Wastewater Facilities: Experts' Views on How Federal Funds Should Be Spent to Improve Security
Published: 2005-01-31T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Since the events of September 11, 2001, the security of the nation's drinking water and wastewater infrastructure has received increased attention from Congress and the executive branch. Wastewater facilities in the United States provide essential services to residential, commercial, and industrial users by collecting and treating wastewater and discharging it into receiving waters. These facilities, however, may possess certain characteristics that terrorists could exploit either to impair the wastewater treatment process or to damage surrounding communities and infrastructure. GAO was asked to obtain experts' views on (1) the key security-related vulnerabilities affecting the nation's wastewater systems, (2) the activities the federal government should support to improve wastewater security, and (3) the criteria that should be used to determine how any federal funds are allocated to improve security, and the best methods to distribute these funds. GAO conducted a systematic, Web-based survey of 50 nationally recognized experts to seek consensus on these key wastewater security issues. EPA expressed general agreement with the report, citing its value as the agency works with its partners to better secure the nation's critical wastewater infrastructure.
section_title: What GAO Found
paragraphs: Experts identified the collection system's network of sewer lines as the most vulnerable asset of a wastewater utility. Experts stated that the sewers could be used either as a means to covertly gain access to surrounding buildings or as a conduit to inject hazardous substances that could impair a wastewater treatment plant's capabilities. Among the other vulnerabilities most frequently cited were the storage and transportation of chemicals used in the wastewater treatment process and the automated systems that control many vital operations. In addition, experts described a number of vulnerabilities not specific to particular assets but which may also affect the security of wastewater facilities. These vulnerabilities include a general lack of security awareness among wastewater facility staff and administrators, interdependencies among various wastewater facility components leading to the possibility that the disruption of a single component could take down the entire system, and interdependencies between wastewater facilities and other critical infrastructures. Experts identified several key activities as most deserving of federal funds to improve wastewater facilities' security. Among those most frequently cited was the replacement of gaseous chemicals used in the disinfection process with less hazardous alternatives. This activity was rated as warranting highest priority for federal funding by 29 of 50 experts. Other security-enhancing activities most often rated as warranting highest priority included improving local, state, and regional collaboration (23 of 50 experts) and supporting facilities' efforts to comprehensively assess their vulnerabilities (20 of 50 experts). When asked how federal wastewater security funds should be allocated among potential recipients, the vast majority of experts suggested that wastewater utilities serving critical infrastructure (e.g., public health institutions, government, commercial and industrial centers) should be given highest priority (39 of 50). Other recipients warranting highest priority included utilities using large quantities of gaseous chemicals (26 of 50) and utilities serving areas with large populations (24 of 50). Experts identified direct federal grants as the most effective method to distribute the funds, noting particular circumstances in which a matching contribution should be sought from recipients. Specifically, a matching requirement was often recommended to fund activities that benefit individual utilities. Grants with no matching requirements were often recommended for activities that should be implemented more quickly and would benefit multiple utilities. The other funding mechanisms experts mentioned most frequently included the federal Clean Water State Revolving Fund, loans or loan guarantees, trust funds, and tax incentives.

section_title: Letter
paragraphs: As requested, this report discusses the views of nationally recognized  experts on key issues concerning wastewater security, including the  potential vulnerabilities of wastewater systems; activities that most  warrant federal support to mitigate the risk of terrorism; and the criteria  that the experts believe should be used to determine how any federal funds  are allocated among recipients to improve their security and the methods  the experts suggest should be used to distribute these funds.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. We will then send copies to other appropriate Congressional  Committees and to the Administrator of the Environmental Protection  Agency. We will also make copies available to others upon request. In  addition, the report will be available at no charge on the GAO Web site at  http://www.gao.gov.
If you or your staffs have any questions concerning this report, please  contact me at (202) 512-3841 or stephensonj@gao.gov or my Assistant  Director, Steve Elstein, at (202) 512-6515 or elsteins@gao.gov. Major  contributors to this report are listed in appendix II.
subsections: section_title: Introduction
paragraphs: Wastewater systems in the United States provide essential services to  residential, commercial, and industrial users by collecting and treating  wastewater and discharging it into receiving waters. In light of the events  of September 11, 2001, Congress and the executive branch have placed  increased attention on improving the security of the nation’s water  infrastructure—including wastewater systems—to protect against future  terrorist threats. While more federal resources have been directed toward  drinking water security than wastewater security, some maintain that  wastewater systems, like drinking water systems, also possess  vulnerabilities that could be exploited. The unique characteristics and  components these systems possess provide for the efficient collection,  treatment, and disposal of wastewater—functions that are vital to the  health of the general public and the environment. However, many of these  same characteristics and components have been identified as potential  means for carrying out a terrorist attack. A terrorist could seek to impair a  wastewater system’s treatment process, to use a wastewater system to  carry out an attack elsewhere, or some combination of both.
Documented accidents and intentional acts highlight the destruction that  arises from an attack on a wastewater system. For example, in June 1977 in  Akron, Ohio, an intentional release of naptha, a cleaning solvent, and  alcohol into a sewer by vandals at a rubber manufacturing plant caused  explosions 3.5 miles away from the plant, damaging about 5,400 feet of  sewer line and resulting in more than $10 million in damage.
subsections: section_title: The Nation’s Wastewater Systems and the Populations They Serve
paragraphs: A majority of the nation’s wastewater is treated by publicly owned  treatment works (POTW) that serve a variety of customers, including  private homes, businesses, hospitals, and industry. These POTWs discharge  treated water into surface waters and are regulated under the Clean Water  Act. Nationwide, there are over 16,000 publicly owned wastewater  treatment plants, approximately 800,000 miles of sewers, and 100,000 major  pumping stations. This infrastructure serves more than 200 million people,  or about 70 percent of the nation’s total population. The remainder is  served by privately owned utilities or by on-site systems, such as septic  tanks. This report addresses both public and private wastewater systems.
Though outnumbered by the small systems, the relative handful of large  wastewater systems serve the great majority of people. As depicted in  figure 2, only 3 percent of the nation’s total wastewater systems  (approximately 500 systems) provide service to 62 percent of the  populations served by POTWs. Each of these systems treats more than 10  million gallons per day (MGD) of wastewater.
section_title: Key Components of a Typical Wastewater System
paragraphs: Wastewater systems vary by size and other factors but, as illustrated in  figure 3, all include a collection system and treatment facility.
subsections: section_title: Collection System
paragraphs: The underground network of sewers includes both sanitary and storm  water collection lines that may range from 4 inches to greater than 20 feet  in diameter. Storm water lines tend to be large in diameter in order to  accommodate a variety of precipitation events. Some of the nation’s older  cities have combined sanitary and storm water lines. Sewers are connected  to all buildings and streets within typical communities through indoor  plumbing and curb drains.
Most systems were designed for easy and frequent access to facilitate  maintenance activities. Access for these purposes is usually conducted  through manholes that are typically located approximately every 300 feet.  Many collection systems rely on gravity to maintain the flow of sewage  through the pipes toward the treatment plant. However, the geographic  expanse of a collection system, both in size and topography, may impede  the flow. For this reason, collection systems may depend on pumping  stations to lift the flow to gain elevation for continued gravity flow until the  wastewater reaches the wastewater treatment plant.
section_title: The Wastewater Treatment Plant
paragraphs: Once the wastewater enters the treatment plant (influent) through the  collection system, the treatment process removes contaminants such as  organic material, dirt, fats, oils and greases, nitrogen, phosphorus, and  bacteria. The influent typically undergoes several stages of treatment  before it is released. Primary treatment includes the removal of larger  objects, such as rags, cans, or driftwood, through a screening device or a  grit removal system, and solids are removed through sedimentation.  Secondary treatment includes a biological process that consumes  pollutants, as well as final sedimentation. Some facilities also use tertiary  treatment to remove nutrients and other matter even further. Following  secondary or tertiary treatment, the wastewater is disinfected to destroy  harmful bacteria and viruses. Disinfection is often accomplished with  chlorine, which is stored on-site at the wastewater treatment plant. The  collection and treatment process is typically monitored and controlled by a  Supervisory Control and Data Acquisition (SCADA) system, which allows  utilities to control such things as the amount of chlorine needed for  disinfection.
section_title: Government and Industry Have Recently Sought to Improve Security
paragraphs: In December 2003, the President issued Homeland Security Presidential  Directive-7 (HSPD-7), which established a national policy for federal  departments and agencies to identify and set priorities for the nation’s  critical infrastructures and to protect them from terrorist attacks. HSPD-7  established the Environmental Protection Agency (EPA) as the lead federal  agency to oversee the security of the water sector, both drinking water and  wastewater. Presidential Decision Directive 63 had done so earlier in May  1998, with a focus primarily on drinking water. Based on the 1998 directive,  EPA and its industry partner, the Association of Metropolitan Water  Agencies (AMWA) established a communication system, the Water  Information Sharing and Analysis Center (Water ISAC). The Water ISAC  was designed to provide real-time alerts of possible terrorist activity and  access to a library of information and contaminant databases to water  utilities throughout the nation. In fiscal year 2004, Congress appropriated  $2 million for the Water ISAC, which today serves more than 1,000 users  from water and wastewater systems. In November 2004, the Water ISAC  launched a free security advisory system known as the Water Security  Channel to distribute federal advisories on security threats via e-mail to the  water sector.
EPA recently established a Water Security Working Group to advise the  National Drinking Water Advisory Council (NDWAC) on ways to address  several specific security needs of the sector.  The working group is made up  of 16 members selected on the basis of experience, geographic location,  and their unique drinking water, wastewater, or security perspectives.  It  represents a diverse collection of drinking water and wastewater utilities of  all sizes, state and local public health agencies, and environmental and rate- setting organizations.  The group's charge includes making  recommendations to the full council by the spring of 2005 that identify  features of an active and effective security program and ways to measure  the adoption of these practices.  The working group is also charged with  identifying incentives for the voluntary adoption of an active and effective  security program in the water and wastewater sector.
The Department of Homeland Security (DHS) is also seeking to enhance  communication between critical infrastructure sectors, like the water  sector, with the government. The Homeland Security Information Network  (HSIN) is being developed to provide the water sector with a suite of  information and communication tools to share critical information both  within the sector, across other sectors, and with DHS. According to DHS,  these information and collaboration tools will facilitate the protection,  stability, and reliability of the nation’s critical water infrastructure and  provide threat-related information to law enforcement and emergency  managers on a daily basis. A Water Sector Coordinating Council  established by the department with representative members of the water  sector community is charged with identifying information and other needs  of the sector, including the appropriate use of and the relationships among  ISAC, the Water Security Channel, and HSIN. According to a DHS official,  the department is also assembling a Government Coordinating Council  made up of federal, state, and local officials to assess impacts across  critical infrastructure sectors, including the water sector.
While federal law does not address wastewater security as  comprehensively as it addresses drinking water security, wastewater  utilities have taken steps, both in concert with EPA and on their own, to  protect their critical components. Since 2002, EPA has provided more than  $10 million to help address the security needs of the wastewater sector. A  large portion of this funding has been awarded to nonprofit technical  support and trade organizations including the Association of Metropolitan  Sewerage Agencies (AMSA) and the Water Environment Federation to  develop tools and training on conducting vulnerability assessments to  reduce utility vulnerabilities and on planning for and practicing response to  emergencies and incidents. Also, according to EPA, because of the  relationship between the drinking water and wastewater sectors, much of  the work and funding that has been allocated for drinking water security  also directly benefits the wastewater sector. The Water Environment  Research Foundation, for instance, has been conducting research on cyber  security, real-time monitoring, the effects of contaminants on treatment  systems, and other topics that could benefit both sectors. In addition, EPA  has supported the development of a variety of resource documents for  utilities such as guidance on addressing threats and security product guides  for evaluating available technologies and has offered additional technical  support to small systems.
To assist in the completion of vulnerability assessments, AMSA with EPA  funding cited above, developed technical assistance documents and  software including the Vulnerability Self Assessment Tool (VSAT) that are  available free of charge to water and wastewater systems. The VSAT  methodology and software offers utilities a structured approach for  assessing their vulnerabilities and establishing a risk-based approach to  taking desired actions.
Even though the wastewater industry has not been required by law to  undertake the security measures undertaken by drinking water utilities,  many in the industry maintain that enhanced security must be pursued.  They note, however, that the implementation of security measures imposes  additional financial costs on a sector that is already experiencing difficulty  in meeting the financial challenges of an aging infrastructure. Accordingly,  the industry has sought federal assistance through the congressional  appropriations process. In 2003, Congress responded by considering  legislation that would have authorized $200 million for use in making grants  to wastewater utilities to conduct vulnerability assessments and implement  security improvements, $15 million for technical assistance for small  systems, and $5 million over 5 years for refinement to vulnerability  assessment methodologies.
section_title: Objectives, Scope, and Methodology
paragraphs: As requested by the Chairman and Ranking Minority Member of the Senate  Committee on Environment and Public Works, this report identifies  experts’ views on the following questions:  What are the key security-related vulnerabilities affecting the nation’s  wastewater systems?
What specific activities should the federal government support to  improve wastewater security?
What are the criteria that should be used to determine how federal funds  are allocated among recipients to improve wastewater security, and how  should the funds be distributed?
It was outside the scope of this review to ascertain the desirability of using  federal funds to support wastewater security or to compare the merits of  federal support of the wastewater industry with others such as the electric  power or transportation industries. Rather, we sought to obtain expert  advice on how best to use federal funds to improve wastewater security,  should Congress agree that they should be appropriated for this purpose.
To obtain information on these three questions, we conducted a three- phase Web-based survey of 50 experts on wastewater security. We  identified these experts from a list of more than 100 widely recognized  experts in one or more key aspects of wastewater security. In compiling  this initial list, we also sought to achieve balance in terms of area of  expertise (i.e., state and local emergency response, preparedness,  engineering, epidemiology, public policy, security, wastewater treatment,  risk assessment, water infrastructure, bioterrorism, and public health).
In addition, we sought experts from (1) key federal organizations (e.g.,  DHS, EPA, and National Science Foundation); (2) key state and local  agencies, including health departments and environmental protection  departments; and (3) key industry and nonprofit organizations such as  AMSA, Environmental Defense, Water Environment Federation, and the  Water Environment Research Foundation; and (4) water utilities serving  populations of varying sizes. Of the approximately 70 experts we  contacted, 50 agreed to participate and complete all three phases of our  survey. A list of the 50 participants in this study is included in appendix I.
To obtain information from the expert panel, we employed a modified  version of the Delphi method. The Delphi method is a systematic process  for obtaining individuals’ views and seeking consensus among them on a  question or problem of interest. Since first developed by the RAND  Corporation in the 1950s, the Delphi method has generally been  implemented using face-to-face group discussions. For this study, however,  we adapted the method to use on the Internet. We used this approach, in  part, to eliminate the potential bias associated with group discussions.  These biasing effects include the dominance of individuals and group  pressure for conformity. Moreover, by creating a virtual panel, we were  able to include many more experts than possible with a live panel, allowing  us to obtain a broad range of opinions.
For each phase in our three-phase Delphi process, we posted a  questionnaire on GAO’s survey Web site. Panel members were notified of  the availability of the questionnaire with an e-mail message. The e-mail  message contained a unique user name and password that allowed each  respondent to log on and fill out a questionnaire but did not allow  respondents access to the questionnaires of others.
In the survey’s first phase, we asked a series of open-ended questions. We  pretested these questions with officials from the wastewater utility  industry, nonprofit research groups, and a federal agency. Responses were  content analyzed to provide the basis for the questions asked in the  subsequent phases. Phase 2 questions were close-ended and asked experts  to rate the relative priority or effectiveness of the Phase 1-identified  security activities, allocation criteria, and funding mechanisms. Experts  were also invited to provide narrative comments.
During the third phase, we provided experts with aggregate group results  from Phase 2, along with their own individual answers to the Phase 2  questionnaire. Experts were asked to compare the group results with their  own individual answers and to use this information as a basis for  reconsidering their answers and revising their individual responses, if so  desired.
In addition to the information obtained from our expert panel, we obtained  documentation from representatives of professional organizations, such as  the National Academy of Sciences, the Water Environment Research  Foundation, and AMSA. We also held interviews with EPA on the agency’s  wastewater security programs. During our interviews, we asked officials to  provide information on program operations, policies, guidance, and  funding levels. We also received training on VSAT from the Water  Environment Federation, which was supported by AMSA, and attended  specialized conferences addressing water security by the American Water  Works Association and other organizations.
We conducted our work from January 2004 through December 2004 in  accordance with generally accepted government auditing standards.
section_title: Experts Identified Key Vulnerabilities That Could Compromise Wastewater Security
paragraphs: Experts responding to our survey identified five key physical assets of  wastewater systems as among the most vulnerable to terrorist-related  attacks: (1) the collection systems’ network of sewers, which includes  underground sanitary, stormwater and combined sewer lines; (2) treatment  chemicals, primarily chlorine, which are used to disinfect wastewater; (3)  key components of the wastewater treatment plant, such as its headworks,  where the raw sewage first enters the treatment plant; (4) control systems,  used to control plant operations; and (5) pumping stations along the  collection system, which lift or pump wastewater to allow gravity flow to  help move sewage to the treatment plant (see fig. 4). Of these assets,  experts ranked the collection systems’ network of sewers and treatment  chemicals as the most vulnerable.
Experts also identified overarching vulnerabilities that could compromise  the overall integrity of the systems’ security. These vulnerabilities include  (1) a general lack of security awareness within the wastewater sector; (2)  interdependencies among components of the wastewater system, opening  the possibility that a failure of any individual component could bring down  the entire system; and (3) interdependencies between the wastewater  system and other critical infrastructure that could fail, such as electric  power supplies.
In general, our panel of experts’ observations were consistent with those of  major organizations that have conducted research on wastewater system  vulnerabilities. Among these organizations are the Water Environment  Federation and the Association of Metropolitan Sewerage Agencies.
subsections: section_title: Experts Identified Five Key Vulnerabilities
paragraphs: The five assets experts considered most vulnerable included the collection  systems’ network of sewer lines, treatment chemicals, key components of  the wastewater treatment plant, control systems, and pumping stations.
subsections: section_title: Collection Systems’ Network of Sewers
paragraphs: Forty-two of the 50 experts we surveyed identified the collection systems’  network of sanitary, storm, and combined sewer lines as among the top five  terrorist-related vulnerabilities of wastewater systems. Experts explained  that adversaries could use the network of sewers to (1) covertly gain  access to intended targets within the service area or to (2) convey  hazardous or flammable substances that may cause explosions at points  along the system or cause harm to the wastewater treatment system or  process.
Access controls to important installations, such as perimeter fencing, can be countered by a  terrorist gaining access to the facility unseen by using the underground collectors. Once  access is gained, any activity could then occur—target reconnaissance or surveillance,  planting of conventional explosives or weapons of mass destruction, hostage taking,   theft of critical documents and items.
Many experts also suggested that adversaries could use the collection  system as an underground transport system—without ever physically  entering the system—for explosive or toxic agents. These substances could  be inserted into the system through storm drains, manholes, or household  drains. Several experts explained that with prior knowledge of a system’s  gravity flow, an adversary could calculate the precise timing and location of  an explosion or calculate the amount of a substance that might be  necessary to disable or destroy the biological processes of a wastewater  treatment plant.
However, even without precise knowledge about a system, significant  damage can occur as a result of underground sewer explosions. These  explosions may also damage natural gas or electric lines often co-located  with sewers. One expert cited the effects of an unintentional explosion that  occurred in 1981 in Louisville, Kentucky, where thousands of gallons of a  highly flammable solvent, hexane, spilled into the sewer lines from a local  processing plant. The fumes created an explosive mixture that was  eventually ignited by a spark from a passing car. The result was a series of  explosions that collapsed a 12-foot diameter pipe and damaged more than 2  miles of streets. While no one was seriously injured, sewer line repairs took  20 months, followed by several more months to repair the streets. A more  serious incident occurred in Guadalajara, Mexico, when a gasoline leak  into a sewer, in April 1992, caused explosions that killed 215 people, injured  1,500 others, damaged 1,600 buildings, and destroyed 1.25 miles of sewer.  The explosion created craters as deep as 24 feet and as large as 150 feet in  diameter. Another alarming incident was an intentional release of a  cleaning solvent (naptha) and alcohol into a sewer that caused explosions  3.5 miles away from the source and damaged about 5,400 feet of sewer line.  This June 1977 incident in Akron, Ohio, by vandals at a rubber  manufacturing plant resulted in more than $10 million in damage.
Adversaries may also use the system to convey substances that disable the  treatment process. For example, as one expert explained, an adversary  could introduce a highly toxic chemical into the sewer that could damage  the biological processes involved in treatment. Several experts warned that  disabling the treatment process could cause the release of improperly  treated sewage, placing the receiving water in jeopardy and potentially  harming human health and the environment. In February 2002, such an  incident occurred in Hagerstown, Maryland, when chemicals from an  unknown source entered the wastewater treatment plant and destroyed the  facility’s biological treatment process. This incident resulted in the  discharge of millions of gallons of partially treated sewage into a major  tributary of the Potomac River, less than 100 miles from a water supply  intake for the Washington, D.C., metropolitan area.
section_title: Wastewater Treatment Chemicals
paragraphs: Thirty-two of the 50 experts we surveyed identified process chemicals used  in wastewater treatment as among the top five terrorist-related wastewater  system vulnerabilities. Wastewater treatment facilities use a variety of  chemicals, including chlorine, sulfur dioxide, and ammonia during the  treatment process. Most experts singled out chlorine gas as a major  chemical of concern because it is an extremely volatile and hazardous  chemical that requires specific precautions for its safe transport, storage,  and use.
Chlorine is a disinfectant that is commonly used in the treatment process  before treated water (effluent) is discharged into local waterways.  However, if chlorine, which is stored and transported as a liquefied gas  under pressure, is accidentally released into the atmosphere, it quickly  turns into a potentially lethal gas. Because gaseous chlorine is heavier than  air, the cloud it forms tends to spread along the ground. Consequently,  accidental or intentional releases of chlorine could be extremely harmful to  those in the immediate area. Exposures to chlorine could burn eyes and  skin, inflame the lungs, and could be deadly if inhaled. One expert pointed  out that accidental releases of chlorine gas have occurred numerous times  and that a deliberate release would be relatively feasible. The expert  further explained that many wastewater plants have been converting from  chlorine gas to alternative disinfection methods for various reasons,  including the risk of a release.
Recognizing that chlorine gas releases pose threats to the public and the  environment, EPA requires, among other things, that any facility storing at  least 2,500 pounds of chlorine gas submit a risk management plan; as of  December 2004, EPA estimates that about 1,200 plants fit this category. The  plan includes an estimate of the potential consequences to surrounding  communities of hypothetical accidental “worst-case” chemical releases  from their plants. These estimates include the residential population  located within the range of a toxic gas cloud produced by a “worst-case”  chemical release, called the vulnerable zone.
Several experts stated that a terrorist could use chlorine gas as a weapon,  either at a wastewater plant that is in close proximity to a specific target  population, or through theft and use at another location. In fact, on  September 11, 2001, railroad tanker cars filled with toxic chemicals  including chlorine sat at a treatment plant across the river from the  Pentagon as it was being attacked. At that time, the population within the  plant’s vulnerable zone was 1.7 million people. Within weeks after  September 11, this facility converted to an alternative disinfection method.  Other facilities have also eliminated the use of chlorine gas, choosing  instead chlorine-based technologies (e.g., sodium hypochlorite, calcium  hypochlorite, mixed oxidant generation) or nonchlorine-based  technologies (e.g., ozone and ultraviolet light). However, as one expert  noted, several dozen wastewater treatment plants in heavily populated  areas continue to use large amounts of chlorine gas.
In addition to concerns over on-site chlorine storage, experts were also  concerned about the safe transport of chemicals to treatment facilities.  Chlorine is delivered to facilities via railways and highways and in various  container sizes ranging from 1-ton cylinders to 90-ton railroad cars (see  figs. 5 and 6). As experts noted, although rail tank cars are designed to  avoid leakage in the event of a derailment, and the containers can  theoretically withstand a bullet from a normal handgun or rifle, one expert  concluded that the “use of explosives to cause a rupture is well within the  skill set of a terrorist.”
Such an attack along a congested transportation corridor could have severe  public health and safety impacts. One expert said that before converting  from chlorine to alternative disinfection methods, a major wastewater  treatment plant in Washington, D.C., received its chlorine supply via rail  shipments that traversed through the center of the city, close to the U.S.
Capitol Building and across two military installations before reaching its  final destination. Derailments of chlorine could have major impacts in  small communities as well, as occurred in Alberton, Montana, in April 1996.  One of the five tankers that derailed ruptured and reportedly released more  than 60 tons of chlorine. Subsequently, a toxic plume of chlorine gas  crossed the Clark Fork River, a major interstate, and surrounding  residences. An estimated 1,000 people were evacuated, 350 people were  hospitalized, and one person died.
section_title: Key Components of the Treatment Plant
paragraphs: In addition to the vulnerability of chemicals stored at a wastewater  treatment plant, experts also listed the key process components of the  treatment plant as vulnerable. Specifically, more than half of the experts  (29 of 50) identified one or more of these components as among the top five  vulnerabilities. One expert explained that, historically, security was not a  consideration in site selection or design of these facilities. While many  utilities planned for natural disasters or vandalism, it was only after  September 11, that many utilities have considered how best to protect  against potential terrorist attacks.
While experts expressed concern over the security of the entire treatment  plant, several identified the headworks as a component that is particularly  vulnerable to attack, as well as critical to the treatment process. This unit is  part of a plant’s primary treatment process, where wastewater carried  through the collection system first enters the treatment plant. It is here that  large objects, such as cans, wood, and plastics are removed from the  wastewater stream. These structures may be open to the atmosphere and,  according to one expert, are easy to attack. Experts explained that  sabotage of the headworks could affect the proper working order of  subsequent treatment processes and could cause the immediate  interruption of the collection system, potentially restricting or completely  blocking wastewater flow. As one expert noted, restricted flow would  could cause backups through the collection system, and the stagnant  wastewater would become a public health hazard within hours, either  through physical contact or through cross-contamination of drinking water  supplies.
section_title: Control Systems
paragraphs: Control systems were also listed as a key vulnerability by 18 of the 50  experts. Many wastewater systems are increasingly relying on the use of  these control systems, including Supervisory Control and Data Acquisition  (SCADA) networks, to serve functions ranging from storing and processing  data to monitoring the system’s condition and controlling its operation. The  primary role of SCADA systems is to monitor and control dispersed assets  from a central location. According to one expert, “The backbone for  process control is the SCADA system.” The expert explained that several  factors contribute to the vulnerability of these controls, including typically  nonsecured process control rooms at treatment plants, remote access to  SCADA, and shared passwords between multiple users.
Experts generally explained that an attack on these systems could interfere  with critical operations. For example, one expert explained that an  adversary could use SCADA systems to introduce either dangerously high  or inadequate levels of chemicals; reduce biological treatment levels; or  cause remote points along the collection system to fail. Although some  facilities could operate their systems manually should the automated  system fail or be compromised, others do not have the personnel or  equipment to do so. For example, as one expert noted, large valves in  modern plants are now typically operated electronically and seldom used  manual operation components (see fig. 7).
While SCADA networks offer operators increased flexibility and efficiency  by controlling processes remotely, they were not designed with security in  mind. The security of these systems is, therefore, often weak. According to  our experts, while many facilities take advantage of their system’s  flexibility, they often do not provide the necessary training on cyber  security or implement security measures such as rotating passwords or  securing network connections. Experts also explained that penetration of  SCADA systems, particularly those that may be nonencrypted and accessed  via the Internet, offers a particularly easy point of access and control of a  wastewater system. One expert provided an example of a breach in cyber  security in 2000 when such a system in Australia was attacked, causing the  release of thousands of gallons of raw sewage. While the actions were not  an act of terrorism, they illustrate how a computer or cyber-related attack  could be used to disrupt wastewater treatment.
section_title: Pumping Stations
paragraphs: Sixteen of the 50 experts identified pumping stations, which are  components that help convey sewage to the wastewater treatment plant, as  among the top vulnerabilities. One expert explained that destroying or  disabling a pumping station could cause the collection system to overflow  raw sewage into the streets and into surface waters and to back up sewage  into homes and businesses. The expert added that adverse effects on public  health and the environment are likely if the target pump station pumps  several million gallons per day of wastewater. Another expert explained,  that within a service area, one pumping station has the capacity to pump 25  million gallons of wastewater per day.
Experts explained that the remoteness and geographic distribution of  pumping stations, and their lack of continuous surveillance, make them  particularly vulnerable (see fig. 8). However, as one expert noted, should  these stations be disabled or destroyed, alternatives such as “pump-around  schemes,” where sewage flow is diverted and rerouted, can often be  implemented within a few days or weeks.
section_title: Overarching Vulnerabilities Affecting Overall Wastewater System Security
paragraphs: In addition to the physical assets identified as among the greatest  vulnerabilities of wastewater systems, some experts also identified  vulnerabilities that may affect the overall security of the nations’  wastewater systems. First, they pointed out that wastewater utilities  generally do not have a security culture because they are often more  focused on operational efficiency and may, therefore, be reluctant to add  security procedures and access control elements to their operations. For  example, one expert noted the ease with which many types of individuals  (employees, contractors, and visitors) and vehicles typically enter  wastewater treatment plant facilities. As this expert pointed out, some  facilities do not check to ensure that individuals entering the property have  legitimate reasons for being there. This expert also raised a concern about  the lack of inspection of incoming truckloads at some wastewater  treatment plants. An adversary could exploit this lack of security by  delivering contaminants or explosives to destroy the treatment process or  the entire facility. In addition to securing entrance checkpoints, two  experts suggested there is little background screening of utility employees.  One expert noted, “People with criminal records, falsified educational  credentials, and other serious liabilities might be hired by utilities that fail  to thoroughly check their backgrounds. The result can be intentional acts  of terrorism on a utility.”
Second, experts pointed to interdependencies among all major wastewater  assets within the treatment system. The system as a whole relies on the  proper working order of all its components to treat a community’s  wastewater. One expert explained that, because treatment plants are less  able to recover from an attack, they may have a higher level of security  than other assets, such as the collection system. However, because  collection and treatment are part of one integrated system, securing one  asset does not ensure that the system as a whole is more protected. For  example, gates and fences around the main treatment plant may stop an  adversary from coming onto the physical property, but it will not prevent a  harmful agent from entering the facility through the collection system—an  event that could destroy the facility’s entire secondary treatment process.
Third, experts identified interdependencies between wastewater systems  and other critical infrastructures. As several experts explained, disruptions  in electric power, cyber systems, and transportation of treatment chemicals  can result in a failure of wastewater treatment systems. One expert  cautioned that the interruption of the power grid could render the  wastewater plant useless, noting, “Several hours without power would  cause the biological treatment process to halt and wastewater would back  up on the collection system.” Such an event occurred in 2003, when a major  power failure caused treatment plants in Cleveland, Ohio, to release at least  60 million gallons of raw untreated wastewater into receiving waters.  Without electric power, operators had no other option but to bypass  treatment and directly discharge the untreated sewage into Lake Erie or the  Cuyahoga River and other tributaries.
Conversely, there are instances in which other infrastructure and activities  may depend on treated wastewater to properly function. For example, in  some parts of the country, effluent is reclaimed and used as cooling water  for power generation, to recharge groundwater, or to water outdoor  landscapes. One expert noted that wastewater treated at a plant in the arid  Western United States is reclaimed and used to provide the only cooling  source for a nuclear power plant that provides power for much of that  region. According to the same expert, the immobilization of this treatment  plant could, within a certain number of days, disable the nuclear plant,  causing a major, multistate power outage.
section_title: Experts Identified Wastewater Security- Enhancing Activities That Warrant Federal Support
paragraphs: Experts most frequently identified 11 specific activities to improve  wastewater security as deserving high priority for federal support (see fig.  9). Three activities are particularly noteworthy because they were given a  rating of highest priority by a substantial number of the experts. These  activities include the following:   Replacing gaseous chemicals used in wastewater treatment with less  hazardous alternatives. Experts viewed these actions as essential to  reduce the vulnerability inherent in systems that rely upon the transport,  storage, and use of potentially hazardous materials such as gaseous  chlorine in their treatment processes. Several experts noted that  replacement could be cost prohibitive for many wastewater utilities and  that it, therefore, warranted federal support.
Improving local, state, and regional collaboration efforts. Experts  identified the development of strong working relationships among  utilities and public safety agencies as critical to protecting wastewater  infrastructure and system customers from potential threats. Some  experts also noted that enhanced partnerships among these groups  would result in improved response capabilities should a wastewater  system be attacked.
Completing vulnerability assessments for individual wastewater  systems. Experts cited these as necessary for utilities to understand  their security weaknesses, to identify appropriate countermeasures, and  to implement risk reduction strategies in a logical, coordinated manner.
The remaining eight activities experts frequently rated as warranting high  or highest priority for federal funding include (1) providing training to  utility employees related to conducting vulnerability assessments and  improving the security culture among employees; (2) improving national  communication efforts between utilities and key entities responsible for  homeland security; (3) installing early warning systems in collection  systems to monitor for or detect sabotage; (4) hardening physical assets of  treatment plants and collection systems; (5) strengthening operations and  personnel procedures; (6) increasing research and development efforts  toward improving threat detection, assessment, and response capabilities;  (7) developing voluntary wastewater security standards and guidance  documents; and (8) strengthening cyber security and Supervisory Control  and Data Acquisition (SCADA) systems.
subsections: section_title: Replace Gaseous Chemicals with Less Hazardous Alternatives
paragraphs: Over half of the experts surveyed (29 of 50) rated the replacement of  gaseous chemicals at wastewater treatment facilities with less hazardous  alternatives as warranting highest priority for federal funding. Another 14  experts rated this activity as high priority. Experts reported that  wastewater systems carrying out treatment processes using gaseous forms  of chemicals, particularly chlorine, make themselves targets for terrorist  attack. However, as one expert noted, changing disinfection technologies  effectively devalues these facilities as targets for “weaponization” of their  existing infrastructure.
Several experts noted that some communities and utilities currently using  gaseous chemical treatment processes have expressed interest in  converting to an alternative treatment technology, but the financial costs  associated with conversion remain prohibitive. However, one stated that  replacing gaseous chemical treatment technology can actually result in  certain offsetting cost savings. For example, the Blue Plains Wastewater  Treatment Plant in Washington, D.C., employed around-the-clock police  units prior to replacing its chlorine gas treatment process. Following  conversion to a less hazardous treatment technology, Blue Plains found  that it could reduce this security posture. In addition, the utility was able to  reduce the need for certain emergency planning efforts and regulatory  paperwork.
Experts suggested alternative treatment technologies such as sodium  hypochlorite (a solution of dissolved chlorine gas in sodium hydroxide)  and ultraviolet disinfection. These alternative processes have been  implemented at several facilities throughout the United States, including  Washington, D.C.; Atlanta, Georgia; Philadelphia, Pennsylvania; Cincinnati,  Ohio; Jacksonville, Florida; and Harahan, Louisiana. The change, for an  individual plant, to sodium hypochlorite may require approximately $12.5  million for new equipment and increase annual chemical costs from  $600,000 for gaseous chlorine to over $2 million for sodium hypochlorite.
Another expert suggested that reducing the size of containers used to  transport and store gaseous chemicals could also prove an effective  deterrent to terrorism. This approach is being implemented by a treatment  plant in the Western United States, where gaseous chlorine is now stored in  1-ton canisters—a significant reduction in size from the larger 90-ton  railroad tanker car size containers the utility previously employed   (see fig. 10).
section_title: Improve Local, State, and Regional Collaboration Efforts
paragraphs: Twenty-three of 50 experts rated efforts to improve local, state, and  regional collaboration as warranting highest priority for federal funding.  Fifteen more experts rated this activity as high priority. Several experts  noted the importance of establishing strong working relationships among  utilities, local and state law enforcement agencies, fire departments, and  other first response agencies in advance of a potential emergency situation.  Many added that enhanced partnerships among these entities can yield  significant benefits to wastewater utilities including an increased ability to  monitor critical infrastructure and facilities, improved understanding of  agency roles and responsibilities, and faster response time to deal with  potential security breaches.
According to one expert, significant personnel and other resources devoted  to emergency response are theoretically available to the wastewater sector.  These resources include law enforcement agencies, fire departments,  public health care facilities, environmental authorities, and other nonprofit  and commercial entities. However, the expert noted that wastewater  facilities remain largely disconnected from these entities, and wastewater  facilities’ efforts for emergency response planning are, therefore, often  undertaken independently. Consequently, emergency response teams do  not gain a full understanding or appreciation of the unique challenges  inherent in maintaining a utility’s wastewater treatment capability.
This lack of collaboration perpetuates the community’s idea that “sewers  lead to  magical place where  simply ‘go away’ without  consequence,” one expert suggested. The expert added that this  misperception is demonstrated by a failure of some in the medical response  community to adequately plan for proper disposal of waste resulting from  decontamination efforts of a chemical, biological, or radiological event.  Directly discharging such material to the wastewater influent stream could  significantly damage or destroy the wastewater treatment process.
Collaboration among local, state, and regional agencies should include  periodic field and “tabletop” exercises to establish and reevaluate the roles,  capabilities, and responsibilities of agencies that would respond to a  terrorist event, according to one expert. Another identified the nonprofit  California Utilities Emergency Association, an entity to which most utilities  in that state belong, as an effective provider of communications, training,  mutual aid coordination, and simulation exercises. The expert also cited  the San Francisco Bay Area Security Information Collaborative as a  successful example of regional collaboration in which participating water  utilities coordinate communications, responses, and emergency planning.
The Environmental Protection Agency (EPA) has provided funding for  training on emergency response for wastewater utilities through  agreements with the Wastewater Operator State Environmental Training  Program, the Water Environment Federation, and other organizations.  Through the Department of Homeland Security’s Office of Domestic  Preparedness, EPA has funded emergency response table-top exercise  training to the nation’s larger wastewater utilities.
section_title: Complete Vulnerability Assessments
paragraphs: Twenty of 50 experts rated the completion of vulnerability assessments as  warranting highest priority for federal funding. Fourteen other experts  rated this activity as high priority. Vulnerability assessments help water  utilities evaluate their susceptibility to potential threats and identify  corrective actions to reduce or mitigate the risk of serious consequences  from vandalism, insider sabotage, or terrorist attack. One expert explained  that this process enables a utility to evaluate its terrorist-related  vulnerabilities and begin to implement security enhancement plans that  directly address those identified vulnerabilities. Another added that the  assessments also present useful findings that should be incorporated into a  utility’s emergency response plan and that they enable an active process for  updating and exercising those plans.
The Bioterrorism Act of 2002 required vulnerability assessments for  drinking water utilities serving more than 3,300 people but did not include a  comparable requirement for wastewater utilities. To foster the completion  of vulnerability assessments among wastewater utilities, EPA has funded  the development of vulnerability assessment methodologies and provided  training to wastewater utilities. EPA has encouraged wastewater utilities to  use methodologies such as those provided by the National Environmental  Training Center for Small Communities, on security and emergency  planning, and the Vulnerability Self Assessment Tool (VSAT), developed  and released by the Association of Metropolitan Sewerage Agencies. The  VSAT methodology and accompanying software provide an interactive  framework for utilities of all sizes to analyze security vulnerabilities to both  manmade threats and natural disasters, evaluate potential  countermeasures for these threats, and enhance response capability in the  event of an emergency situation. This methodology has been continually  updated and improved; VSAT Version 3.1 is currently available to utilities.  Through EPA support, the Water Environment Federation has provided  extensive training of the VSAT tool free of charge to wastewater utility  operators and others involved in environmental protection, public safety,  and security.
section_title: Expand Training Opportunities for Wastewater Utility Operators and Administrators
paragraphs: Thirteen of the 50 experts rated the expansion of training opportunities for  utility personnel as warranting highest priority for federal funding, and an  additional 27 experts suggested this activity warranted a high priority.  According to experts, creating a security-minded culture among  wastewater utilities is critical to building awareness of security  vulnerabilities and implementing appropriate countermeasures.
In particular, experts noted that wastewater system operators and  administrators need to become better educated about the importance of  focusing on security and emergency preparedness issues. Several experts  suggested that managers should have a full understanding of potential  types of terrorist attacks and the systems or mechanisms that could  preclude or mitigate these events. They added that other parties, including  boards of directors of wastewater systems, mayors, and city councils need  to be made aware of potential threats to wastewater systems and the  impact a terrorist event could have upon a facility. One expert stated that  successful development of security awareness among those associated  with wastewater systems could mean the difference between simply  installing security systems and actually becoming secure.
Experts also stated that additional technical training for operators is  necessary to ensure the security of wastewater systems. One noted that  this type of training could avert a catastrophe by enabling a wastewater  operator to recognize a pending disaster as early as possible. Another  expert stated that increased technical training, particularly for smaller  wastewater utilities, is necessary to ensure that funds for physical security  enhancements are used to their maximum potential, thus achieving  maximum benefit for the wastewater utility. One expert also suggested that  devoting funding toward increased technical training will provide  wastewater utility employees with the skills necessary for developing  comprehensive vulnerability assessments and implementing emergency  response plans before a terrorist attack.
Since 2002, EPA has provided more than $10 million to help address the  security needs of the wastewater sector. A large portion of this funding has  been awarded to nonprofit technical support and trade organizations to  develop tools and training on conducting vulnerability assessments to  reduce utility vulnerabilities and on planning for and practicing response to  emergencies and incidents.
section_title: Improve National Communication Efforts between Utilities and Key Entities Responsible for Homeland Security
paragraphs: While only 8 of 50 experts rated efforts to improve communications  between utilities and federal entities responsible for homeland security as  warranting highest priority for federal funding, well over half of the experts  surveyed (31 of 50) rated this activity as high priority. One expert stated  that it is essential to develop an effective communications strategy that  involves the broad range of stakeholders responsible for ensuring  wastewater security. Another emphasized that wastewater utilities need  timely and useful information from federal authorities about increased  threat levels and protective actions that should be implemented.
To improve national communications, EPA provided a grant to AMWA to  develop the Water Information Sharing and Analysis Center (Water ISAC).  The Water ISAC is a secure, Internet-based subscription service that  provides time-sensitive information and expert analysis on threats to both  wastewater and drinking water systems. It serves as a key link in the flow  of water security information among utilities and federal homeland  security, intelligence, law enforcement, public health, and environmental  agencies.
However, according to some experts, Water ISAC does not sufficiently  ensure adequate communication between federal agencies and utilities.  One stated that despite a high reliance upon Water ISAC by drinking water  utilities, this communication vehicle has proven inadequate for meeting the  needs of the broad range of stakeholders involved in protecting drinking  water security. This expert added that the Water ISAC needs to be better  developed if it is to be an essential part of a communications strategy for  the wastewater sector. Another expert noted that several water utilities  have avoided the Water ISAC because of the subscription fees associated  with the service. In the fall of 2004, the Water ISAC announced a new  communication tool known as Water Security Channel. The Water Security  Channel is a password protected site that electronically distributes federal  advisories regarding threat information to the water sector. Water Security  Channel is a service that is free of charge to any wastewater or drinking  water utility that wishes to participate.
For its part, the Department of Homeland Security is implementing its  Homeland Security Information Network (HSIN) initiative, which will  provide a real-time, collaborative flow of threat information to state and  local communities, as well as to individual sectors. According to the  department, this network will be the only tool available that provides  collaborative communications between first responders, emergency  services, the government (local, state, and federal) and other sectors on a  real-time basis. In addition, the department has established a Water Sector  Coordinating Council to identify information and other needs of the sector,  including the appropriate use and the relationships among the Water ISAC,  the Water Security Channel, and HSIN.
section_title: Install Early Warning Systems in Collection Systems to Monitor for or Detect Sabotage
paragraphs: Seven of 50 experts rated the installation of early warning systems in  collection systems to monitor for or detect sabotage as warranting highest  priority for federal funding, and an additional 31 experts rated this activity  as a high priority. A device these experts frequently mentioned to achieve  some degree of monitoring and detection for explosive substances is the  lower explosive level (LEL) meter, which can be inserted into manholes  and connected to central computers. One expert claimed LEL meters have  significantly improved response time in mitigating the potential for  structural damages resulting from explosions within the wastewater  collection system.
One expert also noted that disabling the biological processes occurring at a  wastewater treatment plant would require a large amount of toxic  compounds to be inserted into the collection system, but several experts  stated that this possibility remains of concern because of the open access  collection systems afford. Many experts suggest that additional research is  needed to develop early warning technologies that can sense the presence  and concentration of these types of toxic compounds in the collection  system and relay that information electronically to treatment operators.
section_title: Harden Physical Assets of Treatment Plants and Collection Systems
paragraphs: Eight of 50 experts rated physical hardening of treatment plants and  collection systems as warranting highest priority for federal funding and an  additional 29 experts rated this activity as high priority. Experts stated that  physically securing the perimeter of the treatment plants and pumping  stations with fences, locks, security cameras, alarm systems, motion  detection systems, and other physical barriers can protect critical  treatment components from direct attack or sabotage (see figs. 11 and 12).  One expert noted that the more difficulty terrorists encounter in trying to  reach critical targets in a wastewater system, the less frequently attacks  will be attempted, and the lesser the impact will be if and when these  attempts succeed. Furthermore, improvements to perimeter defenses  surrounding wastewater treatment systems not only deter terrorist  intruders but also restrict access by vandals, contributing toward improved  reliability of electronic surveillance systems. As one expert pointed out,  physical hardening of assets can largely be accomplished with hardware  that requires only minimal maintenance and replacement cost once  installed.
Other experts suggested that actions are needed to provide redundant  capabilities to wastewater treatment systems. According to experts,  additional power, pumping, and collection bypass systems would provide  more reliable treatment capacity that would benefit the public not only in  the event of terrorism but also during nonterrorist events (e.g., natural  disasters, weather-related events, or interrelated infrastructure failures).
Such actions could ensure that wastewater systems maintain full treatment  capabilities during a variety of unforeseen catastrophic events.
Although one expert claimed that protecting the several hundred miles of  sewers in a large urban system is virtually impossible, other experts  suggested that design improvements and physical alterations could limit  access to collection systems. Some experts suggested securing manhole  covers with maintenance-friendly lockdown mechanisms. In addition, one  expert suggested improving engineering designs for wastewater systems in  ways that reduce vulnerability risks posed by infrastructure cross- connections with other water systems.
section_title: Strengthen Operations and Personnel Procedures
paragraphs: Seven of 50 experts rated the strengthening of operations and personnel  procedures at wastewater systems as warranting highest priority for  federal funding, and an additional 24 experts rated this activity as a high  priority. For example, one expert suggested that a highly efficient  background check system should be available to water utilities to get  accurate information on new and existing employees, contractors, and  others who are working at vital facilities, such as wastewater treatment  plants. This expert noted that access to such systems is afforded to airport  administrators and certain law enforcement entities but is largely  inaccessible to water utilities.
Another expert stated that wastewater utilities need procedures to ensure  the security of collection system maps and drawings, while also allowing  reasonable access to them by contractors and developers. The expert  suggested maps could be electronically stored and password protected  with a regularly changed password. Another expert suggested that all  employees and visitors have identification badges with photographs and  electronic strips or sensors that regulate points of access allowed by the  badge.
section_title: Increase Research and Development Efforts to Improve Detection, Assessment, and Response Capabilities
paragraphs: Thirteen of 50 experts rated expanded research and development efforts to  improve detection, assessment, and response capabilities for wastewater  systems as warranting highest priority for federal funding, and an  additional 17 experts suggested this activity warranted a high priority. One  expert stated that new technologies are needed in the wastewater sector to  better protect physical assets by providing reliable surveillance and  detection capabilities with a minimal need for on-site, around-the-clock  security personnel. According to another expert, technologies currently in  development for drinking water utilities could potentially be adapted for  use by wastewater utilities. These technologies would need to detect  hazardous chemical, biological, or radioactive contaminants while  operating in the harsh environment of common, everyday contaminants  found in sewage. Also, improved computer mapping systems tracking the  course and speed of sewage flow could greatly enhance emergency  response activities including evacuations, dilutions of harmful substances  that have been introduced to the sewage flow, and venting of volatile  materials.
EPA’s Office of Research and Development has recently funded research  that is intended to address many of these needs. According to an official  with EPA’s Water Security Division, while these efforts have been primarily  directed toward drinking water security research, some of EPA’s research  findings can be applied to wastewater security. EPA has also developed a  water security research and technical support action plan that outlines  various research and technical support needs that the water industry and  other stakeholders have identified. The plan also proposes specific projects  to address these needs, and EPA has begun work on some of these projects  in collaboration with the Water Environment Research Foundation and the  American Water Works Association Research Foundation. These nonprofit  research organizations have received funding to address a variety of  wastewater security research projects, such as assessing new security  technologies to detect and monitor contaminants and prevent security  breaches. According to EPA, other issues being addressed include public  health protection, vulnerability and protection of water and wastewater  infrastructure, and communication in the event of deliberate attacks or  natural disasters.
section_title: Develop Voluntary Wastewater Security Standards and Guidance Documents
paragraphs: Four of 50 experts rated the development of voluntary wastewater security  standards and guidance documents as warranting highest priority for  federal funding, and half of the experts surveyed (25 of 50) gave this  activity a high priority rating. Experts identified options including  development and issuance of voluntary standards for security of  wastewater facilities (including design standards), a peer review process to  evaluate the quality of wastewater utilities’ vulnerability assessments and  emergency response plans, and creation of a secure Web site that  disseminates lessons learned by utilities throughout the various phases and  processes related to protecting wastewater security.
One expert suggested that developing government standards for the  security of all new facilities would help increase the overall ability of  wastewater systems to withstand threats. The expert stated such standards  should lay out minimum protection standards and provide a framework of  threats utilities should consider when completing vulnerability  assessments. Another expert suggested that, because water utilities seek  guidance from the federal government on whether their individual  treatment plants are secure, one option, in lieu of site visits by EPA, might  be a peer review process of vulnerability assessments and emergency  response plans across wastewater utilities. Development of a secure Web  site for wastewater utilities that includes lessons learned from  assessments, planning, training, and incident responses could also provide  valuable guidance for wastewater utilities, one expert noted.
EPA recently commissioned a study by the National Drinking Water  Advisory Council’s Water Security Working Group to address some of these  needs. The group’s charge is to identify: (1) the features of an active and  effective security program for drinking water and wastewater utilities; (2)  incentives that would encourage water utilities to implement features of  the security program; and (3) ways to measure the extent of utility  implementation of the security program. In addition, in September 2003,  EPA gave funding to the American Society of Civil Engineers to develop  voluntary security standards for drinking water, wastewater, and  stormwater utilities, which were released in December 2004 as interim  standards. A training module is planned for spring 2005.
section_title: Strengthen Cyber Security and SCADA Systems
paragraphs: Five of 50 experts rated efforts to improve cyber security and SCADA  systems as warranting highest priority for federal funding, and an  additional 22 experts gave this activity a high priority rating. According to  one expert, measures should be taken to minimize access to these systems  by improving the security capabilities of hardware systems and software  applications, as well as by implementing appropriate information  technology security policies at wastewater utilities.
One other expert suggested the federal government invest in programs  designed to create, accelerate, and deploy minimally acceptable cyber  security standards for all automated systems where a compromising event  could place a surrounding population at risk. This expert noted that the  need for cyber security standards is not limited exclusively to wastewater  systems, but stated that the particular needs and characteristics of these  utilities should be considered as these standards are developed.
section_title: Experts Identified Key Allocation Criteria and Funding Mechanisms for Addressing Wastewater Security Needs
paragraphs: Numerous wastewater utilities have begun to address security concerns by  completing vulnerability assessments or by undertaking security upgrades.  To date, most security initiatives have been financed by reallocating funds  from other important utility activities or embedding security into ongoing  operations. According to industry representatives, utilities may ultimately  have no choice but to pass these costs along to their customers through  rate increases. Given the cost of these security actions, however, many in  the utility industry believe federal assistance through the congressional  appropriations process is warranted. Experts do not all agree that the  wastewater industry as a whole should receive funding priority, noting that  other sectors such as electricity or transportation may warrant higher  priority. Indeed, while the vast majority of our experts did support federal  funds for security for wastewater utilities, some voiced dissenting opinions  on the matter.
Nonetheless, should Congress and the administration agree to a request for  funds, they will need to address key issues concerning who should receive  the funds and how they should be distributed. With this in mind, we asked  our panel of experts to focus on (1) the types of utilities that should receive  funding priority and (2) the most effective mechanisms for directing these  funds to potential recipients. Overall, we found a high degree of consensus  on the following:  Thirty-nine of the 50 experts indicated that utilities serving critical  infrastructure (including government, commercial, industrial, and  public health centers) should be given highest priority for federal  funding. Half of the experts gave utilities using large quantities of  gaseous chemicals a rating of highest priority while just under half of  the experts gave the same rating to utilities serving large populations.
Direct federal grants are the most favored funding mechanism, with  many experts indicating the circumstances in which such grants should  or should not include matching funds from the recipient. Many favored  direct grants without a matching requirement for a wide variety of  planning and coordination activities, such as completing vulnerability  assessments, conducting training, and developing standards and  guidance. Cost-shared grants were favored for activities that benefit  individual utilities, such as strengthening operation and personnel  procedures, installing early warning systems in collection systems, and  hardening physical assets.
subsections: section_title: Key Criteria to Help Determine Which Utilities Should Receive Funding Priority
paragraphs: The experts identified several characteristics of utilities that should be  used to set funding priorities. The most frequently identified were utilities:  (1) serving critical infrastructure including government, commercial,  industrial, and public health centers; (2) using large quantities of gaseous  chemicals; (3) serving areas with large populations; (4) where a security  breach would adversely impact environmental resources (e.g., receiving  waters); (5) having completed vulnerability assessments; (6) serving areas  with medium or small populations; and (7) serving buildings, monuments,  parks, tourist attractions or other entities that have symbolic value  (see fig. 13).
subsections: section_title: Utilities Serving Critical Infrastructure
paragraphs: More than three quarters of the experts (39 of 50) gave utilities serving  critical infrastructure a highest priority rating. An additional 10 experts  gave these utilities a rating of high priority. These utilities provide service  to institutions that serve as hubs for government activity; commercial and  industrial centers, such as a city’s financial district, power plants, or major  airports; and public health institutions, such as major medical centers and  hospitals. As one expert commented, “while every wastewater system is a  potential target, it seems prudent to assume that the larger the system or  the criticality of facilities served, the greater the potential impact and  hence the more likely the target.” Most experts shared this view, including  one who said the highest priority should go to “the impact the loss of the  treatment facility would have on other vital services” such as providing  cooling water for a nuclear or steam generating power plant.
Some experts said that systems with heavy commercial and industrial  usage are critical to the country’s economic stability, and any major or  sustained disruption could have severe economic as well as public health  consequences. For example, one expert pointed out that critical industrial  customers such as the computer chip manufacturing sector could cost the  economy millions per day should a shutdown be caused by the loss of a  wastewater treatment plant.
section_title: Utilities Using Large Quantities of Gaseous Chemicals
paragraphs: More than half of the experts (26 of 50) gave a rating of highest priority for  funding of utilities using large quantities of gaseous chemicals. An  additional 18 experts rated these utilities as warranting a high priority for  federal funds. Some experts pointed out that many wastewater treatment  plants use large quantities of elemental chlorine and other toxic materials  which, if released to the atmosphere on-site or during transport to the site,  would necessitate widespread evacuations, and possibly cause injuries and  fatalities.
Several experts pointed out that the Environmental Protection Agency’s  (EPA) Risk Management Planning program requires industrial facilities that  use threshold amounts of certain extremely hazardous substances to self- identify their worst-case chemical release scenarios. An expert cautioned,  however, that funds should not be provided to utilities for converting to  less hazardous chemicals (e.g., sodium hypochlorite) when other utilities  have already or are currently looking at disinfection options that could  pose little or no security worker risk, or public health risks.
section_title: Utilities Serving Areas with Large Populations
paragraphs: Almost half of the experts (24 of 50) gave a rating of highest priority to  utilities serving areas with large populations. Seventeen additional experts  rated these utilities as warranting a high priority for federal funds. Many  experts shared the view that providing financial and technical assistance to  the largest treatment plants would protect the greatest number of people.  One expert pointed to EPA’s 2000 Clean Water Needs Survey, which  indicated that about 70 percent of the nation’s sewered population is served  by the 3,500 largest wastewater facilities (out of a total of 16,000 facilities).  Each of these facilities maintains a flow that is greater than 1 million  gallons per day. Thus, this expert concluded, funding the largest plants  provided benefits to the greatest number of people. Finally, a number of  experts suggested that because terrorists are likely to seek to maximize the  number of people killed or injured by their attacks, they may try to strike  systems serving many customers in large metropolitan areas.
section_title: Utilities Where a Security Breach Would Adversely Impact Environmental Resources
paragraphs: While only four experts gave a rating of highest priority to utilities where a  security breach would adversely impact environmental resources, 28 of the  experts rated these utilities as warranting a high priority. Several experts  pointed out the potential for a negative impact on the environment and  public health if raw sewage overflows into receiving bodies of water. One  expert commented that many wastewater treatment plants discharge  highly treated effluent to rivers upstream of the intakes to water treatment  plants serving downstream cities. Damage to these wastewater treatment  plants could cause the discharge of raw sewage that would be only partially  diluted before it reached the intakes of the downstream drinking water  treatment plants. Experts also cited significant potential effects on the  environment. Some mentioned that the discharge of untreated sewage  could impact beaches, critical habitats, or fisheries, causing economic  damage in addition to negative environmental and public health effects.
section_title: Utilities That Have Completed Vulnerability Assessments
paragraphs: Three of the experts gave a highest priority rating to utilities that have  completed vulnerability assessments (VAs). An additional 18 experts gave  these utilities a high priority rating. Some experts said that only utilities  that have completed VAs should be given federal funding. Other experts  pointed out that there should be federal funding for those utilities that have  not yet completed VAs so that they can complete this key task. As one  expert commented, a key benefit of conducting a vulnerability assessment  of a wastewater system is that it allows the areas of the greatest need to be  identified.
Properly conducted, a vulnerability assessment brings in all the necessary  divisions within a plant including operations, information technology,  management, and external forces such as fire departments and local police.  Should a plant demonstrate that it has conducted such an assessment, that  plant would be much more likely to use federal funding efficiently, this  expert added.
section_title: Utilities Serving Areas with Medium or Small Populations
paragraphs: Eight of the 50 experts rated utilities serving areas with medium or small  populations as a high priority for federal funding. An additional 27 experts  rated these utilities as a medium priority. One expert pointed out that such  facilities are least able to afford security enhancements or acquire the  security expertise and, therefore, may be in need of federal support.
The relatively small number of experts giving a high or highest priority  rating for utilities serving areas with medium or small populations may not  fully reflect the concern among some experts for the safety of these  utilities. For example, some who gave a higher priority rating to utilities  serving areas with large populations suggested that the need for federal  support should be an important associated criterion, regardless of system  size. Accordingly, these experts said that some funding could be justified  for both large and small populations based on need. One expert favored a  bifurcated focus with one effort seeking to ensure minimal levels of  security for all utilities, and another expert favored more intensive efforts  focusing on systems serving larger populations.
section_title: Utilities Serving Entities That Have Symbolic Value
paragraphs: Only one expert gave a highest priority rating to utilities serving buildings,  monuments, parks, tourist attractions, or other entities that have symbolic  value. An additional 10 experts rated these utilities as warranting a high  priority. One expert commented that terrorists have already shown that  they want to cause serious economic damage by disrupting tourism.  Another noted that terrorists have also targeted cities that have stadiums,  convention centers, and other attractions where large numbers of people  gather.
section_title: Funding Mechanisms Recommended for Distributing Federal Funds
paragraphs: When we asked the experts to identify how best to distribute federal funds  that may be made available to utilities to address wastewater security, they  overwhelmingly indicated that direct federal grants to utilities would be the  most effective mechanism. The experts also indicated that grants in which  some type of match is required of recipients would be effective. Relatively  fewer experts indicated that the use of trust funds or the Clean Water State  Revolving Fund, particularly for upgrades to be implemented in the short  term, would be effective. Other mechanisms that were rated as less  effective included loans, or loan guarantees, and tax incentives for private  utilities. Figure 14 shows how experts rated six different mechanisms for  funding wastewater security.
subsections: section_title: Direct Federal Grants
paragraphs: Thirty-four of the 50 experts indicated that direct federal grants to the  utility would be very effective in allocating federal funds. An additional 12  said these mechanisms would be somewhat effective in doing so.
Experts expressed a variety of views regarding how best to implement  these grants. For example, some cautioned that a grant program for  wastewater security should be solely dedicated to the protection of the  wastewater infrastructure, rather than being consolidated together with  other programs, such as grants for enhancing homeland security. One said  that, contrary to the way grant programs usually operate, utilities should be  allowed to apply for grants during project implementation or even after the  project is completed. This could reward those who were proactively  addressing their security needs. Among other suggestions, one expert said  that EPA and the Department of Homeland Security (DHS) should  collaborate on allocating these grant funds. This expert stated that “EPA  has technical knowledge about facility operations that is especially  important and DHS has grant funds for homeland security that could be  quickly made available until Congress approves a special allocation.” Some  experts also commented that direct grants are preferable because they are  more likely to result quickly in safety improvements and other desired  changes.
Experts also offered opinions on situations in which it would be  appropriate to offer a grant without requiring a matching contribution from  the recipient. Many, for example, favored direct grants with no match for  activities that benefit multiple utilities, or which should be addressed in the  near term. Such actions would include conducting research and  development to improve detection, developing voluntary wastewater  security standards and guidance, completing vulnerability assessments,  and providing training to utility security personnel on how best to conduct  vulnerability assessments and improve the security culture.
section_title: Grants with Matching Requirement (Cost-Shared Grants)
paragraphs: Thirty of the 50 experts indicated that grants with a matching requirement  (cost-shared grants) would be very effective as a mechanism for providing  funds to wastewater utilities. An additional 16 rated such grants as  somewhat effective.
Experts generally favored cost-shared grants for activities that benefit  individual utilities. For example, 38 of the 50 experts indicated that cost- shared grants were best for strengthening operation and personnel  procedures, such as securing sewer maps and conducting background  checks on new employees. Almost three-quarters of the experts (36 of 50)  indicated that cost-shared grants were also best for installing early warning  systems in collection systems to monitor for or detect sabotage. Similarly,  32 of the 50 experts indicated that recommended cost-shared grants would  be best for improving cyber security and for activities required to harden  physical assets, such as building fences, installing locks, and securing  manhole covers.
section_title: Clean Water State Revolving Fund
paragraphs: The Clean Water State Revolving Fund (CWSRF) is an EPA-administered  program that provides grants to the states to allow them to assist publicly  owned wastewater utilities. States, in turn, use the funds to provide loans  to participating wastewater utilities to assist them in making infrastructure  improvements needed to protect public health and ensure compliance with  the Clean Water Act. Five experts indicated that the CWSRF would be a  very effective funding mechanism to improve wastewater security. An  additional 35 indicated that it would be somewhat effective.
According to an EPA Fact Sheet, states may use the CWSRF to assist  utilities in completing a variety of security-related actions, such as  vulnerability assessments, contingency plans, and emergency response  plans. In addition, the EPA Fact Sheet identifies other infrastructure  improvements that may be eligible for CWSRF funds, such as the  conversion from gaseous chemicals to alternative treatment processes,  installation of fencing or security cameras, securing large sanitary sewers  and installing tamper-proof manholes. Some experts said that the  advantage of the CWSRF is its ability to leverage appropriated federal  funds, thereby enabling it to assist more facilities than direct federal grants.
A number of experts, however, expressed caution about relying heavily on  the CWSRF to support security enhancements. Several questioned whether  the CWSRF was appropriate in an environment where quick, emergency- related decisions were needed, noting that the administrative process in  applying for and receiving the funds can be lengthy. Another noted that the  CWSRF “was not originally established to deal with security-related  projects,” and that the program therefore “either needs to  fixed to deal  with security issues or a separate program needs to be created specifically  for security projects.” Another expert noted that unless additional security- related monies were added to existing CWSRF levels, it would divert much  needed funding away from the kind of critical infrastructure investments  that have been the CWSRF’s primary purpose.
section_title: Loans or Loan Guarantees
paragraphs: Loans are a disbursement of funds by the government to a nonfederal  borrower under a contract that requires the repayment of such funds with  or without interest. Loan guarantees represent a nonfederal loan to which a  federal guarantee is attached. Only one expert indicated that loans and  loan guarantees would be very effective mechanisms for providing federal  support for wastewater security. An additional 34, however, indicated they  would be somewhat effective. Generally, these experts cited the primary  advantage of loans or loan guarantees as offering communities the option  to amortize security-related costs over an extended period of time, while  minimizing the overall cost to the federal treasury. Another expert  commented that a low interest loan could provide some incentive and  needed capital to implement security programs.
A number of experts, however, expressed reservations. One cautioned that  the establishment of any federal loan program to support wastewater  security needs should not come at the expense of federal support for the  CWSRF, given the critical infrastructure needs that already depend on it for  support. Another questioned the value of loans to utilities already strapped  for funds, noting that “while loans have less impact on the federal  government, many wastewater utilities and local governments generally  carry a heavy debt load for capital improvements, and they cannot add  significant additional debt that could affect their bond ratings.”
section_title: Trust Funds
paragraphs: Federal trust funds are accounting mechanisms used to link receipts (from  particular taxes or other sources) that by law have been dedicated for a  specific purpose or program, such as for infrastructure improvement. For  example, such a mechanism is in place for the transportation sector  through the Highway Trust Fund. Eight experts indicated that trust funds  would be a very effective mechanism for distributing funds for the  wastewater security sector. An additional 7 said they would be somewhat  effective. However, almost half of the experts (24 of 50) indicated that they  either had no opinion on this subject or that trust funds were “neither  effective nor ineffective.”
Experts raised a number of issues as to how the trust fund concept would  be implemented. A key consideration was whether the fund would be  dedicated solely to wastewater security needs, or be part of a broader fund  that serves other wastewater infrastructure needs. One expert suggested  that, if wastewater security needs have to compete with the broader range  of the wastewater industry’s infrastructure needs, they may not receive  sufficient priority to be funded adequately. Another expert suggested that a  trust fund should be supported annually by the federal government and  local wastewater utilities, and administered in a manner similar to the  former Wastewater Construction Grants program that funded wastewater  construction. This expert indicated that the fund should be used  exclusively for enhancing wastewater security.
section_title: Tax–Based Incentives
paragraphs: Federal tax-based incentives may include new tax credits for spending on  security improvements and the existing exemptions from federal income  tax of interest income from state and local government bonds. One expert  indicated that tax incentives are very effective, and an additional 14 said  they are somewhat effective. Notably, 20 experts indicated that tax-based  incentives would be very ineffective—a result due in part to the fact that  most wastewater utilities are publicly owned and operated and would,  therefore, not benefit from tax-based incentives, like tax credits that would  be used to reduce federal income tax.
Nonetheless, some experts said that for the smaller proportion of privately  owned systems, tax-based incentives could be beneficial and particularly  efficient. One expert noted, for example, that “in those cases where the  wastewater treatment facility is privately owned, nothing succeeds as well  as tax incentives.” Recognizing the diversity of wastewater systems, this  expert stated further that the owners know their utility better than anyone  and are best able to achieve results in a more cost effective way, if they are  incentivized.
section_title: Conclusions
paragraphs: To date, the federal government’s role in promoting wastewater security  has been limited primarily to supporting various training activities on  completing vulnerability assessments and emergency response plans and  several research projects addressing how contaminants affect treatment  systems and other areas. However, legislation supporting an expanded  federal role, including a substantially greater financial commitment, has  been proposed in the past and may be considered again in the future.
Should such funds be appropriated, key judgments about which recipients  should get funding priority, and how those funds should be spent, will have  to be made in the face of great uncertainty about the likely target of an  attack (i.e., a large but well-protected facility versus a smaller but less- protected facility); the nature of an attack (cyber, chemical, biological,  radiological); and its timing. The experts on our panel have taken these  uncertainties into account in deriving their own judgments about these  issues. These views, while not unanimous, suggest some degree of  consensus on a number of key issues.
We recognize that such sensitive decisions ultimately must take into  account a variety of political, equity, and other considerations. We believe  they should also consider the judgments of the nation's most experienced  individuals on these matters, such as those included on this panel. It is in  this context that we offer these results as an input into the decision-making  process that Congress and the administration will likely go through as they  seek to determine how best to use limited financial resources to reduce the  vulnerability to the nation's wastewater utilities.