Rainwood Pump Station - Executive Summary

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EXECUTIVE SUMMARY 
 
The Metropolitan Utilities District has had in place accidental release and emergency response policies and procedures at our facilities for many years.  Our Safety Policy Statement clearly states our management's commitment to "the safety of the public, our customers and our employees" and that this commitment to safety "takes precedence over expedience in completing any work performed by District employees".  Our emergency response plan includes active response by properly equipped, trained employees working with the local Fire Department Hazmat team.  A full time staff of safety and health professionals and a recently added training staff support this strong commitment to safety and health. 
 
Our Florence Water Treatment facility is the primary water treatment facility for drinking water for the City of Omaha, Nebraska and surrounding communities.  Liquid chlorine is used in the process of disinfection.  The facility houses one 110,000-pound capacity rail car, whic 
h we draw off during the water purification process.  A bank of eight one-ton chlorine cylinders is installed for back-up supply. Another twelve cylinders in storage are also housed at the Florence facility.  These cylinders are used as a back-up chlorine supply for this facility and other pump stations throughout the District. The Florence facility contains a filter plant, chemical building, chlorination room, chlorinator, safety equipment, monitors and alarms.  This facility is staffed 24 hours a day. 
 
The Platte River Water Treatment Plant is also used to supplement the water supply and is located at the Platte River, 4001 Laplatte Road in Bellevue, Nebraska.  This facility houses up to 14 one-ton containers and is equipped with chlorinators, safety equipment, monitors and alarms, and is staffed 24 hours a day. 
 
In addition to the two water treatment plants, the District uses eight pump stations to assist in the water distribution.  Each pump station houses two one-ton chlorine cyli 
nders and is equipped with emergency ventilation and leak detectors. 
 
The responsibility for implementation and handling of the District's Risk Management Plan rests with the Manager of Water Operations.  Alternate program responsibilities rest with the Superintendent of the Florence Water Treatment Plant.  The Director of Safety, Water Supply Engineer, and Director of Training as well as other technical and supervisory areas of the District. 
 
Scenarios included in consideration of chlorine release include both worst case release and alternative scenarios.  These are intended to delineate an area in which significant public impacts can occur. During a worse case scenario, an assumption has been made that the contents of the container are exposed to the atmosphere within ten minutes.  The most likely scenario allows us to take into account the actual site conditions and usage patterns to estimate the most likely severity of the discharge. 
 
Several ways to model the toxic endpoints are c 
onsidered acceptable and were reviewed for use in development of the plan.  The RMP Comp program (Version 1.04) was chosen for the 55-ton tank car.  Both worse case and most-likely scenarios were evaluated using this model. 
 
 
 
The ton cylinders were modeled using the scenarios described in AWWARF Compliance Guidance and Model Risk Management Program for Water Treatment Plants.  The worse case scenario was modeled using Scenario ID# CLW-2 from Table 5-1 in the AWWARF manual.  The most likely scenario was modeled using Scenario ID# CLA-3 from Table 5-5 in the same manual. 
 
All facilities used to house chlorine whether in use or for storage meet or exceed industry standards.  Equipment installed to facilitate the chlorination process and facilities to house chlorine are inspected periodically and scheduled maintenance is performed to ensure system safety and reliability. 
 
Safety information necessary to ensure the facilities and processes meet or exceed codes, standards and/or guidelines  
used in the development and installation of regulated requirements has been compiled and reviewed where appropriate. They include Chlorine Institute Pamphlets, local building and fire codes, National Electric Codes, American National Standards Institute pamphlets, manufacturer guides and applicable state and federal safety codes.  
 
A hazard review was performed using the WTP Hazard Review Checklist for Chlorine Systems provided in the RMP plan for the Water Industry published by the American Water Works Association.   
 
This review included a siting, operation and maintenance, hazard recognition, human factors, container shipment and unloading, stationary tanks, vaporizers, piping and appurtenances, and general conditions.  Any area identified as needing further research was annotated and followed up on to ensure proper measures were implemented to correct deficiencies or mitigate hazards. 
 
Operating procedures used within the Risk Management Plan are addressed in the District's Chlorin 
e Manual.  This manual addresses normal operations, emergency shutdown, normal shutdown, startup following turnaround, consequences of deviation, steps required to correct or avoid deviation, safety and health considerations, and safety systems.  Since the Florence Water Treatment Plant is a surface water treatment facility and is by law required to maintain chlorination at all times, it is considered to be an ongoing process.  No situations fall within the initial startup category.  The District does not have any procedures for temporary operations, as chlorination is a permanent process. While we can change the application point of the chlorine within the plant temporarily, this is done with chlorine solution, not with gaseous or liquid chlorine. 
 
Chlorine manuals are located at the Operators desk in the chemical building and at the Filter Plant.  Each Operator has a personal copy of the Operator Training Manual.   
 
Training requirements for the plan include Hazmat training for all C 
hemical Equipment Mechanics, operating procedure training for operating employees, safety and health training and awareness training for all District employees directly involved in the chlorination process. 
 
Employees are trained on any new or updated procedures prior to starting up that change.  All training is certified and documentation is kept in the training section of the Risk Management Plan. 
 
Compliance audits are conducted at least every three years using the checklist provided in the RMP plan for the Water Industry published by the American Water Works Association.  In addition to this audit, the District performs annual safety and health inspections on all facilities used in the chlorination process.  These inspections check for compliance with state and federal safety requirements, condition of facilities and equipment, availability of personal protective equipment, and safe work practices. 
 
Copies of these reports are forwarded to the appropriate Manager/Supervisor for rev 
iew and corrective action.  The Director of Safety conducts follow-up until all deficiencies are corrected.  All compliance audits and safety reports are filed in the Compliance Audits section of the Plan. 
 
In the event that an incident that results in or could reasonably result in a catastrophic release of chlorine occurs, an incident investigation team will be formed.  This team will investigate and report the findings, causes, and recommendations to the General Manager of the Metropolitan Utilities District. All resolutions and corrective actions will be documented and retained for five years. 
 
The Metropolitan Utilities District Risk Management Plan is a thorough plan encompassing all elements of sound industry practice, combining regulatory and voluntary elements to ensure safe chlorination with minimal risk to its customers, employees and the public.  The management and employees of the District take its responsibilities for this safety seriously and are dedicated to maintaining  
excellence in its processes and product.  This plan is developed with that in mind.
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