ADMINISTRATIVE ORDER ISSUED 12/7/05. ORDER STATES: BASED ON INFORMATION AVAILABLE TO EPA, THE SYSTEM SUBMITTED A WRITTEN COPY OF THE VULUNERABILITY ASSESSMENT ( VA ) TO THE EPA ADMINISTRATOR. THIS SUBMITTAL WAS MAILED ON JUNE 29, 2004. THE SYSTEM FAILED TO CERTIFY TO EPA THAT THEY HAVE COMPLETED AND/OR REVISED THE EMERGENCY RESPONSE PLAN ( ERP ) TO INCORPORATE THE RESULTS OF THE VULUNERABILITY ASSESSMENT ( VA ).