United States                  Office of Water                     EPA 832-F-01-008
Environmental Protection          (4606)                             November 2001
Agency                        Washington, D.C. 20460

                 Use of the Clean Water State Revolving Fund

                 (CWSRF) to Implement Security Measures  at

                 Publicly-owned Wastewater Treatment Works

    Every American needs to be confident that the discharge from their community wastewater
treatment plant is safe.  Adequate protection of publicly-owned treatment works (POTW)
conveyance and treatment systems has been an important goal of the Environmental Protection
Agency's (EPA) wastewater program.  Since the terrorist attacks of September 11, 2001, we
have received questions from states about the eligibility of security measures for financial
assistance through the Clean Water State Revolving Fund (CWSPvF).

    While the events of September 11 have focused attention on this matter, it is important to
note that POTWs have always worked to protect facilities from vandalism and have monitored
influent waste streams to assess their vulnerability to industrial discharges. EPA encourages
state wastewater programs and CWSPvF programs to continue to work with POTWs to help them
identify their vulnerability to security threats and vandalism and take steps to ensure protection
of the public health of their customers. This fact sheet discusses the types of projects that may be
fundable through the CWSPvF that will help POTWs ensure the protection of their facilities.

What is the CWSRF program?

    The EPA CWSPvF program provides grant funding to states to allow them to assist POTWs
to make infrastructure improvements needed to protect public health and ensure compliance with
the Clean Water Act. States may use CWSPvF monies to provide low or zero percent interest rate
loans to municipalities for wastewater infrastructure, including facility and sewer construction
and rehabilitation, storm water management, and combined sewer and sanitary overflow

What can wastewater  utilities do to ensure security?

    Water utilities can take straightforward, commonsense actions to increase security and
reduce threats from terrorism. Areas in which to focus attention, as recommended by the
Association of Metropolitan Sewerage Agencies, the Association of State and Interstate Water
Pollution Control Administrators, the Water Environment Federation, and other leading
professional organizations, include guarding against unplanned physical intrusion, making
security a priority for employees, coordinating actions for effective emergency response and
investing in security and infrastructure improvements.

What security measures can be funded through the CWSRF?
    States may provide CWSRF assistance to POTWs to allow them to complete vulnerability
assessments and contingency and emergency response plans. Many of the types of infrastructure
improvements a wastewater system could need to take to ensure security are also eligible for
CWSRF funding and may have already been included within the scope of infrastructure projects
funded through the program to date. Table 1 identifies specific activities that POTWs could take
to ensure the security of their systems and indicates if the activity would be eligible through the
CWSRF program.
                   Security Measures and Eligibility under the CWSRF Program
Type of Activity
Eligible under CWSRF
Vulnerability Assessments
Contingency/Emergency Response Plans
Security Guards
Security Cameras/Lighting
Motion Detectors
Redundancy (systems and power)
Secure Chemical and Fuel Storage
Lab Equipment
Sewer System
Securing Large Sanitary Sewers
Tamper-proof Manholes
What security measures cannot be funded through the CWSRF?

    It should be noted that maintaining a human presence can be the most important security
measure a POTW can take to ensure that its facilities are protected. The CWSRF program
cannot fund operations and maintenance activities for POTWs and therefore could not provide
financing for an increased human security presence. Likewise, the CWSRF program cannot
provide assistance to help a system purchase the chemicals needed to increase disinfection.

How will states fund POTW projects?

    If a municipality is interested in obtaining financing to implement security measures, the
first step in seeking assistance is to contact the state CWSRF representative - who can be found
on the Office of Wastewater Management website at http://www.epa.gov/owm/finan.html.

    Typically, any project that will receive CWSRF funding must go through public review as
part of development of an annual Intended Use Plan which lays out how the state will implement
its CWSRF program over the subsequent year. States do, however, have the ability to include
procedures in their programs that can allow them to fund emergency projects. Each state should
consider the proposals they receive from municipalities in order to make a determination as to
whether the proposed improvement would qualify as an emergency project that should be
addressed immediately.

    In some cases the types of activities that will need to be implemented may have a longer
time horizon. For example, some communities are switching their treatment process to
eliminate the use of gaseous chlorine. This type of project, which may require time for design
and planning, will be on a longer timeline  than a project needed to install adequate security
fencing, and would thus go through the traditional process for funding CWSRF projects.

Where can I find more information?

    The Agency is coordinating with the water industry to provide information and technical
assistance to states and utilities to help during this time.  EPA is working collaboratively with
the Association of Metropolitan Water Agencies and other groups to develop an Information
Sharing and Analysis Center to bolster coordinated notification and response to threats and
vulnerabilities. For additional information, you can also visit the  following websites:

    EPA Counter-terrorism: http://www.epa.gov/ebtpages/ecounterterrorism.html
    EPA Alert on Chemical Accident Prevention and Site Security:
    U.S. Centers  for Disease Control & Prevention: http://www.bt.cdc.sov
    Association of Metropolitan  Sewerage Agencies: http://www.amsa-cleanwater.org/
    Association of State and Interstate Water Pollution Control Administrators:
    National League of Cities: http://www.nlc.org/nlc  org/site/newsroom/terrorism  response
    National Governors Association, Emergency Management and Terrorism:
       http://www.nga.org/center/topics/lj 188J3  854,00.html

                        Clean Water State Revolving Fund Program
                          U. S. Environmental Protection Agency
                    1200 Pennsylvania Avenue, NW (Mail Code 4204M)
                                Washington, D.C. 20460
                           http ://www. epa. gov/owm/finan.html