6.5 Emergency Response Planning & AWIA Risk and Resilience
Key Takeaways
- The America Water Infrastructure Act of 2018 requires community water systems serving more than 3,300 people to conduct a risk and resilience assessment and then certify an emergency response plan within six months of that assessment, recertifying both on a five-year cycle.
- The incident command system provides a standard structure of command, operations, planning, logistics, and finance and administration that lets a utility integrate with responding agencies.
- A risk and resilience assessment must consider malevolent acts and natural hazards affecting physical barriers, source water, pipes and constructed conveyances, treatment and storage, electronic and computer systems, monitoring practices, chemical use and storage, and operations and maintenance.
- Water and Wastewater Agency Response Networks provide utility to utility mutual aid under pre-signed agreements so that equipment and crews can move without negotiating terms during the emergency.
- An emergency response plan is only as good as its exercise program, which should progress from tabletop discussion through functional drills to full-scale exercises with an after-action report.
Emergency Response Planning & AWIA Risk and Resilience
The ABC criteria list "review and update facility emergency response plans" and "respond to emergencies (e.g., facility upset, equipment failure, spill response, natural disasters, system contamination)" as job tasks. In Virginia those tasks sit on top of a specific federal requirement.
1. The AWIA Requirement
America's Water Infrastructure Act of 2018 (AWIA), Section 2013, amended Section 1433 of the Safe Drinking Water Act. It applies to community water systems serving more than 3,300 people.
The two deliverables
1. Risk and Resilience Assessment (RRA) - must assess the risk to the system from malevolent acts and natural hazards, and must evaluate:
- The risk to the system from malevolent acts and natural hazards;
- The resilience of the pipes and constructed conveyances, physical barriers, source water, water collection and intake, pretreatment, treatment, storage and distribution facilities, electronic, computer, or other automated systems (including the security of such systems);
- The monitoring practices of the system;
- The financial infrastructure of the system;
- The use, storage, or handling of various chemicals by the system; and
- The operation and maintenance of the system. It may also include an evaluation of capital and operational needs for risk and resilience management.
2. Emergency Response Plan (ERP) - must be prepared or revised, and certified to EPA, within six months of certifying the RRA. It must incorporate the findings of the assessment and include:
- Strategies and resources to improve resilience, including physical security and cybersecurity;
- Plans and procedures that can be implemented in the event of a malevolent act or natural hazard that threatens the ability to deliver safe drinking water;
- Actions, procedures, and equipment that can obviate or significantly lessen the impact on public health and on the safety and supply of drinking water, including alternative source water options, relocation of intakes, and construction of flood protection barriers; and
- Strategies to detect malevolent acts or natural hazards that threaten the security or resilience of the system.
The certification cycle
Systems certify completion of each document to EPA (not the documents themselves), and must review and recertify both on a 5-year cycle. Deadlines were staggered originally by system size, and the recurring cycle continues from each system's certification date. Records must be retained for 5 years after certification.
2. Structure of a Usable Emergency Response Plan
A plan that only satisfies the certification is a compliance artifact. A plan that works during an event has these parts:
- System description and critical assets - what must keep running, and what the consequences are if each fails.
- Roles and lines of authority, including who can declare an emergency, who can issue a boil water advisory, and who speaks to the media - with alternates named because emergencies are not scheduled around vacations.
- A current call-down list - staff, on-call rotation, VDH field office, DEQ regional office, local emergency management, fire, police, the electric utility, laboratories, contractors, chemical suppliers, equipment rental, and neighboring utilities. Reviewed quarterly; nothing decays faster than a phone list.
- Event-specific procedures (below).
- Public notification templates with the mandatory health-effects language pre-inserted, ready to fill in.
- Resource inventory - generators, pumps, hoses, fittings, bottled water sources, tankers, fuel contracts.
- Mutual aid agreements.
- Recovery and return-to-service procedures, including flushing plans and sampling plans.
- Training and exercise schedule.
- Revision control - date, version, and who approved it.
3. The Incident Command System
Utilities that write plans in their own vocabulary find that responding agencies do not speak it. ICS, part of the National Incident Management System, is the shared structure.
| Function | Responsibility |
|---|---|
| Incident Command | Overall authority; sets objectives; the only role always filled |
| Operations | Executes the tactical work |
| Planning | Tracks status, develops the incident action plan, documents |
| Logistics | Supplies, equipment, facilities, food, fuel |
| Finance and Administration | Cost tracking, procurement, claims, time - essential for FEMA reimbursement |
Supporting the Incident Commander: a Safety Officer (with authority to stop unsafe operations), a Public Information Officer, and a Liaison Officer.
Key ICS principles worth carrying into a plant: unity of command (each person reports to one supervisor), manageable span of control (3 to 7, optimally 5), common terminology (say "generator," not a plant nickname), and a written Incident Action Plan for each operational period.
4. Event Playbooks
Extended power loss
- Standby generator start and load transfer verified; fuel quantity and refueling contract confirmed at the outset, not on day three.
- Priority load sequence: disinfection first, then raw water pumping, then treatment, then high service.
- Manual operating procedures for every process that normally runs on SCADA.
- Reduce demand through public messaging; use storage strategically and monitor tank levels and system pressure continuously.
Major main break or loss of pressure
- Isolate; maintain positive pressure elsewhere; identify customers affected including critical customers - hospitals, dialysis centers, nursing homes, schools, and food processors, which should be pre-identified in the plan.
- Apply the pre-defined boil water advisory decision criteria rather than debating them in the field.
- Follow the disinfection, flushing, and sampling protocol; rescind only through the defined sequence.
Treatment failure
- Pre-defined shutdown criteria: at what turbidity, residual, or CT shortfall does the plant stop producing rather than distribute inadequately treated water?
- Contact VDH immediately; the state is a resource, not only an enforcer.
- Alternate supply: interconnections with neighboring systems, pre-tested and with valve locations and operating procedures documented.
Suspected contamination
- Treat any report of petroleum or solvent odor, an unexplained illness cluster, a tampering report, or an unexplained water quality anomaly as credible until disproven.
- Do not flush before sampling - flushing destroys the evidence needed to characterize the event.
- Isolate the affected zone if it can be done without depressurizing a larger area.
- Notify VDH, local health, and law enforcement.
- Consider the Water Contaminant Information Tool and EPA's Water Laboratory Alliance for analytical support.
Natural hazards in Virginia
- Hurricanes and coastal flooding - Tidewater plants face storm surge and saltwater intrusion; elevate or waterproof critical electrical gear, pre-position fuel, and plan for extended outages.
- Inland flooding - well head and vault submergence, wellfield inundation, treatment plant flooding.
- Winter storms and ice - frozen instrumentation and sample lines, road access, staffing.
- Drought - source yield, water age in an under-drafted system, and conservation implementation.
- Earthquake - the 2011 Mineral, Virginia event is a reminder that this is not a zero-probability hazard in the Piedmont.
5. Mutual Aid
WARN - the Water and Wastewater Agency Response Network - is a utility-to-utility mutual aid program organized state by state. Virginia participates through VA WARN.
Why it works:
- Agreements are signed in advance, so the legal and reimbursement terms are settled before the emergency rather than negotiated during it.
- It addresses liability, workers' compensation, and reimbursement for the assisting utility.
- Participation is voluntary at the time of the request - an assisting utility may always decline if it needs its own resources.
- It moves what utilities actually need from each other: operators, mechanics, generators, pumps, valve keys, and fittings - resources general emergency management cannot supply.
Related resources: the Virginia Rural Water Association and AWWA Virginia Section for technical assistance, the Emergency Management Assistance Compact (EMAC) for interstate assistance through state emergency management, and FEMA public assistance for eligible costs - which is why the Finance and Administration function must track costs from the first hour.
6. Exercising the Plan
A plan that has never been exercised will fail in ways nobody predicted.
| Exercise type | Description | Effort |
|---|---|---|
| Seminar / workshop | Walk through the plan; orient new staff | Low |
| Tabletop | Discussion-based scenario; participants talk through decisions | Low to moderate |
| Drill | A single function performed for real - start the generator on load, call down the notification list, set up bypass pumping | Moderate |
| Functional exercise | Multiple functions and a simulated command structure, without moving field resources | High |
| Full-scale exercise | Field deployment with responding agencies | Highest |
Build progressively: a tabletop each year, functional drills of specific procedures quarterly, and a full-scale exercise every few years, ideally jointly with local emergency management.
Every exercise produces an after-action report identifying what worked, what did not, and specific corrective actions with owners and due dates. The corrective actions are the point. An exercise that produces a report nobody acts on has cost a day and changed nothing.
Small things exercises reliably reveal: the call list is out of date, nobody knows where the valve key is, the generator will not accept load, the bypass pump fittings do not match, the notification templates are on a server nobody can reach when the network is down, and the one person who knows the alternate intake procedure was on vacation.
Under the America's Water Infrastructure Act, which systems must certify a risk and resilience assessment and an emergency response plan, and on what cycle?
A customer reports a strong gasoline odor from the cold water tap. What is the correct immediate sequence?
What is the purpose of the Finance and Administration function in the incident command system at a water utility emergency?