CPAC Canagagigue Creek Report – Final, July 24, 2015

1

Chemtura Public Advisory Committee (CPAC) – Final Report

Off-Site Contaminants in Sediment of the Canagagigue Creek, Elmira, Ontario

Final, July 24, 2015

CPAC Canagagigue Creek Report – Final, July 24, 2015

2

Table of Contents

1.0 Executive Summary Page 3 2.0 Introduction Page 4 3.0 CPAC Environmental Project Page 7 4.0 CPAC Field Sampling Page 7 5.0 Laboratory Analyses Page 8 6.0 Pine River: Case Study South of the Border Page 10 7.0 Conclusions Page 12

APPENDICES

Appendix A CPAC Discussion of June 2015 ALS Analyses Appendix B Township of Woowich Resolution to Ontario Minister of Environment and

Climate Change, October 15, 2014 Appendix C MBN Environmental Sampling Report and ALS Laboratories – Certificate of

Analysis Appendix D Large Scale Plan of Historic Canagagigue Creek DDT Results Appendix E Ontario Ministry of Environment (MOE) Prescribed Standards, April 15, 2011 Appendix F Conestoga-Rovers and Associates Ltd., Figure 5.1, Former Gravel Pit Area

Investigation, March 2012 Appendix G Conestoga-Rovers and Associates Ltd., June 30, 2015 – Work Plan

Amendment,

CPAC Canagagigue Creek Report – Final, July 24, 2015

3

1.0 Executive Summary In June 2015 the Chemtura Public Advisory Committee (CPAC), a Public Environmental Committee of the Township of Woolwich, retained MBN Environmental Engineering Inc. (MBN) to conduct sampling for contaminants – primarily DDT - in sediments of the Canagagigue Creek, especially those immediately downstream from the Chemtura Site. Alarmingly, DDT levels were found to range from twenty to 2900 times higher than the applicable Ontario Maximum Allowable Concentration standards in Canagagigue Creek sediment 40-50 metres south of the site, whereas no detectable levels of DDT, and similar contaminants, were found upstream of the Chemtura site. In her book titled Silent Spring (1962) Rachel Carson awakened the public to DDT’s lethal effects on songbirds, and its alarming consequences for humans. She disturbingly described the phenomenon now known as bio-magnification, which is the sequence of processes in an ecosystem by which higher concentrations of a particular chemical, such as the pesticides DDT or Dioxin, are reached in organisms higher up the food chain, generally through a series of prey-predator relationships. Twenty five years after Elmira’s drinking water was polluted as a result of NDMA - a potent carcinogen and Chemtura waste – another environmental crisis looms. Based on publically available Ontario Ministry of the Environment (aka MOE, MOEE or MOECC), Conestoga-Rovers and Asssociates Ltd. (CRA) and CPAC data, there is a firm basis to believe that Chemtura’s existing pump and treatment system is inadequate to control leakage from their site, especially eastward and southward as contaminants leak across neighboring farm properties into the Canagagigue Creek. This report concludes with a request to the Township of Woolwich to issue a Resolution to the Ontario Ministry of Environment and Climate Change demanding that adequate investigative and remedial actions be taken forthwith to stop the off-site leakage of environmental contaminants into the Canagagigue Creek from the eastern and southern boundaries of the Chemtura Site.

CPAC Canagagigue Creek Report – Final, July 24, 2015

4

2.0 Introduction The Chemtura Site is a 35 hectare section of land located on the east side of the Town of Elmira, Ontario. It has been home to a variety of chemical operations off and on since the 1900’s. For much of the first 70 years of the Plant’s existence, management of process wastes and/or unwanted or off-spec products largely consisted of pumping these products and wastes to unlined or partially lined pits around the site. Drummed wastes were also routinely buried close to the Canagagigue Creek, as well as along the eastern and southern property boundary.

Figure 1.0 Chemtura Site Location From 1945 to 1948 Uniroyal Chemical, (Uniroyal Chemical changed its name to Crompton Company in 2001 and then to Chemtura in 2006) produced between 200,000 to 300,000 pounds of DDT per year. Off-spec DDT and DDT wastes were routinely disposed of in unlined or partially lined sumps, pits and holding ponds on the site. In the 1940’s two

No

rth

Chemtura

Site

Canagagigue Creek

Canagagigue Creek flow direction (to the Grand River)

CPAC Canagagigue Creek Report – Final, July 24, 2015

5

abandoned gravel pits (GP-1 and GP-2), located in the bottom south-east corner of the Site, were used to collect seepage, overflow, and storm water run-off containing DDT and other chemicals from the waste pits located on the east side of the Site. GP-1 and GP-2 contained standing liquids until 1969 /1970. To this day GP-1 and GP-2 continue to be a potential source of off-site contamination.

Figure 2.0 Location of Former East Side Buried Waste Pits and GP1 and GP2 During the 1960s Elmira's Uniroyal chemical plant under contract with the U.S. government, was one of seven manufacturers supplying the U.S. military with the toxic herbicide Agent Orange. Dioxin was the primary toxic component of Agent Orange, and wastes containing Dioxin were routinely disposed of in GP-1 and GP-2. Dioxin is a general term that describes a group of hundreds of chemicals that are cancer-causing and highly persistent in the environment. In 1995, the United Nations Environment Programme (UNEP) called for global action to be taken on persistent organic pollutants (POPs) which it defined as "chemical substances that persist in the environment, bio-accumulate through the food web, and pose a risk of causing

Former East Side Waste

Pits

Gravel Pit 1 (GP-1)

Gravel Pit 2 (GP-2)

CPAC Canagagigue Creek Report – Final, July 24, 2015

6

adverse effects to human health and the environment". UNEP subsequently prepared an assessment of the worst POPs including DDT, Dioxins and Furans, and Endosulfan – all of which are toxins found on and off the Chemtura site. In November 1997 R. Jaagumagi, Contaminant Assessment Specialist of the Ontario Ministry of the Environment (MOE) and D. Bedard of the MOE prepared a report titled, Sediment and Biological Assessment of Canagagigue Creek at the Uniroyal Chemical Ltd. Plant, Elmira, Ontario, 1995 – 1996. The study focussed on biological effects and sediment contamination in Canagagigue Creek both upstream, on-site and downstream from the Plant Site. The most significant chemical contaminants scrutinized were Dioxins and Furans and DDT. MOE concluded that Dioxins were bioavailable in both Canagagigue Creek and floodplain pools downstream of the Site. The MOE emphasized that organisms throughout the food chain were accumulating tissue residues at levels found in sediments ; however, the MOE collected no additional Canagagigue Creek sediment samples for fifteen years - from 1997 to 2012. In 2011 Conestoga-Rovers and Associates (CRA), a consultant for Chemtura, conducted an environmental investigation of the gravel pit area containing GP-1 and GP-2, and summarized their findings in March 2012 in a report entitled, Former Gravel Pit Area Investigation (Figure 5.1 from this report is found in Appendix F). The CRA investigation found soil levels of Dioxins and Furans less than 100 metres from the property boundary, in GP-1, consistently greater than both the human health and ecological risk-based cleanup criteria [expressed in Toxic Equivalents (TEQs)]. The investigation also found that DDT in soil samples collected from nine locations around the gravel pit area were greater than the human health Lowest Risk Based Cleanup criteria. In the 2011 investigation, however, no samples were taken to investigate the off-site spread of DDT or Dioxins from the area of GP-1 or GP-2. In 2012 MOE collected four downstream creek sediment samples in response to repeated requests from CPAC members. The analysis showed DDT exceedances up to 1700 times the MOE 2011 maximum allowable concentration (MAC). In 2013 MOE collected creek samples for DDT from three other locations and found levels up to seven hundred times above the MOE 2011 MAC MOE conducted additional sampling of creek sediment downstream of the Chemtura Site in June 2014, but as of the date of this report, and despite repeated requests from CPAC, no results have been released. On June 30, 2015, Conestoga Rovers and Associates (CRA) provided a Work Plan Amendment to the MOECC (See Appendix G). The Work Plan proposes to sample surficial soil and groundwater on the East Side of the Chemtura Site; however, CRA states in the Work Plan, “two surficial soil samples locations between GP1/2 and the fence line proposed in the Work Plan will not be included in the sampling program. The rationale for not collecting these samples is to focus resources of the fence line to evaluate the potential for off-Site migration to the east or south of the Site.”

CPAC Canagagigue Creek Report – Final, July 24, 2015

7

3.0 CPAC Environmental Project In April 2015 CPAC received a Grant from the Region of Waterloo to carry out a project to increase knowledge of environmental stewardship issues of particular relevance to Waterloo Region. In June 2015, MBN Environmental Engineering Inc (MBN) on behalf of CPAC conducted sampling of sediment in the Canagagigue Creek for the purpose of determining the off-site spread of DDT into the Canagagigue Creek at the south end of the Chemtura Site. 4.0 CPAC Field Sampling Twelve field samples were collected from sediment in the Canagagigue Creek downstream from the Chemtura Site on June 25, 2015 by Drew Stoltz, P. Eng, PE and Rob Hoag, M.Sc, P.Eng., PE of MBN. The samples were collected under legal Chain of Custody (CCR) procedures and submitted on June 25, 2015 to ALS Environmental laboratories (ALS) located at 60 Northland Road, Unit 1 Waterloo, Ontario. Mr. Hoag and Mr. Stoltz are both certified as Qualified Persons (QP) under Ontario MOE definitions. Table 1 sumarizes the samples collected.

Table 1 Sample Identification

Item Sample Identification Sample Description Comments 1 DUPE – Sample 9 Duplicate of Sed - South of

GP-1 and GP-2 Sampling Zone 2

2 Sed 1 Location 1 – East Side Ditch Sampling Zone 1

3 Sed 2 Location 2 – East Side Ditch Sampling Zone 1

4 Sed 3 Location 3 – East Side Ditch Sampling Zone 1

5 Sed 4 Location 4 – East Side Ditch Sampling Zone 1

6 Sed 5 Location 5 – East Side Ditch Sampling Zone 1

7 Sed 7 Location 7 – South of GP-1

and GP-2 Sampling Zone 2

8 Sed 8 Location 8 - South of GP-1

and GP-2 Sampling Zone 2

9 Sed 9 Location 9 - South of GP-1

and GP-2 Sampling Zone 2

10 Sed 10 Location 10 Sampling Zone 2

11 Sed 11 Field Blank

All-Treat Commercial Sand

12 Sed 12 Upstream Located approximately at Larch’s Creek and Kissing Brige

Trail

CPAC Canagagigue Creek Report – Final, July 24, 2015

8

Figure 3 shows the actual locations of the field samples.

Figure 3.0 - Sampling Points

5.0 Laboratory Analyses Appendix A contains a more detailed discussion of the ALS results. Appendix C contains ALS’s Certificate of Analyses (C of A) as well as MBN’s sampling report. Table 2 summarizes the detected results from the 12 sample locations.

Table 2 – Summary of Analytical Results – OC Pesticides

Sample Number OC Pesticides ug/g (ppm)

MOE Sediment Criteria ug/g (ppm) – Table 8

Comments

Sed 1 <0.15 - 0.42 See table 8 Method Detection Limit (MDL) above criteria

Sed 2 <0.075 - 0.21 See table 8 Method Detection Limit (MDL) above criteria

Sed 3 <0.10 - 0.28 See table 8 Method Detection Limit (MDL) above criteria

Sed 4 <0.15 - 0.42 See table 8 Method Detection Limit (MDL) above criteria

Sed 5 <0.15 - 0.42 See table 8 Method Detection Limit (MDL) above criteria

Sed 7 <0.15 - 0.42 See table 8 Method Detection Limit (MDL) above criteria

Sed 8 0.77 p,p-DDT 0.007 total DDT p,p-DDT above total DDT MAC for sediment

Sed 9 Dupe 0.16 total DDT 0.007 total DDT total DDT above total DDT MAC for sediment

Sed 9 20.8 total DDT 0.007 total DDT total DDT above total DDT MAC for sediment

Sed 9 0.41 total Endosulfan

0.04 Endosulfan in soil total endosulfan above Endosulfan MAC for soil

Sed 10 <0.20 - 0.57 See table 8 Method Detection Limit (MDL) above criteria

Sed 11 – Field Blank <0.010 - 0.028 See table 8 Method Detection Limit (MDL) above criteria

Sed 12 - Upstream <0.050 - 0.14 See table 8 Method Detection Limit (MDL) above criteria

CPAC Canagagigue Creek Report – Final, July 24, 2015

9

As indicated in table 2, both locations 8 and 9 were found to have levels of DDT above the MAC of 0.007ug/g (ppm). Sample Sed 9 was found to have a detection of 20.8 ug/g of total DDT, which is more than 2900 times more than the Ontario MAC. In addition, Sed 9 was found to have a detection of 0.41 ug/g of total endosulfan, which is more than ten times the Ontario MAC for soil. Endosulfan is a restricted-use pesticide that studies have shown can produce birth defects in humans.

Sample Number OC Pesticides ug/g (ppm)

MOE Sediment Criteria ug/g (ppm) – Table 8

Comments

Sed 9 20.8 total DDT 0.007 total DDT More than 2900 times above total DDT MOE MAC

Sed 9 0.41 Endosulfan 0.04 Total Endosulfan

total endosulfan above MOE MAC for soil

Sample Sed 8 was found to have a detection of 0.77 ug/g of p,p-DDT, and Sed 9 duplicate was found to have a detection of 0.166 ug/g p,p-DDT, which is more than twenty times the Ontario MAC. It is noted that interferences above the laboratory Method detection limit (MDL) were found in all field samples, including the upstream sample (Sed 12) as well as the field blank (Sed 11); however, no positive detections were identified in either the field blank or the upstream sample. There is considerable variability of detectable results between Sed 9 and Sed 9 Dupe. Field samples involving non-water soluble contaminants often result in non-homogenous samples, and considerable variability is often found. As already noted, many of the field samples were found to have elevated method detection limits (MDLs) due to interfering compounds. In an effort to characterize some of the potential interfering compounds, the laboratory completed an open scan characterization of two samples – Sed 8 and Sed 9. The GC/MS open scan is not designed to establish concentration levels; however, it does provide useful information as to what other chemicals are found in the field samples. The following additional chemicals were found in Sed 8 and Sed 9:

Isomer of DDT or DDD;

O-cresol;

P-cresol;

Diphenylamine;

Cylclic sulfur compounds (Polycyclic aromatic compounds - PAHs).

The Polycyclic aromatic compounds (PAHs) identified in the open scan have been identified as carcinogenic and mutagenic (as well as teratogenic), and are considered pollutants of concern for the potency of their potential adverse health impacts.

CPAC Canagagigue Creek Report – Final, July 24, 2015

10

Figure 4 shows significant detections of DDT off-site in the Canagagigue Creek over the period of 2011 to 2015, including data from MOECC, CRA and the June 2015 CPAC investigation. A larger version of this Figure is included in Appendix D.

Figure 4 – DDT in Sediment, 2011 to 2015 The 2015 CPAC analytical data and historic MOECC data found non-detectable levels of DDT and Dioxins and Furans upstream of the Chemtura site, at the intersection of the Kissing Bridge Rail trail and Larch’s Creek, which is one of the upper branches of the Canagagigue Creek. As indicated in Figure 4, The 2011 – 2015 analytical data also shows DDT levels ranging from twenty to 2900 times higher than the Ontario MAC in Canagagigue Creek sediment 40-50 metres south of the site. The 2012 and 2013 MOECC data found DDT at levels hundreds of times higher than the Ontario MAC more than three kilometres downstream of the Chemtura site. 6.0 Pine River Superfund Site: Case Study South of the Border Superfund is the name given to the United States environmental program established to address abandoned hazardous waste sites. It is also the name of the fund established by the Comprehensive Environmental Response, Compensation and Liability Act of 1980, (CERCLA statute). The Superfund law was enacted in the wake of the discovery of toxic waste dumps such as Love Canal and Times Beach in the 1970s. It allows the Federal

CPAC Canagagigue Creek Report – Final, July 24, 2015

11

EPA to clean up priority sites and to compel responsible parties to perform cleanups or reimburse the government for EPA-lead cleanups. The Pine River site is located in St. Louis, Michigan, and includes the 52-acre land parcel once occupied by the Michigan Chemical Corporation, and later Velsicol Chemical Company which were in operation from 1935 to 1978. The site was listed on the Superfund National Priorities List in September 1983.

Figure 5 – The Pine River Superfund Site

The chemical contamination of the Pine River Superfund Site and the Chemtura Site are eerily similar. Both are large sites located on formerly pristine rivers that flow to a Great Lake. Both Chemical Companies were chemical producers of war materiel, and both produced the notorious pesticide DDT. Both sites feature multiple aquifers in glacial tills, contaminated among other things with DDT, Chlorobenzene and other halogenated toxins. Both Velsicol Chemical and Chemtura (and its predecessors) claimed that their sites were adequately contained using pump and treat technologies. However, at the urging of the local citizens group – The Pine River Superfund Citizens Task Force - the USEPA was convinced to investigate more closely the spread of chemicals into the Pine River. Sheet piles – essentially giant iron curtains embedded in the soil – were used to isolate and dewater sections of the river. After pumping out the water in sections of the river isolated by sheet piles, the USEPA discovered dense pools of chemicals saturated with DDT that had moved from the Velsichol site via underground gravel “pipelines” or “ gravel seams” into the Pine River unconstrained by the pump-and-treat technology.

CPAC Canagagigue Creek Report – Final, July 24, 2015

12

Figure 6 – Sheet Pile Investigations of the Pine River 7.0 Conclusions In an effort to fully assess chemical impacts to the Canagagigue Creek, CPAC reviewed publically available MOE and CRA data over the period of 2011 to 2013 as well as data collected by MBN Engineering’s June 2015 sampling of the Canagagigue sediment immediately downstream from the Chemtura Site. The analytical data provides compelling evidence that Chemtura-originating contaminants have been, and continue to be moving off the site into the Canagagigue Creek, at levels far in excess of prescribed standards. The 2015 MBN sampling confirmed the warning contained in the 2014 MTE report commissioned by CPAC which stated that “ there is a high potential for off-site contamination.” Twenty five years after Elmira’s drinking water was polluted by a Chemtura chemical – NDMA – another environmental crisis looms. Based on historical MOE, CRA and CPAC data, it is CPAC’s firm belief that the the existing pump and treat system is inadequate to control leakage from the Chemtura site eastward and southward into the Canagagigue Creek, most likely via underground gravel seams. Based on a review of the Pine River Superfund Site in the United States, it is likely that installation of sheet pile around the southern and eastern boundaries, and if necessary in the Canagagigue Creek will be needed to isolate contaminants, and to allow proper delineation of the extent of off-site contamination. It is also likely that bentonite slurry walls, DNAPL collection trenches and associated engineering controls as will also be necessary.

CPAC Canagagigue Creek Report – Final, July 24, 2015

13

Based on the evidence provided in this report there is a firm basis to believe that Chemtura’s existing pump and treatment system is inadequate to control leakage from their site, especially eastward and southward as contaminants leak across neighboring farm properties into the Canagagigue Creek. It is also CPAC’s opinion that the June 30, 2015 CRA Work Plan must be amended to include test pitting along the southern boundary of the Site, between GP1 anf GP2 and the Canagagigue Creek. CPAC requests, therefore, that the Township of Woolwich issue a Resolution to the Ontario Ministry of the Environment and Climate Change (MOECC) demanding that test pitting and analyses be conducted along the southern boundary of the Site, between GP1/2 and the Canagagigue Creek and that remedial actions be taken forthwith to stop the off-site leakage of chemicals on the eastern and southern boundaries of the Chemtura Site. All of which is respectfully submitted.

Graham Chevreau, CPAC Voting Member On behalf of the Chemtura Public Advisory Committee (CPAC) CPAC 2010-2015 Dr. Dan Holt, CPAC Chair Dr. Sebastian Siebel-Achenbach, CPAC Voting Member Vivienne Delaney, CPAC Voting Member Ron Campbell, CPAC Voting Member Graham Chevreau, CPAC Voting Member

CPAC Canagagigue Creek Report – Final, July 24, 2015

14

APPENDICES

Appendix A CPAC Discussion of June 2015 ALS Analyses Appendix B Township of Woowich Resolution to Ontario Minister of Environment and

Climate Change, October 15, 2014 Appendix C MBN Environmental Sampling Report and ALS Laboratories – Certificate of

Analysis Appendix D Large Scale Plan of Historic Canagagigue Creek DDT Results Appendix E Ontario Ministry of Environment (MOE) Prescribed Standards, April 15, 2011 Appendix F Conestoga-Rovers and Associates Ltd., Figure 5.1, Former Gravel Pit Area

Investigiation, March 2012 Appendix G Conestoga-Rovers and Associates Ltd., June 30, 2015 – Work Plan

Amendment,