Monday, November 3, 2008

EPA Water Security Guidance Documents

Last week over on the HSDL.Org blog site Ijakaijan posted some links to newly released EPA documents related to water system security. As you would expect from an EPA mandate point of view, these documents were directed at deliberate water system contamination events rather than onsite water treatment chemical releases. Now I have made my opinion clear (see: “Water Supply Security”) about what I think of the realistic possibility of a terrorist significantly contaminating a municipal water supply, but the EPA has an institutional and Congressional mandate to address such a remote possibility. The system they outlined in the guidance document mentioned in Ijakaijan’s post seems to identify a reasonable set of procedures for municipal water systems to use. My main complaint with that document is its total failure to recognize that many of the water treatment chemicals used at a large number of water treatment facilities are, in and of themselves, a legitimate threat for terrorist attack. For example, figure 1-2 shows the ‘relationship structure’ of a water treatment facility emergency response plan. It identifies fire, water-main breaks, natural disasters, and water system contamination as the incidents that would require incident-specific action plans. There is no mention of an action plan for hazmat release on-site. This is just another indication of the lack of concern at the EPA for security of high-risk chemicals like chlorine, sulfur-dioxide, anhydrous ammonia, and even industrial bleach at water treatment and waste-water treatment facilities. This is one more reason that Congress must act to transfer responsibility for overseeing the security of these chemicals to the federal agency that does take this chemical security risk seriously, DHS.

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