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 Freedom Industries was discovered to be leaking a chemical mixture into the Elk River: – Spill discovered during WV DEP investigation of odor complaints 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 the intake due to the risk of depressurization

WV American Water – Detection & Response

Public 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 Effects Level (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 sampling and flushing plan: – Developed using the distribution system model – System was divided into five zones – Each zone was flushed independently – Sampling confirmed that flushing was successful – Sampling results posted to a public website

Testing Methods for MCHM

• At the beginning of the incident, there was no analytical method for MCHM in water.

• The chemical structure, boiling point, and polarity were 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 MDL Other 4-Methyl-1-cyclohexanemethanol (4-MCHM). Cost of state response is estimated at $3M (WV

Public Broadcasting, Feb. 20)

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 Plumbing

After sampling confirmed that MCHM levels were below the target, the “Do Not Use” notice was lifted: – First zone cleared on Jan 13 (day 4) – Last zone cleared on Jan 18 (day 9) • Instructions provided to residents for flushing premise plumbing systems

Cost of the Spill

• Good Faith of Customers Cost of state response is estimated at $3M (WV

Public 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 75,000 workers impacted (41% of workforce) (Marshall

University, Feb. 13)

• Freedom Industries filed for bankruptcy on Jan. 17 and reached a $2.9M settlement on Jul. 18 (WV

Gazette, 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 Agencies

CDC/ATSDR

• Reviewed results from toxicity studies • Established screening level and health advisories

FEMA

• 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 analysis

USEPA

• On-scene coordinators at site of the spill • Region 3, OGWDW, and ORD provided technical support to the state primacy agency and utility

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

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

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Conduct annual inspection of ASTs by a PE

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Perform Leak detection & inventory control Corrosion control

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

Water Protection Plan July 1, 2016

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Feasibility of alternate source of supply capacity, update their source water protection

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plans and evaluate alternative/backup drinking

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Evaluate ability / duration to shut intake 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 2 nd intake in another source water – nearby River intake

What Monitoring Systems Available for River Dependent Public Water Systems?

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

Feasibility of alternate source of supply

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Raw water storage capacity

Fluorometers –Measure light transmittance that can be used 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

Merrimack Drinking Water Corridor

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. Nashua, NH 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.

Lawrence , MA

Merrimack Drinking Water Corridor – A Public Resource

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.

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BUT …..

Merrimack Drinking Water Corridor – Also the Home of the Industrial Revolution The Merrimack River also has:

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161 Aboveground Oil Storage Tanks storing > 16 million pounds (lbs)=~ 2.29 million gallons

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38 Aboveground Non-Oil Tanks from 18 facilities storing > 3 millions pounds (lbs)

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46 NPDES Dischargers – Includes 12 POTWs. 1 power plan, & 3 Combined Sewer Overflow Communities.

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

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.

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?

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

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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 ?

AST Oil Storage in Merrimack River Drinking Water Corridor = 1,780,000 gallons Other facilities (68%): airport, co generation power plant, etc. Public Service of NH (24%) National Grid (7%) 158,000 gallons

Largest Oil Storage ASTs – Top 5 / ~150 tanks

NAME Town Product Amount Gallons Amount_lbs

Wiggins Airways PSNH 1250 Hooksett Rd Work Ctr Londonderr Aviation Turbine y Fuel Hooksett Petroleum Electrical Insulating Oil Lowell CoGeneration Co LP PSNH Central Warehouse & Mobile Substa Lowell Bow Fuel Oil #2 Petroleum Electrical Insulating Oil Dead River Co. Mancheste Dist. Office Manchester r Bulk Plant Fuel Oil #2 452,479 263,307 149,940 140,789 133,561 3,303,100 1,922,143 1,094,562 1,027,765 975,000

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 substances 2) 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.)

NAME

Priority Non-Oil (ASTs) – Top 10 by Mass

CITY STATE PRODUCT PROPERTY MASS (in lbs)

Manchester Boston Regional Airport Nylon Corp of America Nylon Corp of America Wiggins Airways Manchester NH Manchester NH Manchester NH Londonderry NH Key Polymer Key Polymer Lawrence Lawrence MA MA POTASSIUM ACETATE CAPROLACTAM Toxic Reactive HEXAMETHYLENE DIAMINE Aviation Turbine Fuel Vinyl acetate polymer emulsion Vinyl Copolymer Hygroscopic Highly Flammable Flammable Liquid 854,400 500,000 46,200 440,000 60,000 50,000

UNIT

pounds pounds pounds gallons pounds pounds

ISOLATION DISTANCE (in Feet)

2400 No data 150 1000 2400 Beazer East, Inc. c/o Three Rivers Management, Inc.

Nashua Velcro USA, Inc.

NH Manchester NH Air Products and Chemicals, Inc.

Andover COAL TAR DISTILLATE Highly Flammable MA AQUEOUS AMMONIA Non Flammable Gas Activated Alumina Known Catalytic Activity 57,525 pounds 12,115 11,883 pounds pounds 2400 5,280 NONE

Hooksett–Manchester, NH Non-Oil Storage (ASTs)

NAME Nylon Corp of America ADDRESS Chemical 333 Sundial Ave HEXAMETHYLENEDI AMINE Amount_lbs 100,000

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Hazard Information Corrosive (Highly combustible) Nylon Corp of America 333 Sundial Ave CAPROLACTAM Manchester Boston Regional Airport Colt Refining, Inc One Airport Rd Potassium Acetate 12A Star Dr Potassium Cyanide 600,000 854,400 2,645 Toxic – Can contaminante ground water and streams Highly Toxic (Non combustible) Highly Toxic (Non combustible)

Next Steps- What’s Next for Action?  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.