Drinking Water: Experts' Views on How Future Federal Funding Can
Best Be Spent to Improve Security (31-OCT-03, GAO-04-29).
After the events of September 11, 2001, Congress appropriated
over $100 million to help drinking water systems assess their
vulnerabilities to terrorist threats and develop response plans.
As the Environmental Protection Agency has suggested, however,
significant additional funds may be needed to support the
implementation of security upgrades. Therefore, GAO sought
experts' views on (1) the key security-related vulnerabilities of
drinking water systems; (2) the criteria for determining how
federal funds should be allocated among drinking water systems to
improve their security, and the methods for distributing those
funds; and (3) specific activities the federal government should
support to improve drinking water security. GAO conducted a
systematic Webbased survey of 43 nationally recognized experts to
seek consensus on these key drinking water security issues.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-04-29
ACCNO: A08812
TITLE: Drinking Water: Experts' Views on How Future Federal
Funding Can Best Be Spent to Improve Security
DATE: 10/31/2003
SUBJECT: Appropriated funds
Counterterrorism
Federal funds
Funds management
Internal controls
Potable water
Public utilities
Safety regulation
Water quality
Water treatment
National preparedness
******************************************************************
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GAO-04-29
United States General Accounting Office
GAO
Report to the Committee on Environment
and Public Works, U.S. Senate
October 2003
DRINKING WATER
Experts' Views on How Future Federal Funding Can Best Be Spent to Improve
Security
a
GAO-04-29
Highlights of GAO-04-29, a report to the Committee on Environment and
Public Works, U.S. Senate
After the events of September 11, 2001, Congress appropriated over $100
million to help drinking water systems assess their vulnerabilities to
terrorist threats and develop response plans. As the Environmental
Protection Agency has suggested, however, significant additional funds may
be needed to support the implementation of security upgrades. Therefore,
GAO sought experts' views on (1) the key security-related vulnerabilities
of drinking water systems; (2) the criteria for determining how federal
funds should be allocated among drinking water systems to improve their
security, and the methods for distributing those funds; and (3) specific
activities the federal government should support to improve drinking water
security.
GAO conducted a systematic Webbased survey of 43 nationally recognized
experts to seek consensus on these key drinking water security issues.
GAO recommends that as EPA refines its efforts to help drinking water
utilities reduce their vulnerability to terrorist attacks, the agency
consider the information in this report to help determine: how best to
allocate security-related federal funds among drinking water utilities;
which methods should be used to distribute the funds; and what specific
security-enhancing activities should be supported.
www.gao.gov/cgi-bin/getrpt?GAO-04-29.
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 [email protected].
October 2003
DRINKING WATER
Experts' Views on How Future Federal Funding Can Best Be Spent to Improve
Security
GAO's expert panel cited distribution systems as among the most vulnerable
physical components of a drinking water utility, a conclusion also reached
by key research organizations. Also cited were the computer systems that
manage critical utility functions, treatment chemicals stored on site, and
source water supplies. Experts further identified two overarching
vulnerabilities: (1) a lack of information individual utilities need to
identify their most serious threats; and (2) a lack of redundancy in vital
system components, which increases the likelihood that an attack could
render an entire utility inoperable.
According to over 90 percent of the experts, utilities serving
high-density areas deserve at least a high priority for federal funding.
Also warranting priority are utilities serving critical assets, such as
military bases, national icons, and key academic institutions. Direct
federal grants were clearly the most preferred funding mechanism, with
over half the experts indicating that such grants would be very effective
in distributing funds to recipients. Substantially fewer experts
recommended using the Drinking Water State Revolving Fund for security
upgrades.
When experts were asked to identify specific security-enhancing activities
most deserving of federal support, their responses generally fell into
three categories:
o physical and technological upgrades to improve security and research
to develop technologies to prevent, detect, or respond to an attack
(experts most strongly supported developing near realtime monitoring
technologies to quickly detect contaminants in treated drinking water on
its way to consumers);
o education and training to support, among other things, simulation
exercises to provide responders with experience in carrying out emergency
response plans; specialized training of utility security staff; and
multidisciplinary consulting teams to assess utilities' security
preparedness and recommend improvements; and
o strengthening key relationships between water utilities and other
agencies that may have key roles in an emergency response, such as public
health agencies, law enforcement agencies, and neighboring drinking water
systems; this category also includes developing protocols to encourage
consistent approaches to detecting and diagnosing threats.
Contents
Letter 1
Executive Summary 2
Purpose 2
Background 2
Results in Brief 5
Principal Findings 7
Recommendation for Executive Action 13
Agency Comments 13
Chapter 1 14
Key Components of a Typical Drinking Water System 14
Introduction The Nation's Drinking Water Systems and the Populations They
Serve 16
Government and Industry Have Recently Sought to Improve
Security 17
Efforts to Further Improve Security after the September 11
Attacks 18
Potentially Larger Federal Financial Commitment Sought in Future
Years 19
Objectives, Scope, and Methodology 19
Chapter 2
Experts Identified Key
Vulnerabilities That
Could Compromise
Drinking Water
Systems' Security
Vulnerability of Physical Assets 23 Overarching Issues Affecting Drinking Water
Systems' Security 28
Chapter 3 31
Experts' Views on the Strong Agreement That Allocation Decisions Should
Consider a
Utility's Vulnerability Assessment 32 Allocation and Key Criteria to Help
Determine Which Utilities Should Receive
Distribution of Federal Funding Priority 35
Funds Funding Mechanisms Recommended for Distributing Federal Funds
37
Contents
Chapter 4 43 Activities Experts Activities to Enhance Physical Security
and Support Technological
Improvements 43 Identified As Most Activities to Improve Education and
Training 54 Deserving of Federal Activities to Strengthen Relationships
between Agencies and
Utilities 59
Support Conclusions 65
Recommendation for Executive Action 66
Appendixes
Appendix I: Participating Experts on Drinking Water Security Panel 67
Appendix II: GAO Contacts and Staff Acknowledgments 69 GAO Contacts 69
Acknowledgments 69
Table Table 1: Vulnerability Assessment Completion Deadlines
Figures Figure 1: Figure 2: Figure 3:
Figure 4:
Figure 5:
Figure 6: Figure 7: Figure 8: Figure 9:
Key Components of a Typical Drinking Water System
Key Components of a Typical Drinking Water System
Number of Drinking Water Systems That Serve Various
Populations
Key Vulnerabilities Identified As Compromising Drinking
Water Systems' Security
Experts' Views on Whether Federal Funds Should Be
Allocated Based on Vulnerability Assessment
Information
Experts' Views on Which Types of Water Utilities Should
Receive Priority for Federal Funds
Recommended Approaches for Distributing Federal
Funds
Activities Identified by Expert Panel to Enhance Physical
Security and Support Technological Improvements
ActivitiesIdentifiedby Experts to Improve Education and
Training
4 15
16
24
33 35 38 44 55 60
Figure 10: Activities Identified by Experts to Strengthen Relationships
between Agencies and Utilities
Contents
Abbreviations
AMSA Association of Metropolitan Sewerage Agencies
AMWA Association of Metropolitan Water Agencies
AWWA American Water Works Association
BASIC Bay Area Security Information Collaborative
CDC Centers for Disease Control and Prevention
DWSRF Drinking Water State Revolving Fund
EPA Environmental Protection Agency
ETV Environmental Technology Verification
FBI Federal Bureau of Investigation
ICMA International City/County Management Association
ISAC Information Sharing and Analysis Center
MADIRT Mutual Aid Disaster and Intervention and Response Teams
NRWA National Rural Water Association
NRDC Natural Resources Defense Council
PDD Presidential Decision Directive
SCADA Supervisory Control and Data Acquisition
VA vulnerability assessment
VSAT Vulnerability Self Assessment Tool
WEF Water Environment Federation
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
its entirety without further permission from GAO. However, because this
work may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this material
separately.
A
United States General Accounting Office Washington, D.C. 20548
October 31, 2003
The Honorable James Inhofe
Chairman
The Honorable James Jeffords
Ranking Minority Member
Committee on Environment and Public Works
United States Senate
As requested, this report discusses the views of nationally recognized
experts on key issues concerning drinking water security, including
serious
vulnerabilities of drinking water systems, criteria for allocating federal
funds among systems, and activities that most warrant federal support to
mitigate the risk of terrorism.
As agreed in discussions with your offices, unless you publicly announce
its contents earlier, we plan no further distribution of this report until
30
days from the date of this letter. We will then send copies to other
appropriate congressional committees, and to the Administrator of the
Environmental Protection Agency. We will also make copies available to
others upon request. In addition, the report will be available at no
charge
on the GAO Web site at http://www.gao.gov.
If you or your staffs have any questions concerning this report, please
call
me at (202) 512-3841 or my Assistant Director, Steve Elstein, at
(202) 512-6515. Major contributors to this report are listed in appendix
II.
John B. Stephenson Director, Natural Resources and Environment
Executive Summary
Purpose Drinking water utilities across the country have long been
recognized as potentially vulnerable to terrorist attacks of various
types, including physical disruption, bioterrorism, chemical
contamination, and cyber attack. Damage or destruction by terrorists could
disrupt not only the availability of safe drinking water, but also the
delivery of vital services that depend on these water supplies, such as
fire suppression. Such concerns were greatly amplified by the September
11, 2001, attacks on the World Trade Center and the Pentagon and then by
the discovery of training manuals in Afghanistan detailing how terrorist
trainees could support attacks on drinking water systems.
Congress has since committed significant federal funding to assist
drinking water utilities, with over $100 million appropriated through
fiscal year 2004 to help systems assess their vulnerabilities to terrorist
threats and develop response plans. As significant as these funds are, it
is likely that drinking water utilities will ask the federal government to
provide larger sums to go beyond the planning for upgrading drinking water
security to the actual implementation of security upgrades. Consequently,
as agreed with the Chairman and Ranking Minority Member of the Senate
Committee on Environment and Public Works, this report identifies (1) the
key securityrelated vulnerabilities affecting the nation's drinking water
systems; (2) the criteria that should be used to determine how federal
funds are allocated among recipients to improve their security, and the
methods that should be used to distribute these funds; and (3) specific
activities the federal government should support to improve drinking water
security.
To address these issues, GAO conducted a Web-based Delphi survey process
involving 43 nationally recognized experts. The Delphi method is a
systematic process for obtaining individuals' views on a question or
problem of interest and seeking consensus, if possible. In selecting
members for the expert panel, GAO sought individuals who were widely
recognized as possessing expertise on one or more key aspects of drinking
water security. GAO also sought to achieve balance in representation from
key federal agencies, key state or local agencies, key industry and
nonprofit organizations, and water utilities of varying sizes. A detailed
description of GAO's methodology is presented in chapter 1.
Background Drinking water systems vary by size and other factors, but as
illustrated in figure 1, they most typically include a supply source,
treatment facility, and distribution system. A water system's supply
source may be a reservoir,
Executive Summary
aquifer, or well, or a combination of these sources. Some systems may also
include a dam to help maintain a stable water level, and aqueducts and
transmission pipelines to deliver the water to a distant treatment plant.
The treatment process generally uses filtration, sedimentation, and other
processes to remove impurities and harmful agents, and disinfection
processes such as chlorination to eliminate biological contaminants.
Chemicals used in these processes, most notably chlorine, are often stored
on site at the treatment plant. Distribution systems comprise water
towers, piping grids, pumps, and other components to deliver treated water
from treatment systems to consumers. Particularly among larger utilities,
distribution systems may contain thousands of miles of pipes and numerous
access points.
Executive Summary
infrastructure against criminal and terrorist attacks. The directive
designated the Environmental Protection Agency (EPA) as the lead federal
agency to address the water infrastructure and to work with both public
and private organizations to develop emergency preparedness strategies.
EPA, in turn, appointed the Association of Metropolitan Water Agencies to
coordinate the water industry's role in emergency preparedness. During
this time, this public-private partnership focused primarily on cyber
security threats for the several hundred community water systems that each
served over 100,000 persons. The partnership was broadened in 2001 to
include both the drinking water and wastewater sectors, and focused on
systems serving more than 3,300 people.
Efforts to better protect drinking water infrastructure were accelerated
dramatically after the September 11 attacks. EPA and the drinking water
industry launched efforts to share information on terrorist threats and
response strategies. They also undertook initiatives to develop guidance
and training programs to assist utilities in identifying their systems'
vulnerabilities. As a major step in this regard, EPA supported the
development, by American Water Works Association Research Foundation and
Sandia National Laboratories, of a vulnerability assessment methodology
for larger drinking water utilities. The push for vulnerability
assessments was then augmented by the Public Health Security and
Bioterrorism Preparedness and Response Act of 2002 (Bioterrorism Act).
Among other things, the act required each community water system serving
more than 3,300 individuals to conduct a detailed vulnerability assessment
by specified dates in 2003 or 2004, depending on their size.
Results in Brief GAO's expert panel identified several key physical assets
as the most seriously vulnerable to terrorist attacks. In general, their
observations were similar to those of major public and private
organizations that have assessed the vulnerability of these systems to
terrorist attacks, including the National Academy of Sciences, Sandia
National Laboratories, and key industry associations. In particular, when
asked to identify what they believed to be among the top vulnerabilities
of drinking water utilities, nearly 75 percent of the experts (32 of 43)
identified the distribution system (one or more components). More experts
identified the distribution system as the top vulnerability (12 of 43)
among the components of the drinking water system. The other physical
assets most frequently cited were source water supplies, critical
information systems, and chemicals stored on site that are used in the
treatment process. Importantly, the experts also identified overarching
vulnerability issues that may involve multiple system
Executive Summary
components, or even an entire drinking water system. Chief among these
issues were (1) a lack of redundancy in vital systems, which increases the
likelihood that an attack could render a system inoperable; and (2) the
difficulty many systems face due to a lack of information on the most
serious threats to which they are exposed.
Key criteria experts cited for determining how federal funds to improve
drinking water security should be allocated included (1) the extent to
which information on utilities' vulnerabilities should be considered in
making allocation decisions; and (2) characteristics of the utilities
themselves, such as size and proximity to population centers.
o About 90 percent of the panelists strongly agreed or somewhat agreed
that allocation decisions should be based on vulnerability assessment
information. Several factors, however, complicate the government's ability
to use utilities' vulnerability assessments for this purpose.
o Panelists favored funding priority for utilities serving high-density
populations, with over 90 percent indicating that they deserve at least a
high priority and over 50 percent indicating they deserve highest
priority. Utilities serving critical assets (such as military bases and
other sensitive government facilities, national icons, and key cultural or
academic institutions) were also recommended as high-priority recipients,
while relatively few experts recommended priority for utilities serving
rural or isolated populations.
When asked to identify the most effective mechanisms of distributing
federal drinking water security funds to recipients, over half the experts
indicated that direct federal grants would be very effective in doing so.
Many also favored including a requirement for matching funds as a grant
condition. Fewer experts recommended using the Drinking Water State
Revolving Fund (DWSRF) for this purpose, particularly to support upgrades
that need to be implemented quickly.
When asked to identify and set priorities for security-enhancing
activities most deserving of federal support, the experts most frequently
identified activities that generally fell into three broad categories:
o Physical and technological improvements includes both physical
alterations to improve the security of drinking water systems and the
Executive Summary
development of technologies to prevent, detect, or respond to an attack.
The need to develop near real-time monitoring technologies, which would be
particularly useful in quickly detecting contaminants in water that has
already left the treatment plant for the consumer, had by far the
strongest support.
o Education and training would be used for both utility and nonutility
personnel responsible for preventing, responding to, and recovering from
an attack. These activities include, among other things, support for
simulation exercises to provide responders with experience in carrying out
utilities' emergency response plans; specialized training of utility
personnel responsible for security; general training of utility personnel
to augment security awareness among all staff; and multidisciplinary
consulting teams to independently analyze utilities' security preparedness
and recommend security-related improvements.
o Strengthening relationships is seen as critical between water utilities
and other agencies (public health agencies, enforcement agencies, and
neighboring utilities, among others) that may have key roles in an
emergency response. This category also includes developing common
protocols to engender a consistent approach among utilities in detecting
and diagnosing threats, and the testing of local emergency response
systems to ensure that participating agencies coordinate their actions
effectively.
Principal Findings
Key Vulnerabilities Nearly 75 percent of the experts on GAO's panel (32 of
43) named the distribution system (one or more components) as among the
top vulnerabilities of drinking water systems. In fact, 12 of the 32
experts identified the distribution system as the single most important
vulnerability, a considerably greater number than any other element of the
drinking water system. Their explanations most often related to the
accessibility of distribution systems at numerous points. One expert, for
example, cited the difficulty of preventing the introduction of a
contaminant into a distribution system from inside a public building.
Another expert noted that since the water in a distribution system has
already been treated and is in the final stages of being transferred to
consumers, the distribution of a chemical, biological, or radiological
agent
Executive Summary
in such a manner could be difficult to detect until it is too late to
reverse any harm done.1
Several other components, though not considered as critical as the
distribution system, were still the subject of concern. Nearly half the
experts (20 of 43) identified source water as among drinking water
systems' top vulnerabilities. One expert noted, for example, that "because
of the vast areas covered by watersheds and reservoirs, it is difficult to
maintain security and prevent intentional or accidental releases of
materials that could have an adverse impact on water quality." Yet some
experts cited factors that mitigate the risks associated with source
water, including (1) that source water typically involves a large volume
of water, which in many cases could dilute the potency of contaminants;
(2) the length of time (days or even weeks) that it typically takes for
source water to reach consumers; and (3) that source water will go through
a treatment process in which many contaminants are removed. In addition,
EPA pointed out that as source water goes through the treatment process,
many contaminants are removed.
Also cited as a vulnerability were the sophisticated computer systems that
drinking water utilities have come to rely upon to manage key functions.
These Supervisory Control and Data Acquisition (SCADA) systems allow
operators to monitor and control processes throughout their drinking water
systems. Although SCADA systems have improved water utilities' efficiency
and reduced costs, almost half of the experts on GAO's panel (19 of 43)
identified them as among these utilities' top vulnerabilities. Finally, 13
of the 43 experts identified treatment chemicals, particularly chlorine
used for disinfection, as among utilities' top vulnerabilities. Experts
cited the inherent danger of storing large cylinders of a chemical on
site, noting that their destruction could release toxic gases in densely
populated areas. Some noted, however, that this risk has been alleviated
by utilities that have chosen to use the more stable liquid form of
chlorine instead of the more vulnerable compressed gas canisters that have
traditionally been used.
Experts also identified overarching issues that compromise the integrity
of multiple physical assets, or even the entire drinking water system.
Among these is the lack of redundancy among vital systems. Many drinking
water
1An EPA official noted, however, that distribution systems generally carry
disinfectant residuals that can counteract the potentially harmful effects
of contaminants.
Executive Summary
systems are "linear"-that is, they have single transmission lines leading
into the treatment facility, single pumping stations along the system, and
often employ a single computer operating system. They also depend on the
electric grid, transportation systems, and single sources of raw materials
(e.g., treatment chemicals). Many experts expressed concern that problems
at any of these "single points of failure" could render a system
inoperable unless redundant systems are in place. Experts also cited the
lack of sufficient information to understand the most significant threats
confronting individual utilities. According to the American Water Works
Association, assessments of the most credible threats facing a utility
should be based on knowledge of the "threat profile" in its specific area,
including information about past events that could shed light on future
risks. Experts noted, however, that such information has been difficult
for utilities to obtain. One expert suggested that the intelligence
community needs to develop better threat information and share it with the
water sector.
Allocation and Distribution of Federal Funds
Many drinking water utilities have been financing at least some of their
security upgrades by passing along the costs to their customers through
rate increases. Given the cost of these upgrades, however, drinking water
industry representatives have also sought federal assistance. GAO asked
its expert panel to comment on the factors that should be considered in
allocating federal funds. Specifically, GAO asked the experts to comment
on the following:
o Appropriate use of vulnerability assessment information. About 90
percent of the experts (39 of 43) strongly agreed or somewhat agreed that
funds should be allocated on the basis of vulnerability assessment
information, with some citing the vulnerability assessments (VA) required
by the Bioterrorism Act as the best available source of this information.
Several experts, however, pointed to a number of complicating factors.
Perhaps the most significant constraint is the Bioterrorism Act's
provision precluding the disclosure of any information that is "derived"
from vulnerability assessments submitted to EPA. It is important to
protect sensitive information about each utility's vulnerabilities from
individuals who may then use the information to harm the utility. The law
specifies that only individuals designated by the EPA Administrator may
have access to the assessments and related information. Yet even those
individuals would face constraints in using the information. They would
have difficulty, for example, in citing vulnerability assessments to
support decisions on
Executive Summary
allocating security-related funds among utilities, as well as decisions
concerning research priorities and guidance documents. Others cited an
inherent dilemma affecting any effort to set priorities for funding
decisions based on the greatest risk-whatever does not receive attention
becomes the best target.
o Criteria to help determine which utilities should receive funding
priority. According to 93 percent of the experts (40 of 43), utilities
serving high-density population areas should receive a high or highest
priority in funding (55 percent deemed this criterion as the highest
priority). Most shared the view of one expert, who noted that directing
limited resources to protect the greatest number of people is a common
factor when prioritizing funding. Experts also assigned high priority to
utilities serving critical assets, such as national icons representing the
American image, military bases, and key government, academic, and cultural
institutions. At the other end of the spectrum, only about 5 percent of
the experts (2 of 43) stated that utilities serving rural or isolated
populations should receive a high or highest priority for federal funding.
Generally, these panelists commented that such facilities are least able
to afford security enhancements and are therefore in greatest need of
federal support. Importantly, the relatively small percentage of experts
advocating priority for smaller systems may not fully reflect the concern
among many of the experts for the safety of these utilities. For example,
several who supported higher priority for utilities serving highdensity
populations cautioned that while problems at a large utility will put more
people at risk, utilities serving small population areas may be more
vulnerable because of weaker treatment capabilities, fewer highly trained
operators, and more limited resources.
As for effective mechanisms for distributing federal funds, the expert
panelists viewed direct federal grants as most effective, with 86 percent
of the experts (37 of 43) indicating that this mechanism would be somewhat
or very effective in allocating federal funds. One expert cited EPA's
recent distribution of direct security-related grant funds to larger
systems to perform their VAs as a successful initiative. Also, 74 percent
cited a matching requirement for such grants as somewhat or very
effective. One expert pointed out that such a requirement would
effectively leverage limited federal dollars, thereby providing greater
incentive to participate. The Drinking Water State Revolving Fund received
somewhat less support, with a number of the experts cautioning that as a
funding mechanism, it is suited more for longer-term improvements than for
those requiring more immediate attention.
Executive Summary
Security-Enhancing Activities That Most Warrant Federal Support
When experts were asked to identify and set priorities for the
securityenhancing activities most deserving of federal support, their
responses generally fell into three broad categories:
o Enhancing Physical Security and Supporting Technological Improvements.
These activities fell into nine subcategories. Of these, the development
of "near real-time monitoring technologies," capable of providing near
real-time data for a wide array of potentially harmful water constituents,
received far more support for federal funding than any other
subcategory-over 93 percent of the experts (40 of 43) rated this
subcategory as deserving at least a high priority for federal funding.
More significantly, almost 70 percent (30 of 43) rated it highest
priority. These technologies were cited as critical in efforts to quickly
detect contamination events, minimize their impact, and restore systems
after an event has passed. The experts also voiced strong support for (1)
increasing laboratories' capacity to deal with spikes in demand caused by
chemical, biological, or radiological contamination of water supplies, and
(2) "hardening" the physical assets of drinking water facilities through
improvements such as adding or repairing fences, locks, lighting systems,
and cameras and other surveillance equipment. Some experts, however, cited
the limitations inherent in attempts to comprehensively harden a drinking
water facility's assets. They noted in particular that, unlike nuclear
power or chemical plants, a drinking water system's assets are spread over
large geographic areas, particularly the source water and distribution
systems.
o Improving Education and Training. Over 90 percent of the experts (39 of
43) indicated that improved technical training for security-related
personnel warrants at least a high priority for federal funding, with over
55 percent (24 of 43) indicating that it deserved highest priority. To a
lesser extent, experts supported general training for other utility
personnel to increase their awareness of security issues. The panelists
also underscored the importance of conducting regional simulation
exercises to test emergency response plans, with more than 88 percent (38
of 43) rating this as a high or highest priority for federal funding. Such
exercises are intended to provide utility and other personnel with the
training and experience needed both to perform their individual roles in
an emergency, and to coordinate these roles with other responders.
Finally, about half the experts assigned at least a high priority to
supporting multidisciplinary consulting teams ("Red Teams"), comprising
individuals with a wide array of backgrounds, to provide independent
analyses of utilities' vulnerabilities.
Executive Summary
o Strengthening Relationships between Utilities and Other Key
Organizations. Experts cited the need to improve cooperation and
coordination between drinking water utilities and certain other
organizations as key to improving utilities' security. Among the
organizations most often identified as critical to this effort are public
health and law enforcement agencies, which have data that can help
utilities better understand their vulnerabilities and respond to
emergencies. In addition, the experts reported it is valuable for
utilities to develop mutual aid arrangements with neighboring utilities.
Such arrangements sometimes include, for example, the sharing of back-up
power systems or other critical equipment. One expert described an
arrangement in the San Francisco Bay Area-the Bay Area Security
Information Collaborative (BASIC). The collaborative's eight utilities
meet regularly to address security-related topics. Finally, over 90
percent of the experts (39 of 43) rated the development of common
protocols among drinking water utilities to monitor drinking water threats
as warranting a high or highest priority for federal funding. Drinking
water utilities vary widely in how they perceive threats and detect
contamination, in large part because few common protocols exist that would
help promote a more consistent approach toward these critical functions.
Some experts noted in particular the need for protocols to guide the
identification, sampling, and analysis of contaminants.
Making Key Security Decisions in the Face of Great Uncertainty
EPA has identified improved drinking water security as an important
national goal, and has stated in its Strategic Plan on Homeland Security
that as funds are appropriated, federal resources will be available to
help achieve this goal. Yet key judgments about who should receive
priority for federal resources, and how those funds should be spent, will
have to be made in the face of great uncertainty about the likely target
of an attack, the nature of an attack (whether physical, cyber, chemical,
biological, or radiological), and its timing. The experts on GAO's panel
have had to consider these uncertainties in deriving their own judgments
about these issues. Their judgments, while not unanimous on all matters,
suggested a high degree of consensus on a number of key issues.
GAO recognizes that sensitive funding decisions ultimately must take into
account political, equity, and other considerations. It also believes such
decisions should consider the judgments of the nation's most experienced
individuals on these matters, such as those included on its panel. It is
in this context that GAO offers the results presented in this report as
information
Executive Summary
for Congress and the Administration to consider as they seek the best way
to use limited financial resources to reduce the threat to the nation's
drinking water supply.
Recommendation for GAO recommends that, as EPA refines its efforts to
help drinking water utilities reduce their vulnerability to terrorist
attacks, the EPA
Executive Action Administrator consider the information in this report to
help determine: how best to allocate security-related federal funds among
drinking water utilities, which methods should be used to distribute the
funds, and what specific security-enhancing activities should be
supported.
Agency Comments We provided EPA with a draft of this report for review and
comment. EPA did not submit a formal letter but did provide comments from
officials in its Office of Water and its Office of Homeland Security. The
comments from the Office of Water said that the report's results were
"useful and well thought out." EPA's Office of Homeland Security said that
the report "demonstrates a well conceived and executed project," and that
"a number of the issues raised in the document will be useful to the
agency as it moves forward in the drinking water security program." Both
offices also offered specific technical comments and suggestions, which
have been incorporated.
Chapter 1
Introduction
Drinking water utilities across the country have long been recognized as
being potentially vulnerable to terrorism of various types, including
physical disruption, bioterrorism, chemical contamination, and cyber
attacks. Damage or destruction by such a terrorist attack could disrupt
not only the availability of safe drinking water to consumers, but also
the delivery of vital services that depend on these water supplies, such
as fire suppression.
These concerns were greatly amplified by the September 11, 2001, attacks
on the World Trade Center and the Pentagon. They were further amplified in
ensuing months when training manuals were discovered in Afghanistan
detailing how terrorist trainees could support attacks on drinking water
systems.
Key Components of a Drinking water systems vary by size and other factors
but, as illustrated in figure 2, most typically include a supply source,
treatment facility, and
Typical Drinking Water distribution system.
System
Chapter 1 Introduction
systems, particularly larger systems, rely on surface water such as lakes,
rivers, and streams.
Water treatment generally uses filtration, flocculation, sedimentation,
and other processes to remove impurities and harmful agents, and
disinfection processes (such as chlorination) to eliminate biological
contaminants. Chemicals used in these processes, most notably chlorine,
are often stored on site.
The distribution system comprises several components, such as water
towers, piping grids, and pumps that deliver treated water from treatment
systems to consumers. A key feature of most distribution systems is their
size: Particularly among larger utilities, distribution systems may have
many thousands of miles of pipes.
The Nation's Drinking Nationwide, there are more than 160,000 public water
systems that
individually serve from as few as 25 people to 1 million people or more.
AsWater Systems and the figure 3 illustrates, nearly 133,000 of these
water systems serve 500 orPopulations They fewer people. Only 466 systems
serve more than 100,000 people each, but Serve these systems, located
primarily in urban areas, account for nearly half of
the total population served.
Figure 3: Number of Drinking Water Systems That Serve Various Populations
Source: GAO.
Chapter 1 Introduction
Government and Industry Have Recently Sought to Improve Security
Most drinking water systems long ago developed and maintained emergency
preparedness plans that specified how to notify the public in cases of
emergency, and how to coordinate an emergency response with law
enforcement and other emergency response officials. These plans, however,
paid little attention to the kinds of threats posed by international
terrorist organizations. Rather, they were generally oriented toward
responding to natural disasters and, in some cases, domestic threats such
as vandalism.
Both government and industry officials took a number of steps to broaden
emergency planning in the 1990s. In 1996, the President issued Executive
Order 13010, which listed water supply as one of eight national
infrastructures vital to the security of the United States. In 1997, the
President's Commission on Critical Infrastructure Protection, also
established by executive order, issued a report on the vulnerabilities of
the eight categories of infrastructure and strategies for protecting them.
The report identified three attributes crucial to water supply users:
Water must be available on demand, it must be delivered at sufficient
pressure, and it must be safe for use.1 It warned that susceptibility to
contamination and the loss of flow or pressure can be caused by extensive
water main breaks, the destruction of pumps, or the disruption of power
supplies, and cited these as major vulnerabilities to the nation's water
supply systems.
In response to the report's findings, the President issued Presidential
Decision Directive (PDD) 63 on critical infrastructure protection in 1998.
This directive established a public-private partnership to put in place
prevention, response, and recovery measures that would augment the
security of the nation's critical infrastructure components against
criminal or terrorist attacks. The directive designated the Environmental
Protection Agency (EPA) as the lead federal agency to work with both
public and private organizations to protect the nation's water
infrastructure through the development of emergency preparedness
strategies. The agency, in turn, appointed the Association of Metropolitan
Water Agencies, a nonprofit organization representing the nation's largest
utilities, to coordinate the water industry's role in emergency
preparedness.
1The President's Commission on Critical Infrastructure Protection,
Critical Foundations: Protecting America's Infrastructures, October 1997.
Chapter 1 Introduction
Initially, this public-private partnership focused on the several hundred
community water systems that each served more than 100,000 persons; the
partnership was broadened in 2001 to include systems serving more than
3,300 people. Moreover, as was the case with other infrastructure sectors,
PDD-63 focused primarily on threats to cyber security. Specifically, the
directive established a goal to develop, within five years, a Water
Information Sharing and Analysis Center (Water ISAC). The intent of the
Water ISAC is, among other things, to facilitate the dissemination of
alerts to drinking water and wastewater utilities about threats to their
systems, to analyze incident information, and to serve as a secure source
of sensitive information.
Efforts to Further Improve Security after the September 11 Attacks
Efforts to improve protection of drinking water infrastructure were
broadened and accelerated after the September 11 attacks. In particular,
the partnership accelerated efforts to develop the Water ISAC, which
became operational in December 2002. EPA and the drinking water industry
also launched efforts to develop guidance, tools, and training programs to
assist utilities in identifying their systems' vulnerabilities. As a major
step in this regard, EPA supported the American Water Works Association
Research Foundation and the Sandia National Laboratories to develop a
vulnerability assessment (VA) methodology and training primarily for the
largest water systems. EPA awarded approximately $51 million in fiscal
year 2002 for water security grants to help these water systems complete
vulnerability assessments.
These efforts to better understand drinking water systems' vulnerabilities
were given a significant boost when the President signed the Public Health
Security and Bioterrorism Preparedness and Response Act in June 2002.2
Among other things, title IV of the Bioterrorism Act amended the Safe
Drinking Water Act to require each community water system serving more
than 3,300 individuals to conduct "an assessment of the vulnerability of
its system to a terrorist attack or other intentional acts intended to
substantially disrupt the ability of the system to provide a safe and
reliable supply of drinking water." As illustrated in table 1, the act
phased in this requirement according to system size, requiring
vulnerability assessments for all systems serving populations greater than
3,300 to be completed by June 30, 2004.
2Pub. L. No. 107-188, 116 Stat. 594 (2002) ("Bioterrorism Act").
Chapter 1 Introduction
Table 1: Vulnerability Assessment Completion Deadlines
System size (based on population Vulnerability assessment completion
served) deadline
100,000 or more March 31, 2003
50,000 to 99,999 December 31, 2003
3,301 to 49,999 June 30, 2004
Source: Bioterrorism Act, S 401(a)(2).
EPA guidance calls for these assessments to include: a characterization of
the water system; the identification of possible consequences of
malevolent acts; the critical assets subject to malevolent acts; an
assessment of the threat of malevolent acts; an evaluation of
countermeasures; and a plan for risk reduction. The Bioterrorism Act also
requires each community water system serving more than 3,300 individuals
to prepare or revise an emergency response plan incorporating the results
of the VA no later than 6 months after completing the assessment. In
addition, it directed EPA to provide guidance to smaller systems on how to
conduct vulnerability assessments, prepare emergency response plans, and
address threats.
Potentially Larger Federal Financial Commitment Sought in Future Years
While significant federal funds have been committed to assist utilities in
developing vulnerability assessments and emergency response plans, the
likelihood exists that Congress and the Administration will be asked to
provide much larger sums to go beyond planning for upgrading drinking
water security to the actual implementation of security upgrades. By most
accounts, it will cost billions of dollars to upgrade security for
drinking water utilities. The American Water Works Association, for
example, estimates that it will cost $1.6 billion for initial security
upgrades at all drinking water utilities.
Objectives, Scope, and As requested in a June 9, 2003, letter to the
Comptroller General from the Chairman and Ranking Minority Member of the
Senate Committee on
Methodology Environment and Public Works, this report identifies experts'
views on the following questions:
o What are the key security-related vulnerabilities affecting the
nation's drinking water systems?
Chapter 1 Introduction
o What are the criteria that should be used to determine how federal
funds are allocated among recipients to improve drinking water security,
and how should the funds be distributed?
o What specific activities should the federal government support to
improve drinking water security?
To obtain information on these three questions, we conducted a threephase
Web-based survey of 43 experts on drinking water security. We identified
these experts from a list of more than 50 widely recognized experts in one
or more key aspects of drinking water security. In compiling this initial
list, we also sought to achieve balance in terms of area of expertise
(i.e., state and local emergency response, engineering, epidemiology,
public policy, security and defense, drinking water treatment, risk
assessment and modeling, law enforcement, water infrastructure, resource
economics, bioterrorism, public health, and emergency and crisis
management).
In addition, we attempted to achieve participation by experts from (1) key
federal organizations (e.g., Argonne National Laboratory, Centers for
Disease Control and Prevention, Department of Defense, Department of the
Interior's Bureau of Reclamation, Environmental Protection Agency, and
Federal Bureau of Investigation; (2) key state and local agencies,
including health departments and environmental protection departments; and
(3) key industry and nonprofit organizations such as the American Water
Works Association (AWWA), RAND Corporation, Natural Resources Defense
Council (NRDC), and National Rural Water Association (NRWA); and (4) water
utilities serving populations of varying sizes. Of the 50 experts we
contacted, 43 agreed to participate and complete all three phases of our
survey. A list of the 43 participants in this study is included in
appendix I.
To obtain information from the expert panel, we employed a modified
version of the Delphi method. The Delphi method is a systematic process
for obtaining individuals' views and seeking consensus among them, if
possible, on a question or problem of interest. Since first developed by
the RAND Corporation in the 1950s, the Delphi method has generally been
implemented using face-to-face group discussions. For this study, however,
we administered the method through the Internet. We used this approach, in
part, to eliminate the potential bias associated with group discussions.
These biasing effects include the dominance of individuals and group
pressure for conformity. Moreover, by creating a virtual panel, we were
Chapter 1 Introduction
able to include many more experts than possible with a live panel, which
allowed us to obtain a broad range of opinions.
For each phase in the Delphi method, we posted a questionnaire on GAO's
survey Web site addressing the issues of our study. Panel members were
notified of the availability of the questionnaire with an e-mail message.
The e-mail message contained a unique user name and password that allowed
each respondent to log on and fill out a questionnaire but did not allow
respondents access to the questionnaires of others.
In the first questionnaire, we asked several broad questions, such as,
"What strategies or methods should the federal government consider for
allocating funds to water utilities (or other relevant entities) so as to
ensure that allocation achieves the greatest mitigation of risk per
dollar?" We pretested these questions with officials from the water
utility industry, a nonprofit research group, and academe. Participants
were invited to provide detailed narrative explanations for their
responses.
In the case of two key questions, we sought to identify both additional
detail and the degree to which consensus could be achieved among the
experts on our panel. We used experts' responses to phase 1 questions to
develop more detailed questions for phase 2 about specific actions or
strategies regarding two overall issues: how federal funds could best be
allocated among potential recipients to achieve the most security
improvements per dollar, and which specific activities are most deserving
of federal support. This second questionnaire included closed-ended
questions that allowed panelists to rate the relative priority or
effectiveness of these activities. It also provided experts with the
opportunity to comment on their ratings.
During the third phase of the Delphi process, we provided the aggregated
results from the ratings made in the second questionnaire. We also
provided panel members with the individual ratings they had made in
response to each question. We then invited panel members to use this
information as a basis for changing their answers if they desired.
In addition to the information obtained from our expert panel, we obtained
documentation from representatives of professional organizations, such as
the National Academy of Sciences, RAND Corporation, American Water Works
Association Research Foundation, and Association of Metropolitan Water
Agencies. We also held several interviews with officials at EPA on the
agency's drinking water security programs. During our interviews, we
Chapter 1 Introduction
asked officials to provide information on program operations, policies,
guidance, and funding levels. We also received training on the
Vulnerability Self Assessment Tool supported by the Association of
Metropolitan Sewerage Agencies, and attended specialized conferences
addressing drinking water security by the Water Environment Federation and
other organizations.
We conducted our work from July 2002 through August 2003 in accordance
with generally accepted government auditing standards.
Chapter 2
Experts Identified Key Vulnerabilities That Could Compromise Drinking Water
Systems' Security
Our panel of experts identified several key physical assets of drinking
water systems as the most vulnerable to intentional attack. In general,
their observations were similar to those of public and private
organizations that have assessed the vulnerability of these systems to
terrorist attacks, including the National Academy of Sciences, Sandia
National Laboratories, and key industry associations. In particular,
nearly 75 percent of the experts (32 of 43) identified the distribution
system or its components as among the top vulnerabilities of drinking
water systems.
In addition to identifying systems' physical assets, experts also
identified overarching issues compromising how well these assets are
protected. Chief among these issues are (1) a lack of redundancy in vital
systems, which increases the likelihood that an attack could render a
system inoperable; and (2) the difficulty many systems face in
understanding the nature of the threats to which they are exposed.
Vulnerability of As illustrated in figure 4, when asked to identify what
they believed to be the top vulnerabilities of drinking water utilities,
the four physical assets
Physical Assets most frequently identified by the panel were: (1) the
distribution system, (2) source water supplies, (3) Supervisory Control
and Data Acquisition (SCADA) and other information systems, and (4)
chemicals stored on site that are used to treat source water.
Chapter 2
Experts Identified Key Vulnerabilities That
Could Compromise Drinking Water Systems'
Security
Figure 4: Key Vulnerabilities Identified As Compromising Drinking Water
Systems' Security
Experts Identified Distribution Systems as Most Vulnerable
The distribution system delivers drinking water primarily through a
network of underground pipes to homes, businesses, and other customers.
While the distribution systems of small drinking water utilities may be
relatively simple, larger systems serving major metropolitan areas can be
extremely complex. One such system, for example, measures water use
through 670,000 metered service connections, and distributes treated water
through nearly 7,100 miles of water mains that range from 2 inches to 10
feet in diameter. In addition to these pipelines and connections, other
key distribution system components typically include numerous pumping
stations, treated water storage tanks, and fire hydrants.
Nearly 75 percent, or 32 of 43 of the experts on our panel, named one or
more components of the distribution system as among the top
vulnerabilities of drinking water systems. In fact, 12 of the 32 experts
Chapter 2
Experts Identified Key Vulnerabilities That
Could Compromise Drinking Water Systems'
Security
identified distribution systems as the most critical vulnerability, a
considerably greater number than any other system component. The
explanations they offered most often related to the accessibility of
distribution systems at numerous points. One expert, for example, cited
the difficulty in preventing the introduction of a contaminant into the
distribution system from inside a building "regardless of how much time,
money, or effort we spend protecting public facilities." Experts also
noted that since the water in the distribution system has already been
treated and is in the final stages of being transferred to the consumer,
the distribution of a chemical, biological, or radiological agent in such
a manner would be virtually undetectable until it has affected consumers.
An EPA official added, however, that distribution systems generally carry
disinfectant residuals that can counteract the potentially harmful effects
of contaminants. This official further stated that routine monitoring
performed in drinking water systems might provide some advance warning.
While research on the fate and transport of contaminants within water
treatment plants and distribution systems is under way, according to one
expert, limited technologies are readily available that can detect a wide
range of contaminants once treated water is released through the
distribution system for public use.
Source Water Nearly half the experts (20 of 43) identified source water as
among drinking water systems' top vulnerabilities. Drinking water may come
from surface water, groundwater, or both. The water cycle begins with
rainwater and snowmelt that collect in lakes and rivers and that, in many
cases, interact with groundwater. Large urban water supply systems tend to
rely on surface water sources (rivers, lakes, and reservoirs), while
smaller systems tend to rely more heavily on groundwater.
One expert raised concerns about the inherent challenge in protecting
source waters, noting, "Because of the vast areas covered by watersheds
and reservoirs, it is difficult to maintain security and prevent
intentional or accidental releases of materials that could have an adverse
impact on water quality." Other experts raised additional concerns about
the vulnerability of water intake transmission lines, which regulate the
transfer of water supplies to the systems' treatment plants.
Panel experts and others, however, have stated that concerns over source
water contamination are mitigated somewhat by a number of factors. First,
a large volume of water generally exists at the source, which in many
cases can dilute the potency of agents introduced at this stage of the
drinking
Chapter 2
Experts Identified Key Vulnerabilities That
Could Compromise Drinking Water Systems'
Security
water production process. Second, unlike treated water in the distribution
system, it generally takes many days before source water reaches the
consumer, making it more likely that a contamination problem at this early
stage of the drinking water production process can be detected or treated
before consumers are affected. One utility official noted, for example,
that his water system's surface water supplies travel hundreds of miles
before reaching the treatment plant. Water that was contaminated at the
source would take between 10 days and 6 months to reach the treatment
plant, depending on the source, providing ample opportunity for detection
and adjustments to protect public health.
SCADA Systems To improve their efficiency and reduce operating costs,
drinking water utilities (particularly larger utilities) have come to rely
increasingly on sophisticated computer systems to manage their facilities'
key functions. These Supervisory Control and Data Acquisition (SCADA)
systems allow utility operators to monitor and control processes
throughout their systems, even at remote facilities. SCADA systems
communicate with other control facilities and provide the necessary data
to ensure that the right chemicals are mixed in the right amounts for
treatment processes, and that water pressure and flow are at proper
levels. SCADA systems may also monitor activity along water transmission
pipelines, detecting breaks or pressure loss.
While SCADA systems help utilities manage their operations, they can
create an additional opportunity for sabotage. Almost half of the experts
on our panel (19 of 43) identified SCADA and other information systems as
being among the top vulnerabilities of drinking water systems (although
only one expert ranked it as the top vulnerability). Experts' concerns
include cyber attacks on SCADA systems from a remote location, which
could, for example, release harmful amounts of water treatment chemicals
(such as chlorine) into treated water.
Chapter 2
Experts Identified Key Vulnerabilities That
Could Compromise Drinking Water Systems'
Security
Treatment Chemicals The types and amounts of treatment chemicals applied
by a drinking water facility to its influent varies, depending on the type
of source water (for example, surface water or groundwater) as well as its
quality. Because surface water systems are exposed to direct wet-weather
runoff and to atmospheric forces, they generally require more treatment
under federal and state regulations than do groundwater systems.1
Water suppliers use a variety of treatment processes to remove
contaminants from drinking water. The most commonly used treatment
processes for surface water include filtration to remove particles such as
clays, silts, and microorganisms; flocculation and sedimentation to
consolidate small particles into larger particles that can be more easily
removed from the water; and disinfection to eliminate bacteria and other
microbiological contaminants.
Treatment chemicals are used in some of these processes. The disinfection
process is particularly noteworthy in this regard; chlorine, chloramines,
or chlorine dioxide not only are used at the treatment plant, but also are
frequently present in some form in the pipes that distribute water to
homes and businesses.
Thirteen of the 43 experts identified treatment chemicals as among the top
vulnerabilities of drinking water systems, second only to the distribution
system. Experts commented that it was inherently dangerous to use and
store large cylinders of gaseous chlorine, noting that the destruction of
these storage containers could release toxic chlorine gas in densely
populated areas. Some of these experts noted, however, that this risk is
being alleviated as utilities increasingly use the more stable liquid form
of chlorine instead of the more vulnerable large compressed-gas chlorine
canisters that have traditionally been used. In addition to the risks of
chemical sabotage at the treatment facility, one expert cited the risk of
using tainted treatment chemicals at the facility. According to another
expert, "If these treatment chemicals have been purposely contaminated . .
. prior to delivery, every precautionary measure taken by the water system
has been bypassed."
1A discussion of the influence of these factors on treatment is available
in the preamble in both the Surface Water Treatment Rule and the Stage I
Disinfectants/Disinfection Byproducts Rule.
Chapter 2
Experts Identified Key Vulnerabilities That
Could Compromise Drinking Water Systems'
Security
Overarching Issues In addition to the vulnerabilities associated with
specific water system
components, experts identified several overarching issues thatAffecting
Drinking compromise the integrity of physical assets and the drinking
water systemWater Systems' in its entirety. Chief among these issues are
(1) the lack of redundancy Security among vital systems, and (2) the
difficulty many operators face due to a
lack of information on the most serious threats to which their systems
might be exposed.
Lack of Redundancy among Vital Systems
Drinking water systems are generally "linear" in nature in that they have
single transmission lines leading into the treatment facility, single
pumping stations along the system, and a single computer operating system.
Furthermore, drinking water systems may rely on outside sources of power
and communications, and depend on the transportation sector for the
delivery of supplies, often from a limited number of suppliers. If any of
these external sources were impaired or destroyed, the entire system could
be compromised. Under these circumstances, any "single point of failure"
could render a system inoperable unless there are redundant systems in
place.
Several experts reflected concerns relating to a single point of failure
as a vulnerability. For example, according to one expert, the destruction
of a single physical component of the system, such as a single water
transmission line into the treatment facility, could render the entire
system inoperable. Moreover, she noted, a system that depends on pumps can
be completely put out of service if its electrical supply were
interrupted. Echoing this point, another expert commented, "Experience
with Y2K planning efforts revealed one of the critical interdependencies
nearly all water utilities have is with the electrical power supply
system. Disruption of power supply could have significant impacts on
source, treatment and distribution systems."2
According to one expert, efforts are needed to add redundancy to drinking
water systems and to mitigate systems' near-total reliance on power
suppliers, communications systems, and the transportation sector. However,
such efforts to duplicate major system components would be expensive and
could conflict with the systems' goals of controlling rate
2These comments, made prior to the electric supply disruption of August
2003, were vividly illustrated when that power outage severely disrupted
the water supplies of several cities.
Chapter 2
Experts Identified Key Vulnerabilities That
Could Compromise Drinking Water Systems'
Security
increases. To address the problem, some experts advocated the creation of
utility consortia, such as the Bay Area Security Information Collaborative
(BASIC) and the Mutual Aid Disaster Intervention Response Teams (MADIRT),
through which regional utilities share resources in the event of a
disaster.
Insufficient Information to Understand the Most Significant Threats
A number of experts commented that it is impossible to accurately identify
a utility's most significant vulnerabilities unless the utility has
reliable intelligence regarding its most significant threats. Threats
include the type of adversary (a casual vandal, an anonymous hacker, a
disgruntled employee, or a dedicated terrorist) as well as the mode of
attack (physical, psychological, chemical, biological, or radiological).
According to the American Water Works Association, a utility's assessment
of its most credible threats should be based on knowledge of the threat
profile in its specific area, including such information as past events,
that could shed light on future risks. These assessments often require
information from outside sources, such as local law enforcement officials.
Many experts on our panel noted, however, that such information has not
been easy for utilities to obtain. The following examples illustrate some
of the difficulties utilities have regarding threats:
o According to one expert, "The utility community has very little
specific and useful information on the threat posed to this industry. This
represents a real vulnerability since it makes it harder to judge where
resources might do the most good." Furthermore, "an ongoing working
relationship with groups (mostly federal) that do this type of analysis
could prove extremely valuable in determining how to allocate the limited
resources available."
o Utilities may be preoccupied with unsubstantiated threats, according to
another expert. She noted, "There are many very vulnerable areas, but the
terrorists may not be technically able to target them, or they may not be
interested."
o Another expert stated that utilities need to better understand "how the
threats may . . . exploit utility operations and infrastructure," through
such things as simulation exercises.
Chapter 2
Experts Identified Key Vulnerabilities That
Could Compromise Drinking Water Systems'
Security
o One expert suggested that the intelligence community provide better
threat information and share it with the water sector through the Water
ISAC.
Since the consequences associated with various potential threats are
markedly different, EPA guidance suggests that the threats be analyzed in
the system's vulnerability assessments.3 Some vulnerability assessment
methodologies refer to the threats selected for consideration as a Design
Basis Threat. Because there is no single Design Basis Threat4 for all
water systems in the United States, water systems often have a difficult
time identifying their unique threat profile. As a result, EPA developed a
Baseline Threat Information document for systems serving populations
greater than 3,300 to help assess the most likely threats to their
systems.
3Environmental Protection Agency, Vulnerability Assessment Fact Sheet, EPA
816-F-02-025, November 2002, available on the Web at
http://www.epa.gov/ogwdw000/security/va_fact_sheet_12-19.pdf.
4Design Basis Threat: The threat serves as the basis for the design of
countermeasures as well as the benchmark against which vulnerabilities are
assessed.
Chapter 3
Experts' Views on the Allocation and Distribution of Federal Funds
Many drinking water utilities have been financing at least some of their
security upgrades by passing along the costs to their customers through
rate increases. Given the cost of these upgrades, however, the utility
industry is also asking that the taxpayer shoulder some of the burden
through the congressional appropriations process. Should Congress and the
Administration agree to this request, they will need to address key issues
concerning who should receive the funds and how they should be
distributed. With this in mind, we asked our panel of experts to focus on
several key questions: (1) To what extent should utilities' vulnerability
and risk assessment information be considered in making allocation
decisions? (2) What types of utilities should receive funding priority?
and (3) What are the most effective mechanisms for directing these funds
to recipients? Overall, we found a high degree of consensus on the
following:
o Vulnerability assessment may be a useful tool in determining which
utilities receive priority for federal funds to improve security. Several
factors, however, complicate the government's ability to use a primary
source of this information-the vulnerability assessments (VA) required of
utilities under the Bioterrorism Act. Among the factors, the act prohibits
disclosure of information derived from these assessments submitted to EPA.
o Almost all of the experts gave utilities serving high-density
populations a high or highest funding priority. Utilities serving critical
assets (such as military bases and other sensitive government facilities,
national icons, and key cultural or academic institutions) were also
recommended as high-priority recipients, while relatively few experts
recommended a high or highest priority for utilities serving rural or
isolated populations.
o Direct federal grants are the most favored funding mechanism, with many
experts indicating that such grants should include a requirement for
matching funds from the recipient. Relatively fewer experts recommended
the use of the Drinking Water State Revolving Fund, particularly for
upgrades to be implemented in the near term.
Chapter 3
Experts' Views on the Allocation and
Distribution of Federal Funds
Strong Agreement That Allocation Decisions Should Consider a Utility's
Vulnerability Assessment
As noted in chapter 1, the Bioterrorism Act requires that vulnerability
assessments be prepared by all community water systems serving more than
3,300 individuals. EPA guidance on preparing these assessments states that
the assessments should (1) characterize the water system, including its
mission and objectives; (2) identify and rank the possible consequences of
malevolent acts; (3) determine the critical assets subject to malevolent
acts; (4) assess the threat of malevolent acts; (5) evaluate existing
countermeasures; and (6) analyze risk and develop a plan for reducing risk
and addressing critical priorities first.
In considering whether it is appropriate to use vulnerability and risk
assessment information when making federal funding decisions, about 90
percent of the experts on our panel (39 of 43) strongly agreed or somewhat
agreed that funds should be allocated on the basis of VA information. Some
experts cited the vulnerability assessments required by the Bioterrorism
Act as the best available information about the current condition of our
security infrastructure for drinking water (see fig. 5).
Chapter 3
Experts' Views on the Allocation and
Distribution of Federal Funds
Figure 5: Experts' Views on Whether Federal Funds Should Be Allocated
Based on Vulnerability Assessment Information
It may not be a straightforward matter, however, to use this information
in making such decisions. Several experts pointed to a number of
complicating factors. One pointed out that "vulnerability assessment (VA)
tools were not set up for the purpose of identifying and prioritizing
capital improvement needs for EPA or other federal agencies." He added,
"Using the VAs would require a high degree of interpretation and judgment
on someone's part . . ., using a tool that was not designed to clearly
delineate capital construction needs." Another expert noted similarly that
"since there is no written guidance for threat analysis, there will have
to be some method to rank relative threats among different areas." In
addition, one expert pointed out an inherent dilemma affecting any effort
to prioritize
Chapter 3
Experts' Views on the Allocation and
Distribution of Federal Funds
funding decisions based on the greatest risk-whatever does not receive
attention becomes the best target.1
In addition, a provision of the Bioterrorism Act precludes disclosing all
information "derived" from the vulnerability assessments submitted to EPA.
The provision's intent was to protect sensitive information about
utilities' vulnerabilities from falling into the hands of individuals who
seek to harm the utility. The act therefore specifies that only
individuals designated by the EPA Administrator may have access to the
copies of the VA and information contained in or derived from it. It
further specifies that the information must remain protected at all times.
Thus, while some EPA officials may have access to the information, the
requirement limits how the agency may use that information. EPA would have
difficulty, for example, in citing vulnerability assessment findings to
support decisions or recommendations on allocating security-related funds
among utilities, as well as decisions concerning research priorities or
guidance documents.
To compensate somewhat for these limitations, the American Water Works
Association Research Foundation has initiated a project in which
consultants and trainers, who have conducted multiple assessments, are
seeking to identify lessons learned from the vulnerability assessments
done to date. According to EPA's draft Water Security Research and
Technical Support Implementation Plan, this project is designed to obtain
a more accurate picture of the major vulnerabilities that are generally
facing the nation's drinking water systems and to share that understanding
with interested parties.2 EPA and the Research Foundation plan to use the
results of this project to identify high priority needs and concerns that
could likely be best addressed by EPA, the research community, or both.
This project is scheduled for completion in mid-2004.
1Citing this reason, one expert suggested the addition of a "dual use"
criterion in which the funds spent would also fix some existing utility
deficiency, such as noncompliance with a drinking water standard.
2Environmental Protection Agency, Office of Water, Office of Research and
Development, Water Security Research and Technical Support Implementation
Plan, Preliminary Working Draft, July 2003.
Chapter 3
Experts' Views on the Allocation and
Distribution of Federal Funds
Key Criteria to Help The experts identified several characteristics of
utilities that should be
used to set funding priorities. The most frequently identified were
utilitiesDetermine Which (1) serving high-density populations; (2) serving
sensitive or critical assets, Utilities Should such as military bases,
academic institutions or icons of American culture; Receive Funding (3) in
proximity to population centers (whether they serve these population
centers or serve outlying areas); and (4) serving rural or
isolatedPriority populations, such as small systems with less
sophisticated water systems (see fig. 6).
Figure 6: Experts' Views on Which Types of Water Utilities Should Receive
Priority for Federal Funds
Utilities Serving High-Density Populations. Approximately 93 percent of
the experts (40 of 43) gave high or highest priority to funding utilities
serving high-density populations. As one expert commented, directing
Chapter 3
Experts' Views on the Allocation and
Distribution of Federal Funds
limited resources to protect the greatest number of people is a common
strategy when setting priorities. Most experts shared this view, including
one who noted the "population served would probably lead to economies of
scale-you can protect the most people by spending monies at the large
systems." This expert and others, however, though supportive of funding
priority for utilities serving high-density populations, cautioned that
while targeting high-density populations may be the most equitable to the
entire country, it might not allocate enough to small systems.
Utilities Serving Sensitive or Critical Assets. Seventy-seven percent of
the experts (33 of 43) indicated that utilities serving sensitive or
critical assets should receive a high or highest priority for federal
funding. Experts identified such utilities as those servicing national
icons that represent the American image, those serving military bases, or
those serving sensitive government, academic and cultural institutions. In
addition, according to one expert, utilities in areas typically receiving
extensive media coverage, or that serve venues where large groups gather,
may be of interest to terrorists.
Utilities in Proximity to Population Centers. Twenty-eight percent of the
experts (12 of 43) cited the proximity of a given utility to a major
population center as at least a high funding priority. While most
utilities close to population centers would be expected to serve the
population center in which they are located (hence, this third criterion
would overlap with the first criterion above-utilities serving
high-density populations), some experts pointed out that this is not
always the case. Exceptions cited include suburban utilities that may
serve communities or their major metropolitan areas. Several particularly
noted that the risks associated with an airborne release of chlorine gas
elevated their funding priority for this criterion.
Utilities Serving Rural or Isolated Populations. About 5 percent of the
experts (2 of 43) identified utilities serving rural or isolated
populations as at least a high priority for federal funding. Generally,
these panelists commented that such facilities are least able to afford
security enhancements, and therefore most need federal support. One
expert, for example, stated that in light of their financial constraints,
"smaller utilities do the cheapest thing possible, which means you do a
quick checklist and then forget about it." He added that because these
smaller systems do not have enough staff to do a comprehensive assessment,
they need funding to either hire additional staff or to contract for
outside expertise.
Chapter 3
Experts' Views on the Allocation and
Distribution of Federal Funds
Importantly, the relatively small percentage of experts supporting funding
for rural utilities may not fully reflect the concern many panel experts
have for the safety of these utilities. For example, several who supported
higher priority for utilities serving high-density populations cautioned
that, while problems at a large utility will put more people at risk,
utilities serving small population areas may be more vulnerable because of
weaker treatment capabilities, fewer highly trained operators, and more
limited resources. Another expert added that most waterborne disease
outbreaks have occurred in the systems of smaller utilities.
Funding Mechanisms We also asked the expert panel to comment on how
federal funds should be
distributed to recipients. Nearly 90 percent said that direct federal
grants toRecommended for utilities would be a somewhat or very effective
means of distributing funds Distributing Federal to support security
improvements. The experts also showed strong support Funds for grants in
which some type of match is required of recipients. Figure 7
shows their views on these and other funding mechanisms.
Chapter 3
Experts' Views on the Allocation and
Distribution of Federal Funds
Figure 7: Recommended Approaches for Distributing Federal Funds
Chapter 3
Experts' Views on the Allocation and
Distribution of Federal Funds
Direct Federal Grants Eighty-six percent of the experts (37 of 43)
indicated that direct federal grants to the utility would be somewhat or
very effective in allocating federal funds. Federal grants typically
provide funding for fixed or known periods for specific projects and often
have associated terms and conditions. One expert cited EPA's recent
efforts to quickly distribute security-related grant funds to systems
serving over 100,000 people (mentioned earlier in this chapter), noting,
"By far the most successful funding program I have seen to date was the
large water system Vulnerability Assessment Grant program directed through
the EPA."3
Many experts commented that direct grants could be particularly useful in
quickly addressing lower-cost and more obvious fixes, such as adding gates
and security cameras. Two others said that with some of these shorter-term
items addressed, it may then be appropriate to deal with more complex
issues that require longer-term fixes, such as new buildings and
securityoriented building design. Another expert added that the use of
direct EPA grants could help ensure proper use of the funds, noting,
"Direct EPA grants to water systems should be made available and should
carry a requirement to use Sandia-like methodologies and concepts," and
that "the use of [these tools] will lead water systems to develop
cost-effective risk reduction through effective physical systems, better
policies, procedures and training and through creative consequence
mitigation."
Matching Grants Many favoring direct grants were among those who said that
a matching requirement for such a grant would be desirable for
distributing future federal funds. Specifically, 74 percent of the experts
(32 of 43) said that federal grants with a matching requirement would be
somewhat or very effective in distributing federal funds. One expert
pointed out that such a requirement would effectively leverage limited
federal dollars. Another agreed, noting that such a cost-sharing approach
would offer "a big incentive" in getting utilities to devote their own
funds to enhance their security. The expert cautioned, however, that the
required match would
3As noted earlier in this report, these grants supported VAs, remediation
planning, and emergency plan development through August 2002. EPA issued
grant awards to over 400 publicly owned and privately owned community
water systems that regularly serve populations over 100,000. This program
was noncompetitive, and all eligible utilities that submitted completed
grant applications received awards. The value of each grant did not exceed
$115,000. An EPA official pointed out that higher dollar grant programs
might have additional administrative requirements.
Chapter 3
Experts' Views on the Allocation and
Distribution of Federal Funds
have to be low enough to make the grant attractive, suggesting a maximum
of 50 percent.
Another suggested a strategy to get the most out of a matching grant
program. One, for example, said that participating utilities should be
provided with some initial matching funds to get started, and that
additional funds would then be contingent upon how effective or creative
they were in using the first round of funding.
Funds Distributed by an Independent Agency
Sixty-five percent of the experts (28 of 43) indicated that it would be
somewhat or very effective to have federal funds distributed through an
independent agency. Experts generally characterized an independent agency
as, among other things, being independent of regulatory decision making,
and not bound by traditional points of view.
Several experts elaborated on the desirability of such an independent
entity to allocate security-related funds. One expert, for example,
favored moving the responsibility for allocating funds to a disinterested
third party-one with no infrastructure to support or hidden agenda but
instead with strong decision analysis and consensus building expertise.
Another expert suggested that federal funding be "leveraged with industry
funding through an organization like [the American Water Works Association
Research Foundation.]" The expert further stated that the use of an
organization like the Research Foundation is important because it has a
demonstrably effective two-way communication with the end users, namely
the U.S. water utility industries; the Research Foundation can adequately
represent the needs of industry to the research community as well as
inform the industry of important national-level research findings that
will influence their day-to-day operations. He indicated that
communication between the water utilities and such an independent agency
would be superior to communication between the utilities and EPA, noting,
"Although [EPA] is legitimately engaged in research, [it] is also
perceived as an agency with regulatory authority and is thus viewed
somewhat circumspectly by industry as a whole."
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Experts' Views on the Allocation and
Distribution of Federal Funds
Drinking Water State Revolving Fund
About 51 percent of the experts (22 of 43) indicated that the Drinking
Water State Revolving Fund (DWSRF) would be somewhat or very effective in
distributing federal funds. The DWSRF program provides federal grant funds
to states, which in turn allow the states to help public water systems in
their efforts to protect public health and ensure their compliance with
the Safe Drinking Water Act. States may use DWSRF funds to provide loans
to public water systems, and may reserve a portion of their grants to
finance other projects that protect sources of drinking water and enhance
the technical, financial, and managerial capacity of public water systems.
In particular, under EPA's November 2001 guidance, states may use DWSRF
assistance to help systems complete both vulnerability assessments, and
contingency and emergency response plans.4 Many types of securityrelated
infrastructure improvements to ensure security are also eligible for DWSRF
funding, as specified in the EPA guidance.
According to one expert who favored existing grant and loan programs like
the DWSRF for enhancing security, continuing to support the training and
assistance efforts of lead state agencies "is the most beneficial activity
the federal government could play to encourage water utilities across the
country to address security related issues in a comprehensive and
costeffective manner." Another shared this view, explaining that states
are wellpositioned to help manage the process, and that they "must approve
system upgrades anyway." This expert also suggested that by using the
stateadministered DWSRF, "states could track this information and report
it on a regular basis to EPA and Congress," thereby documenting what has
been accomplished and what still needs to be done.
One expert cautioned, however, that the DWSRF would be effective only if a
process were established that separated funding for security-related needs
from other infrastructure needs. Reflecting the concern expressed by many
others about the timeliness of distributing funds through the DWSRF, this
individual commented that the current DWSRF process is too bureaucratic
and requires too many hurdles for it to be an expeditious means for
providing funds.
4Environmental Protection Agency, Office of Water, Use of the Drinking
Water State Revolving Fund (DWSRF) to Implement Security Measures at
Public Water Systems, EPA 816-F-02-040, November 2001, available on the
Web from http://www.epa.gov/ogwdw000/dwsrf/security-fs.pdf.
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Experts' Views on the Allocation and
Distribution of Federal Funds
Tax-Based Incentives About 28 percent of the experts (12 of 43) reported
that tax-based incentives would be somewhat effective in encouraging water
utilities- specifically privately owned utilities-to invest in security
improvements. The inducements offered in these programs may include tax
credits, property tax exemptions or abatements, and sales and use tax
exemptions.
According to one expert, tax incentives could increase the efficiency of
dollars spent on water security, generating new ideas and approaches.
Furthermore, by offering additional funds for creative and cost-effective
solutions, these ideas could become best practices and shared with others.
Finally, he commented, "If allocations were phased and secondary funds
were based upon how well the first funds were spent, there would be
incentive to spend the first funds wisely." Another expert suggested that
the provision of financial or other tax incentives to utilities should be
contingent upon evidence that they have improved their security as defined
by a standard set of measurements.
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Activities Experts Identified As Most Deserving of Federal Support
When experts were asked to identify and rate the specific
securityenhancing activities most deserving of federal support, the
activities experts most frequently identified fell into three broad
categories:
o Physical and technological improvements. These improvements include
altering drinking water systems to improve physical security, and
conducting research and development on technologies to prevent, detect, or
respond to an attack. Experts most strongly supported near real-time
monitoring technologies, which they considered particularly useful in
quickly detecting contaminants in water that has left the treatment plant
for consumers.
o Education and training. This category includes, among other things,
supporting simulation exercises to provide responders with experience in
carrying out utilities' emergency response plans; specialized training of
utility personnel charged with security and general training to improve
the security awareness of their staffs; and multidisciplinary teams that
can provide independent analysis of utilities' security preparedness and
recommend security-related improvements.
o Strengthening working relationships between utilities and other public
agencies. This category includes strengthening relationships between water
utilities and other entities that may have key roles in an emergency
response (such as public health agencies, enforcement agencies, and
neighboring utilities). It also includes developing common protocols to
engender a consistent approach among utilities in detecting and properly
diagnosing threats, and testing local emergency response systems to ensure
that participating agencies coordinate their actions effectively.
We found that EPA has a number of initiatives that address many of these
activities, some of which are required by the Bioterrorism Act. In most
cases, however, the activities are in the planning stages, are limited in
scope, or are dependent on the availability of future appropriations.
Activities to Enhance Our panel of experts most frequently recommended
nine types of activities
to improve physical security and support technological improvements,
asPhysical Security and figure 8 shows. Of the nine types, the development
and implementation of Support Technological near real-time monitoring
technologies was rated by far the most important Improvements activity
warranting federal support, with many experts stating that this
Chapter 4
Activities Experts Identified As Most
Deserving of Federal Support
critical activity would probably not be implemented by many utilities
without some degree of federal support.
Figure 8: Activities Identified by Expert Panel to Enhance Physical
Security and Support Technological Improvements
Developing Near Real-Time Approximately 93 percent of the panel experts
(40 of 43) rated the Monitoring Technologies expansion of research and
development of near real-time monitoring Viewed As Highest Priority
technologies as having at least a high priority. These technologies were
cited as critical to helping drinking water systems detect and respond
quickly to threats or actual contamination events, to minimize the impact
of any contamination by facilitating a quick response, and to help in
restoring systems after an event. Significantly, almost 70 percent of the
experts (30 of 43) rated this activity as warranting the highest priority
for
Chapter 4
Activities Experts Identified As Most
Deserving of Federal Support
federal funding-far surpassing the rating of any other category. Most of
these experts indicated that smaller utilities would be unable to use
these technologies without federal support.
A wide variety of monitoring technologies can be used in drinking water
systems and, depending on their specific functions, may be deployed at
locations upstream from, within, or downstream from drinking water
treatment plants. Conventional monitors typically measure things such as
pH (acidity and alkalinity), turbidity, conductivity, temperature, organic
compounds and other contaminants. Biomonitors employ living organisms,
such as fish or algae, to provide information on other water constituents
that may impair human health or the environment.
Emerging monitoring technologies are capable of providing near real-time
results for a wider array of potentially harmful water constituents.
According to some experts, near real-time monitors may be strategically
placed at points within the distribution system, where they may be able to
quickly detect potentially dangerous backflows that may enter the system.
They may also be used to augment a system's conventional monitoring
system. As some experts suggested, for example, pressure sensor systems
and biodetector networks could benefit the utility in its security
preparedness as well as its regular operations by describing breaches or
leaks in water mains, or by observing microbial contamination in a
nonterrorist event. Some monitors based on emerging technologies capable
of providing near real-time results may also be placed at the "point of
service," where they can alert the consumer or utility about the potential
for contaminated water entering a home or business.
These views are substantiated by a 2002 report by the National Academies
of Science, which also highlighted the need for improved monitoring
technologies as one of the four highest-priority areas for drinking water
research and development. The report noted that such technologies differ
significantly from those currently used for conventional water quality
monitoring, stating further that sensors are needed for "better, cheaper,
and faster sensing of chemical or biological contaminants."1
1The National Research Council of the National Academies, Making the
Nation Safer: The Role of Science and Technology in Countering Terrorism
(Washington, D.C.: The National Academies Press, 2002).
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Activities Experts Identified As Most
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The need for near real-time monitoring technologies was also recognized in
the Bioterrorism Act, which directed EPA to review analytical
methodologies and detection techniques that can quickly and accurately
provide information on contaminants.2 As an initial step in meeting this
requirement, the agency is reviewing such early warning systems, including
those designed to monitor levels of chemical, biological, and radiological
contaminants or indicators of contaminants.
EPA is also planning to launch a number of projects through its Office of
Water and Office of Research and Development. For example, one project,
planned for November 2003 through May 2004, would entail a detailed
examination of commercially available real-time monitors. According to
EPA, the information derived from this project would be placed in a
compendium for manufacturers and vendors of monitoring technology,
allowing them to better focus technology development efforts.3 Another
project aims to evaluate how well many currently used water monitoring
technologies would deal with the introduction of various contaminants.4
Among other efforts, EPA also hopes to begin a project in November 2003 to
test and evaluate the applicability of other industries' monitoring
technologies to the security-related monitoring needs of drinking water
systems. EPA's preliminary cost estimates for monitoring-related projects
are about $5 million, and their initiation or completion will depend on
the availability of fiscal year 2004 and 2005 funds.
2Bioterrorism Act, S 402.
3In addition, since August 2002, EPA has augmented its Environmental
Technology Verification (ETV) Program to include water security issues.
The ETV Program can be used to test, evaluate, and eventually bring
promising technologies (e.g., detection and "point of use" treatment
technologies) to the marketplace. EPA has spent approximately $2 million
of fiscal year 2002 supplemental funds on the ETV Program and its related
projects, and estimates the total costs for the ETV projects at $8.1
million. Once technologies are verified, EPA believes the technology can
be tested in pilot-scale studies and potentially used at drinking water
systems.
4This work is planned to review both large and small treatment system
monitoring capabilities, distribution systems, and remote telemetry
monitoring research, and will be conducted in controlled conditions at the
Office of Research and Development's Water Awareness Technology Evaluation
Research and Security Center, located at EPA's Test & Evaluation Facility.
The work is projected to end around December 2005.
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Activities Experts Identified As Most
Deserving of Federal Support
Increasing Laboratories' Capacity to Deal with Terrorist Attacks
Over two-thirds of the experts (29 of 43) rated increasing laboratory
capacity as a high or highest priority for federal funding. Many experts
on our panel commented that laboratories are being challenged just to keep
up with their normal responsibilities to collect, test, and analyze large
volumes of water samples for water utilities and other clients.
Consequently, they expressed reservations about the ability of
laboratories to handle these responsibilities in the event of "surge"
events caused by the chemical, biological, or radiological contamination
of water supplies.
As one expert explained, few laboratories can test for a full range of
contaminants, and these limitations would be amplified if the laboratories
had to respond to a terror-related emergency. Another expert believed that
in the event of an emergency, many utilities would be confused about which
labs to use for testing samples of suspect water, and that a network of
labs needs to be established so that quick results of tests could be
obtained. The National Academies of Science report raised similar
concerns, adding that legal concerns over the accuracy of laboratories'
tests may make them reluctant to participate in testing under such severe
conditions. The report concludes that a "dearth of laboratory capacity
poses a serious limitation to our ability to respond to a contamination
attack on the water system."5
One panelist suggested that state health departments need additional
federal funds to better develop the regional capacity to sample water, and
to improve analytical techniques used to detect contaminants. He further
noted that state laboratories can and would serve as a component of an
emergency response team, and that it would be effective for state
laboratory programs to integrate these new or increased responsibilities
with their existing responsibilities under grants from the Centers for
Disease Control and Prevention.6
5The National Research Council of the National Academies, Making the
Nation Safer: The Role of Science and Technology in Countering Terrorism
(Washington, D.C.: The National Academies Press, 2002).
6The Centers for Disease Control and Prevention (CDC) currently supports
programs directed to states in order to improve laboratory capacity and to
ensure public health preparedness, such as the Emerging Infections
Program, the infectious disease Epidemiology and Laboratory Capacity
Program, and the National Electronic Disease Surveillance System. For
fiscal year 2003, CDC made approximately $870 million available to
applicants.
Chapter 4
Activities Experts Identified As Most
Deserving of Federal Support
EPA is actively supporting research in order to improve laboratory
capacity nationwide, and has identified a series of ongoing and future
projects toward that end. One project, which was due for completion in
September 2003, would result in a water-specific compendium of
laboratories that may be able to assist water utilities if contamination
occurs. A related project would assess existing laboratory capacity to
analyze drinking water samples in emergency situations. Another project,
initiated in June 2003, is intended to analyze resource limitations at
laboratories, such as personnel, equipment, training, and methods, and to
provide recommendations to address these limitations.
According to EPA water officials, the agency may spend approximately $2.4
million starting in fiscal year 2003 to carry out these and other projects
to assess and address the capacity of the nation's laboratories to deal
with emergency situations. However, the experts' views on this matter
suggest that given the magnitude of this long-standing problem-even under
normal circumstances-it will be difficult enough to accurately
characterize the challenge of laboratory analysis during a drinking water
emergency, much less address the problem effectively.
"Hardening" Assets and Completing Other Physical Improvements
Over two-thirds of the experts (29 of 43) rated activities that would
improve (or "harden") the basic physical security of drinking water
systems as warranting either a high or highest priority for federal
funding. These activities include, among others, adding or repairing
fences, locks, lighting systems, and cameras and other surveillance
equipment. The National Academies of Science report reached similar
conclusions about the need to harden certain facilities. It describes how
many parts of the drinking water infrastructure remain highly accessible,
and notes that access controls need to be improved. The report further
noted that improved technologies are needed to protect against explosives
delivered by motor vehicle or rail.7
However, the experts' support for hardening activities came with some
notable caveats. For example, one expert said that many utility operators
are reluctant to invest in physical upgrades because of fiscal shortfalls
and other competing Safe Drinking Water Act requirements, despite the
potential for such upgrades to be relatively cheap (many costing less than
7The National Research Council of the National Academies, Making the
Nation Safer: The Role of Science and Technology in Countering Terrorism
(Washington, D.C.: The National Academies Press, 2002).
Chapter 4
Activities Experts Identified As Most
Deserving of Federal Support
$5,000 per system). According to this expert, if "an effective and
adequate grant program could be developed and managed," small amounts of
funding could address the problems of many small drinking water systems.
Some experts also cited the limitations inherent in efforts to
comprehensively harden the physical drinking water facility. For example,
unlike nuclear power or chemical plants, drinking water system assets are
not concentrated in a geographically secure area that can be hardened
against all types of contamination or attack. Rather, they are spread over
large geographic areas, particularly the source water and distribution
systems. Thus, these panelists noted, while some degree of physical
security enhancement at drinking water facilities is appropriate, efforts
to construct physical barriers to comprehensively thwart attacks would be
of limited effectiveness. Several said that efforts might be better
directed at intruder detection, or adding security guards or electronic
equipment.
The American Water Works Association Research Foundation is designing a
project that will collect information on vulnerabilities, threats,
potential security improvements, and innovative solutions to certain
physical vulnerabilities. This project began in June 2003 and is scheduled
for completion in July 2004. EPA also noted that utilities may be eligible
to use a portion of the Drinking Water State Revolving Fund for this
purpose.8
Establishing Engineering Building Standards
Approximately 49 percent of the experts (21 of 43) rated the establishment
of engineering and building standards for drinking water systems, which
integrate security concepts into building design, as having either a high
or highest priority for federal funding. Some noted that improved
standards could yield multiple benefits by improving upon the design and
functionality of a drinking water system while augmenting security to
guard against attack.
Others wrote that new drinking water systems, which are being constructed
and designed regularly, provide opportunities for incorporating security
measures. One expert noted specifically that new design measures "may
include increased physical security, elimination of
8Environmental Protection Agency, Office of Water, Use of the Drinking
Water State Revolving Fund (DWSRF) to Implement Security Measures at
Public Water Systems, EPA 816-F-02-040, November 2001, available on the
Web at http://www.epa.gov/ogwdw000/dwsrf/security-fs.pdf.
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Activities Experts Identified As Most
Deserving of Federal Support
`single points of failure,' the inclusion of redundancy into the overall
design," or the creation of multiple pathways from source to tap. Another
noted that the development and implementation of new or upgraded systems
with better layouts can reduce unauthorized access, improve detection, and
assist in isolating problems at the water facility.
According to another expert, standardization is needed across local
jurisdictions so that neighboring providers may assist one another in a
crisis. This view was echoed in the National Academies of Science report,
which concluded that the lack of standardization impedes the introduction
of new processes and technology."9
According to the EPA Action Plan, the agency is also considering the
development of information on building standards that could enhance
security of drinking water facilities, while improving operations and
better protecting water quality. The plan noted that such standards would
be modeled after those developed by the Department of Defense, which found
that "dual use" aspects of improved design features are desirable because
many security enhancements are not cost effective without some form of
multiple benefit.10 Specifically, the proposed EPA plan includes working
with standards-setting organizations to develop voluntary design standards
and recommendations for new construction, reconstruction, and retrofitting
of drinking water facilities with a focus on integrating security with
ongoing operations.
Requiring Backflow Protections in Water Distribution Systems
Inappropriate use of piping systems, whether intended or not, could result
in a backflow of contaminated water into distribution systems, where it
could then find its way to other consumers. Backflow protection devices
are one way to potentially mitigate this threat when installed either at
access points to buildings or homes, or at cross connections in the
distribution system.
9The National Research Council of the National Academies, Making the
Nation Safer: The Role of Science and Technology in Countering Terrorism
(Washington, D.C.: The National Academies Press, 2002).
10Department of Defense, Unified Facilities Criteria (UFC): Department of
Defense Minimum Antiterrorism Standards for Buildings, UFC 4-010-01, July
2002, available on the Web at
http://www.acq.osd.mil/ie/irm/irm_library/UFC%204_010_01%20-%2031JUL2002.pdf.
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Activities Experts Identified As Most
Deserving of Federal Support
Approximately 47 percent of the experts in our study (20 of 43) said
research and implementation of such backflow protection warranted a high
or highest priority for federal funding. These backflow protection devices
could be coupled closely with monitoring and metering technologies that
can sense contaminant concentrations in drinking water systems. Another
noted further that automated meter reading is already being used, but the
ability to get real-time readings is essential in order to rapidly notify
technicians or officials if a backflow is detected. This could help reduce
or eliminate threats to the distribution system.11
Testing and Further Protecting SCADA and Cyber Systems
Section 402 of the Bioterrorism Act requires a review of "methods and
means by which information systems, including process controls and
Supervisory Control and Data Acquisition (SCADA) and cyber systems at
community water systems, could be disrupted by terrorists or other
groups." Slightly more than one-third (15 of 43) of the experts on our
panel rated federal funding to test and further protect SCADA systems as
warranting a high or highest priority. Information provided at the 2003
American Water Works Association (AWWA) Water Security Congress
highlighted the limited security features inherent in many SCADA systems,
citing few security protocols, lack of firewalls, and SCADA data being
routed outside of a facility. Other SCADA systems are placed in networks
that are accessible through the Internet and, therefore, are exposed to
additional vulnerabilities. One expert added that because the majority of
the SCADA software is created outside the United States, the expert
favored establishing and enforcing security standards for the software, as
well as testing the software before installation at water utilities. This
expert believed that federal activities should include working with
vendors of SCADA systems and related software in order to ensure that
security concerns are appropriately incorporated into the design of these
systems.
According to EPA, to meet its responsibilities under the Bioterrorism Act,
the agency is planning to pursue research in a number of areas to reduce
11The Bioterrorism Act recognized the importance of dealing with this
potentially serious source of contamination. Specifically, section 402 of
the Bioterrorism Act calls for a review of "methods and means by which
pipes, constructed conveyances, collection, pretreatment, treatment,
storage and distribution systems that are utilized in connection with
public water systems could be altered or affected so as to be subject to
cross-contamination of drinking water supplies." In addition, section 402
requires the review of "procedures and equipment necessary to prevent the
flow of contaminated drinking water to individuals served by public water
systems."
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Activities Experts Identified As Most
Deserving of Federal Support
the risks of attacks on drinking water SCADA systems and to better
understand their potential consequences, starting with an identification
of the possible threats posed to such systems. Starting in fiscal year
2004, EPA also intends to (1) develop models that can simulate the
consequences of physical and cyber attacks, emphasizing the distribution
system and eventually cascading or interrelated consequences; (2) assess
the consequences of a loss of pressurized water on other critical
infrastructure sectors such as power, transportation, chemical supplies,
and communications; (3) compile technical information and informational
tools that can help in analyzing the consequences of potential physical
and cyber threats; and (4) establish minimum security standards for the
protection of SCADA systems.
Developing Computer Models of Terrorist Events in Water Systems
Computer modeling can be an important tool in understanding how to prevent
or mitigate contamination episodes. Specifically, modeling can be used to
simulate contamination events, which in turn can enhance the development
of emergency response plans, help select critical locations in
distribution systems for positioning and placing monitoring devices, and
guide the actions of first responders.
About 30 percent of the experts (13 of 43) rated the development of
computer models of terrorist events as deserving a high or highest
priority for federal funding. A number of experts noted the relevance of
this work for understanding the characteristics of distribution systems.
One expert, for example, advocated a "model-based distribution system flow
simulator that can be easily tailored to a specific water system such that
`what-if' contamination scenarios can be posed to the system through
simulation in order to explore weaknesses in the system." The expert
further stated that such a modeling system would also have to take into
account the fate and transport of the candidate contaminants throughout
the system, and that the approach "would be a fusion of information from
both threat assessment and system modeling research efforts."
According to EPA officials, the agency is evaluating distribution system
and source water hydraulic models, such as EPANET, PipelineNet, and
Riverspill, that can be used to follow water movements and tracer
chemicals through distribution systems. EPA notes that several large
utilities are currently using such models, but that medium and small
utilities face challenges in applying them to their systems. EPA was also
planning to initiate a project in September 2003 that will attempt to
improve these models by incorporating health-related data, data
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Activities Experts Identified As Most
Deserving of Federal Support
concerning consumer complaints, Geographic Information System data, and
information from SCADA systems. Overall, EPA's preliminary cost estimates
are $2.8 million for modeling projects to develop more effective
protection of distribution systems.
Establishing Baseline Values for Water Constituents
About 23 percent of the experts (10 of 43) rated the importance of
establishing baseline values (e.g., concentrations of certain chemicals
typically found in a drinking water system) for drinking water system
constituents as a high or highest priority warranting federal support. One
expert noted that developing and understanding the basic characteristics
and typical monitoring results of a distribution system are essential to
understand if and when a drinking water system is subject to
contamination. According to other experts, because distribution systems
may be the most vulnerable portion of a system, and the most complex in
terms of understanding appropriate response actions, baseline data
available from pre-emergency studies could be helpful.
In addition to providing utility operators with information on normal
operating conditions within their systems, understanding baseline levels
of water constituents is often needed to develop certain monitoring
technologies. For example, monitoring devices that measure the light given
off during certain organic reactions can be indicative of possible water
contaminants, but only if baseline luminescence levels are known and can
be incorporated into measurements and calibrations.
In March 2004, EPA plans to launch a project to survey available
information on background levels of certain contaminants of concern that
are known or suspected to occur in source or treated drinking water. The
initiation of this project depends on the progress of another planned
project to develop an improved understanding of the biological, physical,
chemical, and toxicological properties of contaminants.
Improving Treatment About 23 percent of the experts (10 of 43) rated the
improvement of
Technologies technologies that can better treat the kind of chemical or
biological agents likely to be used in attacking a drinking water system
as warranting a high or highest priority for federal funding. While water
treatment technologies have advanced, as indicated in EPA's research and
implementation action plans, treatment capabilities still need to be
evaluated and improved for a wide array of microbial and other
contaminants. One expert noted that research on membranes (filters that
can remove small particulates or
Chapter 4
Activities Experts Identified As Most
Deserving of Federal Support
microorganisms) and other advanced treatment techniques is producing
promising results, and that further progress in this area may be important
in making "water an unattractive target."12 Specifically, treatment
technologies needing further development include ultraviolet systems and
improved reverse osmosis techniques. Finally, other experts believed that
there should be more research and development of point-of-use treatment
devices (possibly installed at the meter), and that a distributed
treatment process-one that involves the treatment of water at multiple
locations within a drinking water system or uses a variety of
methods-would provide additional security against contamination.
According to EPA officials, the agency hopes to initiate a series of
projects to address drinking water treatment issues. Among these are
efforts to (1) identify alternative treatment options by reviewing
literature on contaminants most likely to be used in attacking drinking
water systems; (2) prepare systematic methods to evaluate treatment
technologies for likely contaminants; (3) perform bench-scale studies
(those performed in a laboratory under controlled conditions) to determine
the effectiveness of typical disinfection and contaminant removal
technologies; (4) identify alternative treatment options at the point of
use or point of entry; and (5) develop guidance for discharging
contaminated water that had been used to clean contaminated substances or
equipment.
Activities to Improve Education and Training
Experts strongly supported improved training and education to help ensure
that utility personnel can detect and respond to malevolent acts affecting
their facilities. As shown in figure 9, the education and training
activities most frequently recommended for federal support generally fell
into four categories: (1) specialized training of utility personnel with
security-related responsibilities, (2) support for regional simulation
exercises to test emergency response plans, (3) general security awareness
training for utility personnel not specifically charged with
security-related responsibilities, and (4) use of multidisciplinary
consulting teams ("Red Teams") to independently evaluate drinking water
utilities and their security concerns.
12For general information on membrane treatment options or examples, refer
to EPA's proposed draft Membrane Filtration Guidance Manual, EPA
815-D-03-008, Office of Water, June 2003.
Chapter 4
Activities Experts Identified As Most
Deserving of Federal Support
Figure 9: Activities Identified by Experts to Improve Education and Training
Required Training of Key Utility Personnel
Many experts underscored the importance of training drinking water
personnel with security-related responsibilities in techniques to prevent,
detect, and, if necessary, respond to an attack on their system. This
training would include, for example, training for laboratory technicians
who test for potential contaminants; for utility operators who perform
day-to-day duties or who are uniquely positioned to monitor and respond to
potential contaminants at a treatment facility; and for mechanical, civil,
and environmental engineers who design, repair, and maintain drinking
water systems.
Overall, over 90 percent of the experts (39 of 43) indicated that required
training for security-related personnel warrants at least a high priority
for
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Activities Experts Identified As Most
Deserving of Federal Support
federal funding, with approximately 56 percent (24 of 43) indicating that
it deserved highest priority. One expert said that there should be
mandatory federal training for employees at drinking water systems serving
10,000 people or more.
To date, EPA has launched at least three programs that emphasize technical
training, one directed to states and another to utility employees and
officials. Through one program, beginning in fiscal year 2002, EPA has
made grants available to states and territories that, in part, are
intended to support security-related training and education.13 Also, EPA
has developed two train-the-trainer programs. One of these, begun in
fiscal year 2003 to provide assistance to drinking water systems serving
fewer than 50,000 people, awarded $1.5 million in grants to five nonprofit
training and technical assistance organizations.14 Another program makes
available "no cost" security training for drinking water systems that
serve populations of 50,000 to 100,000.15 This program, which also
provides assistance to develop vulnerability assessments and emergency
response plans, includes provisions for follow-up technical assistance and
training.
Regional Simulation Regional simulation exercises to test emergency
response plans are Exercises to Test intended to provide utility and other
personnel with the training and Emergency Response Plans experience needed
both to perform their individual roles in an emergency
and to coordinate these roles with other responders within and outside the
utility. A successful emergency response plan can help these staff members
more quickly identify and respond to an emergency and more quickly restore
services and public confidence.
13The additional monies are for coordination within the state or territory
on homeland security issues, developing or enhancing vulnerability
assessments and emergency response plans, and setting up a communications
strategy for states and utilities.
14The grants (up to $300,000 per entity) were intended to build staff
expertise in drinking water security, after which these individuals would
train state, tribal and local agencies at no cost on security and
technical issues. Grant recipients included the Maryland Center for
Environmental Training, the National Environmental Services Center, the
National Rural Water Association, the Rural Community Assistance Program,
and the Water Environment Federation.
15This is a program implemented by the International City/County
Management Association (ICMA), an organization representing local
government leaders, and the Water Environment Federation (WEF), a
not-for-profit technical and educational organization.
Chapter 4
Activities Experts Identified As Most
Deserving of Federal Support
The experts on our panel underscored the importance of conducting such
exercises, with more than 88 percent (38 of 43) rating these exercises as
warranting a high or highest priority for federal funding. Exercises not
only give individuals invaluable practice, but also allow officials to
better determine what kind of coordinated response is best for a given
adverse event. Other experts described the need to identify responsible
agencies that will make difficult decisions during an emergency, such as
whether to restrict use of the drinking water supplies. And if water
supplies were disrupted, subsequent issues would also need to be
anticipated, such as how to fight fires, mobilize resources (such as the
distribution of bottled water), and communicate among the emergency
responders and to the public.
EPA's Water Protection Task Force has developed a program to support
training exercises across the United States at systems serving over
100,000 people. In 2003, the agency intends to conduct workshops at
approximately 30 to 45 locations across the United States to provide
guidance on emergency response plans and on the Bioterrorism Act's
requirements; to present an overview on protocols for responding to
contamination events; and to provide information on environmental
laboratory capabilities.16
General Awareness Training on Security Issues
In addition to supporting the specialized training recommended for
responders "on the front lines" of an emergency, experts strongly endorsed
a more general level of training for all utility personnel. The need to
emphasize culture change at utilities, as well as among law enforcement
staff, was summarized by an AWWA official who commented at a recent
security conference about how multimillion-dollar investments in security
technology can be undermined by an employee using a brick to prop open a
usually locked door.
About 79 percent of the experts (34 of 43) rated such "general awareness"
training as warranting at least a high priority for federal funding. One
expert noted that such training is needed because the water sector has
traditionally been slow to respond to new challenges (such as new
16In addition to these workshops, EPA published a guidance document for
utilities to provide for uniform response, recovery and remediation
processes. (See Guidance for Water Utility Response, Recovery &
Remediation Actions for Man-Made and/or Technological Emergencies, EPA
810-R-02-001, April 2002).
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Activities Experts Identified As Most
Deserving of Federal Support
regulations), and that such training could therefore be particularly
important in raising the consciousness of staff to security-related
issues.
During fiscal year 2002, EPA completed general security training, in
collaboration with the American Water Works Association and the Water
Environment Federation, to educate water utility managers and operators
about the "entire spectrum of security issues," including vulnerability
assessments, development of emergency response plans, and risk
communication. The organizations convened workshops, conducted webcasts,
and offered online courses. More recently, EPA's Office of Research and
Development has developed a draft Water Security Research and Technical
Support Implementation Plan for key research-related projects, some of
which involve developing training modules and related guidance documents
that will address monitoring, threat evaluation, and analytical protocols.
This training would address the specialized needs of field and laboratory
personnel. However, according to EPA officials, some of these efforts
would also support the general awareness training needs of the larger
universe of utility personnel.
Multidisciplinary Consulting Teams to Analyze Utilities' Risks and
Vulnerabilities
Multidisciplinary consulting teams, often called "Red Teams," consist of
experts in a wide variety of security-and drinking water-related
disciplines. Red Teams could be used to provide independent analyses of
utilities' vulnerabilities, and to assess their emergency response
preparedness, as well as to educate law enforcement and public health
agencies. Approximately half of the experts (22 of the 43) rated support
for certified Red Teams as warranting either a high or highest priority
for federal funding.
According to one expert, an effective Red Team would consist of "at least
six people with widely varying areas of expertise (physical, water
quality, SCADA, policies and procedures, emergency response, etc.), and
are able to work together and sort through various concerns and priorities
to develop a unified understanding of the security issues at a given
utility." He noted further that the team would visit utilities, and
recommend changes or upgrades to security standards, procedures, and
facilities, based on their best professional judgment. Another expert
noted that Red Teams could make client utilities aware of threat
assessment information, and may be able to review vulnerability
assessments independently.
Chapter 4
Activities Experts Identified As Most
Deserving of Federal Support
Activities to Strengthen Relationships between Agencies and Utilities
Experts also cited enhanced cooperation and coordination among government
organizations and utilities as a key component in drinking water
utilities' efforts to improve their security. Our analysis of experts'
responses identified six types of activities in this category as most
deserving of federal support.17 These activities, in figure 10, include
(1) developing common protocols for monitoring drinking water threats, (2)
improving relationships between drinking water utilities and public health
agencies, (3) improving relationships between utilities and law
enforcement agencies, (4) testing local emergency response systems, (5)
sharing resources among utilities, and (6) establishing physical
interconnections between drinking water facilities and distribution
systems.
17More than 50 percent of the experts rated these activities as deserving
a high or highest priority for federal funding relative to the other
activities. Experts also identified three other activities scoring under
50 percent, including the formation of better relationships between water
associations and federal agencies (about 26 percent), developing public
education programs (about 19 percent), and forming a tracking system to
monitor security funding (about 12 percent).
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Activities Experts Identified As Most
Deserving of Federal Support
Developing Common Protocols to Monitor Drinking Water Threats
According to EPA, drinking water utilities vary widely in how they
perceive threats and detect contamination. These differences often occur
because utilities have few common protocols to help promote a more
consistent approach in performing activities such as assessing or
monitoring threats.
The experts in our study also identified this lack of consistency, with
over 90 percent (39 of 43) rating the development of common protocols to
monitor drinking water threats as warranting a high or highest priority
for federal funding. Some experts described the need for a nationally
consistent and uniform analytical response to contamination threats,
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Activities Experts Identified As Most
Deserving of Federal Support
noting in particular the need to have protocols in place for identifying,
sampling, and analyzing contaminants. Some also cautioned that older
methodologies need to be reexamined in the context of terrorism, and that
new protocols need to be reviewed as they are developed. For example, any
standard process developed for detecting potentially harmful
microorganisms in drinking water needs first to be validated, and then
implemented appropriately for different sizes and types of utilities.
EPA officials cited a number of projects under way to develop or improve
protocols that address a variety of activities highlighted in other
sections of this chapter. They noted that guidance documents in
development will include a "toolbox" with information on how to respond to
threats and attacks. EPA also intends to develop guidance to assist law
enforcement officers and utility officials in assessing the credibility of
threats, and guidance on sampling and performing recovery and remediation
work at the sites of potential or real contamination.
Improving Relationships between Utilities and Public Health Agencies
Drinking water utilities and public health agencies would appear to be
natural allies in a common health-related enterprise-delivering safe,
sanitary water supplies to the vast majority of the nation's population.
Their relationship is seemingly reinforced further in many states where
the state's drinking water office is located within its health department.
Nonetheless, about 86 percent of the experts in our study (37 of 43)
recommended a high or highest funding priority for activities devoted to
improving working relationships between drinking water utilities and
health agencies. Such activities may include
o characterizing and studying potential biological, chemical, and
radiological contaminants and getting this information to all levels of
public health departments and officials;
o clarifying and testing the effectiveness of disinfectants or other
approaches to neutralize such contaminants; and
o standardizing effective public notification processes in the event of
potential or real contamination of drinking water systems.
For example, one expert described an array of potentially valuable
information that should be developed and made available to utilities-
information typically held by public health agencies. Examples cited
Chapter 4
Activities Experts Identified As Most
Deserving of Federal Support
include (1) epidemiological data on diseases or other health incidents in
communities, and (2) data on infections in subgroups of the population
(such as nursing homes) and on hospital laboratory diagnoses, absenteeism
from schools, and pharmacy sales of certain medications such as
antidiarrheal medications. Because state health agencies often regulate
public water utilities and therefore are highly knowledgeable about them,
these agencies should serve an enhanced role in the security of water
systems by, for example, disseminating timely information to utilities and
the public about possible contamination.
EPA has devoted funds to address drinking water security issues as they
relate to public health concerns. For example, the agency's Office of
Water is developing contaminant lists that officials say will better guide
future research and identify information needs. Other planned work
includes determining the infectious or toxic doses of potential
contaminants, and providing information (including restricted information)
to utility operators, public officials, and other security stakeholders.
Strengthening Relationships between Drinking Water Utilities and Law
Enforcement Agencies
More than 80 percent of the experts (36 of 43) rated establishing or
strengthening relationships between drinking water utilities and law
enforcement as having either a high or highest priority for federal
funding. Several experts noted that a close working relationship between
these organizations could help to prevent incidents, through increased
police patrols and the sharing of intelligence information. One expert
noted also that improving these relationships might result in a more rapid
and comprehensive response to adverse or malevolent acts. Another expert,
however, pointed to an underlying problem that often characterizes this
relationship: "There are very few people that currently have a good
understanding of utility operations as well as security issues and
approaches. The lack of understanding of utility operations by law
enforcement and even regulatory agencies is detrimental, as is the lack of
law enforcement and security understanding at utilities. Development of
people that understand both types of knowledge would be highly valuable in
addressing water security." He said that the development of such people is
currently being done by chance.
To date, EPA has largely facilitated security-related training programs
intended for utility officials, although it has recently initiated
programs involving outreach to law enforcement organizations. One program
involves developing outreach materials such as a "top 10" list of tips on
water security for law enforcement officials, a "citizens brochure," and
law
Chapter 4
Activities Experts Identified As Most
Deserving of Federal Support
enforcement training workbooks. EPA has also contacted the National Chiefs
of Police and the National Sheriffs' Association to improve awareness
about drinking water security.
Testing Local Emergency Response Systems
It has long been accepted that in light of the critical function they
serve in local communities, drinking water utilities should have effective
emergency response plans to deal with emergencies. This imperative was
further reinforced by the Bioterrorism Act's recent requirement for such
plans. However, the execution of these plans requires staff to perform
functions beyond their day-to-day responsibilities, as well as coordinate
with personnel from different organizations that may have little to do
with each other except in emergency situations.
Further, an emergency response plan can only be considered reliable if it
is tested periodically. About 60 percent of the experts (26 of 43) in our
study indicated that testing of local emergency response systems warrants
a high or highest priority for federal funding. One expert stated that
funds should be made available to ensure that plans are updated, perhaps
annually. Another noted, "Everyone has been concentrating on assessment
and addressing vulnerabilities [to drinking water systems]. What is even
more important to public safety are the correct response actions to any
emergency situation."
In September 2003, EPA conducted a study to evaluate the performance of a
group of laboratories in a simulated emergency situation involving a
chemical contamination threat to drinking water. This study also assessed
the effectiveness of draft guidance provided by EPA to laboratories for
developing their own response protocols. EPA plans to deliver a series of
workshops in early 2004 that will involve tabletop exercises and drills
for various emergency responders, such as public health and law
enforcement officials, laboratory staff, and selected utility employees.
Sharing Resources among Experts cited mutual aid arrangements among
neighboring drinking water
Utilities utilities as activities that may result in a more efficient use
of resources during a terrorist action. Over half of the experts (23 of
43) said that a high or highest priority should be assigned to federal
funding of activities that facilitate the sharing among utilities of such
resources as common back-up power systems and other critical equipment.
One expert described a collaborative in the San Francisco Bay Area, the
Bay Area Security Information Collaborative (BASIC), in which eight
utilities meet regularly
Chapter 4
Activities Experts Identified As Most
Deserving of Federal Support
to address a wide range of security-related topics. Topics have included
the development of a database of chemical and biological contaminants and
response protocols, regional exercises to prepare for an event, regional
training, information sharing on preparing vulnerability assessments, and
public information messages. Such mutual aid arrangements might be
designed in coordination with state water agencies and their related water
security programs.
Another expert cited standardized Mutual Aid Disaster and Intervention
Response Teams (MADIRT) established by the North Carolina League of
Municipalities, the North Carolina Urban Water Consortium, and North
Carolina's Disaster Preparedness Committee. This cooperative approach is
intended to allow municipalities a means to share personnel, equipment,
materials, and emergency assistance with other communities. MADIRT allows
communities to identify their capabilities in advance of an event,
increase standardization to save time and reduce costs, and simplify
communications. One key effort of this cooperative has been to draft
specifications for water pipe repair, although other repair actions (e.g.,
for generators or SCADA systems) are being considered. The cooperative
also establishes mutual aid coordinators-volunteers across the state who
are trained in the types of aid that utilities may need during
emergencies. At present, municipalities that sign a statewide mutual aid
agreement, and in turn use the teams, would be able to fully qualify for
reimbursement from the Federal Emergency Management Agency, the state, or
both.
Establishing Physical Interconnections between Drinking Water Facilities and
Distribution Systems
Physical interconnections-the linkages and junctions between pipes both
within and between utilities-can be useful in mitigating intentional
contamination. Once contamination has occurred and has been identified,
interconnections might allow a utility operator or emergency response
official to continue to provide service from another source, and aid in
isolating contaminated water from reaching the population at large. They
can also allow fresh, clean water to be pumped in from another part of the
system or from an entirely different system.
Approximately 51 percent of the experts (22 of 43) indicated the
establishment of such interconnections deserves either a high or highest
priority for federal funding. The overarching idea is to have a higher
degree of redundancy in a drinking water system, with distributed sources
of water (e.g., water from both wells and surface water); a wider and more
redundant distribution of treated water (e.g., more than one pipeline of
treated water at a critical location); and increased controls over the
flow of
Chapter 4
Activities Experts Identified As Most
Deserving of Federal Support
such water. According to one expert, system interconnections have been
used for some time, but that more recently, efforts have focused
increasingly on developing them to handle emergency situations. Another
expert commented on the need for remote-controlled valves, and on the need
to be able to connect or bypass pipelines to access alternative sources of
water. Finally, one expert suggested that water could be shared across
interconnected utility systems if one system experienced a suspension of
service. This individual stated that there is so much excess capacity in
the systems that many utilities could supply their own needs and another
system of a similar size.
EPA's preliminary cost estimate for interconnectivity research, such as
contingency planning for alternative sources of water, is about $2.6
million. Among other things, the agency intends to develop case studies
that describe how utilities and populations can share water, how
truck-mounted and portable water facilities can be designed and
implemented during crises, and how redundancy in water systems can better
ensure sustained and consistent water supplies. The agency's work in this
area has been complemented by other projects that use computer modeling to
simulate water flows in distribution systems.
Conclusions EPA's Strategic Plan on Homeland Security sets forth the goal
that "by 2005, unacceptable security risks at water utilities across the
country will be significantly reduced through completion of appropriate
vulnerability assessments; design of security enhancement plans;
development of emergency response plans;and implementation of security
enhancements." The plan further commits to providing federal resources to
help accomplish these goals as funds are appropriated.
Key judgments about which recipients should get funding priority, and how
those funds should be spent, will have to be made in the face of great
uncertainty about the likely targets of attacks, the nature of attacks
(whether physical, cyber, chemical, biological, or radiological), and the
timing of attacks. The experts on our panel have had to consider these
uncertainties in deriving their own judgments about these issues. These
judgments, while not unanimous on all matters, suggested a high degree of
consensus on a number of key issues.
We recognize that such sensitive decisions must ultimately take into
account political, equity, and other considerations. But we believe they
should also consider the judgments of the nation's most experienced
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Activities Experts Identified As Most
Deserving of Federal Support
individuals regarding these matters, such as those included on our panel.
It is in this context that we offer the results presented in this report
as information for Congress and the Administration to consider as they
seek the best way to use limited financial resources to reduce threats to
the nation's drinking water supply.
Recommendation for We recommend that, as EPA refines its efforts to help
drinking water utilities reduce their vulnerability to terrorist attacks,
the Administrator of
Executive Action the EPA consider the information in this report to help
determine: how best to allocate security-related federal funds among
drinking water utilities; which methods should be used to distribute the
funds; and what specific security-enhancing activities should be
supported.
Appendix I
Participating Experts on Drinking Water Security Panel
Gregory Baecher
Pete Baxter
Kevin Bennett
Paul Bennett
Frank Blaha
Jennifer Brower
Liz Casman
Jeff Danneels
Rolf Deininger
John Ditmars
David Dobbins
Jane Downing
Wayne Einfeld
James H. Fetzer
Tim Gablehouse
Gregg Grunenfelder
Eugene Habiger
Todd Humphrey
Gerald Iwan
Steve Jackson
Brian Jenkins
Janet Jensen
Dennis Juranek
Michael Keegan
Dave Lawrence
Vanessa Leiby
Carrie Lewis
John McLaughlin
University of Maryland
Jane's Information Group
Federal Bureau of Investigation, National
Infrastructure Protection Center
New York City Department of
Environmental Protection
American Water Works Association
Research Foundation
RAND
Carnegie Mellon University
Sandia National Laboratories
University of Michigan
Argonne National Laboratory
Black & Veatch Company
U.S. Environmental Protection Agency
Sandia National Laboratories
Tennessee Valley Authority
Gablehouse and Eppel
Washington State Department of Health
San Antonio Water System
Portland Water Bureau
Connecticut Department of Public Health
U.S. Department of the Interior, Bureau
of Reclamation
RAND
U.S. Department of Defense, U.S. Army,
Aberdeen Proving Grounds
U.S. Department of Health and Human
Services, Centers for Disease Control and
Prevention
National Rural Water Association
Wisconsin Rural Water Assocation
Association of State Drinking Water
Administrators
Milwaukee Water Department
Brown and Caldwell
Appendix I
Participating Experts on Drinking Water
Security Panel
Christine L. Moe
Erik Olson
Julian Palmore
Janet Pawlukiewicz
E.L. Quarantelli
Brian Ramaley
Alan Roberson
Ken Rubin
Leonard Shabman
Jim Shell
Kimberly Shoaf
David Spath
Mic Stewart
Billy Turner
Ray Yep
Emory University
National Resources Defense Council
University of Illinois
U.S. Environmental Protection Agency
University of Delaware
Newport News Waterworks
American Water Works Association
PA Consultants
Resources for the Future
Metropolitan Washington Council of Governments
University of California at Los Angeles
California Department of Health Services
Metropolitan Water District of Southern California
Columbus Water Works
Santa Clara Valley Water District
Appendix II
GAO Contacts and Staff Acknowledgments
GAO Contacts John Stephenson, (202) 512-3841 Steve Elstein, (202) 512-6515
Acknowledgments In addition to the individuals named above, important
contributions were made by Don Cowan, Lynn Musser, Diane Raynes, and Aaron
Shiffrin. Charles Bausell, Brandon Haller, Katherine M. Raheb, and Carol
Shulman also made key contributions.
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