Wastewater Facilities
Experts' Views on How Federal Funds Should Be Spent to Improve Security Gao ID: GAO-05-165 January 31, 2005Since the events of September 11, 2001, the security of the nation's drinking water and wastewater infrastructure has received increased attention from Congress and the executive branch. Wastewater facilities in the United States provide essential services to residential, commercial, and industrial users by collecting and treating wastewater and discharging it into receiving waters. These facilities, however, may possess certain characteristics that terrorists could exploit either to impair the wastewater treatment process or to damage surrounding communities and infrastructure. GAO was asked to obtain experts' views on (1) the key security-related vulnerabilities affecting the nation's wastewater systems, (2) the activities the federal government should support to improve wastewater security, and (3) the criteria that should be used to determine how any federal funds are allocated to improve security, and the best methods to distribute these funds. GAO conducted a systematic, Web-based survey of 50 nationally recognized experts to seek consensus on these key wastewater security issues. EPA expressed general agreement with the report, citing its value as the agency works with its partners to better secure the nation's critical wastewater infrastructure.
Experts identified the collection system's network of sewer lines as the most vulnerable asset of a wastewater utility. Experts stated that the sewers could be used either as a means to covertly gain access to surrounding buildings or as a conduit to inject hazardous substances that could impair a wastewater treatment plant's capabilities. Among the other vulnerabilities most frequently cited were the storage and transportation of chemicals used in the wastewater treatment process and the automated systems that control many vital operations. In addition, experts described a number of vulnerabilities not specific to particular assets but which may also affect the security of wastewater facilities. These vulnerabilities include a general lack of security awareness among wastewater facility staff and administrators, interdependencies among various wastewater facility components leading to the possibility that the disruption of a single component could take down the entire system, and interdependencies between wastewater facilities and other critical infrastructures. Experts identified several key activities as most deserving of federal funds to improve wastewater facilities' security. Among those most frequently cited was the replacement of gaseous chemicals used in the disinfection process with less hazardous alternatives. This activity was rated as warranting highest priority for federal funding by 29 of 50 experts. Other security-enhancing activities most often rated as warranting highest priority included improving local, state, and regional collaboration (23 of 50 experts) and supporting facilities' efforts to comprehensively assess their vulnerabilities (20 of 50 experts). When asked how federal wastewater security funds should be allocated among potential recipients, the vast majority of experts suggested that wastewater utilities serving critical infrastructure (e.g., public health institutions, government, commercial and industrial centers) should be given highest priority (39 of 50). Other recipients warranting highest priority included utilities using large quantities of gaseous chemicals (26 of 50) and utilities serving areas with large populations (24 of 50). Experts identified direct federal grants as the most effective method to distribute the funds, noting particular circumstances in which a matching contribution should be sought from recipients. Specifically, a matching requirement was often recommended to fund activities that benefit individual utilities. Grants with no matching requirements were often recommended for activities that should be implemented more quickly and would benefit multiple utilities. The other funding mechanisms experts mentioned most frequently included the federal Clean Water State Revolving Fund, loans or loan guarantees, trust funds, and tax incentives.
GAO-05-165, Wastewater Facilities: Experts' Views on How Federal Funds Should Be Spent to Improve Security
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Report to the Committee on Environment and Public Works, U.S. Senate:
January 2005:
Wastewater Facilities:
Experts' Views on How Federal Funds Should Be Spent to Improve
Security:
GAO-05-165:
GAO Highlights:
Highlights of GAO-05-165, a report to the Committee on Environment and
Public Works, U.S. Senate:
Why GAO Did This Study:
Since the events of September 11, 2001, the security of the nation‘s
drinking water and wastewater infrastructure has received increased
attention from Congress and the executive branch. Wastewater facilities
in the United States provide essential services to residential,
commercial, and industrial users by collecting and treating wastewater
and discharging it into receiving waters. These facilities, however,
may possess certain characteristics that terrorists could exploit
either to impair the wastewater treatment process or to damage
surrounding communities and infrastructure.
GAO was asked to obtain experts‘ views on (1) the key security-related
vulnerabilities affecting the nation‘s wastewater systems, (2) the
activities the federal government should support to improve wastewater
security, and (3) the criteria that should be used to determine how any
federal funds are allocated to improve security, and the best methods
to distribute these funds. GAO conducted a systematic, Web-based survey
of 50 nationally recognized experts to seek consensus on these key
wastewater security issues.
EPA expressed general agreement with the report, citing its value as
the agency works with its partners to better secure the nation‘s
critical wastewater infrastructure.
What GAO Found:
Experts identified the collection system‘s network of sewer lines as
the most vulnerable asset of a wastewater utility. Experts stated that
the sewers could be used either as a means to covertly gain access to
surrounding buildings or as a conduit to inject hazardous substances
that could impair a wastewater treatment plant‘s capabilities. Among
the other vulnerabilities most frequently cited were the storage and
transportation of chemicals used in the wastewater treatment process
and the automated systems that control many vital operations. In
addition, experts described a number of vulnerabilities not specific to
particular assets but which may also affect the security of wastewater
facilities. These vulnerabilities include a general lack of security
awareness among wastewater facility staff and administrators,
interdependencies among various wastewater facility components leading
to the possibility that the disruption of a single component could take
down the entire system, and interdependencies between wastewater
facilities and other critical infrastructures.
Experts identified several key activities as most deserving of federal
funds to improve wastewater facilities‘ security. Among those most
frequently cited was the replacement of gaseous chemicals used in the
disinfection process with less hazardous alternatives. This activity
was rated as warranting highest priority for federal funding by 29 of
50 experts. Other security-enhancing activities most often rated as
warranting highest priority included improving local, state, and
regional collaboration (23 of 50 experts) and supporting facilities‘
efforts to comprehensively assess their vulnerabilities (20 of 50
experts).
When asked how federal wastewater security funds should be allocated
among potential recipients, the vast majority of experts suggested that
wastewater utilities serving critical infrastructure (e.g., public
health institutions, government, commercial and industrial centers)
should be given highest priority (39 of 50). Other recipients
warranting highest priority included utilities using large quantities
of gaseous chemicals (26 of 50) and utilities serving areas with large
populations (24 of 50). Experts identified direct federal grants as the
most effective method to distribute the funds, noting particular
circumstances in which a matching contribution should be sought from
recipients. Specifically, a matching requirement was often recommended
to fund activities that benefit individual utilities. Grants with no
matching requirements were often recommended for activities that should
be implemented more quickly and would benefit multiple utilities. The
other funding mechanisms experts mentioned most frequently included the
federal Clean Water State Revolving Fund, loans or loan guarantees,
trust funds, and tax incentives.
www.gao.gov/cgi-bin/getrpt?GAO-05-165.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact John B. Stephenson at
(202) 512-3841 or stephensonj@gao.gov.
[End of section]
Contents:
Letter:
Executive Summary:
Purpose:
Background:
Results in Brief:
Principal Findings:
Agency Comments and Our Evaluation:
Chapter 1: Introduction:
The Nation's Wastewater Systems and the Populations They Serve:
Key Components of a Typical Wastewater System:
Government and Industry Have Recently Sought to Improve Security:
Objectives, Scope, and Methodology:
Chapter 2: Experts Identified Key Vulnerabilities That Could Compromise
Wastewater Security:
Experts Identified Five Key Vulnerabilities:
Overarching Vulnerabilities Affecting Overall Wastewater System
Security:
Chapter 3: Experts Identified Wastewater Security-Enhancing Activities
That Warrant Federal Support:
Replace Gaseous Chemicals with Less Hazardous Alternatives:
Improve Local, State, and Regional Collaboration Efforts:
Complete Vulnerability Assessments:
Expand Training Opportunities for Wastewater Utility Operators and
Administrators:
Improve National Communication Efforts between Utilities and Key
Entities Responsible for Homeland Security:
Install Early Warning Systems in Collection Systems to Monitor for or
Detect Sabotage:
Harden Physical Assets of Treatment Plants and Collection Systems:
Strengthen Operations and Personnel Procedures:
Increase Research and Development Efforts to Improve Detection,
Assessment, and Response Capabilities:
Develop Voluntary Wastewater Security Standards and Guidance Documents:
Strengthen Cyber Security and SCADA Systems:
Chapter 4: Experts Identified Key Allocation Criteria and Funding
Mechanisms for Addressing Wastewater Security Needs:
Key Criteria to Help Determine Which Utilities Should Receive Funding
Priority:
Funding Mechanisms Recommended for Distributing Federal Funds:
Conclusions:
Appendixes:
Appendix I: Participating Experts on Wastewater Security Panel:
Appendix II: Questions and Responses to the Final Questionnaire for the
Expert Panel:
Appendix III: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Staff Acknowledgments:
Figures:
Figure 1: Key Wastewater System Vulnerabilities Identified by Experts:
Figure 2: System Size by Population (POTW by system size and population
served):
Figure 3: Components of a Typical Community Wastewater System:
Figure 4: Key Wastewater System Vulnerabilities Identified by Experts:
Figure 5: Chlorine Delivery Truck:
Figure 6: Chlorine Railroad Car:
Figure 7: Pump Operated through Remote Automated Systems:
Figure 8: Pumping Station:
Figure 9: Experts' Views on Wastewater Security Activities Most
Deserving of Federal Support:
Figure 10: One-Ton Canisters of Chlorine Gas Stored at a Wastewater
Treatment Plant:
Figure 11: Electronically-Controlled Security Gate:
Figure 12: Security Camera and Infrared Motion Detectors:
Figure 13: Experts' Views on Which Characteristics of Wastewater
Utilities Should Be Used to Set Priority for Federal Funds:
Figure 14: Experts' Views on Mechanisms for Funding Wastewater
Security:
Abbreviations:
AMSA: Association of Metropolitan Sewerage Agencies:
AMWA: Association of Metropolitan Water Agencies:
CWSRF: Clean Water State Revolving Fund:
DHS: Department of Homeland Security:
EPA: Environmental Protection Agency:
HSIN: Homeland Security Information Network:
HSPD: Homeland Security Presidential Directive:
ISAC: Information Sharing and Analysis Center:
LEL: lower explosive level:
MGD: million gallons per day:
POTW: publicly owned treatment works:
SCADA: Supervisory Control and Data Acquisition:
VA: vulnerability assessment:
VSAT: Vulnerability Self Assessment Tool:
Letter January 31, 2005:
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 wastewater security, including the
potential vulnerabilities of wastewater systems; activities that most
warrant federal support to mitigate the risk of terrorism; and the
criteria that the experts believe should be used to determine how any
federal funds are allocated among recipients to improve their security
and the methods the experts suggest should be used to distribute these
funds.
As agreed with your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. 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
contact me at (202) 512-3841 or [Hyperlink, stephensonj@gao.gov] or my
Assistant Director, Steve Elstein, at (202) 512-6515 or [Hyperlink,
elsteins@gao.gov]. 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:
Like safe drinking water, properly treated wastewater is critical to
modern life. Wastewater utilities across the country have long been
engaged in activities to ensure the health and safety of their
customers and to comply with regulatory requirements to prevent harmful
pollutants from being released into the nation's waters. Since the
events of September 11, 2001, the security of the nation's water
infrastructure against terrorist threats has received greater attention
by Congress and executive branch agencies. While more federal resources
have been directed toward drinking water security than wastewater
security, some maintain that wastewater systems, like drinking water
systems, also possess vulnerabilities that could be exploited. It has
been alleged, for example, that the numerous storm drains, manholes,
and sewers that make up a community's wastewater collection systems'
network of sewers could be used to covertly place explosives beneath a
major population center or to introduce substances that may damage a
wastewater treatment plant's process. Such events could result in loss
of life, destruction of property, and harm to the environment.
In 2003, Congress considered legislation that would have provided funds
to, among other activities, assess the vulnerability of wastewater
facilities, make physical security improvements, and conduct research.
Since then, the wastewater industry has expressed its desire for a
strong federal contribution to help meet its security needs. To inform
further deliberations on this topic, as agreed with the Chairman and
Ranking Minority Member of the Senate Committee on Environment and
Public Works, this report identifies experts' views on (1) the key
security-related vulnerabilities affecting the nation's wastewater
systems, (2) specific activities the federal government should support
to improve wastewater security, and (3) the criteria that should be
used to determine how any federal funds are allocated among recipients
to improve their security and the methods that should be used to
distribute these funds.
To address these issues, GAO identified 50 recognized experts from the
wastewater community and surveyed them using a Web-based Delphi
process. The Delphi methodology is a systematic process for obtaining
individuals' views on a question or problem of interest and seeking
consensus if possible. In selecting experts for the expert panel, GAO
sought individuals who are widely recognized as possessing expertise on
one or more key aspects of wastewater security. GAO also sought to
achieve balance in representation from key federal agencies, state or
local agencies, industry and nonprofit organizations, academia, and
water utilities of varying sizes. A detailed description of GAO's
methodology is presented in chapter 1.
Background:
Wastewater systems vary by size and other factors, but all include a
collection system and treatment facility. Collection systems are
generally widely dispersed geographically and have multiple access
points, including drains, catch basins, and manholes, most of which are
not monitored. This underground network of sewers and pumping stations
moves the wastewater away from its point of origination to the
treatment plant. Typical wastewater treatment facilities use a series
of physical, biological, and chemical processes to treat wastewater.
Chemicals used in this process, most notably chlorine, are often stored
on site at the treatment plant. Wastewater systems have become
increasingly computerized and rely on the use of automated controls to
monitor and operate them.
Nationwide, more than 16,000 publicly owned wastewater systems serve
more than 200 million people, or about 70 percent of the nation's total
population. About 500 large public wastewater systems provide service
to 62 percent of the sewered population. To help address the security
needs of the wastewater sector, EPA, since 2002, has provided more than
$10 million to help address the security needs of the wastewater
sector. A large portion of this funding has been awarded to nonprofit
technical support and trade organizations to develop tools and training
on conducting vulnerability assessments to reduce utility
vulnerabilities, on planning for and practicing response to emergencies
and incidents, and for research on a variety of security topics.
Wastewater utilities have had a history of openness with the
communities they serve by sharing, among other things, alerts of
scheduled maintenance activities and information about the quality of
water that is released back into the environment. Many utilities also
provide detailed information about their location, design, and
treatment processes. The September 11 attacks, however, have led many
wastewater utilities to reassess their openness to the general public
and their ability to guarantee safe and reliable services to their
customers and communities. In December 2003, the President issued
Homeland Security Presidential Directive-7, which designated EPA as the
lead agency to address water infrastructure security. EPA has worked
with other organizations, such as the Water Environment Research
Foundation, the Association of Metropolitan Sewerage Agencies, the
Water Environment Federation, and the American Society of Civil
Engineers, to conduct research, provide guidance and, importantly, to
offer training on how to assess wastewater facilities' vulnerabilities.
Unlike drinking water facilities, wastewater utilities are not required
by law to complete these "vulnerability assessments."
Results in Brief:
GAO's panel of experts identified five key wastewater assets as most
vulnerable to terrorist attacks: the collection systems' network of
sewers, treatment chemicals, key components of the treatment plant,
pumping stations, and control systems. Among these assets, 42 of the 50
experts listed the collection systems' network of sewers as a key
vulnerability. Experts explained that adversaries could use this
network of pipes to gain access to intended targets within the service
area, convey hazardous substances that might destroy points along the
system, or incapacitate the wastewater treatment process. In addition,
32 of 50 experts identified process chemicals used in wastewater
treatment as a key vulnerability. Of particular concern is the
accidental or intentional release of gaseous chlorine, used for
disinfection processes, which can burn eyes and skin, inflame the
lungs, and cause death if inhaled.
Experts identified 11 key actions when asked to identify and set
priorities for the security-enhancing activities most deserving of
federal support. Three were particularly noteworthy because they were
given a rating of highest priority by a substantial number of the
experts. The first activity was the replacement of gaseous chemicals
used in wastewater treatment with less hazardous alternatives. Experts
viewed this action as critical to reduce the vulnerability of systems
that rely heavily upon gaseous chlorine in their treatment processes.
Several experts noted that because replacing chlorine could be
prohibitively expensive for many wastewater utilities, replacement was
a particularly strong candidate for federal support. For example, the
change to sodium hypochlorite can require approximately $12.5 million
for new equipment and increase annual chemical costs from $600,000 for
gaseous chlorine to over $2 million for sodium hypochlorite. The second
activity cited was improving local, state, and regional efforts to
coordinate responses in advance of a potential terrorist threat.
According to the experts, enhanced partnerships among these entities
can yield significant benefits to wastewater utilities including an
increased ability to monitor critical infrastructure and facilities,
improved understanding of agency roles and responsibilities, and faster
response time to deal with potential security breaches. Finally, the
third activity cited was completing vulnerability assessments for
individual wastewater systems. Experts viewed these assessments as key
steps toward informing stakeholders about wastewater system
vulnerabilities and countermeasures, and taking steps to implement
appropriate countermeasures.
In identifying and setting priorities for the types of utilities that
should receive federal funds to improve wastewater security, 39 of the
50 experts gave a rating of highest priority to utilities serving
critical infrastructure. These utilities provide service to
institutions that serve as hubs for government activity; commercial and
industrial centers such as cities' financial districts, power plants,
and airports; and public health institutions, such as major medical
centers and hospitals. Just over half of the experts rated utilities
using large quantities of gaseous chemicals as warranting highest
priority for federal funds. Several pointed out that, if these
chemicals were released to the atmosphere while being transported to
the treatment plant or while stored on site, evacuations might be
needed, and personal injuries or fatalities might result. Also
receiving widespread support by the experts were utilities serving
areas with large populations. Fewer experts recommended highest or high
priority for utilities serving entities that have symbolic value or
that serve medium or small populations.
The experts overwhelmingly favored direct federal grants as the best
method to distribute federal funds to potential recipients. They also
specified instances in which some type of match by recipients would be
particularly appropriate. Relatively fewer experts recommended the use
of trust funds or the Clean Water State Revolving Fund, particularly
for upgrades that need to be implemented quickly. Other mechanisms
receiving support from at least some experts included loans or loan
guarantees, and tax incentives for private utilities.
Principal Findings:
Key Vulnerabilities:
Figure 1 summarizes the 50 experts' identification of which wastewater
system components were among the systems' top five vulnerabilities.
Figure 1: Key Wastewater System Vulnerabilities Identified by Experts:
[See PDF for image]
[End of figure]
Collection systems' network of sewers. Forty-two of the 50 experts
named the collection systems' network of sanitary, storm, and combined
sewers. Several noted that sewers make underground travel from a point
of entry to a potential target almost undetectable. Many also suggested
that adversaries could use the collection system as an underground
transport system--without ever physically entering the system--for
explosive or toxic agents. For example, several experts explained, an
adversary could pour a highly toxic chemical into the sewer that could
destroy the biological agents vital to the treatment process.
Treatment chemicals. Thirty-two experts identified treatment chemicals
used in wastewater treatment. Most experts singled out chlorine gas as
a major chemical of concern. Chlorine is extremely volatile and
requires specific precautions for its safe transport, storage, and use.
As experts commented, although railroad tanker cars are designed to
avoid leakage in the event of a derailment, and withstand a bullet from
a normal handgun or rifle, one expert concluded that the "use of
explosives to cause a rupture is well within the skill set of a
terrorist." Such an attack along a congested transportation corridor
could have catastrophic public health and safety impacts.
Key components of the treatment plant. Twenty-nine experts identified
the components of the main wastewater treatment facility. Typical
facilities use multiple treatment processes before discharging the
effluent back to the environment, with each stage of the process
serving an integral role. Experts explained that damage to one or more
of these processes could result in inadequately treated wastewater,
thereby contaminating drinking water sources, harming the environment,
and causing significant economic damage. While many experts expressed
concern for the security of the entire treatment plant, several
identified the headworks, where wastewater carried through the
collection system first enters the plant, as particularly vulnerable to
attack.
Pumping stations. Sixteen of the 50 experts identified pumping
stations, which are often used to move sewage to the treatment plant
when gravity alone is not sufficient, as among the top vulnerabilities.
As one expert explained, destroying or disabling a pumping station
could cause the collection system to overflow raw sewage into the
streets, and into surface waters, and back up sewage into homes and
businesses. Experts explained that the remoteness and geographic
distribution of pumping stations, and their lack of continuous
surveillance, make them particularly vulnerable.
Control systems. Eighteen experts cited the automated Supervisory
Control and Data Acquisition (SCADA) systems, which serve functions
ranging from storing and processing data to monitoring system
conditions and controlling vital system operations. These systems can
be vulnerable because of loose security in the control rooms at some
plants, and remote access to SCADA through the Internet, among other
reasons. One expert described a breach of cyber security in Australia
which caused the release of thousands of gallons of raw sewage.
In addition to the vulnerabilities associated with specific system
components, experts identified several overarching issues that
compromise the integrity of systems' physical assets and their
operations. Chief among them are (1) a general lack of security
awareness within the wastewater sector; (2) interdependencies among
components of the wastewater system, opening the possibility that a
failure of any individual component could bring down the entire system
(e.g., undermining the automated control system could cause numerous
components to fail); and (3) interdependencies between the wastewater
system and other critical infrastructure that could fail, such as
electric power supplies.
Security-Enhancing Activities That Most Warrant Federal Support:
Three security-enhancing activities were most often cited by the
experts as warranting "highest" priority for federal support:
Replacing gaseous chemicals used in wastewater treatment with less
hazardous alternatives. Well over half of experts surveyed (29 of 50)
rated the replacement of gaseous chemicals at wastewater treatment
facilities with less hazardous alternatives as warranting highest
priority for federal funding. Fourteen more experts rated this activity
as a "high" priority. Experts asserted that wastewater systems carrying
out treatment processes using gaseous forms of chemicals, particularly
chlorine, inherently make themselves targets for terrorist attack.
According to several experts, some communities and utilities currently
using gaseous chemical treatment processes are interested in converting
to an alternative treatment technology, but financial costs associated
with conversion remain prohibitive. According to EPA, hypochlorite
compounds tend to have higher operating costs than chlorine
gas.[Footnote 1] Nonchlorine-based technologies, such as ozone and
ultraviolet light, tend to have higher capital costs than chlorine gas,
according to a study prepared for the U.S. Army.[Footnote 2] Another
expert suggested that reducing the size of containers used to transport
and store gaseous chemicals could help to mitigate the problem. This
approach is being implemented by a facility where gaseous chlorine is
now stored in 1-ton containers--a significant reduction in size from
the larger 90-ton railroad car-sized containers the utility previously
employed.
Improving local, state, and regional collaboration efforts. Twenty-
three of 50 experts rated efforts to improve local, state, and regional
collaboration efforts as warranting highest priority for federal
funding. Fifteen more experts rated this activity as a high priority.
As one expert noted, wastewater facilities are often disconnected from
other key entities that participate in emergency planning and response,
and the facilities instead conduct these critical activities without an
appreciation of the need to coordinate with other key players. An
expert identified the nonprofit California Utilities Emergency
Association as an example of an effective provider of communications,
training, mutual aid coordination, and simulation exercises to
participating utilities.
Completing vulnerability assessments for individual wastewater systems.
Twenty of 50 experts rated the completion of vulnerability assessments
as warranting highest priority for federal funding. Fourteen others
rated this activity as a high priority. Experts suggested that
vulnerability assessments enable wastewater utilities to identify and
understand their systems' vulnerabilities and take steps to implement
appropriate countermeasures. As such, they characterized these
assessments as a logical first step in determining how best to spend
funds to improve security.
In addition to these three activities, experts cited eight other
activities as warranting high priority for federal funding: (1)
training utility employees on how best to conduct vulnerability
assessments and improve the security culture among employees; (2)
improving national communication efforts between utilities and key
entities responsible for homeland security; (3) installing early
warning systems in collection systems to monitor for or detect
sabotage; (4) hardening physical assets of treatment plants and
collection systems; (5) strengthening operations and personnel
procedures; (6) increasing research and development efforts aimed at
improving threat detection, assessment, and response capabilities; (7)
developing voluntary wastewater security standards and guidance
documents; and (8) strengthening cyber security and SCADA systems.
Key Allocation Criteria and Distribution Methods for Federal Funding:
GAO asked its expert panel for its views on the appropriate criteria
for determining which utilities should receive federal funds, should
Congress and the administration agree to provide such support. The most
frequently cited criteria included the following:
Utilities serving critical infrastructure. Thirty-nine of the 50
experts accorded highest funding priority to utilities serving critical
infrastructure. An additional 10 experts believed these utilities
warranted a high priority. These utilities provide service to
institutions that serve as hubs for government activity, to commercial
and industrial centers, and to public health institutions. Many experts
noted in particular that systems serving heavy commercial and
industrial customers are critical to the country's economic stability,
and that a major or sustained disruption could have severe economic
and/or public health consequences. One noted, for example, that a
sustained shutdown in the computer chip manufacturing sector, caused by
the loss of a wastewater treatment plant, could cost the economy
millions of dollars per day.
Utilities using large quantities of gaseous chemicals. Citing the
enormous risks posed by gaseous chemicals, just over half of the
experts (26 of 50) recommended highest funding priority to help
utilities convert from these chemicals to safer alternatives. An
additional 18 rated these utilities as warranting a high priority for
federal funds. Some experts cautioned, however, that if funds are used
by utilities merely to convert to less hazardous chemicals (e.g.,
sodium hypochlorite), then the federal government may be perceived as
rewarding these utilities at the expense of utilities that are
considering much safer alternatives.
Utilities serving large populations. Almost half of the experts (24 of
50) gave highest priority to utilities serving areas with large
populations. Seventeen additional experts rated these utilities as
warranting a high priority for federal funds. Many experts shared the
view that providing financial and technical assistance to the largest
treatment plants would protect the greatest number of people. One
expert pointed to EPA's 2000 Clean Water Needs Survey, which indicated
that 62 percent of the nation's sewered population is served by about
500 of the largest wastewater treatment facilities. Furthermore, a
number of experts suggested that terrorists often seek to maximize the
number of people killed or injured by their attacks, and are,
therefore, more likely to target the systems in large metropolitan
areas that serve many customers.
GAO also asked its expert panel for their ratings of how effective each
method would be for distributing federal funds to potential recipients.
Among the mechanisms they recommended:
Direct grants. Direct federal grants were the most favored funding
mechanism, with 34 of the 50 experts indicating that direct federal
grants to utilities would be "very effective" in allocating federal
funds. An additional 12 experts indicated that they would be at least
"somewhat effective." Several experts commented that grants are
preferable because they are more likely to result in safety
improvements and other desired changes more quickly. Experts also
offered the following opinions on situations in which it would be
appropriate to offer a grant with or without a required match from the
recipient:
* Many favored grants without a matching requirement for activities
that benefit multiple utilities. Specific actions include conducting
research and development to improve detection, assessment, and response
capabilities; developing voluntary wastewater security standards and
guidance; completing vulnerability assessments; and providing training
to utility security personnel on how best to conduct vulnerability
assessments and improve the security culture.
* Many favored cost-shared grants for activities that benefit
individual utilities, such as establishing improved operation and
personnel procedures (e.g., conducting background checks on new
employees); installing early warning systems in collection systems to
monitor for or detect sabotage; improving cyber security; and hardening
physical assets through such actions as building fences and installing
or upgrading locks.
Clean Water State Revolving Fund. Five experts cited the Clean Water
State Revolving Fund as a very effective funding mechanism, and 35
others cited it as somewhat effective. Some experts expressed the view
that the fund can leverage appropriated funds and, thereby, assist more
facilities than direct grants. But several others expressed
reservations about using the fund for security enhancement, including
one who said that it "was not originally established to deal with
security-related projects . . . the program either needs to [be] fixed
to deal with security issues or a separate program needs to be created
specifically for security projects." According to one expert, unless
additional security-related monies were added to existing fund levels,
the use of the fund for security would divert much needed funding away
from the kind of critical infrastructure investments that have long
been the fund's primary objective.
Loans or loan guarantees. Only one expert indicated that loans or loan
guarantees would be very effective, although 34 others agreed that they
would be somewhat effective. One expert pointed out that loans would
"allow the community to amortize the costs over 20 years," while
another commented that a low interest loan could provide some incentive
and needed capital to implement security programs. Others cautioned,
however, that while loans would have a smaller impact on the federal
budget than grants, many local governments are already carrying a heavy
debt load for capital improvements, making it difficult for them to
take on significant additional debt without affecting their bond
ratings.
Making Key Security Decisions in the Face of Uncertainty:
To date, the federal government's role in promoting wastewater security
has been limited primarily to supporting various training activities on
how to complete vulnerability assessments and emergency response plans
and several research projects. However, legislation supporting an
expanded federal role, including a substantially greater financial
commitment, has been proposed in the past and may be considered again
in the future.
Should such funds be 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
target of an attack (i.e., a large but well-protected facility versus a
smaller but less-protected facility); the nature of an attack (cyber,
physical, chemical, biological, radiological), and its timing. The
experts on GAO's panel have taken these uncertainties into account in
deriving their own judgments about these issues. These views, while not
unanimous, suggested some degree of consensus on a number of key issues.
GAO recognizes that such sensitive decisions ultimately must take into
account a variety of political, equity, and other considerations. It
believes they should also 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 these results as
information for the decision-making process that Congress and the
administration will likely go through as they seek to determine how
best to use limited financial resources to reduce the vulnerability to
the nation's wastewater utilities.
Agency Comments and Our Evaluation:
GAO 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 Ground Water and Drinking Water, its Office
of Homeland Security, and other relevant offices. The comments
expressed general agreement with the content of the report and noted
that the results will be useful as the agency continues to work with
its partners to better secure the nation's critical wastewater
infrastructure. EPA also offered specific technical comments and
suggestions, which have been incorporated as appropriate.
[End of section]
Chapter 1: Introduction:
Wastewater systems in the United States provide essential services to
residential, commercial, and industrial users by collecting and
treating wastewater and discharging it into receiving waters. In light
of the events of September 11, 2001, Congress and the executive branch
have placed increased attention on improving the security of the
nation's water infrastructure--including wastewater systems--to protect
against future terrorist threats. While more federal resources have
been directed toward drinking water security than wastewater security,
some maintain that wastewater systems, like drinking water systems,
also possess vulnerabilities that could be exploited. The unique
characteristics and components these systems possess provide for the
efficient collection, treatment, and disposal of wastewater-- functions
that are vital to the health of the general public and the environment.
However, many of these same characteristics and components have been
identified as potential means for carrying out a terrorist attack. A
terrorist could seek to impair a wastewater system's treatment process,
to use a wastewater system to carry out an attack elsewhere, or some
combination of both.
Documented accidents and intentional acts highlight the destruction
that arises from an attack on a wastewater system. For example, in June
1977 in Akron, Ohio, an intentional release of naptha, a cleaning
solvent, and alcohol into a sewer by vandals at a rubber manufacturing
plant caused explosions 3.5 miles away from the plant, damaging about
5,400 feet of sewer line and resulting in more than $10 million in
damage.
The Nation's Wastewater Systems and the Populations They Serve:
A majority of the nation's wastewater is treated by publicly owned
treatment works (POTW) that serve a variety of customers, including
private homes, businesses, hospitals, and industry. These POTWs
discharge treated water into surface waters and are regulated under the
Clean Water Act. Nationwide, there are over 16,000 publicly owned
wastewater treatment plants, approximately 800,000 miles of sewers, and
100,000 major pumping stations. This infrastructure serves more than
200 million people, or about 70 percent of the nation's total
population. The remainder is served by privately owned utilities or by
on-site systems, such as septic tanks. This report addresses both
public and private wastewater systems.
Though outnumbered by the small systems, the relative handful of large
wastewater systems serve the great majority of people. As depicted in
figure 2, only 3 percent of the nation's total wastewater systems
(approximately 500 systems) provide service to 62 percent of the
populations served by POTWs. Each of these systems treats more than 10
million gallons per day (MGD) of wastewater.
Figure 2: System Size by Population (POTW by system size and population
served):
[See PDF for image]
[End of figure]
Key Components of a Typical Wastewater System:
Wastewater systems vary by size and other factors but, as illustrated
in figure 3, all include a collection system and treatment facility.
Figure 3: Components of a Typical Community Wastewater System:
[See PDF for image]
[End of figure]
[See PDF for image]
[End of figure]
Collection System:
The underground network of sewers includes both sanitary and storm
water collection lines that may range from 4 inches to greater than 20
feet in diameter. Storm water lines tend to be large in diameter in
order to accommodate a variety of precipitation events. Some of the
nation's older cities have combined sanitary and storm water lines.
Sewers are connected to all buildings and streets within typical
communities through indoor plumbing and curb drains.
Most systems were designed for easy and frequent access to facilitate
maintenance activities. Access for these purposes is usually conducted
through manholes that are typically located approximately every 300
feet. Many collection systems rely on gravity to maintain the flow of
sewage through the pipes toward the treatment plant. However, the
geographic expanse of a collection system, both in size and topography,
may impede the flow. For this reason, collection systems may depend on
pumping stations to lift the flow to gain elevation for continued
gravity flow until the wastewater reaches the wastewater treatment
plant.
The Wastewater Treatment Plant:
Once the wastewater enters the treatment plant (influent) through the
collection system, the treatment process removes contaminants such as
organic material, dirt, fats, oils and greases, nitrogen, phosphorus,
and bacteria. The influent typically undergoes several stages of
treatment before it is released. Primary treatment includes the removal
of larger objects, such as rags, cans, or driftwood, through a
screening device or a grit removal system, and solids are removed
through sedimentation. Secondary treatment includes a biological
process that consumes pollutants, as well as final sedimentation. Some
facilities also use tertiary treatment to remove nutrients and other
matter even further. Following secondary or tertiary treatment, the
wastewater is disinfected to destroy harmful bacteria and viruses.
Disinfection is often accomplished with chlorine, which is stored on-
site at the wastewater treatment plant. The collection and treatment
process is typically monitored and controlled by a Supervisory Control
and Data Acquisition (SCADA) system, which allows utilities to control
such things as the amount of chlorine needed for disinfection.
Government and Industry Have Recently Sought to Improve Security:
In December 2003, the President issued Homeland Security Presidential
Directive-7 (HSPD-7), which established a national policy for federal
departments and agencies to identify and set priorities for the
nation's critical infrastructures and to protect them from terrorist
attacks. HSPD-7 established the Environmental Protection Agency (EPA)
as the lead federal agency to oversee the security of the water sector,
both drinking water and wastewater. Presidential Decision Directive 63
had done so earlier in May 1998, with a focus primarily on drinking
water. Based on the 1998 directive, EPA and its industry partner, the
Association of Metropolitan Water Agencies (AMWA) established a
communication system, the Water Information Sharing and Analysis Center
(Water ISAC). The Water ISAC was designed to provide real-time alerts
of possible terrorist activity and access to a library of information
and contaminant databases to water utilities throughout the nation. In
fiscal year 2004, Congress appropriated $2 million for the Water ISAC,
which today serves more than 1,000 users from water and wastewater
systems. In November 2004, the Water ISAC launched a free security
advisory system known as the Water Security Channel to distribute
federal advisories on security threats via e-mail to the water sector.
EPA recently established a Water Security Working Group to advise the
National Drinking Water Advisory Council (NDWAC) on ways to address
several specific security needs of the sector. The working group is
made up of 16 members selected on the basis of experience, geographic
location, and their unique drinking water, wastewater, or security
perspectives. It represents a diverse collection of drinking water and
wastewater utilities of all sizes, state and local public health
agencies, and environmental and rate-setting organizations. The group's
charge includes making recommendations to the full council by the
spring of 2005 that identify features of an active and effective
security program and ways to measure the adoption of these practices.
The working group is also charged with identifying incentives for the
voluntary adoption of an active and effective security program in the
water and wastewater sector.
The Department of Homeland Security (DHS) is also seeking to enhance
communication between critical infrastructure sectors, like the water
sector, with the government. The Homeland Security Information Network
(HSIN) is being developed to provide the water sector with a suite of
information and communication tools to share critical information both
within the sector, across other sectors, and with DHS. According to
DHS, these information and collaboration tools will facilitate the
protection, stability, and reliability of the nation's critical water
infrastructure and provide threat-related information to law
enforcement and emergency managers on a daily basis. A Water Sector
Coordinating Council established by the department with representative
members of the water sector community is charged with identifying
information and other needs of the sector, including the appropriate
use of and the relationships among ISAC, the Water Security Channel,
and HSIN. According to a DHS official, the department is also
assembling a Government Coordinating Council made up of federal, state,
and local officials to assess impacts across critical infrastructure
sectors, including the water sector.
While federal law does not address wastewater security as
comprehensively as it addresses drinking water security,[Footnote 3]
wastewater utilities have taken steps, both in concert with EPA and on
their own, to protect their critical components. Since 2002, EPA has
provided more than $10 million to help address the security needs of
the wastewater sector. A large portion of this funding has been awarded
to nonprofit technical support and trade organizations including the
Association of Metropolitan Sewerage Agencies (AMSA) and the Water
Environment Federation to develop tools and training on conducting
vulnerability assessments to reduce utility vulnerabilities and on
planning for and practicing response to emergencies and incidents.
Also, according to EPA, because of the relationship between the
drinking water and wastewater sectors, much of the work and funding
that has been allocated for drinking water security also directly
benefits the wastewater sector. The Water Environment Research
Foundation, for instance, has been conducting research on cyber
security, real-time monitoring, the effects of contaminants on
treatment systems, and other topics that could benefit both sectors. In
addition, EPA has supported the development of a variety of resource
documents for utilities such as guidance on addressing threats and
security product guides for evaluating available technologies and has
offered additional technical support to small systems.
To assist in the completion of vulnerability assessments, AMSA with EPA
funding cited above, developed technical assistance documents and
software including the Vulnerability Self Assessment Tool (VSAT) that
are available free of charge to water and wastewater systems. The VSAT
methodology and software offers utilities a structured approach for
assessing their vulnerabilities and establishing a risk-based approach
to taking desired actions.
Even though the wastewater industry has not been required by law to
undertake the security measures undertaken by drinking water utilities,
many in the industry maintain that enhanced security must be pursued.
They note, however, that the implementation of security measures
imposes additional financial costs on a sector that is already
experiencing difficulty in meeting the financial challenges of an aging
infrastructure. Accordingly, the industry has sought federal assistance
through the congressional appropriations process. In 2003, Congress
responded by considering legislation that would have authorized $200
million for use in making grants to wastewater utilities to conduct
vulnerability assessments and implement security improvements, $15
million for technical assistance for small systems, and $5 million over
5 years for refinement to vulnerability assessment methodologies.
Objectives, Scope, and Methodology:
As requested by 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 wastewater systems?
* What specific activities should the federal government support to
improve wastewater security?
* What are the criteria that should be used to determine how federal
funds are allocated among recipients to improve wastewater security,
and how should the funds be distributed?
It was outside the scope of this review to ascertain the desirability
of using federal funds to support wastewater security or to compare the
merits of federal support of the wastewater industry with others such
as the electric power or transportation industries. Rather, we sought
to obtain expert advice on how best to use federal funds to improve
wastewater security, should Congress agree that they should be
appropriated for this purpose.
To obtain information on these three questions, we conducted a three-
phase Web-based survey of 50 experts on wastewater security. We
identified these experts from a list of more than 100 widely recognized
experts in one or more key aspects of wastewater 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, preparedness,
engineering, epidemiology, public policy, security, wastewater
treatment, risk assessment, water infrastructure, bioterrorism, and
public health).
In addition, we sought experts from (1) key federal organizations
(e.g., DHS, EPA, and National Science Foundation); (2) key state and
local agencies, including health departments and environmental
protection departments; and (3) key industry and nonprofit
organizations such as AMSA, Environmental Defense, Water Environment
Federation, and the Water Environment Research Foundation; and (4)
water utilities serving populations of varying sizes. Of the
approximately 70 experts we contacted, 50 agreed to participate and
complete all three phases of our survey. A list of the 50 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 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 adapted the method to use on 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, allowing us to obtain a broad range of opinions.
For each phase in our three-phase Delphi process, we posted a
questionnaire on GAO's survey Web site. 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 survey's first phase, we asked a series of open-ended questions.
We pretested these questions with officials from the wastewater utility
industry, nonprofit research groups, and a federal agency. Responses
were content analyzed to provide the basis for the questions asked in
the subsequent phases. Phase 2 questions were close-ended and asked
experts to rate the relative priority or effectiveness of the Phase 1-
identified security activities, allocation criteria, and funding
mechanisms. Experts were also invited to provide narrative comments.
During the third phase, we provided experts with aggregate group
results from Phase 2, along with their own individual answers to the
Phase 2 questionnaire. Experts were asked to compare the group results
with their own individual answers and to use this information as a
basis for reconsidering their answers and revising their individual
responses, if so 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, the Water
Environment Research Foundation, and AMSA. We also held interviews with
EPA on the agency's wastewater security programs. During our
interviews, we asked officials to provide information on program
operations, policies, guidance, and funding levels. We also received
training on VSAT from the Water Environment Federation, which was
supported by AMSA, and attended specialized conferences addressing
water security by the American Water Works Association and other
organizations.
We conducted our work from January 2004 through December 2004 in
accordance with generally accepted government auditing standards.
[End of section]
Chapter 2: Experts Identified Key Vulnerabilities That Could Compromise
Wastewater Security:
Experts responding to our survey identified five key physical assets of
wastewater systems as among the most vulnerable to terrorist-related
attacks: (1) the collection systems' network of sewers, which includes
underground sanitary, stormwater and combined sewer lines; (2)
treatment chemicals, primarily chlorine, which are used to disinfect
wastewater; (3) key components of the wastewater treatment plant, such
as its headworks, where the raw sewage first enters the treatment
plant; (4) control systems, used to control plant operations; and (5)
pumping stations along the collection system, which lift or pump
wastewater to allow gravity flow to help move sewage to the treatment
plant (see fig. 4). Of these assets, experts ranked the collection
systems' network of sewers and treatment chemicals as the most
vulnerable.
Figure 4: Key Wastewater System Vulnerabilities Identified by Experts:
[See PDF for image]
[End of figure]
Experts also identified overarching vulnerabilities that could
compromise the overall integrity of the systems' security. These
vulnerabilities include (1) a general lack of security awareness within
the wastewater sector; (2) interdependencies among components of the
wastewater system, opening the possibility that a failure of any
individual component could bring down the entire system; and (3)
interdependencies between the wastewater system and other critical
infrastructure that could fail, such as electric power supplies.
In general, our panel of experts' observations were consistent with
those of major organizations that have conducted research on wastewater
system vulnerabilities. Among these organizations are the Water
Environment Federation and the Association of Metropolitan Sewerage
Agencies.
Experts Identified Five Key Vulnerabilities:
The five assets experts considered most vulnerable included the
collection systems' network of sewer lines, treatment chemicals, key
components of the wastewater treatment plant, control systems, and
pumping stations.
Collection Systems' Network of Sewers:
Forty-two of the 50 experts we surveyed identified the collection
systems' network of sanitary, storm, and combined sewer lines as among
the top five terrorist-related vulnerabilities of wastewater systems.
Experts explained that adversaries could use the network of sewers to
(1) covertly gain access to intended targets within the service area or
to (2) convey hazardous or flammable substances that may cause
explosions at points along the system or cause harm to the wastewater
treatment system or process.
As some experts explained, gaining access to buildings or other
intended targets could be accomplished covertly using sewer networks.
Sewers make underground travel from a point of entry to a potential
target almost undetectable. Entering the sewer system is relatively
easy, due to the large number of access points, such as manholes, that
may or may not be protected. Moreover, some sewers, particularly those
in older cities, may be large enough for people and even trucks to
covertly pass through--often beneath some of the most heavily populated
and critical areas--and gain access to potential targets, such as
government and financial districts. Sewer lines range in size from 4
inches to greater than 20 feet in diameter. One expert explained:
Access controls to important installations, such as perimeter fencing,
can be countered by a terrorist gaining access to the facility unseen
by using the underground collectors. Once access is gained, any
activity could then occur--target reconnaissance or surveillance,
planting of conventional explosives or weapons of mass destruction,
hostage taking, [or] theft of critical documents and items.
Many experts also suggested that adversaries could use the collection
system as an underground transport system--without ever physically
entering the system--for explosive or toxic agents. These substances
could be inserted into the system through storm drains, manholes, or
household drains. Several experts explained that with prior knowledge
of a system's gravity flow, an adversary could calculate the precise
timing and location of an explosion or calculate the amount of a
substance that might be necessary to disable or destroy the biological
processes of a wastewater treatment plant.
However, even without precise knowledge about a system, significant
damage can occur as a result of underground sewer explosions. These
explosions may also damage natural gas or electric lines often co-
located with sewers. One expert cited the effects of an unintentional
explosion that occurred in 1981 in Louisville, Kentucky, where
thousands of gallons of a highly flammable solvent, hexane, spilled
into the sewer lines from a local processing plant. The fumes created
an explosive mixture that was eventually ignited by a spark from a
passing car. The result was a series of explosions that collapsed a 12-
foot diameter pipe and damaged more than 2 miles of streets. While no
one was seriously injured, sewer line repairs took 20 months, followed
by several more months to repair the streets. A more serious incident
occurred in Guadalajara, Mexico, when a gasoline leak into a sewer, in
April 1992, caused explosions that killed 215 people, injured 1,500
others, damaged 1,600 buildings, and destroyed 1.25 miles of sewer. The
explosion created craters as deep as 24 feet and as large as 150 feet
in diameter. Another alarming incident was an intentional release of a
cleaning solvent (naptha) and alcohol into a sewer that caused
explosions 3.5 miles away from the source and damaged about 5,400 feet
of sewer line. This June 1977 incident in Akron, Ohio, by vandals at a
rubber manufacturing plant resulted in more than $10 million in damage.
Adversaries may also use the system to convey substances that disable
the treatment process. For example, as one expert explained, an
adversary could introduce a highly toxic chemical into the sewer that
could damage the biological processes involved in treatment. Several
experts warned that disabling the treatment process could cause the
release of improperly treated sewage, placing the receiving water in
jeopardy and potentially harming human health and the environment. In
February 2002, such an incident occurred in Hagerstown, Maryland, when
chemicals from an unknown source entered the wastewater treatment plant
and destroyed the facility's biological treatment process. This
incident resulted in the discharge of millions of gallons of partially
treated sewage into a major tributary of the Potomac River, less than
100 miles from a water supply intake for the Washington, D.C.,
metropolitan area.
Wastewater Treatment Chemicals:
Thirty-two of the 50 experts we surveyed identified process chemicals
used in wastewater treatment as among the top five terrorist-related
wastewater system vulnerabilities. Wastewater treatment facilities use
a variety of chemicals, including chlorine, sulfur dioxide, and ammonia
during the treatment process. Most experts singled out chlorine gas as
a major chemical of concern because it is an extremely volatile and
hazardous chemical that requires specific precautions for its safe
transport, storage, and use.
Chlorine is a disinfectant that is commonly used in the treatment
process before treated water (effluent) is discharged into local
waterways. However, if chlorine, which is stored and transported as a
liquefied gas under pressure, is accidentally released into the
atmosphere, it quickly turns into a potentially lethal gas. Because
gaseous chlorine is heavier than air, the cloud it forms tends to
spread along the ground. Consequently, accidental or intentional
releases of chlorine could be extremely harmful to those in the
immediate area. Exposures to chlorine could burn eyes and skin, inflame
the lungs, and could be deadly if inhaled. One expert pointed out that
accidental releases of chlorine gas have occurred numerous times and
that a deliberate release would be relatively feasible. The expert
further explained that many wastewater plants have been converting from
chlorine gas to alternative disinfection methods for various reasons,
including the risk of a release.
Recognizing that chlorine gas releases pose threats to the public and
the environment, EPA requires, among other things, that any facility
storing at least 2,500 pounds of chlorine gas submit a risk management
plan; as of December 2004, EPA estimates that about 1,200 plants fit
this category. The plan includes an estimate of the potential
consequences to surrounding communities of hypothetical accidental
"worst-case" chemical releases from their plants. These estimates
include the residential population:
located within the range of a toxic gas cloud produced by a "worst-
case" chemical release, called the vulnerable zone.[Footnote 4]
Several experts stated that a terrorist could use chlorine gas as a
weapon, either at a wastewater plant that is in close proximity to a
specific target population, or through theft and use at another
location. In fact, on September 11, 2001, railroad tanker cars filled
with toxic chemicals including chlorine sat at a treatment plant across
the river from the Pentagon as it was being attacked. At that time, the
population within the plant's vulnerable zone was 1.7 million people.
Within weeks after September 11, this facility converted to an
alternative disinfection method. Other facilities have also eliminated
the use of chlorine gas, choosing instead chlorine-based technologies
(e.g., sodium hypochlorite, calcium hypochlorite, mixed oxidant
generation) or nonchlorine-based technologies (e.g., ozone and
ultraviolet light). However, as one expert noted, several dozen
wastewater treatment plants in heavily populated areas continue to use
large amounts of chlorine gas.
In addition to concerns over on-site chlorine storage, experts were
also concerned about the safe transport of chemicals to treatment
facilities. Chlorine is delivered to facilities via railways and
highways and in various container sizes ranging from 1-ton cylinders to
90-ton railroad cars (see figs. 5 and 6). As experts noted, although
rail tank cars are designed to avoid leakage in the event of a
derailment, and the containers can theoretically withstand a bullet
from a normal handgun or rifle, one expert concluded that the "use of
explosives to cause a rupture is well within the skill set of a
terrorist."
Figure 5: Chlorine Delivery Truck:
[See PDF for image]
[End of figure]
Figure 6: Chlorine Railroad Car:
[See PDF for image]
[End of figure]
Such an attack along a congested transportation corridor could have
severe public health and safety impacts. One expert said that before
converting from chlorine to alternative disinfection methods, a major
wastewater treatment plant in Washington, D.C., received its chlorine
supply via rail shipments that traversed through the center of the
city, close to the U.S. Capitol Building and across two military
installations before reaching its final destination. Derailments of
chlorine could have major impacts in small communities as well, as
occurred in Alberton, Montana, in April 1996. One of the five tankers
that derailed ruptured and reportedly released more than 60 tons of
chlorine. Subsequently, a toxic plume of chlorine gas crossed the Clark
Fork River, a major interstate, and surrounding residences. An
estimated 1,000 people were evacuated, 350 people were hospitalized,
and one person died.
Key Components of the Treatment Plant:
In addition to the vulnerability of chemicals stored at a wastewater
treatment plant, experts also listed the key process components of the
treatment plant as vulnerable. Specifically, more than half of the
experts (29 of 50) identified one or more of these components as among
the top five vulnerabilities. One expert explained that, historically,
security was not a consideration in site selection or design of these
facilities. While many utilities planned for natural disasters or
vandalism, it was only after September 11, that many utilities have
considered how best to protect against potential terrorist attacks.
While experts expressed concern over the security of the entire
treatment plant, several identified the headworks as a component that
is particularly vulnerable to attack, as well as critical to the
treatment process. This unit is part of a plant's primary treatment
process, where wastewater carried through the collection system first
enters the treatment plant. It is here that large objects, such as
cans, wood, and plastics are removed from the wastewater stream. These
structures may be open to the atmosphere and, according to one expert,
are easy to attack. Experts explained that sabotage of the headworks
could affect the proper working order of subsequent treatment processes
and could cause the immediate interruption of the collection system,
potentially restricting or completely blocking wastewater flow. As one
expert noted, restricted flow would could cause backups through the
collection system, and the stagnant wastewater would become a public
health hazard within hours, either through physical contact or through
cross-contamination of drinking water supplies.
Control Systems:
Control systems were also listed as a key vulnerability by 18 of the 50
experts. Many wastewater systems are increasingly relying on the use of
these control systems, including Supervisory Control and Data
Acquisition (SCADA) networks, to serve functions ranging from storing
and processing data to monitoring the system's condition and
controlling its operation. The primary role of SCADA systems is to
monitor and control dispersed assets from a central location. According
to one expert, "The backbone for process control is the SCADA system."
The expert explained that several factors contribute to the
vulnerability of these controls, including typically nonsecured process
control rooms at treatment plants, remote access to SCADA, and shared
passwords between multiple users.
Experts generally explained that an attack on these systems could
interfere with critical operations. For example, one expert explained
that an adversary could use SCADA systems to introduce either
dangerously high or inadequate levels of chemicals; reduce biological
treatment levels; or cause remote points along the collection system to
fail. Although some facilities could operate their systems manually
should the automated system fail or be compromised, others do not have
the personnel or equipment to do so. For example, as one expert noted,
large valves in modern plants are now typically operated electronically
and seldom used manual operation components (see fig. 7).
Figure 7: Pump Operated through Remote Automated Systems:
[See PDF for image]
[End of figure]
While SCADA networks offer operators increased flexibility and
efficiency by controlling processes remotely, they were not designed
with security in mind. The security of these systems is, therefore,
often weak.[Footnote 5] According to our experts, while many facilities
take advantage of their system's flexibility, they often do not provide
the necessary training on cyber security or implement security measures
such as rotating passwords or securing network connections. Experts
also explained that penetration of SCADA systems, particularly those
that may be nonencrypted and accessed via the Internet, offers a
particularly easy point of access and control of a wastewater system.
One expert provided an example of a breach in cyber security in 2000
when such a system in Australia was attacked, causing the release of
thousands of gallons of raw sewage. While the actions were not an act
of terrorism, they illustrate how a computer or cyber-related attack
could be used to disrupt wastewater treatment.
Pumping Stations:
Sixteen of the 50 experts identified pumping stations, which are
components that help convey sewage to the wastewater treatment plant,
as among the top vulnerabilities. One expert explained that destroying
or disabling a pumping station could cause the collection system to
overflow raw sewage into the streets and into surface waters and to
back up sewage into homes and businesses. The expert added that adverse
effects on public health and the environment are likely if the target
pump station pumps several million gallons per day of wastewater.
Another expert explained, that within a service area, one pumping
station has the capacity to pump 25 million gallons of wastewater per
day.
Experts explained that the remoteness and geographic distribution of
pumping stations, and their lack of continuous surveillance, make them
particularly vulnerable (see fig. 8). However, as one expert noted,
should these stations be disabled or destroyed, alternatives such as
"pump-around schemes," where sewage flow is diverted and rerouted, can
often be implemented within a few days or weeks.
Figure 8: Pumping Station:
[See PDF for image]
[End of figure]
Overarching Vulnerabilities Affecting Overall Wastewater System
Security:
In addition to the physical assets identified as among the greatest
vulnerabilities of wastewater systems, some experts also identified
vulnerabilities that may affect the overall security of the nations'
wastewater systems. First, they pointed out that wastewater utilities
generally do not have a security culture because they are often more
focused on operational efficiency and may, therefore, be reluctant to
add security procedures and access control elements to their
operations. For example, one expert noted the ease with which many
types of individuals (employees, contractors, and visitors) and
vehicles typically enter wastewater treatment plant facilities. As this
expert pointed out, some facilities do not check to ensure that
individuals entering the property have legitimate reasons for being
there. This expert also raised a concern about the lack of inspection
of incoming truckloads at some wastewater treatment plants. An
adversary could exploit this lack of security by delivering
contaminants or explosives to destroy the treatment process or the
entire facility. In addition to securing entrance checkpoints, two
experts suggested there is little background screening of utility
employees. One expert noted, "People with criminal records, falsified
educational credentials, and other serious liabilities might be hired
by utilities that fail to thoroughly check their backgrounds. The
result can be intentional acts of terrorism on a utility."
Second, experts pointed to interdependencies among all major wastewater
assets within the treatment system. The system as a whole relies on the
proper working order of all its components to treat a community's
wastewater. One expert explained that, because treatment plants are
less able to recover from an attack, they may have a higher level of
security than other assets, such as the collection system. However,
because collection and treatment are part of one integrated system,
securing one asset does not ensure that the system as a whole is more
protected. For example, gates and fences around the main treatment
plant may stop an adversary from coming onto the physical property, but
it will not prevent a harmful agent from entering the facility through
the collection system--an event that could destroy the facility's
entire secondary treatment process.
Third, experts identified interdependencies between wastewater systems
and other critical infrastructures. As several experts explained,
disruptions in electric power, cyber systems, and transportation of
treatment chemicals can result in a failure of wastewater treatment
systems. One expert cautioned that the interruption of the power grid
could render the wastewater plant useless, noting, "Several hours
without power would cause the biological treatment process to halt and
wastewater would back up on the collection system." Such an event
occurred in 2003, when a major power failure caused treatment plants in
Cleveland, Ohio, to release at least 60 million gallons of raw
untreated wastewater into receiving waters. Without electric power,
operators had no other option but to bypass treatment and directly
discharge the untreated sewage into Lake Erie or the Cuyahoga River and
other tributaries.
Conversely, there are instances in which other infrastructure and
activities may depend on treated wastewater to properly function. For
example, in some parts of the country, effluent is reclaimed and used
as cooling water for power generation, to recharge groundwater, or to
water outdoor landscapes. One expert noted that wastewater treated at a
plant in the arid Western United States is reclaimed and used to
provide the only cooling source for a nuclear power plant that provides
power for much of that region. According to the same expert, the
immobilization of this treatment plant could, within a certain number
of days, disable the nuclear plant, causing a major, multistate power
outage.
[End of section]
Chapter 3: Experts Identified Wastewater Security-Enhancing Activities
That Warrant Federal Support:
Experts most frequently identified 11 specific activities to improve
wastewater security as deserving high priority for federal support (see
fig. 9). Three activities are particularly noteworthy because they were
given a rating of highest priority by a substantial number of the
experts. These activities include the following:
* Replacing gaseous chemicals used in wastewater treatment with less
hazardous alternatives. Experts viewed these actions as essential to
reduce the vulnerability inherent in systems that rely upon the
transport, storage, and use of potentially hazardous materials such as
gaseous chlorine in their treatment processes. Several experts noted
that replacement could be cost prohibitive for many wastewater
utilities and that it, therefore, warranted federal support.
* Improving local, state, and regional collaboration efforts. Experts
identified the development of strong working relationships among
utilities and public safety agencies as critical to protecting
wastewater infrastructure and system customers from potential threats.
Some experts also noted that enhanced partnerships among these groups
would result in improved response capabilities should a wastewater
system be attacked.
* Completing vulnerability assessments for individual wastewater
systems. Experts cited these as necessary for utilities to understand
their security weaknesses, to identify appropriate countermeasures, and
to implement risk reduction strategies in a logical, coordinated manner.
The remaining eight activities experts frequently rated as warranting
high or highest priority for federal funding include (1) providing
training to utility employees related to conducting vulnerability
assessments and improving the security culture among employees; (2)
improving national communication efforts between utilities and key
entities responsible for homeland security; (3) installing early
warning systems in collection systems to monitor for or detect
sabotage; (4) hardening physical assets of treatment plants and
collection systems; (5) strengthening operations and personnel
procedures; (6) increasing research and development efforts toward
improving threat detection, assessment, and response capabilities; (7)
developing voluntary wastewater security standards and guidance
documents; and (8) strengthening cyber security and Supervisory Control
and Data Acquisition (SCADA) systems.
Figure 9: Experts' Views on Wastewater Security Activities Most
Deserving of Federal Support:
[See PDF for image]
[End of figure]
Replace Gaseous Chemicals with Less Hazardous Alternatives:
Over half of the experts surveyed (29 of 50) rated the replacement of
gaseous chemicals at wastewater treatment facilities with less
hazardous alternatives as warranting highest priority for federal
funding. Another 14 experts rated this activity as high priority.
Experts reported that wastewater systems carrying out treatment
processes using gaseous forms of chemicals, particularly chlorine, make
themselves targets for terrorist attack. However, as one expert noted,
changing disinfection technologies effectively devalues these
facilities as targets for "weaponization" of their existing
infrastructure.
Several experts noted that some communities and utilities currently
using gaseous chemical treatment processes have expressed interest in
converting to an alternative treatment technology, but the financial
costs associated with conversion remain prohibitive. However, one
stated that replacing gaseous chemical treatment technology can
actually result in certain offsetting cost savings. For example, the
Blue Plains Wastewater Treatment Plant in Washington, D.C., employed
around-the-clock police units prior to replacing its chlorine gas
treatment process. Following conversion to a less hazardous treatment
technology, Blue Plains found that it could reduce this security
posture. In addition, the utility was able to reduce the need for
certain emergency planning efforts and regulatory paperwork.
Experts suggested alternative treatment technologies such as sodium
hypochlorite (a solution of dissolved chlorine gas in sodium hydroxide)
and ultraviolet disinfection. These alternative processes have been
implemented at several facilities throughout the United States,
including Washington, D.C; Atlanta, Georgia; Philadelphia,
Pennsylvania; Cincinnati, Ohio; Jacksonville, Florida; and Harahan,
Louisiana. The change, for an individual plant, to sodium hypochlorite
may require approximately $12.5 million for new equipment and increase
annual chemical costs from $600,000 for gaseous chlorine to over $2
million for sodium hypochlorite.[Footnote 6]
Another expert suggested that reducing the size of containers used to
transport and store gaseous chemicals could also prove an effective
deterrent to terrorism. This approach is being implemented by a
treatment plant in the Western United States, where gaseous chlorine is
now stored in 1-ton canisters--a significant reduction in size from the
larger 90-ton railroad tanker car size containers the utility
previously employed (see fig. 10).
Figure 10: One-Ton Canisters of Chlorine Gas Stored at a Wastewater
Treatment Plant:
[See PDF for image]
[End of figure]
Improve Local, State, and Regional Collaboration Efforts:
Twenty-three of 50 experts rated efforts to improve local, state, and
regional collaboration as warranting highest priority for federal
funding. Fifteen more experts rated this activity as high priority.
Several experts noted the importance of establishing strong working
relationships among utilities, local and state law enforcement
agencies, fire departments, and other first response agencies in
advance of a potential emergency situation. Many added that enhanced
partnerships among these entities can yield significant benefits to
wastewater utilities including an increased ability to monitor critical
infrastructure and facilities, improved understanding of agency roles
and responsibilities, and faster response time to deal with potential
security breaches.
According to one expert, significant personnel and other resources
devoted to emergency response are theoretically available to the
wastewater sector. These resources include law enforcement agencies,
fire departments, public health care facilities, environmental
authorities, and other nonprofit and commercial entities. However, the
expert noted that wastewater facilities remain largely disconnected
from these entities, and wastewater facilities' efforts for emergency
response planning are, therefore, often undertaken independently.
Consequently, emergency response teams do not gain a full understanding
or appreciation of the unique challenges inherent in maintaining a
utility's wastewater treatment capability.
This lack of collaboration perpetuates the community's idea that
"sewers lead to [a] magical place where [materials] simply 'go away'
without consequence," one expert suggested. The expert added that this
misperception is demonstrated by a failure of some in the medical
response community to adequately plan for proper disposal of waste
resulting from decontamination efforts of a chemical, biological, or
radiological event. Directly discharging such material to the
wastewater influent stream could significantly damage or destroy the
wastewater treatment process.
Collaboration among local, state, and regional agencies should include
periodic field and "tabletop" exercises to establish and reevaluate the
roles, capabilities, and responsibilities of agencies that would
respond to a terrorist event, according to one expert. Another
identified the nonprofit California Utilities Emergency Association, an
entity to which most utilities in that state belong, as an effective
provider of communications, training, mutual aid coordination, and
simulation exercises. The expert also cited the San Francisco Bay Area
Security Information Collaborative as a successful example of regional
collaboration in which participating water utilities coordinate
communications, responses, and emergency planning.
The Environmental Protection Agency (EPA) has provided funding for
training on emergency response for wastewater utilities through
agreements with the Wastewater Operator State Environmental Training
Program, the Water Environment Federation, and other organizations.
Through the Department of Homeland Security's Office of Domestic
Preparedness, EPA has funded emergency response table-top exercise
training to the nation's larger wastewater utilities.
Complete Vulnerability Assessments:
Twenty of 50 experts rated the completion of vulnerability assessments
as warranting highest priority for federal funding. Fourteen other
experts rated this activity as high priority. Vulnerability assessments
help water utilities evaluate their susceptibility to potential threats
and identify corrective actions to reduce or mitigate the risk of
serious consequences from vandalism, insider sabotage, or terrorist
attack. One expert explained that this process enables a utility to
evaluate its terrorist-related vulnerabilities and begin to implement
security enhancement plans that directly address those identified
vulnerabilities. Another added that the assessments also present useful
findings that should be incorporated into a utility's emergency
response plan and that they enable an active process for updating and
exercising those plans.
The Bioterrorism Act of 2002 required vulnerability assessments for
drinking water utilities serving more than 3,300 people but did not
include a comparable requirement for wastewater utilities. To foster
the completion of vulnerability assessments among wastewater utilities,
EPA has funded the development of vulnerability assessment
methodologies and provided training to wastewater utilities. EPA has
encouraged wastewater utilities to use methodologies such as those
provided by the National Environmental Training Center for Small
Communities, on security and emergency planning, and the Vulnerability
Self Assessment Tool (VSAT), developed and released by the Association
of Metropolitan Sewerage Agencies. The VSAT methodology and
accompanying software provide an interactive framework for utilities of
all sizes to analyze security vulnerabilities to both manmade threats
and natural disasters, evaluate potential countermeasures for these
threats, and enhance response capability in the event of an emergency
situation. This methodology has been continually updated and improved;
VSAT Version 3.1 is currently available to utilities. Through EPA
support, the Water Environment Federation has provided extensive
training of the VSAT tool free of charge to wastewater utility
operators and others involved in environmental protection, public
safety, and security.
Expand Training Opportunities for Wastewater Utility Operators and
Administrators:
Thirteen of the 50 experts rated the expansion of training
opportunities for utility personnel as warranting highest priority for
federal funding, and an additional 27 experts suggested this activity
warranted a high priority. According to experts, creating a security-
minded culture among wastewater utilities is critical to building
awareness of security vulnerabilities and implementing appropriate
countermeasures.
In particular, experts noted that wastewater system operators and
administrators need to become better educated about the importance of
focusing on security and emergency preparedness issues. Several experts
suggested that managers should have a full understanding of potential
types of terrorist attacks and the systems or mechanisms that could
preclude or mitigate these events. They added that other parties,
including boards of directors of wastewater systems, mayors, and city
councils need to be made aware of potential threats to wastewater
systems and the impact a terrorist event could have upon a facility.
One expert stated that successful development of security awareness
among those associated with wastewater systems could mean the
difference between simply installing security systems and actually
becoming secure.
Experts also stated that additional technical training for operators is
necessary to ensure the security of wastewater systems. One noted that
this type of training could avert a catastrophe by enabling a
wastewater operator to recognize a pending disaster as early as
possible. Another expert stated that increased technical training,
particularly for smaller wastewater utilities, is necessary to ensure
that funds for physical security enhancements are used to their maximum
potential, thus achieving maximum benefit for the wastewater utility.
One expert also suggested that devoting funding toward increased
technical training will provide wastewater utility employees with the
skills necessary for developing comprehensive vulnerability assessments
and implementing emergency response plans before a terrorist attack.
Since 2002, EPA has provided more than $10 million to help address the
security needs of the wastewater sector. A large portion of this
funding has been awarded to nonprofit technical support and trade
organizations to develop tools and training on conducting vulnerability
assessments to reduce utility vulnerabilities and on planning for and
practicing response to emergencies and incidents.
Improve National Communication Efforts between Utilities and Key
Entities Responsible for Homeland Security:
While only 8 of 50 experts rated efforts to improve communications
between utilities and federal entities responsible for homeland
security as warranting highest priority for federal funding, well over
half of the experts surveyed (31 of 50) rated this activity as high
priority. One expert stated that it is essential to develop an
effective communications strategy that involves the broad range of
stakeholders responsible for ensuring wastewater security. Another
emphasized that wastewater utilities need timely and useful information
from federal authorities about increased threat levels and protective
actions that should be implemented.
To improve national communications, EPA provided a grant to AMWA to
develop the Water Information Sharing and Analysis Center (Water ISAC).
The Water ISAC is a secure, Internet-based subscription service that
provides time-sensitive information and expert analysis on threats to
both wastewater and drinking water systems. It serves as a key link in
the flow of water security information among utilities and federal
homeland security, intelligence, law enforcement, public health, and
environmental agencies.
However, according to some experts, Water ISAC does not sufficiently
ensure adequate communication between federal agencies and utilities.
One stated that despite a high reliance upon Water ISAC by drinking
water utilities, this communication vehicle has proven inadequate for
meeting the needs of the broad range of stakeholders involved in
protecting drinking water security. This expert added that the Water
ISAC needs to be better developed if it is to be an essential part of a
communications strategy for the wastewater sector. Another expert noted
that several water utilities have avoided the Water ISAC because of the
subscription fees associated with the service. In the fall of 2004, the
Water ISAC announced a new communication tool known as Water Security
Channel. The Water Security Channel is a password protected site that
electronically distributes federal advisories regarding threat
information to the water sector. Water Security Channel is a service
that is free of charge to any wastewater or drinking water utility that
wishes to participate.
For its part, the Department of Homeland Security is implementing its
Homeland Security Information Network (HSIN) initiative, which will
provide a real-time, collaborative flow of threat information to state
and local communities, as well as to individual sectors. According to
the department, this network will be the only tool available that
provides collaborative communications between first responders,
emergency services, the government (local, state, and federal) and
other sectors on a real-time basis. In addition, the department has
established a Water Sector Coordinating Council to identify information
and other needs of the sector, including the appropriate use and the
relationships among the Water ISAC, the Water Security Channel, and
HSIN.
Install Early Warning Systems in Collection Systems to Monitor for or
Detect Sabotage:
Seven of 50 experts rated the installation of early warning systems in
collection systems to monitor for or detect sabotage as warranting
highest priority for federal funding, and an additional 31 experts
rated this activity as a high priority. A device these experts
frequently mentioned to achieve some degree of monitoring and detection
for explosive substances is the lower explosive level (LEL) meter,
which can be inserted into manholes and connected to central computers.
One expert claimed LEL meters have significantly improved response time
in mitigating the potential for structural damages resulting from
explosions within the wastewater collection system.
One expert also noted that disabling the biological processes occurring
at a wastewater treatment plant would require a large amount of toxic
compounds to be inserted into the collection system, but several
experts stated that this possibility remains of concern because of the
open access collection systems afford. Many experts suggest that
additional research is needed to develop early warning technologies
that can sense the presence and concentration of these types of toxic
compounds in the collection system and relay that information
electronically to treatment operators.
Harden Physical Assets of Treatment Plants and Collection Systems:
Eight of 50 experts rated physical hardening of treatment plants and
collection systems as warranting highest priority for federal funding
and an additional 29 experts rated this activity as high priority.
Experts stated that physically securing the perimeter of the treatment
plants and pumping stations with fences, locks, security cameras, alarm
systems, motion detection systems, and other physical barriers can
protect critical treatment components from direct attack or sabotage
(see figs. 11 and 12). One expert noted that the more difficulty
terrorists encounter in trying to reach critical targets in a
wastewater system, the less frequently attacks will be attempted, and
the lesser the impact will be if and when these attempts succeed.
Furthermore, improvements to perimeter defenses surrounding wastewater
treatment systems not only deter terrorist intruders but also restrict
access by vandals, contributing toward improved reliability of
electronic surveillance systems. As one expert pointed out, physical
hardening of assets can largely be accomplished with hardware that
requires only minimal maintenance and replacement cost once installed.
Figure 11: Electronically-Controlled Security Gate:
[See PDF for image]
[End of figure]
Figure 12: Security Camera and Infrared Motion Detectors:
[See PDF for image]
[End of figure]
Other experts suggested that actions are needed to provide redundant
capabilities to wastewater treatment systems. According to experts,
additional power, pumping, and collection bypass systems would provide
more reliable treatment capacity that would benefit the public not only
in the event of terrorism but also during nonterrorist events (e.g.,
natural disasters, weather-related events, or interrelated
infrastructure failures). Such actions could ensure that wastewater
systems maintain full treatment capabilities during a variety of
unforeseen catastrophic events.
Although one expert claimed that protecting the several hundred miles
of sewers in a large urban system is virtually impossible, other
experts suggested that design improvements and physical alterations
could limit access to collection systems. Some experts suggested
securing manhole covers with maintenance-friendly lockdown mechanisms.
In addition, one expert suggested improving engineering designs for
wastewater systems in ways that reduce vulnerability risks posed by
infrastructure cross-connections with other water systems.
Strengthen Operations and Personnel Procedures:
Seven of 50 experts rated the strengthening of operations and personnel
procedures at wastewater systems as warranting highest priority for
federal funding, and an additional 24 experts rated this activity as a
high priority. For example, one expert suggested that a highly
efficient background check system should be available to water
utilities to get accurate information on new and existing employees,
contractors, and others who are working at vital facilities, such as
wastewater treatment plants. This expert noted that access to such
systems is afforded to airport administrators and certain law
enforcement entities but is largely inaccessible to water utilities.
Another expert stated that wastewater utilities need procedures to
ensure the security of collection system maps and drawings, while also
allowing reasonable access to them by contractors and developers. The
expert suggested maps could be electronically stored and password
protected with a regularly changed password. Another expert suggested
that all employees and visitors have identification badges with
photographs and electronic strips or sensors that regulate points of
access allowed by the badge.
Increase Research and Development Efforts to Improve Detection,
Assessment, and Response Capabilities:
Thirteen of 50 experts rated expanded research and development efforts
to improve detection, assessment, and response capabilities for
wastewater systems as warranting highest priority for federal funding,
and an additional 17 experts suggested this activity warranted a high
priority. One expert stated that new technologies are needed in the
wastewater sector to better protect physical assets by providing
reliable surveillance and detection capabilities with a minimal need
for on-site, around-the-clock security personnel. According to another
expert, technologies currently in development for drinking water
utilities could potentially be adapted for use by wastewater utilities.
These technologies would need to detect hazardous chemical, biological,
or radioactive contaminants while operating in the harsh environment of
common, everyday contaminants found in sewage. Also, improved computer
mapping systems tracking the course and speed of sewage flow could
greatly enhance emergency response activities including evacuations,
dilutions of harmful substances that have been introduced to the sewage
flow, and venting of volatile materials.
EPA's Office of Research and Development has recently funded research
that is intended to address many of these needs. According to an
official with EPA's Water Security Division, while these efforts have
been primarily directed toward drinking water security research, some
of EPA's research findings can be applied to wastewater security. EPA
has also developed a water security research and technical support
action plan that outlines various research and technical support needs
that the water industry and other stakeholders have identified. The
plan also proposes specific projects to address these needs, and EPA
has begun work on some of these projects in collaboration with the
Water Environment Research Foundation and the American Water Works
Association Research Foundation. These nonprofit research organizations
have received funding to address a variety of wastewater security
research projects, such as assessing new security technologies to
detect and monitor contaminants and prevent security breaches.
According to EPA, other issues being addressed include public health
protection, vulnerability and protection of water and wastewater
infrastructure, and communication in the event of deliberate attacks or
natural disasters.
Develop Voluntary Wastewater Security Standards and Guidance Documents:
Four of 50 experts rated the development of voluntary wastewater
security standards and guidance documents as warranting highest
priority for federal funding, and half of the experts surveyed (25 of
50) gave this activity a high priority rating. Experts identified
options including development and issuance of voluntary standards for
security of wastewater facilities (including design standards), a peer
review process to evaluate the quality of wastewater utilities'
vulnerability assessments and emergency response plans, and creation of
a secure Web site that disseminates lessons learned by utilities
throughout the various phases and processes related to protecting
wastewater security.
One expert suggested that developing government standards for the
security of all new facilities would help increase the overall ability
of wastewater systems to withstand threats. The expert stated such
standards should lay out minimum protection standards and provide a
framework of threats utilities should consider when completing
vulnerability assessments. Another expert suggested that, because water
utilities seek guidance from the federal government on whether their
individual treatment plants are secure, one option, in lieu of site
visits by EPA, might be a peer review process of vulnerability
assessments and emergency response plans across wastewater utilities.
Development of a secure Web site for wastewater utilities that includes
lessons learned from assessments, planning, training, and incident
responses could also provide valuable guidance for wastewater
utilities, one expert noted.
EPA recently commissioned a study by the National Drinking Water
Advisory Council's Water Security Working Group to address some of
these needs. The group's charge is to identify: (1) the features of an
active and effective security program for drinking water and wastewater
utilities; (2) incentives that would encourage water utilities to
implement features of the security program; and (3) ways to measure the
extent of utility implementation of the security program. In addition,
in September 2003, EPA gave funding to the American Society of Civil
Engineers to develop voluntary security standards for drinking water,
wastewater, and stormwater utilities, which were released in December
2004 as interim standards. A training module is planned for spring 2005.
Strengthen Cyber Security and SCADA Systems:
Five of 50 experts rated efforts to improve cyber security and SCADA
systems as warranting highest priority for federal funding, and an
additional 22 experts gave this activity a high priority rating.
According to one expert, measures should be taken to minimize access to
these systems by improving the security capabilities of hardware
systems and software applications, as well as by implementing
appropriate information technology security policies at wastewater
utilities.
One other expert suggested the federal government invest in programs
designed to create, accelerate, and deploy minimally acceptable cyber
security standards for all automated systems where a compromising event
could place a surrounding population at risk. This expert noted that
the need for cyber security standards is not limited exclusively to
wastewater systems, but stated that the particular needs and
characteristics of these utilities should be considered as these
standards are developed.
[End of section]
Chapter 4: Experts Identified Key Allocation Criteria and Funding
Mechanisms for Addressing Wastewater Security Needs:
Numerous wastewater utilities have begun to address security concerns
by completing vulnerability assessments or by undertaking security
upgrades. To date, most security initiatives have been financed by
reallocating funds from other important utility activities or embedding
security into ongoing operations. According to industry
representatives, utilities may ultimately have no choice but to pass
these costs along to their customers through rate increases. Given the
cost of these security actions, however, many in the utility industry
believe federal assistance through the congressional appropriations
process is warranted. Experts do not all agree that the wastewater
industry as a whole should receive funding priority, noting that other
sectors such as electricity or transportation may warrant higher
priority. Indeed, while the vast majority of our experts did support
federal funds for security for wastewater utilities, some voiced
dissenting opinions on the matter.
Nonetheless, should Congress and the administration agree to a request
for funds, 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 (1) the types of
utilities that should receive funding priority and (2) the most
effective mechanisms for directing these funds to potential recipients.
Overall, we found a high degree of consensus on the following:
* Thirty-nine of the 50 experts indicated that utilities serving
critical infrastructure (including government, commercial, industrial,
and public health centers) should be given highest priority for federal
funding. Half of the experts gave utilities using large quantities of
gaseous chemicals a rating of highest priority while just under half of
the experts gave the same rating to utilities serving large populations.
* Direct federal grants are the most favored funding mechanism, with
many experts indicating the circumstances in which such grants should
or should not include matching funds from the recipient. Many favored
direct grants without a matching requirement for a wide variety of
planning and coordination activities, such as completing vulnerability
assessments, conducting training, and developing standards and
guidance. Cost-shared grants were favored for activities that benefit
individual utilities, such as strengthening operation and personnel
procedures, installing early warning systems in collection systems, and
hardening physical assets.
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 critical infrastructure including government,
commercial, industrial, and public health centers; (2) using large
quantities of gaseous chemicals; (3) serving areas with large
populations; (4) where a security breach would adversely impact
environmental resources (e.g., receiving waters); (5) having completed
vulnerability assessments; (6) serving areas with medium or small
populations; and (7) serving buildings, monuments, parks, tourist
attractions or other entities that have symbolic value (see fig. 13).
Figure 13: Experts' Views on Which Characteristics of Wastewater
Utilities Should Be Used to Set Priority for Federal Funds:
[See PDF for image]
[End of figure]
Utilities Serving Critical Infrastructure:
More than three quarters of the experts (39 of 50) gave utilities
serving critical infrastructure a highest priority rating. An
additional 10 experts gave these utilities a rating of high priority.
These utilities provide service to institutions that serve as hubs for
government activity; commercial and industrial centers, such as a
city's financial district, power plants, or major airports; and public
health institutions, such as major medical centers and hospitals. As
one expert commented, "while every wastewater system is a potential
target, it seems prudent to assume that the larger the system or the
criticality of facilities served, the greater the potential impact and
hence the more likely the target." Most experts shared this view,
including one who said the highest priority should go to "the impact
the loss of the treatment facility would have on other vital services"
such as providing cooling water for a nuclear or steam generating power
plant.
Some experts said that systems with heavy commercial and industrial
usage are critical to the country's economic stability, and any major
or sustained disruption could have severe economic as well as public
health consequences. For example, one expert pointed out that critical
industrial customers such as the computer chip manufacturing sector
could cost the economy millions per day should a shutdown be caused by
the loss of a wastewater treatment plant.
Utilities Using Large Quantities of Gaseous Chemicals:
More than half of the experts (26 of 50) gave a rating of highest
priority for funding of utilities using large quantities of gaseous
chemicals. An additional 18 experts rated these utilities as warranting
a high priority for federal funds. Some experts pointed out that many
wastewater treatment plants use large quantities of elemental chlorine
and other toxic materials which, if released to the atmosphere on-site
or during transport to the site, would necessitate widespread
evacuations, and possibly cause injuries and fatalities.
Several experts pointed out that the Environmental Protection Agency's
(EPA) Risk Management Planning program requires industrial facilities
that use threshold amounts of certain extremely hazardous substances to
self-identify their worst-case chemical release scenarios. An expert
cautioned, however, that funds should not be provided to utilities for
converting to less hazardous chemicals (e.g., sodium hypochlorite) when
other utilities have already or are currently looking at disinfection
options that could pose little or no security worker risk, or public
health risks.
Utilities Serving Areas with Large Populations:
Almost half of the experts (24 of 50) gave a rating of highest priority
to utilities serving areas with large populations. Seventeen additional
experts rated these utilities as warranting a high priority for federal
funds. Many experts shared the view that providing financial and
technical assistance to the largest treatment plants would protect the
greatest number of people. One expert pointed to EPA's 2000 Clean Water
Needs Survey, which indicated that about 70 percent of the nation's
sewered population is served by the 3,500 largest wastewater facilities
(out of a total of 16,000 facilities). Each of these facilities
maintains a flow that is greater than 1 million gallons per day. Thus,
this expert concluded, funding the largest plants provided benefits to
the greatest number of people. Finally, a number of experts suggested
that because terrorists are likely to seek to maximize the number of
people killed or injured by their attacks, they may try to strike
systems serving many customers in large metropolitan areas.
Utilities Where a Security Breach Would Adversely Impact Environmental
Resources:
While only four experts gave a rating of highest priority to utilities
where a security breach would adversely impact environmental resources,
28 of the experts rated these utilities as warranting a high priority.
Several experts pointed out the potential for a negative impact on the
environment and public health if raw sewage overflows into receiving
bodies of water. One expert commented that many wastewater treatment
plants discharge highly treated effluent to rivers upstream of the
intakes to water treatment plants serving downstream cities. Damage to
these wastewater treatment plants could cause the discharge of raw
sewage that would be only partially diluted before it reached the
intakes of the downstream drinking water treatment plants. Experts also
cited significant potential effects on the environment. Some mentioned
that the discharge of untreated sewage could impact beaches, critical
habitats, or fisheries, causing economic damage in addition to negative
environmental and public health effects.
Utilities That Have Completed Vulnerability Assessments:
Three of the experts gave a highest priority rating to utilities that
have completed vulnerability assessments (VAs). An additional 18
experts gave these utilities a high priority rating. Some experts said
that only utilities that have completed VAs should be given federal
funding. Other experts pointed out that there should be federal funding
for those utilities that have not yet completed VAs so that they can
complete this key task. As one expert commented, a key benefit of
conducting a vulnerability assessment of a wastewater system is that it
allows the areas of the greatest need to be identified.
Properly conducted, a vulnerability assessment brings in all the
necessary divisions within a plant including operations, information
technology, management, and external forces such as fire departments
and local police. Should a plant demonstrate that it has conducted such
an assessment, that plant would be much more likely to use federal
funding efficiently, this expert added.
Utilities Serving Areas with Medium or Small Populations:
Eight of the 50 experts rated utilities serving areas with medium or
small populations as a high priority for federal funding. An additional
27 experts rated these utilities as a medium priority. One expert
pointed out that such facilities are least able to afford security
enhancements or acquire the security expertise and, therefore, may be
in need of federal support.
The relatively small number of experts giving a high or highest
priority rating for utilities serving areas with medium or small
populations may not fully reflect the concern among some experts for
the safety of these utilities. For example, some who gave a higher
priority rating to utilities serving areas with large populations
suggested that the need for federal support should be an important
associated criterion, regardless of system size. Accordingly, these
experts said that some funding could be justified for both large and
small populations based on need. One expert favored a bifurcated focus
with one effort seeking to ensure minimal levels of security for all
utilities, and another expert favored more intensive efforts focusing
on systems serving larger populations.
Utilities Serving Entities That Have Symbolic Value:
Only one expert gave a highest priority rating to utilities serving
buildings, monuments, parks, tourist attractions, or other entities
that have symbolic value. An additional 10 experts rated these
utilities as warranting a high priority. One expert commented that
terrorists have already shown that they want to cause serious economic
damage by disrupting tourism. Another noted that terrorists have also
targeted cities that have stadiums, convention centers, and other
attractions where large numbers of people gather.
Funding Mechanisms Recommended for Distributing Federal Funds:
When we asked the experts to identify how best to distribute federal
funds that may be made available to utilities to address wastewater
security, they overwhelmingly indicated that direct federal grants to
utilities would be the most effective mechanism. The experts also
indicated that grants in which some type of match is required of
recipients would be effective. Relatively fewer experts indicated that
the use of trust funds or the Clean Water State Revolving Fund,
particularly for upgrades to be implemented in the short term, would be
effective. Other mechanisms that were rated as less effective included
loans, or loan guarantees, and tax incentives for private utilities.
Figure 14 shows how experts rated six different mechanisms for funding
wastewater security.
Figure 14: Experts' Views on Mechanisms for Funding Wastewater
Security:
[See PDF for image]
[End of figure]
Direct Federal Grants:
Thirty-four of the 50 experts indicated that direct federal grants to
the utility would be very effective in allocating federal funds. An
additional 12 said these mechanisms would be somewhat effective in
doing so.
Experts expressed a variety of views regarding how best to implement
these grants. For example, some cautioned that a grant program for
wastewater security should be solely dedicated to the protection of the
wastewater infrastructure, rather than being consolidated together with
other programs, such as grants for enhancing homeland security. One
said that, contrary to the way grant programs usually operate,
utilities should be allowed to apply for grants during project
implementation or even after the project is completed. This could
reward those who were proactively addressing their security needs.
Among other suggestions, one expert said that EPA and the Department of
Homeland Security (DHS) should collaborate on allocating these grant
funds. This expert stated that "EPA has technical knowledge about
facility operations that is especially important and DHS has grant
funds for homeland security that could be quickly made available until
Congress approves a special allocation." Some experts also commented
that direct grants are preferable because they are more likely to
result quickly in safety improvements and other desired changes.
Experts also offered opinions on situations in which it would be
appropriate to offer a grant without requiring a matching contribution
from the recipient. Many, for example, favored direct grants with no
match for activities that benefit multiple utilities, or which should
be addressed in the near term. Such actions would include conducting
research and development to improve detection, developing voluntary
wastewater security standards and guidance, completing vulnerability
assessments, and providing training to utility security personnel on
how best to conduct vulnerability assessments and improve the security
culture.
Grants with Matching Requirement (Cost-Shared Grants):
Thirty of the 50 experts indicated that grants with a matching
requirement (cost-shared grants) would be very effective as a mechanism
for providing funds to wastewater utilities. An additional 16 rated
such grants as somewhat effective.
Experts generally favored cost-shared grants for activities that
benefit individual utilities. For example, 38 of the 50 experts
indicated that cost-shared grants were best for strengthening operation
and personnel procedures, such as securing sewer maps and conducting
background checks on new employees. Almost three-quarters of the
experts (36 of 50) indicated that cost-shared grants were also best for
installing early warning systems in collection systems to monitor for
or detect sabotage. Similarly, 32 of the 50 experts indicated that
recommended cost-shared grants would be best for improving cyber
security and for activities required to harden physical assets, such as
building fences, installing locks, and securing manhole covers.
Clean Water State Revolving Fund:
The Clean Water State Revolving Fund (CWSRF) is an EPA-administered
program that provides grants to the states to allow them to assist
publicly owned wastewater utilities. States, in turn, use the funds to
provide loans to participating wastewater utilities to assist them in
making infrastructure improvements needed to protect public health and
ensure compliance with the Clean Water Act. Five experts indicated that
the CWSRF would be a very effective funding mechanism to improve
wastewater security. An additional 35 indicated that it would be
somewhat effective.
According to an EPA Fact Sheet, states may use the CWSRF to assist
utilities in completing a variety of security-related actions, such as
vulnerability assessments, contingency plans, and emergency response
plans. In addition, the EPA Fact Sheet identifies other infrastructure
improvements that may be eligible for CWSRF funds, such as the
conversion from gaseous chemicals to alternative treatment processes,
installation of fencing or security cameras, securing large sanitary
sewers and installing tamper-proof manholes.[Footnote 7] Some experts
said that the advantage of the CWSRF is its ability to leverage
appropriated federal funds, thereby enabling it to assist more
facilities than direct federal grants.
A number of experts, however, expressed caution about relying heavily
on the CWSRF to support security enhancements. Several questioned
whether the CWSRF was appropriate in an environment where quick,
emergency-related decisions were needed, noting that the administrative
process in applying for and receiving the funds can be lengthy. Another
noted that the CWSRF "was not originally established to deal with
security-related projects," and that the program therefore "either
needs to [be] fixed to deal with security issues or a separate program
needs to be created specifically for security projects." Another expert
noted that unless additional security-related monies were added to
existing CWSRF levels, it would divert much needed funding away from
the kind of critical infrastructure investments that have been the
CWSRF's primary purpose.
Loans or Loan Guarantees:
Loans are a disbursement of funds by the government to a nonfederal
borrower under a contract that requires the repayment of such funds
with or without interest. Loan guarantees represent a nonfederal loan
to which a federal guarantee is attached.[Footnote 8] Only one expert
indicated that loans and loan guarantees would be very effective
mechanisms for providing federal support for wastewater security. An
additional 34, however, indicated they would be somewhat effective.
Generally, these experts cited the primary advantage of loans or loan
guarantees as offering communities the option to amortize security-
related costs over an extended period of time, while minimizing the
overall cost to the federal treasury. Another expert commented that a
low interest loan could provide some incentive and needed capital to
implement security programs.
A number of experts, however, expressed reservations. One cautioned
that the establishment of any federal loan program to support
wastewater security needs should not come at the expense of federal
support for the CWSRF, given the critical infrastructure needs that
already depend on it for support. Another questioned the value of loans
to utilities already strapped for funds, noting that "while loans have
less impact on the federal government, many wastewater utilities and
local governments generally carry a heavy debt load for capital
improvements, and they cannot add significant additional debt that
could affect their bond ratings."
Trust Funds:
Federal trust funds are accounting mechanisms used to link receipts
(from particular taxes or other sources) that by law have been
dedicated for a specific purpose or program, such as for infrastructure
improvement. For example, such a mechanism is in place for the
transportation sector through the Highway Trust Fund. Eight experts
indicated that trust funds would be a very effective mechanism for
distributing funds for the wastewater security sector. An additional 7
said they would be somewhat effective. However, almost half of the
experts (24 of 50) indicated that they either had no opinion on this
subject or that trust funds were "neither effective nor ineffective."
Experts raised a number of issues as to how the trust fund concept
would be implemented. A key consideration was whether the fund would be
dedicated solely to wastewater security needs, or be part of a broader
fund that serves other wastewater infrastructure needs.[Footnote 9] One
expert suggested that, if wastewater security needs have to compete
with the broader range of the wastewater industry's infrastructure
needs, they may not receive sufficient priority to be funded
adequately. Another expert suggested that a trust fund should be
supported annually by the federal government and local wastewater
utilities, and administered in a manner similar to the former
Wastewater Construction Grants program that funded wastewater
construction. This expert indicated that the fund should be used
exclusively for enhancing wastewater security.
Tax-Based Incentives:
Federal tax-based incentives may include new tax credits for spending
on security improvements and the existing exemptions from federal
income tax of interest income from state and local government bonds.
One expert indicated that tax incentives are very effective, and an
additional 14 said they are somewhat effective. Notably, 20 experts
indicated that tax-based incentives would be very ineffective--a result
due in part to the fact that most wastewater utilities are publicly
owned and operated and would, therefore, not benefit from tax-based
incentives, like tax credits that would be used to reduce federal
income tax.
Nonetheless, some experts said that for the smaller proportion of
privately owned systems, tax-based incentives could be beneficial and
particularly efficient. One expert noted, for example, that "in those
cases where the wastewater treatment facility is privately owned,
nothing succeeds as well as tax incentives." Recognizing the diversity
of wastewater systems, this expert stated further that the owners know
their utility better than anyone and are best able to achieve results
in a more cost effective way, if they are incentivized.
Conclusions:
To date, the federal government's role in promoting wastewater security
has been limited primarily to supporting various training activities on
completing vulnerability assessments and emergency response plans and
several research projects addressing how contaminants affect treatment
systems and other areas. However, legislation supporting an expanded
federal role, including a substantially greater financial commitment,
has been proposed in the past and may be considered again in the future.
Should such funds be 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
target of an attack (i.e., a large but well-protected facility versus a
smaller but less-protected facility); the nature of an attack (cyber,
chemical, biological, radiological); and its timing. The experts on our
panel have taken these uncertainties into account in deriving their own
judgments about these issues. These views, while not unanimous, suggest
some degree of consensus on a number of key issues.
We recognize that such sensitive decisions ultimately must take into
account a variety of political, equity, and other considerations. We
believe they should also consider the judgments of the nation's most
experienced individuals on these matters, such as those included on
this panel. It is in this context that we offer these results as an
input into the decision-making process that Congress and the
administration will likely go through as they seek to determine how
best to use limited financial resources to reduce the vulnerability to
the nation's wastewater utilities.
[End of section]
Appendixes:
Appendix I: Participating Experts on Wastewater Security Panel:
Expert: Doug Abbott;
Affiliation: Maryland Center for Environmental Training.
Expert: Mark Anderson;
Affiliation: Virginia Department of Health.
Expert: Carol Andress;
Affiliation: Environmental Defense.
Expert: Clifford Arnett;
Affiliation: Columbus Water Works.
Expert: Curt Baranowski;
Affiliation: U.S. Environmental Protection Agency.
Expert: Jeanette Brown;
Affiliation: Stamford Water Pollution Control Authority/American
Academy of Environmental Engineers.
Expert: Leonard Casson;
Affiliation: University of Pittsburgh.
Expert: William Conlon;
Affiliation: Parsons Brinckerhoff Quade & Douglas, Inc.
Expert: Joseph Cotruvo;
Affiliation: Joseph Cotruvo & Associates, LLC.
Expert: James Covel;
Affiliation: Upper Occoquan Sewage Authority.
Expert: Paula Dannenfeldt;
Affiliation: Association of Metropolitan Sewerage Agencies.
Expert: Shuki Einstein;
Affiliation: IDC Architects.
Expert: Richard Fox;
Affiliation: Camp Dresser & McKee, Inc.
Expert: Suzanne Goss;
Affiliation: JEA Electric, Water & Sewer.
Expert: Neil Grigg;
Affiliation: Colorado State University.
Expert: Michael Gritzuk;
Affiliation: City of Phoenix, Water Services Department.
Expert: Charles Haas;
Affiliation: Drexel University.
Expert: Gail Hackney;
Affiliation: Pima Community College.
Expert: Rick Hahn;
Affiliation: R. Hahn & Company, Inc.
Expert: Alan Hais;
Affiliation: U.S. Environmental Protection Agency.
Expert: Miriam Heller;
Affiliation: National Science Foundation.
Expert: Richard Holstein;
Affiliation: Tetra Tech, Inc.
Expert: John Hoornbeek;
Affiliation: National Environmental Training Center for Small
Communities.
Expert: Alan Ispass;
Affiliation: CH2M Hill.
Expert: David Jenkins;
Affiliation: University of California, Berkeley.
Expert: Patrick Karney;
Affiliation: CH2M Hill (formerly with Metropolitan Sewer District of
Greater Cincinnati).
Expert: Bruce Larson;
Affiliation: American Water.
Expert: Cecil Lue-Hing;
Affiliation: Cecil Lue-Hing & Associates, Inc.
Expert: Michael Luers;
Affiliation: Snyderville Basin Water Reclamation District.
Expert: Michael Marcotte;
Affiliation: City of Houston, Department of Public Works and
Engineering (formerly with District of Columbia Water and Sewer
Authority).
Expert: John Masek;
Affiliation: ABS Consulting.
Expert: Paul Orum;
Affiliation: Working Group on Community Right-to- Know.
Expert: Rebecca Parkin;
Affiliation: George Washington University Medical Center.
Expert: Jay Pimpare;
Affiliation: U.S. Environmental Protection Agency.
Expert: Roy Ramani;
Affiliation: Water Environment Research Foundation.
Expert: Daniel Rees;
Affiliation: Scientech, LLC.
Expert: Joan Rose;
Affiliation: Michigan State University.
Expert: H.J. "Bud" Schardein;
Affiliation: Louisville/Jefferson County Metropolitan Sewer District.
Expert: Tom Segars;
Affiliation: Miami-Dade Water and Sewer Department.
Expert: Jim Sullivan;
Affiliation: Water Environment Federation.
Expert: Richard Sustich;
Affiliation: University of Illinois at Urbana- Champaign (formerly with
Metropolitan Water Reclamation District of Greater Chicago).
Expert: James Thomson;
Affiliation: Jason Consultants International.
Expert: Mike Traubert;
Affiliation: Arizona Department of Environmental Quality.
Expert: William Wallace;
Affiliation: Rensselaer Polytechnic Institute.
Expert: Mike Wallis;
Affiliation: East Bay Municipal Utility District.
Expert: Chuck Weber;
Affiliation: Prince William County Service Authority.
Expert: David Weinberg;
Affiliation: U.S. Department of Homeland Security.
Expert: Gary Westerhoff;
Affiliation: Malcolm Pirnie, Inc.
Expert: Gary Yoshida;
Affiliation: Sanitation Districts of Los Angeles County.
Expert: Rae Zimmerman;
Affiliation: New York University.
[End of table]
Source: GAO.
[End of section]
Appendix II: Questions and Responses to the Final Questionnaire for the
Expert Panel:
The body of this report generally identifies which options received the
most favorable responses from the expert panel as to how federal funds
can best be spent to improve wastewater security (i.e., which
activities were viewed as warranting "highest" or "high" funding
priority). The table below provides the full range of responses (e.g.,
"highest priority" to "lowest priority") by the experts to these
questions. The tables also indicate the number of experts in each case
that responded with "no opinion" or "no response."
[See PDF for image]
[End of survey questionnaire]
[End of section]
Appendix III: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
John B. Stephenson, (202) 512-3841;
Steve Elstein, (202) 512-6515:
Staff Acknowledgments:
In addition to the individuals named above, important contributions
were made by Ulana Bihun, Christopher R. Durbin, Lynn Musser, and Diane
B. Raynes. Katherine M. Raheb and Carol Herrnstadt Shulman also made
key contributions.
(360396):
FOOTNOTES
[1] EPA Wastewater Technology Fact Sheet, Chlorine Disinfection, EPA
832-F-99-062, September 1999.
[2] Disinfection Technologies for Potable Water and Wastewater
Treatment: Alternatives to Chlorine Gas, Pacific Northwest National
Laboratory, July 1998.
[3] The Public Health Security and Bioterrorism Preparedness and
Response Act of 2002 (the Bioterrorism Act of 2002), Pub. L. No. 107-
188, required drinking water systems serving more than 3,300 people to
complete vulnerability assessments by June 2004. According to EPA
officials, many combined systems--those providing both drinking and
wastewater services--have voluntarily completed vulnerability
assessments for both. The act further required those systems to prepare
or revise an emergency response plan incorporating the results of the
vulnerability assessment within 6 months after completing the
assessment.
[4] EPA's requirements for "worst-case" release analysis tend to result
in consequence estimates that are significantly higher than what is
likely to actually occur. For example, "worst case" release analysis
does not take into account active mitigation measures facilities often
employ to reduce the consequences of releases.
[5] Department of Energy. 21 Steps to Improve Cyber Security of SCADA
Networks. http://www.eq.doe.gov/pdfs/21stepbooklet.pdf (Downloaded July
1, 2004).
[6] http://c3.org/chlorine-issues/disinfection/water-disinfection.html
[7] Environmental Protection Agency, Fact Sheet, "Use of the Clean
Water State Revolving Fund to Implement Security Measures at Publicly-
owned Wastewater Treatment Works," (Washington, D.C., 2003).
[8] "A Glossary of Terms Used in the Federal Budget Process,"
(Washington, D.C., 1993) 40, 50.
[9] The Water Infrastructure Network, a coalition of groups
representing the interests of the water and wastewater industry, has
advocated the establishment of a trust fund to support a broad range of
water and wastewater infrastructure needs. Some experts on our panel
suggested that should this type of mechanism be established, it should
be structured in a way that supports the industry's security needs.
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