July 9, 2002
Water Security Strategy for Systems Serving
Populations Less than 100,000/15 MGD or Less
I. Introduction
A.	Background
From its inception, the overall vision of the US Environmental Protection Agency (USEPA)
Water Protection Task Force has been to help the greatest number of drinking water and wastewater
systems to be more secure as soon as possible. USEPA is working through cooperative and
collaborative efforts with states, tribes, local government, stakeholder organizations, and drinking
water systems and wastewater utilities to achieve this goal. Through these efforts, USEPA is
striving to assist all drinking water systems and wastewater utilities.
In Fiscal Year (FY) 2002, a major focus of the work has been on supporting very large
drinking water systems (serving a 100,000 or more people) and wastewater utilities (treating more
than 15 million gallons of wastewater per day (MGD)). The water security strategy presented in this
document focuses on the work needed to increase the level of security preparedness of drinking
water systems that serve populations less than 100,000 and wastewater utilities that treat 15 MGD or
less. This strategy also includes tribal drinking water systems and wastewater utilities.
B.	Scope and Purpose
In formulating this water security strategy for systems serving populations less than 100,000
and 15 MGD or less, USEPA is focusing on establishing general goals, objectives and tasks that
would increase security for drinking water systems and wastewater utilities while also meeting
specific statutory requirements (see following discussion). In addition, USEPA is interested in a
flexible implementation strategy that takes into account local and regional circumstances and builds
upon other security initiatives or requirements (e.g., activities supported by other federal agencies
such as US Health and Human Services counter-terrorist preparedness) while at the same time
establishing clear and measurable accomplishments. With these objectives in mind, this strategy
looks to states to facilitate and coordinate many of the key implementation tasks. It is envisioned
that states will utilize partnerships with a variety of stakeholder organizations to best achieve higher
levels of security for the drinking water systems and wastewater utilities they regulate.
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In January 2002, the President signed the FY 02 Supplemental Defense Appropriations Bill
containing $89 million for USEPA to use for a number of security related needs including drinking
water system and wastewater utility vulnerability assessments and emergency response plans. Out
of these funds, USEPA provided approximately $53 million for vulnerability assessments,
emergency response plans, and security planning at drinking water systems serving 100,000 people
or more. USEPA will also use approximately $23 million of the FY 02 funds for security at drinking
water systems serving less than 100,000 people; and $3 million of the FY 02 funds for security at
wastewater utilities treating 15 MGD of wastewater per day or less.
C.	New Legislation
In June 2002 the President signed PL 107-188, the Public Health, Security, and Bioterrorism
Preparedness and Response Act ("Bioterrorism Act") that includes provisions to help safeguard the
nation's public drinking water systems against terrorist and other intentional acts. Key provisions of
the new security-related amendments are summarized below:
2.	Requires community water systems serving populations greater than 3,300 to conduct
vulnerability assessments and submit them to USEPA;
3.	Requires specific elements to be included in a vulnerability assessment;
4.	Requires each system that completes a vulnerability assessment to revise an emergency
response plan and coordinate (to the extent possible) with local emergency planning
committees;
5.	Identifies specific completion dates for both vulnerability assessments and emergency
response plans;
6.	USEPA is to develop security protocols as may be necessary to protect the copies of
vulnerability assessments in its possession;
7.	USEPA is to provide guidance to community water systems serving populations of 3,300 or
less on how to conduct vulnerability assessments, prepare emergency response plans, and
address threats;
8.	USEPA is to provide baseline information to community water systems regarding types of
probable terrorist or other intentional threats;
9.	USEPA is to review current and future methods to prevent, detect and respond to the
intentional introduction of chemical, biological or radiological contaminants into community
water systems and their respective source waters;
10.	USEPA is to review methods and means by which terrorists or other individuals or groups
could disrupt the supply of safe drinking water; and
11.	Authorizes funds to support these activities.
As of this writing, Congress has not mandated similar requirements for wastewater utilities.
In the event that Congress does take such action, this strategy will be revised to include those
requirements.
D.	Size Categorization and Deadlines
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For the purpose of this strategy, drinking water systems and wastewater utilities are classified
according to size. This approach has been taken to better address the needs and circumstances of
drinking water systems and wastewater utilities, particularly for the smaller size groups.
Drinking Water Systems
The strategy covers all public drinking water systems (i.e., community water systems (CWS),
nontransient noncommunity water systems (NTNCWS), and transient noncommunity water
systems (TNCWS)) serving fewer than 100,000 people.
Wastewater Utilities
The strategy covers all wastewater utilities with treatment capacities of 15 MGD or less.
Tables 1.1 and 1.2 below summarize the size categories for drinking water systems and
wastewater utilities and also provide some statistical information on how many systems are expected
to be eventually covered by this strategy.
Table 1.1 Public Drinking Water Systems Serving Populations less than 100,000
System Size (based on population served)
Number of Systems
CWS 25 -3,300
45,503
CWS 3,301 -49,999
7,473
CWS 50,000 - 99,999
457
NTNCWS 25 - 99,999
20,092
TNCWS 25 - 99,999
91,590
Table 1.2 Wastewater Utilities Treating
5 MGD or Less
System Size
Number of Systems
less than 1 MGD
approximately 13,000
1 MGD and up to 15 MGD
approximately 3,000
The Bioterrorism Act of 2002 also delineates community drinking water systems according
to population served. The new legislation requires that vulnerability assessments be completed by
certain dates according to size delineation. Additionally, once community drinking water systems
complete a vulnerability assessment they are required, within six months, to develop or revise their
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emergency response plans and incorporate the results of the vulnerability assessment. Table 1.3
shows the various size designations set forth in the new Bioterrorism Act and lists deadlines for the
vulnerability assessments and emergency response plans. There are no similar legislative provisions
for wastewater utilities.
Table 1.3 Vulnerability Assessment and Emergency Response Plan Completion
Deadlines for Community Water Systems as Required by the Bioterrorism Act of 2002
System Size
(based on
population
served)
Vulnerability Assessment
Completion Deadline
Emergency Response Plan
Completion Deadline
25 -3,300
Not applicable
Not applicable
3,301 -49,999
June 30, 2004
December 31, 2004
50,000 - 99,999
December 31, 2003
June 30, 2004
II. Strategic Approach to Drinking Water System and Wastewater Utility Security
USEPA has developed several strategic objectives to address drinking water system and
wastewater utility security needs and also meet requirements set forth in the Bioterrorism Act for
public drinking water security. These strategic objectives are as follows:
Providing tools and guidance to drinking water systems and wastewater utilities
Providing training and technical assistance including "Train-the-Trainer" programs
Providing financial assistance to undertake vulnerability assessments and emergency
response plans as funds are made available.
Build and maintain reliable communication processes
Build and maintain reliable information systems
Improve knowledge of potential threats, methods to detect attacks, and effectiveness
of security enhancements in the water sector
Improve networking among groups involved in security-related matters - water,
emergency response, laboratory, environmental, intelligence and law enforcement
communities
The following sections provide short descriptions of each of the strategic objectives and the
associated tasks. The first four objectives (A, B, C and D) are specific to drinking water systems
serving populations of less than 100,000 people or treating 15 MGD or less of wastewater. The last
three objectives (E, F and G) will benefit all sizes of drinking water systems and wastewater utilities,
not only those serving populations of less than 100,000 people or treating 15 MGD of less of
wastewater. The tasks in the last three objectives will be started in FY 02.
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A.	Tools and Guidance
USEPA will develop and provide various tools and guidance to assist drinking water systems
and wastewater utilities to carry out vulnerability assessments, implement security improvements,
and effectively respond to terrorist events. Except as otherwise noted, these activities will start in
FY 02. Development will be the responsibility of USEPA in cooperation with states, tribes, utility
organizations, drinking water systems, wastewater utilities, and others as appropriate. Specific tasks
follow:
Develop guidance and tools on how to conduct vulnerability assessments, prepare
emergency response plans, and address threats from terrorists or other intentional
acts. Begin development of initial tools for drinking water systems that serve more
than 3,300 people and all wastewater utilities in FY 02. Complete guidance for
drinking water systems serving less than 3,300 persons in FY 03 (as required under
the Bioterrorism Act of 2002).
Provide baseline information on potential terrorist threats to community drinking
water systems (as required under the Bioterrorism Act of 2002).
B.	Training and Technical Assistance
USEPA will complement the various tools developed by supporting training and technical
assistance to help states, tribes, drinking water systems and wastewater utilities, and training
organizations effectively use the tools and implement security improvements. USEPA will also
work to build effective water security practices into the ongoing USEPA, state, and tribal water
programs. These activities will be started in FY 02 and the specific tasks follow:
Provide training and technical assistance for drinking water systems and wastewater
utilities to carry out vulnerability assessments, emergency response plans and related
security issues. For the majority of the training and technical assistance on
vulnerability assessments and emergency response plans, USEPA will work through
the states. Using grant agreements, USEPA will encourage states to take advantage
of existing tools and training such as "Train-the-Trainer" programs developed as part
of this strategy.
Provide financial support for non-governmental organizations' "Train-the-Trainer"
programs to build staff expertise in water security issues that provide training and
technical assistance to drinking water systems and wastewater utilities. (This
resource pool of trained trainers/professionals will then be available to help states
deliver training and technical assistance to drinking water systems and wastewater
utilities).
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Amend highest priority, existing training programs and management systems to
incorporate security components. USEPA will work with states, tribes, drinking
water systems and wastewater utilities to build effective water security components
into ongoing drinking water system and wastewater utility operations as well as
within USEPA (national and regional), state, and tribal review systems (e.g., sanitary
survey, capacity development, drinking water system and wastewater utility operator
certification, source water assessments, wellhead protection, surface water treatment
optimization for drinking water systems, wastewater utility pretreatment program,
and environmental management systems).
C.	Financial Assistance
The proposed funding allocation (see Attachment 1 of this strategy) reflects the use of
approximately $26 million ($23 million for security at drinking water systems serving less than
100,000 people and $3 million for security at wastewater utilities) made available from the FY 02
Supplemental Defense Appropriation. As funds authorized under the Bioterrorism Act of 2002 are
appropriated, additional financial assistance will be provided to drinking water systems to conduct
vulnerability assessments, develop emergency response plans and/or design and implement security
enhancements. Prior to awarding funds, USEPA will work with partners to develop a process for
determining priorities for the use of the funds and the order in which drinking water facilities will
receive funding.
D.	Reliable Communication Processes
USEPA will provide support to improve communication capabilities between states and
drinking water systems (serving less than 100,000 people). For example, through support from
USEPA, states may develop fax and e-mail lists to disseminate information to drinking water
systems serving less than 100,000 people, or build other mechanisms to improve communications
based on the needs of these systems.
E.	Reliable Information Systems
USEPA will continue to provide financial assistance to the Association of Metropolitan
Water Agencies to establish and maintain a secure Information Sharing and Analysis Center (ISAC)
for the water utility sector to exchange water threats/incident information and analysis.
F.	Improved Knowledge in the Water Security Sector
USEPA will work with other federal agencies, universities, and the private sector to: (a)
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review methods to prevent, detect and respond to chemical, biological, radiological contaminants
into community drinking water systems and wastewater utilities; (b) review methods and means by
which terrorists could disrupt the supply of safe drinking water or take other actions against water
collection, pretreatment, treatment, storage, and distribution facilities; and (c) review methods and
means by which alternative supplies of drinking water could be provided in the event of a disruption.
USEPA will provide guidance on security hardware improvement (for example, locks,
cameras, etc.); USEPA will work with utility representatives to design and then develop a security
hardware evaluation guide that would help drinking water systems and wastewater utilities address
their vulnerabilities and make informed decisions on the effectiveness, cost, operation and
maintenance of security hardware improvements. USEPA will establish a technology verification
program for water utility security improvements and evaluate different technologies. USEPA will
also provide additional guidance and support exchange of information on technologies and
methodologies as new information becomes available.
G. Improved Networking in the Water Security Sector
USEPA will foster coordination among federal, state, tribal, local emergency responders,
health agencies, environmental labs, the medical community, and the law enforcement community at
all levels (federal, state and local) concerning response to suspected and actual terrorist actions
against drinking water systems and wastewater utilities. This will be achieved through training and
support of simulations and emergency response exercises.
III. Measuring Progress and Success
USEPA, states, and stakeholder organizations will work together on establishing overall
measures of success so that progress (i.e., improving security) can be readily identified. More
detailed measures of success would be identified by states.
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Attachment 1
Summary of Proposed Funding Allocation for
Fiscal Year 2002 Supplemental Funds
Activity	Funding Amount
Tool development for drinking water systems	$300,000
Technical assistance & training for drinking water systems	$17,000,000
serving less than 100,000 people (administered through states)
including:
-	Vulnerability self-assessment technical
assistance (tool distribution & training)
-	Emergency response plan technical
assistance (tool distribution & training)
-	Upgrading communications
Drinking Water "Train-the-Trainer" programs	$1,500,000
Incorporate security issues into programs	$2,000,000
Tools, training and technical assistance for wastewater	$3,000,000
utilities
Portion of funds for activities that support all drinking water	$2,200,000
systems and wastewater utilities (Information Sharing and
Analysis Center, Improving Knowledge, Technology
Development and Networking applied to this strategy)
NOTE: These are broad estimates and may be subject to change. Additionally, a small portion of
this funding may be used by USEPA to support these activities with tribes.
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