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CITY OF WICHITA FALLS

INTER-OFFICE MEMORANDUM
Accordingg to Director of Public Works Russell Schreiber P.E.,, Public Works staff has
consulted with Dr. Leonard Ripley
p y P.E. with Freese and Nichols Engineering,
g
g, an industry
specialist
p
in biological
g
wastewater treatment and sludge
g digestion
g
p
,
and disposal,
to determine if the Glycerin
y
y g sulfide
could have beenn the cause for the elevated hydrogen
ggas concentrations found in the area of the incident. He expressed
p
to the staff there was
no ppossible way
y the gglycerin
y
could have caused such elevated hydrogen sulfide
production as the glycerin has very low sulfur content.
The City has also reviewed the permits for all categorical industrial users of the Citys
wastewater collection and treatment systems and, none have large sulfur content in their
discharges to the Citys treatment facilities. The Citys Environmental Coordinator has
interviewed each of the industrial users for any possible upsets in there pre-treatment
process, and any possibility of discharges containing elevated sulfur content. None were
found. The City has also reviewed the Industrial User Surveys (125 industries) that were
completed for the entire City of Wichita Falls from the end of Apr
April
il through the first off
May this year and did not find any industries that use sulfur in a production process.
City staff continues to investigate the connection
connection between the de-watering process for the
current construction project on site and the elevated hydrogen sulfide gas concentration.
The groundwater from the construction site contains elevated levels of sulfate, which
could be contributing to the elevated hydrogen sulfide leve
levels.
ls. The City has had the
contractor stop discharging this water back into the plant, and continues to monitor the
hydrogen sulfide levels in the sludge. The results of this modification could take up to
several weeks to determine the effects. Training records for PPE, hazardous materials,
and Hazard Communications Act are available. Mr. Arredondo and Mr. Sheppard both
attended hazardous materials training on February 3, 2016. This course covered safe
handling of hazardous chemicals, PPE, first aid with respect to hazardous chemicals,
general clean-up safety, acute and chronic effects of exposure, locations of hazardous
chemicals in the workplace, and awareness of the hazardous chemical lists. Training
over hydrogen sulfide was included in this course.7/8/9 City management has consulted
with both internal and external legal counsel to contact the appropriate state and federal
agencies to review occupational safety and best practices within the City, but none of the
contacted agencies came forward for review.
The Occupational Safety and Health Administration (OSHA) was contacted, who then
sent a referral to the Department of State Health Services (DSHS) to conduct a Hazard
Communication Act inspection. The investigation involved interviewing plant
employees, and reviewing safety while working around chemicals and hazardous
substances in the plant. No violations were reported. A third party consultant has also
been contacted in regard to conducting an investigation into safety training, policies, and
procedures at the Waste Water Treatment plant. Official results from all inspections and

5/10

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