Thor Chemicals Margate Remediation and Area Direct Abstraction licences

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Dear Environment Agency,

I believe you have replied to a previous FOI disclosing that a Remediation Process was set up at THOR CHEMICALS Margate for mercury and mixed solvents reaching ground water

(1) Can you provide estimates for the quantity remediated to date at THOR (such as the 470 tonnes of cyclohexanone remediated from the plume chalk layers below the site in the first 12 years of remediation at nearby Sericol)

(2) Can you detail the sites around the two remediation projects that had direct abstraction licences ? Such as the QEQM Hospital Margate (I don't know whether or not it has non-potable abstraction such as for laundry). Such as a laundry at Northwood Ramsgate and agricultural use such as at Pysons Road Ramsgate area.

(3) Given the WMD case connotations, leading to Iraq invasion, of "Red mercury" trade and the 1991 murder of Thor Director Alan Kidger in South Africa could you specify what mercury is or was subject of the remediation ?

(4) Was there liaison or a reporting relationship between EA involvement in remediation control and earlier Health and Safety Executive Action against Thor at Margate ?

(5) Downhill towards Margate from THOR there is a large waste drain. After the 1987 hurricane Thanet Council officers realised that many of the houses along the Ramsgate Road there had built extensions over this pipe on stadard footings and without Building Control clearance and sign off. At number 183 the extension does have deep footings, piers and reinforced oversite and building regs sign off. Under the driveway of 183 the drain branches right as far as I know and ends up feeding a large tank under the road at the junction of the main road to the QEQM Hospital.

Given especially the reasons to suspect the integrity of the drain above the branch point and towards THOR would you particularly answer about the integrity of measures taken to stop the site contamination at THOR pentrating the drainage system ?

(6) Could you detail the "Mixed solvents" subject of remediation and for each give the calculation result for the quantity remediated ?

Yours faithfully,

Richard Card

Enquiries, Unit, Environment Agency

5 Attachments

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Enquiries, Unit, Environment Agency

5 Attachments

Good Afternoon Richard,

 

Thank you for your further information request relating to Thor Chemicals
at Margate.

 

I have passed your enquiry to our customer team for the relevant area and
they will be in touch with you shortly.

 

The Freedom of Information Act and Environmental Information Regulations
state that a public authority must respond to requests for information
within 20 working days, but we aim to respond to all enquiries as quickly
as we can.

 

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Should you wish to contact the customer team directly, please use the
contact details below. Please quote your Enquiry Reference 140910/NE25 in
any correspondence with us regarding this matter.

 

Customers and Engagement
Environment Planning & Engagement
Environment Agency
Kent & South London Area
Orchard House
Endeavour Park
London Road
Addington
West Malling
ME19 5SH

 

03708 506 506

 

If you have any further queries, please do let us know and we will be
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show quoted sections

KSL Enquiries, Environment Agency

2 Attachments

Dear Richard,

RE: KSL 140912/HW56 Thor Chemicals Margate Remediation and Area Direct
Abstraction licences

 

Thank you for your enquiry which we received on 10 September 2014.

 

We respond to requests under the Freedom of Information Act 2000 and
Environmental Information Regulations 2004. Having consulted our technical
teams I am pleased to be able to answer your questions below and provide
some additional background information. Please also be aware there are 2
attachments to this email.

 

Background to Thor site

 

The Thor site operated as a production facility from 1973 to 2005. From
1973 to 1988 the site produced mercury based products. From 1988 to 2005
the plant manufactured isothiszolones (particularly OIT), which are an
active ingredient of fungicides. The site was granted an environmental
permit, number EPR-BV3898IR in 2003. Since 2005 no manufacturing has taken
place and the permit has been varied to deal with the groundwater
remediation processes.

 

When Thor applied for a permit in 2003, under the Environmental Permitting
Regulations, they were required to install boreholes and monitor
groundwater around the site to establish the baseline environmental
conditions. As soon as groundwater contamination was discovered further
investigations were undertaken to establish the type, depth, extent and
magnitude of contamination present on the site and extending off-site.

 

Contamination is present in the soils and made ground on the site. The
unsaturated zone of the Chalk (which is the drier section of the Chalk
aquifer between the ground surface and the groundwater table) is
contaminated with mercury and a mixture of solvents used in the
manufacture of mercury products and OIT. There are particular hot-spots
under the former production area, the former chemical and effluent tanks
and beneath drainage soakaways.

 

The groundwater in the Chalk aquifer also has a plume of solvents used in
the manufacturing processes, with benzene being the primary contaminant of
concern. The mercury contamination of the groundwater is localised and
only a small amount of mercury has reached the groundwater. The highest
concentrations of groundwater contamination by solvents are present under
the former manufacturing area. The concentrations of groundwater
contamination by solvents decrease with the extent of the plume as it
migrates off site. There appears to be no significant solvent
contamination present 180 metres down-hydraulic gradient of the site.

 

Assessments have shown that there are no specific receptors (such as
houses, drains, people etc) at risk from the groundwater contaminated with
solvents, or from any vapours that may come from the solvents, due to the
depth of the groundwater beneath the ground surface (greater than 20
metres).

 

Remediation required

 

We require the ground and the groundwater to be cleaned up beneath the
site so that there will be no on-going risk to the wider environment,
including the groundwater. The legislative drivers for this are the Water
Resources Act 1991, Part 2A of the Environmental Protection Act 1990,
Environmental Permitting Regulations 2010 and the National Planning Policy
Framework. In addition, clean-up of this site will help meet the
objectives of the Water Framework Directive and Groundwater Daughter
Directive for the local groundwater environment.

 

Thor has taken responsibility for the site contamination and has opted to
carry out voluntary remediation.  They provide regular progress updates to
the Environment Agency.

The remediation will take several years, probably decades, and will need
to be a phased operation.  The removal of the more mobile and volatile
component, the mixed solvents, has to come first prior to dealing with the
mercury contamination.

 

Thor is carrying out pump-and-treat to remove the solvents from the plume
of groundwater contamination. This helps prevent the movement of solvents
off-site. Their original permit was varied to allow this remediation
process to take place.

 

Trials showed that a technique called soil-vapour-extraction would help
increase the rate of removal of solvents from the unsaturated chalk, and
to help prevent the solvents reaching the groundwater. To date, Thor has
decided not to pursue this remediation option.

 

Thor has proposed to remove the concrete surfacing on the site. The
Environment Agency has requested that Thor do not carry this work out
until further work has been carried out on the solvent contamination in
the unsaturated zone.

 

At a later phase of the remediation Thor will provide proposals for
dealing with the deeper mercury contamination. Present monitoring shows
that mercury is not migrating off-site in the groundwater.

 

Specific questions and answers

 

Please find below answers to your specific questions.

 

(1) Can you provide estimates for the quantity remediated to date at THOR
(such as the 470 tonnes of cyclohexanone remediated from the plume chalk
layers below the site in the first 12 years of remediation at nearby
Sericol)

 

The quantity of material remediated, to date, at the Thor site includes:

 

·         23431 m^3 water treated through the pump and treat system,
resulting in the removal of approximately:

 

o   407 kg of benzene

o   48 kg of toluene

o   64 kg of 1,2,4-trimethyl benzene

o   119 kg of aromasol

o   61 kg of versatic acid

o   1.6 kg of texanol

o   0.8 kg of phenol

o   0.1 kg of total mercury

 

·         A small amount of volatile contamination was removed from a
single onsite remediation borehole during a trial of a soil vapour
extraction remediation technique. The trial was undertaken for two a week
period between July and August 2010.

 

The report from the trial suggested that this would be an effective
treatment of the unsaturated zone within the chalk rock beneath the site.
The technique would complement the ongoing groundwater treatment
remediation works. The company have not chosen to pursue this as a
remediation option at present.

 

·         A total of 145 m^3 of contaminated soils have been removed for
off-site disposal to an appropriately permitted site.

 

(2) Can you detail the sites around the two remediation projects that had
direct abstraction licences?  Such as the QEQM Hospital Margate (I don't
know whether or not it has non-potable abstraction such as for laundry). 
Such as a laundry at Northwood Ramsgate and agricultural use such as at
Pysons Road Ramsgate area.

 

The abstraction licences within 2 kilometres of the Thor site are included
in the table that is attached. It should be noted that, other than the
abstraction for the remediation on the site itself, all of the licensed
abstractions within 2 kilometres are up-hydraulic gradient of the site.
Given the types of contamination present and the flow regime this means
that there is no risk of the other abstractions being contaminated from
the contaminated groundwater beneath the Thor site.

 

Additionally, when the groundwater contamination was discovered at the
Thor site assessments were carried out to ascertain whether any other
abstractions were at risk and none were identified.

 

(3) Given the WMD case connotations, leading to Iraq invasion, of "Red
mercury" trade and the 1991 murder of Thor Director Alan Kidger in South
Africa could you specify what mercury is or was subject of the
remediation?

 

Thor chemicals produced mercury-based products including phenyl mercury
acetate, phenyl mercury salts and mercuric chloride from 1973 to 1988.

 

According to reports on soil investigations at the site, mercury is
considered to potentially be present in inorganic (mercuric-chloride),
organic (methyl-mercury) and elemental (Hg+) forms.

 

Estimates based on a limited number of soil samples sent for detailed
analysis suggested that around 99.5 % of the mercury is present in the
inorganic (non-volatile) form, with the remaining 0.5 % present as either
elemental or organic mercury (both volatile).

All potential forms of mercury are subject to present and future
remediation plans.

 

(4) Was there liaison or a reporting relationship between EA involvement
in remediation control and earlier Health and Safety Executive Action
against Thor at Margate?

 

No soil or groundwater remediation had commenced on the site at the time
of the Health and Safety Executive (HSE) review of Thor, in the early
1990s.

 

The Environment Agency formed from an amalgamation of the National Rivers
Authority (NRA), Her Majesty’s Inspectorate of Pollution (HMIP) and the
local Waste Regulation Authority (Kent County Council) in 1996.

 

At the time of the HSE review the lead authority and site inspectors for
Thor were based in HMIP.  They had responsibility for the regulation of
the processes on site. They predominantly dealt with air quality emissions
and effluent processes, and did not have awareness of the risks of soil
and groundwater pollution. The NRA’s remit included the protection of
groundwater, but they did not have awareness of the processes and
procedures adopted on the Thor site.

 

When the HSE carried out their assessments of the Thor site in the early
1990s they asked HMIP for information. The HMIP then asked the NRA who
provided their site files to HMIP to aid with the HSE investigation. The
information from both the HMIP and the NRA was sent to the HSE. At that
time the only information that the NRA held on contamination was some
limited soil monitoring from the verge outside the site.

 

The groundwater pollution only became apparent when the Thor site applied
for a permit under the Environmental Permitting Regulations, in 2003, and
were required to install boreholes and monitor groundwater around the site
to establish the baseline environmental conditions. As soon as
contamination was discovered further investigations were undertaken and
remediation commenced.

 

(5) Downhill towards Margate from THOR there is a large waste drain. 
After the 1987 hurricane Thanet Council officers realised that many of the
houses along the Ramsgate Road there had built extensions over this pipe
on standard footings and without Building Control clearance and sign off. 
At number 183 the extension does have deep footings, piers and reinforced
oversite and building regs sign off.  Under the driveway of 183 the drain
branches right as far as I know and ends up feeding a large tank under the
road at the junction of the main road to the QEQM Hospital.

 

Given especially the reasons to suspect the integrity of the drain above
the branch point and towards THOR would you particularly answer about the
integrity of measures taken to stop the site contamination at THOR
penetrating the drainage system?

 

The original site-drainage can be split in to two main groups for this
response, on-site drainage and off-site drainage.

 

On-site:

The on-site surface water and effluent drained to sealed tanks before
being treated and discharging off-site. The rainwater, from roof
down-pipes and from some areas of the site drainage, discharged to
soakaways to the ground.

 

The investigations, and the subsequent remediation, have recognised the
increased risk to groundwater from the use of soakaways to ground and so
have specifically targeted investigations in these areas. The groundwater
beneath the site was found to be a receptor and at risk from contamination
from the site. As soon as it was recognised that site drainage was
discharging to the ground procedures were put in place to prevent and
minimise this practice. Assessments have also been carried out to
ascertain the risk posed to any off-site buildings and services (e.g.
household drainage) from the contaminated groundwater. No unacceptable
risks to the receptors (houses, drains, people etc) were identified.

 

Off-site:

We expect that the large waste drain that you are referring to is the foul
sewer, operated by the local sewerage undertaker. The Thor site did
discharge treated effluent from the site to foul sewer. The discharge to
the foul sewer from the Thor site was controlled by a trade effluent
consent issued by Southern Water Services. We suggest that you contact
Southern Water Services if you require further information on this.
Likewise, the integrity of the foul sewer outside of the site boundary is
the responsibility of the local sewerage undertaker.

 

(6) Could you detail the "Mixed solvents" subject of remediation and for
each give the calculation result for the quantity remediated?

 

Please refer to our response to question 1.

 

I hope this information answers your questions. I have attached our
Standard Notice which explains how you can use this information. Please
contact us within 2 months if you would like us to review any of the
information you have sent or if you have any further queries.
Alternatively you may visit our area office, near West Malling, offices to
review the site files that are on public register by prior appointment.
Please contact us using the details below should you wish to arrange a
suitable time. For information, Thor are operating the remediation scheme
under permit number EPR-BV3898IR.

 

Best wishes,

 

James

 

James Bates
Customers and Engagement Team Leader

Kent and South London

 

T: 03708 506 506

E: [1]ksl[Environment Agency request email]

Tw: [2]www.twitter.com/envagencyse

W: [3]www.gov.uk/environment-agency

 

 

show quoted sections

Dear KSL Enquiries,

Thank you for your detailed and excellent reply.

Yours sincerely,

Richard Card

KSL Enquiries, Environment Agency

1 Attachment

[1]cid:953582011@23032011-1176

 

Dear Sir/Madam

 

Please accept this email as acknowledgement that we have received your
enquiry.

 

We respond to requests for recorded information that we hold under the
Freedom of Information Act 2000 (FOIA) and the associated Environmental
Information Regulations 2004 (EIR).

 

Please note we have up to 20 working days to provide a response but we
will respond more quickly where possible. If your request is chargeable
we will notify you of the cost and action your request once your payment
clears.

 

For more information about our charging scheme please visit our website.

[2]http://www.environment-agency.gov.uk/bus...

 

If you have any queries, please contact us and we will be happy to help.

 

Kind regards 

 

 

Kent and South London Customer and Engagement Team 

 

Direct dial 01732 223224

Direct email  [3]KSL[Environment Agency request email]

                                               

© Environment Agency 2014

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Dear KSL Enquiries,

I am writing directly by post re reports of mercury found by beachcombers at Margate. I will quote the FOI ref.

Yours sincerely,

Richard Card

KSL Enquiries, Environment Agency

1 Attachment

[1]cid:953582011@23032011-1176

 

Dear Sir/Madam

 

Please accept this email as acknowledgement that we have received your
enquiry.

 

We respond to requests for recorded information that we hold under the
Freedom of Information Act 2000 (FOIA) and the associated Environmental
Information Regulations 2004 (EIR).

 

Please note we have up to 20 working days to provide a response but we
will respond more quickly where possible. If your request is chargeable
we will notify you of the cost and action your request once your payment
clears.

 

For more information about our charging scheme please visit our website.

[2]http://www.environment-agency.gov.uk/bus...

 

If you have any queries, please contact us and we will be happy to help.

 

Kind regards 

 

 

Kent and South London Customer and Engagement Team 

 

Direct dial 01732 223224

Direct email  [3]KSL[Environment Agency request email]

                                               

© Environment Agency 2014

Information in this message may be confidential and may be legally privileged. If you have received this message by mistake, please notify the sender immediately, delete it and do not copy it to anyone else.

We have checked this email and its attachments for viruses. But you should still check any attachment before opening it.
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Dorothy Favell left an annotation ()

My interest is with regards to the new Thanet Local Plan and empty brownfield sites that could possibly be used for housing or further manufacturing/retail use. Can anyone please tell me how far the clean up of this site and the contamination has got please. If not completed, can anyone estimate how much longer this will take?