Emergency Operations and ERPs

Community water systems serving populations greater than 3,300 are required to have a plan in place for emergencies in accordance with America’s Water Infrastructure Act of 2018 (AWIA) section 2013(b), which amended Safe Drinking Water Act (SDWA) section 1433(b). According to U.S. EPA, Emergency Response Plans (ERPs) describe "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." ERPs must outline the steps a system should take to ensure the continuation of service during an emergency. The Arizona Department of Environmental Quality has provided an O&M Manual Template that can be used as a starting point in developing a manual from scratch or making improvements to existing emergency O&M procedures. 

They also provided the following list of emergency situations and provisions that community water systems need to address in their ERPs: 

• Loss of source
• Loss of water supply due to major component failure
• Damage to power supply equipment or loss of power
• Contamination of water in the distribution system from backflow
• Collapse of a reservoir, reservoir roof or pumphouse structure
• A break in a transmission or distribution line
• Chemical or microbiological contamination of the water supply

Within these sections of your utility's manual, include provisions for providing alternate water, notice procedures for regulatory agencies and users, disinfection and testing techniques, critical component identification, spare parts inventory and staff training in emergency response procedures.

AWIA Section 2013 Compliance Check

Small community drinking water systems (CWSs) that serve between 3,301 and 49,999 must submit Risk and Resilience Assessment (RRA) certifications by June 30, 2021 and an Emergency Response Plan (ERP) by December 21, 2021 in order to stay in compliance with America’s Water Infrastructure Act (AWIA). Certification must be completed every five years and the ERP updated within six months of that recertification. You can confirm if your water system is impacted by the AWIA on the U.S. EPA website. 

In this era of unpredictability, it is increasingly important to adapt water systems to the ever changing and intensifying events that threats like climate change pose. Building a strong water resilience plan is the best way to prepare yourself and your community against these events. In order to stay ahead of the game, utilities should conduct an assessment to reduce risk, plan for and practice responding to emergencies, and monitor systems for contaminants. 

The AWIA does not require utilities to use any specific tools or methods when conducting these assessments. It does however require utilities to meet all requirements listed in Section 2013 and throughout the act. The U.S. EPA also has more information on how to certify your risk and resilience assessment and your emergency response plan. There is also more information on our website about how to complete your RRA and ERP, as well as information about the AWIA Small Systems Certificate Program.

AWWA & RCAP Release AWIA Small Systems E-Training

The America’s Water Infrastructure Act (AWIA) was signed into law in October 2018, requiring drinking water systems serving more than 3,300 people to develop or update risk and resilience assessments (RRA) and emergency response plans (ERP) within the deadlines determined by system size. With this Act, the U.S. Environmental Protection Agency (EPA) developed guidance documents to help systems comply with these new requirements. These resources include a qualitative RRA Checklist specifically designed for small systems as well as an ERP template. The purpose of these materials is to help systems achieve the minimum compliance under AWIA Section 2013.

To complement these small system resources, the American Water Works Association (AWWA) and Rural Community Assistance Partnership (RCAP) have partnered to build a free e-learning program with funding from the U.S. EPA. The on-demand training condenses ANSI/AWWA standards for security, risk management, and resilience as well as the AWWA’s Risk and Resilience Certification Program to help systems comply with AWIA. This new AWIA Small Systems Certificate Program contains four courses:

• Introduction to Resiliency and America’s Water Infrastructure Act of 2018 (EL272)
• Operational Measures for Resiliency (EL273)
• How to Develop a Risk and Resilience Assessment (EL274)
• How to Develop a Small System Emergency Response Plan (EL275)
• Bonus: Cybersecurity (Available late 2020)

Each course (See preview 1/2) features a series of video presentations with regular knowledge checks, a course evaluation, and a final assessment. The modules within the course (See preview 2 /2) are easy to follow and offer an excellent overview of AWIA knowledge requirements. At the end of the training, participants will receive a certificate of completion. CEU approval is available depending on your operator certification agency. See AWWA's credit policy.

The training also includes a separate AWWA/RCAP worksheet that can be used in the field to conduct an RRA. While housed under the AWWA’s resources for small systems, free registration is available to both members and non-members of the AWWA. To access the course participants are required to create or use a (free) AWWA account. We’ve highlighted the steps to create an account as well as how to access the courses. Any of the following screenshots can be enlarged by simply clicking on them to open the image in a new tab.

Creating a Free Account:

1. At the top right-hand corner of the AWWA website is a link that says Login. Click this link to create a free account.
2. Turn your attention toward the 'Create New Account' section of the new webpage. Read the Privacy Policy and select ‘I Agree – Create Account’.
   
   
   
   
   
3. Enter your email address in the next page.
   Note: During this step the AWWA will check to see if you’ve already created an existing account with this email. If your account already exists and you’ve forgotten your password, you can perform a password reset.
4. To continue creating a new account you will want to fill out each field to the best of your abilities. For the address type, you can select Home, Delivery, or Office/USmail.
   If you choose to use your utility address, keep the address type as office/USmail. Enter every field and select ‘Find Company’.
   1. If your utility is already in the database, select the utility name and then Continue.
   2. If your utility is not listed in the results, you will have to manually enter your address by selecting ‘None of the Above’ and Continue.
5. More fields will appear after entering the address. Entering a phone number is optional, but you will have to choose a secure password. Be sure it is something you will remember or keep it written in a safe place.
6. Check the agreement box to agree to the Consent Capture statement. This statement grants AWWA permission to collect and store your personal information to maintain your account. Your page should now look close to this:
   
   
   
   
   
7. Select Next.
8. Now your account is active! You can tell that you’re logged in because your name will appear at the very top, right-hand corner of any AWWA webpage.

Accessing the Courses:

1. Information about the AWIA Small Systems Certificate e-training can be found at the Small Systems webpage. To find this page using the AWWA navigation bar, hover over ‘Professional Development’ and select ‘Small Systems’. Lots of great small system training and resources can be found here!
   
   
   
   
   
2. From this page, scroll down to ‘Safe Drinking Water Act Compliance Training’ heading. Select the tab ‘AWIA Small Systems Certificate Program’. This tab includes the redemption code ‘SMSYS20’ that will be required in the following steps to provide account access to the courses.
   
   
   
   
   
3. Now make sure you’re logged into the AWWA site and select your name in the top, right-hand corner of the webpage. If your name does not appear in the top navigation then you are not logged in.
4. A page called ‘My Account’ should be loaded. Now select ‘My Courses’ in the left-hand menu. This will bring you to the AWWA eLearning platform. You might want to bookmark this link for easy course access in the future!
   
   
   
   
   
5. In this page under 'Small System Course Access', enter the code ‘SMSYS20’ and select Redeem.
6. Now all free courses available to small systems will be placed in your enrollments. A temporary menu will pop up where you can look through these courses.
   If you close this menu you will be returned to the eLearning home page. By scrolling down you can find the same small system enrollments. These enrollments include the individual courses that make up each small system certificate program. Since this list is not sorted by certificate program, you’ll want to search for each course by the names listed at the beginning of this blog. Start with EL272 and work toward EL275.
   
   
   
   
   

Returning to the Course:

1. Sign in to the AWWA site with your existing account by selecting ‘Login’ in the top, right-hand corner of any AWWA webpage. The username is your email.
2. Once logged in, select your name in the top, right-hand corner of the page where it used to say Login.
3. A webpage called ‘My Account’ should be loaded. Now select ‘My Courses’ in the left-hand menu. This will bring you to the AWWA eLearning platform. You might want to bookmark this link for quicker access next time.
4. Scroll down on the e-learning homepage to access your courses.

We recommend systems check out both the EPA tools as well as the new e-training to decide what worksheets and strategies are best for your utility. Remember that RCAP’s technical assistance providers are available throughout the country to help you achieve AWIA compliance, work through these courses, and even facilitate tabletop exercises for emergency preparedness. For a deeper understanding of AWIA compliance and these small system resources, operators can view the June 10, 2020 webinar recording: Small Systems Guidance for America’s Water Infrastructure Act of 2018.

Hurricanes, Flooding and Wastewater Plants: What Have We Learned?

In recent months, there have been dozens of reports of wastewater treatment plants that have flooded due to heavy hurricane rains and storm surges in Florida, Texas, Puerto Rico and beyond. Both the sheer number of plants affected, and the extent and duration of the flooding have posed significant public health and technical challenges, often stretching communities to their limits. 

To add to these problems, many rural utilities were already struggling to keep their systems operating before the storms struck, so costly, complicated repairs or replacements of damaged infrastructure is simply not an option. For example, Patton Village, Texas had just completed a new wastewater plant — the first of its kind in their community — before Hurricane Harvey struck. Now they can only hope that USDA/FEMA emergency funding will be available to help repair the damage. And even once the systems are up and running again, it is not a given that water systems can count on water rate income to help with their O&M bills - many residents have fled their flood-damaged homes for good.  

The sad truth is that lately, floods have been affecting wastewater plants with unfortunate regularity, and not just in hurricane-prone areas. For example, in Central Illinois, the small town of Hutsonville's wastewater treatment plant has flooded 3 times in the last 2 years, up from once every 5 years, according to its contract operator Shannon Woodward of Connor & Connor, Inc.

Woodward's first piece of advice is not to build on a floodplain, but he also acknowledges that many communities do not have the capital funds for effective protective measures or relocation, and so operators must deal with the hand they are given. His second piece of advice: "Make sure all electrical controls, switch gears and transformers are above the flood stage. That way, when the flood waters subside, you don't have equipment loss and can get back into operation — even if it takes 3 to 6 weeks for the waters to recede." 

Mason City, another small town in Illinois, was able to fund improvements after a flood in 2008 cut off the town’s water supply and nearly overflowed the capacity of its wastewater system. The following year, the city built a stone wall around the water plant, installed flood sensors on the local river, and built effluent pumping stations for the wastewater plant. 

And this article tells the damage and recovery stories of two flooded wastewater plants in Rhode Island. According to the operators of these plants, it is essential to have a flood plan, even if you think your facility is protected. In addition, they maintain it is important to involve wastewater treatment personnel in emergency response exercises or in the incident command structure. On a practical level, the operators encourage SCADA systems to be elevated on the second floor in the operations building if possible. And lastly, they recommend you back up your files and documents electronically. Papers get wet, they say: move them to a dry storage facility. 

Finally, while every community has different characteristics and needs, there are some universal preparedness strategies for wastewater plants. The US EPA recommends practicing mitigation options as the best way to prevent floodwater from invasively appearing. Some of these options include crafting barriers around key assets, having an emergency back-up generator, and keeping key electrical equipment elevated. You can learn more about these options here, or you can watch this helpful video. In addition, many states have their own guidances, such as this one from Minnesota’s Pollution Control Agency.