Remediation Advisory Committee (RAC)

Township of WoolwichRemediation Advisory Committee (RAC)

Agenda

April 11, 20195:00 pm

Council Chambers, 2nd Floor24 Church Street West, Elmira

Pages

1. Disclosures of Pecuniary Interest

2. Approval of Previous Minutes

2.1 December 13, 2018 1

3. Delegations

4. Technical Updates and Review

4.1 Canagagigue Creek Sediment and Floodplain Soil Investigation Report

4.2 Draft Re-Evaluation of Canagagigue Creek Contaminants of PotentialConcern

4.3 Draft Conceptual Site Model Report for the Canagagigue Creek

5. Information Requests

6. Correspondence 14

7. Other Business

7.1 Terms of Reference

8. Next Meeting

8.1 TAG - May 9, 2019 6:30 pm

8.2 RAC - May 16, 2019, 4 pm

9. Adjournment

10. Disclosures of Pecuniary Interest

RAC MEETING MINUTES, DEC 13, 2018 1

Township of Woolwich Remediation Advisory Committee (RAC) Minutes Thursday, December 13, 2018 3:00 p.m. Council Chambers, 2nd Floor Administration Building, 24 Church Street West, Elmira

Present Organization

Sandy Shantz Co-Chair, RAC - Mayor, Township of Woolwich

Tiffany Svensson Chair, Technical Advisory Committee (TAG) Joe Kelly TAG Voting Member Sebastian Siebel-Achenbach TAG Voting Member Ramin Ansari LANXESS Canada Co/Cie Dwight Este LANXESS Canada Co/Cie Jamie Petznick LANXESS Canada Co/Cie

Jason Rice MECP Lisa Schaefer Recorder, Township of Woolwich Nancy Davy GRCA Eric Hodgins Region of Waterloo *various members of the public were in attendance

Regrets Organization None

Disclosures of Pecuniary Interest All disclosures made by RAC members indicated that they had no pecuniary interests to declare and therefore that no conflicts of interest exist.

Approval of Previous Minutes

September 27, 2018

The minutes were approved. MOVED by Sebastian Siebel-Achenbach SECONDED by Joe Kelly THAT the minutes of the September 27, 2018 RAC meeting be adopted.

…CARRIED

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A follow-up technical meeting is still to be scheduled in the first quarter of 2019 to discuss the

east side. The focus will be to address concerns that TAG has with the area identified as the

gap located along the Lanxess eastern property boundary.

Delegations None

Technical Updates and Review

Summary presentation of work plan Supplemental East Side Offsite Groundwater

Investigation

Mr. Ansari led this discussion on behalf of LANXESS. Refer to page two of Appendix A.

In addition to the presentation, the following points were discussed:

• The depth of the wells will be to the municipal aquifer. The exact depths will be outlined in the work plan.

• The existing wells installed at the end of 2017 are ~<20 m from the Lanxess east property line, and the proposed wells for the 2019 supplemental investigation are ~220 m from the Lanxess east property line (with the exception of the ministry requested southern well nest location).

• The intent is to find clean wells. The presumption is that everything right up to the wells is contaminated. They want to find the extent of the contamination not necessarily minimize what they think the extent of the contamination is.

• TAG noted that the proposed well locations in the workplan are very far from the current wells. LANXESS responded that there is already offsite containment, so they want to make sure that that the offsite contamination has not gone far and to determine where the contamination ends. The existing Region of Waterloo monitoring wells further east are clean and the hope is that these proposed wells will also be clean. They hope that these wells will demonstrate that the contamination is captured and not migrating.

• There is not necessarily anything that will be done as the plume is captured in these areas by the remediation system.

• The wells should address groundwater concerns as well. LANXESS believes that the groundwater contours and analytical results from the northern most wells in that area show that there should not be any contaminant impact north and north east.

• The aquifer unit discussed is the upper municipal aquifer. Any of the issues/concerns raised in subsequent work related to the creek and the surficial aquifer would not necessarily be covered in this east side work plan. LANXESS noted that the link between the surficial aquifer and the creek is one of the larger items to include in the CSM.

• Unless contamination is identified that demonstrates the need, there will be no more wells south of the area of known impacts. There are no plans to extend the well locations further to the area identified as the gap. LANXESS feels that soil migration and

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groundwater support this. The Ministry has requested a well placed to the south for the delineation of the horizontal extent.

At the end of the discussion, TAG stated that they feel there is a gap in confirmatory information that encompasses the concerns around the drain feature. TAG is requesting that LANXESS and MECP reconsider the location of the well that is located the furthest south. They would like to have it placed further south in the area that TAG identifies as the gap. Regardless of which work plan this concern gets addressed (i.e. the supplemental east side off-site groundwater investigation work plan OR the creek investigation/ surficial aquifer and RA process), the gap needs to be addressed. In TAG’s opinion there is inadequate data in this area (the gap) for both the surficial soil and surficial aquifer/ ground water. LANXESS agreed to participate in a discussion where all technical information and data relating to delineating contaminant impact in the area known as the gap can be shared and discussed in order to definitively address TAG’s concerns on this subject. It was agreed that this would take place at the January 24, 2019 TAG meeting. That said, Mr. Ansari stated that the location of the southernmost well is much deeper than the surface and the shallow subsurface that TAG says flows in the gap. As a result, this well should capture any potential contamination. He further stated that with groundwater, the ultimate intent is to show if there is groundwater that is escaping the control of the containment system in this area. They believe it is contained and therefore, there is no risk. From a practical perspective, he said there is no concern. From a data gathering perspective, he understands why this would be of interest and why TAG would want to study it. TAG concluded that they want a commitment to address the gap – whether through this workplan, another workplan or the risk assessment process.

Note: A copy of Appendix A has been retained in the Clerk’s Office.

Status Update on the CTS

Mr. Ansari led this discussion on behalf of LANXESS. Refer to page three of Appendix A.

Mr. Ansari stated that they are on track and are still committed to having W9 back up and

running as planned by end of first quarter 2019. He noted that the Trojan UV system addressed

NDMA. It is the additional contaminants that are showing up that are of concern

(benzothiazole and toluene). LANXESS did not have a way to treat these contaminants and did

not want to exceed creek discharge limitations. As a result, they shut down W9 and

investigated it. In the end, bench scale testing and studies showed that a peroxide treatment

could address these molecules. The peroxide is consumed in the oxidation process.


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Status Update on the Creek RA process

Mr. Ansari led this discussion on behalf of LANXESS. Refer to page four of Appendix A.

Mr. Ansari stated that of soil, creek sediment and creek bank flood plain soils, the only

additional constituent of concern that was identified in their recent desktop COPC evaluation

(constituents of potential concern) and may need to be added is 2,4-D in soils. The draft is

being reviewed and the final version should be ready for next week. In terms of the Conceptual

Site Model (CSM), this is where any concerns about the area known as the gap, should be

addressed. The CSM is where the potential sources and pathways are addressed. All of this will

feed into the risk assessment.

TAG inquired where exactly referenced Station 30 (Church St) is located and how they will

consider and determine if the facility itself continues to be a source. It is important to TAG that

the matter of the facility being an ongoing source and what is considered ‘background’ is

adequately assessed and noted. It was confirmed that the sample station 30 is at the northern

boundary of the Lanxess property, just to the south of Church Street.

Overall TAG was pleased with the creek RA process.


TAG Recommendations

Tiffany Svensson reiterated that there is a commitment to meet to discuss the concerns

outlined above. The meeting will be on January 24, 2019.

In addition, Tiffany Svensson will be working with LANXESS and MECP to develop a meeting

schedule that aligns with deliverables for the rest of 2019.

There were no specific recommendations.

Information Requests Tiffany Svensson confirmed that prior to the meeting, she received an email addressing her

request for clarification and information that stemmed from the September Monthly Progress

Report.

There were no other information requests.

Correspondence Tiffany Svensson clarified a clerical error on the correspondence received to date document.

Through the process of addressing the error in the correspondence received, it was realized

that a document was not received. This has also been rectified.

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Other Business

Maintenance and Preventative Maintenance

Mr. Ansari led this discussion on behalf of LANXESS. Refer to pages five and six of Appendix A.

Mr. Hodgins was pleased to see that LANXESS does annual capacity testing of the wells which he feels is critical for remediation. The maintenance program looks good. He feels from the well side it is very consistent and better than what the Region is able to achieve. LANXESS confirmed that they have an onsite tracking system to monitor operational efficiency. LANXESS will follow-up on TAG’s question if there has ever been testing of the capacity of aquifer to accommodate the stated flow rates that are anticipated with W9. LANXESS also confirmed that they are very close to accessing the neighbouring private property for the soil remediation.

Next Meeting The next TAG meeting will be on Thursday, January 24, 2019. The focus on that meeting was to

be on the creek final report. However, given the report will not be delivered on December 14,

2018 as anticipated, due to a ministry request for Lanxess to incorporate previous ministry

comments into the final report. This was noted during the meeting. As a result the creek will

now be the focus of the February TAG meeting not the January as originally proposed.

The January meeting will now address the gap issue and/or the Contaminants Of Potential

Concern (COPC) document. MECP and LANXESS attendance was requested.

The next RAC meeting will be on April 11, 2019 at 4pm.

Adjournment The meeting adjourned at 4:15pm Recorder: L Schaefer

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1 Title of presentation ▪ Speaker ▪ Place, date … [ OPTIONAL ]

RAC Meeting

LANXESS Elmira

Ramin Ansari

December 13, 2018

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East Side Off-Site Groundwater

• Objective: Delineate horizontal extent of NDMA,

2,4,6-trichlorophenol, and 2,4-dichlorophenol in

shallow groundwater on the Property bordering the

eastern Site boundary.

• Collect data to assess vertical groundwater quality in

the Municipal Aquifer beneath the Property.

• Four monitoring well pairs.

• Proposed well locations are optimized to maximize

data quality and distribution, and to minimize

disruption of the existing land use.

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W9 Treatment System Update

▪ Metcon chemical feed system has been delivered to the Elmira facility

▪ The chemical feed system is in the process of being piped to the Trojan UV system

▪ Electrical and instrumentation work is also being completed.

▪ Grating work and containment dyking are pending.

▪ Prestart safety review is scheduled for early January 2019.

▪ Commissioning and startup of the W9 system is scheduled for January 18, 2019.

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▪ Following the process set forth during the September 5, 2018 Canangagigue Creek meeting.

LANXESS, MECP, GHD, representatives of TAG, and the Peer Review Group (Stantec, ERM,

and Geosyntec)

▪ Chemicals of Potential Concern (COPCs) Re-evaluation has been completed and will be issued

to the MECP and stakeholders pending final LANXESS review

Delivery expected next week

▪ Development of Creek Conceptual Site Model (CSM) is currently underway

Document will be submitted to LANXESS in early January 2019 for review

Will be issued to the MECP and stakeholders shortly thereafter.

▪ LANXESS will then await input and comments on the COPC Re-evaluation and CSM

submissions before determining if there is sufficient data to prepare and completed a preliminary

risk assessment.

Creek Risk Assessment Process

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▪ This is not something that has

been discussed, as it is a routine,

on-going activity.

▪ In most instances, preventative

maintenance is more cost-

effective than deferred or no

maintenance.

▪ Including internal and

subcontract labor (operators,

instrument techs, etc):

Between $300,000 to

$400,000/year.

Approximately 20 percent of

the budget.

Preventative Maintenance

Activities• Pressure relief valve - inspected and recertified bi-annually, repairs or replacement as

necessary• Rupture disks – replaced bi-annually. All rupture disks to be replaced by pressure

relief valves by 2020 as part on ongoing treatment system upgrades.• Pressure gages – inspected weekly and repaired as necessary• Actuated valves – real-time monitoring of operation, inspected annually, and repairs

as necessary• Limit switches– inspected annually, levels confirmed and repairs as necessary• Flow meters - real-time monitoring of flows, inspected annually, flows confirmed and

meter replacement or repairs as necessary• Flow deviation – real-time monitoring, system interlocked when a flow deviation

reported• Pipe line inspection and cleaning – monitored weekly, maintenance as necessary• Pressure vessel– inspected every five years, maintenance as necessary• Pressure sensors - real-time monitoring, inspected annually (pressure readings

confirmed), and maintenance as necessary• Liquid level indicators – inspected annually (levels confirmed), and repairs as

necessary• Float switches – inspected annually, operation confirmed and maintenance as

necessary• Well hut inspections – inspected weekly, maintenance as necessary• Variable frequency drives – real time monitoring, data tracked on a weekly basis,

maintenance or replacement as necessary

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Activities (continued)• Pumps and motors – inspected annually, maintenance as necessary• Motor starters – annual inspection, maintenance as necessary• Electrical panels – annual inspection, maintenance as necessary• Lamps – inspected quarterly, replaced once lamps reach 3,500 hours

of operation• Wipers - inspected quarterly, maintenance as necessary• Well rehabilitations – completed as necessary based on well capacity,

flow rate and well head pressure information (two to three well rehabilitations completed annually)

• Well head pressure monitoring and tracking – monitored weekly and tracked on a monthly basis (information used to determine the need for pipe cleaning and/or pump maintenance)

• Pump motor amperage monitor and tracking – real time monitoring, tracked on a monthly basis (information used to determine the need for pipe cleaning and/or pump maintenance)

• pH sensor - inspected annually (readings confirmed), and maintenance as necessary

• ORP sensor - inspected annually(readings confirmed), and maintenance as necessary

• Turbidity sensor – inspected annually (readings confirmed), and maintenance as necessary

• Temperature sensor - inspected annually (readings confirmed), and maintenance as necessary

Preventative Maintenance (continued)

• Building inspections (Building 20A, 44C, 44D and 62) –Rounds completed every two hours, maintenance requirements documented in a building log and repairs as necessary

• Plant wide electrical shutdown and electrical inspections –annually, maintenance as necessary

• Well recovery testing/Specific Capacity testing – completed annually, well rehabilitations as necessary

• Outfall structures – inspected annually, repairs as necessary• Rayox UV treatment Systems – LANXESS is currently

upgrading the central processing units (CPU) on each treatment train. All CPU upgrades to be completed in 2020.

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RAC and TAG Correspondence Received in 2019

Date Received

Date of Document

Type of Document Format of Document

Information for Document (title and author)

January 15 January 15 Report Email LANXESS Canada Co./Cie (LANXESS)

Progress Report – December 2018

GHD

January 17

January 17 Letter Email LANXESS Canada Co./Cie (LANXESS)

Supplemental East Side Off-Site Groundwater Investigation Work Plan LANXESS GHD

January 18

January 18 Written Delegation Email Alan Marshall

Delegation for TAG January 24, 2019 Meeting.

Alan Marshall

January 25

January 25 Technical Memo Email GHD

Memo Re: Re-Evaluation of Canagagigue Creek Contaminants of Potential Concern

Nicole Knezevich and April Gowing

February 13, 2019

May 2013 Map

**previously provided

Email

Existing Topography Scoped Environmental Impact Study for Chemtura Canada by CRA, provided by GHD

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Date Received

Date of Document



February 15, 2019

February 15, 2019

Report Email LANXESS Canada Co./Cie (LANXESS)

Progress Report – January 2019

GHD

February 20, 2019

February 20, 2019

Report (Word Document) Email LANXESS Canada Co./Cie (LANXESS)

GAP Area Summary of Historical Sampling

LANXESS

February 20, 2019

February 20, 2019

Map Email LANXESS Canada Co./Cie (LANXESS)

Topographic Map of GAP area

GHD

February 20, 2019

February 20, 2019

Various attachments and downloadable zip files. Information/data pertaining to Eastside discussion. Follow up from January 24, 2019 TAG meeting.

Email LANXESS Co./Cie and GHD

February 26, 2019

February 25, 2019

Attachments. Additional information/data pertaining to Eastside discussion. Follow up from January 24, 2019 TAG meeting.

Email LANXESS Co./Cie and GHD

February 28, 2019

February 28, 2019


2018 Annual Monitoring Report

GHD

March 28, 2019

March 15, 2019


Progress Report – February 2019

GHD

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Date Received

Date of Document



March 19, 2019

March 18, 2019

Report and Appendices Email and Hardcopy

LANXESS Canada Co./Cie (LANXESS)

Canagagigue Creek Sediment and Floodplain Soil Investigation Report

GHD

March 25, 2019

March 25, 2019

Report and Appendices Email and Hardcopy

LANXESS Canada Co./Cie (LANXESS)

Canagagigue Creek Draft Conceptual Site Model

GHD

March 29, 30 and April 1, 2019

March 29, 30 and April 1, 2019

Written Delegation Emails (3) Alan Marshall

Delegation for TAG April 1, 2019 Meeting regarding Creek Investigation Report.

Alan Marshall

April 3, 2019

April 3, 2019 Letter Email MECP RE: Lanxess Elmira – Preliminary Review Comments, Evaluation of Canagagigue Creek Contaminants of Potential Concern Draft Report

Jason Rice Regional Engineer MECP

Copies of all correspondence received are available upon written request to the Clerk’s office. Contact Lisa Schaefer at [email protected] or call 519-669-1647 for questions.

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