oversight

Year 2000 Computing Crisis: Status of the Water Industry

Published by the Government Accountability Office on 1999-04-21.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                  United States General Accounting Office

GAO               Report to the Special Committee on the
                  Year 2000 Technology Problem, U.S.
                  Senate


April 1999
                  YEAR 2000
                  COMPUTING CRISIS

                  Status of the Water
                  Industry




GAO/AIMD-99-151
                   United States
GAO                General Accounting Office
                   Washington, D.C. 20548                                                            Leter




                   Accounting Information
                   Management Division                                                               Leter




                   B-282528                                                                    Letter

                   April 21, 1999

                   The Honorable Robert F. Bennett
                   Chairman
                   The Honorable Christopher Dodd
                   Vice Chairman
                   Special Committee on the
                     Year 2000 Technology Problem
                   United States Senate

                   A clean supply of drinking water and the removal and treatment of
                   wastewater are critical to the safety and well-being of the public as we
                   move into the next century. At your request, we identified the water utility
                   sector’s vulnerability to Year 2000 problems, the reported status of Year
                   2000 readiness, and activities being undertaken to address this issue. On
                   April 12, 1999, we briefed your office on the results of our work. The
                   briefing slides are included in appendix I.

                   This report provides a high-level summary of the information presented at
                   that briefing, including background information, Year 2000 risks, actions
                   taken by the President’s Council on Year 2000 Conversion, the reported
                   readiness of the drinking water and wastewater industries, actions taken
                   by regulators to oversee water and wastewater facilities’ Year 2000 status,
                   and practices used by leading facilities to address their Year 2000 problems.
                   This report also presents suggestions we are making to reduce the risk of
                   Year 2000-related failures of drinking water or wastewater services, and to
                   ensure that the public has adequate information about what is being done
                   to reduce the risk of such failures.



Results in Brief   Water and wastewater treatment facilities often use automated control
                   systems and equipment to obtain, treat, and distribute drinking water, and
                   to collect, treat, and release wastewater. These control systems and
                   equipment are subject to Year 2000 failures. However, little is known about
                   the Year 2000 status of the nation’s water and wastewater facilities. While
                   the President’s Year 2000 Conversion Council’s water sector working group
                   has undertaken an awareness campaign and is urging national water sector
                   associations to continue to survey their memberships to determine their
                   Year 2000 readiness, to date these associations’ surveys have had low
                   response rates. Further, Environmental Protection Agency (EPA) officials
                   stated that the agency currently lacks the rules and regulations necessary
                   to require water and wastewater facilities to report on their Year 2000



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             status, and that developing such rules and regulations would be a time-
             consuming process.

             We surveyed state regulators to identify their efforts to monitor the Year
             2000 status of the water and wastewater facilities they regulate, and found
             a wide range of responses. A few states were proactively collecting Year
             2000 compliance data from the facilities they regulate, while a much larger
             group of states was disseminating Year 2000 information, and another
             group was not actively using either approach.1 Further, only a handful of
             state regulators believed that under the current regulatory framework, they
             were responsible for ensuring facilities’ Year 2000 compliance, or
             overseeing facilities’ business continuity and contingency plans. As a
             result, insufficient information is available to assess and manage Year 2000
             efforts in the water sector, and little additional information is expected
             under the current regulatory framework.



Background   The United States’ population is served by about 55,000 community
             drinking water facilities and by about 16,000 public wastewater
             facilities.2 While most of these facilities are relatively small, about 3,300
             large and very large drinking water facilities and about 500 large and very
             large wastewater facilities serve the majority of the population.3

             In most communities, water flows or is pumped from a raw water source—
             such as a lake or stream—into a water treatment facility where solids are
             aggregated and filtered out, and chemicals are added to disinfect the water.
             Other chemicals may also be added to control minerals or corrosion.
             Drinking water is then typically pumped into a storage tank or reservoir,
             and distributed via gravity or pumping stations through water mains to
             homes and businesses. Wastewater is subsequently collected from homes
             and businesses through sewer lines and often pumped via pumping stations


             1
               The state Public Utility Commissions we surveyed were more proactive, but they typically oversee a
             minority of the facilities in each state.

             2This excludes people who receive their water from individually-owned and operated sources, includ-
             ing wells and springs. It also excludes those whose wastewater is treated by on-site septic systems or
             privately-owned wastewater facilities.

             3
               According to EPA, large drinking water facilities serve between 10,001 and 100,000 people and very
             large facilities serve over 100,000 people. A major wastewater association categorizes wastewater
             treatment facilities by the flow of wastewater treated per day, with large facilities generally treating
             between 10 million and 100 million gallons per day and the very large facilities treating more than 100
             million gallons per day.




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                          to a wastewater treatment facility. At this facility, solids are allowed to
                          settle out or are filtered out, and chemicals are added to disinfect the
                          effluent before it is released—often to a river, stream, or lake. Treated
                          effluent from wastewater facilities is often taken in by drinking water
                          facilities downstream.



The Water Sector is       Many water facilities rely on information technology and digital controls
                          with embedded microprocessors to process and distribute drinking water,
Vulnerable to Year 2000   and to collect and treat wastewater.4 In large and medium facilities,
Failures                  Supervisory Control and Data Acquisition (SCADA) systems are often used
                          to monitor and control equipment. Programmable logic controllers (PLC)
                          communicate with the SCADA systems and with electronic controls in
                          equipment such as pumps, valves, and sensors. Even smaller facilities that
                          perform many functions manually will often use some level of automation
                          to control their water and wastewater treatment processes.

                          Year 2000-induced failures in SCADA systems, PLCs, or electronic controls
                          could affect a facility’s ability to monitor and control its operations,
                          resulting in loss of pressure in a drinking water system; under- or
                          overtreated drinking water; or overflow of untreated sewage into public
                          waterways. Additionally, although many facilities have manual backup
                          procedures in place, failures of multiple systems may overtax staff
                          resources—even if each failure is manageable in itself.

                          In addition to Year 2000 risks posed by internal systems, water and
                          wastewater facilities are heavily dependent on external entities, including
                          the power and telecommunications infrastructure and chemical suppliers.
                          An official at a large water facility told us that without power, the facility
                          would shut down. He noted that even minor fluctuations in power supply
                          affect the facility’s operations by causing pumps to shut down.




                          4
                            A facility’s level of automation can range from highly automated process controls to mostly manual
                          operations, with medium and large facilities more likely to be highly automated than smaller facilities.




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The President’s          The President’s Council on Year 2000 Conversion established a water
                         sector working group, led by EPA. This working group has undertaken a
Council on Year 2000     number of activities, including an awareness campaign aimed at
Conversion Has Been      disseminating information on the Year 2000 problem to water and
                         wastewater facilities. It has also urged water sector trade associations to
Active in the Water      continue surveying their memberships as to the water and wastewater
Sector, But Little is    facilities’ Year 2000 readiness.
Known About Most
                         To date, associations’ surveys have had low response rates and, as a result,
Water Facilities’ Year   little is known about the status of the nation’s water and wastewater
2000 Readiness           facilities. Specifically, three national drinking water associations sent a
                         voluntary survey to about 4,000 water facility operators through August
                         1998. Survey responses showed that 51 percent of respondents had
                         completed an internal assessment of their Year 2000 risks, and 81 percent
                         expected to complete their internal Year 2000 work in time. However, there
                         was only an 18-percent response rate overall, and these responses
                         accounted for less than 1 percent of the nation’s very small to medium
                         facilities; about 8 percent of the nation’s large facilities; and about 25
                         percent of the very large facilities.

                         Additionally, a national wastewater association surveyed its membership of
                         mostly large public wastewater facilities in June and again in October 1998.
                         The latest survey results indicated that by the end of April 1999, only 35
                         percent of respondents expected to complete Year 2000 repairs, 24 percent
                         expected to complete Year 2000 testing, and 18 percent expected to
                         complete implementation of system repairs. However, the survey response
                         rate was low—falling from a 37-percent response rate in June to a 21-
                         percent response rate in October. Further, because the membership
                         consisted of mostly large facilities, few small and medium facilities
                         participated in this survey. Responses to the latest survey account for less
                         than 1 percent of the nation’s very small to medium public facilities, 7
                         percent of the nation’s large public facilities, and 15 percent of the nation’s
                         very large public facilities.

                         Because the water associations have not had a high response rate, other
                         organizations may need to fill in the gaps in information. EPA officials
                         stated, however, that without developing regulations and information
                         collection rules—which would likely be a very time-consuming process—
                         they lack the means to require facilities to report on their Year 2000 status.
                         As a result, little is known on a national level regarding water facilities’
                         Year 2000 readiness.



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Regulators’ Year 2000    The Safe Drinking Water Act (SDWA) and the Clean Water Act (CWA)
                         provide EPA regulatory authority for drinking water and wastewater
Activities Vary,         quality. EPA has delegated responsibility to most states for basic
Resulting in             regulatory functions such as enforcing drinking water standards, and
                         issuing and enforcing permits that allow wastewater facilities to discharge
Insufficient             treated wastewater. EPA monitors and collects compliance information
Information About the    from the states.
Year 2000 Readiness of
                         In addition to the responsibilities provided under the SDWA and CWA,
the Water Sector         many states have legislation providing Public Utility Commissions (PUCs)
                         other regulatory responsibilities, including rate-setting, handling of
                         consumer complaints, inspections, and audits of private water and
                         wastewater facilities.5 Most state PUCs regulate facilities that serve a
                         small portion of the population. Only a few affect a broader population.
                         Specifically, five states’ PUCs responsible for drinking water and two
                         states’ PUCs responsible for wastewater regulate facilities that serve over
                         half of those states’ population.6

                         We surveyed state administrations and PUCs to identify their efforts to
                         monitor the Year 2000 status of the water and wastewater facilities they
                         regulate and found a wide range of initiatives. A few state administrations
                         were proactively collecting readiness information from the facilities they
                         regulated; a much larger group was disseminating Year 2000 information;
                         and another large group was inactive on the Year 2000 issue. In general, the
                         PUCs were more proactive, but again, most PUCs affect only a small
                         portion of the state population. Appendix I provides further details on each
                         state’s survey responses.

                         In other survey results, only a few state administrations reported that,
                         under the current regulatory framework, they were responsible for
                         ensuring facilities’ Year 2000 compliance or overseeing facilities’ business
                         continuity and contingency plans. EPA officials agreed that current
                         regulations do not require states to take responsibility for the Year 2000
                         issue.



                         5About   20 states also provide PUCs the authority to regulate some public facilities.

                         6
                           The five states with PUCs that regulate drinking water facilities serving over half the population are
                         Connecticut, Indiana, Rhode Island, West Virginia, and Wisconsin. The two states with PUCs that regu-
                         late wastewater facilities serving over half the population are Rhode Island and West Virginia.




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                         Because of the large number of state regulators that are not collecting
                         facilities’ readiness information, there is insufficient information to assess
                         and manage Year 2000 efforts in the water sector. Further, little additional
                         information is expected under the current regulatory framework.



Leading Facilities Use   To gain insight into the practices used at water sector facilities that were
                         identified as having made progress in their Year 2000 efforts, we visited
Common Practices To      small, medium, and large water and wastewater facilities. We found that
Address Year 2000        these leading organizations had practices that were consistent with our
                         published guidance for addressing the Year 2000 issue.7

                         Leading facilities’ practices included (1) gaining executive management
                         support, (2) conducting enterprise-wide inventories of information systems
                         and components, (3) prioritizing systems and components to be converted
                         or replaced, (4) identifying, prioritizing, and mobilizing needed resources,
                         (5) replacing noncompliant systems and hardware, (6) testing converted
                         and replaced systems and components, and (7) developing contingency
                         plans for mission-critical systems. A few facilities had also developed
                         innovative practices—such as bar-coding every inventory item to facilitate
                         tracking its Year 2000 progress and requiring operators to practice running
                         facilities without electronic controls.



Suggested Actions        In order to reduce the risk of Year 2000-related failures of drinking water
                         and wastewater services and to ensure that the public has adequate
                         information about what is being done to reduce the risk of such failures, we
                         suggest that:

                         • The President’s Council on Year 2000 Conversion consider requesting
                           that the water sector associations publicly disclose the status of those
                           facilities that have responded to surveys, and identify those that have
                           not responded. In doing so, the Council may want to consider
                           developing a template for collecting and disclosing Year 2000 status
                           information.
                         • If the current approach of using associations to voluntarily collect
                           information does not yield the necessary information on water facilities’

                         7
                          Year 2000 Computing Crisis: An Assessment Guide (GAO/AIMD-10.1.14, September 1997); Year 2000
                         Computing Crisis: Business Continuity and Contingency Planning (GAO/AIMD-10.1.19, August 1998);
                         and Year 2000 Computing Crisis: A Testing Guide (GAO/AIMD-10.1.21, November 1998).




                         Page 6                              GAO/AIMD-99-151 Year 2000 Status of the Water Industry
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                           Year 2000 readiness by June 1999, the Council consider whether
                           legislative remedies, such as requiring facilities to disclose their Year
                           2000 readiness data by September 1999, are feasible and should be
                           proposed.
                         • The Council, EPA, and the states determine which regulatory
                           organization should take responsibility for assessing and publicly
                           disclosing the status and outlook of water sector facilities’ Year 2000
                           business continuity and contingency plans.

                         EPA officials generally agreed with our suggested actions. However, they
                         noted that associations may be unwilling to disclose facilities’ Year 2000
                         status and state which facilities have not responded to surveys. One
                         official also stated that additional legislation may be needed if EPA is to
                         take responsibility for overseeing facilities’ Year 2000 business continuity
                         and contingency plans.



Objectives, Scope, and   As requested, our objectives were to determine what Year 2000 issues could
                         affect our nation’s water sector and what the President’s Council on Year
Methodology              2000 Conversion, leading facilities, and state regulatory offices are doing to
                         address Year 2000 issues associated with community water and wastewater
                         services.

                         To identify what Year 2000 issues could affect the water and wastewater
                         industries, we contacted trade associations and engineers and utilized
                         government, private-sector, and trade association Internet sites. We also
                         visited selected water and wastewater facilities to obtain information about
                         the extent of system vulnerabilities.

                         To identify the Council’s activities to address Year 2000 issues associated
                         with water and wastewater industries, we met with officials and attended
                         water sector meetings at EPA. To identify what leading facilities are doing
                         to address the Year 2000 problem, we visited leading water sector
                         organizations and identified practices they thought helped them make
                         progress in addressing the Year 2000 problem. Lastly, to identify what state
                         regulatory offices are doing to address the Year 2000 issues associated with
                         community water and wastewater services, we surveyed state water sector
                         regulators in January and February 1999. To do so, we developed a
                         questionnaire, pretested it at three state locations, and administered it by
                         telephone and fax. We validated our results by obtaining documentation to
                         support interviewees’ responses.




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We conducted our work at the Environmental Protection Agency in
Washington, D.C., and at selected water and wastewater treatment facilities
throughout the country. We performed our work from November 1998
through April 1999, in accordance with generally accepted government
auditing standards.

We provided a copy of our briefing materials, which were used in preparing
this report, to Environmental Protection Agency officials representing the
water sector working group of the President’s Council on Year 2000
Conversion. The Deputy Assistant Administrator, the Senior Information
Resources Management Official of the Office of Water, the Special
Assistant to the Director for Ground Water and Drinking Water, and two
Special Assistants to the Office of Wastewater Management provided oral
comments on the briefing. We have incorporated these comments as
appropriate throughout this report.


We are sending copies of this report to the Honorable John Koskinen,
Chairman of the President’s Council on Year 2000 Conversion; the
Honorable Carol M. Browner, Administrator of the Environmental
Protection Agency; the Honorable Jacob J. Lew, Director of the Office of
Management and Budget; and other interested parties. Copies will be made
available to others upon request.

If you have any questions on matters discussed in this letter, please call me
at (202) 512-6408, or Colleen Phillips, Assistant Director, at (202) 512-6326.
We can also be reached by e-mail at willemssenj.aimd@gao.gov and
phillipsc.aimd@gao.gov, respectively. Other major contributors to this
report are listed in appendix II.




Joel C. Willemssen
Director, Civil Agencies Information Systems




Page 8                       GAO/AIMD-99-151 Year 2000 Status of the Water Industry
Appendix I

Briefing on the Year 2000 Status of the Water
Industry                                                                                                       AppIexndi




                      Accounting and Information
                      Management Division

                               Y2K Drinking Water and
                                    Wastewater




                                  April 12, 1999
                               Amended April 19, 1999
             Briefing for the Senate Special Committee on the Year 2000 Technology Problem

             1




                                   Page 9                 GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                   Appendix I
                   Briefing on the Year 2000 Status of the Water
                   Industry




       Briefing Overview
• Objectives and Methodology
• Background: Sector Decomposition and Demographics
• Year 2000 Risks in the Water Sector
• President’s Council on Year 2000 Conversion Actions
  and Reported Sector Status
• GAO Survey: State Regulators’ Actions
• Leading Facilities’ Practices
• Observations
• Suggested Actions

2




                   Page 10                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                     Appendix I
                     Briefing on the Year 2000 Status of the Water
                     Industry




         Objectives
Determine:

    • What Year 2000 issues could affect water and wastewater
      industries

    • What the President’s Council on Year 2000 Conversion is doing
      to address Year 2000 issues associated with water and
      wastewater industries

    • What state regulatory offices are doing to address the Year
      2000 issues associated with community water and wastewater
      services

    • What leading facilities are doing to address the Year 2000
      problem

3




                     Page 11                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                      Appendix I
                      Briefing on the Year 2000 Status of the Water
                      Industry




         Overview of Methodology
To address these objectives, we:

    • contacted trade associations and engineers and utilized
      government, private sector, and trade association Internet sites
      for pertinent water industry and Year 2000 information

    • attended the President’s Council on Year 2000 Conversion water
      utilities sector meetings at the Environmental Protection Agency
      to learn about the Council’s actions and plans

    • surveyed Year 2000 actions of state water sector regulators by
      developing a questionnaire, pretesting it at three state locations,
      and administering the questionnaire by telephone and fax

    • visited leading water sector facilities to learn about best practices
      in addressing the Year 2000 problem
4




                      Page 12                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                    Appendix I
                    Briefing on the Year 2000 Status of the Water
                    Industry




    Background:
    Decomposition of Water Sector

                      W ater U tility S ec tor


        D rin kin g W ater                         W as tew ater
    •   Public and Private Water               •   Public and Private
        Facilities                                 Wastewater Treatment
         • Large                                   Facilities
         • Medium                                    • Large
         • Small                                     • Medium
                                                     • Small
    •   Federal Facilities
         • DOD                                 •   Federal Facilities
         • Others                                    • DOD
                                                     • Others


5




                    Page 13                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                            Appendix I
                            Briefing on the Year 2000 Status of the Water
                            Industry




           Background:
           Water Sector Demographics
• Approximately 55,000 community drinking water facilities serve
  about 94% of the U.S. population.

    • The remainder of the population receive their water from
      individually owned and operated sources including wells,
      cisterns, and springs.

• About 16,000 public wastewater facilities collect and process over
  32 billion gallons of wastewater per day from about 187 million
  people (about 70% of the U.S. population).

    • The remainder of the U.S. population’s wastewater is treated by
      on-site septic systems or privately-owned wastewater facilities.



Source: Environmental Protection Agency


6




                            Page 14                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                         Appendix I
                         Briefing on the Year 2000 Status of the Water
                         Industry




           Background:
           Water Sector Demographics (cont’d.)
The nation’s water and wastewater treatment facilities are diverse:

    • Publicly-Owned:

       • generally owned and operated by local governments--counties
         and municipalities or by water or sanitation districts.

       • serve a majority of the population.

    • Privately-Owned:

       • generally owned and operated for profit.

       • serve a minority of the population.




7




                         Page 15                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                      Appendix I
                      Briefing on the Year 2000 Status of the Water
                      Industry




         Background:
         Water Sector Demographics (cont’d.)
EPA categorizes drinking water facilities according to the number of
people they serve:

Size            Population served                           Number of facilities
Very Small      25-500                                      about 32,000
Small           501-3,300                                   about 14,000
Medium          3,301-10,000                                about 4,000
Large           10,001-100,000                              about 3,000
Very Large      Over 100,000                                about    330

About 75 percent of the population is served by large or very large water
facilities.

Levels of automation range from manual operations to highly automated
process control systems--medium and large facilities tend to be more
automated.
8




                      Page 16                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                        Appendix I
                        Briefing on the Year 2000 Status of the Water
                        Industry




            Background:
            Water Sector Demographics (cont’d.)
The Association of Metropolitan Sewerage Agencies (AMSA)
categorizes wastewater facilities according to the flow of wastewater
treated. These facilities range from very small to very large.

    • About 13,000 public wastewater facilities treat less than 1 million
      gallons per day.

    • 47 public wastewater facilities treat more than 100 million gallons per
      day.


As with drinking water, levels of automation range from manual
operations to highly automated process control systems--medium and
large facilities tend to be more automated.




9




                        Page 17                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                                        Appendix I
                                        Briefing on the Year 2000 Status of the Water
                                        Industry




                 Background: General Schematic of Drinking
                 Water and Wastewater Facilities
                                                                                            Drinking water is typically
                                  Drinking water treatment                                  pumped into storage tanks or
                                  facility:                                                 reservoirs and then distributed via
                                                                                            gravity or pumping stations
                                  Water flows or is pumped into a                           through water mains to homes
                                  facility where typically solids are                       and businesses.
                                  aggregated and filtered out and
                                  chemicals such as chlorine or ozone
                                  are added to disinfect the water.
       Raw                        Other chemicals may be added to
       water                      control minerals or corrosion.
       source:
       lake,
       river,
       stream,                    Wastewater treatment
       acquifer                   facility:
                                   Wastewater flows or is pumped
                                  into a facility where typically
                                  solids are allowed to settle out or
                                  are filtered out and chemicals are                             Wastewater is collected from
                                                                                                 homes and businesses through
                                  added to disinfect the effluent
                                  before it is released.                                         sewer lines and often pumped via
                                                                                                 pumping stations to a treatment
                                                                                                 facility.
     Treated effluent from wastewater facilities is often
     taken in by drinking water facilities downstream

10




                                        Page 18                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                        Appendix I
                        Briefing on the Year 2000 Status of the Water
                        Industry




          Year 2000 Risks in the Water Sector
Many water facilities rely on information technology and digital controls with
embedded microprocessors to process and distribute drinking water and to
collect and treat wastewater.

Potential Year 2000 failure modes and consequences include:

 • Supervisory Control and Data Acquisition (SCADA) systems--which enable
   plant operators to monitor and control equipment throughout a large
   treatment plant--may fail, making it difficult to monitor facility operations.

 • Digital controls for pumps may fail, resulting in lack of pressure in drinking
   water systems or overflow of untreated sewage.

 • Digital controls or sensors for chemical metering systems may fail, resulting
   in under-treated or over-treated drinking water; or discharge of untreated
   sewage, which may render public waters unusable or unsafe.

 • Although many facilities have manual backup procedures, failures of
   multiple systems in a facility may overtax staff resources--even if each
   failure is manageable by itself.

11




                        Page 19                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                     Appendix I
                     Briefing on the Year 2000 Status of the Water
                     Industry




      Year 2000 Risks in the Water Sector:
      Supervisory Control and Data Acquisition


 A central Supervisory
 Control and Data
 Acquisition (SCADA)
 console, from which a
 plant operator can
 monitor and control
 equipment throughout
 a large treatment plant.




12




                     Page 20                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                         Appendix I
                         Briefing on the Year 2000 Status of the Water
                         Industry




            Year 2000 Risks in the Water Sector:
            Programmable Logic Controller

     An equipment cabinet with
     programmable logic
     controllers that
     communicate with electronic
     controls for individual pieces
     of equipment such as
     pumps, valves, and
     sensors, and with the
     central SCADA system.




13




                         Page 21                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                        Appendix I
                        Briefing on the Year 2000 Status of the Water
                        Industry




           Year 2000 Risks in the Water Sector
     Even if a water facility does not use computers or equipment with
     digital controllers, it can be affected by others that do, such as

      • electric power companies,

      • telecommunications companies, and

      • chemical suppliers.




14




                        Page 22                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                        Appendix I
                        Briefing on the Year 2000 Status of the Water
                        Industry




         Actions of the President’s Council on Year
         2000 Conversion Water Utility Sector
The President’s Council on Year 2000 Conversion designated EPA as the lead
for the water utility sector. To date, EPA has

 • disseminated information on the Year 2000 problem;
 • encouraged sector trade associations to survey their membership and to
   conduct follow-up surveys;
 • issued policy to encourage Year 2000 testing by stating its intent to waive
   civil penalties, and to recommend against criminal prosecution, for
   environmental violations caused by Year 2000 testing--subject to certain
   conditions, including the need to correct any testing-related violations
   immediately; and
 • asked its regional offices to encourage states that are not currently doing so
   to take action to address the Year 2000 problem in water facilities.

However, EPA officials say the agency lacks the means to require facilities to
report on their Year 2000 status without the time-consuming development of
regulations and rules.

15




                        Page 23                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                       Appendix I
                       Briefing on the Year 2000 Status of the Water
                       Industry




         President’s Council on Year 2000 Conversion Water
         Utility Sector: Reported Preparedness of Drinking
         Water Facilities
Three key drinking water associations, including the American Water Works
Association (AWWA), sent a voluntary survey to about 4,000 facility operators
through August 1998.

 • 725 operators responded by December 1998. About half reported they had
   completed their Year 2000 assessments of internal systems.

 • AWWA cautions that the responses may be biased in favor of facilities that
   are better prepared for the Year 2000.

 • Survey responses account for less than 1 percent of the nation’s very small
   to medium facilities; about 8 percent of the nation’s large facilities, and
   about 25 percent of the very large facilities.

 • AWWA plans to conduct a follow-up survey and report updated findings by
   July 1999.


16




                       Page 24                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                       Appendix I
                       Briefing on the Year 2000 Status of the Water
                       Industry




         President’s Council on Year 2000 Conversion Water
         Utility Sector: Reported Preparedness of
         Wastewater Facilities

 In June 1998, the Association of Metropolitan Sewerage Agencies (AMSA)
 surveyed its membership of 206 mostly large municipal facilities. AMSA reported

  • 37 percent responded, and
  • of these, 95 percent had begun to implement solutions for the Year 2000
    problem.

 In October 1998, AMSA conducted another survey focusing on when facilities
 expected to complete major conversion steps. AMSA reported

  • 21 percent responded, and
  • the respondents project that by April 1999;
     • 35% would be complete with repair
     • 24% would be complete with testing
     • 18% would be complete with implementation.



17




                       Page 25                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                           Appendix I
                           Briefing on the Year 2000 Status of the Water
                           Industry




             President’s Council on Year 2000 Conversion Water
             Utility Sector: Reported Preparedness of
             Wastewater Facilities (cont’d.)


     • Survey responses account for less than 1 percent of the nation’s very small to
       medium public facilities; about 7 percent of the nation’s large public facilities,
       and about 15 percent of the very large public facilities.

     • The wastewater association plans to conduct a follow-up survey and report
       updated findings by July 1999.




18




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                                        Appendix I
                                        Briefing on the Year 2000 Status of the Water
                                        Industry




                  GAO Survey:
                  Overview of Regulatory Framework
                     Regulation of Drinking Water Contaminants and Discharge of Wastewater                     Other Regulatory Responsibility
                     Effluents                                                                                 (could include rate-setting,
                                                                                                               handling consumer complaints,
                                                                                                               inspections, and audits)
Regulators
US Environmental     The Safe Drinking Water (SDWA) and Clean Water Act (CWA) provide EPA certain
Protection Agency    regulatory responsibilities for water quality. EPA has delegated authority to most
(EPA)                state administrations for basic regulatory functions such as enforcing drinking water
                     standards and issuing and enforcing permits that allow facilities to discharge treated
                     wastewater. EPA monitors and collects compliance information from states.
State                Unless EPA retained authority under SDWA and CWA or this authority was further
administrations      delegated to local administrations, state administrations are responsible for
                     regulatory functions such as enforcing drinking water standards under SDWA and
                     issuing and enforcing permits under CWA. Some state legislation provides
                     additional authority. States report federal compliance information back to EPA, and
                     can lose their regulatory authority if the facilities do not meet regulatory standards.
Public utility                                                                                                 State legislation often provides
commissions                                                                                                    authority to PUCs to regulate
(PUCs)                                                                                                         private water and wastewater
                                                                                                               facilities. Nineteen states also
                                                                                                               provide PUCs the authority to
                                                                                                               regulate some public facilities.
                                                                                                               PUCs typically oversee a minority
                                                                                                               of the facilities in each state.
Local                States may delegate authority to regulate specific components of SDWA and CWA             State and local legislation provide
administrations      to local administrations. Some local administrations also have local legislation that     local administrations with authority
                     provides them with authority to regulate additional health requirements.                  to regulate public water and
                                                                                                               wastewater facilities.




19                  The shaded area indicates the regulators we surveyed




                                        Page 27                                       GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                          Appendix I
                          Briefing on the Year 2000 Status of the Water
                          Industry




            GAO Survey: Scope
• Conducted January through February 1999

• Interviewed the primary drinking water, wastewater, and public utility
  commission contact in each state

• Interviews were conducted via telephone or faxed questionnaire and
  validated by documentation supporting interviewees’ responses

• Respondent rates:

     •   50 drinking water administrations                                 100%
     •   50 wastewater administrations                                     100%
     •   50 public utility commissions--drinking water                      88%
     •   50 public utility commissions--wastewater                          88%




20




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                                Appendix I
                                Briefing on the Year 2000 Status of the Water
                                Industry




           GAO Survey:
           Analysis Approach
 We placed each state regulator into one of three categories:*

  • Proactive--these regulators reported taking action to assess the readiness of
    water or wastewater facilities. Most proactive states also reported taking action
    to provide (1) information about the Year 2000 problem, or (2) guidance about
    how to address the Year 2000 problem to facility operators in their states.

  • Active--these regulators reported taking action to disseminate general
    information about potential Year 2000 problems or notify operators about their
    responsibilities to ensure that their facilities remain in compliance with
    applicable regulations after 1/1/2000, but did not assess the Year 2000
    progress of facilities in their states.

  • Inactive--these regulators reported not taking action to provide information
    about potential Year 2000 problems to facility operators, or to assess the
    readiness of water sector facilities in their states.

21      *Note:  One should not draw conclusions about the state of individual water facilities on the basis of a
        regulator’s level of activity. A regulator’s activity level is one of many factors that may affect facilities’ progress.




                                Page 29                                GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                               Appendix I
                               Briefing on the Year 2000 Status of the Water
                               Industry




            GAO Survey: Summary of Results
                                                                 Water pollution
                                           Public water          control             Public utility
                      Drinking water       commission            administration      commission
 Status               administration       (drinking water)      (wastewater)        (wastewater)
 Proactive—
 Reported taking
 action to assess             2                     34                     3                  21
 readiness of water
 facilities
 Active—
 Reported taking
 action to                    28                    1                     30                  2
 disseminate
 information about
 the problem
 Inactive—
 Reported taking no           20                    3                     17                  0
 action
 Reported lack of
 regulatory                                         6                                         21
 authority
 Did not respond
 to questionnaire                                   6                                         6


22




                               Page 30                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                                                     Appendix I
                                                     Briefing on the Year 2000 Status of the Water
                                                     Industry




                          GAO Survey:
                          Drinking Water Administrations
                           Summary of actions by state drinking water administrations on the Year 2000 problem

                     Condition                                       States                                                     Description
                     Proactive                    Colorado, Minnesota                                 These states reported taking action to assess readiness of
                                                                                                      drinking water facilities. Most of these states also reported
                         (2)                                                                          taking action to provide (1) information about Year 2000, or
                                                                                                      (2) guidance about how to address Year 2000 to operators
                                                                                                      in their states.


                       Active                     Arkansas, California, Florida, Georgia, Hawaii,     These states reported taking action to disseminate
                                                  Idaho, Illinois, Indiana, Iowa, Maryland,           information about the problem or notify operators about
                        (28)                      Massachusetts, Missouri, New Hampshire,             their responsibility for Year 2000, but did not assess the
                                                  New York, North Dakota, Pennsylvania, Rhode         Year 2000 progress of facilities in their states.
                                                  Island, South Carolina, South Dakota,
                                                  Tennessee, Texas, Utah, Vermont, Virginia,
                                                  Washington, Wisconsin, West Virginia,
                                                             1
                                                  Wyoming
                      Inactive                    Alabama, Alaska, Arizona, Connecticut,              These states reported not taking action to provide
                                                  Delaware, Kansas, Kentucky, Louisiana, Maine,       information about potential Year 2000 problems to facility
                        (20)                      Michigan, Mississippi, Montana, Nebraska,           operators, or to assess the readiness of drinking water
                                                  Nevada, New Jersey, New Mexico, North               facilities in their states. Some of these states said they
                                                  Carolina, Ohio, Oklahoma, Oregon                    plan to take action in the future.




1
    The US Environmental Protection Agency has regulatory authority in Wyoming under the Safe Drinking Water Act.




     23                              Note: Facilities may have received Year 2000 information from other
                                     sources, including EPA, trade associations, and other state organizations.




                                                     Page 31                                          GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                                                Appendix I
                                                Briefing on the Year 2000 Status of the Water
                                                Industry




                    GAO Survey: Public Utility Commissions that
                    Regulate Drinking Water
                Summary of actions by state public utility commissions responsible for regulating drinking water facilities
                                                        on the Year 2000 problem1

       Condition                                      States                                                                Description
       Proactive            Alabama, Alaska, Arizona, Arkansas, California, Colorado,            These states reported taking action to assess the Year 2000
                                        2
         (34)               Connecticut , Delaware, Idaho, Illinois, Indiana, Iowa,              status of drinking water facilities. Most of these states also
                            Kentucky, Maine, Maryland, Mississippi, Missouri,                    reported taking action to provide (1) information about Year
                            Montana, Nevada, New Hampshire, New Jersey, New                      2000, or (2) guidance about how to address Year 2000 to
                                 3
                            York , North Carolina, Ohio, Oklahoma, Oregon, Rhode                 operators in their states.
                            Island, South Carolina, Tennessee, Utah, Vermont, West
                            Virginia, Wisconsin, Wyoming
         Active             Florida                                                              This state reported taking action to disseminate information
          (1)                                                                                    about the problem or notify operators about their responsibility
                                                                                                 for Year 2000, but did not assess the Year 2000 progress of
                                                                                                 facilities in the state.
        Inactive            Kansas, Nebraska, Washington                                         These states reported not taking action to provide information
           (3)                                                                                   about potential Year 2000 problems to facility operators, or to
                                                                                                 assess the readiness of drinking water facilities in their states.
                                                                                                 Some of these states said they plan to take action in the future.
  Non-Regulating            Georgia, Michigan, Minnesota, North Dakota, South                    These state public utility commissions reported they are not
        (6)                 Dakota, Texas                                                        responsible for regulating private drinking water facilities.
  Non-Responding            Hawaii, Louisiana, Massachusetts, New Mexico,                        These states did not respond to the questionnaire.
        (6)                 Pennsylvania, Virginia


1
  In most states, the PUC regulates facilities that serve a relatively small percentage of the population. However, in five states--Connecticut, Indiana, Rhode Island, West
Virginia, and Wisconsin—the PUC regulates facilities that serve over half of the population.
2
  Connecticut reported it has collected Year 2000 information from only the 3 largest investor owned water facilities in the state. They said they are only secondarily
tracking the status of the other medium and smaller size water facilities they regulate.
3
   New York reported that they are actively monitoring Year 2000 compliance for the 6 largest regulated facilities serving about 80% of the regulated population.
 They reported that the remaining 374 companies, 20% of the population, are monitored on a less rigorous basis.




24                             Note: Facilities may have received Year 2000 information from other
                               sources, including EPA, trade associations, and other state organizations.




                                                Page 32                                            GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                               Appendix I
                               Briefing on the Year 2000 Status of the Water
                               Industry




          GAO Survey:
          Wastewater Administrations
     Summary of actions by state water pollution control (wastewater) administrations on the Year 2000 problem

      Condition                                      States                                               Description


       Proactive                Alaska, California, Utah                          These states reported taking action to assess readiness of
                                                                                  wastewater facilities. Most of these states have also reported
          (3)                                                                     taking action to provide (1) information about Y2K, or (2)
                                                                                  guidance about how to address Y2K to operators in their
                                                                                  states.

        Active                  Alabama, Colorado, Delaware, Florida, Hawaii,     These states reported taking action to disseminate
                                Idaho, Illinois, Iowa, Kansas, Kentucky, Maine,   information about the problem or notify operators about their
         (30)                   Massachusetts, Michigan, Minnesota, Missouri,     responsibility for Y2K, but did not assess the Year 2000
                                Nebraska, Nevada, New Hampshire, New              progress of facilities in their states.
                                Jersey, New York, North Carolina, Oklahoma,
                                Oregon, Pennsylvania, Rhode Island, South
                                Carolina, South Dakota, Vermont, Wisconsin,
                                Wyoming

       Inactive                 Arkansas, Arizona, Connecticut, Georgia,          These states reported not taking action to provide information
                                Indiana, Louisiana, Maryland, Mississippi,        about potential Y2K problems to facility operators, or to
         (17)                   Montana, New Mexico, North Dakota, Ohio,          assess the readiness of water pollution control facilities in
                                Tennessee, Texas, Virginia, Washington, West      their states. Some of these states said they plan to take
                                Virginia                                          action in the future.




25                 Note: Facilities may have received Year 2000 information from other
                   sources, including EPA, trade associations, and other state organizations.




                               Page 33                                       GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                                                Appendix I
                                                Briefing on the Year 2000 Status of the Water
                                                Industry




                    GAO Survey: Public Utility Commissions that
                    Regulate Wastewater
                    Summary of actions by state public utility commissions responsible for regulating wastewater facilities
                                                                                   1
                                                         on the Year 2000 problem

      Condition                                       States                                                               Description
      Proactive             Alaska, Arizona, Arkansas, Illinois, Indiana, Kentucky,           These states reported taking action to assess the Year 2000
         (21)               Maryland, Mississippi, Missouri, Montana, Nevada, New             status of wastewater facilities. Most of these states also reported
                            Hampshire, New Jersey, North Carolina, Ohio, Rhode                taking action to provide (1) information about Year 2000, or (2)
                            Island, South Carolina, Tennessee, Utah, West Virginia,           guidance about how to address Year 2000 to operators in their
                            Wisconsin                                                         states.
         Active             California, Florida                                               These states reported taking action to disseminate information
          (2)                                                                                 about the problem or notify operators about their responsibility for
                                                                                              Year 2000.
        Inactive                                                                              These states reported taking action to date to provide information
           (0)                                                                                about potential Year 2000 problems to facility operators, or to
                                                                                              assess the readiness of wastewater facilities in their states.
                                                                                              Some of these states said they plan to take action in the future.
    Non-Regulating          Alabama, Colorado, Connecticut, Delaware, Georgia,                These state public utility commissions reported they are not
         (21)               Idaho, Iowa, Kansas, Maine, Michigan, Minnesota,                  responsible for regulating private wastewater facilities.
                            Nebraska, New York, North Dakota, Oklahoma, Oregon,
                            South Dakota, Texas, Vermont2, Washington, Wyoming
    Non-Responding          Hawaii, Louisiana, Massachusetts, New Mexico,                     These states did not respond to the questionnaire.
          (6)               Pennsylvania, Virginia


1
  In most states, the PUC regulates facilities that serve a relatively small percentage of the population. However, in two states--Rhode Island and West Virginia—the PUC
regulates facilities that serve over half the population.
2
  Vermont reported it has regulatory authority for wastewater facilities; however, they reported regulating none at this time.




26                            Note: Facilities may have received Year 2000 information from other
                              sources, including EPA, trade associations, and other state organizations.




                                                Page 34                                            GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                              Appendix I
                              Briefing on the Year 2000 Status of the Water
                              Industry




              GAO Survey: Many People Are Served by
              Facilities with Inactive Regulators

                                        Drin king water popul ation           Wastewater population

                                        served (mil lions)                    served (mi llion s)
Popu lation s se rved by:

Faciliti es with proactive

reg ulators                                            36                                  32

Faciliti es with active

reg ulators                                           151                                  98

Faciliti es with in active

reg ulators                                            58                                  56

Totals                                                245                                 186




•    Note: Facilities may have received Year 2000 information from other sources, including
     EPA, trade associations, and other state organizations.

Source: GAO analysis based on EPA and PUC population data


27




                              Page 35                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                           Appendix I
                           Briefing on the Year 2000 Status of the Water
                           Industry




            GAO Survey: Other Results
     Relatively few state regulators said they were responsible for ensuring the
     Year 2000 compliance of water facilities:

      • only 4 of 100 drinking water and wastewater administrations reported
        being responsible for ensuring Year 2000 compliance

      • less than half of the public utility commissions (PUCs) that reported
        regulating water sector facilities said that they were responsible for
        ensuring Year 2000 compliance

          • some of these PUCs said they could not guarantee the Year 2000
            compliance of water sector facilities they regulate




28




                           Page 36                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                        Appendix I
                        Briefing on the Year 2000 Status of the Water
                        Industry




          GAO Survey: Other Results (cont’d.)
Relatively few state regulators said that they oversee Year 2000 business
continuity and contingency plans (BCCPs) that will be used by water facilities in
the event of a Year 2000 emergency:

 • 3 drinking water administrations and 1 wastewater administration reported
   they would oversee or review facilities’ Year 2000 BCCPs

 • 1 wastewater administration reported that it has an advisory role and
   expects facilities’ BCCPs to be available for inspection

 • 14 PUCs that regulate drinking water and 7 PUCs that regulate wastewater
   facilities said they would oversee or review BCCPs




29




                        Page 37                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                                         Appendix I
                                         Briefing on the Year 2000 Status of the Water
                                         Industry




            Year 2000 Practices at Leading
            Facilities
We observed a number of practices at leading facilities that are consistent
with GAO Guidance:*

 • Obtaining executive management support

 • Conducting an enterprise-wide inventory of information systems and their
   components

 • Prioritizing systems and components to be converted or replaced

 • Identifying, prioritizing, and mobilizing needed resources

 • Replacing noncompliant systems and hardware

 • Testing converted and replaced systems and components

 • Developing contingency plans for mission-critical systems

30     * Year 2000 Computing Crisis: An Assessment Guide (GAO/AIMD-10.1.14, September 1997)
         Year 2000 Computing Crisis: Business Continuity and Contingency Planning (GAO/AIMD-10.1.19, August 1998)
         Year 2000 Computing Crisis: A Testing Guide (GAO/AIMD-10.1.21, November 1998)




                                         Page 38                                            GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                       Appendix I
                       Briefing on the Year 2000 Status of the Water
                       Industry




          Year 2000 Practices at Leading
          Facilities (cont’d.)
Innovative practices observed:

 • identifying and bar coding every piece of electronic equipment to track Year
   2000 status and ensure that all equipment is checked for Year 2000
   compliance

 • scheduling every operator to practice running the facility without electronic
   controls




31




                       Page 39                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                        Appendix I
                        Briefing on the Year 2000 Status of the Water
                        Industry




          Observations
Insufficient information is available to assess and manage water facilities’ Year
2000 efforts.

 • Few states have surveyed the Year 2000 status of water sector facilities
 • Existing national surveys have low response rates
 • Information about the status of small and medium facilities is limited

Little additional information is likely to emerge under the current regulatory
framework.

 • Few additional states plan to survey facilities’ Year 2000 status
 • State regulators responsible for water facilities’ compliance under the Clean
   Water Act and the Safe Drinking Water Act generally report they lack
   specific responsibility for Year 2000 compliance of water facilities’ equipment
 • EPA officials say the agency lacks the means to conduct mandatory
   collection of data on facilities’ Year 2000 status


32




                        Page 40                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                        Appendix I
                        Briefing on the Year 2000 Status of the Water
                        Industry




          Suggested Actions
 In order to reduce the risk of Year 2000-related failures of drinking water or
 wastewater services and ensure that the public has adequate information about
 what is being done to reduce the risk of such failures, we suggest that

  • the President’s Council consider requesting that the water sector
    associations publicly disclose the status of those facilities that have
    responded to surveys, and identify those that have not responded;

      • in doing so, the Council may want to consider developing a template for
        collecting and disclosing Year 2000 status information;

  • if the current approach of using associations to voluntarily collect information
    does not yield the necessary information on water facilities’ Year 2000
    readiness by June 1999, the Council may wish to consider whether
    legislative remedies, such as requiring facilities to disclose their Year 2000
    readiness data by September 1999, are feasible and should be proposed;
    and

33




                        Page 41                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
                  Appendix I
                  Briefing on the Year 2000 Status of the Water
                  Industry




     Suggested Actions (cont’d.)

     • the Council, EPA, and the states should determine which
       regulatory organization should take responsibility for assessing and
       publicly disclosing the status and outlook of water sector facilities’
       Year 2000 business continuity and contingency plans.




34




                  Page 42                           GAO/AIMD-99-151 Year 2000 Status of the Water Industry
Appendix II

Major Contributors to This Report
                                                                                                       ApIpexndi




Accounting and         Robert C. Reining, Evaluator in Charge
                       Sharon O. Byrd, Senior Auditor
Information            Christina M. Bower, Evaluator
Management Division,
Washington, D.C.

Atlanta Field Office   Glenda C. Wright, Senior Information Systems Analyst




(511482)      eL
               rtet    Page 43                    GAO/AIMD-99-151 Year 2000 Status of the Water Industry
Appendix II
Major Contributors to This Report




Page 44                         GAO/AIMD-99-151 Year 2000 Status of the Water Industry
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