November 6.2014 Via Hand Delivery Ingrid Ferrell, Executive Secretary Public Service Commission 201 Brooks Street Charleston, WV 25301 RE: In re: WVAWC Case No. 14-0872-W-GI Dear Ms. Ferrell: On behalf of Business Intervenors, please find enclosed the original-redacted (unbound) and twelve copies redacted (bound) of the Direct Testimony of Joseph A. Cotruvo, Ph.D., BCES. Courtesy copies of the redacted version were mailed to parties of record Should you have any questions regarding this filing, please do not hesitate to call. Sincerely, TCB/tsb cc: John Philip Melick, Esq. (USPS) Tom White, Esq. (USPS) William V. DePaulo, Esq. (USPS) Paul R. Sheridan, Esq. (USPS) 213 Hale Street, Charleston WV 25301 MAILING ADDRESS Post Offce Box 3712 Charleston, WV 25337 PHONE (304) 345-0346 FAX (304) 345-0375 PUBLIC SERVICE OF WEST VIRGINIA CHARLESTON CASE NO. 15-0872-W-GI GENERAL INVESTIGATION PURSUANT TO W.VA. CODE § 24-2-7 INTO THE ACTIONS FO WVAWC IN REACTING TO THE JANUARY 9,2014 CHEMICAL SPILL DIRECT TESTIMONY OF JOSEPH A. COTRUVO, PHD, BCES. November 6,2014 Case No. 14-0872-W-GI Testimony of Joseph A. Cotruvo, PhD, BCES November 6,2014 Page 1of 11 Q. What is your name? A. Joseph A Cotruvo PhD, BCES Q. What are your qualifications to testify about the chemical properties of the substances spilled into the Elk River on January 9,2014, and about the treatment of the contaminated water by the West Virginia American Water Works Company? 7 A. I was Director of United States Environmental Protection Agency’s Drinking Water Criteria and 8 Standards Division from 1976 to 1990, with responsibility for producing standards for drinking water 9 quality. During that time, the agency initiated the EPA Drinking Water Health Advisories to provide short 10 and long term advice on drinking water contamination from unregulated contaminants. Later, I was 11 Director of the Office of Pollution Prevention and Toxics Risk Assessment Division dealing with industrial 12 chemicals under the Toxic Substances Control Act. I received a BS in Chemistry in 1963 from the 13 University of Toledo. I received a PhD in Physical Organic Chemistry from the Ohio State University in 14 1968. I have conducted post-doctoral research in heterocyclic chemistry. Since 2000, \ have been 15 president of Joseph Cotruvo &Associates LLC, where I consult on water and environmental issues. For 16 about 25 years, I have served on the World Health Organization committee that produces Guidelines for 17 Drinking Water Quality. I also serve on several scientific advisory panels on potable water reuse 18 projects. I have engaged in numerous consultations and studies on water quality related issues and 19 organized and edited several monographs for the World Health Organization. I have more than 200 20 publications and technical presentations on a range of water and health topics. I have received 3 best 21 paper awards from the American Water Works Association, and Gold and Bronze medals and a 22 Presidential Meritorious Executive award from USEPA. I am a member of the American Chemical 23 Society, the American Water Works Association and other scientific societies. I am a technical editor for Case No. 14-0872-W-GI Testimony of Joseph A. Cotruvo, PhD, BCES November 6,2014 Page 2 of 11 the Journal of the American Water Works Association, and Water Technology. Finally, I am board certified in environmental science by the American Academy of Environmental Engineers and Scientists. 4. What were you asked to do in relation to this case? 5 A. I was asked to assess information relating to the chemical release on the Elk River on January 9,2014, 6 the chemical and physical properties of the substances spilled into the Elk River, and the water 7 treatment applied at the drinking water plant. 8 9 4. What information have you reviewed in connection with this case? 10 A. I have reviewed numerous documents, testimony, and reports that addressed the event, treatment 11 plant elements, and follow up actions, including testimony and data provided by officials of the West 12 Virginia American Water Company to the West Virginia Public Service Commission. 1 have also reviewed 13 technical information available in the published literature, including MSDS sheets. 14 15 4. What chemicals were spilled into the Elk River? 16 A. Based upon analyses provided by REI Consultants (REI, 2014) in their report of 1/31/14 the chemicals 17 were identified as: 18 Cyclohexanemethanol 1.84% 19 Methylcyclohexanemethanol (MCHM 1) 47.46% 20 Methylcyclohexanemethanol (MCHM2) 32.17% 21 1.4-cyclohexanedimethanol 5.60% 22 1-hydroxymethyl-2-methyl-1-cyclohexane 1.60% Case No. 14-0872-W-GI Testimony of Joseph A. Cotruvo, PhD, BCES November 6,2014 Page 3 of 11 1 4 related Di-PPH comoounds 11.33% total 2 and several unidentified other compounds representing less than 5% 3 They utilized a semi-violatiles scan with EPA Method SW8270D (EPA, 2007) 4 Eastman Chemical’s MSD5 (Eastman 2011) lists the crude product composition as: 5 4-Methylcyclohexanemethanol 6849% 6 4-(methoxymethyl)cyclohexanemethanol 4-22% 7 methyl 4-methoxycyclohexanecarboxylate 5% 8 1,4-cyclohexanedimethanol 1-2% 9 dimethyl 1,4-cyclohexanedicarboxylate 1% 10 methanol 1% 11 water 5% 12 13 Q. What are the properties of the crude grade MCHM and similar chemicals spilled into the Elk River? 14 A. 4-Methylcyclohexanemethanol (C8H160,MW 128.21 g/mole) is a mixture of cyclic alcohol isomers. 15 They can be produced by hydrogenation of dirnethylterephthalate in several steps. Their specific gravity 16 is ‘“0.91 which is less than pure water (LO). The products listed above are commensurate with that 17 production process. 18 1,4-CyclohexanedimethanoI (C8HI6O2, MW 144.21 g/mole) is a cyclic dialcohol byproduct of the 19 production of MCHM. Its specific gravity (1.02) is slightly greater than water (1.0).It is a waxy solid with 20 melting point of 41 to 61°C (106 to 142OF). 21 1-hydroxymethyl-2-methyl-1-cyclohexane and related chemicals would have properties similar to 22 MCHM. Case No. 14-0872-W-GI Testimony of Joseph A. Cotruvo, PhD, BCES November 6,2014 Page 4 of 11 Four related Di-PPH compounds, which are various propylene glycol phenyl ethers and related compounds, would have similar physical and chemical properties based upon the molecular weights and ether and hydroxylation levels. 4 5 4. Can you discuss the water solubility of the chemicals spilled into the Elk River? 6 A. Water solubility of pure chemicals is affected by numerous molecular structural factors, water 7 composition and temperature. Solubility generally declines as temperature declines. Several of the 8 crude product components are reported to be slightly soluble in water, which is not a precisely defined 9 term, but probably on the order of about 1%. Reported levels of MCHM in the raw water intake at the 10 WVAWWC and finished water were initially in the parts per million (PPM) range, a small fraction of a 11 percent. The water solubility of the chemical would affect the interaction between the chemicals and 12 river water, separation and mixing potential, and the composition of water that was received at the 13 water intake to the water plant. Water solubility and related chemical properties and functionality also 14 affect the interaction of the chemicals with the treatment processes being applied for potential removal. 15 The density or specific gravity relative to water’s (1.0 g/ml) for a product that has low water solubility or 16 miscibility along with turbulence will impact whether the product would tend to float on the surface or 17 sink or be suspended. 18 19 20 4. Can you discuss the taste and odor properties of the chemicals spilled into the Elk River? 21 A. A licorice-like odor was reported at numerous times. An odor panel study (McGuire et al, 2014a) 22 included consumer and expert panels. The consumer panel reported odor threshold at 0.55 pg/L (ppb, 23 parts per billion) for MCHM, and odor recognition at 7.4 pg/L (ppb, parts per billion). The expert panel’s Case No. 14-0872-W-GI Testimony of Joseph A. Cotruvo, PhD, 8CES November 6,2014 Page 5 of 11 1 odor threshold of 0.15 pg/L and odor recognition at 2.2 pg/L were lower than the consumer panel’s by 2 about a factor of 4 (McGuire et al, 2014b). 3 4 Q. What were the unit processes in the water treatment plant? 5 A. The WVAWWC plant could be called a modified conventional US water treatment plant. A 6 conventional plant’s basic processes include coagulation, flocculation, sedimentation and granular 7 media filtration by sand or anthracite coal, and chlorine disinfection. However, the WVAWWC 8 treatment process was augmented with potassium permanganate, powdered activated carbon (PAC) 9 and fixed bed granular activated carbon (GAC) probably due to potential chemical and taste and odor 10 problems from the source water. 11 12 0. What is potassium permanganate? 13 A. Potassium permanganate is a chemical that has the capability to chemically oxidize certain types of 14 chemical compounds to a greater or lesser degree and potentially reduce some taste and odor 15 properties. It is well known to be capable of oxidizing and hydroxylating chemicals with unsaturation 16 (double bonds) by converting them to diols. It can also react with some alcohols by converting them to 17 aldehydes, ketones or carboxylic acids, depending upon their structures and levels of activation. For 18 example, secondary alcohols are readily oxidizable to ketones; primary benzyl alcohols are oxidized to 19 the aldehyde and then to the carboxylic acid.