This week the WV Attorney General Office (WVAGO) released their investigation report on the 2014 Elk River Chemical spill. This incident caused a mandatory Do-Not-Use (Water) order to be issued and more than 300,000 residents and countless businesses in a nine-county radius were without potable water for nine (9) days. This incident has now been tied to the Mechanical Integrity of several tanks (and their secondary containment) that held crude methylcyclohexane methanol (MCHM). The report that follows is a summary of the WVAGO findings that resulted from the investigation into the incident. Significantly, the report details the causes of the leak at the tank farm and documents how years of neglect and deteriorating conditions were overlooked and ignored by facility management team(s). Among the most disturbing findings of the investigation was that employees and outside consultants warned of a potentially catastrophic incident due to poor tank conditions and design problems for years, and in some cases offered solutions. In March 2010, an employee issued an Idea Form memo highlighting structural problems at the facility and provided options to correct the problem. Here is a summary of the findings and a copy of the full AG’s report. This is a MUST READ for professional involved in Process Safety and Mechanical Integrity at their workplaces…
Specifically, the employee’s memo stated that “tanks within the dike area are setting in water due to a lack of adequate drainage.” The memo further stated:
“All of the tank bottoms for the ten large tanks at this facility have been replaced since original installation. Slope grade is not away from the tanks and water stands in numerous areas as well as in direct contact with the tank chime and {bottom}. This is the most critical point of a tank with respect to structural integrity. Any failure of this weld or steel plate would result in a potentially catastrophic failure.”
The employee offered two alternatives to remedy the problem:
- Do nothing and replace tank bottoms when loss of containment occurs, and/or
- Dig trenches to try and move water away from tank chime and towards the sump.
Based on the investigation to date, the facility appeared to have chosen Option 1, and the predicted loss of containment and catastrophic failure occurred.
Among the other key findings detailed in this report are the following:
- Two tanks, No. 396 and 397, were more than 75 years old and had holes in the bottom which resulted in chemicals escaping from both. Specifically, tank No. 396 had two holes in the floor measuring 5/8″ x 21/32″ and 14″ x 9/32″ that were located approximately 2 l/z inches to 4 l/z inches inside the tank wall. Tank No. 397 had a 0.2 cm hole.
- Chemicals escaped from the tanks, then flowed northwest to the containment wall in front of tanks 393 and 394.
- The chemicals leaked through and under the containment wall into the rubble-filled ground covering the hillside leading to the Elk River.
- The chemicals also traveled through a corroded culvert and/or pathways created by water leaking from the culvert. The culvert runs between tanks 395 and 394 and over the embankment to the river. Hence, there were at least two entry points in which chemicals were able to flow directly into the Elk River.
- Both tanks sat above a gravel/ soil ground. A concrete pad that existed around the base of each tank did not extend under the tank. When chemicals leaked out of the tank, it leaked directly into the gravel and soil underneath. It is not known how long the chemical had been leaking from the two tanks, but it is believed that it did not start on the day the leak was reported.
- Freezing conditions on Jan. 9, 2014, as well as days leading up to it, affected the leaching into the ground and caused it to pool on the concrete pad around the tanks.
- Containment walls designed to serve as a secondary containment system in case of a leak failed due to neglect and disrepair, which allowed the chemical to flow both underneath and through the cinderblock. The WV AGO investigators documented frozen substances coming out of the wall several days after the event.
- Self-inspection reports by Etowah employees dating back to 1998 repeatedly pointed out that the containment wall was in need of repair.
- Pads sloped down toward the base (chime) of the tanks. This allowed for dirt, mud, and debris to build up under the tank and for water to pool underneath and around it. In 2010, a Freedom Industries engineer expressed concern about the slope and position of the concrete pad.
- The riverbank in front of the tanks suffered severe erosion prior to the January 2014 spill and had been noted going back to 2007. An environmental company provided four proposals to correct the erosion in 2009. None of the proposals appeared to have been accepted.
- Despite obvious warning signs, as well as internal and external inspections and reports highlighting potential problems, Freedom Industries, and Etowah Terminal failed to take reasonable, necessary corrective action.
- The WVAGO investigation also determined that tanks No. 393 and 394 had developed a tilt (due to being located on fill) and were leaning toward the Elk River, with their tipping becoming more severe over time.
CLICK HERE for the full WVAGO Report on this incident.