• further assessment of the impact zone;
• disconnection of potentially impacted cisterns;
• representative sampling of potentially impacted cisterns;
• cleaning of roofs and other structures/surfaces as required;
• issuance of car vouchers for cleaning of impacted vehicles;
• drinking water distribution; and
• continuation of public outreach.

EPA has also initiated pulbic outreach efforts.  A press release was issued on 12/15/2010 that included a formal statement from the Regional Administrator. 

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

The potentially responsible party (PRP) is HOVENSA.

2.1.4 Progress Metrics 

EPA has worked within the Unified Command to ensure that the statistical sampling approach proposed by HOVENSA would be adequate to address the potential contamination in the cisterns.  The EPA Environmental Response Team (ERT) has provided technical guidance to ensure the statistical validity of the sampling effort.  EPA ERT has also provided guidance on the analytical approach to be used by EPA in fingerprint and constituent analyses to substantiate whether the material released from the coker has actually entered cisterns.  HOVENSA will be conducting their own fingerprint analysis;  EPA has split approximately 50% of the samples with HOVENSA for analysis by the ERT SERAS contractor lab in Edison, NJ.  EPA analytical results will be used to confirm analytical data resulting from the HOVENSA sampling effort.

Unified Command, as of 12/17/10, has ramped up field operations and is targeting completion of roof cleaning by 12/26/10. Cistern cleaning will be on hold until conclusions are drawn from the analytical results for samples collected thus far. 

HOVENSA currently has the specified number of teams conducting the following operations: 

• 4 Roof Assessement Teams performing roof, structure and car inspections to determine the need for cleaning, verify the plume boundaries, distribute car vouchers and perform community outreach.  During the period 12/13/10 through 12/17/10, these teams were also collecting cistern samples as directed by Unified Command.  Representative sampling was completed and a total of 45 samples were collected as of C.O.B 12/17/10.  Analytical results are pending. 
• 3  roof cleaning teams are cleaning roofs that were designated as impacted via visual inspection.  Unified Command is considering that any visual contamination will require roof cleaning regardless of extent of coverage.  
• 1 "Hot Shot Team" is being used to inspect homes/roofs for impact in response to complaints recieved from the HOVENSA hotline and assist in confirming the current plume boundaries.   
• 2 water distribution teams have  been established in the Clifton Hill area to service the entire impact area and provide drinking water to area residents.  The distribution teams are being maintained at the Original Pentecostal Chruch and the St. Croix Animal Shelter in Clifton Hill. Drinking water was previously being distributed by providing bottled water.  Water buffalos (tanks) were set up to recieve WAPA water.  The tanks were installed with carbon filtration systems to remove chlorine and improve taste.  These systems have been approved by DPNR and are now on-line and being used to provide water distribution.
• 1 Cistern Reconnection Team is following the roof cleaners to reconnect cisterns at impacted residences as soon as roof cleaning is complete.  Cisterns are being reconnected as quickly as possible to satisfy complaints from area residents that they are missing critical replenishment from new rainfall events.  Information is being distributed to instruct residents that they are not to use cistern water until further notice, regardless of whether reconnection has been made. 

Cisterns were not disconnected at some residents for various reasons including:   

• the resident stated that no cistern exists on the property;
• the resident refused disconnection because no coker residues were observed by the resident;
• the resident refused disconnection because they said that the cisterns are not used for drinking,
• the resident(s) refused disconnection because the resident(s) is (are) angry at Hovensa; or  
• no one was home at the time of contact.

1. No. of roofs inspected:   236 
2. No. of Roofs Impacted:  168
3. No. of Roofs Cleaned:     84
4. No. of Cisterns Sampled:  45
5. No. of gallons water distributed:  2,569 
6. Car Wash Vouchers Issued:   118; 43 were cleaned
7. Calls Received at the call center:  82   

As of 12/15/10, the latest reports from the hospital to ATSDR had indicated that forty six patients were treated on 12/9/10 and thirty six patients (some were return patients) were treated on 12/10/10 at the hospital emergency room with symptoms that were allegedly related to this incident.  Previous statements released to the newspaper that there were 200 or more patients seeking treatment have not been substantiated and are beleived to be mistaken.  VIDOH is working with the local hospitals and doctors to substantiate these claims.

• provide oversight of PRP assessment and cleanup activities, and
• collect and analyze split samples of cisterns with HOVENSA.
• evaluate analytical results to determine impact to cisterns.
• continue public outreach.