EPA Releases VA/ERP Instructions
New documents from the U.S. Environmental Protection Agency (EPA) describe requirements for completing vulnerability assessments (VAs) and emergency response plans (ERPs) mandated by the Bioterrorism Preparedness Act along with instructions on how to comply with the 2002 law, including how to submit copies of VAs as well as VA and ERP completion certifications in a secure manner.
Available for downloading at the agencys Water Infrastructure Security home page, the VA fact sheet and related instructions are intended to help community water systems (CWSs) serving more than 3,300 people comply with the water security provisions of PL 107-188, enacted in mid-2002.
The seven-page VA fact sheet describes their purpose and six common elements while the 23-page instructions document details compliance actions in a question-and-answer format and includes standardized certification forms and submittal instructions.
Of note, the instructions include a disclaimer cautioning that following them is "strictly voluntary for both EPA and affected CWSs" and that EPA may change them in the future "as experience or other circumstances warrant." EPA also notes that it retains "the discretion to adopt approaches on a case-by-case basis which may differ from these instructions where appropriate" and "will consider whether or not the recommendations or interpretations in the instructions are appropriate" in particular situations.
EPA has also posted its protocol for ensuring the security of submitted VAs along with a description of its PL 107-188 responsibilities (no implementing regulations were required or developed).
AWWA recommends that utilities subject to the law download and use the documents, noting that systems serving 100,000 or more people face a March 31 deadline for submitting VA copies and certification forms.