Water Treatment Facilities and CFATS

As readers of this blog are well aware, the current authorization for CFATS exempts water treatment and wastewater treatment facilities from CFATS coverage. HR 2868 (like HR 5577 last year) will, if passed, remove that exemption. While passage of HR 2868 is certainly not a sure thing this year, it is likely that when a reauthorization bill is passed it will remove the water treatment exemption. The American Water Works Association (AWWA) is already trying to get its membership prepared for that eventuality. On Wednesday, July 29th the AWWA is going to host a webinar; Outlook for Chemical Security — Are You Prepared? It will be held from 1:00 to 2:30 pm EDT and will be open to Association members and non-members alike. The cost will be $75 for members and $125 for nonmembers. Agenda The AWWA notes that the webinar will “provide the Department of Homeland Security's (DHS) observations of lessons learned from the implementation of its current program, and drinking water experts will speak to the concurrent challenge of maintaining Safe Drinking Water Act (SDWA) compliance”. There will be three speakers from the water treatment industry as well as a speaker from DHS. There is some confusion as to who will be representing DHS. The AWWA press release on WaterOnLine.com says that Sue Armstrong (Director, Infrastructure Security Compliance Division) will be the speaker, while the AWWA web page says that it will be her Deputy, Dennis Deziel. They are both very familiar with the CFATS program and should be able to provide some valuable insights. The three industry representatives will be:

Kurt Vause, Manager, Engineering Division, Anchorage Water and Wastewater Utility Paul Swaim, Regional Technology Manager, CH2M Hill Steve Creel, Engineering Practice Leader, American Water

The topics that will be covered will be:

“Chemical Security – Status Report on Legislation & Potential Impacts on Drinking Water Utilities “Key Elements of Chemical Facility Security “Maintaining Public Health Protection While Making Treatment Changes “Making Choices When Selecting Disinfectants in a Security Conscious Environment”

Inherently Safer Technology Water treatment facilities using chlorine gas and/or anhydrous ammonia make up a large portion of the ‘dangerous’ chemical facilities identified by the Center for American Progress report Chemical Security 101. The water treatment industry is well aware that they are a major target of IST proponents, but firmly believe that CAP has over simplified their chlorine gas substitution arguments. This is why two of topics discussed during this webinar will address IST related issues. If I were working the political side of this issue for the AWWA I would encourage member utilities to invite their local Congressman and staff to a free viewing of the webinar. It would be very beneficial for these politicians who will be making IST policy decisions to fully understand what actually goes into making the IST decision at a water treatment facility. Chlorine gas is very dangerous if it is released (either deliberately or accidentally) and there are a variety of alternative technologies that are currently available. Unfortunately, they will not work in all situations. Actually, anyone that has an interest in the IST debate should probably view this webinar. The chemical industry needs to see how argue against the IST proponents using arguments other than ‘bureaucrats just don’t understand chemistry’. IST proponents need to understand that the substitution question is just not as simple as ‘bleach does the same thing as chlorine’. Finally, the committee staff for both the Homeland Security Committees and the Energy and Commerce Committees will probably learn more from this presentation than from all of the testimony any of these committees will hear. One other organization that really needs to pay attention to this IST presentation is DHS. DHS will be the ones that will be enforcing any mandatory IST program. It would do well for the management of the Infrastructure Security Compliance Division to watch this presentation. I know that Armstrong/Deziel will be there, but the entire management team should pay attention. I am pretty sure that the AWWA would be willing to share a copy with the Chemical Security Academy to use as part of the inspector training program. This would be good preparation.