Tuesday, August 12, 2008

Water Facility Security Programs

HSToday.US has a brief article about security at water treatment and waste water treatment facilities. The article is based on a Congressional Research Service (CRS) report recently released by the Federation of American Scientists (FAS), a group with no official link to the CRS. The CRS report is a detailed look at the history of government action on water facility security issues since 9/11.


Water Supply Security


I have already done a pretty detailed look (see: “Water Supply Security”) at why there is a fairly low risk of a successful mass casualty attack on water supply systems. It just takes too much preparation, costs too much, and probably won’t cause many people to get sick, much less die. As such it doesn’t fit in with an al Qaeda style terrorist attack profile.


On the other hand a psychological attack on a water system could be used as part of a propaganda campaign against the evils of chlorine or fluorine, urban or suburban sprawl, or any one of a litany of causes espoused by a variety of ecological-action fringe groups. The attack would not even have to be real as an apparent attack (tampered door on a water tower) would cause the utility to issue a warning against drinking or bathing with the water until extensive and expensive testing showed that the water was safe. In fact, a false attack would play to the non-violent self-image of these groups.


Water Facility Chemical Security – Large Chlorine Users


Chemical security at these facilities may be a much larger problem than the water safety issues. Let’s look at some of the data provided in the CRS report. They report (page 2) that there are 184,000 public water and waste water treatment facilities in the <?xml:namespace prefix = st1 ns = "urn:schemas-microsoft-com:office:smarttags" />United States. They report that about 27,600 of these serve about 75% of the population of the country.


The report refers to a 2006 GAO survey of the 200 largest waste water treatment works in the country showing that about half of those facilities use ‘gaseous chlorine’ for disinfection. If we extrapolate that to the 27,600 largest water and waste treatment facilities we have about 13,800 facilities that have significant amounts of chlorine gas on hand.


Since chlorine is a release-toxic COI with an STQ of only 2,500 pounds we would suspect that, if water treatment facilities were covered under CFATS, all of these 13,800 facilities would be required to file Top Screens. This would have been about 1/3 of the total number of Top Screens filed by all covered chemical facilities. There is no way of telling how many of those 13,800 facilities would have been designate high-risk facilities.


One of the major arguments against adding water and waste-water treatment facilities to CFATS was that the large chlorine users were already covered under the EPA Risk Management Program (RMP). It turns out that only about 2,800 (page 17) of the very largest facilities are covered under RMP. That leaves the vast majority of large chlorine-using water-treatment facilities unregulated when it comes to their safe and secure use of chlorine gas.

Water Facility Chemical Security – Small Chlorine Users  

The smaller facilities have even a bigger security problem. There is no data provided about the chlorine use of the remaining 156,400 smaller facilities. I suspect it is a much higher percentage given how easy it is to use chlorine for water disinfection, but let us assume that it is the same (about) 50%. The vast majority of these are not using the one-ton cylinders or rail cars of chlorine so they would not fall under the release-toxic provisions of CFATS.


Chlorine is also covered under the theft/diversion COI provisions of CFATS. The STQ in that role is only 500 lbs, or four 150-lb cylinders of chlorine gas. Lets say that only half of the chlorine-using facilities ever has four cylinders on hand at any one time. That means that about 39,100 facilities would have a theft/diversion STQ amount of chlorine gas and would be required to file a Top Screen. That is more than the number of chemical facilities that actually filed Top Screens in the phase II implementation of CFATS. Needless to say, none of these facilities is covered under RMP.


EPA Security Programs


Another argument used to keep water and wastewater treatment facilities out of CFATS coverage was that there were already EPA security programs in place for those facilities under the 2002 Bioterrorism Preparedness Act. That legislation required that most drinking water treatment facilities complete a vulnerability assessment. And the vast majority of the covered facilities had done so by 2006.


Unfortunately a vulnerability assessment, even if properly done is only a small part of a security program. For water treatment facilities there is no required security program beyond the vulnerability assessment. Wastewater treatment facilities are not even required to perform a vulnerability assessment. Further, the CRS report (page 14) notes that; “EPA is not authorized to require water infrastructure systems to implement specific security improvements or meet particular security standards.”


Money Spent on Water Security Programs


Finally, the CRS report looks at the money spent on security related programs for water infrastructure. According to the report (page 14) the Federal Government spent $794.4 Million dollars on water infrastructure security between FY 2002 and FY 2008. This includes all funds spent by the EPA, the Army Corps of Engineers, and the Bureau of Reclamation. Only about $250 Million of that was spent by the EPA on treatment facilities.


That means that if the EPA spent that money on security for all 184,000 treatment facilities in the United States, each facility received (on average) $1,388 (not millions, just dollars), or about the cost of a gate guard for a month. This is just a mere pittance compared to what the chemical industry (at a smaller number of facilities) expects to pay out to implement CFATS over the next year or two.


Bring Water and Wastewater Treatment Facilities under CFATS


It is no wonder that the House Homeland Security Committee added water and wastewater treatment facilities to CFATS when they drafted the Chemical Facility Anti-Terrorism Act of 2008 (HR 5577). Unfortunately, it looks like this segment of our chemical economy will remain unregulated and woefully unprepared for a terrorist attack while HR 5577 languishes in the House Energy and Commerce Committee.

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