West Virginia American Water’s Response to the Chemical Safety Board’s Final Report on the 2014 Freedom Industries Chemical Spill September 28, 2016 West Virginia American Water cooperatively responded to information requests from the U.S. Chemical Safety and Hazard Investigation Board (“CSB”) during its investigation and we are carefully reviewing the full final report. Upon initial review, we appreciate the CSB report’s focus on the criminally negligent conduct of Freedom Industries that allowed the leak to happen. The report does not direct any recommendations at West Virginia American Water, and we are pleased to see the CSB has acknowledged our source water protection activities as exceeding applicable requirements and a model for the industry. We understand that American Water’s other state utilities have implemented or are in the process of implementing similar steps, aligned with the CSB recommendations, at their surface water treatment plants. However, we believe the CSB’s recommendation to extend these activities to all American Water state utilities would be more effective if made to the US EPA so that any new activities can be implemented in a balanced fashion across the industry instead of only at a very small percentage of the nation’s surface water treatment plants. Source water protection, including contingency planning, is an important part of an overall approach to provide clean, safe water for customers and communities. West Virginia American Water developed a source water monitoring program that combines continuous water quality indicator monitoring with advanced organics analyses to optimize treatment operations and identify the presence of potential contaminants. We also developed a Geographic Information System (GIS) map-based tool that collects information about potential sources of contamination from various publicly available data sources and pulls it into a single database for the area of concern. This approach is consistent with the efforts West Virginia American Water takes to meet or exceed the requirements of the Safe Drinking Water Act. We recently submitted Source Water Protection Plans for each of our water systems to the West Virginia Department of Health and Human Resources for review in accordance with state regulations. Through 2016, seven of our West Virginia American Water plants have received Directors Awards from the Partnership for Safe Water for exceptional plant optimization and performance, some for as many as 15 years. Less than one percent of all U.S. water utilities, and no other water utilities in the state, have achieved this honor. Our preliminary review also indicates that the CSB’s recommendation to AWWA encourages source water protection activities across the entire water industry. West Virginia American Water supports this effort.