Problems with Rockwool and the Water

Early Onsite Issues

Rockwool has been operating since July 7, 2021 and yet there are already issues that may threaten the groundwater and the water resources of the region. The DEP has failed to take action to protect the water resources or human health.

DEP site inspection reports of Rockwool and its correspondence from June and July of 2021 reveal that Rockwool transferred Process (polluted) water from the Reuse Pond to the Stormwater Pond in direct contradiction to its permit; had unreported spills of unknown quantities of unknown substances with unknown effect on the groundwater; and that the pond liners are allowing water to accumulate under them and require repair in both ponds in multiple locations.

Despite all of this the DEP failed to issue even one notice of violation to Rockwool during either of the most recent inspections. These inspections were the first in over a year and were only carried out because the Foundation requested them.

Now the DEP has informed the Foundation that it will no longer communicate with us about Rockwool. This abdication of its duty to the public by the DEP is frankly not surprising but it is incredibly frustrating.

West Virginia has been delegated the duty and responsibility of administering the National Pollutant Discharge Elimination System (NPDES) program in West Virginia. The NPDES program under the Clean Water Act protects the water quality of waters of the US (navigable waters) and waters of the State (surface and groundwater). As the administrator, the DEP grants permits for the discharge of water and monitors enforcement and compliance with permits and state and federal laws and regulations. While the EPA maintains ultimate control of the program in states with delegated power to administer the NPDES program, the regional EPA is typically resistant to get involved in matters of permitting and enforcement. As such, we must engage the DEP, and we must demand good faith transparency and diligence from the DEP.

Timeline

Click through the timeline below by clicking on the date on the left to see the correspondence trail from Rockwool to the DEP and our responses.

Transfer of Process Water from the Stormwater Pond

On the map above, each color denotes a different drainage area.

Pink Highlighted Area:

The top drainage area in pink is more than 40 acres and drains stormwater from rooftops, parking lots, grassy areas and some roads into the stormwater pond. This water is considered “clean” stormwater because it is from the cool or clean end of the facility where the finished goods are handled. This water does still carry pollutants, though. The air emissions contain some pollutants like PM10 that fall to the ground on all surfaces at the site. These pollutants are entrained in the stormwater and carried wherever it goes. How much pollutants? Rockwool PSD (prevention of significant deterioration) Air Permit seems to suggest it is about 76 tons of PM10 per year. What is in the PM10 from Rockwool? The PM10 caries hazardous pollutants including:

• Sulfuric Acid (H2SO4) 16.4 tons per year
• Methanol (CH4))  104 tons per year
• Phenol (C6H5O)   98.9 tons per year
• Formaldehyde (HCHO)  67.7 tons per year
• Carbonyl Sulfide (COS)  1.7 tons per year
• Hydrogen Fluoride (HF) 1.7 tons per year
• Hydrogloric Acid (HCl)  1.3 tons per year
• Hexane (C6H14)  0.3 tons per year
• Benzene (C6H6)  0.1 tons per year
• Lead (Pb)  <0.1 tons per year

Green Highlighted Area:

The drainage area marked in green drains the “dirty” or hot end of the facility. This stormwater contains process water and far more pollutants. This is because it drains the floor drains from the truck washing station, the area around the raw material storage area, the Melt for Reuse area, and the end of the facility where the product is made, where more fugitive emissions are expected to fall to the ground and be entrained in stormwater. This stormwater drains into the Reuse Pond. The water in the Reuse Pond is process water as defined by the EPA. The EPA defines process water as “Process Wastewater means any water which, during manufacturing or processing, comes into direct contact with, or results from the production or use of any raw material, intermediate product, finished product, byproduct, or waste product.” (40 CFR 122.2) This water washes over and therefore comes in direct contact with the intermediate products in the melt for reuse area. What is included in this material? It includes blast furnace slag, converter slag, high-aluminum kaoline clay, aludross (byproduct of aluminum smelting), coal, pet coke, coke fines, anodes, dedusting oil.

Melt for reuse are or B170:

In the image above, see the large piles of material. This area, according to the air permit, is meant to store Melt for Reuse (which is material from the Melting Furnace). Once a week, the Melting Furnace is shut down and this allows the residual melt still in the furnace to harden, which is then removed and stored here. Once a quarter, a portable crusher (machine that makes gravel at a quarry) is brought in and crushes this material so that it can be reused in the melting furnace. It is again then stored here until it is reused. During that time, rain falls on this material and eroded pollutants from this pile are entrained in the stormwater. The stormwater is collected by the gutter around the outside of the area and goes into the drop inlet (noted by the black sock around the grate), then is conveyed to the Reuse Pond. In this way, the Melt for Reuse area contributes a significant amount of pollution to the Rainwater for Reuse Pond. Rockwool’s videos and the inspection reports show that Rockwool is taking process (polluted) water from the Reuse Pond and transferred it to the Stormwater Pond. The Stormwater Pond outlets to the environment where the discharged water and any pollutants it may carry infiltrates into the groundwater. While the inspection report stated that none of this water discharged to the environment, no information was given as to how this was achieved over several weeks when the rain was so heavy, and the valve that is meant to control outflow from this pond was broken.

Liner Issue

According to the June 25, 2021 letter from Rockwool to the DEP, the liner in both the Stormwater Pond (pink shaded area above) and the Reuse Pond (green shaded area above) are having issues that require repair. Water is being allowed to accumulate under the liner. No information is given as to how this is occurring or what water is accumulating.

This diagram (at right) shows how the liner is installed. Notice that it would be difficult for water to enter under the edge of the pond if it were installed according to this diagram. The pond liner over laps the top of the pond by 8 feet and then is buried underground with a 3 foot by 1.5 foot footer.

During Rockwool’s construction, the DEP asked Rockwool to install a double liner in the ponds with an interstitial leak detection system. Rockwool refused citing the cost of the liner.

Rockwool Discharges High Levels of Aluminum

Rockwool Submitted its electronic Discharge Monitoring Report to the DEP on July 20, 2021. It revealed that in the second quarter of 2021 Rockwool reported an elevated aluminum (4.2 mg/L or 4200μg/L) and elevated iron (6.1 mg/L or 6100μg/L) in the stormwater discharge from outlet 002. It did not report any measurements for outlet 001, reporting instead that there was no discharge from 001 during Q2. However, Rockwool had elevated aluminum in the stormwater discharge of outlet number 001 during the first quarter of 2021.

Source of the aluminum

In a letter to the DEP dated July 20, 2021 Rockwool explained it thought the source of the elevated aluminum was related to “land disturbances still undergoing stabilization.” However, this explanation does not make sense. For a majority of construction, a majority of the 100-acre limit of disturbance was disturbed and unvegetated. If the aluminum was from the sediment run off, it would have been elevated throughout construction. The baseline tests done on wells and springs as part of the Foundation’s water testing program would likely have detected aluminum during construction.

Rockwool’s raw materials are high in aluminum. Rockwool uses bauxite and aluminum slag among other materials that are known to be high in aluminum. Rockwool’s Melt for Reuse and final product is at least 18% aluminum oxide[1], meaning the Melt for Reuse material should also be approximately 18% aluminum. This information is based on a 2006 article “Alumina in a Spin” in the periodical Industrial Minerals, where Rockwool is showcased as the world leading manufacturer of mineral wool; Rockwool’s final product is composed of at least 18% aluminum oxide (bioavailable form of aluminum). Rockwool states “the end product chemistry is set in stone.”

Contamination of stormwater

The stormwater from the Melt for Reuse area is meant to drain into the Reuse Pond. This Pond does not discharge into the environment (it is not designed to); instead, the water is drawn back into the process. This is supposed to stop any contaminants from the Melt for Reuse area from being discharged into the environment. However, the inadequate design of the Melt for Reuse area is allowing stormwater from the Melt for Reuse area to spill over into the grass area that drains into outlet 002. (see pictures below) It also appears that in addition to Melt for Reuse raw materials (that look similar to aluminum slag and bauxite) (see picture of jars below) are being stored in the Melt for Reuse area.

As described above, the raw material areas of the facility (green) drain to the Settling Pond of the Reuse Pond where contaminants may settle out. Rockwool must periodically clean this settling pond out. The protocol for this is described in Rockwools Storm Water Pollution Prevention Plan (SWPPP). This protocol states that Rockwool will dry out the settling pond before cleaning it out, then the material will be transported back to the Melt for Reuse area. It appears from the Foundation’s drone photos that this is not being done. It appears as though the material is being cleaned out while water is still present in the settling pond. (pic) It also appears as though some portion of the material is being spilled on the ground where these pollutants can be easily carried into the groundwater through indirect infiltration or carried into outlet 002.

Rockwool’s Operational Stormwater Permit

Unfortunately, Rockwool’s Operational Stormwater Permit (MSGP) does not address these issues. The inadequate nature of the stormwater design at the Melt for Reuse area was addressed by the permit reviewer during the permitting process. The inadequate design of the settling pond and the inadequate procedure for cleaning the settling pond out was not addressed adequately by the permit reviewer. The material in the settling pond was not addressed as a source reasonably expected to effect stormwater.

Rockwool failed to include the Melt for Reuse area, the Melt for Reuse material itself and other material stored there, the settling pond for the Reuse Pond and the procedure for cleaning this pond out as sources that could reasonably be expected to contaminate or pollute stormwater as required by the permit. Rockwool failed to characterize the chemical nature of the materials stored in the Melt for Reuse area as required by the permit. Thus, Rockwool never provided the information to the DEP that the material was high in highly soluble aluminum oxide that was likely to dissolve in and contaminate the stormwater.

This permit is simply inadequate to protect the surface and groundwater from the pollutants at Rockwool.  Rockwool failed to provide true accurate and complete information when applying for the MSGP registration it currently has. The DEP permit reviewer failed to require Rockwool to adequately address the obvious engineering issues in the stormwater design and failed to require that Rockwool provide adequate information to satisfy the permit requirements.

This is why the Foundation’s appeal of this permit and continued work at the DEP and EPA is so critical. And why further enforcement action will likely be necessary.

Groundwater contamination

As part of the Foundation’s Water Monitoring Program several springs around Rockwool were tested for Aluminum prior to Rockwool’s operation. Aluminum was below the detection limit (100μg/L Minimum Detection Limit) in these locations prior to Rockwool’s operation. Repeat sampling was done in August of 2021 following Rockwool’s discharge monitoring results. In this sampling Elk Branch Spring #1 was found to have elevated aluminum levels (189μg/L). The EPA limit for drinking water is 200μg/L. In testing done September of 2021, the same Elk Branch Spring #1 was found to have even higher elevated aluminum levels (3800μg/L), which is more than 19 times the EPA limit for drinking water and 20-fold the previous result.

Aluminum has several adverse health effects. A recent review article is here for your review.

What can you do?

Donate to the Foundation Legal Fund. Especially when new information like this comes to light, we need the help of technical experts and lawyers which increases our financial needs. And if you feel comfortable doing so, share this information with your local elected officials and ask them to help urge the WV DEP to keep our water safe and clean.

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[1] According to a 2006 article “Alumina in a Spin” in the periodical Industrial Minerals, where Rockwool is showcased as the world leading manufacturer of mineral wool, Rockwool’s final product is composed of at least 18% aluminum oxide (bioavailable form of aluminum). Rockwool states “the end product chemistry is set in stone”.