### United States Government Ac countabilit y Office 

# GAO Report to the Chai rman, Committee on Environment and Public Works, U.S. Senate



# SECURING WASTEWATER FACILITIES
Costs of Vulnerability Assessments, Risk Management Plans, and Alternative Disinfection Methods Vary Widely March 2007

GAO-07-480

### What GAO Found

**United States Government Accountability Office** 

### Why GAO Did This Study 

# H ighlights **Accountability Integrity Reliability March 2007**  

# SECURING WASTEWATER FACILITIES
**Costs of Vulnerability Assessments, Risk Management Plans, and Alternative**  **Disinfection Methods Vary Widely** Highlights of GA O-07 -480 , a repo rt to the Chairman, Com m ittee on Enviro nment and Public Works, U.S. Sena te

Wa ste w a t e r fa c ilitie s prov i d e the

e ssenti a l se rvic e of colle cting a n d treating wa ste w a t e r , and disch a r g ing tr eated efflu e nt into

re cei vi ng w a t e rs. Si n c e S e pt emb e r 11, 2001, th e nation’s water i n fras tru c tur e has r e c e iv ed gr ea te r attentio n, in cl uding the risk of te rrorist attacks at wa stewa t e r fac ilitie s tha t store ha za rdous chlorine gas for disinfection.

In 2 0 0 6 , GA O rep o rt ed th a t man y la rge wa stewa t e r fa c ilitie s hav e resp ond ed to this risk by

v o lunta r ily c o nduc t ing v u lne r a b ility

assess ments and co nv er t i ng f r o m
c h lo r i ne ga s to ot he r d i sinfe c t i o n methods

. Th e Clean Air Act

re qui r es al l w a st ew at er f

a ci l i t i e s th at use thres hold qu an tities of chl o ri n e g a s t o pr ep ar e and imple m ent risk ma na ge me nt pl a n s to pre v en t ac ci de nt al r e l e a ses and red u c e th e s e ve ri ty o f an y r e l e ases

.

In thi s s t ud y, GAO w a s ask e d to prov ide informa t ion on (1 ) the

r a nge of c o st s la rg e wa ste w a t e r treatment fa c i litie s incurre d in prepa r ing v u l n e r a b ility

assess ments and ri s k ma na ge me nt plans, and (2) th e cos t s large

wa stewater tre a tme n t fac ilitie s i n curr ed i n co nv erti n g fro m
c h lorine ga s to a l te rnative disinfection process e s. To answer th ese ques tio n s, GAO cond ucted stru ctured tel e ph on e in ter v

iews with a number of fac ilitie s survey ed for the 20 06 report

. The Env i ronmenta l Prote c t i on Ag ency (EPA) agr e ed with th e repo rt and prov ided se vera l tec hni c a l c h a n g e s and cl ari f i c a ti ons. A mong the l a rge w a stewat er facilit ies GAO examin ed, the costs r e ported to prepare vulnerabil ity ass e ssments r a ng ed from $1 ,0 00 to $ 1 7 5 , 0 0 0 , whil e costs to prepare ri sk man a g e ment pla n s ranged fro m le ss than $ 1 ,0 00 to over $31,000. Wh ether the documents were prepared in-house or contracted to third parties such as eng i neering f i rm s was a fa ctor in cost differ e nce s

. Despite hi gher costs, som e fac i l i ties pr eferred to use contractors due to their expertise an d independence. According to one wa stewater se c u rity official , these attributes c a n g i v e contractor findings and recomm endations greater credibil ity wi th utility gove rning boards that determ ine spending priorities. One faci lity t h at used a co ntractor to complete a vu lnerabil ity as sess ment in 2002 did so because, at the tim e , vulnerability as ses s ment software and training wer e not widely a vai labl e. Since that tim e , EPA has incr eas ed funding for t h e development and dissem ination of risk assessment software and relat e d training. Overall, cost esti mates for vul n erability ass e ssm ents and risk man a gement plans did not rela te to facility siz e , as measured by millions of gallons of wa s t ewater tre a ted per da y.

For the larg e wastew ater facil i tie s GA O examined, reports of ac tual and projected c a p ital costs to convert from chlorine gas to alternat ive disinfection methods range from about $65 0,000 to just over $13 million. Most facilities convert e d, or planne d to convert, to d e li ver ed sodi um hypochlorite (ess ential ly a concentrate d form of ho usehold bleach shipped in bulk to the faci lity). M a nagers of these fa ci litie s t o ld GAO they considered o t her options, but chose de livered sodiu m hypochlorite because its c a pital co nversion cos t s were lowe r than those assoc i ated w i th other alternati v e s , such as g e ne rating s odiu m hypochlorite on-site or using ultraviol et li g h t. Overall, t h e primar y fa ctors as soci a t ed with faci l i ties’ conversion costs included the type of alternative disinfection met hod chosen and the siz e of the facil i ty. Other cost factors facilit y man a gers cited included (1) whether existing buildings and related infrastr ucture could be used in the conversion, (2) labor a nd building supply costs, which varied considerabl y among locat ions, (3) the cost of sodium hypochl orite re la ti ve to chlorine gas , and (4) the e x tent to which training, labor, and regu latory complian ce costs were r e duced for utilit ies that no longer had to rel y on chlorine gas

.

www.gao.g o v/ cgi

- bin/getrpt? GA O-07-480

.
To view t he full product, including the scope and methodolog y, click on the link above. For mo re i n forma t i on, conta c t Joh n Stephenso n at (2 02) 512 -3841 o r stephen sonj@ga o .gov.

# Contents

Letter 1

Results in Brief 4 Background 5 Costs of Pre p aring Vulnerability Assessment s and Risk Management Plans among Large Wastewater Facilities Vary Widely 8 Costs of Co nverting to Alternative Disinfection Methods at Large Wastewater Facilities Depend on the Method Used and Other F a c t o r s 1 3 Agency Comments and Our Evaluatio n 20



### Appendi x I Scope and Met h odology 22



### Appendix II Comments from the Environmental Protection Agency 24



### Appendix III GAO Contact and Staff Acknowledgments 25



### Table

Table 1: Rep o rted and Pl anned Disinfection Conversion Costs for Large Wastewater Treatment Faciliti e s 14

Abbreviations

AWWARF American Water Works Association Research Fo undation DHS Department of Homeland Security EPA Environmental Protectio n Agency NACWA National Association of Clean Water Agencies OSHA Occupational Safety and Health Administration POTW publicly ow ned treatment works RAM-W Risk Asse ssment Methodology for Water Utilities VSAT Vulnerabilit y Self Assessment Tool WEF Water Environment Federation

Page i GA O

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- 4 8 0 Wa st ew ater Fa cility Se curit yT his is a work of the U.S. government a nd is not subject to copyrig h t prote c tion in the United States. It may be repro duce d and dist r ibute d in its en tirety without fu rther permissi on fro m G A O

. Howe ver, becaus e this work may c ontai n copyri gh ted imag es or other materi al, permissi on fro m the copyrig h t holder may b e necess a ry if you wish to reprod uce this material se par ately.

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- 4 8 0 Wa st ewater Fa cility Se curit yUnit ed Stat e s Governm e nt Acco unta b ility O f fi ce Wash ingto n , DC 205 48

March 30, 2 0 07

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

Dear Madam Chairman:

Wastewater facilities in t h e United St ates provide essential services to residential, commercial, and industrial users by collecting an d treating wastewater and dischar g ing treat ed effluent into receivin g waters. The Centers for Disease Control and Pr e vention cit e d sewage disposal and water treatment as imp o rtant contributors to the control of infectious diseases, which it consid ers 1 of th e 10 greatest achievements in public health of th e 20th century. Wastewat er disinfecti on, a key co mponent of the wastewater treatment process, re duces the risk that diseas e will be transmitted through wastewater efflue nts. Historically, chlori nation has been the most commonly used method of wastewater disinfection because it destroys a variety of p a thogens and microorganisms.

Since the ev ents of Sept ember 11, 2 0 01, the secur i ty of the n a t i on’s water infrastructure ag ainst terrorist thr eats has receiv e d great er at tention, including the potential f o r terrorist a ttacks at wastewater facilities that store large amounts of chlorine gas. If released, chlorine gas may threaten utility employees and th e public near the affect ed facilities. Th e gas can be deadly if inh a led and , at l o wer doses, can burn the eyes and skin and inflame the l ungs. In a 2 0 04 report, th e White Hou s e Homeland Security Council determined that a terrorist attack on an urban chemical facilit y that resulted in the rupture of a chlo r i ne gas rail car could kill up to 17,500 individuals a nd hospitali ze as many a s 100,0 00.

While federal law does not require wast ewater systems to take security measures to protect spec ifically again s t a terrorist attack, it do es require certain wastewater facili ties to ta ke s ecurity precautions that could mitigate the consequen c e s of such a n attack. Fo r example, t h e Clean Air Act 1 requires wastewater facilities that use threshold quantities of certain

1 Pub. L. N o . 101-549 (1990).

P a g e 1 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tyhazardous substances, such as chlor i ne gas, to p r epare and i m plement a risk management plan d e signed to p r event a ccid e ntal rele ase s of regulate d substances a nd reduce th e severity of those releas es that do o ccur. 2

As we reported in March 2006, 3 many of the nation ’s large wastewater facilities have improved security sinc e September 11, 2001. For instance, a substantial number of facilities repo rted impro v ing securit y fences, increasing s ecurity lighti n g, and im pl ementing improved employee and visitor identification systems, among other security enhan c e m ents. In addition, though not required, many l a rge wastewater faciliti e s reported that they conducted vul n erability as sessments 4 t o identify ris k s to key process components such as the use, storage, an d handling o f chlorine gas. Finally, many faciliti e s reported that they recently stopped or plan to stop using c h lorine gas i n favor of al ternate disin f ection meth ods. Commonly used alterna t ives include sodium hypochlorite, es sentially a concentrated form of household bleach , and u l traviolet light , which break s down disease-causing mi croorganisms.

For wastewater facilit y managers, the costs of p r eparing vul n erability assessments and risk management pl ans and con verting to al ternate disinfection methods must compete for availabl e resources with other infrastructure needs. For instance, in 2003 , in its most recent Clean Water Needs Surve y, the Envir onmental Protection Age n cy (EPA) estimated that, nationwide, wastewater systems faced $181.2 billi on in costs to upgrade treatment systems and sewer lines, reduce th e in cidenc es of combined sewer overflows, which result in the discharge of untreated w a stewater into receivin g waters, an d meet ot her pollution co ntrol requirements. Major U.S. cities, includi ng Washingt on, D.C., an d Cincinnati, Ohio, are facing costs between $1 billion and $2 billion to i m plement necessary capital improvements.

2 EPA requires t h at any facility storing at least 2, 500 pounds of chlorine gas s ubmit a risk management pl an.

3 GAO, S ecuri ng Wa stewa te r F a ci li ti es: Uti l i t i es Ha ve Ma d e I m

p o rta n t Up gra d es but Furth e r I m

p r

ovements to Key S y s tem Comp o nent s Ma y Be Li mi ted by Costs a n d Oth e r Constra i n ts , G A O-06-390 (Wa s hington, D

. C. : Mar. 31 , 2006 ).

4 According to the Envi ronment a l Protection A g ency (E PA), v u lnerability assessments performe d by water sector ut ilitie s address not only utility vulnerabilities, but also utility threats and consequences.

P a g e 2 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tyThis report provides information on (1) the range of costs lar ge wastewater treatment facilities incur r ed in preparing vulnerability assessments and risk management pl ans, and (2) the costs large wastewater treatment facilities incur r ed in converting from chlorine gas t o alternative d i sinfection p r ocesses.

To identify t h e costs of preparing vul n erability as sessments and risk management plans, we conducted struct ured telephone interviews with a select sample of large wastewater fac ilities ident i fied as havi ng completed these assessments in our March 2006 report. 5 Our March report identified 106 l a rge facilities that prepared vu l n erability ass e ssments or had one underway and 85 faciliti e s that were r equired to prepare risk management plans becau se they curr ently used c h lorine gas a s a disinfect ant. From this universe, we chose a nonprobability samp le of facilities based largely on geographi c representatio n and size. 6

To identify t h e costs inc u rred by wastewater treatment facili ties in converting f r om gaseous chlorine to alternative d i sinfection p r ocesses, we conducted s t ructured tel e phone int e rviews with most of the 38 large facilities identified in the March repor t as having converted recently from chlorine gas or indicating that they pl anned to do so. We also conducted site visits wi th some of the faciliti e s. Where avail a ble, we gat h ered documentati on, such as capital pl ans, from these facilities in order to document conversion costs. We supplemented t h e cost infor m ation we gathered at i ndividual w a stewater facilities with information obtained at EPA, the Department of Homeland Security (DHS), and nongovernmental organizations. Reported costs for prep aring vulnerability assessment s , risk management plans, and conversion f r om gaseous chlorine inc l ude both actual and estimated costs. For es timated costs, we asked facility managers to explain ho w they arriv e d at these e s timates. Reported costs were not adj u sted for inflation. We d e termined that reported cost data were sufficiently reliabl e to provide useful information about the costs for preparing vu lnerability assessments, risk management plans, and conversion f r om gaseous chlorine an d th e factors that affe ct t h ese costs. We conduct e d our work between Au gust 2006 an d March 2007 in

5 We define d large wastewater facilitie s as th ose publicly ow ned t r eatment works (POTW ) that serve residential populations of 100,000 or g r eater.

6 Results from nonproba bility samples cannot be used to make inferences a b out a population, bec a use in a nonprobability sample some elem ents of the popula t ion being

s t udied have n o cha n ce or a n unk now n chan ce of being s e le cted as pa rt of the s ample.

P a g e 3 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tyaccordan ce with general ly ac cepted government auditing sta ndards. A more detailed discussion of our scope and metho dology is included in appendix I.

The expenses large wastewater facili ties reported to prepare vulnerabilit y assessments and risk management pl an s varied w i dely among the faciliti e s we intervie wed, costing less than $1 ,000 in some cases to $1 7 5 ,00 0 in others. The cost differences were re lated to whet her the documents were prepared in- house or co ntracted to t h ir d parties such as engi neering firms. Despite higher costs, some facilities preferred to use contract ors due to their experti s e and indep e ndenc e. Ac cording to o n e wastewater security official, thes e attributes can gi ve c o n t ractor findings and recommend ations great er credibilit y wi th utility governing boards that determine spending priorities. Overall, cost estimates of the f acilities we interviewed did not relat e to facilit y s i ze, as measured by millions of gallons of wastewater treated p e r da y. 

# Results in Brief

Large wastewater faciliti e s that converte d or plan to convert from chlorin e gas disinfect ion to altern ative disinfection proces ses also report widely varying costs, ranging fr om about $6 50,000 to jus t over $13 million. Key factors associated with t h ese costs included th e type of alt e rnative 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 facilit y or generated on-site), which has lower capital costs than c onverting to ultraviolet li ght. For example, managers of a t r eatment facility in Virgi n ia told us t h ey spent about $1.2 million in 2004 converti ng to bulk sodium hypochlorite disinfection, while managers of a co mparably sized facilit y in Maryland told us they plan to spend an estima ted $4 million converting to ultraviolet light disinfection by the end of this year. Managers of the Maryland facilit y indicated th at one reaso n they c hos e the more ex pensive ultr aviolet treatment option over b u lk deliverie s of sodium hypochlorite was to reduce risk t o local traffi c that cou l d result from additional d e liveries to the plant. In addition, usi n g ultraviole t light elimin ates the ne e d for wastewater treatment plants to hand le and store significant amounts of hazardous or corrosive chemicals. Other than the disinfection method and facility size, key cost fact ors wastewa t er facilities cited included (1) whether existing buil d ings could be used in t h e conversion, (2) building costs, which varied considerably from location t o location, (3) the higher cost of sodium hypochl orite relative to chlorine gas, and (4) the exte nt to which training, labo r, and regula tory compliance costs were lower at plants that no longer h a d to rely on chlorine gas.

P a g e 4 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tyA majority of the nation ’ s wastewate r is treated b y publicl y o w ned treatment works that serve a variety of customers, including private homes, businesses, hospitals, and in dustry. These publicl y o w ned treatment works are reg u lated by th e Clean W a ter Act. Wastewater treatment includes a coll ection system (the underground net w ork of sewers) and a treatment facility. Wastewater enters the treatment facility through the collection system, where it undergoes an initial st age called primary treatment, during which scre ens remove coarse solids, and grit chambers and sedimentation tanks a llow solids to gradually sink. Next, wastewater enters secon d ary treatme nt , where ba cteria consu m e most of the organic matter in the wastewater. After these processes, wastewater is disinfected t o eliminate r e maining pathogens and other harmful microorganisms. 

# Background

Wastewater facilities typically use bo th chemical and physical disinfection methods, including the f o llowing:

• Chlorine gas . Injecting c h lorine gas i n to a waste stream has been the traditional method of disinfecting wastewater. Chlorine gas i s a powerful oxidizing agent , is relativel y inexpensive , and c a n be stored for an exten d ed period o f time as a li quefied gas under high p r essure. Also, the residual chlorin e that remai n s in the wastewater effluent can prolong disinfection aft e r initial treat ment. Howe ver, chlorine gas is extremely volatile and h a zardous, an d it requires specific precautions for its safe transport, storage, and use

. Because it i s stored and transported as a liquefi ed gas under pressure, if accidentally released, chlorine gas can qui c kly t u rn into a p o tentially l e t h al gas. EPA requires, among other things, that any facilit y s t oring at least 2,500 p o u nds of chlorine gas prepare a ris k manageme n t plan that l ays out ac ci dent prevention and emergen cy respons e activities. At certain concentratio ns, the residual chlorine that remains in wastewater effluent is toxic to aquati c life, so wastewater facilities that use chlorine co mpounds may also need to dechlorin a te the treat m ent stream before dischargin g it to receiving waters. 7 Chlorine can also oxidize cert a in types of organic matt er in wastewater, creatin g hazardous chemical byp r oducts, such as trihalo m ethanes. Our March 2006 report found that many larg e wastewater facilities have discontinued, or are planning to di s c ontinue usi n g chlorine gas as a disinfectant in favor of al ternative dis i nfection methods such as sodium

7 Sulfur dioxide, often used for de chlorination by wastewater facilitie s, is also cove red by risk manageme n t plan rules when used or stored in threshol d amounts.

P a g e 5 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tyhypochlorite delivered in bulk to the f acility. Of the 206 large wastewater facilities responding to o u r survey, o n ly 85 f acilit ies indicated th ey currently use chlorine gas, and 20 of these faci lities plan to switch from the gas to another disinfectant.

• Sodium hypochlorite . Injecting sodiu m hypochlorite—essentially a concentrated form of household bleach—into a waste stream is another chlo rination method of disinfecting wastewater. Sodium hypochlorite is safer than chlorine gas because, if spilled, it remains liquid and can be cont ain e d and reco vered. For t h is reason, it is not subject to E P A’s risk ma nagement pl anning req u i r ements. However, sodium hypochlorite is more expe nsive than ch l o rine gas, an d it degrades qui c kly if it is exposed to sunlight or is not kept at pr oper temperatures. For this reason, pr operly storing delivered sodi um hypochlorite in the con c entration ne cessary to di sinfect wastewater may require an on-site b u ilding wi th environmental controls. Sodium hypochlorite can also be generated on-site at a w a stewater facility using an “electrochlorination system” that produces sodium hypochlorite through an electrical reaction with high-purity salt and softened water. Facilities choosing t h is method of disinfecti on reduce chemical co sts, but face increased el ectrical costs from the generation equipment. Because it is a chlorine compound, wastewater facilities using sodium hypochlorite must also be con cern e d with residual chlorine and hazardous chemical byp r oducts, such as trihalo m ethanes.

• Ultraviolet l i ght. This disinfection method uses u l traviolet lamps to break down disease-caus i ng mi croorganisms in wastewater. Wastewater passes through an op en c h annel with lamps submerged below the water lev e l. T h e lamps transfer electro magnetic en ergy to an organism’s genetic mater i al destroyin g the abi lity of its cells to reproduce. Because ultr aviolet li ght is a physical process rather than a chemical dis i nfectant, it eliminates the need to g e nerate, h a n d le, transport, or store hazardous and co rrosive chemicals. In ad dition, there are no harmful residual effe cts to humans or aquatic l i fe

. However, ultraviolet ligh t disinfectio n may not b e effecti ve gi ven the turbidity of some waste w ater streams. Wastewater faciliti e s using ultraviolet i n stead of ch lorine gas or delivered sodium hypochlorite for disinfection will face add i tional costs to maintain l a mps and increased electrical co sts.

• Ozone. This disinfection method feed s ozone gen erated on-sit e from oxygen exp o sed to a hig h -voltag e cu rrent into a contact cha m ber containing wastewater. According t o EPA, ozone is very effe ctive at destroying vi ruses and bacteria, b u t i t is the least used disinfection

P a g e 6 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tymethod in the United States largely b ecause of its high capital and maintenanc e costs compared to a v ailable alt e rnatives.

According t o EPA, vuln erability ass e ssments he lp water systems evaluat e susceptibility to potenti al threats such as vandali sm or terro ri sm and identify corr ective actio ns that can r e duce or mit i gate th e risk of serious
consequen c e s. The Publ ic Health Se curity and B i oterrorism Preparednes s and Respon se Act of 2002 (the Bioter rorism Act) 8 required dri nking water utilities serving populati ons greater t h an 3,300 to complete vulnerability assessments by June 2004. 9 Wastewater facilities are not requi r ed by law t o complete vulnerability assessments. Congress has considered bills that would have encourag ed or required wa stewater treatment plants to assess vulnerabiliti e s, but no such requirement has become law.

In our March 2006 repor t on wastewater facilit y security efforts, we found that many large wastewater facilitie s have either completed a vulnerabilit y assessment or had one underway. Of the 206 large wastewater facilities that responded to our survey, 106 f a cilities—or 51 percent—r e ported that they had completed a vulnerability assessment or were currently conducting one. Several other facilit ies indicated they had conducted or planned to conduct other types of s ecurity assessments. Facilities cited several reas ons for completing a vul n erability as sessment or some other type of security assessm ent, but most—roughly 77 percent—r e ported doing so on their own initiative. Many faciliti e s indicated they were combined systems—facilities that manage both drinking water and wastewater treatment. As such, 37 pe rcen t of facil i ties reported that they did some type of securit y assessmen t in conjunct i on with the required assessment for their drinking water f acility.

The Clean A i r Act requires wastewat er facilities t h at use or store more than 2,500 p ounds of chl o rine gas to submit to EPA a risk management plan that l a y s out accide nt preventio n and emerg e ncy respon se activities.

8 Pub. L. N o . 107-188 (2002).

9 The Bioterrorism Act req u ired the assessment s to include, but not be limited to, a review of six com p one n ts: (1 ) pipes a nd c onstructe d conveya nces; (2) physical barriers; (3 ) water collection, pret r eatment, treat m ent, storage, and distribution facilities; (4) electronic, computer, or ot her a u tomated systems that are utilized by t h e water system; (5) the use, storage, or handling of various chemicals; a nd (6) the ope ration a n d maintenance of such systems. The act furthe r requi r ed systems to pre pare or revise an emerge nc y response pla n incorporating the results of the vulnera b ility a ssessment wit h in 6 m ont hs af ter com p leting the assessment

.

P a g e 7 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tyUnder this act, EPA requires that about 15,000 f a cilities—including chemical, water, energy, and other s ect or faciliti e s—that produce, use, or store more than threshold amounts of chemicals posing the greatest risk to human he alth and th e environment take a number of steps to prevent and prepare for an acc id ental ch emical rele ase. EPA regulations implementing the Clea n Air Act require that the o w ners and operators of chemical facilities include a facilit y hazard assessment, an accident prevention p r ogram, and an emergen cy re sponse program as part of their risk management plans. The regulati ons required that a summary of eac h facility’s risk managemen t plan be su bmitted to EPA by June 21, 1999. Th e plans are to be revised and resubmitte d to EPA a t least ev ery 5 ye ars, and EPA is to review them and require r evisions, if n ecessary.

Although accurate infor m ation on the costs of vulnerability assessments and risk management pl ans is limited, avail a ble estimates suggest that their costs vary consider ably. A fa cto r contributing to the cost differential was whether they were contracted t o third parties (such as e n gineering consulting fi rms) or prepared in-hous e with existing staff. Despite higher costs, some facilities preferred usin g contractors because th ei r expertise and independence l e nt credibility to their assessments, whic h may be useful in obt aining supp ort for securi ty-related u p grades. Co sts generally did not relat e to facilit y s i ze, as measured by million of gallons of wastewater treated per day. 10

The reported cost of preparing vuln erability assessment s at the 20 l a rge wastewater facilities where we inter v iewed officials ranged f r om $1,000 t o $175,000. W h ether the assessment was done in-h ouse with existing staff or contracted t o a third par t y was a fact or contributing to the co st differences. Officials from several fac ilities told us they used contractors to complete vulnerability assessments in 2002. Fo r example, staff at the Denver Metro Wastewate r Reclamation District reported that a contracto r completed a vulnerabilit y assessmen t in November 2002 for it s Central Treatment Plant, which t r eats 130 mil lion gallons of wastewater per day, a t 

# Costs of Preparing V u lnerability Assessments and Risk Management Plans among Large W a stewater Facilities Va r

y

W i d e l y

V

u lnerabi lity Assessment Costs Depend Pri m arily on Whether a Contractor Is Used

10 In our structured interviews we asked facilit y managers t o provide estimates of their treatment facility’s “existing fl ow” in millions of gallons per day. “E xist ing flow” refe rs to the calculated average flow for a recent 12-mont h period, as defined by EPA in its Clean Water Nee d s Survey, and is a common measure of treatme n t facility size. When we note how many gallons pe r day a facility treats, we ar e referring t o its rep orted “ e xis t ing flow .”

P a g e 8 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tyan estimated cost of $1 75 ,000. Of this cost, $10 0,0 00 was for the contractor, and $7 5,0 00 was estimated for in-ho u se staff time.

Other large wastewater facilities th at reported completing vulnerability assessments in 200 2 were part of co mbined systems that provide both drinking water and wastewater serv ices. These systemwide vulnerability assessments were done before the 2002 Bioterro rism Act req u ired drinking water utilities serving p opulations greater than 3,300 to complete vulnerability assessment s by June 2004. The combined systems that conducted s y stemwide vulnerability a ssessments include the following:

• San Antonio Water System (San An tonio, Texas). According to system staff, a contracto r completed a systemwide vulnerabi l i t y assessment for all its drinking water, wastewater, and relat e d infrastructure in August 2002 for $11 2,00 0. Staff did not provide an estimate of in-house costs related to t h e assessme n t, but prorated the wastewater treatment plants costs rela ted to this contract at $ 37,0 00: $25, 000 for i t s Dos Rios plant, which treats 70 million gallons per day; $5,0 00 e ach for its Leon Creek and S a lado Creek plants, which treat 33 million gallons per day; and $2,000 for its Medio Creek plant, which treats 5 million gallons per day.

• The Phoenix Water S ervi ces Departm ent (Phoeni x , Arizona)

. According t o department staff, a con t ractor completed a syst emwide vulnerability assessment for its five drinking water plants, three wastewater plants, and r e lated infras tructure in November 2002 for $479,725. St aff did not p r ovide an estimate of in-house cost related to the assessment, but esti mated the cont ract cost s related to i t s largest wastewater treatment plant, the 91s t Avenue Sew age Tre a tment Plant, which treats 140 million gallons per day, to b e $100,000.

• Fort Worth Water Depa rtment (For t Worth, Tex a s) . According to department staff, a contr actor completed a systemwide vulnerability assessment for its four drinking water plants and one wastewater treatment plant in Dece mber 2002 a t a cost of $ 2 92,3 00. St aff did not provide an estimate of in-house cost related to th e assessmen t, but estimated the contract c o sts related to its Village Creek Wastewater Treatment Plant, which t r eats 96 million gallons per day, at $73,075.

Wastewater facility man agers cited s everal reasons for using contractors to complete vulnerability assessmen t s . Staff with the Phoenix Water Services Department told us they us ed contractors for their vulnerability assessment because a ci tywide polic y required th at contract s e rvices be used whenever possible. Staff at oth e r wastewate r facilities to ld us that,

P a g e 9 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tydespite the higher costs, they preferr e d to use co ntractors because of thei r expertise. A ccording to a wastewater s ecurity official, co ntra ctor experti s e and indep e n d ence can gi ve contra cto r findings an d recommendations greater credibility with utility govern ing boards that determine spending priorities.

One manager told us that he used a contractor for a 2002 vulnerability assessment because risk managemen t software and tools were not yet availab l e. Af ter the event s of September 11, 2001, EPA provided funding t o the Association of Metropolitan Sew e rage Ag enc i es 11 to devel o p software, called the Vulnerability Self Assessment Tool (VSAT), for water utilities to use to devel op vulnerabi lity assessments. Accord ing to a W a t e r Environment Federation (WEF) official, VSAT be came availa ble in June 2002 . This of ficial also said that EPA provided fu nding to WE F to provide training workshops to wastewater ut ilities on how to use VSAT to conduct vulnerability assessment s beginning October 2002. 12

According t o interviews with waste w ater facilit y managers, large wastewater facilities that prepared vulnerability assessments in-house with existing staff reported lower co sts for preparing the doc ument. These include the f o llowing:

• City of Vent ura Public Works D e partment (V en tura, California)

. According t o facility staff, in-house staff completed a vul n er ability assessment in March 2003 for the Ve ntura Water Reclamation Facility, which treats 9 million gallons per day, at a cost o f roughly $1, 000 in staff time. Facility staff participated in VSAT training sponsored by EPA and co mpleted the assessment using this tool.

11 Now the National Association of Clean Wate r Agencies (NA C WA).

12 Prior to Se ptember 11 , 2001 , EPA worked to develop an d disseminate risk assessment methodol ogies for water utilities. In 2000 , EP A funded an i n itiative with the American Water W o r k s A ssociation Research Fo undatio n (A WWARF) a nd t h e Sandia National Laboratories to apply risk assessment met hod ologies develop e d by the labor atories to water utilities. The methodology, called t h e R i sk Assessment Methodology for Water Utilities (RAM- W ), was designed to assist larg e water utilities and security professionals in assessing the ri sks from malev o lent threats. T hrough a n inte ragency agreem ent with EPA, Sandia Nationa l Labo ratories provide d trai ning to s e lected f i rms in the RA M-W methodol ogy s o that thes e fir m s could t h en provide trainin g and tech nical as s i s tance to water utilities.

P a g e 10 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri ty• City of Fort Wayne Ut ili t ies D i visio n (Fort Way n e, Indiana )

. According t o facility staff, in-house staff completed a vul n er ability assessment in November 200 5 for the Fort Wayne Water Pollu tion Control Plant, which treats 43 milli on gallons per day, at undetermined staff time. Facility staff participated in VSAT training and updated a previous risk assessmen t prepared f o r the facilit y by a contr actor in 2000 at a co ntracted cos t of $10, 00 0.

• City of Euge ne Wast ewa t er Divi sion (Eugene, O regon). According to facility staff, in-house staff completed a vulnerabil ity assessme n t in October 200 5 for the Eu gene/Springf ield Region al Water Poll ution Control Facility, which treats 38 milli on gallons per day, for about $2,0 00 in sta ff time.

• City of Ceda r Rapids Department of Water Pollution Control (Cedar Rapids, Iowa) . According to facilit y s t aff, in-hous e staff completed a vulnerability assessment in Janua ry 2007 for the Cedar Rapid s Wastewater Treatment Plant, which t r eats 35 million gallons per day, for about $5, 000 in staff t i me.

• Detroit Wat er and Se we rage Depart m ent (D etro it, Mi chigan ). According t o department staff, in-h ouse staff completed a vulnerability assessment in January 2 0 05 for the D e troit Wastewater Treatment Plant, which treats 700 m illion gallon s per day, fo r about $20, 000 in staff time.



## Risk Management Plan Costs Al so Influenced by Use of Contractors Costs to pre p are risk management pl ans ranged f r om less tha n $1,0 00 for facilities that completed the plan in-h ouse to over $31, 000 for facilities that used contractors. Costs to update ri s k management plans were gen erally less, ranging from less than $1, 000 to $20, 000 d e p e nding upon whether facilities used in-house staff or contractors.

Costs were generall y hi gher at fa cili ties that use d contractor s. These include the f o llowing:

• The Phoenix Water S ervi ces Departm ent (Phoeni x , Arizona)

. According t o department staff, a con t ractor completed risk management plans for al l the system’s drinking a nd wastewater facilities in 1999 for $230, 086. Costs fo r the 91st Avenue Sewage Treatment Plant were prorated at $ 2 8 ,76 1 . Depar t ment staff said a contractor u pdated the 9 1 st Avenue plant’s risk management plan in 2004 for $20
, 000.

P a g e 11 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri ty• Fort Worth Water Depa rtment (For t Worth, Tex a s) . According to department staff, a contr actor completed risk management pl ans for all of the department’s drinking water and wastewater facilities i n 1999 for $124,718. Co sts related to the Villa ge Creek Wastewater Treat ment Plant’s risk management plan were prorated at $31, 100. Dep a rtment staff reported that the co ntractor later updated th ese risk management plans for $18,040 in 2004, $4,510 of which was for the Village Creek plant.

• City of Fort Wayne Ut ili t ies D i visio n (Fort Way n e, Indiana )

. According t o facility staff, a contract or completed a risk management plan in 2 001 for the Fort Wayne W a te r Pollution Control Plant for $16, 000. Facility staff rep o rted a cont ractor updat e d the pl an i n 2005 for $6,00 0.

• South Central Regional Wastewater Treatment a n d Disposal Board (Delray Bea c h, Florida) . According to facility st aff, a contractor completed a risk management plan in 1999 for the South Central Regional Wa stewater Treatment and Disposal Plant, which treats 18 million gallo ns per day, f o r $10,000. F acility staff r e ported a co ntractor updated it in 2006 for $2, 000.

• City of Portland Bureau of Environmental Serv ices (Portla n d, Oregon) . According to b u reau staff, a contractor completed a risk management plan in 1 9 9 9 for its Columbia Boulevard Waste w ater Treatment Plant, which t r eats 143 mil lion gallons per day, for $30, 000. Bureau staff reported th ey updat e d t h e plan usin g in-house st aff in 2004 for $10,0 00 i n staff time.

Other large wastewater facilities that prepared ri sk management plans inhouse with existing staff reported lower costs fo r preparing t h e documents. These inclu d e the follo wing:

• San Antonio Water System (San An tonio, Texas). According to system staff, in-house staff completed a risk management plan in 1999 for the Dos Rios Wastewater Treatment Plant for between $5,0 00 an d $10, 000 in staff time. In-h ouse staff updated the p l an in 2004 f o r less than $1, 000 i n staff time.

• City of Ceda r Rapids Department of Water Pollution Control (Cedar Rapids, Iowa). According to facilit y s t aff, in-hous e staff completed a risk management plan in January 20 0 0 for the Ce dar Rapids Wastewater Treatment Plant for $5, 000 in staff ti me. In-house staff updated the plan in 2004 for about $250 in staff ti me.

P a g e 12 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri ty• Denver Met r o Waste w ate r Reclamat i o n Distri ct (Denve r, Colorado). According t o district staff, in-house staff completed a risk management plan in 1999 for $10,000 i n staff time. In-house staff updated t h e plan in 2006 for abo u t $1,0 00 in staff time.

• City of Savannah Water and Sewer Bureau (Sa v annah, Georgia). According t o facility staff, in-house staff completed a risk management plan in 1 999 for the President Street Water Pollut i on Control Plant, which treats 17 million gallons per d ay, at a cost of only $150 in staff time. In-house staff updated the pl an in 2006 for about $130 in staff time.

Large wastewater faciliti e s that conver t from chlorine gas dis i nfection to alternative d i sinfection p r ocesses incur widely va rying capit al costs, which generall y depend on the alternative t r eatment chosen and facility size. Other factors that affect capital co sts include th e characteristi cs of individual f a cilities, such as whether existing structures can be used, and local fa ctors, such as bui lding costs. Alternative disinfection processes may also pose higher an nual operati ng costs tha n chlorine g a s. However, these costs may be offse t , at least so mewhat, by savings in training an d labor costs, and regulato ry burdens associated with the handli n g of chlorine gas. Some facilit ies even rep o rted or projected n e t an nual cost savings relat e d to wastewater disinfection.

The 23 l a rge wastewater facilities th at we interviewed reported capital costs for chlorine conv ersion ranging from $646,9 22 to just ov er $13 million. Table 1 identifies the 23 lar ge wastewater facilities that recently converted o r plan to con vert from chlorine gas to another disi nfection method and their reported and plann e d capit al co nversion cost. 

# Costs of Converting to Alternative Disinfection M e thods at Large W a stewater Facilities Depend on the Method Used and Other F a ctors

Disinfecti on Method Chosen, Facility Size and Character istics, and Other Factors Determine Capital Conversion Costs

P a g e 13 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri ty**Table 1: Reported and Planned Di sinfection Conversion Costs for La**  **rg e Wastewat**  **er Treat ment Facilities** 

**Facility name Facility locati**  **on Co**  **n versio**  **n yea**  **r Facility size (i**  **n millio**  **ns of g**  **a llo**  **n s**  **treated p**  **er d ay)**  **a Dis**  **i nfe**  **c t**  **ion me thod**  **Re por**  **te d or**  **p l**  **a nne**  **d**
**co n**  **versio n**  **co st**  **b (in**  **do llars)** 
**Facilities that have complet**  **e d**  **conversion from chlorine gas**  Chamb e rs Cre e k Univers i ty Plac e, W a sh

. 2 0 0 2 19 Ultravio let lig h t $3,90 0,60 8
Blue Pla ins W a shingt on, D

. C. 200 3 307 S o d i um hypoc h l o r i t e 12,98 0,72 6
Northeast Phila de lph ia, Pa. 200 3 190 S o d i um hypoc h l o r i t e 2,600,0 0 0
Back River Baltimore, Md. 200 4 150 S o d i um hypoc h l o r i t e 3,300,0 0 0
Essex and Un i on Elizab eth, N.J. 200 4 6 5 Sodi u m hypoc h l o r i t e 775,0 0 0
Chesa peak e- Elizab eth Virgin ia Be ach, V a

. 2 0 0 4 21 Sodi um hypoc h l o r i t e 1,225,0 0 0
Nansem ond Suffolk, Va. 200 4 17 S o d i um hypoc h l o r i t e 1,650,7 4 0
Columb ia Bo ul evard Portlan d, O r e. 200 5 1 4 3 Sodi u m hypoc h l o r i t e 4,660,4 9 0 Valley Cre e k Bessemer, Ala. 200 5 4 6 Ultravio l e t lig h t 3,561,2 7 2 Dry Creek F o rt W r ight, Ky. 200 5 36 Sodi um hypoc hlorite 646,9 2 2
Southern R egi onal Boynton Be ach

, F l a

. 2 0 0 5 22 Sodi um hypoc hlorite c 2,592,8 0 0
Burbank Burba n k, Calif. 200 5 9 S o d i um hypoc h l o r i t e 2,500,0 0 0
Southeast Phila de lph ia, Pa. 200 6 90 S o d i um hypoc h l o r i t e 1,920,0 0 0 Papill on O m aha, Neb. 200 6 62 Sodi um hypoc hlorite 3,000,0 0 0
**Facilities that plan to c**  **onvert from chlorine gas**
Metro Central Denver, C olo. 200 7 130 S o d i um hypoc h l o r i t e 13,13 5,00 0
F o rt W a yne F o rt W a yne, Ind. 200 7 4 3 Sodi u m hypoc h l o r i t e 1,791,4 1 7
Everett Everett, Wash. 2007 18 S o d i u m hypoc h l o r i t e 2,562,460
South Centra l Delray Be ach, F l a

. 2 0 0 7 18 Sodi um hypoc hlorite c 2,454,7 0 0
Mill Creek Cinci nnati, O h i o 200 8 1 2 0 Sodi u m hypoc h l o r i t e 3,085,0 0 0
W e stern Bran ch Laur el, Md. 200 8 20 U l t r a v i o let lig h t 4,000,0 0 0
South T r eatment Plant Rento n , W a sh

. 2 0 0 9 75 Sodi um hypoc h l o r i t e 2,575,0 0 0
Hartford Hartford, Con n

. 200 9 51 Ultravio let lig ht 10,89 2,00 0 Eugen e-Spri n g field Euge ne, O r e. 200 9 3 8 Sodi u m hypoc h l o r i t e 4,498,0 0 0

Sour ce: GAO

.

a Plant size figure s are figure s fo r existing flow (a measu r e of a v erage daily flow) re ported b y
was t ewater fac ilities in our s u rv ey

.

b Conve r sion co st s we re not adju s t ed for inflation. Fi gures do not reflect change s in a nnual co sts, but are rep o rted co st s for con s truction , labor, and mate rials related to t h e di sinfection co nversion. Reported c o n v e r s i on c o s t s inc l ud e ac tual c o s t s an d es timate s from fac ility manage rs. As suc h

, these cost figure s do n o t repre s ent the prese n t value of t he l i f e-cy cl e cost of con v er si on. C o nver si on cos t s include repo rted temporary an d p e rmanent con v ersion co st s.

c The s e fa c ilities will generate s o d i um hy po c h lorite on- s i te. All other fac ilities lis ted as c o n v erte d or planning to c o n v ert to s odium hyp o c h lorite are ha v i ng the chemic al deliv ered in bulk to the fa c ility

.

P a g e 14 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tyAs shown in the table, 17 of the 23 facilities converted or plan to convert to sodium hypochlorite delivered i n bulk to the f acility. Officials with several of th ese faciliti e s told us they considered ultraviolet d i sinfection, but chose de livered sodi um hypochl orite becaus e of its lower capital conversion costs. The re mainder conver ted or plan to convert to sodium hypochlorite generat ed on-site or ultraviol et li ght. None of the facilities we contacted adopted ozon e.

Interview responses indicate that several factors affect the co st of conversion; among these are disinfecti on method chosen, faci l i ty size, key facility char acteristics such as av ail a ble buildings, and whet her the conversion was permanent or temporary, as foll ows.

Generally, conversion to delivered s odium hypochlorite has t h e lowest capital costs, followed b y sodium hypochlorite generated on- site, and followed again by ultraviolet light. 13 This observation is supported by cost estimates in the Chlorine Gas Decisi on Tool, a sof t ware program released by DHS in March 2006. T h e decision t ool was designed to provide water and wastewater utilities with the means to conduct assessments of alternatives to chlorine g a s disinfecti on. DHS cau tions that the final c o sts of the disinf ection systems will depe nd on project design details, actual labor and material costs, competitive market conditions, actu a l site conditions, f i nal project scope, implementation schedule, con t inuity of personnel and engin eeri n g, and oth e r variable f a ctors. 14 With these caveats, the decision too l estimates that for a wastewater facility with an average disi nfection flo w of 10 m illion gallons p e r 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 o f sodium hypochlorite w ould total $ 1 , 238, 000 , an d ultraviolet disinfection would reach $1,5 26, 000. 15 

### Disinfection Method

13 Convers i on to dis i nfection me thods s u c h as o z one an d ultrafiltration can ha ve higher capital costs than ultraviolet light.

14 The decision t o ol provides cos t estimates for disinfection conversion alternatives where there is limited site-specif i c engineering data

. DHS notes t h at cost estimates were based on cost curves t h a t were developed from a co m b ination of t h e actual construc tion costs of different-sized disinfection systems and c o st e s timates based on c oncept u al designs.

15 DHS notes t h at it is normally expected that a n estimate of thi s type woul d be accurate within +50 pe rcent to -30 pe rc ent.

P a g e 15 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tyOur interviews with wastewater faci l i ties provide specific ex a m ples of conversion costs. For example, managers of th e Chesapeak e-Elizabeth Treatment Plant, which t r eats 21 million gallons per day and serves customers in Virginia B each, Virg ini a , reported s p ending an e s timated $1,2 25,0 00 i n 200 4 con v erting to bul k sodium hypochlorite d i sinfection. Managers of the comparably sized W e stern Branch Wastewat er Treatment Plant, which treats 20 million gallons per day and serves customers in Laurel, Maryland, estimated that th ey will spend $4 million converting to ultraviolet li ght disinfect ion by Janua ry 1, 2 008. Managers of t h e Western Branch plan t indicated t h at one re ason they chose the more e xpensive ultraviolet tr eatment opti on over bul k deliveries o f sodium hypochlorite was to avoid the risk to l o cal traffic t h at could re sult from additional deliveries to the plant. Pl ant manager s indicated t h at bec a use sodium hypochlorite degrades more quickly t h an chlorine gas, truck d e liveries would increase under a disinfection sy stem usin g sodium hypochlorite. They also no ted that ultr aviolet li ght disinfection would eliminate the n e e d for the facili ty to handl e and store significant amo unts of hazardous and corrosive ch emicals.

In addition t o disinfection method chosen, facility size can als o influence capital conversion costs. In general, l a rger faciliti e s spend more converting t o alternative disinfection methods. For example, because larger facilit ies process a greater fl ow of wastewater, converting to delivered so dium hypochlorite would r equire a l a rger sodium hypochlorite storage buil d ing or build ings relative to a smaller facility. It m ay also require addi tional pumps, instrumen t ation, and p i ping to deli ver treatmen t chemicals to a great er nu mber of c ontact tanks. I m portantly, the largest facilities als o tend to ser ve high- c ost urban areas, and their conversion costs reflect the high er c o sts for construction materials and c ontract labo r in these markets. 

### Facility S i z e

For example, the Blue Pl ains Wastew ater Treatment Plant, w h ich treats 307 million gallons per d ay and serves over 2 million customers in the Washington, D.C., metropolitan area , converted from chlorine gas to delivered so dium hypochlorite in 20 03 at a cost of almost $13 million. According t o facility managers, the f acility t e mporarily converted from chlorine gas to delivered sodium hy pochlorite in April 2002 at a cost of $500 ,00 0 , pri m arily for storage tanks, pumps, piping, and rel a t e d instrumenta t ion. It completed the p e rmanent co nversion in October 200 3 at an ad ded cost of abou t $12. 5 million, which in cluded the p u rchase of additional st orage tanks, related pum ps, piping an d instrumentation, and the construction of storage facilities f o r sodium h y pochlorite and sodium bisulfate (used for dechl o rination).

P a g e 16 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tyIn addition t o facility siz e , other physical charact e ristics related to individual f a cilities also play a l a rge role in conversion costs. For instance, the availabil i ty of usable buildings on facility grounds will determine whether a facility needs to construct, expand, or update a buil d ing to properly ho use sodium hypochlorite and its associated meter i ng equipment. I n addition, t h e distance between the storage buil d ing and treatment tanks will determine the am ount of piping needed to deliver stored sodium hypochlorite to the treatment tank s. An example comes from the Hampton Roads Sanitation District which provides wastewater treatment to approximately 1. 6 million people in 17 citi es and counties in southeast Virginia, inclu d ing the citi es of Newport News, Norfolk, Suffolk , Virginia Bea c h, and Wil l i a msburg. In 2004 , the sa nitation district convert e d from chlorin e gas to bulk sodium hy pochlorite disinfection at two of its plants—the Nansemond Treatment Plan t, which t r eats 17 million gallons per day for t h e city of Su ffolk, and th e previously mentioned ChesapeakeElizabeth plant, which treats 21 m illi on 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 b u ilding need ed to be constructed for sodium hypochlor ite storage, while the Chesa p eakeElizabeth plant had an existing build ing that onl y needed to b e upgraded to properly store the che m ical. 

### Other Key Facility Characteristics

Federal disc harge permit requiremen ts related t o individual treatment facilities can also influence conversion costs. Certain wastewater facilities may be allo wed higher chlorine residuals in trea ted effluent because th e y discharge into less sensitive waters. O ften, these facilities do not have to dechlorinate wastewater, saving the f acility the cost of dechl o rination chemicals, e q uipment, a nd storage. For example, the Philad e lphia-area Southeast and Northeast Wastewater Tr eatment Plants, which treat 90 an d 190 million gallons per d ay, respecti v ely, need onl y to chlorinate water prior to discharging into the Delaware River. Bot h plants were conv erted to delivered sodium hypochlorite—the Southeas t plant in 2006 at an estimated co st of $1.9 mil lion and the Northeast plant in 20 03 a t an estimated co st of $2.6 mil lion. In c ont rast, the Balt imore-area Back River Wastewater Treatment Plant, which t r eats 150 mil lion gallons per day and discharges i n to the ec ol ogicall y sen s itive Chesa p eake Ba y, must chlorinate and dechlorinate its wastewater before discharge. This facilit y converted to delivered sodium hypochlorite in 2004 at a r e p o rted cost of $3.3 million.

Finally, some faciliti e s have redu ced conversion costs in the short term through temporary conversions. For example, th e Metropolitan Sewer District of Greater Cinci nnati decide d to convert its Mill Cree k Wastewater 

### Temporary Conversions

P a g e 17 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tyTreatment Plant, which t r eats 120 mil lion gallons per day, fro m chlorine gas to sodiu m hypochlorite disinfect i on soon after September 11, 2001. According t o the plant manager, by mid-October 2001, the f acility h a d begun disinf ecting with sodium hypochlorite by h ooking up a rented sodium hypochlorite trailer to its disi nfection sys t em at a cost of $25 ,00 0

. By May 2002, the facility had complet e d an int e rim conversion to sodium hypochlorite by purchasi n g and inst al ling two 8,000 gallon out door storage tanks for sodium hypoc hlorite at a c o st of $60, 00 0. According to the plant manager, thi s interim disinfection sys t em is still in use today, t hough the plant intend s to permanently con ver t to deliver ed sodium hypochlorite i n 2008 or 2009 at an estimated cost of $3 million. The plant man ager said the permanent conversion would include an unloadi n g station for sodium hypochlorite deliveries a nd a new storage buildin g for the ch e m ical and related instrumentation. The plant manager said t h e new storage build ing was needed to reduce th e decay of st ored sodium hypochlorit e. The pl ant manager ad ded that the storage buil d ing and ad ditional pipi ng would improve plant safety be c a use it would allow for central storag e and delivery of sodium hypochlorite. Curre ntly, sodiu m hypochlorite deliveries are made at several plan t locations f o r odor control which, according to the plant manager, in crease the odds the chemical may be mishandled and accide ntally mixed with other reacta n t chemicals used at the plant, such as ammonia.

Similarly, the Eastern Water Reclam ation Facilit y, which treats 16 million gallons per day and provides service to Orange County, Florida, con vert e d from chlorine gas to sodi um hypochl or ite disinfection at a co st of $60,0 0 0 in November 2001 throu g h the a dditi on of outdo or storage ta nks and related pumps. According to the pl an t manager, t h e facilit y may consider additional changes in th e future, such as permanent sodium hypochlorite storage or o n -site gener ation.



## Changes in Annual Costs V

a ry W i dely , with Some Facilities Reporting Savings Changes in annual costs related to di sinfection treatment con versions were hard to measure due to lack of data. Many f acilit ies we i n terviewed were unable to provide complete in formation on annual costs related to disinfection before and after converti ng from chlorine gas. Av ailable d a ta show that annual ch emical costs rel a ted to disin f ection increased for facilities that converted t o delivered sodium hypochlorite, because sodium

P a g e 18 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tyhypochlorite costs more than chlorin e gas. 16 Availa ble data also show that electrical costs related to disinfection increased for facilities that converted to on-site gen eration of sodi um hypochl orite or ultraviolet light treatment, however these faciliti e s al so saw large reductions i n chemical costs. Available data also show that increases in annual costs related to disinfection were offset somewhat b y savings in training and regulatory requirements, as several facilities th at converted reported a r e duced n eed for staff time devot e d to complying with the EPA risk management planning th a t was required when the plant used c h lorine gas.

A few facilities were even able to repo rt or project annual savi ngs due to the disinfect ion conv ersion. For exa m ple, the wastewater treatment manager of t h e Columbia Boulevard Treatment Plant, which t r eats 143 million gallons per day and provides wastewater service to Portland, Oregon, estimated that annual costs re lated to di sinfection fell by over $100 ,00 0 aft e r the plant completed a 200 5 con ver sion from chlorine gas to delivered so dium hypochlorite disinfection. 17 According to th e wastewater treatment manager, i n cr eases in disinfection ch e m ical costs for the plant were more than offset b y reductions in electri cal , labor, and training cost s. Electrical p o wer costs fell bec a use t h e plant no l onger had to power chlorine gas evaporators, which heat and help co nvert the pr essurized liquid into g a s before it i s injected in to the waste stream. In contrast, sodium hypochlorite is f e d into the waste stream via less en ergy-intensi ve pumps. Labor and traini ng costs also fell becaus e the plant n o longer had to meet the Occupational Safety and Health Administration’s (OSHA) Process Safety Management of High l y Hazardous Chemicals standard, 18 and risk management and emergen cy re sponse planning costs associated with the use of chlorine gas were eli m inated.

16 In ad dition, s o d i um bis u lfate, t h e dec h l orinati on c h emical oft e n us ed w i th s o dium hypoc hlorite, c o s t s more t h an s u lfur dio x ide, the dec h lorinat i on chemical of ten used with chlorine gas

.

17

According to th e w a s tew ater treatment manag e r, a n n u al cos t s related to dis i nfection fell from $411 ,531 f or t h e operating year c o vering July 1, 2004, to June 30 , 2005 , to $302,998 for the operating year cove ring July 1, 2005 , t o June 30, 2006. The wastewater treatment manager report ed the plant’s a nnual ope ration s and maintenance budget at $12.4 million for t h e most re cently complet e d operating ye ar.

18 OSHA’s P r oces s Safety Manag e ment of High l yHaz ard ous C h emicals s t andard (29 CF R 1910.119) c ont ains requireme n ts for the ma nage ment of haz ards associated with processes

us ing highly ha z ardous c h emicals

.

P a g e 19 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tyIn another example, the South Central Regional Wastewater Treatment and Disposal Plant, which treats 18 million gallons per day f o r customers in the citi es of Delray Be ach and Boy n ton Beach, Florida, pre d icts that it too will achi eve annual s avings once it converts f r om chlorine gas to sodium hypochlorite generated on-s i te, which it anticipates completing in September 2 007. Ac cordi n g to the Ex ecutive Director of the S outh Central Regional Wa stewater Treatment and Dis posal Bo ard, potential disruptions of sodium hypochlorite delivery duri n g hurricane seasons motivated th em to begin gen erating their disinfection chemicals o n -site. The p l ant’s most recent fiscal year op erati n g and main tenance bud get for disinfection is estimated to be roughly $307 ,00 0 for chlorine gas and associat ed costs including eq uipment and maintenanc e, labor, and risk management planning. Po stconversion annual op erating and maintenance costs for disinfection are estimated to fall to $ 205, 000 in th e 20 08 c a len d ar year, primarily due to the susp ension of ch lorine gas p u rchases.

We provided a draft of th is report to EPA for review and comment. In its letter, repro duced in ap pendix II, E P A concurred with the results of the report. EPA’s Water Security Division in the Offi ce of Groun d Water and Drinking Water provided technic a l co mments and clarification s that were incorporate d , as approp riate.

As agreed with your offi ce, unl ess you publicly r e lease th e c ontents of this report earlier, we plan n o further di stribution until 30 days from the report date. At that time, we will send copies of this report to the ap propriate congressional committees; interest ed Members of Congress; the Administ rator, EPA; and other interested parties. We will also make copies availab l e to others on request. In ad dition, the r e port will be avail a ble at no charge o n the GAO Web site at http://www.gao.gov

. 

# Agency Comments and Our Evaluation

P a g e 20 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tyShould you or your staff need further informatio n, please co ntact me at (202) 51 2-38 41 or stephensonj@gao.gov . Contact points for our Offices of Congressional Relations and Public A ffairs may be found on t h e last page of this report. GAO staff who made major contributions to this report are listed in appendix III.

Sincerely yo urs,

John B. Stephenson Director, Natural Resources and Enviro nment

P a g e 21 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tyAppendix I: S c o p e and Method ology 

# Appendix I: Scope and Methodology

To identify t h e costs of preparing vul n erability as sessments and risk management plans, we conducted struct ured telephone interviews with a select sample of large wastewater fac ilities ident i fied as havi ng completed these docu m ents in our March 2006 report. 1 Our March report identified 106 l a rge facilities that reported they had prepared vulnerabili ty assessments or had one underway, and 85 faciliti e s that were required to prepare risk management plans beca us e they cur r ently used chlorine gas as a disinfectant. From these two gr oups, we identified 47 f a cilities that reported that they had prepared vul n erability ass e ssments an d currently use chlorine. Of this universe, we chose a nonprobability sample of 25 facilities to assure geogr aphic disper sion and adequate variati on in size, since these f actors were likely to infl uence th eir costs. 2 We co mpleted structured interviews with 20 of the remaining 25 faciliti e s. We sent an interview schedule in ad vance of ea c h of the inte rviews. We c o mpleted the structured interviews between Nov e mber 2006 and Februar y 20 07. Reported co sts included both actual and estimated costs. For estimated costs, we asked facilit y managers to explain ho w they arrived at these estimates. Reported cost s were not adjusted for inflation.

To identify t h e costs incurred by wastewater facilities in converting from gaseous chl o rine to an alternative di sinfection process, we co nducted structured telephone int e rviews with a nonprobability sample of 26 of the 38 larg e facil i ties identifi ed in the Ma rch report a s having rec e ntly converted o r planning to convert fro m chlorine g a s to an alt e rnative disinfection process. We sent an inter v iew schedu le in ad vance of each of the interviews. We completed the stru ctured interviews between October 2006 and Fe bruary 200 7. Reported c o sts included both actu al and estimated costs. For esti mated cost s, we asked facility managers to explain howthey arrive d at these esti mates. Reported costs were not adjusted for inflation. We also conducted site visit s with so me of the facilities. Where available, we gathered documentation, such as capital plans, from these faciliti e s in order to document conversion costs. We supplemented the cost information we gathered at individu al wastewater

1 GAO, S ecuri ng Wa stewa te r F a ci li ti es: Uti l i t i es Ha ve Ma d e I m

p o rta n t Up gra d es but Furth e r I m

p r

ovements to Key S y s tem Comp o nent s Ma y Be Li mi ted by Costs a n d Oth e r Constra i n ts , G A O-06-390 (Wa s hington, D

. C. : Mar. 31 , 2006 ). We define d lar ge w a s t ew ater facilitie s as those publicly ow ned t r eatmen t works (POTW ) that serve residential populations of 100,000 or g r ea ter.

2 Results from nonproba bility samples cannot be used to make inferences a b out a population, bec a use in a nonprobability sample some elem ents of the popula t ion being studied have no cha n ce or a n unknown chance of being sele cted as pa rt of the sample.

P a g e 22 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tyAppendix I: S c o p e and Method ology

facilities with information obtained at the Environmental Protection Agency, t h e Department of Homeland Security, n ongovernmental organization s , and industry representa tives. We d e termined that reported cost data were sufficientl y reliable to provide usef ul information about the costs for preparing vuln erability assessments, risk management plans, an d conversions from gaseous chlorine and the facto r s that affect these costs.

We conduct e d our work between Au gust 2006 an d March 2007 in accordan ce with general ly ac cepted government auditing sta ndards.

P a g e 23 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tyA ppendix II: C o mme nts from the Environ m ental Prot ection Age n cy 

# Appendix II: Comments from the Environmental Protection Agency

P a g e 24 G A O- 07 -4 80 Wastew ater Fac i li ty Sec u ri tyAppendix III: GAO A Conta c t and Staff

c kno w l edg m e n ts

P a g e 25 G A O- 07 -4 80 

# Appendix III: GAO Contact and Staff Acknowledgments

John B. Stephenson, (202) 512-3841 o r stephensonj@gao.gov

In addition t o the cont ac t named abo ve, Jenny Chanley, Steve Elstein, Nicole Harris, Greg Marchand, Tim Mi nelli, Alison O’Neill, Daniel Semick, and Monica Wolford made key contr i butions to this report.

Wastew ater Fac i li ty Sec u ri ty 

# GAO Contact

Acknowledgments

(360738)

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