The ongoing response to the COVID-19 pandemic and its effect on utility personnel and operations is a striking reminder for utility’s emergency response planning preparedness. Through the 2018 American Water Infrastructure Act (AWIA), federal law requires water and wastewater utilities to evaluate their potential risk for service interruption. The AWIA response is time sensitive, with a federal mandate for each utility’s Risk and Resilience Assessment (RRA) filings with the Environmental Protection Agency (EPA) due in 2020 and 2021.
Utility’s risk assessment, response planning, and management implementation of emergency situations has been a requirement for some time, stemming back to the Bioterrorism Act of 2002. While the Bioterrorism Act largely centered around addressing a facility’s vulnerability to terrorist attacks, the broader AWIA requires public utilities to comprehensively plan for hazards, including natural risks like earthquakes, wildfires, flooding and tornadoes, as well as cyberattacks. These incidents can have a detrimental effect on the quality and reliability to utility customer service. An effective and well-formulated emergency response plan (ERP), will protect the utility and its most important asset - its customers. If your organization previously conducted a vulnerability assessment and ERP under the Bioterrorism Act, it’s a good starting place for assembling the more comprehensive RRA required by AWIA.
The AWIA requires that public water/wastewater systems serving populations over 3,300 people conduct the following activities, starting with the RRA. Failure to comply could result in financial and civil penalties.
- Prepare an RRA
- Prepare or update an ERP
- Prepare a certification letter for each and submit to the EPA
- Review and update the RRA and the ERP every five (5) years
- Maintain records for the RRA and the ERP
AWIA Compliance Schedule
The timeframe for completing the necessary RRA, ERP, and follow-up actions depends on the size of your system. Different from the Bioterrorism Act’s vulnerability assessment, your utility does not need to file a report. You do need to file certification confirming you have undergone the assessment, and then file additional certification that you prepared an ERP within a six-month timeframe of completing the assessment.
Risk and Resilience Assessment Checklist
As a utility, you can get started by evaluating what your potential risks are depending on relevant geographic, economic, social, and operational conditions. As you identify risks, rank them by probability of occurrence and scale of impact on the utility. Be sure to consider the following:
- Risk to the system from hazards
- Resilience of system components
- Utility’s monitoring practice
- Financial strength of the utility
- Use, storage, and handling of treatment chemicals
- System operation and maintenance
- Evaluation of capital and operational needs for risk and resilience management
- Management and operations personnel
- System and customer record’s management
- Utility system components
- Pipes and appurtenances
- Pumping and storage infrastructure
- Source water/receiving water
- Distribution system
- Chemical handling, storage, and usage
- Remote and internal electrical and instrumentation controls (EIC), and system control and data acquisition (SCADA)
- Records and billing
- Management and personnel
Preparing Your Emergency Response Plan
Once you have conducted a thorough evaluation of risks to your system, prepare your ERP for handling each risk, focusing on how you can minimize the impact to your customers. Specifically, how will you continue to provide safe water, reduce outages, and maintain system control? For a specific risk, it is important to address what effect(s) it may have on the utility. Then, how would the utility respond? Is the utility self-sufficient, for instance, for back-up electrical power? Does the utility own its own generators, or require moving them onsite for implementation? What about emergency equipment start-up, road access, fuel delivery, and maintenance?
Preparing an ERP for the presented risk will allow you to identify where you may need equipment, cross-trained personnel, communications, remote monitoring equipment (i.e., SCADA), or other alternatives. With this information, management can prepare the necessary financial resources and capital planning to address the equipment and manpower needs. Action items identified in the ERP don’t need to happen all at once. However, identification of these items will allow you to develop a “road map” to implement over time, prepare resources accordingly, and identify plan limitations.
Need help with utility system planning and compliance? Contact us for assistance with your AWIA challenges.
Patrick Lackey, P.E.
Senior Water/Wastewater Engineer
Tammy Reed, P.E.