National Drinking Water
Advisory Council
Water Security Working Group
Findings
Presented to the National Drinking Water
Advisory Council May 18, 2005

-------
TABLE  OF  CONTENTS
Transmittal Memo
Abstract
Executive Summary	i
        Set minimum expectations for security program outcomes, with substantial flexibility for design of utility-
        specific implementation approaches and tactics..  ..     	ii
        Keep security programs fresh and up-to-date, and emphasize inherently more secure practices	  iv
        Create awareness and support for water security	iv
        Invest in water security	     	v
        Form strong, durable partnerships	        ..     	   v
Findings in Sequential Order	vii
        Security	vii
        Incentives	     	      	     ...        	ix
        Measures	          	     .    .      	x
I.    Introduction	1
        Charier and Mission of the Working Group	     	      	  2
        Working Group Composition   	       	      	2
        Security-Sensitive Information 	  3
        The Deliberative Process and Consensus	     	    - 3
        Scope and Application of WSWG Findings	      	4
II.   Security	7
        Approach to Developing Findings on Security	      	7
        Summary of Findings on Security	       	     	8
        One Size Does Not Fit All   	8
        Security Program Scope    	     	        	9
        Significant System Failures and Key Threats    	            	11
        Principles That Support Active and Effective Security Programs  	      .     	      .  .  12
        Security Program Features   	      	    ..13
        Ongoing Improvement	     	     	       	15
        Improve Connections with Public Health	     .   .     	        	16
        Support Development of Contaminant Monitoring Technologies	16
III.   Incentives	17
        Approach to Developing Findings on Incentives	17
        Summary of Findings on Incentives	         	18
        Understanding the Consequences of Failing to Address Security	    ...    .   .18
        Recognition  .   .  . .      	    	         ....  19
        Peer Assistance and Review	       .      	     -    -     ••    -20
        Technical Assistance	        	         	     •   ••    	20
        Access to Security-Related Support and Planning	 22
        Financial Support... .     	        	23
        Rate-Setting Organizations   	      	23
        Regulation	     	     • • 24
IV.   Measures	25
        Approach to Developing Findings on Measures   	     	25
        Attributes of Sound Measures..        	      .       	26

-------
        Types of Measures Considered	
        Summary of Findings on Measures .
        Minimum Measures Utilities Should Use
        Measures for Utilities to Consider
        National Aggregate Measures  	
        Other Measures Considered  .
        Reporting  	
                                                                              .26
                                                                               27
                                                                               27
                                                                               28
                                                                               29
                                                                              .34
                                                                               34
Appendix A
Appendix B

Appendix C
Appendix D
Features and Measures of an Active and Effective Security Program
Chart Showing  Features of an Active and Effective Security Program and  Corresponding
Measures that Utilities Should Use
Measures Utilities Should Consider
Individual Comments of WSWG Members
Attachment 1    Roster of WSWG Members, Federal Resource Personnel, and Outside Experts
Attachment 2   WSWG Operating Procedures
Attachment 3   Annotated Bibliography of Secunty References
Attachment 4   Acronym List

-------
TO:          National Drinking Water Advisory Council

FROM:       Membership of the NOW AC Water Security Working Group

DATE:       May 18, 2005

SUBJECT:    Final WSWG Water Sector Security Findings
The Water Security Working Group (WSWG) is pleased to present these final consensus findings to the
National Drinking Water Advisory Council (NOWAC)

The WSWG represents a wide range of interests and perspectives on water security  The 16 members of
the WSWG include representatives of public and private, small, medium, and large water and wastewater
utilities,  public  health  advocates  and  regulators, and  environmental and  public  health  interest
organizations  Dr Rebecca Head of Monroe County Health Department (also a NDWAC member) and
David Binning of Fairfax Water ably served the WSWG as co-chairs  In addition to Dr.  Head, NDWAC
members on the WSWG were John Young of American Water Works Service Company, Inc , and Jack
Betkoski of the Connecticut Department of Public Utility Control

The WSWG understands that our work is now over, and that the full Council will review our findings and
may make revisions before making recommendations to EPA's Administrator  In previous reports to
EPA, the Council has descnbed any substantial revisions it makes to working group findings; if possible,
we would very much appreciate if this approach could be used to descnbe  any major revisions you might
make to our findings so we can better understand the Council's views

The NDWAC charged us to

•   Identify, compile, and characterize best security practices and policies for drinking water and
    wastewater utilities and provide an approach for considering and adopting these practices and policies
    at a utility level;
•   Consider mechanisms to provide recognition and incentives that facilitate a broad and receptive
    response among the water sector to implement these best security practices and policies, and make
    findings as appropriate, and
•   Consider mechanisms to measure the extent of implementation of these best security practices and
    policies, identify the impediments to their implementation, and make findings as appropriate.

We make 18 findings in response

Security
Findings 1 through 6 establish a consistent expectation for what constitutes an "active and effective"
water security program and  identify 14 features that all active and effective security programs should
share.  Our deliberations emphasized the need for balance between providing the water sector with a more
consistent basis for moving forward with security enhancements and avoiding in any way prescribing the
specific security countermeasures individual utilities should use  We characterize this balance as focusing
on the "what" not the "how"  of security and state clearly that, m the realm of security, "one size does not
fit all."  Findings 7 and 8  address forging closer partnerships between the utility  and public health
communities and  development  of  practical,  affordable  contamination  surveillance  and monitoring
technologies

-------
Incentives.
Findings 9 through IS call on EPA, DHS, state agencies, utility trade associations, and others to create
incentives for development and maintenance of security programs  Many incentives involve education,
such as education to raise utility awareness about the benefits of security enhancements and the potential
liability resulting from a failure  to address security,  and education to ensure that organizations which
influence  utility  costs and  revenues (e g, rate  and fee  setting organizations) understand security
imperatives.  Other incentives involve targeted technical assistance, creation of programs for utility peer-
to-peer assistance and review, and support for inclusion of water utilities in security-related planning and
exercises.  We also appeal to  Congress,  EPA,  and DHS to increase grant and loan funding for water
security.

Measures
Findings 16  and 17 address measurement of  individual security program progress.   We recommend
"core" measures  for use by all  utilities  during annual  self-assessments of security  progress, and we
provide an additional suite of sound measures for utilities to consider.

In Finding 18 we propose three areas of sector-wide, national aggregate  measurement   (1) progress
implementing "active and effective" security programs, as measured by the degree of implementation of
the 14 features of active and effective security programs, (2) progress reducing the number  of assets
identified as a high security risk measured using the results of vulnerability assessments, and (3) progress
reducing the  inherent nsk potential  of utility  operations measured by Clean Air Act Section 112(r)
reporting on hazardous substances and by the number of utilities  that convert from use of gaseous
chlorine to other forms of chlorine or other treatment methods  Except for  the measure based on 112(r)
data, we envision national measures will initially rely on a utility  self-assessment and request  that  EPA
work with the water  sector and stakeholders  to explore options for enhancing the consistency and
credibility of national measures through peer review, 3rd party verification, blind surveys, or other more
independent  assessments   To address concerns about  the  inappropriate  release of individual utility
security sensitive information, we believe EPA  should publish national measures on a strictly aggregated
basis and ensure appropnate confidentiality for submitted data.

Our findings reflect a  consensus  of the diverse perspectives of the WSWG on important water security
program attributes, reached after a systematic effort involving hundreds of hours of work.  We are asking
you to review our findings in light of the arduous process and the delicate nature of reaching consensus

The WSWG greatly appreciates this  opportunity to contribute to water security progress and  we thank
you for allowing us to server  We welcome the NDWAC's review of our work and look forward to your
response

-------
ABSTRACT
The Water Security Working Group (WSWG) was  charged by the  National Drinking Water Advisory Council
(NDWAC) with developing findings on security practices, incentives, and measures. The sixteen members of the
WSWG include representatives of small, medium, and  large  water and wastewater  utilities,  public  health
advocates and regulators, and environmental and public health  interest organizations  The findings contained
in the WSWG document reflect a consensus of these diverse perspectives.

The WSWG presents eighteen  consensus findings.  Findings  1 through 6 establish a consistent expectation for
what constitutes an "active and effective" water sector security program and identify fourteen  features that all
active  and effective security programs should share.   These findings create a balance  between providing the
water sector with a more consistent basis for moving forward with security enhancements and avoiding in any
way  prescribing  the specific security countermeasures  individual utilities should use   In the realm of security,
"one size does not fit all."  Findings 7 and 8 address forging closer partnerships between the utility and public
health communities  and  development  of  practical,  affordable contamination  surveillance  and monitoring
technologies

Findings 9 through  15 call on  EPA,  DHS,  state agencies, utility  trade associations,  and  others  to create
incentives for development and maintenance of security programs,  including: educational efforts to raise utility
awareness about both the benefits of security enhancements and the potential liability resulting  from a failure to
address security,  and to ensure that organizations which influence utility costs and revenues (e g., rate and fee
setting organizations) understand security imperatives; targeted  technical assistance, creation  of programs for
utility peer-to-peer assistance and review, and support for inclusion  of water utilities in security-related planning
and exercises. They also appeal to Congress, EPA, DHS, and other federal agencies to increase grant and loan
funding specifically focused on water sector security.

Findings  16  and 17 address  measurement of individual secunty  program  progress    They identify  "core"
measures for use by all utilities during annual self  assessments of security progress, and provide an additional
suite of measures for utilities to consider

Finding 18 proposes three areas of sector-wide, national aggregate measurement-  (1) implementing  "active
and effective" security programs as measured by the degree of implementation of  the fourteen features of active
and effective security programs, (2) reducing security risks measured by the total number of assets determined to
be a high security risk and the number of former high  secunty risk assets lowered  to medium or low risk, based
on the results of vulnerability assessments, and (3) reducing the  inherent risk  potential of utility  operations
measured by Clean Air Act Section 112(r) reporting on hazardous substances and by the number of utilities that
convert from  use of gaseous chlorine  to  other forms of chlorine or other treatment  methods   The Group
encourages EPA to work with the water sector and stakeholders to explore options for enhancing the consistency
and credibility of national measurement through peer review, third party verification, blind surveys, or other more
independent  assessments.  To  address  concerns about the  inappropriate release of individual  utility security-
sensitive information, the WSWG encourages EPA to  publish national measures on a strictly aggregated basis
and ensure appropriate confidentiality for submitted data
 Water Secunry Wof-pq G'roup ^na^gs Presetted to •'is Noiionoi Dr'planq Water Ad^sory 'Zounc:! 5/1G'05

-------
Water Secumy vVo""nq Group F-na-ngs  fYewmd to The Ncironal Dr.pkmc Warer Ad^'Sory Council 5/16/05

-------
EXECUTIVE SUMMARY
Nationwide, there are over 160,000 public water systems  Together, these systems provide drinking water to
over 300 million people. Public and private wastewater treatment systems serve approximately 75 percent of the
U.S population.  Drinking water and wastewater systems are cntical to the security of the United States because
they deliver needed drinking water supplies and wastewater collection and treatment services and support the
many vital services, such as fire suppression, that rely on a stable supply of water. An attack or even a credible
threat of an attack on water infrastructure could seriously jeopardize the public health and economic vitality of a
community

In fall 2003, the National Drinking Water Advisory Council (NDWAC) chartered  the Water Security Working
Group (WSWG or "the Group") to develop  findings on security practices and  programs,  incentives for broad
adoption of security practices in  the  water sector, and measures to gauge the extent of implementation of
security practices  The  Group was comprised of sixteen members representing  a broad range of perspectives
related to water sector secunty, including participants from large and  small drinking  water and wastewater
treatment providers, rate setting organizations, technical assistance providers, the public health community at the
state and local level, academia, and  community interest groups.  The WSWG  was supported by a  number of
resource  personnel  from federal  agencies  with  interest  and  expertise in  water security   These included
representatives from the U S  Environmental Protection Agency (EPA), Department of Homeland Security (DHS),
Department of Defense (DoD), and the Centers for Disease Control  and Prevention (CDC)  The  WSWG also
was supported by outside experts, including an expert in emergency preparedness and response nominated by
the National Emergency Management Association.

The WSWG met seven  times in person and by conference call between July 2004 and April 2005   Notices of
meetings were published in  the Federal Register in advance of meetings and calls.  Except when security-
sensitive  information was discussed, meetings were open  to the public,  and opportunities for public comment
were  provided at each  meeting   The Group found that, in general, they could accomplish their  deliberations
without discussion of security-sensitive information, and had only two closed sessions throughout the duration of
their deliberations  They used a consensus-based, collaborative problem-solving approach to develop findings
In the few instances where the Group did not reach consensus, the range of views of the Group with respect to
that issue is described

The WSWG makes  eighteen findings dealing with security practices  and programs, incentives, and measures.
Findings  address the basic scope and principles for active and  effective  security programs, establish significant
system failures and key threats that security programs should consider, identify fourteen features that all active
and effective security programs should address, advise steps that government  and others can take to  support
and encourage  utility security efforts  and create  a better climate for secunty,  and describe a framework for
measuring utility  security progress.   Because the WSWG is made  up of  many  stakeholders from  different
perspectives, these findings  are endorsed by a wide range of interested  parties,  including small and  large
utilities, public health advocates and  regulators, first responders, and environmental and  public health interest
organizations.  The WSWG  expects its findings to be considered in that light when they are taken up by the
NDWAC.

Five themes cut  across the WSWG's findings and serve as the organizing structure for this executive summary
Readers  are encouraged to go beyond the executive summary  to  the discussion of each finding in  the  full
document to understand the depth and context of the WSWG's deliberations and findings

Water Securcy Wor'-nq Croup F'nc-rgs rreset:«l to The Ncisona! Drnking Wafer Ad>'.sory Council 5/18/05                 Page •

-------
Set minimum  expectations for
security program  outcomes, with
substantial flexibility for design
of utility-specific implementation
approaches and tactics

Finding  1  establishes  the expectation  of
consistent security  outcomes, with significant
flexibility to  tailor  secunty  approaches and
tactics to  utility-specific circumstances and
operating conditions    finding 2 addresses
the scope  of active  and  effective  security
programs,   and  emphasizes  the  need  for
programs  to address  protection of  public
health,  safety, and confidence   Finding  3
describes  the  potential  significant  system
failures and key threats that  utilities  should
consider  when   developing   active  and
effective  security programs, and Finding  -I
lists  principles  utilities  should  use as they
develop   their   utility-specific   active  and
effective  security programs

The centerpiece of the  WSWG's findings  is
identification  of fourteen   features  that all
active and effective security programs  should
address,   and   a   corresponding   set   of
suggested  program measures.   Fpwiiiis>  5
establishes  the fourteen  features  of  active
and  effective  security  programs,  each  of
which are described in detail m Appendix A
The  text box  at  the right summarizes  the
features  of  active  and  effective  security
programs    Finding  M identifies  measures
that  correspond to the  program  features.
The  Group  expects these  measures  to be
used  by all  utilities  to  form  the basis for
utility-specific  security  self-assessment  and
measurement   programs      Finding   17
encourages  utilities to  consider  a  list  of
additional  measures that could  be used to
round out security measurement programs.
     Features of an Active and Effective Security Program

1   Make  an explicit  and  visible  commitment  of the  senior
    leadership to secunty
2.  Promote secunty awareness throughout the organization.
3.  Assess  vulnerabilities  and   periodically  review  and  update
    vulnerability assessments to  reflect changes in potential threats
    and vulnerabilities
4   Identify secunly priorities and, on an annual  basis, identify the
    resources dedicated to secunty programs and planned secunty
    improvements, if any.
5   Identify  managers and  employees who are  responsible for
    secunty and establish security expectations for all staff.
6.  Establish  physical and procedural controls to restrict access to
    utility infrastructure to only those conduding authorized, official
    business and to detect unauthorized physical intrusions
7   Employ protocols for detection of contamination consistent with
    the recognized limitations  in current contaminant detection,
    monitonng, and surveillance technology
8   Define  security-sensitive  information, establish physical and
    procedural  controls  to  restrict  access to  security-sensitive
    information  as appropriate, detect unauthorized access, and
    ensure  information and communications systems will function
    during emergency response and recovery
9.  Incorporate   secunty  considerations   into   decisions  about
    acquisition,  repair,  mapr maintenance, and replacement  of
    physical  infrastructure; this  should  include  consideration  of
    opportunities to reduce nsk through physical hardening and the
    adoption of inherently lower  nsk design and technology options
10  Monitor  available threat-level information,  escalate security
    procedures in response to relevant threats
11  Incorporate  secunty considerations into emergency response
    and recovery plans, test and review plans regularly, and update
    plans  as necessary to  reflect changes in  potential threats,
    physical    infrastructure,    utility     operations,    cntical
    interdependences,  and  response   protocols   in  partner
    organizations.
12  Develop and implement strategies for regular, ongoing secunty-
    related   communications    with    employees,   response
    organizations, and customers
13  Forge reliable and collaborative partnerships with  communities,
    managers of cntical interdependent infrastructure, and response
    organizations.
14. Develop  utility-specific  measures of  secunty activities and
    achievements,  and self  assess  against these  measures  to
    understand and document program progress
As a complement to the identification of consistent secunty program outcomes through descriptions of security
program  scope, principles,  features, and measures,  the WSWG also  emphasizes  the need  for significant
flexibility to tailor security approaches and tactics to utility-specific circumstances and operating conditions, such
as size, location, water source,  technology, budget, political  support, and legal constraints   These and other
Water Secunty \Vor--.ng Group F.nd.r.gs  Preie^'ed to the Noiionai Drinking Water Adt'tscry Council 5/18/05
                                                     Pag?.

-------
utility-specific circumstances  and  operating conditions must  inform development of specific security tactics.  A
rigid  approach  that requires a certain type  of fence or other access  control,  or a  prescribed  information
technology protection system or a standard set of personnel security policies would, automatically, over-address
security needs for some utilities and under-address security needs for other utilities


The WSWG sees findings  on security program scope, significant  threats and major consequences, principles,
and features coming  together to inform individual  utilities' development of utility-specific security  approaches
and tactics   That  is,  in  developing security  programs specifically tailored  to their specific  circumstances and
operating conditions,  utilities will address each program feature in  light of the program scope, significant threats
and major consequences,  and  principles described by the WSWG.  In later findings on measures, the WSWG
has equipped utilities to consistently measure their  individual progress and  support the emergence of national
aggregate measures of sector-wide progress.   Incentives encourage security progress by creating a  climate that
is friendly to utility secunty efforts. The figure below  illustrates this relationship
   Security Program
      Scope

   Recommendation 2
   Secunty Prog ram
     Principles

   Recommendation 3
 Significant Failures S
     Key Threats

   Recommendation 4
 Features of an
   "Active and
    Effective"
Security Program

Explicit commitment to
secunty
Security culture
VA up to date
Security resources and
implementation priorities
Defined secunty roles and
employee expectations
Intrusion detection &
access control
Contamination detection
Information protection &
continuity
Design and construction
standards
Threat-level based
protocols
ERP tested and up to dale
Communications
Partnerships
Utiity-specrfic measures
and self assessment
                       Recommendations
                              1and5
                                                               Incentives

                                                       Faditate broad and receptive response to
                                                          secunty program implementation

                                                             Recommendations 9-15
   Utility-specific security
 programs address program
   features and measures
  tailored to utility-specific
circumstances and operating
         conditions
                              National Aggregate Measures

                              •Features implementation
                              +Hgh-nsk assets
                              ••Inherent risk

                                      Recommendation 18
                                           Utility-Specific
                                             Measures
Measures All Utilities
   Should Use

 Recommendation 16
                                            Measures Utilities
                                            Should Consider

                                           Recommendation 17
 Water Secunry vVortjpq Group F.r-a.ivjs  Presented to '.he Noiionai Dr-nking Wafer Advisory Council S/ifi/OS
                                                                                      Page i

-------
Keep security programs fresh and up-to-date, and emphasize inherently more
secure practices

Security programs will change over time  The features and measures of active and effective security programs
identified by the WSWG in Findings 5 and 1C emphasize the importance of keeping assessments of vulnerabilities
and  emergency  response plans up-to-date as  "living" documents  They also  stress  the need for ongoing
attention to  security in  annual planning and budgeting,  and  the need  to update utility-specific security
approaches and tactics to incorporate lessons learned from tabletop and field exercises, and from any actual
responses  Security program features and measures also emphasize the need for utilities to take advantage of
opportunities to  improve security through use of plant design and operating choices that are inherently more
secure or that lower the likelihood or potential consequences of a successful attack.  Application of inherently
safer designs and operating procedures dunng plant construction, upgrades, and major maintenance activities
may be the most efficient way for utilities to, over time, improve security   Finally,  the security  program features
and  measures stress that, as technological and other advances give utilities opportunities  to improve security
they should  be  seized.  Finding  6  addresses  this  need directly,  by calling on utilities to use  a continual
improvement approach to learn from  implementation of security programs and to enhance security over time
Create awareness and  support for water security

In some ways, the water and wastewater utility industry is the silent critical infrastructure  In many communities,
even after the terrorist attacks of September 11, 2001, there may be little awareness  of the need to protect
critical water and wastewater assets.  The WSWG strongly believes that utilities need help creating awareness of
the importance of water security, both within the industry and in the communities they serve.  Utilities, especially
small systems with limited resources,  also need a support system to help identify and implement practical, cost-
effective security programs.

F\ndmg 9 calls on  EPA, DHS, state  agencies, and water  and wastewater  utility organizations to provide
information  on the importance  of active and effective security programs to utilities, and to make utilities more
aware of the  benefits  of active and effective security programs  and the  potential negative consequences of
failing to address secunty  I'ineiing 10 addresses recognition of security programs  J-'mdinx ii calls on  EPA and
others to build  on  existing successful peer  review  and assistance programs, such as the Rural  Community
Assistance Partnership program  and the Georgia/National Rural Water Association Small System Peer Assistance
Team, to  establish a peer assistance  and review system for utility security. Advice from a trusted peer will often
be the most  practical, affordable, and relevant way to deliver much needed help and support for security efforts,
especially in small systems.  Findings !2 
-------
Reduction in the inherent risk  potential  of utility operations as  measured  by Clean Air Act Section 112(r)
reporting on hazardous substances and by  the number of utilities  that convert from use of gaseous chlorine to
other forms of chlonne or other treatment methods

The three potential national aggregate measures identified by the  WSWG would be presented in an aggregate
basis only (i.e., individual facility results would not be available)
Invest in water security

Security will not improve without investment of time, attention, and money on the part of all partners. Finding 8
calls on government to support and facilitate development and distribution of reliable, affordable contaminant
monitoring technologies  This is critical to improve the security of distribution systems and to enable the water
sector to develop effective monitoring  and surveillance strategies that include more than reliance on monitonng
of public  health anomalies to identify potential  water  contamination   1'iidinp  i-l  calls  for additional, direct
financial support of utility secunty efforts, and Finding 15 stresses the importance of  education and information
for utility oversight boards  and rate-setting agencies, so reasonable  costs of utility secunty can  be included in
utility rates in a timely way.
Form strong,  durable partnerships

Finally, throughout their deliberations, the WSWG returned to the need to support secunty with strong, durable
partnerships  Utilities  will  not, and  should not, accomplish security alone   They must work within the larger
secunty and response communities and with their customers to improve security.  The features and measures of
active and effective security programs identified by the WSWG in Finding* J and //""describe the importance of
utilities forging connections with local law enforcement, first responders, the public health community, and with
the  communities  and consumers  they  serve   In particular,  the WSWG emphasizes the importance of
partnerships with communities in enhancing public confidence in utilities, improving the effectiveness of security
by  relying on communities  to  notice and report suspicious  events, and increasing public support for utility
secunty efforts.  The WSWG was also particularly interested in improving partnerships between utilities and the
public health  community  F,nditig 7 addresses this interest  specifically by calling  for stronger relationships
between water and wastewater utilities and the public health community
 Water Secure-/ vVor'.ng Group F.nci..-gs  Praceited to :he Nanona! Dr-pk:ng Warer Adi-scry Council 5/18/05

-------
Water Secunfy vVor".nq Group Fina-pqs - Pressmed to The Nci:onoi Dr.nk:ng Wafer Ad*«cry -Council 5/1G/05                   Page v.

-------
FINDINGS  IN  SEQUENTIAL ORDER
Security

Finding 1:  Water and wastewater utility security programs should achieve consistent outcomes using utility-
specific tactics  and implementation approaches that are tailored to individual utilities'  circumstances  and
operating conditions

Finding 2:   Active and effective security programs should address protection of public health,  public safety
(including infrastructure), and public confidence

Finding 3:  Active and effective security programs should consider six significant system failures  and four key
threats, as described below

    Significant System Failures

    1   Loss of pressurized water for a significant part of the system.
    2   Long-term loss of water supply, treatment, or distribution
    3.  Catastrophic release or theft of on-site hazardous chemicals affecting public health
    4   Adverse impacts to public health or confidence resulting from a contamination threat or incident
    5   Long-term loss of wastewater treatment or collection capacity
    6   Use of the collection system as a means of attack on other targets.

    Key Threats

    1   Physical disruption of core facilities, such as chemical storage, or interdependent infrastructure, such as
        power and transportation, either through direct physical targeting or as a  result of collateral damage
    2   Chemical, biological, or radiological material used to contaminate water supplies or infrastructure.
    3   Cyber attack on information technology assets to disrupt service and/or obtain confidential information
    4.  Use of conveyance tunnels or storm, sanitary, or combined sewers to stage an attack against utilities or
        other targets

Finding 4:  Active and effective security programs should be built around eleven pnnciples, as described below

    1.  Secunty should be part of organizational culture and the day-to-day thinking of front-line employees,
        emergency responders, and management.
    2   A strong commitment to security by organization leadership and by the supervising body, such as the
        utility board or rate-setting organization, is critical to success
    3   There is always something that can be done to improve security Even when resources are limited, the
        simple act of increasing organizational attentiveness to security will reduce threat potential and increase
        responsiveness. Preparedness itself can help deter attacks.
    4   Prevention is a key aspect of enhancing security.
    5   Movement towards practices that are inherently safer (i e , have a lower risk potential) may enhance
        security.
 Water Secure} \Vor--.pg Group. f-tia-r.qs  PraseTfd to Trie NcTiona: Dr-pkinc Warer Adv«ory CouncM 5/18/05                Poge •/••

-------
    6   Security programs require ongoing management and monitoring, and an ongoing budget commitment
        A continual reassessment model, where changes are implemented over time as experience with security
        increases, may be useful.
    7.   Consideration of security issues should begin as early as possible in facility construction (i e., it should
        be a factor in building plans and designs)
    8   The relationship between practices that increase safety and those that increase security must be
        recognized and managed. Safety and security may complement each other, may be neutral, or may
        conflict.  For example, a supervisory control and data acquisition (SCAOA) system provides valuable
        operating safety information, but may also introduce a vulnerability that someone could use to cause
        harm or mislead operators.  Similarly, permanently locking a door for security reasons might create a
        safety barrier to an emergency exit
    9   Strong relationships with response partners and the public strengthen security and public confidence
    10. Investment in security should be reasonable considering utilities' specific circumstances  Where  threat
        potential or potential consequences are greater, greater investment is likely warranted
    11  Develop security programs in a way that helps communities understand the need for a security program
        and the utility's overall security management approach, consistent with the need to hold  security
        sensitive information (i e , attributable information about utility-specific vulnerabilities and security
        tactics) closely.

Finding 5:  Active and effective security programs  should include fourteen features, described below.

    1   Make an explicit and visible commitment of the senior leadership to secunty.
    2   Promote security awareness throughout the organization.
    3.   Assess vulnerabilities and periodically review and update vulnerability assessments to reflect changes in
        potential threats and vulnerabilities.
    4   Identify security priorities and, on an  annual basis,  identify the resources dedicated to security programs
        and planned security improvements,  if any
    5.   Identify managers and employees who are responsible for security and establish secunty expectations
        for all staff.
    6.   Establish physical and procedural controls to restrict access to utility infrastructure to only those
        conducting authorized, official business and to detect unauthorized physical intrusions
    7.   Employ protocols for detection of contamination consistent with the recognized limitations in current
        contaminant detection, monitonng, and surveillance technology
    8   Define security-sensitive information, establish physical and procedural controls to restrict access to
        security-sensitive information as appropriate, detect unauthorized access, and ensure information and
        communications systems will function during emergency response and recovery
    9   Incorporate security  considerations into decisions about acquisition, repair, ma|or maintenance, and
        replacement of physical infrastructure, this should include consideration of opportunities to reduce risk
        through physical  hardening and the adoption of inherently lower-risk design and technology options
    10 Monitor available threat-level information; escalate security procedures in response to relevant threats
    11  Incorporate security  considerations into emergency response and recovery plans,  test and review plans
        regularly, and update plans as necessary to reflect changes in potential threats, physical infrastructure,
        utility operations, critical interdependences, and response protocols in partner organizations.
    12. Develop and implement strategies for regular, ongoing security-related communications with
        employees,  response organizations, and  customers.
    13 Forge reliable and collaborative partnerships with the communities, managers of critical interdependent
        infrastructure, and response organizations.
Water Secunry vVoH-jng Group ?.r.a.r.qs  Prewred to :'te NCTSOPQ! C5r.pk:nc Wa:er Advisory Council J/l8/05                Paae VM

-------
    14  Develop utility-specific measures of security activities and achievements, and self assess against these
        measures to understand and document program progress

Finding 6:  Water and wastewater utilities should reassess and seek to improve their security programs on an
ongoing basis

Finding 7:  Relationships between the water and wastewater utility sector and the public health sector should be
strengthened.

Finding 8:   Development and  distribution of reliable, affordable contaminant monitoring technologies is
important to improving utility security and should be facilitated and supported by government
Incentives

Finding 9:  EPA, DHS, state agencies, and water and wastewater utility organizations should provide information
on the importance of active and effective security programs to utilities, and should make owners and operators
more aware of the benefits of active and effective security programs and of the potential  negative consequences
of failing to address security

Finding 10: EPA, DHS, state agencies, and water and wastewater utility organizations should develop programs
and/or awards that recognize utilities that develop and maintain active and effective security programs, and that
demonstrate superior security performance.

Finding  11:   EPA,  DHS, state  agencies,  and water  and wastewater  utility  organizations  should  support
development and implementation of a voluntary utility security peer technical assistance and review program

Finding 12:   EPA,  DHS,  state agencies, and water and  wastewater  utility organizations  should help  utilities
develop active and  effective  security  programs by providing different types of  technical  assistance, including
technology verification information

Finding 13: EPA, DHS, and other federal and state agencies should support utility security programs by helping
utilities obtain access to needed security-related support systems and infrastructure, and  by supporting inclusion
of utilities in security exercises

Finding 14:  Congress, EPA,  DHS and other federal agencies should support secunty enhancements with grant
and loan programs focused on security.

Finding 15:  Utility governing bodies  should recognize costs associated with implementing active and effective
security programs   EPA,  DHS, state agencies,  and utility  organizations should  provide educational  and other
materials to boards and rate setting organizations to help them understand security costs
 Water Secunry tVoi*wq Group F-na-*qs "resfised to :he No::ona! Drinking Wa:er Ad^so-y Couicsl 5/18/05                 Cajse

-------
Measures

Finding 16:  At a minimum, utility self assessment and measurement should include thirteen measures, described
below

     1.  Does a written, enterprise-wide security policy exist, and is the policy reviewed regularly and updated as
        needed?
     2   Are incidents reported in a timely way, and are lessons learned from incident responses reviewed, and
        as appropriate, incorporated into future utility security efforts?
     3   Are reassessments of vulnerabilities made after incidents, and are lessons learned and other relevant
        information incorporated into secunty practices?
     4.  Are security priorities clearly identified, and to what extent do security priorities have resources assigned
        to them?
     5   Are managers and employees who are  responsible for secunty identified?
     6   To what extent are methods  to control access to sensitive assets in place?
     7   Is there a protocol/procedure in place to identify and respond to suspected contamination events?
     8   Is there a procedure to identify and control security-sensitive information, is information correctly
        categorized, and how do control measures perform under testing?
     9.  Is there a protocol/procedure for incorporation of security considerations into internal utility design and
        construction standards for new facilities/infrastructure and major maintenance projects?
     10  Is there a protocol/procedure for responses to threat level changes?
     11. Do exercises address the full range of threats—physical, cyber, and contamination— and is there a
        protocol/procedure to incorporate lessons learned from exerases and actual responses into updates to
        emergency response and recovery plans?
     12. Is there a mechanism for utility employees, partners, and the community to notify the utility of suspicious
        occurrences and other security concerns?
     13. Have reliable and collaborative partnerships with customers, managers of independent interrelated
        infrastructure, and response organizations been established?

Finding 17:   In developing their  self-assessment and  measurement programs, water and  wastewater utilities
should consider the security program measures listed in Appendix C

Finding 18:  EPA should  consider  three potential  measures  of national, sector-wide, aggregate  progress
described below

     1   Implementation of "active and effective" secunty programs as measured by the degree of
        implementation of the fourteen  program features and corresponding feature-specific measures
        suggested by the WSWG
     2    Reduction in security risks as measured by the total number of assets determined to be a high security
        nsk and the number of former high security risk assets lowered to medium or low nsk, based on the
        results of vulnerability assessments
     3   Reduction in the inherent risk potential of utility operations as measured by Clean Air Act Section 112(r)
        reporting on hazardous  substances and by the number of utilities that convert from use of gaseous
        chlorine to other forms of  chlorine or other treatment methods
Water Security Wori'-nq Croup F.nd.r-gs  "resen^d to The Nctiona! Drinking Wafer Adv.so.-v Council 5/1G/05                 Page >

-------
        INTRODUCTION
Nationwide, there are over 1 60,000 public water systems Together,  these systems provide drinking water to
over 300 million people.  Wastewater treatment systems serve approximately 75 percent of the U.S  population
These systems are critical to the security of the United States not only because they deliver needed drinking water
supplies and wastewater collection and treatment services, but also because they support the many vital services,
such as fire suppression, that rely on a stable supply of water. An attack, or even a credible threat of an attack,
on water infrastructure could seriously jeopardize the public health and economic vitality of a community

As with other critical infrastructure sectors, concern over security at water utilities increased dramatically after the
September 11,  2001  terrorist attacks on the  World Trade  Center and  the Pentagon  Immediately after the
attacks, the U S. Environmental Protection Agency (EPA) and the  drinking water and wastewater  industries
launched  a  number of initiatives to develop training and guidelines on water security.  As part of this effort,
initial support was provided for development  of methodologies and training for community water systems on
assessment of water system vulnerabilities and development  of emergency response plans.  Ongoing efforts to
create the Water Information  Sharing and Analysis Center (WaterlSAC),  a secure system  used to  disseminate
security alerts and allow water  and wastewater utilities to exchange ideas about  security related  issues, were
accelerated  In June 2002, President Bush  signed the Public Health Security and Bioterronsm Preparedness and
Response  Act (Bioterronsm Act)   Among  other things, the  Bioterronsm Act  requires each community water
system that serves more than 3,300 individuals to conduct "an assessment of the vulnerability of its system to a
terrorist attack or other intentional acts intended to substantially disrupt  the ability of the system to provide a safe
and reliable supply of drinking  water."  The Bioterrorism Act also requires preparation—or where necessary,
revision—of "an emergency response plan that incorporates the results of vulnerability assessments."

Investment in water security efforts, both  public and private,  also increased after September 11, 2001. In fiscal
year 2002,  EPA awarded  approximately $51  million in grants to help the largest community  water  systems—
those serving populations greater than 100,000—to complete vulnerability assessments.  Since 2002, EPA has
provided over $150  million in support for development of water secunty related tools, training, and technical
assistance to the water sector,  states, and other supporting  partners

As of the writing of this document, 100 percent of large and medium utilities and 93 percent of small community
water systems covered by  the Bioterronsm Act have completed vulnerability assessments, and  100 percent of
large systems, 94  percent of  medium systems,  and 79 percent of  small  systems have completed emergency
response  plans.   While this represents real  progress,  much  work  remains  to  be done.   Understanding
vulnerability is only the first step in improving security   Many water systems that have completed  vulnerability
assessments are now considering what  steps to take  to  address their vulnerabilities  In the  proliferation of
security-related guidelines, products, services,  and consultants that have appeared since September 11, 2001,
water utilities are faced with a complex set of  decisions about how best to invest what will inevitably  be limited
security funding.  In this context, the National  Drinking Water Advisory Council (NDWAC), in consultation with
EPA,  chartered  the Water  Secunty Working Group  (WSWG or "the Group") to provide a forum for the  many
diverse security-related interests to provide much needed guidance for NDWAC and EPA security-related efforts
Water Security vVor'.pg Group F.nd.r.gs  "raiei-ed to The Ncmonol Dr-nking Wa:er Aj/-sory Council 5/10/05                 fogs 1

-------
Charter and Mission of the Working Group

The WSWG was established and charged by the NDWAC, an independent federal advisory council under the
Federal Advisory Committee Act.   The NDWAC advises,  consults with,  and makes findings related to EPA's
activities, function, and  policies under the Safe Dnnkmg Water Act   From time to time,  the NDWAC forms
working groups to deliberate on a specific area of interest and to report back to the Council  The WSWG is one
such group.  The NDWAC directed  the WSWG to.

Identify, compile, and characterize best security practices and policies for drinking water and wastewater utilities,
and provide an approach for considering and adopting these practices and policies at a utility level;
Consider mechanisms to provide  recognition and  incentives that facilitate a broad and receptive response
among  the  water sector to  implement these  best security practices and  policies,  and make  findings  as
appropriate, and
Consider mechanisms to measure  the extent of implementation of these best security practices and policies,
identify the impediments  to their implementation, and make findings as appropriate

Early  m their deliberations,  the WSWG rejected use of  the term "best" to describe their work on security
practices.   The Group  was concerned that defining  "best" security practices would  seem too  much like  a
prescription  of specific activities across the water and  wastewater sector.  Given the  variety of utility-specific
circumstances and operating conditions that exist in the water and wastewater sector, the WSWG rejected the
notion that such a prescription could be developed, or if developed, fulfilled  Instead, the Group chose to make
findings identifying and describing the scope, principles, and features of "active and effective" secunty programs,
and to make related findings on improving the climate for water and wastewater security  Otherwise, the Group
did not amend or modify its  charge  from the NDWAC.
Working Group Composition

The WSWG was  made up  of sixteen  members  representing  a broad range of water security  perspectives.
WSWG membership included participants from  large and small drinking water and  wastewater treatment
providers, rate setting organizations, technical assistance providers, the public health community at  the state and
local level, academic, and environmental interest groups.  Group members were selected by EPA from among
more than 80 nominated individuals.  Selections were made considering the expertise and experience needed to
provide advice on  best security practices,  incentives,  and measures, and the desire  to provide balanced
representation across the water sector  To facilitate communication between the NDWAC and the WSWG,  three
members of the NDWAC were appointed to the WSWG  Because the WSWG is made up of many stakeholders
from different perspectives, these findings are endorsed by a wide range of interested parties, including small
and large utilities, public health advocates and regulators, first responders, and environmental and  public health
interest organizations. The WSWG expects its findings to be considered in that light when they are taken  up by
the National Drinking Water Advisory Council.

The WSWG was supported by a number of resource personnel from federal agencies with interest and expertise
in  water security.  These included representatives from EPA, the  Department of Homeland Security (DHS), the
Department of Defense (DoD), and the Centers for  Disease Control and Prevention (CDC)  The WSWG also
was supported by outside experts, including an expert in emergency preparedness and response nominated by
the National Emergency Management Association. Federal resource personnel  and outside experts participated
in  WSWG  deliberations by providing background, context, or other information or expert opinion, as called

Water Securry WoD'-pq Group Find.r.gs   Presented tc The Nc:;onai Dr.pk:-.o Wa;er Advisory Council 5/18/05                 Poos 2

-------
upon to do so by a member of the WSWG or the facilitation  team  Federal resource personnel and outside
experts did not participate in WSWG decision making

A roster of WSWG members, federal resource personnel, and outside experts is provided as Attachment 1.
Security-Sensitive Information

The WSWG established special procedures for deliberations on security-sensitive information.  For purposes of
their deliberations, the WSWG agreed that security-sensitive information would be identified as

>   Information on system-specific, attributable tactical security procedures; or
>   Integrated or aggregated detail on security (e g , by aggregating information from previously un-aggregated
    sources) that creates a clear picture of a specific targeting or attack opportunity.

Information already available in the public domain in the same form and at the same level of detail as discussed
by the WSWG was not considered security sensitive.

WSWG meetings were closed to the public  as necessary to provide a forum for WSWG members to discuss
security-sensitive information   Protocols for closure of WSWG meetings to the public and discussion of security-
sensitive information are included in Attachment 2, WSWG Operating Procedures.  The WSWG agreed that, to
maximize the usability of their document, they would strive to limit inclusion of security-sensitive information in
the written materials they consider and produce.  In practice, the WSWG found that closing deliberations to the
public  generally was not necessary, and that open  meetings did not prevent substantive  deliberations on the
features and measures of active and effective security programs  In the few instances where the WSWG needed
to discuss specific, attributable security tactics or examples, they used  closed sessions.  Over the course of
approximately 92 hours of deliberations, the WSWG conducted only approximately  11 hours in closed session
The Deliberative Process and Consensus

The WSWG met in person five times between July 2004 and April 2005, and had two full Group conference
calls dunng that period   Notices  of Group meetings and full  Group  conference calls were published  in the
Federal Register  Except where security-sensitive information was discussed, meetings were open to the public.
Opportunities  for public  comment were  provided at each  meeting.   Agendas and  summaries of WSWG
meetings are available on the EPA NDWAC website at www.epa gov/ogwdwndwac/counal.html

The WSWG used a consensus-based, collaborative problem-solving approach to developing findings.  In cases
where the Group did not reach consensus, the  range of views of the Group are described  At the end  of the
consensus-based process, WSWG  members also had an opportunity to submit up to three pages of individual
comments. One WSWG member chose to submit Individual comments, which can be found in Appendix D

The WSWG was served by two co-chairs  To facilitate communication with the NDWAC, one of the WSWG co-
chairs was also a  member of NDWAC   This  individual was  identified  by  EPA and the facilitation team, in
consultation with the three NDWAC members who serve on the WSWG The second co-chair was identified by
the Group using a weight of preferences selection process
 Water Secumy Wor"-nq Group F'Pd'Rjs "res^ived to :ne Nc::ona! Dunking Wafer Adv.sory Council 5/1G'05                 Pcge 3

-------
The role of the WSWG  co-choirs was to act as a sounding board for the facilitation team between  WSWG
meetings, open and close the WSWG meetings,  assist  the facilitation  team in running the meetings,  and
approve WSWG meeting summanes.  The co-chairs also  participated  in deliberations and decision making as
full members of the WSWG. The co-chairs did not determine the WSWG agenda or findings any more or less
than other WSWG members

Additional detail on the WSWG process is available in Attachment 2, WSWG Operating Procedures
Scope and Application of WSWG Findings

The WSWG findings address all three parts of the charge given to the Group by the NDWAC secunty practices
or programs; incentives; and measures.  The WSWG developed findings to apply to all water and wastewater
utilities,  irrespective of  size,  location, ownership,  or regulatory status    The Group  recognizes  that the
Bioterrorism Act requirements for water security apply only to community water systems that serve  more than
3,300 people, however, it  does  not intend to limit its findings to such  systems   While the  Bioterrorism Act
encompasses approximately 91 percent of the population served by dnnking water systems, it addresses only 16
percent of systems.  The vast majority of systems serve populations of 3,300 or fewer

The WSWG decided not to limit its findings to community water systems  that serve 3,300 or more  people for
three  reasons   First, the Group  believes that all  utilities, regardless of type and size, need to take steps to
address secunty   Although threats may be greater or lesser depending on utility-specific  circumstances and
operating conditions, no utility is immune from attack.  Second, the fourteen elements of an active and effective
security program contain considerable flexibility to allow for utility-specific security tactics and approaches  This
encourages utilities to tailor security programs to the level of  resources they can devote to security and to nest
security efforts in broader utility operations designed to safeguard water quality and utility infrastructure  The
WSWG believes that the steps needed to address the features  of an active and effective security program  are, in
many cases, consistent with  the steps needed to maintain technical, management, and operational performance
capacity related to overall water quality, and that many small utilities may be able to craft active and effective
security programs with minimal, if any, capital investment

Third, the WSWG's findings on active and effective security programs  create voluntary guidelines.  While the
Group encourages all  utilities to consider these findings and to  develop active  and effective  security programs,
there are currently no federal regulations on water security and the Group  as a whole is not  suggesting federal
regulations. Without regulations, it is  up to individual utilities and their communities to decide to make the effort
they determine is  appropriate for their specific  circumstances   (For additional information on the WSWG's
diversity of views on the role that regulation should play in water security, see discussion in Chapter II  of this
document)

The WSWG recognizes that many utilities use a multi-barner approach  to water and wastewater management
In a multi-barrier approach,  multiple barriers covenng the  full scope of utility infrastructure are  chosen in
consideration  of utility-specific circumstances  and  operating  conditions,  and  implemented  as an integrated,
seamless system to  protect  drinking water services and quality from source water to tap, and  to protect
wastewater services, from collection through treatment and discharge  Multi-barrier approaches are built  on the
premise that a combination of efforts throughout a utility will be more robust than reliance on  any single tactic or
point of influence.  The WSWG security findings and  the fourteen features of an  active and effective security
program take a similar approach,  calling on  utilities to understand  the specific,  local  circumstances  and
conditions  under which they operate, and to develop an enterprise-wide security  program tailored to those
Water Secunty Wording Croup Fma-r-qs  Presented to The Nc::ona: Dr.nkno Woier Ad.-isory Council 5/1G/05                 "000 4

-------
specific circumstances and operating conditions   In security, this approach is called protection in depth, or
security layering  The WSWG encourages utilities that have  multi-barrier water and  wastewater management
approaches to consider how they might build on these approaches to incorporate security layers

Finally, the WSWG also is very aware that many utilities already have made considerable progress in developing
security programs. In this context, the Group was careful to craft its findings to build upon this progress.
 Water Securry Worf.pq Croup F.no.ngs  Presented to The NoTionai Dr.nkirsc Wc:er Advisory -Council 5/18/05                  Pegs 5

-------
Water jecunry vVoi-'inq Croup F-pd r.qs  Presen'ed to !ie No?:ono: Dr.pkjno Water Ad/isory Council 5/1G'05                     Pcce 6

-------
II.     SECURITY
The first  part of the WSWG charge was to  "identify,  compile, and characterize best security  practices  and
policies for drinking water and wastewater utilities, and provide an approach for considering and adopting these
practices and policies at a utility level "  Early in their deliberations, the WSWG rejected use of the term "best" to
describe  their work on  security practices.  Instead, the Group chose  to  identify and  describe the scope,
principles, and features of "active and effective" security programs, and to make a senes of related findings on
improving the climate for water and wastewater security
Approach to Developing  Findings on Security

The WSWG began deliberations on secunty practices and programs by considering the current body of security-
related guidance.  This included  preparing a detailed  annotated  bibliography  of security-related references
(Attachment 3),  reviewing the security literature,  and identifying  and considering  common  secunty-related
themes  The WSWG also considered presentations on security from Group members and outside experts.  From
these initial deliberations, the WSWG identified twelve common  interests shared across the Group.  The WSWG
used these common interests to guide their findings on  active  and effective security programs, and to set the
stage on which the Group's secunty-related findings should be reviewed
    1   Don't reinvent the wheel, understand and use existing
        information, adding new value.                                     C0/W/WOM
    2.  Limit inclusion of security-sensitive information to maximize the      informed Ctnd SUlded ffl?
        utility of the product and ensure it can be distributed and used     «««,,,,.   * t >      ,          j
    0   c  i.           L.   i-. L.      L         .    .L .L           WMl G s deliberations and
    3.  Seek to maximize benefits by emphasizing actions that have
        the potential to both improve the quality or reliability of utility          Created the btthlS JOt'
        service, and to enhance security                                 agreement OH Substantive
    4   Programs should have measurable goals and timelines                  ,  ,.        .     .
    ,   D   „  ,   ,           1U .       i   i   . i •       -,              findings  related to
    5   Be attentive to concerns that more clearly defining security             ••       "
        practices may create liability concerns, especially for smaller                  SPCUnty.
        utilities, which may not have the resources to implement all        	
        security enhancements immediately.
    6   Be aware that, in some jurisdictions, political or organizational interest in secunty may be diminishing,
        making it more difficult for utility operators to gam the support and resources needed for security
        enhancements
    7.  Recognize the need to tailor secunty programs and practices to utility-specific characteristics, such as
        whether a  utility is urban or rural, and whether it is small, medium, or large in size
    8   Recognize constraints and barriers, but do not let them define security findings.  For example, where a
        practice is desirable but implementation is constrained, findings could call for the practice, and
        recognize  and suggest ways to overcome constraints
    9.  Address prevention as a key aspect of enhancing security
    10  Emphasize that inherently safer practices or practices that have a lower risk potential also have potential
        to enhance security.
    11  Recognize and manage the relationship between practices  that increase safety and those that increase
        secunty. Safety  and security may complement each other, may be neutral, or may conflict.  For
        example, a supervisory control and data acquisition (SCADA) system provides valuable operating safety

Water Secunry WoD'ipq Group F,ns.r.gs   "met'ed to :fie Notional Drinking Waier Adi-'sory Council 5/18'05                fcge 7

-------
        information, but may also introduce a vulnerability that someone could use to cause harm or mislead
        operators  Similarly, permanently locking a door for security reasons might create a safety barrier to an
        emergency exit
    12. Develop findings in a way that creates an awareness of security and an understanding of the rationale
        for findings among water sector stakeholders and the public, and encourage utilities to take a similar
        approach in developing utility-specific programs, consistent with the need to hold security-sensitive
        information closely

Many of the common interests  identified by the WSWG to guide the Group's deliberations on security are also
suggested by the Group as principles for use by utilities as they develop active and  effective security programs
(see Finding 4)
Summary of Findings on  Security

The WSWG developed eight findings on security.  Finding  1  calls for  utilities  to achieve consistent security
outcomes with significant flexibility to tailor security approaches and tactics to utility-specific circumstances and
operating conditions.   Findings 2 through 4  address the scope  of active and effective  security  programs,
significant system failures  and key  threats  that should  be considered,  and program principles   Finding  5
identifies the features that should be present in  all  active and effective utility security programs. Finding 6 calls
on utilities to use a  continual improvement approach to learn  from implementation  of security programs and
enhance security over time   Findings 7 and 8 call for improving the climate for water and wastewater security by
improving connections  between the utility and public health communities, and improving the reliability and
affordability of physical and chemical contaminant  monitoring technologies.
One Size Does  Not Fit Ai!

        Finding 1: Water and wastewater utility security programs should achieve consistent outcomes using
  T    utility-specific tactics  and  implementation  approaches that  are  tailored  to  individual  utilities'
        circumstances and operating conditions

The first item the WSWG discussed and agreed upon was the need to provide individual utilities the means to
tailor security tactics  and approaches  to utility-specific circumstances and operating conditions   At the same
time,  the  Group also recognized the  need to create clear expectations and  promote consistency in security
program outcomes  The Group struck this balance using an approach that is centered around suggesting that
all utilities address fourteen common features of active and effective security programs (detailed in Finding 5), in
the context of utility-specific circumstances and operating conditions

All water  and wastewater utilities should address security in an  informed and systematic way, consider their
specific circumstances and operating  conditions,  and  develop,  implement,  monitor,  and improve specific
security tactics to create  an active and effective security program  appropriate to utility-specific conditions  The
WSWG discussed this as defining "what to do"  instead of  "how  to do  it"  Using this approach, the Group
makes findings  that describe  the  scope of active and  effective security  programs (Finding 2), the significant
system failures and key threats utilities  should consider (Finding 3), security program pnnciples (Finding 4), and
secunty program features (Finding 5)   It is left to individual utilities to determine  how best to craft a security
program that addresses these findings in a way that is appropriate  to their  specific conditions

Water Secunty vVof.pg Group FiPS.rgs  "resented to :he No::onoi Drink:nc Wcier Advisory •Zcu-.cil 5/1G/05                 Tecs 3

-------
Water and wastewater utilities  come  in all  shapes and sizes—there are large urban  utilities and small rural
utilities  There are utilities that rely on ground water and those that rely on surface water There are utilities with
inherently higher-nsk operations in higher risk locations or circumstances, and utilities that operate with a lower
risk profile.  Some utilities have multiple sources of source water and redundant treatment  capacity; others do
not   Some utilities  may  have large  security  budgets,  and  others may face difficult  decisions about setting
priorities between security spending and other necessary spending   Political and public support or interest may
affect a utility's ability to implement security measures  Legal  barriers, especially for public utilities, might affect,
for example,  utilities' ability  to  carry out employee  background checks  or  to implement  other security
approaches.  Some vulnerabilities can be as specific as where an extra set of keys is hanging  The possibilities
are infinite

These and other utility-specific circumstances and conditions must inform development of specific secunty tactics.
A rigid approach  that requires a  certain  type of  fence or other access control,  or a prescribed information
technology protection system or standard  set of personnel security policies would, automatically, over-address
security needs for some  utilities and  under-address security  needs for other  utilities   It would under-invest in
some places, and over-spend in others  In essence, there is no prescriptive, uniform filter that can be applied to
every community in  the  country to determine if they have  established the best possible  security tactics and
countermeasures—as discussed throughout the document, decisions about utility-specific  security tactics and
countermeasures  should be determined in light of utility-specific circumstances and operating conditions. The
WSWG agrees that due  respect should be given to priorities established through utility-specific assessments of
vulnerability. It would be counterproductive for a uniform perspective of security tactics and countermeasures to
override priorities established through utility-specific vulnerability assessments The WSWG  discussed this using
the catch phrase "one size does not fit all "

The WSWG recognizes that their approach will result in considerable variability in the specific security tactics
and approaches individual  utilities implement   Some utilities may—and may need to—create distinct secunty
programs, with new secunty managers and security staff.  Other utilities may appropriately address the program
features simply by ensuring existing managers and  staff address security concerns as part of  their responsibilities
Some utilities may—and  may need to—invest heavily in  physical hardening of infrastructure and access control
(Physical  hardening involves designing-in  the  means to make a facility harder to  attack—or appear harder to
attack—and to  reduce the effect of any attack that may take place)   Other utilities may rely more  heavily on
timely intrusion  detection  and response. This variability is to be expected  and is appropriate to the vanability
inherent in utility circumstances and operations  The WSWG emphasizes that the important outcome is that all
utilities, regardless of size or circumstance,  should address security in an informed and systematic way; should
consider  their specific circumstances  and  operating conditions,  and should develop,  implement, monitor, and
improve specific security tactics to create an active and effective secunty program appropriate to utility-specific
conditions
 Security  Program Scope

  ;>      Finding 2:  Active and effective secunty programs should address protection of public health,  public
  f     safety (including infrastructure), and public confidence.

 After agreeing on the importance of defining secunty outcomes that all utilities should achieve—and at the same
 time  agreeing on  the need  to tailor security tactics and approaches to utility-specific  circumstances  and
 operating conditions—the WSWG turned to describing the scope of an active and effective secunty program.
 Water Secunry vVof-ng Group Finings- PreseTed to :he Nc:ionoi Dnnluiq Wazer Ad* «o!y Ccunc:! 5/1G/05                 fcge 9

-------
The  main outcome of an  active and  effective security  program  is to ensure reliable operation of water and
wastewater infrastructure, reliable drinking  water, and  reliable wastewater collection and treatment services
Reliable, clean water is needed for consumption  and for the prevention of disease and maintenance of public
health; reliable water also is needed for operation of wastewater collection and treatment facilities, and other
facilities necessary to public health.  Reliable water at sufficient pressure is needed to protect public safety and
infrastructure—to fight fires, operate industrial facilities, and cool industrial  and other operations  Reliable water
treatment is needed to prevent uncontrolled—or untreated or not fully  treated—wastewater discharges from
fouling beaches, water bodies, and even drinking water supplies, with serious public health, environmental, and
economic consequences.

The  WSWG  discussed  which of these adverse consequences active and effective  security programs should
address,  and agreed that  protection should be provided across  the full range of adverse consequences that
might be brought about if a water or wastewater utility were to be compromised   The WSWG defined these as
adverse consequences for public health, adverse consequences for public safety, and adverse consequences for
public confidence.  The Group agreed that active and effective  security  programs should protect  against all
these potential adverse  consequences, although they recognized some might be more of a concern than others
based on utility-specific conditions.  For example,  when a utility provides the only potential source of water for
firefightmg, protection of public safety by ensuring the continued reliability of a supply of firefightmg water might
need special attention    Similarly,  interruption of wastewater collection  and treatment  services for a  large
metropolitan  area is different from interruption of such services for a small  town   The Group also discussed the
need to  avoid  adverse consequences, regardless of the  means  that might bnng such consequences about
Whether a water supply is interrupted  because of accident, vandalism, or terrorist attack matters less than the
actions needed to bring a system back on line   In addition to making water and wastewater utilities safer from
attack, active and effective security programs will have the collateral benefit of improving responses to accidents
and  reducing the impact of natural disasters  and vandalism

The  WSWG discussed "protect against" as  meaning the  design  and  implementation of utility-specific security
tactics and approaches  that seek to minimize adverse outcomes  by preventing or being well  prepared to respond
to and recover from an attack or other event, such  as  vandalism.  Active and effective security programs,
therefore, will include elements of prevention (through access and intrusion detection and  control, contaminant
detection and monitoring, physical  hardening of systems, inherently safer design and construction choices, and
controlling access to security-sensitive information), preparedness  (through having  plans and procedures m
place and building the successful partnerships and communication mechanisms needed to  prevent and respond
to an attack), and response,  consequence  management, mitigation,  and recovery  Each of these aspects of
protection are addressed more fully in the fourteen features of  active  and effective water secunty programs
described in Finding 5.

The  WSWG  believes that creating  and sustaining public confidence deserves  special consideration.  Many
WSWG members who own  or operate water  and wastewater utilities were  particularly  concerned  about
sustaining public confidence.  Reliable, safe water is an expectation in the United States  Any real or perceived
threat to the safety of the water supply could—even if no  sickness or death occurs—have  a significant adverse
effect on public health  and safety, and the  economy,  by  causing customers to mistrust water supplies  Utility
operators are very concerned  about this potential outcome and  about the ability of a utility  to effectively recover
from a loss of public confidence   Later findings  on developing  reliable  partnerships and on communication
contemplate  that all utilities will take  steps  to  create and sustain public confidence as part of an  active and
effective security program.
Water Security Waring Croup Fipe-r.gs - "resented to the Nciiona! Dr-nlcinc Wafer AtiVisory Coaic:! 5/1G/05                Rape '• 0

-------
Significant System Failures and Key Threats

        Finding 3: Active and effective security programs should consider six significant system failures and four
        key threats, as descnbed below

After discussing the scope of active and effective security programs, the WSWG discussed the specific potential
significant system  failures that should be guarded against and the types of potential threats that might bring
about significant system failures. Key threats are actions that have the potential, individually or in combination,
to cause a significant system failure Significant system failures are those that, should they occur, are likely to
disrupt or endanger public  health, safety, or confidence  The WSWG identified  six significant  system failures
water and wastewater utilities should consider when developing an active and effective security program.

    1.   Loss of pressurized water for a significant part of the system
    2.   Long-term loss of water supply, treatment, or distribution
    3.   Catastrophic release or theft of on-site hazardous chemicals affecting public health.
    4.   Adverse impacts to  public  health or confidence resulting from a contamination threat or incident
    5   Long-term loss of wastewater treatment or collection capacity
    6   Use of the collection system as a means of attack on other targets

The WSWG defined four key threats that water and wastewater utilities should consider when  developing  an
active and effective security  program

    1   Physical disruption of core facilities, such as chemical storage, or interdependent infrastructure, such as
        communication, power, and transportation, either through direct physical targeting or as  a result of
        collateral damage
    2   Chemical, biological, or radiological material used to contaminate water supplies or infrastructure
    3   Cyber attack on information technology assets to disrupt service and/or obtain confidential information.
    4   Use of conveyance tunnels or storm, sanitary, or combined sewers to stage an attack against utilities or
        other targets

The WSWG  emphasizes  that these significant system  failures and key threats are intended only as a
standard set  of possibilities a utility should consider when choosing security priorities and tactics for its
specific active and effective security program   Consideration of the significant system failures and key
threats  will   inform  how utilities set  specific security  priorities  and  choose  security  tactics and
approaches, but the lists of major system failures and key  threats do  not prejudge or demand any
particular set of  security tactics  or approaches.

The exact definition  of significant system failure for any given utility also will depend on utility-specific
conditions.   For instance, what constitutes a  "significant" part of a water  distribution system may  be
different for a large urban utility than for a small rural utility.  Similarly, whether a system is  particularly
concerned with  the potential  for a "long-term"  loss  of collection or treatment  capacity may differ
depending on  backup  or  redundant  systems, viable  temporary alternatives,  amount of  material
collected, and environmental or economic sensitivity of receiving waters

Some significant system failures and key threats will be more relevant to some utilities than others.  For
 instance, some  utilities  may be particularly  concerned about cyber attack, or use of conveyance

Water Sacuray \Vor'-pq Group F.ps.f-gs  fYes*i!«> to --.e Nc::ona: Dr.pktng Water Ad»-.scrv Council 5/18/05                 P<3{:e • 1

-------
tunnels or storm,  sanitary, or combined sewers to  attack  utility or  other  targets   Other utilities,
because of the nature of their operating systems, or the size or location of their infrastructure, may be
less  concerned  about these  potential threats   It is  important for utilities to consider the  significant
system  failures  and key  threats  critically,  in  light  of their specific  circumstances  and  operating
conditions   For some utilities, other potential significant system failures or key threats may be more
important than those mentioned here

In the context of significant system failures and key threats, the WSWG also discussed transportation of
hazardous chemicals, such as chlorine.  The Group strongly feels that  utilities should be aware of the
schedules  for hazardous  chemicals  being transported to their facilities, the amount of hazardous
chemicals  in transit, and the expected arrival  dates   This information should be used to coordinate
and  collaborate with individuals responsible for hazardous chemical  transportation to enhance the
security of hazardous chemicals in transit, even as the primary responsibility for security of chemicals
in transit remains with the owners/operators of the transportation service
Principles That Support Active and Effective Security Programs

  V    Finding 4: Active and effective security programs should be built around eleven principles, as described
        below

In their deliberations on the scope and features of active and effective security programs, the WSWG identified
eleven principles that apply across utility circumstances  and operating conditions   These principles should be
used by utilities to guide identification of  utility-specific security tactics and approaches  They are meant to
provide a thematic sense of the types  of security tactics and approaches the WSWG  believes will be most
effective across the widest range of utilities
    1    Security should be part of organizational culture and the day-
        to-day thinking of front-line employees, emergency                Principles of(lCtlVe Otld
        responders, and management                                effective Security programs
    2   A strong commitment to security by organization leadership
        and by the supervising body, such as the utility board or rate-      A/KW/rf be USed by Utilities
        setting organization, is critical to success                         lo guide identification of
    3.   There ,s always something that can be done to .mprove             UtllltV-SpCClflC SCCUnty
        secunty  Even when resources are limited, the simple act of              '
        increasing organizational attentiveness to security will reduce       lOCtlCS and approaches.
        threat potential and increase responsiveness  Preparedness
        itself can help deter attacks.
    4.   Prevention is a key aspect of enhancing security
    5.   Movement towards practices that are inherently safer (i e., have a lower risk potential) may enhance
        secunty.
    6   Security programs require ongoing management and monitoring, and an ongoing budget commitment
        A continual reassessment model, where changes are implemented over time as experience with security
        increases, may be useful
    7   Consideration of security issues should begin as early as possible in facility  construction (i e , it should
        be a factor in building plans and designs)

Water Secure1/ vVofinq Croup F.PC!''--QS  Presented to trie Nci:ona! Dnnlurig Water Advisory Council 5/18/05               Pape ": 2

-------
    8.   The relationship between practices that increase safety and those that increase security must be
        recognized and managed Safety and security may complement each other, may be neutral, or may
        conflict. For example, a SCADA system provides valuable operating safety information, but also may
        introduce a vulnerability that someone could use to cause harm or mislead operators  Similarly,
        permanently locking a door for security reasons might create a safety barner to an emergency exit.
    9   Strong relationships with response partners and the public strengthen security and public confidence.
    10  Investment in security should be reasonable considering utilities' specific circumstances.  Where threat
        potential or potential consequences are greater, greater investment likely is warranted.
    11  Utilities should create an awareness of secunty and an understanding of the rationale for their overall
        secunty management approach in the communities they serve, consistent with the need to hold security
        sensitive information (i.e , attributable information about utility-specific vulnerabilities and security
        tactics) closely.

The WSWG emphasizes that, as with the findings on program scope and features, these principles for active and
effective secunty programs do not prejudge  or prescribe specific security tactics or approaches.  As discussed
earlier in this document, there will be wide variability in security tactics and approaches across utilities, and this
variability  is appropriate given the range of utility-specific circumstances  and operating conditions  Again, the
important outcome is that all  utilities, regardless of size or circumstance, should address security in an informed
and  systematic way, consider  their  specific circumstances and operating conditions, and  develop, implement,
monitor, and improve specific secunty approaches and tactics to create an active and effective security program
appropriate to utility-specific conditions
Security Program Features

        Finding 5:  Active and effective security programs should include fourteen features, described below
From their agreement on the scope and principles of active and effective security programs,  and the need to
tailor specific secunty tactics and approaches to utility-specific circumstances  and operating conditions, the
WSWG turned to defining the  common features of active and effective security  programs   The idea behind
defining common features of active and effective security programs is to provide  for consistency  in security
program outcomes, guide utilities' consideration and selection of specific security tactics and  approaches, and
create a foundation from which improvements in security can, over time, be measured and described

The WSWG's findings on features and measures of active and effective security programs  are based  on a
"secunty layering" approach  They call on utilities to understand the specific, local  circumstances and conditions
under which they operate, and to develop  an enterprise-wide security program  tailored to those specific
circumstances and operating conditions   The WSWG suggests an  integrated combination  of utility-specific
tactics that address:

>    Prevention, through intrusion detection and access control, contaminant detection and  monitoring, physical
     hardening of systems, inherently safer design and construction choices, and controlling access to security-
     sensitive information,
>    Preparedness, through having plans and  procedures  in place, participating in training exercises for  these
     plans, and  building the successful partnerships  and communication mechanisms needed to prevent and
     respond to an attack, and
>    Response, consequence management, mitigation, and recovery in the event of an attack.
 Water Secunry Wor'-pg Croup Find.r-.gs  "resente* tc rte Nc::ona' Dnpfong Wmer Advisory -louncil 5/1 G/05                P-ape

-------
WSWG findings call on utilities to address security in all elements of utility infrastructure—from source water to
distnbution  and through  collection and  wastewater treatment—and to  consider the full scope  of potential
significant system failures and key threats against which they must be protected.  A security layenng approach
uses a combination of public involvement and awareness, partnerships,  and physical, chemical,  operational,
and design  controls to increase  overall program performance   The WSWG emphasizes the security layering
approach because the performance of an enterprise-wide,  integrated security program will be more robust than
the performance of the combination of un-mtegrated, individual security tactics

The fourteen  program features  described  by the  WSWG purposefully define high-level  security program
outcomes rather than prescribe specific security approaches or tactics  They were selected from many potential
features of security programs as  those  that,  in the experience and view of the WSWG, are most  important to
increasing security and most relevant across  the broad  range of utility circumstances and operating conditions
The fourteen features are listed below.

    1   Make an explicit and visible commitment of the senior leadership to security.
    2.  Promote security awareness throughout the organization
    3   Assess vulnerabilities and periodically review and update vulnerability assessments to reflect changes in
        potential threats and vulnerabilities.
    4.  Identify security prionties  and, on an  annual  basis,  identify the resources dedicated to security programs
        and planned security improvements,  if any
    5.  Identify managers and employees who are responsible for security  and establish security expectations
        for  all staff
    6   Establish physical and procedural controls to restrict access to utility infrastructure to only those
        conducting authorized, official business and  to detect unauthorized physical intrusions.
    7.  Employ protocols for detection  of contamination consistent with the recognized limitations in current
        contaminant detection, monitoring, and surveillance technology
    8   Define security-sensitive information; establish physical, electronic, and procedural controls to restrict
        access to security-sensitive information as appropnate, detect unauthorized access; and ensure
        information and communications systems will function during emergency response and recovery
    9   Incorporate security considerations into decisions about acquisition, repair, major maintenance, and
        replacement of physical infrastructure, this should include consideration of opportunities to reduce risk
        through physical hardening  and the adoption of inherently lower-risk design and technology options
    10. Monitor available threat-level information and escalate security procedures m response to relevant
        threats.
    11. Incorporate security considerations into emergency response and recovery plans, test and review plans
        regularly, and update plans as  necessary to reflect changes in potential threats, physical infrastructure,
        utility operations, critical  interdependencies,  and response protocols in partner organizations
    12  Develop and implement  strategies for regular, ongoing security-related communications with
        employees,  response organizations, and customers.
    13. Forge reliable and collaborative partnerships with the communities they serve, managers of critical
        interdependent infrastructure, and response organizations.
    14  Develop utility-specific measures of security activities and  achievements, and self assess against these
        measures to understand  and document program progress

Readers are encouraged to  refer  to Appendix A for a detailed description of each security program feature  The
descriptions include the WSWG's views about how each feature might be implemented, examples of successful
implementation strategies, and identification of challenges to overcome
Water Securcy vVor'.pq C>roup Find r.gs  Presented to :ne Nc::onoi Dr.pk:.ic Water Ad.-«ory Council 5/16/05                Pace 1 4

-------
At a practical  level, the point of an active and effective security program is to prepare for,  prevent, mitigate,
respond to, and/or recover from events that could cause significant system failures, and thereby adversely affect
public health, public safety, or public confidence. By necessity, security programs are combinations of layers of
mutually supportive, adjustable approaches and tactics that protect people (customers, employees, visitors, and
the public who live around plants or other infrastructure), infrastructure (pipelines, aqueducts, plants,  structures,
equipment,  tools,  and  vehicles),  information  (employee  records, blueprints  and  diagrams,  privileged
information, vital records, and details of vulnerabilities),  and reputation (consumer confidence and service safety
and reliability).  Attention to prevention,  preparedness, response, consequence management and mitigation,
and recovery is needed

Security programs affect all aspects  of utility operation, including human resources, information technology,
physical infrastructure, operational functions, customer relations, and coordination with non-utility partners The
features are broadly drawn to allow individual utilities to tailor security approaches and tactics to utility-specific
circumstances and operating conditions  At the same time, they are sufficiently important and relevant that they
apply across the full range of utility conditions and should be addressed by all utilities. The WSWG emphasizes
that significant variability  in implementation of the program features is  to be expected  and is  appropriate,
however, to have an active and effective security program, utilities should address each feature and develop
specific implementation approaches and tactics tailored  to their circumstances
Ongoing Improvement

   V   Finding 6: Water and wastewater utilities should reassess and seek to improve their security programs
   '     on an ongoing basis

Ongoing  reassessment and  improvement of secunty programs is important to keep programs "fresh"  and
effective, and to take advantage of emerging approaches and new technologies   Ongoing reassessment  also
will  increase the effectiveness and  efficiency  of security programs and organizations over time  In an  ongoing
reassessment and improvement  system, there is regular, explicit evaluation of tactics and  approaches,  and
thoughtful  assessment of how these tactics  and approaches might be  improved.   Utilities should undertake
regular and expliat evaluation and testing (or exercising) of their secunty programs, document program failures,
and identify  program improvements   These evaluations are  best undertaken by a  team of individuals  that
includes not only line  and  executive managers responsible for security, but also line employees who have
security-related duties  Implementation of security programs should be thoroughly documented and  monitored,
so that progress in  improving security programs can be identified and evaluated,  and further changes  and
improvements made. At a fundamental level, a system of continual reassessment and improvement reflects the
attitude a utility takes towards security   Like developing  a security-improvement culture (discussed in Finding 5
and part  of  features 1  and 2 in Appendix A),  successful reassessment and improvement approaches rely on
employees at all levels of an organization making a commitment to doing their part to improve security

A commitment to continual reassessment and improvement is critically enabled by clear,  measurable goals for
security performance and timelines for achieving this performance  Later in this document, the WSWG suggests
a series of measures related to the fourteen  security program  features   These measures form a starting point
from which utilities can  develop secunty-related goals
 Water Secumy Wof-pg Croup Fipd.ngs  rnsfVta to The Nc::onai Dr.pk:no Warer Advisory Council 5/18/05                Pape "; 5

-------
Improve Connections with Public Health

        Finding 7:  Relationships between the water and wastewater utility sector and the public health sector
        should be strengthened.

Historically, connections between water and wastewater utilities and the public health community have tended to
be ad hoc.  Water and wastewater utilities and public health  organizations need to develop stronger working
relationships, so  they  are  better prepared to  detect problems,  respond, and  recover  in the event of an
emergency  Opportunities for collaboration between water and wastewater utilities and public health agencies
should be provided through  commitment to regular communication, and ongoing joint training, planning, and
exercises.

It also is important for utilities and public health organizations to plan together for consistency of messages in a
utility-related  emergency.  For  example,  utilities and  public  health organizations  should develop consistent
messages  and planning around the potential for boil water advisories and orders, so that the public will receive
consistent  information about how and when to boil water, from both the utility and the public health community.
Coordination is important at all levels of the  public health community—national public health, county health
agencies,  and health-care providers, such as hospitals

Information sharing between utilities and public health agencies can enhance detection  and response   For
example,  increased complaints to water  utilities or public heath  agencies  could indicate a problem,  when
coupled with other public health surveillance data or routine water quality monitoring data   Given current
limitations on physical and chemical monitoring technologies,  attention to public health data may be the mam
form of contaminant detection and monitoring for water-related health problems

It may be  helpful for utilities and public health organizations to establish formal agreements on coordination
These  agreements  could  ensure regular exchange of  information  between  utilities  and  public  health
organizations, and outline roles  and responsibilities during response to and recovery from an emergency
Support Development of Contaminant Monitoring Technologies

        Finding 8:  Development and distribution of reliable, affordable contaminant monitoring technologies is
        important to improving utility security, and should be facilitated and supported by government

In the features of  an active and effective security program, the WSWG calls on utilities  to employ protocols for
detection  of  contamination  consistent  with the  recognized  limitations  in current contaminant  monitonng
technologies    Currently,  utilities' ability to  undertake  chemical, biological,  and radiological monitoring  of
contamination is limited in large  part by the lack of reliable or affordable technology, and the lack of guidance
or experience to interpret monitoring results  While development of guidelines, instruments, and methodologies
for chemical,  biological, and radiological monitonng for contamination is already an evolving area of research,
more progress  is  needed  to provide for more  direct  and real time methods for contaminant monitoring and
interpretation  of monitoring data   The WSWG strongly encourages  government to  continue and increase
financial and  other  support  for  the  development  of chemical,  biological,  and  radiological  monitoring
technologies,  and to assist utilities  in  creating  protocols and  guidelines for  interpretation  of contaminant
monitonng data.
Water Secunry Wor^pg Croup FinB'pgs  "resen'ed to -he NoTiono! Dnnking Wafer Advisory '^curtc:! 5/1S/05                Pgpe ' 6

-------
 III.    INCENTIVES
The second component of the mission given to the WSWG by the NDWAC was to "consider mechanisms to
provide recognition and incentives that facilitate a broad and  receptive response among  the water sector to
implement best security practices and policies, and make findings as appropriate."
Approach to Developing Findings on Incentives

The WSWG began deliberations on incentives by considering what an incentive is. The Group discussed that
incentives are  created by identification of desired behaviors and desired benefits   If the desired behavior is
broad implementation of active and effective security programs, incentives will come  from identification of the
benefits,  or reasons that might motivate utility owners/operators to implement and maintain active and effective
security programs

The WSWG emphasizes that because of the nature of the utility  business and  the responsibilities of utility
owners/operators relative to  public health and  safety,  most utilities are motivated to implement active and
effective security programs as  part of their commitment to serving their customers and communities by providing
clean, reliable water and reliable sanitary services  Most utilities see themselves as implementing a public trust
and take these responsibilities very seriously   Most utility owners/operators and their families live in the cities
and towns that they serve, and have a deep commitment to furthering safe, healthy communities.  At the same
time, the WSWG recognized  that even with this motivation, resources in utilities are not unlimited,  and time,
attention, and  capital investment in  security improvements must compete against other  pnorities   As  time
elapses since September 1 1 , 2001 , attention to security may wane if new, successful attacks are not mounted

The WSWG discussed incentives as a way to help security improvements remain of high concern and compete
more effectively for attention  and funding against other utility  pnorities   In this context, the WSWG identified
several benefits  that, if available, could prompt utilities to develop  and maintain active and effective security
programs.

>   More efficient/effective operations through  inherently  more productive practices, and implementation  of
    actions that improve the quality or reliability of utility service, and enhance security
>   A more safe and secure working environment and community.
>   A more solid, comprehensive business plan
>   Better understanding and support in the community,  which may help rate payers tolerate higher rates that
    correspond to safer operating conditions.
>   Potential reduction in liability, with the potential for resultant reductions in insurance costs or premiums,  by
    demonstrating actions  consistent with  industry  guidelines for  active and effective  security  programs
    Conversely, if an active and effective security program is not implemented, liability may increase. (Note, the
    WSWG did not carry out extensive consultations with  the  insurance industry,  EPA should consider  such
    consultation as a way to further explore the role the insurance industry might play m providing incentives for
    active and effective security programs )
>   Regulatory flexibility  might be  offered if, for  example,  a permit  or regulatory  violation  occurs as a
    consequence of a successful attack
>   More reliable and trusted utility  performance and products, increasing community approval  ratings and
    public trust.
Water Securcy vVor">ng Group F'pS'ngs  Presented to :he Nenonai Dr>nk:ng Warer Adv-sorv Course:! 5/1G/05                Paae 1 7

-------
>   If available, financial support for implementation of security improvements.

The WSWG also discussed that  establishing clear expectations for security, such as those established by the
WSWG's findings on features and measures of active and effective security programs, is, on its own, a powerful
motivator for utilities to take action  Clear expectations set an industry benchmark and a potential basis against
which decision makers within utility organizations, oversight agencies, financial and insurance markets, peers,
customers,  and the public can evaluate progress  It is important lo continue  to emphasize clear expectations for
outcomes of active and effective security programs—to create a yardstick against which utilities can measure
themselves and to establish expectations about performance industry wide.  As noted in  the first finding on
incentives (see Finding 9), the potential for increased liability in the event that a utility fails to adequately address
secunty and an attack or other event interrupts utility services, injures people or property, or otherwise causes
harm, is a powerful motivator for action.
Summary of  Findings on  incentives

The WSWG developed a number of findings on  incentives   Finding  9 addresses the need to reinforce the
importance of active and effective security programs and the potential  for negative consequences if security is
not addressed.  Finding 10 addresses recognition of secunty programs   Finding 11 calls on EPA and others to
establish a peer review system  for utility security   Findings 12 and  13  address technical assistance and other
support for utility security efforts,  and findings 14 and 15 address funding  for secunty by calling  for direct
financial support and for education for utility oversight boards and rate-setting agencies.
Understanding the Consequences of Failing to Address Security

        Finding 9:  EPA, DHS,  state agencies, and water and wastewater utility organizations should  provide
        information on the importance of active  and effective security programs to utilities, and should make
        owners and operators more aware of the benefits of active and effective security programs and of the
        potential negative consequences of failing to address security

Information is a powerful motivator for action   In the utility community, trusted information comes largely from
utility organizations such as the American Water Works Association (AWWA), the Water Environment Federation
(WEF), the National Association of Clean Water Agencies (NACWA),  the Association  of Metropolitan Water
Agencies (AMWA), and the National Rural Water Association (NRWA)  Federal and state agencies and  officials
also have a role to play in providing information  Because  utilities have many priorities and competition for
resources may be great, it is important that security remain a high-profile concern.

While positive reinforcement of the importance of active and effective security  programs may provide adequate
motivation for many utilities that are already interested in improving security, it is also necessary to ensure that
utilities have information about the potential negative consequences of failing to address secunty.  For utilities
that are not yet motivated to address security, information on the  potential negative consequences  of failing  to
act may be the factor that prompts them to begin to take action.  The WSWG identified a number of potential
negative consequences of failing to address security, these include  increasing the potential for attack, vandalism,
or other interruption to utility services by making the utility an "easy" target, reduced response capabilities in the
event of an emergency, and potential liability if an attack or other event interrupts utility  services, injures people
Water Securrry vVor'.ng Group F-ncf r.gs- "resei^d to The Nc::onal Dr-pking Wafer Mr-sory Council 5/1G/05                Page "'8

-------
or property, or otherwise causes harm.  The WSWG discussed increased liability in particular as one of the key
negative consequences of failing to address security needs.

Information on the benefits of an active and effective secunty program and the potential negative consequences
of failing to address security also will raise public awareness of utility security issues and may thereby increase
public support for utility security efforts.  Utilities are very interested in what the public—their customers—want,
and  are very concerned  about maintaining high levels of public support   Public  pressure and  support  for
security improvements will assist utilities that are already taking steps to address security by providing another
argument in support of security investments, and may serve as further motivation for utilities that have not  yet
addressed security issues
Recognition

        Finding 10: EPA, DHS, state agencies, and water and wastewater utility organizations should develop
        programs and/or awards that recognize utilities that develop and maintain active and effective security
        programs, and that demonstrate superior security performance.

Peer pressure and  peer  recognition are  important in any  profession    In the utility community, owners and
operators tend to be highly  aware of the accomplishments of their peers and  attuned to  peer recognition.
Programs like the Partnership for Safe Water, the National Biosolids Partnership, the AWWA Exemplary Source
Water Protection Award and Public  Communications Achievement Award, the NACWA Peak Performance
Award, the NRWA Excellence Awards,  and the AMWA's Gold and  Platinum  awards  for Competitiveness
Achievement and Sustained Competitiveness serve to motivate utility action and  recognize high achievement
Awards such as these can improve utilities' standing in their communities, and increase public support and trust.

By developing awards focused on security performance and improvement, EPA and water and wastewater utility
organizations  will continue to raise the  profile of security in the utility industry, reinforce the importance of
developing  and  maintaining active and  effective  security  programs,  and  motivate utilities  to enhance and
accelerate secunty improvements  As award and recognition programs  are developed, it will be important to
remain sensitive to potential risb associated with calling attention to secunty performance—in particular,  some
members were concerned that security awards could make award-winning utilities  more attractive targets by
drawing attention to them    This concern might be  mitigated by incorporating security considerations as an
additional element of existing  award programs  that recognize overall superior  performance,  rather  than
developing stand alone security awards   Recognition  also might be provided by inviting utilities to participate as
peer reviewers or experts in a utility secunty peer review program  Award and recognition programs also should
recognize that in some cases, the changes to utility operations needed for active and effective  secunty programs
are  more extensive—and may  be  more  difficult to  bring  about—than the types  of operational changes or
performance addressed by existing utility award programs
 W.jter Securay Wor'.pq Group F-nd.r.gs  Presented to :he Ncrsono: Dr.nk:na Wafer Ad^scry Council S/1G/05                Pajie ":

-------
Peer Assistance  and  Review

        Finding 11:  EPA, DHS, state agenaes, and water and wastewater utility organizations should support
   \    development  and implementation  of a voluntary utility security peer technical  assistance  and review
        program

As discussed in Finding  12 on  technical  assistance, forging connections between peers  is a highly  effective
means to deliver support. Programs that offer technical assistance, training, or circuit rider assistance, such as
those offered by the Rural Community Assistance Partnership, the NRWA, and slates often succeed because they
rely on  individuals with similar backgrounds and  responsibilities working together to learn from one another.
For example,  in 2000,  the Dade  County Water & Sewer Authonty worked with the Georgia Rural Water
Association (GRWA) to develop  the GRWA Small System Peer Review Team.  The team matches experts from
small, rural water systems that have information or advice to share with small systems  that need help  What
began in Georgia has now spread to Kentucky, Mississippi, Virginia, and tribal governments on the  East Coast,
with remarkable results  In Georgia, safe drinking water compliance rates have climbed from 73 percent before
the program to 96 percent today.

A utility  security peer technical  assistance and review program could motivate utilities to seek help in developing
active and effective security  programs by delivering help in a way  that is practical, easy-to-use, and respected,
could inspire utilities to take action   Programs, such as those put in place by the Rural  Community Assistance
Partnership (RCAP), NRWA, the GRWA Small System  Peer Review Program, and the QualServe Self Assessment
and Peer Review Program, can serve as models for successful peer approaches

In  addition to  helping utilities put  active  and effective secunty programs in place, a  successful peer review
program can increase confidence in utility security programs   Earlier in this document (see feature  14), the
WSWG suggested that active and effective security programs  should include utility-specific measures of program
achievement  and regular self assessment.   Peer review could be an important complement to utility  self
assessment by  offering confirmation of self assessment findings  or alternative  views and advice  on needed
security improvements.
Technical Assistance

        Finding 12:  EPA, DHS, state  agencies, and water and wastewater utility organizations should help
        utilities develop  active and effective security programs by providing information on different types of
        technical assistance,  including technology verification information

Where utilities are already motivated  to address security issues, technical assistance programs  can provide the
critical added expertise or support needed to make good intentions towards security a reality. Where a utility is
not yet motivated to address secunty issues, technical  assistance can provide the support needed to make
security approachable enough to overcome  resistance  Currently, there are many effective technical assistance
programs and  resources designed to assist utilities in  their efforts  to comply with  the requirements of the
Bioterronsm Act of 2002 and to improve water and wastewater security. These include EPA documents, such as
the Response Protocol Toolbox, ongoing training and assistance efforts offered by states, EPA, and utility industry
associations; circuit rider programs, such as  those put in place by the NRWA and the RCAP, ongoing federally-
funded research into security approaches and products, and comparative information on secunty products, such
Water Secunry Wor'-pg Croup F-nd r.gs  Presen-ed to :ne Nc::onoi Dr.nkinc Water Ad/scry 'Council 5/10/05                Pajje 20

-------
as the EPA Security Product Guides, and online, accessible libraries of information on contaminants and other
secunty-related topics, such as the WaterlSAC  It is important that these efforts continue and be expanded

In particular, utilities would be helped in their efforts to implement active and effective security  programs by
reliable, practical information on the performance capabilities of various security technologies.  As security has
become a higher-profile concern in the utility industry,  a proliferation  of security vendors has come forward to
market a vast array of security-related tools and technologies.  Independent verification of the performance of
these tools and technologies, such as that provided through EPA's "technology Testing and Evaluation  Program
(TTFP) would be a valuable incentive to utilities and would help ensure that  utilities get the most benefit from
their investments in security.  Ihe primary focus of the  T'ltP program is the  testing  of commercially available
technologies,  with  a  keen eye toward  thes end users' security  needs. Homeland security technologies  for
detection, monitoring,  treatment, decontamination, compute" modeling, and design tools will be tested against
a  wide range of performance  characteristics,  requirements, and specifications.   Performance results will be
reported in testing summaries and in side-by-side comparisons between products.   To complement programs
such  as TTEP, programs that promote technology evaluation and  testing before verification efforts  also  are
needed

Utilities also would be  helped by information on options for choosing inherently safer designs and technologies,
and how to factor consideration of inherent safety into design and technology decisions. Inherently safer designs
and technologies reduce the overall risk potential  associated with an activity  The choice of which technology or
design to  use will involve consideration  of  numerous  factors, including  utility-specific circumstances and
operating conditions, hazards and  hazard potential, resources,  security and other utility priorities, and which
technology or design offers the most inherent safety or robust performance.  As described in Finding 5, feature
9—moving towards inherently  safer designs and technologies is desirable as a way  to  reduce the  potential
harmful consequences of a successful attack on a utility,  natural disaster, or other event

In providing technical  assistance, EPA and water and wastewater utility organizations should keep in mind that
different types of assistance may work better for different utilities, depending on utility-specific circumstances and
operating conditions   For example, smaller utilities without staff specifically dedicated to security might be best
helped through question and answer hotlines,  m-person assistance and training, or periodic workshops  Larger
utilities with secunty staff may be able to make  better use of studies, guidance documents, or other approaches

The WSWG emphasizes that regardless of the type of technical assistance,  there are three important elements of
technical assistance that should be considered  as this finding is implemented

>   First, assistance must be  relevant to the receiver  EPA and others should reach out to the utility community
    to ascertain what information, tools, and training they would find most valuable.  This should recognize that
    the needs of large utilities likely are different from the needs of small utilities, and that tailored, or different,
    materials may be needed for different audiences
>   Second,  assistance is best  received when  it comes from a respected peer.  Every effort should be made to
    involve utilities and their  peers in developing  and providing technical assistance to each other.  Circuit rider
    and technical assistance programs, such  as those put in place  by  RCAP  and NRWA, and peer review
    programs, such as the Small System  Peer Review Team and the QualServe Self Assessment and Peer Review
    Program, succeed because they rely on individuals with similar backgrounds and responsibilities working
    together to learn from one  another
>   Third,  assistance materials must be easy to use and accessible   The vast  majority of utilities are small
    systems that do not have staff  specifically dedicated to security and will have limited time, attention,  and
    resources to devote to secunty   It is critical that technical assistance information be well  organized, clearly

Water Secure^ \Vof.pq Croup F.ps.r.gs rrasen'sd tc:he Nc::onai Dr.nkir.0 Wo:er Aj^scry Ccuicil 5/1G/05                Pape 21

-------
    written, and focused on practical, implementation-oriented steps that utility operators can take to improve
    security   Whenever possible, checklists, tables, or other devices should be used to provide information in an
    easily accessible way   No one has time to  pore through a fifty-page document  to find the information
    relevant to them.  In particular, utilities would be helped by easy-to-use information about effective security
    program approaches and tactics, case studies, model and/or example policies,  procedures, templates and
    agreements; checklists, and other practical information.  EPA and states should  consult further with utilities
    to understand what types of technical assistance programs and documents are currently considered helpful
    and should build upon, support, or replicate successful models.

For example,  small communities  have generated a model  that has proven highly effective—the Security and
Environmental Management System (SEMS).  This software was developed  in consultation with state dnnking
water administrators and has been approved by EPA as an  acceptable methodology  to  use for vulnerability
assessments.  The SEMS software has been distributed to small communities with training for relatively no charge
and has been updated by the  U.S  Department of Agriculture for wastewater systems. Many small communities
that have conducted vulnerability assessments used the SEMS model  As discussed above,  the WSWG believes
it will be useful for EPA to examine the appeal  and effectiveness of the SEMS approach  and other technical
assistance approaches and programs to inform future technical assistance efforts.
Access to Security-Related Support and Planning

        Finding 13: EPA, DHS, and other federal and state agencies should support utility security programs by
        helping utilities obtain access to needed  secunty-related support systems and infrastructure, and by
        supporting inclusion of utilities in security exercises

For utilities to succeed in improving security, they need to become an integral part of the web of secunty-related
improvements that have been put into place since the terrorist attacks of September 11, 2001.  Including utilities
in this way will  directly improve utility security; reinforce the idea of security partnerships between utilities,  law
enforcement, and  first  responders, and improve communication between utilities  and their  partners    In
particular,  utilities need  access to secure |omt incident command communication technologies and related
security communication bandwidth, and they need to be part of law enforcement's planning for communications
in the event of an  emergency.  Utilities also should take an  active role in collaborative partnerships and mutual
aid and mutual assistance agreements. An example of the latter is the Water and Wastewater Agency Response
Network, which provides reimbursable mutual assistance and indemnification for water and wastewater agencies
throughout California.  Similarly, representatives of Milwaukee Water Works, the Milwaukee Health Department,
the Department of Public Works,  Milwaukee Metropolitan Sewerage District,  State of Wisconsin  Division of
Health, and Wisconsin Department of Natural Resources meet monthly in a Water-Health Technical Committee
to exchange information, review watershed testing and epidemiological reports, and discuss shared water quality
and health  goals.  Finally,  utilities should be part of  local  and regional disaster and emergency  response
planning and preparation, and should be included in  joint tabletop and other exercises (such as the TOPOFF3
exercise completed in spnng  2005).  This inclusion will  foster testing  of utility security approaches and tactics,
and encourage closer connections, better communication, and partnership with  law enforcement,  public health,
and other first responders.  In surveys carried out by the Government  Accountability Office, dnnking water and
wastewater experts identified support for  utility participation  in emergency response planning and  exercises and
strengthening key relationships between water utilities and other agencies with emergency response roles as one
of the key areas where  federal support, including financial  support, is needed   (See,  Drinking Water: Experts'
Views on How Future Federal Funding Can Best Be Spent to  Improve Security (GAO-04-29, October 2003) and


Water Securay Wors'.ng Group FiPS'pgs Preifn'ed to the Nctsono! Dr.nlonc Wafer Ad»r'sorv Council 5/1G/05               Pgjse 22

-------
Wasfewoter Facilities. Experts' Views on How Federal Funds Should Be Spent to Improve Security (GAO-05-165,
January 2005))
Financial Support

  \    Finding 14:  Congress, EPA, DHS, and other federal agencies should support security enhancements
        with grant and loan programs focused on secunty.

Federal government spending on security has increased dramatically since September 11, 2001. The federal
government supports utility investments m security by providing grant support to states' public health, emergency
preparedness and response, and environmental agencies, and by providing grant and other support to utility
industry associations, research institutions, and others to support training, technical assistance, and development
of assistance tools for water security  It is important that this financial support continue and expand, and  that
funds are focused on  efforts that directly support utility security improvements and are made available to all
utilities regardless of ownership status   The WSWG particularly supports direct grants to utilities to assist  with
security improvements

To  complement support for security, EPA and other federal agencies also should increase funding in  existing
financial assistance  programs, such as  the Drinking Water State  Revolving Fund and the Wastewater State
Revolving Fund (loan funds for improvements to drinking and  wastewater infrastructure), so that funds are
available for all critically needed improvements, including security  improvements.  The WSWG  acknowledges
that, as a practical matter, given the current under-funding of the Drinking Water State Revolving Fund and the
Clean Water State Revolving Fund, it is difficult (if not impossible) to fund investments needed to  improve water
quality and meet new  maximum contaminant limit  standards in a timely way, let alone fund  security   The
WSWG emphasizes that new, increased, directed funding for the Drinking Water State Revolving Fund and the
Clean Water State Revolving Fund is needed if they are to be considered  practical methods of security funding
The Group emphasizes  the need for new resources dedicated to security—it is not the  Group's intention for
federal agencies to simply shift funding from existing water programs to water security, or to simply re-prioritize
spending from the Drinking Water State Revolving Fund or the Clean Water State Revolving Fund

In surveys carried out by the Government Accountability Office, drinking water and wastewater experts identified
specific areas where financial support for secunty improvements are needed, see Drinking Water: Experts' Views
on  How Future Federal Funding Can Best Be Spent to Improve Security (GAO-04-29,  October 2003)  and
Wosfewafer Facilities. Experts' Views on How Federal Funds Should Be Spent to Improve Security (GAO-05-165,
January 2005)
 Rate-Setting Organizations

        Finding 15:  Utility governing bodies should recognize costs associated with implementing active and
   x    effective  security  programs    EPA, DHS,  state agencies, and utility organizations should  provide
   /    educational and  other materials to boards and  rate setting organizations to help them understand
        secunty costs

 For most utilities, rates are set by or in consultation with a governing body  Public utilities generally have boards
 or other oversight organizations that  are responsible for rate setting  Private utilities generally are overseen  by
 Water Securcry Wor'.pq Group F-ps-rgs -"reseTed to:he NcTionoi Drinking WaTer Adv-scry 'ZavncA 5/1 G '05               Pace 23

-------
state  utility  commissions  or other rate-setting organizations   These  governing  bodies must  balance many
considerations in determining allowable utility rates, and must form opinions about how much money and other
resources are needed to operate a utility, when capital improvements are needed, and other issues  Because
security improvements can  represent significant capital investments, and because development of active and
effective security programs,  even where capital investments are not needed, requires resources, it is important
that utility oversight boards and rate-setting organizations are aware  of and provide for timely, appropriate
recovery of security costs  Although rate-setting organizations need reasonable information to document security
costs,  for information security reasons,  the amount and  nature  of the information  provided to rate-setting
organizations to support increases in rates must be balanced and managed
Regulation

When  EPA  announced the  formation  of  the  WSWG,  the Agency expressed its intention to facilitate "the
development of voluntary best security practices."   In the Group's  deliberations,  when  the topic arose, EPA
reiterated its intention to move  towards voluntary  standards  or  guidelines for active and  effective security
programs.   NDWAC members who served on the WSWG also indicated that the WSWG's charge from the
NDWAC was formulated in  the context of voluntary rather than regulatory efforts.  In spite of this  emphasis on
consideration of voluntary standards, the topic of regulation did arise during the WSWG's deliberations

WSWG members have a range of views about  the use of regulations as a way to motivate implementation and
maintenance of active and  effective security programs.   Some members believe that  well-crafted regulations
would  be a powerful and appropriate  motivator.  Members who  support regulations  believe  that regulations
could be developed  that establish the broad outlines and expectations of utility programs,  and acknowledge the
importance  of  providing  significant  flexibility  for individual  utilities to design  programs and  choose security
tactics  that are practical, given utility-specific circumstances and operating conditions  Members  who support
appropriate regulation observe that,  without regulation,  it is increasingly difficult  for  security implementation
priorities to compete for attention  and funding against priorities thai do have a regulatory mandate

Some other members are not supportive of regulation.  Members who do not  support regulation believe that
regulations  are not necessary to  prompt utilities  to implement  and maintain active and  effective security
programs  They note the significant investments in security already made by  water and  wastewater utilities, and
further observe that,  given this progress, any regulatory effort would likely result in some utilities having to re-do
security programs that are already in place and functioning well.   Members who do not support regulation
believe that it would be difficult to craft sufficiently flexible regulatory frameworks that could accommodate the
types of significant  flexibility in  utility-specific  security approaches  and tactics that utilities  need,  and that
regulations would tend to create a "one-size-fits-all" approach

Regardless of their views on regulation, WSWG members agree that it is important  for utilities to step up to the
challenge of voluntarily implementing active and effective security programs
Water Secumy Wording Croup Find'ngs- "reseTed toihe Nci:ono' Dr.nking WcierAd^sory •3ci.".cil 5/16/05                Faae 24

-------
IV    MEASURES
The third component of the mission  given to the WSWG by the NDWAC was to consider mechanisms to
measure the extent of implementation of these best security practices and policies, identify the impediments to
their implementation, and  present findings as appropnate  WSWG  deliberations focused  on mechanisms to
measure the  extent of implementation  of active and  effective  security  programs at individual  utilities and
throughout the water sector.
Approach to  Developing Findings on Measures

In deliberations about measures, the WSWG was guided by a number of key concepts

>   As a starting  point, measures must  help individual utilities to better understand  their  own performance
    relative to the features of active and effective security programs.
>   Walk before you run—in the beginning, simple, binary (e g , yes/no)  measures focused on activities may be
    appropriate at  some utilities; over  time,  utilities should strive for measures of program  achievement,
    outcomes, and performance
>   Strict comparability across utilities is not supportable for all measures  at this time
>   You need to  know what you plan to do before you can measure  it—clear  security policies, plans,  and
    priorities are important precursors to effective measurement.
>   Who will measure, who will use the measure, and how it will be used  are important to the acceptance of the
    measure by utilities, and the ability  of customers and the public to trust measurement results.
>   A measure's baseline should not penalize proactive organizations.
>   Developing and tracking a measure should not compromise security

From these key concepts, the WSWG developed a three-part approach to measures  First, as discussed earlier
m this document and in Appendix A (see  Finding 5, feature 14), the Group suggests that water and wastewater
utilities develop utility-specific security program measures that reflect those security approaches and tactics the
utility has chosen   In Appendix C, the Group lists a number of measures that utilities should consider when
developing utility-specific measurement programs  While they will not be applicable to all utilities, the measures
listed in Appendix C represent the WSWG's best thinking on a menu of sound measures from which utilities
might choose

Second, the WSWG identified a number of  particular measures that address critical security needs and apply
regardless of utility size or circumstances   These measures are listed in Finding 16 and represent the minimum
necessary for credible self-assessment and measurement

Third, the WSWG identified three measures that, when reported by individual utilities and aggregated nationally,
hold the potential to provide a practical basis for understanding and evaluating sector-wide security progress
 Water Secuiriy vVor'^nq Group F.ns-r-gs  Presen'ed to :he Nc::onai Dr-nbng Water Adv-scry Council 5/1G/05                Paae 25

-------
Attributes of Sound Measures

As part of their deliberations,  the WSWG discussed and identified eight attributes of a "sound" measure, as
follows

>   Objective More objective items make better measures than subjective items.
>   Measurable.  Items that can be measured by standard, accepted methods or devices—with standard units of
    measure—are  better than  items  that  have  less  accepted  or non-standard methods  or devices of
    measurement.
>   Defined  Items thai use standard, well understood  definitions of key terms make better  measures than items
    where key terms are less defined.
>   Tradcab/e.  Items that support tracking changes in performance over time  against a stable baseline make
    better measures than items that do not have a stable baseline or cannot be tracked over time.
>   Relevant/useful. Items that are relevant and useful to day-to-day operations, core business functions,  and
    the utilities that are expected to gather and  use the  measurement data make better measures than items that
    are less  relevant to utility operations.  Measures that speak to program achievement  or performance
    generally are more relevant and useful than measures of program activities
>   Specific.  The more specific the item being measured, the better
>   Communicable/understandable.  Items that can be  easily communicated  and understood within  a  utility,
    and to  external partners  and the public,  make  better measures than items that are  more  difficult to
    communicate to non-utility audiences
>   Generalizable/comparable.  Items that can be compared among utilities or aggregated to describe sector-
    wide progress make better measures than items that cannot be compared or generalized.

The WSWG discussed the attributes  of sound  measures as broad  indicators or preferences,  rather than strict
criteria.  The Group recognized  and was comfortable  that (1) there is considerable overlap among attributes,
and (2) not all measures descnbed or suggested by the Group will exhibit all attributes of sound measures.  The
attributes of sound  measures are considerations that the Group used in identifying, describing, and  suggesting
measures; however, the Group may describe or suggest measures that do not exhibit all the attributes of sound
measures
Types of Measures Considered

The WSWG considered two types of measures  measures of activity and measures of achievement  Measures
of activity generally address inputs to a security program—that is, they consider whether a utility has addressed
each feature of an active and effective security program by conducting program activities, such as establishing
policies and procedures, assigning responsibilities,  and conducting activities (e g , inspections, training, drills).
The WSWG believes a sense of security outcomes/achievement can be inferred from activity measures,  because
activity measures assess the extent to which utilities are paying attention to security issues and the extent  to which
utilities have addressed the features of active and effective security programs

Measures of achievement  generally address the  results of activities—that is, whether the way  utilities have
addressed individual features of an active and effective  secunty program have actually improved utility security
Achievement measures address whether and  how activities are working to achieve program goals or outcomes
The  Group believes  both  measure  types are valuable and  appropriate for water and  wastewater  secunty
programs.

Water Securcy vVorf.nq Group F.ns-pgs  Preserved to :he Nc;:onai Drinking Worer Adv4O.*v 'louncsl 5/10/05                Pace 26

-------
Summery of Findings on Measures

The WSWG presents three findings on measures  Finding 16 identifies measures that apply regardless of utility-
specific security tactics  and approaches,  and establishes the expectation  that all  utilities will include  these
measures in their utility-specific measurement programs   Finding 1 7 encourages utilities to consider the  list of
sound measures that the WSWG developed when establishing utility-specific measurement programs  Finally,
Finding 18 addresses national, aggregate measures of sector-wide secunty progress and considerations, such as
verification and consistency,  related to implementation of national, aggregate measures.
Minimum Measures Utilities Should Use

        Finding 16: At a minimum, utility self assessment and measurement should include thirteen  measures,
        described below

Earlier in this document (see Finding 5), the WSWG identified and suggested  that utilities address fourteen
features  of  active and effective security  programs   In feature  14, the WSWG suggests that utilities  should
develop  utility-specific  measures of secunty  activities and achievements, and should self assess  against these
measures to understand and document program progress   In Finding  16, the WSWG identifies a set of
measures of security activities and achievement that should form the basis of a utility-specific self assessment and
measurement program   These are measures that the Group believes will be useful  across the full range of
utilities, regardless of utility size, circumstance, or operating conditions

>    Does a written, enterprise-wide security policy exist, and is the policy reviewed regularly and updated as
     needed?
>    Are  incidents reported in a timely way and reviewed,  and are lessons learned  from incident responses
     incorporated, as appropriate, into future utility security efforts?
>    Are  reassessments  of vulnerabilities made  after incidents, and are lessons learned and other relevant
     information incorporated into security practices?
>    Are  security priorities clearly identified and to what extent do security priorities have resources assigned to
     them?
>    Are  managers and employees who are responsible for secunty identified?
>    To what extent are methods to control access to sensitive assets in place?
>    Is there a protocol/procedure in place to identify and respond to suspected contamination events?
>    Is there  a  procedure  to identify  and  control  security-sensitive  information,  is  information correctly
     categorized, and how do control measures perform under testing?
>    Is there a protocol/procedure for incorporation  of secunty considerations into internal utility  design and
     construction standards for new facilities/infrastructure and ma|or maintenance projects?
>    Is there a protocol/procedure for responses to threat level changes?
>    Do  exercises address the full  range of threats—physical,  cyber, and contamination—and  is there  a
     protocol/procedure  to incorporate lessons  learned  from  exercises and actual responses  into  updates to
     emergency response and recovery plans?
>    Is there a mechanism for utility employees, partners, and the community to notify the utility of suspicious
     occurrences and other security concerns?
>    Have reliable and collaborative partnerships  with customers,  managers of independent  interrelated
     infrastructure, public health officials and providers, and response organizations been established?
 Water SecurTy Wor*i«j Group F'PC "gs - rreseimd to ;he Nc::ona> Drinking Water Adv-sc-y •3cijnc:l 5/16/05                Pape 27

-------
The  measures  identified  here  are not the only measures a  utility might  use  in  their  self-assessment  and
measurement program; rather, they are specific aspects the WSWG believes are  critically  important and apply
regardless  of utility size,  circumstance, or operating  conditions   In suggesting  these measures,  the WSWG
acknowledges that utility-specific circumstances and operating  conditions and the dynamic nature of security
programs may  make other additional measures appropnate for an individual utility.  The WSWG suggests
additional measures for utilities to consider below (see Finding 1 7), and further  acknowledges that individual
utilities  might identify  additional measures not identified  by the  WSWG   They  are, in large  part,  activity
measures.   They consider whether a utility  has  addressed each  feature of an active and effective security
program through program activities, such as establishing policies and procedures,  assigning responsibilities, and
conducting inspections, training, and drills associated with each feature   Over  time, it may be  desirable for
water sector stakeholders to work further with EPA and other  federal  agencies  and stakeholders to develop
supplemental measures more specifically focused on program achievement and outcomes.

The  measures identified  by Finding  16  are specifically tied to each feature of active and effective security
programs  They describe  the minimum effort necessary for measurement and self assessment  Each is phrased
as a question In some cases, the answer may be a simple yes/no;  in others, more information may be needed
The WSWG emphasizes it is suggesting these measures as part of utility-specific self-assessment programs   In
other words,  the only audience for these measures is the utility doing the measuring and anyone the utility elects
to share information with   (For example, a utility might elect to share measurement information with a peer
reviewer in  the  context of  a  voluntary peer  review.)   Utilities should use  these  measures to candidly  and
thoughtfully evaluate their security performance,  and  to identify opportunities to  further improve  their security
posture

Readers  are encouraged to refer  to Appendix  A for a discussion of  each feature and measure   These
discussions include the WSWG's views about how each feature might be  implemented, examples  of successful
implementation strategies, and  identification of challenges to overcome. The table in Appendix B shows  the
suggested features of an active  and effective security program and the associated suggested measures.

Note that, consistent with their early agreement that "one size does not fit all"  and  in recognition that utilities will
develop specific security  approaches  and tactics  appropriate to individual utility  circumstances and operating
conditions, the WSWG decided not to suggest strict comparability of measurement results among utilities at this
time   The  Group discussed examples  of other industries that have developed strict  comparability across
installations—such as the  nuclear power industry—and recognized that the water utility sector does not have the
commonalities  of quantitative  methodology for  risks and  benefits, standardized analyses  on assets  to  be
evaluated,  level of detail  and  evaluation parameters, probability  of occurrence of design basis threats,  and
agreed-upon reliability and failure probability data of various secunty approaches and tactics  that tend  to
support strict comparability
Measures for Utilities to Consider

        Finding 17:  In developing their self-assessment and measurement programs, water and wastewater
        utilities should consider the security program measures listed m Appendix C

During their deliberations to identify measures that all utilities should use, the WSWG identified numerous other
potential measures of active and effective security programs.  The measures suggested above for all  utilities to
use are the minimum necessary to create  a foundation for  a  successful utility security self-assessment and
measurement program   Utilities should supplement the  measures suggested above with additional  measures
Water Securay lA/ofipq Group Fins-rgs Presetted to :he Ncziongi Dr-nk:-.g Wo:er Advisory 'Council 5/1G/05                Pace 23

-------
that reflect the specific security approaches  and tactics  they have chosen.  In Appendix  C,  the WSWG lists
measures considered during its deliberations.  Utilities should consider these measures when developing a utility-
specific self-assessment and measurement program   While not all the measures listed in Appendix C will be
applicable  to  every utility, they cover many  of the elements of a successful measurement program that the
WSWG suggested earlier (existence of program policies and procedures,  training,  testing/exercising,  and
implementing  schedules and plans;  see feature 14) and represent the WSWG's best thinking on what would
constitute sound measures. The list  of measures in Appendix C is not comprehensive.  It is based on the best
thinking of the Group about sound measures for utilities to consider, however, utility-specific circumstances and
operating conditions and the dynamic nature  of security may make other measures, not listed, more appropriate
for individual utilities
National Aggregate Measures

        Finding 18:  In considering measurement of water sector security progress, EPA should consider three
        national, aggregate measures, described below

After  exploring and identifying measures all utilities should use, the WSWG  explored measures of national,
sector-wide, aggregate progress.   The Group  discussed two  facets of national aggregate  measures,  the
substantive basis for measurement and the measurement process.
The Group  agreed that the fourteen features  and associated core measures of active and effective security
programs (see Findings 5  and 16) should serve as the primary substantive basis for measurement.  From  this
discussion, the Group identified three potential national, aggregate measure areas

>   Progress implementing "active and effective" security programs;
>   Progress reduang security risks; and
>   Progress reduang the  inherent risk potential of utility operations

The Group believes that the first two measures can be supported by data that all utilities with active and effective
security programs will have  The measure on reducing the inherent risk potential  of utility operations relies on
two data sources  The first part of the measure relies on data already reported under the Clean Air Act Section
 112(r) and would only affect utilities that are already required to report under  this  Section—there would be no
new reporting   The second part of the measure on  reducing the inherent risk potential of utility  operations
would rely on  new data  Each potential national, aggregate measure is discussed in more detail below

With respect to the measurement process, the Group agreed that:

>   Participation in a  national measurement program,  like development of  an  active and effective security
    program,  is voluntary; and
>   Results of national aggregate measures should be presented only in aggregated form and issues associated
    with the need for data confidentiality (if any) should be fully addressed before any national measurement
    program is put into place

 From  these agreements,  the Group focused on verification  of  measurement results and consistency in  the
 underlying methods and assumptions that utilities use to establish active and effective security programs   The
 Group converged around the idea of a phased approach to a measurement process  In the  first  phase,  the
 national aggregate measures would be based on individual utilities' self assessments of their security programs

Water Secursy vVorf.pq Group Find ngs  "re:*n'»d tc :he Nc::onol Dr.nk:ng Wcier Adi-sory '3cur!c:l 5/1G/05                Pape 29

-------
Finding 5, feature 14, calls on utilities to carry out yearly self assessments of their security practices and progress
as part of active and effective security programs.

In a  potential  second  phase, self-assessments would be complemented by additional,  more independent
assessments that could increase the consistency in  how progress is reported and have the potential to enhance
the overall credibility of national aggregate measures.  As follow-up to the WSWG process, EPA should work
with the water sector and other interested stakeholders to explore and evaluate additional  ways utilities might
voluntarily  enhance or complement their self  assessments.   The Group  identified a  number of potential
enhancements or  complements to self assessment for further exploration, including peer review approaches,
second- and third-party verification approaches, blind or other survey techniques, and incorporation  of security
programs into utility capacity demonstrations  These and other options should be  fully explored  The WSWG
does not presume that all of these options will be found to be appropriate  For example, some members have
concerns about  third party verification, including lack of independence  of third party verifiers, lack of standards
to qualify third party verifiers, lack of  transparency and oversight, and lack of resources for some small utilities to
engage third party verifiers   Other members are concerned that  variability in utility-specific circumstances and
operating conditions will  make any  assessment process that moves beyond self assessment impractical   Still
other members  are less worried about third party  verification, believing that with a clearly  defined focus, and
dedicated resources to implement them, independent assessments could increase consistency in how progress is
reported and enhance the overall credibility of national  aggregate measures

The WSWG discussed  comparability and  consistency  at  some length   The   Group  agreed  that  strict
comparability between security tactics  and approaches at individual utilities  is neither necessary nor desirable
given the diversity of  utility-specific  circumstances and  operating conditions and  corresponding variation in
utility-specific security tactics and approaches.  For example, comparing specific security program tactics and
approaches in Phoenix, AZ to Shelton, WA, and making a judgment about which utility has made more progress
is not necessary or desirable This is consistent with the WSWG's earlier agreement that "one  size does not fit
all" in utility security

The WSWG also  agreed  that as  part  of  exploring  measurement  processes that might complement  self
assessment,  there may naturally be some exploration of  consistency  in  the methods utilities  use  to  identify
threats, assess  risks, and pnontize improvements,  as  these methods  will influence the nature of the security
programs that utilities adopt and, therefore, the results of any assessment of utility progress  The Group believes
that as part of exploring complements to self assessment, EPA, the water sector, and other stakeholders should
consider how to  detect undesirable variability (if any) in the  sector's  fundamental methodologies,  and,  if
undesirable variability is identified, consider means to work with the sector to achieve a more appropriate level
of consistency.   The WSWG emphasizes that this does not contemplate a need for  consistency  in utility-specific
security approaches and tactics.   As  discussed throughout this document, there will be considerable and
appropnate variation in utility-specific  secunty approaches and  tactics, to  correspond with the considerable
diversity of utility-specific circumstances and operating conditions.  In any exploration of complements to self-
assessment  and consistency, EPA, the water sector, and other stakeholders  should explicitly consider the idea
that different types  of utilities might  benefit from different  approaches   For  example, different types of
complements to self assessment might be more appropriate for large utilities than for small utilities.

The WSWG considered only a voluntary national  aggregate measures effort The Group acknowledges that a
purely voluntary effort will face challenges to providing a complete and accurate picture of sector progress.  At
the same time, the WSWG identified a number of factors that should prompt utilities to participate in a voluntary
national aggregate measure effort including.
Water Secuniy Wording Group F.n3.r.gs  Pra5*--,ted to :he Nc::onal Dppkiic Woter Ad^scry Council 5/10/05                Tape 30

-------
>    Credible voluntary measurement efforts will increase the overall credibility of the sector; and
>    A defined measurement effort to evaluate security needs and progress will build national support for security
    efforts and funding by demonstrating need

Finally, the WSWG acknowledges the difficulty, in general, of establishing a measurement system for programs,
like secunty, that are  preventive in nature.  The  Group recognizes that an  important  objective of security
enhancement is to increase the competency and capabilities of local officials (for example, through community
training and exercises), something that may not be indicated through measures of activities.  As discussed earlier
in this document, the Group encourages consideration of movement towards measures that are more oriented
to security outcomes over time
Progress Implementing Active and Effective Security Programs
For  a  potential  measure of implementation progress,  the WSWG  suggests-   Amount  and  degree  of
imp/ementation of the fourteen features of an active and effective security program.

Earlier m this document (see Finding 5, feature 14), the WSWG identifies the features of an active and effective
security program, and  suggests that utilities carry  out self assessment of their progress towards implementing
active and effective security programs. The WSWG also suggests a specific set of measures that tie to each of
the program features  (see Finding  16) and suggests that at least once per year, utilities carry  out  a self-
assessment to evaluate their security practices and  progress (see Finding 5, feature 14).  These self assessments
could provide for a national aggregate picture of the  degree of implementation of each of the fourteen features
of an active and effective secunty program.

Utilities would assess their degree of implementation of each of the fourteen features, based on evaluation of the
feature-related measures,  using a "high, medium,  low" scale   A "high" rating would indicate a utility has fully
addressed a program  feature, a "medium"  rating would indicate a  utility  is in the process of addressing a
program feature (i e, it has begun but not completed work); and a "low" rating would indicate a utility has not
begun, or cannot yet  begin,  to address  a program feature.  The Group  also discussed this as a stoplight
concept, where fully addressed program features are green, features  that  are in progress are yellow, and
features not yet begun  are red.

This  measure will provide a  sense  of the number and percent of utilities fully addressing each  feature of an
active and effective security program, and the number and percent of utilities making  progress towards fully
addressing all  program features.  Examining progress on a feature-by-feature basis, using the feature-related
measures, should indicate where additional attention  is needed—features for which progress is limited or lacking
across the sector may benefit from additional assistance or guidelines.

The WSWG initially considered this measure in a  substantially simpler form, where utilities would use a  simple
yes  or  no to indicate  whether they had addressed each  feature of an active and effective security  program
Many of the measures suggested for utilities to consider in Appendix C and some of the measures suggested for
utilities to  use in Appendix A take  a binary approach  The WSWG  ultimately rejected a binary approach for
national, aggregate measures, because such an  approach would not recognize efforts already underway and
would likely  misrepresent the water  sector's progress.  The WSWG anticipates that many utilities will address the
fourteen features over several years, making more or less progress in each area,  depending on utility-specific
 circumstances and operating  conditions  The suggested high/medium/low approach is designed to provide  a
 more nuanced sense of utility security progress

 Water Securry vVoi»inq Group Fip
-------
Progress Reducing the Number of Security Risks
For a potential measure of progress reducing the number of security risks, the WSWG suggests  Total number
of assets determined  to be  a high  security risk and the number of former high-security risk assets lowered to
medium or low risk, based on assessments of vulnerabilities

Under the  Bioterrorism Act,  community water systems serving over 3,300 people are required to assess system
vulnerabilities   Earlier  in this document (see Finding 5,  feature 3), the WSWG suggested that  all  utilities
(including utilities serving 3,300 or fewer people that were not addressed by the Bioterrorism Act) maintain an
assessment of vulnerabilities as a living document. Utilities have a number of standard publicly or commercially
available vulnerability assessment methodologies available to them   Each of these methodologies approaches
the  assessment  of vulnerabilities   somewhat differently  and  produces  slightly  different  reports    Some
methodologies, such as  the  RAM-W or VSAT  methodologies,  translate  qualitative  risk assumptions  into
somewhat  quantitative vulnerability reports   Other  methodologies, such as  the SEMS methodology, produce
more narrative reports or checklists, and have been used by many smaller utilities

Regardless of the methodology used, one of the outcomes of any robust assessment of vulnerabilities is a sense
of utility-specific assets that present a high risk from a security standpoint (i e , a set  of assets determined to be a
high security  risk, or, a set of high-risk  security assets)   For example, the SEMS methodology provides an
inventory of utility assets and assigns a high,  medium,  or low ranking  to each.  Identification of high-nsk assets
considers both vulnerability  to threats  and the  potential consequences of an  event, and assets can move from
high to medium or low  risk based on either reduction in vulnerabilities or mitigation of potential consequences.
In all of the methodologies,  identification of assets that constitute a high risk from a  security standpoint considers
both vulnerability to threats and the potential consequences of an event, assets  can move from high risk to
medium  or low risk based on either reduction in vulnerabilities or mitigation of potential consequences

This measure would track, on a snapshot basis, the total aggregated number of high-risk assets identified and
the number of high-risk assets that are reduced to lower risk status over time  This change in risk status, from
high to  medium or low, represents progress of the sector in addressing high-risk assets  by, for example,
protecting  against  vulnerabilities or taking  steps to  mitigate  potential consequences    It is  consistent  with
discussions of sector-related measures in the National Infrastructure Protection Plan, where EPA and DHS are
discussing  measurement of assets reduced from high to lower risk.

In their deliberations  on a  measure of progress in reducing security-related risk, including  reductions  in the
number  of high risk assets, the WSWG discussed issues associated with  the baseline against which progress
would be  measured.   The Group acknowledges that an  initial baseline must be established and that this
baseline may change over time as utilities  update their vulnerability assessments   For example, if a  utility
changes its design  basis threat assumptions,  this  may  result in a change to the utility's baseline list of high-risk
assets   Provided basic threat and operating  conditions do  not change, a utility should expect the total number
of high-risk assets to decrease over time, as  security improves   Of course, the number of high-risk  assets also
might  increase over time as a result of increased attention to security or lessons learned from exercises and
actual event  responses  The WSWG emphasizes that the number of high-risk assets will, in all cases, be simply
a snapshot of the current state of the sector

The Group recognizes that  the Bioterrorism Act applies only to larger systems, and that  some smaller systems
may not yet have completed vulnerability assessments  This will be an important consideration in structuring the
details of this progress measure   For example, it  may be that the  baseline of total high-risk security assets
present in  the water sector will appear to  go up  in initial years as smaller systems complete vulnerability

Water Securcy Wording Croup FiPO'f.gs  PresfTed to The NcTionai Dr.pk:nc Wafer /Vd>"scry Council 5/1G/OS                Pise 32

-------
assessments and put active and effective security programs in place, even though, in fad, these actions on the
part of smaller systems likely are increasing the overall security of the sector.


Progress Reducing the Risk Potential Inherent in Utility Operations
For a  potential aggregate measure of progress  reducing  the  risk potential  inherent in utility operations, the
WSWG suggests   Potentially effected residential  population inside the Clean Air Act Section 112(r) worst-case
scenario off-site consequence analysis  areas of water and wastewater utilities nationwide, and number of utilities
that have converted from gaseous to ofher forms of chlorine or other treatment methods

Under Section 112(r) of the Clean Air Act, facilities at which certain types of extremely hazardous substances are
stored or  used must carry out modeling and other  analysis to  determine the potential effects of a sudden,
catastrophic air release of these substances,  and to determine the  potentially effected population.  In  2004,
approximately 1,800 drinking water and 1,200 wastewater utilities reported the results of internal assessments of
potential chemical  release impacts, due largely to use of gaseous chlorine, anhydrous ammonia,  aqueous
ammonia,  and anhydrous sulfur dioxide  This measure  would draw only on these already-reported data  to
evaluate progress in reducing the potential worst case consequences of a successful attack on chemical storage
at water and wastewater utilities

EPA also should consider how data on the largest single vessel of Clean Air Act 112(r) hazardous substances
maintained on site and the end-point distance of the worst-case scenario might create a more complete  picture
of utility efforts to reduce the consequences of a successful attack  on chemical storage at a utility. Each of these
data  sets  is already part  of Section  112(r) reporting   By considenng these data,  measures might more fully
recognize water sector efforts in increasing protection of the public through,  for example, reducing the number
and  size  of  containers  or  implementing passive release  containment  or mitigation measures or  similar
safeguards   Because Section  112(r) allows for consideration of administrative controls that limit the maximum
quantity of hazardous substances held in a single vessel and passive mitigation systems, consideration of these
data  also would  acknowledge some utility efforts to increase the safety of on-site  chemical storage. (Passive
mitigation  systems  are systems  that operate  without human, mechanical, or other energy input  and include
building enclosures, dikes, and containment  walls.)  The  WSWG notes that the mitigation measures that are
considered under Section 112(r)  represent  only  a  few elements  of active and  effective security programs
contemplated by the WSWG.  As a complement to  this measure based on Section 112(r) data, measures  related
to implementation  of  active and  effective security programs  provide for consideration  of the  full  range of
mitigation  efforts  utilities might undertake

The WSWG notes a number of very important caveats to Section  112(r) data that should be provided as  context
for any use of this national aggregate measure.  Most importantly, utilities do not control the number of people
who  choose to live near their infrastructure and, therefore, can  only control the size of their off-site consequence
analysis area, not  the number  of people who live in the off-site consequence analysis area   Utilities might
 undertake aggressive hazardous substance reduction efforts that are masked, at least in part, by population infill
which they do not  control   In addition,  efforts  to reduce the  inherent hazards associated  with water and
wastewater treatment cannot  be simplified to a  finding that would call for  the total elimination  of the use of
 hazardous  substances    For example, in the drinking  water industry, residual  chlorine is  required in  the
 distribution system   The WSWG emphasizes  that decisions about how to manage the risks associated with use
 of hazardous substances are complicated.   For example,  reductions in  the  size  of hazardous substance
 containers have the potential to reduce the size of the off-site consequence analysis area and reduce the number
 of people who could be at risk during a catastrophic release  At  the same time, smaller containers means more


 Water Secumy Woi».nq Group F.nQ..-.gs  Presented to :he Nc::ona: Dr.pkinc Wmer Ad»'.sory Council 5/18/05                Pane 33

-------
frequent delivery  of  substance,  and more transportation of these substances over  roads and through
communities.

As a supplement to measurements that rely  on  data already reported under the Clean Air Act Section 112(r),
EPA also should measure the number or percentage of utilities that have converted from gaseous chlorine to
liquid or solid form chlorine or other water treatment methods such as ozone or ultra-violet light. A measure of
conversion from gaseous chlonne would supplement consideration of Clean Air Ad Section 112(r) data by
providing important detail on  steps utilities are actually taking (and actions utilities can control) to reduce the risk
potential of utility operations.
Other Measures Considered

The WSWG considered, but ultimately decided not to suggest, a national, sector wide, aggregate measure of
progress related to improvement in utility contaminant detection efforts. Earlier in this document (see Finding 5,
feature 7), the WSWG called on utilities to employ protocols for detection of contamination consistent with the
recognized limitations in  current contaminant monitoring technologies.  The  Group  also  recognized  and
expressed concern  that utilities' abilities to undertake chemical, biological, and  radiological  monitoring of
contamination are  limited, in large part, by  the lack of reliable or affordable technology and the  lack of
guidance or experience with how to interpret monitoring results  (See Finding  8 ) At the same time, the Group
is  keenly  interested in rapid development of  practical contaminant detection approaches and in improving
contaminant detection in the water sector, and was interested in the role a  national, sector wide, aggregate
measure of progress in contamination detection could play in creating pressure on EPA and other government
agencies to promote and support rapid development of practical contaminant detection approaches.

Because current limitations in contaminant detection technologies create  a barrier to meaningful measurement
of progress, ultimately, Ihe WSWG decided to place a national, sector wide, aggregate measure related to
contaminant detection in a "wait and see" category.  Th'e Group reiterates its concern that utilities' abilities to
undertake chemical, biological, and radiological monitoring of contamination are limited, in large part, by the
lack of reliable or affordable technology and the lack of guidance or experience in  how to interpret monitoring
results, and again strongly encourages government to continue and increase financial and other support for the
development of chemical,  biological, and radiological  monitoring technologies, and to assist utilities in creating
protocols and  guidance for interpretation of contaminant monitoring  data. As progress in developing practical
contaminant detection approaches  is made,  the  Group  encourages EPA and other government agencies to
continue to explore a national, sector wide, aggregate measure of contaminant detection performance
Reporting

The WSWG is not making  a specific finding on reporting  methods or frequency for national, sector wide,
aggregate measures  To the extent  EPA determines national reporting is  needed,  the Agency should address
reporting methodologies and frequencies in collaboration with the water sector and water sector stakeholders at
that time
Water Securcy vVor'.pq Croup F.ns-r.gs  Presented tc ihe Ncnonal Dr.nking Wa:er Ad^sory Council 5/1C/05               Tape 34

-------
APPENDIX A:   FEATURES  AND MEASURES OF  AN
ACTIVE  AND EFFECTIVE  SECURITY  PROGRAM
In Finding 5, the WSWG identified fourteen features of active and effective security programs to provide for
consistency in security outcomes across utilities, to guide utilities' consideration and selection of specific security
approaches and tactics, and to create a foundation from which improvements in security can,  over time, be
measured and described

The fourteen program features  define high-level security program outcomes,  rather than  specific security
approaches or tactics.  They were selected from among many potential features of security programs as those
that, in the expenence and view of the WSWG, are most important to increasing security and most relevant
across the broad range of utility circumstances and operating conditions.  The features are broadly drawn to
allow individual  utilities to tailor security approaches and  tactics to utility-specific circumstances and operating
conditions  At the same time, they are sufficiently important and relevant that they apply across the full range of
utility conditions and should be addressed by all utilities  The WSWG emphasizes that significant vanability in
implementation of the program features is to be expected and  is appropriate; however, to have an active and
effective secunty program, utilities should address each feature and develop specific implementation approaches
and tactics tailored to their circumstances.

In Finding 16, the WSWG identified security program measures that relate to each feature  Like the program
features, these measures are sufficiently broad to apply across the range of utility circumstances  and operating
conditions,  and sufficiently  important that they  are suggested  for all utilities as the basis of a  utility-specific
security measurement program.

Appendix A is designed to  bring  together the 14 program features identified in  Finding 5 and the program
measures defined for  each  program  feature in Finding 16  Each feature and measure is described in detail
below.
 Explicit Commitment to Security

 Feature  1—Water and wastewater utilities should make an explicit and visible commitment of the
 senior leadership to security.
 Active and effective security programs do not exist in a vacuum—they are integral parts of the organizations they
 serve.  To reinforce this idea, utilities should create an explicit, visible, easily communicated, enterprise-wide
 commitment to security

 Many water and wastewater utilities might make an explicit and visible commitment to security by incorporating
 secunty into  a utility-wide mission or vision statement.  Mission or vision statements, if used, should be simple,
 but complete They should address the full scope of an active and effective security program—that is, protection
 of public health, public safety, and public confidence  They also should place security  in the context of water
 and wastewater utilities' overall core operations, and recognize utilities' commitments to serving the public trust
 Water Secunry •iVorS'.nq Group ?*n}-r.cjs  -"rKemed tc The Ncnonal D.'.nkiRg Warer Ad»-.scry •Zci.nc:! S/1G/05               Pace 35

-------
As with any enterprise-wide commitment, the process of development of an explicit and visible commitment to
security may be just as  important as  the actual language  of the statement that emerges from the process
Utilities should use this process as an opportunity to raise awareness of security throughout the organization and
to help every facet of the enterprise to recognize the contribution they can make to enhancing security.

Utilities also might make an explicit and visible commitment  by promulgating an enterprise-wide security policy,
or set of policies. If used, these policies, like a mission or vision  statement, should address the full scope of an
active and  effective  security program and should be developed using a process that raises awareness of security
throughout the organization.

No matter the  approach used,  the important outcomes  are that the utility  makes an explicit  commitment to
incorporating security  into day-to-day operations and that  this  commitment is  visible to all employees and
customers.
Measure 1—Does a written, enterprise-wide security policy exist, and is the policy reviewed regularly
and updated as needed?
As discussed earlier in this document, to be successful, active and effective security programs cannot exist in a
vacuum—they should be integral  parts of the organizations they serve  This measure establishes the expectation
that, as part of their self assessment and measurement efforts, utilities will ask  themselves whether they have an
enterprise-wide security policy and whether the policy is being appropriately maintained  Note that this measure
contemplates that, as part of an active and effective security  program, a utility  will develop a written, enterprise-
wide security policy, establish a schedule for regular review of the policy, and update the policy as needed. The
Group debated whether it is necessary for an enterprise-wide  policy  on security  to be  written  and ultimately
determined that written policies are needed to help make a  utility's commitment to security visible and tangible
throughout the organization  The Group has chosen not to specify a timeframe for what constitutes "regular"
review of an enterprise-wide security policy; utilities should establish  timeframes  appropriate to their specific
circumstances and  operating conditions   Many WSWG members believe review of an enterprise-wide secunty
policy should be earned out at least once every year, as part  of a yearly review  of security performance, and that
yearly security  reviews  should be incorporated into yearly enterprise-wide planning  and budgeting activities
Integrating secunty into wider organization planning and budgeting in this way has  the potential to highlight
instances where a  security improvement  may  also create  operational improvement (or vice versa), and will
reinforce security as part of the overall organization culture.


Security Culture

Feature  2—Water and wastewater utilities  should promote security awareness  throughout their
organizations.
Every person in a utility organization has something to contribute to enhancing security and  every person should
be expected to make a contribution. The objective of a secunty  culture should  be to increase secunty by making
security awareness a normal, accepted,  and routine part of day-to-day operations  The importance of a security
culture cannot  be  overstated  The best security plans and procedures in the world will not work if they are not
implemented—and implementation relies on  line staff  and managers   Workers on  the  front lines  of an
organization are the people most likely to have occasion to notice something out of the ordinary that may signal
a threat to security   Attentiveness on the parts of these  individuals, and willingness to bring potential security
Water Secunty Wording Group F.nd'r.gs  Pres*n'ed to the Nations! Dr.pkinc Water Advisory '^curci! 5/1G'05                Pace 36

-------
issues to the attention of others, is something a utility can implement to improve security regardless of size or
location.

Creating a security culture involves efforts that are easily described and very tangible,  and efforts that are less
easy to describe  and less tangible.  Examples of tangible efforts include-  employee training; incorporating
secunty into job descriptions, performance standards, and evaluations; creating and maintaining a security tip
line  and suggestion box for employees,  making security a routine part  of staff meetings  and organization
planning, making secunty visible in day-to-day operations through use of badges and  signs;  and creating and
implementing measures of secunty activities and progress.

Some utilities have created a security management team or oversight committee, a group of department heads
and  other leaders in the organization that meets regularly to establish security procedures, set security priorities,
and  ensure cross-organization coordination. A secunty oversight committee creates a  solid, lasting foundation
on which a security program and security culture can be built  At some utilities, the security oversight committee
is also responsible for responding in real-time to threats and security events This combination of oversight and
response duties keeps security policy connected to  the practical side of security implementation.

Less tangible efforts to instill a culture of secunty throughout an  organization are fully as important as the  more
tangible efforts, but are difficult to describe In general, they have to do with those in positions of authonty in an
organization  rewarding attentiveness to secunty, creating a culture where reporting of problems or suspicious
events is the norm, and leading by example   For  example, those in leadership positions might make a point of
following security procedures visibly;  if  badges are required, they would wear security badges  Employees who
raise security concerns  and  who demonstrate attentiveness to security would be acknowledged  and rewarded,
and awareness programs would give employees timely and useful  information about current threats and what to
look for.  All employees would be given an opportunity to contribute to security, not just by wearing identification
and following procedures,  but also by reporting  suspicious or  threatening events and making suggestions for
furthering secunty improvements, for which they would receive timely acknowledgement or feedback to reinforce
the value of reports and suggestions.


Measure 2—Are incidents reported in a timely way, and are lessons learned from incident responses
and training reviewed and, as appropriate, incorporated into future utility security efforts?
Feature 2 establishes the expectation  that as  part  of an  active and effective security program, a utility will
promote security awareness throughout its  organization   This measure  highlights a  key element of security
awareness—the ability of an organization to quickly identify security incidents and to incorporate lessons learned
into future security efforts    As part of implementing this measure, the  WSWG believes utilities should  pay
particular attention to circumstances, if any, where it becomes clear that a secunty incident was not reported in  a
timely way. This might be the case, for example,  where employees are aware a lock or other security barrier  is
damaged, but do not report it, so the  damage is  instead discovered by an internal utility audit or other security
check. These circumstances are important indications of the extent to which security tactics and approaches are
working on the "front lines"  of an organization and are a key measure of the presence  (or absence) of a security
culture. Measure 2 also suggests utilities explicitly review responses to security incidents and incorporate lessons
learned into  future secunty efforts, as appropriate   This ongoing  learning and adapting  as  utilities gam
expenence with secunty is key  to increasing the protectiveness of a security program and to  creating a security
culture  Note that the Group chose not to establish a standard  timeframe  for what constitutes "timely" reporting
of  incidents    Instead, utilities should establish  incident reporting expectations  appropriate  to their specific
circumstances and operating conditions

Water Securcy vVor'.pg Group Fipe.-.gs  "reseTed to The Na::ona: Drinking Warer Aid>'*orY Council 5/1C/05               Pape 37

-------
Up-to-Date Assessment of Vulnerability

Feature 3—Water and wastewater utilities should assess vulnerabilities and periodically review and
update vulnerability assessments to reflect changes in potential threats and vulnerabilities.
Understanding and  assessment of vulnerabilities is  a key building block of an  active and effective security
program   It  establishes critical  security  needs,  identifies and describes  utility-specific circumstances and
operating conditions that define vulnerability, and establishes the key risks and security enhancement priorities
that will drive security planning.  Over time, utilities should expect that the conditions that defined their initial
assessments  of  vulnerability  will  change—they  may  become  less  vulnerable  because  of changes  to
circumstances,  infrastructure,  or operating conditions,  or they  may  become more vulnerable  because  of
changing threat or attack probabilities  Threats will change over time and security improvements will change a
utility's susceptibility to ongoing and new threats   Because circumstances change, utilities should  continually
adjust their security enhancement and maintenance prionties so they remain responsive to vulnerabilities.

This  finding establishes the expectation  that utilities should maintain  their understanding and  assessment of
vulnerabilities  as a  "living  document"  that  reflects current security-related conditions   To accomplish  this
objective, utilities should periodically review and update  their assessment of  vulnerabilities and risks,  including
the design basis threat used as the foundation of the vulnerability assessment   The timing for review will vary
across utilities, depending on  the degree to which security-related conditions are  changing and resources are
available   Utilities should consider their individual circumstances and  establish and implement a schedule for
review of their vulnerabilities.  At a minimum, the WSWG believes all utilities should reassess their vulnerabilities
and  risks at  least once every three to  five years   Conditions  that  might prompt  more frequent review of
vulnerabilities include major facility construction projects, adding new  facility infrastructure (by construction or
acquisition), new information  about specific threats, and significant attacks  or  other events that would  cause
reconsideration of utility vulnerability. Many WSWG members believe utilities would be well served by reviewing
their assessments of vulnerability annually, and believe an annual review should take place   For these updates
to assessments of vulnerabilities to be earned out,  it also  is important for EPA and DHS to provide  updated,
timely, actionable threat information to the water sector.  As discussed more fully in  Feature 10, more progress is
needed in this area

Reviews of vulnerabilities should be earned out by those involved in the  security program  and knowledgeable of
utility operations  An executive should be included to provide an ongoing conduit of information to and from
management, and so that management's awareness of security continues to grow   The information considered
during the review and any changes to the understanding or assessment of vulnerabilities should be documented,
so utilities can form  a long-term basis for decision making and track their progress over time.

The WSWG notes that there are a number  of publicly or  commercially available methodologies utilities can use
to help them  understand and assess vulnerabilities, and  new methodologies are being developed   These
methodologies may be very helpful to utilities in that they create a standard process for vulnerability assessment
that can be replicated, so changes in vulnerability can be  measured over time  The WSWG is not suggesting
use of any particular vulnerability assessment methodology  Rather, utilities should use the methodology that
best suits their particular circumstances, taking care to ensure consideration of the significant system failures and
key threats or methods of attack suggested for consideration earlier in  this document (see Finding 3).   EPA has
published guidance on the basic elements of sound vulnerability assessments; these elements are

>    Characterization of the water system, including its mission and objectives,
>    Identification and pnontization of adverse consequences to avoid;

Water Secunry Woi-'-pg Group Fipd-r.gs -Presti'ed to The National Dr.nking Water Adv-scry Council 5/10/05                P-ajse 33

-------
>    Determination of critical  assets that  might be subject to malevolent acts that could result in undesired
    consequences,
>    Assessment of the likelihood (qualitative probability) of such malevolent acts from adversaries,
>    Evaluation of existing counter-measures; and
>    Analysis of current risk and development of a prioritized plan for risk reduction
Measure 3—Are reassessments of vulnerabilities made after incidents, and are lessons  learned and
other relevant information incorporated into security practices?
Feature 3 establishes the expectation that utilities should maintain their assessments of vulnerabilities as living
documents that reflect current threats and utility-specific security tactics and approaches. This measure suggests
that  utilities  reassess vulnerabilities after  incidents, and  incorporate  lessons learned  and other  relevant
information into security practices   For example, lessons learned in reassessing vulnerabilities after incidents
might help a utility improve its practices for access detection and control.  Alternatively, lessons  learned might
help a utility identify new security priorities  and change the way it invests security resources.  As discussed
throughout this document, the WSWG believes strongly in the importance of ongoing, thoughtful reassessment
and  adaptation,  as  a way to  keep security  programs "fresh"  and  effective,  take advantage of emerging
approaches and new technologies, and perpetuate a security culture throughout an organization.
Resources Dedicated to Security and Security Implementation Priorities

Feature 4—Water and wastewater utilities should identify security priorities and, on an annual basis,
identify the resources dedicated to security programs and planned security improvements, if any.
No organization can sustain focus on a priority in the absence of dedicated resources, and utility security is no
different   To  ensure  utilities sustain focus on their ongoing  security programs and on security improvement
priorities, this  feature  establishes the expectation that utilities  should, through their annual capital, operations
and maintenance, and staff  resources plans, identify  and set aside resources consistent with their specific
identified security needs

The WSWG highlights three ways that utilities might invest resources in security

First, and perhaps most importantly, utilities can and should "invest" in secunty by increasing the amount of time
and attention that executive and line managers give to security. It is important not to underestimate the value of
these contributions—|ust increasing attentiveness  will  improve  security, even if no other changes or investments
are made  Utilities might ensure this extra  attentiveness by including  security in semi-annual  performance
reviews and progress reports, or by making security a standing  item on executive management agendas.

Second,  utilities will invest staff time and resources in security by including security considerations in budgets for
personnel and training. For some larger utilities, this might include adding new staff dedicated to security  For
others, particularly smaller utilities, it may  mean  specific acknowledgment that existing staff are taking on new
security-related responsibilities.  In both cases, utilities  should account and plan for the staff  costs associated
with secunty responsibilities.  Utilities also might dedicate resources to security by including security training and
exercises in their annual operations plans  Even when training and exercises are absorbed by regular operating
budget categories, it should be acknowledged that these expenses will occur, and  that covering these security-
related expenses may  represent a decision to do less of something else.
Water Secumy Wor'ipg Group F'pe.ngs  Pres?-,>snai Dr.nksng Ware.- Advisory -Council 5/18/05                Pgae 3°

-------
Third, and perhaps most obviously, many utilities will make ongoing capital investments in secunty   Capital
investments might include physical hardening  of  structures, investment in monitoring devices, purchase of
emergency response equipment, and design and construction of new facilities and infrastructure.

The WSWG recognizes that  utilities always must balance resource allocations among a number of important
obligations   To reflect their  ongoing  commitment  to security and to, over time, balance resource allocations
among  security improvements  and other organizational  priorities,  utilities should  establish clear secunty
improvement priorities

One way that utilities might record their secunty  improvement priorities is in a security improvement plan.
Security improvement plans create a clear sense of security priorities and place those priorities in the context of
other organizational priorities.  Successful security improvement plans address what a water or wastewater utility
will do relative to all features of an  active and effective security program; not only those associated with physical
hardening  or access  control, or those that require significant capital investment   For example, a successful
security improvement plan will address activities that  help to build a security culture in an organization and
activities associated  with  building  community partnerships, just  as much  as it  addresses  investments an
organization will make in new equipment to improve security

Whatever means utilities use  to document their security improvement priorities, these priorities should be clearly
recorded in a living document that will, by definition, change over time  Security improvement  priorities should
be reviewed, along with other annual plans and investments, with top utility executives at least once a year. This
review might include an update/status report on secunty enhancements undertaken to date, a high-level review
of remaining vulnerabilities and risks,  and a description/identification of pnorities for the upcoming and future
years.   Over  time, this type of annual review will  give utilities  the information they need to  carry out trend
analysis, document  progress, and  form opinions  on  whether the level  of resource investment in security  is
appropriate.

To  the  extent appropriate, utilities  might integrate  a  security improvement plan with other annual operating
plans  Such integration may  provide a valuable opportunity for utilities to continue to integrate security into day-
to-day management, operations, and  tracking  It also may  serve to highlight areas where a potential secunty
improvement  would also create value for another part of the organization; for example,  where a monitoring
protocol that  improves security also improves operations, by allowing operators to fine-tune treatment systems
more efficiently  and effectively.  In  general,  the WSWG believes that utilities are best served by incorporating
security considerations into  the  enterprise-wide capital and operating budgets and plans that are already
prepared.

It is important to note that the WSWG  is not suggesting a standard dollar amount of  security investment that
would be appropriate for all  utilities. As discussed earlier in this document (see Finding 1), each individual utility
must tailor their security approaches and tactics to their speafic circumstances  For some  utilities, it may be
necessary and practical to make large capital investments in security, or to invest in dedicated security staff  For
other utilities, especially smaller utilities, the potential for capital  investment may be  much less—and much less
needed—and  new  security-related  responsibilities and  attentiveness  will be absorbed  into  existing  staff
responsibilities.  The  key  is that utilities make some investment  and that whatever the level of investment of a
particular utility, the investment is made consciously  and in light of a thoughtful assessment of vulnerabilities and
related  security improvement priorities.
Water Security vVor''pg Group F'PC r-tjs- Presented to :he NcTronoi Dnnlurtc WcTer Advisory '^outcil 5/1G/05                Pape 40

-------
Measure 4—Are security  priorities cleaHy identified,  and to what extent do security priorities have
resources assigned to them?
Some WSWG  members believe informed  identification  of  security  priorities and  corresponding  resource
decisions are the keys to an active and  effective security program  Feature 4  establishes the expectation that
utilities will identify and set aside resources consistent with their specific identified security needs in their annual
capital,  operations, and maintenance  budgets,  and staff resources plans.   This measure establishes the
expectation that utilities will  monitor the extent to which priorities are identified and resourced   Note that the
WSWG does not assume all  security prionties will have resources assigned to them.  The Group recognizes that
utilities  may have security priorities in which they cannot afford to invest.  This measure reflects the Group's
belief in the  importance of  utilities recognizing  and monitoring  these situations,  and understanding utilities'
ability to invest in security over time


Defined Security Roles and Employee Expectations

Feature 5—Water and  wastewater utilities should  identify  managers and  employees who  are
responsible for security, and establish security expectations for all staff.
While all utility employees likely have a contribution  to make to  security, establishing overall responsibility for
ensuring a  utility's security  plans are  implemented  and maintained  is  important  to  creating  a sense  of
accountability for secunty  and  providing  for secunty-related leadership    Explicit identification  of  security
responsibilities also is important for development of a security culture.  Accountability for security should be
clearly fixed with an individual or individuals, and established at a high enough level to  ensure that security is
given management attention and to make security a priority for line supervisors and staff.

WSWG members defined a  number of crucial secunty-related roles and responsibilities utilities might consider,
including security program implementation  management, physical intrusion and contamination detection, and
incident command  roles during  emergency  response and  recovery   At  a  minimum,  utilities should identify a
single, designated individual responsible for overall security, even if other security roles and  responsibilities will
likely be dispersed  throughout the organization   In addition, security expectations should be included in job
descriptions and annual performance reviews for all employees with security responsibilities  Even when secunty
is not a full-time duty,  there should be  an  assigned manager in the  utility who is responsible for operating a
meaningful security program

The WSWG emphasizes that implementation of this finding will differ, potentially substantially, depending  on a
utility's  specific circumstances   For example, large urban utilities  might create a security department with a
director and  staff fully dedicated to security program implementation. Alternatively, a small rural utility might
assign all security program implementation responsibilities as part of one individual's |ob
Measure 5—Are managers and employees who are responsible for security identified?
Feature 5 reflects the WSWG belief that accountability for secunty should be clearly fixed with an individual or
individuals,  and  established at a high enough  level  within  the  organization to  ensure security is  given
management attention and to make secunty a priority for line supervisors and staff  This  measure suggests that
utilities should assess whether they have clearly fixed responsibility for secunty by evaluating whether they have
identified managers and employees  with security responsibilities.  As described  earlier in this document, it is
important to recognize that the WSWG is not suggesting a specific security staffing or management structure
Large  urban utilities may create a security department with a director and staff.  Smaller  utilities may assign all

Water secun) Wof-nq Croup F-nd-ngs  Presented to :he NcTionai Deplane Wa:er Advisory Council 5/1G'05                Pace 41

-------
security responsibilities to an existing employee or to a general manager.  Both approaches are consistent with
the WSWG's finding, provided the responsibility for security is clearly understood and there is accountability for
security with organization leadership.
Access Control and  Intrusion Detection

Feature 6—Water and wastewater utilities should establish physical and procedural controls to restrict
access to utility infrastructure to only those conducting authorized, official business, and to detect
unauthorized physical intrusions.
Intrusion detection  and access control  is a cornerstone of all active and effective security programs.  Utilities
should  implement  measures to deter  unauthorized  intrusions  to  facilities and operations,  and  to  detect
unauthorized access to utility assets in a manner that is timely and enables the utility to respond effectively.

Access control will  involve both physical and procedural means to restrict access to treatment facilities and to
supply/distribution/collection networks,  for the purposes of deterring physical harm and/or the introduction of
harmful chemical, biological, or other  substances into the water supply/treatment/distribution and wastewater
collection/treatment systems.  Examples of physical access controls include fencing critical areas, locking gates
and doors, installing barriers at site access points, and installing tamperproof devices at key distribution points.
Procedural examples  include inventorying keys, changing access codes regularly, requiring security passes to
pass gates and access sensitive areas,  establishing a security presence at facility gates, requiring all visitors to
have scheduled appointments, requiring visitors to sign in at a front  desk and display identification at all times,
implementing chemical delivery  and testing  procedures including chain of custody  control, limiting delivery
hours, and  checking  all deliveries to ascertain nature of  material   The American Water Works Association
Research  Foundation's (AWWARF) Security  Prachces Primer for Wafer Utilities  (2004)  provides additional
information on physical and procedural access controls

Monitoring for physical intrusion can include such physical  enhancements as  maintaining well-lighted  facility
perimeters,  monitoring with closed  caption  TV,  installing  motion  detectors,  and utilizing  intrusion alarms.
Procedurally, the  use  of neighborhood  watches, regular employee rounds, and arrangements with local police
and fire departments can support identifying unusual activity in the vicinity of facilities.

All  employees, including contractors and temporary workers with unescorted access to facilities, should have
their identity verified  through background checks to reduce  the  possibility that  ill-intentioned individuals  are
present in an organization.  The degree and  rigor of background checks can be tailored to the responsibilities
and privileges of  the employee, and utility-specific circumstances and operating conditions   For example, front
office clerical staff with no access to cntical facility operations might receive a  lower level of screening than plant
operators.  In small communities, utility  officials might have first hand knowledge of an individual's background,
which could  act  as an effective screening  method absent a more  formal background check  Adjusting  the
degree and rigor of background checks to specific circumstances will help utilities manage concerns related to
the costs of checks and checking delays

WSWG members believe effective background checks are a very useful way to verify employee identity, establish
citizenship, previous criminal activity, and work  eligibility, and to confirm  the  individual  is  not  on a current
terrorist watch list.   Group members  support using  background  checks for these purposes,  even as  they
recognize that some publicly-funded utilities may face legal barriers or constraints on  their  ability to  use
Water Secuny Wofinq Group Find-figs  Presei'ed to :he Ncfsonai Drinking Wawr Adi-sory Council 5/1C/05                Pajse 42

-------
background checks,  particularly  for existing employees.   The Group encourages  public agencies to work to
overcome these barriers so that they can use background checks to enhance security

While  background checks  represent a sound business  practice and can  deter  ill intentioned people  from
attempting to establish employment,  it is important to understand  that they are just one part  of an effective
intrusion detection and access control program.  Background checks may not be sufficient to identify or deter a
determined, sophisticated, systematic attempt to infiltrate a utility organization, since in these cases, individuals
with passable backgrounds are likely to be used  In addition, background checks might create impediments to
business if requirements are overly broad such as to restrict appropriate site access for emergency responders,
customers, business visitors, union industrial hygienists,  and others, and should not create  overly burdensome
cost barriers to legitimate access to employment or information

Utilities also should  establish the means to  readily identify  all  employees.  Many utilities find that use of
identification badges or other photo identification is an efficient way to identify employees.  Photo identification
badges can be displayed by all employees at all times, in plain sight  For some utilities, it has been helpful to tie
identification badges into systems of access control, allowing only certain employees access to security-sensitive
or other critical areas, these systems also can be used to quickly deny access to any individual in  the event of an
emergency or a secunty-related concern

The WSWG notes that individual utilities  may choose to place more or less emphasis on access control  versus
intrusion detection.  For example, some small  utilities have recognized that, as a practical matter, it may be very
difficult to control access to remote, unguarded infrastructure, and have chosen to invest more heavily in systems
or procedures that detect unauthorized access (intrusion) and enable the utility to respond appropriately.


Measure 6—To what extent are methods to control access to sensitive assets in place?
Feature 6  calls on utilities  to establish physical and procedural controls to detect unauthorized intrusions and
restrict access to utility infrastructure to only those conducting authorized, official business  Measure 6 highlights
a key  subset of efforts to detect intrusions and control access by focusing on sensitive assets. The Group is not
describing a standard list of sensitive utility assets, or a particular  set of approaches or tactics that  should be
used to detect and  control access   Rather, utilities should identify sensitive assets  based on their specific
circumstances and  operating conditions, and  should  develop  and  implement  utility-specific  access control
approaches and tactics  There are a number of ways that utilities might assess the  "extent" to which methods to
detect intrusions  and control access are in place   For example, utilities just beginning to develop a security
program  might measure the number and percent of  sensitive  assets protected  by access control  methods.
Utilities with more experience might test intrusion detection and access control methods at sensitive assets and
measure their performance  Over time, measure 6 contemplates that utilities will have well functioning intrusion
detection and access control methods in place for all sensitive assets
 Contamination Detection, Monitoring, and Surveillance

 Feature 7—Water and wastewater utilities should employ protocols for detection of contamination
 consistent with  the  recognized  limitations in  current  contaminant  detection, monitoring,  and
 surveillance technology.
 Contamination  detection,  contaminant monitoring, and surveillance are different but related  elements of a
 contamination warning system.  The WSWG discussed three points with respect to contamination detection,

 Water Securay vVor'.p!} Croup F-pckgs  Presented to :he Ncnono! Drinking Water Adv.scry -Council 5/1G/05                Pape 43

-------
monitonng, and surveillance  physical monitoring or surveillance for contaminants, monitoring or surveillance
of indicators of contamination, and connections with customers and public health providers

Physical monitoring or surveillance for chemical, biological, and radiological contamination is an evolving area,
with research  underway to provide for more direct and real time methods.  Currently, physical monitonng and
surveillance for contamination is limited in large part by a lack of reliable or affordable technology and the lack
of guidance or experience in how to interpret  monitoring  or surveillance results   In  Finding  8, the WSWG
addresses the need to support  development  of practical, real-time contaminant monitoring  and surveillance
systems and protocols to  help utilities evaluate and respond to contaminant monitoring and surveillance data
With a grant from EPA, the Amencan Society of Civil  Engineers recently issued Interim Voluntary Guidelines for
Designing an  Online Contaminant Monitoring System   These guidelines provide information  on assessing the
need for a  contaminant  monitoring  system, locating  instruments and sensors, and responding to suspected
contamination events.

While encouraging use of online  contaminant monitoring or surveillance systems where  they can be put into
place, the WSWG also recognizes that much of the basic scientific and engmeenng knowledge needed, and the
instrumentation needed to accomplish the |ob directly, is not yet available in the marketplace. Other guidelines,
such  as  AWWARF's  Design of Early Warning and Predictive Source-Water Monitoring  Systems (2001) and
Online Monitoring for Drinking Water Utilities (2002), and  EPA's Response Protocol Toolbox,  also encourage
use of current contaminant monitoring approaches, while recognizing the limitations  of current approaches and
the need for additional research and development. Until progress can be made in development of practical and
affordable online contaminant monitoring and surveillance systems, most utilities must use other approaches to
contaminant monitoring and surveillance

In the absence of practical technologies  for contaminant monitoring  and surveillance,  routinely  monitored
physical and chemical parameters  hold some potential to act as contamination surrogates (signaling possible
contamination problems), but this potential is limited.  Until new technologies are reliable and affordable, some
utilities  are  trying to  use careful monitoring of physical and  chemical  contamination  surrogates, and  use
surrogate data, as an indicator of possible contamination problems  Physical and chemical contamination
surrogates include pressure change abnormalities, free and total chlonne  residual,  heterotrophic plate count,
high  volume  total fecal   coliform  analysis,  temperature,  dissolved oxygen,  conductivity, oxygen-reduction
potential, total dissolved solids, turbidity, pH, color, odor, and taste.

Many utilities  already measure these parameters on  a regular basis to control plant operations  and confirm
water quality,  more closely monitoring these parameters may create operational benefits for utilities that extend
far beyond security.  For example, by more closely monitoring water quality parameters, one utility was able to
more effectively target chlormation, thereby reducing operating  costs and  chlorine  usage  At the same time,
there are limited data and experience correlating changes in routinely collected physical or chemical monitoring
data with actual contamination events Often, the relevance of changes in these data to security can be difficult
to interpret and, therefore, is difficult for utilities to act upon from a security perspective

Finally, utilities also should thoughtfully monitor customer complaints and improve connections with local public
health networks to detect public health anomalies   While the  WSWG emphasizes that using customers  as
indicators of potential contamination problems is far less  than  ideal, at a practical level, until  contaminant
monitoring technologies are improved, attention to customer complaints and public health anomalies are an
important way to detect potential  contamination problems  and  other water quality  concerns    Utilities should
consider customer  complaints  from  a security-related  perspective  and should forge closer connections and
partnerships with their local public health communities,  so  that  public health anomalies can be evaluated for

Water Secunry vVori-ipq Group F.pd'ngs  Presented to The National Dnnkina Warer Adv-isory -Zounc:) 5/16/05               Pape 4 4

-------
water security implications  (The need to strengthen connections with public health also is addressed in Finding
7.)
Measure  7—Is  there  a  protocol/procedure  in   place  to  identify and  respond  to  suspected
contamination events?
Feature 7 calls on utilities to employ protocols for detection of contamination  consistent with the recognized
limitations in current contaminant detection technologies.  As discussed  earlier in this  document, the WSWG
recognizes  and  is  concerned  that utilities'  abilities  to undertake  chemical,  biological,  and  radiological
monitoring of contamination are limited, in large part, by the lack of reliable or affordable technology and the
lack of guidance or experience in how  to interpret monitoring results.  Earlier findings call  for aggressive
financial and technical  support for development of cost-effective, reliable contamination  monitoring devices  At
the same time, the WSWG believes that, as  part of an active and  effective security program,  utilities should
employ protocols for detection of  contamination consistent with current  recognized limitations    Efforts might
begin with  a close monitoring of routine water quality testing for anomalies that could  signal a contamination
event,  monitoring  public  health anomalies  and customer  complaints, and having a  protocol  in place for
responding to potential contamination events.  Over time, contaminant detection  efforts might be expanded to
include periodic regular testing for contamination or event-based contamination  testing (i.e , testing in the event
of a specific threat, or identified security breach).  In the future, practical, in-line, real-time parameter-specific
contaminant detection approaches  may become available

Regardless of the approach to contaminant detection a utility uses, measure  7 highlights a crucial aspect of the
success  of  contaminant  detection    the existence of  a  protocol to  identify  and  respond  to  suspected
contamination events
 Information Protection and Continuity

 Feature  8—Water  and  wastewater utilities  should  define security-sensitive  information,  establish
 physical  and  procedural controls to restrict access to  security-sensitive information as appropriate,
 detect unauthorized access, and ensure information and communications systems will function during
 emergency response and recovery.
 Information technology (IT) systems are critical to the smooth and consistent operation of water and wastewater
 utilities, and maintaining access to information and telecommunications systems during an emergency is cntical
 to effective response   This feature establishes the expectation that utilities should protect IT systems, including
 SCADA  systems,   define  and  protect  security-sensitive  and  vital  information,   and  plan  for  effective
 communications during and after emergency responses.

 With respect to protecting  IT systems, the WSWG discussed two areas of emphasis   (1) restricting access to
 critical IT systems (such as SCADA)  to  authorized  personnel  conducting  official  utility  business, and  (2)
 maintenance of an uninterruptible power supply

 Protecting IT systems largely involves using physical hardening and procedural steps to limit the  number of
 individuals authorized  to  access critical  IT systems  and  to  prevent access by  unauthorized individuals
 Procedural steps might include restricting  remote access to  data  networks, safeguarding critical  data  through
 backups  and storage in safe places,  establishing  procedures  to restrict network  access,  and  implementing
 policies to ensure thai IT  contractors  and their  products will not negatively affect IT systems.  Examples of

 Water Securny Woit-ng Group F.ns.rgs  Pre5?i»d to The Ne::onai Dr-nksng Waier Ad.'*cry Counc:! 5/18/05               Pape 45

-------
physical steps to harden SCADA and  IT networks include installing and maintaining  firewalls,  screening the
network  for  viruses, separating  business  systems  from  operational  systems,  installing  a  system for virus
protection, ensuring security and location of SCADA system components, encrypting access via modem to utility
networks—including  wireless  networks,  conducting  regular  penetration  evaluations, avoiding  connecting
modems to desktop systems on the secure network, allowing  remote access only from utility computers, and
establishing and regularly changing computer system access codes

Utilities should also strive for continuous operation of IT systems, even in the event of an attack, by providing for
an uninterruptible power supply and the use of back up power generators or other back up power means

It is also important to control access to  security-sensitive information on utility operations or technical details that
could aid terrorist planning and operations.  The first step in  this process is to review information  sources  to
identify those containing security-sensitive  information.   This  review will  need to consider facility  maps and
blueprints, operations details,  hazardous matenal  utilization,  tactical level security program details, and any
other information on utility operations or technical details that  could aid in planning or execution of an attack
Identification of security-sensitive information  should consider all ways that utilities might use and make public
information (e g , many  utilities may at times engage in competitive bidding processes for construction of new
facilities or infrastructure)   While there is an interest in ensuring  that  such bidding processes are in fad
competitive, care also should be taken to safeguard security-sensitive information   Some  utilities use bid pre-
qualification systems to screen potential bidders for security purposes and then restrict access to security-sensitive
information to screened bidders. Because many utilities are  public or quasi-public agencies, and all utilities
operate to serve  the public  trust, typically  this review also will include developing  an understanding of local
freedom  of information or Sunshine  Act requirements to ensure access  procedures  fully  comply with such
requirements

When  security-sensitive information is  identified, utilities should develop access restrictions and  procedures  to
safeguard  that information   At the same  time, utilities  should also develop procedures that make security-
sensitive information  available to employees and others who need it  If access restrictions are so severe as to
limit practical use of information by employees, the restrictions likely will not be followed and security could be
compromised The WSWG is not suggesting a standard definition of security-sensitive information or a standard
set  of  protocols to control access to such  information.   The water sector may wish to continue to work with
federal agencies, and with community  and  public interest stakeholders, to create guidelines for identification of
security-sensitive information and for providing appropriate access to such information  In  the absence of such
guidelines, utilities  should develop protocols to identify and  provide  appropnate access to security-sensitive
information, based  on their specific circumstances and operating conditions

In addition to controlling access to  security sensitive information,  utilities should  take steps  to ensure  the
preservation of information critical to the continuity of operations.  These steps could include the identification of
information needed to sustain day-to-day operations and arrangements  for the back up and safe keeping  of
such information.

With respect to telecommunications, utilities should take steps to ensure the maintenance of critical internal and
external  communications in  the event of an attack    In  the  event  of  an  emergency,   conventional
telecommunications networks  will come under severe pressure and may fail.  Utilities should  plan  for this
possibility and should evaluate the need and means for providing back up systems that will maintain contact with
police, fire, and  other first response organizations,  and maintain internal communication with  employees  to
ensure safety and to coordinate response activities.
Water Secunry vVor'-pq Group F'nd-r.gs  Presented to !he Nc::onai Dr.pknc Waier Adv.sc-y 'Zcurtc:! 5/18/05                Paae 46

-------
Measure 8—Is there a procedure to identify and control security-sensitive information, is information
correctly categorized, and how do control measures perform under testing?
Feature 8 calls  on utilities to establish physical and procedural controls to define security-sensitive information,
restrict access to such information as appropriate, and detect unauthorized access.  Measure 8 suggests that
utilities should  assess whether they have the tools in place to define  and restrict access to security-sensitive
information,  and evaluate their performance by reviewing whether information is correctly categonzed and
determining how access control methods perform under testing.  Evaluating  whether there  is a procedure to
identify  and  control security-sensitive information is  straightforward    Evaluation of whether information is
correctly categorized  might take  a number of forms, such  as routine auditing or categorization tests  The
purpose  of evaluation of whether information is  correctly categorized  is to determine if  a  utility is identifying
security-sensitive information in  accordance with its utility-specific protocol,  so  that security-sensitive information
is properly identified and controlled and, |ust as important, non-security-sensitive information is made available
to the public as appropriate.  Testing of access control methods might take a number of forms. For example, a
utility might  test  paper  document protection  methods by  submitting  and  then  monitoring  response  to
inappropriate  document  requests.   Testing of electronic  information  protection  methods might  involve
monitoring the  performance of firewalls or other cyber protection devices. The WSWG is not suggesting specific
testing protocols or frequency,  instead, utilities should determine the testing  that is  most appropriate to their
specific  security  tactics  and approaches     The WSWG emphasizes that it does  believe some testing  of
information access control measures is necessary to maintain an active and  effective security program.
 Design and Construction

 Feature 9—Water and wastewater utilities should  incorporate security considerations into decisions
 about acquisition, repair, major maintenance, and replacement of physical infrastructure; this should
 include consideration of opportunities to reduce risk through physical hardening and the adoption of
 inherently lower risk design and technology options.
 Over the long term, utilities have the opportunity to reduce their vulnerability and risk, in part by redefining the
 physical context  in  which they operate   This occurs as  utilities make  investments in  new real  estate or
 infrastructure, and  repair and/or  replace existing infrastructure   All  such activities at  utilities are guided by
 design  and construction standards that direct and constrain the choices the organization will make.  Utilities
 should  incorporate security-related considerations into these standards, with the intent to reduce their inherent
 security risk over time

 To be effective, design and construction standards should  address two  dimensions of  security  risk   physical
 hardening of critical assets and  the adoption of inherently lower security risk technologies and approaches
 Physical hardening  of  critical  assets  is designed  to deter and/or help  mitigate physical damage, service
 disruption, or other serious consequences in the event of attack   Physical  hardening  involves  designing-in the
 means  to make a facility harder to attack (or appear harder to attack) and to reduce the effect of any attack that
 may take place.  This typically involves considerations such as the location of critical infrastructure  relative  to
 penmeter areas and the natural  shielding provided to infrastructure by the choice of building materials (e g ,
 concrete reinforced walls versus  structural glass)   Design choices also  should consider  the  ability  to ensure
 continuity of operations and rapid  recovery in a successful attack, natural disaster, or other event

 The adoption of inherently lower security risk technologies and approaches involves considenng how design and
 technology choices reduce the likelihood or extent of the consequences of concern.  Such choices should further
 consider opportunities  for reducing safety  risk, in addition to  security risk.  For  example, certain treatment

 Water Secunry vVori-.ng Group Findings  Freseved to The Nc::onal Drink^c Wcter Adv.so.-y Council 5/18/05                 Fage 4 7

-------
technologies  may be  less dependent  upon the storage and utilization of hazardous chemicals, reducing both
secunty and safety nsks   Another example might be the purchase of additional buffer real estate, which can
serve both to increase the stand-off and detection distance of a water supply or critical facility, and provide
source water  protection potential.

It is important  to recognize that to incorporate  secunty  considerations into  design  choices, utilities  need
information  about  the  types of  security design  approaches and  equipment  that are  available and the
performance  of  these designs and equipment in multiple  dimensions.   For example,  utilities  would want to
evaluate not  just the way that a  particular design might contribute to security, but would also look at how that
design would affect the  efficiency of day-to-day plant operations and worker safety  Under a grant from EPA,
AWWA recently  issued  Interim  Voluntary Security  Guidelines for Water  Utilities  (2004) and  the Water
Environment Federation  recently issued Interim Voluntary Secunty Guidance (or Wastewater/Stormwater Utilities
(2004).  These documents provide information for designers  and owners/operators of water and wastewater
utilities on design approaches and upgrades that improve secunty and reduce vulnerability   Other documents,
such as the EPA Security Product Guides, provide information  that can help utilities evaluate design options to
optimize design choices
Measure 9—Is there a protocol/procedure for incorporation  of security considerations into internal
utility design and  construction standards for new facilities/infrastructure, and major maintenance
projects?
As discussed earlier in this document, utilities have the opportunity to reduce their vulnerability and risk over the
long term, in part by better incorporating security into utility design   Consistent with its principle of emphasizing
prevention  and  encouraging use  of inherently safer  (i.e , lower risk)  practices,  the WSWG emphasizes the
opportunity that design choices  create to improve security  Feature 9 establishes the expectation that utilities will
incorporate  security considerations  into  decisions about  acquisition,  repair,  and replacement  of physical
infrastructure,  and will  consider opportunities  to  reduce  risk potential through  physical  hardening and the
adoption of inherently lower risk design and technology options.  This measure suggests that utilities verify they
are bnnging security considerations forward as early  in the design process as practicable by incorporating
security into  internal  utility design and  construction standards,  planning, and budgeting   Measure 9 also
emphasizes  the importance of  considering security both during design  and construction of new facilities, and
during infrastructure and major maintenance activities, as these activities likely are more common than new
construction


Threat Levei-Based Protocols

Feature 10—Water and wastewater utilities  should  monitor  available threat-level information and
escalate security procedures  in response to relevant threats.
DHS regularly updates the national threat level in response to information about potential attacks. More specific
information  is also made available  to  utilities through  secure information channels, such as the WaterlSAC
Utilities should monitor this information so that  they are aware of threats and can adjust security operations as
needed. By providing for escalation of security operations  in response to industry-specific threats and focusing
security operations in response  to  specific  threat information,  utilities are  better prepared  to identify and
potentially counter site-specific  threats, and reinforce the expectation that security is a regular part of day-to-day
operations


Water Secunry '/v'op'ipg Group F-nd-rgs- Preset'ed to The Ncisona! Drinking Worer Advisory Council 5/1G/05               Pace 43

-------
The WSWG notes that there was a range of views in the Group about the relative utility of the national threat
levels published by DHS—some members view these national threat levels as having very little relevance to utility
operations; other members were less cntical  of the national threat levels.  Despite this range of views on the
national  threat level system, the Group agreed that more specific information on utility-, facility- or region-
specific threats or concerns is  more useful and  more important to monitor and that EPA and  DHS should
improve their efforts to provide updated, timely, actionable threat information to the water sector

Secure alerts on threats and potential threats to water and wastewater utilities and other critical infrastructure are
available to utilities through a number of national networks, including  WaterlSAC, the Water Security Channel,
Infraguard,  and through local networks,  such as the Northwest  Warning, Alert & Response  Network  (NW
WARN).  Other networks are being developed, including the SouthEast Emergency Response Network and the
DHS Homeland Security Information  Network (HSIN)  Utilities should investigate what networks and information
sources might be available to them locally, and at the state or regional level. The WSWG notes that, in some
cases, it  may be difficult for utilities to gain access to some information networks;  where barriers exist, attempts
should be made to align with those who can and will provide effective information to the utility.

Monitoring threat  information should  be a regular part of the security-program manager's  job, and utility-,
facility- and region-specific threat  levels and information should be shared with those responsible for security
and other key security staff   As part of  security planning, utilities should  develop systems  to access  threat
information,  procedures  that will be followed in the event of  increased industry or facility threat levels,  and
should be prepared to put these procedures in place immediately, so that adjustments are seamless  Enhanced
security procedures might include,  for example  notification to first responders that threat levels have increased,
posting signs or otherwise notifying  line staff and managers, and/or further reducing/controlling access  to the
utility or  increasing contaminant monitoring


Measure 10—Is there a protocol/procedure for responses  to threat level changes?
By altering security practices in  response to specific threats, utilities are better prepared to respond to events and
reinforce security as  a regular part of day-to-day utility operations  Feature  10 calls on utilities to monitor
threat-level information, with an emphasis on information related to the utility and water sectors, and to escalate
secunty  procedures in  response to increased threats as  part of  an active and effective security  program
Measure 10 emphasizes the importance of the planning element associated with feature 10, by  suggesting that
utilities  evaluate whether  they are  prepared  to take  appropriate  action  in response to  changing  threat
information.  The WSWG is not suggesting a specific  threat  threshold for  action or specific actions to take
Utilities should identify the types of threat levels and information they will respond  to, and  the specific responses
they will take, based on their specific circumstances and operating  conditions.

Note that there was a range of views among WSWG  members about the relative utility  of the national threat
levels published by  the DHS.   The  Group does  not  assume  utilities need to implement special security
procedures in response to  changes  in  the national  threat   level.  The Group  is  more concerned  about
attenhveness to threats that are specific to a region, utility, or the water sector more generally  The WSWG also
notes that threats need  not be of a terrorist nature to prompt utilities to implement special security or other
 procedures  Many utilities have already developed special operational procedures that can be put in place in
 response to  storms or other natural disaster threats  These procedures might be used as the basis for special
security  procedures.
 Water Securcy vVoi-'.ng Croup F-rd^gs  PrKifWJ to ihe Ncisona: Dfpk:ng WaTer Adi-scry 'Zcuncil 5/18'05                 Pape 4s?

-------
Emergency Response and Recovery Plans

Feature 11—Emergency response and recovery plans should incorporate security considerations, be
tested and reviewed regularly,  and updated as  necessary to reflect changes  in  potential threats,
physical infrastructure, utility operations, critical interdependencies, and response protocols in partner
organizations.
Emergency response and recovery plans describe who will do what in the event of an emergency  They are the
critical document for establishing emergency response and  recovery roles and priorities, and for assuring the
continued safety of utility operations during and immediately  after  an emergency response.  Over time, the
conditions  that defined  utilities'  initial  emergency response and recovery plans will change, their plans and
priorities should be changed and updated accordingly

This feature  establishes  the expectation that  utilities  should  incorporate  security  considerations  into  their
emergency response  and recovery  plans, and  should maintain  these plans  as  "living  documents."   In
incorporating secunty considerations into  their emergency response and recovery plans, utilities also should be
aware of the National Incident Management System (NIMS) guidelines, established by DHS, and of regional and
local  incident management commands  and  systems, which tend to flow from the national guidelines. Adoption
of NIMS is required to  qualify  for funds dispersed through the DHS  Office of State and Local Government
Preparedness and Coordination. As of the writing of this document, more information on NIMS is available at
http://www.dhs.gov/interweb/assetlibrary/NIMS-90-web.pdf.

The timing for review and  updating  of emergency response and recovery plans will vary across  utilities,
depending  on the degree to which  security-related conditions are changing  and any applicable state-level
planning requirements.   Utilities should  consider their individual circumstances  and establish, develop, and
implement  a schedule for review and  update of emergency response and recovery plans that are appropriate to
their circumstances. At a minimum, the WSWG believes that all utilities should review and (as needed) update
their emergency response and  recovery plan at  least once every year  Conditions that  might prompt more
frequent review of emergency response and recovery plans include major facility construction projects, adding
new facility infrastructure (by construction or acquisition), new response protocols in related cntical infrastructure
(such as the electric  power sector), changes  in  response  protocols  or capabilities of emergency response
organizations, and new information about specific threats

Utilities  also might find it useful to review emergency response and  recovery plans after any event that causes the
plan to be implemented—so that lessons learned from the event response can be incorporated into the plan and
used in  the future.  Many utilities have found it useful to update their emergency response and recovery plans on
a  "page basis" to ensure strict tracking  of  versions and to ensure  that all  responders  have up-to-date
information.  Using this  approach, replacement plan  pages would be sent to all  responders at least once per
year when plans are reviewed and updated.

The WSWG emphasizes that emergency response and recovery plans and planning should include not just the
details of response activities, but also a discussion of the circumstances that would prompt implementation of
the plan and who will  make   decisions about  plan  implementation   Utility plans should  be thoroughly
coordinated with emergency response and recovery planning in  the  larger community.   Coordination is
important,  not just with response organizations, but also with other critical infrastructure sectors, such as electnc
power and public health providers.  Coordination and education  related to emergency response and recovery
planning are also important for  utility customers  Some utilities have found  it helpful for customers to be aware
that their utility has an emergency response and recovery plan in place and to have information  on  what, if

Water Securay iWoH'-nq Croup F.pc-r-gs  "resented to the Notional D.'.pksng Water Ad>'«ory Council 5/1G/05                Paae 50

-------
anything, the plan might call for them to do.  For example, if plans call for customers to be asked to boil water
under certain  circumstances, they will be more likely to correctly carry out this precaution if they have advance
information prepanng them for the possibility  Some utilities have formed relationships with local public health
providers and the Red Cross to prepare public service announcements and other education information  about
response to utility emergencies

This feature also establishes the expectation that utilities should test or exercise their emergency response and
recovery plans regularly.  Plans might be tested  through training and tabletop drills and exercises, or through
real-time simulated responses   The  WSWG believes it is particularly helpful  to carry out these tests in concert
with representatives of critical interdependent infrastructure sectors and with first responders.  Some utilities have
found it useful  to participate in routine meetings of individuals  with  security, response, or  law  enforcement
responsibilities.  Establishing these collaborative partnerships helps in developing and facilitating implementation
of emergency response and recovery plans   It also provides a routine, relatively informal mechanism to trade
up-to-date information  on  threats  and  potential threats, security approaches,  and  response plans and
capabilities   Utilities may wish to refer to the EPA Tabletop  Exercise Planning Guide for  Public Drinking  Water
Systems (January 2005) for additional information on planning and implementing tabletop exercises.


Measure 11—Are  exercises regularly conducted that address  the lull  range of threats—physical,
cyber,  and contamination—and  is there a protocol/procedure to incorporate lessons learned from
exercises and actual responses into updates to emergency response and recovery plans?
Feature 11 establishes the expectation that utilities will incorporate secunty considerations into their emergency
response and recovery plans, that plans will be tested and reviewed regularly, and that plans will be updated as
needed   to  reflect   changes   in  potential  threats,  physical  infrastructure,  utility  operations,   critical
interdependences, and response  protocols in partner organizations. This measure emphasizes the importance
of testing and  exercising  emergency response  plans by suggesting  that utilities evaluate whether exercises
address the full range of physical, cyber, and contamination threats  It also  reinforces the need for emergency
response and recovery  plans  to be maintained as "living documents," by suggesting that utilities evaluate
whether they are prepared to incorporate lessons  learned from exercises  and response into plan updates
Consistent with its focus on ongoing  improvement in  security programs (see Finding 6), the WSWG believes
strongly in the importance of ongoing, thoughtful reassessment as a way to keep security programs "fresh" and
effective, take advantage  of emerging approaches  and new  technologies,  and perpetuate  a  security culture
throughout an organization
 Internal and External  Communications

 Feature  12—Water and wastewater utilities should develop and implement strategies for regular,
 ongoing security-related communications with employees, response organizations, and customers.
 This finding establishes the expectation that utilities should develop and implement communication strategies
 with key partners to increase security and be better prepared to respond to an emergency, whether caused by an
 accident, natural disaster, vandalism,  or terrorist  attack.   Training  utility workers and inviting  community
 members to recognize and report unusual or suspicious events or activities is one of the best ways that utilities
 can improve  their security  posture    During an  emergency, rapid,  confident response may  be  critical to
 safeguarding public and environmental health  One of the keys to both these outcomes is communication
 Water Secure1/ v'v'or>.pg Croup F-nd-rgs Tressed to The NcT:onai Dr.pk:nc Warer Arfv.sory Council 5/18/05                faae 51

-------
The  WSWG  believes  that  effective  communication  strategies  consider  key  messages,   who  is  best
equipped/trusted to deliver  the  key messages,  the  need  for  message consistency, particularly  during  an
emergency, and the best mechanisms for delivering messages and for receiving information and feedback from
key partners   These elements likely will vary depending on the audience with whom  a utility is trying to
communicate   The WSWG  highlights three key audiences for  communication strategies-  utility employees,
response organizations,  and customers

With respect to utility employees, reliable, ongoing communication strategies are a key part of creating an active
and  effective  secunty  culture.   Communications strategies should maintain employee secunty awareness,
motivate staff  to take security seriously, provide ways  for staff to notify appropriate security or other personnel
about unusual or suspicious  events or activities,  ensure employee safety during an  event,  and enable effective
employee participation during event response  This might be accomplished through regular security awareness
briefings and the incorporation of security considerations into regular training activities  Efforts  need to ensure
that staff can distinguish between  normal and unusual  activity (both on and off site and in their professional and
personal lives),  understand how  to notify management of  suspicious activity, understand the nature of and
restrictions on  access to sensitive information and facilities, understand  event-related safety procedures, and
participate effectively in event response activities.

With respect to response organizations, communication strategies should focus on ensuring clarity and reliability
in the  event of an emergency.   As discussed under  feature 8, in  the  event  of an  emergency,  conventional
telecommunications networks will come under severe pressure and may fail   In this context, utilities should
evaluate the need and means for providing back  up  systems that will enable maintaining contact with police,
fire, and other first response organizations,  as well as maintaining internal communication with employees to
ensure safety and to coordinate response activities.

With respect to customers,  communication strategies should especially consider the most effective ways to reach
consumers with information, both in terms of delivery mechanism  and source, and of providing a mechanism for
customers  to communicate with appropriate security or other personnel  about  unusual or suspicious events or
activities.  For example, some customers may be more inclined to pay attention to information that comes from
the public health community  than information that comes from a utility  Some delivery mechanisms  might work
well for customers who are at home during the day, but other mechanisms might be needed for customers who
work dunng the day, or travel frequently   In the event of an emergency, plans should be in place to reliably
disseminate information to people who need it, even  if normal communication mechanisms are compromised
Some utilities  have found  it useful  to invest in ongoing outreach and communication with customers to build
trust, partnership, and open lines of communication well in  advance of any service-related problem or secunty
emergency

Communication strategies also should address who is authorized to speak  for a utility in the event of an
emergency  and ensure that person  has pre-prepared communication  materials and messages that can be
tailored to the specifics  of an event  It may be helpful to practice communication strategies and messages with
local political  leaders who will have a role in public communication during an  actual  public health emergency,
before an emergency occurs.  This will ensure that local political  leaders have accurate expectations about how
an actual public health  emergency will be handled, and will reduce the likelihood that the public could receive
mixed or conflicting messages
Water Secunty Wor"-nq Group F,nd.pgs  Preserved to ''ne Nationa' Dfnkino Wafer Advisory Counc.l 5/1G/05               Pa$e 52

-------
Measure 12—Is there a mechanism for utility employees, partners, and the community to notify the
utility of suspia'ous occurrences and  other security concerns,  and  is there an up-to-date list and
protocol for contacting emergency response partners?
The WSWG strongly  believes that effective two-way communication within utilities and between utilities and their
partners  and customers in surrounding  communities is one of the most  important assets  of  an active  and
effective  security program   Feature 12 describes in detail the WSWG's thoughts on the importance of internal
and  external communication, and expectations for communication efforts in active and  effective security
programs. Measure 12 highlights one of the main  reasons the WSWG  believes communication is important.
effective  communication strategies can dramatically  increase a utility's ability to identify utility-specific security
threats.   Training utility workers and inviting community members to recognize and report unusual or suspicious
events and other security concerns is one of the best ways utilities can improve their security posture.  Residents
who live  near utility infrastructure and observe comings and goings on a daily basis are often best able to notice
changes  that may signal an increasing  threat

The WSWG is not prescribing a specific method utilities should use to provide for notification, utilities should
develop notification strategies best suiting their particular circumstances, communities, and operating conditions
Over time, it also  will  be important for utilities to evaluate the effectiveness of  communication  mechanisms to
ensure that mechanisms are working—this could be done by surveying or testing of communication mechanisms
in tabletop or field exercises, or by evaluating whether a utility is acting on communication received through the
communication  mechanisms it has in  place   For example, if a website  is  the  communication  mechanism for
submitting concerns, it is an effective  mechanism only if someone actually  monitors, evaluates, and ads upon
the submissions.

Note that by highlighting this element of internal and external communications, the WSWG is not intending to
minimize other  elements of this  feature  described  earlier  In  particular, the Group  expects that as  part of
developing active and  effective security programs, utilities will also develop and implement strategies  to ensure
reliable and clear communication during emergencies
 Partnerships

 Feature 13—Water and wastewater utilities should forge reliable and collaborative partnerships with
 the  communities they  serve,  managers  of  critical  interdependent infrastructure,  and response
 organizations.
 During  an actual  response  is not the opportune time to begin to develop good working relationships with
 managers of interdependent infrastructure, such as power supply or first responders  Utilities should identify and
 reach out to  key  partners—including communities, managers of interdependent infrastructure, public health
 officials and providers, and first responders—in advance of an emergency, so they are better prepared to work
 together if an emergency should occur  The  objective of developing reliable, collaborative  partnerships with
 these key partners is to improve security across interdependent infrastructures, improve vigilance toward security
 concerns, and improve responsiveness in the event of an attack

 Effective partnerships not only build  collaborative  working  relationships, they also  clearly define roles  and
 responsibilities, so that people can work together seamlessly if an emergency should occur. These partnerships
 are essential to a utility's ability to enhance security and  to  respond effectively  to emergencies   Developing
 reliable and collaborative partnerships involves reaching out to managers and key staff in other organizations to
 build understanding of their secunty concerns and planning, and to share  information about the utility's security
 Water Secunry Wof.pg Group F.ps-ngs  Prece'ifed tc :he Ncisona' Dr-pksnc Waier AcK-'Scry 'Icuncil 5/1G/05                Paae 53

-------
concerns and planning   It is important to emphasize the need for reciprocity in these relationships—it is |ust as
important for the utility to understand and be able to work with the power sector as it is for the power sector to
understand and be able to work with the utility

In many cases, reaching out to interdependent infrastructure and response organizations may have unforeseen
benefits to daily operations   For example, one utility has worked with the local police and fire departments to
enter information on its critical infrastructure into the police and fire secure global positioning system, so that
police and fire responders are automatically notified of the presence of water utility infrastructure within 1000
yards of a response call.  This day-to-day interaction has increased awareness of, and attentiveness to, water
infrastructure in a way that will automatically increase secunty  In another case, arrangements were made for a
24-hour on-call utility worker to stay at a  local firehouse with the 24-hour on-call fire personnel.  This enabled
the city to dispatch the utility worker for hydrant vandalism, rather than sending a fire truck, which  saved the fire
department  time and money  The utility benefited from better accommodations for their worker  and a  closer,
more collaborative relationship with the fire department

It  is also important for  utilities to develop  partnerships  with  the communities and customers  they  serve
Partnerships help to build credibility within communities and establish public confidence in utility operations  In
the event  of an emergency, these relationships likely will provide a foundation of common understanding and
trust upon which confidence can be restored   Partnerships with communities also can provide real-time security
enhancements, particularly for rural and ex-urban utilities  People who live near utility  infrastructure can be the
eyes and  ears of the utility,  and can be encouraged to notice and report changes in operating procedures or
other suspicious behaviors  Neighborhood watches and other programs can help customers feel connected to
the utility, make them aware of security considerations, and enhance both community partnership and security,
at little cost.  Effective community partnerships can have the important collateral benefit of increasing public
support for security improvements and security-related spending,  and any associated  inconveniences (such as
construction sites) or rate increases.
Measure 13—Have reliable and collaborative partnerships with customers, managers of independent
interrelated infrastructure, and response organizations been established?
Partnerships are a  natural outgrowth of effective communications, effective partnerships will improve security
across interdependent  infrastructure, improve vigilance towards secunty concerns, and improve  the speed and
quality of emergency  response.   Feature 13 establishes the expectation that  utilities will  forge  reliable and
collaborative partnerships with the communities and customers they serve, managers of  critical interdependent
infrastructure,  and response organizations, as part of establishing  active and effective security programs.  This
measure suggestss utilities evaluate the quality of these partnerships

The. WSWG  emphasizes  the  importance  of  utilities  undertaking  a critical  and  thoughtful  evaluation  of
partnerships as part of this measure.  The Group is not suggesting a speafic method to  evaluate partnerships,
however, it strongly encourages utilities to engage partners in a dialogue as part of evaluation and to provide a
forum  in which  partners can  offer informed and candid observations and  suggestions  for improvement   As
discussed earlier in this document, the WSWG  is suggesting these measures as part  of utility-specific self-
assessment programs   Utilities should use the opportunity  that self assessment  provides to be  realistic and
thoughtful about their performance and opportunities to further improve their secunty posture.
Water Securer vVor^pg Croup F'nd-r.gs  Preset'ed to The Notions! Dr-rlunc Waier Adveoiy 'Council 5/18/05                Pajse 5 4

-------
Measures and Self Assessment

Feature 14—Water  and wastewater  utilities  should develop  utility-specific measures of security
activities  and achievements,  and  should self assess against these  measures to  understand  and
document program progress.
It is an axiom of modern organizations that what gets measured gets done.  As part of an active and effective
security program, water and wastewater utilities should develop utility-specific measures  that can be used to
understand and track progress, activities, and achievement.  Measures should be appropriate to utility-specific
circumstances and operating conditions, and should reflect the specific secunty approaches and tactics a utility
has chosen   Measures help a utility venfy that an active and effective secunty program is  in place and help to
document program outcomes.  Although each  utility's measures will be different,  |ust as  each utility's specific
security approaches and tactics will be different,  the WSWG suggests that utilities consider measures  of  a
number of common types of activities and achievements, including the following

>   Existence of program policies and procedures   The WSWG anticipates that,  as part of their specific security
    approaches and  tactics, most, if  not all, utilities will choose to develop some policies and  procedures
    related  to security  For example,  as part of developing an explicit, visible commitment  to security (feature
    1), many utilities may choose to develop an overarching security policy  As part of intrusion detection and
    access  controls (feature 6), many utilities may  choose to develop  employee  and visitor identification
    procedures and access limitations.  Where utilities have chosen to develop policies and  procedures as part
    of their specific security program  approaches or tactics, the existence  of  these policies and  procedures
    should be documented as part of implementing an active and effective security program
>   Training  The WSWG anticipates  training on security approaches and tactics will be part of most, if not all,
    utility secunty programs   Where  security-related  training is planned, utilities should  measure whether the
    training has been carried out as planned and the effectiveness of training as part of implementing an active
    and effective security program
>   Teshng  As  a complement to documenting where security-related policies and  procedures are in place,
    utilities should test  and  measure  whether staff (including contractors) are  operating  consistently with
    established security-related  policies and  procedures, and whether  the  policies  and  procedures result  in
    effective operations, response, and communication  These  tests can take a variety of forms, including
    observing staff activity, retroactive  review  of security related activities,  tabletop and field exercises,  and
    review of lessons learned from secunty activities and emergency responses
>   Implementing schedules and  plans   As part of developing an active and  effective  security program,
    individual utilities will develop utility-specific  schedules  and plans.  For  example,  utilities will  develop
    schedules and plans for carrying  out regular updates to assessments of vulnerabilities  (feature 3)  and
    emergency response plans  (feature 11).   Where these schedules and plans are in  place, utilities should
    measure whether they carry out updates in accordance with schedules and plans

 In addition to suggesting that utilities establish utility-specific measurement and self-assessment programs, the
WSWG suggests a number of specific security measures that apply across the full range of utility circumstances
 and operating conditions (see Finding  16).  The Group emphasizes that these measures are intended  to form the
 basis of a utility-specific measurement program, not replace utility-specific measures

 Once security measures are in place, utilities should regularly conduct  self assessments of their security
 programs  and track  progress against their measures.  At a minimum, the WSWG believes self assessments
 should be  done annually,  as  part of  an annual secunty program  review.   The WSWG  reiterates that self
 assessment should be based on consideration  of the specific measures a utility has  put in  place  The Group

 Water Secunry vVor'-nq Croup FtPS-r-gs Prasei'stf to The NcTionai Drinking Water Advisory Council 5/16/05                Pape 55

-------
does not assume that self assessment will include annual conduct of a full assessment of vulnerabilities, although
some utilities may choose to update their assessments of vulnerabilities annually  The WSWG also  suggests
establishing  a  voluntary,  utility security  peer technical  assistance  and review process  to  complement,  as
individual utilities deem desirable, utility self assessments (see Finding  11)
Water Securny vVor'ipq Group F'nci rajs  Pres*r,:*d to :he No::onai Drinknc Wafer Adt'iscrv Cos.nc:l 5/1G/05                Pajie 56

-------
APPENDIX B:   CHART SHOWING FEATURES  OF AN ACTIVE AND
EFFECTIVE SECURITY PROGRAM AND  CORRESPONDING  MEASURES
THAT  UTILITIES  SHOULD  USE
#                                 Feature
1   Water and wastewater utilities should make an explicit and visible commitment to
    security
2   Water and wastewater utilities should promote security awareness throughout their
    organizations

3.   Water and wastewater utilities should assess vulnerabilities and periodically review
    and update vulnerability assessments to reflect changes in potential threats and
    vulnerabilities
4   Water and wastewater utilities should identify secunty priorities and, on an annual
    basis, identify the resources dedicated to secunty programs and planned secunty
    improvements, if any.
5   Water and wastewater utilities should identify managers and employees who are
    responsible for secunty and establish secunty expectations for all staff
6   Water and wastewater utilities should establish physical and procedural controls to
    restrict access to utility infrastructure to only those conducting authorized, official
    business and to detect unauthonzed physical intrusions.
7.   Water and wastewater utilities should employ protocols for detection of
    contamination consistent with the recognized limitations in current contaminant
    detection, monitoring, and surveillance technology
8   Water and wastewater utilities should define security-sensitive information, establish
    physical and procedural controls to restrict access to security-sensitive information as
    appropnate, detect unauthonzed access, and ensure information and
    communications systems will function during emergency response and recovery
9   Water and wastewater utilities should incorporate secunty considerations into
    decisions about acquisition, repair, mapr maintenance, and replacement of physical
    infrastructure, this should include consideration of opportunities to reduce nsk
    through physical hardening and the adoption of inherently lower nsk design and
    technology options.
10.  Water and wastewater utilities should monitor available threat-level information and
    escalate secunty procedures in response to relevant threats
                              Measure
Does a written, enterpnse-wide secunty policy exist, and is the policy reviewed
regularly and updated as needed?
Are incidents reported in a timely way, and are lessons learned from incident
responses reviewed and, as appropnate, incorporated into future utility security
efforts?
Are reassessments of vulnerabilities made after incidents, and are lessons learned
and other relevant information incorporated into secunty practices?

Are secunty pnonties clearly identified, and to what extent do secunty pnonties have
resources assigned to them?

Are managers and employees who are responsible for secunty identified?

To what extent are methods to control access to sensitive assets in place?
Is there a protocol/procedure in place to identify and respond to suspected
contamination events?

Is there a procedure to identify and control security-sensitive information, is
information correctly categorized, and how do control measures perform under
testing?

Are secunty considerations incorporated into internal utility design and construction
standards for new facilities/infrastructure and mapr maintenance projects?
Is there a protocol/procedure of responses that will be made if threat levels change?
         i'y Wo-k r c Otup F::.di.igi—P-esenled *o th
-------
#                                      Feature                                                                       Measure
11   Emergency response and recovery plans should incorporate security considerations,  Do exercises address the full range of threats—physical, cyber, and contamination—
     be tested and reviewed regularly, and updated as necessary to reflect changes in     and is there a protocol/procedure to incorporate lessons learned from exercises and
     potential threats, physical infrastructure, utility operations, cntical interdependences, actual responses into updates to emergency response and recovery plans?
     and response protocols in partner organizations.
12.  Water and wastewater utilities should develop and implement strategies for regular,  Is there a mechanism for utility employees, partners, and the community to notify the
     ongoing security-related communications with employees, response organizations,   utility of suspicious occurrences and other security concerns?
     and customers
13.  Water and wastewater utilities should forge reliable and collaborative partnerships   Have reliable and collaborative partnerships with customers, managers of
     with the communities they serve, managers of cntical interdependent infrastructure,   independent interrelated infrastructure, and response organizations been
     and response organizations.                                                     established?
14.  Water and wastewater utilities should develop utility-specific measures of security     Not applicable
     activities and achievements and should self assess against these measure to
     understand and document program progress.
tljfler S-sc.'i*y Wo k..-.o fjt,\.p T r-dngs—?"Bsentod «o thi N-jh',- c. Jr. .ring «V.j|.-.',»jv 'ury Co 'no' i,'I o/'"i5                                                              (1oge ifc

-------
APPENDIX C:  ADDITIONAL  MEASURES  UTILITIES
SHOULD CONSIDER
During their deliberations to identify measure that all utilities should use, the WSWG identified numerous other
potential measures of active and effective security programs.  The measures suggested above for all utilities to
use are the  minimum necessary to  create a foundation for a successful utility security self-assessment and
measurement program  Utilities should supplement the measures suggested above with additional measures
that reflect the specific security approaches and tactics they have chosen and that are appropriate to their
specific circumstances and operating  conditions.

This appendix lists measures that the WSWG considered during its deliberations and that it suggests utilities
should consider when developing a utility-specific self-assessment and measurement program. While not all the
measures  listed here will  be applicable to every  utility, they cover many  of  the elements of a successful
measurement program that  the WSWG suggested earlier  (existence of program policies and  procedures,
training, testing/exercising, and implementing schedules and plans, see feature 14) and represent the WSWG's
best thinking on what would constitute sound measures
 Feature 1—Explicit Commitment to Security
 >   Are written security policies and procedures established? (y/n)
 >   Are procedures/protocols updated routinely? (y/n)
 >   Is there a public education program for customers and public officials? (y/n)
 >   Are agreements with emergency response partners in place? (y/n)
 >   Is there an explicit commitment to security? (y/n)
 >   Does the commitment to security address the full scope of the security program? (y/n)
 Feature 2—Security Culture
 >   Are all management and staff secunty trained? (y/n)
 >   Is there documentation of incidents and associated responses? (y/n)
 >   How many incidents/suspicious incidents are reported? (Measure raw number of incidents and changes in
    the number of incidents over time )
 >   Are incidents and responses reviewed with staff? (y/n)
 >   Are lessons learned from incidents and incident response incorporated into future planning? (y/n)
 >   Are there incidents that were not reported or not reported in a timely way and, if so, how many? (y/n and
    number)
 >   Were responses to incidents consistent with established policies and procedures? (y/n)
 >   Are there efforts to promote security awareness throughout the utility? (y/n)
 >   Are security policies and procedures followed? (y/n)
 >   Is there a process/protocol by which suggestions for security improvements can be made by employees and
    the public? (y/n)  How many suggestions are made? Are suggestions followed up on in a timely way? (y/n)
 >   Is there a way to  keep up to date on security improvements and  good secunty practices/models from other
    utilities? (y/n)
 Water Secursy vVor'.pg Croup F.nS-'-.gs  "reserrtd to rto No;:onai Dnnking Wafer Ad>--sory 'Council 5/1E'05               Paae 59

-------
Feature 3—Up-to-Date Assessment of Vulnerability
>   Is there a procedure or protocol that establishes an internal periodic reassessment of vulnerability (including
    design basis threat) and a schedule for this reassessment? (y/n)
>   Is the periodic reassessment done? (y/n)
>   Is it done on schedule? (y/n)
>   Is a reassessment of vulnerabilities conducted after incidents? (y/n)
>   Is follow-up conducted after each reassessment to incorporate changes, lessons learned, and security
    improvements into security practices? (y/n)
>   Are conditions that dnve changes in vulnerability identified and tracked? (y/n)
>   Are reviews of vulnerability carried out by a team of employees from both security and operations? (y/n)


Feature 4—Dedicated Security Resources and Security Implementation Priorities
>   Are solutions to vulnerabilities (steps to take to reduce vulnerabilities or reduce potential consequences)
    identified and built into the security plan (y/n), prioritized (y/n), and given a time frame to complete (y/n)?
>   Have solutions to vulnerabilities  and measures to mitigate potential  consequences been considered and
    evaluated for importance and ability to fund, and funding decisions been made? (y/n)
>   Do solutions to vulnerabilities and measures to mitigate potential consequences have resources assigned to
    them? (Measure number and  type with assigned resources and total percentage with resources assigned )
>   What number of high-priority  security improvements  (solutions to  vulnerabilities)  have been addressed?
    (Measure raw number of vulnerabilities addressed )
>   How  many milestones have  been accomplished  from  the  security  plan?  (Measure  raw number  of
    accomplishments.)
>   How many capital improvement dollars have been spent on security? (Measure raw dollar amount)
>   How many operational improvements have been made? (Measure raw number of  improvements )
>   How many changes have been made in maintenance activities? (Measure raw number of activities )
>   Are the skills needed to implement security improvements identified and available? (y/n)
>   Are resources dedicated to security identified on an annual basis? (y/n)
>   Are planned security improvements, if any, identified? (y/n)
Feature 5—Defined Security Roles and Employee Expectations
>    Does  management/utility board support adoption of security policies? (y/n)
>    Are   security  roles/responsibilities  included  in  |ob   descriptions,  employee  evaluations,  or  other
    documentation of responsibilities? (y/n)
>    Does  staff receive training relative to their security roles/responsibilities (y/n) and is the training ongoing
    (y/n)?
>    Is performance of security roles/responsibilities part of performance evaluations? (y/n)
>    Have  managers and employees who are responsible for security been identified? (y/n)
>    Are background checks performed for current and new employees, including contractors? (y/n)
>    Are there means to readily identify all employees,  contractors, and visitors? (y/n)
Feature 6—Intrusion Detection and Access Control for the Physical Plant
>    Is there a procedure/protocol on intrusion detection and access control? (y/n)
>    Are the procedures/protocols tested regularly? (y/n)
>    Are non-public spaces protected from casual trespass?  (y/n)

Water Securcy \Vors-.nq Group F'ivs.r.gs - iVewi'ed to the Nc::onoi Drinking Water Advisory 'Icuncil 5/18/05                Pace oO

-------
>    Is there a way to control access to sensitive assets? (y/n)
>    Is a security perimeter established (y/n) and is there technology to monitor the established security perimeter
    (y/n)?
>    Are all utility employees and contractors identified? (y/n)
>    Are visitors to the utility checked in and escorted? (y/n)
>    Is access denied to persons who no longer qualify for access? (y/n)
>    Can individuals who are not eligible for access talk their way in to restricted areas? (y/n)
>    Is there a means to control vehicular access? (y/n)
>    Are intrusions detected and responded to in a timely way? (y/n)
>    Are there policies and/or procedures for monitoring chemical delivery schedules and safeguarding chemical
    deliveries? (y/n)
>    Are the chemical delivery policies/procedures tested regularly? (y/n)
Feature 7—Contamination Detection
>    Is there a system of monitoring for contaminant detection? (y/n)
>    What type of monitoring is being used? (descnbe)
>    Is there a system to keep up-to-date on emerging technologies for contamination detection and monitoring?
    (y/n)
>    Have connections been established with  public health networks to detect,  interpret,  and act upon  public
    health anomalies? (y/n)
>    Are customer complaints monitored and evaluated for possible indications of contamination events? (y/n)
>    Have protocols been established for interpreting and responding to indications of public health anomalies?
    (y/n)
Feature 8—Information Protection and Continuity
>   Are there policies and procedures in place that categorize and control security information? (y/n)
>   Are these policies used/followed? (y/n)
>   Is there a training program for information security policies/procedures? (y/n)
>   Is there regular testing of information security policies/procedures? (y/n)
>   How  does  implementation of the policies and procedures perform under  testing—is information secure?
    (Measure performance against testing benchmarks )
>   Are documents correctly categorized  relative to secunty content? (y/n and measure number and percentage
    correctly categorized)
>   Is there a dedicated lead information officer for both paper and electronic information? (y/n)
>   Is there an employee training program for information security and, if so, how many employees have been
    trained? (y/n and number)
>   Is security incorporated into design standards for new information systems? (y/n)
>   Can  the IT firewall  be breached?  (Measure  number of total  attempts and  number and percentage  of
    attempts that are wholly or partially successful.)
>   Are information security considerations incorporated into decisions about  design and acquisition of new
    systems or updates to current systems? (y/n)
Water Securay iVor-ing Group Fins-r.gs  Precei-wd to The Ncisonai Dr.nk:nc Wafer Adi-scry Council 5/1G/05                Page o 1

-------
Feature 9—Design and Construction
>    Is there a protocol in place for examining the potential multiple benefits of design choices, with an emphasis
    on designs that more fully address security? (y/n)
>    Have  security considerations been incorporated into internal utility design and construction standards? (y/n)
>    Do these standards include consideration of opportunities to reduce both security and safety risk through the
    adoption of inherently lower-risk design and technology options? (y/n)
>    Are there policies/procedures in place to ensure that facilities remain secure dunng construction?  (y/n)
>    Is  there a  training program on these policies/procedures and, if  so,  how many employees have been
    trained? (y/n and number)
>    Are these policies/procedures tested regularly? (y/n)
>    Is secunty considered in both design of new facilities/infrastructure and in major maintenance projects? (y/n)
Feature 10—Threat-Level Based Protocols
>    Is an active system in place to identify and assess threat level changes, with an  emphasis on geographic-
    and industry-specific threats? (y/n)
>    Is a list of sources of threat level information created/updated? (y/n)
>    Has the utility developed procedure/protocol of responses that will be made if threat levels change? (y/n)
>    Are responses  undertaken  when  needed? (y/n and  measure the percent  of times correct  response
    undertaken )
>    How much time does it take to make change in protocol relative to established objective? (Measure time
    and change in time over time )
Feature 11—Emergency Response and Recovery Plans Tested and Up-to-Date
>    Does the emergency  response  and recovery plan  incorporate  security-related  threats and responses
    consistent with the assessment of vulnerabilities? (y/n)
>    Is response staff identified and trained? (y/n)
>    What were the results of planned and unplanned drills/exercises? (Measure quality of response )
>    Do exercises set specific objectives and test them? (y/n)
>    How long does it take for full organization to fully mobilize relative  to established objective?  (Measure time
    and change in time over time.)
>    How long does it take for individuals to mobilize relative to established objective? (Measure  time and
    change in time over time )
>    Is there a high, medium, or low rating of coordination with other responders during an exercise?  (Measure
    with survey results )
>    How well do exercises test performance?
>    Are there protocols/procedures to incorporate lessons learned  from exercises and actual  responses into
    updates to the emergency response and recovery plan? (y/n)
>    Do exercises address the full range of threats—physical, cyber, and/or contamination? (y/n)
>    Are security considerations incorporated into emergency response plans? (y/n)
>    Are emergency response and recovery plans updated in response to changes in  security considerations?
    (y/n)
>    Do emergency response and recovery plans reflect an  awareness of the National Incident Management
    System Guidelines? (y/n)
>    Has a schedule for review, reflective of individual utility security-related conditions, been established? (y/n)
>    Has the emergency response and recovery plan been reviewed at least once per year? (y/n)

Water Secuny Waring Group F'PS'r.gs  -Presented to The National Dnnk:nc Wcfer Advisory Council 5/16/05

-------
>    Were emergency response and  recovery plans reviewed and updated as  needed in response to such
    changes as major facility construction projects, new facility infrastructure, and/or new information regarding
    threats? (y/n)
>    Is the emergency response and recovery plan thoroughly coordinated with emergency response planning in
    the larger community? (y/n)
>    Has the emergency response and recovery plan been tested regularly and, if so, when was the last test? (y/n
    and date)
>    Are there contingency plans in place in case of failure of primary response systems or partnerships? (y/n)
Feature 12—Internal and External Communication
>   Has a list of organizations/individuals to communicate with established? (y/n)
>   Has a schedule/cycle of contact established? (y/n)
>   Has that schedule of contacts been  met or exceeded?  (y/n and measure percent  of  contacts met  or
    exceeded on schedule)
>   Do partner organizations know what the utility thinks they should know?  (Measure with survey data.)
>   Is the community aware of its role in improving security and what to watch for? (y/n)
>   Is there a mechanism for employees to make suggestions for security improvements? (y/n)
>   Is there a mechanism for employees to get information about security practices? (y/n)
>   Are security issues included as part of routine employee briefings and staff meetings? (y/n)
>   Is information disseminated to employees, as appropriate, when security practices change?  (y/n)
>   Is information disseminated to employees, as appropriate, when threat levels change? (y/n)
>   Is there redundancy in communication  technologies? (y/n)
>   Is there a way for partners and the community to make suggestions for security improvements? (y/n)
>   Is  there a  way for partners  and the community  to notify the utilities  of suspicious occurrences or other
    security concerns? (y/n)
Feature 13—Partnerships
>   Are key partners identified? (y/n)
>   Has a joint communications plan been established? (y/n)
>   Have communications been undertaken consistent with the plan? (y/n)
>   How many meetings with responders have taken place per year?  (Measure raw number.)
>   Have the needs of partners been met in joint exercises? (Measure with survey data )
>   Have reliable  and  collaborative  partnerships  with  served communities,  managers of interdependent
    infrastructure, and response organizations been established? (y/n)
 Water Securcy '/v'or'ipg Group F.pc.r.gs- Presented to :-!e Ncnonoi Drinking Wanr AeK'.so'y Council 5/1C/05                paae o3

-------
Water Security Won-inq Croup Ftnd'pgs  rresented to -he Notional D.'.pk:nc Wafer Advisory Council 5/1G/05                  Pane 04

-------
APPENDIX D:   INDIVIDUAL COMMENTS  OF  WSWG

MEMBERS	


                                 Comments of Nick Cotranteos
Security for Water: A Personal Distillation
By
Nick Catrantzos, CPP

Security matters  Even the simplest efforts can make a difference  Yet unfunded mandates can dissuade
the very action they are intended to encourage. Ideas like these supplied context and debating points in a
year of Water Security Working Group deliberations   By the end of the year, good ideas and common
ground emerged. Here are the personal lessons I distilled along the way.

Know Your World

Before we can speak intelligently about protecting critical infrastructure, we must know what we want to
protect.  At the strategic level, we must  identify and prioritize our critical assets.  Yet we must also
evaluate options for protecting them, on the one hand, and for reducing the impact of their loss, on the
other hand.  A nsk or vulnerability assessment is a handy tool for making us think these things through.
This process is valuable, no matter the methodology used.  We also need to refresh this process and our
conclusions from time to time  Why' Threats change. Today's critical  asset becomes tomorrow's back-
up system or museum relic  Security options improve, too. Finally, at the day-to-day, micro level, we
must all be alert to our  surroundings   Only the people who work daily at a given site or in a given
operation can recognize what does not belong there. To recognize what is suspicious or out of place, we
must remain aware We must know our world.

Start Somewhere

It is very easy to spend more time complaining about some aspect of security than to actually take a first
step in protecting assets.  Avoid assuming that every imperfection represents a fatal flaw.  Perfect security
is an illusion  Perfect security would require bringing all operations to a halt in order to safeguard them
It would mean going out of business to protect the  business.  Because security can be interpreted so
broadly as to affect everything, it is easy to consider it daunting.  It may also be tempting to refuse to do
anything without an extra funding source  This approach is a recipe for inaction

Security  is never convenient   But it need  not break the bank. Just as  most people think nothing of
carrying  keys and locking their homes, security works best and is easiest to take when integral to our
daily lives  It only becomes oppressive if treated as an applique or transformed into an impossible dream

There are no easy answers   Yet improvement is always possible, even with limited budgets  It is
important to start somewhere  Controlling access to critical facilities, for example, is always possible on
some level. This, plus a security awareness message to employees to watch for and report intruders, plus
a good example by leaders following security rules turns into a basic security program.  It is an example
of adding value without waiting for outside influence  Many smaller utilities have  already figured this
out, outperforming larger entities.

Water Secunry \Vor*-pq Group ?-r\?-r.qs- fYB»n:«d to Trie NcTional Dr.plonc Woier Adi'-sc-y Ccunc:! 5/18/05               paae o5

-------
At Least Ask

There is a management adage that says what gets inspected is what gets respected  Even if you cannot
afford an extra dollar for security, you can still do better  How'  Ask if your own procedures are really
being followed.  Often, exploited vulnerabilities are those others in the organization knew about. Maybe
they did not tell anyone  Or maybe they did, but no one listened.  Or maybe just too much time passed
since someone cared enough to inquire If you cannot do anything else, at least ask

Closing Observations

This report is necessarily imperfect. Yet it is comprehensive, thanks to the exceptional work of the Ross
and Associates facilitation team that toiled indefatigably to canvass all views of WSWG members, no
matter how wide-ranging  Ross's Elizabeth McManus and Rob Greenwood, in particular, mastered a kind
of magic that regularly translated argot into the vulgate and forced us to make sense when too much
brainstorming left us awash in good ideas without the necessary bridge to practicality  It is also a tribute
to the finesse of two bnght and sophisticated co-chairs, Rebecca Head and Dave Binning, who routinely
rescued us when mired in minutia

One consistent value for the reader is  that every suggestion or feature has been fire-tested in at least one
crucible.  Nothing is a cure-all.  Nor is  it intended to  substitute for common sense and informed
management  A utility could follow all the recommendations to the letter and, lacking true commitment,
still fall short of protecting the critical infrastructure under its stewardship  Conversely, another utility
could defend its infrastructure superbly, yet only pick and choose sparingly from the recommended menu
we offer.

Nevertheless, addressing the features and suggestions in this report requires thinking about security at all
levels of the organization.  And this is  where the  greatest  value comes   In our busy worlds, where
security is still competing for attention, it is by no means the core business. This report succeeds when it
generates  senous thought  and even debate about security,  without doing  so at the expense  of core
business Periodically. Regularly  And, eventually, instinctively  At the end of the day, the message we
deliver is that good security is good business


                                     Respectfully submitted,


                                     Nick Catrantzos

                                     Nick Catrantzos, Certified Protection Professional (CPP)
                                     Security and Emergency Manager
                                     Metropolitan Water District of Southern California
Water Security lAteK'inq Croup Find-rgs  Presented to The Nct:ona! Dr.nking Wafer Ad.-iso.-y Council 5/1G/05               Pajie 06

-------
                             Comments of Major Timothy Mulcoda
These comments reflect the opinion/perspective of the Department of Defense (DoD)
Federal Partner (Major Timothy Mukoda, USAF) and do represent an official DoD
position. These comments will not be recognized as an official DoD position until/unless
they have been formally staffed and coordinated through all Services (US Air Force, US
Army, US Navy, US Marine Corps).
Active and effective drinking water and wastewater security programs are directly related to
overall National Security  Two of the primary motivating factors that should drive effective and
efficient program implementation are:

    1)  The ethical responsibility for ensuring protection of public health and welfare,
    2)  Developing and maintaining customer/consumer confidence.

Regulation of a water security program has the potential to be counterproductive to effective
program implementation  First, regulation at the Federal or state level may dnve requirements
that are not applicable at the local level. Second, current programs that are effective but do not
meet strict compliance requirements may be forced to adjust m ways that contribute no overall
value.  Finally, mandatory compliance-related activity may result in unintended consequences
regarding use of resources to meet compliance  This last point is critical to consider in a
resource-constrained environment.

It is important that any guidance related to active and effective water  security programs remain
in the realm of "guidance" This provides a general roadmap for ultimate success, but does not
dictate the exact route by  which success may be achieved Most, if not all, water utilities will
have adequate incentive to lean forward and implement water security programs tailored to local
need based on the factors  listed previously
Water Securry Wor^-nq Croup f-ws-r-qs  Preseved to :ne Nc::onoi Drinking Vs'cter Ad/iioiy CCLT.C:! 5/18/05

-------
Water Securry vVori'.ng Group F'ne-r.gs  Prew,!*
-------
ATTACHMENT  1:   ROSTER OF WSWG MEMBERS,
FEDERAL RESOURCE  PERSONNEL, AND OUTSIDE
EXPERTS	


National Drinking Water Advisory Council
                         AHF*                       *
Contact Information
               Co-Chains
Mr. David Binning
Director
Planning & Engmeenng
Fairfax Water
8560 Arlington Boulevard
Fairfax, Virginia 22031
Phone (O) 703-289-6325
dbinning@fairfaxwater org

Dr. Rebecca Head*
Health Officer/Director
Monroe County Health Department
2353 Custer Road
Monroe, Ml 48161-9769
Phone 734-240-7800
rebecca_head@monroemi org
                Members

 Mr. Doug Anderton
 General Manager
 Dade County Water & Sewer Authority
 PO Box 1047
 250 Bond Street
 Trenton, Georgia 30752
 Phone (O) 706-657-4341
 Phone: (C) 423-991-0096
 danderton5@aol com or danderton@tvn.net
Mr. Paul Bennett
New York City Department of Environmental
Protection, Director of Security Planning
465 Columbus Ave
Valhalla, NY 10595
Phone: (0)914-773-4512
pbennett@dep nyc gov

Honorable John W. Betkoski, III*
Commissioner
Connecticut Department of Public Utility
Control
10 Franklin Square
New Britain, Connecticut 06501
Phone 860-827-2803
|ohn betkoski@po state ct.us or assistant
melissa lupacchmo@po.state.ct us

Mr. NidcCatrantzos
Security & Emergency Manager
Metropolitan Water District of Southern
California
700 N Alameda Street
Los Angeles, California 90012
Phone (0)213-217-7134
ncatrantzos@mwdh2o com

Mr.JeffCooley
Alabama State Coordinator
Community Resource Group, Inc
Rural Community Assistance Program
1110 Hillcrest Road #2D
Mobile, Alabama 36695
Phone: (0)251-776-6635
Phone (C)  251-454-2978
|cooley@crg org or crg-al@msn com
 Water Seccray Wor^pg Group ?-™}-r.tjs  Preserpfd to ihe NcTiona: Dr.pk:.-.g Wa:er Ad>''Scry -Council 5/18'05
                                                                               o'

-------
Mr. Michael Gritauk
Formerly, Director
City of Phoenix Water Services Department
200 W. Washington Street, 9th Floor
Phoenix, Arizona 85003-1611
Phone (0)480-951-1580
michaelgntzuk@yahoo com

Mr. Gregg Grunenfelder
Chief Administrator
Environmental Health Division
Washington State Department of Health
PO. Box 47820
Olympic, Washington 98504-7820
Phone (0)360-236-3053
gregg.grunenfelder@doh.wa gov

Mr. H. J.  'Bud* Schardein
Executive Director
Louisville & Jefferson County Metropolitan Sewer
District
700 West Liberty Street
Louisville, KY 40203
Phone: (O)  502-540-6346
Email bennett@msdlouky org or assistant
schardei@msdlouky.org

Ms. Jennifer Nuzzo
Center for Biosecurity
University of Pittsburgh  Medical Center
The Pier IV Building
621 E. Pratt Street, Suite 210
Baltimore, Maryland 21202
Phone (0)443-573-3315
|nuzzo@upmc-biosecunty org

Mr. Paul Orum
Senior Advisor
Working Group on Community Right-to-
Know
PO Box 15465
Washington, DC 20003
Phone: (O)  202-548-4020
orum@crtk.org
paul_orum@yahoo com

Mr. Roger Selburg
Manager
Division of Public Water Supplies
Illinois Environmental Protection Agency
PO. Box 19276
Springfield, Illinois 62794-9276
Phone: (0)217-785-8653
roger selburg@epa.state.il.us
Mr. David Siburg
General Manager
Kitsap Public Utility District
PUD#1 of Kitsap County
1431 Finn Hill Road
PO  Box 1989
Poulsbo, Washington 98370-0933
Phone- (O) 360-779-9163, ext. 703
Phone  (C) 360-620-7680
dave@kpud.org

Ms. Diane VanDe Hei
Executive Director, Association of
Metropolitan Water Agencies
1620 I Street, NW, Suite 500
Washington, DC 20006
Phone. (0)202-331-2820
vandehei@amwa net

Mr. John S. Young, Jr.*
Vice President
Operations and Investment Performance
American Water Works Service Co , Inc
1025 Laurel  Oak Road
Voorhees, New Jersey 08043
Phone  856-346-8250
iyoung@amwater com
	Designated Federal Official

Mr. Marc Santera
Environmental Protection Agency
Office of Ground Water and Drinking Water
Water Security Division, Security Assistance
Branch
1200 Pennsylvania Avenue, NW
Room 2368J / Mail Code (4608 M)
Washington, DC 20460
Phone. (0)202-564-1597
Fax  202-564-8513
santora marc@epa gov
	US EPA Federal Partners

Ms. Janet Pawlulciewicz
Environmental Protection Agency
pawlukiewicz.janet@epa gov
202-564-3779
Water SecuRT) vVors'.pg Group F.nd-r.gs  Presented to The National Dr.nk:ic Wcrer Advisory 'Ic-jnc:! 5/1G/05
                                       Pace 70

-------
Mr. David Trovers
Environmental Protection Agency
trovers.david@epa gov
202-564-4638

Ms. Debbie Newbeny
Environmental Protection Agency
newberry.debbie@epa gov
202-564-1415
            Other Federal Partners
Dr. Richard Gelting
Centers for Disease Control and Prevention
Environmental Engineer
Environmental Health Services Branch
National Center for Environmental Health
4770 Buford Highway, Mail Stop F28
Atlanta, GA 30341
Phone (770)488-7067
Fax.  (770)488-7310
richard.geltmg@cdc hhs.gov

Mr. Mark D. Miller, R.S., M.P.H.
Alternate for Mr. Richard Gelting
Commander, U.S. Public Health Service
Senior Environmental Health Officer
Center for Disease Control and Prevention
National Center for Environmental Health
Environmental Health Services Branch
4770 Buford Highway, NE (F28)
Atlanta, Ga 30341-3724
Phone 770-488-7652
Fax:770-488-7310
mdmiller@cdc.gov

Mr. John Laws
Coordinator-Water / Wastewater-Dams Sector
specialist,  U.S. Department of Homeland Security,
Information Analysis & Infrastructure Protection
(IAIP), Infrastructure Coordination Division (ICD),
Infrastructure Coordination Analysis Office (ICAO)
 703-235-5404 New Office
 703-883-7651  Office
887-205-6674 pager
 703-883-4589 fax
John Iaws2@dhs.gov
 |laws@mitre org
Ms. Nancy Wong
Department of Homeland Security
Infrastructure Coordination Division
c/o Department of Commerce
1401  Constitution Avenue, NW
Suite 6095
Washington, DC 20230
Phone. 202-482-9055
Fax: 202-482-7499
nancy.wongl@dhs gov

Mr. Timothy J. Mulcoda, Maj, USAF, BSC
Chief, Environmental Operations
AFMSA/SGPE
110 Luke Ave,  Room 405
Boiling AFB, DC 20032
Phone (202)767-4327
Fax- (202) 767-5053 (fax)
timothy mukoda@pentagon.af mil

Mr. Jasper Welsch,
Mississippi Emergency Management Agency
PO Box 4501
Jackson, MS 39296-4501
Phone:601-360-0055
Fax:601-352-8314
jwelsch@msema org
            Facilitation Support Team

 Mr. Rob Greenwood
 Ross & Associates Environmental
 Consulting, Ltd.
 1218 Third Avenue, Suite 1207
 Seattle, WA 98101
 Phone  206-447-1805
 Fax. 206-447-0956
 rob.greenwood@ross-assoc com

 Ms. Elizabeth McManus
 Ross & Associates Environmental
 Consulting, Ltd.
 1218 Third Avenue, Suite 1207
 Seattle, WA 98101
 Phone:206-447-1805
 Fax 206-447-0956
 elizabeth.mcmanus@ross-assoc com
 Water Securay \Vor-.pg Croup F.PS ^s  Prawned tc :he Nc::ona! Dr-rkinc Wc:erAd»"sorv Council 5/18/05
                                                                                               71

-------
Mr. Elijah Levitt
Ross & Associates Environmental
Consulting, Ltd
1218 Third Avenue, Suite 1207
Seattle, WA 98101
Phone-206-447-1805
Fax  206-447-0956
eli|ah.levitt@ross-assoc com

Mr. Ryan Orth
Ross & Associates Environmental
Consulting, Ltd.
1218 Third Avenue, Suite 1207
Seattle, WA 98101
Phone 206-447-1805
Fax: 206-447-0956
ryan orth@ross-assoc com
Water Secunty Wording Group Fine.r.gs  PreseTed to :he Nc!:onal Dr-nking Wafer Adi-scry 'Council 5/16/05               Pope 72

-------
ATTACHMENT 2:   WSWG OPERATING PROCEDURES
                Drink/ra  Mfeter Mvisonj  Gounci/
                            w'                          I
Final Operating  Procedures
Establishment and Mission
The Water Security Working Group (WSWG)  is established and charged by the National  Drinking  Water
Advisory Council (NDWAC)  The Mission of the WSWG is to provide findings to the NDWAC that

        (1)  identify, compile,  and  characterize best security practices and policies  for drinking water  and
        wastewater utilities and provide an approach for considering and adopting these practices and policies
        at a utility level,

        (2) consider mechanisms to provide recognition and incentives that facilitate a broad and  receptive
        response among the water sector to implement  these best security practices  and policies, and make
        findings as appropriate, and

        (3) consider mechanisms to measure the extent of implementation of these best security practices and
        policies, identify the impediments to their implementation, and make findings as appropriate

The WSWG reacted use of the term "best" to describe their work on security practices, instead, the Group will
identify  and describe the components of  "active and effective"  security  programs for  water and wastewater
utilities.   In  addition, the WSWG interprets the scope of its deliberations to include all  water and wastewater
operations, from source water to tap and from collection system to discharge.
 WSWG findings will be presented to the NDWAC for the Council's consideration  The WSWG will not issue
 findings directly to EPA or any other agency or entity, although, of course, individual members are not restricted
 from discussing their views as they so choose. Upon receipt of the WSWG findings, the NDWAC will consider
 the findings and  may pass them to EPA unchanged, or may amend  them to reflect  their own views, or may
 choose not to forward findings to EPA


 Participants and Participation
 Working Group members were selected by EPA from among more than 80 nominated individuals  Selections
 were made considering the expertise and experience needed to provide advice to the NDWAC (and, through the
 NDWAC, to EPA) on best security practices, incentives, and measures, and were based on the need to provide
 balanced and complete  representation across the water sector   To facilitate communication between the
 NDWAC and the WSWG, three members of the NDWAC are also members of the WSWG.

 Direct participation of all WSWG members is essential to the success of the Working Group. For that reason
 members are asked to make every effort to attend Working Group meetings and participate in Working Group
 conference calls   Members who are not able to attend a particular  meeting or conference call may send an
 alternate. The alternate must be a peer of the WSWG member. In an emergency situation, an association staff

 Water Secure} Wor-.ng Group F.nd--gs  Presented' to -he NcTionai Dr-nkinc Ware.- Ack-scry Council 5/18/05               Page 73

-------
member  may serve as an  alternative,  however,  in accordance with the ground rules for NDWAC  working
groups, this will be allowed only once in the duration of the WSWG Alternates may be asked to contribute to
WSWG deliberations  by offering  their  opinion and expertise;  however,  they will not participate in  WSWG
decision making.

WSWG members are encouraged to frame observations  in terms of needs and interests, not in terms of
positions, opportunities  for finding  solutions increase dramatically when discussion  focuses on  needs and
interests   Collaborative problem  solving depends on mutual respect and careful listening among members
Meetings  and  conference  calls  will be  structured  to support  a  respectful  atmosphere,  encourage  the
development  of trust  and  understanding, and provide for participation of all WSWG  members.   WSWG
members agree to act in good faith in all aspects of their deliberations and consensus building  Members agree
to refrain from characterizing the views of other parties in general, and particularly in any  discussions that they
may choose to have with the press

WSWG members are welcome to be accompanied  to the meetings by staff  or other personnel, who may
observe the WSWG meeting and  offer comments or observations consistent with the operating procedures for
public observation and comment

It is the expectation that all WSWG  members will participate through the entire process and that the Working
Group's final document will reflect the consensus or the range of views that exist within the group relative to best
secunty practices, incentives, and measures  However, any party may withdraw from the Working Group at any
time without prejudice.   In the event a  member decides  to withdraw from the process,  he or she  will be
respectfully requested to communicate  the reasons for the  withdrawal, and  may be replaced  by  another
representative of similar expertise and interest.


Co-Chairs
The WSWG will be served by two co-chairs.  One of the co-chairs will be a member of the WSWG who is also a
member  of NDWAC  This  individual will be identified by EPA and  the facilitation team in consultation  with all
three of the NDWAC members who serve on the WSWG The second co-chair will be a member of the WSWG
who is  identified by the Group using a weight of preferences model

The role of the WSWG co-chairs is to act as a sounding board for the  facilitation team between WSWG
meetings, open and  close the WSWG meetings, assist the  facilitation team  in running the meetings, and
approve  WSWG meeting summaries  after the facilitation team has  addressed comments by WSWG members.
The co-chairs also participate in deliberations and decision making as full members of the WSWG   The co-
chairs do not determine the WSWG agenda or findings any more or less than any other WSWG member


Reporting to the NDWAC
The WSWG will identify which  members of the Working  Group will report to  the NDWAC  on the  Group's
findings  It is not assumed  that the co-chairs will be the members  of the WSWG who report to the NDWAC
WSWG members who are also members of the NDWAC may,  in the course of discussions with the NDWAC,
provide informal  updates on  WSWG  deliberations and  progress based on  the final  meeting  summaries,
speaking for themselves as members of the WSWG not  representing  the full  Group   For the winter 2004
NDWAC meeting,  the WSWG agrees that  the three WSWG members who also are NDWAC members will
provide an update to the NDWAC on WSWG activities and progress


Facilitation
The Working Group will be supported by a  neutral, third-party facilitation team. The facilitation role includes.
developing draft agendas,  meeting summaries, report documents, and other  materials;  running  the  WSWG
meetings; focusing  and  facilitating Working Group discussions to  ensure that  the perspectives  of all  WSWG

Water Securry Vvor'-nq Group Finc-rgs -- Tresei'ed to rhe Nciionai Dnnk:ng Water Adi-sory -Course:! 5/1G'05               Pace 74

-------
members come forward; working with Working Group members and  EPA between meetings and conference
calls to support understanding and consensus building;  working with Working Group members and EPA to
identify, organize, synthesize, and provide information and other material needed to support Working Group
deliberations; and, in general, coordinating Working Group activities


Federal Resource Personnel  and Outside Experts
In  addition to the facilitation team, the WSWG will  be  supported by a number of resource personnel from
federal  agencies with interest  and expertise in water  security   This will include  representatives from the
Environmental Protection Agency (EPA), Department of Homeland Secunty (DHS), Department of Defense (DoD),
and the Centers for  Disease Control and Prevention (CDC). As needed, and as resources allow, the Working
Group also may choose to consult with,  or the facilitation support team may identify, additional outside experts
or individuals on specific subject matters  To date, one outside expert, an individual with technical expertise in
emergency response, has been identified

Federal resource personnel and outside  experts may sit at the table dunng WSWG meetings so as to be easily
accessible to Working Group members and may make presentations to the WSWG; however, their support of
Working Group discussions is strictly to provide background, context, or other information or expert opinion, as
called  upon to do so  by a member of  the WSWG or the facilitation  team  Federal resource personnel and
outside experts will not participate in WSWG  decision making.  Federal resource personnel and outside experts
will be copied on all WSWG materials, including draft documents


WSWG Members'  Staff and Supporting Organizations
WSWG  members  may be   staffed  by individuals  from  their organizations  or  by  individuals  from
sponsoring/nominating organizations.  Every  effort will be made to facilitate WSWG members' participation in
the WSWG  process  by ensuring that staff has access to WSWG materials, including internal draft documents
However, staff are not members of the Working Group. To the extent that staff prepare draft comments or other
responses for the WSWG member they support, staff must do so in coordination with and as a representative of
the WSWG member, actual comments or responses must be submitted by the WSWG member, not by staff.


Decision Making and Consensus
The WSWG will use a collaborative, problem-solving approach, and strive to reach consensus   Consensus is
defined as findings  that all can "live with "  If the Working Group does not reach consensus on a particular
issue, the range of views on the Working Group with respect to that issue will be described. Ranges of views,  if
necessary, will be described in the text of the Working Group's  document and will not be attributed to individual
members or interests  unless the WSWG reaches consensus on an  approach to  attnbution   Working Group
members  also will  have an  opportunity to  submit  up  to three pages of individual, attributed  comments
Individual comments will be appended to the Working Group document without modification.


Task Teams
The WSWG  may choose to establish Task Teams to work on information gathering and analysis related to
specific elements of  best security practices, incentives, and measures between meetings of the  full WSWG. Task
Team members must be WSWG members and Task Team meetings are not open to the public.


Meeting Materials and Summaries and Electronic Communication
As much as possible,  meeting  agendas and  supporting materials will  be distributed by the facilitation team at
least one  week before WSWG meetings and conference calls  After WSWG meetings and conference calls,
summaries of key discussion points, tentative areas of  agreement,  and action items will be prepared by the

Water Secure-/  vVofipg Croup F'nd^gs "reifi'ed to The Nc::onal Dunking Wafer Advisory Council 5/1E'05               Pace 75

-------
facilitation team and provided to Working Group members for review  As much as possible, these summaries
will be distributed within two weeks of the meeting or conference call.

All  WSWG  documentation  and  correspondence will  be distributed  to  all WSWG members    Electronic
communication mechanisms (largely email) will be used  to the greatest extent possible to distribute WSWG
meeting materials, summanes, and references


Draft Documents

The WSWG will work with two types of draft documents:  (1) WSWG internal drafts and (2) public drafts.  It is
important to understand that, in general, both types of drafts are public documents, available for public review
upon request to the extent provided for under the Freedom of Information Act  and other applicable public
disclosure laws   The distinction between the two types of drafts documents has to do with when and how they
are distributed.

WSWG internal draft documents will be marked "Internal Draft Working Document—Does Not Represent the
Consensus of the WSWG "   In general, WSWG internal draft documents  are draft meeting summaries and
discussion materials prepared by the facilitation team for  WSWG consideration

To encourage a full and candid exchange of views among WSWG members, internal draft documents will not
be distributed beyond WSWG members and staff, federal partners, identified outside experts, and the facilitation
team   Note that internal draft documents are  likely subject to further distribution,  including distribution to the
press, based on requests under the  Freedom of Information Act or other applicable public disclosure laws  If
such a request is made, the WSWG will be notified

Public draft documents will be marked "Public Draft Working Document—Does Not Represent the Consensus of
the WSWG."  Public drafts  are draft documents that are discussed during the open sessions of full WSWG
meetings and are therefore available to the public at the  meeting

Meeting agendas, final meeting summaries, and presentations made to the WSWG by non-WSWG members
are not draft documents


WSWG Copy List for WSWG Internal Draft Documents

A copy list will be maintained for distribution of WSWG internal draft documents   The list will include WSWG
members' staff, federal  partners, identified outside experts,  and the facilitation team  As described earlier m this
document,  staff may  include individuals  from sponsoring/nominating organizations  who  are  specifically
identified by a WSWG member as staff to the member. To the  extent lhat staff prepares draft comments or other
responses for the WSWG member they support, staff must do so in coordination with and as a representative of
the WSWG member; actual comments or responses must be submitted by the WSWG member, not by staff.

The copy list for internal draft documents will be provided  to WSWG members,  and if individuals are added to
or subtracted from the list, the WSWG will be notified.


WSWG Copy List for Non-Draft Documents

A  copy list will be maintained for the WSWG for distribution of non-draft documents   This  list will  include
individuals who have requested that  they be kept up to date on the WSWG process, and may include members
of the press  The copy list for non-draft documents will be provided to WSWG members, and if individuals are
added to or subtracted from the list, the WSWG will be notified
Water Securrry vVor^ing Group Fipd-ngs  Prese'iW'd to The Nciiona! Dnplonc Wafer Advisory -Council 5/1G'05               Pajse 76

-------
FACA, Open and Closed Meetings, and Public Comment
The WSWG chartering entity, the NDWAC, is a Federal advisory committee established and operating under the
requirements  of the Federal Advisory Committee Act (FACA). The WSWG is a working group to the NDWAC
and is not a Federal advisory committee

Consistent with the ground rules for Working Groups established by the NDWAC, WSWG  meetings will be
announced in the Federal Register

In general WSWG  meetings will be open  to  the public for observation and will include an opportunity for
members  of the  public to offer oral and written comments  Meetings and conference calls of the full WSWG
that are open to  the public will be taped

The WSWG may decide to close portions of their meetings to the public to provide a forum for discussion of
secunty-sensitive information, as described below.


Security Sensitive Information
The WSWG may have occasion to discuss security-sensitive information  For purposes of WSWG deliberations,
the group agrees that security-sensitive information is

>   Information  on system-specific, attributable tactical security procedures, or
>   Integrated or aggregated detail on security (e g , by aggregating information from previous un-aggregated
    sources)  that creates a clear  picture of a specific strike opportunity

Information that is already available in the public domain in the same form  and at the same level of detail
discussed by  the WSWG is not security sensitive

WSWG meetings will be closed  to the public as necessary to provide a forum in which WSWG members can
discuss potentially sensitive information related to specific security tactics used by individual utilities. As much as
possible, closed  meeting sessions will be scheduled to be convenient for those  attending the portions of WSWG
meetings  that are open to the public (e g , they will  be at the beginning or end  of  meetings). During closed
meetings, the following protocols will be used.

>   The  meeting will  be open only to WSWG members, federal  resource personnel, facilitation support
    contractors, and identified outside experts
>   The general topics of discussion covered during the closed portion of the meeting will  be documented in the
    meeting  summary; discussion details will not be summarized
>   Any meeting matenals that  are distributed during the closed portion of the meeting will be collected at the
    end of the meeting unless they are deemed suitable for public disclosure
>   The WSWG will evaluate discussions that occur during a  closed meeting at the end of the meeting and
    determine if any security-sensitive information was discussed that requires protection going forward.  The
    Group agrees that a low threshold for identification of secunty-sensitive information is appropriate, and that
    any individual member can  distinguish information as security sensitive
>   Members who choose to raise  or discuss tactical level secunty-sensitive information or other integrated
    security-sensitive  information will  indicate that  they consider the information  they  are sharing security
    sensitive  Unless permission is given by the person who shared the secunty-sensitive  information, members
    will not attribute any information that a  fellow member asserts is security sensitive, furthermore, members will
    not discuss  such information outside closed  WSWG meetings, provided  such information  is  not already
    available in the public domain in the same form and at the same level of detail
 >   The closed portion of the meeting will not be taped


Water Securiry Wor'.pq Group Find ngs  - Prawned to :'ne Ncxsono! Drinking Warer Ad>-.scry Council 5/18/05                paae 77

-------
The WSWG agrees that to maximize the usability of their Report, they will strive to limit inclusion of secunty
sensitive information in the written materials they consider and produce


Communications with the Press
Recognizing that the way in which Working Group deliberations are publicly characterized will affect the group's
ability to reach consensus, WSWG members and other parties involved in the WSWG process are encouraged
to refer inquiries  from the press to the facilitation team or to final meeting  summaries or other final WSWG
materials   Individuals who choose to speak with the press agree to limit remarks to personal views and to refrain
from characterizing the views of, or attributing comments to, the full WSWG, other individual members, or the
NDWAC
Schedule
The WSWG will provide a final report of their findings to the NDWAC  in time for the Council's spring 2005
meeting   It is anticipated that the Council will meet in May  2005, and that the final WSWG report will be
completed and provided to the Council in April 2005.  The WSWG will commence with its first conference call
on July 6, 2004. It is anticipated that the group will meet in person five  times and will meet by conference call
four to six times.
Water Security Wori'-pq Group Find-rgs  PreseTed to the Nctionoi Dunking Wafer Ad/isory •Zov.cA 5/1G/05                Fape 73

-------
ATTACHMENT 3:   ANNOTATED  BIBLIOGRAPHY OF
SECURITY RESOURCES
American Chemistry Council   Responsible Care Security Code of Management Practices  Washington, DC:
       American Chemistry Council, accessed on-line October 2004  URL:
       http//www.amencanchemistrycom/rc.nsf/7120e6a3c6a45fd8852568d5006a33f4/67f8d93b3aflda
       8685256ccd005946c8/$FILE/ResponsibleCareSecuntyCode.pdf

       The ACC outlines the  key elements of a security program under the Responsible Care management
       system.  Members of Responsible Care use the code as a set of guidelines as they start implementing
       and reviewing their own secunty programs.

American Chemistry  Council,  /mp/ementation Guide for  Responsib/e Care Security Code of Management
       Practices Washington,  DC- American Chemistry Council, July 2002  URL:
       http.//www amencanchemistry com/re nsf/7120e6a3c6a45fd8852568d5006a33f4/67f8d93b3aflda
       8685256ccd005946c8/$FILE/Responsible%20Care%20Site%20Secunty%20Guidancepdf

       This guide provides detailed strategies and examples for implementing the Responsible Care Security
       Code of Management Practices  It is a resource guide for the Responsible Care companies who are
       interested in improving  the development, management, and planning of their new security programs

American Chemistry Council Responsible Care Management System. Washington, D C. American Chemistry
       Council, August 15, 2003, accessed on-line October 2004. URL:
       http-//www amencanchemistry com/rc nsf/2febeebd340dda4a8525680b004b7f4a/baalcOd054bf75
       39852569fc005747c9/$FILE/RCMS%20Technical%20Speafica»ion%20-%2008-l 5-03.pdf

       This document is a full  explanation of Responsible  Care's   management   systems   and   guiding
       principles. It explains the elements of the management system in detail  and covers topics that include
       planning,  operations,  corrective action,  preventative  action,  management  review  for  chemical
       companies that are taking part in the program

American Chemistry Council. Site Security for the U S  Chemical Industry  Amencan Chemical Council,
       Chlorine Institute, and the Synthetic Organic Chemical Manufactures Association  October 2001  URL
       htlp://www c!2 com/SecuntyguidanceACC pdf http //www accnewsmedia com/docs/100789.pdf

       This  document  serves  as  a  general  guide  for the  chemical  industry   to  review  general  laws
               concerning security. The American Chemistry  Council,  the  Synthetic Organic Chemical
       Manufacturers Association, and The Chlorine Institute, Inc.  discuss the benefits and steps needed to be
       taken to develop improved security programs

American Chemistry Council, Chemtrec,  The Chlorine Institute, et al.  Transportation Security Guidelines for the
        U S.  Chemical Industry. Additional authors- Compressed Gas Association & the National Association of
        Chemical Distributors  Washington, DC. 2001
        URL  http //www accnewsmedia com/docs/300/250 doc?DocTypelD=4&TracklD =

       This  set of guidelines covers the benefits of developing a  transportation secunty program, nsk-based
        secunty assessments, and helpful resources.  It targets transportation officials,  business managers, plant
        managers, and others  who are responsible for the secure transportation of their chemical supplies and
        other business materials.
 Water Securry vVor'-ng Croup Fins r-gs rres?--,!«i to The Ncisona' Dr.pkinc Ware.- AcU'-scry Council 5/18/05              Pape 79

-------
American Society of Chemical Engineers, American Water Works Association, & Water Environment Federation
        Interim Guidelines for Designing an Online Contaminant Monitoring System  December 9, 2004

        These Guidelines provide information on assessing the need for a contaminant monitonng system,
        locating instruments and sensors, and responding to suspected contamination events

Amencan Society of Chemical Engineers, American Water Works Association, & Water Environment Federation
        Interim   Voluntary   Security  Guidance   for  Water  Utilities    December  9,   2004   URL
        http://www awwa.org/science/wise/

        The Guidelines provide advice on security considerations regarding operations, management, design,
        cyber security management, equipment, and emergency response planning for water utilities seeking to
        voluntarily improve their security systems.

Amencan Society of Chemical Engineers, American Water Works Association, & Water Environment Federation
        Interim Voluntary Security Guidance  for Wastewater/ Stormwater Utilities  December 9, 2004  URL.
        http://www.awwa org/science/wise/

        The Guidelines provide advice on security considerations regarding operations, management, design,
        cyber security  management,  equipment,  and  emergency  response  planning for wastewater and
        stormwater utilities seeking to voluntarily improve their security systems

American Water Works Association (AWWA)   Emergency Planning for Water Utilities   Denver,  CO.  AWWA
        Manual M-19 (Fourth Edition),  ISBN 1 -58321 -135-7, 2001
        URL (to order on-line)- http //www awwa org/bookstore/product cfm2id=30019

        This  planning  guide for water  utilities presents principles and practices for emergency planning. The
        approach  focuses on how to apply organizational knowledge and experience within a specific system,
        determine the  system vulnerabilities,  address  deficiencies,  and  plan  for alternate strategies  when
        needed    It  includes  sections on hazard summary,  vulnerability assessment, mitigation actions;
        preparedness planning, and emergency response, recovery, and training

American Water Works Association (AWWA).  New Horizons  Critical Infrastructure Protection   Denver, CO-
        AWWA DVD or VMS Tape, 2001.
        URL (to order on-line)  http-//www.awwa org/bookstore/product.cfm2id=64226

        The  goal  of  this 26-mmute video is to generate  conversations among water utility managers and
        selected community leaders about water utility security   It seeks to address the question "How ready or
        safe  is your  water  supply to  hostile acts  of  aggression?"   The video also discusses infrastructure
        vulnerability,  emergency  response  plans, contamination, cyber attack, and other intentional acts of
        destruction.

Amencan Water Works Association Research Foundation & the United States Environmental Protection Agency
        Security Practices  Pnmer  for  Water Utilities.   Sub|ect  Area:   Efficient  and  Customer Responsive
        Organization,    Denver,   CO   and   Washington,   DC,  2004   (DFO)   URL    (to   order)
        http://www awwarf.org/research/TopicsAndPro|ects/execSum/2925 aspx

        This  primer is  an initial assessment of water security for utilities that wish to address pressing security
        concerns.   It covers several topic areas including employee  background checks and security framing,
        mail  screening, coordination with local medical care providers, and information and communications
        secunty
Wafer Secunry Wording Croup F.pd-r.gs  PreieTed to The NcTiona! Dnpk:ng Water Adi-sory Council 5/1G'05                Pape 60

-------
Association of Drinking Water Administrators & National Rural Water Association   Security Vulnerability Self-
        Assessment Guide for Small Drinking Water Systems Serving Populations be/ween  3,300 and J 0,000.
        November      13,       2002              URL      (on-line      download       is      free):
        www asdwa org/docs/2002/FINAL10KSystemVAtooll 11302.pdf

        This  guide was designed  to help drinking water systems serving populations of between 3,300  and
        10,000 persons to  identify critical components of vulnerability assessments, complete assessments
        required under the Bioterronsm Act, and identify security measures to be implemented

Association of Metropolitan  Sewage Agencies.  Asset Based Vulnerability Checklist for Wastewater Utilities
        Washington,    DC     2002.       URL    (on-line   download    is    free)-   http.//www amsa-
        cleanwater org/pubs/2002avcheck pdf

        The Asset Based Checklist is intended for wastewater managers as a means to evaluate their overall
        assets, and  to  subsequently secure and  protect their organization based on the evaluation.  The
        checklist  breaks assets into five categories  the physical plant,  the people (i.e staff), the  knowledge
        base, the information  technology, and the customers   It  provides a system for  prioritizing risk and
        includes steps to improve risk management

Association of Metropolitan Sewage Agencies  Legal Issues in a Time of Crisis Checklist. Washington D.C:
        2002 URL (to order on-line):
        http //securel isproductions net/Merchant2/merchant.mv2Screen=PROD&Store_Code=AMSA&Produc
        t_Code=PSECTY02&Category_Code=PSECTY

        The  Checklist is designed to assist wastewater utilities with assessing the legal issues that  arise from
        bioterronst acts or other crisis situations   It targets public utility attorneys and utility managers who are
        concerned about crisis management, emergency planning,  and response mechanisms, and lays out the
        possible and detailed steps needed in planning to avoid legal complications.

Bernowsky, Joseph,  P.E  Water System  Security  A Field Guide.   Washington,  DC: American Water Works
        Association    (AWWA),    ISBN     1-58321-193-4,    2002.    URL    (to    order    on-line)
        httpV/www awwa org/bookstore/product cfm2id=20501

        This field guide provides tools for  small  and medium sized water utilities to assess vulnerabilities, write
        emergency plans, review threats, examine mitigation measures, implement new security policies, select
        and install new technology, and carryout recovery and response from  an  emergency event   It includes
        a computer  disk with documents and a list of information sources included in the appendix

Burns, Nicolas L , et al.  Security  Analysis  and Response for Water Utilities.  Washington,  DC AWWA, 2001.
        (Available as a supplement to AWWA Manual M-19)

        This concise 20-page guide written in 2001 is now a supplement to Manual M-19: Emergency Planning
        for Water Utilities.  M-19 focuses  mainly on natural disasters such as earthquakes and severe storms.
        This guide  reviews international acts of terrorism, hazard assessment, vulnerability assessment, crisis
        communications, mitigation, and development of a response plan in a post 9/11 world.

 Blaha,  Frank J.  Small System Security-There Is Help And Hope   American Water Works  Association Journal
        Denver,  CO- Vol 95,  Iss   7; pg  31, July 2003  Available through  Proquest's ABI/INFORM Trade &
        Industry database

        This article  focuses on small and medium sized water utilities that are looking to use the Security
        Vulnerability Self-assessment Guide for  Small Drinking Water  Systems  Serving  Populations  between
        3,300 and  10,000  The tools addressed were developed as a partnership between NRWA, ASDWA,
        and the EPA The article reviews each of the six technical issues or elements outlined by the US EPA.

 Water Securry vVor'-pg Group Fins r.gs  "re:?<-,!?
-------
Booth, Ron, Chuck- Hewell, and Dan Ryan  Technical Security and Countermeasures White Paper for Water
        Utilities  The National Council for Public-Private Partnerships, Washington, DC. December  12, 2001.
        URL  http://ncppp.org/inthenews/waterwhitepaper html

        This is a general analysis of measures and damages that water utilities may expect from terrorist threats
        The types of threats and  damages are analyzed bnefly and categorized  into four  areas,  physical
        damage,  damage  to  chemical  storage  areas,  biological/chemical  attack indicators,  and  cyber
        terrorism  The paper includes a "Facility Security Survey,"  which is a detailed checklist of questions for a
        vulnerability assessment (Appendix A).

Bramwell, Moses J. Champlin Water Works Seeks Right Level of Security Against Terror Threats.  Journal of the
        American  Water Works Association (AWWA)   Vol.  94(4) 54-56  Denver, CO-  AWWA,  Apnl 2002
        Available through Proquest's ABI/INFORM Trade & Industry database

        This article is a case study that examines how a water utility in Champlin, Minnesota worked to improve
        their security. It reports on the benefits of having a wireless security system, customizing security systems
        to fit needs and  objectives, and educating alarm and security companies as well staff on  new security
        procedures or designs

Cody, Betsy & Opeland, Claudia. Terronsm and Security Issues Facing the Water Infrastructure       Sector
Washington, DC Congressional Research Service (CRS), Updated May 2003.
        URL. http //www.ncseonline org/NLE/CRS/abstract cfm2NLEid = 39364

        This brief report is a legislative analysis of Federal responses to the call for improved security in critical
        water related infrastructure.  It reviews the details of legislation  focusing on  wastewater utilities (H R
        866 and S  1039) and details the various budget proposals for water security improvements until May
        2003.

Denileon, Gay Porter The Who, What, Why, and How of Counter Terrorism Issues.  American Water  Works
        Association Journal.   Denver, CO- Vol  93,  Iss. 5; pg. 78, 8  pgs,  May  2001   Available through
        Proquest's ABI/INFORM Trade & Industry database

        This white paper provides a  history of water  sector security issues  in  the  late 1990's  and before
        September 1 llh, 2001.  It analyzes the Presidential Decision Directive 63 which established the National
        Infrastructure Protection Center and looks at  how the U.S.  EPA  became  the  lead agency on  "critical
        water infrastructure protection issues for the water supply  sector "  It also includes a checklist of security
        measures for utilities to consider

Dyches, Kim   Drinking Water  System  Emergency Response  Guidebook.  Utah Department of  Environmental
        Quality, Salt Lake City,  UT:  November 2002
        http://drmkingwater.utah gov/documents/compliance/emergency_response_guide pdf

        This guidebook's goal  is to help private and  public  utilities design or prepare a disaster/ emergency
        response plan   It covers several key areas including organizational structure, implementation, how to
        prioritize needed repairs, dispatching  personnel and equipment,  requests for emergency  response or
        aid, and the notification of the public/ how to prepare press releases   It also includes  a "Recovery
        Checklist," which includes steps to recover from a water-related emergency

Garcia, Mary Lynn  The Design and Evaluation of Physical Protection Systems  Sandia National Laboratories
        Butterworth-Heinemann, ISBN  0750673672,  February 2001
        URL  (to order) http://www campusi.com

        This book is a guide to determine the  objectives of  a security system or program, design the  security
        system  in detail,  and evaluate the components and  performance  of the security system   It is targeted

Water Security Wor'-pq Group F.nd'r.gs  Presented to the Notions! Drtnlunc  Water Advisory • Council 5/18/05               Pajse 82

-------
        towards  security  students and  professionals  in the field.   The  book includes  a sample model  for
        performance analysis of security systems to estimate or evaluate performance against threats

Geltmg, Richard J, PhD,  & Miller,  Mark D  Unking  Public Health and Water Utilities to Improve Emergency
        Response  Southern Illinois University  - Carbondale, IL Journal of Contemporary Water Research &
        Education,    Issue   129    -    Water   and   Homeland    Security,   October   2004    URL:
        http //www.ucowr.siu edu/updates/129/geltmg pdf

        This article reviews the necessary  connections between medical  service  providers, water utilities, and
        public health officials in the case of a bioterronst water contamination event The authors state that the
        link between  emergency responder and  water utility managers  will directly influence the speed and
        success of a community's response

Hebert, Robert E , A Bnef  Discussion of Water Security  Issues Following  the September 1 1, 2001  Terrorist
        Attacks.  Washington, DC:  The National Council for Public and Private Partnerships, December 12,
        2001
        URL  http://ncppp org/mthenews/waterdiscussion html

        This article discusses threats to the nation's  water systems on a general  level.  It is  targeted for an
        audience of  elected officials, city  managers, and private utility owners.   The author organizes his
        discussion of secunty into three categories or "pillars": prevention, detection, and response.

Hickman, Ma|or  Donald C.  Chemical and Biological Warfare  Threat. USAF Water Systems at  Risk   Air
        University, Maxwell Air Force Base, AL  September 1999.
        URL. http://www au af.mil/au/awc/awcgate/cpc-pubs/hickman htm

        The strategy  paper examines systems  and ideas to identify critical infrastructure points that may be
        vulnerable to chemical or biological weapons attack  The author reviews four areas to improve security
        and  protection of  the USAF water systems   vulnerability assessments,  re-evaluation  of conventional
        wisdom on chemical and biological weapons, and a review of how engineering and  management of
        water systems are outsourced by the USAF

The Homeland Security Council  Planning Scenarios  Executive Summaries (Created for Use in National,
        Federal, State, and Local Homeland Secunty Planning Activities)  The Homeland Secunty Council:
        David Howe, Senior Director for Response and Planning  Washington, DC  July 2004.
        URL: http //www altheim com/lit/planning_scenanos_exec_summary html

        The Homeland Security Council has developed a list of 15 scenarios that  all national, state-level, and
        local planning officials should use in secunty and safety program  development.

Lancaster-Brooks Khafra, Engineering Consultant.   Water Terrorism  An  Overview of Water & Wastewater
        Security Problems and Solutions, Journal of Homeland Secunty, Northern Virginia February 2002
        URL http //www.homelandsecunty org/|ournal/articles/displayArticle.asp?article=31

        In this article, the author reviews measures to  defend water utilities from malevolent threats of vandalism
        and terrorism The article lists different types of infrastructure that need protection and examines some
        measures that utilities  have adopted for securing them  It also includes a practical list of questions to
        review in the 'Generic Basic Water System Evaluation "

Landers, Jay  Safeguarding Water Utilities Civil Engineering: The Magazine  of the Amencan Society  of Civil
        Engineers. Vol. 72, No 6, June 2002

        The article draws a basic map of where the thinking on water secunty is going through mid-2002  The
        article includes  interviews with experts throughout the sector  and touches on several key areas of
        concern including, redundancy in  security systems, determining infrastructure needs, and looking at cost
 Wafer Securav vVor'.pg Group Find r.gj- -TrKented to The Ncriona! Dr.pkma Wcier Ad>'.sory Council 5/10/05                Pace S3

-------
        considerations of  new  methodologies   The  article  also touches on the differences between  a
        performance-based approach and one based more on compliance

Mayes Larry W., PhD, PE, PH  (Ed ) Water Supply Systems Security McGraw-Hill, New York, NY:  2004.  URL (to
        order):  http//www campusi.com

        This book is wntten by a team of security experts and provides broad coverage of secunty systems for
        the water sector.   Topics indude a review  of  reliability methodologies, modeling methods for early
        warning systems, frameworks to improve the security of a water system  over time,  case  studies taken
        from the field,  analysis  systems for contamination response, safeguards against cyber threats,  and
        specialized systems for remote monitoring and networks

National Biosolids Partnership Elements of an Environmental Management System for Biosolids
                Excerpted chapter (pp 8-15). Element by Element Requirements Alexandria, VA Final Interim
        Draft, May 1,2002.

        This chapter excerpted from an NBP guidance document addresses 1 7 elements which are prudent in
        developing an effective Environmental Management System.

Schlegel,  Julie   Automofed  Distribution  System Monitoring Supports  Water  Quality, Streamlines  Systems
        Management, and Fortifies Security.  American Water Works Association Journal   Denver, CO  Vol
        96, Iss.  1; pg. 44, 3  pgs, January 2004

        In this article,  the author  discusses the  benefits of real  time  water quality monitoring  and its
        management applications for water utility management. The article briefly reviews how multiple water
        quality parameters are monitored simultaneously, the ways in which real-time data can improve water
        utility management, and how distribution monitoring may ameliorate security

Tiemann,  Mary Safeguarding the Nation's Drinking Water:  EPA and Congressional Actions  Washington,  DC:
        Congressional Research Service (CRS), Updated March,  2003
        URL: http //www.ncseonline org/NLE/CRS/abstract.cfm2NLEid=344 19

        This CRS  report is a general analysis of Federal legislation including the Homeland Security Act of 2002
        (the creation of the Department of Homeland Security), the Public Health and Bioterronsm  Preparedness
        Act of 2002, and appropriations for water security activities through March of 2003.


U.S  EPA  Drinking Water Security website  New England Office, Boston, MA-  July 2004
        URL  http.//www epa  gov/ne/eco/drmkwater/dw-secunty html

        The  introductory  article and collection of links  provides sources  of  information  on vulnerability
        assessment for water utilities.  The article summarizes current work and progress on water security in the
        Northeast EPA Region.

U S. EPA.  Emergency Response Plan Guidance for Small and Medium Community Water Systems to Comply
        with the Public Health Security and Bioterrorism Preparedness and Response Act of 2002. Washington
        DC. U S  EPA Office of Water, EPA 816-R-04-002,  April 2004.
        URL-http://www.epa gov/safewater/watersecunty/pubs/small_medium_ERP_guidance040704 pdf

        EPA published this guide for small  and medium  community water systems (serving populations  between
        3,301 and 99,999)  to assist them in their effort  to develop and revise Emergency Response Plans
        (ERPs). The document is target audience includes "key  authorities with critical roles during emergency
        response or remediation actions from a drinking water contamination threat or incident."
Water oecunry vVor'-pq Group Findings  Prssei'ed to :'ne Nciiona: Drinking Worer Adi-scry 'Council 5/1G/05                Pgpe G4

-------
U S  EPA. Guarding Against Terrorist and Security Threats: Suggested Measures for Drinking  Water Utilities,
        Washington DC: Revised August 2004. URL-
        httpY/www dhs.ca gov/ps/ddwem/homeland/Appendix/Appendix!  %20USEPAthreatlevelgucemarch_%
        2031.pdf

        This threat guide uses the Green, Blue, Yellow, Orange, Red threat levels developed by DHS   It also
        outlines measures that water utilities should consider at each given threat level

U S. EPA. Guidance for Water Utility Response, Recovery, and Remediation Actions forMan-Made and/or
        Technological Emergencies.  Washington, DC  U.S. EPA Office of Water, EPA 810-R-02-001, April
        2002  URL  http-//www.epa.gov/safewater/watersecunty/pubs/er-guidance.pdf

        This guide is purely reactive  in nature as it focuses on the steps water utilities must take in response to
        man-made or  technological problems.    It  includes  information  on  incident  types,  guidance
        development, response planning, notification considerations, sample collection, identification, chain of
        custody (of samples), SCADA intrusions, structural damage resulting  from an international  act, and
        notification from health officials.

US  EPA   Instructions to Assist Community Water Systems in Complying  with the Public Health Security and
        Bioterronsm  Preparedness and Response Act of 2002   Washington, DC   U.S. EPA Office of Water,
        EPA 810-B-02-001, January 2003.
        URL: http //www epa gov/safewater/watersecunty/pubs/util-inst.pdf

        This document is aimed at water utility managers who have questions about complying with the Public
        Health Security and Bioterronsm  Preparedness and Response Act of 2002  It answers questions as to
        instructions at a glance, determining the size of the utility, compliance requirements,  key dates, and
        ways in which to submit the information back to EPA

U.S. EPA  Large Water  System  Emergency Response Plan  Outline:  Guidance to Assist Community Water
        Systems in Complying with the Public Health Security and Bioterronsm  Preparedness and Response  Act
        of 2002.  Washington DC U S EPA Office of Water (4601M), EPA 810-F-03-007, July 2003
        URL. http //www.epa.gov/safewater/watersecunty/pubs/erp-long-outline.pdf

        This document is similar intent to the previous, but targeted at larger community water systems (CWS)
        It covers  different  topics that include  emergency planning processes,  emergency  response plans,
        identification  of alternative  water sources, chain of command  charts, communications  procedures,
        personnel  safety,  equipment, property  protection,  training  exercises (or drills),  emergency  action
        procedures, incident specific emergency action procedures, next steps, and other references

U S  EPA's Drinking  Water Academy  Learner's Guide to Security  Considerations for Small  Drinking Water
        Systems-  Major Security Considerations When Performing a Sanitary Survey of a Small Water System.
        Washington, DC U S. EPA Office of Water, publication  EPA 816-R-03-013, August 2003. (DFO)
        URL (to order)  http //www.epa gov/OGWDW/dwa/resources.html

        The Learner's  Guide is a tool to be used  by  community water systems serving fewer  than 10,000
        people   It was  developed as part  of  a partnership  with  the Association of State  Drinking Water
        Administrators (ASDWA)  and the EPA  Drinking Water Academy's  Sanitary Survey  Workgroup    It
        examines a multiple barrier approach to security, utility  management, water sources, water pumps, the
        water treatment process, storage facilities, and distribution systems  at small water utilities

U S  EPA  Response Protocol Toolbox  Planning for and Responding to  Contamination Threats to Drinking
        Water Systems. Washington, D C. December 2003 to April 2004  (DFO)
        URL  http://www epa gov/safewater/watersecurity/pubs/guide_response_overview.pdf
Water Secunry vVor>.pg Croup F^nd-nqs  Prawved tc The NcTionai Dr.pking Warer Ad>'.sory Council 5/16/05                Pane G5

-------
        The goal of this EPA Toolbox is to assist water utilities to "effectively and appropriately respond to
        intentional contamination threats and incidents "  It was written and revised by the EPA in partnership
        with  the  Metropolitan  Water District  of  Southern  California.  It  targets  water utilities,  laboratories,
        emergency responders, state drinking water programs, technical assistance providers, public health and
        law enforcement officials It includes an overview and six separate modules (or tools) that can be used
        independently

U S. EPA's Drinking Water Academy, & the  National Environmental Training Association  DVD/Video Security
        Considerations.   Small Water Systems  Are  We  Ready? Can  We Respond? Can We  Recover?
        Washmgton, D.C.: 2003 (DFO)

        A video produced for state and local water systems interested in improving their security programs The
        video focuses on key topics in water security.  The video is based on EPA's "Learner's Guide to Security
        Considerations for Small Drinking Water  Systems Major Security Considerations When Performing a
        Sanitary Survey of a Small Water System."

U S. EPA.  Security Product Guide- Water and Wastewater Security Program Guide  Washington DC  US. EPA
        website, 2004.
        Overview— URL: http //www.epa gov/safewater/secunty/guide/index html
        Table of Contents—
        URL  http://www.epa gov/safewater/watersecunty/guide/tableofcontents html

        The web-based guide provides information on products that may help utilities improve  physical and
        cyber security measures   The guide evaluates products  that  are  applicable to improving distribution
        systems, wastewater collection systems, pumping stations, treatment processes, mam plan) and remote
        sites,  personnel  entry,  chemical delivery  and  storage, SCADA,  and control systems for water and
        wastewater treatment systems.

U S  EPA.   Survey Results  on  Information Used by Water Utilities  to  Conduct Vulnerability  Assessments
        Washington  DC-   U.S.  EPA Office of the Inspector General,  Report No.  2004-M-001, January 20,
        2004.
        URL. http //www.epa.gov/oig/reports/2004/20040120-2004-M-0001.pdf

        The survey evaluates the information that  some utilities used in the process of writing their vulnerability
        assessments  It  examines the "usefulness of information provided  to water utilities  by  the EPA and
        others, to discuss other security concerns that water utilities have expressed, and to look at performance
        indicators that may measure improvements tn water secunty levels or programs."

U.S  EPA.  Table Top Exercise CD ROM: Tram-the-Tramer Materials Description (from trainings organized by the
        U S.  EPA for the Response  Protocol Toolbox). Washington  DC  U.S. EPA Office of Water Security,
        August 2004.

        The target audience for this CD ROM is water utility managers and staff as well as their partners in the
        response community. The goal of the CD is to improve and strengthen the relationships between water
        utilities and emergency response groups before an incident occurs  The CD includes an introduction,
        tabletop exercises, and tram-the-trainer materials for training workshops (based on the RPTB modules)
        for printing and distribution.

U.S. EPA.  Top Ten List for Small  Ground Water  Suppliers   Boston, MA  U S. EPA Northeast Office website,
        2004
        URL.  http://www epa gov/ne/eco/drinkwater/pdfs/drinkmgH2Ofactsheet pdf

        This top ten list is a "how to" fact sheet prepared by the  EPA's Northeast Office  It  allows small water
        utilities to quickly examine a short list of tasks and actions which will indicate their preparedness for a
        water related emergency.

Water Securay vVor^pq Group F.r>d.r.gs  Presented to :!-ie Ncnona: Dnnkino Water Ack-sory Council 5/10/05                Pace G6

-------
U S. EPA.  Wafer Security Wefasife Washington, DC Office of U S EPA- accessed Apnl 2005.
        URL  http //cfpub epa gov/safewater/watersecurity/index.cfm

        This official U.S. EPA water security page provides information on VA's, emergency planning, security
        enhancements, legislation and directives, trainings, grants, other tools, publications, and related links
        It is  an important source of materials and information for  a water utility manager  and interested
        officials

U S GAO  Report to the Committee on Environment and Public Works,  U S. Senate—Drinking Water- Expert
        Views on How Future Federal  Funding  Can Best Be Spent to Improve Security   Washington, DC
        GAO-04-29     Drinking     Water     Security,     October     2003          (DFO)     URL
        http-//www gao gov/new.items/d0429.pdf

        The GAO  report  reviews the state of water security in a  broad manner. The U.S. Senate Environment
        and Public Works committee commissioned the systematic web based research  to discuss water security
        matters with 43 selected experts.  The GAO recommends that the  EPA use the report as a guide to
        allocating  funding or resources to water utilities.  It  outlines the methods it recommends to distribute
        Federal funding, and a compilation of security-enhancing activities that utilities may undertake.

U S GAO. Tesfimony Before the Subcommittee on Environment and Hazardous Materials, Committee on Energy
        and  Commerce,  House of Representatives—Drinking Water  Experts' Views on How Federal Funding
        Can  Best Be Spent To Improve Security. Washington, DC GAO-04-1098T Drinking  Water  Security,
        September 30, 2004
        URL- http //www.gao gov/new items/d041098t pdf

        U S  GAO Testimony to follow up on the Report Senafe—Drinking Water: Expert Views on How Fufure
        Federal Funding Can Best Be Spent to  Improve Security.  This is the most recent discussion of the report
        before the US Congress (House of Representatives.

U S GAO   Wastewater Facilities Experts' Views on How Federal  Funds Should Be Spent to Improve  Security
        Washington, DC- GAO-05-165, January 31, 2005.  URL-  http //www gao gov/new items/d05165 pdf
        Abstract URL  http-//www.gao.gov/docsearch/abstract php?rptno=GAO-05-l 65
        Highlights URL http.//www gao gov/highlights/d05165high.pdf

        The  U S  GAO summarizes  their findings from a web-based survey which involved interviews of 50
        experts across the nation to learn more about specific wastewater issues. The  issues included: "(1) key
        secunty-related vulnerabilities affecting wastewater systems, (2) activities the federal government should
        support to improve wastewater security, and (3) criteria that should be  used to  determine  how any
        federal funds are allocated to improve security,  and the best methods to distribute these  funds."
 Water Securiry vVor-'.nq Group f-M-^t  rmfffl to The Ncisona: Dr-nk:nc Water Ad/isory Council 5/18/05                Paae 87

-------
Water Security vVori-ing Group Find'^-gs   Pres*n«*d to :he Nctsona! Dnnlurto Warer Ad.-.sory Council 5/16/05                   Poae G3

-------
ATTACHMENT 4:   ACRONYM  LIST
ACC - American Chemistry Council
ADWA - Association of Drinking Water Administrators
ASCE - Amencan Society of Civil Engineers
AMWA - Association of Metropolitan Water Agencies
AWWA - American Water Works Association
AWWARF - Amencan Water Works Association Research Foundation
Bioterronsm Preparedness and Response Act - Bioterrorism Ad
Cl - American Chlorine Institute
EPA-The Environmental Protection Agency
ERP - Emergency Response/ Recovery Plan
GAO - Government Accountability Office
HSC - Homeland Security Council
HSIN - Homeland Security Information Network
IT - Information Technology
CDC - Centers for Disease Control and Prevention
DHS - Department of Homeland Secunty
DoD - Department of Defense
NACWA- National Association of Clean Water Agencies
NBP - National Biosolid Partnership
NDWAC - National Drinking Water Advisory Council
NRWA - National Rural Water Association
NW WARN - NorthWest Warning and Alert Response Network
RAM-W - Risk Assessment Methodology for Water
SCADA - Secure Supervisory Control and Data Acquisition
SEMS - Security and Environmental Management System
V-SAT - Vulnerability Self-Assessment Tool
WaterlSAC - The Water Information Sharing and Analysis Center
WEF - Water Environment Federation
WSWG - The Water Security Working Group
WSCC - Water Secunty Coordination Council
 Water Secursy iVof-pq Croup F'PO-rgs Prsse'i'ed to The Ncisona! Dr-nking Ware.' Ad^sory Council 5/16/05              Page 89

-------
Water Secunry vVof.ng Group F.nd-r.gs  Presented to ihe Nciiona! Drirking Wafer Adv.sory Council S/l G/05

-------