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© HDR, all rights reserved.© HDR, all rights reserved.
AWIARisk & Resilience Assessment & Emergency Response PlanLessons Learned
HDR Introductions
David Carani
Water Quality Section Manager
Roger Null
National Utility Planning Lead & AWIA Lead
Aaron Robison
Senior Project Manager
1. AWIA – It’s the Law!
2. National Standard – AWWA J100
3. MO Pending Legislation
4. Lessons Learned
5. MPUA Toolkits
6. Open Discussion
Agenda
Natural Hazards Risks – not if but when!
Community Water Systems serving more than 3,300 persons must:
✓Risk and Resilience Assessment (RRA)
✓Update Emergency Response Plan (ERP)
✓Submit Certification to EPA for each
✓Review and update every 5 years
✓Record maintenance
America’s Water Infrastructure Act of 2018 (AWIA)
But I did a Vulnerability Assessment…What’s Different Now?
AWIA Requirements – Prepare and Certify RRA & ERPs
Community Water
System (pop. served)
Certify Risk & Resilience
Assessment (RRA) prior to:
Certify ERP within 6 months of
RRA, but not later than:
>100K March 31, 2020 September 30, 2020
50K to 100K December 31, 2020 June 30, 2021
3,300 to <50K June 30, 2021 December 30, 2021
What if No Letter is Submitted? Utility is subject to enforcement action by EPA under §1414 of SDWA
Penalty up to $25,000 per day
What Must a Utility Assess?
• Pipes and constructed conveyances
• Physical barriers
• Source water
• Water collection and intake
• Pretreatment, treatment, storage and distribution facilities
• Electronic, computer, or other automated systems
All Critical Components of the System
Harmful Algal Blooms (HABs)
• Earthy / Musty Culprits
• Methyl Iso-Borneol (MIB)
• Geosmin
• Odor Threshold 5 to 10 ng/L
• Erodes public confidence
Example Source Water Concerns
• Malevolent Acts and Natural Hazards
• Monitoring practices of the system
• Financial infrastructure
• Use, storage, or handling of various chemicals
• Operation and maintenance of the system
• May include evaluation of capital and operational needs for risk and resilience management
What Must a Utility Assess?
Natural Hazard Vulnerability/Risk Assessment
• Hurricane
• Tornado
• Flooding
• Earthquake
• Wildfire
• Fire
• Erosion/Landslide
• Dam Failure
• Extreme Heat/Algae Blooms
• Drought
• Storms/Lightning/Hail
• Winter Weather
• Animals
Human-Caused Hazard Vulnerability Risk/Assessment• Vandalism
• Physical Sabotage – Internal & External
• Physical Sabotage - External
• Cyber – Internal & External
• Terrorism
• Contamination – Accidental & Intentional
• Dependency – Loss of Power
• Dependency – Loss of Supply Chain
• Dependency – Loss of Staff
• Dependency – Human Error/Neglect
• Dependency - Loss of Communication
• Transportation Accidents/Incident
• Hazmat Incident
• Proximity Hazard
An Integrated Project Approach to AWIA Compliance Provides a Resilience Milestone
What do you want to get out of the RRA & ERP?
National Standard –AWWA J100
• Industry Standard for water and wastewater utilities
• Adopted as an ANSI Standard in 2010
• US SAFETY Act Approved
• All-hazards approach
• Provides due diligence
1. Asset Characterization
2. Threat Characterization
3. Consequence Analysis
4. Vulnerability Analysis
5. Threat Analysis
6. Risk/Resilience Analysis
7. Risk/Resilience Management
Cyber Security is getting a lot of attention locally.
AWWA J100 Standard –7 Step Process
RRA Report ERP Report
• Documents Process and Decision
• J100 Workbook (spreadsheet tool)
• Critical Asset Summary Sheets
• Mitigation Measures and Implementation Plan
• Physical and cybersecurity strategies
• Response plans, procedures, and equipment
• Specific actions to lessen impact on public health
• Detection strategies
RRA & ERP Certification Letter
Certification of Review Every Five Years
Guidance Document M19
• Emergency Planning for Water and Wastewater Utilities
• Manual that provides detailed best practices to meet industry standards.
• Originally issued in 1973 and was last updated in 2018.
• Consensus of the water sector
Our ERP Gap Assessment Approach Focuses Our Efforts in these Key Areas
2003 Water Utility ERP
Existing Water Utility ERP
Existing City/County ERP
WARN/EMAC
GAP Assessment
2020/2021 AWIA ERP
Update
Guidelines, Standards,
and RRA Findings
• State-based ERP Guidelines
• AWIA Federal ERP
Guidelines
• AWWA M19-18 - Emergency
Planning Manual
• ANSI/AWWA G440-17 -
Emergency Preparedness
Practices
• AWIA RRA Findings (J100
Standard)
ERP Response
Training
Exercises
BCP/COOP
Alignment
SCADA/IT Assessment Required by the AWIA – HB 2120?
Can be a tiered approach
1. Begin with the free AWWA Cyber Security Tool for basic identification of issues
2. Consider more in-depth Cyber audit after the basics are improved
3. Utilize additional detailed evaluation tools and testing after the basics are improved
Cybersecurity
• Governor Parson’s signed in July 2020
• Applies to all cities less than 30,000 population
• Must develop and implement:
• Cyber Risk Plan
• Valve Inspection Program
• Hydrant Inspection Program
• Provide compliance reports upon request by DNR
• Voluntary Lead Testing in Public Elementary Schools
Missouri House Bill 2120
Effective Tools, Resources & Strategies
Key Lessons Learned
• Collaboration is important
• Scalable effort based on objective
• Field inspection is important
• Mitigation measure identification and implementation are needed
• Mitigation measures must go beyond physical security
• Pandemic planning is more important now
• Business continuity planning is key
• Training is essential
Assessment Tools• Many tools - no singular solution
• Customized tools
• EPA – VSAT 2.0
• EPA - Small System RRA Checklist
• AEM – PARRE
• AWWA Cybersecurity Tool
• ESRI Survey123
• UAS (Drone) Technology
• Detailed Model Analysis
• EPA Response Protocol Toolbox (ERP)
• Different approaches fit different utilities – what is your objective?
• Minimum compliance?
• Commitment to risk and resilience management?
• Commitment to integrated assessment, planning and management approach?
Small Utility Checklists
• For utilities 3,300 to <50,000
• Help small systems meet AWIA RRA requirements
• Does not cover all aspects of water system security & resilience
• Asset management
• Climate change
• Emergency preparedness & response
Comparison of the Checklist and VSAT
• EPA published VSAT Web 2.0 in August 2019 to assist larger systems with risk assessments to comply with AWIA
*EPA (2020) America’s Water Infrastructure Act (AWIA) Risk and Resilience Checklist and Lessons Learned
https://www.epa.gov/water-research/small-systems-monthly-webinar-series
MPUA and HDR: AWIA and CS Asset Management Tool Kits
© HDR, all rights reserved.
Aaron Robison
Robison, Aaron
816-590-5264 Cell