Corps of oil, Part 3
Part 1, Part 2
The first two parts of this series described the series of oil spills that occurred at the Corps of Engineers' three gate-and-pump structures at the mouths of New Orleans' 17th Street, Orleans Avenue, and London Avenue outfall canals, which drain into Lake Pontchartrain. In those two posts, I covered the period from May, 2006 through September, 2007, a time of serious flux for the pumps and the gates and which included 22 spills, all of which should have been reported to the feds. Fewer than half apparently got called in, a possibly very serious violation of federal environmental law.
For most of the background on spill reporting, as well as a primer on how the pumps function, Part 1 is your best bet. This part will take us up to the present day, when spill reporting has become insanely rare.
In mid-September, 2007, the Corps' Hurricane Protection Office declared the pumps "done" (page 1 here) and turned them over to the New Orleans Operations Division. It would take nearly another year for the pump supply contract with MWI to be completely closed out, but as of autumn, 2007, the pumps were effectively out of the testing phase.
And while spill response seems to have been formalized during this time with the inking of cleanup contracts, one thing did not change in the handover - the failure to report oil spills. In fact, it worsened. While some fraction of spills before the end of testing in 2007 actually got reported to the National Response Center (as required by federal law), just one spill in the ensuing three years was reported to the NRC - a 15 gallon release just this month. State reporting was poor as well. Meanwhile, the Corps paid tens of thousands of dollars to their contracted oil spill response company, Quaternary Resources Investigations of Baton Rouge, to clean up spills during that same period. There's over a half dozen task orders worth over $93,000 to QRI for spill cleanups spread over two contracts - a remarkably obvious paper trail easily cross referenced against the federal and state websites.
Many of those oil releases are related to corrosion of the pumps. As I've written in four previous posts (here, here, here, and here), corrosion has been haunting these pumps from the very beginning. The hose fittings on the pumps were rusting less than a month after they made it to the canals in June, 2006 (via SCPR Flickr):
Here's a closeup of one of those rusty hose connections (via SCPR Flickr):
Some of the leaks through the 2006-07 period can undoubtedly be traced back to corrosion-related causes. And even with a somewhat temporary fix in early 2007, it was inevitable that corrosion would catch up with the mostly carbon steel pumps sitting in the brackish waters of Lake Pontchartrain. That's exactly what has happened over the last year, as seen in these pictures of 17th Street pumps E5 and E7 after just two years in the water, taken from the 2009 Conhagen report on their repairs:
One of the ways the Corps selects pumps to be overhauled is checking which ones have corroded so badly - like those photographed above - that they are already spilling oil. The way they do this is by looking through an inspection hatch on the elbow above the pump. This happened in 2009 when the Corps discovered hundreds of gallons of hydraulic fluid had already been dumped through completely corroded parts on pump E7 at 17th Street, shown above. The story of E7 is detailed here. The title of that post, "Imminent," is taken from that Conhagen report, which warned the Corps of imminent pump failures if all the pumps were not repaired.
The Corps has not really heeded the warning. To date, the Corps has pulled only 15 of the 40 larger 60" pumps for corrosion repairs, and only the 10 yanked out this spring have gotten complete overhauls, changing out almost all the carbon steel parts for stainless steel. The five that came out in 2009 went back in the water with slightly newer but just-as-corrosion-prone carbon steel piping. The remaining 25 large pumps are just waiting for refits, turning to rust in the interim. The Corps has not set aside enough cash to do all the remaining repairs. And they have been cagey about their own, non-contracted work on the 14 smaller bridge pumps at 17th Street, so we can't really know how ready those are. Here's the status based on the work so far:
17th Street
Orleans Avenue
London Avenue
Hopefully these rusty pumps will have their inevitable corrosion-caused oil spills under clear blue skies, rather than during a storm when they are desperately needed.
There's more to it. The very act of pulling them out to address the corrosion causes of oil spills also causes an oil spill, as the hoses at the pumps are disconnected and hydraulic oil comes pouring out. Here's those hoses:
There's a good description of what happens during the removal of one of these pumps in the spill report for the May 27, 2009 removal of pump W10 at the 17th Street canal. That spill report is the only one - state or federal - for a release related to the corrosion repairs.
So in recent times there can be spills resulting from corrosion, and there can be spills resulting from attempts to address corrosion. But whatever the cause, QRI is supposed to get a task order and respond to the spill. The Corps Spill Prevention, Control, and Countermeasure - or "SPCC" - plans for each site (17th Street, Orleans Avenue, London Avenue) say so. The spill or spills must be reported immediately to the NRC, and - if the spill is greater than 42 gallons - to the state of Louisiana. Not once has the Corps reported a spill resulting from pump repairs over the last year to the NRC. In 2010, the task orders to QRI have oddly dried up as well, according to the Corps' responses to my FOIA requests.
But the failure to report spills goes beyond the 2009-10 round of corrosion-related pump overhauls. After the Corps Operation Division took over the pumps in fall, 2007, there was a spate of diesel fuel spills. Diesel powers the engines on the pump drive skids and the backup generators on the platforms. Each site has a number of large and small diesel tanks, as well as miles of piping to convey it. Secondary spill containment does not appear to have been very well designed on the parts of the structures built in 2006. That is, there is none.
The diesel spills include the release with the largest confirmed quantity to date: 1000-2000 gallons of fuel oil on October 22, 2007. That spill does not appear in the NRC or state databases.
The report to the state for another diesel spill - on April 18, 2008 - was one of the two turned over to me as a result of a FOIA request to the Corps (the other was for the May 27, 2009 spill while pulling 17th Street pump W10). That one supposedly dumped between 75 and 150 gallons of diesel to the ground and the New Orleans drainage system because a valve was left open. It too does not appear in the NRC database.
In total I count 18 spills at the three sites since October 1, 2007, with an estimated 1100 gallons of hydraulic oil and between 1100 and 2100 gallons of diesel spilled.
So, we begin with those 2007-08 diesel spills, and then finish up with the 2009-10 spills resulting from corrosion...
October 22, 2007 at London Avenue
Quantity released: 1050-2000 gallons of fuel oil (from QRI task order)
NRC report: No
LDEQ report: No
Description: From $10,140 task order #3 to the first QRI contract, here's the only information we have: "The contractor shall respond to a spill at the London Avenue Canal of about 1050 gallons of fuel spilled from a fuel tank into it's fuel containment. Heavy rainfall that night increased the fuel/water mixture. Vacuum trucks will be necessary for this spill event."
However, the line item on the same task order says "Response to approximately 2000 gallon diesel spill at London Avenue canal."
The information on this spill is scanty, but it was likely over land, not water. Due to the interconnections between the city's drainage system and the lake, this one should have been reported to the NRC, LDEQ, and others.
October 30, 2007 at London Avenue
Quantity released: 25-30 gallons of fuel oil (from QRI task order)
NRC report: No
LDEQ report: No
Description: From $3600 task order #4 to the first QRI contract, here's the only information we have: "The contractor shall respond to a spill at the London Avenue Canal of about 25-30 gallons of fuel spilled from a fuel truck."
Note that the information on this spill is scanty, but it was likely over land, not water. But like the previous one, this did not exempt it from reporting requirements.
April 17-18, 2008 at 17th Street
Quantity released: 75-150 gallons of fuel oil (from various sources)
NRC report: No
LDEQ report: Yes (Corps internal and LDEQ public)
Description: Diesel fuel oil overflowed from the small fuel tank on the skid (also known as a "day tank") for pump E6. The extra oil came from the main 20,000 gallon diesel tank on the east side of the site. A foreign substance had wedged in the seat of a main fuel valve, and a secondary valve downstream had been left open. Oil flowed through the valves to the day tank and spilled on the floor of the drive shed.
That floor - like that of all six drive sheds - drains directly to the ground below. There is no secondary containment for spills in the drive sheds. Oil contaminated the ground between the shed and the storm drains and seeped into the drainage system. The soil and gravel - an estimated 55-70 cubic yards - had to be carted away by QRI, which responded under $31,977.90 task order #6 to their first contract.
It is unclear how the Corps estimated how much diesel had gone in the city drains (they claimed it was "2 ounces or less") before they responded to the spill, since they did not witness when the spill started. According to the Corps own report, the spill was called in to the New Orleans Fire Department by a local resident at around 11 PM on April 17.
The internal Corps spill report, prepared by Corps engineer Ray Newman, explicitly excludes reporting the spill to the National Response Center:
June 26, 2008 at 17th Street
Quantity released: 35 gallons of hydraulic oil (estimate from QRI task order)
NRC report: No
LDEQ report: No (but the quantity as reported in the task order is below the state reportable quantity of 42 gallons)
Description: From $10,724.73 task order #7 of the first QRI contract: "Respond to one hydraulic oil spill at the 17th Street Canal Interim Closure Structure East Side Pump #5 Platform and Yard beginning at 0900 hours on 26 June 2008. Provide labor, material and equipment to perform environmental remediation of a hydraulic oil spill over water, but contained within the existing soft boom estimated to be 35 gallons. Spill is spread from Pump No. 1E (north) to Pump No. 8E (south) within the boom containment. Equipment to include boat, absorbent pads, soft boom and miscellaneous supplies. Remove and dispose of excessive oil-contaminated trash built up in boom containment area along with all absorbent material used in the clean up in accordance with all appplicable laws and regulations."
March 20, 2009 at 17th Street
Quantity released: Unknown. I guess 50 gallons based on description.
NRC report: No
LDEQ report: No
Description: From $5325.75 task order #3 of the second QRI contract: "Install a double boom around hydraulic pumps #3 and #7 before these pumps are pulled up from the water as scheduled 03/23/2009. Clean up all hydraulic fluid that spills during the pump liftoff and when the pumps are reinstalled after the repair. Remove the boom after the pumps are tested and function properly."
This one is quite interesting. Corrosion repairs to the hydraulic pumps didn't really start in earnest until May of 2009, but this spill response task order indicates pumps getting pulled out two months before that. I can only guess that these are bridge pumps #3 and #7 and not any of the 60" pumps along the side of the canal. If they are bridge pumps, that's very interesting, because these same pumps again got pulled out in the spring of 2010.
May 22, 2009 at London Avenue
Quantity released: 40 gallons (from QRI task order)
NRC report: No
LDEQ report: No
Description: From $5399.16 task order #4 to the second QRI contract: "Provide labor, material, and use of eqipment [sic] to clean up about 40 gallons of hydraulic fluid that spilled from pump 1E at London Avenue Canal."
The cause of this spill is unknown, and this pump was not of the four at London Avenue pulled out for overhauls over the last year.
May 27, 2009 at 17th Street
Quantity released: 40 gallons (from LDEQ report)
NRC report: No
LDEQ report: Yes
A full description of the LDEQ report for this spill can be found here.
Description: From $12,408.58 task order #5 to the second QRI contract: "Install a double boom around the hydraulic pump 10W before the pump is pulled up from the water as scheduled on May 27, 2009. Clean up all hydraulic fluid that spilled and will spill during the pump liftoff. Clean up all the hydraulic fluid that spills when the pumps are reinstalled after repair. Remove the boom after the pumps are tested and function property."
Oddly, despite the large report to the state, there is no report of this spill on the NRC website.
June 6, 2009 at 17th Street
Quantity released: 40 gallons (from QRI task order)
NRC report: No
LDEQ report: No
Description: From $7941.06 task order #6 to the second QRI contract: "Install Double Boom around Bridge Pumps #1 and #6 and clean up a hydraulic oil spill, estimated under 50 Gallons at 17th street canal."
These pumps were pulled as part of the initial piping repair work at 17th Street completed under task order #1 to the first Healtheon repair contract, as described here.
Some time just prior to July 27, 2009 at 17th Street
Quantity released: "Hundreds of gallons" of hydraulic oil (likely about 300 gallons, the capacity of one of MWI's reservoirs, though could be more)
NRC report: No
LDEQ report: No
Description: On July 27, 2009, QRI got a task order for cleanup associated with a planned spill. The oil would be spilled when pumps E5 and E7 were pulled for repair at 17th Street. The details on the planned spill are in the next description.
However, that task order is only for the cleanup resulting from planned spill during the actual pump pulls. Not reported in the task order but definitely described elsewhere is the much larger spill that precipitated the removal and repair of E5 and E7 in the first place.
From task order #3 on the first Healtheon contract: "Pump 7E - Remove inspection hatch from elbow assembly. Utilizing a vacuum truck and/or suction pump, remove approximately 700 gallons of oil with water from the pump interior water surface. Utilize a licensed contractor to dispose of oily water waste in accordance with all applicable state and federal regulations."
And from the Conhagen report on the repairs to 17th Street pumps E5 and E7: "The first thing we did was to remove the inspection covers from the pumps and check the inside of the pumps for oil. Of the 4 units overhauled, only pump 5E [could be a typo, may have been 7E] had a significant amount of oil inside the pump (several hundred gallons). The oil was pump[ed] out and disposed of."
We don't know the exact date of discovery of the spill, but it was probably some time between the pump drill on May 27 and mid-July. It is remarkable that there is no NRC or LDEQ report on this particular incident. The spillage of hundreds of gallons when there was nothing else going on at the site - I would think - would be something worth alerting the feds and the state about, especially since it is required by law.
July 27, 2009 at 17th Street
Quantity released: 50 gallons (from QRI task order)
NRC report: No
LDEQ report: No
Description: QRI got $4531.78 task order #7 for the cleanup in connection with the pulling of pumps E5 and E7, which were repaired by Conhagen under task order #3 to first Healtheon repair contract. The QRI task order estimates the spill to be less than 50 gallons, the contractural designation for a "small" spill. I suspect it was a little larger than that (the pull of just pump W10 in May at the same site produced 40 gallons on its own - surely two pumps would spill more).
The much larger spill that precipitated that repair is described immediately above.
On or about September 4, 2009 at 17th Street
Quantity released: Unknown. I guess 80 gallons (40 gallons per pump).
NRC report: No
LDEQ report: No
Description: Task order #3 to the first Healtheon contract called for pulling four pumps out of the water at 17th Street - E5, E7, W8, and W9. But task order #7 to the second QRI contract only called for spill response for two of those pumps - E5 and E7. There is no task order for spill response to pulling the other two pumps. Yet they did get pulled and repaired, as shown by the Conhagen testing records.
I am basing the date of this incident on those testing records, assuming that W8 and W9 were pulled out around the same day E5 and E7 were tested in the canal. That may or may not be right, but my point is there is no reporting of the oil spill involved in pulling two of the four pumps Conhagen worked on under this work order in 2009.
On or about February 16, 2010 at 17th Street
Quantity released: Unknown. I guess 80 gallons (40 gallons per pump).
NRC report: No
LDEQ report: No
Description: We know from task order #4 to the first Healtheon contract and from the March 16, 2010 Fox 8 report (detailed here) that pumps W5 and W6 were pulled out from 17th Street soon after February 1, 2010, the effective date of the task order. Using an estimate of four weeks to overhaul the two pumps, and working backward from the reinstallation date of March 16, I'm assuming they were pulled out sometime around February 16.
There is no task order to QRI for spill response for that date, or for any date in February for that matter. Nor is there federal or state reporting for this spill. Yet, the hoses had to be disconnected from those pumps and hydraulic oil had to fall in the canal. One cannot fight gravity.
On or about March 16, 2010 at 17th Street
Quantity released: Unknown. I guess 80 gallons (40 gallons per pump).
NRC report: No
LDEQ report: No
Description: From task order #2 to the new Healtheon contract and my recent posts, we know pumps E1 and E2 both got pulled out around the same time W5 and W6 were going back in. We know they went back in about a month later, on April 15, 2010. But yet again, there apparently is no task order to QRI for spill response associated with this pump removal, and there is definitely no NRC report.
On or about March 16, 2010 at 17th Street
Quantity released: Unknown. I guess 120 gallons (40 gallons per pump).
NRC report: No
LDEQ report: No
Description: We know that some of the bridge pumps got pulled out at 17th Street around this time, though the date is honestly a guess on my part. I wrote about the pulling of at least 3 bridge pumps in my post "This year's scramble." There's no federal or state reports on the oil which must have been spilled when those pumps had their hoses disconnected and were pulled up out of the canal.
On or about March 16, 2010 at London Avenue
Quantity released: Unknown. I guess 80 gallons (40 gallons per pump).
NRC report: No
LDEQ report: No
Description: From task order #2 to the new Healtheon contract and my recent posts, we know pumps E3 and E4 at London Avenue both got pulled out around the same time W5 and W6 got replaced at 17th Street. Once again, there's no reporting around the inevitable spill that results when hydraulic oil hoses get disconnected and pumps get pulled.
On or about April 15, 2010 at 17th Street
Quantity released: Unknown. I guess 80 gallons (40 gallons per pump).
NRC report: No
LDEQ report: No
Description: Pumps E1 and E2 went back in and pumps E6 and E8 got pulled on or around the 15th (see crane visible in shots taken that day at my June 3, 2010 post, "This year's scramble"). But once again, there's apparently no documentation around the inevitable oil spill when those pumps were removed.
On or about May 1, 2010 at London Avenue
Quantity released: Unknown. I guess 80 gallons (40 gallons per pump).
NRC report: No
LDEQ report: No
Description: We know from task order #3 to the new Healtheon pump overhaul contract that pumps W3 and W4 were pulled here. It happened some time shortly after E6 and E8 came out at 17th Street. But once again, as with almost all the pump pulls in 2009 and 2010, there's no documentation regarding what happened when they disconnected the oil-laden hoses on W3 and W4 over the canal waters.
June 2, 2010 at 17th Street
Quantity released: 15 gallons (from NRC report)
NRC report: Yes
LDEQ report: No
Description: "Hydraulic oil was discovered below the pumps that leaked from the pumps." Unfortunately this is all we have so far. However, the report does note the cleanup contractor was contacted, so perhaps we'll eventually see a task order on the QRI contract related to this spill.
This spill is the first one reported to the NRC in over three years, since March 24, 2007. Too little too late.
Spill activity (or inactivity) associated with pump repairs since this June, 2010 event can be found here. A brief description of the booms can be found here.
Molly Peterson and Karen Gadbois contributed to this report.
The first two parts of this series described the series of oil spills that occurred at the Corps of Engineers' three gate-and-pump structures at the mouths of New Orleans' 17th Street, Orleans Avenue, and London Avenue outfall canals, which drain into Lake Pontchartrain. In those two posts, I covered the period from May, 2006 through September, 2007, a time of serious flux for the pumps and the gates and which included 22 spills, all of which should have been reported to the feds. Fewer than half apparently got called in, a possibly very serious violation of federal environmental law.
For most of the background on spill reporting, as well as a primer on how the pumps function, Part 1 is your best bet. This part will take us up to the present day, when spill reporting has become insanely rare.
In mid-September, 2007, the Corps' Hurricane Protection Office declared the pumps "done" (page 1 here) and turned them over to the New Orleans Operations Division. It would take nearly another year for the pump supply contract with MWI to be completely closed out, but as of autumn, 2007, the pumps were effectively out of the testing phase.
And while spill response seems to have been formalized during this time with the inking of cleanup contracts, one thing did not change in the handover - the failure to report oil spills. In fact, it worsened. While some fraction of spills before the end of testing in 2007 actually got reported to the National Response Center (as required by federal law), just one spill in the ensuing three years was reported to the NRC - a 15 gallon release just this month. State reporting was poor as well. Meanwhile, the Corps paid tens of thousands of dollars to their contracted oil spill response company, Quaternary Resources Investigations of Baton Rouge, to clean up spills during that same period. There's over a half dozen task orders worth over $93,000 to QRI for spill cleanups spread over two contracts - a remarkably obvious paper trail easily cross referenced against the federal and state websites.
Many of those oil releases are related to corrosion of the pumps. As I've written in four previous posts (here, here, here, and here), corrosion has been haunting these pumps from the very beginning. The hose fittings on the pumps were rusting less than a month after they made it to the canals in June, 2006 (via SCPR Flickr):
Here's a closeup of one of those rusty hose connections (via SCPR Flickr):
Some of the leaks through the 2006-07 period can undoubtedly be traced back to corrosion-related causes. And even with a somewhat temporary fix in early 2007, it was inevitable that corrosion would catch up with the mostly carbon steel pumps sitting in the brackish waters of Lake Pontchartrain. That's exactly what has happened over the last year, as seen in these pictures of 17th Street pumps E5 and E7 after just two years in the water, taken from the 2009 Conhagen report on their repairs:
One of the ways the Corps selects pumps to be overhauled is checking which ones have corroded so badly - like those photographed above - that they are already spilling oil. The way they do this is by looking through an inspection hatch on the elbow above the pump. This happened in 2009 when the Corps discovered hundreds of gallons of hydraulic fluid had already been dumped through completely corroded parts on pump E7 at 17th Street, shown above. The story of E7 is detailed here. The title of that post, "Imminent," is taken from that Conhagen report, which warned the Corps of imminent pump failures if all the pumps were not repaired.
The Corps has not really heeded the warning. To date, the Corps has pulled only 15 of the 40 larger 60" pumps for corrosion repairs, and only the 10 yanked out this spring have gotten complete overhauls, changing out almost all the carbon steel parts for stainless steel. The five that came out in 2009 went back in the water with slightly newer but just-as-corrosion-prone carbon steel piping. The remaining 25 large pumps are just waiting for refits, turning to rust in the interim. The Corps has not set aside enough cash to do all the remaining repairs. And they have been cagey about their own, non-contracted work on the 14 smaller bridge pumps at 17th Street, so we can't really know how ready those are. Here's the status based on the work so far:
17th Street
Orleans Avenue
London Avenue
Hopefully these rusty pumps will have their inevitable corrosion-caused oil spills under clear blue skies, rather than during a storm when they are desperately needed.
There's more to it. The very act of pulling them out to address the corrosion causes of oil spills also causes an oil spill, as the hoses at the pumps are disconnected and hydraulic oil comes pouring out. Here's those hoses:
There's a good description of what happens during the removal of one of these pumps in the spill report for the May 27, 2009 removal of pump W10 at the 17th Street canal. That spill report is the only one - state or federal - for a release related to the corrosion repairs.
So in recent times there can be spills resulting from corrosion, and there can be spills resulting from attempts to address corrosion. But whatever the cause, QRI is supposed to get a task order and respond to the spill. The Corps Spill Prevention, Control, and Countermeasure - or "SPCC" - plans for each site (17th Street, Orleans Avenue, London Avenue) say so. The spill or spills must be reported immediately to the NRC, and - if the spill is greater than 42 gallons - to the state of Louisiana. Not once has the Corps reported a spill resulting from pump repairs over the last year to the NRC. In 2010, the task orders to QRI have oddly dried up as well, according to the Corps' responses to my FOIA requests.
But the failure to report spills goes beyond the 2009-10 round of corrosion-related pump overhauls. After the Corps Operation Division took over the pumps in fall, 2007, there was a spate of diesel fuel spills. Diesel powers the engines on the pump drive skids and the backup generators on the platforms. Each site has a number of large and small diesel tanks, as well as miles of piping to convey it. Secondary spill containment does not appear to have been very well designed on the parts of the structures built in 2006. That is, there is none.
The diesel spills include the release with the largest confirmed quantity to date: 1000-2000 gallons of fuel oil on October 22, 2007. That spill does not appear in the NRC or state databases.
The report to the state for another diesel spill - on April 18, 2008 - was one of the two turned over to me as a result of a FOIA request to the Corps (the other was for the May 27, 2009 spill while pulling 17th Street pump W10). That one supposedly dumped between 75 and 150 gallons of diesel to the ground and the New Orleans drainage system because a valve was left open. It too does not appear in the NRC database.
In total I count 18 spills at the three sites since October 1, 2007, with an estimated 1100 gallons of hydraulic oil and between 1100 and 2100 gallons of diesel spilled.
So, we begin with those 2007-08 diesel spills, and then finish up with the 2009-10 spills resulting from corrosion...
October 22, 2007 at London Avenue
Quantity released: 1050-2000 gallons of fuel oil (from QRI task order)
NRC report: No
LDEQ report: No
Description: From $10,140 task order #3 to the first QRI contract, here's the only information we have: "The contractor shall respond to a spill at the London Avenue Canal of about 1050 gallons of fuel spilled from a fuel tank into it's fuel containment. Heavy rainfall that night increased the fuel/water mixture. Vacuum trucks will be necessary for this spill event."
However, the line item on the same task order says "Response to approximately 2000 gallon diesel spill at London Avenue canal."
The information on this spill is scanty, but it was likely over land, not water. Due to the interconnections between the city's drainage system and the lake, this one should have been reported to the NRC, LDEQ, and others.
October 30, 2007 at London Avenue
Quantity released: 25-30 gallons of fuel oil (from QRI task order)
NRC report: No
LDEQ report: No
Description: From $3600 task order #4 to the first QRI contract, here's the only information we have: "The contractor shall respond to a spill at the London Avenue Canal of about 25-30 gallons of fuel spilled from a fuel truck."
Note that the information on this spill is scanty, but it was likely over land, not water. But like the previous one, this did not exempt it from reporting requirements.
April 17-18, 2008 at 17th Street
Quantity released: 75-150 gallons of fuel oil (from various sources)
NRC report: No
LDEQ report: Yes (Corps internal and LDEQ public)
Description: Diesel fuel oil overflowed from the small fuel tank on the skid (also known as a "day tank") for pump E6. The extra oil came from the main 20,000 gallon diesel tank on the east side of the site. A foreign substance had wedged in the seat of a main fuel valve, and a secondary valve downstream had been left open. Oil flowed through the valves to the day tank and spilled on the floor of the drive shed.
That floor - like that of all six drive sheds - drains directly to the ground below. There is no secondary containment for spills in the drive sheds. Oil contaminated the ground between the shed and the storm drains and seeped into the drainage system. The soil and gravel - an estimated 55-70 cubic yards - had to be carted away by QRI, which responded under $31,977.90 task order #6 to their first contract.
It is unclear how the Corps estimated how much diesel had gone in the city drains (they claimed it was "2 ounces or less") before they responded to the spill, since they did not witness when the spill started. According to the Corps own report, the spill was called in to the New Orleans Fire Department by a local resident at around 11 PM on April 17.
The internal Corps spill report, prepared by Corps engineer Ray Newman, explicitly excludes reporting the spill to the National Response Center:
"What other agencies were notified:
a. The New Orleans Fire Department
b. The New Orleans Sewage [sic] and Water Board
c. Louisiana Incident Reporting"
June 26, 2008 at 17th Street
Quantity released: 35 gallons of hydraulic oil (estimate from QRI task order)
NRC report: No
LDEQ report: No (but the quantity as reported in the task order is below the state reportable quantity of 42 gallons)
Description: From $10,724.73 task order #7 of the first QRI contract: "Respond to one hydraulic oil spill at the 17th Street Canal Interim Closure Structure East Side Pump #5 Platform and Yard beginning at 0900 hours on 26 June 2008. Provide labor, material and equipment to perform environmental remediation of a hydraulic oil spill over water, but contained within the existing soft boom estimated to be 35 gallons. Spill is spread from Pump No. 1E (north) to Pump No. 8E (south) within the boom containment. Equipment to include boat, absorbent pads, soft boom and miscellaneous supplies. Remove and dispose of excessive oil-contaminated trash built up in boom containment area along with all absorbent material used in the clean up in accordance with all appplicable laws and regulations."
March 20, 2009 at 17th Street
Quantity released: Unknown. I guess 50 gallons based on description.
NRC report: No
LDEQ report: No
Description: From $5325.75 task order #3 of the second QRI contract: "Install a double boom around hydraulic pumps #3 and #7 before these pumps are pulled up from the water as scheduled 03/23/2009. Clean up all hydraulic fluid that spills during the pump liftoff and when the pumps are reinstalled after the repair. Remove the boom after the pumps are tested and function properly."
This one is quite interesting. Corrosion repairs to the hydraulic pumps didn't really start in earnest until May of 2009, but this spill response task order indicates pumps getting pulled out two months before that. I can only guess that these are bridge pumps #3 and #7 and not any of the 60" pumps along the side of the canal. If they are bridge pumps, that's very interesting, because these same pumps again got pulled out in the spring of 2010.
May 22, 2009 at London Avenue
Quantity released: 40 gallons (from QRI task order)
NRC report: No
LDEQ report: No
Description: From $5399.16 task order #4 to the second QRI contract: "Provide labor, material, and use of eqipment [sic] to clean up about 40 gallons of hydraulic fluid that spilled from pump 1E at London Avenue Canal."
The cause of this spill is unknown, and this pump was not of the four at London Avenue pulled out for overhauls over the last year.
May 27, 2009 at 17th Street
Quantity released: 40 gallons (from LDEQ report)
NRC report: No
LDEQ report: Yes
A full description of the LDEQ report for this spill can be found here.
Description: From $12,408.58 task order #5 to the second QRI contract: "Install a double boom around the hydraulic pump 10W before the pump is pulled up from the water as scheduled on May 27, 2009. Clean up all hydraulic fluid that spilled and will spill during the pump liftoff. Clean up all the hydraulic fluid that spills when the pumps are reinstalled after repair. Remove the boom after the pumps are tested and function property."
Oddly, despite the large report to the state, there is no report of this spill on the NRC website.
June 6, 2009 at 17th Street
Quantity released: 40 gallons (from QRI task order)
NRC report: No
LDEQ report: No
Description: From $7941.06 task order #6 to the second QRI contract: "Install Double Boom around Bridge Pumps #1 and #6 and clean up a hydraulic oil spill, estimated under 50 Gallons at 17th street canal."
These pumps were pulled as part of the initial piping repair work at 17th Street completed under task order #1 to the first Healtheon repair contract, as described here.
Some time just prior to July 27, 2009 at 17th Street
Quantity released: "Hundreds of gallons" of hydraulic oil (likely about 300 gallons, the capacity of one of MWI's reservoirs, though could be more)
NRC report: No
LDEQ report: No
Description: On July 27, 2009, QRI got a task order for cleanup associated with a planned spill. The oil would be spilled when pumps E5 and E7 were pulled for repair at 17th Street. The details on the planned spill are in the next description.
However, that task order is only for the cleanup resulting from planned spill during the actual pump pulls. Not reported in the task order but definitely described elsewhere is the much larger spill that precipitated the removal and repair of E5 and E7 in the first place.
From task order #3 on the first Healtheon contract: "Pump 7E - Remove inspection hatch from elbow assembly. Utilizing a vacuum truck and/or suction pump, remove approximately 700 gallons of oil with water from the pump interior water surface. Utilize a licensed contractor to dispose of oily water waste in accordance with all applicable state and federal regulations."
And from the Conhagen report on the repairs to 17th Street pumps E5 and E7: "The first thing we did was to remove the inspection covers from the pumps and check the inside of the pumps for oil. Of the 4 units overhauled, only pump 5E [could be a typo, may have been 7E] had a significant amount of oil inside the pump (several hundred gallons). The oil was pump[ed] out and disposed of."
We don't know the exact date of discovery of the spill, but it was probably some time between the pump drill on May 27 and mid-July. It is remarkable that there is no NRC or LDEQ report on this particular incident. The spillage of hundreds of gallons when there was nothing else going on at the site - I would think - would be something worth alerting the feds and the state about, especially since it is required by law.
July 27, 2009 at 17th Street
Quantity released: 50 gallons (from QRI task order)
NRC report: No
LDEQ report: No
Description: QRI got $4531.78 task order #7 for the cleanup in connection with the pulling of pumps E5 and E7, which were repaired by Conhagen under task order #3 to first Healtheon repair contract. The QRI task order estimates the spill to be less than 50 gallons, the contractural designation for a "small" spill. I suspect it was a little larger than that (the pull of just pump W10 in May at the same site produced 40 gallons on its own - surely two pumps would spill more).
The much larger spill that precipitated that repair is described immediately above.
On or about September 4, 2009 at 17th Street
Quantity released: Unknown. I guess 80 gallons (40 gallons per pump).
NRC report: No
LDEQ report: No
Description: Task order #3 to the first Healtheon contract called for pulling four pumps out of the water at 17th Street - E5, E7, W8, and W9. But task order #7 to the second QRI contract only called for spill response for two of those pumps - E5 and E7. There is no task order for spill response to pulling the other two pumps. Yet they did get pulled and repaired, as shown by the Conhagen testing records.
I am basing the date of this incident on those testing records, assuming that W8 and W9 were pulled out around the same day E5 and E7 were tested in the canal. That may or may not be right, but my point is there is no reporting of the oil spill involved in pulling two of the four pumps Conhagen worked on under this work order in 2009.
On or about February 16, 2010 at 17th Street
Quantity released: Unknown. I guess 80 gallons (40 gallons per pump).
NRC report: No
LDEQ report: No
Description: We know from task order #4 to the first Healtheon contract and from the March 16, 2010 Fox 8 report (detailed here) that pumps W5 and W6 were pulled out from 17th Street soon after February 1, 2010, the effective date of the task order. Using an estimate of four weeks to overhaul the two pumps, and working backward from the reinstallation date of March 16, I'm assuming they were pulled out sometime around February 16.
There is no task order to QRI for spill response for that date, or for any date in February for that matter. Nor is there federal or state reporting for this spill. Yet, the hoses had to be disconnected from those pumps and hydraulic oil had to fall in the canal. One cannot fight gravity.
On or about March 16, 2010 at 17th Street
Quantity released: Unknown. I guess 80 gallons (40 gallons per pump).
NRC report: No
LDEQ report: No
Description: From task order #2 to the new Healtheon contract and my recent posts, we know pumps E1 and E2 both got pulled out around the same time W5 and W6 were going back in. We know they went back in about a month later, on April 15, 2010. But yet again, there apparently is no task order to QRI for spill response associated with this pump removal, and there is definitely no NRC report.
On or about March 16, 2010 at 17th Street
Quantity released: Unknown. I guess 120 gallons (40 gallons per pump).
NRC report: No
LDEQ report: No
Description: We know that some of the bridge pumps got pulled out at 17th Street around this time, though the date is honestly a guess on my part. I wrote about the pulling of at least 3 bridge pumps in my post "This year's scramble." There's no federal or state reports on the oil which must have been spilled when those pumps had their hoses disconnected and were pulled up out of the canal.
On or about March 16, 2010 at London Avenue
Quantity released: Unknown. I guess 80 gallons (40 gallons per pump).
NRC report: No
LDEQ report: No
Description: From task order #2 to the new Healtheon contract and my recent posts, we know pumps E3 and E4 at London Avenue both got pulled out around the same time W5 and W6 got replaced at 17th Street. Once again, there's no reporting around the inevitable spill that results when hydraulic oil hoses get disconnected and pumps get pulled.
On or about April 15, 2010 at 17th Street
Quantity released: Unknown. I guess 80 gallons (40 gallons per pump).
NRC report: No
LDEQ report: No
Description: Pumps E1 and E2 went back in and pumps E6 and E8 got pulled on or around the 15th (see crane visible in shots taken that day at my June 3, 2010 post, "This year's scramble"). But once again, there's apparently no documentation around the inevitable oil spill when those pumps were removed.
On or about May 1, 2010 at London Avenue
Quantity released: Unknown. I guess 80 gallons (40 gallons per pump).
NRC report: No
LDEQ report: No
Description: We know from task order #3 to the new Healtheon pump overhaul contract that pumps W3 and W4 were pulled here. It happened some time shortly after E6 and E8 came out at 17th Street. But once again, as with almost all the pump pulls in 2009 and 2010, there's no documentation regarding what happened when they disconnected the oil-laden hoses on W3 and W4 over the canal waters.
June 2, 2010 at 17th Street
Quantity released: 15 gallons (from NRC report)
NRC report: Yes
LDEQ report: No
Description: "Hydraulic oil was discovered below the pumps that leaked from the pumps." Unfortunately this is all we have so far. However, the report does note the cleanup contractor was contacted, so perhaps we'll eventually see a task order on the QRI contract related to this spill.
This spill is the first one reported to the NRC in over three years, since March 24, 2007. Too little too late.
Spill activity (or inactivity) associated with pump repairs since this June, 2010 event can be found here. A brief description of the booms can be found here.
Molly Peterson and Karen Gadbois contributed to this report.
Labels: Rusty pumps
1 Comments:
http://www.nola.com/hurricane/index.ssf/2010/07/levee_authority_engineers_to_f.html
More corrosion issues creeping up. SELFPA-E and the Corps are having it out over whether or not extra steel (1/8" corrosion allowance) offers enough corrosion protection for a 50-year design life.
Note there's no mention of cathodic protection (sacrificial anode or induced current) in the Corps plans, either.
My 2-cents: it depends on the exact location to be installed, but probably not. It's also sort of silly to spend all the time and effort sandblasting and painting sheet pile. You could just as easily get sheet pile that comes with an HDPE-coating.
By Clay, at July 17, 2010 9:34 AM
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