The Freedom Spill – Why?

While the folks directly affected by the spill are worried about where they are going to get their clothes washed and take a bath, the bigger question is why did this happen? Why did an industrial chemical get into a city water distribution system? The Chemical Safety Board is scheduled to have a team arrive tomorrow to start their investigation.

The investigation will probably take much less time than normal; investigating a leak where everything is still together is a lot easier than reconstructing explosions and fires. If there isn’t another conflict with DOJ on crime scene vs chemical incident scene investigation we should see something in a couple of months.

But, given the news reports that I’ve seen, access to Google Maps and a little knowledge of process chemistry I think I can piece together a pretty fair picture of what probably happened.

The Facility

Looking at the facility on Google Maps, it is clear that it is (as news reports have noted) that this is a chemical storage facility, not a chemical manufacturing facility. There are 10 large storage tanks clearly visible within the facility, three smaller tanks and a number of much smaller storage containers. The 13 identifiable tanks all appear to be within a brick wall that probably serves as the primary spill containment. The area encircled by the brick wall is certainly large enough to contain spills of all of the tanks at the facility.

It is also obvious that the facility is very close to the Elk River with not much more than a chain link fence separating it from the river’s high water mark. There appears to be a barge loading/unloading facility at the water’s edge. The rail line that can be seen along the eastern boundary of the facility is no longer connected to anything beyond the property.

There is a tank truck loading facility between the large tanks and the perimeter fence. Tank trucks come in the north gate at the facility, get loaded and depart through the south gate near the administrative building.

The Spill

At some time on Thursday morning a tank containing Crude MCHM started leaking. From news reports the leaking tank was a 48,000 gallon tank so it was one of the ten large tanks. Most facilities do not have leak detection equipment for their bulk storage tanks unless there is potential for catastrophic consequences and the Crude MCHM certainly does not fit into that category.

Most leak detection regimes rely on preventive maintenance programs to prevent large leaks and small leaks are typically detected by employees working in the vicinity of the storage tanks. With the Freedom Industries leak being as much as 5,000 gallons (about what an over-the-road chemical tank truck carries) this was a fairly large leak. It will be interesting to see what the CSB says about the source of the leak.

Containment Failure

The news report sited above says that the containment overflowed. That does not seem to be possible. The three foot brick wall around the tank farm should have been more than high enough to contain the entire contents of one of the tanks, much less 5,000 gallons.

Ken Ward reported that the West Virginia Department of Environmental Protection (WVDEP) has ordered Freedom to empty all of their tanks at the site because the containment was not adequate to hold a spill. I suspect that the brick wall has cracks in it near the foundation that would allow any pooling liquid to leak out. This would have been obvious to the facility maintenance team every time that it rained and water collected within the containment area.

No Spill Response

The third part of any spill containment plan also failed in this instance. Any time a major leak is detected in a tank farm, one of the things that has to be done immediately is to check to ensure that the spill is being contained by the containment barrier. Any leaks in that barrier need to be controlled with mobile spill control equipment. News reports indicate that the WVDEP inspectors saw no such efforts being made when they showed up at the site.

The Water Company Response

News reports from WSAZ indicated during the initial response on Thursday that the water company felt that their inlet treatment system would deal with the relatively low amount of contamination (I have seen figures of 41 ppm for this spill) in the river water used to feed the water treatment plant. This is certainly true for a wide variety of contaminants that such facilities typically see.

This is not a chemical that the water company is required to test for, so there was no method of identifying this chemical in their water readily available on site. There are literally tens of thousands of industrial chemicals and testing for their presence in water can be quite difficult for a well-equipped water testing laboratory. Very few water treatment facilities can afford such facilities and most rely on out-side labs for non-routine testing. On site labs only test for those chemicals identified by State and federal environmental regulations; Crude MCHM does not show up on those lists.

According to news stories water system samples were sent to an outside lab for analysis even though the treatment facility thought that their system would remove the chemical upon intake. When that proved not to be the case, the emergency ‘no contact’ order was issued even though there is no clear indication that there was (or was not for that matter) any hazard associated with the level of contamination in the system.

Emergency Planning

There have been the inevitable complaints about the lack of a plan to deal with this particular problem. Particularly in the wake of the West Fertilizer tragedy last summer questions have been asked about whether or not Freedom Industries had fulfilled their community notification responsibilities. Ken Ward reported yesterday that the appropriate Tier II forms had been submitted to State and local agencies.

So why wasn’t there a plan in place to deal with this? Why would there be? Emergency planning folks get flooded with Tier II documents, particularly in an area with a large chemical industry like this area in West Virginia. Local emergency planning committees (LEPC) required by EPA regulations are largely voluntary groups with little or no local funding and certainly no federal funding beyond the odd grant or two.

If there is any actual emergency response planning done by these committees (and the Federal government does not actually require any planning to take place otherwise they would be forced to pay for it) it will be concentrated on the most hazardous chemical facilities in the area. In the Charleston, WV area that would include places that make chemicals that will kill people at concentrations of MCHM seen in the current water supply or cause truly catastrophic explosions or fires.

And there is no requirement for anyone to talk to a local water treatment facility in any of this emergency planning. They are not an emergency response organization.

From responses that we have seen to other chemical incidents in the area, I suspect that the chemical response planning and training in the Charleston, WV area is probably some of the best in the country. It didn’t include a response to this type of incident, mainly because it was too low on the potential consequence ladder.

Safe Levels of MCHM Set

Ken Ward reports today that the U.S. Agency for Toxic Substances and Disease Registry (ASTDR), part of the U.S. Centers for Disease Control and Prevention (CDC) had determined a ‘safe level’ of MCHM in drinking water, 1 ppm. This is a calculated value not a tested value. It is from an authoritative source so the local water company will be off the hook for any liability for potential injures from up to that level of contamination in the water supply once things are started back up.

I suspect that they will try to take the levels lower than that, just to be on the safe side. On the other hand, people are getting fed up about not being able to wash themselves or their clothes, and local businesses are being hurt by the necessary closures because of the lack of water. I’m sure the management of the water company is really happy to see this number.