Thursday, April 5, 2018

TOUGH SLEDDING READING THE NEW (2017) CREEK REPORT



I've been reading hydrogeological reports for twenty-seven years now, starting with a 1991 Varnicolor Chemical HydroG report written by Golder Associates. I still remember the comment written by hydrogeologist Wilf Ruland on the inside cover of that report after I complained to him of inconsistencies and illogical conclusions or statements. He wrote "Remember who was paying their (Golder) bills.".

Since that time besides likely literally hundreds of reports on Varnicolor, Uniroyal & followup companies, Safety-Kleen, Deilcraft, Sunar, C.G.T., Ciba-Geigy, Northstar Aerospace and many more, I've also read, dissected, questioned and debated with consultants on reports dealing with Hydrology or surface water. I've read and reread all the Canagagigue Creek Reports from 2012 through to this present one I'm working on. Ditto for the 1995-97 Jaagumagi & Bedard Ministry of Environment (M.O.E.) detailed study of the Canagagigue Creek. I've attended all the presentations by the M.O.E. over the years on the creek including one done by an old friend (now a Doctor as in PHd!) I met at Pat Potter's down in Dunnville decades ago. Hi Rachel!

So why is this current one giving me trouble? Why am I struggling with reading it and putting everything together? There may be a number of reasons. Firstly this report is far larger and more detailed than particularly the ones about the creek since 2012. There are far more samples taken plus a few more locations sampled albeit nowhere near enough. The Figures presented are not particularly user friendly and reading the location names on the coloured maps is not easy. Imagine trying to read those same Figures God help us if they were photocopies of coloured maps. Therefore thanks again for the hard copy even though it's difficult enough. The Tables are extensive with Table 3 being 14 pages long, Table 4 being 18 pages long, Table 5 being 62 pages long and Table 6 being 120 pages long. The next five Tables of soil and sediment results vary from a low of six pages to a high of 64 pages.

As is my usual practice I do NOT simply read either the Executive Summary alone or even the text on its' own. In fact the text in this Report is a quite skinny 23 pages only. Far too many reports by Uniroyal Chemical and its' successors' consultants and possibly some others have gilded the lily and cherry picked data from their own reports in order to come up with Conclusions that are far too rosy and gentle on their clients who are afterall paying for their reports. That in fact is the huge sham of allegedly professional consultants who would like both repeat business from their current clients as well as positive references given by them to other future clients. It is our governments who make the rules and pass the laws which grotesquely favour these incestuous and self-serving relationships. The key is self-serving relationships favouring polluters versus a system that should be favouring the public interest only.

Another part of the problem is reconciling the text with the hundreds of pages of Tables. It is very difficult when finally in hindsight you realize that the text strongly appears to be quoting repeatedly the wrong criteria known as Table 8 (M.O.E.) for DDT and its' metabolytes DDD and DDE. The criteria for soils are less stringent than the criteria for sediments in the bottom of the creek. This is likely due to the fact that there are lifeforms which not only reside in the sediments (benthic community) but also that are consumed on a daily basis by higher lifeforms such as fish, frogs, etc.. Therefore the soils criteria for example in Tables 3 & 5 in this Report are .05, .05 and .078 ppm. respectively for DDD, DDE and DDT. However for sediments the criteria in this Report (Tables 4 & 6 etc.) are more stringent namely .008, .005 and .007 ppm. respectively for DDD, DDE and DDT. Unfortunately on pages 17-20 in the text the values quoted as being for sediments are in fact the soil criteria of .05, .05 and .078. Again to further complicate reconciling the text to the Tables is the fact that our idiot Mayor relied upon the grossly biased word of Chemtura and the Ontario M.O.E. to remove myself, CPAC (Citizens Public Advisory Committee) and the general public from being able to question either Chemtura/Lanxess or their consultants GHD, the authors of this report at public RAC (Remediation Advisory Committee) and TAG (Technical Advisory Group) meetings in which Chemtura and GHD might be present. Well done politicians in successfully removing the very few (if only?) citizens who will read this report cover to cover from being able to confirm errors and flaws in the report. These errors may turn out to have some sort of explanation or not, we will never know for certain with the current "cringeworthy" (Pat Merlihan's word) process in place while at the same time the company, the M.O.E. and the politicians crow about their pretend public consultation.


5 comments:

  1. So my summary of this blog is kudos for a greater number of samples and more locations, and more tables, maps and figures and a shorter text that is backed up by the tables etc. And there is frustration that council and mayor have prevented all advisory committees from questioning the results in person with the consultants or the company that hired them to do this study. Am I reading this correctly? If I am what now can be done other then another study with further sample locations and river/creek and floodplain samples at more costs and to what conclusions and actions that may happen? I just can't wait to read this text.

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  2. Technically the appointed by Mayor appointees of TAG (some not all her curling buddies) can ask questions however usually Lanxess and GHD don't attend TAG meetings. RAC meetings usually have Lanxess present and TWO TAG members only can attend and ask questions. As stated in an earlier posting the data from this Report will be used to fuel an HHRA and or an ERA (Human Health Risk Assessment/Ecological Risk Assessment) which will highly subjectively determine where and how much soil and sediments will be removed.

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  3. So would an HHRA and or an ERA be paid for by Lanxess and if so who orders them to do so and who determines your last sentence?

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  4. Yes and the M.O.E. negotiates the specific terms of the HHRA/ERA with Lanxess as well as the amount of remediation. This is all done privately. Therefore the two guiltiest parties responsible for the disaster namely the polluter and his inept "regulator" jointly decide the cleanup without serious input from the locals who have suffered the consequences of their negligence.

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  5. I think because those two have the budget and know how and nobody else such as the public are offering to do it and pay for it. Sad but reality and I see it day in and day out in the Committees I am on.

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