TAG MEETING OF THURSDAY, OCTOBER 24, 2019

TAG - Technical Advisory Group


Oddly we were advised that generic criteria that both the provincial and federal government post in order to advise the public as to what the criteria are for various toxic chemicals, aren't really what ends up being used. We were advised at the TAG meeting by the MOE that these published generic criteria are actually the lowest criteria i.e. the lowest concentrations . Specifically they are lower than site specific concentration criteria that are determined and calculated allegedly based upon site specific factors. I think that that is horse manure. It is assuming that site specifics always mitigate risk. Why can't some sites various characteristics actually magnify the risk? Is Site Specific Risk Assessment nothing more than a mathematical, psuedo scientific method of letting powerful polluters off the cleanup hook? Is it nothing more than giving environmental tax credits to cooperative polluters?

We were then advised that biological information is more important than sediment chemistry. In other words alleged and non-specified biological information trumps the actual concentrations of toxic chemicals found in creek sediments. Again the whole idea seems to be an intention to make the entire process far more subjective than objective. Afterall hard numbers of maximum concentrations of toxic chemicals permitted to be present in sediments really would make things clear and obvious.

Funny how this "biological" information is so vague. Funny how what is or is not relevant is left entirely up to the polluter, his consultants and his friendly "regulator". Odd to me that generations of children swimming in the contaminated Martin pond courtesy of the Stroh Drain just doesn't seem to interest any of those parties.

More horse manure was peddled such as a Human Health Risk Assessment (HHRA) should be taking action before Public Health departments see a problem. Odd how that didn't happen with the Northstar Aerospace contamination in the Bishop St. community in Cambridge. Odd how Public Health have never gotten around to determining health impacts both on Uniroyal Chemical/Crompton/Chemtura employees nor on the local Elmira community, much less on the downstream farmers and families. Utter crap and wishful thinking.

An Ecological Risk Assessment should note that birds eat the entire fish including the head and internal organs such as livers that accumulate toxins. Human beings don't do that but they do eat larger fish which have had more time to bio-accumulate toxins in the creek.

Further peculiar comments from the MOE experts included that they were conservative (protectful) in their assumptions. Then they said that they don't expect to see adverse effects. What the hell. The concentrations in creek sediments and soils are so far in excess of all the provincial and federal criteria yet they don't expect to see adverse effects? Why the hell do you think chub, shiners, suckers and carp predominate in the creek? It's because trout and other fish species can't survive in the polluted environment. The fish that are there have tissue residue concentrations of PCBs, Mercury, DDT, and dioxins again far in excess of the criteria. What kind of crap are they trying to sell us?

Even the fish tissue residues that we were given turn out to be bogus. Susan Bryant reminded TAG that the MOE tested ground up fish tissues that had had the fat, livers, and heads removed first. In other words they cherry picked the lower concentration tissues for toxic chemical testing.

Regarding Toluene and other NAPL (non aqueous phase liquid) leakage from the groundwater on Lanxess's south-west corner into the Canagagigue Creek, Tiffany Svensson, TAG Chair, advised of the e-mail that I had sent her and TAG regarding current concentrations as well as depth of free phase LNAPL floating on the water table in the south-west corner of the site. This of course combined with the recent revelations by a MOE/MECP hydrogeologist (Cynthia Doughty) that the shallow aquifer is still leaking into the Creek is bad news. Ms. Bryant also supported my ongoing concerns around the presence of leaking toluene.

David Hofbauer suggested that slopes previously stabilized on the Lanxess site for 20, 50 or even 100 year storms that are now occurring every 5, 10 or 20 years were also a concern. They may no longer be doing the job they were sesigned for.

Joe Kelly commented that asphalt capping on-site was "glossing over" problems. He also indicated that he challenged some of the remarks from Lanxess/GHD regarding alternative sampling methods. Joe was not amused by the shovel versus core sampling method that was primarily used as it reduced dioxin/DDT readings as the fines were not captured via shovel sampling.

TAG are working hard. Unfortunately their legitimate concerns will be glossed over, deflected, ignored, or trumped with junk science as has been going on for the last thirty years here in Elmira, Ontario.