Lake Forest Regional Wastewater Treatment Plant - Executive Summary

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The Lake Forest Regional Wastewater Treatment Plant (WWTP) is a publicly owned wastewater treatment facility in northwest Harris County.  The facility serves Lake Forest Utility District, Harris County Municipal Utility District No. 18, Cypress Creek Utility District and Malcomson Road Utility District.  Each of these entities participates in the Lake Forest Plant Advisory Council, which has authority to make all policy and procedural decisions for the facility.  A contract operations company operates the facility. 
Lake Forest Regional WWTP utilizes two toxic chemicals, chlorine and sulfur dioxide, to disinfect treated plant effluent.  Chlorine and sulfur dioxide are stored on site in 2,000-pound steel cylinders.  The chemical feed equipment is used to measure and apply the chemicals to the treated effluent for disinfection.  There are no administrative controls or active mitigation systems in place at Lake Forest Regional WWTP that would affect consideration of the release scenarios  
discussed below. 
As part of the Risk Management Program, Lake Forest Regional WWTP has established a prevention program to identify potential hazards and implement operational and maintenance procedures to reduce the risk of an accidental release.  The facilities used at Lake Forest Regional WWTP are designed and constructed in accordance with applicable ANSI, ASTM, and ASME standards.  The prevention program includes annual hazard reviews, on-going safety training for personnel, daily equipment inspection and annual preventative maintenance.  A system has been established to investigate any hazardous incident related to the chemical storage and feed system.  Lake Forest Regional WWTP has also established a compliance audit team to review the on-going prevention program and update the program as necessary to provide continued protection to the facility employees and the surrounding community. 
The Lake Forest Regional WWTP has not had any accidental releases of a regulated toxic subst 
ance that caused any on-site or offsite effects within the past five years. 
As part of the Risk Management Program, Lake Forest Regional WWTP has developed two scenarios to evaluate the possible effects of an accidental release and assist emergency personnel to respond appropriately.  The "worst-case scenario" and the "alternative release scenario" were developed using the EPA's "RMP Guidance for Wastewater Treatment Plants." 
The worst-case scenario for the facility is based on the release of an entire 2,000-pound cylinder of chlorine over a period of 10 minutes.  This scenario could have hazardous effects up to 1.3 miles downwind of the vessel.  Within 1.3 miles of the facility, there are homes, schools, businesses and recreation areas that could be affected by the worst-case release. 
The alternative scenario for a chlorine release is based on a 1/2-inch diameter rust hole on a chlorine storage vessel.  This scenario could have hazardous effects up to 0.4 miles downwind of the vess 
An alternative scenario for a sulfur dioxide release was not prepared for this facility. Sulfur dioxide is stored below the EPA's threshold limit at the Lake Forest Regional WWTP and is not subject to the Risk Management Program requirements.  
The Cypress Creek Volunteer Fire Department (VFD) is the local emergency responder responsible for handling an accidental chemical release at Lake Forest Regional WWTP.  The emergency contact number for this agency is 911.  Lake Forest Regional WWTP has coordinated and provided a copy of the Risk Management Program for the facility to the Cypress Creek VFD and the Harris County Local Emergency Planning Committee (LEPC) for Unincorporated Areas.
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