1. West Virginia’s Elk River Spill – Lessons Learned EPA New England Drinking Water, Oil, EPCRA and Enforcement Coordination

2. 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

3. 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)

4. 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

5. 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

6. 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

7. 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

8. 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) 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, Jul, 18)

9. 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

10. 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

11. 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)

12. 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

13. 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

14. 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

15. West Virginia law (SB 373 – PWS Protection Act) Now Requires: Water Protection Plan July 1, 2016 Evaluate: 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.

16. 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

17. What Monitoring Systems Available for River Dependent Public Water Systems? Water Protection Plan July 1, 2016 Evaluate: 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

18. 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

19. 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

20. 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

21. 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.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?

22. 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.

23. 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).

24. What was the universe of Oil ASTs & storage amounts ? (24%) Other facilities (68%): airport, co- generation power plant, etc. AST Oil Storage in Merrimack River Drinking Water Corridor = 1,780,000 gallons

25. Largest Oil Storage ASTs – Top 5 / ~150 tanks NAMETownProductAmount GallonsAmount_lbs Wiggins Airways Londonderr y Aviation Turbine Fuel 452,4793,303,100 PSNH 1250 Hooksett Rd Work Ctr HooksettPetroleum Electrical Insulating Oil 263,3071,922,143 Lowell CoGeneration Co LP LowellFuel Oil #2149,9401,094,562 PSNH Central Warehouse & Mobile Substa BowPetroleum Electrical Insulating Oil 140,7891,027,765 Dead River Co. Dist. Office- Manchester Bulk Plant Mancheste r Fuel Oil #2133,561975,000

26. 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.)

27. Priority Non-Oil (ASTs) – Top 10 by Mass NAMECITYSTATEPRODUCTPROPERTYMASS (in lbs) UNITISOLATION DISTANCE (in Feet) Manchester- Boston Regional Airport ManchesterNHPOTASSIUM ACETATE Toxic854,400pounds2400 Nylon Corp of America ManchesterNHCAPROLACTAMReactive500,000poundsNo data Nylon Corp of America ManchesterNHHEXAMETHYLENE DIAMINE Hygroscopic46,200pounds150 Wiggins AirwaysLondonderryNHAviation Turbine Fuel Highly Flammable 440,000gallons1000 Key PolymerLawrenceMAVinyl acetate polymer emulsion Flammable Liquid 60,000pounds2400 Key PolymerLawrenceMAVinyl Copolymer-50,000pounds- Beazer East, Inc. c/o Three Rivers Management, Inc. NashuaNHCOAL TAR DISTILLATE Highly Flammable 57,525pounds2400 Velcro USA, Inc.ManchesterNHAQUEOUS AMMONIA Non- Flammable Gas 12,115pounds5,280 Air Products and Chemicals, Inc. AndoverMAActivated AluminaKnown Catalytic Activity 11,883poundsNONE

28. Hooksett–Manchester, NH Non-Oil Storage (ASTs) NAMEADDRESSChemicalAmount_lbs Hazard Information Nylon Corp of America 333 Sundial Ave HEXAMETHYLENEDI AMINE 100,000 Corrosive (Highly combustible) Nylon Corp of America 333 Sundial Ave CAPROLACTAM600,000Toxic – Can contaminante ground water and streams Manchester- Boston Regional Airport One Airport Rd Potassium Acetate854,400Highly Toxic (Non- combustible) Colt Refining, Inc 12A Star DrPotassium Cyanide2,645Highly Toxic (Non- combustible)

29.  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?