HAPPY THANKSGIVING: UNHAPPY MOE/MECP HYDROGEOLOGIST

I am referring to Ministry hydrogeologist, Cynthia Doughty in the title above. Perhaps"unhappy" is a little inaccurate. She is however strongly criticizing two Lanxess Canada documents both issued in February 2018 (YES 18!!!!) and obviously written earlier.

Ms. Doughty begins by advising that the second document dealing with potential Enhanced Technologies for the Lanxess site in Elmira, Ontario is unsigned and with no company name (consultants?) provided. She is clearly unimpressed with that. The first document that she is commenting on is a Clean-Up Framework for the Off-Site Municipal Aquifer. That document "...refers to section numbers; however, there are no section numbers in the document." Again it is my interpretation that she is unimpressed with that kind of amateur hour (my words) effort.

I have a little (ha!) beef of my own. Having read both the titles of these more than a year and half old crucial documents to the ongoing and constantly behind schedule "cleanup" of the off-site aquifers and having carefully read Ms. Doughty's comments/criticisms, it is my belief that I have never received those two documents. Well if so that's yet one more indictment of what passes for public consultation these days in Elmira, Ontario. I have sent a polite e-mail to the TAG/RAC Support person (Lisa) asking her to send me (belatedly?) those documents.

Ms. Doughty is also clearly unimpressed with the details or lack thereof in these two documents. Her words include (Pg. 2)"Additional details would be necessary...", "Additional information should be provided.", (pg. 3) "Additional explanation is required...", "There is insufficient information provided...", (pg. 4) "Additional details are required...".

We are advised that Lanxess and their consultants GHD are considering additional extraction wells, injection wells, and directed groundwater recirculation, whatever that might be. Ms. Doughty also would like more details and timelines for this potential new remediation method. There is also a Flowchart provided in the first document that indicates that in-situ technologies are back on the burner to be considered. Truly amazing. Both myself in 2009 and Dr. Richard Jackson in 2016 tried to get Chemtura/CRA to take this methodology seriously.

These two reports as well as Ms. Doughty make references to the actual criteria to determine when the aquifers have achieved cleanup. The old CPAC (2011-2015) and particularly Sebastian Seibel-Achenbach and Dr. Dan Holt pushed the MOE/MECP hard for this information. The MOE/MECP once again gave a future date to present this criteria that is now long past without fulfilling their promise.

On the last page, item 12. of Ms. Doughty's critique she in no uncertain terms advises Lanxess that the remedial objectives will NOT be revised based upon remedial technologies selected. Similarly settling upon unambiguous cleanup criteria will NOT revise the remedial objectives.

It is clear that Ms. Doughty is not satisfied with Lanxess's efforts in these two documents. Only time will tell how much Lanxess improve upon them. As always the public are the losers when both guilty parties literally spend years talking back and forth about remediation that is already years behind schedule.