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.