criteria and framework selection for managing risks to ... · utility participants agreed that...

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Briefing Note

Criteria and Framework Selection for Managing Risks to

Surface Water Supplies Karen Setty, Jennifer Heymann, Robert Raucher, Robert McConnell, Jamie Bartram

Water utilities often face various risks to their sources of drinking water supply. A new study is underway to help US drinking water suppliers prioritize and manage these risks.

September 2018

Background

Proactive risk management planning for drinking water safety represents an innovative approach applied in countries such as the UK, Canada, and Australia to help protect public health. A growing body of evidence suggests these programs are associated with water quality, compliance, operational performance, public health, reputational, and financial benefits. Still, a number of barriers have limited their application in the US. Such programs are not required in the US, although similar voluntary standards (e.g., AWWA/ANSI J100 and G300) exist. Since regulatory compliance is a major driver for US utilities, broader efforts at disseminating source water risk management programming are often limited by resource or other constraints. This project seeks to improve on the Source Water Assessment Programs (SWAPs) required by the 1996 Safe Drinking Water Act (SDWA) amendments by moving beyond risk identification toward prioritization and active risk management, specifically for surface water sources in mixed-use watersheds. It combines systematic investigation of risk management frameworks and tools in use by the water sector, with guidance development, utility pilot testing, and evaluation. This report summarizes the objectives and key outcomes of a facilitated workshop held May 3, 2018 at the University of North Carolina at Chapel Hill. The workshop supported the tailored collaboration between the Water Research Foundation (WRF) and Tampa Bay Water: “Evaluation of Risk Management Frameworks and Tools and their Application for Managing Source Water Risks in the United States” (project 4748).

Briefing Note: Framework Selection for Managing Risks to Surface Water Supplies

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Workshop Format The workshop nested within a two-year research project having four separate six-month phases (Figure 1). It took place at the beginning of phase II as an opportunity to share and validate findings from phase I, vet key issues, and establish consensus around future directions.

Figure 1. Schematic illustrating four project phases of six-months each Objectives of the workshop were to:

Facilitate interaction among all project participants, providing an opportunity for both structured and open dialogue;

Share key insights from the first project phase, including the literature review, survey of participating utilities, interviews with external utility practitioners, and the criteria applied to rank applicability of potential risk management frameworks;

Participate in hands-on exercises to increase understanding of how risk management approaches apply to surface water sources;

Reach consensus on which risk management framework(s) to deploy in pilot studies with four participating utilities; and

Determine priorities for pilot implementation guidance.


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Workshop participants (Box 1) included the WRF research manager and regional liaison, project technical advisor, and members of the three-person WRF Project Advisory Committee. Representatives joined from the four participating water utilities, and research team members from the University of North Carolina at Chapel Hill and Corona Environmental Consulting facilitated the workshop.

The first half of the workshop consisted of an introductory set of presentations to share the impetus for the research effort, establish the context, and offer relevant background information and historical perspectives on source water protection, water safety planning, and risk management. Another presentation summarized the methods and findings from the phase I research effort, and described the basis for draft recommendations for risk management framework(s) selection. Presentations were interspersed with participant questions, responses, and reflections to foster a constructive dialogue (Figure 2).

Box 1. Participants in Water Research Foundation Project 4748 Workshop (May 3, 2018) Workshop facilitators: Karen Setty, University of North Carolina at Chapel Hill Jamie Bartram, University of North Carolina at Chapel Hill Robert Raucher, Corona Environmental Consulting Workshop participants: Katie Henderson, Water Research Foundation (Denver) Alan Roberson, Association of State Drinking Water Administrators Tim Bartrand, Corona Environmental Consulting Jennifer Heymann, American Water, Project Advisory Committee Rich Gullick, RCAP Solutions, Inc., Project Advisory Committee Robert McConnell, Tampa Bay Water, co-funder and participating utility Shawn Jones, Tampa Bay Water, co-funder and participating utility Mishelle Nobel, Fairfax Water, participating utility Shawn Wiley, Suez North America, participating utility Laura Dale, Suez Delaware, participating utility Richard Stuck, Greater Cincinnati Water Works, participating utility Unable to attend: Reid Campbell, Halifax Water, Project Advisory Committee Observers: Alice Fulmer, Water Research Foundation (Raleigh) Ghanja O’Flaherty, University of North Carolina at Chapel Hill


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Figure 2. Workshop participants engaged in discussion The latter half of the workshop included a series of interactive group activities, with participants breaking into small groups for a hypothetical role-playing exercise. A group decision-making exercise followed, in which individuals assigned weights to the evaluation criteria and ranked the risk management frameworks. The workshop concluded with a brief exercise involving the various steps of risk management frameworks to determine where utilities desired the most implementation support. These steps included:

Establishing a team, context, and vision;

Risk identification;

Risk assessment (characterization and inventorying existing controls; Figure 3);

Risk prioritization;

Risk mitigation (selecting strategies and implementation);

Monitoring and validation; and

Communication and outreach.


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Figure 3. Example of a risk evaluation matrix shared at the workshop, where S1 and S2 represent hypothetical hazards to source waters and the red cells represent the highest-priority risks

Key Findings Workshop participants reviewed 24 potential evaluation criteria in five categories: implementation feasibility and cost for the utility, risk identification, risk characterization, risk management, and clarity and ease of communication. The criteria consistently ranked as most important for a risk management framework for source water-related risks were:

Applicable to many geographic settings and different types of utilities;

Helps to quantify or rank identified risks to source waters (e.g., define priorities based on likelihood and consequences);

Considers multiple facets of risk (e.g., economic or financial, regulatory, public health, customer relations, and utility reputation);

Provides relatively comprehensive coverage and identification of potential hazards;

Relies on readily available or readily obtained data; and

Supports clarity in conveying risk-based information within the utility, and to governing boards, public officials, regulators, watershed stakeholders, customers, and the public.

Research led by UNC compared these criteria to guidance from the US Environmental Protection Agency, Food and Drug Administration, AWWA, the International Standards Organization, Australia, the European Commission, and the World Health Organization. Out of nine different risk management programs considered, the research, structured exercises, and facilitated discussion built consensus around hybridizing two frameworks:

(1) The AWWA/ANSI G300 Standard offers a suitable foundation, given its focus on source water protection, its relatively widespread availability and applicability in the US, and appeal to participants;

(2) The Water Safety Plan (WSP) framework and supporting materials developed by the World Health Organization (WHO), though less commonly applied in a US context, were particularly accessible and well matched with participants’ evaluation criteria and theory about program implementation.


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WSPs offer a model for integrating risk assessment, risk management, and iterative improvement aspects into current source water protection approaches.

Since the G300 Standard is beginning to undergo a round of review and revision, PAC members and utility participants agreed that providing input from the WRF 4748 research effort would support a path toward sustainable integration of the two approaches. Findings also suggested these two risk management programs could and should be improved with suitable enhancements drawn from other frameworks and associated tools. Importantly, tools for integrating cost considerations based on the Techneau project and the Australian Drinking Water Guidelines would enhance a flexible overarching framework for the US.

While participants validated that all components of a holistic framework or plan are crucial to enable the system to function effectively, they identified some challenges relative to specific risk management steps (Box 2). Participants requested that guidance and tools for each step be combined with case study illustrations of correct application.

Insights from Discussion

Research-informed discussions offered some future directions for enabling risk management program success, described below. Challenge: US utilities often have bits and pieces of source water risk management, but may not have a cohesive program or plan, nor an in-house champion. Potential Solutions: Overall, participants felt having a team engagement and process-oriented approach tends to work better for preventive purposes than an outcome-oriented approach. A cohesive utility approach enables the entire process to function more effectively and enables quality improvement cycles, as well as integration of source water risk management activities with utilities’ treatment, distribution, financial, and reputational risk management processes. Program sustainability, information redundancy, and embedding of risk management processes is a critical issue, especially with staff turnover and related workforce continuity issues prevalent at water utilities.

Box 2. Common challenges faced by US utilities undertaking source water risk management

Team engagement (as a starting point and area where short-term benefits are often observable)

Prioritizing risks (e.g., approaches to better characterize and rank risks)

Mitigating risks o Vetting mitigation options based on cost/resource availability and anticipated

level of risk reduction (e.g., obtaining approval for budget and staff resources)

o Ranking options for mitigating risks o Implementing the high-priority risk mitigation strategies

Monitoring and validation to assess the effectiveness of risk mitigation strategies (and adjust as needed)


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Challenge: Monitoring for source water quality is often complex and expensive, and produces little added value if it does not function as intended. Potential Solutions: Monitoring was considered a critical and multi-faceted component of source water risk management. Generally, monitoring plans should specify their objectives (e.g., to differentiate between operational versus compliance versus long-term research monitoring). In addition to contamination event detection, monitoring plans should broadly address early warning and risk mitigation. For example, monitoring the integrity of controls or barriers, such as chemical storage tanks in the watershed, is a key component of risk management and source water protection approaches. Developing enhanced online monitoring systems requires buy-in from upper management and commitment to sensor maintenance and quality assurance. Follow-up data analysis and communication similarly require vested attention. Utilities should establish trigger or action levels of monitored parameters and develop communication strategies and tools for delivering monitoring results (both within the utility and more broadly). Challenge: Participants noted HACCP and other approaches typically applied to engineered batch processes sometimes have limited applicability to water service provision involving inputs and processes outside of the direct control of the utility. Water utilities provide a service (a continuous process), as compared to a product (a batch process, such as packaged food or bottled water). With a batch process, there are opportunities to test and recall finished products if one suspects the quality is compromised. In contrast, water utilities cannot stop water production and distribution without imposing sizeable adverse consequences on their organization, customers, and community. Potential Solutions: Looking beyond risks to source waters or water quality at the intake, utilities would ideally integrate their risk management approach with a broader utility- and community-oriented perspective of risks. This would entail all considering risks borne by the utility and other stakeholders, and planning to manage their potential occurrence and consequences. Outreach and partnerships, for example facilitated by an in-house risk manager or external watershed group, can help to ensure lines of communication are open when problems crop up. Guidance must define the terminology and purpose of the risk management framework. For example, when articulating “risk,” one should clarify “of what,” and “to whom.” Over the long term, risk management certifications may be a useful mechanism to promote adoption, recognition, and standardization for both utilities and watershed stakeholders.

Next Steps This project will continue to develop targeted guidance to support the utility pilot efforts from September 2018 to March 2019. Participants will continue to communicate individually with the AWWA Standards Committee, to help integrate project activities with their efforts to revise the G300 Standard. Final guidance for US utilities will be available upon project wrap-up, around September 2019.

Stay tuned for future updates!

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