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 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) •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, 2016 Public Evaluate: • • • • Water Systems to analyze existing storage Feasibility of alternate source of supply capacity, update Raw water storage capacity their source water protection Ability to isolate/divert contamination plans and evaluate alternative/backup drinking 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 2nd 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 Gas Chromatograph Detect organic compounds in source Water Protection Plan – July 1, 2016 Evaluate: waters Feasibility of alternate source of supply • Raw water storage capacity Fluorometers –Measure light transmittance that can • Ability to isolate/divert contamination •to Evaluate ability / duration to shut intake chlorophyll. track oil spills. Can also monitor • 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 Nashua, the risks from NH 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. 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. BUT ….. Merrimack Drinking Water Corridor – Also the Home of the Industrial Revolution 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 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? • 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 ? AST Oil Storage in Merrimack River Drinking Water Corridor = 1,780,000 gallons Other facilities (68%): airport, cogeneration power plant, etc. Public Service of NH (24%) National Grid (7%) 158,000 gallons Largest Oil Storage ASTs – Top 5 / ~150 tanks NAME Town Wiggins Airways PSNH 1250 Hooksett Rd Work Ctr Londonderr Aviation Turbine y Fuel Hooksett Petroleum Electrical Insulating Oil Lowell Lowell CoGeneration Co LP PSNH Central Bow Warehouse & Mobile Substa Product Amount Gallons Amount_lbs 452,479 3,303,100 263,307 1,922,143 Fuel Oil #2 149,940 1,094,562 Petroleum Electrical Insulating Oil 140,789 1,027,765 133,561 975,000 Dead River Co. Mancheste Fuel Oil #2 Dist. Office- r Manchester Bulk Plant 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.) Priority Non-Oil (ASTs) – Top 10 by Mass NAME CITY STATE PRODUCT ManchesterBoston Regional Airport Nylon Corp of America Nylon Corp of America Wiggins Airways Manchester NH POTASSIUM ACETATE Toxic 854,400 pounds 2400 Manchester NH CAPROLACTAM Reactive 500,000 pounds No data Manchester NH Hygroscopic 46,200 pounds 150 gallons 1000 Lawrence MA 60,000 pounds 2400 Key Polymer Lawrence MA Highly Flammable Flammable Liquid - 440,000 Key Polymer HEXAMETHYLENE DIAMINE Aviation Turbine Fuel Vinyl acetate polymer emulsion Vinyl Copolymer 50,000 pounds - NH COAL TAR DISTILLATE Highly Flammable 57,525 pounds 2400 Velcro USA, Inc. Manchester NH AQUEOUS AMMONIA 12,115 pounds 5,280 Air Products and Chemicals, Inc. Andover NonFlammable Gas Activated Alumina Known Catalytic Activity 11,883 pounds NONE Londonderry NH Beazer East, Inc. Nashua c/o Three Rivers Management, Inc. MA PROPERTY MASS (in lbs) UNIT ISOLATION DISTANCE (in Feet) Hooksett–Manchester, NH Non-Oil Storage (ASTs) Amount_lbs 100,000 •Hazard Information NAME Nylon Corp of America ADDRESS Chemical 333 Sundial HEXAMETHYLENEDI Ave AMINE Nylon Corp of America 333 Sundial CAPROLACTAM Ave 600,000 Toxic – Can contaminante ground water and streams ManchesterBoston Regional Airport One Airport Potassium Acetate Rd 854,400 Highly Toxic (Noncombustible) Colt Refining, Inc 12A Star Dr Potassium Cyanide 2,645 Highly Toxic (Noncombustible) Corrosive (Highly 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 nonoil 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.