Saturday, June 28, 2014

LAST THURSDAY'S CPAC MEETING



Jaimie Connelly, senior M.O.E. hydrogeologist, referred to his May 2, 2008 DNAPL letter as a technical review of the status of the Investigation to date. By this point in time eight of the ten private meetings had been completed as well as the bulk of the written reports. I wonder if both Jaimie's letter as well as Wilf Ruland's were more along the line of Minority Reports. Both of them parted ways severely with Conestoga Rovers on a number of huge DNAPL issues. While Jaimie was forthcoming, albeit technical and carefully worded, it was strange as to how early he departed. Thus after he was gone Jeff Merriman of Chemtura had free rein to claim there was a concensus on the DNAPL Technical Committee. George Karlos (M.O.E.) alleged that Jaimie had a very bad back and thus we were to assume that was why he left early. If these parties had a history of honesty It would be easier to buy that scenario.

George K. responded to further inquiries regarding the cleanup criteria that will be required in 2028. Once again the M.O.E. don't have an answer although George claims that they are working on it.

We were advised that the *Responsible Care verification is set for March 2015 and thus to date no decisions have been made as to who will represent Elmira citizens. Clearly there are only one or two CPAC members out of seven that Chemtura would care for but it should be CPAC as a whole who choose. I expect that Chemtura again this time will use all manipulative means to stock the team with their fellow travellors.

Financial assurance was again raised with me suggesting that the M.O.E. required it from Varnicolor Chemical so why not Chemtura. Chair Dr. Dan also advised that Woolwich Bio-En provided one as well so why not Chemtura. Ron Campbell indicated that as the taxpayers were paying 50% of the off-site cleanup on an ongoing basis we had a legitimate basis to want our investment protected by a Financial Assurance from Chemtura.

Jaimie answered many questions regarding his DNAPL letter including ones related to source removal rather than hydraulic containment. Jaimie emphasized that the latter was good for short and medium term stopping the spread of dissolved contaminants but that it does not deal with long term threats or with Dense Non Aqueous Phase Liquids. Regarding the shallow aquifer containment, he referred to it as imperfect. Jaimie had little or no answer to my question why the shallow DNAPL beneath RPW5, 6 & 7 could not be removed. Interestingly Jaimie indicated that there was no stopping date for on-site hydraulic containment as long as DNAPL source material remained there.

Graham Chevreau inquired as to whether the Bedrock Aquifer was contained. Jaimie indicated that it was not on site but that it was off-site at wells W4, W5A and E7.

Mark Bauman asked questions around In Situ Chemical Oxidation. Jaimie advised that the big problem with ISCO was the delivery to the appropriate areas. I advised that Chemtura do a test run on site in areas of higher contamination. Ron Campbell suggested that if it worked off-site then try it on site. It would be "a great opportunity" he said. Jeff Merriman actually agreed that Chemtura would seriously consider it. That and a cup of coffee might give you a decent cup of coffee on a good day.

Jaimie commented that on-site cleanup at Chemtura will never happen in our lifetimes. He also oddly suggested to me that the June 21, 2000 Amending Order relieved Chemtura of the higher standards/criteria demanded in the November 1991 Control Order. I knew it did this regarding 100% containment in all aquifers provision but Jaimie seemed to be suggesting that it also took away the requirement for removal of DNAPL as a contaminant source. I've reread the 2000 Amending order and i don't see that.

Both Susanna and Mark Bauman took strangely strong positions in favour of agreeing to only two additional soil sample points. George (M.O.E.) wanted this agreement from CPAC and those two were clearly agreeable. Fortunately Graham, Ron and I discussed "representative" sampling as well as two sample points only in such a large area being hit or miss. Ron even suggested "Do it right or don't do it at all. ". While it was suggested that "a tidal wave" would be required to send water and solvents through Chemtura's wetland onto the neighbours property (east); interestingly we were given a somewhat similar scenario. Jeff M. described a scenario whereby on a regular basis (annually?) gates in the retention pits were opened and they were drained en mass allegdly towards furrows directing them southwards towards GP1 & 2.

Ron Campbell worked hard to convince George to do the right thing despite Susanna and Mark's attempts to undermine. Ron suggested that two sample points weren't enough, weren't adequate and definitely was not normal sampling procedure. George mostly talked in circles trying to avoid both Ron's and my points. Finally Ron said "Come on George there's lots of evidence to support an Order" to do the work off site. George kept making excuses as to why the M.O.E. couldn't take samples on the neighbour's property as well as why they were only going to take two samples near the property line. George's excuses were exactly that. They and Chemtura are covering up yet again.

I also advised that as Chemtura's contaminants had been found one mile away in the south wellfield as well as five miles away at the mouth of the Canagagigue Creek at the Grand River; then who was he fooling that they hadn't moved a few feet across an imaginary property border. Graham stated that the sample points had to be necessary, reasonable and protective of the environment and that so far they were not. He also stated that "representative" sampling had a formal process. There is a methodology involved to determine how many samoples are representative and that George was ignoring that standard operating practice.

CPAC as a whole, less Mark & Susanna, were not impressed with either Chemtura or the M.O.E.'s excuses, delays and obfuscations. They are unable to give intelligent, reasonable answers to important questions. Quite frankly in hindsight Chemtura and the M.O.E. have also lied again regarding pretending that they don't have evidence that these eastern pits, especially RPE 4 & 5 have not discharged either directly onto the neighbouring property or southwards into the wetland and from there overland ionto the neighbour's property.

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