AWIA Risk Requirements

Risk and Resilience: What you need to know, and where to find resources.

Passed in 2018, America’s Water Infrastructure Act requires community water systems to file a “risk and resilience” assessment with the EPA. Within 6 months of the assessment, water systems must develop an emergency response plan. Links to the process, certification requirements and resources can be found at: https://www.epa.gov/waterresilience/americas-water-infrastructure-act-risk-assessments-and-emergency-response-plans

Who must file a risk and resilience assessment?

Any community water system that serves more than 3,300 persons is required to file an assessment and emergency response plan. While a community water system is defined as any drinking water utility that consistently serves at least 25 people or has 15 service connections year-round, only those serving over 3,300 people are impacted by this requirement.

When do I need to file?

The due dates for both the assessments and the plan are dependent upon the size of your service population.

Service PopulationRisk and Resilience AssessmentEmergency Response Plan
≥ 100,000 peopleMarch 31, 2020September 30, 2020
Serving ≥ 50,000 and ≤ 99,999December 31, 2020June 30, 2021
Serving ≥ 3,301 and ≤ 49,999June 30, 2021December 30, 2021

Continuing requirements

Every five years, your utility must review your risk and resilience assessment and adjust if needed. You then must recertify your assessment with the EPA. Within six months of recertification of your risk and resilience assessment, you must review your emergency response plan and revise if necessary.

Is there a form or a standard I must follow?

The short answer is no. Your utility’s assessment and plan must meet all the criteria in AWIA Section 2013(a) and (b), but the AWIA does not require that you use any particular standard, tool or method for conducting your assessment or developing your plan. Please be aware that your risk assessment and emergency response plan need to include assessments for accidental emergencies (chemical leaks, equipment malfunctions), natural disasters and changing conditions (flooding or drought from climate change for example) as well as malevolent acts of sabotage, both on your physical assets and your cyber control systems.

The lack of a hard and fast standard recognizes the need for these assessments and plans to be flexible and tailored to each utility’s needs. However, there are some guidance documents that can act as a road map to the development of these documents. The AWWA has developed the J100-10 Risk and Resilience Management of Water and Wastewater Systems to guide utilities in their assessments, available for purchase here: https://www.awwa.org/Store/Product-Details/productId/21625.

Establishing priorities, determining strategies, and finding funding sources.

The EPA’s Resilient Strategies Guide will help you identify possible priorities to evaluate and strategies to fortify your assets based on your utility type (it includes wastewater/stormwater as options, in addition to drinking water), your utility size and state. The “Launch Guide” button is at: https://www.epa.gov/crwu/resilient-strategies-guide-water-utilities#/ which will take you to the guide launch page: https://www.epa.gov/crwu/resilient-strategies-guide-water-utilities#/utility-information?utilityName=&region=101&utilityType=4&utilitySize=1315

Malevolent acts, a new concern.

The risk for terrorism and potential sabotage must be taken seriously. The EPA has designed a guide to assist in this aspect of risk assessment and plan development, Baseline Information on Malevolent Acts for Community Water Systems. This guide provides step by step assessments for different utility types and threats. The link to the EPA’s site is https://www.epa.gov/waterriskassessment/baseline-information-malevolent-acts-community-water-systems which includes the link to the document pdf at: https://www.epa.gov/sites/production/files/2019-07/documents/baseline_information_malevolent_acts_508_072519.pdf

Risk Assessment for extreme weather.

If extreme weather is a major risk for your utility, there is an assessment tool that will help you project current and long-term conditions. CREAT has interactive maps to help evaluate your area and integrates with the resilient strategies guide. https://www.epa.gov/crwu/creat-risk-assessment-application-water-utilities

This resource also helps identify strategies and, in some cases, funding sources for implementation.

Don’t forget chemical safety.

One of the asset categories identified is “The use, storage or handling of chemicals”. Be sure to evaluate all your chemicals for vulnerability to accidental spills and leaks, as well as unauthorized access. Secondary containment is a must for all your chemical feeds, but is even more important for your gaseous chemicals, as they pose a higher threat to the surrounding community.

The example cites chlorine as a chemical of concern for uncontrolled release. Maintaining a chlorine residual is key to the safety of your water, so necessary for the health of your community. But, maintaining safe chlorine handling practices is also critical to the safety of your employees and surrounding populations. Be sure to evaluate your handling practices and all the options for containment and release mitigation, to ensure that your equipment and protocols are providing the necessary level of safety.

Your communities depend on you.

You know your water is literally the life giver to your community. The economic and physical health of your communities are only as stable as the water you provide. Thorough risk assessment and emergency planning is critical to maintaining your utility and the welfare of your community.