A recently released report by the Inspector General of the EPA includes information on the EPA security program for water treatment and wastewater treatment facilities. Many of these facilities would meet the definition of a chemical facility under CFATS if it weren’t for the Section 550 exemption. With that in mind we’ll take a quick look at the results of this report. This may be even more important if the CFATA of 2008 passes in its current form. The new legislation removes the Section 550 exemption for water facilities.
The report concludes with a series of recommendations for prioritizing EPA efforts in their drinking water program. The report suggests that:
“Priority should be given to: water security-response capability, chemical security at drinking water facilities, variances/exemptions and waivers, effectiveness of Agency funding, and the contaminant selection process.” (Italics added)
Federal Oversight
The report was prepared at the request of the Office of Ground Water and Drinking Water (OGWDW). The purpose was to look at past reports and recommendations that had been made by the Inspector General’s office dealing with improvements to the Drinking Water Program. Security was just one of the areas covered by this report.
The EPA was designated at the Federal agency that was responsible for the security oversight of drinking water and wastewater treatment facilities. The Water Security Division of the OGWDW is the office within EPA directly tasked with that responsibility for water treatment facilities.
Most of their efforts are directed at protecting the safety of drinking water from contamination with chemical or biological agents. Only a small part of their attention is directed at protecting the hazardous chemicals at those sites from terrorist attacks. This is one of the reasons that provisions of the proposed CFATA of 2008 {Section 2103(f)} would bring the chemicals at water treatment plants under DHS regulations.
Current Status of the Program
The IG found that the EPA has accomplished a great deal in their security program. It required that all water treatment facilities complete a security vulnerability analysis. According to the report “(n)early all of the drinking water utilities mandated to complete vulnerability assessments and Emergency Response Plans have done so” (page 8).
The EPA provided technical and financial assistance to facilities for these SVAs (pages 8 and 9). Facilities serving more than 100,000 people initially received $115,000 each to complete these SVA’s. Smaller facilities shared in $68.9 Million for the same purpose.
As part of the Water Critical Infrastructure Partnership Advisory Council, the EPA has helped to develop a series of tools that utilities can use to evaluate their security posture. These tools include “22 utility measures, which include 3 hazardous chemical measures and 3 risk reduction measures” (page 9). Additionally, the Council developed 18 other measures that could be used by outside agencies to evaluate these water treatment systems.
The IG’s report noted that the current situation is relatively static from an enforcement point of view. As such they expect the EPA to have a problem “maintaining a “culture of security” at water systems in the absence of further EPA requirements” (page 16).
Future Evaluations
Since this report was based on a review of investigations and studies and not on actual investigations, the conclusions of the report include suggestions for future studies and investigations. Two of those areas for suggested studies deal with security; those areas are response capability and chemical security.
Any security plan must include a plan for actions to be taken in event of an attack. This emergency response plan must be periodically tested and evaluated if it is to be effective in an actual emergency. The report notes that they “found no comprehensive examinations of whether States/utilities are actually using their completed Emergency Response Plans in response efforts” (page 16).
The report notes that there has been ‘considerable congressional interest’ in chemical security issues at water treatment and wastewater treatment facilities. Unfortunately there have been no studies about chemical security at water treatment plants though wastewater treatment facilities have been examined. The reports note that such studies and reports are essential for adequate congressional oversight.
This report will provide some useful information in the upcoming discussion of the potential role of DHS in overseeing chemical security at water treatment facilities. It is well worth reading by anyone interested in that debate.
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