APPENDIX XIII: Transportation Threats

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1 APPENDIX XIII: Transportation Threats

2 ESSEX REGION SOURCE PROTECTION AREA - ASSESSMENT REPORT APPENDIX XIII - TRANSPORTATION THREATS The Clean Water Act provides for the addition of local (non-prescribed) drinking water threats, associated with the transportation of specified substances along transportation corridors such as roads, railways, and waterways. As per the letter dated August 09, 2011, from Ian Smith, Director, Source Protection Branch of the Ministry of the Environment, the transportation of fuels, organic solvents, pesticides/herbicides, fertilizers, and dense non-aqueous phase liquids (DNAPLs) have been approved as local threats for the Essex Region Source Protection Area. The letter from Stan Taylor, dated June 06, 2011, in this Appendix, describes the rationale for the addition of transportation threats. The letter from Ian Smith, also in this Appendix, describes the circumstances, such as the quantities of the substances being transported, resulting in low, moderate, or significant threats in various vulnerable areas. In addition, the Event Based Approach described in Section of the Assessment Report, included the modeling of spills of large volumes of fuel, at various locations, as an evaluation of fuel as a potential significant threat in the event based areas of the water treatment plants with intakes in Lake St. Clair, the Detroit River and Lake Erie. The volumes of fuel which would result in significant threats in various vulnerable areas are summarized below:

3 Water Treatment Plant(s) Significant Threats Above Grade Handling and Storage; or Transportation of Liquid Fuel Containing 2% Benzene Lakeshore and Stoney Point 15,000 L EBA A.H. Weeks (Windsor) 15,000 L EBA(upstream of intakes) 3,000,000 L EBA(downstream of intakes) Amherstburg 15,000,000 EBA(upstream of the intake, from the intake to vicinity of Turkey Creek, including Turkey Creek watershed) 3,000,000 L EBA (upstream of the intake, from vicinity of Turkey Creek to Upper Detroit River) 15,000,000 L EBA (downstream of the intake) Harrow-Colchester South 15,000 L EBA Union 15,000 L EBA (Cedar/Wigle/Mill Creeks, Leamington Area Drainage) 34,000 L EBA (Sturgeon Creek) Pelee Island West Shore 15,000 L EBA Wheatley 15,000 L EBA

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17 360 Fairview Avenue West, Essex, Ontario, Canada N8M 1Y6 phone: (519) fax: (519) June 6, 2011 Ian Smith Director, Source Protection Programs Branch Ontario Ministry of the Environment 2 St Clair Ave W - 8th Floor Toronto, ON M4V 1L5 Dear Mr. Smith, Re: Request to add the Transportation of Substances along Transportation Corridors as Other or Non-Prescribed Drinking Water Quality Threats This letter is in support of our request to add the transportation of substances, along transportation corridors in the Essex Region Source Protection Area, to other or non-prescribed drinking water quality threats. The transportation of substances along corridors is currently not a prescribed drinking water quality threat. The Essex Region Source Protection Committee (SPC) has expressed concerns about transportation corridor threats. This was one of the reasons why it was important to the SPC to delineate IPZ-3s for Lake St. Clair intakes, and the Detroit River intakes, as there are many high intensity transportation corridors outside of the IPZ-2s, and also within the IPZ-2s. The SPC also requests the addition of the transportation of substances along transportation corridors as local or other threats, to support the events based work that was undertaken for threats analysis and IPZ-3 delineation for the Detroit River and Lake St. Clair intakes within the Essex Region Source Protection Area (SPA). This work, involving the modeling of fuel spills from tanker trucks at various locations throughout our Region, is now included in the Updated/Amended Proposed Assessment Report. The value and importance of this work has been greatly appreciated by municipal councillors and the public, as expressed at several recent municipal council meetings and public open houses. / 2

18 June 6, 2011 I. Smith Page 2 Numerous provincial highways, county and local roads, railways, navigation channels and ferries pass through the various vulnerable areas in the Essex Region SPA. The parameters or substances of interest each appear on the list of prescribed drinking water threats. However, the eligible circumstances in the Tables of Drinking Water Threats (MOE, 2009) relate only to their storage and handling. In the event that these substances were spilled while being transported along corridors within the vulnerable areas, they may also pose a risk to the quality of municipal drinking water sources. In fact, events based modeling work conducted in the Essex Region SPA has already shown that tanker truck fuel spills at various locations would reach the drinking water intakes in Lake St. Clair, the Detroit River, and Lake Erie, with concentrations of benzene affecting the use of the source water for various municipal drinking water systems. To assist the Ministry with its consideration of our request as per Technical Rule 119, and the five hazard rating factors listed by Technical Rule 120, we offer the following additional information: The toxicity and environmental fate of the substances of interest are given in Table 1. Information presented is as according to the Ministry s October 2006 Draft Guidance Modules, Where relevant information was not available, additional data sources were sought (referenced in table). Quantities and methods of potential release of the substances of interest that are typically carried along the corridors are indicated in Table 2. The maximum quantity of a substance transported along corridors is dictated by the carrying capacity of the vehicles or vessels traveling along them. The larger the quantity transported, the greater the risk to drinking water sources in the event of a spill or other mishap. With respect to the transportation of substances along corridors, the method of release would be through a spill. Spills may occur as a result of a traffic accident along highways and roads, derailments along railways, or groundings, collisions, and other mishaps in navigation channels. Mechanical failures may also result in spills along each of these corridors. / 3

19 June 6, 2011 I. Smith Page 3 Historical spill records from information available are indicated in Table 3. Industrial and ship spills along the Detroit River and St. Clair River corridors are provided. From an MOE publication Industrial Spills in Ontario (May 2005), spills occurred in 2003 and 2004 from MISA facilities (inorganic chemicals and metal sectors) in the Essex Region SPA. This information is indicative of the high susceptibility of drinking water sources in this area to spills. Spills such as these could have an effect on the quality of the drinking water sources. The types of vulnerable areas that are or would be affected by transportation corridors in the Essex Region SPA are listed in Table 4. The vulnerable areas are related to surface water sources (Intake Protection Zones) and groundwater areas (Highly Vulnerable Aquifers, and Significant Groundwater Recharge Areas). The vulnerability scoring for the vulnerable areas is provided in Table 5. As mentioned earlier, through the events based approach, it was found that fuel spills from tanker trucks result in the identification of significant drinking water threats in vulnerable areas in the Essex Region SPA. Should the need arise in the future, the SPC would request the addition of the transportation of other substances also, as other threats. Thank you for your consideration of our request. If you have any questions about our request, please contact me at (519) ext. 354 or via at staylor@erca.org. Sincerely, Stan Taylor, P.Eng Source Water Protection Program Manager / 4

20 June 6, 2011 I. Smith Page 4 Enclosures: 1. Table 1. Toxicity Scores and Environmental Fate of substances requested to be added as nonprescribed drinking water threats along corridors 2. Table 2. Potential quantity of contaminant carried through various transportation mechanisms 3. Table 3. Transportation-related spills in the Detroit River and St. Clair River from 2002 to Table 4. Transportation Corridors and Vulnerable Areas in the Essex Region SPA 5. Table 5. Vulnerability Scores for Vulnerable Areas in the Essex Region SPA C Teresa McLellan, Liaison Officer, Source Protection Implementation, Source Protection Programs Branch, Ministry of the Environment

21 Table 1. Toxicity Scores and Environmental Fate of substances requested to be added as non-prescribed drinking water threats along corridors (Unless otherwise indicated, information is from MOE October 2006 Draft Guidance Modules) Toxicity Environmental Fate Substance Score SW (lakes) SW (rivers) GW (dis) Organic Solvents Carbon Tetrachloride Chloroform Methylene Chloride (dichloromethane) Pentachlorophenol DNAPLs Dioxane-1, Polycyclic Aromatic Hydrocarbons Tetrachloroethylene Trichloroethylene Vinyl Chloride Fuels Petroleum hydrocarbons (C6-10) Petroleum hydrocarbons (C>10-16) Petroleum hydrocarbons (C>16-34) Petroleum hydrocarbons (C>34-50) Benzene Toluene Ethylbenzene Xylene Pesticides Atrazine Diacamba D-2,4 (Dichlorophenoxyacetic Acid) Dichloropropene-1, Glyphosphate MCPA MCPB Mecoprop Slightly toxic 1 Not available Not available Potential 2 Metalaxyl Moderately toxic 2 Not available Not available Potential 2 Metachlor Pendimethalin Slightly toxic Not Not 2 available available 1. USEPA 2. Not available

22 Table 1 CONTINUED. Toxicity Scores and Environmental Fate of substances requested to be added as non-prescribed drinking water threats along corridors (Unless otherwise indicated, information is from MOE October 2006 Draft Guidance Modules) Substance Toxicity Score Environmental Fate SW (lakes) SW (rivers) GW (dissolved) Commercial Fertilizers Nitrogen* Phosphorus Not available Not available Not available Not available *Toxicity Score and Environmental Fate Values are for Nitrate

23 Table 2. Potential quantity of contaminant carried through various transportation mechanisms. Transportation Corridor Roads and Highways Transport Mechanism Substance Transported Potential volume transported Passenger vehicles Fuel in fuel tanks liters Tractor trailers liters (in two tanks) Busses Up to 850 liters Tank Truck Fuel, DNAPL, Pesticides, 11,000 34,000 litres 1 Organic Solvents Dry Bulk Truck Dry powder pesticides 11,000 34,000 litres 1 Box Trucks Packaged goods, drums and barrels of product (e.g. pesticides, organic solvents, DNAPL, Fuels) Tractor-trailers Packaged goods, drums and barrels of product Railways Tank cars Petrochemicals, pesticides, organic solvents, DNAPLs Navigation Channel Ferries As cargo: Fuels, DNAPLs, Pesticides, Organic solvents kg 3 Up to ~20,000 kg Engine: Fuels, DNAPLs Private boats Fuels, DNAPL litres 4 Tankers As cargo: Fuels, DNAPL, Organic solvents, Pesticides Engine: Fuels, DNAPLs 37,000 liters (food service) 2 87,064 liters (dangerous goods) 2 114,000 liters (natural gas, LPG) 2 (see vehicle capacity above) As fuel (quantity unknown) < 78,850 tonnes in the Great Lakes 5 Volume not determined Cruise lines Fuels Volume not determined

24 Table 3. Transportation-related spills in the Detroit River and St. Clair River from 2002 to 2005 Substance Spilled Quantity Spilled Location of spill (State/Province, Facility, River) Chlorine 7.6 m 3 MI: Detroit Edison, Detroit River (2,000 gallons) Lubricating oil and diesel fuel 378 to 965 m 3 (100,000 to 255,000 MI: Mystery spill, Rouge/Detroit River gallons) Asphalt 227 m 3 MI: Midwest Supply, Detroit River (60,000 gallons) Lubricating oil 1 m 3 MI: Detroit Edison, Detroit River (270 gallons) Clarified oil 1.5 m 3 (396 gallons) MI: National Steel Corp., Detroit River Oil 0.3 m 3 MI: Praxair, Detroit River (75 gallons) No. 2-D fuel oil 0.3 m 3 MI: Vessel, Detroit River (75 gallons) Lubricating oil 0.6 m 3 MI: Praxair, Detroit River (157 gallons) Oil-like substance 0.34 m 3 MI: Vessel, Detroit River (90 gallons) Primarily non-petroleum Contaminated substances Not known MI: Mystery spill, Rouge/Detroit River Coal tar 0.38 m 3 MI: U.S. Steel, Detroit River (100 gallons) Oil-like substance 0.23 m 3 MI: U.S. Steel, Detroit River (60 gallons) Oil-like substance 7.6 m 3 (2000 gallons) MI: Mystery spill, Rouge/Detroit River Oil-like substance 45 m 3 (12,000 gallons) MI: Mystery spill, Rouge/Detroit River Diesel oil 2 m 3 MI: Cargill Salt, St. Clair River (550 gallons) Benzene Not known ON: Imperial Oil, St. Clair River Ethylene dichloride Not known ON: Dow dredging, St. Clair River Vinyl chloride 132 kg ON: Royal Polymer, St. Clair River Toluene Not known ON: Sunoco Refinery, St. Clair River Cooling water with methyl ethyl ketone and methyl isobutyl ketone 170 m 3 (45,000 gallons) ON: Imperial Oil, St. Clair River

25 Substance Spilled Quantity Spilled Caustic (high ph) 12.6 m 3 wastewater (3,330 gallons) Hydrocarbon with Not known toluene Crude oil 0.2 m 3 (50 gallons) Oil 1.1 m 3 (300 gallons) Oily bilge water 0.24 m 3 (62.5 gallons) Location of spill (State/Province, Facility, River) ON: Lambton Generating Station, St. Clair River ON: Sunoco, St. Clair River MI: Detroit Edison, St. Clair River ON: Imperial Oil, St. Clair River ON: Shell Oil, St. Clair River, The American Spirit owned by the American Steamship Company (Source of Information: Report on Spills in the Great Lakes Basin, International Joint Commission, July 2006)

26 Table 4. Transportation Corridors and Vulnerable Areas in the Essex Region SPA Vulnerable Area Provincial Highways County, City and Local roads Railways Ships Ferries Pleasure Craft IPZ-1 yes yes yes yes IPZ-2 yes yes yes yes yes yes IPZ-3* yes yes yes yes yes yes HVA yes yes SGRA yes yes *The IPZ-3s for Lake Erie intakes are yet to be delineated but would include some of the transportation corridors indicated above Table 5. Vulnerability Scores for Vulnerable Areas in the Essex Region SPA Surface Water Intake or Groundwater Area Vulnerability Score IPZ-1 IPZ-2 IPZ-3a IPZ-3b IPZ-3c Groundwater Area Stoney Point NA Lakeshore NA (Belle River) A. H. Weeks (Windsor) NA* NA* NA* NA East Intake A. H. Weeks (Windsor) NA* NA* NA* NA West Intake Amherstburg NA* NA* NA* NA Harrow-Colchester NA* NA* NA* NA Union Primary Intake NA* NA* NA* NA Union Emergency NA* NA* NA* NA Intake Pelee Island NA* NA* NA* NA Wheatley** Primary NA* NA* NA* NA Intake Wheatley** Emergency NA* NA* NA* NA Intake Highly Vulnerable NA NA NA NA NA 6 Aquifers Significant Groundwater Recharge Areas NA NA NA NA NA 2, 4, 6 *IPZ-3s are delineated for the Detroit River and Lake St. Clair intakes (and are yet to be delineated for Lake Erie intakes) but the IPZ-3s are assigned scores only for the Lake St. Clair intakes, as per the Technical Rules **Not in the Essex Region Source Protection Area, but IPZs extend into Essex Region

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