Practical Steps to Modify Your Risk and Resiliency Assessment and Emergency Response Plans
By Thomas LeCourt, PE
America’s Water Infrastructure Act (AWIA), passed in October 2018, requires water systems that serve populations of 3,300 or more to perform a risk and resiliency assessment of their systems and update their emergency response plans. When the legislation passed, it seemed unimaginable that 18 months later, we would be in the peak of the Coronavirus pandemic, yet here we are navigating the best ways to keep water systems running while following federal and state health and safety guidelines.
The AWIA differs from previous legislation aimed at water system security because it emphasizes an “all-hazards approach”. Following the terrorist bombings on September 11, 2001, the Bioterrorism Act of 2002 required all water systems to conduct a vulnerability assessment to protect against manmade acts of terrorism. But natural hazards like Hurricane Katrina in 2005, Hurricane Sandy in 2012, or the tornadoes that ripped through Massachusetts and Maine in June 2011 also exposed water system vulnerabilities. In addition to the physical facilities that a water system operates and maintains, there are also electronic systems that may control treatment, financial, or other critical operations that must be protected against cyber-attacks.
Compliance with the AWIA requires examination of all these potential hazards and the compliance dates are staggered based on population served (see attached fact sheet). Even though the systems that serve less than 50,000 people have until June 2021 to comply with the requirements, assessing a system’s risk and resiliency takes time and planning.
Water and wastewater utilities are considered essential services during this time of stay-at-home restrictions and social distancing. However, many water utilities are currently operating with reduced staffing or modified operations, forcing them to confront, and hopefully improve, their resiliency in emergency situations. One silver lining of working under emergency conditions is that it can often be the best way to measure the effectiveness of response plans and provide an opportunity to improve them.
Even while working under modified operations, water utilities can take simple measures to help prepare for submitting their risk and resiliency assessment and updating their emergency response plans:
- Document how your water operations have been modified. Have the modifications been effective? If not, what additional modifications were necessary to improve their effectiveness?
- Have you experienced any supply chain interruptions (difficulties getting chemicals, PPE, other materials)? Create an inventory of all critical materials and document your strategies for acquiring any hard-to-get items. Communicate with your vendors to ensure they can provide needed supplies and stock up on inventory as space, costs, and expiration dates allow. Consider sourcing materials and chemicals from two or more suppliers from different regions to mitigate supply chain disruptions.
- Consider joining your State’s Water/Wastewater Agency Response Network (WARN) if not already a member. Membership in WARN allows public water and wastewater systems to receive rapid mutual aid and assistance from other public systems to restore services damaged by natural or man-made incidents.
- As the pandemic continues, create a “lessons learned” document that can be incorporated into the development of your risk and resiliency assessment or help to improve your emergency response plan.
Water utilities and other water industry professionals are diligently working together to address the unfolding situation of COVID-19 and ensure that both water quality and service to communities remain uninterrupted while keeping employees safe. You can find more information on America’s Water Infrastructure Act.
Thomas LeCourt has served on a broad range of projects involving water supply, treatment, and distribution for both surface water and groundwater supplies. His expertise includes water system planning, distribution system modeling, water conservation planning, and rate evaluations, and financing. Tom is knowledgeable of requirements of many regulations including the Surface Water Treatment Rule, the Disinfectants/Disinfection By-Products Rule, the Lead and Copper Rule, and the Groundwater Rule. He is active in the New England Water Works Association and currently serves as a Massachusetts State Director on the NEWWA Board of Directors.