Drinking Water Security

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"The superior man, when resting in safety, does not forget that danger may come. When in a state of security he does not forget the possibility of ruin. When all is orderly, he does not forget that disorder may come. Thus his person is not endangered, and his States and all their clans are preserved."

Confucius (551 BC - 479 BC)

Do you know what to do if a phone caller claims they have contaminated the water system?
Do you have an alternate supply of drinking water? Has your water system participated in a training exercise with the fire dept., police dept., local government and the local emergency management agency? Have you budgeted for additional security items? Ensuring the safety of the public water supply is our top priority. With increased vigilance, we can minimize the risk of terrorist or other intentional acts against Tennessee water systems and ensure that all customers continue to receive safe drinking water.

Vulnerability Assessments and Emergency Response Plans.
The Public Health Security and Bioterrorism and Response Act (H.R. 3448) required all community public water systems serving 3,300 people or more to conduct a vulnerability assessment and prepare or revise, where necessary, an emergency response plan that incorporates the results of the vulnerability assessment. Water systems serving between 3,300 and 49,999 people were required to submit their Vulnerability Assessment to the EPA by June 30, 2004. These water systems were also required to certify to the EPA the revision of their Emergency Response Plan by December 31, 2004. Larger systems (serving more than 50,000 people) were required to submit a Vulnerability Assessment and an Emergency Response Plan Certification to the EPA on earlier dates.

* Note - EPA interprets "completion" to mean the date the vulnerability assessment and certification were sent to EPA -- either the date shown on the express or courier service mailing slip if submitted in this manner, or the postmark if sent via the U.S. Postal Service. Community water systems should be aware that if they fail to comply with their respective vulnerability assessment submittal requirements six months after their appropriate deadline date, then they may be liable for failing to comply with both the vulnerability assessment submittal requirements and the emergency response plan certification requirements of the Bioterrorism Act.

Requirements of an Emergency Operations Plan.
The Bioterrorism Act required community water systems serving populations greater than 3,300 to prepare or revise an ERP that incorporated the results of the Vulnerability Assessment. The ERP should include “plans, procedures, and identification of equipment that can be implemented or utilized in the event of a terrorist or other intentional attack” on the CWS. The ERP should include “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.”

For questions on ERP Certification Submission, go to the EPA document, "7 Easy Steps to Submitting your Emergency Response Plan (ERP) Certification."

The EPA document "Emergency Response Plan Guidance for Small and Medium Community Water Systems to Comply with the Public Health Security and Bioterrorism Preparedness and Response Act of 2002." contains guidelines for completing an Emergency Operations Plan.

The Tennessee Division of Water Supply will issue a new state guidance document, "Guidance for Emergency Operations Planning for Community Water Systems" in 2005.

Water systems serving fewer than 3,300 people.
A vulnerability assessment is an integral part of a good emergency plan. Although not mandated by H.R. 3448, the Division of Water Supply strongly encourages small water systems serving populations under 3,300 to complete a vulnerability assessment. By completing a vulnerability assessment, you will enhance the security of your water system and identify areas of potential improvements. "Security Vulnerability Self-assessment Guides for Small Drinking Water Systems" are available from the Division of Water Supply, 6^th Floor, L & C Tower, 401 Church Street, Nashville, TN 37243-1549, by calling 615-532-0191, by faxing a request to 615-532-0503, or on the web (see link above). After completing the security vulnerability assessment, please return the "Certificate of Completion" to the Tennessee Division of Water Supply Central Office at the 401 Church Street address.