POLLUTION

OF THE

ST. CLAIR RIVER(SARNIA AREA)

A SITUATION REPORT

PREPARED BY

ENVIRONMENT CANADA

AND THE

ONTARIO MINISTRY OF ENVIRONMENT

UNDER THE AUSPICES

OF 'THE CANADA-ONTARIO AGREEMENT

RESPECTING GREAT LAKES WATER QUALITY

(ENGLISH ONLY)

NOVEMBER 18, 19854

TD227.S731985copy 2

MOE

MNST t OF lit

F F B - 51986

HAZARDOUS CONri ..,,JINAW

n

TD Pollution Of th" St C;vr Rivrri227 ;Sarm-i are,,!

.S73 55431985

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ST. CLAIR RIVER SITUATION REPORT

A. I ,TrRODUCTION

B. ENVIRONMENTAL CONDITONS

1) Sources: Point SourcesNon-point SourcesSurface Waste Disposal SitesSpill Summary

2) Deep Well Injection Practices

- Introduction

- Geology/Hydrogeology of the Area- Locations of WellsSubstances and Quantities Disposed

- Previous Upwelling

3) Historical and Present Quality of Water and Sediments and theirImpact on Biota Along the Length of the St. Clair River

4) Transport of Hazardous Waste

C. PRESbWr SCIENTIFIC STUDIES AND REMEDIAL ACTIONS

1) Ferchloroethylene Spill2) Dow Clean-up Plan3) DOE St. Clair River Pollution Investigation4) Ongoing Provincial Studies5) Upper Great Lakes Connecting Channels Study

D. CONCLUSION

ST. CLAIR RIVER SITUATION REPORT

A. INTRODUCTION

Dow Chemical's spill of perchloroethylene into the St. Clair Rivernear Sarnia in August 1985 and the occurrence of small "globs",(fist size) of a tarry substance on the river bottom have become afocus of public environmental concern in Ontario. Concern centreson the safety of the drinking water supply drawn from the St.Clair and the extent and source of contamination of the St. ClairRiver in the Sarnia area. This situation report, compiled byEnvironment Canada and the Ontario Ministry of Environment;provides a summary of the environmental conditions of the river,past and present pollution control practices in the area; andcurrent government actions.

B. ENVIRONMENTAL CONDITIONS

1. POINT SOURCES - INDUSTRIAL

The "Chemical Valley" at Sarnia is composed of a number ofpetroleum refineries and petrochemical plants, mostly adjacent tothe river, within ten kilometres south of the business core. Table1 lists the industries in order of location (north to south) andprovides a list of products. The facility list represents the bulkof the industry located on the St. Clair River and the area alongthe shoreline which is most degraded in terms of water and sedimentquality. The attached man shows the location of the St. ClairRiver and Sarnia in southwestern Ontario along with the location ofspecific facilities identified in the attached table.

These industries discharge a daily total of 1.7 billion litres ofprocess, doling and storm water (1983 annual average). TheOntario Ministry of the Environment regulates the discharge ofconventional pollutants such as suspended solids, metals such aslead, and a limited group of organic contaminants such as totalphenols. This is effected by a variety of means such as ControlOrders, Certificates of Approval and the use of Ontario's GeneralIndustrial Discharge Objectives or Federal Industry SpecificRegulations and Guidelines. Control Orders and Certificates ofApproval may or may not stipulate actual discharge objectives forspecific pollutants. Over the last 20 years, the industries in thearea have accomplished major reductions in the discharge ofpollutants by installing end-of-pipe treatment such as theinstallation of bio-oxidation plants at Polysar and the petroleumrefineries, modifying manufacturing processes, and recyclingwastestreams.

V

ST. CLAIR RIVER INDUSTRIAL POINT 9OURCESI

Table

# NAME 'TYPE PRODUCTS

1 Esso Petroleum Canada Petroleum Refinery Gasoline, Stove Oil, Diesel Fuel, Jet Fuel, Rome Heating Oil,Lube Oil, Waxes, Asphalt, LPG

2 Esso Chemical Canada Petrochemical PVC, Olefins, Lubricant Additives, Polyethylene Resins,Benzene, Toluene, Xylene

3 Cabot Carbon Petrochemical Carbon Black

4 Fiberglass Canada Petrochemical/Inorganic Glass Fiber Insulation

5 Polysar Limited Petrochemical Synthetic Rubber, Rubber Latex, Benzene, Ethyl Benzene,Styrene, Butadiene, Isobutylene

6 Dow Chemical Canada Petrochemical Styrene, Polystyrene, Propylene Glycol, Chlorine, Caustic Soda,Methychloride, Perchloroethylene, Latexes, Vinyl Chloride, HighDensity Polyethylene, Polystyrene Foam, *Trichloroethane, OtherChlorinated Solvents

7 Sunoco Inc. Petroleum Refinery Gasolines, Kerosene, Jet Fuel, Heating Oils, Aromatics,Sulphur, LPG, Heating Oil

8 Shell Canada Ltd. Petroleum Refinery Gasolines, Aromatic and Aliphatic Solvents, Stove Oil, DieselFuel, Hxw Heating Oil, Bunker Fuel, Fuel Gas, Propane, Butane,Butylenes and Liquid'Sulphur

9 Ethyl Corporation Petrochemical Ethyl Chloride, Ethylene Dichloride, Tetraethyl Lead AntiknockAdditive, Phenolic Antioxidants, Aluminum Alkyls

10 Dupont of Canada Petrochemical Low to High Grade Polyethylene Resins

11 Petrosar Limited Petrochemical Refinery Ethylene, Propylene, Butadiene, Isobutylene, Butylene, Benzene,Toluene, Gasoline, Fuel Oil, LPG, Synthetic Natural Gas

12 Union Carbide Petrochemical Polyethylene Resins

1 Industries south of Corunna not included (CIL-Fertilizers, Ontario Hydro - Coal Fired Generating Station, Chinook Chemicals- Methyamines (seasonal discharge)).

/3324.3

ST. CLAIR RIVER STUDY AREA

Lake Huron

MICHIGAN ONTARIO

Port HureS

roitDet

Lake %.-

St. Clair

Windsor

Lake Eric

T.ESSO PETROLEUM CANADA

SARNIA WPCPESSO CHEMICAL CANADA

SARNIA TOWNSHIP DITCH --POLYSAR CORPORATION LTD.

DOW CHEMICAL OF CANADA LTD.

SUNOCOINCORPORATED

SHELL CANADA LTD.

ETHYL CORPORATION OF CANADA.LTD.DUPONT OF CANADA LTD.PETROSAR LTD.

CORUNNA WPCP

ONTARIO HYDRO NLAMBTON

GENERATIONSTATION

CABOT CARBONFIBERGLASPOLYSAR.HOLMES INSULATIONFIBERGLAS

(DISPOSAL SITE)ESSO Petroleum(Disposal Site)POLYSAR

(DISPOSAL SITE)DOW CHEMICAL

(DISPOSAL SITE)SARNIA TOWNSHIP

DITCH

Scale (Km.)0 1 2

During the late 1970's an increased awareness of toxic organiccompounds and the laboratory technology for their identificationallowed the analysis of these effluents for trace organics(Ontario Ministry of the Environment 1975 and 1977,Environmental Protection Service/Ontario Ministry of theEnvironment 1979-1980). The results of these studies indicatedthat some effluents contained very high concentrations ofindustrial organic pollutants in excess of one part per million(1 ppm). The industries found to be discharging organics inexcess of 1 ppm were asked to control the effluent immediately,while those compounds discharged in excess of 0.1 ppm were to besubject to increased monitoring. The present quality of theseeffluents will be evaluated in detail during 1986 under an EPS -Ontario Region - Ontario Ministry of the Environment cooperativesurvey of all point sources to the river. This survey willidentify sources requiring further reinediation and is part ofthe Canada/U.S. Upper Great Lakes Connecting Channels Study.

In terms of direct discharges to the St. Clair, the SarniaZbwnship Ditch, which runs through Polysar property isconsidered as an 'industrial point source because it containsindustrial process effluent and cooling water and treated runoffor leachate from four industrial dumpsites owned by imperialOil, Fiberglass, Dow Chemical and Polysar. The Township Ditchmay be a major source of organics to the river due to thepresence of treated process water (Polysar, Cabot Carbon,Fiberglass) and treated leachate and/or runoff fran theindustrial dumpsites (collectively known as the Scott Roaddump). on one occasion during 1985, storm-induced runoff underhigh flow conditions was apparently responsible for largeincreases in concentrations of PCBs, hexachlorobenzene andoctochlorostyrenes detected in the Township Ditch, primarily insuspended solids and not in the aqueous phase. An additional,minor discharge is the dewatering effluent from the CN Railwaytunnel which is contaminated with gases such as phenolics,chlorides and hydrogen sulphide.

See Appendix 1 for more information concerning Industrial Point.Sources.

Point Sources - Municipal

The upper river fran Point Edward to Corunna also receives thedischarge from three municipal water pollution control plants(WPCPs) - Point Wward, Sarnia and Corunna - which have acombined capacity of 73 million litres per day. The PointEdward and Sarnia WPCPs provide primary treatment withphosphorus removal. The Corunna Plant is an extended aerationfacility with phosphorus removal.

In addition to the WPCPs, urban runoff (storm sewers) andcombined storm/sanitary waste (combined sewer overflows) alsodischarge to the river. Sarnia is the major urban centre andhas 4 wet weather combined sewer overflows and 11 storm wateroutfalls. Two of the combined sewer overflows and three of thestorm sewers service the "Chemical Valley" and are potentialsources of industrial organics.

NON-POINT SOURCES

An indirect yet potentially significant source of contaminantsarises from urban and rural runoff and drainage of unknownorigin into tributaries.

In a recent study conducted by Agriculture Canada forEnvironment Canada, it has been reported that about 2.5 millionkg of agricultural pesticides are used annually in theagricultural land draining into the Detroit-St. Clair Riverconnecting channels. Approximately 70% of these pesticides havebeen identified as potentially environmentally hazardous. whiledocumentationn of the use of these agricultural pesticides iscomplete, the fate of these chemicals in the environment remainsunclear. Recent analysis of surface water (Thames River),ground water (drinki-ng wells), and municipal drinking watersupplies by provincial authorities have identified high levelsof several of the pesticides used extensively in agriculture.Further definitive documentation* of this emerging issue isrequired.

Surveys in 1984 and in 1985 by the Ministry of the Environmenthave provided estimates of loading contributions from. water andsuspended solids entering the St. Clair River from adjacentwatersheds. In addition to conventional water chemistryparameters, nutrients, phenols, mercury and heavy metals wereroutinely analyzed.

Additional organic compodnds measured, included PCBs,chlorinated aromatics, chlorophenols, herbicides and pesticides.

Typically, 1984 organic contaminant levels under low flow dryweather conditions were below detection levels with someexceptions associated with aqueous fraction as opposed tosuspended solids.

Elevated levels were also noted for the pesticides atrazine,Ethion, and Mevinphos in Talford and Baby Creeks. The lattertwo were detected in July and possibly originate fromm

agricultural land runoff.

W TE DISPOSAL SITES

There are eleven waste disposal sites in Lambton County within 3Ian of the St. Clair River. This includes 2 landfarmingoperations for refinery wastes, 7 landfills, 4 settling ponds,and .1 drum storage facility. A tabular summary of theactivities of these facilities' is attached. The informationprovided below applies only to active sites. Those which mayhave been used historically but are now closed, are notincluded. An example is the Ladney property which is privatelyowned and has been covered and seeded.

Landfarming

Landfarming or landspreading involves the application ofpetroleum wastes to the upper soil zone where it's decomposed byspoil bacteria. Shell and Esso annually dispose of 18,580 cubicmeters of oily wastes and sludges by landfarming. Esso is themajor land farmer disposing of 17,900 cubic meters.

Groundwater and surface water monitoring is conducted at bothsites wick are located on clay or till with very lowpermeability. Impact on these waters is negligible.

Landfills (Disposal Sites)

Dow, Esso, Polysar, Fiberglass, Ontario Hydro, Unitec andWelland Chemicals Limited operate landfills for industrialwaste. The province of Ontario is responsible for licensingthese sites. Prior to remediation, leachate from Dow's ScottRoad site was migrating into the Scott Road Drain which emptiesinto the St. Clair via the Township Ditch. The site wassubsequently bermed for the collection Leachate, which is nowtreated using activated carbon prior to discharging to the ScottRDad Drain. The Scott Road and Township Ditches weresubsequently excavated to remove contaminated sediments whichwere placed in the Dow landfill. Imperial Oil (Esso Petroleumand Esso Chemcial) Fiberglass and Polysay also operate disposalsites along Scott Road. Further sampling of sediments, water,leachate and runoff is necessary to determine whether thedisposal sites are a continuing source of organics. Sanepreliminary sampling will be conducted as part of EnvironmentCanada's intensive six week study.

The waste types being landfilled vary considerably from solventswith chlorinated hydrocarbons at Dow's Scott Road site to coaland fly ash at Ontario Hydro's site.

Monitoring of surface water, runoff and groundwater also variesconsiderably. Dow has monitored at the Scott Road site since1980 but does not monitor at its LaSalle Road site. Polysar andWelland Chemicals Limited have monitoring programs but Esso doesnot. Ontario Hydro monitors only runoff pH from the fly ashsite. As part of the Upper Great Lakes Connecting ChannelsStudy, these disposal sites will be assessed to determine thepotential impact on groundwater and surface water.

.

All landfills are located in clay or clay tills with lowpermeability.

a

SITE WASTE TYPE ANNUAL QUANTITIES RUNNOFF/LH:ACHATE MONITORING COMMENTS(WT. OR VOL. ) COLLECTION

Dow-Scott Road - oily sludges, solvents - 1,000 T Yes Surface and ground - on clay till(1948) with chlorinated H.C. water since 1980 - sheet pile curtain

(esp. (2"-15') below gradehexachlorobutadiene)

LANDFILL - contaminated soil.

ESSO-Scott Read - refinery coke, spent - 11,000 T None None - an clay till with lowcatalysts, coke and permeabilityconstructional and catalysts (conductivity 10-8cm/sec)demolition debris - 45,000 T

LANDFILL of debris

Polysar-Scott - inert sludges, plastic - 25,000 m3 - lagoons for Surface waters for: - capped with fly ash orRoad resins and alkali, runoff and - pH clay

inorganic and rubber waste leachate - TUC - continuous composite orwastes - phenols batch sampling

LANDFILL - copper - silty clay till- ammonia conductivity 8x10-8 to

3x10-7

cm/sec- dissolved org. carbonand phenols in groundwater near site

Lbw-La Salle - latex solids, graphite, - 22,800 T - proposed None - clay cappingRoad gycol filter cake, solid (berms)

alkali sludges, ditches,sludges, chemical - 8,900 m3 runoff pond)

LANDFILL fertilizer wastes, plant liquidand animal wastes andsome toxic wastes

vI

CHART/3324

SITE WASTE TYPE ANNUAL QUANTITIES RUNNOFF/LEACHATE MONITORING COMMENTS(WP. OR VOL.) COLLECTION

Ontario Hydro - coal ash - 28,000 T None - silty clay till (50-60%(Courtright) clay) 40n thick

LANDFILL runoff- fly ash collection pH of runoff - above ground

ditches

Unitec Inc. - rockwool, phenol - 19,000 T - runoff and Unknown - individual cells(1974) formaldehyde resin, leachate - 4m brown clay

fibreglass collected in - 30m gray claylagoon

LANDFILL - sprayirrigation

Shell (1950) - spent lime (to settling - Nil Nr" - wastes no longer.to pondpond) - clay till (21m thick)

POND

Shell L-16 - bio sludge and oil waste - 680 m3 - runoff Adequate ground and - claycollection suface water - 10 cm/year ground water

- till drainage velocity

LANDFARMsystem

CHART/3324.1

V

C

SITE WASTE TYPE ANNUAL QUANTITIES RUNNOFF/LEACHATE MONITORING COMMENTS(WP. OR VOL.) COLLECTION .

ESSO - refinery waste - 17,900 m3 Ground water and - till (low conductivity)- lime sludges, surface water doneanaerobically digested but not documentedactivated sludges oil

LANDFARM sludges

CIL - low level radioative - drainage Surface water and(Courtright) (limited quantity) ditches ground water

radian and uranium inwaste gypsum slurry

PONDS - ponds with clay dykes

WeIland - perimeter Some sampling done - discharge from treatmentChemicals Ltd. - drum storage, liquid ditches (into - surface water lagoons to Scott Road

effluent storage pond Talfour Creek) - ground water drainLANDFILL - anhydrous aluminum result in - runoff - 3-5m brown clayPOND chloride landfilled in leachate 30m of gray till

DRUM STORAGE. drums irrigration

CHARD/3324.2

Ponds

Shell, CIL and Welland Chemical have ponds for the treatment orstorage of their wastes. The Shell settling pond for spent limeslurries is no longer used; CIL operates two ponds for gypsumslurry waste and Welland Chemical operates a liquid effluentstorage pond, as well as a lagoon waste treatment system whichdischarges to the St. Clair River via the Scott Road Drain.

Surface water and groundwater monitoring to identifyseepage is done at CIL and Welland Chemical Limited.

pond

Drum Storage

Welland Chemical Limited operate a drummed storage facility.

Waste Disposal Summary

1. The types of waste disposal practices near the St. ClairRiver include landfarming, landfilling of hazardous andnon-hazardous waste, pond storage, lagoon treatment, and.drum storage.

2. Monitoring of surface and groundwater sources variesconsiderably.

3. Soil permeability beneath the sites is low, thereforemigration of contaminants through the soil fran surface andnear surface waste sources is slow.

SPILL SUMMARY

During the years 1972 to 1984, there were 275 spills reported inthe Sarnia area. In 161 cases, or 58% of the spills, someproduct entered the St. Clair River, or its tributaries.

Companies with the highest frequency spills:

Polysar 48 spillsDow Chemical 29 "

Imperial Oil/Esso 37 "

CNR 11 "Sun Oil 13 "

following products:

Product Spills # Spills Total Volume

Oil 40 1,000 metric tonsAcid 11 n155 "

Paint 10 n n59Phenol 9 n n7Styrene 7 n16Sodium hydroxide n84Vinyl chloride 3 n23Xylene Q11 "

Benzene 2 0.5 "

During the 12 year period the most significant spills included the

The remaining 187 records include releases of bilge water, sludges,process water, carbon black and other undefined mixtures.

Contingency Plans

Several contingency plans for spills are established. The OntarioMinistry of the Environment, Canadian Coast Guard and EnvironmentCanada all have contingency plans in place to deal with spills ofoil and hazardous materials. There are also agreements between the3 agencies to provide support to each other at the request of thelead agency. The responsibility for the lead role is dividedbetween DOE, MOE and CCG.

DOE is responsible for spills from federal facilities and alsobecomes involved when a spill impacts federal property, such asWalpole Island in the St. Clair River.

MOE has jurisdiction over all other land based pollutionincidents.

CCG is the lead agency for Marine spills and in cases where theinternational boundary is affected.

International Spills

Annex 9 of the Great Lakes Water Quality Agreement gives theCanadian and U.S. Coast Guards responsibility for the Canada/UnitedStates Joint Marine Pollution Contingency Plan for Spills of Oiland other Noxious Substances. Notification procedures areestablished and members of a Joint Response Team are identified, todeal with major international spills.

Although the Joint Plan has been used to notify the Canadian andU.S. agencies of major incidents such as the recentperch loroe thy lene spill, it has not been necessary to invoke theplan in the Sarnia area.

` A detailed supplement to the joint plant for the Detroit-St. ClairRiver System has been prepared to identify local concerns andresources.

/Z_

Summary of Spills in St. Clair River in excess of 40 mP-tric tonnes.

1- Ship named "Parkerevans" collision, 210 MT of Bunker "C" spilled on.Juin 5, 1972 in St.Clair River. 90% recovered.

2- Overflow at "Polysar" of 159 MT of industrial waste (lignliquor)spilled on Juin 23, 1975 on land & water. 90% recovered.

3- Pipe leak at "Imperial Oil Ltd", 239 MT of Phenol waste waterspilled on July 22, 1975 in St. Clair River. 0% recovered.

4- Pipe leak at "Sun Oil", 150 MT of Bunker "C" spilled onJanuary 28, 1976 in St. Clair River. 90% recovered.

5- Plant upset at "Polysar", 86.5 MT of Latex rubber spilledin St. Clair River on January 30, 1980. 0% recovered.

6- Dyke failure at "Dow Chemical", 4,079 MT of Sodium chlorate spilledin St. Clair River on November 21, 1979. Under 30% recovered.

7- Fitting failure at "CN-Rail", 85.7 MT of Bunker "C" spilled on July 6,1977 on land. 90% recovered.

8- Overflow at "Polysar", 411.2 MT of Styrene spilled on St. Clair Riveron May 20,1978. 90% recovered.

9- Pipe leak at "Imperial Oil", 348 MT of Gasoline spilled on landon December 26, 1981. 100% recovered.

10- Pipe Leak at "Dow chemical", 379 MT of sodium chloride spilled inSt. Clair River on December 22, 1981. 90% recovered.

11- Dyke failure at "SUNOIL", 91 MT of process water spilled inSt. Clair River on December 18, 1975. Under 30% recovered.

12- Pipe Leak at "SUNOIL", 300 MT of Bunker "C" spilled on land inSt. Clair River area on January 29, 1976. 100% recovered.

13- Overflow at "Esso Petroleum", 45.5 MT of washwater spilled to theSt. Clair River area on September 7, 1982. 0% recovered.

14- Pipe Leak at "Esso", 164 MT of salt water "brine" spilled onground on January 8, 1984. 90% recovered.

15- Fitting failure at "Esso", 116 MT of fuel #2 spilled in St. ClairRiver on February 22, 1984. 90% recovered.

-13-2. DEEP WELL INJECTION PRACTICES

INTRODUCTION

Deep well waste disposal is the injection of a liquid waste, underpressure or by gravity, into a porous geological strata. Upwardmigration from the disposal zone, potentially resulting in groundwater or surface water contamination, will occur if the confiningbeds contain natural permeable channelways, such as faults andfractures, and if hydraulic pressures are sufficient. Injectionpressures, if high enough, can fracture the overlying formations.Abandoned, poorly constructed and improperly plugged boreholes mayalso aid upward migration.

From 1958 to 1976, disposal wells discharged about 8 x 106 m3 ofindustrial wastes at pressures up to 450 psi into the Detroit RiverGroup in the Sarnia area. These activities were terminated as aresult of breakouts of brine and wastes at the surface. The typesof waste injected were primarily spent caustics, acids, phenols,hydrocarbons, and brines (see attached Tables).

Since 1976, provincial authorities have allowed gravity disposal ofwastes (cavern washing and oil field brines) five miles away fromthe river. The deep well operations were approved by the Ministryof Natural Resources and operators were required to submit monthlyreports on injection volumes to the ministry of the Environment(OWRC).

Geology and Hydrogeology of Lambton Co. in the Vicinity of Sarnia

A vertical 'section' cut through the ground in this area woulddisplay, beginning at the top: 30 to 50 meters of clay (lake andglacial deposits) overlying bedrock consisting primarily of shale(Larobton and Hamilton groups) over limestone and dolomite (DetroitRiver Group), over limestone, shale and salt ('Salina Formation',see attached diagram). Sand and gravel occurs between the clay andupper shale; groundwater within this zone constitutes the primarysource of well water in the area. This zone is referred to as the'freshwater aquifer'.

Oil and gas deposits occur at various depths within the rock units.Wells drilled into these rocks for exploration and production overthe last 100 years have resulted in an abundance of abandoned andoften improperly plugged oil and gas wells.

The ideal concept of deep well injection of wastes is to place thematerial at sufficient depths and under 'confining' rock units(such as shale) which will prevent their subsequent entry into theecosystem. However, the 'Detroit River Group', into which Most ofthe wastes were injected, does not fully meet the generallyaccepted criteria applied to disposal zones and confining beds.Unknown, abandoned wells, natural fractures (joints and faults)and, possibly caves, as well as man-induced fractures (franpressure injection of the wastes) all provide potential channelsfor the wastes to move up into the freshwater aquifer.

More recent data from groundwater and gas monitoring in the CNrailway tunnel could indicate that waste disposed in the DetroitRiver Group may have entered the freshwater aquifer. Inaddition, temporal variations of chloride concentrations and thecomposition of gases entering the tunnel suggest that theoperation of gas caverns in the Salina Formation influencesmovement of contaminants within and above the Detroit RiverGroup. This is an area which will require further investigation.

Although industrial disposal operations have ceased, salt minewastes and oil field brines have continually been disposed inthe Detroit River Group. These activities, along with residualpressures in the Detroit River and possibly, the storage of gasand propane in salt caverns, may result in the migration ofpollutants from the deep wells upward into the freshwateraquifer and subsequently into the river.

I

Ground Surface

Clay Till

Fresh WaterAquifer

BedrockConfining Units

DisposalFormation

1I

11 I

44

I I

I

-t

Schematic of possible failure pathways formigration of contaminants from the disposalzone to the fresh water aquifer

f

Location of Wells

There were 16 injection wells which received liquid industrialwastes. These extend approximately 205 meters (600 feet) belowground surface into the Detroit River Group limestone formationunder pressures of 0 to 450 psi. In addition, Dow Chemicaloperated two storage caverns at a depth of 580 meters (1900feet) under gravity feed into the Salina (salt) formation. Amap of the well locations is attached.

Substances and Quantities Disposed

See attached table.

Previous Upwelling

There is historical documentation to suggest that pressurizedwaste has migrated from the Detroit River Group formationresulting in the flowing of industrial wastes from abandonedwells in both Lambton County and Port Huron Michigan areas. In1967, several abandoned wells in Port Huron, Michigan began toflow, yielding water containing phenols and hydrogen sulphide.In 1972, an abandoned 44m (140 ft.) well behind the CapitolTheatre in Sarnia began to flow. The greenish liquid containedhigh levels of phenol, chloride, hydrogen sulphide and organiccarbon. In the same year, 2 water wells on the Imperial OilLtd. property began to discharge similar-type liquids. Deepwell disposal of such waste was subsequently discontinued,however, deep well disposal of brine wastes continues.

Ado YrII Head total leleclloo tone Wall- Averasm Injection total 04A urC1.ap+ey 1.11 . for floe flevatloo Oepln Interval W44 Pressure Mate Y rle f l

f

ref) gaaw vo 4"'.V WIF Conc of t fwf F F 1

e d o eletl ill Jfpe. . ee rtersl eet IMeters) eet (Neten 1 pet 6uis/day Iw Nay1 laluctlue obis Jim of Waste

Marcus a la+afon Enntsaillan 5 11 el5 12061 961 (293) Oetrolt liver rr. 0 to 150 140 (Iltl) I91U-1411 2/41 11110 Spent Causticw ll -1al

6tl9S-- ' 11 19 -2 101 110141,

(42,921) lalustrlal wastee U-Stl0 ( 166-1 ) ))US

In1Y.psan 1A12 12 61U (24141 452 (260) 5511 - 852 SU IIU (ku.0) 1905-74 Ac 1.1

Ci.ry.nnf1166-20d)

490,000 f.aust lc! Walls ld 673 (205) 1000 (305) 511 1909.11

900)(77, Br10tlynuwater

irlcll 11 9A !Alibi. an Moore IU 9 664 (2112) 59) (182) U 300 147,11 1958-1913 nyArourouns60000r 11:'wt Y.IIs 12

I,919,0Uu Chlorides

18 10 9 663.4 (202) 100 (213) 613 )AU J I 1973-1916(]14,6301

IthorsP henuls

Shell fl

CIA front 68 951 1290) 6011 - 91N) 3'10 12215) ISgO (23tl) 1962-1912 phenolsanna IIMI-1141

L 1 M111 ea

a2 lC front 6tl 950 (29411 650 - 950 not utll-6.26G.t"I

26011995_ (194-29u) Ited,

Sun 111

C(j.'plnr

t 1.600toe Sarela It.t, 19 964 (294) 615 - 464 Um 1211681 191M1 1965-1973 3.460.00 Spent Caastfc1206-2941 (SItl,SUil

I'ultevr

furpors-10 Meg,

Plan35 90,1 (211) 450 (3101) 211 j]02) 1961-1910 !00,0111 Spent Caustic

thin 12(111,291) Vhelwlt

Iwllerlal Oul011

:a tl110 (244) 605 - tl00 1200 (191) 19Stl-1901 Spent Caustic(181-2IC) Phenalst14111v4

5 Well. Out t8 220 1250) 61:'1 - 320 1200 (191) 1960-1961 41.3Utl,3311Sulfides

0%01 IC of$ 12061 629 - 6l5 400-ISU 330 152.41 1960-1912 (7,521.424)(IS2-2116) 12154-1107)

Out ID 820 (25J) 035 - 8?0 25341 (402) 1961-102'194-1501

nus Ik 010 (250) 635 - tl2U 2uWl (Jill) 1961-191?1194-!.U)

Lau1.711n 1 b 1aa101on Soalora 15 2 1249 (11111 115 - 1234 310 (2551) 1200 (191) I'M-19)2 1.)SU,UW Steam Co:Wle44aW Ytth

11011,14

1 1110 ypw 1596.202) aaw"la Anu C412

2 rolls .' n 15 4 607.5 (IU5) 1!19 1)Jill 1911 34U (24i-156) 110 (2551) (21h1 11911

Ih1r M 1 rldun Same NM 29 Cavern Sallna Salt It 9W

1i 1

7- lq ,191W

1-11 4.ekkl Yasle III Is(6161 Solid C.Ad) ddsldue

Industrial Waste Injectlon Wells, Lambton County, Ontario.

10 - Wel I I.D. Number- Industrial Waste

Injection(,-L t",g)-'Cavern - Wash Ing

Brine Injection® - Oil-Field Brine

InjectionA - Oil-Field Brine

injection toGuelph Fm

Location of disposal wells in part of

Lambton County (From URN, 1984)

-/I-3. Historical and Present Quality of Water and Sediments and their

Impact on Biota Along the Lenat.- o t:a St. Clair River

Heavy urban and industrial development and use as a transportationcorridor have contributed to water quality impairment in the GreatLakes connecting channels including the St. Clair River. Althoughconventional water quality in these areas has improved since the1960's, pollutants such as heavy metals and persistant organiccompounds (e.g., OC Pesticides, PCBs) remain in the fish andsediment and water in amounts at times exceeding jurisdictionalobjectives or guidelines. A brief description of the nature of theproblem is outlined in the table below (Water Quality Board 1985).

NATURE OF THE PROBLEM

Types of ProblemsEncountered

Possible Sources ofthe Problems

Conventional PollutantsHeavy MetalsToxic OrganicsContaminated SedimentsBiota ImpactedBeach ClosingsFish Consumption Advisories

Bacterial contamination fromlimits local recreational use.

Municipal Point SourcesIndustrial Point sourcesCombined Sewer OverflowsGroundwater

combined sewer overflows at Sarnia

Residual sediment contamination and, to a lesser degree, industrialdischarges are slowing the recovery of the benthic fauna, adjacentto and downstream of the petroleum and petrochemical complex inSarnia and Moore Township.

Trace organic contamination of water, sediment and fish identifiedbut significance not known - studies proceeding.

Sediments in several locations along the Ontario shoreline of theSt. Clair River remain contaminated with trace organics, PCB andheavy metals and require confined disposal if dredged.

Water

The St. Clair River is subject to industrial discharges fromrefineries and petrochemical plants amounting to a total flow of500 million gallons/day or 0.5% of the total river flow. Most ofthese discharges take place in the nearshore area where limitedmixing is coupled with the build-up of contaminants due to multiplesources (about 20 direct outfalls to the river).

_Z4_

Total phenol levels along the Ontario shoreline are now within the1978 Great Lakes Water Quality Agreement Objective. Thiscompliance was achieved as a result of the introduction ofbiological oxidation units by mist of the industries in theirprocess streams prior to effluent discharge to the river.

.The Ontario Ministry of the Environment intensive programs during1982-84 indicated that chlorinated organics such ashexachlorobenzene (HCB), octachlorobenzene (OCB) were detected inparts per trillion levels in nearshore river waters. Thesecompounds were found to persist along a 2-km reach of riverfrontfrom the Township Ditch to the Dow/Suncor property line. ShellCanada and Petrosar Limited effluents have also contributed to thepersistence of these compounds.

On occasion, concentrations of chlorinated contaminants haveapproached parts per billion levels and resulted in exceedances ofproposed objectives or criteria for the protection of aquatic life.The magnitude of exceedance was up to 370-fold for HCB, 13-fold forHCBD and 5-fold for OCB. No transboundary pollution occurs fromthe Ontario discharges downstream as far as the river mouth delta.In the river delta, however, traces of these compounds occur in the

South Channel where transboundary movement to the State of Michiganis prevalent. In this channel, contaminants such as HCB, aremainly associated with the water phase.

Environment Ontario's Drinking Water Surveillance Program (DWSP)indicates that no organic compounds have been found to exceed theOntario Drinking Water Objectives or other health-relatedguidelines. Dibenzo-p-dioxins and dibenzofurans have not beendetected in any form in any treated water samples.

Sediment

St. Clair River sediments are generally characterized by sand andgravel overlying a clay hardpan. Shoreline development such aslandscaping and construction of docks and breakwalls in the mid1970's have likely resulted in increased amounts of sand andcrushed stone along the immediate riverfront of the ChemicalValley.

The Ontario Ministry of the Environment investigations in 1983 and1985 indicated surficial sediment contamination with heavy metals(particularly mercury, although decreased significantly in recentyears), PCBs (up to 3000 ug/kg), HCB (up to 600 ug/kg) and OCS (upto 580 ug/kg). Total chlorinated dibenzo-o-dioxins (CDD) and totalchlorinated dibenzofurans (CDF) have been detected at levels of 5and 22 ppb, respectively. No tetradioxins, nor 2, 3, 7, 8-TCDDwere detected in these sediment samples.

-.24-These contaminants were found to be localized in a reach of 1.5 kmlength along the Polysar/Dow riverfront. Sediments in the vicinityof the Walpole and Wallaceburg water intakes contained relativelylow levels of Octa - CDDs and Octa CDFs, no PCBs, buthexachlorobenzene levels ranged from 100-200 ppb.

During the 1977 St. Clair River Organics Study, oil globules wereobserved ,in the bottom sediments. These globules were attributedto spills from freighters, docked ships during cargo handling andindustrial sources.

Using technology developed in 1984 and 1985, analysis of an oilylayer above the sediment showed elevated levels of chlorinatedorganics (mainly tetrachloroethylene in ppm range). Tbtalchlorinated dioxins in the 1985 samples amounted to an average of35 ppb and the total chlorinated dibenzofurans averaged 81 ppb.Thiis oily layer and associated contaminants were localized andconfined to an area of 20 x 50 m in the vicinity of Dow Chemical.

The attached 2 tables provide data on: (1) sediments from the St.Clair River south of the CN tunnel (collected in 1984 by NVM ); and(2) results of the analyses of 1984 and 1985 samples of the oilylayer off Dow.

Biota

Benthic- community structure analyses by the Ministry of theEnvironment in 1968 and 1977 revealed the resurgence of bottomdwelling life forms along the Ontario shoreline of the river;however, there was a zone of severe impairment (5 km long x 78 mwide) along the chemical valley waterfront. During May 1985, anupdate of biological conditions of this area indicated signs offurther improvements as evidenced by the presence of organismsindicative of good water quality. A repeat of this biologicalsurvey in November 1985 suggested that there was little changebetween seasons with the exception of a degraded area (20 x 50 m)in the vicinity of Dow's lst Street sewer complex. The remainingportion of the river, as well as the entire U.S. shoreline,exhibited healthy benthic communities not affected by theindustrial discharges.

Programs using clams introduced to the river in cages "andcollections of fish, such as the young-of-the-year spottailshiners, have confirmed the findings of water quality programsindicating that chlorinated organics are prevalent at elevatedlevels in a 2-lam section of the waterfront from the Township Ditchto the Dow/Suncor property line. The caged clams data furtherreveal that the impact of upstream sources of PCBs, OCS, HCB, HCBD,QCB may extend as far as Port Lambton, 35 km downstream from theChemical Valley.

The spottail shiners data indicate a decline of HCB levels from 406ng/g (ppb) in 1979 to. 6 ng/g (ppb) in 1983. Polycyclic arcr atichydrocarbon (PAH) residues in spottail shiners collected downstreamfrom Suncor total 4.6 ng/g (wet weight whole fish) and thepercentage of known or suspected carcinogens was about 423 of thetotal PAH level.

A(W ARIVER SEDIMENT ANALYSES

FROM BOTTOM OF ST. CLAIR RIVER1984

Parameter No. of StationsDetected

Hexachloroethane 8

Hexachlorobutadiene 11

Peatachlorobenzene 10

Hexachlorobenzene 11

Octachlorostyrene 10

Total PCB's 11

Concentrations (ppb)Average Range

18.9 0.828-43 .

>5,532.0 0.99-40,000

353.0 0.14=1800

>4,320.7 2.0-23,000

976.1 0.24-3,900

3,559.9 2.0-14,000

- 21-

ST. CLAIR RIVERSLUDGE SAMPLE ANALYSES(1984 and 1985 samples)

i) Parameter .Concentr tion (ppm)1984 T 1985

HexachloroethaneHexachlorobutadienePentachloropropeneTetrachlorobuteneHexachloropropenePentachlorobutadieneHexachlorobuteneTetrachlorobenzeneDiphenyl EtherPentachlorobenzeneHexachlorobenzene2,4-D(Ester Acid?)Dibutyl PhthalateN-Dichloromethyl-

PentachloroanilineOctachlorostyreneNapthalenePentachloropropaneC4 BiphenylMethyl PhenanthreneSulphur (S8)FluoranthenePyreneC16 H13N PAHPerchloroethyleneChloroform1,1,1-TrichloroethaneCarbon Tetrachloride

ii) Parameter

TettachorodibenzofuranTetrachorodibenzodioxinPentachorodibenzofuranPenrachorodibenzodioxinHexachorodibenzofuranHexachorodibenzodioxinHeptachorodibenzofuranHeptachorodibenzodioxinOctachorodibenzofuranOctachorodibenzodioxin

14001100 .

7040

17025060504075

60050

36080

180

35,000

1,1001,600

60

40

1,200

7017019139

3014

1512

>100,000300

1,100> 25,000

Concentration (ppb)1984 . 1985

58.318.36.07.7

14114.2

24260180

3032ND*68NDND28ND2814

*ND - not detectable

Data obtained from the analysis of emerald shiners in 1985 at threelocations in the St. Clair River (Blue Water Bridge control,downstream from Suncor and Stag Islam]) revealed no traces oftetrachlorinated dibenzo-dioxins. There was indication, however,that Lake Huron may be a source of tetrad ibenzofurans, since thecontrol station indicated a level of 1200 pot. Similarly, sportfish analysis revealed. a level of 4 ppt of 2, 3, 7, 8-TCDD (with amaximum of 9 ppt) in channel catfish fran Lake Huron.

The Ontario Sport Fish data base for the St. Clair River containsinformation on persistant contaminants such as mercury, PCB, mirex,organochlorine, pesticides and 2,3,7,8-TCDD. Consumptionadvisories on the data base are published in the "Guide to EatingOntario Sport Fish".

At present, certain species and sizes are advised for limited ornon consumption based on mercury (22 cases) and PCB (7 cases). Nospecimen tested exceeded (or in fact approached) the CanadianFederal tolerance of 20 ppt for 2,3,7,8-ICDD.

The advisories for mercury and PCB are presently less restrictivethan in previous years due to declining levels of both substances.More recent samples of various species of sport fish were analyzedfor hexachlorobenzene and octachlorostyrene. rnw levels (ppb) ofthese compounds were found; health advisory levels for HCB and OCSare currently not available.

During July 1984 samples of the attached algae Cladophora werecollected by the Ministry of the Environment fran five shorelinesites in the St. Clair River bordering the industrial canplex atCorunna (Shell Canada/Ethyl Corp. of Canada/Petrosar) and.analyzedfor heavy metals and PCBs (triplicate analyses). For comparison,a background control sample of Cladonhora was also taken upstreamof Sarnia. Results show the presence o a number of contaminants(i.e., nickel, selenium, barium, copper, chrrxnium, manganese,lead, arsenic, mercury, PCBs) at levels above background in thevicinity of Corunna; and of these contaminants, point sourceloadings of selenium, lead, mercury, PCBs are indicated.

- Z5-4. HAZARDOUS WASTE TRAVSBORDER MOVEMENT IN THE SARNIA AREA

The majority of the hazardous waste entering the country at Sarniais destined for the Tricil waste management facility in Corunna, 12km southeast of Sarnia. In 1977 an estimated 2,400 cubic meters ofimported waste was disposed of at Tricil. This volume hasincreased steadily to 22,000 cubic meters in 1984. The wastesdisposed of at Tricil came from the U.S., 80% caning across theBlue Water Bridge at Sarnia.

The Tricil Corunna facility is comprised of a high temperatureliquid injector incinerator and a controlled solid waste landfill.They are licensed by the Ontario Ministry of the Environment toreceive oily water, acids, alkalis, waste oils, organic solvents,amines, glycols, other organics (except PCBs) and other inorganics,pigments, paints, printing and adhesive wastes.

The Ontario Ministry of the Environment have undertaken a computersearch of waste movement records prior to 1977 to see if there wereany discrepancies or unusual movements by Dow or other Sarnia-canpanies. None were found.

Wastes moving internationally, interprovincially, orintraprovincially must be manifested, as of July 1, 1985, inaccordance with the Transport of Dangerous Goods Regulations, andOntario Regulation 309. The manifest system is a "cradle to grave"means of tracking wastes, with the responsibility placed on thegenerator for its ultimate disposal. There is also aprenotification requirement for wastes entering Canada. The natureof the waste and its destination must be identified by thegenerator in the prenotification which must be submitted annually.

International and interprovincial movement of wastes is federalresponsibility under TDGA. Interprovincial movement is theresponsibility of the province. Licensing of waste haulers is doneby the province under agreement with Transport Canada.

Under TDGA all industries that offer hazardous wastes for Transportin quantities over 500 kg or in bulk must register every five yearswith the Transport of Dangerous Goods Office of Transport Canada.

REMEDIAL ACTIONS AND SCIENTIFIC STUDIES

1 Perchloroethylene Spill

Dow Chemical spilled an estimted 9,400 gallons ofperchloroethylene, of which 5,500 gallons were recoveredfrom catch basins on Dow's property and from the river.Approximately 2,500 gallons reached the St. Clair River atSarnia between August 13 and August 16. The estimate isbased on MOE's modelling of the spill.

On August 14, Dow Chemical found high levels ofcontaminants in a sample taken the previous day from one ofits sewers which leads to the St. Clair River. The companyinformed MOE about the problem the same day.

The company began a suction cleanup of the heavier-than-water liquid on August 16, and recovered about 5,500gallons from the river sediment and sewer catch basins.

MOE-Sarnia has advised local municipalities of its testingprogram and provided analytical results to local medicalofficers of health. Information has also been provided tothe Michigan Department of Natural Resources, Health andWelfare Canada and Environment Canada.

MOE concluded the investigation and on September 30 DowChemical Canada Inc. in Sarnia was charged with six countsunder Ontario's environmental legislation. Dow pleaded notguilty to the charges and a trial date of January 15-16 wasset for Sarnia Provincial Offences Court.

Four charges (under Section 16(1) of the Ontario WaterResources Act) are laid for discharging perchloroethyleneinto the St. Clair River on four days during the week ofAugust 12, 1985.

Two other charges (under Section 13(1) of the EnvironmentalProtection Act) are for causing harm and materialdiscomfort to people as a result of the chemical spill.

Raw water samples taken September 3 at Walpole Island andWallaceburg contained 2-7 parts per billionperchloroethylene. The World Health Organization'stentative criteria for drinking water is 10 parts perbillion. Nothing was detected in samples from Stag Island,Belle River, Windsor, and Amherstburg.

. -2

DOW CHEMICAL CANADA INC.Vidal Street, P.O. Box 3030, Sarnia, Ontario, N7T 7M 1

October 23, 1905

2, DOW'S PROPOSAL FOR REMOVAL OF ST. CLAIR RIM SEDD MT

1. Because there is visual evidence of perchloroethylere (PCE)trapped in the St. Clair River sediment near Dow's First St. areacutfalls Dow proposes to remove the loose PCE contaminatedsediment in this area.

2. The area of sediment removal is defined as a 150' X 150' areabounded on the east by Dow's seawall and on the north by anextension of our property line with Poipsar. This area wasdefined by a visual inspection using divers. A rope grid iscurrently staked'to the river bottom in this area. The 150' X150' area includes the 30' X 100' low area of particular concernto the MOE. The average depth of sediment in this area isestimated to be 6" so approximately 450 cu. yds. of sediment willbe removed.

3. Sediment will be removed by means of high powered vacuum trucks.One truck will be positioned on a stabilized barge in the riverand another one on shore near Dow's Third St. outfall. Sedimentwill be sucked from the bottom through hoses into the truck andthen transferred to a watertight Dinosaur bucket on a smalltransfer barge. The small barge will then be moved to the ThirdSt. outfall area where the material will be removed from thebucket by the second vacuum truck. The end of the hose 411 havea special nozzle attachment and valve which will be operated bydivers at the bottom.

The Job will be carried out working from north to south and eastto west. Any large debris encountered (e.g., rocks, tree stumps)will be moved aside but not removed.

4 No downstream impact is expected. As an additional precautionduring the sediment removal process a series of grab samples willbe taken daily approximately 2 hours after the removal work hasstarted. The samples will be taken approximately 3' from the.bottom of the river at the following locations:

1) one sample upstream of work area

2) two samples approximately 1000' directly downstream fromwork area

3) three samples along a transect at Dow's south baandary withSuncor

4) one sample from the LIS # 8 station south of Courtright

The samples will be analyzed by Dow for perchloroethylene (LOD 0.1ppb). The data will be assessed by Dow and the MOE prior tostarting the next days, work. The MOE will sample drinking waterintakes do nriver before and during the removal operation. Dowwill analyze the samples for PCE. All samples will be subject torandom crosschecks by the MOE Lab.

The following criteria will be used for purposes of the monitoringprogramme :

a) 1-da -SNARL = 2300 ppb PCE This level not to be exceeded atmow-dun noun aty .

b) 10-day SNARL = 175 ppb PCE. This level not to be exceeded atthe Dow--b-un boundary as an average daily concentration overthe duration of the programme.

5

C) 70-yr. W.H.O. Criteria = 10 b PCE.' This level not to beexceeded` at any of the drinking water intakes.

Disposal of the removed sediment will be as follows:

a) Material from vacuums trucks will be stored in a clay-linedpond in block 120 where it will be allowed to settle.

b) Clear water will be decanted and t°ansferred by vacuum truckto Plant 35 for processing by CPFC.

c) The remaining solids will be stream-stripped to remove the PCEand then landfilled at Dow's Scott Road Landfill site. ThePCE removed will be recycled through the CPEC system forrecovery.

6. The estimated timing of this project is as follows:

a) The removal operation should take approximately two weekssubject to weather conditions.

b) Treatment of decanted water and sediment will take somewhatlonger. It is estimated that 8 - 9 months may be necessary toprocess this material because of winter freeze-up.

c) The starting date is tentatively scheduled for October 28,1985.

Disposal of Dredged Material

MOE will be informed prior to commencing disposalof dredged material.

Water:

Water phase directed to Chlorinated ProductsEcology column (CPEC).

Based on low solubility, no dioxin is expected inthe water phase.

CPEC considered 98% efficient in perchloroethylenerecovery. Water discharge from CPEC to sewer should be lessthan 2 ppm before dilution in sewer.

If water phase does contain dioxin, dioxin wouldstrip with perchloroethylene which is directed to thechlorinated solvents reactor.

The dioxin fraction would become a component ofthe heavy tars generated in the reactor which are subsequent-ly destroyed in the Thermal Oxidizer (TOX Unit) which isconsidered capable of destroying dioxin.

Sediment:

To be transferred by bucket to a steam stripper.Condensed volatiles from stripper directed to CPEC.

Dow is of the opinion that most dioxin will remainwith solids rather than strip off.

Any dioxin which may be stripped with the perchloro-ethylene will go ultimately to the TOX unit as'above.

Anticipated that perchloroethylene remaining insolids after stripping will be less than 1000 ppm.

g

Landfill:

Scott Road site is approved for chlorinated solidsand hazardous materials.

Dioxin should not leach from solids. In the eventit does, leachate treatment by activated carbon filter bedwill control.

Ministry Ministbre Southwestern Region duof the de Region Sud-OuestEnvironment I'Environnement

985 Adelaide Street South 995 sud, rue 4deia,oeLondon Ontario London (Ontario,N6E 1V3 N6E 1V3519/681.3600 5191681.3600

November 8, 1985

Dow Chemical Canada Inc.,Vidal Street,P. 0. Box 3030,Sarnia, Ontario.N7T 7M1

Attention: Mr. S. Bolt

Dear Mr. Bolt:

This letter will confirm the Hinistry of theEnvironment's approval of y3ur company's proposal of October23, 1985 and the additions to i- of November 5, 1985, forthe removal of contaminated sediment on the floor of the St.Clair River adjacent to your company's property. Thisapproval is subject to the procedures outlined in yourproposal and the following conditions:

1. The procedures for removal of material from the riverbottom, its transfer to the barge, its transfer fromthe barge to the vacuum truck, and its placement in thepond on Dow property be in accordance with requirementsof the Ministry- of Labour for protection of workers.

2. The sampling program during removal will be carried outas follows:

(a) One sample to be taken 1000' upstream of work areaat mid-depth 125' from shore.

(b) At a transect 1000' downstream from work areasamples will be collected at a lateral distance of251, 1251, 225' from shore and entail the follow-ing:

(i) hourly sampling for suspended solids at-the1000' location (251, 1251, 225' from shore)at surface mid-depth and sediment waterinterface.

T I'4

>V

Dow Chemical Canada Inc. -_U - Uovember 8, 1985

(ii) Every two ,lours, starting one hour beforework s-art up and for duration of the firstthree operating days, samples will be analy-sed for perchlorcethylene at mid-depth andthe sediment water interface. (A decisionwill be made on the sampling frequency andlocations based on the results of the firstthree days samples).

(c) Three samples should be taken along Dow's southboundary with Suncor on a transect from shore at251, 125' and 225'. These samples should be takenat the sediment water interface and at mid-depth.Samples should be taken 3 times/day (early morn-ing, after start-up; mid-day and late afternoon).A decision will be made on the sampling programbased on results of the first 3 days operation.

(d) One sample should be taken from LIS #8 station atCourtright (mid-depth).

3. The removal of material will stop at the direction ofM:CEE if monitoring indicates the criteria have beenexceeded or additional information is required by MOE.

4. Liquid level in the storage pond shall be maintainedbelow ground level.

And recognizing the following actions will or have formedpart of the clean-up project:

(1) A MOE diver will observe the clean-up work as itprogresses.

(2) Temporary facilities for treating with powderedactivated carbon installed at Walpole Island andWallaceburg will be placed in operation during thetest stages and should monitoring indicate thepresence or likely presence of perchloroethyelenein the raw water supply the treatment wouldcontinue.

(3) Air samples will be collected at the storage pondto monitor air emissions.

(4) Borehole results from the storage pond bottom havebeen assessed by the MOE hydrogeologist andconfirm the integrity of the pond to contain thesediment material removed from the river.

Dow Chemical Canada inc:. - 3,Z- November 8, _185

- (5) information n the daily samrlinc will be providedto the MOH, municipalities and Michigan Departmentof Natural Resources. Communicatic-, with MichiganDNR (and the U.S. Environmental Agency) has beenestablished for this project.

(6) Samples of raw and trea-ced water will be collectedat Wallaceburg and Walpole Island during theclean-up project.

The Ministry ma%p require some changes or addition-al information as this work proceeds. Communication duringevery phase of the clean-up is important. In this regard,our contact person will be Mr. K. Haniff (336-4030) of'ourSarnia Office. Back-up contacts should be obtained from Mr.Haniff.

Yours truly,

DAMcT:mw D. A. McTavish, P. Eng.,F 08 01 Regional Director.

3.

-33-St. Clair River Pollution-Investi ation

Environment Canada

OBJECTIVE

To comprehensively define the extent of contamination in a 3 km.reach of the St. Clair River, (on the U.S. and Canadian sides ofthe river), which presently exhibits 'tarry patches' oforganochlorine waste and highly contaminated sediments.

PRIORITY ACTIVITIES

1. Collect sediment samples along 10 transects; 2 above the CNtunnel and 8 downstream. Transects below tunnel will belocated on lines already established by the University ofWindsor. Six sediments samples will be collected from eachtransect, 3 on each side of the river, for a total of 60.samples.

2. Water samples will be collected from 'deep holes' in theSt. Clair River delta around Walpole Island. Preliminaryevidence suggests these could be deep groundwater sources(karst springs).

3. Collect samples from 18 to 20 industrial effluent pointsouces on the Canadian side of the St. Clair river, withinthe 3 km. stretch south of the CN tunnel.

PARTICIPANTS

Environment Canada

- Office of the Regional Director General- National Water Research Institute- Environmental Protection Service - Ontario Region

Work Schedule (tentative)

Sampling: November 3 to December 2, 1985Analyses: December 2 to December 16, 1985DOE Report: December 20, 1985

Ongoing Activities (coordination and consultation with)

1.- University of Windsor, Great Lakes Institute,hydrogeological studies of groundwater seepage into thebottom of the St. Clair River.

Contact: R. Patterson (NHRI)

2. St. Clair River water column sampling and analyses.

Contact: B. Oliver (NWRI)

-3q-

3. Suficial river water analyses for volatile organicindustrial effluents.

Contact: K. Kaiser (NWRI)

4. Underwatertransectspatch'.

Contact:

video photography along University of Windsorin the vicinity of the previously observed 'tarry

K. Rodgers (NWRI)

5. Co-ordination with ongoing MOE investigations of sediment,water and benthos.

Contact: F. Fleischer (MOE)

-2s,-

PRNINCIAL (MINISTRY OF THE ENVIRONMENT) CURRENT STUDIES

Surveys of (May '85, Nov. '85) St. Clair River benthic fauna andsediments to assess improvements due to remedial measures andimpacts of chemical spoils.

Sept. 23-28/85 intensive survey downstream of Dow Chemical toidentify impact of tetrachloroethylene spill on water, sediments,biota.

Development and testing of a fate model using a typical organiccompound discharged into the river to discern concentrations insediments, water and biota.

1984 and 1985 survey of tributary inputs of trace contaminants.

Report on bacterial conditions along the Sarnia waterfront,assessing impact of developments at Sarnia Bay on the dispersion ofdischarges from storm and combined sewer overflows.

Report on 1983 sediment and benthos survey in Lake St. Clair.

Analyze 1984 sampling of trace organics and 1984 clambiomonitoring.

Investiage industrial and municipal sources and quantify loadingsof contaminants of existing or potential concern at majorfacilities in the connecting channels and Lake St. Clair.

Investigate non-point sources of pollution in the study areawatershed to quantify by source type the loadings of contaminantsof concern reaching the connecting channels and Lake St. Clair fromtributaries.

Stratified water quality sampling at 2 major tributaries (SydenhamRiver, Thames River) for annual nutrient and contaminant loadingestimates.

In-place Pollutants Program: Survey sediments, benthic organismsand sculpins to determine impacts of contaminants in sediments onwater quality and aquatic biota; benthic surveys to determinetoxicity of contaminated sediments on aquatic biota; reporting on1984 sediment and macrozoobenthic surveys to asses the impact ofin-place pollutants on several groups of macroinvertebrates andseasonal variation in contaminant body burdens.

Collections of young-of-the-year spottail shiners from 10localities for point-source identifications, assessment ofeffectiveness of remedial measures, temporal trend assessment.

Ontario Drinking Water Surveillance Program. W-)nitoring ofinorganic and organic contaminants (5 times per year) at raw,finished and distribution system locations.

Sampling of raw water from 3 municipal intakes (at Sarnia,Amherstburg, Kingsville) to monitor long-term trends relative tophosphorus removal programs.

Sportfish Contaminants Surveillance for development of ConsumptionGuidelines. Collection consists of edible portions frar 257 adultfish. Collection also at Lake St. Clair and Southern Lake Huron.

..U-

5 EXECUTIVE SUMMARY OF THE UGLCC WORK PLAN

BACKGROUND

The Upper Great Lakes Connecting Channels consists of fournavigational waterways. The St. Marys River connects LakesSuperior and Huron. The St. Clair River and Lake St. Clairflow into the Detroit River, connecting Lake Huron and LakeErie. Heavy urban and industrial development, and the useof the channels as transportation corridors through one ofNorth America's great inland waterways, have contributed towater quality degradation in these channels. Pollutionproblems, including mercury contamination in Lake St. Clairand phenols in the St. Marys River, were recognized in theseareas as early as the 19401s. The designation of theSt. Marys, St. Clair and Detroit Rivers as class A areas ofconcern by the International Joint Commission (IJC) in 1981was based on evidence of significant environmental degrada-tion and severe impairment of beneficial uses. Althoughwater quality in these areas has improved, persistentpollutants such as heavy metals, organochlorine pesticidesand PCBs remain in the fish, sediment and water.

In his November 1983 speech to the IJC meeting.inIndianapolis, Indiana, the U.S. Environmental ProtectionAgency Administrator William Ruckelshaus announced a U.S.study on the St. Marys, St. Clair and Detroit Rivers,including Lake St. Clair, and invited Canadian support. ByFebruary 1984, the State of Michigan, Environment Canada,Department of Fisheries and Oceans, and the Ontario Ministryof the Environment had all agreed to merge their ongoingstudies and develop new programs in conjunction with theU.S. agencies. The City of Detroit, also having ongoingstudies, subsequently joined the effort. Since then theresearch and environmental laboratories of the variousCanadian and U.S. regional and federal agencies plus thoseof several universities, are committed to providing thenecessary support to determine the sources, fate and impactof toxic contaminants released to the connecting channels.

STUDY PURPOSE

The purpose of the Study is:

1) to facilitate the development of remedial action plans;and

2) develop a framework for long term understanding ofecosystem-contaminant dynamics for these waterbodies.

.../2

z

While considerable progress has been made in the control ofpollution in the Upper Great Lakes Connecting Channels(UGLCC), these areas continue to be designated as Areas ofConcern by the International Joint Commission (IJC). Toidentify and address the remaining problems in thesegeographic areas, Canadian and U.S. environmental agencieshave agreed to embark on a three year study of theSt. Marys, St. Clair and Detroit Rivers, and Lake St. Clair.The study will evaluate historical and current scientificdata, augmented as necessary by coordinated surveillance andresearch efforts to identify and quantify the impacts ofconventional pollutants and toxic substances from pointsources, nonpoint sources (both runoff and contaminated-groundwater) and tributaries on beneficial human uses. Theresultant data will be used to recommend specific actions toaddress remaining and emerging concerns.. These recommenda-tions will provide guidance for the sponsoring agencies intheir development of programs for management of pollutioncontrols and for long term monitoring of the effectivenessof these programs.

STUDY AREA

The study area includes St. Marys, St. Clair River, LakeSt. Clair, the Detroit River and the Western Basin of LakeErie as it relates to impacts from the Detroit River. Thetributaries to the above system will be considered as partof the study area if their individual study is needed toaccurately define specific sources and effects of contami-nants. In the case of contaminated groundwater and associa-ted waste sites, the study will be limited to those areashaving present or potential impact on the water quality ofthe study area.

PARTICIPANTS AND MANAGEMENT STRUCTURE

The study will be conducted jointly by agencies of theFederal governments of the United States and Canada, theState of Michigan, and the Province of Ontario. The studyis directed by a three-tiered management structure: theManagement Committee, the Activity Integration Committee andthe Study Work Groups.

.../3

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The Management Committee consists of representatives of theprincipal U.S. and Canadian agencies participating in thestudy. These include the U.S. Environmental ProtectionAgency (EPA), Michigan Department of Natural Resources(MDNR), U.S. Fish and Wildlife Service (FWS), NationalOceanic and Atmospheric Administration (NOAA), U.S. ArmyCorps of Engineers (COE), City of Detroit, CanadianDepartment of the Environment (DOE), Department of Fisheriesand Oceans (DFO), and the Ontario Ministry of theEnvironment (OMOE). The responsibility of the ManagementCommittee is to identify the issues and define the studystructure, approve the study work plans, and approve thefinal study report for submittal to the participatingagencies.

The Activity Integration Committee (AIC) consists of thechairmen of the technical work groups plus representativesof U.S. and Canadian federal and regional governments. Itis responsible for preparing and overseeing implementationof the study work plan and the drafting of the final studyreport.

Members of the work groups are scientific technical expertsfrom participating governmental agencies. They have majorresponsibilities for identifying, planning and coordinatingthe surveillance and research activities.

SCHEDULE

This project will proceed in several stages: planning andorganization, 1st field year, 2nd field year, and reportpreparations. The planning and organization activities werebegun in early 1984, the completion of data collection andanalysis is anticipated at the close of the 1986 fieldsession, and the final report will be delivered to thesponsoring agencies in the Fall of 1987.

APPROACH AND ACTIVITIES

In order to meet the objectives and goals of the Upper GreatLakes Connecting Channels Study, 68 activities have beenproposed and grouped into 8 general categories. These are:point sources, nonpoint sources, water quality, sediments,biota modeling, data quality management and administrativesupport.

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Because the focus of the UGLCC Study is to define remainingneeds for regulatory and remedial actions, the activities tobe implemented within the Study reflect the two broadcategories of concern: toxic contamination and habitatdestruction. The study will address problems of continuinginputs and of in-place pollutants (i.e. contaminatedsediments). Activities will assess the relativecontribution to contaminant problems from industrial andmunicipal point sources, from agricultural and urban runoff,and from selected combined sewer overflows. Contaminatedgroundwater and hazardous waste sites that should receivefurther study will be identified. In-place pollutants,i.e., those associated with sediments, may represent asource for downstream loadings, and their contribution tothe overall problems will be evaluated.

Estimates of loading of contaminants will be made as well asan identification of the nature (chemical and species) andlocation of the problem. As new problems are identifiedand better understanding is gained of the existingsituation, the information will be relayed to appropriateagencies for follow-up.

Habitat evaluations are needed to define both the problemsand the solutions for maintaining the UGLCC for the highestattainable use. Destruction of habitat results fromphysical alterations as well as toxic influences. To bridgebetween toxic contaminants and habitat evaluations, someactivities will identify and quantify ecosystem indicatorsand processes. These studies will assist in theinterpretation of how contaminants have affected habitat andwill also assist in the setting of priorities for subsequentremedial actions.

The modeling output will be a mass balance model forcontaminants that can be used as a management tool to assessthe effectiveness of implemented remedial actions.. Grossmass balance calculations for selected contaminants willalso be made for the St. Clair and Detroit Rivers todetermine if these areas act as a net source or sink for thecompounds.

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Intensive studies will be implemented on small segments ofthe UGLCC stystem, including mass balance determinations inthe Trenton Channel area of the Detroit River, biologicaleffects of in-place pollutants in the Detroit River, andhydrodynamic studies of the St. Clair and Detroit Rivers andof Lake St. Clair. The results of these special investiga-tions will contribute to a comprehensive understanding ofphysical, chemical and biological processes that should beincorporated into more general environmental models for theoverall study area.

July 19, 1985

C. CONCLUSION

1. Clean-up of Dow Chemical's perch loroethylene spill is currentlyunder the direct supervision by the Ontario Ministry ofEnvironment. Environment Canada is providing technical adviceand support as required. As a further precaution, the JointContingency Plan under the 1978 (Feat Lakes Water QualityAgreement was used to notify Canadian and U.S. agencies. MOEhas taken precautionary measures in safeguarding drinking watersupplies of downstream municipalities by distributing activated

carbon powder for use in the treatment process throughout theclean-up operation. Also MOE is undertaking intensive waterquality monitoring in river downstream from the site.Technical experts from Michigan Department of Natural Resourcesand U.S. Environmental Pollution Agency have been fullyconsulted and are on-site as observers prior to and during theclean-up operation.

2. Environment Canada is proceeding to carry out a short (6 week)intensive investigation to determine the extent and sources ofpollution to a 3km reach of the river directly downstream ofthe Canadian National Railroad tunnel in Sarnia. This studyconsists of three parts including a sediment survey,characterization of industrial effluents, and examination ofselected karst holes in the river bottom as possible sinks orsources of polluted material.

3. Upper Lakes Connecting Channel Study

A four party (Environment Canada, Environment Ontario, Michiganand U.S. EPA) study of the Detroit, St. Clair and St. Mary'sRivers is currently underway. This study began in 1984 as ajoint effort designed to define the sources and environmentaleffects of pollution to those interconnecting channels.Jurisdictions have undertaken this study as the basis forRemedial Action Plans to be developed to address these Areas ofConcern for submission to the International Joint Commission inthe continuing implementation of the 1978 Canada-U.S. GreatLakes Mater Quality Agreement. Also this study will capitalizeon activities previously mentioned in this report.

4 4-ESSO PETROLEUM CANADA APPENDIX I

Located in Sarnia, this petroleum refinery dischargesdirectly to the St. Clair River. The company has metministry Petroleum Refineries Effluent ConcentrationGuidelines.

In 1970, one Control Order was issued to the company forcontrolling hydrocarbons to the atmosphere, hydrocarbonwere successfully controlled. Esso modified its fuelcomposition to meet Ontario Regulation 151/81 for sulphurdioxide emissions to the atmosphere. Regulation 151/81 isa special regulation used in Chemical Valley for thestringent control of S02 levels.

Storm water from the Esso site contains phenolic compoundsand is a danger to aquatic life. Esso treats storm waterin an on-site industrial treatment plant (BIOX). Thecompany has never been prosecuted but has received twoviolation notices issued in 1984 for failure to operate itsBIOX in an environmentally acceptable fashion.

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PETROSAR LTD

Petrosar Ltd., a petroleum refinery located in Corunna,discharges effluent directly to the St. Clair River. Thedischarge quality meets the ministry Petroleum RefineryEffluent Concentration Guidelines except for phenols.

Phenols, which are toxic to aquatic life, continue to be aproblem and are due to BIOX plant upsets. The company ismaking improvements to the BIOX system. .

There have been no Control orders issued to Petrosar Ltd.but one was proposed concerning smoky flaring. The Orderwas dropped after the company proposed and installed a $6million abatement program.

The company has never been prosecuted and is in compliancewith Regulation 151/81 concerning sulphur dioxide inChemical Valley.

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ESSO CHEMICALS CAMADA LTD.

Located in Sarnia, Esso makes plastic resins and dischargesits effluent directly into the St. Clair River.

Esso's discharge meets ministry Industrial EffluentConcentration Guidelines and the company complies with thefederal Vinyl Chloride Emission Regulation. However, therehave been vinyl chloride emissions that have been reportedto the federal government.

A Control Order was issued in 1973/74 requiring treatmentof wastewater to control organics which are toxic to fish.The company has complied with the order. Esso has neverbeen charged by the ministry.

SHELL CANADA LTD.

Located in Corunna, the refinery discharges to TalfordCreek and then into the St. Clair River.

The company's discharge quality met the Ministry'sPetroleum Refinery Effluent Concentration Guidelines.

A Control Order was issued in 1971 to control hydrocarbonsto the air. The Order was met. A Program Approval wasissued in 1981 for the company to meet Ontario Regulation151/81 for the control of sulphur dioxide in the ChemicalValley area.

There have been no prosecutions against the company but aviolation notice was issued in 1985 for failing to complywith the conditions on the landfill Certificate of Approval.

-4f.

Located in Sarnia, the company makes synthetic rubber anddischarges effluent directly into the St. Clair River.

The discharge quality met all ministry requirements set outin a Requirement and Direction (R&D) issued in 1977. A $25million BIOX plant began operaton in 1983 and brought thecompany in compliance with the R&D. The 1979 St. ClairRiver Study identified high levels of benzene coming fromthe plant. Since the start up of the BIOX most benzene hasbeen removed before entering the St. Clair River.

Polysar was convicted in 1978 for a spill into the riverand was fined $5,000.

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FIBERGLAS CANADA INC.

Located in Sarnia, the company manufactures glass woolinsulation and discharges effluent into the Cole Drainwhich flows into the St. Clair River.

The company's phenol discharge exceeds the ministry'sguideline and the company has been fingered as the sourceof process water spills, which are currently underinvestigation.

The Ministry has received numerous air pollution complaintsabout this industry. A Program Approval was issued in 1973for air particulate. An investigation of the industry isunderway in anticipation of issuing another Control Orderfor parti.culate some time in 1985. The company has neverbeen prosecuted by the ministry.

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ETHYL CANADA INC.

Located in Corunna, the chemical manufacturer dischargeseffluent directly to the St. Clair River.

The company does not meet the ministry's new target forlead. Excessive levels of chlorinated volatile organicshave been identified in the final effluent and the companyhas been requested to find the source and to control thedischarge. A Control Order may be required to completethis remedial action.

There have been no prosecutions or orders issued on thecompany.

-V1-DUPONT CANADA INC.

Located in Corunna, this compnay manufactures plastic resinand discharges directly to the St. Clair River.

The company meets ministry Industrial EffluentConcentration Guidelines.

The company has never been prosecuted nor been placed underControl Orders but at one time experienced a noise problemthat has since been rectified.

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DOW CHEMICAL CANADA INC.

Located in Sarnia, the chemical manufacturer dischargeseffluent directly to the St. Clair River.

The company has identified occasional levels of benzene,styrene and ethyl benzene in its effluent and will requireadditional control to reduce these levels. The company iscurrently investigating appropriate controls.

Levels of hexachlorobutadiene and hexachlorobenzene in onesewer have resulted in levels in the river that exceedWorld Health Organization desirable concentration of 10parts per trillion. The company is investigating furthercontrols.

Controls were issued on the company in 1971 and 1972 foremissions to the atmosphere, including chlorine.

A condition was put on the company to monitor for traceorganic compounds and the company has an action level ofone part per million for total organic compounds.

The company has installed abatement equipment to meet thefederal Vinyl Chloride Regulation.

Dow controls landfill leachate by carbon treatment.

The company was charged with six counts under Ontario'senvironmental legislation in September, 1985 for a spill ofperchloroethylene into the St. Clair River in August, 19.85.

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CANADIAN INDUSTRIES LIMITED

Located in Courtright, this fertilizer producer dischargeseffluent directly into the St. Clair River.

The company discharge quality met the ministry's IndustrialEffluent Concentration Guidelines.

A phosphate plant is to be closed in 1986/87 eliminatingthe need for gypsum ponds which produce radiation andfluoride. The ponds will be treated and capped.

A control order for the control of fluoride to theatmosphere was issued in 1970. Vegetation studies indicateelevated but not excessive levels of fluoride off companyproperty. The company has never been prosecuted.

UNION CARBIDE CANADA LTD.

Located in Corunna, this manufacturer of plastic resinsputs its effluent discharge directly into the St. ClairRiver.

Its discharge quality meets the ministry IndustrialEffluent Concentration Guidelines. There have been noControl Orders or Prosecution of Union Carbide.

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SUNCOR SUNOCO GROUP

This petroleum refinery located in Sarnia puts effluentdirectly into the St. Clair River.

Its discharge quality meets the ministry's PetroleumRefinery Effluent Concentration Guidelines, but does notmeet the federal Guidelines for Petroleum Refineries.Instead of a Control order to correct this situation, a

condition on the Certificate of Approval for its $350million Hydrocracker Complex required the company to expandthe biological treatment plant to improve plant effluent byNovember, 1986.

A Control Order was issued to the company in 1971 for thecontrol of hydrocarbons. The company has never beenprosecuted but was issued a violation notice in 1985 forfailure to comply with a condition on the landfillCertificate of Approval.

The company is in compliance with Regulation 151/81 forsulphur dioxide emissions into Chemical Valley. All stormwater from the company's tank farm is directed to thecompany's treatment plant to remove phenols which are toxicto aquatic life.

I

CABOT CARBON

The company located in Sarnia produces carbon block anddischarges to the St. Clair River via the Cole Drain.

Storm water exceeded discharge criteria but the company hassince installed a treatment device and now meets ministrycriteria.

The company has a periodic particulate problem. MOE hasrequested the company to install monitoring equipmentdesigned to eliminate bag house failure which is the rootof the problem.

No Control Orders have been issued on the company and theyhave never been prosecuted.