Every community water system that serves a population of greater than 3,300 persons is required to:
- Conduct a vulnerability assessment
- Certify and submit a copy of the assessment to the USEPA Administrator (see schedule below);
- Prepare or revise an emergency response plan that incorporates the results of the vulnerability assessment; and
- Certify to the USEPA Administrator, within 6 months of completing the vulnerability assessment, that the system has completed or updated their emergency response plan.
Summary of Federal Requirements
On 12 June 2002 the Public Health Security and Bioterrorism Preparedness and Response Act of 2002 – Title IV, Section 401, amended the Safe Drinking Water Act. In this amendment, each community water system serving a population of greater than 3,300 persons is required to conduct an assessment of the vulnerability of its system to a terrorist attack or other intentional acts intended to substantially disrupt the ability of the system to provide a safe and reliable supply of drinking water.
The vulnerability assessment are required to include, but is not be limited to, a review of pipes and constructed conveyances, physical barriers, water collection, pretreatment, treatment, storage and distribution facilities, electronic, computer or other automated systems which are utilized by the public water system, the use, storage, or handling of various chemicals, and the operation and maintenance of such system.
Upon completion of the assessment, the water system must submit to the USEPA Administrator a written copy of the assessment. All due dates for the completion and submission of the assessments have already passed.
Based on the results of the vulnerability assessment, the community water system serving a population greater than 3,300 should prepare or revise, where necessary, an emergency response plan. Certification shall be given to the EPA Administrator that the emergency response plan has been completed. The emergency response plan must include, but is not limited to, the following:
- plans, procedures, and identification of equipment that can be implemented or utilized in the event of a terrorist or other intentional attack on the public water system
- actions, procedures, and identification of equipment which can obviate or significantly lessen the impact of terrorist attacks or other intentional actions on the public health and the safety and supply of drinking water provided to communities and individuals.
Detailed assistance, including Instructions to Assist Community Water Systems in Complying with The Public Health Security and Bioterrorism Preparedness and Response Act, Title IV is available here. Additionally, there is free software available to aid in conducting the assessment.
The Vulnerability Self Assessment Tool™ for Water & Wastewater Utilities
The Vulnerability Self Assessment Tool (VSAT™) software was developed to support water and wastewater utility vulnerability assessments using a qualitative risk assessment methodology. VSAT™ software is available, free of charge, for wastewater utilities (VSATwastewater™), drinking water utilities (VSATwater™), and for utilities providing both services (VSATwater/wastewater™).
Summary of State Requirements
This is primarily a Federal mandate although there may be local requirements to conduct assessments of smaller drinking water systems.
Laws and Statutes
Public Health Security and Bioterrorism Preparedness and Response Act of 2002
Safe Drinking Water Act