(PLEASE NOTE: Dr. Kolb's statement follows Dr. Baecher's.)
EPA WATER SECURITY RESEARCH AND TECHNICAL SUPPORT PLAN
Gregory B. Baecher, Ph.D.
Professor of Civil and Environmental Engineering
University of Maryland, College Park
Member of the Panel on Water System Security Research
Water Science and Technology Board
National Research Council
The National Academies
Subcommittee on Environment, Technology and Standards
Committee on Science
U.S. House of Representatives
"Homeland Security Research and Development at the EPA:
Taking Stock and Looking Ahead”
May 19, 2004
Good afternoon, Chairman Ehlers and members of the Committee. Thank you for the invitation to discuss the security of our nation’s water systems. I am Gregory B. Baecher, Professor of Civil and Environmental Engineering at the University of Maryland, and a member of the National Research Council Panel on Water System Security Research. The National Research Council (NRC) is the operating arm of the National Academy of Sciences, National Academy of Engineering, and the Institute of Medicine of the National Academies, chartered by Congress in 1863 to advise the government on matters of science and technology. The Panel on Water System Security Research was organized by the National Research Council’s Water Science and Technology Board in response to an Environmental Protection Agency request to review EPA Homeland Security efforts in the areas of water systems and safe buildings.
The consequences of a terrorist attack on the nation’s water supply to public health, national security, and the nation’s economic services could be significant. Terrorist incidents of the recent past have heightened concerns regarding the vulnerabilities of public water systems to deliberate attack. The Environmental Protection Agency (EPA) bears lead responsibilities for protecting water systems from terrorist threats, and the agency is working in partnership with federal, state, and local government agencies, water and wastewater utilities, and professional associations to ensure safe water supplies.
To support its water security responsibilities, the EPA developed the Water Security Research and Technical Support Action Plan (Action Plan), released in 2003, which identifies critical security issues for drinking water and wastewater, outlines research and technical support needs within these issues, and presents a prioritized list of research and technical support projects to address these needs. The Action Plan is being used by EPA to establish funding priorities for water security research and technical support efforts over a three-year period.
The National Research Council’s Panel on Water System Security Research conducted a review of the Action Plan from May through September of 2003. The report resulting from our studies provides an assessment according to the following questions: (1) has the Action Plan completely and accurately identified important issues and needs for water security; and if not, what issues and needs should be added; (2) are the needs appropriately sequenced; (3) are the projects recommended for funding in the Action Plan appropriate to meet our water security needs, are they correctly prioritized and sequenced, and is their timing realistic; and (4) overall, what changes of content or structure in the Action Plan are recommended to improve the presentation to convey more clearly the water security research and technical support program that is described? It should be noted that the panel was reviewing a work in progress and also that we functioned on a very fast timetable. The panel focused its review on an April 2003 draft of the Action Plan, although the program was continuously maturing during the review period, and many developments have undoubtedly occurred since the review was completed.
At your Committee’s request, my comments focus on:
· Key findings and recommendations of the National Academies’ report, A Review of the EPA Water Security Research and Technical Support Plan (Parts 1 & 2); and
· Collaboration among EPA, the Department of Homeland Security (DHS), and other interests, to ensure that EPA is properly focusing its research agenda; and what steps EPA and DHS should take to improve this collaboration?
Key Findings and Recommendations
Given the urgency and limited time within which EPA has been working on water security, our panel commended EPA for the speed and diligence of its efforts. Nevertheless, given time and resource constraints on the water security program, the panel recognized that EPA needed to prioritize its efforts to meet urgent needs, while simultaneously preserving a longer-term research and technical support strategy for water security and remaining mindful of the agency’s other essential tasks that contribute to public health and security. In order to assist the EPA in prioritizing its water security efforts, the panel recommended that the EPA focus on building a practical program of water security research and technical support, emphasizing a continuing improvement in response and recovery capacity, while identifying cost-effective countermeasures based on an understanding of the nature and likelihood of potential threats.
The Action Plan contains an extensive list of drinking water and wastewater research and technical support needs and associated projects that cover many critical water security issues. However, the projects will not, in themselves, result in improved protection of the nation’s drinking water and wastewater systems. Improved protection will result only when the information and knowledge gained from the projects are integrated into funded water security plans that are implemented by collaborations among private and public organizations.
The figure below suggests a framework for how individual research and technical support projects contained in the Action Plan could contribute to improved water security. Specifically, the Action Plan encompasses data collection and assessments; database creation; new scientific research, tools and methods development; and communication strategies. In order to assist utilities and regional agencies in utilizing this information, our panel suggested that a comprehensive guidance document be developed that would direct a utility through available prevention strategies, information resources, communication planning, and response and recovery actions.
Example framework for depicting the contributions of the Water Security Research and Technical Support Action Plan to the broader needs for protecting the nation’s water systems (including drinking water and wastewater).
The Action Plan recognizes that information is essential to effective response and recovery programs, but there should be emphasis on making this information immediately useful. If an event were to happen tomorrow, water systems, local and state health departments, and emergency response agencies would have to respond on the basis of whatever information was available. The ability to respond and recover will be a process of successive approximations that will improve as information and methods improve. The Action Plan should be implemented with this iterative process in mind.
The panel was concerned by the management responsibilities arising from the Action Plan. Project managers will need to be continually aware of related activities inside and outside EPA to minimize duplication of effort and to allow updating of protocols as new data are generated. If projects suffer from frequent change of leadership, coordination will be impaired, harming essential integrating functions. The panel suggested that EPA implement a management plan that includes adequate resources and stable leadership to coordinate the many projects. This plan should include a schedule for reviewing the progress of the overall water security effort and for periodically reassessing priorities.
The Action Plan is silent on the financial resources required to complete the proposed research and technical support projects and to implement the countermeasures needed to improve water security. The panel concluded that the EPA should attempt to quantify benefits and costs resulting from the proposed research and technical support projects, and further study should be directed to better acknowledging business-enabling, dual-use benefits of security enhancements. More emphasis is needed on communicating the value of water and increased water system security with the public, rate regulators, and local elected and appointed officials, because increased revenues through user-rate increases or reallocations of resources will be needed to create the necessary financial resources to implement such countermeasures.
The panel recognized the need to act quickly to address issues of water security. The EPA strategy in the Action Plan to emphasize immediate usability and first approximations is a sound one, but certain research or technological advances may be accomplished only through long-term research investments. The panel recommended that the Action Plan clarify which of its research activities are short-term, applied efforts and highlight long-term research needs, so that a collaboration of agencies could work to ensure that substantive, mission-oriented research questions in water security are not overlooked.
Collaboration Among EPA, DHS, and Other Interests
The Action Plan concentrates, understandably, on matters that the EPA has traditionally handled and for which it has expertise. While there have been problems of both overlap and gaps in the activities of the EPA and other federal agencies under ordinary circumstances, the lack of urgency in most cases has allowed these issues to be addressed over time. In the midst of an emergency, however, time may not allow for the discovery that a critical activity, which was thought to be under the control of another agency, had been overlooked due to poor coordination. Although the Action Plan recognizes the importance of coordination among relevant agencies, there are assumptions made throughout the Action Plan about the activities and capabilities of other agencies that may not be correct or may be over stated.
The rapidity and high stakes of potential terrorist attacks on water supplies suggest that the EPA should pay particular attention to improving interagency coordination and to determining the roles, capabilities, and training of other agencies with regard to water security. The special circumstances of a purposeful attack will require that the roles and responsibilities of various relevant parties (including law enforcement, FBI, and environmental and public health authorities) be worked out in detail ahead of time. The use of field and table-top simulation exercises is necessary to help utilities and federal, state and local agencies develop improved coordination and response and recovery strategies. All personnel who would respond to a water system attack should be involved, including water and wastewater utilities, police, public health workers, and emergency medical personnel.
The events contemplated by the Action Plan take place in the context of a potential crime. Roles and responsibilities of cognizant parties, including law enforcement, must be established ahead of time. The anthrax episodes of 2001 brought this into sharp relief. Legal issues related to criminal investigations, such as chain of custody, preservation of evidence, and control of information need to be considered in advance; the need for information dissemination to the public, to environmental response teams, and to health authorities will create opposing demands at critical times.
Developing an effective communication strategy that meets the needs of the broad range of stakeholders, including response organizations, water organizations and utilities, public health agencies, and the media, while addressing security concerns, should be among the highest priorities for the EPA. Criteria for classifying and distributing sensitive information should be developed that recognize the need for all water utilities, local and state agencies, researchers and consultants to have access to water security information. Consideration needs to be taken of how the water security information databases will be accessed, who will be granted access, who will control and update databases, and how new databases will be integrated with current systems. The EPA should thoroughly examine the consequences of various levels of information security and fund formal studies on the risks and benefits of widely transmitting water security data (including involvement of a wider research community). The dangers of keeping information too closely guarded may, in fact, be greater than those of informing an ill-intentioned person.
Action Plan Projects and Implementation
The drinking water research needs and projects identified in the Action Plan are lengthy and detailed, and, if pursued, would provide significant information, tools, and methods to help water managers respond to threats or attacks. Less information is presented in the Action Plan regarding threats to the nation’s wastewater infrastructure, making it difficult to assess the adequacy of the proposed research. In its review of the Action Plan, the panel proposed revisions to the 35 water security needs and suggested two additional needs. The panel also evaluated the focus, priority, and timing of 123 projects, and suggested 18 new projects.
The Action Plan discusses how to conduct the research through collaborations with other organizations but at the time of the review did not include plans for funding this research or integrating the results into effective preparedness and response plans for the nation’s utilities. The panel concluded that an implementation plan was needed that would clearly articulate the roles and responsibilities of other organizations and federal agencies in respect to implementation of this research and technical support plan. Not all water security research and technical support guidance will be the responsibility of the EPA, but in order to develop effective collaborations, clear allocations of responsibilities are needed. In order to facilitate fast and effective implementation of this research plan, the panel recommended that the Action Plan include a thorough and up-to-date assessment of water security research activities that are underway in other agencies or organizations (e.g., the Department of Defense and universities) as well as a summary of related ongoing EPA efforts, beyond those outlined in the Action Plan.
Plans should also be included for communicating research findings and distributing the tools resulting from the Action Plan projects to stakeholders in a timely manner. For example, risk communication is a critical component in an overall crisis management strategy. The EPA needs to consider how to incorporate the current state of the knowledge in risk communication into its guidance to water utilities and organizations.
Again, thank you for the opportunity to discuss the safety of our nation’s water systems. Drinking water is critical to public health and the nation’s security and economy. The EPA activities that were the subject of our studies are critical to the nation’s safety and should continue, considering the recommendations of our panel. I will be happy to answer questions you may have.
REVIEW OF EPA HOMELAND SECURITY EFFORTS:
SAFE BUILDINGS PROGRAM RESEARCH IMPLEMENTATION PLAN
Charles E. Kolb Jr., Ph.D.
Aerodyne Research Inc.
Member, Committee on Safe Buildings Program
Board on Chemical Sciences and Technology
Division on Earth and Life Studies
National Research Council
The National Academies
Environment, Technology and Standards Subcommittee
U.S. House of Representatives
May 19, 2004
Good morning Mr. Chairman and members of the Committee. My name is Charles Kolb. I am President of Aerodyne Research, Inc. in Billerica, Massachusetts, and served as a member of the Committee on Safe Buildings of the National Research Council. The Research Council is the operating arm of the National Academy of Sciences, National Academy of Engineering, and the Institute of Medicine of the National Academies, chartered by Congress in 1863 to advise the government on matters of science and technology. I am here today to discuss the findings of a Research Council Review of the Environmental Protection Agency (EPA) Safe Buildings Program Research Implementation Plan. This review was requested and sponsored by EPA. It was carried out by a committee of twelve experts who gave their time pro bono for the review. The committee members had expertise in areas including toxicology, chemistry, mechanical engineering, building technology, indoor air quality, microbiology, toxic chemical and biological agent detection, and aerosol distribution microphysics and dynamics. The committee began its work in March of 2003 and delivered its report to EPA in October 2003. My comments are based on the results of that report.
The committee was asked to review the EPA’s Research Implementation Plan for its Safe Buildings Program. The plan presented to the committee attempted to address the three issues of (1) protecting building occupants during a terrorist attack that contaminates the indoor air with chemical or biological agents, (2) safe, efficient, and cost-effective decontamination of buildings that have been contaminated with chemical or biological agents, including disposal of contaminated materials, and (3) conveying information about decontamination to relevant stakeholders. The committee was asked to review the research plan and comment on whether it accurately identified the research issues, and appropriately prioritized and sequenced projects to address those research needs.
The committee was confronted very quickly with the reality that given the budget and 3-year time frame proposed for this program, the EPA had proposed a rather ambitious program. In the committee’s judgment, the research plan as it was presented to them at the time was unlikely to achieve all of its goals, and the committee therefore determined to focus its recommendations on those that could help EPA prioritize within the four major program areas it had identified. Those four program areas—detection, containment, decontamination, and disposal—did encompass the major areas of research required to protect and decontaminate structures. However, the committee concluded that given the limits on time and resources, and given EPA’s core skills, the areas of detection and containment should be scaled back and made subordinate to the areas of decontamination and disposal. I will elaborate by discussing each of the four areas in turn.
Decontamination is an area in which EPA has considerable expertise from its experience with Superfund sites, brownfield projects, and with other programs to mitigate contamination by toxic industrial and agricultural chemicals. The committee saw EPA’s primary role in safe buildings as that of providing the ability to completely restore domestic facilities rapidly and safely after an attack. In the short timeframe of the current program, the committee thought that EPA should focus on developing standardized test protocols for determining the effectiveness and performance of decontamination technologies and on applying those protocols to evaluate available and developing decontamination systems. Although the Department of Defense has test protocols in place for its decontamination procedures, these are not appropriate for use in civilian facilities where long-term occupancy with no adverse chronic health effects is the goal. The committee recommended that EPA use its existing Environmental Technology Verification (ETV) program to test and evaluate the performance of proposed decontamination systems.
For disposal of materials post-decontamination, such as clean-up materials, contaminated solvents, and building materials that could not be fully decontaminated, the EPA program focuses on thermal incineration and landfills. However, thermal treatments may not be viable approaches in some states where air quality regulations or local stakeholder concerns prevent incineration of waste. EPA needs to analyze the layers of federal, state, and local regulations to understand where and in what circumstances incineration might be considered. The committee thought EPA should concentrate its current efforts in solid waste disposal on developing criteria that if met would permit the large volume of post-decontamination waste likely to be generated to be disposed of in municipal landfills. The key question is whether the material can be decontaminated or stabilized sufficiently to meet the criteria for acceptance as municipal waste rather than being treated as toxic waste. The EPA also needs to determine whether current hazardous waste disposal methods are adequate for handling any liquid wastes generated in the decontamination process.
The area of detection is of course crucial to confirming the extent of contamination, and confirming the success of decontamination. Logically, detection spans two distinct regimes: 1) continuous, real-time, automated instrumentation designed to sound alarms and/or trigger containment systems when a building is attacked, and 2) post attack agent detection systems designed to assess the degree of contamination and the success of clean-up efforts. The committee identified many other agencies and private firms that are involved in sophisticated detector and detection system development aimed at the first regime and felt that the small investment EPA could make in this area and its limited expertise with continuous, real-time detection instrumentation was not likely to have significant impact. In the limited timeframe and resources accorded to the current program, EPA has little possibility of making a significant contribution in “detect-to-warn” systems. The committee thought that EPA efforts in detection under the current program should be fully directed towards detection technology and standards useful for decontamination and disposal activities—that is, to post-event activity. EPA is highly suited to develop the standards for detection technology needed in decontamination and disposal efforts, to lead the development of test protocols and test-beds for these detectors, and to sponsor realistic testing for that decontamination/disposal detection equipment.
Finally, the plan presented to the committee included projects aimed at containing agents introduced into a building in order to mitigate the harmful effects to building occupants. However, the vast number of chemical and biological agents, each with its own toxicity signature, and the essentially unbounded number of building types, creates a challenge to providing meaningful advice regarding containment during attack. Development of practical containment strategies that are broadly applicable to buildings or to classes of buildings requires a major research endeavor that is beyond the scope of the current program. However, there are real needs associated with containment of identified agents during post-event decontamination and disposal that should be addressed by the EPA’s program.
In its report the committee stressed time and again the need to focus the current program on goals that were realizable within its short three-year timeframe. However, the committee also recognized considerable longer-term research needs in all four of these program areas. In addition to carrying out a program of prioritized short-term research, the committee recommended that EPA include in its current effort a planning function for longer-term research. Longer-term research needed includes research:
· To better characterize the extent of an attack, including better standards for cleanup levels, better sampling methodology, and better understanding of the transport, robustness, and viability of chemical and biological agents across the full range of public structures,
· To develop methods for decontamination of sensitive equipment and priceless objects, and hard-to-reach places such as the interior of ductwork and the area above ceiling tiles,
· To evaluate the toxicology of decontaminating agents, and any toxic by-products that might be formed during the decontamination process, and
· To better understand and improve the tools for modeling building airflows, contaminant dispersal patterns, and other information needed to develop practical real-time containment strategies.
In summary, the committee found that EPA had correctly identified the research areas that need to be addressed to enable better building protection, decontamination and recommissioning post-event. But the research implementation plan presented to the committee in 2003 was overly ambitious given the timeline and resources available to the program. The committee recommended that the EPA scale back its efforts within the program to those elements that could produce meaningful results within that timeframe, enhance collaboration and coordination with other federal efforts to maximize the results of the program, and produce a longer-term research plan that might be implemented if funding were made available.
Thank you for the opportunity to present these findings to you today.