Securing Wastewater Facilities: Costs of Vulnerability		 
Assessments, Risk Management Plans, and Alternative Disinfection 
Methods Vary Widely (30-MAR-07, GAO-07-480).			 
                                                                 
In 2006, GAO reported that many large wastewater facilities have 
responded to this risk by voluntarily conducting vulnerability	 
assessments and converting from chlorine gas to other		 
disinfection methods. The Clean Air Act requires all wastewater  
facilities that use threshold quantities of chlorine gas to	 
prepare and implement risk management plans to prevent accidental
releases and reduce the severity of any releases. In this study, 
GAO was asked to provide information on (1) the range of costs	 
large wastewater treatment facilities incurred in preparing	 
vulnerability assessments and risk management plans, and (2) the 
costs large wastewater treatment facilities incurred in 	 
converting from chlorine gas to alternative disinfection	 
processes. To answer these questions, GAO conducted structured	 
telephone interviews with a number of facilities surveyed for the
2006 report. The Environmental Protection Agency (EPA) agreed	 
with the report and provided several technical changes and	 
clarifications. 						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-07-480 					        
    ACCNO:   A67572						        
  TITLE:     Securing Wastewater Facilities: Costs of Vulnerability   
Assessments, Risk Management Plans, and Alternative Disinfection 
Methods Vary Widely						 
     DATE:   03/30/2007 
  SUBJECT:   Chemicals						 
	     Cost analysis					 
	     Critical infrastructure				 
	     Emergency preparedness				 
	     Facility security					 
	     Homeland security					 
	     Public utilities					 
	     Risk assessment					 
	     Risk management					 
	     Strategic planning 				 
	     Wastewater 					 
	     Wastewater management				 
	     Wastewater treatment				 
	     Wastewater treatment plants			 
	     Cost estimates					 

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GAO-07-480

   

     * [1]Results in Brief
     * [2]Background
     * [3]Costs of Preparing Vulnerability Assessments and Risk Manage

          * [4]Vulnerability Assessment Costs Depend Primarily on Whether a
          * [5]Risk Management Plan Costs Also Influenced by Use of Contrac

     * [6]Costs of Converting to Alternative Disinfection Methods at L

          * [7]Disinfection Method Chosen, Facility Size and Characteristic

               * [8]Disinfection Method
               * [9]Facility Size
               * [10]Other Key Facility Characteristics
               * [11]Temporary Conversions

          * [12]Changes in Annual Costs Vary Widely, with Some Facilities Re

     * [13]Agency Comments and Our Evaluation
     * [14]GAO Contact
     * [15]Acknowledgments
     * [16]GAO's Mission
     * [17]Obtaining Copies of GAO Reports and Testimony

          * [18]Order by Mail or Phone

     * [19]To Report Fraud, Waste, and Abuse in Federal Programs
     * [20]Congressional Relations
     * [21]Public Affairs

Report to the Chairman, Committee on Environment and Public Works, U.S.
Senate

United States Government Accountability Office

GAO

March 2007

SECURING WASTEWATER FACILITIES

Costs of Vulnerability Assessments, Risk Management Plans, and Alternative

GAO-07-480

Contents

Letter 1

Results in Brief 4
Background 5
Costs of Preparing Vulnerability Assessments and Risk Management Plans
among Large Wastewater Facilities Vary Widely 8
Costs of Converting to Alternative Disinfection Methods at Large
Wastewater Facilities Depend on the Method Used and Other Factors 13
Agency Comments and Our Evaluation 20
Appendix I Scope and Methodology 22
Appendix II Comments from the Environmental Protection Agency 24
Appendix III GAO Contact and Staff Acknowledgments 25

Table

Table 1: Reported and Planned Disinfection Conversion Costs for Large
Wastewater Treatment Facilities 14

Abbreviations

AWWARF American Water Works Association Research Foundation
DHS Department of Homeland Security
EPA Environmental Protection Agency
NACWA National Association of Clean Water Agencies
OSHA Occupational Safety and Health Administration
POTW publicly owned treatment works
RAM-W Risk Assessment Methodology for Water Utilities
VSAT Vulnerability Self Assessment Tool
WEF Water Environment Federation

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separately.

United States Government Accountability Office
Washington, DC 20548

March 30, 2007

The Honorable Barbara Boxer
Chairman
Committee on Environment and Public Works
United States Senate

Dear Madam Chairman:

Wastewater facilities in the United States provide essential services to
residential, commercial, and industrial users by collecting and treating
wastewater and discharging treated effluent into receiving waters. The
Centers for Disease Control and Prevention cited sewage disposal and water
treatment as important contributors to the control of infectious diseases,
which it considers 1 of the 10 greatest achievements in public health of
the 20th century. Wastewater disinfection, a key component of the
wastewater treatment process, reduces the risk that disease will be
transmitted through wastewater effluents. Historically, chlorination has
been the most commonly used method of wastewater disinfection because it
destroys a variety of pathogens and microorganisms.

Since the events of September 11, 2001, the security of the nation's water
infrastructure against terrorist threats has received greater attention,
including the potential for terrorist attacks at wastewater facilities
that store large amounts of chlorine gas. If released, chlorine gas may
threaten utility employees and the public near the affected facilities.
The gas can be deadly if inhaled and, at lower doses, can burn the eyes
and skin and inflame the lungs. In a 2004 report, the White House Homeland
Security Council determined that a terrorist attack on an urban chemical
facility that resulted in the rupture of a chlorine gas rail car could
kill up to 17,500 individuals and hospitalize as many as 100,000.

While federal law does not require wastewater systems to take security
measures to protect specifically against a terrorist attack, it does
require certain wastewater facilities to take security precautions that
could mitigate the consequences of such an attack. For example, the Clean
Air Act^1 requires wastewater facilities that use threshold quantities of
certain hazardous substances, such as chlorine gas, to prepare and
implement a risk management plan designed to prevent accidental releases
of regulated substances and reduce the severity of those releases that do
occur.^2

1Pub. L. No. 101-549 (1990).

As we reported in March 2006,^3 many of the nation's large wastewater
facilities have improved security since September 11, 2001. For instance,
a substantial number of facilities reported improving security fences,
increasing security lighting, and implementing improved employee and
visitor identification systems, among other security enhancements. In
addition, though not required, many large wastewater facilities reported
that they conducted vulnerability assessments^4 to identify risks to key
process components such as the use, storage, and handling of chlorine gas.
Finally, many facilities reported that they recently stopped or plan to
stop using chlorine gas in favor of alternate disinfection methods.
Commonly used alternatives include sodium hypochlorite, essentially a
concentrated form of household bleach, and ultraviolet light, which breaks
down disease-causing microorganisms.

For wastewater facility managers, the costs of preparing vulnerability
assessments and risk management plans and converting to alternate
disinfection methods must compete for available resources with other
infrastructure needs. For instance, in 2003, in its most recent Clean
Water Needs Survey, the Environmental Protection Agency (EPA) estimated
that, nationwide, wastewater systems faced $181.2 billion in costs to
upgrade treatment systems and sewer lines, reduce the incidences of
combined sewer overflows, which result in the discharge of untreated
wastewater into receiving waters, and meet other pollution control
requirements. Major U.S. cities, including Washington, D.C., and
Cincinnati, Ohio, are facing costs between $1 billion and $2 billion to
implement necessary capital improvements.

^2EPA requires that any facility storing at least 2,500 pounds of chlorine
gas submit a risk management plan.

^3GAO, Securing Wastewater Facilities: Utilities Have Made Important
Upgrades but Further Improvements to Key System Components May Be Limited
by Costs and Other Constraints, [22]GAO-06-390 (Washington, D.C.: Mar. 31,
2006).

^4According to the Environmental Protection Agency (EPA), vulnerability
assessments performed by water sector utilities address not only utility
vulnerabilities, but also utility threats and consequences.

This report provides information on (1) the range of costs large
wastewater treatment facilities incurred in preparing vulnerability
assessments and risk management plans, and (2) the costs large wastewater
treatment facilities incurred in converting from chlorine gas to
alternative disinfection processes.

To identify the costs of preparing vulnerability assessments and risk
management plans, we conducted structured telephone interviews with a
select sample of large wastewater facilities identified as having
completed these assessments in our March 2006 report.^5 Our March report
identified 106 large facilities that prepared vulnerability assessments or
had one underway and 85 facilities that were required to prepare risk
management plans because they currently used chlorine gas as a
disinfectant. From this universe, we chose a nonprobability sample of
facilities based largely on geographic representation and size.^6

To identify the costs incurred by wastewater treatment facilities in
converting from gaseous chlorine to alternative disinfection processes, we
conducted structured telephone interviews with most of the 38 large
facilities identified in the March report as having converted recently
from chlorine gas or indicating that they planned to do so. We also
conducted site visits with some of the facilities. Where available, we
gathered documentation, such as capital plans, from these facilities in
order to document conversion costs. We supplemented the cost information
we gathered at individual wastewater facilities with information obtained
at EPA, the Department of Homeland Security (DHS), and nongovernmental
organizations. Reported costs for preparing vulnerability assessments,
risk management plans, and conversion from gaseous chlorine include both
actual and estimated costs. For estimated costs, we asked facility
managers to explain how they arrived at these estimates. Reported costs
were not adjusted for inflation. We determined that reported cost data
were sufficiently reliable to provide useful information about the costs
for preparing vulnerability assessments, risk management plans, and
conversion from gaseous chlorine and the factors that affect these costs.
We conducted our work between August 2006 and March 2007 in accordance
with generally accepted government auditing standards. A more detailed
discussion of our scope and methodology is included in appendix I.

^5We defined large wastewater facilities as those publicly owned treatment
works (POTW) that serve residential populations of 100,000 or greater.

^6Results from nonprobability samples cannot be used to make inferences
about a population, because in a nonprobability sample some elements of
the population being studied have no chance or an unknown chance of being
selected as part of the sample.

Results in Brief

The expenses large wastewater facilities reported to prepare vulnerability
assessments and risk management plans varied widely among the facilities
we interviewed, costing less than $1,000 in some cases to $175,000 in
others. The cost differences were related to whether the documents were
prepared in-house or contracted to third parties such as engineering
firms. Despite higher costs, some facilities preferred to use contractors
due to their expertise and independence. According to one wastewater
security official, these attributes can give contractor findings and
recommendations greater credibility with utility governing boards that
determine spending priorities. Overall, cost estimates of the facilities
we interviewed did not relate to facility size, as measured by millions of
gallons of wastewater treated per day.

Large wastewater facilities that converted or plan to convert from
chlorine gas disinfection to alternative disinfection processes also
report widely varying costs, ranging from about $650,000 to just over $13
million. Key factors associated with these costs included the type of
alternative disinfection method chosen and the size of the facility. The
majority of the facilities we examined converted or plan to convert to
sodium hypochlorite (either delivered in bulk to the facility or generated
on-site), which has lower capital costs than converting to ultraviolet
light. For example, managers of a treatment facility in Virginia told us
they spent about $1.2 million in 2004 converting to bulk sodium
hypochlorite disinfection, while managers of a comparably sized facility
in Maryland told us they plan to spend an estimated $4 million converting
to ultraviolet light disinfection by the end of this year. Managers of the
Maryland facility indicated that one reason they chose the more expensive
ultraviolet treatment option over bulk deliveries of sodium hypochlorite
was to reduce risk to local traffic that could result from additional
deliveries to the plant. In addition, using ultraviolet light eliminates
the need for wastewater treatment plants to handle and store significant
amounts of hazardous or corrosive chemicals. Other than the disinfection
method and facility size, key cost factors wastewater facilities cited
included (1) whether existing buildings could be used in the conversion,
(2) building costs, which varied considerably from location to location,
(3) the higher cost of sodium hypochlorite relative to chlorine gas, and
(4) the extent to which training, labor, and regulatory compliance costs
were lower at plants that no longer had to rely on chlorine gas.

Background

A majority of the nation's wastewater is treated by publicly owned
treatment works that serve a variety of customers, including private
homes, businesses, hospitals, and industry. These publicly owned treatment
works are regulated by the Clean Water Act. Wastewater treatment includes
a collection system (the underground network of sewers) and a treatment
facility. Wastewater enters the treatment facility through the collection
system, where it undergoes an initial stage called primary treatment,
during which screens remove coarse solids, and grit chambers and
sedimentation tanks allow solids to gradually sink. Next, wastewater
enters secondary treatment, where bacteria consume most of the organic
matter in the wastewater. After these processes, wastewater is disinfected
to eliminate remaining pathogens and other harmful microorganisms.

Wastewater facilities typically use both chemical and physical
disinfection methods, including the following:

           o Chlorine gas. Injecting chlorine gas into a waste stream has
           been the traditional method of disinfecting wastewater. Chlorine
           gas is a powerful oxidizing agent, is relatively inexpensive, and
           can be stored for an extended period of time as a liquefied gas
           under high pressure. Also, the residual chlorine that remains in
           the wastewater effluent can prolong disinfection after initial
           treatment. However, chlorine gas is extremely volatile and
           hazardous, and it requires specific precautions for its safe
           transport, storage, and use. Because it is stored and transported
           as a liquefied gas under pressure, if accidentally released,
           chlorine gas can quickly turn into a potentially lethal gas. EPA
           requires, among other things, that any facility storing at least
           2,500 pounds of chlorine gas prepare a risk management plan that
           lays out accident prevention and emergency response activities. At
           certain concentrations, the residual chlorine that remains in
           wastewater effluent is toxic to aquatic life, so wastewater
           facilities that use chlorine compounds may also need to
           dechlorinate the treatment stream before discharging it to
           receiving waters.^7 Chlorine can also oxidize certain types of
           organic matter in wastewater, creating hazardous chemical
           byproducts, such as trihalomethanes. Our March 2006 report found
           that many large wastewater facilities have discontinued, or are
           planning to discontinue using chlorine gas as a disinfectant in
           favor of alternative disinfection methods such as sodium
           hypochlorite delivered in bulk to the facility. Of the 206 large
           wastewater facilities responding to our survey, only 85 facilities
           indicated they currently use chlorine gas, and 20 of these
           facilities plan to switch from the gas to another disinfectant.

           o Sodium hypochlorite. Injecting sodium hypochlorite--essentially
           a concentrated form of household bleach--into a waste stream is
           another chlorination method of disinfecting wastewater. Sodium
           hypochlorite is safer than chlorine gas because, if spilled, it
           remains liquid and can be contained and recovered. For this
           reason, it is not subject to EPA's risk management planning
           requirements. However, sodium hypochlorite is more expensive than
           chlorine gas, and it degrades quickly if it is exposed to sunlight
           or is not kept at proper temperatures. For this reason, properly
           storing delivered sodium hypochlorite in the concentration
           necessary to disinfect wastewater may require an on-site building
           with environmental controls. Sodium hypochlorite can also be
           generated on-site at a wastewater facility using an
           "electrochlorination system" that produces sodium hypochlorite
           through an electrical reaction with high-purity salt and softened
           water. Facilities choosing this method of disinfection reduce
           chemical costs, but face increased electrical costs from the
           generation equipment. Because it is a chlorine compound,
           wastewater facilities using sodium hypochlorite must also be
           concerned with residual chlorine and hazardous chemical
           byproducts, such as trihalomethanes.

           o Ultraviolet light. This disinfection method uses ultraviolet
           lamps to break down disease-causing microorganisms in wastewater.
           Wastewater passes through an open channel with lamps submerged
           below the water level. The lamps transfer electromagnetic energy
           to an organism's genetic material destroying the ability of its
           cells to reproduce. Because ultraviolet light is a physical
           process rather than a chemical disinfectant, it eliminates the
           need to generate, handle, transport, or store hazardous and
           corrosive chemicals. In addition, there are no harmful residual
           effects to humans or aquatic life. However, ultraviolet light
           disinfection may not be effective given the turbidity of some
           wastewater streams. Wastewater facilities using ultraviolet
           instead of chlorine gas or delivered sodium hypochlorite for
           disinfection will face additional costs to maintain lamps and
           increased electrical costs.

           o Ozone. This disinfection method feeds ozone generated on-site
           from oxygen exposed to a high-voltage current into a contact
           chamber containing wastewater. According to EPA, ozone is very
           effective at destroying viruses and bacteria, but it is the least
           used disinfection method in the United States largely because of
           its high capital and maintenance costs compared to available
           alternatives.

^7Sulfur dioxide, often used for dechlorination by wastewater facilities,
is also covered by risk management plan rules when used or stored in
threshold amounts.

According to EPA, vulnerability assessments help water systems evaluate
susceptibility to potential threats such as vandalism or terrorism and
identify corrective actions that can reduce or mitigate the risk of
serious consequences. The Public Health Security and Bioterrorism
Preparedness and Response Act of 2002 (the Bioterrorism Act)^8 required
drinking water utilities serving populations greater than 3,300 to
complete vulnerability assessments by June 2004.^9 Wastewater facilities
are not required by law to complete vulnerability assessments. Congress
has considered bills that would have encouraged or required wastewater
treatment plants to assess vulnerabilities, but no such requirement has
become law.

In our March 2006 report on wastewater facility security efforts, we found
that many large wastewater facilities have either completed a
vulnerability assessment or had one underway. Of the 206 large wastewater
facilities that responded to our survey, 106 facilities--or 51
percent--reported that they had completed a vulnerability assessment or
were currently conducting one. Several other facilities indicated they had
conducted or planned to conduct other types of security assessments.
Facilities cited several reasons for completing a vulnerability assessment
or some other type of security assessment, but most--roughly 77
percent--reported doing so on their own initiative. Many facilities
indicated they were combined systems--facilities that manage both drinking
water and wastewater treatment. As such, 37 percent of facilities reported
that they did some type of security assessment in conjunction with the
required assessment for their drinking water facility.

The Clean Air Act requires wastewater facilities that use or store more
than 2,500 pounds of chlorine gas to submit to EPA a risk management plan
that lays out accident prevention and emergency response activities. Under
this act, EPA requires that about 15,000 facilities--including chemical,
water, energy, and other sector facilities--that produce, use, or store
more than threshold amounts of chemicals posing the greatest risk to human
health and the environment take a number of steps to prevent and prepare
for an accidental chemical release. EPA regulations implementing the Clean
Air Act require that the owners and operators of chemical facilities
include a facility hazard assessment, an accident prevention program, and
an emergency response program as part of their risk management plans. The
regulations required that a summary of each facility's risk management
plan be submitted to EPA by June 21, 1999. The plans are to be revised and
resubmitted to EPA at least every 5 years, and EPA is to review them and
require revisions, if necessary.

^8Pub. L. No. 107-188 (2002).

^9The Bioterrorism Act required the assessments to include, but not be
limited to, a review of six components: (1) pipes and constructed
conveyances; (2) physical barriers; (3) water collection, pretreatment,
treatment, storage, and distribution facilities; (4) electronic, computer,
or other automated systems that are utilized by the water system; (5) the
use, storage, or handling of various chemicals; and (6) the operation and
maintenance of such systems. The act further required systems to prepare
or revise an emergency response plan incorporating the results of the
vulnerability assessment within 6 months after completing the assessment.

Costs of Preparing Vulnerability Assessments and Risk Management Plans among
Large Wastewater Facilities Vary Widely

Although accurate information on the costs of vulnerability assessments
and risk management plans is limited, available estimates suggest that
their costs vary considerably. A factor contributing to the cost
differential was whether they were contracted to third parties (such as
engineering consulting firms) or prepared in-house with existing staff.
Despite higher costs, some facilities preferred using contractors because
their expertise and independence lent credibility to their assessments,
which may be useful in obtaining support for security-related upgrades.
Costs generally did not relate to facility size, as measured by million of
gallons of wastewater treated per day.^10

Vulnerability Assessment Costs Depend Primarily on Whether a Contractor Is Used

The reported cost of preparing vulnerability assessments at the 20 large
wastewater facilities where we interviewed officials ranged from $1,000 to
$175,000. Whether the assessment was done in-house with existing staff or
contracted to a third party was a factor contributing to the cost
differences. Officials from several facilities told us they used
contractors to complete vulnerability assessments in 2002. For example,
staff at the Denver Metro Wastewater Reclamation District reported that a
contractor completed a vulnerability assessment in November 2002 for its
Central Treatment Plant, which treats 130 million gallons of wastewater
per day, at an estimated cost of $175,000. Of this cost, $100,000 was for
the contractor, and $75,000 was estimated for in-house staff time.

^10In our structured interviews we asked facility managers to provide
estimates of their treatment facility's "existing flow" in millions of
gallons per day. "Existing flow" refers to the calculated average flow for
a recent 12-month period, as defined by EPA in its Clean Water Needs
Survey, and is a common measure of treatment facility size. When we note
how many gallons per day a facility treats, we are referring to its
reported "existing flow."

Other large wastewater facilities that reported completing vulnerability
assessments in 2002 were part of combined systems that provide both
drinking water and wastewater services. These systemwide vulnerability
assessments were done before the 2002 Bioterrorism Act required drinking
water utilities serving populations greater than 3,300 to complete
vulnerability assessments by June 2004. The combined systems that
conducted systemwide vulnerability assessments include the following:

           o San Antonio Water System (San Antonio, Texas). According to
           system staff, a contractor completed a systemwide vulnerability
           assessment for all its drinking water, wastewater, and related
           infrastructure in August 2002 for $112,000. Staff did not provide
           an estimate of in-house costs related to the assessment, but
           prorated the wastewater treatment plants costs related to this
           contract at $37,000: $25,000 for its Dos Rios plant, which treats
           70 million gallons per day; $5,000 each for its Leon Creek and
           Salado Creek plants, which treat 33 million gallons per day; and
           $2,000 for its Medio Creek plant, which treats 5 million gallons
           per day.

           o The Phoenix Water Services Department (Phoenix, Arizona).
           According to department staff, a contractor completed a systemwide
           vulnerability assessment for its five drinking water plants, three
           wastewater plants, and related infrastructure in November 2002 for
           $479,725. Staff did not provide an estimate of in-house cost
           related to the assessment, but estimated the contract costs
           related to its largest wastewater treatment plant, the 91st Avenue
           Sewage Treatment Plant, which treats 140 million gallons per day,
           to be $100,000.

           o Fort Worth Water Department (Fort Worth, Texas). According to
           department staff, a contractor completed a systemwide
           vulnerability assessment for its four drinking water plants and
           one wastewater treatment plant in December 2002 at a cost of
           $292,300. Staff did not provide an estimate of in-house cost
           related to the assessment, but estimated the contract costs
           related to its Village Creek Wastewater Treatment Plant, which
           treats 96 million gallons per day, at $73,075.

Wastewater facility managers cited several reasons for using contractors
to complete vulnerability assessments. Staff with the Phoenix Water
Services Department told us they used contractors for their vulnerability
assessment because a citywide policy required that contract services be
used whenever possible. Staff at other wastewater facilities told us that,
despite the higher costs, they preferred to use contractors because of
their expertise. According to a wastewater security official, contractor
expertise and independence can give contractor findings and
recommendations greater credibility with utility governing boards that
determine spending priorities.

One manager told us that he used a contractor for a 2002 vulnerability
assessment because risk management software and tools were not yet
available. After the events of September 11, 2001, EPA provided funding to
the Association of Metropolitan Sewerage Agencies^11 to develop software,
called the Vulnerability Self Assessment Tool (VSAT), for water utilities
to use to develop vulnerability assessments. According to a Water
Environment Federation (WEF) official, VSAT became available in June 2002.
This official also said that EPA provided funding to WEF to provide
training workshops to wastewater utilities on how to use VSAT to conduct
vulnerability assessments beginning October 2002.^12

According to interviews with wastewater facility managers, large
wastewater facilities that prepared vulnerability assessments in-house
with existing staff reported lower costs for preparing the document. These
include the following:

           o City of Ventura Public Works Department (Ventura, California).
           According to facility staff, in-house staff completed a
           vulnerability assessment in March 2003 for the Ventura Water
           Reclamation Facility, which treats 9 million gallons per day, at a
           cost of roughly $1,000 in staff time. Facility staff participated
           in VSAT training sponsored by EPA and completed the assessment
           using this tool.

           o City of Fort Wayne Utilities Division (Fort Wayne, Indiana).
           According to facility staff, in-house staff completed a
           vulnerability assessment in November 2005 for the Fort Wayne Water
           Pollution Control Plant, which treats 43 million gallons per day,
           at undetermined staff time. Facility staff participated in VSAT
           training and updated a previous risk assessment prepared for the
           facility by a contractor in 2000 at a contracted cost of $10,000.

           o City of Eugene Wastewater Division (Eugene, Oregon). According
           to facility staff, in-house staff completed a vulnerability
           assessment in October 2005 for the Eugene/Springfield Regional
           Water Pollution Control Facility, which treats 38 million gallons
           per day, for about $2,000 in staff time.

           o City of Cedar Rapids Department of Water Pollution Control
           (Cedar Rapids, Iowa). According to facility staff, in-house staff
           completed a vulnerability assessment in January 2007 for the Cedar
           Rapids Wastewater Treatment Plant, which treats 35 million gallons
           per day, for about $5,000 in staff time.

           o Detroit Water and Sewerage Department (Detroit, Michigan).
           According to department staff, in-house staff completed a
           vulnerability assessment in January 2005 for the Detroit
           Wastewater Treatment Plant, which treats 700 million gallons per
           day, for about $20,000 in staff time.

^11Now the National Association of Clean Water Agencies (NACWA).

^12Prior to September 11, 2001, EPA worked to develop and disseminate risk
assessment methodologies for water utilities. In 2000, EPA funded an
initiative with the American Water Works Association Research Foundation
(AWWARF) and the Sandia National Laboratories to apply risk assessment
methodologies developed by the laboratories to water utilities. The
methodology, called the Risk Assessment Methodology for Water Utilities
(RAM-W), was designed to assist large water utilities and security
professionals in assessing the risks from malevolent threats. Through an
interagency agreement with EPA, Sandia National Laboratories provided
training to selected firms in the RAM-W methodology so that these firms
could then provide training and technical assistance to water utilities.

Risk Management Plan Costs Also Influenced by Use of Contractors

Costs to prepare risk management plans ranged from less than $1,000 for
facilities that completed the plan in-house to over $31,000 for facilities
that used contractors. Costs to update risk management plans were
generally less, ranging from less than $1,000 to $20,000 depending upon
whether facilities used in-house staff or contractors.

Costs were generally higher at facilities that used contractors. These
include the following:

           o The Phoenix Water Services Department (Phoenix, Arizona).
           According to department staff, a contractor completed risk
           management plans for all the system's drinking and wastewater
           facilities in 1999 for $230,086. Costs for the 91st Avenue Sewage
           Treatment Plant were prorated at $28,761. Department staff said a
           contractor updated the 91st Avenue plant's risk management plan in
           2004 for $20,000.

           o Fort Worth Water Department (Fort Worth, Texas). According to
           department staff, a contractor completed risk management plans for
           all of the department's drinking water and wastewater facilities
           in 1999 for $124,718. Costs related to the Village Creek
           Wastewater Treatment Plant's risk management plan were prorated at
           $31,100. Department staff reported that the contractor later
           updated these risk management plans for $18,040 in 2004, $4,510 of
           which was for the Village Creek plant.

           o City of Fort Wayne Utilities Division (Fort Wayne, Indiana).
           According to facility staff, a contractor completed a risk
           management plan in 2001 for the Fort Wayne Water Pollution Control
           Plant for $16,000. Facility staff reported a contractor updated
           the plan in 2005 for $6,000.

           o South Central Regional Wastewater Treatment and Disposal Board
           (Delray Beach, Florida). According to facility staff, a contractor
           completed a risk management plan in 1999 for the South Central
           Regional Wastewater Treatment and Disposal Plant, which treats 18
           million gallons per day, for $10,000. Facility staff reported a
           contractor updated it in 2006 for $2,000.

           o City of Portland Bureau of Environmental Services (Portland,
           Oregon). According to bureau staff, a contractor completed a risk
           management plan in 1999 for its Columbia Boulevard Wastewater
           Treatment Plant, which treats 143 million gallons per day, for
           $30,000. Bureau staff reported they updated the plan using
           in-house staff in 2004 for $10,000 in staff time.

Other large wastewater facilities that prepared risk management plans
in-house with existing staff reported lower costs for preparing the
documents. These include the following:

           o San Antonio Water System (San Antonio, Texas). According to
           system staff, in-house staff completed a risk management plan in
           1999 for the Dos Rios Wastewater Treatment Plant for between
           $5,000 and $10,000 in staff time. In-house staff updated the plan
           in 2004 for less than $1,000 in staff time.

           o City of Cedar Rapids Department of Water Pollution Control
           (Cedar Rapids, Iowa). According to facility staff, in-house staff
           completed a risk management plan in January 2000 for the Cedar
           Rapids Wastewater Treatment Plant for $5,000 in staff time.
           In-house staff updated the plan in 2004 for about $250 in staff
           time.

           o Denver Metro Wastewater Reclamation District (Denver, Colorado).
           According to district staff, in-house staff completed a risk
           management plan in 1999 for $10,000 in staff time. In-house staff
           updated the plan in 2006 for about $1,000 in staff time.

           o City of Savannah Water and Sewer Bureau (Savannah, Georgia).
           According to facility staff, in-house staff completed a risk
           management plan in 1999 for the President Street Water Pollution
           Control Plant, which treats 17 million gallons per day, at a cost
           of only $150 in staff time. In-house staff updated the plan in
           2006 for about $130 in staff time.

Costs of Converting to Alternative Disinfection Methods at Large Wastewater
Facilities Depend on the Method Used and Other Factors

Large wastewater facilities that convert from chlorine gas disinfection to
alternative disinfection processes incur widely varying capital costs,
which generally depend on the alternative treatment chosen and facility
size. Other factors that affect capital costs include the characteristics
of individual facilities, such as whether existing structures can be used,
and local factors, such as building costs. Alternative disinfection
processes may also pose higher annual operating costs than chlorine gas.
However, these costs may be offset, at least somewhat, by savings in
training and labor costs, and regulatory burdens associated with the
handling of chlorine gas. Some facilities even reported or projected net
annual cost savings related to wastewater disinfection.

Disinfection Method Chosen, Facility Size and Characteristics, and Other Factors
Determine Capital Conversion Costs

The 23 large wastewater facilities that we interviewed reported capital
costs for chlorine conversion ranging from $646,922 to just over $13
million. Table 1 identifies the 23 large wastewater facilities that
recently converted or plan to convert from chlorine gas to another
disinfection method and their reported and planned capital conversion
cost.

Table 1: Reported and Planned Disinfection Conversion Costs for Large
Wastewater Treatment Facilities

                                              Facility                            
                                              size (in                            
                                              millions                            
                                                    of                   Reported 
                                               gallons                 or planned 
                                               treated                 conversion 
                     Facility      Conversion      per  Disinfection   cost^b (in 
Facility name        location      year         day)^a  method           dollars) 
Facilities that have completed conversion from chlorine gas
Chambers Creek       University    2002                 Ultraviolet               
                     Place, Wash.                   19  light          $3,900,608 
Blue Plains          Washington,   2003                 Sodium                    
                     D.C.                          307  hypochlorite   12,980,726 
Northeast            Philadelphia, 2003                 Sodium                    
                     Pa.                           190  hypochlorite    2,600,000 
Back River           Baltimore,    2004                 Sodium                    
                     Md.                           150  hypochlorite    3,300,000 
Essex and Union      Elizabeth,    2004                 Sodium                    
                     N.J.                           65  hypochlorite      775,000 
Chesapeake-Elizabeth Virginia      2004                 Sodium                    
                     Beach, Va.                     21  hypochlorite    1,225,000 
Nansemond            Suffolk, Va.  2004                 Sodium                    
                                                    17  hypochlorite    1,650,740 
Columbia Boulevard   Portland,     2005                 Sodium                    
                     Ore.                          143  hypochlorite    4,660,490 
Valley Creek         Bessemer,     2005                 Ultraviolet               
                     Ala.                           46  light           3,561,272 
Dry Creek            Fort Wright,  2005                 Sodium                    
                     Ky.                            36  hypochlorite      646,922 
Southern Regional    Boynton       2005                 Sodium                    
                     Beach, Fla.                    22  hypochlorite^c  2,592,800 
Burbank              Burbank,      2005                 Sodium                    
                     Calif.                          9  hypochlorite    2,500,000 
Southeast            Philadelphia, 2006                 Sodium                    
                     Pa.                            90  hypochlorite    1,920,000 
Papillon             Omaha, Neb.   2006                 Sodium                    
                                                    62  hypochlorite    3,000,000 
Facilities that plan to convert from chlorine gas
Metro Central        Denver, Colo. 2007                 Sodium                    
                                                   130  hypochlorite   13,135,000 
Fort Wayne           Fort Wayne,   2007                 Sodium                    
                     Ind.                           43  hypochlorite    1,791,417 
Everett              Everett,      2007                 Sodium                    
                     Wash.                          18  hypochlorite    2,562,460 
South Central        Delray Beach, 2007                 Sodium                    
                     Fla.                           18  hypochlorite^c  2,454,700 
Mill Creek           Cincinnati,   2008                 Sodium                    
                     Ohio                          120  hypochlorite    3,085,000 
Western Branch       Laurel, Md.   2008                 Ultraviolet               
                                                    20  light           4,000,000 
South Treatment      Renton, Wash. 2009                 Sodium                    
Plant                                               75  hypochlorite    2,575,000 
Hartford             Hartford,     2009                 Ultraviolet               
                     Conn.                          51  light          10,892,000 
Eugene-Springfield   Eugene, Ore.  2009                 Sodium                    
                                                    38  hypochlorite    4,498,000 

Source: GAO.

aPlant size figures are figures for existing flow (a measure of average
daily flow) reported by wastewater facilities in our survey.

bConversion costs were not adjusted for inflation. Figures do not reflect
changes in annual costs, but are reported costs for construction, labor,
and materials related to the disinfection conversion. Reported conversion
costs include actual costs and estimates from facility managers. As such,
these cost figures do not represent the present value of the life-cycle
cost of conversion. Conversion costs include reported temporary and
permanent conversion costs.

cThese facilities will generate sodium hypochlorite on-site. All other
facilities listed as converted or planning to convert to sodium
hypochlorite are having the chemical delivered in bulk to the facility.

As shown in the table, 17 of the 23 facilities converted or plan to
convert to sodium hypochlorite delivered in bulk to the facility.
Officials with several of these facilities told us they considered
ultraviolet disinfection, but chose delivered sodium hypochlorite because
of its lower capital conversion costs. The remainder converted or plan to
convert to sodium hypochlorite generated on-site or ultraviolet light.
None of the facilities we contacted adopted ozone.

Interview responses indicate that several factors affect the cost of
conversion; among these are disinfection method chosen, facility size, key
facility characteristics such as available buildings, and whether the
conversion was permanent or temporary, as follows.

  Disinfection Method

Generally, conversion to delivered sodium hypochlorite has the lowest
capital costs, followed by sodium hypochlorite generated on-site, and
followed again by ultraviolet light.^13 This observation is supported by
cost estimates in the Chlorine Gas Decision Tool, a software program
released by DHS in March 2006. The decision tool was designed to provide
water and wastewater utilities with the means to conduct assessments of
alternatives to chlorine gas disinfection. DHS cautions that the final
costs of the disinfection systems will depend on project design details,
actual labor and material costs, competitive market conditions, actual
site conditions, final project scope, implementation schedule, continuity
of personnel and engineering, and other variable factors.^14 With these
caveats, the decision tool estimates that for a wastewater facility with
an average disinfection flow of 10 million gallons per day and a peak
disinfection flow of 20 million gallons per day, capital costs for
conversion to delivered sodium hypochlorite would amount to $533,000,
on-site generation of sodium hypochlorite would total $1,238,000, and
ultraviolet disinfection would reach $1,526,000.^15

13Conversion to disinfection methods such as ozone and ultrafiltration can
have higher capital costs than ultraviolet light.

^14The decision tool provides cost estimates for disinfection conversion
alternatives where there is limited site-specific engineering data. DHS
notes that cost estimates were based on cost curves that were developed
from a combination of the actual construction costs of different-sized
disinfection systems and cost estimates based on conceptual designs.

^15DHS notes that it is normally expected that an estimate of this type
would be accurate within +50 percent to -30 percent.

Our interviews with wastewater facilities provide specific examples of
conversion costs. For example, managers of the Chesapeake-Elizabeth
Treatment Plant, which treats 21 million gallons per day and serves
customers in Virginia Beach, Virginia, reported spending an estimated
$1,225,000 in 2004 converting to bulk sodium hypochlorite disinfection.
Managers of the comparably sized Western Branch Wastewater Treatment
Plant, which treats 20 million gallons per day and serves customers in
Laurel, Maryland, estimated that they will spend $4 million converting to
ultraviolet light disinfection by January 1, 2008. Managers of the Western
Branch plant indicated that one reason they chose the more expensive
ultraviolet treatment option over bulk deliveries of sodium hypochlorite
was to avoid the risk to local traffic that could result from additional
deliveries to the plant. Plant managers indicated that because sodium
hypochlorite degrades more quickly than chlorine gas, truck deliveries
would increase under a disinfection system using sodium hypochlorite. They
also noted that ultraviolet light disinfection would eliminate the need
for the facility to handle and store significant amounts of hazardous and
corrosive chemicals.

  Facility Size

In addition to disinfection method chosen, facility size can also
influence capital conversion costs. In general, larger facilities spend
more converting to alternative disinfection methods. For example, because
larger facilities process a greater flow of wastewater, converting to
delivered sodium hypochlorite would require a larger sodium hypochlorite
storage building or buildings relative to a smaller facility. It may also
require additional pumps, instrumentation, and piping to deliver treatment
chemicals to a greater number of contact tanks. Importantly, the largest
facilities also tend to serve high-cost urban areas, and their conversion
costs reflect the higher costs for construction materials and contract
labor in these markets.

For example, the Blue Plains Wastewater Treatment Plant, which treats 307
million gallons per day and serves over 2 million customers in the
Washington, D.C., metropolitan area, converted from chlorine gas to
delivered sodium hypochlorite in 2003 at a cost of almost $13 million.
According to facility managers, the facility temporarily converted from
chlorine gas to delivered sodium hypochlorite in April 2002 at a cost of
$500,000, primarily for storage tanks, pumps, piping, and related
instrumentation. It completed the permanent conversion in October 2003 at
an added cost of about $12.5 million, which included the purchase of
additional storage tanks, related pumps, piping and instrumentation, and
the construction of storage facilities for sodium hypochlorite and sodium
bisulfate (used for dechlorination).

  Other Key Facility Characteristics

In addition to facility size, other physical characteristics related to
individual facilities also play a large role in conversion costs. For
instance, the availability of usable buildings on facility grounds will
determine whether a facility needs to construct, expand, or update a
building to properly house sodium hypochlorite and its associated metering
equipment. In addition, the distance between the storage building and
treatment tanks will determine the amount of piping needed to deliver
stored sodium hypochlorite to the treatment tanks. An example comes from
the Hampton Roads Sanitation District which provides wastewater treatment
to approximately 1.6 million people in 17 cities and counties in southeast
Virginia, including the cities of Newport News, Norfolk, Suffolk, Virginia
Beach, and Williamsburg. In 2004, the sanitation district converted from
chlorine gas to bulk sodium hypochlorite disinfection at two of its
plants--the Nansemond Treatment Plant, which treats 17 million gallons per
day for the city of Suffolk, and the previously mentioned
Chesapeake-Elizabeth plant, which treats 21 million gallons per day. The
Nansemond plant conversion cost an estimated $1.65 million, while the
slightly larger Chesapeake-Elizabeth plant conversion cost about $1.2
million. Costs were higher at the Nansemond plant because a building
needed to be constructed for sodium hypochlorite storage, while the
Chesapeake-Elizabeth plant had an existing building that only needed to be
upgraded to properly store the chemical.

Federal discharge permit requirements related to individual treatment
facilities can also influence conversion costs. Certain wastewater
facilities may be allowed higher chlorine residuals in treated effluent
because they discharge into less sensitive waters. Often, these facilities
do not have to dechlorinate wastewater, saving the facility the cost of
dechlorination chemicals, equipment, and storage. For example, the
Philadelphia-area Southeast and Northeast Wastewater Treatment Plants,
which treat 90 and 190 million gallons per day, respectively, need only to
chlorinate water prior to discharging into the Delaware River. Both plants
were converted to delivered sodium hypochlorite--the Southeast plant in
2006 at an estimated cost of $1.9 million and the Northeast plant in 2003
at an estimated cost of $2.6 million. In contrast, the Baltimore-area Back
River Wastewater Treatment Plant, which treats 150 million gallons per day
and discharges into the ecologically sensitive Chesapeake Bay, must
chlorinate and dechlorinate its wastewater before discharge. This facility
converted to delivered sodium hypochlorite in 2004 at a reported cost of
$3.3 million.

  Temporary Conversions

Finally, some facilities have reduced conversion costs in the short term
through temporary conversions. For example, the Metropolitan Sewer
District of Greater Cincinnati decided to convert its Mill Creek
Wastewater Treatment Plant, which treats 120 million gallons per day, from
chlorine gas to sodium hypochlorite disinfection soon after September 11,
2001. According to the plant manager, by mid-October 2001, the facility
had begun disinfecting with sodium hypochlorite by hooking up a rented
sodium hypochlorite trailer to its disinfection system at a cost of
$25,000. By May 2002, the facility had completed an interim conversion to
sodium hypochlorite by purchasing and installing two 8,000 gallon outdoor
storage tanks for sodium hypochlorite at a cost of $60,000. According to
the plant manager, this interim disinfection system is still in use today,
though the plant intends to permanently convert to delivered sodium
hypochlorite in 2008 or 2009 at an estimated cost of $3 million. The plant
manager said the permanent conversion would include an unloading station
for sodium hypochlorite deliveries and a new storage building for the
chemical and related instrumentation. The plant manager said the new
storage building was needed to reduce the decay of stored sodium
hypochlorite. The plant manager added that the storage building and
additional piping would improve plant safety because it would allow for
central storage and delivery of sodium hypochlorite. Currently, sodium
hypochlorite deliveries are made at several plant locations for odor
control which, according to the plant manager, increase the odds the
chemical may be mishandled and accidentally mixed with other reactant
chemicals used at the plant, such as ammonia.

Similarly, the Eastern Water Reclamation Facility, which treats 16 million
gallons per day and provides service to Orange County, Florida, converted
from chlorine gas to sodium hypochlorite disinfection at a cost of $60,000
in November 2001 through the addition of outdoor storage tanks and related
pumps. According to the plant manager, the facility may consider
additional changes in the future, such as permanent sodium hypochlorite
storage or on-site generation.

Changes in Annual Costs Vary Widely, with Some Facilities Reporting Savings

Changes in annual costs related to disinfection treatment conversions were
hard to measure due to lack of data. Many facilities we interviewed were
unable to provide complete information on annual costs related to
disinfection before and after converting from chlorine gas. Available data
show that annual chemical costs related to disinfection increased for
facilities that converted to delivered sodium hypochlorite, because sodium
hypochlorite costs more than chlorine gas.^16 Available data also show
that electrical costs related to disinfection increased for facilities
that converted to on-site generation of sodium hypochlorite or ultraviolet
light treatment, however these facilities also saw large reductions in
chemical costs. Available data also show that increases in annual costs
related to disinfection were offset somewhat by savings in training and
regulatory requirements, as several facilities that converted reported a
reduced need for staff time devoted to complying with the EPA risk
management planning that was required when the plant used chlorine gas.

A few facilities were even able to report or project annual savings due to
the disinfection conversion. For example, the wastewater treatment manager
of the Columbia Boulevard Treatment Plant, which treats 143 million
gallons per day and provides wastewater service to Portland, Oregon,
estimated that annual costs related to disinfection fell by over $100,000
after the plant completed a 2005 conversion from chlorine gas to delivered
sodium hypochlorite disinfection.^17 According to the wastewater treatment
manager, increases in disinfection chemical costs for the plant were more
than offset by reductions in electrical, labor, and training costs.
Electrical power costs fell because the plant no longer had to power
chlorine gas evaporators, which heat and help convert the pressurized
liquid into gas before it is injected into the waste stream. In contrast,
sodium hypochlorite is fed into the waste stream via less energy-intensive
pumps. Labor and training costs also fell because the plant no longer had
to meet the Occupational Safety and Health Administration's (OSHA) Process
Safety Management of Highly Hazardous Chemicals standard,^18 and risk
management and emergency response planning costs associated with the use
of chlorine gas were eliminated.

^16In addition, sodium bisulfate, the dechlorination chemical often used
with sodium hypochlorite, costs more than sulfur dioxide, the
dechlorination chemical often used with chlorine gas.

^17According to the wastewater treatment manager, annual costs related to
disinfection fell from $411,531 for the operating year covering July 1,
2004, to June 30, 2005, to $302,998 for the operating year covering July
1, 2005, to June 30, 2006. The wastewater treatment manager reported the
plant's annual operations and maintenance budget at $12.4 million for the
most recently completed operating year.

^18OSHA's Process Safety Management of Highly Hazardous Chemicals standard
(29 CFR 1910.119) contains requirements for the management of hazards
associated with processes using highly hazardous chemicals.

In another example, the South Central Regional Wastewater Treatment and
Disposal Plant, which treats 18 million gallons per day for customers in
the cities of Delray Beach and Boynton Beach, Florida, predicts that it
too will achieve annual savings once it converts from chlorine gas to
sodium hypochlorite generated on-site, which it anticipates completing in
September 2007. According to the Executive Director of the South Central
Regional Wastewater Treatment and Disposal Board, potential disruptions of
sodium hypochlorite delivery during hurricane seasons motivated them to
begin generating their disinfection chemicals on-site. The plant's most
recent fiscal year operating and maintenance budget for disinfection is
estimated to be roughly $307,000 for chlorine gas and associated costs
including equipment and maintenance, labor, and risk management planning.
Postconversion annual operating and maintenance costs for disinfection are
estimated to fall to $205,000 in the 2008 calendar year, primarily due to
the suspension of chlorine gas purchases.

Agency Comments and Our Evaluation

We provided a draft of this report to EPA for review and comment. In its
letter, reproduced in appendix II, EPA concurred with the results of the
report. EPA's Water Security Division in the Office of Ground Water and
Drinking Water provided technical comments and clarifications that were
incorporated, as appropriate.

As agreed with your office, unless you publicly release the contents of
this report earlier, we plan no further distribution until 30 days from
the report date. At that time, we will send copies of this report to the
appropriate congressional committees; interested Members of Congress; the
Administrator, EPA; and other interested parties. We will also make copies
available to others on request. In addition, the report will be available
at no charge on the GAO Web site at http://www.gao.gov .

Should you or your staff need further information, please contact me at
(202) 512-3841 or [email protected] . Contact points for our Offices
of Congressional Relations and Public Affairs may be found on the last
page of this report. GAO staff who made major contributions to this report
are listed in appendix III.

Sincerely yours,

John B. Stephenson
Director, Natural Resources and Environment

Appendix I: Scope and Methodology

To identify the costs of preparing vulnerability assessments and risk
management plans, we conducted structured telephone interviews with a
select sample of large wastewater facilities identified as having
completed these documents in our March 2006 report.^1 Our March report
identified 106 large facilities that reported they had prepared
vulnerability assessments or had one underway, and 85 facilities that were
required to prepare risk management plans because they currently used
chlorine gas as a disinfectant. From these two groups, we identified 47
facilities that reported that they had prepared vulnerability assessments
and currently use chlorine. Of this universe, we chose a nonprobability
sample of 25 facilities to assure geographic dispersion and adequate
variation in size, since these factors were likely to influence their
costs.^2 We completed structured interviews with 20 of the remaining 25
facilities. We sent an interview schedule in advance of each of the
interviews. We completed the structured interviews between November 2006
and February 2007. Reported costs included both actual and estimated
costs. For estimated costs, we asked facility managers to explain how they
arrived at these estimates. Reported costs were not adjusted for
inflation.

To identify the costs incurred by wastewater facilities in converting from
gaseous chlorine to an alternative disinfection process, we conducted
structured telephone interviews with a nonprobability sample of 26 of the
38 large facilities identified in the March report as having recently
converted or planning to convert from chlorine gas to an alternative
disinfection process. We sent an interview schedule in advance of each of
the interviews. We completed the structured interviews between October
2006 and February 2007. Reported costs included both actual and estimated
costs. For estimated costs, we asked facility managers to explain how they
arrived at these estimates. Reported costs were not adjusted for
inflation. We also conducted site visits with some of the facilities.
Where available, we gathered documentation, such as capital plans, from
these facilities in order to document conversion costs. We supplemented
the cost information we gathered at individual wastewater facilities with
information obtained at the Environmental Protection Agency, the
Department of Homeland Security, nongovernmental organizations, and
industry representatives. We determined that reported cost data were
sufficiently reliable to provide useful information about the costs for
preparing vulnerability assessments, risk management plans, and
conversions from gaseous chlorine and the factors that affect these costs.

^1GAO, Securing Wastewater Facilities: Utilities Have Made Important
Upgrades but Further Improvements to Key System Components May Be Limited
by Costs and Other Constraints, [25]GAO-06-390 (Washington, D.C.: Mar. 31,
2006). We defined large wastewater facilities as those publicly owned
treatment works (POTW) that serve residential populations of 100,000 or
greater.

^2Results from nonprobability samples cannot be used to make inferences
about a population, because in a nonprobability sample some elements of
the population being studied have no chance or an unknown chance of being
selected as part of the sample.

We conducted our work between August 2006 and March 2007 in accordance
with generally accepted government auditing standards.

Appendix II: Comments from the Environmental Protection Agency

Appendix III: GAO Contact and Staff Acknowledgments

GAO Contact

John B. Stephenson, (202) 512-3841 or [email protected]

Acknowledgments

In addition to the contact named above, Jenny Chanley, Steve Elstein,
Nicole Harris, Greg Marchand, Tim Minelli, Alison O'Neill, Daniel Semick,
and Monica Wolford made key contributions to this report.

(360738)

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www.gao.gov/cgi-bin/getrpt?GAO-07-480 .

To view the full product, including the scope
and methodology, click on the link above.

For more information, contact John Stephenson at (202) 512-3841 or
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Highlights of [34]GAO-07-480 , a report to the Chairman, Committee on
Environment and Public Works, U.S. Senate

March 2007

SECURING WASTEWATER FACILITIES

Costs of Vulnerability Assessments, Risk Management Plans, and Alternative
Disinfection Methods Vary Widely

Wastewater facilities provide the essential service of collecting and
treating wastewater, and discharging treated effluent into receiving
waters. Since September 11, 2001, the nation's water infrastructure has
received greater attention, including the risk of terrorist attacks at
wastewater facilities that store hazardous chlorine gas for disinfection.

In 2006, GAO reported that many large wastewater facilities have responded
to this risk by voluntarily conducting vulnerability assessments and
converting from chlorine gas to other disinfection methods. The Clean Air
Act requires all wastewater facilities that use threshold quantities of
chlorine gas to prepare and implement risk management plans to prevent
accidental releases and reduce the severity of any releases.

In this study, GAO was asked to provide information on (1) the range of
costs large wastewater treatment facilities incurred in preparing
vulnerability assessments and risk management plans, and (2) the costs
large wastewater treatment facilities incurred in converting from chlorine
gas to alternative disinfection processes. To answer these questions, GAO
conducted structured telephone interviews with a number of facilities
surveyed for the 2006 report. The Environmental Protection Agency (EPA)
agreed with the report and provided several technical changes and
clarifications.

Among the large wastewater facilities GAO examined, the costs reported to
prepare vulnerability assessments ranged from $1,000 to $175,000, while
costs to prepare risk management plans ranged from less than $1,000 to
over $31,000. Whether the documents were prepared in-house or contracted
to third parties such as engineering firms was a factor in cost
differences. Despite higher costs, some facilities preferred to use
contractors due to their expertise and independence. According to one
wastewater security official, these attributes can give contractor
findings and recommendations greater credibility with utility governing
boards that determine spending priorities. One facility that used a
contractor to complete a vulnerability assessment in 2002 did so because,
at the time, vulnerability assessment software and training were not
widely available. Since that time, EPA has increased funding for the
development and dissemination of risk assessment software and related
training. Overall, cost estimates for vulnerability assessments and risk
management plans did not relate to facility size, as measured by millions
of gallons of wastewater treated per day.

For the large wastewater facilities GAO examined, reports of actual and
projected capital costs to convert from chlorine gas to alternative
disinfection methods range from about $650,000 to just over $13 million.
Most facilities converted, or planned to convert, to delivered sodium
hypochlorite (essentially a concentrated form of household bleach shipped
in bulk to the facility). Managers of these facilities told GAO they
considered other options, but chose delivered sodium hypochlorite because
its capital conversion costs were lower than those associated with other
alternatives, such as generating sodium hypochlorite on-site or using
ultraviolet light. Overall, the primary factors associated with
facilities' conversion costs included the type of alternative disinfection
method chosen and the size of the facility. Other cost factors facility
managers cited included (1) whether existing buildings and related
infrastructure could be used in the conversion, (2) labor and building
supply costs, which varied considerably among locations, (3) the cost of
sodium hypochlorite relative to chlorine gas, and (4) the extent to which
training, labor, and regulatory compliance costs were reduced for
utilities that no longer had to rely on chlorine gas.

References

Visible links
  22. http://www.gao.gov/cgi-bin/getrpt?GAO-06-390
  25. http://www.gao.gov/cgi-bin/getrpt?GAO-06-390
  34. http://www.gao.gov/cgi-bin/getrpt?GAO-07-480
*** End of document. ***