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Home My WebLink About2020-01 Performance Audit Report: Contingency Plans at County of Hawai'i's Department of Water SupplyContingency Plans at County of HawaiTs Department of Water Supply March 3, 2020 Aaron S. Y. Chung Chair & Presiding Officer Council District 2 March 3, 2020 JNK�•�F .4k- i •. r�4rFvc'nasy W.AluItt of Pubjul"i Bonnie S. Nims, CGAP Legislative Auditor OFFICE OF THE LEGISLATIVE AUDITOR 25 Aupuni Street Hilo, Hawaii 96720 * (808) 961-8386 * Fax (808) 961-8905 website: h9ps:11hawadcouno�.gov e-mail: publiclao&hawaiicount gov The Honorable Aaron S. Y. Chung, Council Chairperson and Members of the Hawaii County Council Hawaii County Council 25 Aupuni Street Hilo, Hawaii 96720 Dear Chair Chung and Council Members, Business Address 120 Pauahi Street Suite 309 Hilo, Hawai `i 96720 In accordance with Hawaii County Charter Section 3-18(d)(2), attached is the Office of the Legislative Auditor's report of our audit of contingency plans at the Department of Water Supply (DWS). As requested by Hawaii County Council in Resolution 287-17, the purpose of our audit was to determine whether the DWS had adequate contingency plans to guarantee sufficient water supply to customers at all times, including during a disruption of deep water well. Since January 2017, up to five of DWS's deep water wells were intermittently in and out of service, restricting valuable water service to residents, businesses, and the public throughout North Kona. As described in the attached report, DWS should further develop and implement complete, detailed, and written contingency plans by district as well as update their Continuity of Operations Plan. If you need any further information, please contact me at 961-8386. We sincerely thank the staff of the Department of Water Supply for their assistance and cooperation during the audit process. We greatly appreciate all of their valuable time and efforts spent on providing us information. Respectfully, Bonnie S. Nims, CGAP Legislative Auditor Hawai `i County is an Equal Opportunity Provider and Employer cc: Harry Kim, Mayor Keith Okamoto, Chief Engineer, Manager Kawika Uyehara, Deputy Engineer/Manager Water Board Jon Henricks, County Clerk Hawai `i County is an Equal Opportunity Provider and Employer Report Highlights March 3, 2020 Contingency Plans at the County of Hawai`i's Department of Water Supply What was theam,, jre • - • purpose of this audit? As required by federal law, DWS developed the Since January 2017, up to Continuity of Operations Plan (COOP) (August 2010), five of DWS's deep water which addressed operational procedures of disaster wells were intermittently in events. DWS developed three contingency plans in 2017 and out of service, restricting when four wells became inoperable. valuable water service to residents, businesses, and We reviewed both the COOP and the contingency plans the public throughout North and found that DWS should improve their contingency Kona. plans. Specifically, the contingency plans should contain sufficient detail including prioritizing and clearly We conducted this documenting emergency procedure by district, describe performance audit to types and implementation guidance and types of water evaluate if the County's usage restrictions, as well as clearly documenting their Department of Water Supply communication procedures. Furthermore, DWS should (DWS) had adequate fully complete the COOP with vendor names and/or contingency plans to contact information. guarantee sufficient water supply to customers at all Department's management has generally agreed with times, including during a the comments and recommendations in this report. disruption of deep well Their complete response to this audit can be found on operations. page 15: Department's Comment. We initiated the audit on What • • we recommend? request of the Hawaii County Council (Resolution 287-17) To help ensure prompt resolution and communication to and numerous constituent the ratepayers of any future deep well operation concerns regarding repair disruptions, we recommend DWS improve their delays and water restrictions contingency and COOP plans to provide sufficient detail for the North Kona area. as described above in "What did we find" and as prescribed by best practices. A complete list of our recommendations can be found on page 14: "What do we recommend?" This audit was conducted in accordance with general accepted government auditing standards. This page intentionally left blank. Table of Contents Introduction...................................................................................................................1 Audit Objectives, Scope and Methodology................................................................. 3 AuditResults................................................................................................................. 5 Recommendations...................................................................................................... 14 Department's Comments............................................................................................ 15 Appendix A — Audit Criteria........................................................................................ 20 Appendix B — Operations Emergency Action Plan ................................................... 29 This page intentionally left blank. Introduction The Office of the Legislative Auditor conducted this performance audit of contingency plans at the County of Hawaii Department of Water Supply (DWS) pursuant to Section 3-18 of the Hawaii County Charter, which outlines the Office of the Legislative Auditor's primary duties. Performance audits typically examine the effectiveness, economy, or efficiency of a government program. They can include analyzing the services of a department or activity, identifying possible cost savings, identifying the outcomes achieved by a program, or comparing actual department practices against the practices called for in law or policy. Our objective in performance auditing is to improve public services provided by county government. We do this by recommending specific actions that will address the issues we raise and by providing valuable information to the public, the administration, program leadership, the Hawaii County Council, and the Mayor. Beginning in January 2017, four of the thirteen (31 %) North Kona deep wells were intermittently in and out of service. Although customers had access to water, water usage restrictions were advised. These deep wells were all located in the North Kona area along the North Kona Belt Road or Highway 180 along a stretch of road approximately 12 miles. Waiaha Deep Well (1,754 feet) r �Y IF Photo courtesy of the Office of the Legislative Auditor. Well was non -operational at time of photo. Because of the out of service wells, water restrictions were implemented affecting North Kona residents. Water restrictions ranged from a 10% voluntary, a 25% mandatory, and up to an emergency water restriction for essential use only such as hygiene, health, and safety usage. In October 2017, Hawaii County Council's Resolution No. 287-17 requested the Office of the Legislative Auditor to conduct a performance audit to ensure DWS had adequate contingency plans to guarantee sufficient water supply to customers at all times, including during a disruption of deep well operations. This resolution was co -introduced by Council Member Karen Eoff, Kona District 8 and former Council Member Dru Kanuha, Kona District 7. Department of Water Supply Contingency Plan Introduction I 1 Based on concerns from numerous effected, or possibly effected, County residents as well as the Council's request, the Office of the Legislative Auditor determined an audit of DWS's contingency plans was warranted. Department of Water Supply Contingency Plan Introduction 12 Audit Objectives The objective of the audit was to determine if the Department of Water Supply has adequate contingency plans to provide sufficient water to customers even during a disruption of deep well operations. Audit Scope and Methodology To accomplish our objective, we: • Developed an understanding of the policies, procedures, and processes; • Assessed compliance with applicable Federal Laws, Hawaii Revised Statutes, County of Hawaii Charter, County of Hawaii Code, and DWS's Rules and Regulations; • Compared DWS's performance, procedures, practices, and processes to recommended industry best practices; • Compared DWS's current continuity plan to recommended industry best practices; • Conducted site visits to observe current conditions of various deep water wells; • Corroborated information through interviews with appropriate personnel and reviewed documentation of controls such as inspection reports, monitoring logs, etc. ; • Reviewed Water Board Minutes to obtain an understanding of current work in process and progression of work conducted in deep wells; and • Reviewed additional documentation and information that pertained to deep well operations. We conducted this audit from October 2017 to August 2019. During the course of our audit, we requested and reviewed several plans provided by DWS. We reviewed these plans for any information related to contingency actions that addressed water shortages or water disruptions during non -disaster. We compared the available plans against local and federal plan requirements. In addition, we compared those plans to best practices including other water jurisdictions' contingency plans that addressed water shortages and disruptions during non -disaster. Several jurisdictions had both continuity and contingency plans in place that covered most any type of water emergency situations. We conducted this performance audit in accordance with general accepted government auditing standards. Those standards require that we plan and perform the audit to Department of Water Supply Contingency Plan Audit Objective, Scope and Methodology 13 obtain sufficient and appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. Our conclusions on the adequacy of contingency plans are detailed within this report. We sincerely thank DWS's staff for their assistance and cooperation during this audit. Department's management generally agreed with the comments and recommendations in this report. Their complete response to this audit can be found on page 15: Department's Comments. Department of Water Supply Contingency Plan Audit Objective, Scope and Methodology 14 Audit Results The Department of Water Supply should improve both their continuity and contingency plans to help guarantee sufficient water supply at all times, including during disruptions of deep well operations and to preserve public trust. Contingency and continuity plans are similar: they both require specific procedures in instances where things go wrong to allow for continuing operations. A continuity plan is a broader plan that includes steps on the prevention and recovery of operations in the event of a disaster. Whereas a contingency plan is a vital part of the continuity plan that helps organizational leaders prepare for all kinds of worst-case scenarios. In other words, contingency plans cover in -the -moment procedures in an emergency while a continuity plan covers how an organization will get up and running again. Best practices say that contingency plans should address specific criteria for the initiation and termination of water shortage stages. Plans should also include procedures on the initiation and termination of water shortage stages, procedures for notification and education of the public, and procedures for monitoring the situation during water shortage stages. DWS has several contingency plans as well as a continuity plan. However, DWS did not develop the contingency plans until four wells became inoperable in 2017. We reviewed these plans and found: 1. DWS's 2017 contingency plans should be improved including: a. Contingency plans should contain sufficient detail including prioritizing and clearly documenting emergency procedures. b. Plans should include emergency contingencies by district. c. Plans should describe types and implementation guidance of water usage restrictions. d. Plans should clearly document communication procedures. 2. Details of DWS's Continuity of Operations Plan (COOP) should be fully completed. Department of Water Supply Contingency Plan Audit Results 15 1. DWS's 2017 contingency plans should be improved. At the time several deep wells became inoperable in 2017, DWS did not have any written contingency plans. In response to increasing number of out of service wells, DWS developed and implemented three different contingency plans: • Kona Operations Initial Plan (June 02, 2017) A hand-written plan that contains instructions on procedures to take if two different scenarios exist. ➢ Scenario 1: Describes procedures if Kalaoa Well fails. ➢ Scenario 2: Describes procedures if Honokohau well or Kealeohu well failed. This scenario uses the same procedures as scenario one but with more "aggressive conservation measures" (No measures were stated). Department of Water Supply Contingency Plan Audit Results 16 • North Kona Response and Responsibilities Plan (July 13, 2017) (Figure 1) - Charts the Administrative and Operation divisions' processes in the event a fifth well breaks. North Kona Response and Responsibilities Plan Immediately Initiate DWS Kona Contingency Plan for Redirecting Water: Install Orifice Plates on Highest 101 (518") Dispatch Water Accounts Tankers to Pre- WSI ]Construction Determined Inspector(s): Locations Follow up on Initiate Expedited Reported Wasteful Manufacturing for Residential Usage OPS Pumps ] Motors Ops Immediately Suspend ! ops Evaluate and Temporary 1 OPSoPs Initiate Connection Irrigation 1 Agriculture 1 l to Makalei Golf Accounts OPSi oPs Course CUST SVC Event: Procure supplies Loss of Additional Source DPS! (bottled water, ADMIN Initiate Bid Docs etc_) for public4----ADMIN for Emergency consumption Repairs Purposes- ADMIN— Coordinate DMINCoordinate DWS Communications Notify Civil Defense and Emergency Meeting within 24 Mayor's Office Declaration Issue Emergency Water Restriction hours of Event. Notice via text, email, media (h+, radio. newspaper, press release, etc_) CD 1 Mayor! DWS NO Decide if County Emergency YES Reevaluate Declaration is necessary. need for rationing daily_ Monitoring DECIDE IF Issue Request shall continue Na— RATIONING IS for Assistance throughout NEEDED. � (RFA) event YES Is rationing needed? Initiate Rationing Plan YES Initiate Mobilize Rationing Plan —OPS--* Crews, Alert OPS DVVS Response Plan for the FoIloo.,iIng Edent: HPD & HFD Revised- 7+' 30D1 i Source: DWS Figure 1 Department of Water Supply Contingency Plan Audit Results 17 • Operations Emergency Action Plan (August 10, 2017) (See Appendix B) — Is a companion document to the "North Kona Response and Responsibilities Plan" (above) and describes internal communication procedures during an emergency, back-up water sources, and rotating shut-off implementation. We reviewed these three plans and found they did not provide detailed information (i.e., the "who, what, when, where, why, and how"), address emergency contingency plans by district, describe types of water restrictions and when restrictions should be implemented, or clearly document the Department's communication procedures. 1a. Contingency plans should contain sufficient detail including prioritizing and clearly documenting emergency procedures. Although DWS developed three contingency plans during the 2017 well breakdowns, they should contain detailed procedures for staff to follow. • Kona Operation Initial Plan - While the Kona Operations Initial Plan contains some step-by-step instructions, it does not contain sufficiently detailed information to ensure emergency procedures are completed efficiently. In addition, the Plan does not specifically include who is responsible, when these procedures should take place, or what aggressive conservation measures will be taken. Finally, as further described below in 1 c, the Plan does not define the different types of water usage restrictions. • North Kona Response and Responsibilities Plan - The North Kona Response and Responsibilities Plan (Figure 1) shows each process and procedure which occurs simultaneously. The Plan contains divisional responsibilities but it does not list the individual personnel responsible for each step or procedure, the timing or triggers for each step, the communications protocol, or any potential water usage restrictions. In addition, there are no references or instructions to refer to the companion document "Operations Emergency Action Plan". • Operations Emergency Action Plan - The Emergency Operations Action Plan (Appendix B) details the individuals responsible for duties but does not describe when to communicate, whom to communicate with, and what to communicate. Furthermore, the back-up water source and the rotating shut-off implementation sections only contain questions to be asked - it does not indicate the steps to take based on the answers to the questions. Department of Water Supply Contingency Plan Audit Results 18 Best practices include detailed information to ensure that appropriate individuals follow the procedures in the correct order for each type of disaster (e.g., droughts, water shortages, water disruptions). Without detailed procedures that prioritize and document a clear process flow (i.e., who is going to do it, when it should be done, and how to do it), emergency procedures may not be carried out efficiently. In addition, plans should include stages or levels that characterize triggers, procedures, types of water restrictions, and detailed procedures for each stage of an emergency. 1b. Plans should include emergency contingencies by district. While the three plans described above do address some of the procedures DWS should take during well failures, the plans only apply to the North Kona area — they do not address procedure by district. Without comprehensive procedures and clear guidance, managing water systems during emergencies may be inefficient and challenging for DWS staff. Best practices recommend a perpetual, formalized plan for quick reference during any type of impending or immediate disaster or disruption of water service occurring by district. Honokohau Deep Well (1,740 feet) x � ff- I� n- Photo courtesy of the Office of the Legislative Auditor. Well was non -operational at time of photo. 1c. Plans should describe types and implementation guidance of water usage restrictions. DWS has implemented three types of water restrictions while North Kona wells were nonoperational. The least serious being 10% voluntary water restriction where DWS requests the public to reduce their normal water usage. The next level of restriction is a 25% mandatory water restriction of the public's daily usage. Lastly, an Emergency Water Restriction Notice, which limits water usage to health and safety needs only. None of the plans included information on when DWS will implement water restrictions or the types of restrictions. Furthermore, the plans did not include detailed steps or communications procedures during impending or immediate disaster or disruption of water service. Without addressing water restrictions in their plans, DWS cannot consistently and effectively Department of Water Supply Contingency Plan Audit Results 19 reduce water usage or communicate restrictions to the public. Public trust may deteriorate without consistent implementation of these restrictions. 1d. Plans should clearly document communication procedures. The contingency plans prepared by DWS did not contain detailed procedures for ensuring timely communications or notices to the public during well failures. The plans did not include any why, when, who, or how they would notify the public when water shortages or disruptions occur. In addition, as mentioned above, there was no clear public definition for implementing the different levels of water restriction including what each restriction entailed. When developing communications procedures, DWS should consider the information that has the most impact to the public. For example, the San Diego Water Shortage Contingency Plan (August 2017) describes their ...when there is a need for urgent water conservation, people basically want to know the following-- 1. ollowing: 1. What they need to do — specifically— to save water 2. How much water they need to save and for how long 3. Why they need to save water 4. What water agencies are doing to correct the supply problem or address the situation experience from previous droughts and public opinion polls: Best practice examples clearly document their communication plans and included the "why", "when", and "how" their communications will be implemented to keep the public apprised of current situations. For example, the Seattle Public Utilities Water Shortage Contingency Plan has a "Public Message" template assigned to each plan stage. The San Diego Water Shortage Contingency Plan contains a section titled "Communication Plan" that outlines the coordination, key audiences, communication objectives, and various strategies and tactics. Finally, the Yucaipa Valley Water District Water Shortage Contingency Plan has suggested communication actions for each stage including sample press releases and suggests monthly billing reminders to conserve water. (See Appendix A) Department of Water Supply Contingency Plan Audit Results 110 During the time the wells were inoperable, DWS held numerous engineers' brainstorming meetings to help develop contingency plans and procedures. While DWS did complete three contingency plans in 2017, they were unaware of the level of detail that should be included in complete contingency plans. DWS should have a detailed, written, contingency plan by district. The plan should be specific to include the "why" (the purpose of the policy), "who" (is responsible), "what" (conservation measure will be taken), "when" and "how" (the procedures that should take place). In addition, the plan should address each type of water usage restriction (including criteria, timing, and procedures for implementation) and the notification and communication procedures for each water usage restriction. 2. Details of DWS's Continuity of Operations Plan should be fully completed. As described above, a continuity plan is prepared to ensure that essential operations can be performed during an emergency that may disrupt normal operations during disasters. The plan should establish policy and provide clear guidance of essential functions and direct the reallocation of personnel and resources. DWS hired a contractor to complete their Continuity of Operations Plan (COOP) (August 2010). This plan was prepared under a grant from the Federal Emergency Management Agency's (FEMA) grant programs and in accordance with direction from Homeland Security Presidential Directives, Federal Continuity Directives, and Continuity Guidance Circular 1 (CGC 1). FEMA also requires the organization to conduct and document a risk assessment at least every five years. The COOP provides a framework in which local government, along with its officials, departments, agencies, offices, and other governmental entities, can plan and perform their respective functions during a disaster or national emergency. County of Hawaii Department of Water Supply's COOP includes essential operations and functions that must be performed, or quickly resumed in a disaster or national emergency. While the impact of these emergencies cannot be predicted, planning for operations under these conditions may lessen the impact of the emergency on people, facilities, and services. The COOP lists critical vendors and contact information for some essential functions such as information technology, accounting, and payroll (Figure 2). However, several of the essential functions display "None" or "N/A" for the vendor names and contact information. Without this information, it would be difficult to facilitate quicker response time during water disruptions. Department of Water Supply Contingency Plan Audit Results 111 DWS COOP Plan Table of Essential Functions with Vendor Information 'Fable 10 Critical Vendors VENDORSCRITICAL 71 Management None NIA NIA Maintenance and repair of None NIA NIA lines, hydrants and valves Maintenance of wells and pumps None VA NIA and repairs Information technology oceanic Times Warner Internet Service Hawaii Telcom IF Phone Service Maintenance and repair of None WA WA vehicles Water al' Various Various Various unlit testingsupplies Radio and telecommunications None WA NIA En ineerin Nane P+VA NIA Payroll and accounting Harris Computer Systems Accounting and Billing Systems Meter reading and billing Harris Computer Systems Accounting and Billing Systems CNlections and cashiering Harris Computer Systems Accounting and Billing Systems Source: DWS COOP Plan Figure 2 A Federal Government guideline for developing a continuity plan is to conduct a business process analysis to identify and document all elements necessary to perform essential functions. This analysis identifies functional processes, workflows, activities, resources, personnel expertise, supplies, equipment, infrastructure, systems, data, and alternate locations in the execution of each essential function. (See Appendix A.) In addition, best practice examples include criteria for each water shortage stages and or levels of alerts, warnings, severe and critical water shortage emergencies. Some also include detailed objectives, triggers, public communication, and operating actions during each stage or level. Without a detailed, written continuity and contingency plan, communication to the public, as well as public trust, may have suffered. Without detailed, written continuity and contingency plans that outline emergency procedures for alerting, notifying, activating, and deploying personnel, identifying essential functions; establishing a continuity facility; and identifying personnel with authority and knowledge of these functions, communications to the public and public trust may have suffered. Department of Water Supply Contingency Plan Audit Results 112 During a Community Forum at the West Hawaii Civic Center on July 20, 2017, the audience expressed concern on both the deep well functionality and DWS's communication efforts. A West Hawaii Today article on July 23, 2017, published some of the public's concerns regarding the deep well status: Examples of public concerns: "They've been trying to communicate, but I don't know if they've been doing as good as they could have" "I wanted to get a basic understanding of why the problem occurred and what mitigating measures are being taken to reduce future risk..." (When asked of D WS's communication efforts) No'; "Not at all. There's just a few signs on the road. If you aren't on social media, if you aren't listening to the radio or reading the paper then you may be completely oblivious. If you're a visitor you're going to be completely oblivious Source: Concerned residents sound off at water meeting, West Hawaii Today, by Max Dible, July 23, 2017 Without sufficient communication, public trust can erode. The City of Santa Cruz Water Shortage Contingency Plan (March 2009) makes a point on the importance of communication: Effective communication is essential to the success of any water shortage contingency plan in achieving the desired water use reductions. All customers need to be adequately informed about water supply conditions, understand the need to conserve, and know what actions they are being request or required to take to mitigate the shortage. The Water Department naturally assumes a central role in publicizing the extent of the water shortage problem and in advising and assisting customers to conserve. The more severe the shortage, the more vigorous the public information campaign will need to be. Department of Water Supply Contingency Plan Audit Results 113 The Department of Water Supply should improve both their continuity and contingency plans to help guarantee sufficient water supply at all times, including during disruptions of deep well operations, and to preserve public trust. This audit recommends the Department of Water Supply address the following recommendations: Develop and Implement a Complete Contingency and Communication Plan by District We recommend the Department of Water Supply develop a written contingency plan by district to address emergency situations to mitigate potential impact on any community. Or, at a minimum, include contingency plans that address important risk scenarios into their existing Continuity of Operations Plan. We further recommend the Department of Water Supply develop and implement a communications plan to notify the public, administration, stakeholders, and all governmental agencies that rely on information that may affect them or a community. The plan should include but not limited to timely notices and updated status of water events and holding community public meetings timely. Update Continuity Operations Plan We recommend the Department of Water Supply update their Continuity of Operations Plan (COOP) to include essential vendor contact information to ensure that quick reference information is accessible and available during emergencies. Department of Water Supply Contingency Plan Audit Recommendations 114 Department's Comments DEPARTMENT OF WATER SUPPLY CDU NTY OF HAWAII 345 KEKl1ANAi5'A STREET, SUITE 20 HILO, HAWAI'196720 TELEPHONE (808} 961-8050 - FAX(808)961-8657 February 26, 2020 Ms. Bonnie S. Nims Office of the Legislative Auditor Attention; Ms. Maxinne Pacheco 120 Pauahi Street, Suite 309 1 silo, I-II 96720 Dear Ms. Nims: Subject: Rcspanses to Legislative Auditor's report "Contingency Plans at County of Hawaii's Department of Water Supply, undated" 1'he Office of the Legislative Auditor's draft report for the Department of Water Supply (DWS) was reviewed. In general, the DWS agrees with the audit report and recommendations. DWS recognizes that this experience and audit report provides an opportunity to improve on DWS' operations, contingency planning and communication methods. The DWS reiterates that all North Kona customers were supplied with potable water during 2017 when issues with the wells were being experienced. The following ar-- DWS' comments to the draft audit report. Page ,# Paragraph # Report Statement DWS' Response 1 4'h "Beginning in January Statement that water "access" was 2017, .-restricting valuable restricted to residents, businesses, water access to residents, private and public services is not businesses. private and entirely true. Customers had "access" public services." to water. During the water restriction period, DWS requested water be used for stealth and safety needs only. t 2"`l "Audit Scope and Reference to DWS Rules and Methodology" Regulations 3-2 should be included. This explains DWS' role in providing water, it also explains DWS' right to limit water usage, in case its necessary. ... Water, Our 94ost Oecious �Rgsource ... 9it rW40 ?Gine. . The Department of MW Supply Is an Equal Opporlunav provider and employer. Department of Water Supply Contingency Plan Department Comments 115 Ms. Bonnie S. Nims Page 2 February 26, 2020 Page # Paragraph # Report Statement DWS' Response 3 (cont.) 2°1 (cont.) "Audit Scope and 3-2 (1) ...."The Department further Methodology" (cont.) disclaims all warranties, expressed or implied, and reserves the right to shut off water mains for repairs, extensions, alterations, termination of water service as provided herein, for conservation measures, and for other reasons deemed by the Board to be necessary and proper, without notice. 3-2 (2) Whenever, in the Department's opinion, special conservation measures are advisable in order to forestall water shortage and a consequent emergency, the Department may restrict the use of water by any reasonable method of control. The Department shall also have the right to limit the quantity of water taken from any of its facilities, including but not limited to temporary standpipes, outlets and hose bibbs. In determining the priorities in restricting the use of water, the health and safety of the public shall be given first consideration over other uses. 5 T .aA 1. DWS's 2017 contingency la. Contingency plans for smaller plans should be improved water systems are documented and including: have heen used in prior occasions_ a. Contingency plans should 1c. & d. Levels and triggers for water contain sufficient detail usage restrictions and communication including prioritizing and procedures will be reviewed and clearly documenting updated. emergency procedures. Department of Water Supply Contingency Plan Department Comments 116 Ms. Bonnie S. Nims Page 3 February 26, 2020 Page # Paragraph # Report Statement DWS' Response 5 (cont.) Last (cont.) c. Plans should describe 2. Details of Continuity of Operations types and implementation Plan (COOP) will be reviewed and guidance of water usage updated restrictions. d. Plans should clearly document communication procedures. 2. Details of D W S's Continuity of Operations Plan (COOP) should be fully completed. 6 "Scenario 2" This scenario uses the same More "aggressive conservation procedures as scenario one measures" could have included but with more "aggressive increased communication to existing conservation measures" (No customers or increased patrols of measures were stated). neighborhoods to enforce the water restrictions. We reviewed these three Although the auditors assert plans and found they did not inadequate "who, what, when, provide detailed information where", basic details are included in (i.e., the "who, what, when, any of the three (3) plans. The where, why, and how"), contingency plans should be general address emergency in nature and allow for flexibility to contingency plans island allow staff to determine the wide, describe types of appropriate and most prudent water restrictions and when response for that event. restrictions should be implemented, or clearly document the Department's communication procedures K la. Kona Operation Initial Remove reference to Figure I. Plan 8 I a. North Kona Response Revise reference to Figure 2 to refer and Responsibilities Plan — to Figure 1. "The Plan contains This response plan purposefully listed divisional responsibilities, responsibilities by DivisionlPosition but it does not list the Title versus individual individual personnel people/personnel as during an responsible for each step or emergency DWS will be looking for procedure, the timing or available manpower in each triggers for each step" respective Division to assist versus an individual position. Department of Water Supply Contingency Plan Department Comments 117 Ms. Bonnie S. Nims Page 4 February 2b, 2426 Page # Paragraph # Report Statement DWS' Response 8 la. Operations Emergency The scenario of rotating shut-off Action Plan — "Furthermore, areas was contemplated but not fully the back-up water source developed and coordinated with other and the rotating shut-off agencies. implementation sections These measures were contemplated only contain questions to be for an emergency event like a main asked - it does not indicate break or structure fire, not because of the steps to take based on concerns of supplying water normally the answers to the to customers. questions." 9 1 C Plans should describe types Levelsitriggers for water usage and implementation restrictions will be reviewed and guidance of water usage updated. restrictions. I t.l I d Plans should clearly Communication procedures wil l be document communication reviewed and updated. procedures. 1 1 1.41 While DWS did complete DWS internally discussed three contingency plans in contingency plans for North Kona in 2017, they were unaware of early 2017 when problems with the the level of detail that should wells were experienced. Primary be included in complete mission is to ensure water service to contingency plans. DWS customers were maintained. should have a detailed, Contingency plans were in place, written, island wide through verbal discussions, contingency plan. organi7ational history and infrastructure designs and not in a formal written format. These procedures were successful as Operations handled the situation and adjusted the system to maintain adequate supply. This provided staff with learning experiences and opportunities to reduce or modify the critical situation in a reasonable timeframe. Details of DWS's Continuity Details of Continuity of Operations of Operations Plan should be Plan will be completed. fully completed. Department of Water Supply Contingency Plan Department Comments 118 Ms. Bonnie S. Nims Page 5 February 26, 2020 Page # Paragraph # Report Statement DWS' Response 14 ?nd Develop and Implement a Contingency and communication Complete Island Wide plans will be reviewed and updated. Contingency and DWS has procured a consultant to Communication Plan. conduct a Risk and Resiliency Upda=e Continuity Assessment and Emergency Operations Plan Response Plan (update) as required by the American Water Infrastructure Act of 2018. As required, this Assessment shall be reviewed and certified or updated every 5 years. DWS is also working with Hawaii County Civil Defense on the County's update of the Hazard Mitigation flan. Evaluations and analyses from these efforts should be coordinated and used to also update DWS' contingency plans and Continuity of Operations Plan. Should you have any questions please contact Mr. Kawika Uyehara at (808) 961-8050. Sincerely yours, Keith K. Okamoto, P.E. Manager — Chief Engineer KKU:drnj Department of Water Supply Contingency Plan Department Comments 119 Appendix A: Audit Criteria What are the Federal standards or guidelines for continuity plans? U.S. Department of Homeland Security Federal Emergency Management Agency Federal Continuity Directive 1, Issue Date: January 17, 2017 states: Annex B: Essential Functions ...3. Conduct a BPA (Business Process Analysis) to identify and document all elements necessary to perform essential functions. The BPA must: a. Identify and map the functional processes, workflows, activities, resources, personnel expertise, supplies, equipment, infrastructure, systems, data, and alternate locations inherent to the execution of each essential function; and, ... What are some best practices for contingency plans? ➢ Rancho California Water District Water Shortage Contingency Plan: In summary, a section of this plan contains criteria for five water shortage stages and they are as follows:. • Stage 1 —Water Supply Watch Criteria:... customers are requested to continue to use water efficiently, maximize recycled water use, and practice sensible voluntary water conservation... • Stage 2 — Water Supply Alert Criteria: There is a probability that the district may not be able to meet all of the water demands of its customers. ... Imported water supply shortages are expected. Additional voluntary use reduction measures will be called upon during this stage. Some nonessential outdoor water -use restrictions in the residential, commercial, and agricultural sectors may be implemented • Stage 3 — Water Supply Warning Criteria: Water supply shortages (local or imported) for the District are expected to continue and possibly worsen, or the District is mandated by a state or federal regulatory agency with jurisdiction over the District to reduce water use.... Some restrictions on certain non-essential outdoor residential, commercial, agricultural, and landscape water use will be implemented. ... Allocation surcharges, monetary assessments and/or fines for non-compliance of restrictions will be imposed. Department of Water Supply Contingency Plan Appendix A 120 • Stage 4: Extreme Water Supply Warning Criteria: Water supply shortages (local or imported) are expected to worsen, or the District is mandated by a state or federal regulatory agency with jurisdiction over the District to reduce water use... If Stage 4 is the result of an extended drought and has been triggered by Condition No. 1 of Section 2 of this WSC Plan, The District will explore increased incentives for implementation of demand management measures that will have immediate and substantial impacts on water demands... More severe restrictions on non-essential outdoor water use will be implemented... Significant Allocation Surcharges, monetary assessments, and/or fines for non-compliance of such restrictions will be imposed. • Stage 5 — Water Supply Emergency Criteria: Water supply shortages (local or imported) are expected to worsen, or the District is mandated by a state or federal regulatory agency with jurisdiction over the District to reduce water use... or may be as a result of an emergency situation resulting in the inability of the District's water distribution system to deliver all of the District's supply. Restrictions on all non-essential outdoor and indoor water use will also be implemented. The District will work to achieve an appropriate balance of water budget decreases to all customer classes as water shortages increase. Allocation Surcharges, monetary assessments and/or fines for non-compliance of such restrictions will be imposed. ➢ San Diego County Water Authority Water Shortage Contingency Plan August 2017: The Water Authority's Water Shortage Contingency Plan (WSCP) includes six distinct levels of potential shortage, along with "normal" conditions when no out - of -the -ordinary water -saving actions are called for. It also includes a "catastrophic" condition when extreme events prompt emergency -oriented water - saving measures to preserve supplies for health and safety. It's possible for the desired scope of water -saving actions or outcomes to vary widely at each level of the plan. In addition, their plan contains several potential communication strategies and tactics that can be deployed to help the Water Authority successfully implement each level of the WSCP. In Section 9, Communication Plan includes: • Level 1 Strategies and Tactics: This section lists a number of strategies the Water Authority has used to guide successful drought response campaigns in the past and should be considered during Level 1 of the WSCP (up to 10 percent voluntary conservation)... • Level 2 Strategies and Tactics: In the event of a more severe supply shortage or demand management period that requires entering Level 2 of Department of Water Supply Contingency Plan Appendix A 121 the WSCP (up to 20 percent mandatory conservation), the Water Authority will continue to deploy or enhance Level 1 strategies and tactics as needed, and will consider supplemental strategies and tactics... • Level 3-4 Strategies and Tactics: In the event of a more severe supply shortage or demand management period that requires entering Level 3 or 4 of the WSCP (up to 30 percent or 40 percent mandatory conservation, respectively), the Water Authority will continue to deploy or enhance Level 2 strategies and tactics as needed, and will consider supplemental strategies and tactics... • Level 5-6 Strategies and Tactics: In the event of a situation that requires entering Level 5 or 6 of the WSCP (up to or greater than 50 percent mandatory conservation, respectively), the Water Authority will continue to deploy or enhance Level 3-4 strategies and tactics as needed, and will consider supplemental strategies and tactics... to reflect increased shortage conditions... • Catastrophic Shortage Communications: In the event of a natural disaster, infrastructure failure or other situation that requires regional water use to be quickly prioritized for or limited to essential public health and safety needs, the Water Authority will immediately deploy or enhance appropriate communication strategies and tactics from WSCP Levels 1-6 as needed, and will consider strategies and tactics... to reflect the need for urgent, emergency -driven water conservation... ➢ Seattle Public Utilities Water Shortage Contingency Plan July 2006: In the Introduction section, it states: "This plan provides guidelines for Seattle Public Utilities (SPU) to manage water supply and demand in the event of a supply problem. Such problems could include imminent supply disruptions resulting from a major pipeline failure as well as forecasted water supply shortages due to droughts. "Water shortage" as is discussed in this document means that SPU will not have the normal amount of water to provide to its customers. It is extremely improbable that SPU would ever run out of water. The stages noted in the plan will be implemented depending on the magnitude of the water shortage. This document supplements the 2007 Water System Plan, and updates the April 2001 Water Shortage Contingency Plan (WSCP). In this plan, section 3 explains the different phases of their Curtailment Plan. In summary, we note the following contents of their plan: • Advisory Stage: o Overview: The public is informed as early as meaningful data are available that a water shortage may occur. Department of Water Supply Contingency Plan Appendix A 122 o Objective: Prepare the Department, City, relevant agencies and water users for potential water shortage thereby allowing all parties adequate planning and coordination time. o Triggers: There are a variety of weather and other conditions that may cause concern about water availability and a potential water shortage. SPU will enter the "Advisory Stage" if supply conditions and supply forecasts raise significant concerns about the utility's ability to meet supply needs later in the year. In addition, it addresses Public Message, Communication Actions, and Operating Actions during this Advisory Stage. • Voluntary Stage: o Overview: If supply conditions worsen, the plan moves to the Voluntary Stage which relies on voluntary cooperation and support of customers to meet target consumption goals. During this stage, specific voluntary actions are suggested for both residential and commercial customers. o Objectives: Take necessary supply management actions to further stretch available supply; Maintain or reduce demand to meet target consumption levels by customer voluntary actions; Forestall or minimize need later for more stringent demand or supply management actions; Minimize the disruption to customers' lives and businesses while meeting target consumption goals; and Maintain the highest drinking water quality standards throughout the shortage. o Triggers: The "Voluntary Stage" will be implemented when one or both of the following factors applies: 1) supply conditions have not improved, or have worsened, 2) demand levels need to be reduced given supply conditions. Public Message, Communication Actions, Operating Actions, and Supply and Demand Management Actions are also addressed like the Advisory Stage above. • Mandatory Stage: o Overview: If the Voluntary Stage does not result in the reduction needed, or supply conditions worsen, the Mandatory Stage would be implemented. This stage prohibits or limits certain actions, and may be accompanied by an enforcement plan which could include fines for repeated violation. o Objectives: Achieve targeted consumption reduction goals by restricting defined water uses; Ensure that adequate water supply Department of Water Supply Contingency Plan Appendix A 123 will be available for the duration of the situation to protect public health and safety and to balance the need for stream flows for instream resources, including fish habitat; Minimize the disruption to customers' lives and businesses while meeting target consumption goals; Maintain the highest drinking water quality standards throughout the shortage; and Promote equity among customers by establishing clear restrictions that affect all customers. o Triggers: The "Mandatory Stage" will be implemented if supply conditions have not improved, or the level of demand needs to be further reduced. Public Message, Communication Actions, Operating Actions, and Supply and Demand Management Actions are also included. • EMERGENCY CURTAILMENT STAGE: o Overview: This stage addresses the most severe need for demand reduction and includes a combination of mandatory measures and rate surcharges. This would be used as the last stage of a progressive situation, such as a drought of increasing severity, or to address an immediate crisis, such as a facility failure. o Objectives: Strive to meet the water use goals established for this stage, recognizing that customers' lives and businesses may be significantly impacted in order to achieve necessary water savings. o Triggers: The water savings needed to ensure sufficient water is available for public health and safety throughout the water shortage are not being achieved, or conditions have worsened, therefore, more stringent measures are needed. This stage also addresses Public Message, Communication Actions, Operating Actions, and Supply and Demand Management Actions. ➢ Salt Lake City Department of Public Utilities 2004 Water Conservation Master Plan: Water Shortage Contingency Plan: To summarize parts of the plan, Section VII: Stages and Responses state that "This Plan provides for five Water Shortage stages and responses of increasing severity, as progressively more serious conditions warrant. The triggering criteria described are based on the projected percentage of water available from a number of sources, including, but not limited to snow pack, soil moisture, surface water, ground water, stored water, and spot market water. Degrees of flexibility have been built into this Plan to allow for timely adjustments at all levels of planning and implementation. Key elements of a successful demand management program are that the resources and hardships are shared as Department of Water Supply Contingency Plan Appendix A 124 equitably as possible, and that customers are kept informed about the status of the shortage. The five stages are characterized as follows: • STAGE 1—ADVISORY Stage: the public is informed as early as meaningful data are available that a possible shortage may occur. • STAGE 2—MILD Stage: this stage is initiated if supply conditions worsen and relies on voluntary cooperation and support of water customers to meet target consumption goals. During this stage, specific voluntary actions are suggested for all customers, and specific mandatory actions are identified for municipal customers, including parks, golf courses, schools, and other government facilities. • STAGE 3—MODERATE Stage: this stage is to be initiated if the Mild Stage does not result in the reduction needed, or circumstances warrant its initiation as specified in Section V: Initiation. This stage increases the prohibition or limitation of certain actions and relies on both voluntary and mandatory actions. • STAGE 4—SEVERE Stage: this stage is to be initiated if the Moderate Stage does not result in the reduction needed, or circumstances warrant its initiation as specified in Section V: Initiation. The Severe Stage has increasingly stringent prohibitions and limits on certain actions, including certain mandatory actions for residential and commercial customers. • STAGE 5—CRITICAL Stage: this stage addresses the most critical need for demand reduction and increases the number of restricted water uses and mandatory actions. This could be used as a stage of a progressive situation, such as a drought of increasing severity, or to address an immediate crisis, such as a facility failure. In summary, the plan explains each of the five stages, addresses Triggers, Objectives, Response, Target, and Termination of Stage. ➢ City of Santa Cruz Water Department Water Shortage Contingency Plan March 2009: This report is a best practice that demonstrates a five stage structure to their water shortage contingency plan. A copy of the table is shown below. Department of Water Supply Contingency Plan Appendix A 125 Table ES -1. Five Stage Structure to Water Shortage Contingency Plan Stage Magnitude of Water Shortage Stage Title 1 0-5% Water Shortage Alert 2 5-15% Water Shortage Warning 3 15-25% Water Shortage Emergency 4 25-35% Severe Water Shortage Emergency 5 35-50% Critical Water Shortage Emergency Source: Santa Cruz Water Shortage Contingency Plan ➢ Yucaipa Valley Water District Water Shortage Contingency Plan adopted June 15, 2011: This best practice of a water shortage contingency plan states in Section 4 — Phased Curtailment Plan: "The Water Shortage Contingency Plan provides four stages of response based on increasing severity, as progressively more serious conditions warrant. This type of response would be appropriate to apply to a summer drought or other water service disruption. The four stages include a variety of communication, internal operations, and supply and demand management strategies as appropriate, and are characterized as follows: • Advisory Stage — The public is informed as early as meaningful data are available that a possible shortage may occur. • Voluntary Stage — If supply conditions worsen, the plan moves to the Voluntary Stage, which relies on voluntary cooperation and support of customers to meet target consumption goals. During this stage, specific voluntary actions are suggested for both residential and commercial customers. • Mandatory Stage — If the Voluntary Stage does not result in the reduction needed, the Mandatory Stage prohibits or limits certain actions. This stage would be accompanied by an enforcement plan, which could include fines for repeated violation. • Emergency Curtailment — This addresses the most severe need for demand reduction and could include a combination of mandatory measures and rate surcharges. This could be used as the last stage of a progressive situation, such as a drought of increasing severity, or to address an immediate crisis, such as a facility failure." Department of Water Supply Contingency Plan Appendix A 126 In summary, this water shortage contingency plan contains similar curtailment stages to other best practice noted in this criteria section of our report. ➢ Seattle Parks and Recreation Water Shortage Contingency Plan Revised March 2005: This plan is another example or best practice of water shortage contingency plan that provides phased curtailment plan. There are four stages of response based upon increasing severity, as progressively more serious conditions warrant. We summarized the plan as follows: • Advisory Stage — Objectives include: to prepare the Department, City, relevant agencies and water users for potential water shortage thereby allowing all parties adequate planning and coordination time; to undertake supply management actions that forestall or minimize the need later for more stringent demand or supply management actions. Also included were two triggers, a short public message, communication actions and internal operating actions to be implemented during this stage. • Voluntary Stage — Objectives include: to maintain or reduce demand to meet target consumption levels by voluntary actions, to forestall or minimize need later for more stringent demand or supply management actions; to minimize disruption to Parks' projects and programs while meeting target consumption goals; to minimize impact on revenue producing programs; and to continue use and maintain valuable assets. Also, included were two triggers, a short public message, communication actions, and internal operating actions to be implemented during this stage. In addition, other departments are listed along with action procedures for some types of existing programs. • Mandatory Stage — Objectives include: to achieve targeted consumption reduction goals by restricting defined water uses; to protect public health and safety and ensure survival of valuable assets; to minimize disruption to Parks' projects and programs while meeting target consumption goals; and to minimize impact on revenue producing programs. Also included was a short description of triggers and public message, communication actions, and internal operating actions to be implemented during this mandatory stage. In addition, descriptions similar to the voluntary stage was included. Emergency Curtailment — At this stage, SPU recognizes that a critical water situation exists. Without additional significant curtailment action, a shortage of water for public health and safety will be imminent. No prior emergency in the Seattle water system's history fits this description. This stage is characterized by two basic approaches. More information can be Department of Water Supply Contingency Plan Appendix A 127 found at: https://www.seattle.gov/Documents/Departments/ParksAndRecreation/PoliciesPlanning/ PI anWaterShortage.pdf Department of Water Supply Contingency Plan Appendix A 128 Appendix B: Operations Emergency Action Plan Operations Emergency Action Plan — plan modified for Kona Well Emergency on 20170810 Emergency occurs — share news & updates with who? Internal & Immediate (after hours and weekends — 76% of every week): • Electricians �, Electrician Supervisor — only if help required • Operations Management — Baseyard S Hilo—.= (Electrician) determination if to involve ME If no water areas, and many trouble calls keeping staff from fixing problem, District Supervisor has discretion on assigning additional staff to answer emergency calls. During large emergencies Hilo Baseyard staff may be on-call or called in to assist. • Administration — Manager— or Deputy— and their discretion for PR Internal & normal office hours: Engineer Division . Can call= if he needs to pull plans for planning purposes. Finance Division & Customer Service continue to keep customer service staff informed of possible outage and extend of issue. Administration will follow triage flow chart on who to inform (Handout: "Event: Loss of Additional Source") What: Back-up water source: • Water buffalo — from baseyards. 3 small (400 gallon) tanks on trailers are stored with safe and sampled water and these can be mobilized and placed into service quickly. "Baseyard staff authorized to haul & operate" list would need to be generated and maintained. Drive -time from other districts would need to be factored in prior to mobilization. These are typically not mobilized, but have fresh water replaced and are sampled every 2 weeks. • ACR Contract hauler. Will take at least 2 hours from Hilo to Kona, plus time for driver to modify schedule and pack for 12 hour shift. First tanker load will need to be filled in Hilo @ baseyard and sampled by micro -lab for pathogen test. This may involve Microlab staff being on-call for reporting to baseyard for sampling. Hilo baseyard would need to be opened and tanker filled. If second truck mobilized, also need to have that filled and sampled. Potential future wish list would be to purchase a tanker (with emergency preparedness funds) to have DWS tanker available for emergencies? • Spigots in nearby neighborhoods where water connected. Should we be tracking water consumption by installing meters on these temporary spigots? If not a lot of use, move to higher need area? Typically, these are directly connected to fire hydrant with adapters and terminate with a hose bibb. If we do not currently have units configured at each baseyard that are ready to go, configure one for every field track with backflow prevention device? Hydrant adaptor, backflow device, meter, spigot, could potentially install orifice on meter to reduce maximum flow and protect users. Note, whoever connects to hydrant should smell and taste to confirm no contamination... Also, consider purchasing or making portable signs saying "potable water station ahead" that can fit inside our sign bases. Department of Water Supply Contingency Plan Appendix B 129 Operations Emergency Action Plan — plan modified for Kona Well Emergency on 20170810 What: Rotating Shut-off implementation: • Who will be mobilized and what timing? Can we logistically warn people 24 hours in advance? Planned for 8 am start time. • Set up sawhorses with plywood sign outside subdivision. Inform area prior to shutting off so they may store water for drinking and flushing? Electronic signs at entrances to subdivisions? • Share FEMA Emergency Supply List, other handcarry notices drafted & shared earlier? • Share "Modified hand carry for water shut off' — turning off pumps as necessary. Refer questions to baseyard or main office? Share "Modified hand carry for water service restoration" at same time as shut off? • Expect assistance from Civil Defense and other county staff if this situation occurs. Additional assistance? • When would union contracts allow assistance from non-union workers? When could we request assistance from Public Works or Wastewater county staff? Could we hire near -by DSO to assist (Pural, Hawaii Water or AquaEngineers)? Could RCAC or HRWA staff help with informing about water shut -offs? Could fire protection staffing or civil defense assist in some of these efforts? (Note -Names of DWS Personnel were redacted from original document) Department of Water Supply Contingency Plan Appendix B 130