500 LEE STREET EAST - SUITE 1600 - PO. BOX 553 CHARLESTON. WEST VIRGINIA 25322 jl TELEPHONE: 304-340-IOW - TELECOPIER: 3W-340-I I30 rwvjockronkell~roni Direct Dial No. (304) 340-1251 Fax No. (304) 340-1080 e-mail: ccallas~jacksonkelly.com State Bar ID No. 5991 April 4,2016 Via Hand Delivery Ingrid Ferrell, Director .. Executive Secretary Division Public Service Commission of West Virginia 201 Brooks Street Charleston, WV Re: Case No. 14-0872-W-GI - West Virginia-American Water Company Dear Ms. Ferrell: Enclosed for filing are the Company's revised redactions, prepared in accordance with the March 28 Order. As these documents originated as data responses, we are providing one copy to you for that purpose. As a courtesy, we have enclosed a second set that the Commission may wish to use in responding to the pending FOIA request. We are also providing copies to counsel of record. Please date stamp the extra copy of this letter, and return it with our messenger. As always, we appreciate your assistance. istophe . Callas CLC/mrv a Enclosures c: Jacqueline Lake Roberts and Tom White, Esqs. (w/enc) William V. DePaulo, Esq. (wlenc) Paul R. Sheridan, Esq. (wlenc) Anthony J. Majestro, Esq. (wknc) Timothy C. Bailey, Esq. (wlenc) Jonathan Marshall, Esq. (w/enc) David A. Sade, Esq. (wknc) 0. Last Revised: August 2012 Original: November 1992 G10000001-0001 Highly Sensitive Confidential INDEX Policies List NUMBER SUBJECT 1:l Establishment Policies and Procedures 1:2 Chain of Command 1:3 Authority of Emergency Procedures 1:4 Relations with the News Media 1:5 Emergency Purchasing Policy 1:6 Security Plan Policy iI Highly Sensitive Confidential G10000001~0002 POLLCY 1:l Establishment of Policies and Procedures: The administration of a business enterprise, large or small, employs a vehicle of communication to inform its employees of management policies. Methods of communication have taken the form of memoranda, instructions, procedures, and correspondence. Policies establish guidelines within which an organization operates. Policies enable operating personnel to make decisions in recurring situations - with assurance that decisions will be consistent with objectives of the business. Procedures express how something is to be accomplished in accordance with established policy and are in much greater detail. They are always internally oriented and are not issued unless authorized by a policy. The separation of policy and procedure enables employees to more readily review and become familiar with the brief statements of policy without being encumbered by the more detailed related procedures. I G10000001~0003 Hiohlv Sensitive Confidential POLICY 1:2 Chain of Command: In the day-to-day operation of any organization, it is important to know who is in charge. If the Number One person is not available, who is the second in command? This concern is even more important during emergency operations. Confusion and potentially serious problems can result from lack of a clear understanding of who has what authority. If more than one person feels he/she is in charge, difficult conflicts occur. In emergency situations, there is no time for “turf wars” over authority or responsibility. Normally, the manager is in the command position. He delegates certain authority and responsibility fo management personnel, but he is still in charge. In the event that the manager is unable to command in a time of an emergency due to injury, illness, or being out of town, or any time where it is evident that the manager cannot fully participate in the quick decision making required by the disaster, the power of authority, delegation, and responsibility will go the next person in succession. _INOTE: Each district will establish a succession list (refer to Resource Section 3:’l). The order in which individuals are listed in Resource Section 3:l will dictate who would assume the command position. Hiahly Sensitive Confidential POLICY 1:3 Authoritv of Emergencv Procedures: The most vital life support of a community is its water supply system. There may be emergency situations such as floods, civil disorders, storms, earthquakes, severe cold weather, or other conditions requiring quick decisive action to minimize disruptions of service to the community. Emergencies have happened and can occur in the future. To assist employees, a manual has been adopted and identified as West Virginia- American Water Emeraencv Preparedness Manual. This manual is a guide for establishing appropriate actions to maintain service while involved in an emergency situation. It is the manager’s responsibility to make certain employees are fully aware of emergency procedures. Highly Sensitive Confidential POLICY 1:4 Relations With the News Media: The company’s relations with the news media will be very important during emergencies. It is essential that all statements released to the press be as accurate and consistent as possible. Therefore, to ensure news releases are consistent and accurate, onlv the SuDerintendent (next in succession if Superintendent is unable to fulfill his duties) or his designated representative will communicate to the news media. Whenever possible, news releases are to be in writing. This will ensure that all information released is known to the Superintendent and has been presented in the same format to all news media. Also, it is essential in dealing with news media representatives that all reporters are treated equally. Any information released must be available to all media. Highly Sensitive Confidential POLICY 15 Emersencv Purchasinsl Policv: Under normal circumstances and when feasible in an emergency situation, the West Virginia American Water will use established policies and procedures in purchasing goods and services needed for operation. In a disaster situation, purchases may take on a sense of urgency. Operational personnel may not have the time to go through normal checks and balances or to wait for deliveries from national suppliers. Therefore, all purchases deviating from normal purchasing procedures must be approved by the Superintendent or his designated representative. Highly Sensitive Confidential POLICY 1:6 Security Plan (Terrorism) 1.0 POLICY West Virginia-American Water (VIVAW) has committed to anticipate, evaluate, and manage risks by maintaining a crisis management program that emphasize prevention and effective emergency preparedness, response, and recovety. This commitment is essential to ensure that our customers receive a dependable supply of safe drinking water. This commitment cuts across all levels of the company, corporate headquarters, subsidiaries, local systems, and individual facilities. The WVAW crisis management program consists of planning, training, and exercising, as well as proactive coordination with the local jurisdictions with whom we contract to provide water supplies and Federal, State, and local regulators. In addition, our plan emphasizes vigorous outreach to our residential, institutional, and industrial customers. WVAW continually strives to improve our crisis and emergency management capabilities. We believe that by implementing these tools, we will be able to maintain operations in a responsible manner. 2.0 PURPOSE AND SCOPE All of WVAWs systems are subject to a variety of threats, from natural disasters to hazardous materials spills. Over the years, most of our systems have successfully dealt with incidents resulting from these threats and have effective response plans in place. However, over the past few years, a new menace has emerged, the threat of terrorism. This is an unfamiliar threat to most WVAW management and staff. Therefore, this program has been developed to help us deal with the risk. ~ ~ ~ ~ ...... i j I~ rmation i !L_,_._,_._,_._,__,_,_,.,~,~,~.~,~.~.....,~~........,~....,.,..~~,~.~,~~~~~.....~~....,~,.,~.......~....~...~.~.~~....,...~.~..~....~.~.........-....-.-..........-. Prevention is the first priority of all of WVAWs operations. However, despite our best efforts at security, incidents may still occur. Recognizing this, WVAW's policies and procedures are designed to rapidly detect and limit the negative effects of such incidents on our operations. The desired goal is a "seamless" crisis management structure with no gaps or inconsistencies. This structure has the capability to mobilize the full range of resources available to the company quickly and effectively, if required. Highly Sensitive Confidential G10000001L0008 3.0 CORPORATE OVERVIEW West Virginia-American Water is the largest investor-owned water utility in the state, its headquarters is in Charleston, WV. It serves the water needs of 160,000 customers from 9 water treatment facilities. 4.0 RESPONSIBILITIES AND AUTHORITIES Within WVAW, responsibilityfor emergency response, management support, and crisis ent is ganizational units, based on either r their to support response, or both. Acco delivery of safe water to our customers begins with the senior executives of the company and extends downward through staff and managers of districts, individual facility supervisors, and individual associates. Each has a role to play. A responsible individual within each WVAW drinking water syste ned principal responsibilityfor the coordination and accomplishment o role should be recognized by inclusion in the- of the assigned individual. At our small operating ctly initiate many of the planning tasks. Within our may be empowered to delegate responsibility for some The is at a level within the system that is commensurate with these important responsibilities. In some