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FOSC Desk Report for the Enbridge Line 6B Oil Spill in Marshall, Michigan

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FOSC Desk Report for the Enbridge Line 6B Oil Spill in Marshall, Michigan We would lil~e to thanl~ the agencies listed below and the agencies, companies, organizations and individuals that contributed to the Line 6B response efforts. ~_.USGS ~.......s••voc• "~;;'t . ow · · ?t~ --... science for a changing world ~-;,;: . : ,~l U.S. Deportment of Tronsp()'totion Pipeline and Hazardous Materials ~•• w '<"'' ' Safety Administration ATSDR (·"'~ US Army Corps AGENCY FOR TOXIC AND DISEASE REGISTRYSUBSTANCES \,,...,_..,~}\_ of Engineers® IMICHIGANI S·H·P·O STATl: HISTORIC I PR£SCRVATION OFFICE I DE€\ D epartm e n t of AGRICUlTURE •Rura l Deve lopme nt MIOSHA ~ CALHOUN CONSE RVAT ION DI ST RI CT M ICH I GA N "We wanted to absolutely mal<e sure that this massive volume of spilled oil did not even come close to threatening one of our Great Lal<es; and as I go away from this incident, that will be something that I feel most proud of - the fact that we made sure the Great Labes were not affected." - Ralph Dollhopf "Following what is arguably the most expansive oil spill to impact a U.S. freshwater ecosystem, the success of this cleanup is a direct result of thousands of dedicated DIVISION, A responders, strong management and sound science." _Jeff Kimble EXECUTIVE SUMMARY This report has been written as outlined in 40 Code of Federal Regulations 300.165 (b) which tasks the Federal On Scene Coordinator (FOSC) to record the situation as it developed, the actions taken, the resources committed and the problems encountered. This FOSC Report documents all phases of the response to the rupture and resultant diluted bitumen heavy crude oil discharge from the 30-inch Enbridge Energy, Limited Partnership and its affiliates (Enbridge) Line 6b Pipeline which occurred on or about July 25, 2010. This report covers the period from mobilization of the first On-Scene Coordinator from the U.S. Environmental Protection Agency (EPA or Agency) on July 26, 2010 through the cessation of field activities as directed by the Agency on November 18, 2014. Report Structure This FOSC Report is organized into 13 sections, each with a subset of topics addressed as they pertain to the subject topic. When possible, these topics and subtopics are arranged chronologically to aid the reader in comprehension of the flow and progression of the response. The first sections of the report include Chronology of Events, followed by the Discharge Summary and Regulatory Authority that guided the FOSC in Sections 2 and 3, respectively. Section 4, Command and Control, outlines the structure of the response as it developed and became formalized over the life of the project. This section also explains how government and responsible party (RP) resources were managed and deployed, how support areas were arranged, and regulatory compliance efforts initiated by the FOSC. Section 5 is the largest of the report sections and explains Operations progression throughout the response. This section contains a comprehensive discussion of what work the FOSC directed Enbridge to accomplish pursuant to EPA Administrative Orders, how that work was planned and implemented, what resources were utilized, and the evolution of the strategic approaches that were ultimately necessary for success. Section 6, Planning, details the plans and procedures used to guide and control the structure of the response and collect and disseminate information and data to the crews tasked with accomplishing the work. This effort was enhanced as described in Section 8 by a large amount of highly critical and necessary science to support operations. Sections 9 and 10 describe the Logistics and Finance support of the overall project, respectively. In Section 11, the FOSC details how site communications were managed, which led to support from the community and dissemination of information to the public. Section 12 presents recommendations regarding preventative measures, ways to improve response, and suggested changes that may aid future response actions. 4 Section 13, References, is the final section and provides a bibliography on the resources utilized in the aid of development of this report. Section 1: Chronology A discharge of heavy crude oil, including tar sands bitumen blended with lighter hydrocarbon diluents (also known as DilBit), occurred from the Enbridge Line 6B into Talmadge Creek, a tributary of the Kalamazoo River, in Marshall, Michigan on or about July 25, 2010 during a flood event. The floodwaters distributed the discharged Line 6B oil along 2.2 miles (mi) of Talmadge Creek and its floodplain and downstream into the Kalamazoo River channel and its backwaters and extensive overbank areas of forested floodplains, islands, and wetlands. As the discharged Line 6B oil migrated downstream, the lighter diluent volatilized. Eventually the Line 6B oil grew denser than water and/or aggregated with sediment, submerging and settling into areas of the Kalamazoo River with lower water velocity. As floodwaters receded, drapes of oil of various thicknesses covered the floodplain areas. The downstream extent of Line 6B oil was in the vicinity of the Morrow Lake Dam, approximately 40 mi downstream of the discharge location. Because the discharge went unreported for over 17 hours, response efforts were not initiated until the following day. EPA personnel and contractors responded to the Line 6B discharge on July 26, 2010. EPA issued an initial Clean Water Act (CWA) § 311 Administrative Order requiring response actions to Enbridge on July 27, 2010. During the response, EPA issued several orders to Enbridge directing them to conduct specific work activities. These orders consolidated and formalized the work initiated under the first few days of the emergency response and lasted through the end of EPA’s on-site presence. Pursuant to these orders, EPA directed Enbridge to contain and recover all spilled oil, remove the contaminated soil and restore the source area where the spill originated, assess and implement cleanup plans for the downstream impacted areas of the spill, and work within the Incident Command System (ICS). EPA also coordinated or brought in experts to coordinate community and public health monitoring and protection, recovery and rehabilitation of impacted wildlife, and the identification and assessment of submerged oil in the Kalamazoo River system. Through the life of the response, EPA implemented managerial control of all response actions. Section 2: Discharge Summary Heavy rainfall prior to the discharge event and flooded river conditions during the discharge affected the fate and transport of the oil. Between July 22 and 25, 2010 approximately 5.7 inches of rain fell over the Kalamazoo River watershed in the vicinity of the spill. The oil was forced from the pipeline under pressure up through saturated hydric soils to the ground surface. Once the oil reached the ground surface it flowed through connected low-lying emergent wetlands as 5 overland flow until it reached the flooded channel and overbank areas of Talmadge Creek. Streams of oil moved along the surface of Talmadge Creek and its overbank areas into the flooded Kalamazoo River channel and its overbank areas within the first few hours following the onset of the spill. The discharge coincided with the peak of flooding for the Kalamazoo River on July 26, 2010, and overbank areas remained inundated for about six days after the discharge. Upon arrival at the incident, an EPA On Scene Coordinator (OSC) surveyed the extent of contamination from the discharged oil via helicopter. During the oversight, EPA observed that the oil covered the entire surface of Talmadge Creek over its 2.2 mi reach to the river, entered the Kalamazoo River, and remained as bank to bank coverage until the Ceresco Dam, which was approximately six mi downstream from the confluence of Talmadge Creek and the Kalamazoo River. At the downstream side of the dam, oil was still pervasive but diminished to approximately 50% coverage of the river surface area due to mixing and breaking up while flowing over the dam. The discharged oil was a mixture of heavy crude oils, specifically oil sand region crudes with up to 20% diluent to make the oil viscosity conducive to movement through the pipeline. The initial response actions focused on high benzene levels in air surrounding the near shore and source area environments due to volatilization of the diluent component of the discharged oil. As the oil weathered, less volatility was associated with the material. Sediment-loaded waters and river turbulence caused by man-made and natural conditions led to the formation of oil particle aggregates and sinking of some portions of the discharged oil. The National Transportation Safety Board issued a report with its determination on the causes of the discharge on July 10, 2012. Section 3: Regulatory Authority The National Contingency Plan (NCP) prescribes extraordinary requirements for EPA during an inland discharge that is declared a Spill of National Significance (SONS) or for one that is considered a “substantial threat discharge.” The Line 6B discharge clearly fell into the category of a “substantial threat discharge.” As such, from the outset, EPA affirmatively directed response actions via the FOSC and the Order. While the discharge was not formally declared a SONS, EPA Headquarters and Region 5 effectively managed it as one. Pursuant to Section 311(b) of the CWA, the EPA Administrator has determined that discharges of oil that: a) violate applicable clean water standards; and/or b) cause a sheen upon or discoloration of the surface of the water or adjoining shorelines or
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