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

January 2005: 

Wastewater Facilities: 

Experts' Views on How Federal Funds Should Be Spent to Improve 
Security: 

GAO-05-165: 

GAO Highlights: 

Highlights of GAO-05-165, a report to the Committee on Environment and 
Public Works, U.S. Senate: 

Why GAO Did This Study: 

Since the events of September 11, 2001, the security of the nationís 
drinking water and wastewater infrastructure has received increased 
attention from Congress and the executive branch. Wastewater facilities 
in the United States provide essential services to residential, 
commercial, and industrial users by collecting and treating wastewater 
and discharging it into receiving waters. These facilities, however, 
may possess certain characteristics that terrorists could exploit 
either to impair the wastewater treatment process or to damage 
surrounding communities and infrastructure. 

GAO was asked to obtain expertsí views on (1) the key security-related 
vulnerabilities affecting the nationís wastewater systems, (2) the 
activities the federal government should support to improve wastewater 
security, and (3) the criteria that should be used to determine how any 
federal funds are allocated to improve security, and the best methods 
to distribute these funds. GAO conducted a systematic, Web-based survey 
of 50 nationally recognized experts to seek consensus on these key 
wastewater security issues.

EPA expressed general agreement with the report, citing its value as 
the agency works with its partners to better secure the nationís 
critical wastewater infrastructure. 

What GAO Found: 

Experts identified the collection systemís network of sewer lines as 
the most vulnerable asset of a wastewater utility. Experts stated that 
the sewers could be used either as a means to covertly gain access to 
surrounding buildings or as a conduit to inject hazardous substances 
that could impair a wastewater treatment plantís capabilities. Among 
the other vulnerabilities most frequently cited were the storage and 
transportation of chemicals used in the wastewater treatment process 
and the automated systems that control many vital operations. In 
addition, experts described a number of vulnerabilities not specific to 
particular assets but which may also affect the security of wastewater 
facilities. These vulnerabilities include a general lack of security 
awareness among wastewater facility staff and administrators, 
interdependencies among various wastewater facility components leading 
to the possibility that the disruption of a single component could take 
down the entire system, and interdependencies between wastewater 
facilities and other critical infrastructures.

Experts identified several key activities as most deserving of federal 
funds to improve wastewater facilitiesí security. Among those most 
frequently cited was the replacement of gaseous chemicals used in the 
disinfection process with less hazardous alternatives. This activity 
was rated as warranting highest priority for federal funding by 29 of 
50 experts. Other security-enhancing activities most often rated as 
warranting highest priority included improving local, state, and 
regional collaboration (23 of 50 experts) and supporting facilitiesí 
efforts to comprehensively assess their vulnerabilities (20 of 50 
experts).

When asked how federal wastewater security funds should be allocated 
among potential recipients, the vast majority of experts suggested that 
wastewater utilities serving critical infrastructure (e.g., public 
health institutions, government, commercial and industrial centers) 
should be given highest priority (39 of 50). Other recipients 
warranting highest priority included utilities using large quantities 
of gaseous chemicals (26 of 50) and utilities serving areas with large 
populations (24 of 50). Experts identified direct federal grants as the 
most effective method to distribute the funds, noting particular 
circumstances in which a matching contribution should be sought from 
recipients. Specifically, a matching requirement was often recommended 
to fund activities that benefit individual utilities. Grants with no 
matching requirements were often recommended for activities that should 
be implemented more quickly and would benefit multiple utilities. The 
other funding mechanisms experts mentioned most frequently included the 
federal Clean Water State Revolving Fund, loans or loan guarantees, 
trust funds, and tax incentives. 

www.gao.gov/cgi-bin/getrpt?GAO-05-165. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact John B. Stephenson at 
(202) 512-3841 or stephensonj@gao.gov. 

[End of section]

Contents: 

Letter: 

Executive Summary: 

Purpose: 

Background: 

Results in Brief: 

Principal Findings: 

Agency Comments and Our Evaluation: 

Chapter 1: Introduction: 

The Nation's Wastewater Systems and the Populations They Serve: 

Key Components of a Typical Wastewater System: 

Government and Industry Have Recently Sought to Improve Security: 

Objectives, Scope, and Methodology: 

Chapter 2: Experts Identified Key Vulnerabilities That Could Compromise 
Wastewater Security: 

Experts Identified Five Key Vulnerabilities: 

Overarching Vulnerabilities Affecting Overall Wastewater System 
Security: 

Chapter 3: Experts Identified Wastewater Security-Enhancing Activities 
That Warrant Federal Support: 

Replace Gaseous Chemicals with Less Hazardous Alternatives: 

Improve Local, State, and Regional Collaboration Efforts: 

Complete Vulnerability Assessments: 

Expand Training Opportunities for Wastewater Utility Operators and 
Administrators: 

Improve National Communication Efforts between Utilities and Key 
Entities Responsible for Homeland Security: 

Install Early Warning Systems in Collection Systems to Monitor for or 
Detect Sabotage: 

Harden Physical Assets of Treatment Plants and Collection Systems: 

Strengthen Operations and Personnel Procedures: 

Increase Research and Development Efforts to Improve Detection, 
Assessment, and Response Capabilities: 

Develop Voluntary Wastewater Security Standards and Guidance Documents: 

Strengthen Cyber Security and SCADA Systems: 

Chapter 4: Experts Identified Key Allocation Criteria and Funding 
Mechanisms for Addressing Wastewater Security Needs: 

Key Criteria to Help Determine Which Utilities Should Receive Funding 
Priority: 

Funding Mechanisms Recommended for Distributing Federal Funds: 

Conclusions: 

Appendixes: 

Appendix I: Participating Experts on Wastewater Security Panel: 

Appendix II: Questions and Responses to the Final Questionnaire for the 
Expert Panel: 

Appendix III: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Staff Acknowledgments: 

Figures: 

Figure 1: Key Wastewater System Vulnerabilities Identified by Experts: 

Figure 2: System Size by Population (POTW by system size and population 
served): 

Figure 3: Components of a Typical Community Wastewater System: 

Figure 4: Key Wastewater System Vulnerabilities Identified by Experts: 

Figure 5: Chlorine Delivery Truck: 

Figure 6: Chlorine Railroad Car: 

Figure 7: Pump Operated through Remote Automated Systems: 

Figure 8: Pumping Station: 

Figure 9: Experts' Views on Wastewater Security Activities Most 
Deserving of Federal Support: 

Figure 10: One-Ton Canisters of Chlorine Gas Stored at a Wastewater 
Treatment Plant: 

Figure 11: Electronically-Controlled Security Gate: 

Figure 12: Security Camera and Infrared Motion Detectors: 

Figure 13: Experts' Views on Which Characteristics of Wastewater 
Utilities Should Be Used to Set Priority for Federal Funds: 

Figure 14: Experts' Views on Mechanisms for Funding Wastewater 
Security: 

Abbreviations: 

AMSA: Association of Metropolitan Sewerage Agencies: 

AMWA: Association of Metropolitan Water Agencies: 

CWSRF: Clean Water State Revolving Fund: 

DHS: Department of Homeland Security: 

EPA: Environmental Protection Agency: 

HSIN: Homeland Security Information Network: 

HSPD: Homeland Security Presidential Directive: 

ISAC: Information Sharing and Analysis Center: 

LEL: lower explosive level: 

MGD: million gallons per day: 

POTW: publicly owned treatment works: 

SCADA: Supervisory Control and Data Acquisition: 

VA: vulnerability assessment: 

VSAT: Vulnerability Self Assessment Tool: 

Letter January 31, 2005: 

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 wastewater security, including the 
potential vulnerabilities of wastewater systems; activities that most 
warrant federal support to mitigate the risk of terrorism; and the 
criteria that the experts believe should be used to determine how any 
federal funds are allocated among recipients to improve their security 
and the methods the experts suggest should be used to distribute these 
funds.

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

If you or your staffs have any questions concerning this report, please 
contact me at (202) 512-3841 or [Hyperlink, stephensonj@gao.gov] or my 
Assistant Director, Steve Elstein, at (202) 512-6515 or [Hyperlink, 
elsteins@gao.gov]. Major contributors to this report are listed in 
appendix II.

Signed by: 

John B. Stephenson: 
Director, Natural Resources and Environment: 

[End of section]

Executive Summary: 

Purpose: 

Like safe drinking water, properly treated wastewater is critical to 
modern life. Wastewater utilities across the country have long been 
engaged in activities to ensure the health and safety of their 
customers and to comply with regulatory requirements to prevent harmful 
pollutants from being released into the nation's waters. Since the 
events of September 11, 2001, the security of the nation's water 
infrastructure against terrorist threats has received greater attention 
by Congress and executive branch agencies. While more federal resources 
have been directed toward drinking water security than wastewater 
security, some maintain that wastewater systems, like drinking water 
systems, also possess vulnerabilities that could be exploited. It has 
been alleged, for example, that the numerous storm drains, manholes, 
and sewers that make up a community's wastewater collection systems' 
network of sewers could be used to covertly place explosives beneath a 
major population center or to introduce substances that may damage a 
wastewater treatment plant's process. Such events could result in loss 
of life, destruction of property, and harm to the environment.

In 2003, Congress considered legislation that would have provided funds 
to, among other activities, assess the vulnerability of wastewater 
facilities, make physical security improvements, and conduct research. 
Since then, the wastewater industry has expressed its desire for a 
strong federal contribution to help meet its security needs. To inform 
further deliberations on this topic, as agreed with the Chairman and 
Ranking Minority Member of the Senate Committee on Environment and 
Public Works, this report identifies experts' views on (1) the key 
security-related vulnerabilities affecting the nation's wastewater 
systems, (2) specific activities the federal government should support 
to improve wastewater security, and (3) the criteria that should be 
used to determine how any federal funds are allocated among recipients 
to improve their security and the methods that should be used to 
distribute these funds.

To address these issues, GAO identified 50 recognized experts from the 
wastewater community and surveyed them using a Web-based Delphi 
process. The Delphi methodology is a systematic process for obtaining 
individuals' views on a question or problem of interest and seeking 
consensus if possible. In selecting experts for the expert panel, GAO 
sought individuals who are widely recognized as possessing expertise on 
one or more key aspects of wastewater security. GAO also sought to 
achieve balance in representation from key federal agencies, state or 
local agencies, industry and nonprofit organizations, academia, and 
water utilities of varying sizes. A detailed description of GAO's 
methodology is presented in chapter 1.

Background: 

Wastewater systems vary by size and other factors, but all include a 
collection system and treatment facility. Collection systems are 
generally widely dispersed geographically and have multiple access 
points, including drains, catch basins, and manholes, most of which are 
not monitored. This underground network of sewers and pumping stations 
moves the wastewater away from its point of origination to the 
treatment plant. Typical wastewater treatment facilities use a series 
of physical, biological, and chemical processes to treat wastewater. 
Chemicals used in this process, most notably chlorine, are often stored 
on site at the treatment plant. Wastewater systems have become 
increasingly computerized and rely on the use of automated controls to 
monitor and operate them.

Nationwide, more than 16,000 publicly owned wastewater systems serve 
more than 200 million people, or about 70 percent of the nation's total 
population. About 500 large public wastewater systems provide service 
to 62 percent of the sewered population. To help address the security 
needs of the wastewater sector, EPA, since 2002, has provided more than 
$10 million to help address the security needs of the wastewater 
sector. A large portion of this funding has been awarded to nonprofit 
technical support and trade organizations to develop tools and training 
on conducting vulnerability assessments to reduce utility 
vulnerabilities, on planning for and practicing response to emergencies 
and incidents, and for research on a variety of security topics.

Wastewater utilities have had a history of openness with the 
communities they serve by sharing, among other things, alerts of 
scheduled maintenance activities and information about the quality of 
water that is released back into the environment. Many utilities also 
provide detailed information about their location, design, and 
treatment processes. The September 11 attacks, however, have led many 
wastewater utilities to reassess their openness to the general public 
and their ability to guarantee safe and reliable services to their 
customers and communities. In December 2003, the President issued 
Homeland Security Presidential Directive-7, which designated EPA as the 
lead agency to address water infrastructure security. EPA has worked 
with other organizations, such as the Water Environment Research 
Foundation, the Association of Metropolitan Sewerage Agencies, the 
Water Environment Federation, and the American Society of Civil 
Engineers, to conduct research, provide guidance and, importantly, to 
offer training on how to assess wastewater facilities' vulnerabilities. 
Unlike drinking water facilities, wastewater utilities are not required 
by law to complete these "vulnerability assessments."

Results in Brief: 

GAO's panel of experts identified five key wastewater assets as most 
vulnerable to terrorist attacks: the collection systems' network of 
sewers, treatment chemicals, key components of the treatment plant, 
pumping stations, and control systems. Among these assets, 42 of the 50 
experts listed the collection systems' network of sewers as a key 
vulnerability. Experts explained that adversaries could use this 
network of pipes to gain access to intended targets within the service 
area, convey hazardous substances that might destroy points along the 
system, or incapacitate the wastewater treatment process. In addition, 
32 of 50 experts identified process chemicals used in wastewater 
treatment as a key vulnerability. Of particular concern is the 
accidental or intentional release of gaseous chlorine, used for 
disinfection processes, which can burn eyes and skin, inflame the 
lungs, and cause death if inhaled.

Experts identified 11 key actions when asked to identify and set 
priorities for the security-enhancing activities most deserving of 
federal support. Three were particularly noteworthy because they were 
given a rating of highest priority by a substantial number of the 
experts. The first activity was the replacement of gaseous chemicals 
used in wastewater treatment with less hazardous alternatives. Experts 
viewed this action as critical to reduce the vulnerability of systems 
that rely heavily upon gaseous chlorine in their treatment processes. 
Several experts noted that because replacing chlorine could be 
prohibitively expensive for many wastewater utilities, replacement was 
a particularly strong candidate for federal support. For example, the 
change to sodium hypochlorite can require approximately $12.5 million 
for new equipment and increase annual chemical costs from $600,000 for 
gaseous chlorine to over $2 million for sodium hypochlorite. The second 
activity cited was improving local, state, and regional efforts to 
coordinate responses in advance of a potential terrorist threat. 
According to the experts, enhanced partnerships among these entities 
can yield significant benefits to wastewater utilities including an 
increased ability to monitor critical infrastructure and facilities, 
improved understanding of agency roles and responsibilities, and faster 
response time to deal with potential security breaches. Finally, the 
third activity cited was completing vulnerability assessments for 
individual wastewater systems. Experts viewed these assessments as key 
steps toward informing stakeholders about wastewater system 
vulnerabilities and countermeasures, and taking steps to implement 
appropriate countermeasures.

In identifying and setting priorities for the types of utilities that 
should receive federal funds to improve wastewater security, 39 of the 
50 experts gave a rating of highest priority to utilities serving 
critical infrastructure. These utilities provide service to 
institutions that serve as hubs for government activity; commercial and 
industrial centers such as cities' financial districts, power plants, 
and airports; and public health institutions, such as major medical 
centers and hospitals. Just over half of the experts rated utilities 
using large quantities of gaseous chemicals as warranting highest 
priority for federal funds. Several pointed out that, if these 
chemicals were released to the atmosphere while being transported to 
the treatment plant or while stored on site, evacuations might be 
needed, and personal injuries or fatalities might result. Also 
receiving widespread support by the experts were utilities serving 
areas with large populations. Fewer experts recommended highest or high 
priority for utilities serving entities that have symbolic value or 
that serve medium or small populations.

The experts overwhelmingly favored direct federal grants as the best 
method to distribute federal funds to potential recipients. They also 
specified instances in which some type of match by recipients would be 
particularly appropriate. Relatively fewer experts recommended the use 
of trust funds or the Clean Water State Revolving Fund, particularly 
for upgrades that need to be implemented quickly. Other mechanisms 
receiving support from at least some experts included loans or loan 
guarantees, and tax incentives for private utilities.

Principal Findings: 

Key Vulnerabilities: 

Figure 1 summarizes the 50 experts' identification of which wastewater 
system components were among the systems' top five vulnerabilities.

Figure 1: Key Wastewater System Vulnerabilities Identified by Experts: 

[See PDF for image]

[End of figure]

Collection systems' network of sewers. Forty-two of the 50 experts 
named the collection systems' network of sanitary, storm, and combined 
sewers. Several noted that sewers make underground travel from a point 
of entry to a potential target almost undetectable. Many also suggested 
that adversaries could use the collection system as an underground 
transport system--without ever physically entering the system--for 
explosive or toxic agents. For example, several experts explained, an 
adversary could pour a highly toxic chemical into the sewer that could 
destroy the biological agents vital to the treatment process.

Treatment chemicals. Thirty-two experts identified treatment chemicals 
used in wastewater treatment. Most experts singled out chlorine gas as 
a major chemical of concern. Chlorine is extremely volatile and 
requires specific precautions for its safe transport, storage, and use. 
As experts commented, although railroad tanker cars are designed to 
avoid leakage in the event of a derailment, and withstand a bullet from 
a normal handgun or rifle, one expert concluded that the "use of 
explosives to cause a rupture is well within the skill set of a 
terrorist." Such an attack along a congested transportation corridor 
could have catastrophic public health and safety impacts.

Key components of the treatment plant. Twenty-nine experts identified 
the components of the main wastewater treatment facility. Typical 
facilities use multiple treatment processes before discharging the 
effluent back to the environment, with each stage of the process 
serving an integral role. Experts explained that damage to one or more 
of these processes could result in inadequately treated wastewater, 
thereby contaminating drinking water sources, harming the environment, 
and causing significant economic damage. While many experts expressed 
concern for the security of the entire treatment plant, several 
identified the headworks, where wastewater carried through the 
collection system first enters the plant, as particularly vulnerable to 
attack.

Pumping stations. Sixteen of the 50 experts identified pumping 
stations, which are often used to move sewage to the treatment plant 
when gravity alone is not sufficient, as among the top vulnerabilities. 
As one expert explained, destroying or disabling a pumping station 
could cause the collection system to overflow raw sewage into the 
streets, and into surface waters, and back up sewage into homes and 
businesses. Experts explained that the remoteness and geographic 
distribution of pumping stations, and their lack of continuous 
surveillance, make them particularly vulnerable.

Control systems. Eighteen experts cited the automated Supervisory 
Control and Data Acquisition (SCADA) systems, which serve functions 
ranging from storing and processing data to monitoring system 
conditions and controlling vital system operations. These systems can 
be vulnerable because of loose security in the control rooms at some 
plants, and remote access to SCADA through the Internet, among other 
reasons. One expert described a breach of cyber security in Australia 
which caused the release of thousands of gallons of raw sewage.

In addition to the vulnerabilities associated with specific system 
components, experts identified several overarching issues that 
compromise the integrity of systems' physical assets and their 
operations. Chief among them are (1) a general lack of security 
awareness within the wastewater sector; (2) interdependencies among 
components of the wastewater system, opening the possibility that a 
failure of any individual component could bring down the entire system 
(e.g., undermining the automated control system could cause numerous 
components to fail); and (3) interdependencies between the wastewater 
system and other critical infrastructure that could fail, such as 
electric power supplies.

Security-Enhancing Activities That Most Warrant Federal Support: 

Three security-enhancing activities were most often cited by the 
experts as warranting "highest" priority for federal support: 

Replacing gaseous chemicals used in wastewater treatment with less 
hazardous alternatives. Well over half of experts surveyed (29 of 50) 
rated the replacement of gaseous chemicals at wastewater treatment 
facilities with less hazardous alternatives as warranting highest 
priority for federal funding. Fourteen more experts rated this activity 
as a "high" priority. Experts asserted that wastewater systems carrying 
out treatment processes using gaseous forms of chemicals, particularly 
chlorine, inherently make themselves targets for terrorist attack. 
According to several experts, some communities and utilities currently 
using gaseous chemical treatment processes are interested in converting 
to an alternative treatment technology, but financial costs associated 
with conversion remain prohibitive. According to EPA, hypochlorite 
compounds tend to have higher operating costs than chlorine 
gas.[Footnote 1] Nonchlorine-based technologies, such as ozone and 
ultraviolet light, tend to have higher capital costs than chlorine gas, 
according to a study prepared for the U.S. Army.[Footnote 2] Another 
expert suggested that reducing the size of containers used to transport 
and store gaseous chemicals could help to mitigate the problem. This 
approach is being implemented by a facility where gaseous chlorine is 
now stored in 1-ton containers--a significant reduction in size from 
the larger 90-ton railroad car-sized containers the utility previously 
employed.

Improving local, state, and regional collaboration efforts. Twenty- 
three of 50 experts rated efforts to improve local, state, and regional 
collaboration efforts as warranting highest priority for federal 
funding. Fifteen more experts rated this activity as a high priority. 
As one expert noted, wastewater facilities are often disconnected from 
other key entities that participate in emergency planning and response, 
and the facilities instead conduct these critical activities without an 
appreciation of the need to coordinate with other key players. An 
expert identified the nonprofit California Utilities Emergency 
Association as an example of an effective provider of communications, 
training, mutual aid coordination, and simulation exercises to 
participating utilities.

Completing vulnerability assessments for individual wastewater systems. 
Twenty of 50 experts rated the completion of vulnerability assessments 
as warranting highest priority for federal funding. Fourteen others 
rated this activity as a high priority. Experts suggested that 
vulnerability assessments enable wastewater utilities to identify and 
understand their systems' vulnerabilities and take steps to implement 
appropriate countermeasures. As such, they characterized these 
assessments as a logical first step in determining how best to spend 
funds to improve security.

In addition to these three activities, experts cited eight other 
activities as warranting high priority for federal funding: (1) 
training utility employees on how best to conduct vulnerability 
assessments and improve the security culture among employees; (2) 
improving national communication efforts between utilities and key 
entities responsible for homeland security; (3) installing early 
warning systems in collection systems to monitor for or detect 
sabotage; (4) hardening physical assets of treatment plants and 
collection systems; (5) strengthening operations and personnel 
procedures; (6) increasing research and development efforts aimed at 
improving threat detection, assessment, and response capabilities; (7) 
developing voluntary wastewater security standards and guidance 
documents; and (8) strengthening cyber security and SCADA systems.

Key Allocation Criteria and Distribution Methods for Federal Funding: 

GAO asked its expert panel for its views on the appropriate criteria 
for determining which utilities should receive federal funds, should 
Congress and the administration agree to provide such support. The most 
frequently cited criteria included the following: 

Utilities serving critical infrastructure. Thirty-nine of the 50 
experts accorded highest funding priority to utilities serving critical 
infrastructure. An additional 10 experts believed these utilities 
warranted a high priority. These utilities provide service to 
institutions that serve as hubs for government activity, to commercial 
and industrial centers, and to public health institutions. Many experts 
noted in particular that systems serving heavy commercial and 
industrial customers are critical to the country's economic stability, 
and that a major or sustained disruption could have severe economic 
and/or public health consequences. One noted, for example, that a 
sustained shutdown in the computer chip manufacturing sector, caused by 
the loss of a wastewater treatment plant, could cost the economy 
millions of dollars per day.

Utilities using large quantities of gaseous chemicals. Citing the 
enormous risks posed by gaseous chemicals, just over half of the 
experts (26 of 50) recommended highest funding priority to help 
utilities convert from these chemicals to safer alternatives. An 
additional 18 rated these utilities as warranting a high priority for 
federal funds. Some experts cautioned, however, that if funds are used 
by utilities merely to convert to less hazardous chemicals (e.g., 
sodium hypochlorite), then the federal government may be perceived as 
rewarding these utilities at the expense of utilities that are 
considering much safer alternatives.

Utilities serving large populations. Almost half of the experts (24 of 
50) gave highest priority to utilities serving areas with large 
populations. Seventeen additional experts rated these utilities as 
warranting a high priority for federal funds. Many experts shared the 
view that providing financial and technical assistance to the largest 
treatment plants would protect the greatest number of people. One 
expert pointed to EPA's 2000 Clean Water Needs Survey, which indicated 
that 62 percent of the nation's sewered population is served by about 
500 of the largest wastewater treatment facilities. Furthermore, a 
number of experts suggested that terrorists often seek to maximize the 
number of people killed or injured by their attacks, and are, 
therefore, more likely to target the systems in large metropolitan 
areas that serve many customers.

GAO also asked its expert panel for their ratings of how effective each 
method would be for distributing federal funds to potential recipients. 
Among the mechanisms they recommended: 

Direct grants. Direct federal grants were the most favored funding 
mechanism, with 34 of the 50 experts indicating that direct federal 
grants to utilities would be "very effective" in allocating federal 
funds. An additional 12 experts indicated that they would be at least 
"somewhat effective." Several experts commented that grants are 
preferable because they are more likely to result in safety 
improvements and other desired changes more quickly. Experts also 
offered the following opinions on situations in which it would be 
appropriate to offer a grant with or without a required match from the 
recipient: 

* Many favored grants without a matching requirement for activities 
that benefit multiple utilities. Specific actions include conducting 
research and development to improve detection, assessment, and response 
capabilities; developing voluntary wastewater security standards and 
guidance; completing vulnerability assessments; and providing training 
to utility security personnel on how best to conduct vulnerability 
assessments and improve the security culture.

* Many favored cost-shared grants for activities that benefit 
individual utilities, such as establishing improved operation and 
personnel procedures (e.g., conducting background checks on new 
employees); installing early warning systems in collection systems to 
monitor for or detect sabotage; improving cyber security; and hardening 
physical assets through such actions as building fences and installing 
or upgrading locks.

Clean Water State Revolving Fund. Five experts cited the Clean Water 
State Revolving Fund as a very effective funding mechanism, and 35 
others cited it as somewhat effective. Some experts expressed the view 
that the fund can leverage appropriated funds and, thereby, assist more 
facilities than direct grants. But several others expressed 
reservations about using the fund for security enhancement, including 
one who said that it "was not originally established to deal with 
security-related projects . . . the program either needs to [be] fixed 
to deal with security issues or a separate program needs to be created 
specifically for security projects." According to one expert, unless 
additional security-related monies were added to existing fund levels, 
the use of the fund for security would divert much needed funding away 
from the kind of critical infrastructure investments that have long 
been the fund's primary objective.

Loans or loan guarantees. Only one expert indicated that loans or loan 
guarantees would be very effective, although 34 others agreed that they 
would be somewhat effective. One expert pointed out that loans would 
"allow the community to amortize the costs over 20 years," while 
another commented that a low interest loan could provide some incentive 
and needed capital to implement security programs. Others cautioned, 
however, that while loans would have a smaller impact on the federal 
budget than grants, many local governments are already carrying a heavy 
debt load for capital improvements, making it difficult for them to 
take on significant additional debt without affecting their bond 
ratings.

Making Key Security Decisions in the Face of Uncertainty: 

To date, the federal government's role in promoting wastewater security 
has been limited primarily to supporting various training activities on 
how to complete vulnerability assessments and emergency response plans 
and several research projects. However, legislation supporting an 
expanded federal role, including a substantially greater financial 
commitment, has been proposed in the past and may be considered again 
in the future.

Should such funds be appropriated, key judgments about which recipients 
should get funding priority, and how those funds should be spent, will 
have to be made in the face of great uncertainty about the likely 
target of an attack (i.e., a large but well-protected facility versus a 
smaller but less-protected facility); the nature of an attack (cyber, 
physical, chemical, biological, radiological), and its timing. The 
experts on GAO's panel have taken these uncertainties into account in 
deriving their own judgments about these issues. These views, while not 
unanimous, suggested some degree of consensus on a number of key issues.

GAO recognizes that such sensitive decisions ultimately must take into 
account a variety of political, equity, and other considerations. It 
believes they should also 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 these results as 
information for the decision-making process that Congress and the 
administration will likely go through as they seek to determine how 
best to use limited financial resources to reduce the vulnerability to 
the nation's wastewater utilities.

Agency Comments and Our Evaluation: 

GAO 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 Ground Water and Drinking Water, its Office 
of Homeland Security, and other relevant offices. The comments 
expressed general agreement with the content of the report and noted 
that the results will be useful as the agency continues to work with 
its partners to better secure the nation's critical wastewater 
infrastructure. EPA also offered specific technical comments and 
suggestions, which have been incorporated as appropriate.

[End of section]

Chapter 1: Introduction: 

Wastewater systems in the United States provide essential services to 
residential, commercial, and industrial users by collecting and 
treating wastewater and discharging it into receiving waters. In light 
of the events of September 11, 2001, Congress and the executive branch 
have placed increased attention on improving the security of the 
nation's water infrastructure--including wastewater systems--to protect 
against future terrorist threats. While more federal resources have 
been directed toward drinking water security than wastewater security, 
some maintain that wastewater systems, like drinking water systems, 
also possess vulnerabilities that could be exploited. The unique 
characteristics and components these systems possess provide for the 
efficient collection, treatment, and disposal of wastewater-- functions 
that are vital to the health of the general public and the environment. 
However, many of these same characteristics and components have been 
identified as potential means for carrying out a terrorist attack. A 
terrorist could seek to impair a wastewater system's treatment process, 
to use a wastewater system to carry out an attack elsewhere, or some 
combination of both.

Documented accidents and intentional acts highlight the destruction 
that arises from an attack on a wastewater system. For example, in June 
1977 in Akron, Ohio, an intentional release of naptha, a cleaning 
solvent, and alcohol into a sewer by vandals at a rubber manufacturing 
plant caused explosions 3.5 miles away from the plant, damaging about 
5,400 feet of sewer line and resulting in more than $10 million in 
damage.

The Nation's Wastewater Systems and the Populations They Serve: 

A majority of the nation's wastewater is treated by publicly owned 
treatment works (POTW) that serve a variety of customers, including 
private homes, businesses, hospitals, and industry. These POTWs 
discharge treated water into surface waters and are regulated under the 
Clean Water Act. Nationwide, there are over 16,000 publicly owned 
wastewater treatment plants, approximately 800,000 miles of sewers, and 
100,000 major pumping stations. This infrastructure serves more than 
200 million people, or about 70 percent of the nation's total 
population. The remainder is served by privately owned utilities or by 
on-site systems, such as septic tanks. This report addresses both 
public and private wastewater systems.

Though outnumbered by the small systems, the relative handful of large 
wastewater systems serve the great majority of people. As depicted in 
figure 2, only 3 percent of the nation's total wastewater systems 
(approximately 500 systems) provide service to 62 percent of the 
populations served by POTWs. Each of these systems treats more than 10 
million gallons per day (MGD) of wastewater.

Figure 2: System Size by Population (POTW by system size and population 
served): 

[See PDF for image]

[End of figure]

Key Components of a Typical Wastewater System: 

Wastewater systems vary by size and other factors but, as illustrated 
in figure 3, all include a collection system and treatment facility.

Figure 3: Components of a Typical Community Wastewater System: 

[See PDF for image]

[End of figure]

[See PDF for image]

[End of figure]

Collection System: 

The underground network of sewers includes both sanitary and storm 
water collection lines that may range from 4 inches to greater than 20 
feet in diameter. Storm water lines tend to be large in diameter in 
order to accommodate a variety of precipitation events. Some of the 
nation's older cities have combined sanitary and storm water lines. 
Sewers are connected to all buildings and streets within typical 
communities through indoor plumbing and curb drains.

Most systems were designed for easy and frequent access to facilitate 
maintenance activities. Access for these purposes is usually conducted 
through manholes that are typically located approximately every 300 
feet. Many collection systems rely on gravity to maintain the flow of 
sewage through the pipes toward the treatment plant. However, the 
geographic expanse of a collection system, both in size and topography, 
may impede the flow. For this reason, collection systems may depend on 
pumping stations to lift the flow to gain elevation for continued 
gravity flow until the wastewater reaches the wastewater treatment 
plant.

The Wastewater Treatment Plant: 

Once the wastewater enters the treatment plant (influent) through the 
collection system, the treatment process removes contaminants such as 
organic material, dirt, fats, oils and greases, nitrogen, phosphorus, 
and bacteria. The influent typically undergoes several stages of 
treatment before it is released. Primary treatment includes the removal 
of larger objects, such as rags, cans, or driftwood, through a 
screening device or a grit removal system, and solids are removed 
through sedimentation. Secondary treatment includes a biological 
process that consumes pollutants, as well as final sedimentation. Some 
facilities also use tertiary treatment to remove nutrients and other 
matter even further. Following secondary or tertiary treatment, the 
wastewater is disinfected to destroy harmful bacteria and viruses. 
Disinfection is often accomplished with chlorine, which is stored on- 
site at the wastewater treatment plant. The collection and treatment 
process is typically monitored and controlled by a Supervisory Control 
and Data Acquisition (SCADA) system, which allows utilities to control 
such things as the amount of chlorine needed for disinfection.

Government and Industry Have Recently Sought to Improve Security: 

In December 2003, the President issued Homeland Security Presidential 
Directive-7 (HSPD-7), which established a national policy for federal 
departments and agencies to identify and set priorities for the 
nation's critical infrastructures and to protect them from terrorist 
attacks. HSPD-7 established the Environmental Protection Agency (EPA) 
as the lead federal agency to oversee the security of the water sector, 
both drinking water and wastewater. Presidential Decision Directive 63 
had done so earlier in May 1998, with a focus primarily on drinking 
water. Based on the 1998 directive, EPA and its industry partner, the 
Association of Metropolitan Water Agencies (AMWA) established a 
communication system, the Water Information Sharing and Analysis Center 
(Water ISAC). The Water ISAC was designed to provide real-time alerts 
of possible terrorist activity and access to a library of information 
and contaminant databases to water utilities throughout the nation. In 
fiscal year 2004, Congress appropriated $2 million for the Water ISAC, 
which today serves more than 1,000 users from water and wastewater 
systems. In November 2004, the Water ISAC launched a free security 
advisory system known as the Water Security Channel to distribute 
federal advisories on security threats via e-mail to the water sector.

EPA recently established a Water Security Working Group to advise the 
National Drinking Water Advisory Council (NDWAC) on ways to address 
several specific security needs of the sector. The working group is 
made up of 16 members selected on the basis of experience, geographic 
location, and their unique drinking water, wastewater, or security 
perspectives. It represents a diverse collection of drinking water and 
wastewater utilities of all sizes, state and local public health 
agencies, and environmental and rate-setting organizations. The group's 
charge includes making recommendations to the full council by the 
spring of 2005 that identify features of an active and effective 
security program and ways to measure the adoption of these practices. 
The working group is also charged with identifying incentives for the 
voluntary adoption of an active and effective security program in the 
water and wastewater sector.

The Department of Homeland Security (DHS) is also seeking to enhance 
communication between critical infrastructure sectors, like the water 
sector, with the government. The Homeland Security Information Network 
(HSIN) is being developed to provide the water sector with a suite of 
information and communication tools to share critical information both 
within the sector, across other sectors, and with DHS. According to 
DHS, these information and collaboration tools will facilitate the 
protection, stability, and reliability of the nation's critical water 
infrastructure and provide threat-related information to law 
enforcement and emergency managers on a daily basis. A Water Sector 
Coordinating Council established by the department with representative 
members of the water sector community is charged with identifying 
information and other needs of the sector, including the appropriate 
use of and the relationships among ISAC, the Water Security Channel, 
and HSIN. According to a DHS official, the department is also 
assembling a Government Coordinating Council made up of federal, state, 
and local officials to assess impacts across critical infrastructure 
sectors, including the water sector.

While federal law does not address wastewater security as 
comprehensively as it addresses drinking water security,[Footnote 3] 
wastewater utilities have taken steps, both in concert with EPA and on 
their own, to protect their critical components. Since 2002, EPA has 
provided more than $10 million to help address the security needs of 
the wastewater sector. A large portion of this funding has been awarded 
to nonprofit technical support and trade organizations including the 
Association of Metropolitan Sewerage Agencies (AMSA) and the Water 
Environment Federation to develop tools and training on conducting 
vulnerability assessments to reduce utility vulnerabilities and on 
planning for and practicing response to emergencies and incidents. 
Also, according to EPA, because of the relationship between the 
drinking water and wastewater sectors, much of the work and funding 
that has been allocated for drinking water security also directly 
benefits the wastewater sector. The Water Environment Research 
Foundation, for instance, has been conducting research on cyber 
security, real-time monitoring, the effects of contaminants on 
treatment systems, and other topics that could benefit both sectors. In 
addition, EPA has supported the development of a variety of resource 
documents for utilities such as guidance on addressing threats and 
security product guides for evaluating available technologies and has 
offered additional technical support to small systems.

To assist in the completion of vulnerability assessments, AMSA with EPA 
funding cited above, developed technical assistance documents and 
software including the Vulnerability Self Assessment Tool (VSAT) that 
are available free of charge to water and wastewater systems. The VSAT 
methodology and software offers utilities a structured approach for 
assessing their vulnerabilities and establishing a risk-based approach 
to taking desired actions.

Even though the wastewater industry has not been required by law to 
undertake the security measures undertaken by drinking water utilities, 
many in the industry maintain that enhanced security must be pursued. 
They note, however, that the implementation of security measures 
imposes additional financial costs on a sector that is already 
experiencing difficulty in meeting the financial challenges of an aging 
infrastructure. Accordingly, the industry has sought federal assistance 
through the congressional appropriations process. In 2003, Congress 
responded by considering legislation that would have authorized $200 
million for use in making grants to wastewater utilities to conduct 
vulnerability assessments and implement security improvements, $15 
million for technical assistance for small systems, and $5 million over 
5 years for refinement to vulnerability assessment methodologies.

Objectives, Scope, and Methodology: 

As requested by the Chairman and Ranking Minority Member of the Senate 
Committee on Environment and Public Works, this report identifies 
experts' views on the following questions: 

* What are the key security-related vulnerabilities affecting the 
nation's wastewater systems?

* What specific activities should the federal government support to 
improve wastewater security?

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

It was outside the scope of this review to ascertain the desirability 
of using federal funds to support wastewater security or to compare the 
merits of federal support of the wastewater industry with others such 
as the electric power or transportation industries. Rather, we sought 
to obtain expert advice on how best to use federal funds to improve 
wastewater security, should Congress agree that they should be 
appropriated for this purpose.

To obtain information on these three questions, we conducted a three- 
phase Web-based survey of 50 experts on wastewater security. We 
identified these experts from a list of more than 100 widely recognized 
experts in one or more key aspects of wastewater security. In compiling 
this initial list, we also sought to achieve balance in terms of area 
of expertise (i.e., state and local emergency response, preparedness, 
engineering, epidemiology, public policy, security, wastewater 
treatment, risk assessment, water infrastructure, bioterrorism, and 
public health).

In addition, we sought experts from (1) key federal organizations 
(e.g., DHS, EPA, and National Science Foundation); (2) key state and 
local agencies, including health departments and environmental 
protection departments; and (3) key industry and nonprofit 
organizations such as AMSA, Environmental Defense, Water Environment 
Federation, and the Water Environment Research Foundation; and (4) 
water utilities serving populations of varying sizes. Of the 
approximately 70 experts we contacted, 50 agreed to participate and 
complete all three phases of our survey. A list of the 50 participants 
in this study is included in appendix I.

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

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

In the survey's first phase, we asked a series of open-ended questions. 
We pretested these questions with officials from the wastewater utility 
industry, nonprofit research groups, and a federal agency. Responses 
were content analyzed to provide the basis for the questions asked in 
the subsequent phases. Phase 2 questions were close-ended and asked 
experts to rate the relative priority or effectiveness of the Phase 1- 
identified security activities, allocation criteria, and funding 
mechanisms. Experts were also invited to provide narrative comments.

During the third phase, we provided experts with aggregate group 
results from Phase 2, along with their own individual answers to the 
Phase 2 questionnaire. Experts were asked to compare the group results 
with their own individual answers and to use this information as a 
basis for reconsidering their answers and revising their individual 
responses, if so desired.

In addition to the information obtained from our expert panel, we 
obtained documentation from representatives of professional 
organizations, such as the National Academy of Sciences, the Water 
Environment Research Foundation, and AMSA. We also held interviews with 
EPA on the agency's wastewater security programs. During our 
interviews, we asked officials to provide information on program 
operations, policies, guidance, and funding levels. We also received 
training on VSAT from the Water Environment Federation, which was 
supported by AMSA, and attended specialized conferences addressing 
water security by the American Water Works Association and other 
organizations.

We conducted our work from January 2004 through December 2004 in 
accordance with generally accepted government auditing standards.

[End of section]

Chapter 2: Experts Identified Key Vulnerabilities That Could Compromise 
Wastewater Security: 

Experts responding to our survey identified five key physical assets of 
wastewater systems as among the most vulnerable to terrorist-related 
attacks: (1) the collection systems' network of sewers, which includes 
underground sanitary, stormwater and combined sewer lines; (2) 
treatment chemicals, primarily chlorine, which are used to disinfect 
wastewater; (3) key components of the wastewater treatment plant, such 
as its headworks, where the raw sewage first enters the treatment 
plant; (4) control systems, used to control plant operations; and (5) 
pumping stations along the collection system, which lift or pump 
wastewater to allow gravity flow to help move sewage to the treatment 
plant (see fig. 4). Of these assets, experts ranked the collection 
systems' network of sewers and treatment chemicals as the most 
vulnerable.

Figure 4: Key Wastewater System Vulnerabilities Identified by Experts: 

[See PDF for image]

[End of figure]

Experts also identified overarching vulnerabilities that could 
compromise the overall integrity of the systems' security. These 
vulnerabilities include (1) a general lack of security awareness within 
the wastewater sector; (2) interdependencies among components of the 
wastewater system, opening the possibility that a failure of any 
individual component could bring down the entire system; and (3) 
interdependencies between the wastewater system and other critical 
infrastructure that could fail, such as electric power supplies.

In general, our panel of experts' observations were consistent with 
those of major organizations that have conducted research on wastewater 
system vulnerabilities. Among these organizations are the Water 
Environment Federation and the Association of Metropolitan Sewerage 
Agencies.

Experts Identified Five Key Vulnerabilities: 

The five assets experts considered most vulnerable included the 
collection systems' network of sewer lines, treatment chemicals, key 
components of the wastewater treatment plant, control systems, and 
pumping stations.

Collection Systems' Network of Sewers: 

Forty-two of the 50 experts we surveyed identified the collection 
systems' network of sanitary, storm, and combined sewer lines as among 
the top five terrorist-related vulnerabilities of wastewater systems. 
Experts explained that adversaries could use the network of sewers to 
(1) covertly gain access to intended targets within the service area or 
to (2) convey hazardous or flammable substances that may cause 
explosions at points along the system or cause harm to the wastewater 
treatment system or process.

As some experts explained, gaining access to buildings or other 
intended targets could be accomplished covertly using sewer networks. 
Sewers make underground travel from a point of entry to a potential 
target almost undetectable. Entering the sewer system is relatively 
easy, due to the large number of access points, such as manholes, that 
may or may not be protected. Moreover, some sewers, particularly those 
in older cities, may be large enough for people and even trucks to 
covertly pass through--often beneath some of the most heavily populated 
and critical areas--and gain access to potential targets, such as 
government and financial districts. Sewer lines range in size from 4 
inches to greater than 20 feet in diameter. One expert explained: 

Access controls to important installations, such as perimeter fencing, 
can be countered by a terrorist gaining access to the facility unseen 
by using the underground collectors. Once access is gained, any 
activity could then occur--target reconnaissance or surveillance, 
planting of conventional explosives or weapons of mass destruction, 
hostage taking, [or] theft of critical documents and items.

Many experts also suggested that adversaries could use the collection 
system as an underground transport system--without ever physically 
entering the system--for explosive or toxic agents. These substances 
could be inserted into the system through storm drains, manholes, or 
household drains. Several experts explained that with prior knowledge 
of a system's gravity flow, an adversary could calculate the precise 
timing and location of an explosion or calculate the amount of a 
substance that might be necessary to disable or destroy the biological 
processes of a wastewater treatment plant.

However, even without precise knowledge about a system, significant 
damage can occur as a result of underground sewer explosions. These 
explosions may also damage natural gas or electric lines often co- 
located with sewers. One expert cited the effects of an unintentional 
explosion that occurred in 1981 in Louisville, Kentucky, where 
thousands of gallons of a highly flammable solvent, hexane, spilled 
into the sewer lines from a local processing plant. The fumes created 
an explosive mixture that was eventually ignited by a spark from a 
passing car. The result was a series of explosions that collapsed a 12- 
foot diameter pipe and damaged more than 2 miles of streets. While no 
one was seriously injured, sewer line repairs took 20 months, followed 
by several more months to repair the streets. A more serious incident 
occurred in Guadalajara, Mexico, when a gasoline leak into a sewer, in 
April 1992, caused explosions that killed 215 people, injured 1,500 
others, damaged 1,600 buildings, and destroyed 1.25 miles of sewer. The 
explosion created craters as deep as 24 feet and as large as 150 feet 
in diameter. Another alarming incident was an intentional release of a 
cleaning solvent (naptha) and alcohol into a sewer that caused 
explosions 3.5 miles away from the source and damaged about 5,400 feet 
of sewer line. This June 1977 incident in Akron, Ohio, by vandals at a 
rubber manufacturing plant resulted in more than $10 million in damage.

Adversaries may also use the system to convey substances that disable 
the treatment process. For example, as one expert explained, an 
adversary could introduce a highly toxic chemical into the sewer that 
could damage the biological processes involved in treatment. Several 
experts warned that disabling the treatment process could cause the 
release of improperly treated sewage, placing the receiving water in 
jeopardy and potentially harming human health and the environment. In 
February 2002, such an incident occurred in Hagerstown, Maryland, when 
chemicals from an unknown source entered the wastewater treatment plant 
and destroyed the facility's biological treatment process. This 
incident resulted in the discharge of millions of gallons of partially 
treated sewage into a major tributary of the Potomac River, less than 
100 miles from a water supply intake for the Washington, D.C., 
metropolitan area.

Wastewater Treatment Chemicals: 

Thirty-two of the 50 experts we surveyed identified process chemicals 
used in wastewater treatment as among the top five terrorist-related 
wastewater system vulnerabilities. Wastewater treatment facilities use 
a variety of chemicals, including chlorine, sulfur dioxide, and ammonia 
during the treatment process. Most experts singled out chlorine gas as 
a major chemical of concern because it is an extremely volatile and 
hazardous chemical that requires specific precautions for its safe 
transport, storage, and use.

Chlorine is a disinfectant that is commonly used in the treatment 
process before treated water (effluent) is discharged into local 
waterways. However, if chlorine, which is stored and transported as a 
liquefied gas under pressure, is accidentally released into the 
atmosphere, it quickly turns into a potentially lethal gas. Because 
gaseous chlorine is heavier than air, the cloud it forms tends to 
spread along the ground. Consequently, accidental or intentional 
releases of chlorine could be extremely harmful to those in the 
immediate area. Exposures to chlorine could burn eyes and skin, inflame 
the lungs, and could be deadly if inhaled. One expert pointed out that 
accidental releases of chlorine gas have occurred numerous times and 
that a deliberate release would be relatively feasible. The expert 
further explained that many wastewater plants have been converting from 
chlorine gas to alternative disinfection methods for various reasons, 
including the risk of a release.

Recognizing that chlorine gas releases pose threats to the public and 
the environment, EPA requires, among other things, that any facility 
storing at least 2,500 pounds of chlorine gas submit a risk management 
plan; as of December 2004, EPA estimates that about 1,200 plants fit 
this category. The plan includes an estimate of the potential 
consequences to surrounding communities of hypothetical accidental 
"worst-case" chemical releases from their plants. These estimates 
include the residential population: 

located within the range of a toxic gas cloud produced by a "worst- 
case" chemical release, called the vulnerable zone.[Footnote 4]

Several experts stated that a terrorist could use chlorine gas as a 
weapon, either at a wastewater plant that is in close proximity to a 
specific target population, or through theft and use at another 
location. In fact, on September 11, 2001, railroad tanker cars filled 
with toxic chemicals including chlorine sat at a treatment plant across 
the river from the Pentagon as it was being attacked. At that time, the 
population within the plant's vulnerable zone was 1.7 million people. 
Within weeks after September 11, this facility converted to an 
alternative disinfection method. Other facilities have also eliminated 
the use of chlorine gas, choosing instead chlorine-based technologies 
(e.g., sodium hypochlorite, calcium hypochlorite, mixed oxidant 
generation) or nonchlorine-based technologies (e.g., ozone and 
ultraviolet light). However, as one expert noted, several dozen 
wastewater treatment plants in heavily populated areas continue to use 
large amounts of chlorine gas.

In addition to concerns over on-site chlorine storage, experts were 
also concerned about the safe transport of chemicals to treatment 
facilities. Chlorine is delivered to facilities via railways and 
highways and in various container sizes ranging from 1-ton cylinders to 
90-ton railroad cars (see figs. 5 and 6). As experts noted, although 
rail tank cars are designed to avoid leakage in the event of a 
derailment, and the containers can theoretically withstand a bullet 
from a normal handgun or rifle, one expert concluded that the "use of 
explosives to cause a rupture is well within the skill set of a 
terrorist."

Figure 5: Chlorine Delivery Truck: 

[See PDF for image]

[End of figure]

Figure 6: Chlorine Railroad Car: 

[See PDF for image]

[End of figure]

Such an attack along a congested transportation corridor could have 
severe public health and safety impacts. One expert said that before 
converting from chlorine to alternative disinfection methods, a major 
wastewater treatment plant in Washington, D.C., received its chlorine 
supply via rail shipments that traversed through the center of the 
city, close to the U.S. Capitol Building and across two military 
installations before reaching its final destination. Derailments of 
chlorine could have major impacts in small communities as well, as 
occurred in Alberton, Montana, in April 1996. One of the five tankers 
that derailed ruptured and reportedly released more than 60 tons of 
chlorine. Subsequently, a toxic plume of chlorine gas crossed the Clark 
Fork River, a major interstate, and surrounding residences. An 
estimated 1,000 people were evacuated, 350 people were hospitalized, 
and one person died.

Key Components of the Treatment Plant: 

In addition to the vulnerability of chemicals stored at a wastewater 
treatment plant, experts also listed the key process components of the 
treatment plant as vulnerable. Specifically, more than half of the 
experts (29 of 50) identified one or more of these components as among 
the top five vulnerabilities. One expert explained that, historically, 
security was not a consideration in site selection or design of these 
facilities. While many utilities planned for natural disasters or 
vandalism, it was only after September 11, that many utilities have 
considered how best to protect against potential terrorist attacks.

While experts expressed concern over the security of the entire 
treatment plant, several identified the headworks as a component that 
is particularly vulnerable to attack, as well as critical to the 
treatment process. This unit is part of a plant's primary treatment 
process, where wastewater carried through the collection system first 
enters the treatment plant. It is here that large objects, such as 
cans, wood, and plastics are removed from the wastewater stream. These 
structures may be open to the atmosphere and, according to one expert, 
are easy to attack. Experts explained that sabotage of the headworks 
could affect the proper working order of subsequent treatment processes 
and could cause the immediate interruption of the collection system, 
potentially restricting or completely blocking wastewater flow. As one 
expert noted, restricted flow would could cause backups through the 
collection system, and the stagnant wastewater would become a public 
health hazard within hours, either through physical contact or through 
cross-contamination of drinking water supplies.

Control Systems: 

Control systems were also listed as a key vulnerability by 18 of the 50 
experts. Many wastewater systems are increasingly relying on the use of 
these control systems, including Supervisory Control and Data 
Acquisition (SCADA) networks, to serve functions ranging from storing 
and processing data to monitoring the system's condition and 
controlling its operation. The primary role of SCADA systems is to 
monitor and control dispersed assets from a central location. According 
to one expert, "The backbone for process control is the SCADA system." 
The expert explained that several factors contribute to the 
vulnerability of these controls, including typically nonsecured process 
control rooms at treatment plants, remote access to SCADA, and shared 
passwords between multiple users.

Experts generally explained that an attack on these systems could 
interfere with critical operations. For example, one expert explained 
that an adversary could use SCADA systems to introduce either 
dangerously high or inadequate levels of chemicals; reduce biological 
treatment levels; or cause remote points along the collection system to 
fail. Although some facilities could operate their systems manually 
should the automated system fail or be compromised, others do not have 
the personnel or equipment to do so. For example, as one expert noted, 
large valves in modern plants are now typically operated electronically 
and seldom used manual operation components (see fig. 7).

Figure 7: Pump Operated through Remote Automated Systems: 

[See PDF for image]

[End of figure]

While SCADA networks offer operators increased flexibility and 
efficiency by controlling processes remotely, they were not designed 
with security in mind. The security of these systems is, therefore, 
often weak.[Footnote 5] According to our experts, while many facilities 
take advantage of their system's flexibility, they often do not provide 
the necessary training on cyber security or implement security measures 
such as rotating passwords or securing network connections. Experts 
also explained that penetration of SCADA systems, particularly those 
that may be nonencrypted and accessed via the Internet, offers a 
particularly easy point of access and control of a wastewater system. 
One expert provided an example of a breach in cyber security in 2000 
when such a system in Australia was attacked, causing the release of 
thousands of gallons of raw sewage. While the actions were not an act 
of terrorism, they illustrate how a computer or cyber-related attack 
could be used to disrupt wastewater treatment.

Pumping Stations: 

Sixteen of the 50 experts identified pumping stations, which are 
components that help convey sewage to the wastewater treatment plant, 
as among the top vulnerabilities. One expert explained that destroying 
or disabling a pumping station could cause the collection system to 
overflow raw sewage into the streets and into surface waters and to 
back up sewage into homes and businesses. The expert added that adverse 
effects on public health and the environment are likely if the target 
pump station pumps several million gallons per day of wastewater. 
Another expert explained, that within a service area, one pumping 
station has the capacity to pump 25 million gallons of wastewater per 
day.

Experts explained that the remoteness and geographic distribution of 
pumping stations, and their lack of continuous surveillance, make them 
particularly vulnerable (see fig. 8). However, as one expert noted, 
should these stations be disabled or destroyed, alternatives such as 
"pump-around schemes," where sewage flow is diverted and rerouted, can 
often be implemented within a few days or weeks.

Figure 8: Pumping Station: 

[See PDF for image]

[End of figure]

Overarching Vulnerabilities Affecting Overall Wastewater System 
Security: 

In addition to the physical assets identified as among the greatest 
vulnerabilities of wastewater systems, some experts also identified 
vulnerabilities that may affect the overall security of the nations' 
wastewater systems. First, they pointed out that wastewater utilities 
generally do not have a security culture because they are often more 
focused on operational efficiency and may, therefore, be reluctant to 
add security procedures and access control elements to their 
operations. For example, one expert noted the ease with which many 
types of individuals (employees, contractors, and visitors) and 
vehicles typically enter wastewater treatment plant facilities. As this 
expert pointed out, some facilities do not check to ensure that 
individuals entering the property have legitimate reasons for being 
there. This expert also raised a concern about the lack of inspection 
of incoming truckloads at some wastewater treatment plants. An 
adversary could exploit this lack of security by delivering 
contaminants or explosives to destroy the treatment process or the 
entire facility. In addition to securing entrance checkpoints, two 
experts suggested there is little background screening of utility 
employees. One expert noted, "People with criminal records, falsified 
educational credentials, and other serious liabilities might be hired 
by utilities that fail to thoroughly check their backgrounds. The 
result can be intentional acts of terrorism on a utility."

Second, experts pointed to interdependencies among all major wastewater 
assets within the treatment system. The system as a whole relies on the 
proper working order of all its components to treat a community's 
wastewater. One expert explained that, because treatment plants are 
less able to recover from an attack, they may have a higher level of 
security than other assets, such as the collection system. However, 
because collection and treatment are part of one integrated system, 
securing one asset does not ensure that the system as a whole is more 
protected. For example, gates and fences around the main treatment 
plant may stop an adversary from coming onto the physical property, but 
it will not prevent a harmful agent from entering the facility through 
the collection system--an event that could destroy the facility's 
entire secondary treatment process.

Third, experts identified interdependencies between wastewater systems 
and other critical infrastructures. As several experts explained, 
disruptions in electric power, cyber systems, and transportation of 
treatment chemicals can result in a failure of wastewater treatment 
systems. One expert cautioned that the interruption of the power grid 
could render the wastewater plant useless, noting, "Several hours 
without power would cause the biological treatment process to halt and 
wastewater would back up on the collection system." Such an event 
occurred in 2003, when a major power failure caused treatment plants in 
Cleveland, Ohio, to release at least 60 million gallons of raw 
untreated wastewater into receiving waters. Without electric power, 
operators had no other option but to bypass treatment and directly 
discharge the untreated sewage into Lake Erie or the Cuyahoga River and 
other tributaries.

Conversely, there are instances in which other infrastructure and 
activities may depend on treated wastewater to properly function. For 
example, in some parts of the country, effluent is reclaimed and used 
as cooling water for power generation, to recharge groundwater, or to 
water outdoor landscapes. One expert noted that wastewater treated at a 
plant in the arid Western United States is reclaimed and used to 
provide the only cooling source for a nuclear power plant that provides 
power for much of that region. According to the same expert, the 
immobilization of this treatment plant could, within a certain number 
of days, disable the nuclear plant, causing a major, multistate power 
outage.

[End of section]

Chapter 3: Experts Identified Wastewater Security-Enhancing Activities 
That Warrant Federal Support: 

Experts most frequently identified 11 specific activities to improve 
wastewater security as deserving high priority for federal support (see 
fig. 9). Three activities are particularly noteworthy because they were 
given a rating of highest priority by a substantial number of the 
experts. These activities include the following: 

* Replacing gaseous chemicals used in wastewater treatment with less 
hazardous alternatives. Experts viewed these actions as essential to 
reduce the vulnerability inherent in systems that rely upon the 
transport, storage, and use of potentially hazardous materials such as 
gaseous chlorine in their treatment processes. Several experts noted 
that replacement could be cost prohibitive for many wastewater 
utilities and that it, therefore, warranted federal support.

* Improving local, state, and regional collaboration efforts. Experts 
identified the development of strong working relationships among 
utilities and public safety agencies as critical to protecting 
wastewater infrastructure and system customers from potential threats. 
Some experts also noted that enhanced partnerships among these groups 
would result in improved response capabilities should a wastewater 
system be attacked.

* Completing vulnerability assessments for individual wastewater 
systems. Experts cited these as necessary for utilities to understand 
their security weaknesses, to identify appropriate countermeasures, and 
to implement risk reduction strategies in a logical, coordinated manner.

The remaining eight activities experts frequently rated as warranting 
high or highest priority for federal funding include (1) providing 
training to utility employees related to conducting vulnerability 
assessments and improving the security culture among employees; (2) 
improving national communication efforts between utilities and key 
entities responsible for homeland security; (3) installing early 
warning systems in collection systems to monitor for or detect 
sabotage; (4) hardening physical assets of treatment plants and 
collection systems; (5) strengthening operations and personnel 
procedures; (6) increasing research and development efforts toward 
improving threat detection, assessment, and response capabilities; (7) 
developing voluntary wastewater security standards and guidance 
documents; and (8) strengthening cyber security and Supervisory Control 
and Data Acquisition (SCADA) systems.

Figure 9: Experts' Views on Wastewater Security Activities Most 
Deserving of Federal Support: 

[See PDF for image]

[End of figure]

Replace Gaseous Chemicals with Less Hazardous Alternatives: 

Over half of the experts surveyed (29 of 50) rated the replacement of 
gaseous chemicals at wastewater treatment facilities with less 
hazardous alternatives as warranting highest priority for federal 
funding. Another 14 experts rated this activity as high priority. 
Experts reported that wastewater systems carrying out treatment 
processes using gaseous forms of chemicals, particularly chlorine, make 
themselves targets for terrorist attack. However, as one expert noted, 
changing disinfection technologies effectively devalues these 
facilities as targets for "weaponization" of their existing 
infrastructure.

Several experts noted that some communities and utilities currently 
using gaseous chemical treatment processes have expressed interest in 
converting to an alternative treatment technology, but the financial 
costs associated with conversion remain prohibitive. However, one 
stated that replacing gaseous chemical treatment technology can 
actually result in certain offsetting cost savings. For example, the 
Blue Plains Wastewater Treatment Plant in Washington, D.C., employed 
around-the-clock police units prior to replacing its chlorine gas 
treatment process. Following conversion to a less hazardous treatment 
technology, Blue Plains found that it could reduce this security 
posture. In addition, the utility was able to reduce the need for 
certain emergency planning efforts and regulatory paperwork.

Experts suggested alternative treatment technologies such as sodium 
hypochlorite (a solution of dissolved chlorine gas in sodium hydroxide) 
and ultraviolet disinfection. These alternative processes have been 
implemented at several facilities throughout the United States, 
including Washington, D.C; Atlanta, Georgia; Philadelphia, 
Pennsylvania; Cincinnati, Ohio; Jacksonville, Florida; and Harahan, 
Louisiana. The change, for an individual plant, to sodium hypochlorite 
may require approximately $12.5 million for new equipment and increase 
annual chemical costs from $600,000 for gaseous chlorine to over $2 
million for sodium hypochlorite.[Footnote 6]

Another expert suggested that reducing the size of containers used to 
transport and store gaseous chemicals could also prove an effective 
deterrent to terrorism. This approach is being implemented by a 
treatment plant in the Western United States, where gaseous chlorine is 
now stored in 1-ton canisters--a significant reduction in size from the 
larger 90-ton railroad tanker car size containers the utility 
previously employed (see fig. 10).

Figure 10: One-Ton Canisters of Chlorine Gas Stored at a Wastewater 
Treatment Plant: 

[See PDF for image]

[End of figure]

Improve Local, State, and Regional Collaboration Efforts: 

Twenty-three of 50 experts rated efforts to improve local, state, and 
regional collaboration as warranting highest priority for federal 
funding. Fifteen more experts rated this activity as high priority. 
Several experts noted the importance of establishing strong working 
relationships among utilities, local and state law enforcement 
agencies, fire departments, and other first response agencies in 
advance of a potential emergency situation. Many added that enhanced 
partnerships among these entities can yield significant benefits to 
wastewater utilities including an increased ability to monitor critical 
infrastructure and facilities, improved understanding of agency roles 
and responsibilities, and faster response time to deal with potential 
security breaches.

According to one expert, significant personnel and other resources 
devoted to emergency response are theoretically available to the 
wastewater sector. These resources include law enforcement agencies, 
fire departments, public health care facilities, environmental 
authorities, and other nonprofit and commercial entities. However, the 
expert noted that wastewater facilities remain largely disconnected 
from these entities, and wastewater facilities' efforts for emergency 
response planning are, therefore, often undertaken independently. 
Consequently, emergency response teams do not gain a full understanding 
or appreciation of the unique challenges inherent in maintaining a 
utility's wastewater treatment capability.

This lack of collaboration perpetuates the community's idea that 
"sewers lead to [a] magical place where [materials] simply 'go away' 
without consequence," one expert suggested. The expert added that this 
misperception is demonstrated by a failure of some in the medical 
response community to adequately plan for proper disposal of waste 
resulting from decontamination efforts of a chemical, biological, or 
radiological event. Directly discharging such material to the 
wastewater influent stream could significantly damage or destroy the 
wastewater treatment process.

Collaboration among local, state, and regional agencies should include 
periodic field and "tabletop" exercises to establish and reevaluate the 
roles, capabilities, and responsibilities of agencies that would 
respond to a terrorist event, according to one expert. Another 
identified the nonprofit California Utilities Emergency Association, an 
entity to which most utilities in that state belong, as an effective 
provider of communications, training, mutual aid coordination, and 
simulation exercises. The expert also cited the San Francisco Bay Area 
Security Information Collaborative as a successful example of regional 
collaboration in which participating water utilities coordinate 
communications, responses, and emergency planning.

The Environmental Protection Agency (EPA) has provided funding for 
training on emergency response for wastewater utilities through 
agreements with the Wastewater Operator State Environmental Training 
Program, the Water Environment Federation, and other organizations. 
Through the Department of Homeland Security's Office of Domestic 
Preparedness, EPA has funded emergency response table-top exercise 
training to the nation's larger wastewater utilities.

Complete Vulnerability Assessments: 

Twenty of 50 experts rated the completion of vulnerability assessments 
as warranting highest priority for federal funding. Fourteen other 
experts rated this activity as high priority. Vulnerability assessments 
help water utilities evaluate their susceptibility to potential threats 
and identify corrective actions to reduce or mitigate the risk of 
serious consequences from vandalism, insider sabotage, or terrorist 
attack. One expert explained that this process enables a utility to 
evaluate its terrorist-related vulnerabilities and begin to implement 
security enhancement plans that directly address those identified 
vulnerabilities. Another added that the assessments also present useful 
findings that should be incorporated into a utility's emergency 
response plan and that they enable an active process for updating and 
exercising those plans.

The Bioterrorism Act of 2002 required vulnerability assessments for 
drinking water utilities serving more than 3,300 people but did not 
include a comparable requirement for wastewater utilities. To foster 
the completion of vulnerability assessments among wastewater utilities, 
EPA has funded the development of vulnerability assessment 
methodologies and provided training to wastewater utilities. EPA has 
encouraged wastewater utilities to use methodologies such as those 
provided by the National Environmental Training Center for Small 
Communities, on security and emergency planning, and the Vulnerability 
Self Assessment Tool (VSAT), developed and released by the Association 
of Metropolitan Sewerage Agencies. The VSAT methodology and 
accompanying software provide an interactive framework for utilities of 
all sizes to analyze security vulnerabilities to both manmade threats 
and natural disasters, evaluate potential countermeasures for these 
threats, and enhance response capability in the event of an emergency 
situation. This methodology has been continually updated and improved; 
VSAT Version 3.1 is currently available to utilities. Through EPA 
support, the Water Environment Federation has provided extensive 
training of the VSAT tool free of charge to wastewater utility 
operators and others involved in environmental protection, public 
safety, and security.

Expand Training Opportunities for Wastewater Utility Operators and 
Administrators: 

Thirteen of the 50 experts rated the expansion of training 
opportunities for utility personnel as warranting highest priority for 
federal funding, and an additional 27 experts suggested this activity 
warranted a high priority. According to experts, creating a security- 
minded culture among wastewater utilities is critical to building 
awareness of security vulnerabilities and implementing appropriate 
countermeasures.

In particular, experts noted that wastewater system operators and 
administrators need to become better educated about the importance of 
focusing on security and emergency preparedness issues. Several experts 
suggested that managers should have a full understanding of potential 
types of terrorist attacks and the systems or mechanisms that could 
preclude or mitigate these events. They added that other parties, 
including boards of directors of wastewater systems, mayors, and city 
councils need to be made aware of potential threats to wastewater 
systems and the impact a terrorist event could have upon a facility. 
One expert stated that successful development of security awareness 
among those associated with wastewater systems could mean the 
difference between simply installing security systems and actually 
becoming secure.

Experts also stated that additional technical training for operators is 
necessary to ensure the security of wastewater systems. One noted that 
this type of training could avert a catastrophe by enabling a 
wastewater operator to recognize a pending disaster as early as 
possible. Another expert stated that increased technical training, 
particularly for smaller wastewater utilities, is necessary to ensure 
that funds for physical security enhancements are used to their maximum 
potential, thus achieving maximum benefit for the wastewater utility. 
One expert also suggested that devoting funding toward increased 
technical training will provide wastewater utility employees with the 
skills necessary for developing comprehensive vulnerability assessments 
and implementing emergency response plans before a terrorist attack.

Since 2002, EPA has provided more than $10 million to help address the 
security needs of the wastewater sector. A large portion of this 
funding has been awarded to nonprofit technical support and trade 
organizations to develop tools and training on conducting vulnerability 
assessments to reduce utility vulnerabilities and on planning for and 
practicing response to emergencies and incidents.

Improve National Communication Efforts between Utilities and Key 
Entities Responsible for Homeland Security: 

While only 8 of 50 experts rated efforts to improve communications 
between utilities and federal entities responsible for homeland 
security as warranting highest priority for federal funding, well over 
half of the experts surveyed (31 of 50) rated this activity as high 
priority. One expert stated that it is essential to develop an 
effective communications strategy that involves the broad range of 
stakeholders responsible for ensuring wastewater security. Another 
emphasized that wastewater utilities need timely and useful information 
from federal authorities about increased threat levels and protective 
actions that should be implemented.

To improve national communications, EPA provided a grant to AMWA to 
develop the Water Information Sharing and Analysis Center (Water ISAC). 
The Water ISAC is a secure, Internet-based subscription service that 
provides time-sensitive information and expert analysis on threats to 
both wastewater and drinking water systems. It serves as a key link in 
the flow of water security information among utilities and federal 
homeland security, intelligence, law enforcement, public health, and 
environmental agencies.

However, according to some experts, Water ISAC does not sufficiently 
ensure adequate communication between federal agencies and utilities. 
One stated that despite a high reliance upon Water ISAC by drinking 
water utilities, this communication vehicle has proven inadequate for 
meeting the needs of the broad range of stakeholders involved in 
protecting drinking water security. This expert added that the Water 
ISAC needs to be better developed if it is to be an essential part of a 
communications strategy for the wastewater sector. Another expert noted 
that several water utilities have avoided the Water ISAC because of the 
subscription fees associated with the service. In the fall of 2004, the 
Water ISAC announced a new communication tool known as Water Security 
Channel. The Water Security Channel is a password protected site that 
electronically distributes federal advisories regarding threat 
information to the water sector. Water Security Channel is a service 
that is free of charge to any wastewater or drinking water utility that 
wishes to participate.

For its part, the Department of Homeland Security is implementing its 
Homeland Security Information Network (HSIN) initiative, which will 
provide a real-time, collaborative flow of threat information to state 
and local communities, as well as to individual sectors. According to 
the department, this network will be the only tool available that 
provides collaborative communications between first responders, 
emergency services, the government (local, state, and federal) and 
other sectors on a real-time basis. In addition, the department has 
established a Water Sector Coordinating Council to identify information 
and other needs of the sector, including the appropriate use and the 
relationships among the Water ISAC, the Water Security Channel, and 
HSIN.

Install Early Warning Systems in Collection Systems to Monitor for or 
Detect Sabotage: 

Seven of 50 experts rated the installation of early warning systems in 
collection systems to monitor for or detect sabotage as warranting 
highest priority for federal funding, and an additional 31 experts 
rated this activity as a high priority. A device these experts 
frequently mentioned to achieve some degree of monitoring and detection 
for explosive substances is the lower explosive level (LEL) meter, 
which can be inserted into manholes and connected to central computers. 
One expert claimed LEL meters have significantly improved response time 
in mitigating the potential for structural damages resulting from 
explosions within the wastewater collection system.

One expert also noted that disabling the biological processes occurring 
at a wastewater treatment plant would require a large amount of toxic 
compounds to be inserted into the collection system, but several 
experts stated that this possibility remains of concern because of the 
open access collection systems afford. Many experts suggest that 
additional research is needed to develop early warning technologies 
that can sense the presence and concentration of these types of toxic 
compounds in the collection system and relay that information 
electronically to treatment operators.

Harden Physical Assets of Treatment Plants and Collection Systems: 

Eight of 50 experts rated physical hardening of treatment plants and 
collection systems as warranting highest priority for federal funding 
and an additional 29 experts rated this activity as high priority. 
Experts stated that physically securing the perimeter of the treatment 
plants and pumping stations with fences, locks, security cameras, alarm 
systems, motion detection systems, and other physical barriers can 
protect critical treatment components from direct attack or sabotage 
(see figs. 11 and 12). One expert noted that the more difficulty 
terrorists encounter in trying to reach critical targets in a 
wastewater system, the less frequently attacks will be attempted, and 
the lesser the impact will be if and when these attempts succeed. 
Furthermore, improvements to perimeter defenses surrounding wastewater 
treatment systems not only deter terrorist intruders but also restrict 
access by vandals, contributing toward improved reliability of 
electronic surveillance systems. As one expert pointed out, physical 
hardening of assets can largely be accomplished with hardware that 
requires only minimal maintenance and replacement cost once installed.

Figure 11: Electronically-Controlled Security Gate: 

[See PDF for image]

[End of figure]

Figure 12: Security Camera and Infrared Motion Detectors: 

[See PDF for image]

[End of figure]

Other experts suggested that actions are needed to provide redundant 
capabilities to wastewater treatment systems. According to experts, 
additional power, pumping, and collection bypass systems would provide 
more reliable treatment capacity that would benefit the public not only 
in the event of terrorism but also during nonterrorist events (e.g., 
natural disasters, weather-related events, or interrelated 
infrastructure failures). Such actions could ensure that wastewater 
systems maintain full treatment capabilities during a variety of 
unforeseen catastrophic events.

Although one expert claimed that protecting the several hundred miles 
of sewers in a large urban system is virtually impossible, other 
experts suggested that design improvements and physical alterations 
could limit access to collection systems. Some experts suggested 
securing manhole covers with maintenance-friendly lockdown mechanisms. 
In addition, one expert suggested improving engineering designs for 
wastewater systems in ways that reduce vulnerability risks posed by 
infrastructure cross-connections with other water systems.

Strengthen Operations and Personnel Procedures: 

Seven of 50 experts rated the strengthening of operations and personnel 
procedures at wastewater systems as warranting highest priority for 
federal funding, and an additional 24 experts rated this activity as a 
high priority. For example, one expert suggested that a highly 
efficient background check system should be available to water 
utilities to get accurate information on new and existing employees, 
contractors, and others who are working at vital facilities, such as 
wastewater treatment plants. This expert noted that access to such 
systems is afforded to airport administrators and certain law 
enforcement entities but is largely inaccessible to water utilities.

Another expert stated that wastewater utilities need procedures to 
ensure the security of collection system maps and drawings, while also 
allowing reasonable access to them by contractors and developers. The 
expert suggested maps could be electronically stored and password 
protected with a regularly changed password. Another expert suggested 
that all employees and visitors have identification badges with 
photographs and electronic strips or sensors that regulate points of 
access allowed by the badge.

Increase Research and Development Efforts to Improve Detection, 
Assessment, and Response Capabilities: 

Thirteen of 50 experts rated expanded research and development efforts 
to improve detection, assessment, and response capabilities for 
wastewater systems as warranting highest priority for federal funding, 
and an additional 17 experts suggested this activity warranted a high 
priority. One expert stated that new technologies are needed in the 
wastewater sector to better protect physical assets by providing 
reliable surveillance and detection capabilities with a minimal need 
for on-site, around-the-clock security personnel. According to another 
expert, technologies currently in development for drinking water 
utilities could potentially be adapted for use by wastewater utilities. 
These technologies would need to detect hazardous chemical, biological, 
or radioactive contaminants while operating in the harsh environment of 
common, everyday contaminants found in sewage. Also, improved computer 
mapping systems tracking the course and speed of sewage flow could 
greatly enhance emergency response activities including evacuations, 
dilutions of harmful substances that have been introduced to the sewage 
flow, and venting of volatile materials.

EPA's Office of Research and Development has recently funded research 
that is intended to address many of these needs. According to an 
official with EPA's Water Security Division, while these efforts have 
been primarily directed toward drinking water security research, some 
of EPA's research findings can be applied to wastewater security. EPA 
has also developed a water security research and technical support 
action plan that outlines various research and technical support needs 
that the water industry and other stakeholders have identified. The 
plan also proposes specific projects to address these needs, and EPA 
has begun work on some of these projects in collaboration with the 
Water Environment Research Foundation and the American Water Works 
Association Research Foundation. These nonprofit research organizations 
have received funding to address a variety of wastewater security 
research projects, such as assessing new security technologies to 
detect and monitor contaminants and prevent security breaches. 
According to EPA, other issues being addressed include public health 
protection, vulnerability and protection of water and wastewater 
infrastructure, and communication in the event of deliberate attacks or 
natural disasters.

Develop Voluntary Wastewater Security Standards and Guidance Documents: 

Four of 50 experts rated the development of voluntary wastewater 
security standards and guidance documents as warranting highest 
priority for federal funding, and half of the experts surveyed (25 of 
50) gave this activity a high priority rating. Experts identified 
options including development and issuance of voluntary standards for 
security of wastewater facilities (including design standards), a peer 
review process to evaluate the quality of wastewater utilities' 
vulnerability assessments and emergency response plans, and creation of 
a secure Web site that disseminates lessons learned by utilities 
throughout the various phases and processes related to protecting 
wastewater security.

One expert suggested that developing government standards for the 
security of all new facilities would help increase the overall ability 
of wastewater systems to withstand threats. The expert stated such 
standards should lay out minimum protection standards and provide a 
framework of threats utilities should consider when completing 
vulnerability assessments. Another expert suggested that, because water 
utilities seek guidance from the federal government on whether their 
individual treatment plants are secure, one option, in lieu of site 
visits by EPA, might be a peer review process of vulnerability 
assessments and emergency response plans across wastewater utilities. 
Development of a secure Web site for wastewater utilities that includes 
lessons learned from assessments, planning, training, and incident 
responses could also provide valuable guidance for wastewater 
utilities, one expert noted.

EPA recently commissioned a study by the National Drinking Water 
Advisory Council's Water Security Working Group to address some of 
these needs. The group's charge is to identify: (1) the features of an 
active and effective security program for drinking water and wastewater 
utilities; (2) incentives that would encourage water utilities to 
implement features of the security program; and (3) ways to measure the 
extent of utility implementation of the security program. In addition, 
in September 2003, EPA gave funding to the American Society of Civil 
Engineers to develop voluntary security standards for drinking water, 
wastewater, and stormwater utilities, which were released in December 
2004 as interim standards. A training module is planned for spring 2005.

Strengthen Cyber Security and SCADA Systems: 

Five of 50 experts rated efforts to improve cyber security and SCADA 
systems as warranting highest priority for federal funding, and an 
additional 22 experts gave this activity a high priority rating. 
According to one expert, measures should be taken to minimize access to 
these systems by improving the security capabilities of hardware 
systems and software applications, as well as by implementing 
appropriate information technology security policies at wastewater 
utilities.

One other expert suggested the federal government invest in programs 
designed to create, accelerate, and deploy minimally acceptable cyber 
security standards for all automated systems where a compromising event 
could place a surrounding population at risk. This expert noted that 
the need for cyber security standards is not limited exclusively to 
wastewater systems, but stated that the particular needs and 
characteristics of these utilities should be considered as these 
standards are developed.

[End of section]

Chapter 4: Experts Identified Key Allocation Criteria and Funding 
Mechanisms for Addressing Wastewater Security Needs: 

Numerous wastewater utilities have begun to address security concerns 
by completing vulnerability assessments or by undertaking security 
upgrades. To date, most security initiatives have been financed by 
reallocating funds from other important utility activities or embedding 
security into ongoing operations. According to industry 
representatives, utilities may ultimately have no choice but to pass 
these costs along to their customers through rate increases. Given the 
cost of these security actions, however, many in the utility industry 
believe federal assistance through the congressional appropriations 
process is warranted. Experts do not all agree that the wastewater 
industry as a whole should receive funding priority, noting that other 
sectors such as electricity or transportation may warrant higher 
priority. Indeed, while the vast majority of our experts did support 
federal funds for security for wastewater utilities, some voiced 
dissenting opinions on the matter.

Nonetheless, should Congress and the administration agree to a request 
for funds, they will need to address key issues concerning who should 
receive the funds and how they should be distributed. With this in 
mind, we asked our panel of experts to focus on (1) the types of 
utilities that should receive funding priority and (2) the most 
effective mechanisms for directing these funds to potential recipients. 
Overall, we found a high degree of consensus on the following: 

* Thirty-nine of the 50 experts indicated that utilities serving 
critical infrastructure (including government, commercial, industrial, 
and public health centers) should be given highest priority for federal 
funding. Half of the experts gave utilities using large quantities of 
gaseous chemicals a rating of highest priority while just under half of 
the experts gave the same rating to utilities serving large populations.

* Direct federal grants are the most favored funding mechanism, with 
many experts indicating the circumstances in which such grants should 
or should not include matching funds from the recipient. Many favored 
direct grants without a matching requirement for a wide variety of 
planning and coordination activities, such as completing vulnerability 
assessments, conducting training, and developing standards and 
guidance. Cost-shared grants were favored for activities that benefit 
individual utilities, such as strengthening operation and personnel 
procedures, installing early warning systems in collection systems, and 
hardening physical assets.

Key Criteria to Help Determine Which Utilities Should Receive Funding 
Priority: 

The experts identified several characteristics of utilities that should 
be used to set funding priorities. The most frequently identified were 
utilities: (1) serving critical infrastructure including government, 
commercial, industrial, and public health centers; (2) using large 
quantities of gaseous chemicals; (3) serving areas with large 
populations; (4) where a security breach would adversely impact 
environmental resources (e.g., receiving waters); (5) having completed 
vulnerability assessments; (6) serving areas with medium or small 
populations; and (7) serving buildings, monuments, parks, tourist 
attractions or other entities that have symbolic value (see fig. 13).

Figure 13: Experts' Views on Which Characteristics of Wastewater 
Utilities Should Be Used to Set Priority for Federal Funds: 

[See PDF for image]

[End of figure]

Utilities Serving Critical Infrastructure: 

More than three quarters of the experts (39 of 50) gave utilities 
serving critical infrastructure a highest priority rating. An 
additional 10 experts gave these utilities a rating of high priority. 
These utilities provide service to institutions that serve as hubs for 
government activity; commercial and industrial centers, such as a 
city's financial district, power plants, or major airports; and public 
health institutions, such as major medical centers and hospitals. As 
one expert commented, "while every wastewater system is a potential 
target, it seems prudent to assume that the larger the system or the 
criticality of facilities served, the greater the potential impact and 
hence the more likely the target." Most experts shared this view, 
including one who said the highest priority should go to "the impact 
the loss of the treatment facility would have on other vital services" 
such as providing cooling water for a nuclear or steam generating power 
plant.

Some experts said that systems with heavy commercial and industrial 
usage are critical to the country's economic stability, and any major 
or sustained disruption could have severe economic as well as public 
health consequences. For example, one expert pointed out that critical 
industrial customers such as the computer chip manufacturing sector 
could cost the economy millions per day should a shutdown be caused by 
the loss of a wastewater treatment plant.

Utilities Using Large Quantities of Gaseous Chemicals: 

More than half of the experts (26 of 50) gave a rating of highest 
priority for funding of utilities using large quantities of gaseous 
chemicals. An additional 18 experts rated these utilities as warranting 
a high priority for federal funds. Some experts pointed out that many 
wastewater treatment plants use large quantities of elemental chlorine 
and other toxic materials which, if released to the atmosphere on-site 
or during transport to the site, would necessitate widespread 
evacuations, and possibly cause injuries and fatalities.

Several experts pointed out that the Environmental Protection Agency's 
(EPA) Risk Management Planning program requires industrial facilities 
that use threshold amounts of certain extremely hazardous substances to 
self-identify their worst-case chemical release scenarios. An expert 
cautioned, however, that funds should not be provided to utilities for 
converting to less hazardous chemicals (e.g., sodium hypochlorite) when 
other utilities have already or are currently looking at disinfection 
options that could pose little or no security worker risk, or public 
health risks.

Utilities Serving Areas with Large Populations: 

Almost half of the experts (24 of 50) gave a rating of highest priority 
to utilities serving areas with large populations. Seventeen additional 
experts rated these utilities as warranting a high priority for federal 
funds. Many experts shared the view that providing financial and 
technical assistance to the largest treatment plants would protect the 
greatest number of people. One expert pointed to EPA's 2000 Clean Water 
Needs Survey, which indicated that about 70 percent of the nation's 
sewered population is served by the 3,500 largest wastewater facilities 
(out of a total of 16,000 facilities). Each of these facilities 
maintains a flow that is greater than 1 million gallons per day. Thus, 
this expert concluded, funding the largest plants provided benefits to 
the greatest number of people. Finally, a number of experts suggested 
that because terrorists are likely to seek to maximize the number of 
people killed or injured by their attacks, they may try to strike 
systems serving many customers in large metropolitan areas.

Utilities Where a Security Breach Would Adversely Impact Environmental 
Resources: 

While only four experts gave a rating of highest priority to utilities 
where a security breach would adversely impact environmental resources, 
28 of the experts rated these utilities as warranting a high priority. 
Several experts pointed out the potential for a negative impact on the 
environment and public health if raw sewage overflows into receiving 
bodies of water. One expert commented that many wastewater treatment 
plants discharge highly treated effluent to rivers upstream of the 
intakes to water treatment plants serving downstream cities. Damage to 
these wastewater treatment plants could cause the discharge of raw 
sewage that would be only partially diluted before it reached the 
intakes of the downstream drinking water treatment plants. Experts also 
cited significant potential effects on the environment. Some mentioned 
that the discharge of untreated sewage could impact beaches, critical 
habitats, or fisheries, causing economic damage in addition to negative 
environmental and public health effects.

Utilities That Have Completed Vulnerability Assessments: 

Three of the experts gave a highest priority rating to utilities that 
have completed vulnerability assessments (VAs). An additional 18 
experts gave these utilities a high priority rating. Some experts said 
that only utilities that have completed VAs should be given federal 
funding. Other experts pointed out that there should be federal funding 
for those utilities that have not yet completed VAs so that they can 
complete this key task. As one expert commented, a key benefit of 
conducting a vulnerability assessment of a wastewater system is that it 
allows the areas of the greatest need to be identified.

Properly conducted, a vulnerability assessment brings in all the 
necessary divisions within a plant including operations, information 
technology, management, and external forces such as fire departments 
and local police. Should a plant demonstrate that it has conducted such 
an assessment, that plant would be much more likely to use federal 
funding efficiently, this expert added.

Utilities Serving Areas with Medium or Small Populations: 

Eight of the 50 experts rated utilities serving areas with medium or 
small populations as a high priority for federal funding. An additional 
27 experts rated these utilities as a medium priority. One expert 
pointed out that such facilities are least able to afford security 
enhancements or acquire the security expertise and, therefore, may be 
in need of federal support.

The relatively small number of experts giving a high or highest 
priority rating for utilities serving areas with medium or small 
populations may not fully reflect the concern among some experts for 
the safety of these utilities. For example, some who gave a higher 
priority rating to utilities serving areas with large populations 
suggested that the need for federal support should be an important 
associated criterion, regardless of system size. Accordingly, these 
experts said that some funding could be justified for both large and 
small populations based on need. One expert favored a bifurcated focus 
with one effort seeking to ensure minimal levels of security for all 
utilities, and another expert favored more intensive efforts focusing 
on systems serving larger populations.

Utilities Serving Entities That Have Symbolic Value: 

Only one expert gave a highest priority rating to utilities serving 
buildings, monuments, parks, tourist attractions, or other entities 
that have symbolic value. An additional 10 experts rated these 
utilities as warranting a high priority. One expert commented that 
terrorists have already shown that they want to cause serious economic 
damage by disrupting tourism. Another noted that terrorists have also 
targeted cities that have stadiums, convention centers, and other 
attractions where large numbers of people gather.

 

Funding Mechanisms Recommended for Distributing Federal Funds: 

When we asked the experts to identify how best to distribute federal 
funds that may be made available to utilities to address wastewater 
security, they overwhelmingly indicated that direct federal grants to 
utilities would be the most effective mechanism. The experts also 
indicated that grants in which some type of match is required of 
recipients would be effective. Relatively fewer experts indicated that 
the use of trust funds or the Clean Water State Revolving Fund, 
particularly for upgrades to be implemented in the short term, would be 
effective. Other mechanisms that were rated as less effective included 
loans, or loan guarantees, and tax incentives for private utilities. 
Figure 14 shows how experts rated six different mechanisms for funding 
wastewater security.

Figure 14: Experts' Views on Mechanisms for Funding Wastewater 
Security: 

[See PDF for image]

[End of figure]

Direct Federal Grants: 

Thirty-four of the 50 experts indicated that direct federal grants to 
the utility would be very effective in allocating federal funds. An 
additional 12 said these mechanisms would be somewhat effective in 
doing so.

Experts expressed a variety of views regarding how best to implement 
these grants. For example, some cautioned that a grant program for 
wastewater security should be solely dedicated to the protection of the 
wastewater infrastructure, rather than being consolidated together with 
other programs, such as grants for enhancing homeland security. One 
said that, contrary to the way grant programs usually operate, 
utilities should be allowed to apply for grants during project 
implementation or even after the project is completed. This could 
reward those who were proactively addressing their security needs. 
Among other suggestions, one expert said that EPA and the Department of 
Homeland Security (DHS) should collaborate on allocating these grant 
funds. This expert stated that "EPA has technical knowledge about 
facility operations that is especially important and DHS has grant 
funds for homeland security that could be quickly made available until 
Congress approves a special allocation." Some experts also commented 
that direct grants are preferable because they are more likely to 
result quickly in safety improvements and other desired changes.

Experts also offered opinions on situations in which it would be 
appropriate to offer a grant without requiring a matching contribution 
from the recipient. Many, for example, favored direct grants with no 
match for activities that benefit multiple utilities, or which should 
be addressed in the near term. Such actions would include conducting 
research and development to improve detection, developing voluntary 
wastewater security standards and guidance, completing vulnerability 
assessments, and providing training to utility security personnel on 
how best to conduct vulnerability assessments and improve the security 
culture.

Grants with Matching Requirement (Cost-Shared Grants): 

Thirty of the 50 experts indicated that grants with a matching 
requirement (cost-shared grants) would be very effective as a mechanism 
for providing funds to wastewater utilities. An additional 16 rated 
such grants as somewhat effective.

Experts generally favored cost-shared grants for activities that 
benefit individual utilities. For example, 38 of the 50 experts 
indicated that cost-shared grants were best for strengthening operation 
and personnel procedures, such as securing sewer maps and conducting 
background checks on new employees. Almost three-quarters of the 
experts (36 of 50) indicated that cost-shared grants were also best for 
installing early warning systems in collection systems to monitor for 
or detect sabotage. Similarly, 32 of the 50 experts indicated that 
recommended cost-shared grants would be best for improving cyber 
security and for activities required to harden physical assets, such as 
building fences, installing locks, and securing manhole covers.

Clean Water State Revolving Fund: 

The Clean Water State Revolving Fund (CWSRF) is an EPA-administered 
program that provides grants to the states to allow them to assist 
publicly owned wastewater utilities. States, in turn, use the funds to 
provide loans to participating wastewater utilities to assist them in 
making infrastructure improvements needed to protect public health and 
ensure compliance with the Clean Water Act. Five experts indicated that 
the CWSRF would be a very effective funding mechanism to improve 
wastewater security. An additional 35 indicated that it would be 
somewhat effective.

According to an EPA Fact Sheet, states may use the CWSRF to assist 
utilities in completing a variety of security-related actions, such as 
vulnerability assessments, contingency plans, and emergency response 
plans. In addition, the EPA Fact Sheet identifies other infrastructure 
improvements that may be eligible for CWSRF funds, such as the 
conversion from gaseous chemicals to alternative treatment processes, 
installation of fencing or security cameras, securing large sanitary 
sewers and installing tamper-proof manholes.[Footnote 7] Some experts 
said that the advantage of the CWSRF is its ability to leverage 
appropriated federal funds, thereby enabling it to assist more 
facilities than direct federal grants.

A number of experts, however, expressed caution about relying heavily 
on the CWSRF to support security enhancements. Several questioned 
whether the CWSRF was appropriate in an environment where quick, 
emergency-related decisions were needed, noting that the administrative 
process in applying for and receiving the funds can be lengthy. Another 
noted that the CWSRF "was not originally established to deal with 
security-related projects," and that the program therefore "either 
needs to [be] fixed to deal with security issues or a separate program 
needs to be created specifically for security projects." Another expert 
noted that unless additional security-related monies were added to 
existing CWSRF levels, it would divert much needed funding away from 
the kind of critical infrastructure investments that have been the 
CWSRF's primary purpose.

Loans or Loan Guarantees: 

Loans are a disbursement of funds by the government to a nonfederal 
borrower under a contract that requires the repayment of such funds 
with or without interest. Loan guarantees represent a nonfederal loan 
to which a federal guarantee is attached.[Footnote 8] Only one expert 
indicated that loans and loan guarantees would be very effective 
mechanisms for providing federal support for wastewater security. An 
additional 34, however, indicated they would be somewhat effective. 
Generally, these experts cited the primary advantage of loans or loan 
guarantees as offering communities the option to amortize security- 
related costs over an extended period of time, while minimizing the 
overall cost to the federal treasury. Another expert commented that a 
low interest loan could provide some incentive and needed capital to 
implement security programs.

A number of experts, however, expressed reservations. One cautioned 
that the establishment of any federal loan program to support 
wastewater security needs should not come at the expense of federal 
support for the CWSRF, given the critical infrastructure needs that 
already depend on it for support. Another questioned the value of loans 
to utilities already strapped for funds, noting that "while loans have 
less impact on the federal government, many wastewater utilities and 
local governments generally carry a heavy debt load for capital 
improvements, and they cannot add significant additional debt that 
could affect their bond ratings."

Trust Funds: 

Federal trust funds are accounting mechanisms used to link receipts 
(from particular taxes or other sources) that by law have been 
dedicated for a specific purpose or program, such as for infrastructure 
improvement. For example, such a mechanism is in place for the 
transportation sector through the Highway Trust Fund. Eight experts 
indicated that trust funds would be a very effective mechanism for 
distributing funds for the wastewater security sector. An additional 7 
said they would be somewhat effective. However, almost half of the 
experts (24 of 50) indicated that they either had no opinion on this 
subject or that trust funds were "neither effective nor ineffective."

Experts raised a number of issues as to how the trust fund concept 
would be implemented. A key consideration was whether the fund would be 
dedicated solely to wastewater security needs, or be part of a broader 
fund that serves other wastewater infrastructure needs.[Footnote 9] One 
expert suggested that, if wastewater security needs have to compete 
with the broader range of the wastewater industry's infrastructure 
needs, they may not receive sufficient priority to be funded 
adequately. Another expert suggested that a trust fund should be 
supported annually by the federal government and local wastewater 
utilities, and administered in a manner similar to the former 
Wastewater Construction Grants program that funded wastewater 
construction. This expert indicated that the fund should be used 
exclusively for enhancing wastewater security.

Tax-Based Incentives: 

Federal tax-based incentives may include new tax credits for spending 
on security improvements and the existing exemptions from federal 
income tax of interest income from state and local government bonds. 
One expert indicated that tax incentives are very effective, and an 
additional 14 said they are somewhat effective. Notably, 20 experts 
indicated that tax-based incentives would be very ineffective--a result 
due in part to the fact that most wastewater utilities are publicly 
owned and operated and would, therefore, not benefit from tax-based 
incentives, like tax credits that would be used to reduce federal 
income tax.

Nonetheless, some experts said that for the smaller proportion of 
privately owned systems, tax-based incentives could be beneficial and 
particularly efficient. One expert noted, for example, that "in those 
cases where the wastewater treatment facility is privately owned, 
nothing succeeds as well as tax incentives." Recognizing the diversity 
of wastewater systems, this expert stated further that the owners know 
their utility better than anyone and are best able to achieve results 
in a more cost effective way, if they are incentivized.

Conclusions: 

To date, the federal government's role in promoting wastewater security 
has been limited primarily to supporting various training activities on 
completing vulnerability assessments and emergency response plans and 
several research projects addressing how contaminants affect treatment 
systems and other areas. However, legislation supporting an expanded 
federal role, including a substantially greater financial commitment, 
has been proposed in the past and may be considered again in the future.

Should such funds be appropriated, key judgments about which recipients 
should get funding priority, and how those funds should be spent, will 
have to be made in the face of great uncertainty about the likely 
target of an attack (i.e., a large but well-protected facility versus a 
smaller but less-protected facility); the nature of an attack (cyber, 
chemical, biological, radiological); and its timing. The experts on our 
panel have taken these uncertainties into account in deriving their own 
judgments about these issues. These views, while not unanimous, suggest 
some degree of consensus on a number of key issues.

We recognize that such sensitive decisions ultimately must take into 
account a variety of political, equity, and other considerations. We 
believe they should also consider the judgments of the nation's most 
experienced individuals on these matters, such as those included on 
this panel. It is in this context that we offer these results as an 
input into the decision-making process that Congress and the 
administration will likely go through as they seek to determine how 
best to use limited financial resources to reduce the vulnerability to 
the nation's wastewater utilities.

[End of section]

Appendixes: 

Appendix I: Participating Experts on Wastewater Security Panel: 

Expert: Doug Abbott; 
Affiliation: Maryland Center for Environmental Training.

Expert: Mark Anderson; 
Affiliation: Virginia Department of Health.

Expert: Carol Andress; 
Affiliation: Environmental Defense.

Expert: Clifford Arnett; 
Affiliation: Columbus Water Works.

Expert: Curt Baranowski; 
Affiliation: U.S. Environmental Protection Agency.

Expert: Jeanette Brown; 
Affiliation: Stamford Water Pollution Control Authority/American 
Academy of Environmental Engineers.

Expert: Leonard Casson; 
Affiliation: University of Pittsburgh.

Expert: William Conlon; 
Affiliation: Parsons Brinckerhoff Quade & Douglas, Inc.

Expert: Joseph Cotruvo; 
Affiliation: Joseph Cotruvo & Associates, LLC.

Expert: James Covel; 
Affiliation: Upper Occoquan Sewage Authority.

Expert: Paula Dannenfeldt; 
Affiliation: Association of Metropolitan Sewerage Agencies.

Expert: Shuki Einstein; 
Affiliation: IDC Architects.

Expert: Richard Fox; 
Affiliation: Camp Dresser & McKee, Inc.

Expert: Suzanne Goss; 
Affiliation: JEA Electric, Water & Sewer.

Expert: Neil Grigg; 
Affiliation: Colorado State University.

Expert: Michael Gritzuk; 
Affiliation: City of Phoenix, Water Services Department.

Expert: Charles Haas; 
Affiliation: Drexel University.

Expert: Gail Hackney; 
Affiliation: Pima Community College.

Expert: Rick Hahn; 
Affiliation: R. Hahn & Company, Inc.

Expert: Alan Hais; 
Affiliation: U.S. Environmental Protection Agency.

Expert: Miriam Heller; 
Affiliation: National Science Foundation.

Expert: Richard Holstein; 
Affiliation: Tetra Tech, Inc.

Expert: John Hoornbeek; 
Affiliation: National Environmental Training Center for Small 
Communities.

Expert: Alan Ispass; 
Affiliation: CH2M Hill.

Expert: David Jenkins; 
Affiliation: University of California, Berkeley.

Expert: Patrick Karney; 
Affiliation: CH2M Hill (formerly with Metropolitan Sewer District of 
Greater Cincinnati).

Expert: Bruce Larson; 
Affiliation: American Water.

Expert: Cecil Lue-Hing; 
Affiliation: Cecil Lue-Hing & Associates, Inc.

Expert: Michael Luers; 
Affiliation: Snyderville Basin Water Reclamation District.

Expert: Michael Marcotte; 
Affiliation: City of Houston, Department of Public Works and 
Engineering (formerly with District of Columbia Water and Sewer 
Authority).

Expert: John Masek; 
Affiliation: ABS Consulting.

Expert: Paul Orum; 
Affiliation: Working Group on Community Right-to- Know.

Expert: Rebecca Parkin; 
Affiliation: George Washington University Medical Center.

Expert: Jay Pimpare; 
Affiliation: U.S. Environmental Protection Agency.

Expert: Roy Ramani; 
Affiliation: Water Environment Research Foundation.

Expert: Daniel Rees; 
Affiliation: Scientech, LLC.

Expert: Joan Rose; 
Affiliation: Michigan State University.

Expert: H.J. "Bud" Schardein; 
Affiliation: Louisville/Jefferson County Metropolitan Sewer District.

Expert: Tom Segars; 
Affiliation: Miami-Dade Water and Sewer Department.

Expert: Jim Sullivan; 
Affiliation: Water Environment Federation.

Expert: Richard Sustich; 
Affiliation: University of Illinois at Urbana- Champaign (formerly with 
Metropolitan Water Reclamation District of Greater Chicago).

Expert: James Thomson; 
Affiliation: Jason Consultants International.

Expert: Mike Traubert; 
Affiliation: Arizona Department of Environmental Quality.

Expert: William Wallace; 
Affiliation: Rensselaer Polytechnic Institute.

Expert: Mike Wallis; 
Affiliation: East Bay Municipal Utility District.

Expert: Chuck Weber; 
Affiliation: Prince William County Service Authority.

Expert: David Weinberg; 
Affiliation: U.S. Department of Homeland Security.

Expert: Gary Westerhoff; 
Affiliation: Malcolm Pirnie, Inc.

Expert: Gary Yoshida; 
Affiliation: Sanitation Districts of Los Angeles County.

Expert: Rae Zimmerman; 
Affiliation: New York University.

[End of table]

Source: GAO.

[End of section]

Appendix II: Questions and Responses to the Final Questionnaire for the 
Expert Panel: 

The body of this report generally identifies which options received the 
most favorable responses from the expert panel as to how federal funds 
can best be spent to improve wastewater security (i.e., which 
activities were viewed as warranting "highest" or "high" funding 
priority). The table below provides the full range of responses (e.g., 
"highest priority" to "lowest priority") by the experts to these 
questions. The tables also indicate the number of experts in each case 
that responded with "no opinion" or "no response."

[See PDF for image]

[End of survey questionnaire]

[End of section]

Appendix III: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

John B. Stephenson, (202) 512-3841; 
Steve Elstein, (202) 512-6515: 

Staff Acknowledgments: 

In addition to the individuals named above, important contributions 
were made by Ulana Bihun, Christopher R. Durbin, Lynn Musser, and Diane 
B. Raynes. Katherine M. Raheb and Carol Herrnstadt Shulman also made 
key contributions.

(360396): 

FOOTNOTES

[1] EPA Wastewater Technology Fact Sheet, Chlorine Disinfection, EPA 
832-F-99-062, September 1999.

[2] Disinfection Technologies for Potable Water and Wastewater 
Treatment: Alternatives to Chlorine Gas, Pacific Northwest National 
Laboratory, July 1998.

[3] The Public Health Security and Bioterrorism Preparedness and 
Response Act of 2002 (the Bioterrorism Act of 2002), Pub. L. No. 107- 
188, required drinking water systems serving more than 3,300 people to 
complete vulnerability assessments by June 2004. According to EPA 
officials, many combined systems--those providing both drinking and 
wastewater services--have voluntarily completed vulnerability 
assessments for both. The act further required those systems to prepare 
or revise an emergency response plan incorporating the results of the 
vulnerability assessment within 6 months after completing the 
assessment. 

[4] EPA's requirements for "worst-case" release analysis tend to result 
in consequence estimates that are significantly higher than what is 
likely to actually occur. For example, "worst case" release analysis 
does not take into account active mitigation measures facilities often 
employ to reduce the consequences of releases.

[5] Department of Energy. 21 Steps to Improve Cyber Security of SCADA 
Networks. http://www.eq.doe.gov/pdfs/21stepbooklet.pdf (Downloaded July 
1, 2004).

[6] http://c3.org/chlorine-issues/disinfection/water-disinfection.html

[7] Environmental Protection Agency, Fact Sheet, "Use of the Clean 
Water State Revolving Fund to Implement Security Measures at Publicly- 
owned Wastewater Treatment Works," (Washington, D.C., 2003).

[8] "A Glossary of Terms Used in the Federal Budget Process," 
(Washington, D.C., 1993) 40, 50.

[9] The Water Infrastructure Network, a coalition of groups 
representing the interests of the water and wastewater industry, has 
advocated the establishment of a trust fund to support a broad range of 
water and wastewater infrastructure needs. Some experts on our panel 
suggested that should this type of mechanism be established, it should 
be structured in a way that supports the industry's security needs. 

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