a

GAO

United States General Accounting Office

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

GAO-04-29
GAO’s expert panel cited distribution systems as among the most 

vulnerable physical components of a drinking water utility, a conclusion 

also reached by key research organizations. Also cited were the 

computer systems that manage critical utility functions, treatment 

chemicals stored on site, and source water supplies. Experts further 

identified two overarching vulnerabilities: (1) a lack of information 

individual utilities need to identify their most serious threats; and (2) a 

lack of redundancy in vital system components, which increases the 

likelihood that an attack could render an entire utility inoperable. 

According to over 90 percent of the experts, utilities serving high-density 

areas deserve at least a high priority for federal funding. Also warranting 

priority are utilities serving critical assets, such as military bases, 

national icons, and key academic institutions. Direct federal grants were 

clearly the most preferred funding mechanism, with over half the experts 

indicating that such grants would be very effective in distributing funds 

to recipients. Substantially fewer experts recommended using the 

Drinking Water State Revolving Fund for security upgrades. 

When experts were asked to identify specific security-enhancing 

activities most deserving of federal support, their responses generally fell 

into three categories: 

• physical and technological upgrades to improve security and 

research to develop technologies to prevent, detect, or respond to 

an attack (experts most strongly supported developing near realtime monitoring technologies to quickly detect contaminants in 

treated drinking water on its way to consumers); 

• education and training to support, among other things, 

simulation exercises to provide responders with experience in 

carrying out emergency response plans; specialized training of 

utility security staff; and multidisciplinary consulting teams to 

assess utilities’ security preparedness and recommend 

improvements; and 

• strengthening key relationships between water utilities and 

other agencies that may have key roles in an emergency response, 

such as public health agencies, law enforcement agencies, and 

neighboring drinking water systems; this category also includes 

developing protocols to encourage consistent approaches to 

detecting and diagnosing threats. 

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 

Stephensonj@gao.gov. 

Highlights of GAO-04-29, a 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 
Page i GAO-04-29 Drinking Water Security

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

Introduction

14

Key Components of a Typical Drinking Water System 14

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

23

Vulnerability of Physical Assets 23

Overarching Issues Affecting Drinking Water Systems’ Security 28

Chapter 3

Experts’ Views on the 

Allocation and 

Distribution of Federal 

Funds

31

Strong Agreement That Allocation Decisions Should Consider a 

Utility’s Vulnerability Assessment 32

Key Criteria to Help Determine Which Utilities Should Receive 

Funding Priority 35

Funding Mechanisms Recommended for Distributing Federal Funds 

37
Contents

Page ii GAO-04-29 Drinking Water Security

Chapter 4

Activities Experts 

Identified As Most 

Deserving of Federal 

Support

43

Activities to Enhance Physical Security and Support Technological 

Improvements 43

Activities to Improve Education and Training 54

Activities to Strengthen Relationships between Agencies and 

Utilities 59

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 19

Figures Figure 1: Key Components of a Typical Drinking Water System 4

Figure 2: Key Components of a Typical Drinking Water System 15

Figure 3: Number of Drinking Water Systems That Serve Various 

Populations 16

Figure 4: Key Vulnerabilities Identified As Compromising Drinking 

Water Systems’ Security 24

Figure 5: Experts’ Views on Whether Federal Funds Should Be 

Allocated Based on Vulnerability Assessment 

Information 33

Figure 6: Experts’ Views on Which Types of Water Utilities Should 

Receive Priority for Federal Funds 35

Figure 7: Recommended Approaches for Distributing Federal 

Funds 38

Figure 8: Activities Identified by Expert Panel to Enhance Physical 

Security and Support Technological Improvements 44

Figure 9: Activities Identified by Experts to Improve Education and 

Training 55

Figure 10: Activities Identified by Experts to Strengthen 

Relationships between Agencies and Utilities 60
Contents

Page iii GAO-04-29 Drinking Water Security

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 

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reproduce this material separately.
Page 1 GAO-04-29 Drinking Water Security

United States General Accounting Office

Washington, D.C. 20548

A

October 31, 2003 Letr

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 
Page 2 GAO-04-29 Drinking Water Security

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

Page 3 GAO-04-29 Drinking Water Security

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

Page 4 GAO-04-29 Drinking Water Security

Figure 1: Key Components of a Typical Drinking Water System

Until the 1990s, emergency planning at drinking water utilities generally 

focused on responding to natural disasters and, in some cases, domestic 

threats such as vandalism. In the 1990s, however, both government and 

industry officials broadened the process to account for terrorist threats. 

Among the most significant actions taken was the issuance in 1998 of 

Presidential Decision Directive 63 to protect the nation’s critical 

Source: GAO.

Post

treatment

storage

Water storage

tank

Pumping

station

Residential

area

Distribution

system

Chemical storage

Water treatment plant

City

Filtration

Sedimentation

Disinfection

Reservoir/

river
Executive Summary

Page 5 GAO-04-29 Drinking Water Security

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

Page 6 GAO-04-29 Drinking Water Security

components, or even an entire drinking water system. Chief among these 

issues were (1) a lack of redundancy in vital systems, which increases the 

likelihood that an attack could render a system inoperable; and (2) the 

difficulty many systems face due to a lack of information on the most 

serious threats to which they are exposed.

Key criteria experts cited for determining how federal funds to improve 

drinking water security should be allocated included (1) the extent to 

which information on utilities’ vulnerabilities should be considered in 

making allocation decisions; and (2) characteristics of the utilities 

themselves, such as size and proximity to population centers.

• About 90 percent of the panelists strongly agreed or somewhat agreed 

that allocation decisions should be based on vulnerability assessment 

information. Several factors, however, complicate the government’s 

ability to use utilities’ vulnerability assessments for this purpose.

• Panelists favored funding priority for utilities serving high-density 

populations, with over 90 percent indicating that they deserve at least a 

high priority and over 50 percent indicating they deserve highest 

priority. Utilities serving critical assets (such as military bases and other 

sensitive government facilities, national icons, and key cultural or 

academic institutions) were also recommended as high-priority 

recipients, while relatively few experts recommended priority for 

utilities serving rural or isolated populations.

When asked to identify the most effective mechanisms of distributing 

federal drinking water security funds to recipients, over half the experts 

indicated that direct federal grants would be very effective in doing so. 

Many also favored including a requirement for matching funds as a grant 

condition. Fewer experts recommended using the Drinking Water State 

Revolving Fund (DWSRF) for this purpose, particularly to support 

upgrades that need to be implemented quickly.

When asked to identify and set priorities for security-enhancing activities 

most deserving of federal support, the experts most frequently identified 

activities that generally fell into three broad categories:

• Physical and technological improvements includes both physical 

alterations to improve the security of drinking water systems and the
Executive Summary

Page 7 GAO-04-29 Drinking Water Security

development of technologies to prevent, detect, or respond to an attack. 

The need to develop near real-time monitoring technologies, which 

would be particularly useful in quickly detecting contaminants in water 

that has already left the treatment plant for the consumer, had by far the 

strongest support.

• Education and training would be used for both utility and nonutility 

personnel responsible for preventing, responding to, and recovering 

from an attack. These activities include, among other things, support for 

simulation exercises to provide responders with experience in carrying 

out utilities’ emergency response plans; specialized training of utility 

personnel responsible for security; general training of utility personnel 

to augment security awareness among all staff; and multidisciplinary 

consulting teams to independently analyze utilities’ security 

preparedness and recommend security-related improvements.

• Strengthening relationships is seen as critical between water utilities 

and other agencies (public health agencies, enforcement agencies, and 

neighboring utilities, among others) that may have key roles in an 

emergency response. This category also includes developing common 

protocols to engender a consistent approach among utilities in detecting 

and diagnosing threats, and the testing of local emergency response 

systems to ensure that participating agencies coordinate their actions 

effectively.

Principal Findings

Key Vulnerabilities Nearly 75 percent of the experts on GAO’s panel (32 of 43) named the 

distribution system (one or more components) as among the top 

vulnerabilities of drinking water systems. In fact, 12 of the 32 experts 

identified the distribution system as the single most important 

vulnerability, a considerably greater number than any other element of the 

drinking water system. Their explanations most often related to the 

accessibility of distribution systems at numerous points. One expert, for 

example, cited the difficulty of preventing the introduction of a 

contaminant into a distribution system from inside a public building. 

Another expert noted that since the water in a distribution system has 

already been treated and is in the final stages of being transferred to 

consumers, the distribution of a chemical, biological, or radiological agent 
Executive Summary

Page 8 GAO-04-29 Drinking Water Security

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 

1

An EPA official noted, however, that distribution systems generally carry disinfectant 

residuals that can counteract the potentially harmful effects of contaminants.
Executive Summary

Page 9 GAO-04-29 Drinking Water Security

systems are “linear”—that is, they have single transmission lines leading 

into the treatment facility, single pumping stations along the system, and 

often employ a single computer operating system. They also depend on the 

electric grid, transportation systems, and single sources of raw materials 

(e.g., treatment chemicals). Many experts expressed concern that problems 

at any of these “single points of failure” could render a system inoperable 

unless redundant systems are in place. Experts also cited the lack of 

sufficient information to understand the most significant threats 

confronting individual utilities. According to the American Water Works 

Association, assessments of the most credible threats facing a utility 

should be based on knowledge of the “threat profile” in its specific area, 

including information about past events that could shed light on future 

risks. Experts noted, however, that such information has been difficult for 

utilities to obtain. One expert suggested that the intelligence community 

needs to develop better threat information and share it with the water 

sector.

Allocation and Distribution 

of Federal Funds

Many drinking water utilities have been financing at least some of their 

security upgrades by passing along the costs to their customers through 

rate increases. Given the cost of these upgrades, however, drinking water 

industry representatives have also sought federal assistance. GAO asked its 

expert panel to comment on the factors that should be considered in 

allocating federal funds. Specifically, GAO asked the experts to comment 

on the following:

• Appropriate use of vulnerability assessment information. About 90 

percent of the experts (39 of 43) strongly agreed or somewhat agreed 

that funds should be allocated on the basis of vulnerability assessment 

information, with some citing the vulnerability assessments (VA) 

required by the Bioterrorism Act as the best available source of this 

information. Several experts, however, pointed to a number of 

complicating factors. Perhaps the most significant constraint is the 

Bioterrorism Act’s provision precluding the disclosure of any 

information that is “derived” from vulnerability assessments submitted 

to EPA. It is important to protect sensitive information about each 

utility’s vulnerabilities from individuals who may then use the 

information to harm the utility. The law specifies that only individuals 

designated by the EPA Administrator may have access to the 

assessments and related information. Yet even those individuals would 

face constraints in using the information. They would have difficulty, for 

example, in citing vulnerability assessments to support decisions on 
Executive Summary

Page 10 GAO-04-29 Drinking Water Security

allocating security-related funds among utilities, as well as decisions 

concerning research priorities and guidance documents. Others cited an 

inherent dilemma affecting any effort to set priorities for funding 

decisions based on the greatest risk—whatever does not receive 

attention becomes the best target. 

• Criteria to help determine which utilities should receive funding 

priority. According to 93 percent of the experts (40 of 43), utilities 

serving high-density population areas should receive a high or highest 

priority in funding (55 percent deemed this criterion as the highest 

priority). Most shared the view of one expert, who noted that directing 

limited resources to protect the greatest number of people is a common 

factor when prioritizing funding. Experts also assigned high priority to 

utilities serving critical assets, such as national icons representing the 

American image, military bases, and key government, academic, and 

cultural institutions. At the other end of the spectrum, only about 5 

percent of the experts (2 of 43) stated that utilities serving rural or 

isolated populations should receive a high or highest priority for federal 

funding. Generally, these panelists commented that such facilities are 

least able to afford security enhancements and are therefore in greatest 

need of federal support. Importantly, the relatively small percentage of 

experts advocating priority for smaller systems may not fully reflect the 

concern among many of the experts for the safety of these utilities. For 

example, several who supported higher priority for utilities serving 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

Page 11 GAO-04-29 Drinking Water Security

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:

• Enhancing Physical Security and Supporting Technological 

Improvements. These activities fell into nine subcategories. Of these, 

the development of “near real-time monitoring technologies,” capable of 

providing near real-time data for a wide array of potentially harmful 

water constituents, received far more support for federal funding than 

any other subcategory—over 93 percent of the experts (40 of 43) rated 

this subcategory as deserving at least a high priority for federal funding. 

More significantly, almost 70 percent (30 of 43) rated it highest priority. 

These technologies were cited as critical in efforts to quickly detect 

contamination events, minimize their impact, and restore systems after 

an event has passed. The experts also voiced strong support for (1) 

increasing laboratories’ capacity to deal with spikes in demand caused 

by chemical, biological, or radiological contamination of water supplies, 

and (2) “hardening” the physical assets of drinking water facilities 

through improvements such as adding or repairing fences, locks, 

lighting systems, and cameras and other surveillance equipment. Some 

experts, however, cited the limitations inherent in attempts to 

comprehensively harden a drinking water facility’s assets. They noted in 

particular that, unlike nuclear power or chemical plants, a drinking 

water system’s assets are spread over large geographic areas, 

particularly the source water and distribution systems.

• Improving Education and Training. Over 90 percent of the experts (39 

of 43) indicated that improved technical training for security-related 

personnel warrants at least a high priority for federal funding, with over 

55 percent (24 of 43) indicating that it deserved highest priority. To a 

lesser extent, experts supported general training for other utility 

personnel to increase their awareness of security issues. The panelists 

also underscored the importance of conducting regional simulation 

exercises to test emergency response plans, with more than 88 percent 

(38 of 43) rating this as a high or highest priority for federal funding. 

Such exercises are intended to provide utility and other personnel with 

the training and experience needed both to perform their individual 

roles in an emergency, and to coordinate these roles with other 

responders. Finally, about half the experts assigned at least a high 

priority to supporting multidisciplinary consulting teams (“Red Teams”), 

comprising individuals with a wide array of backgrounds, to provide 

independent analyses of utilities’ vulnerabilities. 
Executive Summary

Page 12 GAO-04-29 Drinking Water Security

• 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

Page 13 GAO-04-29 Drinking Water Security

for Congress and the Administration to consider as they seek the best way 

to use limited financial resources to reduce the threat to the nation's 

drinking water supply.

Recommendation for 

Executive Action

GAO recommends that, as EPA refines its efforts to help drinking water 

utilities reduce their vulnerability to terrorist attacks, the EPA 

Administrator consider the information in this report to help determine: 

how best to allocate security-related federal funds among drinking water 

utilities, which methods should be used to distribute the funds, and what 

specific security-enhancing activities should be supported.

Agency Comments We provided EPA with a draft of this report for review and comment. EPA 

did not submit a formal letter but did provide comments from officials in its 

Office of Water and its Office of Homeland Security. The comments from 

the Office of Water said that the report’s results were “useful and well 

thought out.” EPA’s Office of Homeland Security said that the report 

“demonstrates a well conceived and executed project,” and that “a number 

of the issues raised in the document will be useful to the agency as it moves 

forward in the drinking water security program.” Both offices also offered 

specific technical comments and suggestions, which have been 

incorporated.
Page 14 GAO-04-29 Drinking Water Security

Chapter 1

Introduction Chapte1r

Drinking water utilities across the country have long been recognized as 

being potentially vulnerable to terrorism of various types, including 

physical disruption, bioterrorism, chemical contamination, and cyber 

attacks. Damage or destruction by such a terrorist attack could disrupt not 

only the availability of safe drinking water to consumers, but also the 

delivery of vital services that depend on these water supplies, such as fire 

suppression.

These concerns were greatly amplified by the September 11, 2001, attacks 

on the World Trade Center and the Pentagon. They were further amplified 

in ensuing months when training manuals were discovered in Afghanistan 

detailing how terrorist trainees could support attacks on drinking water 

systems. 

Key Components of a 

Typical Drinking Water 

System

Drinking water systems vary by size and other factors but, as illustrated in 

figure 2, most typically include a supply source, treatment facility, and 

distribution system.
Chapter 1

Introduction

Page 15 GAO-04-29 Drinking Water Security

Figure 2: Key Components of a Typical Drinking Water System

As the figure shows, a water system’s supply source may include a 

reservoir, aquifer, or well, or a combination of these sources. The supply 

source may also include a dam as well as aqueducts and transmission 

pipelines to deliver the water to a distant treatment plant. Many water 

systems rely on groundwater as their primary water source, but most 

Source: GAO.

Post

treatment

storage

Water storage

tank

Pumping

station

Residential

area

Distribution

system

Chemical storage

Water treatment plant

City

Filtration

Sedimentation

Disinfection

Reservoir/

river
Chapter 1

Introduction

Page 16 GAO-04-29 Drinking Water Security

systems, particularly larger systems, rely on surface water such as lakes, 

rivers, and streams.

Water treatment generally uses filtration, flocculation, sedimentation, and 

other processes to remove impurities and harmful agents, and disinfection 

processes (such as chlorination) to eliminate biological contaminants. 

Chemicals used in these processes, most notably chlorine, are often stored 

on site.

The distribution system comprises several components, such as water 

towers, piping grids, and pumps that deliver treated water from treatment 

systems to consumers. A key feature of most distribution systems is their 

size: Particularly among larger utilities, distribution systems may have 

many thousands of miles of pipes.

The Nation’s Drinking 

Water Systems and the 

Populations They 

Serve 

Nationwide, there are more than 160,000 public water systems that 

individually serve from as few as 25 people to 1 million people or more. As 

figure 3 illustrates, nearly 133,000 of these water systems serve 500 or 

fewer people. Only 466 systems serve more than 100,000 people each, but 

these systems, located primarily in urban areas, account for nearly half of 

the total population served.

Figure 3: Number of Drinking Water Systems That Serve Various Populations

3,467

4,799

19,706

132,974

0 20,000 40,000 60,000 80,000 100,000 120,000 140,000

501 – 3,300

3,301 – 10,000

10,001 – 100,000

Greater than 100,000

< 500

–

Number of systems 161,412 

Source: GAO.

Population served

466
Chapter 1

Introduction

Page 17 GAO-04-29 Drinking Water Security

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.

1

The President’s Commission on Critical Infrastructure Protection, Critical Foundations: 

Protecting America’s Infrastructures, October 1997.
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Introduction

Page 18 GAO-04-29 Drinking Water Security

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.

2

Pub. L. No. 107-188, 116 Stat. 594 (2002) (“Bioterrorism Act”).
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Introduction

Page 19 GAO-04-29 Drinking Water Security

Table 1: Vulnerability Assessment Completion Deadlines

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 

Methodology

As requested in a June 9, 2003, letter to the Comptroller General from the 

Chairman and Ranking Minority Member of the Senate Committee on 

Environment and Public Works, this report identifies experts’ views on the 

following questions:

• What are the key security-related vulnerabilities affecting the nation’s 

drinking water systems?

System size (based on population 

served)

Vulnerability assessment completion 

deadline

100,000 or more March 31, 2003

50,000 to 99,999 December 31, 2003

3,301 to 49,999 June 30, 2004
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Introduction

Page 20 GAO-04-29 Drinking Water Security

• What are the criteria that should be used to determine how federal funds 

are allocated among recipients to improve drinking water security, and 

how should the funds be distributed?

• What specific activities should the federal government support to 

improve drinking water security?

To obtain information on these three questions, we conducted a 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 
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Introduction

Page 21 GAO-04-29 Drinking Water Security

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

Page 22 GAO-04-29 Drinking Water Security

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.
Page 23 GAO-04-29 Drinking Water Security

Chapter 2

Experts Identified Key Vulnerabilities That 

Could Compromise Drinking Water Systems’ 

Security Chapte2r

Our panel of experts identified several key physical assets of drinking 

water systems as the most vulnerable to intentional attack. In general, their 

observations were similar to those of public and private organizations that 

have assessed the vulnerability of these systems to terrorist attacks, 

including the National Academy of Sciences, Sandia National Laboratories, 

and key industry associations. In particular, nearly 75 percent of the 

experts (32 of 43) identified the distribution system or its components as 

among the top vulnerabilities of drinking water systems.

In addition to identifying systems’ physical assets, experts also identified 

overarching issues compromising how well these assets are protected. 

Chief among these issues are (1) a lack of redundancy in vital systems, 

which increases the likelihood that an attack could render a system 

inoperable; and (2) the difficulty many systems face in understanding the 

nature of the threats to which they are exposed.

Vulnerability of 

Physical Assets

As illustrated in figure 4, when asked to identify what they believed to be 

the top vulnerabilities of drinking water utilities, the four physical assets 

most frequently identified by the panel were: (1) the distribution system, 

(2) source water supplies, (3) Supervisory Control and Data Acquisition 

(SCADA) and other information systems, and (4) chemicals stored on site 

that are used to treat source water.
Chapter 2

Experts Identified Key Vulnerabilities That 

Could Compromise Drinking Water Systems’ 

Security

Page 24 GAO-04-29 Drinking Water 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

Page 25 GAO-04-29 Drinking Water 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

Page 26 GAO-04-29 Drinking Water 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

Page 27 GAO-04-29 Drinking Water 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.”

1

A discussion of the influence of these factors on treatment is available in the preamble in 

both the Surface Water Treatment Rule and the Stage I Disinfectants/Disinfection 

Byproducts Rule.
Chapter 2

Experts Identified Key Vulnerabilities That 

Could Compromise Drinking Water Systems’ 

Security

Page 28 GAO-04-29 Drinking Water Security

Overarching Issues 

Affecting Drinking 

Water Systems’ 

Security

In addition to the vulnerabilities associated with specific water system 

components, experts identified several overarching issues that 

compromise the integrity of physical assets and the drinking water system 

in its entirety. Chief among these issues are (1) the lack of redundancy 

among vital systems, and (2) the difficulty many operators face due to a 

lack of information on the most serious threats to which their systems 

might be exposed.

Lack of Redundancy among 

Vital Systems

Drinking water systems are generally “linear” in nature in that they have 

single transmission lines leading into the treatment facility, single pumping 

stations along the system, and a single computer operating system. 

Furthermore, drinking water systems may rely on outside sources of power 

and communications, and depend on the transportation sector for the 

delivery of supplies, often from a limited number of suppliers. If any of 

these external sources were impaired or destroyed, the entire system could 

be compromised. Under these circumstances, any “single point of failure” 

could render a system inoperable unless there are redundant systems in 

place.

Several experts reflected concerns relating to a single point of failure as a 

vulnerability. For example, according to one expert, the destruction of a 

single physical component of the system, such as a single water 

transmission line into the treatment facility, could render the entire system 

inoperable. Moreover, she noted, a system that depends on pumps can be 

completely put out of service if its electrical supply were interrupted. 

Echoing this point, another expert commented, “Experience with Y2K 

planning efforts revealed one of the critical interdependencies nearly all 

water utilities have is with the electrical power supply system. Disruption 

of power supply could have significant impacts on source, treatment and 

distribution systems.”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 

2

These comments, made prior to the electric supply disruption of August 2003, were vividly 

illustrated when that power outage severely disrupted the water supplies of several cities.
Chapter 2

Experts Identified Key Vulnerabilities That 

Could Compromise Drinking Water Systems’ 

Security

Page 29 GAO-04-29 Drinking Water 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:

• According to one expert, “The utility community has very little specific 

and useful information on the threat posed to this industry. This 

represents a real vulnerability since it makes it harder to judge where 

resources might do the most good.” Furthermore, “an ongoing working 

relationship with groups (mostly federal) that do this type of analysis 

could prove extremely valuable in determining how to allocate the 

limited resources available.”

• Utilities may be preoccupied with unsubstantiated threats, according to 

another expert. She noted, “There are many very vulnerable areas, but 

the terrorists may not be technically able to target them, or they may not 

be interested.”

• Another expert stated that utilities need to better understand “how the 

threats may . . . exploit utility operations and infrastructure,” through 

such things as simulation exercises.
Chapter 2

Experts Identified Key Vulnerabilities That 

Could Compromise Drinking Water Systems’ 

Security

Page 30 GAO-04-29 Drinking Water Security

• 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.

3

Environmental Protection Agency, Vulnerability Assessment Fact Sheet, EPA 816-F-02-025, 

November 2002, available on the Web at 

http://www.epa.gov/ogwdw000/security/va_fact_sheet_12-19.pdf.

4

Design Basis Threat: The threat serves as the basis for the design of countermeasures as 

well as the benchmark against which vulnerabilities are assessed.
Page 31 GAO-04-29 Drinking Water Security

Chapter 3

Experts’ Views on the Allocation and 

Distribution of Federal Funds Chapte3r

Many drinking water utilities have been financing at least some of their 

security upgrades by passing along the costs to their customers through 

rate increases. Given the cost of these upgrades, however, the utility 

industry is also asking that the taxpayer shoulder some of the burden 

through the congressional appropriations process. Should Congress and 

the Administration agree to this request, they will need to address key 

issues concerning who should receive the funds and how they should be 

distributed. With this in mind, we asked our panel of experts to focus on 

several key questions: (1) To what extent should utilities’ vulnerability and 

risk assessment information be considered in making allocation decisions? 

(2) What types of utilities should receive funding priority? and (3) What are 

the most effective mechanisms for directing these funds to recipients? 

Overall, we found a high degree of consensus on the following:

• Vulnerability assessment 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.

• Almost all of the experts gave utilities serving high-density populations a 

high or highest funding priority. Utilities serving critical assets (such as 

military bases and other sensitive government facilities, national icons, 

and key cultural or academic institutions) were also recommended as 

high-priority recipients, while relatively few experts recommended a 

high or highest priority for utilities serving rural or isolated populations.

• Direct federal grants are the most favored funding mechanism, with 

many experts indicating that such grants should include a requirement 

for matching funds from the recipient. Relatively fewer experts 

recommended the use of the Drinking Water State Revolving Fund, 

particularly for upgrades to be implemented in the near term.
Chapter 3

Experts’ Views on the Allocation and 

Distribution of Federal Funds

Page 32 GAO-04-29 Drinking Water Security

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

Page 33 GAO-04-29 Drinking Water Security

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

Page 34 GAO-04-29 Drinking Water Security

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.

1

Citing this reason, one expert suggested the addition of a “dual use” criterion in which the 

funds spent would also fix some existing utility deficiency, such as noncompliance with a 

drinking water standard.

2

Environmental Protection Agency, Office of Water, Office of Research and Development, 

Water Security Research and Technical Support Implementation Plan, Preliminary 

Working Draft, July 2003.
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Experts’ Views on the Allocation and 

Distribution of Federal Funds

Page 35 GAO-04-29 Drinking Water Security

Key Criteria to Help 

Determine Which 

Utilities Should 

Receive Funding 

Priority

The experts identified several characteristics of utilities that should be 

used to set funding priorities. The most frequently identified were utilities 

(1) serving high-density populations; (2) serving sensitive or critical assets, 

such as military bases, academic institutions or icons of American culture; 

(3) in proximity to population centers (whether they serve these population 

centers or serve outlying areas); and (4) serving rural or isolated 

populations, such as small systems with less sophisticated water systems 

(see fig. 6).

Figure 6: Experts’ Views on Which Types of Water Utilities Should Receive Priority 

for Federal Funds

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

Page 36 GAO-04-29 Drinking Water Security

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.
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Distribution of Federal Funds

Page 37 GAO-04-29 Drinking Water Security

Importantly, the relatively small percentage of experts supporting funding 

for rural utilities may not fully reflect the concern many panel experts have 

for the safety of these utilities. For example, several who supported higher 

priority for utilities serving high-density populations cautioned that, while 

problems at a large utility will put more people at risk, utilities serving 

small population areas may be more vulnerable because of weaker 

treatment capabilities, fewer highly trained operators, and more limited 

resources. Another expert added that most waterborne disease outbreaks 

have occurred in the systems of smaller utilities.

Funding Mechanisms 

Recommended for 

Distributing Federal 

Funds

We also asked the expert panel to comment on how federal funds should be 

distributed to recipients. Nearly 90 percent said that direct federal grants to 

utilities would be a somewhat or very effective means of distributing funds 

to support security improvements. The experts also showed strong support 

for grants in which some type of match is required of recipients. Figure 7 

shows their views on these and other funding mechanisms.
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Experts’ Views on the Allocation and 

Distribution of Federal Funds

Page 38 GAO-04-29 Drinking Water Security

Figure 7: Recommended Approaches for Distributing Federal Funds
Chapter 3

Experts’ Views on the Allocation and 

Distribution of Federal Funds

Page 39 GAO-04-29 Drinking Water Security

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 

3

As noted earlier in this report, these grants supported VAs, remediation planning, and 

emergency plan development through August 2002. EPA issued grant awards to over 400 

publicly owned and privately owned community water systems that regularly serve 

populations over 100,000. This program was noncompetitive, and all eligible utilities that 

submitted completed grant applications received awards. The value of each grant did not 

exceed $115,000. An EPA official pointed out that higher dollar grant programs might have 

additional administrative requirements.
Chapter 3

Experts’ Views on the Allocation and 

Distribution of Federal Funds

Page 40 GAO-04-29 Drinking Water Security

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

Page 41 GAO-04-29 Drinking Water Security

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.

4

Environmental Protection Agency, Office of Water, Use of the Drinking Water State 

Revolving Fund (DWSRF) to Implement Security Measures at Public Water Systems, EPA 

816-F-02-040, November 2001, available on the Web from 

http://www.epa.gov/ogwdw000/dwsrf/security-fs.pdf.
Chapter 3

Experts’ Views on the Allocation and 

Distribution of Federal Funds

Page 42 GAO-04-29 Drinking Water Security

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.
Page 43 GAO-04-29 Drinking Water Security

Chapter 4

Activities Experts Identified As Most 

Deserving of Federal Support Chapte4r

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:

• Physical and technological improvements. These improvements 

include altering drinking water systems to improve physical security, 

and conducting research and development on technologies to prevent, 

detect, or respond to an attack. Experts most strongly supported near 

real-time monitoring technologies, which they considered particularly 

useful in quickly detecting contaminants in water that has left the 

treatment plant for consumers.

• Education and training. This category includes, among other things, 

supporting simulation exercises to provide responders with experience 

in carrying out utilities’ emergency response plans; specialized training 

of utility personnel charged with security and general training to 

improve the security awareness of their staffs; and multidisciplinary 

teams that can provide independent analysis of utilities’ security 

preparedness and recommend security-related improvements.

• Strengthening working relationships between utilities and other 

public agencies. This category includes strengthening relationships 

between water utilities and other entities that may have key roles in an 

emergency response (such as public health agencies, enforcement 

agencies, and neighboring utilities). It also includes developing common 

protocols to engender a consistent approach among utilities in detecting 

and properly diagnosing threats, and testing local emergency response 

systems to ensure that participating agencies coordinate their actions 

effectively.

We found that EPA has a number of initiatives that address many of these 

activities, some of which are required by the Bioterrorism Act. In most 

cases, however, the activities are in the planning stages, are limited in 

scope, or are dependent on the availability of future appropriations.

Activities to Enhance 

Physical Security and 

Support Technological 

Improvements

Our panel of experts most frequently recommended nine types of activities 

to improve physical security and support technological improvements, as 

figure 8 shows. Of the nine types, the development and implementation of 

near real-time monitoring technologies was rated by far the most important 

activity warranting federal support, with many experts stating that this 
Chapter 4

Activities Experts Identified As Most 

Deserving of Federal Support

Page 44 GAO-04-29 Drinking Water Security

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 

Monitoring Technologies 

Viewed As Highest Priority

Approximately 93 percent of the panel experts (40 of 43) rated the 

expansion of research and development of near real-time monitoring 

technologies as having at least a high priority. These technologies were 

cited as critical to helping drinking water systems detect and respond 

quickly to threats or actual contamination events, to minimize the impact 

of any contamination by facilitating a quick response, and to help in 

restoring systems after an event. Significantly, almost 70 percent of the 

experts (30 of 43) rated this activity as warranting the highest priority for 
Chapter 4

Activities Experts Identified As Most 

Deserving of Federal Support

Page 45 GAO-04-29 Drinking Water Security

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

1

The National Research Council of the National Academies, Making the Nation Safer: The 

Role of Science and Technology in Countering Terrorism (Washington, D.C.: The National 

Academies Press, 2002).
Chapter 4

Activities Experts Identified As Most 

Deserving of Federal Support

Page 46 GAO-04-29 Drinking Water Security

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.

2

Bioterrorism Act, S 402.

3

In addition, since August 2002, EPA has augmented its Environmental Technology 

Verification (ETV) Program to include water security issues. The ETV Program can be used 

to test, evaluate, and eventually bring promising technologies (e.g., detection and “point of 

use” treatment technologies) to the marketplace. EPA has spent approximately $2 million of 

fiscal year 2002 supplemental funds on the ETV Program and its related projects, and 

estimates the total costs for the ETV projects at $8.1 million. Once technologies are verified, 

EPA believes the technology can be tested in pilot-scale studies and potentially used at 

drinking water systems. 

4

This work is planned to review both large and small treatment system monitoring 

capabilities, distribution systems, and remote telemetry monitoring research, and will be 

conducted in controlled conditions at the Office of Research and Development’s Water 

Awareness Technology Evaluation Research and Security Center, located at EPA’s Test & 

Evaluation Facility. The work is projected to end around December 2005.
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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

5

The National Research Council of the National Academies, Making the Nation Safer: The 

Role of Science and Technology in Countering Terrorism (Washington, D.C.: The National 

Academies Press, 2002).

6

The Centers for Disease Control and Prevention (CDC) currently supports programs 

directed to states in order to improve laboratory capacity and to ensure public health 

preparedness, such as the Emerging Infections Program, the infectious disease 

Epidemiology and Laboratory Capacity Program, and the National Electronic Disease 

Surveillance System. For fiscal year 2003, CDC made approximately $870 million available 

to applicants.
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Activities Experts Identified As Most 

Deserving of Federal Support

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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 

7

The National Research Council of the National Academies, Making the Nation Safer: The 

Role of Science and Technology in Countering Terrorism (Washington, D.C.: The National 

Academies Press, 2002).
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Activities Experts Identified As Most 

Deserving of Federal Support

Page 49 GAO-04-29 Drinking Water Security

$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 

8

Environmental Protection Agency, Office of Water, Use of the Drinking Water State 

Revolving Fund (DWSRF) to Implement Security Measures at Public Water Systems, EPA 

816-F-02-040, November 2001, available on the Web at 

http://www.epa.gov/ogwdw000/dwsrf/security-fs.pdf.
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Activities Experts Identified As Most 

Deserving of Federal Support

Page 50 GAO-04-29 Drinking Water Security

‘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.

9

The National Research Council of the National Academies, Making the Nation Safer: The 

Role of Science and Technology in Countering Terrorism (Washington, D.C.: The National 

Academies Press, 2002).

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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Deserving of Federal Support

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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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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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concerning consumer complaints, Geographic Information System data, 

and information from SCADA systems. Overall, EPA’s preliminary cost 

estimates are $2.8 million for modeling projects to develop more effective 

protection of distribution systems.

Establishing Baseline Values 

for Water Constituents

About 23 percent of the experts (10 of 43) rated the importance of 

establishing baseline values (e.g., concentrations of certain chemicals 

typically found in a drinking water system) for drinking water system 

constituents as a high or highest priority warranting federal support. One 

expert noted that developing and understanding the basic characteristics 

and typical monitoring results of a distribution system are essential to 

understand if and when a drinking water system is subject to 

contamination. According to other experts, because distribution systems 

may be the most vulnerable portion of a system, and the most complex in 

terms of understanding appropriate response actions, baseline data 

available from pre-emergency studies could be helpful.

In addition to providing utility operators with information on normal 

operating conditions within their systems, understanding baseline levels of 

water constituents is often needed to develop certain monitoring 

technologies. For example, monitoring devices that measure the light given 

off during certain organic reactions can be indicative of possible water 

contaminants, but only if baseline luminescence levels are known and can 

be incorporated into measurements and calibrations.

In March 2004, EPA plans to launch a project to survey available 

information on background levels of certain contaminants of concern that 

are known or suspected to occur in source or treated drinking water. The 

initiation of this project depends on the progress of another planned 

project to develop an improved understanding of the biological, physical, 

chemical, and toxicological properties of contaminants.

Improving Treatment 

Technologies

About 23 percent of the experts (10 of 43) rated the improvement of 

technologies that can better treat the kind of chemical or biological agents 

likely to be used in attacking a drinking water system as warranting a high 

or highest priority for federal funding. While water treatment technologies 

have advanced, as indicated in EPA’s research and implementation action 

plans, treatment capabilities still need to be evaluated and improved for a 

wide array of microbial and other contaminants. One expert noted that 

research on membranes (filters that can remove small particulates or 
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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.
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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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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 

Exercises to Test 

Emergency Response Plans

Regional simulation exercises to test emergency response plans are 

intended to provide utility and other personnel with the training and 

experience needed both to perform their individual roles in an emergency 

and to coordinate these roles with other responders within and outside the 

utility. A successful emergency response plan can help these staff members 

more quickly identify and respond to an emergency and more quickly 

restore services and public confidence.

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.
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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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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.
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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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Figure 10: Activities Identified by Experts to Strengthen Relationships between 

Agencies and Utilities

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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noting in particular the need to have protocols in place for identifying, 

sampling, and analyzing contaminants. Some also cautioned that older 

methodologies need to be reexamined in the context of terrorism, and that 

new protocols need to be reviewed as they are developed. For example, 

any standard process developed for detecting potentially harmful 

microorganisms in drinking water needs first to be validated, and then 

implemented appropriately for different sizes and types of utilities.

EPA officials cited a number of projects under way to develop or improve 

protocols that address a variety of activities highlighted in other sections of 

this chapter. They noted that guidance documents in development will 

include a “toolbox” with information on how to respond to threats and 

attacks. EPA also intends to develop guidance to assist law enforcement 

officers and utility officials in assessing the credibility of threats, and 

guidance on sampling and performing recovery and remediation work at 

the sites of potential or real contamination.

Improving Relationships 

between Utilities and Public 

Health Agencies

Drinking water utilities and public health agencies would appear to be 

natural allies in a common health-related enterprise—delivering safe, 

sanitary water supplies to the vast majority of the nation’s population. 

Their relationship is seemingly reinforced further in many states where the 

state’s drinking water office is located within its health department.

Nonetheless, about 86 percent of the experts in our study (37 of 43) 

recommended a high or highest funding priority for activities devoted to 

improving working relationships between drinking water utilities and 

health agencies. Such activities may include

• characterizing and studying potential biological, chemical, and 

radiological contaminants and getting this information to all levels of 

public health departments and officials;

• clarifying and testing the effectiveness of disinfectants or other 

approaches to neutralize such contaminants; and

• standardizing effective public notification processes in the event of 

potential or real contamination of drinking water systems.

For example, one expert described an array of potentially valuable 

information that should be developed and made available to utilities—

information typically held by public health agencies. Examples cited 
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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 
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enforcement training workbooks. EPA has also contacted the National 

Chiefs of Police and the National Sheriffs’ Association to improve 

awareness about drinking water security.

Testing Local Emergency 

Response Systems

It has long been accepted that in light of the critical function they serve in 

local communities, drinking water utilities should have effective 

emergency response plans to deal with emergencies. This imperative was 

further reinforced by the Bioterrorism Act’s recent requirement for such 

plans. However, the execution of these plans requires staff to perform 

functions beyond their day-to-day responsibilities, as well as coordinate 

with personnel from different organizations that may have little to do with 

each other except in emergency situations.

Further, an emergency response plan can only be considered reliable if it is 

tested periodically. About 60 percent of the experts (26 of 43) in our study 

indicated that testing of local emergency response systems warrants a high 

or highest priority for federal funding. One expert stated that funds should 

be made available to ensure that plans are updated, perhaps annually. 

Another noted, “Everyone has been concentrating on assessment and 

addressing vulnerabilities [to drinking water systems]. What is even more 

important to public safety are the correct response actions to any 

emergency situation.”

In September 2003, EPA conducted a study to evaluate the performance of 

a group of laboratories in a simulated emergency situation involving a 

chemical contamination threat to drinking water. This study also assessed 

the effectiveness of draft guidance provided by EPA to laboratories for 

developing their own response protocols. EPA plans to deliver a series of 

workshops in early 2004 that will involve tabletop exercises and drills for 

various emergency responders, such as public health and law enforcement 

officials, laboratory staff, and selected utility employees.

Sharing Resources among 

Utilities

Experts cited mutual aid arrangements among neighboring drinking water 

utilities as activities that may result in a more efficient use of resources 

during a terrorist action. Over half of the experts (23 of 43) said that a high 

or highest priority should be assigned to federal funding of activities that 

facilitate the sharing among utilities of such resources as common back-up 

power systems and other critical equipment. One expert described a 

collaborative in the San Francisco Bay Area, the Bay Area Security 

Information Collaborative (BASIC), in which eight utilities meet regularly 
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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 
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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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individuals regarding these matters, such as those included on our panel. It 

is in this context that we offer the results presented in this report as 

information for Congress and the Administration to consider as they seek 

the best way to use limited financial resources to reduce threats to the 

nation's drinking water supply.

Recommendation for 

Executive Action

We recommend that, as EPA refines its efforts to help drinking water 

utilities reduce their vulnerability to terrorist attacks, the Administrator of 

the EPA consider the information in this report to help determine: how best 

to allocate security-related federal funds among drinking water utilities; 

which methods should be used to distribute the funds; and what specific 

security-enhancing activities should be supported.
Page 67 GAO-04-29 Drinking Water Security

Appendix I

Participating Experts on Drinking Water Apendxies

Security Panel ApendxiI

Gregory Baecher University of Maryland

Pete Baxter Jane’s Information Group

Kevin Bennett Federal Bureau of Investigation, National 

Infrastructure Protection Center

Paul Bennett New York City Department of 

Environmental Protection

Frank Blaha American Water Works Association 

Research Foundation

Jennifer Brower RAND 

Liz Casman Carnegie Mellon University

Jeff Danneels Sandia National Laboratories

Rolf Deininger University of Michigan

John Ditmars Argonne National Laboratory

David Dobbins Black & Veatch Company

Jane Downing U.S. Environmental Protection Agency

Wayne Einfeld Sandia National Laboratories

James H. Fetzer Tennessee Valley Authority

Tim Gablehouse Gablehouse and Eppel

Gregg Grunenfelder Washington State Department of Health

Eugene Habiger San Antonio Water System

Todd Humphrey Portland Water Bureau

Gerald Iwan Connecticut Department of Public Health

Steve Jackson U.S. Department of the Interior, Bureau 

of Reclamation

Brian Jenkins RAND

Janet Jensen U.S. Department of Defense, U.S. Army, 

Aberdeen Proving Grounds 

Dennis Juranek U.S. Department of Health and Human 

Services, Centers for Disease Control and 

Prevention

Michael Keegan National Rural Water Association

Dave Lawrence Wisconsin Rural Water Assocation

Vanessa Leiby Association of State Drinking Water 

Administrators

Carrie Lewis Milwaukee Water Department

John McLaughlin Brown and Caldwell
Appendix I

Participating Experts on Drinking Water 

Security Panel

Page 68 GAO-04-29 Drinking Water Security

Christine L. Moe Emory University

Erik Olson National Resources Defense Council

Julian Palmore University of Illinois

Janet Pawlukiewicz U.S. Environmental Protection Agency

E.L. Quarantelli University of Delaware

Brian Ramaley Newport News Waterworks

Alan Roberson American Water Works Association

Ken Rubin PA Consultants

Leonard Shabman Resources for the Future

Jim Shell Metropolitan Washington Council of 

Governments

Kimberly Shoaf University of California at Los Angeles

David Spath California Department of Health Services

Mic Stewart Metropolitan Water District of Southern 

California

Billy Turner Columbus Water Works

Ray Yep Santa Clara Valley Water District
Page 69 GAO-04-29 Drinking Water Security

Appendix II

GAO Contacts and Staff Acknowledgments ApendxiI

GAO Contacts John Stephenson, (202) 512-3841

Steve Elstein, (202) 512-6515

Acknowledgments In addition to the individuals named above, important contributions were 

made by Don Cowan, Lynn Musser, Diane Raynes, and Aaron Shiffrin. 

Charles Bausell, Brandon Haller, Katherine M. Raheb, and Carol Shulman 

also made key contributions.

(360364)
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