Vulnerability Assessments: A Key to Water Security

Guidelines for keeping community water systems safe and secure

• By Mike Flory, REM
• May 01, 2004

There is a bumper sticker that I see from time to time that reads "Water is Life." The sticker, I believe, originated from the Texas Water Commission, a former regulatory agency headquartered in Austin, Texas. There is quite an accurate statement on the sticker, as has become more apparent in today's world.

Water is the key ingredient for human sustenance and its availability in certain geographical areas makes the resource more valuable than gold. For example, the water supply in the western part of Texas cannot compare to the eastern part of the state's supply, thus creating much drought for the west. The eastern part of Texas faces other challenges associated with water as it pertains to population growth and subsidence. Southeast Texas, and large cities such as Houston, must raise the level of sensitivity toward residual and commercial water conservation programs as just one step in the attack against fast population growth and water usage. Houston alone will add two million more people by the year 2020.

The aforementioned challenges are compounded by the new era of terrorism and the vulnerability attached to terrorism. Communities' water systems are critical for public health and safety. The protection of these systems must be a high priority to officials, owners and operations. This article will present some helpful guidelines in this protection and focus on water systems serving populations between 3,300 and 10,000 people.

The Law
Vulnerability assessments are directed under the Public Health Security and Bioterrorism Preparedness and Response Act of 2002. Community water systems (CWS) with more than 3,300 and fewer than 50,000 people must submit completed vulnerability assessments to the U.S. Environmental Protection Agency (EPA) no later than June 30, 2004. This assessment needs to be coordinated with the local emergency planning committee.

The Bioterrorism Law requires vulnerability assessments to include the following:

• A review of pipes and constructed conveyances
• Physical barriers
• Water collection facilities
• Pretreatment facilities
• Treatment facilities
• Storage and distribution facilities
• Electronic, computed or other automated systems utilized by the water system
• The use, storage or handling of various chemicals and the operation and maintenance of such a system

The self-assessment should be conducted on all components of the system (wellhead or surface water intake treatment plant, storage tank(s), pumps, distribution system and other important components of the system).

Also under the Public Health Security and Bioterrorism Preparedness and Response Act of 2002, all systems serving a population greater than 3,300 people must complete or revise an emergency response plan (ERP) based on the vulnerability assessment. This ERP must be completed or revised within six months of submitting a vulnerability assessment to EPA. The process of completing the vulnerability assessment and the emergency response plan helps develop a specific list of priorities intended to reduce risks of threats of attack. Actions should be prioritized based on the most likely threats to a specific system.

One of the efforts to pursue before creating a system is to identify critical services and customers, such as hospitals or power facilities, as well as critical areas of the drinking water system. This identification helps determine the plan of action should an attack occur that results in a disruption of vital communication services.

Community water systems also should attempt to determine what types of assailants and threats they are trying to protect against. Local law enforcement can be of assistance to determine the kind of threats that might occur to the facility. Additionally, the regional EPA can provide a copy of "Baseline Threat Information for Vulnerability Assessments of Community Water Systems" that will help assess the most likely threats.

When determining a threat matrix, examples of possibilities include natural disasters, low-level inside terrorists, high-level outside terrorists and vandals. Also, community water systems must determine the goal of the threat, how it can be accomplished and how the facility can prevent the threat from happening.

Below is a list of information that is part of a vulnerability assessment. The list serves as a general thought process and can be made more thorough through the vulnerability assessment format or by hiring a professional security firm.

Facility and System Characteristics

General Items:

• The facility must have a written ERP.
• Have the facility designer listed on the Basic Data page participate in a review of EPA's Baseline Threat Information Document.
• Restrict access to critical components of the water system to authorized personnel only.
• All critical facilities should be locked where appropriate.
• Critical door, windows and other points of entry such as tank and roof hatches and vents should be closed and locked.
• There should be external lighting around all critical components of your water system.
• Warning signs should be posted on all critical components of the water system.
• Patrols and inspections of all source intakes, buildings, storage tanks, equipment and all other critical components should be done.
• The area around all the critical components of the water system should be free of objects that may be used for breaking and entering.
• All entry points to the water system should be easily seen.
• The water system should have an alarm system that will detect unauthorized entry or attempted entry at all critical components.
• A key control and accountability policy should be in place.
• All entry codes and keys should be limited to water system personnel only.
• The water system should have an updated operations and maintenance manual that includes evaluations of security systems.
• A neighborhood watch program for the water system would be helpful.

Water Sources
Special attention should be given to various water system components. Water resources (surface water intakes or wells) should be secured. The greatest threat surrounds the surface water supplies. Where it is more difficult to secure areas, local law enforcement needs to be increased. Also look for public support with terrorist awareness. The public can be of great help by being vigilant and reporting suspicious activity. Below are other suggestions that can add strength to the overall programs.

• Seal wellheads securely and properly.
• Make sure well vents and caps are screened and secured.
• Make sure observation/test and abandoned wells are properly secured to prevent tampering.
• The surface water source needs securing with fences and gates. Have system personnel visit the source often.

Treatment Plant and Supplies
Outsource vendors and suppliers of the water system and treatment plant must be monitored for security reasons. All deliveries of chemicals and supplies should be made in the presence of water system personnel. During the check-in of these chemicals and supplies, verification of the delivery personnel credentials must be done. This verification should also include picture identification.

Recordkeeping has always served as a good measure for security, as well as inventory management. Keeping a journal of deliveries helps the water system personnelidentify potential hazardous chemicals and any new changes to the inventory mix. The process also assists in the proper storage and security of the area that chemicals are placed. Access to the chemical storage area should be available only to authorized personnel.

Emergency response planning should include having tools and equipment on site for any immediate action that may be needed. Items such as fire extinguishers, dry sweeps and other emergency response tools and supplies should be readily available and accessible.

Terrorist action can focus on contamination of the water system. For that reason, the system needs to be monitored and checked continuously. Water quality monitoring ensures the public's safety and is a strong preventive measure. Other measures that can be taken to complement monitoring relate to facility management. Tank ladders, access hatches and entry points should be secured. Vents and overflow pipes need to be properly protected with screens and/or gates. Control of the use of hydrants and valves is mandatory. Flush hydrants need to be kept locked to prevent contaminants from being put into the distribution system. The water system should implement a backflow prevention program.

Ron Sparks, president of the national and international security consultancy Sparks Technical Service, emphasizes the special attention needed at the water source locations. Mr. Sparks states, "There can never be too many checks and balances in place for a secure water system."

Personnel
Employment standards in this changing global economy have required continuous changes in best hiring practices. Real threats to several industries have brought issues such as background checks to a whole new level. Basic entry level positions must include a deeper look into potential employees' pasts.

Marshall Whichard, CEO of T. Marshall Consultants, a leading investigative firm, sums it up in the following statement, "A firm should conduct adequate and meaningful background investigations in a manner that demonstrates the company is serious about their reputation and the company's standing in the community."

Whichard further gives a short version on how to accomplish that goal in three steps.

1. Entry-level background investigation to verify the identification, residency and possible criminal history of a job applicant.
2. Mid-level supervisory background investigation before promoting an employee to a more responsible position. Even though this potential supervisor has been with you for several years, you may not be aware of problem areas over the time span.
3. Management position promotion or new hires in an upper management position should involve information obtained by means of an in-depth background investigation, including criminal and civil filings in county of current residence, prior county of residence, judgment and lien filing, resume verification, education verification and previous employer job position verification and, if feasible, inspection of previous employers' personnel files.

Current personnel should have picture identification cards on their person and a copy in their office file. These identification cards also will come in handy in case of an emergency response.

The company's employees should wear uniforms and drive vehicles clearly and prominently displaying the water system's name. Personnel also should be trained in all of the firm's security procedures and be advised on reporting procedures should a suspicious situation occur. This procedure can be accomplished by a checklist document.

Procedures for terminating employees must require that the employees turn in their identification cards and badges, keys and other security-related items. Disgruntled employees have knowledge about the operation of the water system. This could create a situation where the former employee could harm the system if not handled correctly.

Public Relations
The community water systems' customers should be educated about the system. Making the customers aware, it allows them to help report any suspicious activity. The water system should also advise customers of any increased preventive security measures to protect the water system from vandalism.

Policy and procedures on public relations include dealing with public information requests and restricting distribution of sensitive information. Each water system should have one person designated to provide the media with information. All employees should be trained not to respond to media except through the media relations officers.

Public health issues are of high priority in the case of a contamination or health outbreak. As soon as possible after a disease outbreak, the testing personnel and the laboratory need to be advised of the incident. In outbreaks caused by microbial contaminants, it is critical to discover the type of contaminant and its method of transport (water, food, etc.).

Public relations, as part of the vulnerability plan, are a major necessity. Getting the word out to the public by all methods is significant.

Information, Storage, Computers and Controls
System security, including computerized controls like a Supervisory Control and Data Acquisition (SCADA) system, also need enhancement to protect records and critical information. You do not want terrorists to have the opportunity to use information to disrupt or contaminate the water system.

As part of this overall security, passwords need to be protected and virus protection installed and upgraded regularly. Also, a plan to back up computers is prudent. If the water system has a Web site, there may be information on the Internet that can be harmful in disrupting the system.

Conclusion
This article's purpose is to give a general scope of elements needed to create a vulnerability assessment of community water systems. Certainly there is much more in-depth information needed in this assessment. Guidelines for further help can be obtained through EPA and other associations.

Some of the information for this article was obtained through EPA, the Association of State Drinking Water Administrators and the National Rural Water Association.

e-Sources

• U.S. Environmental Protection Agency's Vulnerability Assessment Fact Sheet -- www.epa.gov/safewater/security/va_fact_sheet_12-19.pdf
• American Water Works Association's Water Security Resources -- www.awwa.org/Advocacy/learn/security/about/03InfrastructureSecurityRes.cfm
• Association of State Drinking Water Administrators -- www.asdwa.org
• National Rural Water Association -- www.nrwa.org

This article originally appeared in the 05/01/2004 issue of Environmental Protection.