This is the third in a short series of posts about what
probably should have happened in Charleston, WV a little over a week ago now
when a spill of Crude MCHM shutdown the water supply of well over 100,000
people for most of a week. The earlier post (listed below) I described how the
water company could have kept the water out of its system in a perfect world.
Even if the Freedom facility and the water treatment
facility did not live in a perfect world, if communications had been perfect
then the prolonged shutdown and the post-shutdown exposure anxiety could have
been avoided in this instance. What would this perfect communication looked
like.
Potential Hazards
Identified
By all news reports, Freedom Industries had complied with
all of its chemical notification requirements. It had filed it reports to State
and local authorities about the bulk storage of Crude MCHM. As is typical for
these reports, particularly for those chemicals not regulatorially (new word)
identified as hazardous, the reports were briefly looked at and then filed.
If the State and local authorities had entered the chemical
storage data into an appropriate georgraphical information system (GIS)
application, they would have seen that there was just a short distance away a
water treatment plant that could be affected in the event of a spill at the
Freedom site that made it into the nearby river. While the State and local
authorities can be forgiven for not knowing if this could have any specific
impact to the treatment facility, they should have notified the facility of the
type and quantity of any chemicals in bulk storage upstream of the facility.
If the water treatment facility had received advanced
notification from State and local authorities, it could have determined in
advance whether or not their routine treatment activities would remove the chemical
from any water entering the facility. They also could have acquired the testing
capability to detect the chemical in their inlet and output waters.
Leak Notifications
There is no CERCLA reporting
requirement for Crude MCHM as it is not a hazardous chemical and thus does
not have a federal ‘reportable quantity’. However, given the close proximity of
the tank farm to the Elk River, as soon as the leak broached the containment
wall there should have been notification to the Coast Guard’s National Response
Center (NRC), the agency that is responsible for coordinating all chemical
spill information.
One would like to think that the NRC had appropriate GIS
programs in place to identify the location of the spill and immediately be
aware of the downstream water treatment plant. Immediate notification could
then have been made to the plant about the spill.
Assuming that the Elk River is flowing at a relatively
gentle 3 mph and is a half-mile upstream of the water treatment plant’s
intakes, it would have taken the about 20 minutes for the first traces of the
Crude MCHM to reach the intakes. This makes it clear that any notifications
would have to be made promptly and follow-up actions needed to be taken with
dispatch to avoid contamination of the treatment facility equipment.
Community Notification
As soon as the water treatment facility became aware of an
upstream spill of a chemical that they knew could not be removed by their
treatment processes, plans would have been initiated for a shutdown of the
water intake. These plans would have included notification to all customers
(direct notification and notification via the media) that there would be an
impending shortage of treated water. This would have allowed people to start
taking measures to ensure that they had drinking water on hand for the time of
the shutdown.
Communications
According to Law
It currently appears that Freedom Industries made all of the
chemical notifications, including spill notification (none), required by law.
It appears that current reporting requirements (and follow-up planning requirements)
do not address the special case of chemical spills upstream of the water intake
of a water treatment facility.
It is readily apparent that the chemical notification and
planning processes need to be revised to address this situation. In a future
post in the series, I will propose what I think those changes should include.
Posts
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