CPAC MON. AUG. 30/10

August 17, 2010

Delegation of Al Marshall to the Public CPAC Meeting of August 30, 2010


Pat McLean has often responded to criticism of CPAC’s lack of action and or aggressiveness by stating that the Chemtura Public Advisory Committee are an ADVISORY committee only, no more and no less. I will respond to that comment shortly.
Since 1991 Uniroyal (Chemtura) have been ostensibly directed in the environmental cleanup of their site by a number of M.O.E. Control Orders, including the 1991 one. It stated that DNAPL (dense non aqueous phase liquid) shall be removed as a contaminant source. At the same time this Control Order also stated that there was to be hydraulic containment in all aquifers. Well we know how that turned out. It was never achieved and it wasn’t even attempted. Then literally years later CPAC was advised via my Appeal of a Certificate of Approval, that the 1991 Control Order had been amended to permit off site flow of contaminated groundwater.
To this day CPAC have NOT publicly responded to this outrage. Similarily they have not publicly discussed, clarified or explained a meeting at the University of Waterloo in January 2007 to discuss remediation of DNAPL at Chemtura. Finally CPAC’s silence has been overwhelming in regards to my revelation that Conestoga Rovers, Chemtura and the Ontario M.O.E. have known for twelve years that there is free phase DNAPL outside of the Chemtura site, smack dab in the middle of the Elmira Aquifer .
CPAC stands for Chemtura PUBLIC Advisory Committee. It does not stand for Chemtura PRIVATE Advisory Committee.
The 1991 Control Order expressly named the former operating ponds in the south- west corner of Uniroyal as the source of DNAPLS. These ponds are identified as RPW5, RPW6, RPW7, and RPW8. CRA, the consultants to Uniroyal tacitly did the same with their claim in 1994 that hydraulic containment of the south-west would stop 97.5 % of the discharge of contaminants to Canagagigue Creek.

Currently there is a contaminated site in Cambridge undergoing remediation. Although there is some pump and treat hydraulic containment involved, it is for the original and primary purpose of hydraulic containment, to wit short term stopping of the spread of groundwater pollution. In Cambridge source removal/ destruction is underway. The type of Source Zone Remediation being used in the Bishop St. community is known as ISCO, or in situ chemical oxidation. It was but one of many technologies which were examined for the purpose of removing free phase DNAPL (trichloroethylene) from the subsurface, both shallow and deep.
Speaking of source zone remediation , this is exactly what Pat, Susan , Wilf and I were advised 3 ½ years ago at the University of Waterloo. Source zone remediation of DNAPLs can and should be undertaken in order to remove or destroy as much as possible. This is the message that I’ve brought back to CPAC and the public and to date Pat, Susan and Wilf have refused to PUBLICLY comment. In private I have no idea what their story is . I do know that the disgraceful private technical meetings of the DNAPL sub committee are an outrage, and twenty years ago APT Environment would not tolerate private technical meetings concerning Uniroyal Chemical. Oh how things have changed!
Furthermore there are numerous studies online describing the limitations and advantages of source zone remediation. One of them is “Assessing the Feasibility of DNAPL Source Zone Remediation: Review of Case Studies “ . This study by GeoSyntec Consultants from Guelph Ontario looks at over 100 contaminated sites in the U.S. and concludes that with proper examination of the remedial alternatives, that over 80% of the mass of DNAPL can be removed from the subsurface.

The Elmira wellfields were shut down twenty-one years ago. Without source removal, both on and offsite they will never be restored to drinking standards. This alleged restoration by 2028 is the big lie promulgated by politicians and the Ministry of the Environment. This lie appears to also be embraced by CPAC. It is my opinion that CPAC have made good strides in lessening air pollution in Elmira. It is also my opinion that CPAC have turned their backs on their own July 2003 Request for Action report , which asked for source removal of specific areas. At the very least, CPAC are years overdue to PUBLICLY advise the citizens of Elmira as to where CPAC now stands in regards to Source Removal, DNAPLS and whether or not the Elmira Aquifer will ever be restored. That is my response to Chair, Pat McLean in regards to CPAC being an advisory committee. Start advising.

Alan Marshall Elmira Environmental Hazards Team