Securing Wastewater Facilities
Utilities Have Made Important Upgrades but Further Improvements to Key System Components May Be Limited by Costs and Other Constraints Gao ID: GAO-06-390 March 31, 2006Wastewater facilities provide essential services to residential, commercial, and industrial users, yet they may possess certain characteristics that terrorists could exploit to impair the wastewater treatment process or to damage surrounding infrastructure. For example, large underground collector sewers could be accessed by terrorists for purposes of placing destructive devices beneath buildings or city streets. GAO was asked to determine (1) what federal statutory authorities and directives govern the protection of wastewater treatment facilities from terrorist attack, (2) what steps critical wastewater facilities have taken since the terrorist attacks of September 11, 2001, (9/11) to ensure that potential vulnerabilities are addressed, and (3) what steps the Environmental Protection Agency (EPA) and the Department of Homeland Security (DHS) have taken to help these facilities in their efforts to address such vulnerabilities.
Federal law does not address wastewater security as comprehensively as it does drinking water security. For example, the Public Health Security and Bioterrorism Preparedness and Response Act of 2002 required drinking water facilities serving populations greater than 3,300 to complete vulnerability assessments, but no such requirement exists for wastewater facilities. While federal law governing wastewater security is limited, Homeland Security Presidential Directive 7 designated EPA as the lead agency to oversee the security of the water sector, including both drinking water and wastewater. The directive tasked EPA with several responsibilities, including the development of mechanisms for information sharing and analysis within the water sector. Our survey of over 200 of the nation's large wastewater facilities shows that many have made security improvements since 9/11. Most facilities indicated they have completed, have under way, or plan to complete some type of security assessment. Similarly, more than half of responding facilities indicated they did not use potentially dangerous gaseous chlorine as a wastewater disinfectant. Survey responses show that other security measures taken after 9/11 have generally focused on controlling access to the treatment plant through improvements in visual surveillance, security lighting, and employee and visitor identification. Little effort, however, has been made to address collection system vulnerabilities, as many facilities cited the technical complexity and expense involved in securing collection systems that cover large areas and have many access points. Others reported that taking other measures, such as converting from gaseous chlorine, took priority over collection system protections. While EPA and DHS have initiatives to address wastewater facility security, efforts to provide critical and threat-related information would benefit from closer coordination. EPA and DHS fund multiple information services designed to communicate information to the water sector--specifically, EPA funds the Water Information Sharing and Analysis Center (WaterISAC) and its Water Security Channel, while DHS funds the Homeland Security Information Network (HSIN). EPA, DHS, and other industry experts are concerned that these multiple information services may overlap and produce inefficiencies. For example, a substantial part of the $2 million annual grant EPA uses to fund the WaterISAC is dedicated to purchasing computer services likely available through DHS and HSIN at no cost. A Water Sector Coordinating Council was established by the water sector to help determine the appropriate relationship among these information services. A preliminary review is under way to examine options for improving coordination between the WaterISAC, the Water Security Channel, and HSIN; however, the scope and time frame for completion of this review is unclear.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-06-390, Securing Wastewater Facilities: Utilities Have Made Important Upgrades but Further Improvements to Key System Components May Be Limited by Costs and Other Constraints
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United States Government Accountability Office:
GAO:
Report to the Chairman, Committee on Environment and Public Works, U.S.
Senate:
March 2006:
Securing Wastewater Facilities:
Utilities Have Made Important Upgrades but Further Improvements to Key
System Components May Be Limited by Costs and Other Constraints:
GAO-06-390:
GAO Highlights:
Highlights of GAO-06-390, a report to the Chairman, Committee on
Environment and Public Works, U.S. Senate.
Why GAO Did This Study:
Wastewater facilities provide essential services to residential,
commercial, and industrial users, yet they may possess certain
characteristics that terrorists could exploit to impair the wastewater
treatment process or to damage surrounding infrastructure. For
example, large underground collector sewers could be accessed by
terrorists for purposes of placing destructive devices beneath
buildings or city streets.
GAO was asked to determine (1) what federal statutory authorities and
directives govern the protection of wastewater treatment facilities
from terrorist attack, (2) what steps critical wastewater facilities
have taken since the terrorist attacks of September 11, 2001, (9/11) to
ensure that potential vulnerabilities are addressed, and (3) what steps
the Environmental Protection Agency (EPA) and the Department of
Homeland Security (DHS) have taken to help these facilities in their
efforts to address such vulnerabilities.
What GAO Found:
Federal law does not address wastewater security as comprehensively as
it does drinking water security. For example, the Public Health
Security and Bioterrorism Preparedness and Response Act of 2002
required drinking water facilities serving populations greater than
3,300 to complete vulnerability assessments, but no such requirement
exists for wastewater facilities. While federal law governing
wastewater security is limited, Homeland Security Presidential
Directive 7 designated EPA as the lead agency to oversee the security
of the water sector, including both drinking water and wastewater. The
directive tasked EPA with several responsibilities, including the
development of mechanisms for information sharing and analysis within
the water sector.
Our survey of over 200 of the nation‘s large wastewater facilities
shows that many have made security improvements since 9/11. Most
facilities indicated they have completed, have under way, or plan to
complete some type of security assessment. Similarly, more than half
of responding facilities indicated they did not use potentially
dangerous gaseous chlorine as a wastewater disinfectant. Survey
responses show that other security measures taken after 9/11 have
generally focused on controlling access to the treatment plant through
improvements in visual surveillance, security lighting, and employee
and visitor identification. Little effort, however, has been made to
address collection system vulnerabilities, as many facilities cited the
technical complexity and expense involved in securing collection
systems that cover large areas and have many access points. Others
reported that taking other measures, such as converting from gaseous
chlorine, took priority over collection system protections.
While EPA and DHS have initiatives to address wastewater facility
security, efforts to provide critical and threat-related information
would benefit from closer coordination. EPA and DHS fund multiple
information services designed to communicate information to the water
sector”specifically, EPA funds the Water Information Sharing and
Analysis Center (WaterISAC) and its Water Security Channel, while DHS
funds the Homeland Security Information Network (HSIN). EPA, DHS, and
other industry experts are concerned that these multiple information
services may overlap and produce inefficiencies. For example, a
substantial part of the $2 million annual grant EPA uses to fund the
WaterISAC is dedicated to purchasing computer services likely available
through DHS and HSIN at no cost. A Water Sector Coordinating Council
was established by the water sector to help determine the appropriate
relationship among these information services. A preliminary review is
under way to examine options for improving coordination between the
WaterISAC, the Water Security Channel, and HSIN; however, the scope and
time frame for completion of this review is unclear.
What GAO Recommends:
GAO is recommending that EPA work with DHS to identify areas where the
WaterISAC and HSIN could be better coordinated, focusing on (1) how
duplications and overlap could be addressed, and (2) how water systems‘
access to critical information could be improved. GAO also recommends
that EPA help identify time frames to complete these tasks. EPA and
DHS generally agreed with the report.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-390].
To view the full product, including the scope
and methodology, click on the link above.
For more information, contact John Stephenson at (202) 512-3841 or
stephensonj@gao.gov.
[End of Section]
Contents:
Letter:
Results in Brief:
Background:
Federal Laws and Directives Related to Wastewater Security Are Limited:
Many Large Wastewater Facilities Have Made Security Improvements but
Efforts to Protect Collection Systems Have Been Limited:
EPA and DHS Have Several Initiatives to Enhance Wastewater Facility
Security, Yet a Key Effort Requires Additional Coordination:
Conclusions:
Recommendation for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Scope and Methodology:
Appendix II: Survey of Wastewater Treatment Facilities:
Appendix III: Comments from the Environmental Protection Agency:
Appendix IV: GAO Contact and Staff Acknowledgments:
Table:
Table 1: Wastewater Facility Managers' Opinions on Recommended Federal
Role:
Figures:
Figure 1: Vulnerability and Security Assessments at Large Wastewater
Facilities:
Figure 2: Gaseous Chlorine Use at Large Wastewater Facilities:
Figure 3: Security Measures at Large Wastewater Facilities That Still
Use Gaseous Chlorine:
Figure 4: Security Measures at Large Wastewater Facilities:
Abbreviations:
AMWA: Association of Metropolitan Water Agencies:
ASCE: American Society of Civil Engineers:
CWNS: Clean Watershed Needs Survey:
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:
MOU: memorandum of understanding:
NACWA: National Association of Clean Water Agencies:
NDWAC: National Drinking Water Advisory Council:
POTW: publicly-owned treatment works:
RAM-W: Risk Assessment Methodology for Water Utilities:
RMP: Risk Management Plan:
SCADA: Supervisory Control and Data Acquisition:
SEMS: Security and Emergency Management System:
VSAT: Vulnerability Self Assessment Tool:
WEF: Water Environment Federation:
United States Government Accountability Office:
Washington, DC 20548:
March 31, 2006:
The Honorable James M. Inhofe:
Chairman:
Committee on Environment and Public Works:
United States Senate:
Dear Mr. Chairman:
Wastewater facilities in the United States provide essential services
to residential, commercial, and industrial users by collecting and
treating wastewater and discharging treated effluent into receiving
waters. These facilities may also provide opportunities for terrorists
to either impair the wastewater treatment process or damage surrounding
communities and infrastructure. For example, damage to a wastewater
facility or collection system could prevent water from being treated,
impacting downriver water intakes. Destroying tanks that hold large
amounts of chemicals at treatment plants could release toxic chemical
agents, such as gaseous chlorine, that can be deadly if inhaled and, at
lower doses, could burn eyes and skin and inflame the lungs. Large
underground collector sewers could be accessed by terrorist groups for
purposes of placing destructive devices beneath buildings or city
streets.
In January 2005, we reported the views of nationally recognized experts
on key issues concerning wastewater security.[Footnote 1] The five
assets experts considered most vulnerable included (1) the collection
systems' network of sewer lines used to move wastewater away from its
point of origination to the treatment plant; (2) treatment chemicals,
such as gaseous chlorine, used to disinfect wastewater; (3) key
components of the wastewater treatment plant, such as its headworks,
where raw sewage first enters the plant; (4) automated control systems
that control many vital operations, such as the amount of chlorine
needed for disinfection; and (5) pumping stations along the collection
system that lift or pump wastewater to the treatment plant. The experts
noted that security-enhancing activities that most warrant federal
support include replacing gaseous chemicals used in wastewater
treatment with less hazardous alternatives; improving local, state, and
regional collaboration efforts; and completing vulnerability
assessments for individual wastewater systems. 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 the highest priority. Other recipients warranting highest
priority included utilities using large quantities of gaseous chemicals
and utilities serving areas with large populations.
As a follow-on to that review, this report examines: (1) what federal
statutory authorities and directives govern the protection of
wastewater treatment facilities from terrorist attack, (2) what steps
critical wastewater treatment facilities have taken since the terrorist
attacks of September 11, 2001, (hereafter referred to as "9/11") to
ensure that potential vulnerabilities are addressed, and (3) what steps
the Environmental Protection Agency (EPA) and the Department of
Homeland Security (DHS) have taken to help these facilities in their
efforts to address such vulnerabilities.
To identify federal statutory authorities and directives that govern
protection of wastewater treatment facilities, we reviewed applicable
laws; Homeland Security Presidential Directives; and EPA and DHS
policies, guidance, and regulations related to wastewater security. To
determine what steps critical wastewater treatment facilities have
taken since 9/11 to ensure that potential vulnerabilities are
addressed, we conducted a Web-based survey of the nation's publicly-
owned treatment works (POTWs) that serve residential populations of
100,000 or greater. Together, these facilities provide wastewater
service to approximately 36 percent of the U.S. population served by
POTWs. We received an 82 percent response rate to the survey. To
determine what steps EPA and DHS have taken to help these facilities in
their efforts to address such vulnerabilities, we reviewed relevant EPA
and DHS guidance and other documents, and interviewed agency personnel.
We also interviewed state and local officials with oversight for
wastewater treatment operations and security. Information about federal
efforts to enhance wastewater security from the perspective of
wastewater treatment facilities was provided to us through our Web-
based survey. We conducted our work between May 2005 and February 2006
in accordance with generally accepted government auditing standards.
See appendix I for a more detailed discussion of our scope and
methodology.
Results in Brief:
Federal law does not address wastewater security as comprehensively as
it does drinking water security. In particular, wastewater facilities
are not required by law to complete vulnerability assessments. This
stands in contrast to the requirements for drinking water utilities in
the Public Health Security and Bioterrorism Preparedness and Response
Act of 2002 (the Bioterrorism Act),[Footnote 2] which required drinking
water utilities serving populations greater than 3,300 to complete
vulnerability assessments by June 2004. The Clean Air Act does require
wastewater facilities using more than 2,500 pounds of gaseous chlorine
to submit to EPA a risk management plan that lays out accident
prevention and emergency response activities. Also, under EPA guidance,
the Clean Water State Revolving Fund program, administered by the
states with EPA funding to help local governments meet their wastewater
treatment needs, can be used in many instances for certain wastewater
system security enhancements. While federal statutes governing
wastewater security are limited, in December 2003, the president issued
Homeland Security Presidential Directive 7 (HSPD-7), designating EPA as
the lead agency to oversee the security of the water sector (including
both drinking water and wastewater). Under the directive, EPA is
responsible for (1) identifying, prioritizing, and coordinating
infrastructure protection activities for the nation's drinking water
and water treatment systems; (2) working with federal departments and
agencies, state and local governments, and the private sector to
facilitate vulnerability assessments; (3) encouraging the development
of risk management strategies to protect against, and mitigate the
effects of, potential attacks on critical resources; and (4) developing
mechanisms for information sharing and analysis.
Our survey of large wastewater facilities indicates that many have made
security improvements since 9/11. While not required, most facilities
indicated they have completed, have under way, or plan to complete some
type of security assessment. For example, 51 percent of facilities
responding to our survey indicated that they either completed a
vulnerability assessment similar to that required of drinking water
facilities under the Bioterrorism Act, or have one currently under way.
In addition, another 23 percent of facilities reported that they have
conducted, had under way, or planned to conduct, some type of security
assessment. Survey responses show that security measures undertaken by
large wastewater facilities after 9/11 have generally focused on
controlling access to the treatment plant through improvements in
visual surveillance, security lighting, and employee and visitor
identification. Survey results also show that facilities are continuing
to move away from the use of gaseous chlorine as a wastewater
disinfectant. Fifty-six percent of facilities indicated they do not use
chlorine gas as a wastewater disinfectant, while another ten percent
indicated they plan to stop using the gas. Importantly, survey results
show that facilities have taken little action to address collection
system vulnerabilities. Many facilities cited a shortage of the
considerable funds required to secure a collection system that covers a
large area and has many, often remote, access points. Consequently, few
have installed, or plan to install, manhole intrusion sensors, manhole
locks, or sensors to detect toxics or other biochemical threats to
their collection system. Others reported that taking other measures,
such as converting from gaseous chlorine to a safer disinfection
process, took priority over protecting infrastructure in their
collection systems. Survey results show that a lack of funding and
federal security guidelines remain a concern for many wastewater
facility managers. For its part, EPA is funding efforts to develop
security guidance related to wastewater collection systems that should
help inform wastewater facility managers of security options in this
area.
While EPA and DHS have several initiatives under way to address the
security concerns of wastewater facility managers, efforts to provide
critical and threat-related information would benefit from additional
coordination. EPA and DHS fund multiple information services designed
to communicate information to the water sector. Specifically, EPA funds
the Water Information Sharing and Analysis Center (WaterISAC) and its
Water Security Channel, while DHS funds the Homeland Security
Information Network (HSIN). EPA, DHS, and other industry experts have
expressed concern that these multiple information services may overlap
and produce inefficiencies. A Water Sector Coordinating Council was
created with representative members of the water community to, among
other things, identify the appropriate use of and the relationship
among the WaterISAC, the Water Security Channel, and HSIN. We believe
that steps could be taken that would improve the efficiency with which
limited available funds are being spent to communicate information to
the water sector. For example, a substantial part of the $2 million
annual grant EPA uses to fund the WaterISAC is dedicated to purchasing
computer services likely available through DHS and HSIN at no cost.
According to EPA, a preliminary review is under way by the Water Sector
Coordinating Council that examines options for improving coordination
between the WaterISAC, the Water Security Channel, and HSIN. However,
the scope of the preliminary review is not clear, nor is a time frame
set to complete the review. Consequently, we are recommending that the
Administrator of EPA work with DHS and the Water Sector Coordinating
Council to identify areas where the WaterISAC and HSIN networks could
be better coordinated, focusing in particular on (1) how operational
duplications and overlap could be addressed, and (2) how water systems'
access to timely security threat information could be improved. We are
also recommending that EPA work with DHS and the Water Sector
Coordinating Council to identify realistic time frames for the
completion of these tasks.
Background:
Nationwide, more than 16,000 POTWs serve more than 200 million people,
or about 70 percent of the nation's total population. The remaining
population is served by privately-owned utilities or by on-site
systems, such as septic tanks. A relative handful of large wastewater
systems serve the great majority of people, as about 500 large public
wastewater systems provide service to 62 percent of the population
connected to a sewer system. In addition to serving residential
populations, approximately 27,000 commercial and industrial facilities
rely on wastewater treatment facilities to treat their wastewater.
POTWs discharge treated effluent into receiving waters and are
regulated under the Clean Water Act.
Wastewater systems vary by size and other factors, but all include a
collection system and a treatment facility.
* The collection system is the underground network of sewers including
both sanitary and storm water collection lines. Collection systems tend
to be dispersed geographically and have multiple access points,
including drains, catch basins, and manholes. Lines may range from 4
inches to greater than 20 feet in diameter, and access is usually
conducted through manholes that are typically 300 feet apart. Many
collection systems rely on gravity to maintain the flow of sewage
through the pipes toward the treatment plant. However, collection
systems may also depend on pumping stations to propel the flow when
gravity alone is insufficient. Nationwide, there are approximately
800,000 miles of sewer lines and 100,000 major pumping stations.
* The wastewater treatment facility receives wastewater from the
collection system and begins the treatment process which typically
involves several stages before treated effluent is released into
receiving waters. Primary treatment includes removal of larger objects
through a screening device or a grit removal system, and the removal of
solids through sedimentation. Secondary stage 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 these treatments,
the wastewater is disinfected to destroy harmful bacteria and viruses.
Disinfection is often accomplished with chlorine, which is stored in
gaseous or liquid form on-site at the wastewater treatment plant. The
collection system 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.
Wastewater treatment facilities may possess certain characteristics
that terrorists could exploit either to impair the wastewater treatment
process or to damage surrounding communities and infrastructure. For
example, the numerous storm drains, manholes, and sewers that make up a
community's wastewater collection system's 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. Damage to (or destruction of) tanks that hold large amounts of
gaseous chlorine used to disinfect wastewater could release the
potentially lethal gas into the atmosphere. Such events could result in
loss of life, destruction of property, and harm to the environment.
Documented accidents and intentional acts highlight the destruction
that could arise from an attack on a wastewater system.
* 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.
* In 1981 in Louisville, Kentucky, thousands of gallons of a highly
flammable solvent, hexane, spilled into the sewer lines from a local
processing plant. Fumes from the solvent ignited, and the resulting
explosions collapsed a 12-foot diameter pipe and damaged more than 2
miles of streets. No one was seriously injured, but sewer line repairs
took 20 months, followed by several more months to repair the streets.
* In 1992 in Guadalajara, Mexico, a gasoline leak into a sewer caused
explosions that killed 215 people, injured 1,500 others, damaged 1,600
buildings, and destroyed 1.25 miles of sewer.
* In 2002 in Hagerstown, Maryland, chemicals from an unknown source
entered the wastewater treatment plant and destroyed the facility's
biological treatment process. The event 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.
In January 2005, we reported the views of 50 nationally recognized
experts on key issues concerning wastewater security. Our panel of
experts identified five key wastewater assets as most vulnerable to
terrorist attacks: the collection systems' network of sewers (42 of 50
experts), treatment chemicals (32 of 50 experts), key components of the
treatment plant (29 of 50 experts), control systems (18 of 50 experts),
and pumping stations (16 of 50 experts). When asked to identify and set
priorities for the security-enhancing activities most deserving of
federal support, the expert panel identified 11 key actions, but ranked
three as deserving highest priority--replacing gaseous chemicals used
in the wastewater treatment process; improving local, state, and
regional efforts to coordinate responses in advance of a potential
terrorist threat; and completing vulnerability assessments for
individual wastewater systems.
Federal Laws and Directives Related to Wastewater Security Are Limited:
Federal law does not address wastewater security as comprehensively as
it does drinking water security. In particular, wastewater facilities
are not required by law to complete vulnerability assessments. The
Clean Air Act does require wastewater facilities using certain amounts
of hazardous substances, such as chlorine gas, to submit to EPA a risk
management plan that lays out accident prevention and emergency
response activities. Also, under EPA guidance, the Clean Water State
Revolving Fund can be used in many instances for certain wastewater
system security enhancements. While federal law governing wastewater
security is limited, in December 2003, the president issued HSPD-7. The
directive designated EPA as the lead agency to oversee the security of
the water sector, including both drinking water and wastewater critical
infrastructures.
Federal Law Does Not Address Wastewater Security As It Does Drinking
Water:
In 2002, Congress passed the Bioterrorism Act, which amended various
laws, including the Safe Drinking Water Act.[Footnote 3] The
Bioterrorism Act required drinking water systems serving more than
3,300 people to complete vulnerability assessments of their facilities
by June 2004 and to prepare or update an existing emergency response
plan. The Bioterrorism Act required the assessments to include, but not
be limited to, a review of six components: (1) pipes and constructed
conveyances; (2) physical barriers; (3) water collection, pretreatment,
treatment, storage, and distribution facilities; (4) electronic,
computer, or other automated systems which are utilized by the public
water system; (5) the use, storage, or handling of various chemicals;
and (6) the operation and maintenance of such systems.[Footnote 4]
Under the act, the emergency response plans were to include plans,
procedures, and identification of equipment to lessen the impact on
public health and the drinking water supply of terrorist attacks or
other intentional acts against drinking water systems. The act
authorized $210 million for fiscal year 2002, mostly to assist drinking
water systems in completing vulnerability assessments, preparing or
updating response plans, and making needed security improvements.
Drinking water systems are not required to implement any risk-reduction
actions based on their vulnerability assessments or report to EPA on
measures that have been implemented.
In 2003, the Congress considered alternative bills that would have
encouraged or required wastewater treatment plants to assess the
vulnerability of wastewater facilities, make physical security
improvements, and conduct research. However, the legislation did not
become law and, consequently, no such requirement or specific funding
exists for wastewater facilities.
Other Federal Environmental Laws Address Some Areas of Security at
Wastewater Facilities:
While federal law does not require wastewater systems to take security
measures to protect specifically against a terrorist attack, it does
require certain wastewater facilities to take security precautions that
could mitigate the consequences of such an attack. For example, the
1990 Clean Air Act amendments[Footnote 5] mandated EPA oversight of
risk management planning at facilities that handle more than specified-
threshold quantities of hazardous substances, including the gaseous
chlorine often used as a disinfectant at wastewater
facilities.[Footnote 6] Specifically, EPA regulations implementing the
Clean Air Act require these facilities to prepare Risk Management Plans
(RMPs) that summarize the potential threat of sudden, accidental, large
releases of certain chemicals; including the results occurring off-site
in a worst-case chemical accident, and the facility's plan to prevent
releases and mitigate any damage. RMPs are to be revised and
resubmitted to EPA at least every 5 years, and EPA is required to
review them and require revisions, if necessary.
For a March 2003 report,[Footnote 7] EPA told us it believed the Clean
Air Act could be interpreted to provide authority to address site
security from terrorist attacks at RMP facilities, because the act
imposes certain requirements on these facilities regarding "accidental
releases." The act defines an accidental release as an unanticipated
emission of a regulated substance or other extremely hazardous
substance into the air, so any chemical release caused by a terrorist
attack could be considered "unanticipated" and covered under the Clean
Air Act. Such an interpretation would provide EPA with authority under
the act's RMP provisions and general duty clause[Footnote 8] to require
security measures or vulnerability assessments with regard to
terrorism. However, EPA has not attempted to use these Clean Air Act
provisions because it is concerned that such an interpretation would
pose significant litigation risk and has concluded that chemical
facility security would be more effectively addressed by passage of
specific legislation.
Wastewater facilities that store certain amounts of hazardous chemicals
may also be subject to the Resource Conservation and Recovery
Act.[Footnote 9] Under regulations implementing the act, facilities
that house hazardous waste generally must take certain security
actions, such as posting warning signs and using a 24-hour surveillance
system, or surrounding the active portion of the facility with a
barrier and controlled entry gates.[Footnote 10] However, according to
EPA, these security measures are aimed at keeping out trespassers or
wanderers, not intentional intruders.
Other federal statutes impose safety requirements on certain wastewater
facilities that may incidentally reduce the likelihood and mitigate the
consequences of terrorist attacks. For example, the Occupational Safety
and Health Act[Footnote 11] imposes a number of safety requirements,
including a general duty to furnish a workplace free from recognized
hazards that may cause death or serious physical harm to employees. The
Emergency Planning and Community Right-to-Know Act[Footnote 12]
requires owners of facilities that maintain specified quantities of
certain extremely hazardous chemicals to submit information annually on
their chemical inventory to state and local emergency response
officials. The act also requires that each state establish a State
Emergency Response Commission to oversee local emergency planning and
create local emergency planning committees. These committees must
develop and periodically review their communities' emergency response
plans, including the identification of chemical facilities, and outline
procedures for response personnel to follow in the event of a chemical
incident.
Aside from statutes that address some areas of wastewater security, EPA
has asserted that federal funding is available for wastewater security-
related measures through the Clean Water State Revolving Fund (CWSRF)
program.[Footnote 13] The CWSRF is an EPA-administered program that
provides grants to the states to fund a variety of water-quality
projects, including those at municipal wastewater treatment facilities.
States may use the funds to provide loans to local governments to
assist wastewater utilities in making infrastructure improvements
needed to protect public health and ensure compliance with the Clean
Water Act. According to EPA, 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, EPA has identified other infrastructure
improvements that may be eligible for funding, 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 14] In our January 2005
report summarizing experts' views on wastewater security, a number of
experts expressed caution about relying heavily on the CWSRF program to
support security enhancements, largely because of the time-lag in
obtaining funds for security-related measures, and because such demands
on the CWSRF would divert needed funding away from the kind of critical
infrastructure investments that are the CWSRF program's primary purpose.
Another source of federal funding potentially available for wastewater
security-related measures is the State Homeland Security Grant Program
administered by DHS. This program's primary objectives are to enhance
the capacity of state and local emergency responders to prevent,
protect against, respond to, and recover from terrorist incidents
involving chemical, biological, radiological, nuclear, and explosive
devices; agriculture; and cyber attacks. Under the program, grants are
provided to states for a variety of purposes, including homeland
security-related training and protection of critical infrastructure,
although authority to make physical security improvements is limited.
States are required to allocate at least 80 percent of these grant
funds to "local units of governments," which, as defined in the
conference report accompanying the Department of Homeland Security
Appropriations Act for fiscal year 2006, include water districts,
special districts, and other political subdivisions of a state.
EPA Was Assigned Lead Federal Responsibility for Water-Sector Security
Including Wastewater Facilities:
In December 2003, the president issued 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 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 water supply.
Under HSPD-7, EPA is responsible for (1) identifying, prioritizing, and
coordinating infrastructure protection activities for the nation's
drinking water and water treatment systems; (2) working with federal
departments and agencies, state and local governments, and the private
sector to facilitate vulnerability assessments; (3) encouraging the
development of risk management strategies to protect against and
mitigate the effects of potential attacks on critical resources; and
(4) developing mechanisms for information sharing and analysis.
HSPD-7 also called for DHS to integrate all critical infrastructure
security efforts among federal agencies and to complete a comprehensive
national plan for critical infrastructure and key resource protection-
-now called the National Infrastructure Protection Plan. Under HSPD-7,
seven federal agencies, including EPA, were designated sector-specific
agencies. DHS issued guidance tasking each sector-specific agency with
developing sector-specific plans for input into the comprehensive plan.
Each sector-specific plan is supposed to outline strategies for (1)
collaborating with all relevant federal departments and agencies, state
and local governments, and the private sector; (2) identifying assets;
(3) conducting or facilitating vulnerability assessments; and (4)
encouraging risk management strategies to protect against and mitigate
the effects of an attack. The water sector-specific plan will be an
appendix to the National Infrastructure Protection Plan. On January 20,
2006, DHS issued its revised National Infrastructure Protection Plan
based on comments it received on an earlier version of the plan. DHS
accepted additional comments on the revised version until February 6,
2006, and expects to issue a final version of the plan later in 2006.
Sector-specific agencies are required to submit their sector-specific
plans to DHS within 6 months after the National Infrastructure
Protection Plan is made final.
Many Large Wastewater Facilities Have Made Security Improvements but
Efforts to Protect Collection Systems Have Been Limited:
Our survey of large wastewater facilities indicates that many have
taken steps to improve security. Most facilities that responded to our
survey have completed, have under way, or plan to complete some type of
security assessment. Roughly two-thirds of facilities also reported
they used a disinfectant other than gaseous chlorine or plan to switch
from the gas. Of those facilities that continue to use gaseous
chlorine, many have taken steps to increase security by limiting and
monitoring access to gaseous chlorine storage areas or through other
actions. Survey responses show that since 9/11, wastewater treatment
facilities have also focused security efforts on controlling and
limiting access to their treatment plants. Importantly, facilities have
taken fewer security actions intended to protect treatment collection
systems. Many facilities reported that taking other measures to protect
their treatment plants, including converting from gaseous chlorine to a
safer disinfection process, took priority over protecting
infrastructure in their collection systems. Survey results show a lack
of funding and federal security guidelines remain a concern for many
wastewater facility managers.
Most Facilities Have Conducted or Plan to Conduct Some Type of Security
Assessment:
Seventy-four percent of facilities that responded to our survey
reported they completed, were in the process of completing, or planned
to complete some type of security assessment--either a vulnerability
assessment, similar to that which was required of drinking water
facilities under the Bioterrorism Act, or another type of security
assessment. As shown in figure 1, 106 facilities--or 51 percent of
those responding to our survey--indicated that they had completed a
vulnerability assessment or were currently conducting a vulnerability
assessment.
Figure 1: Vulnerability and Security Assessments at Large Wastewater
Facilities:
[See PDF for image]
Source: GAO survey of wastewater facilities.
[End of figure]
Of the 106 facilities that indicated they had either completed a
vulnerability assessment or had one under way, 80 indicated their
vulnerability assessments were complete, while 26 indicated the
assessment was still in process. As shown in the figure, 22 facilities-
-or 11 percent of all responses--indicated they had conducted another
type of security assessment or were in the process of conducting
another type of security assessment, while 24 facilities--or 12 percent
of all responses--indicated they plan to conduct either a vulnerability
or another type of security assessment.
Twenty-three facilities--or 11 percent of total responses--indicated
they had no plans to conduct any type of security assessment. When
asked to identify reasons for not conducting a vulnerability or
security assessment, 17 of these 23 facilities cited a lack of
requirement to do so, while 15 noted that they considered security
actions taken at their facilities adequate for their security needs.
Thirteen of these facilities indicated that their emergency response
plan was updated and this seemed sufficient to address potential
vulnerabilities.
Facilities cited several reasons for completing a vulnerability or some
other type of security assessment, but most--roughly 77 percent--
reported doing so on their own initiative. Thirty-seven percent of
facilities reported that they did so in conjunction with the required
assessment for their drinking water facility.[Footnote 15] To a lesser
extent, facilities cited state, local, and utility governing-body
requirements as reasons they conducted assessments. See appendix II for
survey results related to vulnerability and security assessments at
large wastewater facilities.
Most Large Facilities Have Discontinued or Plan to Discontinue Use of
Gaseous Chlorine, and Chlorine Users Have Pursued Other Security
Enhancements:
As shown in figure 2, over half of large wastewater facilities in our
survey reported they use an alternative to gaseous chlorine in their
disinfection process. These results are consistent with studies which
conclude that over the past decade, wastewater treatment facilities
have moved away from gaseous chlorine as a disinfectant.
Figure 2: Gaseous Chlorine Use at Large Wastewater Facilities:
[See PDF for image]
Source: GAO survey of wastewater facilities.
Note: Totals do not add to 100 percent due to rounding.
[End of figure]
Of the facilities not using gaseous chlorine, 89 reported using sodium
hypochlorite as their primary disinfectant. Sodium hypochlorite is
essentially a strong version of household bleach and is considered
safer than gaseous chlorine. Seventeen facilities report they are using
ultraviolet light as their primary disinfectant. The remaining
facilities did not identify the type of disinfectant method used at
their facility.
In our January 2005 report, we noted that 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. However,
one expert noted some costs may be offset through savings in regulatory
paperwork and certain emergency planning efforts. In our survey, we
asked facilities that switched from gaseous chlorine if their annual
costs increased, stayed the same, or decreased after switching to an
alternate disinfection method. Fifty-eight facilities reported that
costs increased, 11 noted that costs have stayed about the same, and
one facility reported that costs decreased.
Of the 85 facilities that reported use of gaseous chlorine, 20--or
roughly 10 percent of all 206 reporting facilities--indicated that they
have plans to switch from gaseous chlorine to another disinfectant. In
addition, as shown in figure 3, many reported taking additional steps
after 9/11 to mitigate the potential risks associated with continued
reliance on chlorine.
Figure 3: Security Measures at Large Wastewater Facilities That Still
Use Gaseous Chlorine:
[See PDF for image]
Source: GAO survey of wastewater facilities.
[A] Other physical improvements include, among others, improvements to
gates and fencing; physical barriers, security guards, intrusion alarms
and motion detectors; and enclosure of the chlorine storage area.
Results are based on 85 facilities that reported using gaseous chlorine
as a primary disinfectant.
[End of figure]
Forty-one facilities using gaseous chlorine reported that they
instituted controls for selective access to chlorine storage areas
after 9/11, while 30 facilities reported making other security
improvements to the storage area, such as installing electronic
surveillance of the chlorine storage area or improving gates and
fencing. Fewer facilities reported that they decided to store gaseous
chlorine in smaller-quantity containers, likely because most reported
they already stored the gas in one-ton containers, which are among the
smallest containers used at large wastewater facilities for the
gas.[Footnote 16] See appendix II for survey results on gaseous
chlorine use at large wastewater facilities.
Security Efforts Have Generally Focused on Improved Control of
Wastewater Treatment Plant Access, While Efforts to Protect Collection
Systems Have Been Limited:
As shown in figure 4, many facilities reported taking basic security
measures prior to 9/11, such as installing vehicle gates and security
fencing. Survey respondents also indicated that many information
technology security measures, such as virus protection programs, backup
power supplies, and firewall and intrusion detection systems, were
implemented before 9/11.
The figure shows that security enhancements made or planned by large
wastewater facilities after 9/11 generally focus on controlling access
to the treatment plant. Such security enhancements include adding
visual surveillance monitoring, increasing security lighting,
implementing employee and visitor identification policies, adding guard
stations, and upgrading SCADA capability and security.
Importantly, few facilities reported taking measures to address
collection system vulnerabilities other than having available redundant
pumping devices or collection bypass systems. For example, few have
installed or plan to install manhole intrusion sensors, manhole locks,
or sensors to detect toxics or other biochemical threats to their
collection systems. This lack of attention to collection system
vulnerabilities is important because 42 of the 50 experts polled in our
January 2005 report on wastewater security identified the collection
systems' network of sanitary, storm, and combined sewers as the most
vulnerable asset of a wastewater utility. Several noted that sewers
make underground travel from a point of entry to a potential target
almost undetectable, possibly allowing sewers to be used as an
underground transport system for explosive or toxic agents.
Many facilities reported that other measures to protect their treatment
plants, including converting from gaseous chlorine to a safer
disinfection process, took priority over protecting infrastructure in
their collection systems. Other managers cited the difficulty and
expense in securing collection systems that, by nature, cover a large
area and have many, often remote, access points. One manager expressed
confusion about whether to concentrate monitoring resources on large
interceptor sewer lines to prevent entry or on toxic materials that
could be introduced at nearly every access point to his system. Others
noted the lack of facility control over collection systems. One
facility manager told us his facility treats wastewater that is
collected from 17 separate collection systems. Finally, a number of
respondents questioned whether the technologies purportedly available
to detect potential threats introduced to collection systems are
sufficiently capable of achieving this objective.
Figure 4: Security Measures at Large Wastewater Facilities:
[See PDF for image]
Source: GAO survey of wastewater facilities.
Note: Figure is based on results from 206 wastewater facilities.
[End of figure]
Nonetheless, a few facility managers with whom we spoke told us they
have made efforts to address collection system security, particularly
in the protection of their pump stations. One facility manager told us
his facility has a project under way to install security locks and card-
access controls at all 93 of its pumping stations. According to the
manager, the concentration of and need to protect capital equipment,
and the potential impact of damage or destruction of that
infrastructure prompted the facility to direct its capital improvement
efforts to securing pumping stations.
While many facilities in our survey indicated they made some security
improvements after 9/11, facility managers cited limited resources and
other priorities as reasons for not implementing further security
measures. Facility managers and other industry experts with whom we
spoke noted that security upgrades must compete with other
infrastructure needs for available resources. For instance, many
wastewater facilities' collection systems are outdated, and they are
already facing large costs to expand and repair their aging systems and
reduce incidences of combined sewer overflows.[Footnote 17] Major U.S.
cities, such as Washington, D.C., and Cincinnati, Ohio, are facing
costs between $1 and $2 billion to implement necessary capital
improvements. See appendix II for survey results on physical,
personnel, and information technology security measures taken at large
wastewater facilities.
Many Facility Managers Reported a Need for Additional Funding and Other
Assistance to Further Security Improvements:
In our survey, we asked wastewater facility managers what the federal
government could do to improve security at wastewater facilities.
Facility manager responses are categorized in table 1.
Table 1: Wastewater Facility Managers' Opinions on Recommended Federal
Role:
Recommended federal role: Funding;
Number of responses: 102.
Recommended federal role: Guidelines, standards, best practices,
expertise, and information;
Number of responses: 36.
Recommended federal role: Training and education;
Number of responses: 14.
Recommended federal role: Requirements and mandates;
Number of responses: 14.
Recommended federal role: Providing threat or security information;
Number of responses: 9.
Recommended federal role: Other;
Number of responses: 18.
Source: GAO survey of wastewater facilities.
[End of table]
Facility managers predominantly recommended additional funding to
further wastewater security improvements. Many facility managers
recommended targeting funding to specific measures, such as performing
vulnerability assessments, purchasing specific security equipment such
as surveillance cameras, or covering costs associated with switching
from gaseous chlorine to a safer disinfectant. To a much lesser extent,
wastewater facility managers commented that the federal government
could be of greater assistance in providing security guidance,
standards, and best practices. For example, one facility manager we
interviewed expressed a need for federal guidance and best practices on
collection system security. For its part, in 2002, EPA provided funding
to the American Society of Civil Engineers (ASCE) to develop a set of
security guidance documents that cover the design of online contaminant
monitoring systems, and physical security enhancements of drinking
water, wastewater, and storm water infrastructure systems. ASCE sub-
contracted with American Water Works Association and the Water
Environment Federation (WEF) for assistance on this project. In 2004
these documents were released as interim voluntary security design
standards for the water sector and finalized standards are to be
established in late 2006 or early 2007. These security-focused
documents are intended to serve as a foundation to help water utilities
address potential vulnerabilities through sound design, construction,
and operation and maintenance practices. According to a WEF
representative, one set of standards is to be directed at physical
security measures for wastewater collection systems. The security
standards are to be published in late 2006 and are to include both
prescriptive and performance-based criteria that focus on physical
security upgrades that reduce risk to water, wastewater, and storm
water infrastructure arising from malevolent events.
EPA and DHS Have Several Initiatives to Enhance Wastewater Facility
Security, Yet a Key Effort Requires Additional Coordination:
EPA and DHS have a number of initiatives under way related to
wastewater facility security. For example, EPA has funded programs to
develop vulnerability assessment tools and provide training to
wastewater facilities on the use of these tools, while DHS has
conducted site assessment visits at wastewater facilities. While these
initiatives are helping to address security concerns in the wastewater
sector, EPA and DHS efforts could nonetheless be more effective with
greater coordination over how best to convey security-related and
threat information to the wastewater treatment community.
EPA and DHS Have Several Initiatives Under Way Related to Wastewater
Security:
Since 2002, EPA has provided more than $10 million to help address the
security needs of the wastewater sector. EPA funded the development and
dissemination of several risk assessment methodologies to assist water
sector utilities in identifying how to better protect their critical
infrastructures. In addition, EPA funded training for wastewater
utilities on how to conduct risk assessments and update or complete
emergency response plans. EPA provided funding to the Association of
Metropolitan Sewerage Agencies[Footnote 18] to develop a software tool,
called the Vulnerability Self Assessment Tool (VSAT), for drinking
water utilities. In addition, through an interagency agreement with
EPA, the Department of Energy's Sandia National Laboratories provided
training to selected firms in a vulnerability assessment methodology
developed by the labs, called the Risk Assessment Methodology for Water
Utilities (RAM-W). For vulnerability assessments at smaller water
systems, EPA supported the dissemination of the Security and Emergency
Management System (SEMS) software tool.
Sixty-nine wastewater facilities responding to our survey indicated
they used, were currently using, or planned to use the VSAT software to
complete a vulnerability or security assessment; 27 facilities
indicated they either used, were currently using, or planned to use the
RAM-W assessment tool. Another four facilities indicated they either
used, were currently using, or planned to use the SEMS software.
EPA has also reorganized its own internal structure and sought input
from experts outside of the agency to better assist the wastewater
industry's security efforts. In particular, in 2003, EPA created a
Water Security Division to work with the states, tribes, drinking water
and wastewater utilities, and other partners to enhance the security of
water and wastewater utilities and the ability to respond effectively
to security threats and breaches. In addition, in 2004, the National
Drinking Water Advisory Council (NDWAC),[Footnote 19] at EPA's request,
established a Water Security Working Group made up of 16 members from
wastewater utilities, drinking water utilities, and environmental and
rate-setting organizations to advise on the development of best
security practices and policies for water utilities. The group advises
the NDWAC on ways to address several specific security needs of the
sector. In June 2005, the working group provided NDWAC with a report
that identified features of an active and effective security program
and ways to measure the adoption of these practices.
As noted, EPA provided funding to ASCE to develop a set of security
guidance documents that cover the design of online contaminant
monitoring systems, and physical security enhancements of drinking
water, wastewater, and storm water infrastructure systems. This effort,
called the Water Infrastructure Security Enhancement project, is to
address physical infrastructure security needs in the water sector by
issuing guidance documents, training materials, and voluntary standards
relating to water infrastructure security. The project group is
currently developing physical security standards that focus on physical
security upgrades to reduce risk to water, wastewater, and storm water
arising from malevolent acts.
For its part, DHS has two broad initiatives that have facilitated
efforts to improve wastewater security. First, the Buffer Zone
Protection program is a DHS grant program designed to reduce specific
vulnerabilities at a critical infrastructure or key resource site by
assisting local law enforcement to develop a plan for preventative and
protective measures that make it more difficult for terrorists to plan
or launch attacks from the immediate vicinity of the site. They also
identify equipment that could be purchased to mitigate the
vulnerabilities. Upon plan approval, DHS grants funds for procuring
materials and equipment necessary for implementation of the site's
buffer zone protection plan. According to DHS, as of October 31, 2005,
security at 14 wastewater facilities has been reviewed under the Buffer
Zone Protection program.
Under its second broad initiative, the Site Assistance Visits program,
DHS visits critical infrastructure sites nationwide to address key
areas of concern at facilities requiring security enhancements. DHS
subject matter experts in the areas of physical security measures,
system interdependencies, and terrorist attack prevention conduct these
visits--generally lasting 1 to 3 days--in which, among other things,
the vulnerabilities of the site or facility are identified and
mitigation options are discussed. According to DHS, as of October 31,
2005, a total of 350 site assessment visits have been conducted. Of
this total, seven were conducted with wastewater facilities.
In addition to these programs, DHS funded a NACWA project to develop a
decision tree and report template to help water systems assess and
examine chlorine gas alternatives for water and wastewater
disinfection. The decision tree guides water systems in evaluating the
potential costs and benefits of conversion and determining whether an
alternative disinfection method will still enable them to meet their
permit requirements. The report template is to ensure that the results
of the decision tree analysis are reported in a consistent format,
improving a water system's ability to pursue and secure any available
state or federal funding for conversion. According to a NACWA
representative, they are in the process of finishing the design of the
decision tool and, once the final product is reviewed and approved by
DHS, printing of the CD tool will begin. NACWA expects to make the tool
available to water and wastewater utilities free of charge no later
than the end of March 2006.
While EPA and DHS have these wastewater security-related initiatives
under way, the Congress has expressed concerns that EPA's homeland
security responsibilities are not well articulated in relation to DHS'
responsibilities. In the conference report for the fiscal year 2005
Consolidated Appropriations Act, conferees directed EPA to enter into a
memorandum of understanding (MOU) with DHS that defines the
relationship and responsibilities of the two entities regarding
homeland security and protection. EPA did not enter into the MOU, but
instead, on November 1, 2005, issued a report to the Congress entitled
"Homeland Security Roles and Responsibilities and Interactions Between
EPA and the Department of Homeland Security." The report identified the
homeland security-specific authorities, core mission authorities,
presidential directives, and existing MOUs EPA uses to implement its
homeland security roles and responsibilities. In the report, EPA stated
that it believes its homeland security roles and responsibilities are
sufficiently delineated not only through statutes, presidential
directives, and existing MOUs, but also through planning documents and
deliverables associated with a wide variety of collaborative homeland
security-related projects that EPA and DHS are carrying out.
Multiple Efforts to Provide Critical and Threat-Related Information to
the Water Sector Need Additional Coordination:
In December 2002, the Association of Metropolitan Water Agencies (AMWA)
received a grant from EPA to establish a communication system to share
security information with water sector utilities, known as the Water
Information Sharing and Analysis Center (WaterISAC).[Footnote 20] The
WaterISAC is one of thirteen critical infrastructure and key resource
sector-specific information sharing and analysis centers. The WaterISAC
was designed to meet the information sharing needs of both water and
wastewater utilities by providing real-time alerts of possible
terrorist activity, allowing for the secure reporting of incidents and
the sharing of information among users, and allowing access to a
library of security-related information and contaminant databases.
Beginning in fiscal year 2003, EPA has annually provided AMWA with a $2
million grant to support the WaterISAC. This grant is augmented by
subscription fees paid by drinking water and wastewater
systems.[Footnote 21] In November 2004, the WaterISAC launched a free
security advisory system known as the Water Security Channel that
distributes federal advisories on security threats via e-mail to the
water sector. The Water Security Channel also includes a searchable
archive of federal alerts, advisories, and bulletins. However, it does
not provide access to the same level of service as the subscription-
based WaterISAC. WaterISAC subscribers receive additional services,
including a secure communication system, access to vulnerability
assessment tools and resources, access to an online library related to
water security issues, and access to databases about chemical,
biological, and radiological agents.
DHS has also sought to enhance communication between critical
infrastructure sectors and the government. Under the Homeland Security
Act of 2002, DHS is responsible for reducing the vulnerability of the
national infrastructure and for coordinating and communicating with all
key stakeholders on homeland security-related matters. According to
DHS, to fulfill this mandate, it requires a communication system that
provides equal and appropriate access to security information to all
owners and operators of critical infrastructure and key resources. In
2004, it piloted a new secure network, the Homeland Security
Information Network (HSIN), to help achieve this mandate.
HSIN is DHS' primary conduit through which it shares information on
domestic terrorist threats, suspicious activity reports, and incident
management. It is composed of multiple communities of interest,
including the HSIN Critical Sector (HSIN-CS) program, which is intended
to enhance the protection, preparedness, and crisis communication and
coordination capabilities of the nation's 17 critical infrastructure
and key resource sectors identified in HSPD-7. The HSIN platform for
critical sectors is being developed and offered to each sector to
provide a suite of information and communication tools to share
critical information both within the sector, with DHS, and eventually
across sectors. Because the water sector is one of the nation's 17
critical infrastructure and key resources, a HSIN-CS portal for the
sector, called HSIN Water Sector (HSIN-WS), is currently being
developed by DHS. A Water Sector Coordinating Council was also
established by the water sector with representative members of the
water sector community and charged with identifying information and
other needs of the sector, including the appropriate use of and the
relationship among Water ISAC, the Water Security Channel, and
HSIN.[Footnote 22]
While these efforts are helping to improve communication, staff at EPA
and DHS, as well as other industry experts with whom we spoke, have
expressed concern that the evolution of the information sharing and
dissemination function for the water sector has resulted in several
inefficiencies.
* WaterISAC access is limited to drinking water and wastewater
subscribers, plus a restricted number of subscribers from EPA and the
state drinking water programs. For example, the agreement limits
designated users to five individuals at EPA headquarters and one person
in each EPA region, for a total of fifteen EPA users. States are
limited to only two users. EPA staff note that access for others in the
sector, such as the technical service community, universities, training
centers and laboratories, would benefit the overall protection of
drinking water and wastewater critical infrastructures. EPA and DHS
staff told us that, depending upon the user policy established by the
sector, the HSIN network could allow for broader sharing of access than
currently available under the WaterISAC.
* Only a small portion of the water sector is reached by the WaterISAC.
According to EPA staff, just over 530 utilities are reached by the
WaterISAC, while over 8,000 utilities receive information through the
Water Security Channel. However, the Water Security Channel does not
provide the same level of notification and information sharing provided
by the WaterISAC. The Water Security Channel is essentially a "push e-
mail system" that sends out general security bulletins to water
utilities and other users, and allows for searches of previous
bulletins. This service is much more limited than that provided to
WaterISAC subscribers, which provides a secure communication system for
users to share information, access to vulnerability assessment tools
and resources, access to an online library related to water security
issues, and access to databases about chemical, biological, and
radiological agents. One water industry representative told us that the
WaterISAC recently lowered its subscription fees due to industry
concerns that the fees were limiting WaterISAC subscriptions. EPA staff
told us that the water sector generally has less funding available to
support ISAC services than other sectors such as electric, financial,
and transportation.
* WaterISAC duplicates some operational functions likely available
through HSIN. EPA estimates that roughly $600,000 to $700,000 of the
annual $2 million WaterISAC grant is used to support computer hardware
and software for the secure web portal. Meanwhile, to support HSIN, DHS
funds similar computer software and hardware and its related technical
support. EPA staff noted that WaterISAC could make use of the software
and hardware platform available through HSIN. EPA staff believed that
WaterISAC could then better focus its resources on managing its user
list, managing information content on the secure web site, and
analyzing and distributing threat information, while leaving DHS to
manage and run the hardware and software.
The current reach and levels of service offered by the WaterISAC and
the Water Security Channel do not meet DHS' objective to establish a
communication system that provides equal and appropriate access to
security information to all owners and operators in this critical
infrastructure area. According to EPA and DHS staff, the Water Sector
Coordinating Council will consider options to improve coordination
between the WaterISAC, the Water Security Channel, and HSIN. Using
funding from the supporting grant from EPA, the WaterISAC is currently
examining options for coordination between the WaterISAC, the Water
Security Channel, and HSIN. EPA noted that this review is ongoing and
will likely be presented in preliminary form to the Water Sector
Coordinating Council in a mid-March 2006 meeting. However, the scope of
the preliminary review is not clear, nor is a time frame set to
complete the review. According to DHS, the creation of the DHS Homeland
Infrastructure Threat and Risk Analysis Center will assist in
information sharing of intelligence threat information between DHS and
federal, state, and private sector partners.
Conclusions:
Many of the nation's large wastewater facilities have made security
improvements since the terrorist attacks of September 11, 2001. Of
particular note, many have completed some type of security assessment,
and additional facilities have such assessments under way. Our survey
also found that wastewater facilities are continuing to move away from
the use of potentially dangerous gaseous chlorine as a wastewater
disinfectant. One area of continuing concern is the difficulty these
facilities are having in addressing vulnerabilities associated with
their collection systems. Facility managers explained that with limited
funding available, other important measures considered to be more
feasible and affordable were assigned greater priority. EPA is
attempting to help address this difficult issue through funding the
American Society of Civil Engineers project to develop voluntary
physical security standards for the water sector.
Despite limited federal authority over security at the nation's
wastewater facilities, EPA, as the lead agency for water sector
security, has worked with DHS and industry groups to advance wastewater
security by providing vulnerability assessment tools, training,
guidance, and burgeoning information sharing networks. These efforts,
combined with the individual initiatives of many wastewater facilities,
have resulted in measurable security improvements. However, these
efforts could benefit from additional coordination, and we acknowledge
and support EPA's and DHS' commitment to do so. As these agencies move
forward, we believe they should act upon the opportunities we have
identified that could improve both the efficiency with which limited
dollars are being spent, as well as the delivery of vital information
services to the wastewater community. Specifically, a substantial part
of the $2 million annual EPA grant that funds WaterISAC goes to support
a computer platform that may be available at no cost through HSIN.
Recommendation for Executive Action:
We recommend that the Administrator of EPA work with DHS and the Water
Sector Coordinating Council to identify areas where the WaterISAC and
HSIN networks could be better coordinated, focusing in particular on
(1) how operational duplications and overlap could be addressed, and
(2) how water systems' access to timely security threat information
could be improved. We also recommend that EPA work with DHS and the
Water Sector Coordinating Council to identify realistic time frames for
the completion of these tasks.
Agency Comments and Our Evaluation:
We provided a draft of this report to DHS and EPA for review and
comment. DHS agreed with the factual content of the report, and its
Office of Infrastructure Protection provided written technical comments
and clarifications that have been incorporated, as appropriate. In its
letter, reproduced in appendix III, EPA concurred with the results of
the report. EPA's Water Security Division in the Office of Ground Water
and Drinking Water also provided technical comments and clarifications
that were incorporated, as appropriate.
As agreed with your office, unless you publicly release the contents of
this report earlier, we plan no further distribution until 30 days from
the report date. At that time, we will send copies of this report to
the appropriate congressional committees; interested Members of
Congress; the Administrator, Environmental Protection Agency; the
Secretary, Department of Homeland Security; and other interested
parties. We will also make copies available to others on request. In
addition, the report will be available at no charge on the GAO Web site
at [Hyperlink, http://www.gao.gov.].
Should you or your staff need further information, please contact me at
(202) 512-3841 or [Hyperlink, stephensonj@gao.gov]. Contact points for
our Offices of Congressional Relations and Public Affairs may be found
on the last page of this report. GAO staff who made major contributions
to this report are listed in appendix IV.
Sincerely yours,
Signed By:
John B. Stephenson:
Director, Natural Resources and Environment:
[End of Section]
Appendix I: Scope and Methodology:
To identify federal statutory authorities and directives that govern
protection of wastewater treatment facilities, we reviewed applicable
laws, Homeland Security Presidential Directives, and policies,
guidance, and regulations related to wastewater security from the
Environmental Protection Agency (EPA) and the Department of Homeland
Security (DHS). In addition, we interviewed officials in EPA's Water
Security Division, as well as DHS officials in various areas of the
agency. In addition, we spoke with representatives for wastewater
industry associations with which EPA has collaborated to actively
assist wastewater treatment facilities to address their security issues.
To determine the steps critical wastewater treatment facilities have
taken since 9/11 to address potential vulnerabilities, we conducted a
Web-based survey of the nation's largest wastewater treatment
facilities. For the purpose of this review, we defined "critical
wastewater facilities" as the 253 wastewater facilities in the United
States that have service area populations of 100,000 or greater, as
identified in the results of EPA's 2004 Clean Watershed Needs
Survey.[Footnote 23] As a result of Hurricane Katrina, one facility in
our initial population of 253 facilities that was identified as a New
Orleans facility was omitted, leaving a total 252 facilities in our
survey population. We drafted the survey in consultation with our own
survey professionals. In addition, we solicited the review and comment
of knowledgeable officials from the National Academy of Sciences, the
Water Environment Federation, and the National Association of Clean
Water Agencies, as well as several wastewater security experts
identified in our January 2005 report on wastewater security.[Footnote
24] We conducted seven pretests to check that (1) the questions were
clear and unambiguous, (2) terminology was used correctly, (3) the
information was feasible to obtain, and (4) the survey was
comprehensive and unbiased. The pretest sites were chosen to include
facilities representing different geographic regions, and utilities
both with single and multiple facilities. One pretest was done in
person and six were done over the phone.
Our survey asked wastewater treatment facility representatives to
provide a variety of information, such as whether their facilities had
conducted security assessments; what measures, if any, they had taken
or were planning to take in several security areas; and their
perspectives on what role the federal government should assume in
wastewater treatment facility security. The survey was made available
between October 1, 2005, and January 15, 2006, and a unique user
identification number and a password were provided to each surveyed
facility. Three e-mail reminders were sent out to nonresponders, and
then follow-up phone calls were made to all nonresponding facilities. A
total of 206 of 252 wastewater treatment facilities responded to the
survey, resulting in an 82 percent survey response rate. Other
wastewater facilities that did not respond to the survey generally
cited security concerns related to providing potentially sensitive
information or a general policy of not answering surveys.
Because this was not a sample survey, there are no sampling errors.
However, the practical difficulties of conducting any survey may
introduce errors, commonly referred to as non-sampling errors. For
example, difficulties in how a particular question is interpreted or in
the sources of information that are available to respondents can
introduce unwanted variability into the survey results. We took steps
both at the data collection and at the analysis phases to minimize
these non-sampling errors. Since this was a Web-based survey,
respondents entered their answers directly into the electronic
questionnaire, which removes one source of error. When the data were
analyzed, a second, independent analyst checked all relevant computer
programs.
To determine what steps EPA and DHS have taken to help wastewater
facilities in their efforts to address vulnerabilities, we took several
approaches. First, through semi-structured interviews with agency
officials and industry association representatives, as well as document
reviews, we researched various programs that EPA and DHS have under
way. Second, we identified programs that require cross-agency
collaboration between EPA and DHS, and we examined in depth those that
wastewater treatment facility representatives identified as potentially
useful. We also interviewed state and local officials with oversight
for wastewater treatment operations and security. Third, one section of
our survey gathered information about facility representatives'
experiences with, perspectives on, and expectations for, the federal
role in wastewater treatment facility security. Responses to open-ended
questions were categorized and tallied to analyze their content for
subsequent research findings. Finally, to develop conclusions about the
level of coordination between the two agencies in the implementation of
these programs, we interviewed agency officials about their
perspectives on how well the agencies are working together.
[End of section]
Appendix II: Survey of Wastewater Treatment Facilities:
[See PDF for image]
[End of figure]
[End of section]
Appendix III: Comments from the Environmental Protection Agency:
United States Environmental Protection Agency:
Washington, D.C. 20460:
Office Of Water:
Mr. John B. Stephenson:
Director:
Natural Resources and the Environment Government:
Accountability Office:
Washington, DC 20548:
Dear Mr. Stephenson:
Thank you for the opportunity to review the draft Government
Accountability Office (GAO) Report; Security Wastewater Facilities:
Utilities Have Made Important Upgrades, Though Further Improvements To
Key System Components May Be Limited by Costs and Other Constraints. We
appreciate the information in the report and have already begun to
address some of the concerns that you raised. Staff members from my
program have provided GAO with technical comments on the draft under
separate cover.
We all rely on clean, safe, and secure water. Therefore, from a public
health and economic perspective, it is critical that we protect our
nation's wastewater infrastructure. Your report recommends that the
Environmental Protection Agency (EPA or Agency) work with the
Department of Homeland Security (DHS) and the Water Sector Coordinating
Council to identify areas where the Water Information Sharing and
Analysis Center (WaterISAC) and the Department of Homeland Security's
Homeland Security Information Network (HSIN) could be better
coordinated, focusing in particular on (1) how operational duplications
and overlap could be addressed, and (2) how water systems' access to
timely security threat information could be improved. GAO also
recommends that EPA work with DHS and the Water Sector Coordinating
Council to identify realistic timeframes for the completion of these
tasks.
The results and recommendation of the report are useful, well thought
out, and demonstrate a well conceived and executed project. The Agency
has a number of initiatives underway to address GAO's recommendations.
EPA continues to encourage the Water Sector Coordinating Council to
consider how the WaterISAC and HSIN could be integrated to be more
useful to the sector.
The Association of Metropolitan Water Agencies (AMWA) operates the
WaterISAC using funding from a directed grant from EPA. The most recent
grant agreement included a term and condition to evaluate how WaterISAC
and HSIN features might be effectively combined. As a result of this
task in AMWA's grant agreement, the WaterISAC is in the process of
conducting an evaluation of the two systems. Furthermore, the Water
Sector Coordinating Council has asked AMWA to conduct a similar
evaluation of the features of WaterISAC and HSIN. EPA continues to work
with DHS and the Water Government Coordinating Council to seek
opportunities to improve the features of HSIN for eventual adoption by
the water sector.
A number of the issues raised in the document will be useful to the
Agency as it moves forward with the wastewater and drinking water
security program. EPA has been designated as the Sector Specific Agency
for the Water Sector - which covers both drinking water and wastewater
utilities. To ensure the safety of our nation's drinking water supply
and the protection of water quality by reducing the risk to public
health, the environment, and critical infrastructure, the Agency is
committed to continuing to collaborate and build upon existing
relationships with DHS and other parties - including utilities, other
critical infrastructure sectors, state, local and tribal governments,
and stakeholders. This coordination is critical in order to better
understand interdependencies, develop tools and training, improve
information sharing and exchange mechanisms, and conduct research
activities to ensure that critical infrastructure operations in the
water sector are not interrupted by potential terrorist or other
intentional acts.
I appreciated the opportunity to coordinate with your staff on this
project. Should you need additional information or have further
questions, please contact me or Cynthia C. Dougherty, Director of the
Office of Ground Water and Drinking Water at (202) 564-3750.
Sincerely,
Signed By:
Benjamin H. Grumbles:
Assistant Administrator:
[End of section]
Appendix IV: GAO Contact and Staff Acknowledgments:
GAO Contact:
John B. Stephenson (202) 512-3841:
Acknowledgments:
In addition to the contact named above, Nancy Bowser, Jenny Chanley,
Steve Elstein, Greg Marchand, Tim Minelli, Cynthia Norris, Jerry
Sandau, Rebecca Spithill, and Monica Wolford made key contributions to
this report.
(360576):
[End of section]
FOOTNOTES
[1] GAO, Wastewater Facilities: Experts' Views on How Federal Funds
Should Be Spent to Improve Security, GAO-05-165 (Washington, D.C.: Jan.
31, 2005).
[2] Pub. L. No. 107-188 (2002).
[3] 42 U.S.C. §§ 300f-300j.
[4] When we discuss vulnerability assessments in this report, we are
referring to assessments that include the review criteria identified in
the Bioterrorism Act and in EPA guidance. EPA issued guidance on
vulnerability assessments for drinking water systems regulated under
the Bioterrorism Act that stated the assessments should address six key
elements: (1) characterization of the system, including its mission and
objectives; (2) identification and prioritization of adverse
consequences to avoid; (3) determination of critical assets that might
be subject to malevolent acts that could result in undesired
consequences; (4) assessment of the likelihood of such malevolent acts;
(5) evaluation of existing countermeasures; and (6) analysis of current
risk, and development of a prioritized plan for risk reduction.
[5] Pub. L. No. 101-549 (1990).
[6] EPA requires that any facility storing at least 2,500 pounds of
chlorine gas submit a RMP.
[7] GAO, Homeland Security: Voluntary Initiatives Are Under Way at
Chemical Facilities, but the Extent of Security Preparedness Is
Unknown, GAO-03-439 (Washington, D.C.: March 14, 2003).
[8] Specifically, section 112(r)(1) of the Clean Air Act includes a
general duty clause directing owners and operators of facilities that
produce, process, handle, or store listed or other extremely hazardous
substances to identify hazards, design and maintain a safe facility to
prevent releases, and minimize the consequences of any accidental
releases that occur.
[9] Pub. L. No. 94-580 (1976), 42 U.S.C. §§ 6901-6992k.
[10] 40 C.F.R. § 264.14.
[11] Pub. L. No. 91-596 (1970), 29 U.S.C. §§ 651-678.
[12] Pub. L. No. 99-499 (1986), 42 U.S.C. §§ 11001-11050.
[13] Pub. L. No. 100-7 (1987).
[14] EPA fact sheet, "Use of the Clean Water State Revolving Fund to
Implement Security Measures at Publicly-owned Wastewater Treatment
Works" (Washington, D.C., 2003).
[15] Forty-eight percent of facilities responding to our survey
indicated they were combined systems, in that they managed both
drinking water and wastewater treatment.
[16] Specifically, of the 85 facilities reporting current use of
gaseous chlorine, 59 store gaseous chlorine in one-ton containers. This
method of storage is considered by experts to be safer than storing it
in larger containers because ruptures or leaks would be limited to
smaller areas. Three facilities reported storing gaseous chlorine in
150-pound cylinders. Six facilities reported storing gaseous chlorine
in 17-ton tractor trailers, while nine reported storing the gas in 91-
ton rail cars. Eight facilities did not report a storage method.
[17] Combined sewer systems collect rainwater runoff, domestic sewage,
and industrial wastewater in the same pipe. During periods of heavy
rainfall or snowmelt the wastewater volume in a combined sewer system
can exceed the capacity of the sewer system or treatment plant,
resulting in an overflow and discharge of untreated wastewater directly
to nearby streams, rivers, or other water bodies. EPA considers these
overflows to be a major pollution concern for the approximately 772
cities that have combined sewer systems.
[18] Now the National Association of Clean Water Agencies (NACWA).
[19] NDWAC is a federal advisory committee that supports EPA in
performing its duties and responsibilities related to the national
drinking water program. The council was created on December 16, 1974,
through a provision in the Safe Drinking Water Act.
[20] Information Sharing and Analysis Centers (ISACs) are confidential
venues for sharing security vulnerabilities and solutions within an
industry. Presidential Decision Directive 63 and Executive Order 13231
designated the water sector (and other industry sectors) as critical to
the nation's well-being and called for the establishment of ISACs to
promote the flow of security information. Additionally, HSPD-7
encouraged creation of private-sector information sharing and analysis
mechanisms, such as the Water ISAC, to protect drinking water and
wastewater infrastructure from attack.
[21] Water and wastewater systems with a service population over
100,000 pay an annual fee of $1,000, systems between 50,000 and 100,000
pay $500, and systems serving less than 50,000 pay $200 annually. The
annual fee pays for one user per system. Additional users are allowed,
with limits, for additional fees.
[22] According to DHS, sector coordinating councils are to be developed
for each critical infrastructure and key resource area and will be
responsible to determine and support the most effective method of
information sharing and communication for the sector, whether by using
the current ISAC or building new mechanisms.
[23] EPA's Office of Wastewater Management conducts the Clean Watershed
Needs Survey (CWNS) on a periodic basis. The CWNS, a joint effort
between states and EPA, is conducted in response to Section 205(a) and
516 of the Clean Water Act.
[24] GAO-05-165.
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