2.1.1 Narrative
See previous POLREPs for site information and actions conducted from January 9, 2014 through February 3, 2014.
2.1.2 Response Actions to Date
During this operational period, efforts were concentrated on water management on Site, including prevention of the potentially MCHM-contaminated water from reaching the Elk River. A large amount of the water was the result of increased precipitation, both heavy rain and snow that had melted due to a slight increase in temperatures. Additional sources of the water have not yet been defined. One of the sources was determined to be water that is seeping from the subsurface soils/materials beneath the Site, including inside the containment area and along the slope that leads to the river.
Discussions this week concerning the off-Site water focused on determination of the source(s) of the water. Suggestions were made to conduct a dye test and follow the water pathway that originates from the opposite side of Barlow Road. However, WVDEP had concerns about both the test being unsuccessful and the dye reaching the river. Therefore, the dye test was not conducted.
The RP and WVDEP contacted West Virginia Department of Highways (WVDOH) in order to obtain a permit for clearing activities in the ditch located between the abandoned railroad that parallels the front of the facility and Barlow Road. WVDOH granted the permit to the RP’s contractor. The RP also contacted the lessor of the abandoned railroad, who granted permission to the RP to conduct operations in their right-of-way. CEC has drafted and submitted a plan for clearing the ditch, which involves light excavation to the original grade to re-establish natural storm water flow in the ditch. The RP is hopeful to identify a pathway for the off-Site water and divert the water around the facility to prevent further infiltration of the water into the containment area.
Throughout the week, the RP’s contractor conducted 24-hour pumping operations from all pooled areas of the Site, including from both inside and outside of the containment area and the interceptor trench. The RP's contractor estimated that approximately 1,000 gallons of water per hour were discharging into the culvert in the containment area. Additional time was required for pumping operations, as low temperatures occasionally caused the hoses to freeze. All of the water that has been collected was pumped into on-Site tanks and will be tested and disposed of in accordance with applicable state and federal requirements. A method of disposal of the MCHM-contaminated water is still being investigated; current options include disposal at a WWTP or solidification and subsequent disposal at a landfill.
Multiple layers of booms were deployed and/or repositioned near the shoreline of the facility. Attention was focused on the rising water level in the Elk River, which rose to approximately 12 feet on February 5, 2014, according to the gages at Queen Shoals, WV. The RP’s contractor conducted 24-hour inspections and maintenance of the booms, replacing the boom as required. By February 11, 2014, the water level in the Elk River decreased to approximately 6.5 feet, also according to the gage at Queen Shoals. At this time, concern about the discharge rate of water and height of the river has greatly diminished, as the river level has dropped to normal levels and no significant precipitation events are forecasted.
A honeycomb box with a vacuum hose inserted was placed in the trench, located downgradient of the culvert pipe that discharges to the rear of the facility. The honeycomb box was used to facilitate pumping the accumulated water out of the trench and to hold the poly liner in place. Prior to a forecasted heavy rain event, a plywood cover was installed over the trench boxes and tarps were placed from the top of the hillside, extending down the hillside and over the plywood cover to the downgradient side of the trench; this was done to allow precipitation runoff to flow to the river without contacting potentially contaminated soil and to prevent water accumulating in the trench from overflowing. The RP's contractor conducts 24-hour oversight of the interceptor trench area. Currently, the water is pumped out of the trench every three hours.
Throughout the week, the facility continued to load-out glycerin product from the on-Site tanks and transport it to customers. The RP estimates that all of the product stored in the on-Site tanks will be removed from the Site within two weeks. The RP is under WVDEP order to remove all of the chemicals/product on Site by March 15, 2014.
Load out of MCHM/PPH product stored at the Poca Blending facility began during the reporting period. The product was transported for sale to customers.
The FBI’s Evidence Response Team was on Site on February 6 and 7, 2014. The team conducted a three-dimensional survey of the tanks and containment area.
CSB was on Site and continued their investigation. CSB is working with the facility to obtain the section of tank 396 that failed so they can test the tank for its metallurgical properties and physical composition. CSB’s completed study will recommend requirements for tank composition and specifications. CSB is subcontracting a tank expert to complete a survey of the tanks on Site and collect the necessary section from tank 396. Following the completion of CSB’s investigation, the RP will dismantle, cut, and remove the three MCHM tanks from the Site.
Following removal of the MCHM tanks, under WVDEP approved plans and oversight, the RP’s contractors will proceed with investigation/remediation efforts. The investigation will focus on potential subsurface contamination on Site, assessing if the MCHM is pooled in the substructure of the containment pad and/or the soils of the western slope of the facility, along the pathway to the river.
Sampling efforts included collection of groundwater samples from the seven monitoring wells that were installed on Site in mid-January 2014. On February 6, 2014, monitoring wells MW-1, MW-2, and MW-7 were purged and left to re-charge. These wells are located along the eastern side of the facility, between the containment wall and Barlow Road. The RP’s contractor and WVDEP collected split samples from each of these wells. EPA’s contractor collected a split sample from monitoring well MW-2. On February 7-8, 2014, CEC collected groundwater samples from monitoring wells MW-3, MW-4, MW-5, and MW-6 using micro-purge (low-flow) sampling protocols, except for the VOC fraction which was collected using a dedicated bailer. These wells are located at the base of the slope behind the facility, adjacent to the Elk River. The RP’s contractor, WVDEP, and EPA’s contractor collected split samples from each of these four monitoring wells. The EPA samples were shipped to the OASQA Laboratory in Ft. Meade, MD to be analyzed for VOCs, and MCHM/PPH constituents.
The RP’s contractor collected an additional water sample from just outside of the eastern tank containment wall. The sample was collected to further evaluate options for re-routing off-Site water around the Site.
OSHA was periodically on Site to inspect the conditions of the work zones and monitor worker safety.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The Responsible Party is identified as Freedom Industries, and is under orders from WVDEP. There are four orders and one revision to an order. Orders include: a cease and desist order; an order to develop a plan to empty all 14 tanks on Site; an order to remove all material from on-site above ground storage tanks (AST) by March 15, 2014; an order to report all on-site and all information of MCHM/PPH; and an order to begin to dismantle all ASTs on or before March 15, 2014.
2.1.4 Progress Metrics
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