CORRECTION REGARDING STROH DRAIN, DITCH & BERM

Following is copy of an e-mail sent earlier this morning to Tiffany Svensson, (TAG Chair), Joe Kelly (member), Sebastian Seibel-Achenbach (CPAC & TAG member) and Lisa Schaefer (Support Co-ordinator for RAC/TAG - Woolwich Township employee)




Tiffany & Joe: I have been rereading old but very relevant reports describing the overland flow of liquid wastes from the east side pits. Two of the sources are the 1985 "A History of Uniroyal Waste Management at Elmira" by W. Jackman, J. Ralston,and A. Smith. The first two gentlemen are from the Ontario MOE and the last is from the GRCA. The second report is the August 1991 "Environmental Audit" produced by Conestoga Rovers (CRA) under order from the MOE and on behalf of Uniroyal Chemical.

The 1985 report states on page 4 : "By 1948, seepage from the ponds was being collected in open ditches and drained to a gravel pit (GP on Fig. 1)."
"The 2,4-D wastewater continued to be pumped to the ponds until 1965 when the municipal waste treatment plant..."

And on page 6 : "Any wash water from the 2,4,5-T process entered the same waste streams as the 2,45-D process."

The August 1991 Environmental Audit on Page 37 states that liquid wastes leaked out the bottom of RPE-1 because it was built on a sand lens and caused "vegetative stress" on both crops on the east side and vegetation on the west side. as far away as the Canagagigue Creek.

However as per page 38, pits RPE-2, 3.4 were built on top of clay and hence there was much less and much slower leakage through the bottom. The obvious fact was that ongoing and daily pumping of liquid wastes into these pits resulted in significant overflows of wastewater versus CRA's claim of "intermittent" flow.

Page 39 states: "Intermittent overflow from the pits was collected in open ditches and drained to a gravel pit on the south-east portion of the property." Furthermore "This seepage toward the gravel pit continued until approximately 1965, when the Elmira STP began to receive wastes from Uniroyal." And on the same page "...the east pits continued to be used to equalize the loadings to the Elmira STP."

Page 43 states: "Seepage and overflow from the pits RPE-1 to RPE-5 was directed by drainage ditches into gravel pits located in the south-east portion of the site. This practice began in the early 1940s until approximately 1970 when the east side ponds were closed and /or lined. Liquids would pond in the gravel pits and eventually seep down into the subsurface soils. Liquid waste water was continuously standing in the gravel pits until the east side pits were closed. When seepage from these pits subsided in the early 1970s, the gravel pits dried up."

Prior to my commenting/criticizing CRA's obvious conflict of interest (i.e. client driven and paid for reports) and choice of language (
"seepage", "intermittent") to minimize the extent of pollution and cost of cleanup to their client (Uniroyal Chemical) I wish to ask Lisa Schaefer to please send this e-mail report to all of TAG at a minimum. Thank you Lisa. Secondly I wish to advise that Woolwich Township should have both these reports, and much more, in their archives. If not then either the MOE/MECP or Lanxess should be able to provide them to Lisa, Tiffany and all TAG members. As a last resort I am the proud owner of a complete set of Uniroyal to Lanxess reports (approx. 1980 - 2019) and I would either e-mail you entire pages as Attachments or possibly bring in the reports for you to examine with myself present.

Point One: Note in the above quotes how many times seepage and overflows were directed into a gravel pit (SINGULAR!) versus gravel pits plural. That is because they were directed towards a gravel pit (GP-1) only, however GP-1 was not in the current location where CRA conveniently moved it to on their maps over the last three decades. I have the maps showing its relocation from its original location on the north-east side of the diagonal ridge of high ground that a number of us walked on top of on April 11, 2019 during our site tour.

Point Two: We are supposed to believe that "seepage" or "intermittent overflow" of the east side pits resulted in surface drainage in open ditches (versus say in an enclosed pipe) over a distance of 300 metres from RPE-5 and closer to 750 metres from RPE-2 which is much further north. That is ridiculous nonsense. Only very large volumes of liquids waste waters would flow that distance without being entirely absorbed into the soil along the way. Furthermore CRA have stated that these waste water flows resulted in "continuously standing" liquids in the gravel pits.

Point Three: From 1946 until very close to 1970, the east side pits were the recipients of the vast bulk of process waste waters and liquid wastes generated by Uniroyal and successors production processes on the west side of the creek. From 1942 until 1946 liquid wastes were simply put directly into Shirt Factory Creek (SFC) and from there the Canagagigue or directly allowed to run off the river flats into the Canagagigue Creek. From 1946 until 1970 they were pumped via two pipelines across the creek and over to the east side pits. The waste waters averaged around 165,000 Imperial Gallons Per Day (IGPD) with lows of 140,000 gallons and highs of 240,000 IGPD. These daily volumes could not possibly be absorbed by the soil and indeed they were not. They flowed southwards and eastwards following the ground surface elevation contours until they ended in a large depression on the Stroh property to the immediate east of the Stroh Drain, Ditch & Berm. Yes these liquid wastes were not in a pipe and certainly spread out with some going west towards the creek on Uniroyal's property and some going into the currently known GP-1 location. Most however went over to the Stroh property. Ground surface elevation contours do not lie. My large map has these contours now for the entire east side and these contours are sourced from the MOE/MECP, GRCA, CRA, MTE and others and are consistent with each other.

Joe, in regards to the small pond just south of RPE-5 your observation was worthy however that depression is the result of contaminated soil being excavated and put into RPE-5 in 1969 essentially after the east side pits were out of service. This information is also in the Environmental Audit.

Sincerely Alan Marshall CPAC & EH-Team member P.S. TAG & CPAC member Sebastian Seibel- Achenbach has more current and extensive knowledge of these matters than TAG hence his position being closer to mine than to some TAG members.