Friday, August 2, 2013

CFATS Knowledge Center Update – 08-02-13

Today the folks at ISCD updated their CFATS Knowledge Center web site. The added a link to the August 2013 CFATS Update to the Documentation section, updated the response to FAQ 1407 and add a new FAQ and response, FAQ 1732.

FAQ 1407

You have to look really close to find the change in the response to FAQ 1407. The first link in the answer ( was actually the URL””. That link probably hasn't worked in some time. The new version has changed the actual URL to what is shown on the page.

BTW: This revised FAQ is not mentioned in the ‘Latest News’ section of the CFATS Knowledge Center. I suppose that it really isn’t necessary since this is a change in links not procedure. This makes the change very transparent (it took me some time to track it down). The new FAQ below is appropriately advertised in the ‘Latest News’ section.

FAQ 1732

This new FAQ is:

“How can I determine if my facility’s wastewater treatment operation meets the Chemical Facility Anti-Terrorism Standards (CFATS) exemption under 6 CFR 27.110(b) for the Federal Water Pollution Control Act?”

The authorizing language for the CFATS program (the infamous §550 of the Homeland Security Appropriations Act of 2007 Public Law 109-295) exempts “Treatment Works as defined in section 212 of the Federal Water Pollution Control Act, Public Law 92-500, as amended”. To meet this exemption {codified in 6 CFR §27.110(b)} a treatment works must be permitted under the National Pollutant Discharge Elimination System (NPDES).

This FAQ response explains this exemption and provides a link to an EPA site that provides more information on the NPDES (along with an explanation of the application process). It also goes on to explain that:

“A copy of the facility’s most recent active NPDES permit should be submitted to DHS as proof that the wastewater treatment portion of the facility should be exempt from CFATS.”

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