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Chapter 3
Review of Identified Water Security Research Needs
In keeping with the format used within the EPA Action Plan, this chapter discusses
research issues and needs separately for drinking water and wastewater. The drinking
water research needs within the Action Plan are lengthy, detailed, and if met would go a
long way toward providing the overall response guidance mentioned in Chapter 2 as
necessary to help water managers respond appropriately to threats or attacks on water
supply systems. Considerably less information is presented in the Action Plan regarding
threats to the nation's wastewater infrastructure, making it difficult to assess the
adequacy of the proposed research. The significantly greater text and research focused
on drinking water within the Action Plan is likely a reflection of the report's authors'
expertise as well as the perception of drinking water supply systems as more vulnerable
targets of a potential terrorist attack with more direct human health consequences in
comparison to wastewater treatment plants.
DRINKING WATER
The research ant} technical support needs for preventing, preparing for, and
responding to physical, cyber, and contaminant attacks on drinking water supply systems
are categorized in the Action Plan under six major headings: (1) protecting physical and
cyber infrastructure, (2) identifying drinking water contaminants, (3) improving
analytical methodologies and monitoring systems for drinking water, (4) containing,
treating, decontaminating, and disposing of contaminated water and materials, (5)
planning for contingencies and addressing infrastructure interdependencies, and (6)
targeting impacts on human health and informing the public about risks. A detailed
evaluation for the individual research needs identified in the Action Plan is presented
below, which identifies notable gaps and redundancies and suggests changes in emphasis.
The application of the needs to small versus large utilities is also discussed.
25
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A Review of the EPA Water Security~4ction Plan
Protecting Physical and Cyber Infrastructure (Action Plan Section 3.1)
Drinking water utilities (supply works, treatment plants and distribution systems)
consist of physical assets, human assets, and cyber assets. The physical assets include
piping, valving, reservoirs, pumps, and treatment works; human assets include operators
and management personnel; cyber assets include software and hardware devoted to
process control, operation of remote facilities, and accounting. The security of water
utilities depends upon mitigating threats to these assets.
The EPA Action Plan delineates this work into three categories of research and
technical support needs:
a) An updated identification and prioritization of physical threats to drinking
water infrastructure, including an improved understanding of the
vulnerability of water systems to cyber threats and improved means to assess
these vuinerabilities.
b) A thorough understanding and documentation of the consequences of
physical or cyber attacks on the drinking water infrastructure, including the
evaluation and testing of computational models and decision science.
c) A suite of countermeasures to prevent or mitigate the effects of physical and
cyber attacks on water infrastructure, including improved design of water
systems to reduce vulnerabilities in the long term.
Commentary on Identified :Needs
3.1.a Identification and Prioritization of Physical Threats. Identifying and
prioritizing physical and cyber threats to water infrastructure represents an important first
step before countermeasures can be developed. There is a substantial base of experience
on physical threat identification that has been gained from the vulnerability assessments
completed by larger utilities and those in progress by smaller utilities. Under American
Water Works Association Research Foundation (AwwaRF) project 2909, there is to be a
focus on review, prioritization, and lessons learned from these activities. Furthermore,
there has been considerable effort spent at other facilities, such as in the chemical and
power industries, on protection from physical and cyber threats. Need 3. pa should strive
to incorporate knowledge gained from these efforts rather than on re-inventing such
knowledge.
Another type of threat that may be worth considering is the dissemination of
malicious disinformation (e.g., on the safety or reliability of a given system) via external
web sites and other electronic means. Such actions have the potential for producing long-
lasting impacts on the reputation of water suppliers, with potential consequences of
having concerned users ultimately switching to less adequate alternate supplies.
In the assessment of resources to protect, source water catchment structures and areas
(reservoirs, watersheds, artificial impoundments) and raw water conveyance structures
(aqueducts, underground flow paths) should be given consideration. Other points where
vulnerability may occur could include remote monitoring stations, points of chemical
addition (e.g., dechlorination or fluoridation), and remote wellheads, especially those with
associated disinfection facilities.
3.1.b Understanding and Documentation of the Consequences of Physical or
Cyber Attacks. The vulnerability assessment efforts noted in the previous section have
also resulted in the preparation of consequence analyses as part of the mandated filing.
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Review of Research Needs
27
To the degree possible, the EPA should take advantage of the efforts of AwwaRF project
2909 and similar reviews to help it in its understanding of consequences of physical or
cyber attacks. In addition, the EPA should take advantage of prior threat, vulnerability,
and consequence assessments in understanding potential impacts on water systems from
cyber and physical threats. For example, lessons can be learned from the efforts taken for
assessing cyber vulnerability in preparation for the year 2000 (Y2K) and from homeland
security analyses of Supervisory Control and Data Acquisition (SCADA) system
vuInerabilities and consequences for water and other utilities.
3.1.c Countermeasures to Prevent or Mitigate the Effects of Physical and Cyber
Attacks. Research to reduce vuInerabilities in water systems to physical and cyber
attacks is a third important need. In preventing or mitigating the effects of attacks to
cyber systems, a key component is understanding the vulnerability of and consequences
from malfunctioning or sabotaged SCADA systems. This understanding could be
facilitated by interaction with control and software vendors and with users in other
industries. The importance of this might be underscored by rewording item 3. l.c to read
"...including improved design of SCADA and water systems ...." Specific attention
should be placed on addressing internal threats (e.g., the disgruntled employee) and
making use of existing SCADA system attack countermeasures that have been developed
for other analogous institutions.
Additional Research and Technical Support Needs
In the development and assessment of countermeasures, it is important to identify
both the costs and the benefits, from more obvious examples such as the benefit of risk
reduction to ancillary or spin-off benefits. For example, the installation of secure Internet
sites for a utility (implemented perhaps for secure process monitoring purposes) might
also serve as a platform for implementation of either business-to-business or consumer e-
commerce, and thereby permit an additional revenue stream (or reduction in costs of
activities previously conducted non-electronically) to be realized. The suite of
countermeasures that might be developed should be described by a tiered arrangement to
permit selection as appropriate in a given locale (small versus large utilities, different
geographic environments, etch.
The identification of a suite of countermeasures is useful only to the degree that
necessary measures can be implemented and can be paid for. A major priority should be
in communicating the need for security measures with the consumer and in promoting
willingness to pay for implementation of necessary countermeasures. Hence, the
following additional need is suggested:
Assessments of costs and benefits (direct and indirect) associated with various
countermeasures; and development of programs to assist implementing organizations
(including water utilities) in communicating with the public, customers, rate
regulators, and local elected and appointed officials regarding the value of water,
increased water system security, and increased rate structures to create the necessary
financial resources to implement such countermeasures.
Application to Large versus Small Systems
An important difference for the Action Plan to consider is that small water systems
(those serving less that 3,300 people) will not be required to conduct vulnerability
assessments. This means that the EPA will have less information about the types of
threats to which small systems may be subjected. This should be considered in
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A Review of the EPA Water Security Action Plan
addressing the first need and in devising appropriate and cost-effective countermeasures
to reduce the vulnerabilities of small systems. Second, when recommendations are made
regarcling consequences or countermeasures for protecting SCADA systems, the EPA
shouts! consider the differences between the largest ant} more sophisticated systems and
the vast majority of the systems which are quite small anct may have limited or no
SCADA systems and limited resources with which to secure the systems they do have.
The Action Plan should focus on coming up with relatively simple-to-implement best
practices (such as separating SCADA networks from data networks and installing
firewalls) that can work across the broad range of water system types, rather than on the
highly technical detail that would be needed for the more extensive and complicated
systems.
Recommendations
In conclusion, the pane! recommends the following rewritten needles:
· An updated icientification and prioritization of physical threats to and
vuinerabilities of drinking water infrastructure, taking into account the substantial
information gained from the vulnerability assessments of the nation s larger water
systems and on other vulnerability and consequence assessments of water
systems and their cyber infrastructure, along with improved means to assess these
vuInerabilities.
.
.
.
A thorough understanding and documentation of the consequences of physical or
cyber attacks on the drinking water supply sources and infrastructure, including
the evaluation and testing of computational models and decision science.
A suite of countermeasures to prevent, or mitigate, the effects of physical ant!
cyber attacks on water infrastructure, including improved design of SCADA and
water systems to reduce vuinerabilities.
Assessments of costs and benefits (direct and indirect) associated with various
countermeasures; and development of programs to assist implementing
organizations (including water utilities) in communicating with the public,
customers, rate regulators, and local elected and appointed officials regarding the
value of water, increased water system security, and increased rate structures to
create the necessary financial resources to implement such countermeasures.
Contaminant Identification (Action Plan Section 3.2)
As the scope of available pathogens and hazardous chemicals expands so should our
assessment of the threats and consequences they pose to water security. Identification of
the contaminants ot concern IS an initial step in protecting the nation s water supplies.
Knowledge of critical contaminant properties, such as toxicity, environmental fate, and
methods for mitigation, will be needed to respond effectively to threats on our water
supplies.
The EPA Action Plan delineates this work into four categories of research and
technical support needs:
a) A manageable, prioritized list of both contaminants and threat scenarios that
might be used to destroy, disrupt, or disable drinking water supplies and
systems.
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Review of Research Needs
b) A contaminant database for consultation by approved individuals and
organizations that describes critically important information on contaminants
with the potential to harm drinking water supplies and systems.
c) A surrogate/simulant database for use in testing and evaluating methods,
approaches, and technologies to more effectively protect drinking water
supplies and systems.
d) Methods and means to securely maintain and, when appropriate, transmit
information on contaminants and threat scenarios applicable to drinking
water supplies and systems.
This is a logical and comprehensive breakdown ofthe needs. There are no obvious gaps.
29
Commentary on Identified Needs
3.2.a Development of a List of Contaminants and Threat Scenarios. The
development of a list of contaminants, both chemical and biological, is an important early
step that will ultimately serve to guide the development of analytical techniques and
treatment technologies. However, the pane! struggled with the scope of this need. The
word "manageable," which was not defined in the Action Plan, raised concerns that
potentially relevant contaminants might be overlooked. Yet, developing a single list of
all possible contaminants could be an endless task, as the list would always be incomplete
and would require extensive time and effort to develop and continuously update.
One approach proposed would be to develop a list that would include only those
contaminants of potential concern to water security based on a well-defined set of
criteria, such as human toxicity, current and future availability, and solubility in water,
among others. The EPA should work to develop this set of criteria. To expedite the
formation of the water security contaminant list, existing lists (e.g., from the CDC or the
EPA Office of Pollution Prevention & Toxics) could be re-visited with these criteria in
mind. In addition, a mechanism needs to be built into this process ensuring that the list is
regularly updated as new information becomes available. Considering that the compiled
list of contaminants will guide water security activities, this list should be as complete as
is practicable.
The Action Plan suggests that the list of contaminants should be prioritized. In order
for this to occur, the list should also contain associated information regarding a
contaminant's potential for being a threat (e.g., the well-ciefined set of criteria described
above). This is the kind of information anticipated to be included in the database
mentioned below (3.2.b); thus, there is significant overlap between these two needs (3.2.a
and 3.2.b). Prioritization is a subjective process that will depend on the weighting of
various criteria and on currently available data about a contaminant (see NRC, 1999 for a
more thorough treatment of contaminant prioritization). The types of information
expected to be useful in prioritizing contaminants include, for example, an assessment of
the contaminant's threat consequence, its current level of availability, or its resistance to
residual chlorine. This information and any prioritization scheme would need to be
transparent to the users of the list. The database format allows for alternate groupings or
prioritization schemes based on the specific needs of treatment engineers, toxicologists,
microbiologists, physical scientists, emergency response providers, etc.
An assessment of contaminant threat scenarios is necessary to improving water
security because the means of introducing a contaminant into the water system can
significantly affect the consequences of an attack. As more is learned about modes of
attack, and as new modes of attack become available due to changes in technology,
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A Review of the EPA Water Security Action Plan
policy, or practice, the threat scenarios will change. Given the description of two
separate research projects in the Action Plan (p. 21), it appears that the authors intended
for there to be both a list of water security contaminants en cl a list of threat scenarios.
Although the lists are related, this approach is advisable as threat scenarios identified may
highlight appropriate and necessary countermeasures that could be implemented, which
would not be specific to any particular contaminant (e.g., backflow restriction devices).
Also, this approach would prevent the consideration of current threat scenarios from
constraining the list of water security contaminants. This sentiment should be expressed
more clearly by explicitly separating the delineation of threat scenarios from the need for
creating a list of contaminants.
3.2.b Development of a Database on the Critical Contaminants. As the list of
contaminants is assembled, the most relevant physical, chemical, biological, and
toxicological data should be included in a supplementary database. The nature of the
data to be included in this database should be established based on perceived needs from
potential end users, which would include emergency response personnel, public health
department personnel, toxicologists, planners, treatment engineers/scientists, etc. Based
on the anticipated uses of the supplementary database, the relevant contaminant
properties should be identified. This task of identifying appropriate categories of
information to be contained in this database would likely be the first project for such an
activity. It should be noted that some of the parameters needed for the database will be
contaminant specific. For example, a parameter critical for understanding viruses in
water supply systems may have no bearing on the behavior of other pathogens.
Filling in every gap within the database of critical contaminants and relevant
parameters may not be necessary or worthwhile. Rather, research should be initiated to
fill the most important gaps in the contaminant properties lists. This might include
combing the literature for contaminant-specific information, and it should also embrace
theoretical, semi-empirical, and expert judgment as needed. One way to organize the
research and data gathering needs associated with the database is to determine early on
which contaminant properties are most useful for particular classes of contaminants. In
many cases, estimates or educated guesses might be used in place of well-established
contaminant-specific data in order to address near-term risk management needs, although
the sources and the reliability of the data should be noted.
3.2.c Development of a Surrogate/Simulant Database. Simulants or surrogates
are intended to be similar in some specific way to individual contaminants or a group of
target contaminants, but they are less toxic and therefore less hazardous to work with
than the contaminants of concern. The nature of the similarity between target and
simulant would necessarily depend on the type of investigation for which it will be user!
(e.g., size and charge would be key parameters if removal by membrane filtration is the
focus). An ideal simulant would be non-toxic and easily measured using an analytical
method applicable to the contaminant of concern, but this may not be possible in many
cases. Studies on treatment, decontamination, transport, and environmental fate of
contaminants could benefit from a few well-selected simulant compouncts or
microorganisms. Developing a complete and comprehensive database of surrogates ant!
simulants would not likely be a wise use of resources. One of the end products of this
work would be a set of guidelines or an operational handbook describing how surrogates
or simulants should be used. Consideration should be given to selection of the simulant,
handling, analysis, and data interpretation.
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Review of Research Needs
31
3.2.d Means for Maintaining and Transmitting Information on the Above.
Once compiled, the information that is the subject of research needs 3.2.a through 3.2.c
should be continually updated and made available to those for whom it was intended. As
discussed in detail in Chapter 2, information security will play an important role in
carrying out the Action Plan. A plan for providing essential information to response
agencies, while restricting access to classified information should also be developed.
Application to Large versus Small Systems
The identification of contaminant lists and compilation of data are centralized
activities that do not have any specific bearing on utility size. However, the nature and
relative importance of certain threat scenarios may be highly dependent on utility size.
Data handling and transfer may also be different for large utilities versus small ones.
Recommendations
In conclusion, the panel recommends the following rewritten needs:
A list of contaminants that might be used to destroy, disrupt, or disable drinking
water supplies and systems. This list would be linked to relevant associated
contaminant information (stored in the database mentioned below), which could
be used to prioritize or group the individual contaminants, as users of the list
deem appropriate.
· An assessment of threat scenarios which could result in harmful exposure of the
public or utility personnel to drinking water contaminants.
A contaminant database for consultation by approved individuals and
organizations that describes critically important information on contaminants
with the potential to harm drinking water supplies and systems.
Identification of a few well-selected surrogates or simulants for use in testing and
evaluating fate and transport characteristics and treatment technologies for
priority contaminants.
Methods and means to securely maintain and, when appropriate, transmit
information on contaminants and threat scenarios applicable to drinking water
supplies anti systems.
Contaminant Monitoring and Analysis (Action Plan Section 3.3)
needs:
Reliable detection of contaminants is essential to protecting consumers against
chemical and biological attacks on water supplies. As the scope of available pathogens
and toxic chemicals expands, so must our abilities expand to detect their presence. Early
detection of an intrusion will be one defense against widespread exposure. Aside from
the more obvious need to define the extent of contamination, advise the public of the
contamination, and, if necessary, take actions to avoid exposure, detection methods and
associated protocols are needed for purposes of assessing performance of treatment and
decontamination efforts.
The EPA Action Plan delineates this work into seven research and technical support
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A Review of the EPA Water Security Action Plan
a) A "play book" for analytical response to contaminant threats and attacks on
water supplies and systems, including protocols for identifying "unknown"
contaminants.
b) Improved analytical hardware and analysis methodologies for biological,
chemical, and radiological contaminants in water.
c) Requirements for monitoring technologies used in responding to biological,
chemical, and radiological contamination events.
d) Testing and evaluation of monitoring technologies, including standard
operating procedures, for biological, chemical, and radiological contaminants
and threats.
Testing and evaluation of drinking water "Early Warning Systems" (EWSs),
and EWSs from other sectors amenable to application in the water
environment.
An improved and expanded laboratory capacity and capability (as necessary)
to be fully prepared in responding to threats or attacks on water.
g) Training modules and evaluation exercises for analytical methodologies and
monitoring systems.
This set of needs is quite comprehensive. vet depending on interpretations there maY
be some important gaps. There may also be some reasons for combining portions of
these.
-7 ~ -- -or- = -- ------or- --7 ------ ---he
~ ~ . . . ~
Commentary on Identifie dNeeds
3.3.a "Play Book" for Analytical Response. The analytical "play book" includes
decision trees as well as analytical methodologies and end points and is therefore much
more than a toolbox. An ideal play book for analytical response would combine tools
(e.g., formal analytical methods and early warning system detection methods) and
provide clear direction to those trying to identify or clarify a known or perceived threat.
This play book would also include protocols for sampling and identifying unknown
contaminants. The play book would also consider special sampling needs and the
analytical environment. Early investigations at sites where high toxicity levels are
deemed possible might require the use of small mobile "Hazmat"-type labs. Once the
nature of the contamination is better understood, subsequent analysis would likely take
place in state or federal laboratories.
The analytical play book should serve as one component of a larger integrated
response guidance, which needs to be created to enable other appropriate parallel actions
(e.g., communication, remediation, risk assessment, emergency response). Other
components of this response guidance are discussed in sections 3.4.a' and 3.6.a'. The
integrated prevention and response plan should invoke appropriate action from within the
analytical play book when a disease outbreak of unknown origin is detected. In other
words, the play book should include protocols for water quality sampling to determine
whether drinking water is a potential vector of a disease outbreak.
3.3.b Improved Hardware and Analysis Methodologies. The need for new
methods and analytical hardware is obvious when one considers that even the most
abbreviated of contaminant lists is r-r~ _h_____~l_ --
microorganisms for which there are no properly validated methods. In some cases there
may never have even been an attempt to detect the contaminant in a water matrix. The
nonulated with numerous chem~ca Is or
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Review of Research Needs
33
problem of analyzing for a contaminant threat of unknown origin is so challenging that
general screening methods may have to be developed and user! in lieu of or in addition to
the traditional well-validated specific method.
3.3.c Requirements for Monitoring Technologies. This sub-category is not clearly
described in the EPA document, and the project list does not seem to logically follow
from the preceding text. This confusion limited a thorough review of this neecl.
Nevertheless, the development of quality assurance methods and other analytical features
within need 3.3.c is a logical extension of need 3.3.b. New analytical methodologies will
need to be accompanied by adequate protocols for sampling, analytical performance, and
quality assurance, as described in the Action Plan. The document also highlights
considerations that should be given to safety, sample transport, and integration with other
activities issues which may also be addressed by the analytical play book.
There are some rather unique quality assurance and quality control (QA/QC),
sampling, and detection issues that characterize this sub-category that were overlooked in
the discussion of this need in the Action Plan. Analytical quality assurance probably
takes on greater importance when considering contaminants that can cause widespread
illness and/or panic. For this reason, standard QA/QC procedures neec! to be carefully
examined in light of the high stakes involved. Rates of false positives and false negatives
should be clearly understood and results should be interpreted accordingly.
Research should also explicitly address some aspects of sampling protocols and some
of the unique challenges faced when monitoring treatment efficiency. Sampling may be
especially problematic for hazardous contaminants because of concerns over the health of
the technician and possible spreading of the contaminant by opening closed systems (e.g.,
unwanted exposure from opening hydrants). Protocols need to be developed to match the
level of care during sampling with the likelihood of risk.
Sampling guidelines are needed that address issues of spatial and temporal sampling
requirements for particular types of events. Toxic contaminants may be relatively
insoluble or in a particulate or micellized form. Any of these can lead to non-
homogeneous distributions of contaminants.
Elevated concentrations may exist at
interfaces (e.g., air:water, pipe:water) or imbedded in solid phases (e.g., biofilms, scale
formations, aquifer materials). Methods for sampling such heterogeneous systems need
to be considered. Refined sampling methodology may be needed for detecting pathogens
in complex field settings.
The Action Plan notes in section 3.4 that point-of-use/point-of-entry (POW/POE)
devices already in place may trap some contaminants, thereby serving as remote
sampling devices during a contamination event. The analyses of POW/POE devices
would be almost experimental in nature and produce only qualitative results because of
the many unknowns and uncontrolled variables (e.g., volume of flow during the event,
length of time in use, variability of the types of absorber, and competition with other
actsorbates from the water). In order to obtain valid historical water contamination data, a
proactive network of metered surveillance water sampling units with defined
characteristics, such as flow through units with activated carbon collectors or microbial
sampling devices, would be required. Such a surveillance network would be costly to
establish and would require a regular schedule of collection, replacement, and analysis.
The monitoring of treatment efficiency presents some other unique challenges. This
is especially problematic when residuals streams (e.g., backwash water, settled sludge)
need to be examined for assessing hazards or formulating mass balances. For example,
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HI Review of the EPA Water Security Action Plan
microbial contaminants may be especially difficult to detect against the high background
of particulate matter.
3.3.d Testing and Evaluation of Monitoring Technologies. Although very
important, this particular sub-category does not merit separate treatment within the
Action Plan. For the purposes of this discussion, monitoring is assumed to refer to
analysis of contaminants or surrogates in the field, possibly using flow-through devices.
Work on monitoring (and sensing) technologies is taking place in many different fields
for many different purposes. There have been startling advancements in the sensitivity
and selectivity of micro devices for field deployment. However, the distinction between
classical laboratory methods and field monitors may be an artificial one. In particular,
detection of chemical contaminants includes a spectrum of techniques, many of which
can be used with both laboratory and field methods. The two often employ identical
methodology and even similar hardware. There may be cases where field sampling
requires additional concentration techniques that would not be required in standard
laboratory protocols, and monitoring technologies will need to be thoroughly tested under
field conditions, but these issues can be addressed in the above needs. For this reason it
seems unnecessary to separate needs 3.3.b and 3.3.a7.
3.3.e Early Warning Systems. Early warning systems are valuable components in
the overall analytical effort. They may be the only means by which a utility is alerted to
potential problems, prior to widespread illness. In some cases, existing and commonly
used technologies may be employed as early warning systems. Examples include online
sensors for turbidity, UV absorbance, pressure, conductivity, and chlorine residual.
However, while the appropriate technology may be available, other factors such as signal
processing capabilities and sufficient baseline data may need additional attention. These
factors should be considered in the Action Plan.
The EPA may want to include the use of dedicated water sampling devices as part of
an overall water quality monitoring plan where the devices could function as a non-
specif~c early warning system. Other monitoring systems could also be considered, such
as a flow-through biomonitoring system using selected fish species (e.g., medaka, flat
head minnows, or trout) whose behavior and physical state could quickly reflect the
presence of a toxic material in the water. Maintaining such a system is complicated and
costly, requiring fixed facilities with technical staff and active management. In addition,
decision logic would need to be developed to determine the interpretation and follow-up
that would be needed in the event that a physiological reaction was noted in the fish.
There is also a spectrum of new technologies that are applicable to early warning
systems, some of which come from other fields of study. Some of these technologies are
compound specific, whereas others are used to measure bulk or surrogate parameters.
3.3.f Assessment of National Laboratory Capability. The ability of the nation's
analytical laboratories to respond to a toxic attack will depend on the nature and scope of
the attack. Most of the potential toxic chemical and biological agents are not routinely
measured by water testing laboratories. While methods and equipment may be developed
to measure these agents, there will be little incentive for commercial laboratories to
acquire these capabilities unless routine monitoring is needed. Nevertheless, the most
common emergency scenario is one of a sudden need for fast and reliable analysis of
non-standard analyses. Strategies need to be developed that will ensure the ready
availability of such analytical services. These strategies should include a tiered capability
analytical structure, matching the most sophisticated analytical needs to the laboratories
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Review of Research Needs
35
that are best equipped to handle them. Commercial laboratories will have to resolve
liability issues prior to taking a role in analytical response and will need analytical
methods that will minimize risks to workers. Liability issues may require that
government laboratories play a leading role in analytical readiness, or that commercial
labs be compensated in new and creative ways for providing analytical services for high
risk or likely threat contaminants.
Analytical readiness also requires that the nation's laboratories be able to effectively
respond to threats. Thus, capacity and need should be geographically well matched. It is
of little advantage if advanced laboratory capabilities exist in California, when an attack
occurs in Florida that requires rapid turn-around. Mobile analysis units might be
evaluated relative to regionally distributed laboratories for their ability to meet local
laboratory needs (in terms of timeliness, reliability, and capacity) following a terrorist
threat.
3.3.g Training. Training of personnel for routine monitoring as well as event
sampling and analysis of biological and chemical hazards in water should necessarily
follow the development of key analytical protocols anc! the analytical play book. The
EPA has appropriately recognized this by including the need for training modules and
evaluation exercises in the Action Plan. Adequate training of personnel from water
utilities and local and state agencies is essential to early detection and to effective water
terrorism response. To promote collaboration and effective response, public health
officials should also be involved in this training.
Application to Large versus Small Systems
In general, small utilities, whether they are community or non-community water
systems, will not have in-house capabilities to monitor or measure specific priority
contaminants. However, they may be able to monitor for some indicators that could
serve as early warning systems (e.g., monitoring chlorine residual). Other more
sophisticated early warning systems will probably be too expensive or complicated for
small systems to easily employ.
Once there is credible evidence for a toxic attack, the analytical play book would
probably require that state agencies become involved and that state personnel and
laboratory facilities would become available, such that utility size may not affect the path
taken. On the other hand, some of the early stages in the play book could be tailored to
utility size based on (differing analytical and diagnostic capabilities.
Recommendations
In conclusion, the panel recommends the following rewritten needs:
A "play book" for sampling and analytical response to contaminant threats and
attacks on water supplies and systems, including protocols for identifying
"unknown" contaminants, that will serve as a vita] component of an overall
integrated guidance plan.
Improved analytical hardware and associated field and laboratory analysis
methodologies (including generic simple techniques and laboratory-based, off-
line, and real-time monitoring technologies) for biological, chemical, and
radiological contaminants in water.
Requirements for appropriate QA/QC and sampling approaches in response to
suspected biological, chemical, and radiological contamination events.
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Recommendations
A Review of the EPA Water Security Action Plan
In conclusion, the pane! recommends the following rewritten needs:
.
.
Improved distribution system models that can be used to more effectively protect
drinking water in the event of deliberate contamination, which should consider
not only technical improvements to such models, but also operator training to
better use the models, the availability of information needed to run the models,
and the dual-use benefits of mode! development.
Improved understanding and documentation of the environmental fate of
contaminants in source waters, within drinking water systems, and once they are
released, focusing first on a literature review and then on either the identification
of generic physical and chemical parameters that are predictive of contaminant
behavior in water supply systems or on a small set of fate and transport
paradigms for common threat scenarios.
· Technologies and treatment processes to achieve multiple goals, and effective
disposal and/or treatment technologies for water and equipment that have been
contaminated, including in-place conventional technologies, new preventive
technologies, mobile technologies, and technologies that can mitigate
contaminant spread through the distribution system.
· A methodology, approach, or guide for use in determining when a drinking water
system is no longer contaminated and when it can be placed back into limited or
unlimited service. (This need is one component of the overall response guidance,
which is also expressed in Chapter 2 and sections 3.3.a and 3.6.d, and would be
best expressed in combination with those needs.)
Contingency Planning and Infrastructure Interdependencies
(Action Plan Section 3.5)
Water systems will need to develop contingency plans for providing a sufficient
quantity of adequate quality water to their service area in the event that deliberate
malfeasance (or "natural" hazards) causing service disruption occurs. Water systems,
particularly (but not only) larger ones, are increasingly relying on automation, and they
depend on the reliable functioning of other systems (e.g., electric, telecommunications).
Thus, contingency planning should consider the potential for disruption to occur not only
within a water supply system but also to one or more of these necessary auxiliary
systems.
The EPA Action Plan delineates this work into three categories of research and
technical support needs:
a) Assessment of water supply alternatives for different-sized drinking water
systems at different geographical locations in the United States when the
usual supply of water is not available.
· · . . ..
_ O
b) Testing and evaluation of improved technologies and approaches for
providing supplies of water in the event of both long-term and short-term
disruptions to drinking water systems.
An improved understanding of water system interdependencies with other
infrastructure sectors that are critical to national security.
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Commentary on Identified Needs
3.5.a Assessment of Water Supply Alternatives. The Action Plan stresses the
importance of contingency planning for a range of system types, but this research need
should be expanded to acknowledge that size and geographic location are not the only
factors that account for diversity in water systems. Other factors, which may influence
the nature of the required contingency plan or infrastructure interdependence, include:
· type of source water (e.g., lake, river, groun(lwater, etc.)
· existence of multiple sources of supply
· use of water purchased from a wholesaler
· interconnections with neighboring water systems
· system design (looped distribution, ability to blend supplies in distributions
treatment type)
· pressure source (predominantly gravity systems versus predominantly pumped
systems)
The degree to which contingency planning can and should rely on consumer
preparedness should be addressed. Is it realistic to rely on POU treatment or on
consumer stockpiling of potable water (for how long; with what degree of compliance
can be anticipated)? Such consumer preparedness can only be carried out with the
assistance of a well-developeci communication plan for response prior to and during an
emergency. This communication plan should be developed upfront and should be known
in advance by the potential recipients of information to minimize misinformation during
an incident.
It should be noted that other benefits could arise from planning for contingencies
resulting from terrorist actions or threats. These include improved preparedness for
natural hazards (e.g., earthquakes, floods, tornadoes) or accidents (e.g., crashes, chemical
tank failures). Indeed, the ancillary benefits that may arise from preparing for
contingencies from terrorist actions or threats may make the implementation of such
preparations more economically justifiable to ratepayers, regulators, and other
stakehol(iers.
3.5.b Testing and Evaluation of Improved Technologies and Approaches for
Providing Supplies of Water. Previous sections of this report (~3.3.c and 3.4.c) have
discussed POU devices and how they might be utilized both for sampling and treatment
purposes during a contamination event. That discussion is relevant here as well. In
addition, identification and enumeration of technologies for providing emergency potable
water supply would also be valuable, probably in the form of a database. To what
degree, for example, are military resources available to handle the task of water supply
during large-scale interruption? The appropriate alternative strategies for a given
location will be site-specific but should be enumerated in such a database.
3.5.c An Improved Understanding of Water System Interdependencies with
Other Infrastructure Sectors. This need should be expanded to include an
understanding of the reliability of systems upon which continued functioning of the water
system depends (e.g., electric power, road transportation, telecommunications), and an
assessment of the weakest links among the systems that are required for continued
functioning. For large utilities, a fault tree analysis for the most critical components or
processes might be conducted, and in this manner such dependencies could be detected.
It might be a more efficient use of resources to "harden" aspects of other infrastructure so
as to promote reliability of a particular water system component (e.g., electric power
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utility substation), rather than to harden an aspect of the water utility itself. It should be
noted that preparation for the Y2K changeover proved to be a valuable source of lessons
regarding interdependencies, and this knowledge should be captured in responding to the
challenge of terrorism.
A potential contingency response by utilities to system vulnerability is ~iisaggregation
or decentralization of supply and/or treatment systems. The Action Plan should consider
to what degree this is beneficial or undesirable from a preparedness viewpoint (e.g., is
there an optimum level of disaggregation or a maximum safe level of aggregations.
Additional Research and Technical Support NeedEs
Missing from this section is a discussion of a key element to successful operation of
most water systems the human factor. The Action Plan should consider under what
circumstances the operation of a water treatment plant (or supply system) could be
adversely impacted by the incapacitation ofthe operating personnel and whether there are
potential contingencies or mitigations for such occurrences. The Action Plan should also
consider potential back-up support that might exist for this failure pathway (e.g.,
importing personnel from neighboring utilities, or military and civilian emergency
response personnel). It should be noted that a failure of"human subsystems" that could
impact a water system could occur as a result of a direct attack via a non-water route, for
example via a massive community bioterrorism incident in which a substantial fraction of
operating personnel were affected.
Application to Large versus Small! Systems
Contingency planning is highly dependent upon the size, location, and type of water
supply system to be protected. In general, smaller systems may be less dependent upon
automated control technologies, and therefore less vulnerable to cyber threats. Small
systems may or may not be able to readily arrange for alternative sources of supply or
redundant connections from other necessary infrastructure systems (especially for small
systems in sparsely populated regions). These considerations indicate that the overall
response guidance needs to consider diverse strategies depending upon the threat
encountered as well as the nature of the system.
Recommendations
In conclusion, the pane! suggests the following rewording of the identified needs:
Assessment of water supply alternatives for different types of drinking water
systems in the United States (reflective of effects of size, type of supply, system
design, and type of distribution system), when the usual supply of water is not
available.
Testing and evaluation of improved technologies and approaches for providing
supplies of water in the event of both long-term and short-term disruptions to
drinking water systems. The evaluation of approaches should include customer
preparedness and should assess degree of reliability of the options.
· An improved understanding of water system interdependencies and the reliability
of such interdependencies with other infrastructure sectors that are critical to
national security.
· Explicit understanding of the role of failure of the "human subsystem" in water
system operation, and the development of contingencies for responding to such
eventualities.
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Targeting Impacts on Human Health and Informing the Public about Risks
(Action Plan Section 3.6)
43
Because human health protection is one of the ultimate endpoints of the EPA s water
security efforts, research into better understanding the human response to contamination
or threat scenarios is critical. This includes not only human physical response to different
classes of waterborne contaminants and ways to measure that response, but also the social
and psychological response to contamination events and how best to communicate
relevant threat information to all stakehoIclers.
The EPA Action Plan delineates this work into five categories of research and
technical support needs:
a) An improved understanding of contaminant exposure routes, and the acute
and chronic public health effects from contaminants in drinking water
supplies and systems.
b) A health surveillance network to help public health officials and water utility
operators rapidly identify and control a disease outbreak or other public
health emergency associated with contaminated drinking water.
c) A methodology or procedure for using non-traclitional data sources (e.g.,
LDso' Quantitative Structure Activity Relationship (QSAR]) for the
derivation of acute anile chronic toxicity values applied to water.
d) A risk management/risk assessment framework for identifying the impact of
decontamination/treatment options and the subsequent risk assessment
response.
Methods and means to communicate risks to local communities with respect
to threats and to respond to customers and the media in the case of an attack
on drinking water systems.
Commentary on Iclentifiec!Neecits
3.6.a An Improved Understanding of Contaminant Exposure Routes and the
Acute and Chronic Public Health Effects from Contaminants in Drinking Water.
The large scope of this need makes it unusable as an objective in an Action Plan. Taken
literally it describes a decades-long research agenda that has already been in progress for
many years. It includes yet another database with no clear idea of how this product will
be used, articulated with other databases and systems, and maintained over time. An
EPA strategy that emphasizes immediate usability and first approximations is a sound
one. This need, therefore, should be interpreted in that light and be stated more modestly
and specifically.
Generic categories corresponding to the three routes of exposure (inhalation,
ingestion, dermal) could be developed to provide generic models for different large
classes of agents that would provide some initial, albeit crude, guidance in a relatively
short span of time, and the details could be continually filled in as additional information
becomes available (e.g., regarding sensitive subpopulations such as children, the elderly,
and immunocompromised individuals). This is consistent with the notion in section 3.2
of developing a short list of possible threat scenarios that consider explicitly certain
exposure routes.
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3.6.b A Health Surveillance Network Associated with Contaminated Drinking
Water. In describing this need, the EPA makes assumptions about the activities and
capabilities of the CDC and other Department of Health and Human Services (DHHS)
agencies that need to be corrected. The Action Plan states that if the twater]
contaminant causes a notifiable disease, it will be picked up by existing health
surveillance systems, and thereby presumes that most notifiable diseases (e.g., giardiasis
and cryptosporidiosis) are typically reported and in a timely fashion. Indeed, the
percentage of reportable diseases reported by even the largest and most sophisticated
active disease surveillance systems is surprisingly low (for an example from New York
City see NRC, 2000, Chapter 6~. The Action Plan also incorrectly notes that a national
surveillance system for potentially waterborne diseases is well underway. The Action
Plan should contain an accurate evaluation and description of current surveillance and
other related activities in the public health sector, and the EPA should define its role and
research agenda in this regard. The EPA may not be the lead agency for public health
surveillance but should be an active participant in understanding and establishing
effective surveillance for waterborne agents, since it is the lead agency for water security.
The primary goalies) of the waterborne surveillance system should be stated. Is the
primary goal to detect a possible terrorist attack, or detect outbreaks of accidental
contamination, or both? If the goal is to detect a terrorist attack, then surveillance may
focus on very different agents and illnesses. The Action Plan should describe the overall
needs of a surveillance program and how waterborne surveillance woulc! fit into a larger
surveillance program. The plan should also address the investigative response (e.g., who
will take the lead for initiating action, and how will the investigative teams coordinate
their activities?) in addition to describing research activities. Finally, the needs for
training and coordination of local health department employees and medical personal in
the development of an effective water surveillance program should be acknowledged.
Public health surveillance is important to help detect possible outbreaks or epidemics.
The surveillance activities should be sensitive enough to detect increased risks early
enough for the initiation of timely investigations, mitigation actions, ant! efforts to
prevent the spread of illness. Surveillance activities can be designed to monitor various
outcomes such as selected diseases (e.g., cases reported by clinicians), symptoms (e.g.,
complaints to nurse practitioners), events (e.g., sale of anti-diarrhea! medicines), and/or
laboratory analyses (e.g., positive stool specimens for Cryptosporiclium). If the incidence
of any of the outcomes is increased, officials must then assess the risk and take
appropriate actions. Information will be required about the possible routes of exposure
(ingestion, inhalation, dermal), modes of transmission (indoors and outdoor airborne,
foodborne, waterborne, person-to-person, direct contact), type and source of
contamination, and water supply treatment or isolation options. Thus, surveillance
activities will need to include a well-thought-out plan not only how best to monitor
outcomes of interest but also how to coordinate the response of a team of investigators
(epidemiologists, physicians, microbiologists, chemists, and engineers) if water is the
suspected mode of transmission. There is a substantial communication component to this
need on many levels (e.g., among the investigators, with the public), especially for
intentional contamination events that are investigated in the context of a potential crime.
In recent years, several active disease surveillance systems have been initiated at the
local and state level for the improved detection of both foodborne and waterborne
outbreaks. An evaluation of these systems should be included among the research needs.
The effectiveness of monitoring various alternative outcomes (e.g., complaints,
symptoms, drug sales, sentential populations) should also be evaluated.
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45
Finally, water quality monitoring and analysis should be used in conjunction with
active disease surveillance data to help confirm or deny the role of water as a route of
transmission during an event. This suggests better linking this research need with the
monitoring activities discussed in section 3.3.
3.6.c A Methodology for Using Non-traditional Data for the Derivation of
Toxicity Values Applied to Water. This need would be applicable in cases where new
contaminants are noted for which there are few or no available toxicological data. The
EPA already has substantial in-house resources and expertise in predictive toxicology,
especially in the New Chemicals Program within the Office of Pollution Prevention and
Toxics (OPPT). The Office of Ground Water and Drinking Water/Office of Science and
Technology also has a functioning Health Advisory Program for non-regulated
contaminants that includes short-term exposure scenarios. It would be logical and
probably most efficient for the EPA to make use of those resources rather than
contracting externally. The Food and Drug Administration is also engaged in some
similar work, and the Department of Defense (DOD) has efforts in these areas.
Collaborations between the active organizations for a concerted! effort would appear to be
highly desirable and most efficient.
Use of single point toxicity estimates such as LD50 values ant! structure/activity
relationships to project acute toxicity values for human populations is a difficult concept
and one that would require significant validation before carrying much weight in a
decision process. Work is underway and some models do exist (e.g., MCASE, TOPCAT,
DEREK3, PALLAS). The DOD's Armed Forces Medical Intelligence Center recently
held a conference on prediction of acute toxicity that concluded that acute toxicity
endpoint QSARs are less well developed than QSARs for chronic toxicity endpoints
(William Waugh, EPA OPPT, personal communication, 2003~.
QSAR methodologies have been developed for many longer-term toxicology
endpoints, such as cancer and reproduction and neurotoxicity, and these are used
routinely by the OPPT New Chemicals Program. Commercially available systems also
exist. QSAR or other predictive systems for ecological endpoints also exist (e.g.,
ECOSAR and Aquatox), and these would be relevant for assessing the potential
consequences of discharges of contaminated wastewater.
, · . . . . . . . . · · . .
_ _ (~ 1
Predictive airborne
contaminant assessment work related to terrorism Is also underway in the OPPT (e.g.,
Acute Exposure Guideline Levels). This would also have applicability in the water
context for aerosol exposures in the home and in water and wastewater treatment plants.
Predictive tools applied to microbial contaminants have not developed as far as it has
for chemical toxicology. The concept of Virulence Factor Activity Relationships
(VFARs) has been suggested as appropriate for some pathogens. However, the state of
the art and the scientific complexities involved place this in the long-term basic research
realm. The far-reaching implications of this potential too} in public health and medicine
are such that it would be best addressed by a research agency such as NIH rather than the
EPA.
3.6.d Frameworks for Assessing and Managing Risks. The centrality of risk
assessment and risk management to an overall response for water security stands in stark
~ The NRC's Risk Assessment in the Federal Government: Managing the Process (1983)
distinguishes risk management and risk assessment, and this view is reflected in the Action Plan.
Therefore, the distinction is maintained here.
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contrast to its brief treatment in Action Plan. Indeed, the need statement suggests that
risk assessment follows risk management, which is counter to prevailing uses of both
terms (see NRC, 1983 for detailed} descriptions). As envisioned by the panel, this
particular need should stress the importance of integrating risk assessment and risk
management into decision making during all stages from threat assessment to event
response. Although the Action Plan recognizes that on-scene decision makers will
require the support of a risk assessment/risk management protocol and it emphasizes the
utility of table-top exercises, no information is provided on possible frameworks for use
cluring contamination events or threat scenarios. This need requires considerably more
thought from the EPA authors, and it should be put in the appropriate context, since it
represents another component of the overall response guidance mentioned in Chapter 2,
section 3.3.a, and section 3.4.a7.
3.6.e Methods and Means to Communicate Risks to Local Communities. Prior
to the development of methods and means to communicate risks to communities, there
should be an established relationship in place with these communities. This relationship
is the result of a detailed risk communication planning process that identifies not only the
people with whom risks must be communicated, but also the appropriate methods and
tools that can and should be used in diverse scenarios. Thus, risk communication cannot
be viewed as the last step in the management of water system security but should be
incorporated throughout. No one method or means will be appropriate for all places or
times. Knowing what tool to use, and when, and how can only be determined through
communication planning and research. For example, standard public health notices (e.g.
"boil water" or '~do not use," as mentioned in section 3.4.d of the Action Plan) may not be
effective in all or even a majority of cases (O'Donnell, et al., 2000~.
Risk communication can be defined as a process to develop two-way communication
between various parties that addresses the needs and concerns of all affected parties
(NRC, 1989~. Risk communication is an essential component in the overall risk
management scheme. It should not be considered a separate piece of the mode! to be
utilized and developed after the other steps, but something that should be factored into
each step of the risk management model. Additionally, risk communication is not limited
to the thoughtful development of tools to assist in the communication process. It is a
methodology or strategic planning process to establish contact up-front with various
constituent groups within and outside of an agency, facility or community. This process
takes into account how communities see risk and requires earning trust and credibility
and explaining risk.
There are seven important steps in risk communication planning: 1 ) issue
identification and clarification; 2) setting the goal for the communication; 3) profiling or
understanding the nature of the issue or event and the parties that will be affected; 4)
identifying and assessing audience need and concerns; 5) message development; 6)
method development; and 7) plan implementation and evaluation (Pflugh et al., 1992~. In
order for a plan to be successful, it must be in place prior to an event with all potentially
affected parties informed in advance of what will be communicated and what they will be
asked to do to protect themselves.
Information developed in advance and in consultation with the potentially affected
parties will yield the response required and desired by the communicator should a
national security situation arise. Having a plan in place, using tools developed through
the risk communication planning process, and knowing how people will respond to risk
information will help in the distribution of information to the appropriate people as
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47
needed. Releasing appropriate information in a timely fashion can build trust and may
moderate the public response in the event of an actual attack or a hoax.
Application to Large versus Small Systems
For at least one research need in this section, there are considerations that should be
taken into account for small versus large water supply systems. Resources for local
health surveillance may be very limited for small water systems, and some surveillance
methods may not be as effective for small systems. Thus, the evaluation of an active
disease surveillance system should include an assessment of its effectiveness and
financial feasibility for systems of various sizes.
Recommendations
.
.
.
.
.
In conclusion, the pane' recommends the following rewritten needs:
An improved understanding of contaminant exposure routes (not only direct
ingestion but also dermal and inhalation exposures), and of the acute and chronic
public health effects from contaminants in drinking water supplies anci systems,
which should focus on generic models for different large classes of agents.
A health surveillance network to rapidly identify and help control a disease
outbreak or other public health emergency associated with contaminated drinking
water. This effort should be cognizant of active disease surveillance efforts
already underway, the limitations of active disease surveillance, and the
respective roles of the EPA and other public health agencies.
An evaluation of the utility and validity of using non-traditional data sources
(e.g., LD50, QSAR) for the derivation of acute and chronic toxicity values applied
to water.
A risk assessment/risk management framework for identifying the impact of
decontamination/treatment options and the subsequent response. (This need is
one component of the overall response guidance, which is also expressed in
Chapter 2 and sections 3.3.a and 3.4.d, and would be best expressed in
combination with those needs.)
Methods and means to communicate threat risks to local communities and to
respond to customers and the media in the case of an attack on drinking water
systems, the success of which will depend upon the prior existence of an
established relationship with communities that is the result of a detailed risk
communication planning process.
WASTEWATER
In areas of dense population, the carriage and appropriate treatment and disposal of
human waste via the wastewater system provides an essential service to the maintenance
of public health and sanitation. Wastewater collection and treatment systems are also
control points for water quality protection. There are many health-related issues when
considering the security of the nation's wastewater plants, because many surface water
supplies of drinking water contain treated wastewater. The purposeful impairment of
wastewater treatment facilities could notably affect drinking water quality downstream.
In addition, there are other beneficial uses of surface water resources that can be
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adversely affected by disturbances in the wastewater system, including aquatic
ecosystems and contact recreation.
The wastewater collection system, by design, serves as an access point to numerous
structures in a region. Hence this system is not only physically vulnerable to terrorist
activities, but it also presents a potential conduit for malicious use to damage structures
that may be serviced by the system. Thus, it is appropriate that consideration be given to
the security of the nation's wastewater systems, although the human health consequences
may be somewhat more indirect than in the case of drinking water systems.
Wastewater Infrastructure (Action Plan Section 4.0)
The EPA Action Plan delineates this work into six categories of research ant!
technical support needs:
a) A thorough understanding and documentation of the possible threats to the
nation's wastewater treatment and collection system infrastructure, including
the interdependencies with drinking water systems and other critical
infrastructure.
b) An updated assessment of the possible health and safety risks related to
potentially hazardous substances used by wastewater utilities or intentionally
introduced into wastewater collection and treatment systems, including any
impacts on residuals management operations (sewage sludge).
c) Improved intrusion monitoring and surveillance technologies to quickly
notify wastewater utilities when these technologies are compromised by
physical and cyber threats or chemical, biological, and radiological
contaminants.
d) Improved designs for wastewater systems to reduce vulnerability to physical
threats and as a way to prevent or mitigate the effects of attacks on
wastewater infrastructure.
Enhanced prevention and response planning methods, including emergency
response, contingency planning, and risk communication protocols and
guidance for systems of varying sizes.
Methods and means to securely maintain and, when appropriate, transmit
information on contaminants and threat scenarios applicable to wastewater
systems.
Commentary on Identified Needs
In general the panel is concerned that the level of detail in this section of the Action
Plan is much less than the level of detail that exists in section 3.0. Broad threats to
wastewater systems include contaminant impact on facility performance, effects on
receiving water quality and associated damage to environmental targets such as aquatic
ecosystems, physical damage to collection systems or treatment facilities, and use of the
sewer system as a means to get undetected access to sensitive locations. In addition,
impacts on stormwater and collection systems (either separate or combined) should be
considered. Within the Action Plan, more thorough and thoughtful analyses are needed
1 ~ , , · ~ , ,
to consider the security needs OI wastewater Infrastructure.
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Certain distinct features differentiate wastewater systems from drinking water
systems. First, wastewater system disruption is physically simple in that it is possible to
introduce materials to a sewer on a surreptitious basis from almost anywhere (an intrinsic
design feature of such systems). Second, it is impossible to turn off a wastewater
collection system, which could make mitigation of a contamination event very difficult.
The Action Plan should address the broad spectrum of threats to wastewater systems
and a various facility types. The interdependencies between drinking water and
wastewater systems should be considered. For example, contaminated drinking water
can serve as an input to the wastewater system and contaminated wastewater may
adversely impact downstream sources of drinking water.
Emergency responders would benefit from an examination of the possibility and
availability of emergency points of relocation of an effluent discharge or the availability
and utility of emergency treatment systems to continue to protect vulnerable water
resources. Emergency relocation or treatment may be especially useful where wastewater
discharge is a major contributor to groundwater recharge or where it impacts a nearby
surface water intake for drinking water supplies.
The degree to which deliberately introduced contaminants pass through a wastewater
treatment plant and either into the effluent or the sludge needs to be reviewed. The
potential impact of residuals from cleanup of a terrorist event needs to be judged (e.g.,
could wash waters sent to a sewer damage routine plant operation or pose a major
additional loader. Occupational risks to wastewater collection system and treatment plant
operators from these materials need to be assessed, along with recommendations for
personal protective gear when contamination is suspected.
Recommendations
The security of the nation's wastewater infrastructure needs additional effort within
the Action Plan, similar to that undertaken for drinking water systems, including input
from various stakeholder groups. Based on the information presented in the Action Plan,
the following rewording of needs is suggested:
.
.
.
A thorough understanding and documentation of the possible threats to the
nation's wastewater treatment and collection system infrastructure, including the
interdependencies with drinking water systems and other critical infrastructure.
An updated assessment of the possible health, safety and environmental risks
related to potentially hazardous substances used by wastewater utilities or
intentionally introduced into wastewater collection and treatment systems, or
stormwater conveyance and treatment systems, including any impact on residuals
management operations (sewage sludge).
An assessment of the possible health, safety, and environmental risks related to
potentially hazardous substances produced during response to security threats
(e.g., decontamination materials and their byproducts) which may be discharged
to sewer systems or stormwater conveyance systems.
Improved intrusion monitoring and surveillance technologies to quickly notify
wastewater utilities when these facilities or technologies are compromised by
physical and cyber threats or chemical, biological, and radiological contaminants.
(Note that some of this information may be transferred from knowledge gained
while assessing drinking water systems.)
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.
.
.
Improved designs for wastewater systems to reduce vulnerability to physical
threats and as a way to prevent or mitigate the effects of attacks on wastewater
infrastructure.
Enhanced prevention and response planning methods, including emergency
response, contingency planning, and risk communication protocols and guidance
for wastewater systems of varying types (size, geographic location, design). The
potential for emergency relocation of discharge or alternative treatment should
also be assessed.
Methods and means to securely maintain and, when appropriate, transmit
information on contaminants and threat scenarios applicable to wastewater
systems.
Representative terms from entire chapter:
drinking water
