oversight

Drinking Water: Experts' Views on How Future Federal Funding Can Best Be Spent to Improve Security

Published by the Government Accountability Office on 2003-10-31.

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

               United States General Accounting Office

GAO            Report to the Committee on Environment
               and Public Works, U.S. Senate



October 2003
               DRINKING WATER
               Experts’ Views on
               How Future Federal
               Funding Can Best Be
               Spent to Improve
               Security




GAO-04-29
               a
                                                October 2003


                                                DRINKING WATER

                                                Experts’ Views on How Future Federal
Highlights of GAO-04-29, a report to the        Funding Can Best Be Spent to Improve
Committee on Environment and Public
Works, U.S. Senate                              Security



After the events of September 11,               GAO’s expert panel cited distribution systems as among the most
2001, Congress appropriated over                vulnerable physical components of a drinking water utility, a conclusion
$100 million to help drinking water             also reached by key research organizations. Also cited were the
systems assess their vulnerabilities
to terrorist threats and develop
                                                computer systems that manage critical utility functions, treatment
response plans. As the                          chemicals stored on site, and source water supplies. Experts further
Environmental Protection Agency                 identified two overarching vulnerabilities: (1) a lack of information
has suggested, however, significant             individual utilities need to identify their most serious threats; and (2) a
additional funds may be needed to               lack of redundancy in vital system components, which increases the
support the implementation of                   likelihood that an attack could render an entire utility inoperable.
security upgrades. Therefore, GAO
sought experts’ views on (1) the
                                                According to over 90 percent of the experts, utilities serving high-density
key security-related vulnerabilities
of drinking water systems; (2) the              areas deserve at least a high priority for federal funding. Also warranting
criteria for determining how                    priority are utilities serving critical assets, such as military bases,
federal funds should be allocated               national icons, and key academic institutions. Direct federal grants were
among drinking water systems to                 clearly the most preferred funding mechanism, with over half the experts
improve their security, and the                 indicating that such grants would be very effective in distributing funds
methods for distributing those                  to recipients. Substantially fewer experts recommended using the
funds; and (3) specific activities the          Drinking Water State Revolving Fund for security upgrades.
federal government should support
to improve drinking water security.
                                                When experts were asked to identify specific security-enhancing
GAO conducted a systematic Web-                 activities most deserving of federal support, their responses generally fell
based survey of 43 nationally                   into three categories:
recognized experts to seek
consensus on these key drinking                     •   physical and technological upgrades to improve security and
water security issues.
                                                        research to develop technologies to prevent, detect, or respond to
                                                        an attack (experts most strongly supported developing near real-
                                                        time monitoring technologies to quickly detect contaminants in
GAO recommends that as EPA                              treated drinking water on its way to consumers);
refines its efforts to help drinking
water utilities reduce their
vulnerability to terrorist attacks,
                                                    •   education and training to support, among other things,
the agency consider the                                 simulation exercises to provide responders with experience in
information in this report to help                      carrying out emergency response plans; specialized training of
determine: how best to allocate                         utility security staff; and multidisciplinary consulting teams to
security-related federal funds                          assess utilities’ security preparedness and recommend
among drinking water utilities;                         improvements; and
which methods should be used to
distribute the funds; and what
specific security-enhancing                         •   strengthening key relationships between water utilities and
activities should be supported.                         other agencies that may have key roles in an emergency response,
                                                        such as public health agencies, law enforcement agencies, and
                                                        neighboring drinking water systems; this category also includes
www.gao.gov/cgi-bin/getrpt?GAO-04-29.                   developing protocols to encourage consistent approaches to
To view the full product, including the scope           detecting and diagnosing threats.
and methodology, click on the link above.
For more information, contact John
Stephenson at (202) 512-3841 or
Stephensonj@gao.gov.
Contents



Letter                                                                                               1


Executive Summary                                                                                    2
                          Purpose                                                                    2
                          Background                                                                 2
                          Results in Brief                                                           5
                          Principal Findings                                                         7
                          Recommendation for Executive Action                                       13
                          Agency Comments                                                           13


Chapter 1                                                                                           14
                          Key Components of a Typical Drinking Water System                         14
Introduction              The Nation’s Drinking Water Systems and the Populations They
                            Serve                                                                   16
                          Government and Industry Have Recently Sought to Improve
                            Security                                                                17
                          Efforts to Further Improve Security after the September 11
                            Attacks                                                                 18
                          Potentially Larger Federal Financial Commitment Sought in Future
                            Years                                                                   19
                          Objectives, Scope, and Methodology                                        19


Chapter 2                                                                                           23
                          Vulnerability of Physical Assets                                          23
Experts Identified Key    Overarching Issues Affecting Drinking Water Systems’ Security             28
Vulnerabilities That
Could Compromise
Drinking Water
Systems’ Security

Chapter 3                                                                                           31
                          Strong Agreement That Allocation Decisions Should Consider a
Experts’ Views on the        Utility’s Vulnerability Assessment                                     32
Allocation and            Key Criteria to Help Determine Which Utilities Should Receive
                             Funding Priority                                                       35
Distribution of Federal   Funding Mechanisms Recommended for Distributing Federal Funds
Funds                                                                                               37




                          Page i                                      GAO-04-29 Drinking Water Security
                            Contents




Chapter 4                                                                                               43
                            Activities to Enhance Physical Security and Support Technological
Activities Experts            Improvements                                                              43
Identified As Most          Activities to Improve Education and Training                                54
                            Activities to Strengthen Relationships between Agencies and
Deserving of Federal          Utilities                                                                 59
Support                     Conclusions                                                                 65
                            Recommendation for Executive Action                                         66


Appendixes
              Appendix I:   Participating Experts on Drinking Water Security Panel                      67
             Appendix II:   GAO Contacts and Staff Acknowledgments                                      69
                            GAO Contacts                                                                69
                            Acknowledgments                                                             69


Table                       Table 1: Vulnerability Assessment Completion Deadlines                      19


Figures                     Figure 1: Key Components of a Typical Drinking Water System                  4
                            Figure 2: Key Components of a Typical Drinking Water System                 15
                            Figure 3: Number of Drinking Water Systems That Serve Various
                                       Populations                                                      16
                            Figure 4: Key Vulnerabilities Identified As Compromising Drinking
                                       Water Systems’ Security                                          24
                            Figure 5: Experts’ Views on Whether Federal Funds Should Be
                                       Allocated Based on Vulnerability Assessment
                                       Information                                                      33
                            Figure 6: Experts’ Views on Which Types of Water Utilities Should
                                       Receive Priority for Federal Funds                               35
                            Figure 7: Recommended Approaches for Distributing Federal
                                       Funds                                                            38
                            Figure 8: Activities Identified by Expert Panel to Enhance Physical
                                       Security and Support Technological Improvements                  44
                            Figure 9: Activities Identified by Experts to Improve Education and
                                       Training                                                         55
                            Figure 10: Activities Identified by Experts to Strengthen
                                       Relationships between Agencies and Utilities                     60




                            Page ii                                       GAO-04-29 Drinking Water Security
Contents




Abbreviations

AMSA                  Association of Metropolitan Sewerage Agencies
AMWA                  Association of Metropolitan Water Agencies
AWWA                  American Water Works Association
BASIC                 Bay Area Security Information Collaborative
CDC                   Centers for Disease Control and Prevention
DWSRF                 Drinking Water State Revolving Fund
EPA                   Environmental Protection Agency
ETV                   Environmental Technology Verification
FBI                   Federal Bureau of Investigation
ICMA                  International City/County Management Association
ISAC                  Information Sharing and Analysis Center
MADIRT                Mutual Aid Disaster and Intervention and Response Teams
NRWA                  National Rural Water Association
NRDC                  Natural Resources Defense Council
PDD                   Presidential Decision Directive
SCADA                 Supervisory Control and Data Acquisition
VA                    vulnerability assessment
VSAT                  Vulnerability Self Assessment Tool
WEF                   Water Environment Federation




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 reproduce this material separately.




Page iii                                               GAO-04-29 Drinking Water Security
A
United States General Accounting Office
Washington, D.C. 20548



                                    October 31, 2003                                                                Leter




                                    The Honorable James Inhofe
                                    Chairman
                                    The Honorable James Jeffords
                                    Ranking Minority Member
                                    Committee on Environment and Public Works
                                    United States Senate

                                    As requested, this report discusses the views of nationally recognized
                                    experts on key issues concerning drinking water security, including serious
                                    vulnerabilities of drinking water systems, criteria for allocating federal
                                    funds among systems, and activities that most warrant federal support to
                                    mitigate the risk of terrorism.

                                    As agreed in discussions with your offices, unless you publicly announce
                                    its contents earlier, we plan no further distribution of this report until 30
                                    days from the date of this letter. We will then send copies to other
                                    appropriate congressional committees, and to the Administrator of the
                                    Environmental Protection Agency. We will also make copies available to
                                    others upon request. In addition, the report will be available at no charge
                                    on the GAO Web site at http://www.gao.gov.

                                    If you or your staffs have any questions concerning this report, please call
                                    me at (202) 512-3841 or my Assistant Director, Steve Elstein, at
                                    (202) 512-6515. Major contributors to this report are listed in appendix II.




                                    John B. Stephenson
                                    Director, Natural Resources
                                     and Environment




                                    Page 1                                          GAO-04-29 Drinking Water Security
Executive Summary



Purpose      Drinking water utilities across the country have long been recognized as
             potentially vulnerable to terrorist attacks of various types, including
             physical disruption, bioterrorism, chemical contamination, and cyber
             attack. Damage or destruction by terrorists could disrupt not only the
             availability of safe drinking water, but also the delivery of vital services that
             depend on these water supplies, such as fire suppression. Such concerns
             were greatly amplified by the September 11, 2001, attacks on the World
             Trade Center and the Pentagon and then by the discovery of training
             manuals in Afghanistan detailing how terrorist trainees could support
             attacks on drinking water systems.

             Congress has since committed significant federal funding to assist drinking
             water utilities, with over $100 million appropriated through fiscal year 2004
             to help systems assess their vulnerabilities to terrorist threats and develop
             response plans. As significant as these funds are, it is likely that drinking
             water utilities will ask the federal government to provide larger sums to go
             beyond the planning for upgrading drinking water security to the actual
             implementation of security upgrades. Consequently, as agreed with the
             Chairman and Ranking Minority Member of the Senate Committee on
             Environment and Public Works, this report identifies (1) the key security-
             related vulnerabilities affecting the nation’s drinking water systems; (2) the
             criteria that should be used to determine how federal funds are allocated
             among recipients to improve their security, and the methods that should be
             used to distribute these funds; and (3) specific activities the federal
             government should support to improve drinking water security.

             To address these issues, GAO conducted a Web-based Delphi survey
             process involving 43 nationally recognized experts. The Delphi method is a
             systematic process for obtaining individuals’ views on a question or
             problem of interest and seeking consensus, if possible. In selecting
             members for the expert panel, GAO sought individuals who were widely
             recognized as possessing expertise on one or more key aspects of drinking
             water security. GAO also sought to achieve balance in representation from
             key federal agencies, key state or local agencies, key industry and nonprofit
             organizations, and water utilities of varying sizes. A detailed description of
             GAO’s methodology is presented in chapter 1.



Background   Drinking water systems vary by size and other factors, but as illustrated in
             figure 1, they most typically include a supply source, treatment facility, and
             distribution system. A water system’s supply source may be a reservoir,



             Page 2                                            GAO-04-29 Drinking Water Security
Executive Summary




aquifer, or well, or a combination of these sources. Some systems may also
include a dam to help maintain a stable water level, and aqueducts and
transmission pipelines to deliver the water to a distant treatment plant. The
treatment process generally uses filtration, sedimentation, and other
processes to remove impurities and harmful agents, and disinfection
processes such as chlorination to eliminate biological contaminants.
Chemicals used in these processes, most notably chlorine, are often stored
on site at the treatment plant. Distribution systems comprise water towers,
piping grids, pumps, and other components to deliver treated water from
treatment systems to consumers. Particularly among larger utilities,
distribution systems may contain thousands of miles of pipes and
numerous access points.




Page 3                                         GAO-04-29 Drinking Water Security
                                            Executive Summary




Figure 1: Key Components of a Typical Drinking Water System




                                                                                  Chemical storage


                                                                                                     Disinfection
                        Reservoir/                                                               Filtration
                        river                                                                Sedimentation



                                               Water treatment plant

                                                                          Post
                                                      Water storage       treatment
                                                      tank                storage

                                                              Pumping
                                                              station

                                                                             Distribution
                                                                             system

                                     City




  Residential
  area



Source: GAO.



                                            Until the 1990s, emergency planning at drinking water utilities generally
                                            focused on responding to natural disasters and, in some cases, domestic
                                            threats such as vandalism. In the 1990s, however, both government and
                                            industry officials broadened the process to account for terrorist threats.
                                            Among the most significant actions taken was the issuance in 1998 of
                                            Presidential Decision Directive 63 to protect the nation’s critical



                                            Page 4                                          GAO-04-29 Drinking Water Security
                   Executive Summary




                   infrastructure against criminal and terrorist attacks. The directive
                   designated the Environmental Protection Agency (EPA) as the lead federal
                   agency to address the water infrastructure and to work with both public
                   and private organizations to develop emergency preparedness strategies.
                   EPA, in turn, appointed the Association of Metropolitan Water Agencies to
                   coordinate the water industry’s role in emergency preparedness. During
                   this time, this public-private partnership focused primarily on cyber
                   security threats for the several hundred community water systems that
                   each served over 100,000 persons. The partnership was broadened in 2001
                   to include both the drinking water and wastewater sectors, and focused on
                   systems serving more than 3,300 people.

                   Efforts to better protect drinking water infrastructure were accelerated
                   dramatically after the September 11 attacks. EPA and the drinking water
                   industry launched efforts to share information on terrorist threats and
                   response strategies. They also undertook initiatives to develop guidance
                   and training programs to assist utilities in identifying their systems’
                   vulnerabilities. As a major step in this regard, EPA supported the
                   development, by American Water Works Association Research Foundation
                   and Sandia National Laboratories, of a vulnerability assessment
                   methodology for larger drinking water utilities. The push for vulnerability
                   assessments was then augmented by the Public Health Security and
                   Bioterrorism Preparedness and Response Act of 2002 (Bioterrorism Act).
                   Among other things, the act required each community water system serving
                   more than 3,300 individuals to conduct a detailed vulnerability assessment
                   by specified dates in 2003 or 2004, depending on their size.



Results in Brief   GAO’s expert panel identified several key physical assets as the most
                   seriously vulnerable to terrorist attacks. In general, their observations were
                   similar to those of major public and private organizations that have
                   assessed the vulnerability of these systems to terrorist attacks, including
                   the National Academy of Sciences, Sandia National Laboratories, and key
                   industry associations. In particular, when asked to identify what they
                   believed to be among the top vulnerabilities of drinking water utilities,
                   nearly 75 percent of the experts (32 of 43) identified the distribution system
                   (one or more components). More experts identified the distribution system
                   as the top vulnerability (12 of 43) among the components of the drinking
                   water system. The other physical assets most frequently cited were source
                   water supplies, critical information systems, and chemicals stored on site
                   that are used in the treatment process. Importantly, the experts also
                   identified overarching vulnerability issues that may involve multiple system



                   Page 5                                          GAO-04-29 Drinking Water Security
Executive Summary




components, or even an entire drinking water system. Chief among these
issues were (1) a lack of redundancy in vital systems, which increases the
likelihood that an attack could render a system inoperable; and (2) the
difficulty many systems face due to a lack of information on the most
serious threats to which they are exposed.

Key criteria experts cited for determining how federal funds to improve
drinking water security should be allocated included (1) the extent to
which information on utilities’ vulnerabilities should be considered in
making allocation decisions; and (2) characteristics of the utilities
themselves, such as size and proximity to population centers.

• About 90 percent of the panelists strongly agreed or somewhat agreed
  that allocation decisions should be based on vulnerability assessment
  information. Several factors, however, complicate the government’s
  ability to use utilities’ vulnerability assessments for this purpose.

• Panelists favored funding priority for utilities serving high-density
  populations, with over 90 percent indicating that they deserve at least a
  high priority and over 50 percent indicating they deserve highest
  priority. Utilities serving critical assets (such as military bases and other
  sensitive government facilities, national icons, and key cultural or
  academic institutions) were also recommended as high-priority
  recipients, while relatively few experts recommended priority for
  utilities serving rural or isolated populations.

When asked to identify the most effective mechanisms of distributing
federal drinking water security funds to recipients, over half the experts
indicated that direct federal grants would be very effective in doing so.
Many also favored including a requirement for matching funds as a grant
condition. Fewer experts recommended using the Drinking Water State
Revolving Fund (DWSRF) for this purpose, particularly to support
upgrades that need to be implemented quickly.

When asked to identify and set priorities for security-enhancing activities
most deserving of federal support, the experts most frequently identified
activities that generally fell into three broad categories:

• Physical and technological improvements includes both physical
  alterations to improve the security of drinking water systems and the




Page 6                                          GAO-04-29 Drinking Water Security
                      Executive Summary




                         development of technologies to prevent, detect, or respond to an attack.
                         The need to develop near real-time monitoring technologies, which
                         would be particularly useful in quickly detecting contaminants in water
                         that has already left the treatment plant for the consumer, had by far the
                         strongest support.

                      • Education and training would be used for both utility and nonutility
                        personnel responsible for preventing, responding to, and recovering
                        from an attack. These activities include, among other things, support for
                        simulation exercises to provide responders with experience in carrying
                        out utilities’ emergency response plans; specialized training of utility
                        personnel responsible for security; general training of utility personnel
                        to augment security awareness among all staff; and multidisciplinary
                        consulting teams to independently analyze utilities’ security
                        preparedness and recommend security-related improvements.

                      • Strengthening relationships is seen as critical between water utilities
                        and other agencies (public health agencies, enforcement agencies, and
                        neighboring utilities, among others) that may have key roles in an
                        emergency response. This category also includes developing common
                        protocols to engender a consistent approach among utilities in detecting
                        and diagnosing threats, and the testing of local emergency response
                        systems to ensure that participating agencies coordinate their actions
                        effectively.



Principal Findings

Key Vulnerabilities   Nearly 75 percent of the experts on GAO’s panel (32 of 43) named the
                      distribution system (one or more components) as among the top
                      vulnerabilities of drinking water systems. In fact, 12 of the 32 experts
                      identified the distribution system as the single most important
                      vulnerability, a considerably greater number than any other element of the
                      drinking water system. Their explanations most often related to the
                      accessibility of distribution systems at numerous points. One expert, for
                      example, cited the difficulty of preventing the introduction of a
                      contaminant into a distribution system from inside a public building.
                      Another expert noted that since the water in a distribution system has
                      already been treated and is in the final stages of being transferred to
                      consumers, the distribution of a chemical, biological, or radiological agent



                      Page 7                                         GAO-04-29 Drinking Water Security
Executive Summary




in such a manner could be difficult to detect until it is too late to reverse
any harm done.1

Several other components, though not considered as critical as the
distribution system, were still the subject of concern. Nearly half the
experts (20 of 43) identified source water as among drinking water
systems’ top vulnerabilities. One expert noted, for example, that “because
of the vast areas covered by watersheds and reservoirs, it is difficult to
maintain security and prevent intentional or accidental releases of
materials that could have an adverse impact on water quality.” Yet some
experts cited factors that mitigate the risks associated with source water,
including (1) that source water typically involves a large volume of water,
which in many cases could dilute the potency of contaminants; (2) the
length of time (days or even weeks) that it typically takes for source water
to reach consumers; and (3) that source water will go through a treatment
process in which many contaminants are removed. In addition, EPA
pointed out that as source water goes through the treatment process, many
contaminants are removed.

Also cited as a vulnerability were the sophisticated computer systems that
drinking water utilities have come to rely upon to manage key functions.
These Supervisory Control and Data Acquisition (SCADA) systems allow
operators to monitor and control processes throughout their drinking
water systems. Although SCADA systems have improved water utilities’
efficiency and reduced costs, almost half of the experts on GAO’s panel (19
of 43) identified them as among these utilities’ top vulnerabilities. Finally,
13 of the 43 experts identified treatment chemicals, particularly chlorine
used for disinfection, as among utilities’ top vulnerabilities. Experts cited
the inherent danger of storing large cylinders of a chemical on site, noting
that their destruction could release toxic gases in densely populated areas.
Some noted, however, that this risk has been alleviated by utilities that
have chosen to use the more stable liquid form of chlorine instead of the
more vulnerable compressed gas canisters that have traditionally been
used.

Experts also identified overarching issues that compromise the integrity of
multiple physical assets, or even the entire drinking water system. Among
these is the lack of redundancy among vital systems. Many drinking water


1
 An EPA official noted, however, that distribution systems generally carry disinfectant
residuals that can counteract the potentially harmful effects of contaminants.




Page 8                                                   GAO-04-29 Drinking Water Security
                              Executive Summary




                              systems are “linear”—that is, they have single transmission lines leading
                              into the treatment facility, single pumping stations along the system, and
                              often employ a single computer operating system. They also depend on the
                              electric grid, transportation systems, and single sources of raw materials
                              (e.g., treatment chemicals). Many experts expressed concern that problems
                              at any of these “single points of failure” could render a system inoperable
                              unless redundant systems are in place. Experts also cited the lack of
                              sufficient information to understand the most significant threats
                              confronting individual utilities. According to the American Water Works
                              Association, assessments of the most credible threats facing a utility
                              should be based on knowledge of the “threat profile” in its specific area,
                              including information about past events that could shed light on future
                              risks. Experts noted, however, that such information has been difficult for
                              utilities to obtain. One expert suggested that the intelligence community
                              needs to develop better threat information and share it with the water
                              sector.



Allocation and Distribution   Many drinking water utilities have been financing at least some of their
of Federal Funds              security upgrades by passing along the costs to their customers through
                              rate increases. Given the cost of these upgrades, however, drinking water
                              industry representatives have also sought federal assistance. GAO asked its
                              expert panel to comment on the factors that should be considered in
                              allocating federal funds. Specifically, GAO asked the experts to comment
                              on the following:

                              • Appropriate use of vulnerability assessment information. About 90
                                percent of the experts (39 of 43) strongly agreed or somewhat agreed
                                that funds should be allocated on the basis of vulnerability assessment
                                information, with some citing the vulnerability assessments (VA)
                                required by the Bioterrorism Act as the best available source of this
                                information. Several experts, however, pointed to a number of
                                complicating factors. Perhaps the most significant constraint is the
                                Bioterrorism Act’s provision precluding the disclosure of any
                                information that is “derived” from vulnerability assessments submitted
                                to EPA. It is important to protect sensitive information about each
                                utility’s vulnerabilities from individuals who may then use the
                                information to harm the utility. The law specifies that only individuals
                                designated by the EPA Administrator may have access to the
                                assessments and related information. Yet even those individuals would
                                face constraints in using the information. They would have difficulty, for
                                example, in citing vulnerability assessments to support decisions on



                              Page 9                                         GAO-04-29 Drinking Water Security
Executive Summary




   allocating security-related funds among utilities, as well as decisions
   concerning research priorities and guidance documents. Others cited an
   inherent dilemma affecting any effort to set priorities for funding
   decisions based on the greatest risk—whatever does not receive
   attention becomes the best target.

• Criteria to help determine which utilities should receive funding
  priority. According to 93 percent of the experts (40 of 43), utilities
  serving high-density population areas should receive a high or highest
  priority in funding (55 percent deemed this criterion as the highest
  priority). Most shared the view of one expert, who noted that directing
  limited resources to protect the greatest number of people is a common
  factor when prioritizing funding. Experts also assigned high priority to
  utilities serving critical assets, such as national icons representing the
  American image, military bases, and key government, academic, and
  cultural institutions. At the other end of the spectrum, only about 5
  percent of the experts (2 of 43) stated that utilities serving rural or
  isolated populations should receive a high or highest priority for federal
  funding. Generally, these panelists commented that such facilities are
  least able to afford security enhancements and are therefore in greatest
  need of federal support. Importantly, the relatively small percentage of
  experts advocating priority for smaller systems may not fully reflect the
  concern among many of the experts for the safety of these utilities. For
  example, several who supported higher priority for utilities serving high-
  density populations cautioned that while problems at a large utility will
  put more people at risk, utilities serving small population areas may be
  more vulnerable because of weaker treatment capabilities, fewer highly
  trained operators, and more limited resources.

As for effective mechanisms for distributing federal funds, the expert
panelists viewed direct federal grants as most effective, with 86 percent of
the experts (37 of 43) indicating that this mechanism would be somewhat
or very effective in allocating federal funds. One expert cited EPA’s recent
distribution of direct security-related grant funds to larger systems to
perform their VAs as a successful initiative. Also, 74 percent cited a
matching requirement for such grants as somewhat or very effective. One
expert pointed out that such a requirement would effectively leverage
limited federal dollars, thereby providing greater incentive to participate.
The Drinking Water State Revolving Fund received somewhat less support,
with a number of the experts cautioning that as a funding mechanism, it is
suited more for longer-term improvements than for those requiring more
immediate attention.



Page 10                                        GAO-04-29 Drinking Water Security
                          Executive Summary




Security-Enhancing        When experts were asked to identify and set priorities for the security-
Activities That Most      enhancing activities most deserving of federal support, their responses
                          generally fell into three broad categories:
Warrant Federal Support
                          • Enhancing Physical Security and Supporting Technological
                            Improvements. These activities fell into nine subcategories. Of these,
                            the development of “near real-time monitoring technologies,” capable of
                            providing near real-time data for a wide array of potentially harmful
                            water constituents, received far more support for federal funding than
                            any other subcategory—over 93 percent of the experts (40 of 43) rated
                            this subcategory as deserving at least a high priority for federal funding.
                            More significantly, almost 70 percent (30 of 43) rated it highest priority.
                            These technologies were cited as critical in efforts to quickly detect
                            contamination events, minimize their impact, and restore systems after
                            an event has passed. The experts also voiced strong support for (1)
                            increasing laboratories’ capacity to deal with spikes in demand caused
                            by chemical, biological, or radiological contamination of water supplies,
                            and (2) “hardening” the physical assets of drinking water facilities
                            through improvements such as adding or repairing fences, locks,
                            lighting systems, and cameras and other surveillance equipment. Some
                            experts, however, cited the limitations inherent in attempts to
                            comprehensively harden a drinking water facility’s assets. They noted in
                            particular that, unlike nuclear power or chemical plants, a drinking
                            water system’s assets are spread over large geographic areas,
                            particularly the source water and distribution systems.

                          • Improving Education and Training. Over 90 percent of the experts (39
                            of 43) indicated that improved technical training for security-related
                            personnel warrants at least a high priority for federal funding, with over
                            55 percent (24 of 43) indicating that it deserved highest priority. To a
                            lesser extent, experts supported general training for other utility
                            personnel to increase their awareness of security issues. The panelists
                            also underscored the importance of conducting regional simulation
                            exercises to test emergency response plans, with more than 88 percent
                            (38 of 43) rating this as a high or highest priority for federal funding.
                            Such exercises are intended to provide utility and other personnel with
                            the training and experience needed both to perform their individual
                            roles in an emergency, and to coordinate these roles with other
                            responders. Finally, about half the experts assigned at least a high
                            priority to supporting multidisciplinary consulting teams (“Red Teams”),
                            comprising individuals with a wide array of backgrounds, to provide
                            independent analyses of utilities’ vulnerabilities.


                          Page 11                                        GAO-04-29 Drinking Water Security
                           Executive Summary




                           • Strengthening Relationships between Utilities and Other Key
                             Organizations. Experts cited the need to improve cooperation and
                             coordination between drinking water utilities and certain other
                             organizations as key to improving utilities’ security. Among the
                             organizations most often identified as critical to this effort are public
                             health and law enforcement agencies, which have data that can help
                             utilities better understand their vulnerabilities and respond to
                             emergencies. In addition, the experts reported it is valuable for utilities
                             to develop mutual aid arrangements with neighboring utilities. Such
                             arrangements sometimes include, for example, the sharing of back-up
                             power systems or other critical equipment. One expert described an
                             arrangement in the San Francisco Bay Area—the Bay Area Security
                             Information Collaborative (BASIC). The collaborative’s eight utilities
                             meet regularly to address security-related topics. Finally, over 90
                             percent of the experts (39 of 43) rated the development of common
                             protocols among drinking water utilities to monitor drinking water
                             threats as warranting a high or highest priority for federal funding.
                             Drinking water utilities vary widely in how they perceive threats and
                             detect contamination, in large part because few common protocols exist
                             that would help promote a more consistent approach toward these
                             critical functions. Some experts noted in particular the need for
                             protocols to guide the identification, sampling, and analysis of
                             contaminants.



Making Key Security        EPA has identified improved drinking water security as an important
Decisions in the Face of   national goal, and has stated in its Strategic Plan on Homeland Security
                           that as funds are appropriated, federal resources will be available to help
Great Uncertainty
                           achieve this goal. Yet key judgments about who should receive priority for
                           federal resources, and how those funds should be spent, will have to be
                           made in the face of great uncertainty about the likely target of an attack,
                           the nature of an attack (whether physical, cyber, chemical, biological, or
                           radiological), and its timing. The experts on GAO’s panel have had to
                           consider these uncertainties in deriving their own judgments about these
                           issues. Their judgments, while not unanimous on all matters, suggested a
                           high degree of consensus on a number of key issues.

                           GAO recognizes that sensitive funding decisions ultimately must take into
                           account political, equity, and other considerations. It also believes such
                           decisions should consider the judgments of the nation's most experienced
                           individuals on these matters, such as those included on its panel. It is in this
                           context that GAO offers the results presented in this report as information



                           Page 12                                          GAO-04-29 Drinking Water Security
                     Executive Summary




                     for Congress and the Administration to consider as they seek the best way
                     to use limited financial resources to reduce the threat to the nation's
                     drinking water supply.



Recommendation for   GAO recommends that, as EPA refines its efforts to help drinking water
                     utilities reduce their vulnerability to terrorist attacks, the EPA
Executive Action     Administrator consider the information in this report to help determine:
                     how best to allocate security-related federal funds among drinking water
                     utilities, which methods should be used to distribute the funds, and what
                     specific security-enhancing activities should be supported.



Agency Comments      We provided EPA with a draft of this report for review and comment. EPA
                     did not submit a formal letter but did provide comments from officials in its
                     Office of Water and its Office of Homeland Security. The comments from
                     the Office of Water said that the report’s results were “useful and well
                     thought out.” EPA’s Office of Homeland Security said that the report
                     “demonstrates a well conceived and executed project,” and that “a number
                     of the issues raised in the document will be useful to the agency as it moves
                     forward in the drinking water security program.” Both offices also offered
                     specific technical comments and suggestions, which have been
                     incorporated.




                     Page 13                                        GAO-04-29 Drinking Water Security
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Introduction                                                                                            Chapte1
                                                                                                              r




                         Drinking water utilities across the country have long been recognized as
                         being potentially vulnerable to terrorism of various types, including
                         physical disruption, bioterrorism, chemical contamination, and cyber
                         attacks. Damage or destruction by such a terrorist attack could disrupt not
                         only the availability of safe drinking water to consumers, but also the
                         delivery of vital services that depend on these water supplies, such as fire
                         suppression.

                         These concerns were greatly amplified by the September 11, 2001, attacks
                         on the World Trade Center and the Pentagon. They were further amplified
                         in ensuing months when training manuals were discovered in Afghanistan
                         detailing how terrorist trainees could support attacks on drinking water
                         systems.



Key Components of a      Drinking water systems vary by size and other factors but, as illustrated in
                         figure 2, most typically include a supply source, treatment facility, and
Typical Drinking Water   distribution system.
System




                         Page 14                                        GAO-04-29 Drinking Water Security
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                                            Introduction




Figure 2: Key Components of a Typical Drinking Water System




                                                                                  Chemical storage


                                                                                                     Disinfection
                        Reservoir/                                                               Filtration
                        river                                                                Sedimentation



                                               Water treatment plant

                                                                          Post
                                                      Water storage       treatment
                                                      tank                storage

                                                              Pumping
                                                              station

                                                                             Distribution
                                                                             system

                                     City




  Residential
  area



Source: GAO.



                                            As the figure shows, a water system’s supply source may include a
                                            reservoir, aquifer, or well, or a combination of these sources. The supply
                                            source may also include a dam as well as aqueducts and transmission
                                            pipelines to deliver the water to a distant treatment plant. Many water
                                            systems rely on groundwater as their primary water source, but most




                                            Page 15                                         GAO-04-29 Drinking Water Security
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                                                 Introduction




                                                 systems, particularly larger systems, rely on surface water such as lakes,
                                                 rivers, and streams.

                                                 Water treatment generally uses filtration, flocculation, sedimentation, and
                                                 other processes to remove impurities and harmful agents, and disinfection
                                                 processes (such as chlorination) to eliminate biological contaminants.
                                                 Chemicals used in these processes, most notably chlorine, are often stored
                                                 on site.

                                                 The distribution system comprises several components, such as water
                                                 towers, piping grids, and pumps that deliver treated water from treatment
                                                 systems to consumers. A key feature of most distribution systems is their
                                                 size: Particularly among larger utilities, distribution systems may have
                                                 many thousands of miles of pipes.



The Nation’s Drinking                            Nationwide, there are more than 160,000 public water systems that
                                                 individually serve from as few as 25 people to 1 million people or more. As
Water Systems and the                            figure 3 illustrates, nearly 133,000 of these water systems serve 500 or
Populations They                                 fewer people. Only 466 systems serve more than 100,000 people each, but
                                                 these systems, located primarily in urban areas, account for nearly half of
Serve                                            the total population served.



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

                  Population served
                              <
                              – 500                                                                               132,974

                         501 – 3,300                    19,706

                      3,301 – 10,000         4,799

                    10,001 – 100,000        3,467

                Greater than 100,000       466

                                       0            20,000       40,000   60,000   80,000   100,000   120,000     140,000
                                       Number of systems 161,412
Source: GAO.




                                                 Page 16                                        GAO-04-29 Drinking Water Security
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Government and           Most drinking water systems long ago developed and maintained
                         emergency preparedness plans that specified how to notify the public in
Industry Have Recently   cases of emergency, and how to coordinate an emergency response with
Sought to Improve        law enforcement and other emergency response officials. These plans,
                         however, paid little attention to the kinds of threats posed by international
Security                 terrorist organizations. Rather, they were generally oriented toward
                         responding to natural disasters and, in some cases, domestic threats such
                         as vandalism.

                         Both government and industry officials took a number of steps to broaden
                         emergency planning in the 1990s. In 1996, the President issued Executive
                         Order 13010, which listed water supply as one of eight national
                         infrastructures vital to the security of the United States. In 1997, the
                         President’s Commission on Critical Infrastructure Protection, also
                         established by executive order, issued a report on the vulnerabilities of the
                         eight categories of infrastructure and strategies for protecting them. The
                         report identified three attributes crucial to water supply users: Water must
                         be available on demand, it must be delivered at sufficient pressure, and it
                         must be safe for use.1 It warned that susceptibility to contamination and
                         the loss of flow or pressure can be caused by extensive water main breaks,
                         the destruction of pumps, or the disruption of power supplies, and cited
                         these as major vulnerabilities to the nation’s water supply systems.

                         In response to the report’s findings, the President issued Presidential
                         Decision Directive (PDD) 63 on critical infrastructure protection in 1998.
                         This directive established a public-private partnership to put in place
                         prevention, response, and recovery measures that would augment the
                         security of the nation’s critical infrastructure components against criminal
                         or terrorist attacks. The directive designated the Environmental Protection
                         Agency (EPA) as the lead federal agency to work with both public and
                         private organizations to protect the nation’s water infrastructure through
                         the development of emergency preparedness strategies. The agency, in
                         turn, appointed the Association of Metropolitan Water Agencies, a
                         nonprofit organization representing the nation’s largest utilities, to
                         coordinate the water industry’s role in emergency preparedness.




                         1
                          The President’s Commission on Critical Infrastructure Protection, Critical Foundations:
                         Protecting America’s Infrastructures, October 1997.




                         Page 17                                                GAO-04-29 Drinking Water Security
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                         Initially, this public-private partnership focused on the several hundred
                         community water systems that each served more than 100,000 persons; the
                         partnership was broadened in 2001 to include systems serving more than
                         3,300 people. Moreover, as was the case with other infrastructure sectors,
                         PDD-63 focused primarily on threats to cyber security. Specifically, the
                         directive established a goal to develop, within five years, a Water
                         Information Sharing and Analysis Center (Water ISAC). The intent of the
                         Water ISAC is, among other things, to facilitate the dissemination of alerts
                         to drinking water and wastewater utilities about threats to their systems, to
                         analyze incident information, and to serve as a secure source of sensitive
                         information.



Efforts to Further       Efforts to improve protection of drinking water infrastructure were
                         broadened and accelerated after the September 11 attacks. In particular,
Improve Security after   the partnership accelerated efforts to develop the Water ISAC, which
the September 11         became operational in December 2002. EPA and the drinking water
                         industry also launched efforts to develop guidance, tools, and training
Attacks                  programs to assist utilities in identifying their systems’ vulnerabilities. As a
                         major step in this regard, EPA supported the American Water Works
                         Association Research Foundation and the Sandia National Laboratories to
                         develop a vulnerability assessment (VA) methodology and training
                         primarily for the largest water systems. EPA awarded approximately $51
                         million in fiscal year 2002 for water security grants to help these water
                         systems complete vulnerability assessments.

                         These efforts to better understand drinking water systems’ vulnerabilities
                         were given a significant boost when the President signed the Public Health
                         Security and Bioterrorism Preparedness and Response Act in June 2002.2
                         Among other things, title IV of the Bioterrorism Act amended the Safe
                         Drinking Water Act to require each community water system serving more
                         than 3,300 individuals to conduct “an assessment of the vulnerability of its
                         system to a terrorist attack or other intentional acts intended to
                         substantially disrupt the ability of the system to provide a safe and reliable
                         supply of drinking water.” As illustrated in table 1, the act phased in this
                         requirement according to system size, requiring vulnerability assessments
                         for all systems serving populations greater than 3,300 to be completed by
                         June 30, 2004.


                         2
                         Pub. L. No. 107-188, 116 Stat. 594 (2002) (“Bioterrorism Act”).




                         Page 18                                                  GAO-04-29 Drinking Water Security
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                         Table 1: Vulnerability Assessment Completion Deadlines

                         System size (based on population         Vulnerability assessment completion
                         served)                                  deadline
                         100,000 or more                          March 31, 2003
                         50,000 to 99,999                         December 31, 2003
                         3,301 to 49,999                          June 30, 2004
                         Source: Bioterrorism Act, S 401(a)(2).


                         EPA guidance calls for these assessments to include: a characterization of
                         the water system; the identification of possible consequences of
                         malevolent acts; the critical assets subject to malevolent acts; an
                         assessment of the threat of malevolent acts; an evaluation of
                         countermeasures; and a plan for risk reduction. The Bioterrorism Act also
                         requires each community water system serving more than 3,300 individuals
                         to prepare or revise an emergency response plan incorporating the results
                         of the VA no later than 6 months after completing the assessment. In
                         addition, it directed EPA to provide guidance to smaller systems on how to
                         conduct vulnerability assessments, prepare emergency response plans, and
                         address threats.



Potentially Larger       While significant federal funds have been committed to assist utilities in
                         developing vulnerability assessments and emergency response plans, the
Federal Financial        likelihood exists that Congress and the Administration will be asked to
Commitment Sought in     provide much larger sums to go beyond planning for upgrading drinking
                         water security to the actual implementation of security upgrades. By most
Future Years             accounts, it will cost billions of dollars to upgrade security for drinking
                         water utilities. The American Water Works Association, for example,
                         estimates that it will cost $1.6 billion for initial security upgrades at all
                         drinking water utilities.



Objectives, Scope, and   As requested in a June 9, 2003, letter to the Comptroller General from the
                         Chairman and Ranking Minority Member of the Senate Committee on
Methodology              Environment and Public Works, this report identifies experts’ views on the
                         following questions:

                         • What are the key security-related vulnerabilities affecting the nation’s
                           drinking water systems?



                         Page 19                                           GAO-04-29 Drinking Water Security
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Introduction




• What are the criteria that should be used to determine how federal funds
  are allocated among recipients to improve drinking water security, and
  how should the funds be distributed?

• What specific activities should the federal government support to
  improve drinking water security?

To obtain information on these three questions, we conducted a three-
phase Web-based survey of 43 experts on drinking water security. We
identified these experts from a list of more than 50 widely recognized
experts in one or more key aspects of drinking water security. In compiling
this initial list, we also sought to achieve balance in terms of area of
expertise (i.e., state and local emergency response, engineering,
epidemiology, public policy, security and defense, drinking water
treatment, risk assessment and modeling, law enforcement, water
infrastructure, resource economics, bioterrorism, public health, and
emergency and crisis management).

In addition, we attempted to achieve participation by experts from (1) key
federal organizations (e.g., Argonne National Laboratory, Centers for
Disease Control and Prevention, Department of Defense, Department of
the Interior’s Bureau of Reclamation, Environmental Protection Agency,
and Federal Bureau of Investigation; (2) key state and local agencies,
including health departments and environmental protection departments;
and (3) key industry and nonprofit organizations such as the American
Water Works Association (AWWA), RAND Corporation, Natural Resources
Defense Council (NRDC), and National Rural Water Association (NRWA);
and (4) water utilities serving populations of varying sizes. Of the 50
experts we contacted, 43 agreed to participate and complete all three
phases of our survey. A list of the 43 participants in this study is included in
appendix I.

To obtain information from the expert panel, we employed a modified
version of the Delphi method. The Delphi method is a systematic process
for obtaining individuals’ views and seeking consensus among them, if
possible, on a question or problem of interest. Since first developed by the
RAND Corporation in the 1950s, the Delphi method has generally been
implemented using face-to-face group discussions. For this study, however,
we administered the method through the Internet. We used this approach,
in part, to eliminate the potential bias associated with group discussions.
These biasing effects include the dominance of individuals and group
pressure for conformity. Moreover, by creating a virtual panel, we were



Page 20                                          GAO-04-29 Drinking Water Security
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able to include many more experts than possible with a live panel, which
allowed us to obtain a broad range of opinions.

For each phase in the Delphi method, we posted a questionnaire on GAO’s
survey Web site addressing the issues of our study. Panel members were
notified of the availability of the questionnaire with an e-mail message. The
e-mail message contained a unique user name and password that allowed
each respondent to log on and fill out a questionnaire but did not allow
respondents access to the questionnaires of others.

In the first questionnaire, we asked several broad questions, such as, “What
strategies or methods should the federal government consider for
allocating funds to water utilities (or other relevant entities) so as to ensure
that allocation achieves the greatest mitigation of risk per dollar?” We
pretested these questions with officials from the water utility industry, a
nonprofit research group, and academe. Participants were invited to
provide detailed narrative explanations for their responses.

In the case of two key questions, we sought to identify both additional
detail and the degree to which consensus could be achieved among the
experts on our panel. We used experts’ responses to phase 1 questions to
develop more detailed questions for phase 2 about specific actions or
strategies regarding two overall issues: how federal funds could best be
allocated among potential recipients to achieve the most security
improvements per dollar, and which specific activities are most deserving
of federal support. This second questionnaire included closed-ended
questions that allowed panelists to rate the relative priority or effectiveness
of these activities. It also provided experts with the opportunity to
comment on their ratings.

During the third phase of the Delphi process, we provided the aggregated
results from the ratings made in the second questionnaire. We also
provided panel members with the individual ratings they had made in
response to each question. We then invited panel members to use this
information as a basis for changing their answers if they desired.

In addition to the information obtained from our expert panel, we obtained
documentation from representatives of professional organizations, such as
the National Academy of Sciences, RAND Corporation, American Water
Works Association Research Foundation, and Association of Metropolitan
Water Agencies. We also held several interviews with officials at EPA on
the agency’s drinking water security programs. During our interviews, we



Page 21                                          GAO-04-29 Drinking Water Security
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Introduction




asked officials to provide information on program operations, policies,
guidance, and funding levels. We also received training on the Vulnerability
Self Assessment Tool supported by the Association of Metropolitan
Sewerage Agencies, and attended specialized conferences addressing
drinking water security by the Water Environment Federation and other
organizations.

We conducted our work from July 2002 through August 2003 in accordance
with generally accepted government auditing standards.




Page 22                                        GAO-04-29 Drinking Water Security
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Experts Identified Key Vulnerabilities That
Could Compromise Drinking Water Systems’
Security                                                                                           Chapte2
                                                                                                         r




                   Our panel of experts identified several key physical assets of drinking
                   water systems as the most vulnerable to intentional attack. In general, their
                   observations were similar to those of public and private organizations that
                   have assessed the vulnerability of these systems to terrorist attacks,
                   including the National Academy of Sciences, Sandia National Laboratories,
                   and key industry associations. In particular, nearly 75 percent of the
                   experts (32 of 43) identified the distribution system or its components as
                   among the top vulnerabilities of drinking water systems.

                   In addition to identifying systems’ physical assets, experts also identified
                   overarching issues compromising how well these assets are protected.
                   Chief among these issues are (1) a lack of redundancy in vital systems,
                   which increases the likelihood that an attack could render a system
                   inoperable; and (2) the difficulty many systems face in understanding the
                   nature of the threats to which they are exposed.



Vulnerability of   As illustrated in figure 4, when asked to identify what they believed to be
                   the top vulnerabilities of drinking water utilities, the four physical assets
Physical Assets    most frequently identified by the panel were: (1) the distribution system,
                   (2) source water supplies, (3) Supervisory Control and Data Acquisition
                   (SCADA) and other information systems, and (4) chemicals stored on site
                   that are used to treat source water.




                   Page 23                                         GAO-04-29 Drinking Water Security
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                          Figure 4: Key Vulnerabilities Identified As Compromising Drinking Water Systems’
                          Security




Experts Identified        The distribution system delivers drinking water primarily through a
Distribution Systems as   network of underground pipes to homes, businesses, and other customers.
                          While the distribution systems of small drinking water utilities may be
Most Vulnerable           relatively simple, larger systems serving major metropolitan areas can be
                          extremely complex. One such system, for example, measures water use
                          through 670,000 metered service connections, and distributes treated water
                          through nearly 7,100 miles of water mains that range from 2 inches to 10
                          feet in diameter. In addition to these pipelines and connections, other key
                          distribution system components typically include numerous pumping
                          stations, treated water storage tanks, and fire hydrants.

                          Nearly 75 percent, or 32 of 43 of the experts on our panel, named one or
                          more components of the distribution system as among the top
                          vulnerabilities of drinking water systems. In fact, 12 of the 32 experts


                          Page 24                                           GAO-04-29 Drinking Water Security
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               Experts Identified Key Vulnerabilities That
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               Security




               identified distribution systems as the most critical vulnerability, a
               considerably greater number than any other system component. The
               explanations they offered most often related to the accessibility of
               distribution systems at numerous points. One expert, for example, cited the
               difficulty in preventing the introduction of a contaminant into the
               distribution system from inside a building “regardless of how much time,
               money, or effort we spend protecting public facilities.” Experts also noted
               that since the water in the distribution system has already been treated and
               is in the final stages of being transferred to the consumer, the distribution
               of a chemical, biological, or radiological agent in such a manner would be
               virtually undetectable until it has affected consumers. An EPA official
               added, however, that distribution systems generally carry disinfectant
               residuals that can counteract the potentially harmful effects of
               contaminants. This official further stated that routine monitoring
               performed in drinking water systems might provide some advance warning.
               While research on the fate and transport of contaminants within water
               treatment plants and distribution systems is under way, according to one
               expert, limited technologies are readily available that can detect a wide
               range of contaminants once treated water is released through the
               distribution system for public use.



Source Water   Nearly half the experts (20 of 43) identified source water as among drinking
               water systems’ top vulnerabilities. Drinking water may come from surface
               water, groundwater, or both. The water cycle begins with rainwater and
               snowmelt that collect in lakes and rivers and that, in many cases, interact
               with groundwater. Large urban water supply systems tend to rely on
               surface water sources (rivers, lakes, and reservoirs), while smaller systems
               tend to rely more heavily on groundwater.

               One expert raised concerns about the inherent challenge in protecting
               source waters, noting, “Because of the vast areas covered by watersheds
               and reservoirs, it is difficult to maintain security and prevent intentional or
               accidental releases of materials that could have an adverse impact on water
               quality.” Other experts raised additional concerns about the vulnerability
               of water intake transmission lines, which regulate the transfer of water
               supplies to the systems’ treatment plants.

               Panel experts and others, however, have stated that concerns over source
               water contamination are mitigated somewhat by a number of factors. First,
               a large volume of water generally exists at the source, which in many cases
               can dilute the potency of agents introduced at this stage of the drinking



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                water production process. Second, unlike treated water in the distribution
                system, it generally takes many days before source water reaches the
                consumer, making it more likely that a contamination problem at this early
                stage of the drinking water production process can be detected or treated
                before consumers are affected. One utility official noted, for example, that
                his water system’s surface water supplies travel hundreds of miles before
                reaching the treatment plant. Water that was contaminated at the source
                would take between 10 days and 6 months to reach the treatment plant,
                depending on the source, providing ample opportunity for detection and
                adjustments to protect public health.



SCADA Systems   To improve their efficiency and reduce operating costs, drinking water
                utilities (particularly larger utilities) have come to rely increasingly on
                sophisticated computer systems to manage their facilities’ key functions.
                These Supervisory Control and Data Acquisition (SCADA) systems allow
                utility operators to monitor and control processes throughout their
                systems, even at remote facilities. SCADA systems communicate with other
                control facilities and provide the necessary data to ensure that the right
                chemicals are mixed in the right amounts for treatment processes, and that
                water pressure and flow are at proper levels. SCADA systems may also
                monitor activity along water transmission pipelines, detecting breaks or
                pressure loss.

                While SCADA systems help utilities manage their operations, they can
                create an additional opportunity for sabotage. Almost half of the experts
                on our panel (19 of 43) identified SCADA and other information systems as
                being among the top vulnerabilities of drinking water systems (although
                only one expert ranked it as the top vulnerability). Experts’ concerns
                include cyber attacks on SCADA systems from a remote location, which
                could, for example, release harmful amounts of water treatment chemicals
                (such as chlorine) into treated water.




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Treatment Chemicals   The types and amounts of treatment chemicals applied by a drinking water
                      facility to its influent varies, depending on the type of source water (for
                      example, surface water or groundwater) as well as its quality. Because
                      surface water systems are exposed to direct wet-weather runoff and to
                      atmospheric forces, they generally require more treatment under federal
                      and state regulations than do groundwater systems.1

                      Water suppliers use a variety of treatment processes to remove
                      contaminants from drinking water. The most commonly used treatment
                      processes for surface water include filtration to remove particles such as
                      clays, silts, and microorganisms; flocculation and sedimentation to
                      consolidate small particles into larger particles that can be more easily
                      removed from the water; and disinfection to eliminate bacteria and other
                      microbiological contaminants.

                      Treatment chemicals are used in some of these processes. The disinfection
                      process is particularly noteworthy in this regard; chlorine, chloramines, or
                      chlorine dioxide not only are used at the treatment plant, but also are
                      frequently present in some form in the pipes that distribute water to homes
                      and businesses.

                      Thirteen of the 43 experts identified treatment chemicals as among the top
                      vulnerabilities of drinking water systems, second only to the distribution
                      system. Experts commented that it was inherently dangerous to use and
                      store large cylinders of gaseous chlorine, noting that the destruction of
                      these storage containers could release toxic chlorine gas in densely
                      populated areas. Some of these experts noted, however, that this risk is
                      being alleviated as utilities increasingly use the more stable liquid form of
                      chlorine instead of the more vulnerable large compressed-gas chlorine
                      canisters that have traditionally been used. In addition to the risks of
                      chemical sabotage at the treatment facility, one expert cited the risk of
                      using tainted treatment chemicals at the facility. According to another
                      expert, “If these treatment chemicals have been purposely contaminated
                      . . . prior to delivery, every precautionary measure taken by the water
                      system has been bypassed.”




                      1
                       A discussion of the influence of these factors on treatment is available in the preamble in
                      both the Surface Water Treatment Rule and the Stage I Disinfectants/Disinfection
                      Byproducts Rule.




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Overarching Issues         In addition to the vulnerabilities associated with specific water system
                           components, experts identified several overarching issues that
Affecting Drinking         compromise the integrity of physical assets and the drinking water system
Water Systems’             in its entirety. Chief among these issues are (1) the lack of redundancy
                           among vital systems, and (2) the difficulty many operators face due to a
Security                   lack of information on the most serious threats to which their systems
                           might be exposed.



Lack of Redundancy among   Drinking water systems are generally “linear” in nature in that they have
Vital Systems              single transmission lines leading into the treatment facility, single pumping
                           stations along the system, and a single computer operating system.
                           Furthermore, drinking water systems may rely on outside sources of power
                           and communications, and depend on the transportation sector for the
                           delivery of supplies, often from a limited number of suppliers. If any of
                           these external sources were impaired or destroyed, the entire system could
                           be compromised. Under these circumstances, any “single point of failure”
                           could render a system inoperable unless there are redundant systems in
                           place.

                           Several experts reflected concerns relating to a single point of failure as a
                           vulnerability. For example, according to one expert, the destruction of a
                           single physical component of the system, such as a single water
                           transmission line into the treatment facility, could render the entire system
                           inoperable. Moreover, she noted, a system that depends on pumps can be
                           completely put out of service if its electrical supply were interrupted.
                           Echoing this point, another expert commented, “Experience with Y2K
                           planning efforts revealed one of the critical interdependencies nearly all
                           water utilities have is with the electrical power supply system. Disruption
                           of power supply could have significant impacts on source, treatment and
                           distribution systems.”2

                           According to one expert, efforts are needed to add redundancy to drinking
                           water systems and to mitigate systems’ near-total reliance on power
                           suppliers, communications systems, and the transportation sector.
                           However, such efforts to duplicate major system components would be
                           expensive and could conflict with the systems’ goals of controlling rate


                           2
                            These comments, made prior to the electric supply disruption of August 2003, were vividly
                           illustrated when that power outage severely disrupted the water supplies of several cities.




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                              increases. To address the problem, some experts advocated the creation of
                              utility consortia, such as the Bay Area Security Information Collaborative
                              (BASIC) and the Mutual Aid Disaster Intervention Response Teams
                              (MADIRT), through which regional utilities share resources in the event of
                              a disaster.



Insufficient Information to   A number of experts commented that it is impossible to accurately identify
Understand the Most           a utility’s most significant vulnerabilities unless the utility has reliable
                              intelligence regarding its most significant threats. Threats include the type
Significant Threats           of adversary (a casual vandal, an anonymous hacker, a disgruntled
                              employee, or a dedicated terrorist) as well as the mode of attack (physical,
                              psychological, chemical, biological, or radiological). According to the
                              American Water Works Association, a utility’s assessment of its most
                              credible threats should be based on knowledge of the threat profile in its
                              specific area, including such information as past events, that could shed
                              light on future risks. These assessments often require information from
                              outside sources, such as local law enforcement officials.

                              Many experts on our panel noted, however, that such information has not
                              been easy for utilities to obtain. The following examples illustrate some of
                              the difficulties utilities have regarding threats:

                              • According to one expert, “The utility community has very little specific
                                and useful information on the threat posed to this industry. This
                                represents a real vulnerability since it makes it harder to judge where
                                resources might do the most good.” Furthermore, “an ongoing working
                                relationship with groups (mostly federal) that do this type of analysis
                                could prove extremely valuable in determining how to allocate the
                                limited resources available.”

                              • Utilities may be preoccupied with unsubstantiated threats, according to
                                another expert. She noted, “There are many very vulnerable areas, but
                                the terrorists may not be technically able to target them, or they may not
                                be interested.”

                              • Another expert stated that utilities need to better understand “how the
                                threats may . . . exploit utility operations and infrastructure,” through
                                such things as simulation exercises.




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• One expert suggested that the intelligence community provide better
  threat information and share it with the water sector through the Water
  ISAC.

Since the consequences associated with various potential threats are
markedly different, EPA guidance suggests that the threats be analyzed in
the system’s vulnerability assessments.3 Some vulnerability assessment
methodologies refer to the threats selected for consideration as a Design
Basis Threat. Because there is no single Design Basis Threat4 for all water
systems in the United States, water systems often have a difficult time
identifying their unique threat profile. As a result, EPA developed a
Baseline Threat Information document for systems serving populations
greater than 3,300 to help assess the most likely threats to their systems.




3
 Environmental Protection Agency, Vulnerability Assessment Fact Sheet, EPA 816-F-02-025,
November 2002, available on the Web at
http://www.epa.gov/ogwdw000/security/va_fact_sheet_12-19.pdf.
4
 Design Basis Threat: The threat serves as the basis for the design of countermeasures as
well as the benchmark against which vulnerabilities are assessed.




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Experts’ Views on the Allocation and
Distribution of Federal Funds                                                                  Chapte3
                                                                                                     r




               Many drinking water utilities have been financing at least some of their
               security upgrades by passing along the costs to their customers through
               rate increases. Given the cost of these upgrades, however, the utility
               industry is also asking that the taxpayer shoulder some of the burden
               through the congressional appropriations process. Should Congress and
               the Administration agree to this request, they will need to address key
               issues concerning who should receive the funds and how they should be
               distributed. With this in mind, we asked our panel of experts to focus on
               several key questions: (1) To what extent should utilities’ vulnerability and
               risk assessment information be considered in making allocation decisions?
               (2) What types of utilities should receive funding priority? and (3) What are
               the most effective mechanisms for directing these funds to recipients?
               Overall, we found a high degree of consensus on the following:

               • Vulnerability assessment may be a useful tool in determining which
                 utilities receive priority for federal funds to improve security. Several
                 factors, however, complicate the government’s ability to use a primary
                 source of this information—the vulnerability assessments (VA) required
                 of utilities under the Bioterrorism Act. Among the factors, the act
                 prohibits disclosure of information derived from these assessments
                 submitted to EPA.

               • Almost all of the experts gave utilities serving high-density populations a
                 high or highest funding priority. Utilities serving critical assets (such as
                 military bases and other sensitive government facilities, national icons,
                 and key cultural or academic institutions) were also recommended as
                 high-priority recipients, while relatively few experts recommended a
                 high or highest priority for utilities serving rural or isolated populations.

               • Direct federal grants are the most favored funding mechanism, with
                 many experts indicating that such grants should include a requirement
                 for matching funds from the recipient. Relatively fewer experts
                 recommended the use of the Drinking Water State Revolving Fund,
                 particularly for upgrades to be implemented in the near term.




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Strong Agreement That     As noted in chapter 1, the Bioterrorism Act requires that vulnerability
                          assessments be prepared by all community water systems serving more
Allocation Decisions      than 3,300 individuals. EPA guidance on preparing these assessments states
Should Consider a         that the assessments should (1) characterize the water system, including its
                          mission and objectives; (2) identify and rank the possible consequences of
Utility’s Vulnerability   malevolent acts; (3) determine the critical assets subject to malevolent
Assessment                acts; (4) assess the threat of malevolent acts; (5) evaluate existing
                          countermeasures; and (6) analyze risk and develop a plan for reducing risk
                          and addressing critical priorities first.

                          In considering whether it is appropriate to use vulnerability and risk
                          assessment information when making federal funding decisions, about 90
                          percent of the experts on our panel (39 of 43) strongly agreed or somewhat
                          agreed that funds should be allocated on the basis of VA information. Some
                          experts cited the vulnerability assessments required by the Bioterrorism
                          Act as the best available information about the current condition of our
                          security infrastructure for drinking water (see fig. 5).




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Figure 5: Experts’ Views on Whether Federal Funds Should Be Allocated Based on
Vulnerability Assessment Information




It may not be a straightforward matter, however, to use this information in
making such decisions. Several experts pointed to a number of
complicating factors. One pointed out that “vulnerability assessment (VA)
tools were not set up for the purpose of identifying and prioritizing capital
improvement needs for EPA or other federal agencies.” He added, “Using
the VAs would require a high degree of interpretation and judgment on
someone’s part . . ., using a tool that was not designed to clearly delineate
capital construction needs.” Another expert noted similarly that “since
there is no written guidance for threat analysis, there will have to be some
method to rank relative threats among different areas.” In addition, one
expert pointed out an inherent dilemma affecting any effort to prioritize




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funding decisions based on the greatest risk—whatever does not receive
attention becomes the best target.1

In addition, a provision of the Bioterrorism Act precludes disclosing all
information “derived” from the vulnerability assessments submitted to
EPA. The provision’s intent was to protect sensitive information about
utilities’ vulnerabilities from falling into the hands of individuals who seek
to harm the utility. The act therefore specifies that only individuals
designated by the EPA Administrator may have access to the copies of the
VA and information contained in or derived from it. It further specifies that
the information must remain protected at all times.

Thus, while some EPA officials may have access to the information, the
requirement limits how the agency may use that information. EPA would
have difficulty, for example, in citing vulnerability assessment findings to
support decisions or recommendations on allocating security-related funds
among utilities, as well as decisions concerning research priorities or
guidance documents.

To compensate somewhat for these limitations, the American Water Works
Association Research Foundation has initiated a project in which
consultants and trainers, who have conducted multiple assessments, are
seeking to identify lessons learned from the vulnerability assessments done
to date. According to EPA’s draft Water Security Research and Technical
Support Implementation Plan, this project is designed to obtain a more
accurate picture of the major vulnerabilities that are generally facing the
nation’s drinking water systems and to share that understanding with
interested parties.2 EPA and the Research Foundation plan to use the
results of this project to identify high priority needs and concerns that
could likely be best addressed by EPA, the research community, or both.
This project is scheduled for completion in mid-2004.




1
 Citing this reason, one expert suggested the addition of a “dual use” criterion in which the
funds spent would also fix some existing utility deficiency, such as noncompliance with a
drinking water standard.
2
 Environmental Protection Agency, Office of Water, Office of Research and Development,
Water Security Research and Technical Support Implementation Plan, Preliminary
Working Draft, July 2003.




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Key Criteria to Help   The experts identified several characteristics of utilities that should be
                       used to set funding priorities. The most frequently identified were utilities
Determine Which        (1) serving high-density populations; (2) serving sensitive or critical assets,
Utilities Should       such as military bases, academic institutions or icons of American culture;
                       (3) in proximity to population centers (whether they serve these population
Receive Funding        centers or serve outlying areas); and (4) serving rural or isolated
Priority               populations, such as small systems with less sophisticated water systems
                       (see fig. 6).



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




                       Utilities Serving High-Density Populations. Approximately 93 percent of
                       the experts (40 of 43) gave high or highest priority to funding utilities
                       serving high-density populations. As one expert commented, directing



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limited resources to protect the greatest number of people is a common
strategy when setting priorities. Most experts shared this view, including
one who noted the “population served would probably lead to economies
of scale—you can protect the most people by spending monies at the large
systems.” This expert and others, however, though supportive of funding
priority for utilities serving high-density populations, cautioned that while
targeting high-density populations may be the most equitable to the entire
country, it might not allocate enough to small systems.

Utilities Serving Sensitive or Critical Assets. Seventy-seven percent of the
experts (33 of 43) indicated that utilities serving sensitive or critical assets
should receive a high or highest priority for federal funding. Experts
identified such utilities as those servicing national icons that represent the
American image, those serving military bases, or those serving sensitive
government, academic and cultural institutions. In addition, according to
one expert, utilities in areas typically receiving extensive media coverage,
or that serve venues where large groups gather, may be of interest to
terrorists.

Utilities in Proximity to Population Centers. Twenty-eight percent of the
experts (12 of 43) cited the proximity of a given utility to a major
population center as at least a high funding priority. While most utilities
close to population centers would be expected to serve the population
center in which they are located (hence, this third criterion would overlap
with the first criterion above—utilities serving high-density populations),
some experts pointed out that this is not always the case. Exceptions cited
include suburban utilities that may serve communities or their major
metropolitan areas. Several particularly noted that the risks associated
with an airborne release of chlorine gas elevated their funding priority for
this criterion.

Utilities Serving Rural or Isolated Populations. About 5 percent of the
experts (2 of 43) identified utilities serving rural or isolated populations as
at least a high priority for federal funding. Generally, these panelists
commented that such facilities are least able to afford security
enhancements, and therefore most need federal support. One expert, for
example, stated that in light of their financial constraints, “smaller utilities
do the cheapest thing possible, which means you do a quick checklist and
then forget about it.” He added that because these smaller systems do not
have enough staff to do a comprehensive assessment, they need funding to
either hire additional staff or to contract for outside expertise.




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                       Importantly, the relatively small percentage of experts supporting funding
                       for rural utilities may not fully reflect the concern many panel experts have
                       for the safety of these utilities. For example, several who supported higher
                       priority for utilities serving high-density populations cautioned that, while
                       problems at a large utility will put more people at risk, utilities serving
                       small population areas may be more vulnerable because of weaker
                       treatment capabilities, fewer highly trained operators, and more limited
                       resources. Another expert added that most waterborne disease outbreaks
                       have occurred in the systems of smaller utilities.



Funding Mechanisms     We also asked the expert panel to comment on how federal funds should be
                       distributed to recipients. Nearly 90 percent said that direct federal grants to
Recommended for        utilities would be a somewhat or very effective means of distributing funds
Distributing Federal   to support security improvements. The experts also showed strong support
                       for grants in which some type of match is required of recipients. Figure 7
Funds                  shows their views on these and other funding mechanisms.




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Figure 7: Recommended Approaches for Distributing Federal Funds




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                        Experts’ Views on the Allocation and
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Direct Federal Grants   Eighty-six percent of the experts (37 of 43) indicated that direct federal
                        grants to the utility would be somewhat or very effective in allocating
                        federal funds. Federal grants typically provide funding for fixed or known
                        periods for specific projects and often have associated terms and
                        conditions. One expert cited EPA’s recent efforts to quickly distribute
                        security-related grant funds to systems serving over 100,000 people
                        (mentioned earlier in this chapter), noting, “By far the most successful
                        funding program I have seen to date was the large water system
                        Vulnerability Assessment Grant program directed through the EPA.”3

                        Many experts commented that direct grants could be particularly useful in
                        quickly addressing lower-cost and more obvious fixes, such as adding gates
                        and security cameras. Two others said that with some of these shorter-term
                        items addressed, it may then be appropriate to deal with more complex
                        issues that require longer-term fixes, such as new buildings and security-
                        oriented building design. Another expert added that the use of direct EPA
                        grants could help ensure proper use of the funds, noting, “Direct EPA
                        grants to water systems should be made available and should carry a
                        requirement to use Sandia-like methodologies and concepts,” and that “the
                        use of [these tools] will lead water systems to develop cost-effective risk
                        reduction through effective physical systems, better policies, procedures
                        and training and through creative consequence mitigation.”

Matching Grants         Many favoring direct grants were among those who said that a matching
                        requirement for such a grant would be desirable for distributing future
                        federal funds. Specifically, 74 percent of the experts (32 of 43) said that
                        federal grants with a matching requirement would be somewhat or very
                        effective in distributing federal funds. One expert pointed out that such a
                        requirement would effectively leverage limited federal dollars. Another
                        agreed, noting that such a cost-sharing approach would offer “a big
                        incentive” in getting utilities to devote their own funds to enhance their
                        security. The expert cautioned, however, that the required match would



                        3
                         As noted earlier in this report, these grants supported VAs, remediation planning, and
                        emergency plan development through August 2002. EPA issued grant awards to over 400
                        publicly owned and privately owned community water systems that regularly serve
                        populations over 100,000. This program was noncompetitive, and all eligible utilities that
                        submitted completed grant applications received awards. The value of each grant did not
                        exceed $115,000. An EPA official pointed out that higher dollar grant programs might have
                        additional administrative requirements.




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                          have to be low enough to make the grant attractive, suggesting a maximum
                          of 50 percent.

                          Another suggested a strategy to get the most out of a matching grant
                          program. One, for example, said that participating utilities should be
                          provided with some initial matching funds to get started, and that
                          additional funds would then be contingent upon how effective or creative
                          they were in using the first round of funding.



Funds Distributed by an   Sixty-five percent of the experts (28 of 43) indicated that it would be
Independent Agency        somewhat or very effective to have federal funds distributed through an
                          independent agency. Experts generally characterized an independent
                          agency as, among other things, being independent of regulatory decision
                          making, and not bound by traditional points of view.

                          Several experts elaborated on the desirability of such an independent entity
                          to allocate security-related funds. One expert, for example, favored moving
                          the responsibility for allocating funds to a disinterested third party—one
                          with no infrastructure to support or hidden agenda but instead with strong
                          decision analysis and consensus building expertise. Another expert
                          suggested that federal funding be “leveraged with industry funding through
                          an organization like [the American Water Works Association Research
                          Foundation.]” The expert further stated that the use of an organization like
                          the Research Foundation is important because it has a demonstrably
                          effective two-way communication with the end users, namely the U.S.
                          water utility industries; the Research Foundation can adequately represent
                          the needs of industry to the research community as well as inform the
                          industry of important national-level research findings that will influence
                          their day-to-day operations. He indicated that communication between the
                          water utilities and such an independent agency would be superior to
                          communication between the utilities and EPA, noting, “Although [EPA] is
                          legitimately engaged in research, [it] is also perceived as an agency with
                          regulatory authority and is thus viewed somewhat circumspectly by
                          industry as a whole.”




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Drinking Water State   About 51 percent of the experts (22 of 43) indicated that the Drinking Water
Revolving Fund         State Revolving Fund (DWSRF) would be somewhat or very effective in
                       distributing federal funds. The DWSRF program provides federal grant
                       funds to states, which in turn allow the states to help public water systems
                       in their efforts to protect public health and ensure their compliance with
                       the Safe Drinking Water Act. States may use DWSRF funds to provide loans
                       to public water systems, and may reserve a portion of their grants to
                       finance other projects that protect sources of drinking water and enhance
                       the technical, financial, and managerial capacity of public water systems.
                       In particular, under EPA’s November 2001 guidance, states may use DWSRF
                       assistance to help systems complete both vulnerability assessments, and
                       contingency and emergency response plans.4 Many types of security-
                       related infrastructure improvements to ensure security are also eligible for
                       DWSRF funding, as specified in the EPA guidance.

                       According to one expert who favored existing grant and loan programs like
                       the DWSRF for enhancing security, continuing to support the training and
                       assistance efforts of lead state agencies “is the most beneficial activity the
                       federal government could play to encourage water utilities across the
                       country to address security related issues in a comprehensive and cost-
                       effective manner.” Another shared this view, explaining that states are well-
                       positioned to help manage the process, and that they “must approve system
                       upgrades anyway.” This expert also suggested that by using the state-
                       administered DWSRF, “states could track this information and report it on
                       a regular basis to EPA and Congress,” thereby documenting what has been
                       accomplished and what still needs to be done.

                       One expert cautioned, however, that the DWSRF would be effective only if
                       a process were established that separated funding for security-related
                       needs from other infrastructure needs. Reflecting the concern expressed
                       by many others about the timeliness of distributing funds through the
                       DWSRF, this individual commented that the current DWSRF process is too
                       bureaucratic and requires too many hurdles for it to be an expeditious
                       means for providing funds.




                       4
                        Environmental Protection Agency, Office of Water, Use of the Drinking Water State
                       Revolving Fund (DWSRF) to Implement Security Measures at Public Water Systems, EPA
                       816-F-02-040, November 2001, available on the Web from
                       http://www.epa.gov/ogwdw000/dwsrf/security-fs.pdf.




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Tax-Based Incentives   About 28 percent of the experts (12 of 43) reported that tax-based
                       incentives would be somewhat effective in encouraging water utilities—
                       specifically privately owned utilities—to invest in security improvements.
                       The inducements offered in these programs may include tax credits,
                       property tax exemptions or abatements, and sales and use tax exemptions.

                       According to one expert, tax incentives could increase the efficiency of
                       dollars spent on water security, generating new ideas and approaches.
                       Furthermore, by offering additional funds for creative and cost-effective
                       solutions, these ideas could become best practices and shared with others.
                       Finally, he commented, “If allocations were phased and secondary funds
                       were based upon how well the first funds were spent, there would be
                       incentive to spend the first funds wisely.” Another expert suggested that the
                       provision of financial or other tax incentives to utilities should be
                       contingent upon evidence that they have improved their security as defined
                       by a standard set of measurements.




                       Page 42                                        GAO-04-29 Drinking Water Security
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Activities Experts Identified As Most
Deserving of Federal Support                                                                           Chapte4
                                                                                                             r




                        When experts were asked to identify and rate the specific security-
                        enhancing activities most deserving of federal support, the activities
                        experts most frequently identified fell into three broad categories:

                        • Physical and technological improvements. These improvements
                          include altering drinking water systems to improve physical security,
                          and conducting research and development on technologies to prevent,
                          detect, or respond to an attack. Experts most strongly supported near
                          real-time monitoring technologies, which they considered particularly
                          useful in quickly detecting contaminants in water that has left the
                          treatment plant for consumers.

                        • Education and training. This category includes, among other things,
                          supporting simulation exercises to provide responders with experience
                          in carrying out utilities’ emergency response plans; specialized training
                          of utility personnel charged with security and general training to
                          improve the security awareness of their staffs; and multidisciplinary
                          teams that can provide independent analysis of utilities’ security
                          preparedness and recommend security-related improvements.

                        • Strengthening working relationships between utilities and other
                          public agencies. This category includes strengthening relationships
                          between water utilities and other entities that may have key roles in an
                          emergency response (such as public health agencies, enforcement
                          agencies, and neighboring utilities). It also includes developing common
                          protocols to engender a consistent approach among utilities in detecting
                          and properly diagnosing threats, and testing local emergency response
                          systems to ensure that participating agencies coordinate their actions
                          effectively.

                        We found that EPA has a number of initiatives that address many of these
                        activities, some of which are required by the Bioterrorism Act. In most
                        cases, however, the activities are in the planning stages, are limited in
                        scope, or are dependent on the availability of future appropriations.



Activities to Enhance   Our panel of experts most frequently recommended nine types of activities
                        to improve physical security and support technological improvements, as
Physical Security and   figure 8 shows. Of the nine types, the development and implementation of
Support Technological   near real-time monitoring technologies was rated by far the most important
                        activity warranting federal support, with many experts stating that this
Improvements


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                             critical activity would probably not be implemented by many utilities
                             without some degree of federal support.



                             Figure 8: Activities Identified by Expert Panel to Enhance Physical Security and
                             Support Technological Improvements




Developing Near Real-Time    Approximately 93 percent of the panel experts (40 of 43) rated the
Monitoring Technologies      expansion of research and development of near real-time monitoring
                             technologies as having at least a high priority. These technologies were
Viewed As Highest Priority   cited as critical to helping drinking water systems detect and respond
                             quickly to threats or actual contamination events, to minimize the impact
                             of any contamination by facilitating a quick response, and to help in
                             restoring systems after an event. Significantly, almost 70 percent of the
                             experts (30 of 43) rated this activity as warranting the highest priority for


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federal funding—far surpassing the rating of any other category. Most of
these experts indicated that smaller utilities would be unable to use these
technologies without federal support.

A wide variety of monitoring technologies can be used in drinking water
systems and, depending on their specific functions, may be deployed at
locations upstream from, within, or downstream from drinking water
treatment plants. Conventional monitors typically measure things such as
pH (acidity and alkalinity), turbidity, conductivity, temperature, organic
compounds and other contaminants. Biomonitors employ living organisms,
such as fish or algae, to provide information on other water constituents
that may impair human health or the environment.

Emerging monitoring technologies are capable of providing near real-time
results for a wider array of potentially harmful water constituents.
According to some experts, near real-time monitors may be strategically
placed at points within the distribution system, where they may be able to
quickly detect potentially dangerous backflows that may enter the system.
They may also be used to augment a system’s conventional monitoring
system. As some experts suggested, for example, pressure sensor systems
and biodetector networks could benefit the utility in its security
preparedness as well as its regular operations by describing breaches or
leaks in water mains, or by observing microbial contamination in a
nonterrorist event. Some monitors based on emerging technologies
capable of providing near real-time results may also be placed at the “point
of service,” where they can alert the consumer or utility about the potential
for contaminated water entering a home or business.

These views are substantiated by a 2002 report by the National Academies
of Science, which also highlighted the need for improved monitoring
technologies as one of the four highest-priority areas for drinking water
research and development. The report noted that such technologies differ
significantly from those currently used for conventional water quality
monitoring, stating further that sensors are needed for “better, cheaper, and
faster sensing of chemical or biological contaminants.”1




1
 The National Research Council of the National Academies, Making the Nation Safer: The
Role of Science and Technology in Countering Terrorism (Washington, D.C.: The National
Academies Press, 2002).




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The need for near real-time monitoring technologies was also recognized in
the Bioterrorism Act, which directed EPA to review analytical
methodologies and detection techniques that can quickly and accurately
provide information on contaminants.2 As an initial step in meeting this
requirement, the agency is reviewing such early warning systems, including
those designed to monitor levels of chemical, biological, and radiological
contaminants or indicators of contaminants.

EPA is also planning to launch a number of projects through its Office of
Water and Office of Research and Development. For example, one project,
planned for November 2003 through May 2004, would entail a detailed
examination of commercially available real-time monitors. According to
EPA, the information derived from this project would be placed in a
compendium for manufacturers and vendors of monitoring technology,
allowing them to better focus technology development efforts.3 Another
project aims to evaluate how well many currently used water monitoring
technologies would deal with the introduction of various contaminants.4
Among other efforts, EPA also hopes to begin a project in November 2003
to test and evaluate the applicability of other industries’ monitoring
technologies to the security-related monitoring needs of drinking water
systems. EPA’s preliminary cost estimates for monitoring-related projects
are about $5 million, and their initiation or completion will depend on the
availability of fiscal year 2004 and 2005 funds.




Bioterrorism Act, S 402.
2


3
 In addition, since August 2002, EPA has augmented its Environmental Technology
Verification (ETV) Program to include water security issues. The ETV Program can be used
to test, evaluate, and eventually bring promising technologies (e.g., detection and “point of
use” treatment technologies) to the marketplace. EPA has spent approximately $2 million of
fiscal year 2002 supplemental funds on the ETV Program and its related projects, and
estimates the total costs for the ETV projects at $8.1 million. Once technologies are verified,
EPA believes the technology can be tested in pilot-scale studies and potentially used at
drinking water systems.
4
 This work is planned to review both large and small treatment system monitoring
capabilities, distribution systems, and remote telemetry monitoring research, and will be
conducted in controlled conditions at the Office of Research and Development’s Water
Awareness Technology Evaluation Research and Security Center, located at EPA’s Test &
Evaluation Facility. The work is projected to end around December 2005.




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Increasing Laboratories’   Over two-thirds of the experts (29 of 43) rated increasing laboratory
Capacity to Deal with      capacity as a high or highest priority for federal funding. Many experts on
                           our panel commented that laboratories are being challenged just to keep up
Terrorist Attacks          with their normal responsibilities to collect, test, and analyze large volumes
                           of water samples for water utilities and other clients. Consequently, they
                           expressed reservations about the ability of laboratories to handle these
                           responsibilities in the event of “surge” events caused by the chemical,
                           biological, or radiological contamination of water supplies.

                           As one expert explained, few laboratories can test for a full range of
                           contaminants, and these limitations would be amplified if the laboratories
                           had to respond to a terror-related emergency. Another expert believed that
                           in the event of an emergency, many utilities would be confused about
                           which labs to use for testing samples of suspect water, and that a network
                           of labs needs to be established so that quick results of tests could be
                           obtained. The National Academies of Science report raised similar
                           concerns, adding that legal concerns over the accuracy of laboratories’
                           tests may make them reluctant to participate in testing under such severe
                           conditions. The report concludes that a “dearth of laboratory capacity
                           poses a serious limitation to our ability to respond to a contamination
                           attack on the water system.”5

                           One panelist suggested that state health departments need additional
                           federal funds to better develop the regional capacity to sample water, and
                           to improve analytical techniques used to detect contaminants. He further
                           noted that state laboratories can and would serve as a component of an
                           emergency response team, and that it would be effective for state
                           laboratory programs to integrate these new or increased responsibilities
                           with their existing responsibilities under grants from the Centers for
                           Disease Control and Prevention.6



                           5
                            The National Research Council of the National Academies, Making the Nation Safer: The
                           Role of Science and Technology in Countering Terrorism (Washington, D.C.: The National
                           Academies Press, 2002).
                           6
                            The Centers for Disease Control and Prevention (CDC) currently supports programs
                           directed to states in order to improve laboratory capacity and to ensure public health
                           preparedness, such as the Emerging Infections Program, the infectious disease
                           Epidemiology and Laboratory Capacity Program, and the National Electronic Disease
                           Surveillance System. For fiscal year 2003, CDC made approximately $870 million available
                           to applicants.




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                            EPA is actively supporting research in order to improve laboratory capacity
                            nationwide, and has identified a series of ongoing and future projects
                            toward that end. One project, which was due for completion in September
                            2003, would result in a water-specific compendium of laboratories that may
                            be able to assist water utilities if contamination occurs. A related project
                            would assess existing laboratory capacity to analyze drinking water
                            samples in emergency situations. Another project, initiated in June 2003, is
                            intended to analyze resource limitations at laboratories, such as personnel,
                            equipment, training, and methods, and to provide recommendations to
                            address these limitations.

                            According to EPA water officials, the agency may spend approximately $2.4
                            million starting in fiscal year 2003 to carry out these and other projects to
                            assess and address the capacity of the nation’s laboratories to deal with
                            emergency situations. However, the experts’ views on this matter suggest
                            that given the magnitude of this long-standing problem—even under
                            normal circumstances—it will be difficult enough to accurately
                            characterize the challenge of laboratory analysis during a drinking water
                            emergency, much less address the problem effectively.



“Hardening” Assets and      Over two-thirds of the experts (29 of 43) rated activities that would
Completing Other Physical   improve (or “harden”) the basic physical security of drinking water systems
                            as warranting either a high or highest priority for federal funding. These
Improvements
                            activities include, among others, adding or repairing fences, locks, lighting
                            systems, and cameras and other surveillance equipment. The National
                            Academies of Science report reached similar conclusions about the need to
                            harden certain facilities. It describes how many parts of the drinking water
                            infrastructure remain highly accessible, and notes that access controls
                            need to be improved. The report further noted that improved technologies
                            are needed to protect against explosives delivered by motor vehicle or rail.7

                            However, the experts’ support for hardening activities came with some
                            notable caveats. For example, one expert said that many utility operators
                            are reluctant to invest in physical upgrades because of fiscal shortfalls and
                            other competing Safe Drinking Water Act requirements, despite the
                            potential for such upgrades to be relatively cheap (many costing less than


                            7
                             The National Research Council of the National Academies, Making the Nation Safer: The
                            Role of Science and Technology in Countering Terrorism (Washington, D.C.: The National
                            Academies Press, 2002).




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                           $5,000 per system). According to this expert, if “an effective and adequate
                           grant program could be developed and managed,” small amounts of
                           funding could address the problems of many small drinking water systems.

                           Some experts also cited the limitations inherent in efforts to
                           comprehensively harden the physical drinking water facility. For example,
                           unlike nuclear power or chemical plants, drinking water system assets are
                           not concentrated in a geographically secure area that can be hardened
                           against all types of contamination or attack. Rather, they are spread over
                           large geographic areas, particularly the source water and distribution
                           systems. Thus, these panelists noted, while some degree of physical
                           security enhancement at drinking water facilities is appropriate, efforts to
                           construct physical barriers to comprehensively thwart attacks would be of
                           limited effectiveness. Several said that efforts might be better directed at
                           intruder detection, or adding security guards or electronic equipment.

                           The American Water Works Association Research Foundation is designing
                           a project that will collect information on vulnerabilities, threats, potential
                           security improvements, and innovative solutions to certain physical
                           vulnerabilities. This project began in June 2003 and is scheduled for
                           completion in July 2004. EPA also noted that utilities may be eligible to use
                           a portion of the Drinking Water State Revolving Fund for this purpose.8



Establishing Engineering   Approximately 49 percent of the experts (21 of 43) rated the establishment
Building Standards         of engineering and building standards for drinking water systems, which
                           integrate security concepts into building design, as having either a high or
                           highest priority for federal funding. Some noted that improved standards
                           could yield multiple benefits by improving upon the design and
                           functionality of a drinking water system while augmenting security to
                           guard against attack.

                           Others wrote that new drinking water systems, which are being
                           constructed and designed regularly, provide opportunities for
                           incorporating security measures. One expert noted specifically that new
                           design measures “may include increased physical security, elimination of


                           8
                            Environmental Protection Agency, Office of Water, Use of the Drinking Water State
                           Revolving Fund (DWSRF) to Implement Security Measures at Public Water Systems, EPA
                           816-F-02-040, November 2001, available on the Web at
                           http://www.epa.gov/ogwdw000/dwsrf/security-fs.pdf.




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                       ‘single points of failure,’ the inclusion of redundancy into the overall
                       design,” or the creation of multiple pathways from source to tap. Another
                       noted that the development and implementation of new or upgraded
                       systems with better layouts can reduce unauthorized access, improve
                       detection, and assist in isolating problems at the water facility.

                       According to another expert, standardization is needed across local
                       jurisdictions so that neighboring providers may assist one another in a
                       crisis. This view was echoed in the National Academies of Science report,
                       which concluded that the lack of standardization impedes the introduction
                       of new processes and technology.”9

                       According to the EPA Action Plan, the agency is also considering the
                       development of information on building standards that could enhance
                       security of drinking water facilities, while improving operations and better
                       protecting water quality. The plan noted that such standards would be
                       modeled after those developed by the Department of Defense, which found
                       that “dual use” aspects of improved design features are desirable because
                       many security enhancements are not cost effective without some form of
                       multiple benefit.10 Specifically, the proposed EPA plan includes working
                       with standards-setting organizations to develop voluntary design standards
                       and recommendations for new construction, reconstruction, and
                       retrofitting of drinking water facilities with a focus on integrating security
                       with ongoing operations.



Requiring Backflow     Inappropriate use of piping systems, whether intended or not, could result
Protections in Water   in a backflow of contaminated water into distribution systems, where it
                       could then find its way to other consumers. Backflow protection devices
Distribution Systems   are one way to potentially mitigate this threat when installed either at
                       access points to buildings or homes, or at cross connections in the
                       distribution system.




                       9
                        The National Research Council of the National Academies, Making the Nation Safer: The
                       Role of Science and Technology in Countering Terrorism (Washington, D.C.: The National
                       Academies Press, 2002).

                        Department of Defense, Unified Facilities Criteria (UFC): Department of Defense Minimum
                       10

                       Antiterrorism Standards for Buildings, UFC 4-010-01, July 2002, available on the Web at
                       http://www.acq.osd.mil/ie/irm/irm_library/UFC%204_010_01%20-%2031JUL2002.pdf.




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                       Approximately 47 percent of the experts in our study (20 of 43) said
                       research and implementation of such backflow protection warranted a high
                       or highest priority for federal funding. These backflow protection devices
                       could be coupled closely with monitoring and metering technologies that
                       can sense contaminant concentrations in drinking water systems. Another
                       noted further that automated meter reading is already being used, but the
                       ability to get real-time readings is essential in order to rapidly notify
                       technicians or officials if a backflow is detected. This could help reduce or
                       eliminate threats to the distribution system.11



Testing and Further    Section 402 of the Bioterrorism Act requires a review of “methods and
Protecting SCADA and   means by which information systems, including process controls and
                       Supervisory Control and Data Acquisition (SCADA) and cyber systems at
Cyber Systems          community water systems, could be disrupted by terrorists or other
                       groups.” Slightly more than one-third (15 of 43) of the experts on our panel
                       rated federal funding to test and further protect SCADA systems as
                       warranting a high or highest priority. Information provided at the 2003
                       American Water Works Association (AWWA) Water Security Congress
                       highlighted the limited security features inherent in many SCADA systems,
                       citing few security protocols, lack of firewalls, and SCADA data being
                       routed outside of a facility. Other SCADA systems are placed in networks
                       that are accessible through the Internet and, therefore, are exposed to
                       additional vulnerabilities. One expert added that because the majority of
                       the SCADA software is created outside the United States, the expert
                       favored establishing and enforcing security standards for the software, as
                       well as testing the software before installation at water utilities. This expert
                       believed that federal activities should include working with vendors of
                       SCADA systems and related software in order to ensure that security
                       concerns are appropriately incorporated into the design of these systems.

                       According to EPA, to meet its responsibilities under the Bioterrorism Act,
                       the agency is planning to pursue research in a number of areas to reduce


                       11
                          The Bioterrorism Act recognized the importance of dealing with this potentially serious
                       source of contamination. Specifically, section 402 of the Bioterrorism Act calls for a review
                       of “methods and means by which pipes, constructed conveyances, collection, pretreatment,
                       treatment, storage and distribution systems that are utilized in connection with public water
                       systems could be altered or affected so as to be subject to cross-contamination of drinking
                       water supplies.” In addition, section 402 requires the review of “procedures and equipment
                       necessary to prevent the flow of contaminated drinking water to individuals served by
                       public water systems.”




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                             the risks of attacks on drinking water SCADA systems and to better
                             understand their potential consequences, starting with an identification of
                             the possible threats posed to such systems. Starting in fiscal year 2004, EPA
                             also intends to (1) develop models that can simulate the consequences of
                             physical and cyber attacks, emphasizing the distribution system and
                             eventually cascading or interrelated consequences; (2) assess the
                             consequences of a loss of pressurized water on other critical infrastructure
                             sectors such as power, transportation, chemical supplies, and
                             communications; (3) compile technical information and informational
                             tools that can help in analyzing the consequences of potential physical and
                             cyber threats; and (4) establish minimum security standards for the
                             protection of SCADA systems.



Developing Computer          Computer modeling can be an important tool in understanding how to
Models of Terrorist Events   prevent or mitigate contamination episodes. Specifically, modeling can be
                             used to simulate contamination events, which in turn can enhance the
in Water Systems             development of emergency response plans, help select critical locations in
                             distribution systems for positioning and placing monitoring devices, and
                             guide the actions of first responders.

                             About 30 percent of the experts (13 of 43) rated the development of
                             computer models of terrorist events as deserving a high or highest priority
                             for federal funding. A number of experts noted the relevance of this work
                             for understanding the characteristics of distribution systems. One expert,
                             for example, advocated a “model-based distribution system flow simulator
                             that can be easily tailored to a specific water system such that ‘what-if’
                             contamination scenarios can be posed to the system through simulation in
                             order to explore weaknesses in the system.” The expert further stated that
                             such a modeling system would also have to take into account the fate and
                             transport of the candidate contaminants throughout the system, and that
                             the approach “would be a fusion of information from both threat
                             assessment and system modeling research efforts.”

                             According to EPA officials, the agency is evaluating distribution system and
                             source water hydraulic models, such as EPANET, PipelineNet, and
                             Riverspill, that can be used to follow water movements and tracer
                             chemicals through distribution systems. EPA notes that several large
                             utilities are currently using such models, but that medium and small
                             utilities face challenges in applying them to their systems. EPA was also
                             planning to initiate a project in September 2003 that will attempt to
                             improve these models by incorporating health-related data, data



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                               concerning consumer complaints, Geographic Information System data,
                               and information from SCADA systems. Overall, EPA’s preliminary cost
                               estimates are $2.8 million for modeling projects to develop more effective
                               protection of distribution systems.



Establishing Baseline Values   About 23 percent of the experts (10 of 43) rated the importance of
for Water Constituents         establishing baseline values (e.g., concentrations of certain chemicals
                               typically found in a drinking water system) for drinking water system
                               constituents as a high or highest priority warranting federal support. One
                               expert noted that developing and understanding the basic characteristics
                               and typical monitoring results of a distribution system are essential to
                               understand if and when a drinking water system is subject to
                               contamination. According to other experts, because distribution systems
                               may be the most vulnerable portion of a system, and the most complex in
                               terms of understanding appropriate response actions, baseline data
                               available from pre-emergency studies could be helpful.

                               In addition to providing utility operators with information on normal
                               operating conditions within their systems, understanding baseline levels of
                               water constituents is often needed to develop certain monitoring
                               technologies. For example, monitoring devices that measure the light given
                               off during certain organic reactions can be indicative of possible water
                               contaminants, but only if baseline luminescence levels are known and can
                               be incorporated into measurements and calibrations.

                               In March 2004, EPA plans to launch a project to survey available
                               information on background levels of certain contaminants of concern that
                               are known or suspected to occur in source or treated drinking water. The
                               initiation of this project depends on the progress of another planned
                               project to develop an improved understanding of the biological, physical,
                               chemical, and toxicological properties of contaminants.



Improving Treatment            About 23 percent of the experts (10 of 43) rated the improvement of
Technologies                   technologies that can better treat the kind of chemical or biological agents
                               likely to be used in attacking a drinking water system as warranting a high
                               or highest priority for federal funding. While water treatment technologies
                               have advanced, as indicated in EPA’s research and implementation action
                               plans, treatment capabilities still need to be evaluated and improved for a
                               wide array of microbial and other contaminants. One expert noted that
                               research on membranes (filters that can remove small particulates or


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                         microorganisms) and other advanced treatment techniques is producing
                         promising results, and that further progress in this area may be important
                         in making “water an unattractive target.”12 Specifically, treatment
                         technologies needing further development include ultraviolet systems and
                         improved reverse osmosis techniques. Finally, other experts believed that
                         there should be more research and development of point-of-use treatment
                         devices (possibly installed at the meter), and that a distributed treatment
                         process—one that involves the treatment of water at multiple locations
                         within a drinking water system or uses a variety of methods—would
                         provide additional security against contamination.

                         According to EPA officials, the agency hopes to initiate a series of projects
                         to address drinking water treatment issues. Among these are efforts to (1)
                         identify alternative treatment options by reviewing literature on
                         contaminants most likely to be used in attacking drinking water systems;
                         (2) prepare systematic methods to evaluate treatment technologies for
                         likely contaminants; (3) perform bench-scale studies (those performed in a
                         laboratory under controlled conditions) to determine the effectiveness of
                         typical disinfection and contaminant removal technologies; (4) identify
                         alternative treatment options at the point of use or point of entry; and (5)
                         develop guidance for discharging contaminated water that had been used
                         to clean contaminated substances or equipment.



Activities to Improve    Experts strongly supported improved training and education to help ensure
                         that utility personnel can detect and respond to malevolent acts affecting
Education and Training   their facilities. As shown in figure 9, the education and training activities
                         most frequently recommended for federal support generally fell into four
                         categories: (1) specialized training of utility personnel with security-related
                         responsibilities, (2) support for regional simulation exercises to test
                         emergency response plans, (3) general security awareness training for
                         utility personnel not specifically charged with security-related
                         responsibilities, and (4) use of multidisciplinary consulting teams (“Red
                         Teams”) to independently evaluate drinking water utilities and their
                         security concerns.




                         12
                          For general information on membrane treatment options or examples, refer to EPA’s
                         proposed draft Membrane Filtration Guidance Manual, EPA 815-D-03-008, Office of Water,
                         June 2003.




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                           Figure 9: Activities Identified by Experts to Improve Education and Training




Required Training of Key   Many experts underscored the importance of training drinking water
Utility Personnel          personnel with security-related responsibilities in techniques to prevent,
                           detect, and, if necessary, respond to an attack on their system. This training
                           would include, for example, training for laboratory technicians who test for
                           potential contaminants; for utility operators who perform day-to-day duties
                           or who are uniquely positioned to monitor and respond to potential
                           contaminants at a treatment facility; and for mechanical, civil, and
                           environmental engineers who design, repair, and maintain drinking water
                           systems.

                           Overall, over 90 percent of the experts (39 of 43) indicated that required
                           training for security-related personnel warrants at least a high priority for



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                           federal funding, with approximately 56 percent (24 of 43) indicating that it
                           deserved highest priority. One expert said that there should be mandatory
                           federal training for employees at drinking water systems serving 10,000
                           people or more.

                           To date, EPA has launched at least three programs that emphasize technical
                           training, one directed to states and another to utility employees and
                           officials. Through one program, beginning in fiscal year 2002, EPA has
                           made grants available to states and territories that, in part, are intended to
                           support security-related training and education.13 Also, EPA has developed
                           two train-the-trainer programs. One of these, begun in fiscal year 2003 to
                           provide assistance to drinking water systems serving fewer than 50,000
                           people, awarded $1.5 million in grants to five nonprofit training and
                           technical assistance organizations.14 Another program makes available “no
                           cost” security training for drinking water systems that serve populations of
                           50,000 to 100,000.15 This program, which also provides assistance to
                           develop vulnerability assessments and emergency response plans, includes
                           provisions for follow-up technical assistance and training.



Regional Simulation        Regional simulation exercises to test emergency response plans are
Exercises to Test          intended to provide utility and other personnel with the training and
                           experience needed both to perform their individual roles in an emergency
Emergency Response Plans   and to coordinate these roles with other responders within and outside the
                           utility. A successful emergency response plan can help these staff members
                           more quickly identify and respond to an emergency and more quickly
                           restore services and public confidence.




                           13
                            The additional monies are for coordination within the state or territory on homeland
                           security issues, developing or enhancing vulnerability assessments and emergency response
                           plans, and setting up a communications strategy for states and utilities.
                           14
                            The grants (up to $300,000 per entity) were intended to build staff expertise in drinking
                           water security, after which these individuals would train state, tribal and local agencies at
                           no cost on security and technical issues. Grant recipients included the Maryland Center for
                           Environmental Training, the National Environmental Services Center, the National Rural
                           Water Association, the Rural Community Assistance Program, and the Water Environment
                           Federation.
                           15
                             This is a program implemented by the International City/County Management Association
                           (ICMA), an organization representing local government leaders, and the Water Environment
                           Federation (WEF), a not-for-profit technical and educational organization.




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                             The experts on our panel underscored the importance of conducting such
                             exercises, with more than 88 percent (38 of 43) rating these exercises as
                             warranting a high or highest priority for federal funding. Exercises not only
                             give individuals invaluable practice, but also allow officials to better
                             determine what kind of coordinated response is best for a given adverse
                             event. Other experts described the need to identify responsible agencies
                             that will make difficult decisions during an emergency, such as whether to
                             restrict use of the drinking water supplies. And if water supplies were
                             disrupted, subsequent issues would also need to be anticipated, such as
                             how to fight fires, mobilize resources (such as the distribution of bottled
                             water), and communicate among the emergency responders and to the
                             public.

                             EPA’s Water Protection Task Force has developed a program to support
                             training exercises across the United States at systems serving over 100,000
                             people. In 2003, the agency intends to conduct workshops at approximately
                             30 to 45 locations across the United States to provide guidance on
                             emergency response plans and on the Bioterrorism Act’s requirements; to
                             present an overview on protocols for responding to contamination events;
                             and to provide information on environmental laboratory capabilities.16



General Awareness Training   In addition to supporting the specialized training recommended for
on Security Issues           responders “on the front lines” of an emergency, experts strongly endorsed
                             a more general level of training for all utility personnel. The need to
                             emphasize culture change at utilities, as well as among law enforcement
                             staff, was summarized by an AWWA official who commented at a recent
                             security conference about how multimillion-dollar investments in security
                             technology can be undermined by an employee using a brick to prop open a
                             usually locked door.

                             About 79 percent of the experts (34 of 43) rated such “general awareness”
                             training as warranting at least a high priority for federal funding. One
                             expert noted that such training is needed because the water sector has
                             traditionally been slow to respond to new challenges (such as new



                             16
                              In addition to these workshops, EPA published a guidance document for utilities to
                             provide for uniform response, recovery and remediation processes. (See Guidance for
                             Water Utility Response, Recovery & Remediation Actions for Man-Made and/or
                             Technological Emergencies, EPA 810-R-02-001, April 2002).




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                               regulations), and that such training could therefore be particularly
                               important in raising the consciousness of staff to security-related issues.

                               During fiscal year 2002, EPA completed general security training, in
                               collaboration with the American Water Works Association and the Water
                               Environment Federation, to educate water utility managers and operators
                               about the “entire spectrum of security issues,” including vulnerability
                               assessments, development of emergency response plans, and risk
                               communication. The organizations convened workshops, conducted
                               webcasts, and offered online courses. More recently, EPA’s Office of
                               Research and Development has developed a draft Water Security Research
                               and Technical Support Implementation Plan for key research-related
                               projects, some of which involve developing training modules and related
                               guidance documents that will address monitoring, threat evaluation, and
                               analytical protocols. This training would address the specialized needs of
                               field and laboratory personnel. However, according to EPA officials, some
                               of these efforts would also support the general awareness training needs of
                               the larger universe of utility personnel.



Multidisciplinary Consulting   Multidisciplinary consulting teams, often called “Red Teams,” consist of
Teams to Analyze Utilities’    experts in a wide variety of security- and drinking water-related disciplines.
                               Red Teams could be used to provide independent analyses of utilities’
Risks and Vulnerabilities      vulnerabilities, and to assess their emergency response preparedness, as
                               well as to educate law enforcement and public health agencies.
                               Approximately half of the experts (22 of the 43) rated support for certified
                               Red Teams as warranting either a high or highest priority for federal
                               funding.

                               According to one expert, an effective Red Team would consist of “at least
                               six people with widely varying areas of expertise (physical, water quality,
                               SCADA, policies and procedures, emergency response, etc.), and are able
                               to work together and sort through various concerns and priorities to
                               develop a unified understanding of the security issues at a given utility.” He
                               noted further that the team would visit utilities, and recommend changes or
                               upgrades to security standards, procedures, and facilities, based on their
                               best professional judgment. Another expert noted that Red Teams could
                               make client utilities aware of threat assessment information, and may be
                               able to review vulnerability assessments independently.




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Activities to Strengthen   Experts also cited enhanced cooperation and coordination among
                           government organizations and utilities as a key component in drinking
Relationships between      water utilities’ efforts to improve their security. Our analysis of experts’
Agencies and Utilities     responses identified six types of activities in this category as most
                           deserving of federal support.17 These activities, in figure 10, include (1)
                           developing common protocols for monitoring drinking water threats, (2)
                           improving relationships between drinking water utilities and public health
                           agencies, (3) improving relationships between utilities and law
                           enforcement agencies, (4) testing local emergency response systems, (5)
                           sharing resources among utilities, and (6) establishing physical
                           interconnections between drinking water facilities and distribution
                           systems.




                           17
                            More than 50 percent of the experts rated these activities as deserving a high or highest
                           priority for federal funding relative to the other activities. Experts also identified three other
                           activities scoring under 50 percent, including the formation of better relationships between
                           water associations and federal agencies (about 26 percent), developing public education
                           programs (about 19 percent), and forming a tracking system to monitor security funding
                           (about 12 percent).




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                         Figure 10: Activities Identified by Experts to Strengthen Relationships between
                         Agencies and Utilities




Developing Common        According to EPA, drinking water utilities vary widely in how they perceive
Protocols to Monitor     threats and detect contamination. These differences often occur because
                         utilities have few common protocols to help promote a more consistent
Drinking Water Threats   approach in performing activities such as assessing or monitoring threats.

                         The experts in our study also identified this lack of consistency, with over
                         90 percent (39 of 43) rating the development of common protocols to
                         monitor drinking water threats as warranting a high or highest priority for
                         federal funding. Some experts described the need for a nationally
                         consistent and uniform analytical response to contamination threats,



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                               noting in particular the need to have protocols in place for identifying,
                               sampling, and analyzing contaminants. Some also cautioned that older
                               methodologies need to be reexamined in the context of terrorism, and that
                               new protocols need to be reviewed as they are developed. For example,
                               any standard process developed for detecting potentially harmful
                               microorganisms in drinking water needs first to be validated, and then
                               implemented appropriately for different sizes and types of utilities.

                               EPA officials cited a number of projects under way to develop or improve
                               protocols that address a variety of activities highlighted in other sections of
                               this chapter. They noted that guidance documents in development will
                               include a “toolbox” with information on how to respond to threats and
                               attacks. EPA also intends to develop guidance to assist law enforcement
                               officers and utility officials in assessing the credibility of threats, and
                               guidance on sampling and performing recovery and remediation work at
                               the sites of potential or real contamination.



Improving Relationships        Drinking water utilities and public health agencies would appear to be
between Utilities and Public   natural allies in a common health-related enterprise—delivering safe,
                               sanitary water supplies to the vast majority of the nation’s population.
Health Agencies
                               Their relationship is seemingly reinforced further in many states where the
                               state’s drinking water office is located within its health department.

                               Nonetheless, about 86 percent of the experts in our study (37 of 43)
                               recommended a high or highest funding priority for activities devoted to
                               improving working relationships between drinking water utilities and
                               health agencies. Such activities may include

                               • characterizing and studying potential biological, chemical, and
                                 radiological contaminants and getting this information to all levels of
                                 public health departments and officials;

                               • clarifying and testing the effectiveness of disinfectants or other
                                 approaches to neutralize such contaminants; and

                               • standardizing effective public notification processes in the event of
                                 potential or real contamination of drinking water systems.

                               For example, one expert described an array of potentially valuable
                               information that should be developed and made available to utilities—
                               information typically held by public health agencies. Examples cited



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                              include (1) epidemiological data on diseases or other health incidents in
                              communities, and (2) data on infections in subgroups of the population
                              (such as nursing homes) and on hospital laboratory diagnoses,
                              absenteeism from schools, and pharmacy sales of certain medications such
                              as antidiarrheal medications. Because state health agencies often regulate
                              public water utilities and therefore are highly knowledgeable about them,
                              these agencies should serve an enhanced role in the security of water
                              systems by, for example, disseminating timely information to utilities and
                              the public about possible contamination.

                              EPA has devoted funds to address drinking water security issues as they
                              relate to public health concerns. For example, the agency’s Office of Water
                              is developing contaminant lists that officials say will better guide future
                              research and identify information needs. Other planned work includes
                              determining the infectious or toxic doses of potential contaminants, and
                              providing information (including restricted information) to utility
                              operators, public officials, and other security stakeholders.



Strengthening Relationships   More than 80 percent of the experts (36 of 43) rated establishing or
between Drinking Water        strengthening relationships between drinking water utilities and law
                              enforcement as having either a high or highest priority for federal funding.
Utilities and Law
                              Several experts noted that a close working relationship between these
Enforcement Agencies          organizations could help to prevent incidents, through increased police
                              patrols and the sharing of intelligence information. One expert noted also
                              that improving these relationships might result in a more rapid and
                              comprehensive response to adverse or malevolent acts. Another expert,
                              however, pointed to an underlying problem that often characterizes this
                              relationship: “There are very few people that currently have a good
                              understanding of utility operations as well as security issues and
                              approaches. The lack of understanding of utility operations by law
                              enforcement and even regulatory agencies is detrimental, as is the lack of
                              law enforcement and security understanding at utilities. Development of
                              people that understand both types of knowledge would be highly valuable
                              in addressing water security.” He said that the development of such people
                              is currently being done by chance.

                              To date, EPA has largely facilitated security-related training programs
                              intended for utility officials, although it has recently initiated programs
                              involving outreach to law enforcement organizations. One program
                              involves developing outreach materials such as a “top 10” list of tips on
                              water security for law enforcement officials, a “citizens brochure,” and law



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                          enforcement training workbooks. EPA has also contacted the National
                          Chiefs of Police and the National Sheriffs’ Association to improve
                          awareness about drinking water security.



Testing Local Emergency   It has long been accepted that in light of the critical function they serve in
Response Systems          local communities, drinking water utilities should have effective
                          emergency response plans to deal with emergencies. This imperative was
                          further reinforced by the Bioterrorism Act’s recent requirement for such
                          plans. However, the execution of these plans requires staff to perform
                          functions beyond their day-to-day responsibilities, as well as coordinate
                          with personnel from different organizations that may have little to do with
                          each other except in emergency situations.

                          Further, an emergency response plan can only be considered reliable if it is
                          tested periodically. About 60 percent of the experts (26 of 43) in our study
                          indicated that testing of local emergency response systems warrants a high
                          or highest priority for federal funding. One expert stated that funds should
                          be made available to ensure that plans are updated, perhaps annually.
                          Another noted, “Everyone has been concentrating on assessment and
                          addressing vulnerabilities [to drinking water systems]. What is even more
                          important to public safety are the correct response actions to any
                          emergency situation.”

                          In September 2003, EPA conducted a study to evaluate the performance of
                          a group of laboratories in a simulated emergency situation involving a
                          chemical contamination threat to drinking water. This study also assessed
                          the effectiveness of draft guidance provided by EPA to laboratories for
                          developing their own response protocols. EPA plans to deliver a series of
                          workshops in early 2004 that will involve tabletop exercises and drills for
                          various emergency responders, such as public health and law enforcement
                          officials, laboratory staff, and selected utility employees.



Sharing Resources among   Experts cited mutual aid arrangements among neighboring drinking water
Utilities                 utilities as activities that may result in a more efficient use of resources
                          during a terrorist action. Over half of the experts (23 of 43) said that a high
                          or highest priority should be assigned to federal funding of activities that
                          facilitate the sharing among utilities of such resources as common back-up
                          power systems and other critical equipment. One expert described a
                          collaborative in the San Francisco Bay Area, the Bay Area Security
                          Information Collaborative (BASIC), in which eight utilities meet regularly


                          Page 63                                         GAO-04-29 Drinking Water Security
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                            to address a wide range of security-related topics. Topics have included the
                            development of a database of chemical and biological contaminants and
                            response protocols, regional exercises to prepare for an event, regional
                            training, information sharing on preparing vulnerability assessments, and
                            public information messages. Such mutual aid arrangements might be
                            designed in coordination with state water agencies and their related water
                            security programs.

                            Another expert cited standardized Mutual Aid Disaster and Intervention
                            Response Teams (MADIRT) established by the North Carolina League of
                            Municipalities, the North Carolina Urban Water Consortium, and North
                            Carolina’s Disaster Preparedness Committee. This cooperative approach is
                            intended to allow municipalities a means to share personnel, equipment,
                            materials, and emergency assistance with other communities. MADIRT
                            allows communities to identify their capabilities in advance of an event,
                            increase standardization to save time and reduce costs, and simplify
                            communications. One key effort of this cooperative has been to draft
                            specifications for water pipe repair, although other repair actions (e.g., for
                            generators or SCADA systems) are being considered. The cooperative also
                            establishes mutual aid coordinators—volunteers across the state who are
                            trained in the types of aid that utilities may need during emergencies. At
                            present, municipalities that sign a statewide mutual aid agreement, and in
                            turn use the teams, would be able to fully qualify for reimbursement from
                            the Federal Emergency Management Agency, the state, or both.



Establishing Physical       Physical interconnections—the linkages and junctions between pipes both
Interconnections between    within and between utilities—can be useful in mitigating intentional
                            contamination. Once contamination has occurred and has been identified,
Drinking Water Facilities   interconnections might allow a utility operator or emergency response
and Distribution Systems    official to continue to provide service from another source, and aid in
                            isolating contaminated water from reaching the population at large. They
                            can also allow fresh, clean water to be pumped in from another part of the
                            system or from an entirely different system.

                            Approximately 51 percent of the experts (22 of 43) indicated the
                            establishment of such interconnections deserves either a high or highest
                            priority for federal funding. The overarching idea is to have a higher degree
                            of redundancy in a drinking water system, with distributed sources of
                            water (e.g., water from both wells and surface water); a wider and more
                            redundant distribution of treated water (e.g., more than one pipeline of
                            treated water at a critical location); and increased controls over the flow of



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              such water. According to one expert, system interconnections have been
              used for some time, but that more recently, efforts have focused
              increasingly on developing them to handle emergency situations. Another
              expert commented on the need for remote-controlled valves, and on the
              need to be able to connect or bypass pipelines to access alternative sources
              of water. Finally, one expert suggested that water could be shared across
              interconnected utility systems if one system experienced a suspension of
              service. This individual stated that there is so much excess capacity in the
              systems that many utilities could supply their own needs and another
              system of a similar size.

              EPA’s preliminary cost estimate for interconnectivity research, such as
              contingency planning for alternative sources of water, is about $2.6 million.
              Among other things, the agency intends to develop case studies that
              describe how utilities and populations can share water, how truck-mounted
              and portable water facilities can be designed and implemented during
              crises, and how redundancy in water systems can better ensure sustained
              and consistent water supplies. The agency’s work in this area has been
              complemented by other projects that use computer modeling to simulate
              water flows in distribution systems.



Conclusions   EPA’s Strategic Plan on Homeland Security sets forth the goal that “by 2005,
              unacceptable security risks at water utilities across the country will be
              significantly reduced through completion of appropriate vulnerability
              assessments; design of security enhancement plans; development of
              emergency response plans; and implementation of security enhancements.”
              The plan further commits to providing federal resources to help
              accomplish these goals as funds are appropriated.

              Key judgments about which recipients should get funding priority, and how
              those funds should be spent, will have to be made in the face of great
              uncertainty about the likely targets of attacks, the nature of attacks
              (whether physical, cyber, chemical, biological, or radiological), and the
              timing of attacks. The experts on our panel have had to consider these
              uncertainties in deriving their own judgments about these issues. These
              judgments, while not unanimous on all matters, suggested a high degree of
              consensus on a number of key issues.

              We recognize that such sensitive decisions must ultimately take into
              account political, equity, and other considerations. But we believe they
              should also consider the judgments of the nation’s most experienced



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                     individuals regarding these matters, such as those included on our panel. It
                     is in this context that we offer the results presented in this report as
                     information for Congress and the Administration to consider as they seek
                     the best way to use limited financial resources to reduce threats to the
                     nation's drinking water supply.



Recommendation for   We recommend that, as EPA refines its efforts to help drinking water
                     utilities reduce their vulnerability to terrorist attacks, the Administrator of
Executive Action     the EPA consider the information in this report to help determine: how best
                     to allocate security-related federal funds among drinking water utilities;
                     which methods should be used to distribute the funds; and what specific
                     security-enhancing activities should be supported.




                     Page 66                                         GAO-04-29 Drinking Water Security
Appendix I

Participating Experts on Drinking Water                                          Appendx
                                                                                       ies




Security Panel                                                                    Append
                                                                                       x
                                                                                       Ii




               Gregory Baecher      University of Maryland
               Pete Baxter          Jane’s Information Group
               Kevin Bennett        Federal Bureau of Investigation, National
                                    Infrastructure Protection Center
               Paul Bennett         New York City Department of
                                    Environmental Protection
               Frank Blaha          American Water Works Association
                                    Research Foundation
               Jennifer Brower      RAND
               Liz Casman           Carnegie Mellon University
               Jeff Danneels        Sandia National Laboratories
               Rolf Deininger       University of Michigan
               John Ditmars         Argonne National Laboratory
               David Dobbins        Black & Veatch Company
               Jane Downing         U.S. Environmental Protection Agency
               Wayne Einfeld        Sandia National Laboratories
               James H. Fetzer      Tennessee Valley Authority
               Tim Gablehouse       Gablehouse and Eppel
               Gregg Grunenfelder   Washington State Department of Health
               Eugene Habiger       San Antonio Water System
               Todd Humphrey        Portland Water Bureau
               Gerald Iwan          Connecticut Department of Public Health
               Steve Jackson        U.S. Department of the Interior, Bureau
                                    of Reclamation
               Brian Jenkins        RAND
               Janet Jensen         U.S. Department of Defense, U.S. Army,
                                    Aberdeen Proving Grounds
               Dennis Juranek       U.S. Department of Health and Human
                                    Services, Centers for Disease Control and
                                    Prevention
               Michael Keegan       National Rural Water Association
               Dave Lawrence        Wisconsin Rural Water Assocation
               Vanessa Leiby        Association of State Drinking Water
                                    Administrators
               Carrie Lewis         Milwaukee Water Department
               John McLaughlin      Brown and Caldwell



               Page 67                           GAO-04-29 Drinking Water Security
Appendix I
Participating Experts on Drinking Water
Security Panel




Christine L. Moe                      Emory University
Erik Olson                            National Resources Defense Council
Julian Palmore                        University of Illinois
Janet Pawlukiewicz                    U.S. Environmental Protection Agency
E.L. Quarantelli                      University of Delaware
Brian Ramaley                         Newport News Waterworks
Alan Roberson                         American Water Works Association
Ken Rubin                             PA Consultants
Leonard Shabman                       Resources for the Future
Jim Shell                             Metropolitan Washington Council of
                                      Governments
Kimberly Shoaf                        University of California at Los Angeles
David Spath                           California Department of Health Services
Mic Stewart                           Metropolitan Water District of Southern
                                      California
Billy Turner                          Columbus Water Works
Ray Yep                               Santa Clara Valley Water District




Page 68                                            GAO-04-29 Drinking Water Security
Appendix II

GAO Contacts and Staff Acknowledgments                                                         Appendx
                                                                                                     Ii




GAO Contacts      John Stephenson, (202) 512-3841
                  Steve Elstein, (202) 512-6515



Acknowledgments   In addition to the individuals named above, important contributions were
                  made by Don Cowan, Lynn Musser, Diane Raynes, and Aaron Shiffrin.
                  Charles Bausell, Brandon Haller, Katherine M. Raheb, and Carol Shulman
                  also made key contributions.




(360364)          Page 69                                      GAO-04-29 Drinking Water Security
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