New York Rural Water Association

Following the horrific events of September 11, 2001, there has been an increased focus on vulnerability assessments and emergency response plans. A vulnerability assessment is a determination of the susceptibility of a water system’s components to particular emergencies, either intentional or non-intentional. It also establishes corrective actions designed to minimize system failure during emergencies. Recent federal and state legislation requires that a vulnerability assessment address terrorist attack or other intentional acts. A vulnerability assessment would also address non-intentional acts such as:

Power outage;Prolonged water outage;Transmission and/or distribution system failure;Treatment equipment failure;Pump failure;Loss of SCADA;MCL violation or contamination of supply;Chemical incident at facility;Drought;Flood;Severe weather;Earthquake;Fire; and
Hazardous materials spill.

An emergency response plan should identify and outline the steps necessary to ensure that potable water is available during all phases of a water supply emergency. Specifically it should include:

Development of procedures to notify consumers during all phases of a water supply emergency;Development of criteria and procedures for determining and the subsequent reporting of critical water levels or safe yield of the source(s) of water;Identification of existing and future sources of water available during normal non-emergency and water supply emergency conditions;Identification of all available water storage;Location of existing and possible future interconnections;Development of a specific action plan outlining all steps to be carried out during a water supply emergency, including State notification, emergency notification rosters, and follow-up corrective actions;Procedures for water conservation and water use restrictions during a water supply emergency;Procedures for prioritization of potable water use during a water supply emergency;Identification of emergency equipment needed; and
Development of criteria and procedures for ability to meet peak water demands and fire flow conditions concurrently.

Regulatory Requirements

Unless otherwise shown that a water supplier’s gross annual operating revenue does not exceed $125,000, all community water systems in New York serving a population of 3,301 or more are now required to prepare and submit a vulnerability assessment and an emergency response plan. The vulnerability assessment and emergency response plan should now be separate documents that are submitted to NYSDOH. All community water systems serving a population of 3,301 or more also must submit a revised vulnerability assessment and emergency response plan to NYSDOH by January 1, 2003. These revisions should specifically address vulnerability to terrorist attack. Such an assessment must include consultation with local and state law enforcement agencies.Community water systems that serve 3,300 people or less are generally not required to submit a vulnerability assessment or emergency response plan. However the NYSDOH and/or county health departments have the authority under Part 5-1.33(f) to specifically require a community water system with a gross operating revenue of less than $125,000 to submit a vulnerability assessment and an emergency response plan.

Tools and Assistance for You

Vulnerability assessments and emergency response plans may seem like a daunting task, particularly if you are required to meet the January 1, 2003 deadline. Fortunately, NYRWA has tools and technical assistance to offer you. First, all of NYRWA’s water program personnel are able to assist you in completing vulnerability assessments and emergency response plans at no cost. For example, completion of an emergency plan is now a requirement of my Ground Water Source Protection Program. In addition to our on-site technical assistance, NYRWA has three important tools to provide you with. First, the National Rural Water Association (our parent organization), in conjunction with the Association of State Drinking Water Administrators (ASDWA) developed a document entitled Security Vulnerability Self-Assessment Guide for Small Drinking Water Systems. This document was adopted and modified by the NYSDOH for public water systems with populations of 3,300 people or less. A copy of this helpful document was mailed to every community water system of 3,300 people or less in New York. Although designed for smaller systems, this document could also be used for less complex systems of between 3,300 and 10,000 population to help assess security needs. These systems should also consult with local and state law enforcement agencies and possibly other security experts. NYRWA has copies of the security vulnerability self-assessment guide in paper and electronic formats and our staff is very familiar with the guide.Second, I have developed a template for a vulnerability assessment that can be used by water systems. This template involves assessing the impacts of various emergencies on your system’s different components. Third, I have developed an emergency response plan template that allows you to readily create a plan. Both plan templates meet all applicable state and federal requirements and were written to be user-friendly. These templates should help you complete a vulnerability assessment and an emergency response plan in a user-friendly manner. Best of all, NYRWA will assist you by answering your questions or even helping you fill in the necessary information.

Contact Information

If you would like a copy of our templates (including the security vulnerability self-assessment guide) you can download the templates from our website: www.nyruralwater.org or you can contact our office for a copy on CD-ROM. In addition, I would be glad to assist any groundwater system in completing your vulnerability assessment and/or emergency response plan. Give me a call at 1-888-NYRURAL or email me at Winkley@nyruralwater.org