Letter to Community Water Systems Serving 3,301 People or More

NY State Community Water Systems

Serving 3,301 people or more

June 29, 2012

Water Supply Emergency Plans - Revisions Due on or about January 2013

Dear Community Water System Administrator:

The Public Health Law and State Sanitary Code require that certain public drinking water systems review, update and submit water supply Emergency Response Plans (ERP) and Vulnerability Assessments (VA) every five years. This letter reminds you of your obligations as a water supplier to revise and resubmit your VA/ERP documents. The VA/ERP resubmittals are a New York State requirement, revised documents should not be submitted to EPA.

You have received this letter because the New York State Department of Health has determined that water from your system serves a total population of 3,301 or greater. If you were not previously required to submit an emergency response plan or vulnerability assessment and have received this letter, it is because information in our database now indicates that water from your system serves a total population equal to 3,301 or greater, both directly and by interconnection to other water systems. The population served by your water system is actually entered into this database by your Local Health Department. If you believe that you have received this letter in error, and water from your system serves a total population less than 3,301, please contact your Local Health Department as soon as possible.

The Bureau of Water Supply Protection has reviewed VAs and ERPs for over 360 individual systems, completed detailed security assessments of water systems, and assisted state and federal response agencies, Local Health Departments and water utilities with numerous water related emergencies throughout New York State. This experience has highlighted some basic weaknesses with some of the VAs and ERPs that we have on file, notably: incomplete or out of date contact information; and incomplete or inaccurate infrastructure information.

Contact Information: Complete and up-to-date contact information in your ERP is absolutely essential. Include multiple points of contacts for key personnel, emergency responders, law enforcement, critical customers, response agencies, regulatory personnel, vendors, media outlets and others. This information is critical for your ability to obtain assistance and emergency information, to notify your customers of emergency conditions, to meet your regulatory obligations, and to communicate with other personnel that may be deployed to assist your system in repair operations. This can also help you when your records are lost or inaccessible during an event.

Infrastructure Information: Similarly, including complete, up-to-date system information in your ERP can be extremely helpful in an emergency event. Be sure your ERP has complete and up-to-date infrastructure information. Where appropriate: consider plans to improve redundancies and security for critical assets and key resources; formalize criteria for exercising and activating emergency interconnections; and put into place agreements and protocols for obtaining emergency repair materials, equipment, and personnel. Consider joining NYWARN (www.nywarn.org), developing an individual mutual aid agreement with a neighboring utility, and completing a letter of understanding with local equipment vendors for 24 hour sales and stocking of key parts.

More information about completing your VA/ERP update is available online.

Support is also available in the form of VA and ERP templates for small systems.

The VA template has been revised to consolidate two earlier versions into one simpler VA document.

If you need assistance completing your VA/ERP by your submittal deadline, please contact your Local Health Department. Technical assistance may be available from your Local Health Department, the Bureau of Water Supply Protection, or the New York Rural Water Association.

Thank you in advance for your continued cooperation in complying with the emergency plan requirements. The water sector in New York State has made significant progress in securing its drinking water infrastructure as part of an all hazards approach to protecting public health. Recent emergencies in NY State have shown that this preparedness has greatly benefited all.

If you have questions concerning your system or how these emergency plan requirements affect your system, please contact your local health department representative.

Sincerely,

Roger C. Sokol, Ph.D.

Director, Bureau of Water Supply Protection