Resources to Promote RRAs and ERPs for CWS that Serve Less than 3,301, non-CWS, and Wastewater Systems

Community drinking water systems (CWS) that serve less than 3,301 people, non-community water systems (non-CWS), and wastewater systems are not required to certify completion of a Risk and Resilience Assessment (RRA) or Emergency Response Plan (ERP) to EPA under America’s Water Infrastructure Act (AWIA) section 2013/Safe Drinking Water Act (SDWA) section 1433. However, natural disasters and malevolent acts also occur at these facilities, therefore EPA encourages these systems to plan for disasters that could disrupt system operations by conducting RRAs and developing ERPs.

To encourage water systems not required by SDWA section 1433 to create RRAs and ERPs, EPA created the Very Small Drinking Water and Wastewater System Resilience Continuing Education Unit (CEU) Program; EPA, the National Rural Water Association (NRWA), and the Rural Community Assistance Partnership (RCAP) will provide signed certificates of completion to community drinking water systems that serve less than 3,301 people, non-community water systems, and wastewater systems who create RRAs and ERPs under the guidance of a NRWA or RCAP technical assistance provider. Water and wastewater system operators could then receive CEU credit hours for the hours they spent developing the RRAs and ERPs, if allowed by their state or tribal operator certification program.

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Resources 

Workshops for Water Systems that Serve Under 3,301 and Wastewater Systems

From fall 2023 through fall 2024, EPA hosted a series of five virtual workshops to assist CWSs serving under 3,301 people, non-CWSs, and wastewater systems with developing or updating RRAs and ERPs, similar to those CWSs that were required to create RRAs and ERPs in accordance with SDWA section 1433. The webinars included:

  • How to create a RRA and ERP using EPA's free tools
  • Information on how to participate in the Very Small Drinking Water and Wastewater System Resilience CEU Program

Please view a recording of one of the webinars for wastewater systems below. Even though the recorded content focuses on wastewater systems, it is still relevant to drinking water systems since EPA has a drinking water version of every tool highlighted in the webinar.

Very Small Drinking Water and Wastewater System Resilience CEU Program Frequently Asked Questions (FAQs)

1. How many CEU hours can a water or wastewater system operator receive for a signed certificate? 

Water or wastewater system personnel who assist in the development of the RRA and ERP reports may receive no more than 10 training hours total. The NRWA or RCAP technical assistance provider who is working with the system will be responsible for determining the appropriate number of CEU hours to award to the author(s) and will include the number of hours, up to a maximum of 10 hours per individual, on the signed certificate of completion.

EPA proposed that the course length range from 1-10 hours to provide flexibility to the individual provider and student to use the time they need for their individual circumstances. However, individual state or tribal operator certification programs may choose to set the maximum course length eligible for CEU credit at greater or fewer than 10 hours for completing both the RRA and ERP.

2. How will operator certification programs know which individuals contributed to the RRA and ERP and how much they contributed? 

Each drinking water and wastewater system that participates in this program will meet with an NRWA or RCAP technical assistance provider in order to receive a certificate. The technical assistance provider will verify which individuals contributed and how much they contributed. No more than three co-authors on the RRA and ERP will be allowed to receive a certificate of completion per utility.

Once the training is complete, the participating technical assistance provider should email dwresilience@epa.gov for assistance completing the Certificate of Completion, including the required signature of an EPA representative, prior to submitting the certificate to the state operator certification program.

3. At what point is the RRA and ERP training considered to be completed? 

The training is completed when the drinking water or wastewater system has a complete RRA and ERP that meets the specifications of SDWA section 1433. Each system that participates in this program will meet with a NRWA or RCAP technical assistance provider as part of the requirement of receiving a certificate. The technical assistance provider will determine when the RRA and ERP documents are complete.

Once the training is complete, the participating technical assistance provider should email dwresilience@epa.gov for assistance completing the Certificate of Completion, including the required signature of an EPA representative, prior to submitting the certificate to the state operator certification program.

4. Which standards/methodologies can be used to create a RRA and ERP to be eligible to receive a certificate of completion signed by EPA and NRWA or RCAP? 

Water and wastewater systems must use the methodology of EPA’s Small System Risk and Resilience Assessment Checklist and Emergency Response Plan Template and Guidance or another EPA approved RRA/EPA template in order to be eligible to receive a certificate of completion. Other EPA approved templates include: 

If a partnering technical assistance provider 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 this list of approved templates.

Please note that requiring the use of approved templates is different than the requirement under SDWA section 1433. SDWA section 1433 certification does not require the use of any standards, methods, or tools for the RRA or ERP. The EPA templates and other approved tools offer a straightforward methodology that, if correctly followed, will produce an SDWA section 1433-compliant RRA and ERP. EPA will not sign a certificate of completion unless an approved template is used.

If a water or wastewater system already has their RRA or ERP created in a different format that they prefer to use other than EPA’s Small System Risk and Resilience Assessment Checklist and Emergency Response Plan Template and Guidance, or other EPA-approved template, they can keep their preferred format but must work through one of the approved RRA and ERP templates to ensure that all required information is included. In other words, the final format of the RRA and ERP is completely up to the water or wastewater system, but the framework/methodology of an EPA-approved template must be used as a reference for updating the RRA and ERP.

5. Who is eligible to participate in this program and receive a certificate? 

CWSs that serve under 3,301 people, non-CWSs of any size, and wastewater systems of any size may participate in this program. For information on EPA’s definitions of public water systems, including definitions of CWSs and non-CWSs, please visit EPA's information abut public water systems webpage.  

CWSs that serve over 3,300 have a statutory requirement under SDWA section 1433 to certify completion of a RRA and ERP to EPA by set deadlines. This initiative is focused on increasing resilience across the sector for systems that do not need to comply with SDWA section 1433. EPA, NRWA, and RCAP agree that developing these assessments and plans will benefit these systems and the communities that they serve.  

6. If an applicable system completed a RRA and ERP before the roll out of this program, do they have any option to participate and still get CEU credit hours? 

CEU credit hours will not be allowed retroactively. However, a CWS that serves under 3,301, a non-CWS, or wastewater system that created a RRA and ERP before may still participate in this program by working with a technical assistance provider to review, identify possible gaps or weaknesses, using EPA’s Small System Risk and Resilience Assessment Checklist and Emergency Response Plan Template and Guidance or another approved resource, and incorporating updates to their RRA or ERP. The hours spent reviewing and update the RRA and ERP would be displayed on the certificate of completion.  

Each Public Water System Identification Number (PWSID) or wastewater permit number may only receive a certificate of completion for three personnel once within a 5-year period, either for the work done to create the documents from scratch or update/improve pre-existing documents.  If a water or wastewater system operator oversees multiple PWSIDs or wastewater systems, CEUs will only be granted for one provider-led course for one PWSID or wastewater system that the individual oversees. System operators and technical assistance providers must then follow the pre-established method used by their operator certification program to apply for CEU credit hours.

7. Can you receive a certificate of completion if you only complete one of the two documents, either the RRA or the ERP? 

No, certifications of completion will only be given to systems that create both an RRA and an ERP.  

8. Which state and tribal operator certification programs participate in the Very Small Drinking Water and Wastewater System Resilience CEU Program? 

EPA has applied for CEU pre-approval with all 50 states, the Intertribal Council of Arizona (ITCA), and the United South and Eastern Tribes (USET). However, not all state and tribal operator certification programs have approved this CEU program at this time. The following state and tribal operator certification programs participate in this CEU program so far (last updated on 9/16/2024):

State/Tribal Operator Certification Program Drinking Water (DW), Wastewater (WW), or Both? Notes
AL Both  
AK Both  
AZ Both Does not provide approval up-front but will consider applications on a case-by-case basis.
CA DW Approved for 8 credit hours for full completion of this course.
CO Both Approved for 1 training unit (TU) for full completion of this course. Approval expired on 12/31/2023; please contact dwresilience@epa.gov if there is interest in extending the expiration date.
CT WW  
DE Both  
GA Both Approved for 3 credit hours for full completion of this course.
HI WW Approved for 1 CEU for 8 hours.
ID Both  
IN Both Approval is valid through 12/31/2024.
ITCA Both Does not provide approval up-front but will consider applications on a case-by-case basis.
KY Both  
LA Both  
MA Both  
MD Both  
ME Both WW program does not provide approval up-front but will consider applications on a case-by-case basis.
MI Both Approved for 3 hours total for DW and WW programs: the informational section taught by EPA approved technical assistance providers will be awarded 1 hour (0.1 CEC); completion of the RRA will be awarded 1 hour (0.1 CEC); and completion of the ERP will be awarded 1 hour (0.1 CEC).
MN Both WW program does not provide approval up-front but will consider applications on a case-by-case basis as "indirect" training.
MS DW  
MT Both Approved as a dual credit course, if a combined system creates an RRA and ERP that covers both the drinking water and wastewater sides of their operations. Approval is valid through 5/31/2026.
ND Both

Approved for one credit hour for full completion of this course.
NH Both  
NJ Both  
NM Both  
NV Both DW approval is valid through 12/31/2024. WW approval is valid 3 years after the date of original approval, 6/27/2026.
NY DW DW program requires completion of a course evaluation form upon completion of the program (EPA can provide this form).
NY WW WW program approved for one credit hour for full completion of this course.
OK Both Application was submitted through Communities Unlimited and will be approved on a per class basis.
OR Both Approved for one credit hour for full completion of this course.
RI Both  
TX Both  
UT Both Approval valid through 8/2026.
VA Both Does not provide approval up-front but will consider applications on a case-by-case basis.
VT Both  
WA Both DW program approved for 3 credit hours for full completion of this course upon receipt of a completed training roster, with approval valid through 10/27/2025. WW program will allow the typical, 1-10 hours for full completion of this course, with approval valid through 11/2/2025.
WI Both Upon course completion, contact dwresilience@epa.gov for assistance submitting training roster per DNR instructions. Approval valid through 05/31/2025.
WV Both  
WY Both DW program will allow 5 hours for completion of the RRA and 10 hours for the ERP, for a total of 15 hours for full completion of this course. WW program will allow the typical, 1-10 hours for full completion of this course.

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Last updated on October 16, 2024