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Preparing an AWIA-Compliant Emergency Response Plan by Charlene Kormondy, US EPA

Preparing an AWIA-Compliant Emergency Response Plan

By now, your water system is likely familiar with America’s Water Infrastructure Act (AWIA) Section 2013, which requires Community Water Systems (CWSs) serving more than 3,300 people to develop or update a Risk and Resilience Assessment (RRA) and Emergency Response Plan (ERP) and certify completion of each to the United States Environmental Protection Agency (EPA). The graphic below shows the RRA and ERP deadlines, based on system population size, for the current AWIA certification cycle. All RRA deadlines have now passed. If your system, has not certified the RRA, please complete this requirement immediately.  If you are a small-sized CWS (serve 3,301 – 49,999 people) that recently completed your RRA, the next step is to develop or update an ERP that incorporates findings of your RRA and certify completion of the ERP to EPA by December 31, 2021.

What is an ERP?

An ERP describes strategies, resources, plans, and procedures utilities can use to prepare for and respond to an incident, natural or man-made, that threatens life, property, or the environment. Incidents can range from small main breaks or localized flooding to large-scale hurricanes, earthquakes, or system contamination, among other examples. According to AWIA, ERPs must include these four components:

  1. Resilience Strategies – Strategies and resources to improve resilience, including physical security and cybersecurity
  2. Emergency Plans and Procedures – Plans and procedures for responding to a natural hazard or malevolent act that threatens safe drinking water
  3. Mitigation Actions – Actions and equipment to lessen the impact of a malevolent act or natural hazard, including alternative water sources, relocating intakes and flood protection barriers
  4. Detection Strategies – Strategies to detect malevolent acts or natural hazards that threaten the system

 

In addition, CWSs shall to the extent possible coordinate with local emergency planning committees (established under the Emergency Planning and Community Right-To-Know Act of 1986) when preparing or revising an ERP under AWIA.

 

ERP Guidance and Template

EPA has created an easy-to use ERP Template and Instructions to assist water utilities with developing an ERP in accordance with AWIA. The ERP Template and Guidance is available to download here epa.gov/waterutilityresponse/develop-or-update-drinking-water-utility-emergency-response-plan.The ERP Template and Instructions is a PDF document that features an embedded blank ERP template in Word format that can be easily accessed and modified by utility personnel to meet their own water system needs. To access the embedded Word document, download the ERP template and open in a PDF reader.  If you experience technical issues opening the template, ensure you are using a PDF reader and your settings are adjusted to allow embedded documents to open.

 

EPA does not require CWSs to use any designated standards, methods, or tools to conduct RRAs or ERPs. However, the ERP Template and Guidance is a tool provided as optional support during the process. If your CWS already has an ERP, you may use your existing ERP document as a starting point. Please review the document to make sure that the ERP covers all the criteria specified in AWIA and is up to date when it is certified to EPA.

 

EPA has hosted a series of free, virtual trainings on how to develop an AWIA ERP. For recordings of these trainings or information on upcoming ERP trainings, please visit epa.gov/waterresilience/awia-section-2013#TNG

 

Certification Process

After the ERP has been completed, it needs to be certified to EPA. For information on how to certify, including a video and a PDF tutorial of how to use the electronic certification system, visit epa.gov/waterresilience/how-certify-your-risk-and-resilience-assessment-or-emergency-response-plan. If you already created an account to electronically certify your RRA and are logging back in to certify your ERP, here is how to navigate the electronic system to certify your ERP:

  1. Log in to epa.gov with your User ID and Password.
  2. From the home screen, click “Services”.
  3. Locate the water system and click the drop-down arrow.
  4. Click “Add New Role To Existing Organization”.
  5. Under “Choose a Role,” click “Certifying Official – Emergency Response Plan”.
  6. Click “Continue”.
  7. Enter the PWSID and click “Continue”.
  8. You will be returned to the home page. Locate the water system and click “Certify your Emergency Response Plan”. You will be taken to the Emergency Response Plan certificate to complete your submission.

 

5-Year Certification Cycle

After the initial AWIA certification deadlines, each CWS serving more than 3,300 people must review its RRA and ERP at least once every five years to determine if it should be revised. Upon completion of such a review, the CWS must certify to EPA that it has reviewed its RRA and ERP and revised them, if applicable. Future AWIA certification cycle deadlines will occur 5 years from the original deadlines written in the law. For example, for the next 5-year AWIA certification cycle, small-sized CWSs must recertify their RRA by June 30, 2026 and ERP by December 31, 2026. Note that while ERP certification to EPA is only required every 5 years, utilities are encouraged to continuously update their ERPs for new information, such as new emergency contacts or after significant incidents to build in any lessons learned during response.

 

For more information on the AWIA Section 2013 requirements, visit epa.gov/waterresilience/awia-section-2013. Questions about the requirements can be sent to dwresilience@epa.gov.

Author: Charlene Kormondy

Agency: U.S. Environmental Protection Agency, Office of Water, Water Security Division

Address: 1200 Pennsylvania Ave, NW, Washington, D.C. 20460

Phone: (202) 564-3807

E-mail: kormondy.charlene@epa.gov

 

 

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