In January 2024, CyberArmyofRussia compromised water utility HMIs in Muleshoe, Hale Center, Abernathy, and Lockney — Panhandle Texas towns with no cybersecurity program and PLCs exposed to the internet. A tank overflowed in Muleshoe before operators manually intervened. AWIA Section 2013 requires a Risk & Resilience Assessment and Emergency Response Plan. Most Texas water systems are not in compliance.
Water utilities have become a priority target for state-sponsored actors, ransomware groups, and ideologically-motivated hackers alike. Exposed OT equipment, remote access with no MFA, and legacy PLCs accessible via public internet are the common thread. These aren't hypothetical scenarios — they're documented incidents.
Texas water utilities operate under a layered regulatory environment — federal AWIA and EPA obligations, CISA sector goals, TCEQ state oversight, and voluntary NIST/CISA frameworks that are increasingly referenced in enforcement actions. Here's every requirement in scope and how CoreRecon covers it.
| Framework | Who's in Scope | Key Requirements | Penalty / Consequence | CoreRecon Coverage |
|---|---|---|---|---|
| AWIA Section 2013 | Community water systems serving >3,300 people; wastewater systems serving >3,300 for ERPs | Risk & Resilience Assessment (RRA) every 5 years — cybersecurity of SCADA, monitoring systems, and chemical handling is mandatory scope; Emergency Response Plan (ERP) within 6 months of RRA; certify to EPA | EPA enforcement action; TCEQ compliance referral; reputational exposure in public certification record | Fortress AWIA RRA cyber component documentation, control system asset inventory, SCADA vulnerability mapping, ERP cybersecurity annex — Compliance Pack add-on included at Fortress tier |
| EPA Section 1433 / SDWA | All public water systems; enforceable under Safe Drinking Water Act | Vulnerability Assessments for systems >100,000 service connections; cybersecurity now embedded in EPA enforcement posture following 2023 failed rulemaking; EPA March 2023 memo directing SDWA survey to include cybersecurity | Civil penalties up to $25,000/day; compliance orders; operator license jeopardy on TCEQ side | Sentinel Vulnerability assessment support, 24/7 SOC monitoring, incident documentation for EPA/TCEQ reporting obligations |
| CISA Water Sector Goals | All water and wastewater systems; non-binding but referenced in TCEQ audits and EPA guidance | CISA Cross-Sector Cybersecurity Performance Goals (CPGs): asset inventory, MFA on remote access, network segmentation, patch cadence, incident reporting to WaterISAC and CISA | Non-binding but creates expected standard of care; cited in post-incident enforcement; grants contingent on adoption | Fortress Full CPG implementation mapping, MFA enforcement on remote access, OT network segmentation, WaterISAC threat feed integration |
| TCEQ Requirements | All Texas public water systems; TCEQ has oversight authority for water quality and operator compliance | TCEQ inspections now include IT/OT security posture; operator license requirements include safeguarding instrumentation and monitoring systems; public notification obligations when monitoring systems are compromised | Operator license suspension; compliance orders; public notification mandates; fines for delayed notifications | Sentinel TCEQ inspection documentation, incident timeline preservation, public notification support, operator compliance evidence package |
| NIST CSF 2.0 | Voluntary but referenced by AWIA, EPA, and CISA as the expected implementation framework for water utilities | Identify (asset inventory, risk assessment), Protect (access controls, OT segmentation), Detect (continuous monitoring), Respond (incident response plan), Recover (business continuity for water service) | Non-binding; failure to implement creates evidentiary gap in post-incident litigation and regulatory enforcement | Fortress NIST CSF maturity assessment, control gap remediation, ongoing monitoring mapped to Detect function, IR plan documentation |
| CISA Shields Up | All critical infrastructure operators including water; heightened since Russia-Ukraine conflict and 2024 TX incidents | Reduce attack surface (patch exposed systems), increase logging, prepare IR plans, report incidents to CISA, implement emergency remote access controls; WaterISAC membership for threat intel sharing | Non-binding; failure to act on known advisories creates FCA-style liability if federal funds received | Command External attack surface reduction, CISA advisory implementation tracking, 30-min SLA on OT incidents, WaterISAC integration, threat intel sharing |
Water utilities built SCADA systems before cybersecurity was a consideration. Unitronics Vision, Allen-Bradley ControlLogix, Modicon M340 — these PLCs control chlorination, pressure regulation, and tank levels. Many are reachable from Shodan. Here's how CoreRecon closes each exposure without disrupting treatment operations.
Texas has more than 7,000 public water systems — the most of any state. Over 80% serve communities under 10,000 population with no dedicated IT staff, no cybersecurity budget, and no visibility into their own control systems. TCEQ oversight is increasing. AWIA compliance gaps are widespread.
The January 2024 Texas water utility attacks were the first documented state-linked OT compromise of U.S. water infrastructure. Here's the incident timeline and the detection points that a monitored environment would have identified — and the broader context from similar incidents.
CoreRecon's water utility tiers cover your IT staff endpoints, OT/SCADA network monitoring, and AWIA compliance documentation. Compliance Pack add-on for AWIA evidence collection and RRA support. No minimums. No 3-year contracts. Sized for rural districts and large municipal systems alike.
| Tier | Price / Endpoint / Month | What's Included | Best For |
|---|---|---|---|
| Sentinel | $89 | 24/7 SOC monitoring, endpoint detection & response on IT/staff systems, external attack surface scan (identifies exposed SCADA/VNC/RDP), MFA enforcement on remote access, TCEQ incident documentation support, attack surface hardening for internet-exposed OT devices, monthly executive report, IR letter for cyber insurance | Small rural water districts and SUDs (<10 staff endpoints); no dedicated IT; AWIA systems >3,300; first layer of OT exposure remediation; TCEQ audit preparation |
| Fortress | $109 | All Sentinel + OT/SCADA passive network monitoring (NTA sensors at IT/OT boundary), AWIA RRA cybersecurity component documentation (Compliance Pack included), Emergency Response Plan cyber annex, NIST CSF 2.0 mapping, CISA CPG implementation, WaterISAC threat feed integration, anomalous setpoint command detection, SIEM, 30-min SLA on OT incidents, vendor access monitoring | Mid-size utilities (10–100 staff endpoints); full AWIA RRA + ERP compliance; active OT/SCADA monitoring; municipal utilities with regulatory obligations; systems post-incident requiring remediation documentation |
| Command | $129 | All Fortress + continuous OT threat hunting, advanced Modbus/DNP3/EtherNet/IP protocol anomaly detection, CISA Shields Up full implementation, annual OT penetration test, red team tabletop (chemical poisoning scenario), supply chain threat intel for water sector, IRGC/Sandworm hunt packages, EPA enforcement-ready evidence package | Large municipal utilities (100+ endpoints); regional water authorities; systems serving >50,000 connections; post-incident EPA/TCEQ audit environments; utilities seeking comprehensive AWIA certification posture |
CoreRecon's water utility assessment maps your IT and OT attack surface, identifies every internet-exposed SCADA and HMI device, documents your AWIA RRA compliance gaps, and delivers a prioritized remediation plan. The external scan alone typically finds 3–8 exposures operators weren't aware of. No credit card. No commitment.
Request your free assessment →Delivered within 14 days • External OT scan included • AWIA gap review included