Drinking Water
Experts' Views on How Future Federal Funding Can Best Be Spent to Improve Security Gao ID: GAO-04-29 October 31, 2003After the events of September 11, 2001, Congress appropriated over $100 million to help drinking water systems assess their vulnerabilities to terrorist threats and develop response plans. As the Environmental Protection Agency has suggested, however, significant additional funds may be needed to support the implementation of security upgrades. Therefore, GAO sought experts' views on (1) the key security-related vulnerabilities of drinking water systems; (2) the criteria for determining how federal funds should be allocated among drinking water systems to improve their security, and the methods for distributing those funds; and (3) specific activities the federal government should support to improve drinking water security. GAO conducted a systematic Webbased survey of 43 nationally recognized experts to seek consensus on these key drinking water security issues.
GAO's expert panel cited distribution systems as among the most vulnerable physical components of a drinking water utility, a conclusion also reached by key research organizations. Also cited were the computer systems that manage critical utility functions, treatment chemicals stored on site, and source water supplies. Experts further identified two overarching vulnerabilities: (1) a lack of information individual utilities need to identify their most serious threats; and (2) a lack of redundancy in vital system components, which increases the likelihood that an attack could render an entire utility inoperable. According to over 90 percent of the experts, utilities serving high-density areas deserve at least a high priority for federal funding. Also warranting priority are utilities serving critical assets, such as military bases, national icons, and key academic institutions. Direct federal grants were clearly the most preferred funding mechanism, with over half the experts indicating that such grants would be very effective in distributing funds to recipients. Substantially fewer experts recommended using the Drinking Water State Revolving Fund for security upgrades. When experts were asked to identify specific security-enhancing activities most deserving of federal support, their responses generally fell into three categories: (1) physical and technological upgrades to improve security and research to develop technologies to prevent, detect, or respond to an attack (experts most strongly supported developing near realtime monitoring technologies to quickly detect contaminants in treated drinking water on its way to consumers); (2) education and training to support, among other things, simulation exercises to provide responders with experience in carrying out emergency response plans; specialized training of utility security staff; and multidisciplinary consulting teams to assess utilities' security preparedness and recommend improvements; and (3) strengthening key relationships between water utilities and other agencies that may have key roles in an emergency response, such as public health agencies, law enforcement agencies, and neighboring drinking water systems; this category also includes developing protocols to encourage consistent approaches to detecting and diagnosing threats.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-04-29, Drinking Water: Experts' Views on How Future Federal Funding Can Best Be Spent to Improve Security
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Report to the Committee on Environment and Public Works, U.S. Senate:
October 2003:
DRINKING WATER:
Experts' Views on How Future Federal Funding Can Best Be Spent to
Improve Security:
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-29] GAO-04-29:
GAO Highlights:
Highlights of GAO-04-29, a report to the Committee on Environment and
Public Works, U.S. Senate
Why GAO Did This Study:
After the events of September 11, 2001, Congress appropriated over
$100 million to help drinking water systems assess their
vulnerabilities to terrorist threats and develop response plans. As
the Environmental Protection Agency has suggested, however,
significant additional funds may be needed to support the
implementation of security upgrades. Therefore, GAO sought experts‘
views on (1) the key security-related vulnerabilities of drinking
water systems; (2) the criteria for determining how federal funds
should be allocated among drinking water systems to improve their
security, and the methods for distributing those funds; and (3)
specific activities the federal government should support to improve
drinking water security.
GAO conducted a systematic Web-based survey of 43 nationally
recognized experts to seek consensus on these key drinking water
security issues.
What GAO Found:
GAO‘s expert panel cited distribution systems as among the most
vulnerable physical components of a drinking water utility, a
conclusion also reached by key research organizations. Also cited were
the computer systems that manage critical utility functions, treatment
chemicals stored on site, and source water supplies. Experts further
identified two overarching vulnerabilities: (1) a lack of information
individual utilities need to identify their most serious threats; and
(2) a lack of redundancy in vital system components, which increases
the likelihood that an attack could render an entire utility
inoperable.
According to over 90 percent of the experts, utilities serving high-
density areas deserve at least a high priority for federal funding.
Also warranting priority are utilities serving critical assets, such
as military bases, national icons, and key academic institutions.
Direct federal grants were clearly the most preferred funding
mechanism, with over half the experts indicating that such grants
would be very effective in distributing funds to recipients.
Substantially fewer experts recommended using the Drinking Water State
Revolving Fund for security upgrades.
When experts were asked to identify specific security-enhancing
activities most deserving of federal support, their responses
generally fell into three categories:
* physical and technological upgrades to improve security and research
to develop technologies to prevent, detect, or respond to an attack
(experts most strongly supported developing near real-time monitoring
technologies to quickly detect contaminants in treated drinking water
on its way to consumers);
* education and training to support, among other things, simulation
exercises to provide responders with experience in carrying out
emergency response plans; specialized training of utility security
staff; and multidisciplinary consulting teams to assess utilities‘
security preparedness and recommend improvements; and
strengthening key relationships between water utilities and other
agencies that may have key roles in an emergency response, such as
public health agencies, law enforcement agencies, and neighboring
drinking water systems; this category also includes developing
protocols to encourage consistent approaches to detecting and
diagnosing threats.
What GAO Recommends:
GAO recommends that as EPA refines its efforts to help drinking water
utilities reduce their vulnerability to terrorist attacks, the agency
consider the information in this report to help determine: how best to
allocate security-related federal funds among drinking water
utilities; which methods should be used to distribute the funds; and
what specific security-enhancing activities should be supported.
[End of section]
Contents:
Letter:
Executive Summary:
Purpose:
Background:
Results in Brief:
Principal Findings:
Recommendation for Executive Action:
Agency Comments:
Chapter 1:
Key Components of a Typical Drinking Water System:
The Nation's Drinking Water Systems and the Populations They Serve:
Government and Industry Have Recently Sought to Improve Security:
Efforts to Further Improve Security after the September 11 Attacks:
Potentially Larger Federal Financial Commitment Sought in Future Years:
Objectives, Scope, and Methodology:
Chapter 2:
Vulnerability of Physical Assets:
Overarching Issues Affecting Drinking Water Systems' Security:
Chapter 3:
Strong Agreement That Allocation Decisions Should Consider a Utility's
Vulnerability Assessment:
Key Criteria to Help Determine Which Utilities Should Receive Funding
Priority:
Funding Mechanisms Recommended for Distributing Federal Funds:
Chapter 4:
Activities to Enhance Physical Security and Support Technological
Improvements:
Activities to Improve Education and Training:
Activities to Strengthen Relationships between Agencies and Utilities:
Conclusions:
Recommendation for Executive Action:
Appendixes:
Appendix I: Participating Experts on Drinking Water Security Panel:
Appendix II: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Acknowledgments:
Table:
Table 1: Vulnerability Assessment Completion Deadlines:
Figures:
Figure 1: Key Components of a Typical Drinking Water System:
Figure 2: Key Components of a Typical Drinking Water System:
Figure 3: Number of Drinking Water Systems That Serve Various
Populations:
Figure 4: Key Vulnerabilities Identified As Compromising Drinking Water
Systems' Security:
Figure 5: Experts' Views on Whether Federal Funds Should Be Allocated
Based on Vulnerability Assessment Information:
Figure 6: Experts' Views on Which Types of Water Utilities Should
Receive Priority for Federal Funds:
Figure 7: Recommended Approaches for Distributing Federal Funds:
Figure 8: Activities Identified by Expert Panel to Enhance Physical
Security and Support Technological Improvements:
Figure 9: Activities Identified by Experts to Improve Education and
Training:
Figure 10: Activities Identified by Experts to Strengthen Relationships
between Agencies and Utilities:
Abbreviations:
AMSA: Association of Metropolitan Sewerage Agencies:
AMWA: Association of Metropolitan Water Agencies:
AWWA: American Water Works Association:
BASIC: Bay Area Security Information Collaborative:
CDC: Centers for Disease Control and Prevention:
DWSRF: Drinking Water State Revolving Fund:
EPA: Environmental Protection Agency:
ETV: Environmental Technology Verification:
FBI: Federal Bureau of Investigation:
ICMA: International City/County Management Association:
ISAC: Information Sharing and Analysis Center:
MADIRT: Mutual Aid Disaster and Intervention and Response Teams:
NRWA: National Rural Water Association:
NRDC: Natural Resources Defense Council:
PDD: Presidential Decision Directive:
SCADA: Supervisory Control and Data Acquisition:
VA: vulnerability assessment:
VSAT: Vulnerability Self Assessment Tool:
WEF: Water Environment Federation:
Letter October 31, 2003:
The Honorable James Inhofe:
Chairman:
The Honorable James Jeffords:
Ranking Minority Member Committee on Environment and Public Works:
United States Senate:
As requested, this report discusses the views of nationally recognized
experts on key issues concerning drinking water security, including
serious vulnerabilities of drinking water systems, criteria for
allocating federal funds among systems, and activities that most
warrant federal support to mitigate the risk of terrorism.
As agreed in discussions with your offices, unless you publicly
announce its contents earlier, we plan no further distribution of this
report until 30 days from the date of this letter. We will then send
copies to other appropriate congressional committees, and to the
Administrator of the Environmental Protection Agency. We will also make
copies available to others upon request. In addition, the report will
be available at no charge on the GAO Web site at [Hyperlink, http://
www.gao.gov.]
If you or your staffs have any questions concerning this report, please
call me at (202) 512-3841 or my Assistant Director, Steve Elstein, at
(202) 512-6515. Major contributors to this report are listed in
appendix II.
Signed by;
John B. Stephenson:
Director, Natural Resources and Environment:
[End of section]
Executive Summary:
Purpose:
Drinking water utilities across the country have long been recognized
as potentially vulnerable to terrorist attacks of various types,
including physical disruption, bioterrorism, chemical contamination,
and cyber attack. Damage or destruction by terrorists could disrupt not
only the availability of safe drinking water, but also the delivery of
vital services that depend on these water supplies, such as fire
suppression. Such concerns were greatly amplified by the September 11,
2001, attacks on the World Trade Center and the Pentagon and then by
the discovery of training manuals in Afghanistan detailing how
terrorist trainees could support attacks on drinking water systems.
Congress has since committed significant federal funding to assist
drinking water utilities, with over $100 million appropriated through
fiscal year 2004 to help systems assess their vulnerabilities to
terrorist threats and develop response plans. As significant as these
funds are, it is likely that drinking water utilities will ask the
federal government to provide larger sums to go beyond the planning for
upgrading drinking water security to the actual implementation of
security upgrades. Consequently, as agreed with the Chairman and
Ranking Minority Member of the Senate Committee on Environment and
Public Works, this report identifies (1) the key security-related
vulnerabilities affecting the nation's drinking water systems; (2) the
criteria that should be used to determine how federal funds are
allocated among recipients to improve their security, and the methods
that should be used to distribute these funds; and (3) specific
activities the federal government should support to improve drinking
water security.
To address these issues, GAO conducted a Web-based Delphi survey
process involving 43 nationally recognized experts. The Delphi method
is a systematic process for obtaining individuals' views on a question
or problem of interest and seeking consensus, if possible. In selecting
members for the expert panel, GAO sought individuals who were widely
recognized as possessing expertise on one or more key aspects of
drinking water security. GAO also sought to achieve balance in
representation from key federal agencies, key state or local agencies,
key industry and nonprofit organizations, and water utilities of
varying sizes. A detailed description of GAO's methodology is presented
in chapter 1.
Background:
Drinking water systems vary by size and other factors, but as
illustrated in figure 1, they most typically include a supply source,
treatment facility, and distribution system. A water system's supply
source may be a reservoir, aquifer, or well, or a combination of these
sources. Some systems may also include a dam to help maintain a stable
water level, and aqueducts and transmission pipelines to deliver the
water to a distant treatment plant. The treatment process generally
uses filtration, sedimentation, and other processes to remove
impurities and harmful agents, and disinfection processes such as
chlorination to eliminate biological contaminants. Chemicals used in
these processes, most notably chlorine, are often stored on site at the
treatment plant. Distribution systems comprise water towers, piping
grids, pumps, and other components to deliver treated water from
treatment systems to consumers. Particularly among larger utilities,
distribution systems may contain thousands of miles of pipes and
numerous access points.
Figure 1: Key Components of a Typical Drinking Water System:
[See PDF for image]
[End of figure]
Until the 1990s, emergency planning at drinking water utilities
generally focused on responding to natural disasters and, in some
cases, domestic threats such as vandalism. In the 1990s, however, both
government and industry officials broadened the process to account for
terrorist threats. Among the most significant actions taken was the
issuance in 1998 of Presidential Decision Directive 63 to protect the
nation's critical infrastructure against criminal and terrorist
attacks. The directive designated the Environmental Protection Agency
(EPA) as the lead federal agency to address the water infrastructure
and to work with both public and private organizations to develop
emergency preparedness strategies. EPA, in turn, appointed the
Association of Metropolitan Water Agencies to coordinate the water
industry's role in emergency preparedness. During this time, this
public-private partnership focused primarily on cyber security threats
for the several hundred community water systems that each served over
100,000 persons. The partnership was broadened in 2001 to include both
the drinking water and wastewater sectors, and focused on systems
serving more than 3,300 people.
Efforts to better protect drinking water infrastructure were
accelerated dramatically after the September 11 attacks. EPA and the
drinking water industry launched efforts to share information on
terrorist threats and response strategies. They also undertook
initiatives to develop guidance and training programs to assist
utilities in identifying their systems' vulnerabilities. As a major
step in this regard, EPA supported the development, by American Water
Works Association Research Foundation and Sandia National Laboratories,
of a vulnerability assessment methodology for larger drinking water
utilities. The push for vulnerability assessments was then augmented by
the Public Health Security and Bioterrorism Preparedness and Response
Act of 2002 (Bioterrorism Act). Among other things, the act required
each community water system serving more than 3,300 individuals to
conduct a detailed vulnerability assessment by specified dates in 2003
or 2004, depending on their size.
Results in Brief:
GAO's expert panel identified several key physical assets as the most
seriously vulnerable to terrorist attacks. In general, their
observations were similar to those of major public and private
organizations that have assessed the vulnerability of these systems to
terrorist attacks, including the National Academy of Sciences, Sandia
National Laboratories, and key industry associations. In particular,
when asked to identify what they believed to be among the top
vulnerabilities of drinking water utilities, nearly 75 percent of the
experts (32 of 43) identified the distribution system (one or more
components). More experts identified the distribution system as the top
vulnerability (12 of 43) among the components of the drinking water
system. The other physical assets most frequently cited were source
water supplies, critical information systems, and chemicals stored on
site that are used in the treatment process. Importantly, the experts
also identified overarching vulnerability issues that may involve
multiple system components, or even an entire drinking water system.
Chief among these issues were (1) a lack of redundancy in vital
systems, which increases the likelihood that an attack could render a
system inoperable; and (2) the difficulty many systems face due to a
lack of information on the most serious threats to which they are
exposed.
Key criteria experts cited for determining how federal funds to improve
drinking water security should be allocated included (1) the extent to
which information on utilities' vulnerabilities should be considered in
making allocation decisions; and (2) characteristics of the utilities
themselves, such as size and proximity to population centers.
* About 90 percent of the panelists strongly agreed or somewhat agreed
that allocation decisions should be based on vulnerability assessment
information. Several factors, however, complicate the government's
ability to use utilities' vulnerability assessments for this purpose.
* Panelists favored funding priority for utilities serving high-density
populations, with over 90 percent indicating that they deserve at least
a high priority and over 50 percent indicating they deserve highest
priority. Utilities serving critical assets (such as military bases and
other sensitive government facilities, national icons, and key cultural
or academic institutions) were also recommended as high-priority
recipients, while relatively few experts recommended priority for
utilities serving rural or isolated populations.
When asked to identify the most effective mechanisms of distributing
federal drinking water security funds to recipients, over half the
experts indicated that direct federal grants would be very effective in
doing so. Many also favored including a requirement for matching funds
as a grant condition. Fewer experts recommended using the Drinking
Water State Revolving Fund (DWSRF) for this purpose, particularly to
support upgrades that need to be implemented quickly.
When asked to identify and set priorities for security-enhancing
activities most deserving of federal support, the experts most
frequently identified activities that generally fell into three broad
categories:
* Physical and technological improvements includes both physical
alterations to improve the security of drinking water systems and the
development of technologies to prevent, detect, or respond to an
attack. The need to develop near real-time monitoring technologies,
which would be particularly useful in quickly detecting contaminants in
water that has already left the treatment plant for the consumer, had
by far the strongest support.
* Education and training would be used for both utility and nonutility
personnel responsible for preventing, responding to, and recovering
from an attack. These activities include, among other things, support
for simulation exercises to provide responders with experience in
carrying out utilities' emergency response plans; specialized training
of utility personnel responsible for security; general training of
utility personnel to augment security awareness among all staff; and
multidisciplinary consulting teams to independently analyze utilities'
security preparedness and recommend security-related improvements.
* Strengthening relationships is seen as critical between water
utilities and other agencies (public health agencies, enforcement
agencies, and neighboring utilities, among others) that may have key
roles in an emergency response. This category also includes developing
common protocols to engender a consistent approach among utilities in
detecting and diagnosing threats, and the testing of local emergency
response systems to ensure that participating agencies coordinate their
actions effectively.
Principal Findings:
Key Vulnerabilities:
Nearly 75 percent of the experts on GAO's panel (32 of 43) named the
distribution system (one or more components) as among the top
vulnerabilities of drinking water systems. In fact, 12 of the 32
experts identified the distribution system as the single most important
vulnerability, a considerably greater number than any other element of
the drinking water system. Their explanations most often related to the
accessibility of distribution systems at numerous points. One expert,
for example, cited the difficulty of preventing the introduction of a
contaminant into a distribution system from inside a public building.
Another expert noted that since the water in a distribution system has
already been treated and is in the final stages of being transferred to
consumers, the distribution of a chemical, biological, or radiological
agent in such a manner could be difficult to detect until it is too
late to reverse any harm done.[Footnote 1]
Several other components, though not considered as critical as the
distribution system, were still the subject of concern. Nearly half the
experts (20 of 43) identified source water as among drinking water
systems' top vulnerabilities. One expert noted, for example, that
"because of the vast areas covered by watersheds and reservoirs, it is
difficult to maintain security and prevent intentional or accidental
releases of materials that could have an adverse impact on water
quality." Yet some experts cited factors that mitigate the risks
associated with source water, including (1) that source water typically
involves a large volume of water, which in many cases could dilute the
potency of contaminants; (2) the length of time (days or even weeks)
that it typically takes for source water to reach consumers; and (3)
that source water will go through a treatment process in which many
contaminants are removed. In addition, EPA pointed out that as source
water goes through the treatment process, many contaminants are
removed.
Also cited as a vulnerability were the sophisticated computer systems
that drinking water utilities have come to rely upon to manage key
functions. These Supervisory Control and Data Acquisition (SCADA)
systems allow operators to monitor and control processes throughout
their drinking water systems. Although SCADA systems have improved
water utilities' efficiency and reduced costs, almost half of the
experts on GAO's panel (19 of 43) identified them as among these
utilities' top vulnerabilities. Finally, 13 of the 43 experts
identified treatment chemicals, particularly chlorine used for
disinfection, as among utilities' top vulnerabilities. Experts cited
the inherent danger of storing large cylinders of a chemical on site,
noting that their destruction could release toxic gases in densely
populated areas. Some noted, however, that this risk has been
alleviated by utilities that have chosen to use the more stable liquid
form of chlorine instead of the more vulnerable compressed gas
canisters that have traditionally been used.
Experts also identified overarching issues that compromise the
integrity of multiple physical assets, or even the entire drinking
water system. Among these is the lack of redundancy among vital
systems. Many drinking water systems are "linear"--that is, they have
single transmission lines leading into the treatment facility, single
pumping stations along the system, and often employ a single computer
operating system. They also depend on the electric grid, transportation
systems, and single sources of raw materials (e.g., treatment
chemicals). Many experts expressed concern that problems at any of
these "single points of failure" could render a system inoperable
unless redundant systems are in place. Experts also cited the lack of
sufficient information to understand the most significant threats
confronting individual utilities. According to the American Water Works
Association, assessments of the most credible threats facing a utility
should be based on knowledge of the "threat profile" in its specific
area, including information about past events that could shed light on
future risks. Experts noted, however, that such information has been
difficult for utilities to obtain. One expert suggested that the
intelligence community needs to develop better threat information and
share it with the water sector.
Allocation and Distribution of Federal Funds:
Many drinking water utilities have been financing at least some of
their security upgrades by passing along the costs to their customers
through rate increases. Given the cost of these upgrades, however,
drinking water industry representatives have also sought federal
assistance. GAO asked its expert panel to comment on the factors that
should be considered in allocating federal funds. Specifically, GAO
asked the experts to comment on the following:
* Appropriate use of vulnerability assessment information. About 90
percent of the experts (39 of 43) strongly agreed or somewhat agreed
that funds should be allocated on the basis of vulnerability assessment
information, with some citing the vulnerability assessments (VA)
required by the Bioterrorism Act as the best available source of this
information. Several experts, however, pointed to a number of
complicating factors. Perhaps the most significant constraint is the
Bioterrorism Act's provision precluding the disclosure of any
information that is "derived" from vulnerability assessments submitted
to EPA. It is important to protect sensitive information about each
utility's vulnerabilities from individuals who may then use the
information to harm the utility. The law specifies that only
individuals designated by the EPA Administrator may have access to the
assessments and related information. Yet even those individuals would
face constraints in using the information. They would have difficulty,
for example, in citing vulnerability assessments to support decisions
on allocating security-related funds among utilities, as well as
decisions concerning research priorities and guidance documents. Others
cited an inherent dilemma affecting any effort to set priorities for
funding decisions based on the greatest risk--whatever does not receive
attention becomes the best target.
* Criteria to help determine which utilities should receive funding
priority. According to 93 percent of the experts (40 of 43), utilities
serving high-density population areas should receive a high or highest
priority in funding (55 percent deemed this criterion as the highest
priority). Most shared the view of one expert, who noted that directing
limited resources to protect the greatest number of people is a common
factor when prioritizing funding. Experts also assigned high priority
to utilities serving critical assets, such as national icons
representing the American image, military bases, and key government,
academic, and cultural institutions. At the other end of the spectrum,
only about 5 percent of the experts (2 of 43) stated that utilities
serving rural or isolated populations should receive a high or highest
priority for federal funding. Generally, these panelists commented that
such facilities are least able to afford security enhancements and are
therefore in greatest need of federal support. Importantly, the
relatively small percentage of experts advocating priority for smaller
systems may not fully reflect the concern among many of the experts for
the safety of these utilities. For example, several who supported
higher priority for utilities serving high-density populations
cautioned that while problems at a large utility will put more people
at risk, utilities serving small population areas may be more
vulnerable because of weaker treatment capabilities, fewer highly
trained operators, and more limited resources.
As for effective mechanisms for distributing federal funds, the expert
panelists viewed direct federal grants as most effective, with 86
percent of the experts (37 of 43) indicating that this mechanism would
be somewhat or very effective in allocating federal funds. One expert
cited EPA's recent distribution of direct security-related grant funds
to larger systems to perform their VAs as a successful initiative.
Also, 74 percent cited a matching requirement for such grants as
somewhat or very effective. One expert pointed out that such a
requirement would effectively leverage limited federal dollars, thereby
providing greater incentive to participate. The Drinking Water State
Revolving Fund received somewhat less support, with a number of the
experts cautioning that as a funding mechanism, it is suited more for
longer-term improvements than for those requiring more immediate
attention.
Security-Enhancing Activities That Most Warrant Federal Support:
When experts were asked to identify and set priorities for the
security-enhancing activities most deserving of federal support, their
responses generally fell into three broad categories:
* Enhancing Physical Security and Supporting Technological
Improvements. These activities fell into nine subcategories. Of these,
the development of "near real-time monitoring technologies," capable of
providing near real-time data for a wide array of potentially harmful
water constituents, received far more support for federal funding than
any other subcategory--over 93 percent of the experts (40 of 43) rated
this subcategory as deserving at least a high priority for federal
funding. More significantly, almost 70 percent (30 of 43) rated it
highest priority. These technologies were cited as critical in efforts
to quickly detect contamination events, minimize their impact, and
restore systems after an event has passed. The experts also voiced
strong support for (1) increasing laboratories' capacity to deal with
spikes in demand caused by chemical, biological, or radiological
contamination of water supplies, and (2) "hardening" the physical
assets of drinking water facilities through improvements such as adding
or repairing fences, locks, lighting systems, and cameras and other
surveillance equipment. Some experts, however, cited the limitations
inherent in attempts to comprehensively harden a drinking water
facility's assets. They noted in particular that, unlike nuclear power
or chemical plants, a drinking water system's assets are spread over
large geographic areas, particularly the source water and distribution
systems.
* Improving Education and Training. Over 90 percent of the experts (39
of 43) indicated that improved technical training for security-related
personnel warrants at least a high priority for federal funding, with
over 55 percent (24 of 43) indicating that it deserved highest
priority. To a lesser extent, experts supported general training for
other utility personnel to increase their awareness of security issues.
The panelists also underscored the importance of conducting regional
simulation exercises to test emergency response plans, with more than
88 percent (38 of 43) rating this as a high or highest priority for
federal funding. Such exercises are intended to provide utility and
other personnel with the training and experience needed both to perform
their individual roles in an emergency, and to coordinate these roles
with other responders. Finally, about half the experts assigned at
least a high priority to supporting multidisciplinary consulting teams
("Red Teams"), comprising individuals with a wide array of backgrounds,
to provide independent analyses of utilities' vulnerabilities.
* Strengthening Relationships between Utilities and Other Key
Organizations. Experts cited the need to improve cooperation and
coordination between drinking water utilities and certain other
organizations as key to improving utilities' security. Among the
organizations most often identified as critical to this effort are
public health and law enforcement agencies, which have data that can
help utilities better understand their vulnerabilities and respond to
emergencies. In addition, the experts reported it is valuable for
utilities to develop mutual aid arrangements with neighboring
utilities. Such arrangements sometimes include, for example, the
sharing of back-up power systems or other critical equipment. One
expert described an arrangement in the San Francisco Bay Area--the Bay
Area Security Information Collaborative (BASIC). The collaborative's
eight utilities meet regularly to address security-related topics.
Finally, over 90 percent of the experts (39 of 43) rated the
development of common protocols among drinking water utilities to
monitor drinking water threats as warranting a high or highest priority
for federal funding. Drinking water utilities vary widely in how they
perceive threats and detect contamination, in large part because few
common protocols exist that would help promote a more consistent
approach toward these critical functions. Some experts noted in
particular the need for protocols to guide the identification,
sampling, and analysis of contaminants.
Making Key Security Decisions in the Face of Great Uncertainty:
EPA has identified improved drinking water security as an important
national goal, and has stated in its Strategic Plan on Homeland
Security that as funds are appropriated, federal resources will be
available to help achieve this goal. Yet key judgments about who should
receive priority for federal resources, and how those funds should be
spent, will have to be made in the face of great uncertainty about the
likely target of an attack, the nature of an attack (whether physical,
cyber, chemical, biological, or radiological), and its timing. The
experts on GAO's panel have had to consider these uncertainties in
deriving their own judgments about these issues. Their judgments, while
not unanimous on all matters, suggested a high degree of consensus on a
number of key issues.
GAO recognizes that sensitive funding decisions ultimately must take
into account political, equity, and other considerations. It also
believes such decisions should consider the judgments of the nation's
most experienced individuals on these matters, such as those included
on its panel. It is in this context that GAO offers the results
presented in this report as information for Congress and the
Administration to consider as they seek the best way to use limited
financial resources to reduce the threat to the nation's drinking water
supply.
Recommendation for Executive Action:
GAO recommends that, as EPA refines its efforts to help drinking water
utilities reduce their vulnerability to terrorist attacks, the EPA
Administrator consider the information in this report to help
determine: how best to allocate security-related federal funds among
drinking water utilities, which methods should be used to distribute
the funds, and what specific security-enhancing activities should be
supported.
Agency Comments:
We provided EPA with a draft of this report for review and comment. EPA
did not submit a formal letter but did provide comments from officials
in its Office of Water and its Office of Homeland Security. The
comments from the Office of Water said that the report's results were
"useful and well thought out." EPA's Office of Homeland Security said
that the report "demonstrates a well conceived and executed project,"
and that "a number of the issues raised in the document will be useful
to the agency as it moves forward in the drinking water security
program." Both offices also offered specific technical comments and
suggestions, which have been incorporated.
[End of section]
Chapter 1: Introduction:
Drinking water utilities across the country have long been recognized
as being potentially vulnerable to terrorism of various types,
including physical disruption, bioterrorism, chemical contamination,
and cyber attacks. Damage or destruction by such a terrorist attack
could disrupt not only the availability of safe drinking water to
consumers, but also the delivery of vital services that depend on these
water supplies, such as fire suppression.
These concerns were greatly amplified by the September 11, 2001,
attacks on the World Trade Center and the Pentagon. They were further
amplified in ensuing months when training manuals were discovered in
Afghanistan detailing how terrorist trainees could support attacks on
drinking water systems.
Key Components of a Typical Drinking Water System:
Drinking water systems vary by size and other factors but, as
illustrated in figure 2, most typically include a supply source,
treatment facility, and distribution system.
Figure 2: Key Components of a Typical Drinking Water System:
[See PDF for image]
[End of figure]
As the figure shows, a water system's supply source may include a
reservoir, aquifer, or well, or a combination of these sources. The
supply source may also include a dam as well as aqueducts and
transmission pipelines to deliver the water to a distant treatment
plant. Many water systems rely on groundwater as their primary water
source, but most systems, particularly larger systems, rely on surface
water such as lakes, rivers, and streams.
Water treatment generally uses filtration, flocculation,
sedimentation, and other processes to remove impurities and harmful
agents, and disinfection processes (such as chlorination) to eliminate
biological contaminants. Chemicals used in these processes, most
notably chlorine, are often stored on site.
The distribution system comprises several components, such as water
towers, piping grids, and pumps that deliver treated water from
treatment systems to consumers. A key feature of most distribution
systems is their size: Particularly among larger utilities,
distribution systems may have many thousands of miles of pipes.
The Nation's Drinking Water Systems and the Populations They Serve:
Nationwide, there are more than 160,000 public water systems that
individually serve from as few as 25 people to 1 million people or
more. As figure 3 illustrates, nearly 133,000 of these water systems
serve 500 or fewer people. Only 466 systems serve more than 100,000
people each, but these systems, located primarily in urban areas,
account for nearly half of the total population served.
Figure 3: Number of Drinking Water Systems That Serve Various
Populations:
[See PDF for image]
[End of figure]
Government and Industry Have Recently Sought to Improve Security:
Most drinking water systems long ago developed and maintained emergency
preparedness plans that specified how to notify the public in cases of
emergency, and how to coordinate an emergency response with law
enforcement and other emergency response officials. These plans,
however, paid little attention to the kinds of threats posed by
international terrorist organizations. Rather, they were generally
oriented toward responding to natural disasters and, in some cases,
domestic threats such as vandalism.
Both government and industry officials took a number of steps to
broaden emergency planning in the 1990s. In 1996, the President issued
Executive Order 13010, which listed water supply as one of eight
national infrastructures vital to the security of the United States. In
1997, the President's Commission on Critical Infrastructure Protection,
also established by executive order, issued a report on the
vulnerabilities of the eight categories of infrastructure and
strategies for protecting them. The report identified three attributes
crucial to water supply users: Water must be available on demand, it
must be delivered at sufficient pressure, and it must be safe for
use.[Footnote 2] It warned that susceptibility to contamination and the
loss of flow or pressure can be caused by extensive water main breaks,
the destruction of pumps, or the disruption of power supplies, and
cited these as major vulnerabilities to the nation's water supply
systems.
In response to the report's findings, the President issued Presidential
Decision Directive (PDD) 63 on critical infrastructure protection in
1998. This directive established a public-private partnership to put in
place prevention, response, and recovery measures that would augment
the security of the nation's critical infrastructure components against
criminal or terrorist attacks. The directive designated the
Environmental Protection Agency (EPA) as the lead federal agency to
work with both public and private organizations to protect the nation's
water infrastructure through the development of emergency preparedness
strategies. The agency, in turn, appointed the Association of
Metropolitan Water Agencies, a nonprofit organization representing the
nation's largest utilities, to coordinate the water industry's role in
emergency preparedness.
Initially, this public-private partnership focused on the several
hundred community water systems that each served more than 100,000
persons; the partnership was broadened in 2001 to include systems
serving more than 3,300 people. Moreover, as was the case with other
infrastructure sectors, PDD-63 focused primarily on threats to cyber
security. Specifically, the directive established a goal to develop,
within five years, a Water Information Sharing and Analysis Center
(Water ISAC). The intent of the Water ISAC is, among other things, to
facilitate the dissemination of alerts to drinking water and wastewater
utilities about threats to their systems, to analyze incident
information, and to serve as a secure source of sensitive information.
Efforts to Further Improve Security after the September 11 Attacks:
Efforts to improve protection of drinking water infrastructure were
broadened and accelerated after the September 11 attacks. In
particular, the partnership accelerated efforts to develop the Water
ISAC, which became operational in December 2002. EPA and the drinking
water industry also launched efforts to develop guidance, tools, and
training programs to assist utilities in identifying their systems'
vulnerabilities. As a major step in this regard, EPA supported the
American Water Works Association Research Foundation and the Sandia
National Laboratories to develop a vulnerability assessment (VA)
methodology and training primarily for the largest water systems. EPA
awarded approximately $51 million in fiscal year 2002 for water
security grants to help these water systems complete vulnerability
assessments.
These efforts to better understand drinking water systems'
vulnerabilities were given a significant boost when the President
signed the Public Health Security and Bioterrorism Preparedness and
Response Act in June 2002.[Footnote 3] Among other things, title IV of
the Bioterrorism Act amended the Safe Drinking Water Act to require
each community water system serving more than 3,300 individuals to
conduct "an assessment of the vulnerability of its system to a
terrorist attack or other intentional acts intended to substantially
disrupt the ability of the system to provide a safe and reliable supply
of drinking water." As illustrated in table 1, the act phased in this
requirement according to system size, requiring vulnerability
assessments for all systems serving populations greater than 3,300 to
be completed by June 30, 2004.
Table 1: Vulnerability Assessment Completion Deadlines:
System size (based on population served): 100,000 or more;
Vulnerability assessment completion deadline: March 31, 2003.
System size (based on population served): 50,000 to 99,999;
Vulnerability assessment completion deadline: December 31, 2003.
System size (based on population served): 3,301 to 49,999;
Vulnerability assessment completion deadline: June 30, 2004.
Source: Bioterrorism Act, S 401(a)(2).
[End of table]
EPA guidance calls for these assessments to include: a characterization
of the water system; the identification of possible consequences of
malevolent acts; the critical assets subject to malevolent acts; an
assessment of the threat of malevolent acts; an evaluation of
countermeasures; and a plan for risk reduction. The Bioterrorism Act
also requires each community water system serving more than 3,300
individuals to prepare or revise an emergency response plan
incorporating the results of the VA no later than 6 months after
completing the assessment. In addition, it directed EPA to provide
guidance to smaller systems on how to conduct vulnerability
assessments, prepare emergency response plans, and address threats.
Potentially Larger Federal Financial Commitment Sought in Future Years:
While significant federal funds have been committed to assist utilities
in developing vulnerability assessments and emergency response plans,
the likelihood exists that Congress and the Administration will be
asked to provide much larger sums to go beyond planning for upgrading
drinking water security to the actual implementation of security
upgrades. By most accounts, it will cost billions of dollars to upgrade
security for drinking water utilities. The American Water Works
Association, for example, estimates that it will cost $1.6 billion for
initial security upgrades at all drinking water utilities.
Objectives, Scope, and Methodology:
As requested in a June 9, 2003, letter to the Comptroller General from
the Chairman and Ranking Minority Member of the Senate Committee on
Environment and Public Works, this report identifies experts' views on
the following questions:
* What are the key security-related vulnerabilities affecting the
nation's drinking water systems?
* What are the criteria that should be used to determine how federal
funds are allocated among recipients to improve drinking water
security, and how should the funds be distributed?
* What specific activities should the federal government support to
improve drinking water security?
To obtain information on these three questions, we conducted a three-
phase Web-based survey of 43 experts on drinking water security. We
identified these experts from a list of more than 50 widely recognized
experts in one or more key aspects of drinking water security. In
compiling this initial list, we also sought to achieve balance in terms
of area of expertise (i.e., state and local emergency response,
engineering, epidemiology, public policy, security and defense,
drinking water treatment, risk assessment and modeling, law
enforcement, water infrastructure, resource economics, bioterrorism,
public health, and emergency and crisis management).
In addition, we attempted to achieve participation by experts from (1)
key federal organizations (e.g., Argonne National Laboratory, Centers
for Disease Control and Prevention, Department of Defense, Department
of the Interior's Bureau of Reclamation, Environmental Protection
Agency, and Federal Bureau of Investigation; (2) key state and local
agencies, including health departments and environmental protection
departments; and (3) key industry and nonprofit organizations such as
the American Water Works Association (AWWA), RAND Corporation, Natural
Resources Defense Council (NRDC), and National Rural Water Association
(NRWA); and (4) water utilities serving populations of varying sizes.
Of the 50 experts we contacted, 43 agreed to participate and complete
all three phases of our survey. A list of the 43 participants in this
study is included in appendix I.
To obtain information from the expert panel, we employed a modified
version of the Delphi method. The Delphi method is a systematic process
for obtaining individuals' views and seeking consensus among them, if
possible, on a question or problem of interest. Since first developed
by the RAND Corporation in the 1950s, the Delphi method has generally
been implemented using face-to-face group discussions. For this study,
however, we administered the method through the Internet. We used this
approach, in part, to eliminate the potential bias associated with
group discussions. These biasing effects include the dominance of
individuals and group pressure for conformity. Moreover, by creating a
virtual panel, we were able to include many more experts than possible
with a live panel, which allowed us to obtain a broad range of
opinions.
For each phase in the Delphi method, we posted a questionnaire on GAO's
survey Web site addressing the issues of our study. Panel members were
notified of the availability of the questionnaire with an e-mail
message. The e-mail message contained a unique user name and password
that allowed each respondent to log on and fill out a questionnaire but
did not allow respondents access to the questionnaires of others.
In the first questionnaire, we asked several broad questions, such as,
"What strategies or methods should the federal government consider for
allocating funds to water utilities (or other relevant entities) so as
to ensure that allocation achieves the greatest mitigation of risk per
dollar?" We pretested these questions with officials from the water
utility industry, a nonprofit research group, and academe. Participants
were invited to provide detailed narrative explanations for their
responses.
In the case of two key questions, we sought to identify both additional
detail and the degree to which consensus could be achieved among the
experts on our panel. We used experts' responses to phase 1 questions
to develop more detailed questions for phase 2 about specific actions
or strategies regarding two overall issues: how federal funds could
best be allocated among potential recipients to achieve the most
security improvements per dollar, and which specific activities are
most deserving of federal support. This second questionnaire included
closed-ended questions that allowed panelists to rate the relative
priority or effectiveness of these activities. It also provided experts
with the opportunity to comment on their ratings.
During the third phase of the Delphi process, we provided the
aggregated results from the ratings made in the second questionnaire.
We also provided panel members with the individual ratings they had
made in response to each question. We then invited panel members to use
this information as a basis for changing their answers if they desired.
In addition to the information obtained from our expert panel, we
obtained documentation from representatives of professional
organizations, such as the National Academy of Sciences, RAND
Corporation, American Water Works Association Research Foundation, and
Association of Metropolitan Water Agencies. We also held several
interviews with officials at EPA on the agency's drinking water
security programs. During our interviews, we asked officials to provide
information on program operations, policies, guidance, and funding
levels. We also received training on the Vulnerability Self Assessment
Tool supported by the Association of Metropolitan Sewerage Agencies,
and attended specialized conferences addressing drinking water security
by the Water Environment Federation and other organizations.
We conducted our work from July 2002 through August 2003 in accordance
with generally accepted government auditing standards.
[End of section]
Chapter 2: Experts Identified Key Vulnerabilities That Could Compromise
Drinking Water Systems' Security:
Our panel of experts identified several key physical assets of drinking
water systems as the most vulnerable to intentional attack. In general,
their observations were similar to those of public and private
organizations that have assessed the vulnerability of these systems to
terrorist attacks, including the National Academy of Sciences, Sandia
National Laboratories, and key industry associations. In particular,
nearly 75 percent of the experts (32 of 43) identified the distribution
system or its components as among the top vulnerabilities of drinking
water systems.
In addition to identifying systems' physical assets, experts also
identified overarching issues compromising how well these assets are
protected. Chief among these issues are (1) a lack of redundancy in
vital systems, which increases the likelihood that an attack could
render a system inoperable; and (2) the difficulty many systems face in
understanding the nature of the threats to which they are exposed.
Vulnerability of Physical Assets:
As illustrated in figure 4, when asked to identify what they believed
to be the top vulnerabilities of drinking water utilities, the four
physical assets most frequently identified by the panel were: (1) the
distribution system, (2) source water supplies, (3) Supervisory Control
and Data Acquisition (SCADA) and other information systems, and (4)
chemicals stored on site that are used to treat source water.
Figure 4: Key Vulnerabilities Identified As Compromising Drinking Water
Systems' Security:
[See PDF for image]
[End of figure]
Experts Identified Distribution Systems as Most Vulnerable:
The distribution system delivers drinking water primarily through a
network of underground pipes to homes, businesses, and other customers.
While the distribution systems of small drinking water utilities may be
relatively simple, larger systems serving major metropolitan areas can
be extremely complex. One such system, for example, measures water use
through 670,000 metered service connections, and distributes treated
water through nearly 7,100 miles of water mains that range from 2
inches to 10 feet in diameter. In addition to these pipelines and
connections, other key distribution system components typically include
numerous pumping stations, treated water storage tanks, and fire
hydrants.
Nearly 75 percent, or 32 of 43 of the experts on our panel, named one
or more components of the distribution system as among the top
vulnerabilities of drinking water systems. In fact, 12 of the 32
experts identified distribution systems as the most critical
vulnerability, a considerably greater number than any other system
component. The explanations they offered most often related to the
accessibility of distribution systems at numerous points. One expert,
for example, cited the difficulty in preventing the introduction of a
contaminant into the distribution system from inside a building
"regardless of how much time, money, or effort we spend protecting
public facilities." Experts also noted that since the water in the
distribution system has already been treated and is in the final stages
of being transferred to the consumer, the distribution of a chemical,
biological, or radiological agent in such a manner would be virtually
undetectable until it has affected consumers. An EPA official added,
however, that distribution systems generally carry disinfectant
residuals that can counteract the potentially harmful effects of
contaminants. This official further stated that routine monitoring
performed in drinking water systems might provide some advance warning.
While research on the fate and transport of contaminants within water
treatment plants and distribution systems is under way, according to
one expert, limited technologies are readily available that can detect
a wide range of contaminants once treated water is released through the
distribution system for public use.
Source Water:
Nearly half the experts (20 of 43) identified source water as among
drinking water systems' top vulnerabilities. Drinking water may come
from surface water, groundwater, or both. The water cycle begins with
rainwater and snowmelt that collect in lakes and rivers and that, in
many cases, interact with groundwater. Large urban water supply systems
tend to rely on surface water sources (rivers, lakes, and reservoirs),
while smaller systems tend to rely more heavily on groundwater.
One expert raised concerns about the inherent challenge in protecting
source waters, noting, "Because of the vast areas covered by watersheds
and reservoirs, it is difficult to maintain security and prevent
intentional or accidental releases of materials that could have an
adverse impact on water quality." Other experts raised additional
concerns about the vulnerability of water intake transmission lines,
which regulate the transfer of water supplies to the systems' treatment
plants.
Panel experts and others, however, have stated that concerns over
source water contamination are mitigated somewhat by a number of
factors. First, a large volume of water generally exists at the source,
which in many cases can dilute the potency of agents introduced at this
stage of the drinking water production process. Second, unlike treated
water in the distribution system, it generally takes many days before
source water reaches the consumer, making it more likely that a
contamination problem at this early stage of the drinking water
production process can be detected or treated before consumers are
affected. One utility official noted, for example, that his water
system's surface water supplies travel hundreds of miles before
reaching the treatment plant. Water that was contaminated at the source
would take between 10 days and 6 months to reach the treatment plant,
depending on the source, providing ample opportunity for detection and
adjustments to protect public health.
SCADA Systems:
To improve their efficiency and reduce operating costs, drinking water
utilities (particularly larger utilities) have come to rely
increasingly on sophisticated computer systems to manage their
facilities' key functions. These Supervisory Control and Data
Acquisition (SCADA) systems allow utility operators to monitor and
control processes throughout their systems, even at remote facilities.
SCADA systems communicate with other control facilities and provide the
necessary data to ensure that the right chemicals are mixed in the
right amounts for treatment processes, and that water pressure and flow
are at proper levels. SCADA systems may also monitor activity along
water transmission pipelines, detecting breaks or pressure loss.
While SCADA systems help utilities manage their operations, they can
create an additional opportunity for sabotage. Almost half of the
experts on our panel (19 of 43) identified SCADA and other information
systems as being among the top vulnerabilities of drinking water
systems (although only one expert ranked it as the top vulnerability).
Experts' concerns include cyber attacks on SCADA systems from a remote
location, which could, for example, release harmful amounts of water
treatment chemicals (such as chlorine) into treated water.
Treatment Chemicals:
The types and amounts of treatment chemicals applied by a drinking
water facility to its influent varies, depending on the type of source
water (for example, surface water or groundwater) as well as its
quality. Because surface water systems are exposed to direct wet-
weather runoff and to atmospheric forces, they generally require more
treatment under federal and state regulations than do groundwater
systems.[Footnote 4]
Water suppliers use a variety of treatment processes to remove
contaminants from drinking water. The most commonly used treatment
processes for surface water include filtration to remove particles such
as clays, silts, and microorganisms; flocculation and sedimentation to
consolidate small particles into larger particles that can be more
easily removed from the water; and disinfection to eliminate bacteria
and other microbiological contaminants.
Treatment chemicals are used in some of these processes. The
disinfection process is particularly noteworthy in this regard;
chlorine, chloramines, or chlorine dioxide not only are used at the
treatment plant, but also are frequently present in some form in the
pipes that distribute water to homes and businesses.
Thirteen of the 43 experts identified treatment chemicals as among the
top vulnerabilities of drinking water systems, second only to the
distribution system. Experts commented that it was inherently dangerous
to use and store large cylinders of gaseous chlorine, noting that the
destruction of these storage containers could release toxic chlorine
gas in densely populated areas. Some of these experts noted, however,
that this risk is being alleviated as utilities increasingly use the
more stable liquid form of chlorine instead of the more vulnerable
large compressed-gas chlorine canisters that have traditionally been
used. In addition to the risks of chemical sabotage at the treatment
facility, one expert cited the risk of using tainted treatment
chemicals at the facility. According to another expert, "If these
treatment chemicals have been purposely contaminated . . . prior to
delivery, every precautionary measure taken by the water system has
been bypassed.":
Overarching Issues Affecting Drinking Water Systems' Security:
In addition to the vulnerabilities associated with specific water
system components, experts identified several overarching issues that
compromise the integrity of physical assets and the drinking water
system in its entirety. Chief among these issues are (1) the lack of
redundancy among vital systems, and (2) the difficulty many operators
face due to a lack of information on the most serious threats to which
their systems might be exposed.
Lack of Redundancy among Vital Systems:
Drinking water systems are generally "linear" in nature in that they
have single transmission lines leading into the treatment facility,
single pumping stations along the system, and a single computer
operating system. Furthermore, drinking water systems may rely on
outside sources of power and communications, and depend on the
transportation sector for the delivery of supplies, often from a
limited number of suppliers. If any of these external sources were
impaired or destroyed, the entire system could be compromised. Under
these circumstances, any "single point of failure" could render a
system inoperable unless there are redundant systems in place.
Several experts reflected concerns relating to a single point of
failure as a vulnerability. For example, according to one expert, the
destruction of a single physical component of the system, such as a
single water transmission line into the treatment facility, could
render the entire system inoperable. Moreover, she noted, a system that
depends on pumps can be completely put out of service if its electrical
supply were interrupted. Echoing this point, another expert commented,
"Experience with Y2K planning efforts revealed one of the critical
interdependencies nearly all water utilities have is with the
electrical power supply system. Disruption of power supply could have
significant impacts on source, treatment and distribution
systems."[Footnote 5]
According to one expert, efforts are needed to add redundancy to
drinking water systems and to mitigate systems' near-total reliance on
power suppliers, communications systems, and the transportation sector.
However, such efforts to duplicate major system components would be
expensive and could conflict with the systems' goals of controlling
rate increases. To address the problem, some experts advocated the
creation of utility consortia, such as the Bay Area Security
Information Collaborative (BASIC) and the Mutual Aid Disaster
Intervention Response Teams (MADIRT), through which regional utilities
share resources in the event of a disaster.
Insufficient Information to Understand the Most Significant Threats:
A number of experts commented that it is impossible to accurately
identify a utility's most significant vulnerabilities unless the
utility has reliable intelligence regarding its most significant
threats. Threats include the type of adversary (a casual vandal, an
anonymous hacker, a disgruntled employee, or a dedicated terrorist) as
well as the mode of attack (physical, psychological, chemical,
biological, or radiological). According to the American Water Works
Association, a utility's assessment of its most credible threats should
be based on knowledge of the threat profile in its specific area,
including such information as past events, that could shed light on
future risks. These assessments often require information from outside
sources, such as local law enforcement officials.
Many experts on our panel noted, however, that such information has not
been easy for utilities to obtain. The following examples illustrate
some of the difficulties utilities have regarding threats:
* According to one expert, "The utility community has very little
specific and useful information on the threat posed to this industry.
This represents a real vulnerability since it makes it harder to judge
where resources might do the most good." Furthermore, "an ongoing
working relationship with groups (mostly federal) that do this type of
analysis could prove extremely valuable in determining how to allocate
the limited resources available.":
* Utilities may be preoccupied with unsubstantiated threats, according
to another expert. She noted, "There are many very vulnerable areas,
but the terrorists may not be technically able to target them, or they
may not be interested.":
* Another expert stated that utilities need to better understand "how
the threats may . . . exploit utility operations and infrastructure,"
through such things as simulation exercises.
* One expert suggested that the intelligence community provide better
threat information and share it with the water sector through the Water
ISAC.
Since the consequences associated with various potential threats are
markedly different, EPA guidance suggests that the threats be analyzed
in the system's vulnerability assessments.[Footnote 6] Some
vulnerability assessment methodologies refer to the threats selected
for consideration as a Design Basis Threat. Because there is no single
Design Basis Threat[Footnote 7] for all water systems in the United
States, water systems often have a difficult time identifying their
unique threat profile. As a result, EPA developed a Baseline Threat
Information document for systems serving populations greater than 3,300
to help assess the most likely threats to their systems.
[End of section]
Chapter 3: Experts' Views on the Allocation and Distribution of Federal
Funds:
Many drinking water utilities have been financing at least some of
their security upgrades by passing along the costs to their customers
through rate increases. Given the cost of these upgrades, however, the
utility industry is also asking that the taxpayer shoulder some of the
burden through the congressional appropriations process. Should
Congress and the Administration agree to this request, they will need
to address key issues concerning who should receive the funds and how
they should be distributed. With this in mind, we asked our panel of
experts to focus on several key questions: (1) To what extent should
utilities' vulnerability and risk assessment information be considered
in making allocation decisions? (2) What types of utilities should
receive funding priority? and (3) What are the most effective
mechanisms for directing these funds to recipients? Overall, we found a
high degree of consensus on the following:
* Vulnerability assessment information should have a substantial
bearing on which utilities receive priority for federal funds to
improve security. Several factors, however, complicate the government's
ability to use a primary source of this information--the vulnerability
assessments (VA) required of utilities under the Bioterrorism Act. The
major complication is the law's prohibition against disclosing
information derived from these assessments submitted to EPA.
* Almost all of the experts gave utilities serving high-density
populations a high or highest funding priority. Utilities serving
critical assets (such as military bases and other sensitive government
facilities, national icons, and key cultural or academic institutions)
were also recommended as high-priority recipients, while relatively few
experts recommended a high or highest priority for utilities serving
rural or isolated populations.
* Direct federal grants are the most favored funding mechanism, with
many experts indicating that such grants should include a requirement
for matching funds from the recipient. Relatively fewer experts
recommended the use of the Drinking Water State Revolving Fund,
particularly for upgrades to be implemented in the near term.
Strong Agreement That Allocation Decisions Should Consider a Utility's
Vulnerability Assessment:
As noted in chapter 1, the Bioterrorism Act requires that vulnerability
assessments be prepared by all community water systems serving more
than 3,300 individuals. EPA guidance on preparing these assessments
states that the assessments should (1) characterize the water system,
including its mission and objectives; (2) identify and rank the
possible consequences of malevolent acts; (3) determine the critical
assets subject to malevolent acts; (4) assess the threat of malevolent
acts; (5) evaluate existing countermeasures; and (6) analyze risk and
develop a plan for reducing risk and addressing critical priorities
first.
In considering whether it is appropriate to use vulnerability and risk
assessment information when making federal funding decisions, about 90
percent of the experts on our panel (39 of 43) strongly agreed or
somewhat agreed that funds should be allocated on the basis of VA
information. Some experts cited the vulnerability assessments required
by the Bioterrorism Act as the best available information about the
current condition of our security infrastructure for drinking water
(see fig. 5).
Figure 5: Experts' Views on Whether Federal Funds Should Be Allocated
Based on Vulnerability Assessment Information:
[See PDF for image]
[End of figure]
It may not be a straightforward matter, however, to use this
information in making such decisions. Several experts pointed to a
number of complicating factors. One pointed out that "vulnerability
assessment (VA) tools were not set up for the purpose of identifying
and prioritizing capital improvement needs for EPA or other federal
agencies." He added, "Using the VAs would require a high degree of
interpretation and judgment on someone's part . . ., using a tool that
was not designed to clearly delineate capital construction needs."
Another expert noted similarly that "since there is no written guidance
for threat analysis, there will have to be some method to rank relative
threats among different areas." In addition, one expert pointed out an
inherent dilemma affecting any effort to prioritize
funding decisions based on the greatest risk--whatever does not receive
attention becomes the best target.[Footnote 8]
In addition, a provision of the Bioterrorism Act precludes disclosing
all information "derived" from the vulnerability assessments submitted
to EPA. The provision's intent was to protect sensitive information
about utilities' vulnerabilities from falling into the hands of
individuals who seek to harm the utility. The act therefore specifies
that only individuals designated by the EPA Administrator may have
access to the copies of the VA and information contained in or derived
from it. It further specifies that the information must remain
protected at all times.
Thus, while some EPA officials may have access to the information, the
requirement limits how the agency may use that information. EPA would
have difficulty, for example, in citing vulnerability assessment
findings to support decisions or recommendations on allocating
security-related funds among utilities, as well as decisions concerning
research priorities or guidance documents.
To compensate somewhat for these limitations, the American Water Works
Association Research Foundation has initiated a project in which
consultants and trainers, who have conducted multiple assessments, are
seeking to identify lessons learned from the vulnerability assessments
done to date. According to EPA's draft Water Security Research and
Technical Support Implementation Plan, this project is designed to
obtain a more accurate picture of the major vulnerabilities that are
generally facing the nation's drinking water systems and to share that
understanding with interested parties.[Footnote 9] EPA and the Research
Foundation plan to use the results of this project to identify high
priority needs and concerns that could likely be best addressed by EPA,
the research community, or both. This project is scheduled for
completion in mid-2004.
Key Criteria to Help Determine Which Utilities Should Receive Funding
Priority:
The experts identified several characteristics of utilities that should
be used to set funding priorities. The most frequently identified were
utilities (1) serving high-density populations; (2) serving sensitive
or critical assets, such as military bases, academic institutions or
icons of American culture; (3) in proximity to population centers
(whether they serve these population centers or serve outlying areas);
and (4) serving rural or isolated populations, such as small systems
with less sophisticated water systems (see fig. 6).
Figure 6: Experts' Views on Which Types of Water Utilities Should
Receive Priority for Federal Funds:
[See PDF for image]
[End of figure]
Utilities Serving High-Density Populations. Approximately 93 percent of
the experts (40 of 43) gave high or highest priority to funding
utilities serving high-density populations. As one expert commented,
directing limited resources to protect the greatest number of people is
a common strategy when setting priorities. Most experts shared this
view, including one who noted the "population served would probably
lead to economies of scale--you can protect the most people by spending
monies at the large systems." This expert and others, however, though
supportive of funding priority for utilities serving high-density
populations, cautioned that while targeting high-density populations
may be the most equitable to the entire country, it might not allocate
enough to small systems.
Utilities Serving Sensitive or Critical Assets. Seventy-seven percent
of the experts (33 of 43) indicated that utilities serving sensitive or
critical assets should receive a high or highest priority for federal
funding. Experts identified such utilities as those servicing national
icons that represent the American image, those serving military bases,
or those serving sensitive government, academic and cultural
institutions. In addition, according to one expert, utilities in areas
typically receiving extensive media coverage, or that serve venues
where large groups gather, may be of interest to terrorists.
Utilities in Proximity to Population Centers. Twenty-eight percent of
the experts (12 of 43) cited the proximity of a given utility to a
major population center as at least a high funding priority. While most
utilities close to population centers would be expected to serve the
population center in which they are located (hence, this third
criterion would overlap with the first criterion above--utilities
serving high-density populations), some experts pointed out that this
is not always the case. Exceptions cited include suburban utilities
that may serve communities or their major metropolitan areas. Several
particularly noted that the risks associated with an airborne release
of chlorine gas elevated their funding priority for this criterion.
Utilities Serving Rural or Isolated Populations. About 5 percent of the
experts (2 of 43) identified utilities serving rural or isolated
populations as at least a high priority for federal funding. Generally,
these panelists commented that such facilities are least able to afford
security enhancements, and therefore most need federal support. One
expert, for example, stated that in light of their financial
constraints, "smaller utilities do the cheapest thing possible, which
means you do a quick checklist and then forget about it." He added that
because these smaller systems do not have enough staff to do a
comprehensive assessment, they need funding to either hire additional
staff or to contract for outside expertise.
Importantly, the relatively small percentage of experts supporting
funding for rural utilities may not fully reflect the concern many
panel experts have for the safety of these utilities. For example,
several who supported higher priority for utilities serving high-
density populations cautioned that, while problems at a large utility
will put more people at risk, utilities serving small population areas
may be more vulnerable because of weaker treatment capabilities, fewer
highly trained operators, and more limited resources. Another expert
added that most waterborne disease outbreaks have occurred in the
systems of smaller utilities.
Funding Mechanisms Recommended for Distributing Federal Funds:
We also asked the expert panel to comment on how federal funds should
be distributed to recipients. Nearly 90 percent said that direct
federal grants to utilities would be a somewhat or very effective means
of distributing funds to support security improvements. The experts
also showed strong support for grants in which some type of match is
required of recipients. Figure 7 shows their views on these and other
funding mechanisms.
Figure 7: Recommended Approaches for Distributing Federal Funds:
[See PDF for image]
[End of figure]
Direct Federal Grants:
Eighty-six percent of the experts (37 of 43) indicated that direct
federal grants to the utility would be somewhat or very effective in
allocating federal funds. Federal grants typically provide funding for
fixed or known periods for specific projects and often have associated
terms and conditions. One expert cited EPA's recent efforts to quickly
distribute security-related grant funds to systems serving over 100,000
people (mentioned earlier in this chapter), noting, "By far the most
successful funding program I have seen to date was the large water
system Vulnerability Assessment Grant program directed through the
EPA."[Footnote 10]
Many experts commented that direct grants could be particularly useful
in quickly addressing lower-cost and more obvious fixes, such as adding
gates and security cameras. Two others said that with some of these
shorter-term items addressed, it may then be appropriate to deal with
more complex issues that require longer-term fixes, such as new
buildings and security-oriented building design. Another expert added
that the use of direct EPA grants could help ensure proper use of the
funds, noting, "Direct EPA grants to water systems should be made
available and should carry a requirement to use Sandia-like
methodologies and concepts," and that "the use of [these tools] will
lead water systems to develop cost-effective risk reduction through
effective physical systems, better policies, procedures and training
and through creative consequence mitigation.":
Matching Grants:
Many favoring direct grants were among those who said that a matching
requirement for such a grant would be desirable for distributing future
federal funds. Specifically, 74 percent of the experts (32 of 43) said
that federal grants with a matching requirement would be somewhat or
very effective in distributing federal funds. One expert pointed out
that such a requirement would effectively leverage limited federal
dollars. Another agreed, noting that such a cost-sharing approach would
offer "a big incentive" in getting utilities to devote their own funds
to enhance their security. The expert cautioned, however, that the
required match would have to be low enough to make the grant
attractive, suggesting a maximum of 50 percent.
Another suggested a strategy to get the most out of a matching grant
program. One, for example, said that participating utilities should be
provided with some initial matching funds to get started, and that
additional funds would then be contingent upon how effective or
creative they were in using the first round of funding.
Funds Distributed by an Independent Agency:
Sixty-five percent of the experts (28 of 43) indicated that it would be
somewhat or very effective to have federal funds distributed through an
independent agency. Experts generally characterized an independent
agency as, among other things, being independent of regulatory decision
making, and not bound by traditional points of view.
Several experts elaborated on the desirability of such an independent
entity to allocate security-related funds. One expert, for example,
favored moving the responsibility for allocating funds to a
disinterested third party--one with no infrastructure to support or
hidden agenda but instead with strong decision analysis and consensus
building expertise. Another expert suggested that federal funding be
"leveraged with industry funding through an organization like [the
American Water Works Association Research Foundation.]" The expert
further stated that the use of an organization like the Research
Foundation is important because it has a demonstrably effective two-way
communication with the end users, namely the U.S. water utility
industries; the Research Foundation can adequately represent the needs
of industry to the research community as well as inform the industry of
important national-level research findings that will influence their
day-to-day operations. He indicated that communication between the
water utilities and such an independent agency would be superior to
communication between the utilities and EPA, noting, "Although [EPA] is
legitimately engaged in research, [it] is also perceived as an agency
with regulatory authority and is thus viewed somewhat circumspectly by
industry as a whole.":
Drinking Water State Revolving Fund:
About 51 percent of the experts (22 of 43) indicated that the Drinking
Water State Revolving Fund (DWSRF) would be somewhat or very effective
in distributing federal funds. The DWSRF program provides federal grant
funds to states, which in turn allow the states to help public water
systems in their efforts to protect public health and ensure their
compliance with the Safe Drinking Water Act. States may use DWSRF funds
to provide loans to public water systems, and may reserve a portion of
their grants to finance other projects that protect sources of drinking
water and enhance the technical, financial, and managerial capacity of
public water systems. In particular, under EPA's November 2001
guidance, states may use DWSRF assistance to help systems complete both
vulnerability assessments, and contingency and emergency response
plans.[Footnote 11] Many types of security-related infrastructure
improvements to ensure security are also eligible for DWSRF funding, as
specified in the EPA guidance.
According to one expert who favored existing grant and loan programs
like the DWSRF for enhancing security, continuing to support the
training and assistance efforts of lead state agencies "is the most
beneficial activity the federal government could play to encourage
water utilities across the country to address security related issues
in a comprehensive and cost-effective manner." Another shared this
view, explaining that states are well-positioned to help manage the
process, and that they "must approve system upgrades anyway." This
expert also suggested that by using the state-administered DWSRF,
"states could track this information and report it on a regular basis
to EPA and Congress," thereby documenting what has been accomplished
and what still needs to be done.
One expert cautioned, however, that the DWSRF would be effective only
if a process were established that separated funding for security-
related needs from other infrastructure needs. Reflecting the concern
expressed by many others about the timeliness of distributing funds
through the DWSRF, this individual commented that the current DWSRF
process is too bureaucratic and requires too many hurdles for it to be
an expeditious means for providing funds.
Tax-Based Incentives:
About 28 percent of the experts (12 of 43) reported that tax-based
incentives would be somewhat effective in encouraging water utilities-
-specifically privately owned utilities--to invest in security
improvements. The inducements offered in these programs may include tax
credits, property tax exemptions or abatements, and sales and use tax
exemptions.
According to one expert, tax incentives could increase the efficiency
of dollars spent on water security, generating new ideas and
approaches. Furthermore, by offering additional funds for creative and
cost-effective solutions, these ideas could become best practices and
shared with others. Finally, he commented, "If allocations were phased
and secondary funds were based upon how well the first funds were
spent, there would be incentive to spend the first funds wisely."
Another expert suggested that the provision of financial or other tax
incentives to utilities should be contingent upon evidence that they
have improved their security as defined by a standard set of
measurements.
[End of section]
Chapter 4: Activities Experts Identified As Most Deserving of Federal
Support:
When experts were asked to identify and rate the specific security-
enhancing activities most deserving of federal support, the activities
experts most frequently identified fell into three broad categories:
* Physical and technological improvements. These improvements include
altering drinking water systems to improve physical security, and
conducting research and development on technologies to prevent, detect,
or respond to an attack. Experts most strongly supported near real-time
monitoring technologies, which they considered particularly useful in
quickly detecting contaminants in water that has left the treatment
plant for consumers.
* Education and training. This category includes, among other things,
supporting simulation exercises to provide responders with experience
in carrying out utilities' emergency response plans; specialized
training of utility personnel charged with security and general
training to improve the security awareness of their staffs; and
multidisciplinary teams that can provide independent analysis of
utilities' security preparedness and recommend security-related
improvements.
* Strengthening working relationships between utilities and other
public agencies. This category includes strengthening relationships
between water utilities and other entities that may have key roles in
an emergency response (such as public health agencies, enforcement
agencies, and neighboring utilities). It also includes developing
common protocols to engender a consistent approach among utilities in
detecting and properly diagnosing threats, and testing local emergency
response systems to ensure that participating agencies coordinate their
actions effectively.
We found that EPA has a number of initiatives that address many of
these activities, some of which are required by the Bioterrorism Act.
In most cases, however, the activities are in the planning stages, are
limited in scope, or are dependent on the availability of future
appropriations.
Activities to Enhance Physical Security and Support Technological
Improvements:
Our panel of experts most frequently recommended nine types of
activities to improve physical security and support technological
improvements, as figure 8 shows. Of the nine types, the development and
implementation of near real-time monitoring technologies was rated by
far the most important activity warranting federal support, with many
experts stating that this critical activity would probably not be
implemented by many utilities without some degree of federal support.
Figure 8: Activities Identified by Expert Panel to Enhance Physical
Security and Support Technological Improvements:
[See PDF for image]
[End of figure]
Developing Near Real-Time Monitoring Technologies Viewed As Highest
Priority:
Approximately 93 percent of the panel experts (40 of 43) rated the
expansion of research and development of near real-time monitoring
technologies as having at least a high priority. These technologies
were cited as critical to helping drinking water systems detect and
respond quickly to threats or actual contamination events, to minimize
the impact of any contamination by facilitating a quick response, and
to help in restoring systems after an event. Significantly, almost 70
percent of the experts (30 of 43) rated this activity as warranting the
highest priority for federal funding--far surpassing the rating of any
other category. Most of these experts indicated that smaller utilities
would be unable to use these technologies without federal support.
A wide variety of monitoring technologies can be used in drinking water
systems and, depending on their specific functions, may be deployed at
locations upstream from, within, or downstream from drinking water
treatment plants. Conventional monitors typically measure things such
as pH (acidity and alkalinity), turbidity, conductivity, temperature,
organic compounds and other contaminants. Biomonitors employ living
organisms, such as fish or algae, to provide information on other water
constituents that may impair human health or the environment.
Emerging monitoring technologies are capable of providing near real-
time results for a wider array of potentially harmful water
constituents. According to some experts, near real-time monitors may be
strategically placed at points within the distribution system, where
they may be able to quickly detect potentially dangerous backflows that
may enter the system. They may also be used to augment a system's
conventional monitoring system. As some experts suggested, for example,
pressure sensor systems and biodetector networks could benefit the
utility in its security preparedness as well as its regular operations
by describing breaches or leaks in water mains, or by observing
microbial contamination in a nonterrorist event. Some monitors based on
emerging technologies capable of providing near real-time results may
also be placed at the "point of service," where they can alert the
consumer or utility about the potential for contaminated water entering
a home or business.
These views are substantiated by a 2002 report by the National
Academies of Science, which also highlighted the need for improved
monitoring technologies as one of the four highest-priority areas for
drinking water research and development. The report noted that such
technologies differ significantly from those currently used for
conventional water quality monitoring, stating further that sensors are
needed for "better, cheaper, and faster sensing of chemical or
biological contaminants."[Footnote 12]
The need for near real-time monitoring technologies was also recognized
in the Bioterrorism Act, which directed EPA to review analytical
methodologies and detection techniques that can quickly and accurately
provide information on contaminants.[Footnote 13] As an initial step in
meeting this requirement, the agency is reviewing such early warning
systems, including those designed to monitor levels of chemical,
biological, and radiological contaminants or indicators of
contaminants.
EPA is also planning to launch a number of projects through its Office
of Water and Office of Research and Development. For example, one
project, planned for November 2003 through May 2004, would entail a
detailed examination of commercially available real-time monitors.
According to EPA, the information derived from this project would be
placed in a compendium for manufacturers and vendors of monitoring
technology, allowing them to better focus technology development
efforts.[Footnote 14] Another project aims to evaluate how well many
currently used water monitoring technologies would deal with the
introduction of various contaminants.[Footnote 15] Among other efforts,
EPA also hopes to begin a project in November 2003 to test and evaluate
the applicability of other industries' monitoring technologies to the
security-related monitoring needs of drinking water systems. EPA's
preliminary cost estimates for monitoring-related projects are about $5
million, and their initiation or completion will depend on the
availability of fiscal year 2004 and 2005 funds.
Increasing Laboratories' Capacity to Deal with Terrorist Attacks:
Over two-thirds of the experts (29 of 43) rated increasing laboratory
capacity as a high or highest priority for federal funding. Many
experts on our panel commented that laboratories are being challenged
just to keep up with their normal responsibilities to collect, test,
and analyze large volumes of water samples for water utilities and
other clients. Consequently, they expressed reservations about the
ability of laboratories to handle these responsibilities in the event
of "surge" events caused by the chemical, biological, or radiological
contamination of water supplies.
As one expert explained, few laboratories can test for a full range of
contaminants, and these limitations would be amplified if the
laboratories had to respond to a terror-related emergency. Another
expert believed that in the event of an emergency, many utilities would
be confused about which labs to use for testing samples of suspect
water, and that a network of labs needs to be established so that quick
results of tests could be obtained. The National Academies of Science
report raised similar concerns, adding that legal concerns over the
accuracy of laboratories' tests may make them reluctant to participate
in testing under such severe conditions. The report concludes that a
"dearth of laboratory capacity poses a serious limitation to our
ability to respond to a contamination attack on the water
system."[Footnote 16]
One panelist suggested that state health departments need additional
federal funds to better develop the regional capacity to sample water,
and to improve analytical techniques used to detect contaminants. He
further noted that state laboratories can and would serve as a
component of an emergency response team, and that it would be effective
for state laboratory programs to integrate these new or increased
responsibilities with their existing responsibilities under grants from
the Centers for Disease Control and Prevention.[Footnote 17]
EPA is actively supporting research in order to improve laboratory
capacity nationwide, and has identified a series of ongoing and future
projects toward that end. One project, which was due for completion in
September 2003, would result in a water-specific compendium of
laboratories that may be able to assist water utilities if
contamination occurs. A related project would assess existing
laboratory capacity to analyze drinking water samples in emergency
situations. Another project, initiated in June 2003, is intended to
analyze resource limitations at laboratories, such as personnel,
equipment, training, and methods, and to provide recommendations to
address these limitations.
According to EPA water officials, the agency may spend approximately
$2.4 million starting in fiscal year 2003 to carry out these and other
projects to assess and address the capacity of the nation's
laboratories to deal with emergency situations. However, the experts'
views on this matter suggest that given the magnitude of this long-
standing problem--even under normal circumstances--it will be difficult
enough to accurately characterize the challenge of laboratory analysis
during a drinking water emergency, much less address the problem
effectively.
"Hardening" Assets and Completing Other Physical Improvements:
Over two-thirds of the experts (29 of 43) rated activities that would
improve (or "harden") the basic physical security of drinking water
systems as warranting either a high or highest priority for federal
funding. These activities include, among others, adding or repairing
fences, locks, lighting systems, and cameras and other surveillance
equipment. The National Academies of Science report reached similar
conclusions about the need to harden certain facilities. It describes
how many parts of the drinking water infrastructure remain highly
accessible, and notes that access controls need to be improved. The
report further noted that improved technologies are needed to protect
against explosives delivered by motor vehicle or rail.[Footnote 18]
However, the experts' support for hardening activities came with some
notable caveats. For example, one expert said that many utility
operators are reluctant to invest in physical upgrades because of
fiscal shortfalls and other competing Safe Drinking Water Act
requirements, despite the potential for such upgrades to be relatively
cheap (many costing less than $5,000 per system). According to this
expert, if "an effective and adequate grant program could be developed
and managed," small amounts of funding could address the problems of
many small drinking water systems.
Some experts also cited the limitations inherent in efforts to
comprehensively harden the physical drinking water facility. For
example, unlike nuclear power or chemical plants, drinking water system
assets are not concentrated in a geographically secure area that can be
hardened against all types of contamination or attack. Rather, they are
spread over large geographic areas, particularly the source water and
distribution systems. Thus, these panelists noted, while some degree of
physical security enhancement at drinking water facilities is
appropriate, efforts to construct physical barriers to comprehensively
thwart attacks would be of limited effectiveness. Several said that
efforts might be better directed at intruder detection, or adding
security guards or electronic equipment.
The American Water Works Association Research Foundation is designing a
project that will collect information on vulnerabilities, threats,
potential security improvements, and innovative solutions to certain
physical vulnerabilities. This project began in June 2003 and is
scheduled for completion in July 2004. EPA also noted that utilities
may be eligible to use a portion of the Drinking Water State Revolving
Fund for this purpose.[Footnote 19]
Establishing Engineering Building Standards:
Approximately 49 percent of the experts (21 of 43) rated the
establishment of engineering and building standards for drinking water
systems, which integrate security concepts into building design, as
having either a high or highest priority for federal funding. Some
noted that improved standards could yield multiple benefits by
improving upon the design and functionality of a drinking water system
while augmenting security to guard against attack.
Others wrote that new drinking water systems, which are being
constructed and designed regularly, provide opportunities for
incorporating security measures. One expert noted specifically that new
design measures "may include increased physical security, elimination
of 'single points of failure,' the inclusion of redundancy into the
overall design," or the creation of multiple pathways from source to
tap. Another noted that the development and implementation of new or
upgraded systems with better layouts can reduce unauthorized access,
improve detection, and assist in isolating problems at the water
facility.
According to another expert, standardization is needed across local
jurisdictions so that neighboring providers may assist one another in a
crisis. This view was echoed in the National Academies of Science
report, which concluded that the lack of standardization impedes the
introduction of new processes and technology."[Footnote 20]
According to the EPA Action Plan, the agency is also considering the
development of information on building standards that could enhance
security of drinking water facilities, while improving operations and
better protecting water quality. The plan noted that such standards
would be modeled after those developed by the Department of Defense,
which found that "dual use" aspects of improved design features are
desirable because many security enhancements are not cost effective
without some form of multiple benefit.[Footnote 21] Specifically, the
proposed EPA plan includes working with standards-setting organizations
to develop voluntary design standards and recommendations for new
construction, reconstruction, and retrofitting of drinking water
facilities with a focus on integrating security with ongoing
operations.
Requiring Backflow Protections in Water Distribution Systems:
Inappropriate use of piping systems, whether intended or not, could
result in a backflow of contaminated water into distribution systems,
where it could then find its way to other consumers. Backflow
protection devices are one way to potentially mitigate this threat when
installed either at access points to buildings or homes, or at cross
connections in the distribution system.
Approximately 47 percent of the experts in our study (20 of 43) said
research and implementation of such backflow protection warranted a
high or highest priority for federal funding. These backflow protection
devices could be coupled closely with monitoring and metering
technologies that can sense contaminant concentrations in drinking
water systems. Another noted further that automated meter reading is
already being used, but the ability to get real-time readings is
essential in order to rapidly notify technicians or officials if a
backflow is detected. This could help reduce or eliminate threats to
the distribution system.[Footnote 22]
Testing and Further Protecting SCADA and Cyber Systems:
Section 402 of the Bioterrorism Act requires a review of "methods and
means by which information systems, including process controls and
Supervisory Control and Data Acquisition (SCADA) and cyber systems at
community water systems, could be disrupted by terrorists or other
groups." Slightly more than one-third (15 of 43) of the experts on our
panel rated federal funding to test and further protect SCADA systems
as warranting a high or highest priority. Information provided at the
2003 American Water Works Association (AWWA) Water Security Congress
highlighted the limited security features inherent in many SCADA
systems, citing few security protocols, lack of firewalls, and SCADA
data being routed outside of a facility. Other SCADA systems are placed
in networks that are accessible through the Internet and, therefore,
are exposed to additional vulnerabilities. One expert added that
because the majority of the SCADA software is created outside the
United States, the expert favored establishing and enforcing security
standards for the software, as well as testing the software before
installation at water utilities. This expert believed that federal
activities should include working with vendors of SCADA systems and
related software in order to ensure that security concerns are
appropriately incorporated into the design of these systems.
According to EPA, to meet its responsibilities under the Bioterrorism
Act, the agency is planning to pursue research in a number of areas to
reduce the risks of attacks on drinking water SCADA systems and to
better understand their potential consequences, starting with an
identification of the possible threats posed to such systems. Starting
in fiscal year 2004, EPA also intends to (1) develop models that can
simulate the consequences of physical and cyber attacks, emphasizing
the distribution system and eventually cascading or interrelated
consequences; (2) assess the consequences of a loss of pressurized
water on other critical infrastructure sectors such as power,
transportation, chemical supplies, and communications; (3) compile
technical information and informational tools that can help in
analyzing the consequences of potential physical and cyber threats; and
(4) establish minimum security standards for the protection of SCADA
systems.
Developing Computer Models of Terrorist Events in Water Systems:
Computer modeling can be an important tool in understanding how to
prevent or mitigate contamination episodes. Specifically, modeling can
be used to simulate contamination events, which in turn can enhance the
development of emergency response plans, help select critical locations
in distribution systems for positioning and placing monitoring devices,
and guide the actions of first responders.
About 30 percent of the experts (13 of 43) rated the development of
computer models of terrorist events as deserving a high or highest
priority for federal funding. A number of experts noted the relevance
of this work for understanding the characteristics of distribution
systems. One expert, for example, advocated a "model-based distribution
system flow simulator that can be easily tailored to a specific water
system such that 'what-if' contamination scenarios can be posed to the
system through simulation in order to explore weaknesses in the
system." The expert further stated that such a modeling system would
also have to take into account the fate and transport of the candidate
contaminants throughout the system, and that the approach "would be a
fusion of information from both threat assessment and system modeling
research efforts.":
According to EPA officials, the agency is evaluating distribution
system and source water hydraulic models, such as EPANET, PipelineNet,
and Riverspill, that can be used to follow water movements and tracer
chemicals through distribution systems. EPA notes that several large
utilities are currently using such models, but that medium and small
utilities face challenges in applying them to their systems. EPA was
also planning to initiate a project in September 2003 that will attempt
to improve these models by incorporating health-related data, data
concerning consumer complaints, Geographic Information System data, and
information from SCADA systems. Overall, EPA's preliminary cost
estimates are $2.8 million for modeling projects to develop more
effective protection of distribution systems.
Establishing Baseline Values for Water Constituents:
About 23 percent of the experts (10 of 43) rated the importance of
establishing baseline values (e.g., concentrations of certain chemicals
typically found in a drinking water system) for drinking water system
constituents as a high or highest priority warranting federal support.
One expert noted that developing and understanding the basic
characteristics and typical monitoring results of a distribution system
are essential to understand if and when a drinking water system is
subject to contamination. According to other experts, because
distribution systems may be the most vulnerable portion of a system,
and the most complex in terms of understanding appropriate response
actions, baseline data available from pre-emergency studies could be
helpful.
In addition to providing utility operators with information on normal
operating conditions within their systems, understanding baseline
levels of water constituents is often needed to develop certain
monitoring technologies. For example, monitoring devices that measure
the light given off during certain organic reactions can be indicative
of possible water contaminants, but only if baseline luminescence
levels are known and can be incorporated into measurements and
calibrations.
In March 2004, EPA plans to launch a project to survey available
information on background levels of certain contaminants of concern
that are known or suspected to occur in source or treated drinking
water. The initiation of this project depends on the progress of
another planned project to develop an improved understanding of the
biological, physical, chemical, and toxicological properties of
contaminants.
Improving Treatment Technologies:
About 23 percent of the experts (10 of 43) rated the improvement of
technologies that can better treat the kind of chemical or biological
agents likely to be used in attacking a drinking water system as
warranting a high or highest priority for federal funding. While water
treatment technologies have advanced, as indicated in EPA's research
and implementation action plans, treatment capabilities still need to
be evaluated and improved for a wide array of microbial and other
contaminants. One expert noted that research on membranes (filters that
can remove small particulates or microorganisms) and other advanced
treatment techniques is producing promising results, and that further
progress in this area may be important in making "water an unattractive
target."[Footnote 23] Specifically, treatment technologies needing
further development include ultraviolet systems and improved reverse
osmosis techniques. Finally, other experts believed that there should
be more research and development of point-of-use treatment devices
(possibly installed at the meter), and that a distributed treatment
process--one that involves the treatment of water at multiple locations
within a drinking water system or uses a variety of methods--would
provide additional security against contamination.
According to EPA officials, the agency hopes to initiate a series of
projects to address drinking water treatment issues. Among these are
efforts to (1) identify alternative treatment options by reviewing
literature on contaminants most likely to be used in attacking drinking
water systems; (2) prepare systematic methods to evaluate treatment
technologies for likely contaminants; (3) perform bench-scale studies
(those performed in a laboratory under controlled conditions) to
determine the effectiveness of typical disinfection and contaminant
removal technologies; (4) identify alternative treatment options at the
point of use or point of entry; and (5) develop guidance for
discharging contaminated water that had been used to clean contaminated
substances or equipment.
Activities to Improve Education and Training:
Experts strongly supported improved training and education to help
ensure that utility personnel can detect and respond to malevolent acts
affecting their facilities. As shown in figure 9, the education and
training activities most frequently recommended for federal support
generally fell into four categories: (1) specialized training of
utility personnel with security-related responsibilities, (2) support
for regional simulation exercises to test emergency response plans, (3)
general security awareness training for utility personnel not
specifically charged with security-related responsibilities, and (4)
use of multidisciplinary consulting teams ("Red Teams") to
independently evaluate drinking water utilities and their security
concerns.
Figure 9: Activities Identified by Experts to Improve Education and
Training:
[See PDF for image]
[End of figure]
Required Training of Key Utility Personnel:
Many experts underscored the importance of training drinking water
personnel with security-related responsibilities in techniques to
prevent, detect, and, if necessary, respond to an attack on their
system. This training would include, for example, training for
laboratory technicians who test for potential contaminants; for utility
operators who perform day-to-day duties or who are uniquely positioned
to monitor and respond to potential contaminants at a treatment
facility; and for mechanical, civil, and environmental engineers who
design, repair, and maintain drinking water systems.
Overall, over 90 percent of the experts (39 of 43) indicated that
required training for security-related personnel warrants at least a
high priority for federal funding, with approximately 56 percent (24 of
43) indicating that it deserved highest priority. One expert said that
there should be mandatory federal training for employees at drinking
water systems serving 10,000 people or more.
To date, EPA has launched at least three programs that emphasize
technical training, one directed to states and another to utility
employees and officials. Through one program, beginning in fiscal year
2002, EPA has made grants available to states and territories that, in
part, are intended to support security-related training and
education.[Footnote 24] Also, EPA has developed two train-the-trainer
programs. One of these, begun in fiscal year 2003 to provide assistance
to drinking water systems serving fewer than 50,000 people, awarded
$1.5 million in grants to five nonprofit training and technical
assistance organizations.[Footnote 25] Another program makes available
"no cost" security training for drinking water systems that serve
populations of 50,000 to 100,000.[Footnote 26] This program, which also
provides assistance to develop vulnerability assessments and emergency
response plans, includes provisions for follow-up technical assistance
and training.
Regional Simulation Exercises to Test Emergency Response Plans:
Regional simulation exercises to test emergency response plans are
intended to provide utility and other personnel with the training and
experience needed both to perform their individual roles in an
emergency and to coordinate these roles with other responders within
and outside the utility. A successful emergency response plan can help
these staff members more quickly identify and respond to an emergency
and more quickly restore services and public confidence.
The experts on our panel underscored the importance of conducting such
exercises, with more than 88 percent (38 of 43) rating these exercises
as warranting a high or highest priority for federal funding. Exercises
not only give individuals invaluable practice, but also allow officials
to better determine what kind of coordinated response is best for a
given adverse event. Other experts described the need to identify
responsible agencies that will make difficult decisions during an
emergency, such as whether to restrict use of the drinking water
supplies. And if water supplies were disrupted, subsequent issues would
also need to be anticipated, such as how to fight fires, mobilize
resources (such as the distribution of bottled water), and communicate
among the emergency responders and to the public.
EPA's Water Protection Task Force has developed a program to support
training exercises across the United States at systems serving over
100,000 people. In 2003, the agency intends to conduct workshops at
approximately 30 to 45 locations across the United States to provide
guidance on emergency response plans and on the Bioterrorism Act's
requirements; to present an overview on protocols for responding to
contamination events; and to provide information on environmental
laboratory capabilities.[Footnote 27]
General Awareness Training on Security Issues:
In addition to supporting the specialized training recommended for
responders "on the front lines" of an emergency, experts strongly
endorsed a more general level of training for all utility personnel.
The need to emphasize culture change at utilities, as well as among law
enforcement staff, was summarized by an AWWA official who commented at
a recent security conference about how multimillion-dollar investments
in security technology can be undermined by an employee using a brick
to prop open a usually locked door.
About 79 percent of the experts (34 of 43) rated such "general
awareness" training as warranting at least a high priority for federal
funding. One expert noted that such training is needed because the
water sector has traditionally been slow to respond to new challenges
(such as new regulations), and that such training could therefore be
particularly important in raising the consciousness of staff to
security-related issues.
During fiscal year 2002, EPA completed general security training, in
collaboration with the American Water Works Association and the Water
Environment Federation, to educate water utility managers and operators
about the "entire spectrum of security issues," including vulnerability
assessments, development of emergency response plans, and risk
communication. The organizations convened workshops, conducted
webcasts, and offered online courses. More recently, EPA's Office of
Research and Development has developed a draft Water Security Research
and Technical Support Implementation Plan for key research-related
projects, some of which involve developing training modules and related
guidance documents that will address monitoring, threat evaluation, and
analytical protocols. This training would address the specialized needs
of field and laboratory personnel. However, according to EPA officials,
some of these efforts would also support the general awareness training
needs of the larger universe of utility personnel.
Multidisciplinary Consulting Teams to Analyze Utilities' Risks and
Vulnerabilities:
Multidisciplinary consulting teams, often called "Red Teams," consist
of experts in a wide variety of security-and drinking water-related
disciplines. Red Teams could be used to provide independent analyses of
utilities' vulnerabilities, and to assess their emergency response
preparedness, as well as to educate law enforcement and public health
agencies. Approximately half of the experts (22 of the 43) rated
support for certified Red Teams as warranting either a high or highest
priority for federal funding.
According to one expert, an effective Red Team would consist of "at
least six people with widely varying areas of expertise (physical,
water quality, SCADA, policies and procedures, emergency response,
etc.), and are able to work together and sort through various concerns
and priorities to develop a unified understanding of the security
issues at a given utility." He noted further that the team would visit
utilities, and recommend changes or upgrades to security standards,
procedures, and facilities, based on their best professional judgment.
Another expert noted that Red Teams could make client utilities aware
of threat assessment information, and may be able to review
vulnerability assessments independently.
Activities to Strengthen Relationships between Agencies and Utilities:
Experts also cited enhanced cooperation and coordination among
government organizations and utilities as a key component in drinking
water utilities' efforts to improve their security. Our analysis of
experts' responses identified six types of activities in this category
as most deserving of federal support.[Footnote 28] These activities, in
figure 10, include (1) developing common protocols for monitoring
drinking water threats, (2) improving relationships between drinking
water utilities and public health agencies, (3) improving relationships
between utilities and law enforcement agencies, (4) testing local
emergency response systems, (5) sharing resources among utilities, and
(6) establishing physical interconnections between drinking water
facilities and distribution systems.
Figure 10: Activities Identified by Experts to Strengthen Relationships
between Agencies and Utilities:
[See PDF for image]
[End of figure]
Developing Common Protocols to Monitor Drinking Water Threats:
According to EPA, drinking water utilities vary widely in how they
perceive threats and detect contamination. These differences often
occur because utilities have few common protocols to help promote a
more consistent approach in performing activities such as assessing or
monitoring threats.
The experts in our study also identified this lack of consistency, with
over 90 percent (39 of 43) rating the development of common protocols
to monitor drinking water threats as warranting a high or highest
priority for federal funding. Some experts described the need for a
nationally consistent and uniform analytical response to contamination
threats, noting in particular the need to have protocols in place for
identifying, sampling, and analyzing contaminants. Some also cautioned
that older methodologies need to be reexamined in the context of
terrorism, and that new protocols need to be reviewed as they are
developed. For example, any standard process developed for detecting
potentially harmful microorganisms in drinking water needs first to be
validated, and then implemented appropriately for different sizes and
types of utilities.
EPA officials cited a number of projects under way to develop or
improve protocols that address a variety of activities highlighted in
other sections of this chapter. They noted that guidance documents in
development will include a "toolbox" with information on how to respond
to threats and attacks. EPA also intends to develop guidance to assist
law enforcement officers and utility officials in assessing the
credibility of threats, and guidance on sampling and performing
recovery and remediation work at the sites of potential or real
contamination.
Improving Relationships between Utilities and Public Health Agencies:
Drinking water utilities and public health agencies would appear to be
natural allies in a common health-related enterprise--delivering safe,
sanitary water supplies to the vast majority of the nation's
population. Their relationship is seemingly reinforced further in many
states where the state's drinking water office is located within its
health department.
Nonetheless, about 86 percent of the experts in our study (37 of 43)
recommended a high or highest funding priority for activities devoted
to improving working relationships between drinking water utilities and
health agencies. Such activities may include:
* characterizing and studying potential biological, chemical, and
radiological contaminants and getting this information to all levels of
public health departments and officials;
* clarifying and testing the effectiveness of disinfectants or other
approaches to neutralize such contaminants; and:
* standardizing effective public notification processes in the event of
potential or real contamination of drinking water systems.
For example, one expert described an array of potentially valuable
information that should be developed and made available to utilities--
information typically held by public health agencies. Examples cited
include (1) epidemiological data on diseases or other health incidents
in communities, and (2) data on infections in subgroups of the
population (such as nursing homes) and on hospital laboratory
diagnoses, absenteeism from schools, and pharmacy sales of certain
medications such as antidiarrheal medications. Because state health
agencies often regulate public water utilities and therefore are highly
knowledgeable about them, these agencies should serve an enhanced role
in the security of water systems by, for example, disseminating timely
information to utilities and the public about possible contamination.
EPA has devoted funds to address drinking water security issues as they
relate to public health concerns. For example, the agency's Office of
Water is developing contaminant lists that officials say will better
guide future research and identify information needs. Other planned
work includes determining the infectious or toxic doses of potential
contaminants, and providing information (including restricted
information) to utility operators, public officials, and other security
stakeholders.
Strengthening Relationships between Drinking Water Utilities and Law
Enforcement Agencies:
More than 80 percent of the experts (36 of 43) rated establishing or
strengthening relationships between drinking water utilities and law
enforcement as having either a high or highest priority for federal
funding. Several experts noted that a close working relationship
between these organizations could help to prevent incidents, through
increased police patrols and the sharing of intelligence information.
One expert noted also that improving these relationships might result
in a more rapid and comprehensive response to adverse or malevolent
acts. Another expert, however, pointed to an underlying problem that
often characterizes this relationship: "There are very few people that
currently have a good understanding of utility operations as well as
security issues and approaches. The lack of understanding of utility
operations by law enforcement and even regulatory agencies is
detrimental, as is the lack of law enforcement and security
understanding at utilities. Development of people that understand both
types of knowledge would be highly valuable in addressing water
security." He said that the development of such people is currently
being done by chance.
To date, EPA has largely facilitated security-related training programs
intended for utility officials, although it has recently initiated
programs involving outreach to law enforcement organizations. One
program involves developing outreach materials such as a "top 10" list
of tips on water security for law enforcement officials, a "citizens
brochure," and law enforcement training workbooks. EPA has also
contacted the National Chiefs of Police and the National Sheriffs'
Association to improve awareness about drinking water security.
Testing Local Emergency Response Systems:
It has long been accepted that in light of the critical function they
serve in local communities, drinking water utilities should have
effective emergency response plans to deal with emergencies. This
imperative was further reinforced by the Bioterrorism Act's recent
requirement for such plans. However, the execution of these plans
requires staff to perform functions beyond their day-to-day
responsibilities, as well as coordinate with personnel from different
organizations that may have little to do with each other except in
emergency situations.
Further, an emergency response plan can only be considered reliable if
it is tested periodically. About 60 percent of the experts (26 of 43)
in our study indicated that testing of local emergency response systems
warrants a high or highest priority for federal funding. One expert
stated that funds should be made available to ensure that plans are
updated, perhaps annually. Another noted, "Everyone has been
concentrating on assessment and addressing vulnerabilities [to drinking
water systems]. What is even more important to public safety are the
correct response actions to any emergency situation.":
In September 2003, EPA conducted a study to evaluate the performance of
a group of laboratories in a simulated emergency situation involving a
chemical contamination threat to drinking water. This study also
assessed the effectiveness of draft guidance provided by EPA to
laboratories for developing their own response protocols. EPA plans to
deliver a series of workshops in early 2004 that will involve tabletop
exercises and drills for various emergency responders, such as public
health and law enforcement officials, laboratory staff, and selected
utility employees.
Sharing Resources among Utilities:
Experts cited mutual aid arrangements among neighboring drinking water
utilities as activities that may result in a more efficient use of
resources during a terrorist action. Over half of the experts (23 of
43) said that a high or highest priority should be assigned to federal
funding of activities that facilitate the sharing among utilities of
such resources as common back-up power systems and other critical
equipment. One expert described a collaborative in the San Francisco
Bay Area, the Bay Area Security Information Collaborative (BASIC), in
which eight utilities meet regularly to address a wide range of
security-related topics. Topics have included the development of a
database of chemical and biological contaminants and response
protocols, regional exercises to prepare for an event, regional
training, information sharing on preparing vulnerability assessments,
and public information messages. Such mutual aid arrangements might be
designed in coordination with state water agencies and their related
water security programs.
Another expert cited standardized Mutual Aid Disaster and Intervention
Response Teams (MADIRT) established by the North Carolina League of
Municipalities, the North Carolina Urban Water Consortium, and North
Carolina's Disaster Preparedness Committee. This cooperative approach
is intended to allow municipalities a means to share personnel,
equipment, materials, and emergency assistance with other communities.
MADIRT allows communities to identify their capabilities in advance of
an event, increase standardization to save time and reduce costs, and
simplify communications. One key effort of this cooperative has been to
draft specifications for water pipe repair, although other repair
actions (e.g., for generators or SCADA systems) are being considered.
The cooperative also establishes mutual aid coordinators--volunteers
across the state who are trained in the types of aid that utilities may
need during emergencies. At present, municipalities that sign a
statewide mutual aid agreement, and in turn use the teams, would be
able to fully qualify for reimbursement from the Federal Emergency
Management Agency, the state, or both.
Establishing Physical Interconnections between Drinking Water
Facilities and Distribution Systems:
Physical interconnections--the linkages and junctions between pipes
both within and between utilities--can be useful in mitigating
intentional contamination. Once contamination has occurred and has been
identified, interconnections might allow a utility operator or
emergency response official to continue to provide service from another
source, and aid in isolating contaminated water from reaching the
population at large. They can also allow fresh, clean water to be
pumped in from another part of the system or from an entirely different
system.
Approximately 51 percent of the experts (22 of 43) indicated the
establishment of such interconnections deserves either a high or
highest priority for federal funding. The overarching idea is to have a
higher degree of redundancy in a drinking water system, with
distributed sources of water (e.g., water from both wells and surface
water); a wider and more redundant distribution of treated water (e.g.,
more than one pipeline of treated water at a critical location); and
increased controls over the flow of such water. According to one
expert, system interconnections have been used for some time, but that
more recently, efforts have focused increasingly on developing them to
handle emergency situations. Another expert commented on the need for
remote-controlled valves, and on the need to be able to connect or
bypass pipelines to access alternative sources of water. Finally, one
expert suggested that water could be shared across interconnected
utility systems if one system experienced a suspension of service. This
individual stated that there is so much excess capacity in the systems
that many utilities could supply their own needs and another system of
a similar size.
EPA's preliminary cost estimate for interconnectivity research, such as
contingency planning for alternative sources of water, is about $2.6
million. Among other things, the agency intends to develop case studies
that describe how utilities and populations can share water, how truck-
mounted and portable water facilities can be designed and implemented
during crises, and how redundancy in water systems can better ensure
sustained and consistent water supplies. The agency's work in this area
has been complemented by other projects that use computer modeling to
simulate water flows in distribution systems.
Conclusions:
EPA's Strategic Plan on Homeland Security sets forth the goal that "by
2005, unacceptable security risks at water utilities across the country
will be significantly reduced through completion of appropriate
vulnerability assessments; design of security enhancement plans;
development of emergency response plans; and implementation of security
enhancements." The plan further commits to providing federal resources
to help accomplish these goals as funds are appropriated.
Key judgments about which recipients should get funding priority, and
how those funds should be spent, will have to be made in the face of
great uncertainty about the likely targets of attacks, the nature of
attacks (whether physical, cyber, chemical, biological, or
radiological), and the timing of attacks. The experts on our panel have
had to consider these uncertainties in deriving their own judgments
about these issues. These judgments, while not unanimous on all
matters, suggested a high degree of consensus on a number of key
issues.
We recognize that such sensitive decisions must ultimately take into
account political, equity, and other considerations. But we believe
they should also consider the judgments of the nation's most
experienced individuals regarding these matters, such as those included
on our panel. It is in this context that we offer the results presented
in this report as information for Congress and the Administration to
consider as they seek the best way to use limited financial resources
to reduce threats to the nation's drinking water supply.
Recommendation for Executive Action:
We recommend that, as EPA refines its efforts to help drinking water
utilities reduce their vulnerability to terrorist attacks, the
Administrator of the EPA consider the information in this report to
help determine: how best to allocate security-related federal funds
among drinking water utilities; which methods should be used to
distribute the funds; and what specific security-enhancing activities
should be supported.
[End of section]
Appendixes:
Appendix I: Participating Experts on Drinking Water Security Panel:
Gregory Baecher; University of Maryland.
Pete Baxter; Jane's Information Group.
Kevin Bennett; Federal Bureau of Investigation, National Infrastructure
Protection Center.
Paul Bennett; New York City Department of Environmental Protection.
Frank Blaha; American Water Works Association Research Foundation.
Jennifer Brower; RAND.
Liz Casman; Carnegie Mellon University.
Jeff Danneels; Sandia National Laboratories.
Rolf Deininger; University of Michigan.
John Ditmars; Argonne National Laboratory.
David Dobbins; Black & Veatch Company.
Jane Downing; U.S. Environmental Protection Agency.
Wayne Einfeld; Sandia National Laboratories.
James H. Fetzer; Tennessee Valley Authority.
Tim Gablehouse; Gablehouse and Eppel.
Gregg Grunenfelder; Washington State Department of Health.
Eugene Habiger; San Antonio Water System.
Todd Humphrey; Portland Water Bureau.
Gerald Iwan; Connecticut Department of Public Health.
Steve Jackson; U.S. Department of the Interior, Bureau of Reclamation.
Brian Jenkins; RAND.
Janet Jensen; U.S. Department of Defense, U.S. Army, Aberdeen Proving
Grounds.
Dennis Juranek; U.S. Department of Health and Human Services, Centers
for Disease Control and Prevention.
Michael Keegan; National Rural Water Association.
Dave Lawrence; Wisconsin Rural Water Assocation.
Vanessa Leiby; Association of State Drinking Water Administrators.
Carrie Lewis; Milwaukee Water Department.
John McLaughlin; Brown and Caldwell.
Christine L. Moe; Emory University.
Erik Olson; National Resources Defense Council.
Julian Palmore; University of Illinois.
Janet Pawlukiewicz; U.S. Environmental Protection Agency.
E.L. Quarantelli; University of Delaware.
Brian Ramaley; Newport News Waterworks.
Alan Roberson; American Water Works Association.
Ken Rubin; PA Consultants.
Leonard Shabman; Resources for the Future.
Jim Shell; Metropolitan Washington Council of Governments.
Kimberly Shoaf; University of California at Los Angeles.
David Spath; California Department of Health Services.
Mic Stewart; Metropolitan Water District of Southern California.
Billy Turner; Columbus Water Works.
Ray Yep; Santa Clara Valley Water District.
[End of section]
Appendix II: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
John Stephenson, (202) 512-3841 Steve Elstein, (202) 512-6515:
Acknowledgments:
In addition to the individuals named above, important contributions
were made by Don Cowan, Lynn Musser, Diane Raynes, and Aaron Shiffrin.
Charles Bausell, Brandon Haller, Katherine M. Raheb, and Carol Shulman
also made key contributions.
:
(360364):
:
FOOTNOTES
[1] An EPA official noted, however, that distribution systems generally
carry disinfectant residuals that can counteract the potentially
harmful effects of contaminants.
[2] The President's Commission on Critical Infrastructure Protection,
Critical Foundations: Protecting America's Infrastructures, October
1997.
[3] Pub. L. No. 107-188, 116 Stat. 594 (2002) ("Bioterrorism Act").
[4] A discussion of the influence of these factors on treatment is
available in the preamble in both the Surface Water Treatment Rule and
the Stage I Disinfectants/Disinfection Byproducts Rule.
[5] These comments, made prior to the electric supply disruption of
August 2003, were vividly illustrated when that power outage severely
disrupted the water supplies of several cities.
[6] Environmental Protection Agency, Vulnerability Assessment Fact
Sheet, EPA 816-F-02-025, November 2002, available on the Web at http:/
/www.epa.gov/ogwdw000/security/va_fact_sheet_12-19.pdf.
[7] Design Basis Threat: The threat serves as the basis for the design
of countermeasures as well as the benchmark against which
vulnerabilities are assessed.
[8] Citing this reason, one expert suggested the addition of a "dual
use" criterion in which the funds spent would also fix some existing
utility deficiency, such as noncompliance with a drinking water
standard.
[9] Environmental Protection Agency, Office of Water, Office of
Research and Development, Water Security Research and Technical Support
Implementation Plan, Preliminary Working Draft, July 2003.
[10] As noted earlier in this report, these grants supported VAs,
remediation planning, and emergency plan development through August
2002. EPA issued grant awards to over 400 publicly owned and privately
owned community water systems that regularly serve populations over
100,000. This program was noncompetitive, and all eligible utilities
that submitted completed grant applications received awards. The value
of each grant did not exceed $115,000. An EPA official pointed out that
higher dollar grant programs might have additional administrative
requirements.
[11] Environmental Protection Agency, Office of Water, Use of the
Drinking Water State Revolving Fund (DWSRF) to Implement Security
Measures at Public Water Systems, EPA 816-F-02-040, November 2001,
available on the Web from http://www.epa.gov/ogwdw000/dwsrf/security-
fs.pdf.
[12] The National Research Council of the National Academies, Making
the Nation Safer: The Role of Science and Technology in Countering
Terrorism (Washington, D.C.: The National Academies Press, 2002).
[13] Bioterrorism Act, S 402.
[14] In addition, since August 2002, EPA has augmented its
Environmental Technology Verification (ETV) Program to include water
security issues. The ETV Program can be used to test, evaluate, and
eventually bring promising technologies (e.g., detection and "point of
use" treatment technologies) to the marketplace. EPA has spent
approximately $2 million of fiscal year 2002 supplemental funds on the
ETV Program and its related projects, and estimates the total costs for
the ETV projects at $8.1 million. Once technologies are verified, EPA
believes the technology can be tested in pilot-scale studies and
potentially used at drinking water systems.
[15] This work is planned to review both large and small treatment
system monitoring capabilities, distribution systems, and remote
telemetry monitoring research, and will be conducted in controlled
conditions at the Office of Research and Development's Water Awareness
Technology Evaluation Research and Security Center, located at EPA's
Test & Evaluation Facility. The work is projected to end around
December 2005.
[16] The National Research Council of the National Academies, Making
the Nation Safer: The Role of Science and Technology in Countering
Terrorism (Washington, D.C.: The National Academies Press, 2002).
[17] The Centers for Disease Control and Prevention (CDC) currently
supports programs directed to states in order to improve laboratory
capacity and to ensure public health preparedness, such as the Emerging
Infections Program, the infectious disease Epidemiology and Laboratory
Capacity Program, and the National Electronic Disease Surveillance
System. For fiscal year 2003, CDC made approximately $870 million
available to applicants.
[18] The National Research Council of the National Academies, Making
the Nation Safer: The Role of Science and Technology in Countering
Terrorism (Washington, D.C.: The National Academies Press, 2002).
[19] Environmental Protection Agency, Office of Water, Use of the
Drinking Water State Revolving Fund (DWSRF) to Implement Security
Measures at Public Water Systems, EPA 816-F-02-040, November 2001,
available on the Web at http://www.epa.gov/ogwdw000/dwsrf/security-
fs.pdf.
[20] The National Research Council of the National Academies, Making
the Nation Safer: The Role of Science and Technology in Countering
Terrorism (Washington, D.C.: The National Academies Press, 2002).
[21] Department of Defense, Unified Facilities Criteria (UFC):
Department of Defense Minimum Antiterrorism Standards for Buildings,
UFC 4-010-01, July 2002, available on the Web at http://
www.acq.osd.mil/ie/irm/irm_library/UFC%204_010_01%20-%2031JUL2002.pdf.
[22] The Bioterrorism Act recognized the importance of dealing with
this potentially serious source of contamination. Specifically, section
402 of the Bioterrorism Act calls for a review of "methods and means by
which pipes, constructed conveyances, collection, pretreatment,
treatment, storage and distribution systems that are utilized in
connection with public water systems could be altered or affected so as
to be subject to cross-contamination of drinking water supplies." In
addition, section 402 requires the review of "procedures and equipment
necessary to prevent the flow of contaminated drinking water to
individuals served by public water systems."
[23] For general information on membrane treatment options or examples,
refer to EPA's proposed draft Membrane Filtration Guidance Manual, EPA
815-D-03-008, Office of Water, June 2003.
[24] The additional monies are for coordination within the state or
territory on homeland security issues, developing or enhancing
vulnerability assessments and emergency response plans, and setting up
a communications strategy for states and utilities.
[25] The grants (up to $300,000 per entity) were intended to build
staff expertise in drinking water security, after which these
individuals would train state, tribal and local agencies at no cost on
security and technical issues. Grant recipients included the Maryland
Center for Environmental Training, the National Environmental Services
Center, the National Rural Water Association, the Rural Community
Assistance Program, and the Water Environment Federation.
[26] This is a program implemented by the International City/County
Management Association (ICMA), an organization representing local
government leaders, and the Water Environment Federation (WEF), a not-
for-profit technical and educational organization.
[27] In addition to these workshops, EPA published a guidance document
for utilities to provide for uniform response, recovery and remediation
processes. (See Guidance for Water Utility Response, Recovery &
Remediation Actions for Man-Made and/or Technological Emergencies, EPA
810-R-02-001, April 2002).
[28] More than 50 percent of the experts rated these activities as
deserving a high or highest priority for federal funding relative to
the other activities. Experts also identified three other activities
scoring under 50 percent, including the formation of better
relationships between water associations and federal agencies (about 26
percent), developing public education programs (about 19 percent), and
forming a tracking system to monitor security funding (about 12
percent).
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