

Compliance Audits must be conducted and be certified every three (3) years to evaluate the program, procedures, and practices are adequate to comply with the rule. In order for an audit to comply with the 40 CFR 68.58 rule the auditor must be knowledgeable of the process, give a written report of the findings, a compliance schedule for deficiencies must be established, the owner has to retain the two most recent audits.

Here’s a chart to help know your compliance dates:































Note: x=If there is a program change in audit or revision years, then training is required.

Chart Credit: Utility Compliance Inc.

  1. Hazard Reviews

Conducting an accurate Offsite Consequence Analysis (OCA) will product two scenarios, a worst-case and an alternate case scenario. Think of the worst-case scenario as who in the general public will be affected if there is a release of chemicals from the facility. By the quantity of the produce, wind direction, and other variables the scenario should be carried out to its end point. A circle is drawn around the facility to the endpoint distance in all directions to ascertain what public receptors or environmental receptors are in the “circle of death”. Worst-case scenarios are highly unlikely, but must be accounted for in your hazard determination.

Conversely, the alternate scenario is the most likely occurrence with treatment facility. In the case of chlorine gas, when the operators change from an empty bank of cylinders to a full bank some gas may escape the regulator or chlorine distribution system. The gas will be released into the room and in most cases not reach the operations control room before dissipation.

  1. Operating Procedures

There are six phases to the operating procedures that must be effectively addressed. Detail each step and write a narrative as to what is involved in each step of the process. In addition, add the number of personnel needed, Personal Protective Equipment (PPE) that must be worn, and any other considerations for each of the following phases:

  • Normal Start-up
  • Normal Operations
  • Normal Shutdown
  • Emergency Shutdown and Operations
  • Initial Start-up
  • Temporary Operations
  1. Training

Training is an important criteria for this program, because the utility staff are the first line of defense. 40 CFR 68.54, states that the owner or operator “MAY” certify in writing that the employee “has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as provided in the operating procedures” (EPA, 2014). This is not a requirement, but it’s a good practice to record refresher training, initial training, and annual training events.

With regulators, it didn’t happen unless it is documented in writing (with signatures from attendees). Refresher training SHALL be every three years or if there are changes in the program or process. It’s a good practice to document training with an exam to prove operator mastery of the program and process phases.

  1. Maintenance

Maintaining mechanical integrity of the process systems is a must in 40 CFR 68.56. Training on the safety of working on the maintenance of the components is a requirement for this section. Even the contractor must be trained as to the hazards surrounding the maintenance to the equipment. In addition, the equipment must be tested and inspected to ensure that they are within the recommendation of the manufacturer, industry standards and codes, and good engineering practices.

  1. Compliance Audits


After an internal or external audit is complete, then the process for abatement of deficiencies must be clear and specific. Each action item must be given to an accountable party for correction. It is not enough for the audit review team to tell the operator to fix the problem with no timeline for abatement. Here is a sample form for Action Item assignment with risk assessment and follow-up:



B-Within 7 days

C- Within 30 Days


60 Days

E-After 60 Days

Action Item








1-Not Likely



4-Very Likely

Risk Total

(Severity x Probability)=


Code, System, or Regulation

Action to be Completed

Assigned to

Target Date

Completion Date


A.I. #1




Chlorine Regulators

Fix slow leak in manifold system


June 1, 2014

June 1, 2014

Chart Credit: Utility Compliance Inc.

  1. Incident Management

40 CFR 68.60 has a summary of how incident investigations should be conducted and recorded. However, prior to the investigation make sure that in the event stage that all notifications are made to the National Response Center (NRC) and/or State Emergency Response Commissions (SERCs). When making the initial notification have these items ready for the incident notification center:

  • The chemical name
  • An indication of whether the substance is extremely hazardous
  • An estimate of the quantity released into the environment
  • The time and duration of the release
  • Whether the release occurred into air, water, and/or land
  • Any known or anticipated acute or chronic health risks associated with the emergency, and where necessary, advice regarding medical attention for exposed individuals
  • Proper precautions, such as evacuation or sheltering in place
  • Name and telephone number of contact person (As quoted from EPA, 2014).

Written notification is required to local emergency response and the state emergency response entities as soon as practicable after the event. Other notification rules can be found in 40 CFR 355.40 to avoid penalties (40 CFR 355.50) that can be up to $25,000 for each violation, civil penalties up to $25,000 per day, and criminal penalties for up to two years imprisonment.

The RMP system is necessary to protect the surrounding community from extremely hazardous chemical, but the regulations are very strict and daunting. There has been a movement for utilities to replace the use of these chemicals where practical and appropriate. If you have an active RMP, then these 7 tips will help you meet or to stay in compliance.


5 Steps to Peak Plant Performance | TPO – Treatment Plant Operator Magazine


Wastewater treatment plants should aim to produce quality effluent without using a treatment aid for process control, and the best way to do that is by being proactive. By using these five steps, a plant will operate efficiently and will produce quality effluent well within the National Pollution Discharge Elimination System permit limits.


Read more:

5 Steps to Peak Plant Performance | TPO – Treatment Plant Operator Magazine.