Very Small Drinking Water and Wastewater System Resilience Continuing Education Unit CEU Program Standard Operating Procedure

Very Small Drinking Water and Wastewater System Resilience Continuing
Education Unit (CEU) Program-Standard Operating Procedure

Program Overview

The U.S. Environmental Protection Agency (EPA) Water Infrastructure and Cyber Resilience Division
(WICRD), the National Rural Water Association (NRWA), and the Rural Community Assistance
Partnership (RCAP) will provide signed certificates for up to three personnel at community drinking
water systems (CWSs) that serve less than 3,301, non-CWSs, and wastewater systems who create risk
and resilience assessments (RRAs) and emergency response plans (ERPs). The certificates can be
submitted to state or tribal operator certification programs to receive continuing education unit (CEU)
credit hours towards the operator's license renewal.

This CEU program will serve as an incentive for water and wastewater systems who do not have to
comply with America's Water Infrastructure Act (AWIA) Section 2013 to prepare RRAs and ERPs. AWIA
Section 2013 requires that CWSs serving populations more than 3,300 conduct and certify completion of
a RRA and ERP to EPA. CWSs that serve less than 3,301, non-CWSs, and wastewater systems are not
required to certify completion of a RRA or ERP to EPA. However, natural disasters and malevolent acts
also occur at these facilities, therefore EPA, RCAP, and NRWA encourage these systems to plan for
disasters that could disrupt system operations by conducting RRAs and developing ERPs.

EPA's WICRD will apply for CEU pre-approval of this program within all 50 states. To qualify to receive a
signed certificate, public drinking water and wastewater system personnel need to reach out to set up a
meeting with either a NRWA or RCAP technical assistance provider (TAP). The TAP will help walk the
water or wastewater system through the process of completing a RRA using EPA's AWIA Small System
Risk and Resilience Assessment Checklist and ERP using EPA's Emergency Response Plan Template and
Guidance or other EPA approved templates, such as RCAP & AWWA's Small Systems Risk and Resilience
Assessment Worksheet. After the RRA and ERP are complete, the TAP will present the water or
wastewater system with a certificate signed by themselves, as well as a representative from EPA's
WICRD. The signed certificate will contain the name(s) of the individual(s) who worked on the RRA and
ERP, as well as how many hours they spent working on the documents up to a maximum of ten hours
per person. System operators must then submit their signed certificate to their respective state or tribal
operator certification program to receive CEU credit.

Role Of EPA WICRD

• Apply for CEU pre-approval of this program with all state, federal, and tribal primacy agencies for
water and wastewater systems. Maintain a list of state and tribal operator certification programs
that do and do not participate in this CEU program on EPA's AWIA RRA and ERP website: https://
www.epa.gov/waterresilience/awia-section-2013#under3301

Provide RCAP and NRWA with a copy of the RRA and ERP Primer for Very Small Drinking Water
and Wastewater Systems.

• Provide RRA and ERP certificate of completion template to NRWA and RCAP for TAPs to sign and
award to water and wastewater system personnel once RRA and ERP have been completed. The
regional partners and state associations will also be given an option to add their own state/local
logos to the certificate of completion if desired.

• Host two virtual information sessions with NRWA and RCAP TAPs to describe the program and
the role of the TAP. Create a short training video for RCAP and NRWA to share with their new
TAPs during their regularly scheduled trainings.

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• Lead a series of workshops throughout 2023 to teach water systems how to develop RRAs and
ERPs and explain the opportunity available to CWSs that serve less than 3,301, non-CWSs, and
wastewater systems to potentially earn CEU credits towards maintaining their operator's license.

• Provide training materials to state and regional rural water associations and RCAP Regional
Partners for ongoing trainings on RRA and ERP development.

• Promote the program through EPA communication networks to advertise its existence to water
and wastewater systems and at annual meetings and conferences held by NRWA, RCAP, the
Association of State Drinking Water Administrators (ASDWA), and other organizations, as
appropriate. This includes posting and distribution of a 2-page primer on the program.

• Coordinate with EPA's National Operator Certification Program and Drinking Water Capacity and
Compliance Assistance Division to ensure that the CEU program is an activity that NRWA and
RCAP TAPs can do under EPA's technical assistance grant program.

• Launch the program in October/November 2022.

Role of Local/State/Regional Rural Water Association or RCAP Regional Partner

• Maintain a list of water and wastewater systems who were issued a certificate under this
program. Report numbers to NRWA, RCAP, and EPA twice a year for internal tracking purposes.
RCAP communicated that they plan to use their existing DCS tracking system to pull this
information using pre-existing RRA and ERP tasks.

• Conduct ongoing training for TAPs on RRA and ERP development. EPA will share materials and
PowerPoint slides that associations can use to host trainings for their TAPs on RRA and ERP
development.

Role of Technical Assistance Provider

• Meet with the water or wastewater system at least once to explain what they must do to receive
a RRA and ERP certificate of completion signed by the TAP and EPA WICRD representative.

• Use EPA's AWIA Small System Risk and Resilience Assessment Checklist and Emergency Response
Plan Template and Guidance methodology or another EPA approved RRA/EPA template when
working with water or wastewater systems to create or update RRAs and ERPs. Other EPA
approved templates include the RCAP & AWWA's Small Systems Risk and Resilience Assessment
Worksheet. If a partnering TAP wants to use a template that is not on this list, they should email
dwresilience@epa.gov a copy of the template for EPA's review and approval BEFORE beginning
work with the water or wastewater system. Once approved, EPA will add the template to the list
of approved templates that can be used for this program.

• Review the RRA and ERP with the water or wastewater system to verify completion and
adherence to AWIA Section 2013 requirements before issuing a certificate of completion.

• Protect the potentially sensitive information in RRAs and ERPs by using proper security
precautions (password protected files, avoid emailing information with sensitive information,
etc.) to prevent a leak of RRA or ERP documents to a malicious actor.

• Provide no more than three certificates of completion within a 5-year period to each water
system that participates in the program. Record the number of hours worked by each individual
on RRA and ERP development on the certificate, up to a maximum of 10 hours per individual.
Record the date that the certificate is provided to the water system.

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• Add logo of state/local rural water association or RCAP regional partner next to the US EPA logo,
complete the specified text for the TAP, and sign the certificate.

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