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Member Update (MU05-11)

Member Pipeline - Member Services & Information - Update (MU05-11)

To: Members & Affiliates
Standing Committee Members
From: National Office
Date: July 15, 2005
Subject: NACWA SECURITY INITIATIVES UPDATE
Reference: MU 05-11

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NACWA continues to play a leadership role on the issue of wastewater infrastructure security. Both federally-funded efforts and other security-related initiatives command the Association’s time and attention. The following presents an update of many of these initiatives.

Planning for Decontamination Wastewater: A Guide for Utilities Readied for Release
In early 2004 NACWA entered into a cooperative agreement with the U.S. Environmental Protection Agency (EPA) for a project titled Decontamination Wastewater – A Guide for Utilities. The Guide is intended to enhance the level of awareness and preparedness within the wastewater treatment community regarding the potential sources and impacts of biological, chemical, and radiological contaminants from terrorist incidents. The final Guide is currently in design, but has been delayed slightly by further EPA review. The Guide was sent to several offices within EPA for review, including the Office of Wastewater Management, the Office of Radiation and Indoor Air, the Office of Homeland Security, and the Office of Research and Development, and other federal and state agencies, including the Centers for Disease Control and Prevention and the New York State Department of Health. NACWA staff received substantive comments from these agencies and is currently working to address them. NACWA anticipates that the Guide will be released in early August.

Chlorine Gas Decision Tree Project Underway
NACWA continues to make steady progress on the development of a decision tree for water and wastewater utilities to use in evaluating alternatives to chlorine gas disinfection. NACWA is under contract with the Department of Homeland Security (DHS) to develop the decision tree. In May, NACWA, its subcontractor, DHS, and the Project Oversight Committee (comprised of NACWA member representatives), met via conference call to review and provide comment on a mock-up version of the decision tree. DHS reaction to the mock-up was favorable and since that time NACWA has been working to develop a complete draft of the decision tree that will include a user’s manual with step-by-step instructions on the information utilities will need to use the decision tree, graphical depictions of the outputs, and a draft version of the report template that will serve as a stand-alone summary of the evaluation. The draft was recently completed and will soon be reviewed by DHS and then circulated to the Project Oversight Committee for review and comment. The final decision tree should be completed by late August – early September.

Water Security Working Group Report Endorsed by NDWAC
With the overarching mission of identifying the best security practiced and policies for water utilities, the Water Sector Working Group (WSWG) of the National Drinking Water Advisory Committee (NDWAC) has completed their work. The resulting report, or Findings of the Working Group, identifies six significant failures and four key threats, sets forth eleven guiding principles for active and effective security programs and describes fourteen features of active and effective security programs. It also identifies incentives and endorses aggregate measures of sector progress.

In early June, the National Drinking Water Advisory Committee (NDWAC) voted to accept and endorse the findings of the Water Sector Working Group (WSWG) and send them forward to the U.S. Environmental Protection Agency with no changes. The WSWG, in its transmittal memo to the NDWAC, clarified that they were respectfully requesting that the NDWAC forward their report to EPA for use in support of the national water security program. In response, the NDWAC agreed to forward the WSWG report to EPA. The NDWAC will recommend that EPA use the WSWG findings to support the national water security program, invite EPA's attention to use of the findings by both individual utilities and water security partners, and specifically ask EPA to work with partners to provide additional guidance on the fourteen features of active and effective security programs. The NDWAC also will ask EPA for an update on progress using the WSWG findings within a year. It is anticipated that the Findings will be made available to interested utilities soon.

GAO Scopes New Wastewater Security Study
The Government Accountability Office (GAO) has received a request from the Senate Environment and Public Works (EPW) to conduct a second study on wastewater security. In March the GAO released a report titled, Wastewater Facilities: Experts' Views on How Federal Funds Should Be Spent to Improve Security (http://www.gao.gov/new.items/d05165.pdf). The report recommended priorities as to how the federal government should spend its resources in the wastewater treatment security arena.

The GAO is in the process of ‘scoping’ the new study, which will focus its sights on the following questions posed by the Senate EPW Committee:

The GAO has sought the guidance of NACWA as the work to identify sources for this information and methods to gather responses. They have acknowledged that their biggest concern centers around the third question, as it may be difficult to answer given data limitations and the reluctance of systems to provide this kind of information. Currently a web-based survey is planned and several NACWA utilities will likely review the survey and provide input prior to its distribution.

Wastewater Threat Document Released
Produced by the Water Environment Federation under a cooperative agreement with EPA, the Wastewater Threat Document is intended to provide guidance to managers of clean water utilities regarding system vulnerabilities and composition of threats. The Document provides a description of the nature of vulnerabilities, as well as general and specific vulnerabilities that exist. It reviews the elements
which comprise a threat including potential adversaries and their capabilities, potential motives and objectives, their knowledge of wastewater systems and approaches and tactics that may be employed. Also discussed are the factors that influence threat likelihood and sources of up-to-date information on threats.

Appendices to the Document contain a comprehensive glossary of terms, a summary of chemical and emergency planning regulations, and a detailed discussion of the wastewater system distribution/collection system threat. The Wastewater Threat Document is available at www.WaterSC.org.

Anthrax Protocol Poised for Publication in National Response Team Guidance
After more than three years of effort from NACWA, its members, and the U.S. Environmental Protection Agency (EPA), the National Response Team (NRT) is poised to include the Anthrax Protocol in its Technical Assistance for Anthrax Response guidance. The NRT is comprised of 16 federal agencies with emergency management responsibilities. Following the anthrax attacks in the fall of 2001, wastewater utilities in Florida, Washington DC, and New York were faced with managing the decontamination wastewater generated during the cleanups of several anthrax contaminated buildings. These communities sought guidance from EPA on whether they should allow the discharge of the decontamination wastewater to their collection systems and if so, under what conditions should they accept the wastewater.

With the leadership of the NACWA Pretreatment and Hazardous Waste Committee and officials from the City of Boca Raton, Florida, the Association initiated a dialogue with EPA on the issue and was instrumental in the drafting of the protocol. Based on the response taken by the City of Boca Raton, the protocol serves as a guide to aid wastewater utilities and first responders in establishing communication, properly handling containerized decontamination wastewater, and managing the pretreatment of the wastewater prior to discharge and understanding the conditions under which discharge to the sewer system can take place. The sensitive nature of the subject coupled with the lack of prior study of this issue resulted in multiple levels of review by several federal agencies, delaying the release of the protocol. NACWA is pleased to announce that a pre-publication version of the protocol is available to members only on the Association’s website (http://www.nacwa.org/private/legreg/outreach/2005-07Anthrax.pdf). The protocol also served as the foundation for the Association’s broader guidance, Planning for Decontamination Wastewater: A Guide for Utilities.

Water Contaminant Information Tool (WCIT) Under Development
The Water Contaminant Information Tool (WCIT) is a secure, online database under development by the U.S. Environmental Protection Agency (EPA) that will provide information on contaminants of concern for water security. As envisioned, WCIT will be a planning tool that can be utilized to update vulnerability assessments, emergency response plans and site-specific response guidelines. It can also serve as a response tool, providing real time data on water contaminants to help first responders (including utilities) make better decisions.

WCIT will contain information relevant to both water and wastewater utilities. The initial beta testing is complete, and the first version of WCIT (for water) will be available in early fall 2005. Currently, information for 16 contaminants is contained in the database. It will ultimately contain information on 45 contaminants. Several NACWA utilities recently reviewed the wastewater and decontamination interface for the WCIT and provided detailed comments to EPA. Additional information regarding WCIT can be obtained by contacting Ashley Smith at EPA, 202/564-0917 or smith.ashley-m@epa.gov.

VSAT™ Software to be Enhanced
NACWA continues its support of water and wastewater utilities through its Vulnerability Self Assessment Tool (VSAT™). The Association is current finalizing discussions with the U.S. Environmental Protection Agency to secure additional funding for sustaining activities in support of the software tool through the term of our current federal assistance agreement (September 30, 2006). As proposed, NACWA would direct the funds to five specific activities:

EPA Releases Guide on Collaboratives
The EPA’s National Homeland Security Research Center (NHSRC) has published Security Information Collaboratives: A Guide for Water Utilities. The purpose of the Guide is to inform both drinking water and wastewater utilities about the benefits of establishing collaborative arrangements with other organizations to share information on water security. The Guide provides suggestions for establishing a collaborative and includes three case studies (utility to utility, utility to public health, and utility to law enforcement) to show how utilities can successfully coordinate with various key water security partners to enhance security and public health protection. Its step-by-step approach is intended to help individual utilities identify and create security-information collaboratives that best meet the needs of their particular situations. The Guide may be downloaded at http://www.epa.gov/nhsrc/news/news051805.htm.

Water Sector Coordinating Council to Review National Infrastructure Protection Plan
The Water Sector Coordinating Council’s (WSCC) leadership and members have been focusing their attention recently on an invitation from the National Infrastructure Advisory Council (NIAC) to engage – on behalf of the sector – in a study group examining the Sector Partnership Model set forth in the Interim National Infrastructure Protection Plan (I-NIPP). The NIAC is a Presidential Advisory Committee, chartered under the Federal Advisory Committee Act (FACA), to advise the President through the Secretary of the Department of Homeland Security. It is comprised of senior executive leadership from a cross-section of the critical infrastructures.

Because the Sector Coordinating Councils are viewed as principal stakeholders in the Sector Partnership Model, input from them will be extremely important to this effort. The NIAC’s goal is to have a cross-sector study group, consisting of the councils’ chairpersons, established to study the entire vertical of the Sector Partnership Model and cross-sector challenges. It is also anticipated that additional study groups will be established for each sector consisting of the members of that sector’s coordinating council to comment on the I-NIPP and Sector Specific Plans (SSP) for the sector.

The recommendations of the Integrated Study Group, comprised of the councils’ chairpersons, will be presented to the full NIAC at their July 12, 2005 meeting. The sector specific Study Groups will have a longer time frame to submit their input on the I-NIPP and SSP to the Working Group. Sector coordinating councils are in no way being placed subordinate to the NIAC nor will participating in this study in any way change their structure or charters.

The WSCC will convene for its next meeting on August 10 – 11 in Washington, DC.

Series of Water Security Workshops Concludes in Chicago
The final in a series of three Water Sector Security Workshops will be held in Chicago, Illinois from July 6-8.
The workshops, convened in Phoenix, Philadelphia, and Chicago, were intended to provide water and wastewater (water sector) utilities and other key stakeholders a mechanism to develop a list of trends and needs to enhance the overall security of the nation. Participants have also helped develop recommendations on how to best meet the identified needs. Representatives from NACWA leadership, staff and members have attended each of the workshops. Interim reports have been prepared after each of the two preceding workshops and are available on the WaterISAC to subscribers (www.WaterISAC.org). Following the Chicago Workshop a final report will be produced for future consideration by the U.S. Environmental Protection Agency, who funded the workshops via a cooperative agreement with the Water Environment Federation.

WaterISAC and WaterSC Continue to Gain Subscribers
The Water Information Sharing & Analysis Center (WaterISAC) continues outreach to new subscribers based on a lower subscription fees for utilities approved last July. Currently the ISAC has 431 subscribers, with just over 1,000 end users. A highly secure encrypted instant messaging and virtual meeting space has been implemented. This will allow WaterISAC subscribers to conduct real time discussions of sensitive security matters.

The WaterISAC’s Water Security Channel (WaterSC) went live last November. This free service provides the U.S. Environmental Protection Agency (EPA) and Department of Homeland Security (DHS ) security notices to a list of vetted, password protected, e-mail recipients. NACWA works closely with the WaterISAC and the WaterSC to continue to assure wastewater systems involvement in the programs. The NACWA summer conference is featured on the home page of the WaterSC, which can be accessed at www.WaterSC.org. The WaterISAC Board of Managers, on which former NACWA President, William B. Schatz serves, recently approved the addition of consultants or firms that specialize in providing service to drinking water and/or wastewater utilities to those eligible to access the WaterSC.

NACWA’s National Office will continue to keep members apprised of new initiative and developments in the security arena.