West Virginia’s Elk River Spill – Lessons Learned

EPA New England Drinking Water, Oil, EPCRA and Enforcement Coordination

Lessons Learned from West Virginia’s Elk River Spill

• Overview of the incident, the response, and the consequences:

• Roles of response partners

• Preparing for future contamination incidents in Maine

West Virginia’s Elk River Spill- Events• On January 9, 2014, a tank owned by FreedomIndustries was discovered to be leaking a chemicalmixture into the Elk River:

– Spill discovered during WV DEP investigation of odorcomplaints at 11:25 am

– Initial spill volume estimates as low as 1,500 gallons

– The leak occurred 1.5 miles upstream of the sole intake for the WV American Water (WVAW)

WV American Water – Detection & Response

• WVAW was notified of spill at 11:45 am.

• MCHM detected in finished water ~4:00 pm. Plant serves about 300,000 people in 9 counties.

• Operators increased KMnO4 dose and added Powdered Activated Carbon in addition to GAC filters.

WVAW decided against shutting down theintake due to the risk of depressurization

WV American Water – Detection & ResponsePublic Notification Response

• WVAW issued a “Do Not Use” notice on Jan. 9 @ 5:45 pm, less than 2 hours after MCHM was detected in the finished water

• Tap water could only be used for flushing toilets and fire suppression

• Federal disaster declaration was approved by President Obama on Jan. 10 @ 12:46 am

• Distribution of bottled water began next day(Jan. 10) at 7:30 am to 100,000 households in 9 counties

Contaminant Properties of MCHM

Eastman: Material Safety Data Sheet• Basic Properties:– Solubility– Density– Boiling and flash points

• Animal Toxicity Studies:– Skin irritation (rabbit) = strong– Oral LD50 (rat) = 825 mg/kg– 4-week No Observed Adverse EffectsLevel (rat) = 100 mg/kg/day

Distribution System Flushing• On Jan. 11 (day 2), ATSDR released a “screening level” of 1.0 ppm for MCHM

• WVAW immediately started to develop a samplingand flushing plan:– Developed using thedistribution system model– System was divided intofive zones– Each zone was flushedindependently– Sampling confirmed thatflushing was successful– Sampling results postedto a public website

Testing Methods for MCHM• At the beginning of the incident, there was noanalytical method for MCHM in water.

• The chemical structure, boiling point, and polaritywere used to select potential analytical approaches

FOR MCHM -Two EPA, GC/MS methods were modified:1) EPA SW846, methylene chloride extraction, 0.5 ppb MDL

2) EPA 524.2(3), purge and trap, 3 ppb MDLOther 4-Methyl-1-cyclohexanemethanol (4-MCHM). Cost of state response is estimated at $3M (WVPublic Broadcasting, Feb. 20)

• Running cost to WVAW as of August 2014 is $11M,including $1.1M for GAC filter replacement(Associated Press, Aug. 8)• WVAW named in 58 law suits (Associated Press, Aug. 8)• Cost of lost business revenues $61M, with 75,000workers impacted (41% of workforce) (MarshallUniversity, Feb. 13)• Freedom Industries filed for bankruptcy on Jan. 17and reached a $2.9M settlement on Jul. 18 (WVGazette, Jul, 18)

Immediate Consequences• Over 300,000 residents of Charleston without tap water for 10 days• 369 individuals sought medical care at hospital emergency departments (WVBPH and ATSDR, April 2014):

– 356 (96.5%) individuals treated and released– 13 (3.5%) hospitalized

– Common symptoms included nausea, rash, vomiting, abdominal pain, and diarrhea– No severe illnesses were attributed to exposures to chemicals released during the spill• Critical services, such as hospitals, were impacted by the water use restrictions

Flushing Premise PlumbingAfter samplingconfirmed that MCHMlevels were below thetarget, the “Do Not Use”notice was lifted:– First zone cleared onJan 13 (day 4)– Last zone cleared onJan 18 (day 9)• Instructions providedto residents forflushing premiseplumbing systems

Cost of the Spill

• Good Faith of Customers

Cost of state response is estimated at $3M (WVPublic Broadcasting, Feb. 20)

• Running cost to WVAW as of August 2014 is $11M,including $1.1M for GAC filter replacement(Associated Press, Aug. 8)• WVAW named in 58 law suits (Associated Press, Aug. 8)• Cost of lost business revenues $61M, with 75,000workers impacted (41% of workforce) (MarshallUniversity, Feb. 13)• Freedom Industries filed for bankruptcy on Jan. 17and reached a $2.9M settlement on Jul. 18 (WVGazette, July 18)

EPA Technical Capability Technical Support

• Programs and labs in EPA Office of Ground Water & Drinking Water and EPA’s Research Lab in Cincinatti Provided 100s of scientists and engineers with deep, technical knowledge in specialized fields:

• Fundamental chemistry and biology• Contaminant fate and transport• Analytical methods• Treatability• Modeling

Approximately a dozen subject matter experts supported the response to the distribution

Federal AgenciesCDC/ATSDR• Reviewed results from toxicity studies• Established screening level and health advisoriesFEMA• Logistical support for response (e.g., water distribution)• Disaster relief funding• National Guard Civil Support Teams• Distributed bottled water• Staffed call centers (WV Poison Control)• Provided broad support for sampling and analysisUSEPA• On-scene coordinators at site of the spill• Region 3, OGWDW, and ORD provided technical supportto the state primacy agency and utility

New West Virginia Law (SB 373 –PWS Protection Act)

•The WV Legislature created a bill in response to the incident to protect the vulnerable public water supply requiring that AST owners address:

• Conduct annual inspection of ASTs by a PE

• Perform Leak detection & inventory control

• Corrosion control

West Virginia law (SB 373 –PWS Protection Act) Now Requires:

Water Protection Plan July 1, 2016Evaluate:• Feasibility of alternate source of supply• Raw water storage capacity• Ability to isolate/divert contamination• Evaluate ability / duration to shut intake

Public Water Systems to analyze existing storage capacity, update their source water protection plans and evaluate alternative/backup drinking water sources.

What is the System (WV American Water) Doing to

Improve Source Water Quality and Supply?

•Continuing to monitor for MCMH – Annual WQ Report noted no detections

•Evaluating any bonding of MCMH to internal piping of the drinking water treatment plant.

•Considering a 2nd intake in another source water – nearby River intake

What Monitoring Systems Available for River Dependent Public Water Systems?

Water Protection Plan July 1, 2016Evaluate:• Feasibility of alternate source of supply• Raw water storage capacity• Ability to isolate/divert contamination• Evaluate ability / duration to shut intake

Multiprobes – Can include Temperature, pH, specific conductance, dissolved oxygen, turbidity and chlorophyll probes

Gas Chromatograph – Detect organic compounds in source waters

Fluorometers –Measure light transmittance that can be used to track oil spills. Can also monitor chlorophyll.

Total Organic Carbon Analyzer -Detects changes in organic carbon levels in source – especially useful in detecting petroleum spills.

Source: http://www.epa.gov/oem/docs/oil/fss/fss04/schulte_04.pdf

The EPA NE Drinking Water Program and the Oil Spill Response Program started reviewing the Merrimack “drinking water corridor” to assess the risks from Aboveground Storage Tanks. This section of the river starts at the City of Lawrence’s intake to a dam in Hooksett, NH which is upstream of Nashua’s NH’s intake.

Merrimack Drinking Water Corridor

Lawrence, MA

Nashua, NH

The Merrimack River is a Class B surface water which supplies drinking water for five (5) Massachusetts communities. These community systems serve more than 533,000 people. (Lowell, Lawrence, Methuen, Andover, and Tewksbury, MA) as well as Nashua, New Hampshire. BUT …..

Merrimack Drinking Water Corridor – A Public Resource

The Merrimack River also has: 161 Aboveground Oil Storage

Tanks storing > 16 million pounds (lbs)=~ 2.29 million gallons

38 Aboveground Non-Oil Tanks from 18 facilities storing

> 3 millions pounds (lbs) 46 NPDES Dischargers –

Includes 12 POTWs. 1 power plan, & 3 Combined Sewer Overflow Communities.

Merrimack Drinking Water Corridor – Also the Home of the Industrial Revolution

Data Sources Used:1) The Emergency Planning and Community Right-to-Know Act

(EPCRA) Tier 2 database – Database contains critical information on mass of chemicals, physical and chemical hazards, facility location, and emergency facility contacts.

2) Computer Aided Management of Emergency Operations (CAMEO)- On-line library which contains chemical characteristics information. Source: Emergency Response, National Oceanic and Atmospheric Administration.

3) Water Contaminant Information Tool – Contain valuable contaminant data related to fate & transport, methods, early warning expectations and treatment options, EPA Office of Water.

4) ICIS –Integrated Compliance Information System, Database source for the National Pollutant Discharge Elimination System, EPA OW.

Merrimack Drinking Water Corridor Where Did We Find the AST Data?

Non-Oil Tanks – Region evaluating t all 38 tanks for contaminants of concern for drinking water. (Green Text)

For Oil Tanks – The 30 largest tanks within 1 mile of the river in each state (MA& NH) were prioritized.

What Was Our Approach to Determining Risk from ASTs?

• Determine Total Oil universe - 161 tanks (within the Merrimack Drinking Water Corridor- defined as 1 mile of shoreline.

• Determine which geographic areas have the largest concentration of tanks:

1) Manchester & Hooksett & Merrimack (NH);2) Lowell and; 3) Andover/Methuen/Lawrence (MA).

What was the universe of Oil ASTs & storage amounts ?

Public Service of NH

National Grid

(7%) 158,000 gallons

(24%)Other facilities (68%): airport, co-generation power plant, etc.

AST Oil Storage in Merrimack River Drinking Water Corridor = 1,780,000 gallons

Largest Oil Storage ASTs – Top 5 / ~150 tanks

NAME Town Product Amount Gallons Amount_lbs

Wiggins Airways

Londonderry

Aviation Turbine Fuel

452,479 3,303,100

PSNH 1250 Hooksett Rd Work Ctr

Hooksett Petroleum Electrical Insulating Oil

263,307 1,922,143

Lowell CoGeneration Co LP

Lowell Fuel Oil #2 149,940 1,094,562

PSNH Central Warehouse & Mobile Substa

Bow Petroleum Electrical Insulating Oil

140,789 1,027,765

Dead River Co. Dist. Office-Manchester Bulk Plant

Manchester

Fuel Oil #2 133,561 975,000

What Was Our Approach to Determining Risk For Non-Oil Tanks ?

Total of 45 tanks in MA and NH with contaminants of concern for Drinking Water:Tanks/Facilities were evaluated based on:

1) Presence of extremely hazardous substances2) Properties of Materials Stored (Flammable, Corrosive,

Drinking Water MCL, etc.)

* Note: Many of the larger facilities are required to report through EPCRA. For the EPCRA Tier 2 Program, the reporting threshold is 10,000 lbs (except for VT which uses a 100 lb threshold.)

Priority Non-Oil (ASTs) – Top 10 by MassNAME CITY STATE PRODUCT PROPERTY MASS (in lbs) UNIT ISOLATION

DISTANCE (in Feet)

Manchester-Boston Regional Airport

Manchester NH POTASSIUM ACETATE

Toxic 854,400 pounds 2400

Nylon Corp of America

Manchester NH CAPROLACTAM Reactive 500,000 pounds No data

Nylon Corp of America

Manchester NH HEXAMETHYLENEDIAMINE

Hygroscopic 46,200 pounds 150

Wiggins Airways Londonderry NH Aviation Turbine Fuel

Highly Flammable

440,000 gallons 1000

Key Polymer Lawrence MA Vinyl acetate polymer emulsion

Flammable Liquid

60,000 pounds 2400

Key Polymer Lawrence MA Vinyl Copolymer - 50,000 pounds -

Beazer East, Inc. c/o Three Rivers Management, Inc.

Nashua NH COAL TAR DISTILLATE

Highly Flammable

57,525 pounds 2400

Velcro USA, Inc. Manchester NH AQUEOUS AMMONIA

Non-Flammable Gas

12,115 pounds 5,280

Air Products and Chemicals, Inc.

Andover MA Activated Alumina Known Catalytic Activity

11,883 pounds NONE

Hooksett–Manchester, NHNon-Oil Storage (ASTs)

NAME ADDRESS Chemical Amount_lbs

•Hazard Information

Nylon Corp of America

333 Sundial Ave

HEXAMETHYLENEDIAMINE

100,000 Corrosive (Highly combustible)

Nylon Corp of America

333 Sundial Ave

CAPROLACTAM 600,000 Toxic – Can contaminante ground water and streams

Manchester-Boston Regional Airport

One Airport Rd

Potassium Acetate 854,400 Highly Toxic (Non-combustible)

Colt Refining, Inc

12A Star Dr Potassium Cyanide 2,645 Highly Toxic (Non-combustible)

Outreach to Aboveground Tank Owners:Mailing brochures called: “What Your Business Can Do to Help Protect & Secure Drinking Water Sources!” to oil and non-oil AST owners. (Summer 2014)

-Review AST sites storing non-oil materials for potential hazards & anticipated spill

response.

- Conducting two Tabletop Exercise Workshops with MA and NH Public Drinking

Water Suppliers, Tank Owners and First Responders (February and March 2015);

- Coordinate with Geographic Based Response Plan developers (FY’14-15)

-Coordinate with State Drinking Water Programs and Environmental Agencies.

-Target Inspections of SPCC and EPCRA facilities.

Next Steps- What’s Next for Action?