MINUTES
CHEMTURA PUBLIC ADVISORY COMMITTEE (C.P.A.C.) MEETING
Thursday, November 1, 2012
Council Chambers
Present:
Dan Holt
Vivienne Delaney
Ron Campbell
Sebastian Siebel-Achenbach
Mark Bauman
Dwight Este
Jeff Merriman
Jozef Olejarz
Alex Zorzitto
Chemtura Canada Co./Cie
Chemtura Canada Co./Cie
Chemtura Canada Co./Cie
Chemtura Canada Co./Cie
Steve Quigley
Steve Harris
Conestoga Rovers and Associates
Conestoga Rovers and Associates
Laura Fracassi
Robin Grey
Sussex Group
Sussex Group
Bill Bardswick
George Karlos
Steve Martindale
Jackie Lamport
Jamie Connelly
Ministry of the Environment
Ministry of the Environment
Ministry of the Environment
Ministry of the Environment
Ministry of the Environment
Eric Hodgins
Regional Municipality of Waterloo
Dr. Henry Regier
Alan Marshall
Richard Clausi
Sandra Bair
Nick Betts
Larry Wiens
Resident
Resident
Resident
Resident
Resident
Resident
Gail Martin
Elmira Independent
Julie Forth
Township of Woolwich (Recorder)
Regrets:
David Brenneman
Christine Broughton
1. Call to Order
Dr. Holt called the meeting to order at 6:04 p.m. and had guests introduce themselves. He also raised
awareness for Movember.
Dr. Holt reported that he met yesterday with Dr. Jim McGeer, Associate Professor Biology, Director, Laurier
Institute for Water multi-disciplinary and collaborative mission which combines hydrological sciences, ecology
and biochemical sciences, public policy and management and all of the various areas of research that go with
it. They discussed the possibility of CPAC doing some things with the institute i.e. working with some of the
students in research projects or dissertations.
1
2. Roll Call
Dan Holt
Chair
Mark Bauman
Ron Campbell
Vivienne Delaney
David Marks
Sebastian Siebel-Achenbach
3. Approval of Agenda
MOVED BY David Marks; SECONDED BY Vivienne Delaney: THAT the Agenda of the November 1, 2012
CPAC Meeting be adopted.
CARRIED…
4. Delegations (10 minute max)
4.1 Mr. Alan Marshall
Referring to the two page document signed by Jamie Connelly, Mr. Marshall highlighted the following:
Limitations at the end of the second page advise the public that Mr. Connelly, Senior Hydrogeologist for
the MOE had written the two page document based on the data provided by Conestoga-Rovers &
Associates (CRA), clearly indicates no guarantee the information is accurate, says all his conclusions
recommendations and opinions are based on information from CRA that he does not stand behind. Mr.
Marshall stated he finds it astounding that the government and regulator would put into a document they
are relying on industry and suggesting they do not stand behind their document.
The document of October 31, 2012 it basically attempting to do a review of Alan Deal’s document of
August 29, 2012 with one difference, the CRA document dealing with probable DNAPL found 20 years
ago near Elmira water tower. CRA came up with the ‘oopsie’ defense with several lines of evidence
suggesting DNAPLs. When CRA responded on August 29th skipped odours that came up from oil
samples. Jamie Connelly in his review addressed allegedly elevated Chlorobenzene concentrations at
OW57-32R stating they are really not elevated only 3000 parts per billion… significantly less than 1%
solubility. Mr. Connelly continues to suggested acetone may be responsible. Alan Deal undercuts him,
states some compounds at not typically detected in groundwater beneath the Elmira area. Mr. Marshalls
finds it an incredible reach and stretch of imagination to blame acetone for allegedly higher
concentrations of Chlorobenzene. Also, Jamie Connelly refers back to study done by CRA on cosolvency. Study referred to mercaptobenzothiazole (MBT) not Chlorobenzene. MBT as it is known has a
very low solubility and at aquifer temperatures is normally a solid. Astounding when discovered off-site at
concentrations 1-4000 times its lab solubility. Study done by CRA compared acetone concentration in
groundwater with MBT. No study of acetone increasing solubility of Chlorobenzene. Therefore, if Mr.
Connelly is going to make a conclusion he needs data from a neutral unbiased party that would indicate
that if acetone existed in groundwater that it would affect solubility in groundwater. Mr. Marshall quoted
“The acetone itself is subject to rapid degradation and consequently detected at low levels or not at all in
current monitoring” Jamie Connelly does not mention what kind of monitoring however the implication is
clearly groundwater. Mr. Marshall added this statement is not accurate. Acetone does degrade rapidly in
the air. It will also volatilize in the subsurface above the water table. In groundwater it does not degrade
faster than other solvents. Mr. Connelly is making an excuse why they do not have acetone today.
Acetone essentially is a non-issue. There were some concentrations in half dozen wells in worst
contaminated spots on the Chemtura site. If Jamie Connelly is going to make statements, he needs to
back them up. Overall the two page document inaccurate and incorrect. Mr. Marshall further quoted,
“However I do note there is no evidence that either the Borg Textiles or Varnicolor sites are source
properties for Chlorobenzene contamination. No evidence for acetone as a co-solvent for
Chlorobenzene.” Mr. Marshall suggested there are seven separate pieces of evidence indicating that
either Borg Textiles or Varnicolor are a source property for Chlorobenzene concentration. The seven
pieces are the iridescent sheen on the mud recirculation water taken from 30m below the surface, stained
soil cuttings that have been assiduously avoided by CRA and Jamie Connelly, odours from over 100 feet
below ground surface has been ignored, Although 3000 parts per billion have been higher concentrations
historically of 4800, 5000 ppb which are 1% solubility. The Howard Street storm drains as mentioned in
last months delegation Chlorobenzene was discovered in surface storm drains running down Howard
Avenue between Borg Textiles and Varnicolor (see Golder Report ‘90s and Canviro ‘86). Finally last two
add to weight of evidence, Alan Deal’s report August 29, 2012 and Jamie Connelly’s report yesterday add
2
evidence to probability of DNAPL by water tower, he alleged the reports are unscientific, unsupported
and inaccurate.
5. Approval of Minutes
5.1 Minutes of September 27, 2012
Page 1, under Present, David Marks was present
Page 2, 4.1, last sentence to read “Mr. Marshall stated that the MOE locally have a long history to live up
to and he eagerly awaits their fact based, scientific analysis based upon their obvious self interest
in putting this issue to rest.”
Page 5, paragraph 8, last sentence to read, “Alan Deal responded he did not do that part of the report but
sometimes we get anomalous results.”
Page 6, paragraph 7, sentence one and two to read, “Ron Campbell asked how many wells are not
showing increasing or decreasing trends. Alan deal responded 50-60 wells.”
Page 9, Alan Marshall clarified that Richard Clausi commented that unless the bottom of the Creek was
concreted that there would be sediment.
Page 9, paragraph 6, sentence 1, to read “Ron Campbell clarified that looking at the downstream
contaminants and sediments is not a priority action item in terms of priorities established with Dr.
Gail Krantzberg.”
MOVED BY Sebastian Siebel-Achenbach; SECONDED BY Ron Campbell:
September 27, 2012 CPAC Meeting be adopted as amended.
THAT the Minutes of the
CARRIED…
6. Business Arising from the Minutes
6.1 Chemtura Public Advisory Committee
6.1.1 Plant Activities Summary for October, 2012
Jeff Merriman highlighted the following from the Plant Activities Summary. There have been no
odour complaints. Flowrates are above target containing contaminated groundwater. Work
continues on design on remediation for gravel pit 1 and 2 on southeast part of property in support of
permit application to the GRCA. Anticipate getting on way with that work late spring early summer
of 2013. Computer modeling work has been big undertaking for CRA. Most of the work was done
by Steve Harris. Certificates of approval appreciate hearing comments from CPAC, those
forwarded to Ministry, continuing to review application. Anticipate receiving approval soon.
Community Outreach - Chemtura website now up and running. Information on the Canadian
facilities, Responsible Care® commitment, and upcoming events is available. Additional features
and links will be added in the future. Very pleased with turn out for community fall day on October
20th about 170 people took in poster displays and videos and tours of groundwater treatment
facility. This is one important way to engage directly with people of community.
Jozef Olejarz thanked Dr. Holt for attending the Community Fall Day. Neighbours and people who
live in Elmira attended. The media was present. Former employees that attended were surprised
about changes at the plant as it had been many years for some since they saw the plant. There
was a total of 9 plant tours. 20 people per bus. Hope to continue with those events and in the future
invite others to see first had to see how the plant works and meet employees. Guests had a chance
to talk directly to them about what they do and how they work.
Jeff Merriman provided information on a second handout with the Plant Activities Summary. One
question raised at the last CPAC meeting, summary similar to Appendix ‘D’ of Annual Monitoring
Report what percentage of wells that have increasing, decreasing or no trends for three primary
contaminants.
6.1.2
Status Report on 5 Year Groundwater Computer Modeling – Presentation – Steve Quigley
Steve Harris
Steve Quigley introduced Steve Harris who manages CRA’s numerical modeling and is a Company expert in
groundwater modeling. He has been the technical lead on putting this model update together. He
will assist in answering questions at the end of the presentation.
Started with Executive Summary. Tool to determine next steps to achieve requirement to clean up aquifer by
2028 consistent with the Optimization Study. The updated model shows dynamically the need to
relocate extraction wells to where they are required, need to increase pumping rates and/or in-situ
remediation. Need to inject chemicals into the subsurface to degrade NDMA and Chlorobenzene in
3
key locations to achieve aquifer clean-up. In order to determine which the correct option to select
there are some data gaps needed to fill.
Recommendations based on the model driven by mission to identify alternatives that will assist Chemtura in
achieving remediation their commitment to clean-up the Municipal Aquifer by 2028.
 Resolving data gaps, areas in aquifer where we are not certain what conditions are. We think that the
aquifer thins near E7, need to find out where it thins out. Close to plant site is a municipal aquitard. An
aquitard is a zone of clay material where there is little groundwater flow. Need to know the limit of that
aquitard in the area of the plant site.
 Run the model and look to see where need to pump water.
 Pilot testing, not until recently has it become feasible to do in-situ remediation of NDMA in groundwater.
Lab test done recently, indicate may work and want to pilot test this.
 Several recommendations with respect to pumping groundwater. MOE has given permission to pump
wells need to apply to pump more groundwater. Company should be pumping as much as permitted.
 Want to do pumping tests on monitoring well, can pump well or install an additional extraction well to
remove contamination that is there. Need to know where can extract wells. Some movement needs to
take place. Where can they be installed to get water to treatment system.
 Recognize recommendation to install wells that are far away from existing pipelines. Talking to vendors
now about complications or issues associated with that.
 Timing is critical. Need to do these things as soon as is practical. Locations seen in some plots significant
NDMA contamination. Need to focus on these areas and address in remaining years.
 In-situ remediation in key areas highly recommended.
 Model is digital representation of the natural environment. It involves making a lot of assumptions about
what happens in the natural environment. Sometimes you are right and sometimes other things that have
gone on within that 50-200 m. need to take groundwater samples and monitor performance based on
what is actually seen.
 Groundwater model is an important tool. Use to refine new well locations and pumping rates.
 Cease operating wells that a having marginal impact on clean up and reallocate the capacity of the
existing systems to new wells. If a well has reached remediation targets it should be shut down take the
treatment capacity and use it in another location where it is needed. New pipelines may be needed.
 Treat groundwater when required but bypass treatment systems with groundwater that does not require
treatment for surface water discharge.
Those are recommendations from modeling work.
Will frame where recommendations from
Off-site collection and treatment system – MOE 1990 Control Order required Uniroyal Chemical to develop a
long term collection and treatment system. That treatment system was first described in 1994 in
the Ministry’s approval of the Remedial Action Plan which provided for extraction wells that would
be installed in the town. (Showed maps of extraction wells. Two wells, pipe lines and treatment
system called the Off-site Containment Treatment System (Off-Site CTS). The Off-Site CTS started
in August 1998 and within a year the Company began drilling and installed W5A and W5B. Off-Site
CTS operated with well at south of town that was the Municipal supply well E7 or E9. Started with
E9 and moved to E7. System contained groundwater and removed contamination from aquifer.
The system that operated from then on included the wells W3 and W4 and W5A and W5B installed
near the plant site. Treatment system that was constructed at the time - activated carbon, removed
in the towers and then water flows through UV oxidation system, water is then discharged to
Canagagigue Creek under approval by the Ministry. Built and operated in 1990s most of it operates
in similar fashion today. As part of ongoing assessment of what to do with groundwater
contamination under the town, we do and did look at alternative technologies.
Described alternative technologies looked at. Physical source removal, in the case of the off-site groundwater
being remediated no lagoons pits or disposal area that can be excavated. Can not go in and
excavate over 2 square km. to remove this material, it is not feasible. Pump and treat is the
technology being used and it is effective. Physical barriers, put in some sites a sheet pile wall and
excavate a trench were contamination is relatively shallow (up to about 50-60 ft) and there is
generally restricted to a source area where you would install physical barrier. Contamination is too
wide spread, this would not be effective. Air sparging is a technique where air is bubbled through
the aquifer volatilizing contamination also used to inject air or methane to act as a mechanism to
4
increase the biological degradation of contaminants in the groundwater however it will not work on
NDMA.
Hydrofracturing enhancements are potentially applicable. Want to move contaminants out or in-situ treatment
chemicals into low permeable zones. Need to evaluate feasibility in conjunction with in-situ
oxidation. Might work for some in-situ techniques or additional pumping, has to be analyzed through
feasibility analysis and looked at in pilot test.
In-Situ Chemical Oxidation is injection of oxidant into sub surface. Do not have to pump water. How much
oxidant do you need to inject, however far does it travel, how long does it last – need of pilot study.
In-Situ Enhanced Bioremediation is where we inject nutrients and potentially substrate to biologically degrade
contaminants – not effective for NDMA.
Treatment walls install involve the installation of material into a trench as water passes through the material
the contaminants degrade – due to the wide spread area of contamination, this is not applicable or
effective technology for this circumstance
Monitored natural attenuation is using nature to take care of the contamination. Degradation, disassociation,
pollution dispersion are things that occur naturally. When down to trace concentrations that is often
the case where remediation will include letting nature take its course, and monitor to make sure it is
effective.
Nanotechnology not proven to be applicable but may be available in the future.
30 year remediation timeframe was developed from 1980s era groundwater flow and transport model that no
one is using or relying on. However, this is immaterial as it has been ordered. It is in the 2000
Amending Order that the Company is required to clean-up by August 2028 and the Company is
working towards it.
What is groundwater modeling? Groundwater modeling is a science developed over past 30-40 years and
began to be used to assess the success of clean-up, design of remediation systems groundwater
movement in the late 80s and 90s. Digital representation of what occurs in environment. Put
together simple illustration of issues in groundwater monitoring. Showed image of aquifer and
different layers confined aquifer, aquitard, unconfined aquifer, vadose zone. Discussed water flow
through different materials and different hydraulic gradients. Need to understand these items to
reflect natural conditions in the model. Some professional judgment goes into calibration. Have to
look at representativeness of the model how does it match conditions that are observed. Model is a
predictive tool, best tool available to assist in deciding correct path to achieve the remediation
objective.
Don’t typically expect model to give precise prediction of future conditions however it is an important tool to
determine next steps. There are some natural boundaries to the groundwater system. The
Conestogo River and Grand River are discharge points for groundwater and act as limits for what
we model as we know the elevations. In the North end there is an assigned a fixed hydraulic head
boundary important to determine how much water flows through aquifer. The purple grid cells
represent cells in model. Cells in centre of town 10m square, reflects amount of data in middle of
town, less information as move further away. Think about groundwater model as a three
dimensional Excel spreadsheet. Cross section of layers in the model through centre of town, need
to describe characteristics of each layer. Have 430 or more monitoring wells or more, information
used to ensure correct description and properties of those units. Once model is set up it is
calibrated and set parameters based on test results. Run model and then compare statistics, if they
match then calibration is good. Often have to go back and modify input parameters. Outcome to get
good match to observed conditions. Then have to establish transport model. Now have to establish
how contaminants move. Typically have starting concentration, an observed data set. It is very
unusual to have the release source for use in calculations. Believe best tool available to do these
analysis to guide Company to meet August 2028 commitment.
Push and pull between groundwater extraction wells, need to determine best configuration to contain what
was off-site and contain what was on-Site. Predicted we would remove 95.9 percent of NDMA in
the Municipal Aquifer by 2028. Not good enough, remediation standard 9 parts per trillion for
NDMA in groundwater. Optimization study looked at optimal configurations, simulation did not
5
completely reduce. Needed to have a dynamic system that responded to changes that were
observed in groundwater and adjust your remediation response to those changes. We removed a
lot of mass of NDMA. This is typically the problem you remove a lot of mass and then the amount
you remove declines over time and flattens out.
In Elmira have low permeability layers, NDMA present adjacent to aquitard in relatively large concentrations.
Material will diffuse into aquitard. One of the reasons way in-situ remediation is attractive to them.
Uncertainty with what was happening with bedrock, have resolved that uncertainty. Since
completing Optimization Study Company has done a lot. Prepared timeline showed timeline.
Developed seasonal pumping regime
Development and installation of ammonia treatment system which allowed them to pump greater amounts of
groundwater, addressed biological issues with the treatment system which has been significant
over the past few years.
Timeline shows a lot has been done. In 1994 when W4 was installed and the Company began operating this
system in 1998 is when the off-site remediation system began in earnest. Reviewed data collected
and changes that have occurred. The model update is very important to reflect all the data that they
have and the changes that have occurred since we did the modeling for the Optimization Study.
Pump about a million gallons of water a day through the remediation system. Not a small amount of water.
Water contains contaminants which are treated before they are discharged. Has to be an
improvement in water quality and there has been. Periods have been less in the past due to fewer
wells and operational issues.
Showed slides of changes in amount of NDMA. Total area of impact is less today. Reduction showing
significant improvement. Also looked at Chlorobenzene concentrations. Contamination reduced in
areas significantly. High concentration areas are gone in areas. Concentrations also reduced a
positive improvement.
Wells and boreholes installed since 2000. Model that CRA used is called MODFLO widely used to monitor
water movement in natural environment. We added a contaminant transport model MT3DMS. That
was developed by the University of Alabama. It is similarily used in concert with MODFLO to
evaluate the movement of contaminants by regulators, industry and consultants worldwide.
Chemtura installed 20 wells on-Site. Discussed all wells installed for monitoring and pumping. A 3D
computer visualization of geology was prepared and is available for CPAC. Recalibrated
groundwater flow model under both steady state and transient conditions.
Showed diagrams of groundwater levels that were used to calibrated groundwater flow model. Very
reasonable representation of groundwater elevations under the town. Discussed data gaps and
where more information is needed. Recalibrate transport model. Took starting conditions and
simulated the movement over 13 year period using 7 average pumping rates, to reflect changes
that occurred in the remediation system over time. How well does model match in field versus
predictions/simulations for 1998 to 2011. Reasonable match to observe conditions and predicted
conditions for past 13 year period. Modeled forward from August 2012 to August 2028. August
2011 data as starting conditions because that is the most recent information available, it assumes
nothing has changed over the course of the year.
Model confirms that alternative strategies are needed to meet clean-up targets. Began process of evaluating
alternative strategies. Looked at different operation including in-situ remediation. More pumping is
necessary to achieve objectives. Conducted sensitivity analysis as well. What was envisaged in
the Optimization Study is shown to be correct. The dynamic relocation of additional extraction wells
moving them to where they are needed will give us what we need which is to reduce NDMA
concentrations in the Municipal Upper and Lower aquifers to less than drinking water standard.
Showed models for NDMA and Chlorobenzene to show concentrations in Municipal Upper and
Lower aquifer.
In-situ remediation and increased pumping gets similar result. Need to have more pumping in addition to in
situ remediation. Wells and pumping a little different but still get result to drinking water standard.
Relocation of wells. Looking at the profile of E7, within two years water in those areas would be cleaned to
drinking water standard and would no longer have to pump water from E7 to treat it. Theoretically
the water could be used for consumption if that is what is desired. One of the extraction wells the
model said we should consider putting in is called 6A in the center of the town. Showed results if
wells are relocated.
6
Summary of Recommendations:
Data gaps to resolve
Pilot tests need to be done.
Pumping as much as is permitted by approvals as sought.
Pumping tests on monitoring wells, potentially installing extraction wells in new locations, consider feasibility
of putting in those wells. UV treatment systems at the well heads. Timing is of the essence, need to
keep moving forward. Addressing areas where residual NDMA contamination remains. Responding
to what is monitored is critical. Continue use of groundwater model. Cease to operate wells that
have done their job. Treat only what is necessary.
Done all this work and will issue report, next steps proposed are to submit work plan for data gap resolution
by end of this month. Will have the work done 60 days after Ministry approval. Submitting pilot test
work plan by December 15th will complete injections within 60 days from ministry approval. Length
of monitoring will depend on what is observed.
Engineering evaluations do concurrent with first items, completed design and approval. Looking at bulk of
work being done within next few months and believe need to move expeditiously.
Eric Hodgins stated he appreciated the presentation and commended Company and CRA for taking an
aggressive look at the whole remediation program and it is exciting to see some potential changes
coming forward. Eric Hodgins asked the following:
1. Can you explain the scenarios where you shut off wells to see what might bleed out from the aquitard,
what those entailed and what was observed? Steve Quigley clarified what they did was turn off areas
where NDMA was bleeding back into the aquifer, we have some built in recontamination of the
groundwater. Cannot validate that so we turned off those areas from bleeding back into the aquifer. It
improved things, but not sufficiently to make that much of a change.
2.
One slide showed in-situ remediation scenarios municipal upper aquifer source at some distance
from edge of Company property, however lower, you had that right up to where the pinchout occurred.
Can you provide some rationale as to why it is offset. Steve Quigley responded, if you look at the in-situ
areas in distant past there was a municipal wellfield operating in the north end of town. When this
contamination was first discovered and delineated it had two lobes one moved towards the south (E7)
and the other moved towards the north towards the north wellfield. The contamination to the north is still
a remnant of that contamination that moved to the north wellfield. It has not changed much over the
course of time. It is static and is problematic with respect to finishing clean up which is why targeted it for
in-situ program. The Municipal Lower Aquifer is the area where it is uncertain if the Municipal Lower
actually looks like this we need to delineate that. That is where contamination peaking in that area.
3.
Can you clarify which scenario E7 well cleaned up in two years and when do we get the report?
Steve Quigley responded preferred scenarios 24 and 25 which have that outcome. Mr. Hodgins also
asked what would be the configuration. Mr. Quigley replied, the total pumping rate roughly three times
the rate pumping now. Full report will be available November 8, 2012. Jeff Merriman added he has a
handout for everyone this evening, copy of presentation and 7 page executive summary of the full
groundwater modeling report. Copy of presentation does not have graphics Steve Quigley pulled up
outside of the presentation. Can make available a copy of full presentation including graphics on memory
stick for full presentation. Full report is about 3” thick, highly technical, 90 full size pages. Memory stick
copy and hardcopy available and Jeff Merriman will be taking orders at the conclusion of the meeting. Dr.
Holt polled CPAC and everyone wanted a memory stick. Also CPAC would like a 3D model. Jeff
Merriman noted he can certainly do that and suggested that be done at a separate meeting with a
presentation of the 3D model. Dr. Holt asked if this can be done at the November 29th meeting? Jeff
Merriman confirmed that yes this can be done at the next meeting.
4.
Councillor Bauman asked if there is any risk of destabilizing soils or dehydrating community with
the increased pumping. Steve Quigley responded there is a limit to what you can pump from the aquifer
because the wells will go dry. One thing need to resolve 300 gallons a minute from a well. Need to sort
through discrepancies between what model says we can try and what the aquifer can deliver. We cannot
dewater the aquifer. Councillor Bauman also asked when E7 is at a certain point if stop pumping for two
years and resume pumping will it stay at that point? Steve Quigley responded if we do the other things
recommended it should, still need to monitor. Councillor Bauman further asked if there are other
contaminants can get at and physically remove them rather than pumping them out? Steve Quigley
answered sources of NDMA on the plant site are contained. There are other sources on the site such as
the municipal landfill at the south end of the property, there has been some removal done over the course
of time but there is a physical limitation because of what is there i.e. structures and storm water retention
7
ponds. Mr. Quigley added he does not think there is a mother load of contamination that would change.
No measure they could do with source removal that would affect what model shows. Source removal on
the plant site should be evaluated on its own merit not as it relates to off site cleanup.
Councillor Bauman asked do you know what contaminants would be in each 3D cube? Steve Quigley
discussed how they get an estimate what of is in each cube. If wanted can tell what is in each cube for each
chemical. With respect to OW57-32R what is most recent observation of DNAPL in that cube? Can we
monitor it? If went into that cube would find DNAPL there? Steve Quigley responded don’t think so. Councillor
Bauman asked when was the last time it was checked? Mr. Quigley answered we monitor groundwater in
that area regularly. Looked at groundwater quality in that area. We have not installed any boreholes in that
area since we installed the initial monitoring well. Councillor Bauman stated there is an ongoing argument, if
there is a way to check, can we check? Steve Quigley responded the way to check is to measure the
groundwater quality. The groundwater quality is not indicative of the presence of DNAPL. He added the only
thing about this argument is that people talk about 1% solubility he noted this is a guide, a rule of thumb. It
has no basis in science really need to look at other pieces of evidence. The data says no evidence of
DNAPL. People doing this evaluation Jamie Connelly and Alan Deal need to trust their training and
experience.
Dr. Siebel-Achenbach asked if pumping rates for wells envisioned going up by 300% over current rates. Steve
Quigley answered 300% over what we are doing now. Overall number going up that much but it depends on
the well we are talking about. Some wells will pump at same rate, new wells will pump at similar or greater
rates. Dr. Siebel-Achenbach asked if he is not concerned that they will get those flowrates. Mr. Quigley
replied that is why we need to do the pumping tests to see what can be extracted. Dr. Siebel-Achenbach
added if the model confirms you need to get 300% increases and realistically that may not be possible are
you still going to achieve your target. Steve Quigley answered, yes, because the model supports the amount
of groundwater extraction that we are seeing. Difference between what is in the aquifer and what model has
assigned to aquifer. If model says to pump x and cannot do it physically, the performance in clean up will be
similar because will be extracting practically what can be extracted from those locations. The absolute
number will only be known once pumping tests are conducted.
Dr. Siebel-Achenbach asked if the rate was set ten years ago in the initial model. Steve Quigley replied the
Optimization Study recommended the rates but adjustments have been made over time based on the model
check that was done 4-5 years ago. Dr. Siebel-Achenbach says we are now asking for three times the level
set by the study does that indicate problems with the model. Are we confident that even three times is
sufficient to do the job by 2028. Steve Quigley responded the modeling that was done ten years ago with the
Optimization Study was not looking at this issue on containment. We structured the model if those who are
going to review it were trained in the area looking at the calibration from the Optimization Study you will see
we were focused on containing the impact. The conditions set up in that model are different than what we
have done for this model. We are now focused on what is needed to achieve 2028 targets. There are model
construction issues that are a little different it is not correct to say that this is the same model we have made
quite a few improvements and changes to give us these tools today.
Dr. Holt remarked there has been many years of lower than optimal pumping rates. How can we be assured
that the increased pumping rates will be met. Steve Quigley answered pumping rates had a lot to do initially
with restrictions on amounts that can be discharged. Those restrictions have been removed, have had
problems with biological inhibition to work through. Cannot guarantee 100% but have worked through other
problems to put them in a better position to achieve them. In addition to that, much of the treatment where
required is going to be a more straightforward exercise to achieve the pumping targets.
Ron Campbell clarified that earlier in the year the 2028 deadline would not be met based on the criteria CPAC
evaluated and then CPAC heard it would be met. What he is hearing is that we do require alternative
methods. Now he is hearing alternative strategies including new extraction wells, relocation of wells, different
remediation strategies, in-situ, possibly oxidizers and pilot studies are needed. If that does not work and if
pumping rates are not met the 2028 deadline could still be a challenge. He added his understanding is that
2028 will not be met unless we do introduce new technologies and increased pumping. Steve Quigley
responded yes, the study was to identify what needs to be done to get 2028 deadline met. CRA has made
recommendations to put the Company in a position to do that.
Alan Marshall stated CPAC would be interested in knowing that 6.5 years ago discussed that in-situ chemical
oxidation (ISCO) be in used in Elmira. April 24, 2006 meeting there was a conversation between Alan
8
Marshall and Jamie Connelly. Mr. Marshall asked him questions about it. Jamie Connelly expressed concern,
“Jamie Connelly noted that in order to effective the chemical must be in contact with contaminated material in
the subsurface, need to know where contaminants are located and then you would have to inject the material
into the subsurface and get it in contact with it. Mr. Connelly raised concerns about byproducts when break
down some of these chemicals. Hoping this isn’t the case with Chlorobenzene. Hope there is some due
diligence, hope not CRA and the MOE but CPAC get a peer review as there are issues around ISCO. Neverthe-less he applauds CRA, ISCO is a form of source removal/destruction. Alan recalled asking does ISCO
only work on dissolved contaminant or does it also work on free phase DNAPL? Mark suggested primarily it
works on dissolved but you inject it where you suspect there could be free phase. By reducing the dissolved
you increase the rate of the free phase dissolving into the groundwater. ISCO is a form of source removal
and he expressed he hopes CPAC gets a peer reviewer. Steve Quigley commented the one thing about
passage of time is you get more experience. CRA has experience using in situ chemical oxidation and know it
works on very large and complicated sites. CRA would never dream of using potassium permanganate to
clean up NDMA. Other chemicals that are more pointedly effective better for going after NDMA. Do need to
do the pilot test to see that it works and not generating any unforeseen by-products. There are some things
that need to be resolved.
Dr. Siebel-Achenbach asked regarding alternatives looked at and rejected such as source removal. Why
physical source removal was not optimal? Steve Quigley asked on-site or off-site. We have done source
removal on-Site. Where appropriate source removal should be done. The model presentation is focused on
all of the off-site contamination. The remediation strategy for the site as embodied in the original Control
Order and as implemented is to contain the impact on the site, deal with issues on the site and the Off-site
Collection and Treatment System is to collect and treat that impacted ground water. CRA and the ministry
recognized early on it was not feasible to do source removal in the context of excavation underneath a town,
not practical approach. He added on-Site there has been source removal and that is a separate discussion.
Ron Campbell clarified, do not think ministry said not feasible said is was not their jurisdiction. Steve Quigley
responded there were elements of the original Control Order that required removal. That removal was
because of an adverse affect on the natural environment. Buried Waste excavation was a source removal
program that the ministry had authority and jurisdiction to do. He noted what Mr. Campbell is referring to is
the issues related to GP1 and GP2. Mr. Campbell responded not remotely.
Steve Martindale commented the original order (1984) was to remove waste on-Site and study. 1991 order
and agreement required that on-Site contamination not be allowed off-site, that ordered containment. After
that then remediate the aquifer. The Company and consultant wanted to study if it would help clean up if
allowed some of lower concentrations of contamination be pumped off-site if collected until that time there
was not supposed to be any contamination coming off-site at all.
Dr. Holt in a report from environment agency, plumes from DNAPLs, wells drilled from surface down, shows
well can go through two or three plumes and report not contaminated even though plumes above that well
that are contaminated. Dr. Holt asked will a 3D model show if that is going through plume? Steve Quigley
responded no massive quantities of water not pumped, if missed something we would see surprising
concentrations in a particular well. Stealth plumes escaping from site are extremely rare that this would
actually happen in his experience. Mr. Quigley added the 3D model is as good as what you put into it. If
something is occurring between two monitoring points than the model will not predict that it is there.
Jeff Merriman noted that among the 430+ monitoring wells on-Site and off-site, we have nested monitoring
wells in different levels, many locations have picture in every aquifer. Not in every case have wells that
installed in different levels.
Alan Marshall clarified some of these aquifers are thirty feet thick. The well screen may be six or seven feet,
so having a well screen in the Upper Aquifer, one in the Municipal Lower and one in the Municipal Upper
literally means nothing. It is the same thing. You have a well screen at 6 or 7 feet in a 30 or 40 ft aquifer, you
could easily miss the highest concentrations.
David Marks asked are extraction wells screened to the whole aquifer. Is it fair to say if the monitoring well
misses it, the extraction well is catching it. Steve Quigley replied yes that’s correct.
Dr. Holt noted this model shows can stop pumping and treating over next 15 years, is that correct? Steve
Quigley responded, the model shows there is a way to achieve the clean-up by 2028. Dr. Holt further asked,
9
if there are contaminant in soil or bedrock very slow to dissolve if you stop pump and treat will the water
become contaminated again because you are not treating it. Steve Quigley responded there has to be an end
game discussion with the Ministry the process by which we would be shutting down portions of the extraction
system. Typically there is monitoring that needs to be done that demonstrates that those wells can be shut
down. Dr. Holt asked if this model is specifically for three different contaminants? Mr. Quigley answered this
model is for the groundwater flow system and then we’ve modeled the movement of NDMA, Chlorobenzene
and ammonia. It has been set up for those three, any other contaminant have data for can model for as well.
Dr. Holt originally there were several different contaminants, are there other contaminants that should be
included. Mr. Quigley responded there is a monitoring program in place where we do broadscan analyses on
the watering that is extracted and we also do monitoring rounds that periodically include a larger number of
contaminants.
Dr. Holt asked if CRA has data on the short and long term effects of in-situ chemicals. Steve Quigley
responded part of MOE approvals process is based on state of these chemicals. MOE is always concerned
about chemicals that are used and residuals that may be left behind.
6.2 Ministry of the Environment
6.2.1 Monthly Progress Report for October 2012
Steve Martindale reported that Jamie Connelly did his review on OW57-32R and provided a report.
6.2.2 Outstanding Agenda Questions List
Dr. Holt asked if Mr. Martindale had answers to questions relating to OW57-32R. Mr. Martindale
responded, most questions now pertain to other parties than the Ministry, dependent on answer get
from other parties. Jeff Merriman noted Chemtura/CRA had one outstanding question, answer
prepared by Alan Deal was distributed to everyone today.
Councillor Bauman noted based on the report seen, does the MOE believe that 2028 is possible.
Do you see yourself having in-house capabilities for this analysis or will you be looking for outside
help? CPAC has been looking for some independent help other than CRA. Would engage peer
reviewer to look at this report. Okay to answer at later date. Steve Martindale replied, actually
Jamie Connelly has been talking about getting some help, will be internal help. Do not see a hiring
third party at this time but the answer is premature. George Karlos added we typically will review,
have a tech report section that has expertise to review these reports. He noted he does not recall a
situation where the MOE has had to bring in outside support for a review. Something the MOE
does not anticipate but can get back with absolute for sure.
Dr. Siebel-Achenbach asked if there is any proviso if the August 2028 deadline is not met, anything
in the Control Order to suggest punishment or punitive measures? George Karlos answered do not
think anything in Control Order that sets what may happen if deadline or actions taken if deadline is
not met. The whole idea that the deadline was set based on modeling, modeling at the time would
get to result wanted. The report that came back showed that the modeling is doing its job showing
where to improve.
Dr. Siebel-Achenbach noted if the original modeling is incorrect or
underestimated the time required to get job done or seeing change in that strategy are still
confident the 2028 deadline can be met, if not what are consequences? Mr. Karlos replied, the
order states the Company and MOE will continue to remediate that aquifer until level below drinking
water standards, if get to 2028 and aquifer isn’t clean up then will keep working to get it done. Mr.
Karlos added he cannot guarantee there will not be any unforeseen circumstances.
Jeff Merriman clarified fact that what we are now seeing having to increase flowrates we have
always anticipated additional modifications and additional wells would be needed and dynamic
relocation of wells has always been part of the plan. He added the last major modeling run was
designed to get us to this point. Dr. Siebel-Achenbach remarked that we are comparing apples to
oranges on what the models were designed to do. The initial model was designed for containment.
Jeff Merriman further clarified, containment was always the objective for the groundwater on-Site.
The objective for groundwater off-site always was and still is clean-up and restoration to drinking
water standards so the modeling for the off-site effort has not changed. Vivienne Delaney asked
what happens in two years of the five year plan? Will be checking to make sure there is an update?
Or in five years will you say we should have been doing it? George Karlos replied he believes there
is annual monitoring that is happening to make sure what is supposed to be happening in the
aquifer is happening along with the five year checking points. Vivienne asked will the MOE followup with their own data or by what CRA is saying. She does not think we are getting information we
10
can rely on? George Karlos clarified, if she is asking if the MOE will do independent monitoring.
Will the MOE be keeping a closer eye on what is happening? Mr. Karlos responded the MOE has
set course through orders and annual monitoring and five year reassessment of progress. Every
five years CPAC is going to have same discussion, return to the model, surprising if CRA does not
say need to do more fine tuning, a constant continuous improvement. Need to have a date other
wise what are you working toward. Process is unfolding as designed. We will keep having these
discussions every year. If things do not pan out need another discussion. Balancing that will
continue to happen. CRA is looking at introducing things to make some areas cleaner sooner.
Dr. Holt expressed concern as to why it had to take five years to get to this point, why not institute
those changes five years ago. Bill Bardswick challenged that five years ago issues were dealt with
properly at that time and made decisions at that time that were right decisions to make. Dwight Este
appreciated Vivenne’s comments and we will take that back in terms of how we can best use the
modeling effort to keep moving forward.
Jozef Olejarz stated at a recent presentation that we need to look at scientific fact and if the model
tells need to make change, then make a change. If a bigger change is needed then we will make a
change. Equal interest as Company has an equal stake in to meet the deadline. Many discussions
and meeting and commitment to completed this model and clean up. Without information may make
a different decision or approach, many here would not expect to go that way. Need to make specific
time frame.
Bill Bardswick spoke to if the Company does not meet the clean-up date, what actions can be
taken. This question has been asked before and will provide another response. The Company is
expected to meet the 30 year deadline and will push them to meet that goal because at end of the
day, if the Company does not meet it, technically it is a violation. If they have not met a condition of
an order it is subject to referral to investigation and enforcement to determine (with lawyers) if they
have done everything reasonable to meet that number. It is a due diligence defence or did they not
do anything. There is a huge amount of effort everyone is putting in, the Company is spending lots
of money, the MOE is spending lots of resources at the end of that time period technically it’s a
violation. Did they do everything reasonable possible to avoid being in violation. Sit down with all
these technical people, work hard trying to ensure we collectively reach that goal. Suggested that
lawyer from attorney general would not take them to court for all the work that is being done,
however if that happens hope to say everyone did best to meet it. That’s the law if it all plays out
after 30 year period. Dr. Holt stated what leaves CPAC to believe this is there is no such thing as a
financial assurance attachment to 2028 deadline. Legal system will come back and say they tried
their best so too bad. Mr. Bardswick added that CPAC is raising the fact that the MOE could do a
lot more if they had more money. Mr. Bardswick stated CPAC raised the issue of financial
assurance but does not see how that relates. Dr. Holt remarked that if the Company does not meet
the 2028 deadline without financial assurance we could not continue the effort. Mr. Bardswick
replied if they do not meet the 2028 deadline, the Company is still working and spending money on
cleaning this up.
Alan Marshall noted that five years ago when we did this review Bill Bardswick said everything was
okay. In 2003 CPAC issued source removal request which was totally ignored by the Ministry and
Chemtura. There are a lot of semantics going on, there are good things happening, the source
destruction, ISCO, 300% improvement in pumping is a good thing. Five years ago it could have and
should have been done.
Bill Bardswick emphasized the on-Site and off-site have to be separated. Yes, CPAC always
wanted a more aggressive on-site clean up. The discussion tonight is about off-site clean up.
DNAPL is an issue that has gone on for ten years or longer. Hydrogeologists from all the
stakeholders have looked at this and there is a difference of opinion. Looked at this DNAPL issue,
used knowledge and skills and have given responses with respect to DNAPL issue. Do not confuse
on-site and off -site, tonight we are talking about the off-site.
Richard Clausi stated there have been significant changes in the last five years and certainly in the
last two years. We are all moving towards a common end with a lot of improvement, good
improvements and he hopes minutes of tonight’s meeting do not become part of court battle in the
future. Are moving forward but noted that there is some mistrust going back many years. Good
11
things happen then the history starts to fade into bad faith. Then things go bad very quickly. Getting
a better and better picture of what is happening. Company has come back with some wonderful
ideas. Think the Company is going right way and will continue as long as good faith is there.
Ron Campbell appreciates the efforts of CRA, MOE and Chemtura and the public point to make
legal requirements are to clean up aquifer to the Ontario drinking water standards by 2028. He
remarked that Mr. Karlos stated that the requirement is to have the aquifer come online by 2028
and I heard Eric Hodgins say that E7 and E9 were sold so there is no chance of them coming
online by 2028. Mr. Campbell clarified the requirement is to have them cleaned up to the drinking
water standard by 2028 and how that moves forward after that would be different discussions.
George Karlos replied, yes that is correct.
6.2.3
Monitoring in the Canagagigue Creek – Presentation George Karlos, Assistant Director West
Central Region
George Karlos reported on the presentation that he gave last time he was here. He has tried to get
an idea about any indicators or any pressing scientific or technical reasons about whether to go
back down into the creek for specified or targeted sampling. There is nothing driving them to a
certain type of sampling regime. Suggested that Councillor Bauman would like to see them do this
for a public confidence perspective, to get an idea of what is going on down there. The other thing
he had heard related to pond on G.P. Martin farm, swimming pond a suspicion that might be
channel that would connect between Chemtura site and where pond currently resides. The last he
heard from Dr. Siebel-Achenbach the sooner the better. Put together a proposal looking to get
going as early as middle to late November to go back down to the floodplain to revisit the three
sites, to be the most representative sites. First location will be doing sediment sampling on exposed
bank area of creek relatively close to Chemtura site, two other locations looking at in stagnant pool
where contamination was highest in 1996/97 and the third was a small pond previously located in a
grazing area. Feedback from technical support was to go back down there, follow same type of
sampling procedure as was followed in 1996/97. Have spoken with Chemtura and they have
agreed to cover the cost of independent sampling for analysis so don’t have to wait for results. First
step in the Ministry’s proposal, going downstream looking to see if fencing in place is still there and
whether or not geographically possible to equate whether or not that Chemtura site is and where
channel way is that Susan Bryant was talking about might connect to the pond on the G.P. Martin
site. Want to get CPAC’s feedback on proposal. Time is of the essence and we would like to get
staff out there as soon as possible.
Councillor Bauman noted at the beginning of the meeting we were talking about sediment areas at
the base of Creek being a gravel bottom, but there would be some sediment areas and sediment
would be moving down the stream continually. Suggested one other area of study i.e. sediment
from within the Creek, which would indicate new contamination coming in as an area to check. If
new contamination is being washed in would show up in the Creek sediment but would not change
in the ponds that would be flooded areas. That may be one more level of confidence. George
Karlos answered yes, need to do some thinking to see if that would be representative of something
coming off the property or whether it is just sediment moving around.
Dr. Siebel-Achenbach asked if issue at pond why not go to check it out at G.P. Martin pond
wouldn’t that be part of due diligence. Mr. Karlos answered yes, if the MOE believes there are
significant issues in a swimming pond on a farm then yes would check it out. Want to make sure
there have been no issues really identified. Need to go out to check to make sure the movement of
contaminant through erosion is even possible. If not possible then we simply would not be
undertaking sampling in an area without good reason. Dr. Holt asked what will the MOE be testing
for? Mr. Karlos replied total organic carbon, DDT, dioxins and furans which matches what was in
the 1996/97 report.
Alan Marshall questioned when mid to late November what will get is told wasted tax pay money, if
you were keen on this that you would be bringing a written proposal/workplan as to where, what. If
you want buy-in from public, CPAC or SWAT, give us an opportunity to actually look at it and give
feedback. George Karlos noted that first of all, at no point in any discussion was there a request for
a written proposal. The two discussions is the presentation that was made at the last meeting and
again the discussion about what the MOE is proposing. This is one of those things thinking it is a
good thing not trying to slow this down. Did not hear from CPAC don’t come back with proposal
12
unless it is a written proposal. Mr. Marshall reiterated that SWAT wants a written proposal that
identifies the areas the MOE proposes to sample. He added if we are going to get something
significant and worthwhile then let CPAC and the public see the details as to what we are saying
yes to.
Councillor Bauman stated at some point need to trust people. If we ask for exact workplan and
there could be dioxins that happen to show in that workplan before you get there to test. He stated
we can trust Mr. Karlos and his team and is anxious to go ahead with it without a written workplan.
Dr. Siebel-Achenbach stated he agrees that the decision is straight forward. Not talking about
public money being spent here as Chemtura has agreed to pay for the lab work. Alan Marshall
commented the MOE will use public money to do the sampling. Ron Campbell clarified nice to see
done in support of what George Karlos is proposing to do three or four sample spots. David Marks
supports MOE sampling, expect we will get a detailed scientific report once the sampling is
complete. Mr. Karlos responded CPAC will get a written summary in a report showing exactly what
the MOE did and their findings. He added the question is whether or not CPAC wants to rigorously
debate a written proposal and put into jeopardy when this can move forward.
MOVED BY Dr. Siebel-Achenbach; SECONDED BY Councillor Bauman: THAT CPAC agree to the Ministry
of the Environment pursuing downstream testing at Canagagigue Creek at specific sites.
CARRIED…
6.2.4. Comments on DNAPL at OW57-32R
Jamie Connelly thanked Alan for his comments and feedback. In terms of issue of DNAPL Steve
Quigley made good point. 1% is rule of thumb that is widely applied. Alan also mentioned
concentrations did not really meet 1% also look at effective solubility issue, should consider it a flag
whether or not should be looked at further. Make few points for DNAPL to move it has to be in
connected body, wants to move down when hits stratigraphic barrier a low permeability zone, it will
move out. To move out it has to have connected body needs source. At some points will move
connections. First point do not see evidence that there is a trail of DNAPL leading back to the site.
Since concentrations are elevated what alternative explanations are there. Suggested one being
acetone. Could just say that the concentrations are elevated here. Not above solublility. Suggested that
it is well established that acetone is a co-solvent and promote solubility of organic contaminants. Well
established from literature and testing at the site that there have been historical occurrences of acetone
at quite high levels. Quite plausible that acetone has historically promoted movement off site of organic
chemicals not as a DNAPL, in the aqueous phase. It has enhanced the aqueous phase solubility of
some of these chemicals. Acetone present may have degraded. Site in Hamilton acetone within a
period of approximately ten years was non-detect. It does degrade in some cases and is a perfectly
viable mechanism to understand how it can move far from the site at high levels. If there are other
questions Mr. Connelly can respond to comments. In terms of alternate sources, DNAPL does not
move with water it moves through the water under its own set of constraints and physical forces. He
reported there is no reason to think it will make it to OW57-32R as it follows the stratigraphy. Ron
Campbell asked if acetone could there be another solvent? Mr. Connelly responded that acetone is the
only co-solvent he is aware of, which is why he selected that one.
Councillor Bauman referred to the limitations comment that you can not verify if the information is
accurate or complete. When he looks at the gentlemen representing Chemtura, CRA and the Ministry,
surely someone come up with some proof if there is DNAPL there or not. Want to put this issue to bed
and move on. Jamie Connelly responded from the available data the MOE has, can say don’t think it is
at all likely that there is DNAPL at that location. Dr. Siebel-Achenbach asked if we can get third party to
assess this? Would this help out to finalize matter.
Alan Marshall commented OW57-32R is approximately southwest of Chemtura, Mr. Connelly
suggested it would be a great coincidence if happened to be in direction of the site. Already confirmed
that DNAPL may have left site in a southwest direction from the M2 area towards CH47 on the Yara
property. Alan Marshall said it is in April 3, 2006 report said that DNAPL mobilized and free phase
flowed to M2 coincidentally in the same direction. Alan first page “Migration of DNAPL from Chemtura
to off-site location would leave a trail of residual DNAPL in the aquifer core space.” Mr. Marshall noted
this is an issue he raised i.e. all residual DNAPL is a trail from a leading pool of mobile, free phase
DNAPL.
13
Jeff Merriman commented on the likelihood that there is DNAPL at this site. If there was a source of
Chlorobenzene DNAPL at OW57, we would expect concentrations in groundwater in that area to say
relatively high because DNAPL is a powerful source of contamination and can continue to load up the
aquifer. That is not what has been seen. We’ve seen initial concentrations at the extraction well. When
started pumping that well in 1998 we saw relatively high concentrations of DNAPL. If DNAPL was there
expect to see little decline in that. What we have seen is a ten fold decrease in that location. You would
not see that if there is a DNAPL source around OW57-32R this is a strong piece of evidence that
DNAPL is not at OW57-32R.
Steve Quigley asked Jamie Connelly to explain the purpose of the limitation language and second do
you believe the information that CRA supplied to you was incomplete or inaccurate. Jamie Connelly
responded limitation language standard language that the Ministry puts in part for legal reasons and
that people who read the memo are aware that Mr. Connelly does not go back and check all the raw
data and do that level of analysis. At some point you rely on other qualified professionals unless you
have reason to question it. Mr. Connelly added he has no reason to believe there is any reason to
question it. Bill Bardswick added it is standard limitation language seen on all reports, see it all the time.
If information changes then the review changes, it is a standard clause.
Alan Marshall stated that is the oldest fallacy going, that a pumping well W4 is perhaps less than 20
feet to OW57 to pretend that there is no DNAPL at OW57-32 because the concentrations have gone
down. You are pumping from another well in the same aquifer 15 or 20 feet away. If you can not
reduce the concentrations in an observation well 15 or 20 feet away by a massive pumping well then
you cannot do anything. Concentrations will decrease as long as you are pumping. Rubbish to tell
public that concentrations from well will not go down if there is DNAPL present. David Marks stated that
well did pump very high concentrations at one time. Jeff Merriman added yes it was pumping high
concentrations and DNAPL was never seen in the well and now it is a tenfold decrease. Mr. Marks
added in regards to other comments he has heard regarding OW57-32R i.e. oil slicks this was a
common occurrence in the old days when drilling wells because hydrocarbons were used to lubricate
the rods. You would see a slick on top of the mud pit. Staining, colours does not cut it because that
could be mineralization. Mr. Marks stated in his opinion he does not know if there is DNAPLs there or
not but he will look at it. Mr. Marks asked what the odours detected smelled like. He added the items
being brought up are qualitative not quantative. Mr. Marshall responded that is how it was reported by
CRA.
Eric Hodgins asked why does it matter if determine DNAPL there or not. Alan Marshall responded the
whole premise of clean-up of the Elmira Aquifer is that all the residual and/or free phase is on the
Chemtura site and allegedly there are not other sources in the middle of the Elmira Aquifer. Mr.
Marshall suggested there are a minimum of three, possibly half a dozen or more off-site. Purpose of
pumping and treating is to clean up dissolved contaminants. If off-site source material it is presuming
and assuming no off-site sources. Eric Hodgins is aware in the Elmira aquifer that the plumes have a
multitude of different sources, low conductivity materials, clays that that the material has seeped into.
No model can properly predict that. Have to shut off some of the assumed sources to properly evaluate
what might be happening that might tell us something useful. Mr. Hodgins states he does not feel all
this energy collectively trying to determine if DNAPL there all these other sources where chemical can
come in and out and does not think this is going to make any difference on remediation. There are other
sources out there. Mr. Marshall asked Mr. Hodgins if he is not concerned that if there is free phase
DNAPL pools are you not concerned that they will dissolve, even with pumping wells much more slowly.
You are referring to contaminants diffusing into the aquitard. Mr. Hodgins responded if there are
patches of DNAPL they are going to affect remediation in short term but does not matter rather focus on
the massive amount of plume and shrink down. If pumps turned off, and see rebound then need to
address whether there is DNAPL there. Other bigger picture things and energy to spend their time on.
Yes, it is important to keep there but bigger picture issues to be properly dealt with.
Vivienne Delaney expressed concern about other companies that have contaminated and is concerned
about possible other large areas. Mr. Hodgins replied he is not concerned about the other companies.
There is one plume out there and is happy to let them deal with it. Do not feel in collective energy to
spend time looking for other sources when the current source is so big and so large, and the energy,
resources and staff time needed to clean it up. If there are other sources they will be come more
apparent. He believes with the previous experience the Company and the consultants identify that
there other sources and they are the first to want to bring other companies or sources into the game
14
because it helps reduce their individual costs. Ms. Delaney asked what about other companies that
have already left. They cannot be pulled in once they have left. Eric Hodgins replied still have
Company here so what difference does it make. Ms. Delaney stated it does not seem fair they should
be dealing with other companies’ problems. Need to remember that the existing contamination took
forty years of historic practices to create, do not see these types of plumes being generated. They are
all residual, they are all historical. Vivienne added still does not seem fair that Chemtura will be paying
for other companies. Mr. Hodgins added he does not have the evidence or the responsibility to go out
and search for other companies. If this is what CPAC wants to do, and if the committee collectively
gets enough information, that then becomes a decision between CPAC and the Ministry of the
Environment. Ms. Delaney referred to Mr. Hodgins’ comment to forget about DNAPLs there is more to
worry about. Mr. Hodgins said yes, the clean up of the aquifer, the pumping system, the in-situ
remediation, the design that is where we need to focus our energies. Eric Hodgins stated there are all
kinds of complications out in the natural environment that is going to make this clean-up difficult. He
encourages and commends the Company for being more aggressive and dealing with it in a manner
that we have always hoped they would. That is what I meant by more work to do.
Ron Campbell stated that because of the settlement agreement and the funding formula Chemtura shall
clean-up aquifer. If there are other pockets get cleaned up through this town that is not a bad thing if
other things are cleaned up through this process. Mr. Hodgins noted he was referring as to whether or
not DNAPL was present at OW57 in relation to Chemtura, if there has been, it is long gone. We are
looking at dissolved phase. He added he is looking to review the report and substantiate what they are
saying. He noted he thinks that their approach seems logical.
Dwight Este stated the Control Order issued against Chemtura, we are working to clean up the aquifer.
It is not in the Company’s best interest to see if there are other sources. Ms. Delaney added in her
opinion there is more out there and who is going to go out to look at it? Mr. Este added he is not sure
that as group we look at other sources. The goal is to clean up aquifer by 2028 and that is our
commitment.
Dr. Holt reported that the Property Standards Committee is looking at Lot 91. The MOE is still working
on that ongoing situation. Jackie Lamport reported the MOE did some sampling end of July and
beginning of August, and is waiting for some results. Those results will go to tech support for review
and then will share with property owner and discussion will happen in determining what we do with
those results. Dr. Holt asked if that would have any affect on cleaning up property? Ms. Lamport
responded, no.
6.3 Chemtura Public Advisory Committee
6.3.1 SWAT
Ron Campbell finds the news about 3D modeling encouraging. He added CPAC has some
concerns regarding the statement of limitations clause. Regarding a third party technical review
consultant to work with CPAC, Mr. Campbell noted he forwarded some correspondence to Chair
Holt this afternoon that has not as yet been communicated to CPAC or the Township.
Ron Campbell reported that information provided to the committee is to be reviewed and discussed
at a later date.
6.3.2 Financial Request
Dr. Siebel-Achenbach asked if it would be possible to receive funding from Chemtura or the MOE
for a third party to review the five year plan. Jozef Olejarz suggested that CPAC has a budget and
that is what it is for, refer to budget and use it wisely. Dr. Siebel-Achenbach responded the reason
for the request is that CPAC is not able to technically review reports not able to properly assess
information provided in 3 inch document. CPAC would appreciate and feel they deserve a third
party to assist in that task. Dr. Siebel-Achenbach requested Chemtura come forward on an annual
basis to defray the cost to review these important documents. Mr. Olejarz reiterated that he would
need to see some facts. David Marks commented that one of the things CPAC discussed was
groundwater modeling. I am not a groundwater modeler as it is a niche of expertise. He added that
he is cognizant of the limitations of it but one thing CPAC did discuss was getting some prices and
providing a firm workplan. Ron Campbell comment added that CPAC feels it is an act of due
diligence of CPAC as CPAC represents that community and the public. He added that would also
assist the Ministry, CRA and Chemtura that nothing is getting missed. Dr. Holt remarked that
CPAC hopes to have something more detailed at the November 29th meeting.
15
Ron Campbell asked if Dr. Holt had anything to report in terms of the resolution put forward to the
Minister of the Environment requesting funding. Dr. Holt responded that the last thing he heard was
that the Minister had been in hospital. He is out now and it is a matter of catching up. An
appointment with the Minister is in the process of being set up.
Dwight Este noted if CPAC is looking to put together a proposal they need to be clear in terms of
what their expectations are looking for from Chemtura in their review. If you are looking for a review
as to how the modeling was done that is a rather large undertaking. If you are looking at what the
proposals are in terms of the proposed work for cleaning up the aquifer, that to us is a separate
undertaking and so I think we need to be very clear in terms of what you are looking for in a peer
review. Dr. Holt requested Mr. Este send him an outline in terms of what Chemtura would like to
see in a proposal. What are you going to look at to evaluate the request then CPAC can be more
specific in addressing those issues. Councillor Bauman noted that CPAC should be asking the
questions not expect Chemtura to ask them for us. Dr. Holt stressed not input regarding the peer
review but input regarding the financial assistance that is being asked for. Dwight Este responded
as a public advisory committee CPAC needs to come up with what it is you want reviewed and give
proposal so that Chemtura can evaluate whether to accept it or not. Ron Campbell added that
CPAC’s request for a technical consultant would go to the CAO and to the Township and they
would decide how to proceed. Direction would go to the CAO.
Eric Hodgins advised the committee that the Region of Waterloo will also be looking at the report
and to reinforce to CPAC there is a big difference between reviewing a report to look at the
modeling adequacy. Does not mean we cannot ask questions or analyze some of the assumptions
that may have gone into the modeling in order to gain an understanding of the limitations or the
accuracy of the predictions. Region’s review will focus on does model support conclusions that are
drawn and the recommendations that are made from the report. The Region will be hiring an
external consultant who is not a modeler but has previously provided input to this committee to
review and provide information to committee. He provides a very high level overview and provides
good context to committees that do not have strong scientific foundations such as this one. A
review of the details of the modeling is tens of thousands of dollars and a lot of time that would
have to go into that. Dr. Holt noted that CPAC’s request is not limited to the Five Year Review.
6.3.5 GP1 & GP2
Dr. Siebel-Achenbach restated the public’s position for the record they are not in agreement with
Chemtura’s decision to partially excavate GP1 and GP2.
7. New Business
None
8. Public Forum
None.
9. Outstanding Activity List – as of October, 2012
Not available.
10. Next Meeting Thursday, November 29, 2012 at 6:00 p.m. in Council Chambers
11. Agenda Items
11.1 3D modeling presentation at the next meeting Steve Quigley
11.2 Jeff Merriman reminded everyone that there are copies of the presentation available in addition to the
Executive Summary from the three inch report. If you require a full report they will be available in
approximately one week when they will be printed. Lastly, I heard that CPAC would like copies of the
presentation with all of the figures on a flashdrive. I will provide those for CPAC as well as anyone else
requesting a copy please see me following the meeting.
Jozef Olejarz felt offended about some of the comments made, everyone should be feel comfortable here. We
have roles and an agenda and need to move along in a timely fashion. Need to stick to rules in principles as
to who is permitted to speak and when questions are permitted. Mr. Olejarz requested assistance to look at
the protocol for these meetings. Overall, he thanked everyone for listening to the proposal. Chemtura is really
trying to solve the problem and do not have any kind of hidden agenda.
12. Meeting adjourned at 9:55 p.m.
MOVED BY Mark Bauman; SECONDED BY Ron Campbell: THAT the meeting be adjourned
CARRIED…
16