There is an interesting post on the Security Notes blog at ASDWA.org about the latest version of the Roadmap to a Secure & Resilient Water Sector. This is a document prepared by the Water Sector Coordinating Council and the Water Sector Government Coordinating Council via the Critical Infrastructure Partnership Advisory Council (CIPAC).
The introduction to the Roadmap provides a vision statement for the Water Sector:
“The Water Sector’s vision is a secure and resilient drinking water and wastewater infrastructure that provides clean and safe water as an integral part of daily life, ensuring the economic vitality of and public confidence in the Nation’s drinking water and wastewater service through a layered defense of effective preparedness and security practices in the sector.”
I understand that the priority for the water sector is its responsibility to provide safe drinking water and cleaned waste water. As a long-time consumer of drinking water from public treatment works I whole heartedly endorse the hard work and attention to detail that members of this sector bring to this task.
Chemical Hazards Not Addressed
As a process chemical professional and a student of chemical security I do, however, have to take serious exception to this document completely ignoring the responsibility that this sector has to be a good steward of the chemical assets that it uses for disinfection of both drinking water and waste water. There is absolutely no mention in the Roadmap of protecting employees and neighbors from either the accidental or deliberate release of hazardous chemicals like chlorine gas, industrial grade bleach and other chemicals used in the water treatment process.
Water treatment and waste water treatment facilities are some of the largest consumers of chlorine gas in the country. While many facilities have switched to the use of chlorine bleach or other less hazardous treatment methods, there are still a large number of facilities that use chlorine gas by the rail car load and an even larger number that use 1-ton chlorine cylinders for the purpose of disinfecting water.
In addition to the potential for accidental or deliberate releases of these chemicals there are also the potential hazards from inadvertent or deliberate mixing of incompatible chemicals on these sites. Such mixtures can certainly put facility employees at risk for dangerous chemical exposures and there is also the potential for off-site exposure. Additionally, these incompatible chemical accidents have the potential for putting these facilities out of operation for varying amounts of time due to collateral equipment damage and facility decontamination requirements.
The failure to address these potential risks is particularly disconcerting because municipal water treatment facilities are exempt from both the chemical security requirements of the CFATS program and the chemical safety requirements of the OSHA PSM program.
I suspect that most water treatment professionals do their best to safely handle and store these hazardous chemicals; it is after all their health and safety that are most at risk. Having said that, however, it is easy to understand that in their desire to efficiently provide clean drinking water and cleaned waste water, it would be easy to lose sight of what is necessary to provide adequate chemical safety and security.
Chemical Safety and Security Executive Order
The Chemical Safety and Security Working Group needs to take a close look at the water treatment industry and their various exemptions from chemical safety and security regulations on the Federal level under the review mandated by §4(b) of the Chemical Safety and Security Executive Order (EO 13650) . While the EPA (through State agencies in most cases) has over sight responsibility for these facilities, they do not have the personnel or specific program mandates to adequately oversee all of the chemical safety and security programs that other organizations using the same chemicals must respond to.