During this reporting period, Freedom Industries gave the West Virginia Department of Highways (WVDOH) the required 48-hour notification of planned excavation near Barlow Road.  The planned excavation included clearing the trench between the road and the railroad tracks in an attempt to divert some of the off-site water away from the site.  Heavy snowfall during the reporting period delayed this work.

Three-foot diameter culvert pipe, intended to be cut into sections and placed in the intercept trench, was delivered to the site.  Work in the intercept trench was also delayed due to the large amount of snow on-site.

The facility continued to empty the storage tanks on the site.  Some of this work was made difficult by low temperatures and viscous material in the tanks.  The facility proposed a plan to decommission tanks 393 and 394, which are located at the north end of the facility.  The proposed plan included cleaning and removal of the tanks.  Approval was granted by the EPA, WVDEP, CSB, and the US Attorney’s Office to proceed with the plan.  All parties agreed that the removal of the tanks, which weigh approximately 47 tons each, would decrease the risk of the hillside slipping and allow extra room for equipment required to decommission the remaining tanks.

The RP’s contractor conducted 24-hour monitoring of the sumps and interceptor trench.  Pumping operations from the sumps, both inside and outside of the containment area and the intercept trench, occurred as needed.  All of the water that has been collected has been 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 has not been determined.

The RP's environmental consultant collected samples from the intercept trench on Friday, 2/14/14.  The samples were to be analyzed for general chemistry and treatability.  The facility planned to reference these results at an upcoming meeting with the Publicly Owned Treatment Works (POTW), which is a possible outlet for treatment and disposal of the off-site water. 

Data through 2/10/14 at WVAWC continues to show non-detect levels for samples that were collected at their intake. 

The contractor attempted to excavate a trench in the eastern area of the containment wall.  However, at a depth of approximately 4-6 inches, a petroleum odor and an unidentified pipe were discovered.  The operation was suspended and the area was backfilled.  

Three roll-offs containing MCHM-contaminated liners and soil were removed from the site.  Empty roll-offs were delivered to the site.

The WVDEP contacted the US Army Corps of Engineers (US ACOE) to request assistance with possible river levels in the coming weeks.  Heavy snowfall during the week has caused concern about rising river levels following the snow melt.  The facility and the WVDEP requested that the US ACOE assist by keeping the river level at or below 12 feet by using the Bluestone, Sutton, and Winfield Dams.  The precipitation from the previous rain storm and snow melt caused the river to crest at 12 feet and this was approximately 3.5 feet below the interceptor trench.  The US ACOE was not able to agree or disagree with the request at that time.  An additional on site tank, with a capacity of 400,000 gallons, was being prepared for water storage, in anticipation of increased water flow following the snow melt, which was expected to happen when the temperatures rise in the early part of the following week.

During routine boom maintenance, the contractor discovered a brown mass in the river.  The mass floated to the top of the river.  The mass had no odor of MCHM.  A sample of the mass was collected.  The contractor continued to monitor the boom and repair and replace areas of the boom as needed.

• Divert the runoff water that is entering the containment area;
• Maintain/improve as necessary the intercept trench between the Site and the Elk River;
• Dismantle the MCHM tanks on Site and provide the necessary portions of the tanks to investigative entities;
• Remove the three MCHM tanks from the Site. 

• There is the possibility of an unknown amount of MCHM/PPH and potentially other chemical liquids may exist beneath the tank;
• There is an unknown amount of MCHM/PPH that has seeped into the soils/materials located along the river bank;
• There is a large amount of water (approximately 500,000 gallons), potentially contaminated with MCHM, stored in tanks on Site.