System Vulnerability Assessments and Emergency Response Plans

SERCAP team members in Virginia have been making calls to small public works directors and water and wastewater utility operators across the state to engage them in writing, updating, and revising system vulnerability assessments and emergency response plans for their water and wastewater utilities. As is the case with any type of project, it is usually easier to begin these projects with town employees who are already familiar with the processes and materials needed to create these documents. This article can serve as a primer on system vulnerability assessments and emergency management plans to prepare any water/waste utility staff who may get a call from a friendly RCAP voice on the line asking, “Do you need assistance with your system vulnerability assessment (SVA) and/or emergency response plan (ERP)?”

What are System Vulnerability Assessments?

A System Vulnerability Assessment (SVA), is both a document and a process by which that document gets filled out. It is meant to be an opportunity to recall and record all of the safety measures that are already in place for a system and to check whether more safety measures ought to be taken. A standard SVA has three elements: a broad-strokes inventory of material assets and software systems that are owned or used by the water utility, an account of steps taken to keep those assets, systems, and employees safe, and an analysis of the current risk levels and risk types that those assets are subject to.

In SERCAP’s experience here in Virginia, there seem to be roughly two types of system vulnerability plan documents. One is a questionnaire that lists a set of best practices that can be checked off, with room for comments added and the other is a matrix that includes space for threat type, risk level, and comments for each asset. Since we are working on several SVA projects in a short period of time, we have been testing both types of documents. Each has some benefits and some drawbacks, but both include the three essential components listed above (to reiterate –an inventory, a list of what is done to keep that inventory safe, and a risk assessment). There are many templates out there from EPA and others, including one co-developed by RCAP and the American Water Works Association that goes into depth but is still easy to use for small systems and TA providers alike.

If a system has already done an asset management plan, then it is likely that they will have a great deal of the material that they need in order to complete the SVA. They should have both an inventory and a risk analysis for their major assets. Similarly, if a system has already undergone a community needs assessment, they should have basic inventory, risk analysis, and even proposed capital investments and operations changes for the system. This also works both ways: if a system is already undertaking an SVA, they may consider developing some parts of their community needs assessment or asset management plan at the same time.

What is an Emergency Response Plan?

Emergency response plans (ERPs) have more components than SVAs, and although they require less analysis (for example, they do not require consideration of what kinds of risks a 20,000-gallon water tank might be subject to), they do require clarity, because they should serve as the go-to document for water and wastewater system employees who need to know what to do in case of an emergency.

ERPs are likely to be quite different for each community, because each community is subject to different risks, has different assets, has different forms of government, and is of a different size, both geographically and demographically. Nonetheless, if a town or system does not have an ERP, a good substantive starting point is to include the following:

• basic system information;
• a chain of command for the town (who calls who, who is responsible for what);
• a list of organizations that should be notified of certain emergencies (like the Office of Drinking Water, for instance);
• a list of likely emergencies;
• response plans for specific emergencies;
• alternative water sources; and
• a plan for returning to normal operation.

As is probably clear from that list, ERPs require input from not only water utility operators, but also town administrators, town law enforcement, and other public works employees. It is perhaps unsurprising then, that ERPs can take some time to finalize. Coordinating and soliciting responses from many different people is often a difficult and time-consuming aspect of a project.

Fortunately, in our experience in Virginia, most towns have an existing ERP or the beginning of one. On many occasions, these have been found buried digitally in files on computers and/or printed in binders under lab tables in facilities. It is equally important that ERPs are updated in regular intervals to ensure that the emergency plans are still relevant and include current staff, updated components, and current information for external partners.

Why Create or Update SVAs and ERPs?

Perhaps the favorite filing system of any water/wastewater utility is the minds of the employees who work there. Certainly, one of the best parts of utilities management projects for me is when I get to talk to town administrators, employees, and citizens and hear about who installed what and why they did it in such an unusual way, or about the last time a wild emergency happened and people banded together to make sure that it wouldn’t happen again. Stories, memory, and experience are really important parts of running any utility.

However, especially in emergency situations, the information that floats around offices, break rooms, truck cabs, and roadsides needs to be accessible easily and quickly. The brand-new night-shift employee who may or may not take the occasional nap in the old office chair needs to know exactly what to do if there is a chlorine leak, or if the backup generator malfunctions. This means that the ERP should be written down, labeled clearly, and stored where everyone knows they can find it.

In addition to the ERP, the SVA has a high level of importance as well. Creating it and updating it regularly is a useful tool for making adjustments to regular operating procedures, when necessary, and for identifying important improvements to the system. It can also be an opportunity to exchange information among operators and administrators about any ongoing or new safety concerns, especially in light of more severe and more frequent natural disasters. EPA has released an ERP template for small systems, which can be viewed here.

Some Lessons and Tips

Developing and updating SVAs and ERPs will generate different information for every system, but there are a few things it might be useful to look out for while doing so.

During the SVA, there may be upgrades and updates to the system that may seem like they are unrelated to vulnerability, but actually are. For instance, the water plant manager in Gretna, Virginia (VA) pointed out that investing in an extra settling basin may make it possible to reduce the amount of chlorine that the system uses. Less chlorine on the premises could mean easier deliveries, less strain on the ventilation system, and a more manageable emergency if something goes wrong.

Often, the easiest and most important update to the ERP is an update to the contacts and chain of command lists.

Sometimes, it is much faster to gather the information for the SVA and ERP in person. Don’t be afraid to schedule in-person meetings with necessary parties.

Do not keep or share information from the SVA or ERP with anyone who does not need that information! SVA and ERP documents are considered sensitive. The United States Department of Agriculture (USDA) and the Environmental Protection Agency (EPA), for instance, do not keep them on record. They should not be publicly available on a website. They should be immediately deleted from TAP records once the certification of completion is filled out.

Does your system or region participate in WARNS? WARNs are a way for neighboring systems to help each other during system-specific emergencies (short on chemicals) or during large-scale regional disasters (sharing operators, or equipment.) Please check to see if your system could be part of the WARN network.

Updating or creating an SVA and/or an ERP only takes a little bit of effort and coordination, and they are really important for ensuring the safety of your customers. Hopefully, this has made beginning the process a little bit easier. Don’t be afraid to reach out to an RCAP TAP to get more information!