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Are you ready for March 31, 2020?…This is the deadline for the community water systems serving 100,000 or more persons to complete their risk and resilience assessment.

Are you ready for March 31, 2020?

 

March 31, 2020 is fast approaching.  This is the deadline for the community water systems serving 100,000 or more persons to complete their risk and resilience assessment.  I have tried to send this email to just those systems and anyone who works with water systems on these projects.  My apologies if you were included in error, but you may have a future compliance date on the horizon.

 

Will you be ready to certify completion of your risk assessment by March 31, 2020?  If you haven’t already done so, here is the portal to register and submit the certification:  https://www.epa.gov/waterresilience/how-certify-your-risk-and-resilience-assessment-or-emergency-response-plan

 

Be sure to have your 9 digit PWS-ID number, which must begin with the two-letter state abbreviation (DE, MD, PA, VA, WV, DC) followed by 7 digits (e.g. PA1234567).

 

EPA prefers that you use this portal as it eliminates the need for any paper submissions. (There are instructions on this same web page for email or paper submissions).  You will use this same portal to provide your ERP certification 6 months after providing your risk assessment certification, but in no case later than September 30, 2020.

 

Speaking of ERPs, I worked with PADEP to determine how our requirements differ.

Pennsylvania’s community water systems (CWS) should be aware that the AWIA requirements are broader than the current PADEP requirements.  Below is a list of areas not included within the PADEP ERP template, but are required by AWIA:

  • ERP distribution list and history of updates (highly recommended features)
  • Detection Strategies (such as intrusion alarms, cyber threats, online water quality monitoring surveillance tools)
  • Core Procedures which EPA describes as the “building blocks” for incident specific response procedures, since these apply across a broad variety of incidents:
    • Family well-being planning for responders and water employees
    • Access related challenges (e.g. road closures) and options to work around
    • Sampling and analysis plans
    • Incident Command System positions and roles, internally and with response partners
    • Physical security* (e.g. actions to be taken to secure a facility once an incident has occurred)
    • Cyber security* (e.g. actions to be taken for added protection during an incident)

 

* While actions should be taken to harden facilities prior to any incident, additional actions may be necessary during an incident to further protect physical assets and connectivity.  For physical security, this may include such things as added access control or lockdown procedures, and raising the level of attention to security during an incident.  These are in addition to the day-to-day procedures.

As community water suppliers work to comply with AWIA’s ERP requirements, please pay attention to these areas and ensure these are adequately covered in your plans.  Nothing prohibits you from having plans that contain more information.  Again, both EPA’s and PADEP’s requirements should be viewed as minimum aspects of ERPs.  Your plans should be comprehensive to meet your specific needs and should be exercised on a regular basis and updated based on lessons learned from these exercises.

 

Having any issues with finishing this work on time?  If so, we really should talk, so give me a call.

 

Patti Kay Wisniewski

Drinking Water Preparedness and Resiliency Coordinator

US EPA Region 3

Drinking Water Section (3WD21)

Water Division

1650 Arch Street

Phila, PA  19103

 

215-814-5668

Cell: 215-514-7893

Email: Wisniewski.patti-kay@epa.gov

(note the hyphen appears in email only)

 

 

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