RESPONSE SENT TODAY TO LANXESS, MOE/MECP, WOOLWICH TWN., TAG, RAC, REGION & CPAC

April 16, 2022 ......................................................................................... THE PROBLEM IS NOT THAT TECHNOLOGIES DO NOT EXIST: THE PROBLEM IS THE TOTAL CONTROL OF THE CLEANUP BY THE POLLUTER AND THEIR UNSURPRISING RELIANCE ON THE CHEAPEST & LEAST EFFECTIVE TECHNOLOGY NAMELY PUMP & TREAT ..................................................................................................................................... Jaimie: Thank you for your clarifications and responses to questions raised at the last TAG meeting (March 24/22). I attended (virtually) as usual and was (un)able to assist particularly with the first three questions as Woolwich Township and your employer (Lanxess) feel that the cost of having a very knowledgeable and experienced citizen present at meetings and quite able to clarify and answer TAG's questions is too high. Informed criticism and embarassing questions leading to a loss of credibility for agencies, institutions, politicians and polluters really is outrageous and obviously can not be tolerated. ...................................................................................................................................... I also thank you for the very interesting article by Donald l Siegel that you passed on. Although some might view his position and opinions as merely those of an apologist for polluters, I do not. On page 3 of your comments to TAG you state that “Other technologies of today are either not viable in the Elmira case, or haven't been discovered and developed by the scientific and engineering community yet.” That is not correct. One of the simplest (not cheapest however) technologies is source removal. On the odd occasion when Uniroyal/Crompton/Chemtura/Lanxess have attempted it, generally the results have been very good. Attempts at using ISCO (In Situ Chemical Oxidation) on the Lanxess site (near pumping well W3) were amateurish and incompetent according to Dr. Richard Jackson the first Chair of TAG (2015 & 2016). I must ask you and Ramin how you believe that the myriad of other remediation technologies including different forms of sub-surface source removal and or encapsulation, thermal technologies etc. are not viable as none have been tried. ................................................................................................................................................... Mr. Siegel could be faulted for suggesting that regulatory agencies are unrealistic in their demands that polluters clean up contaminated aquifers to drinking water standards. He appears to be unhappy that these criteria are so very small. Hopefully those very small concentrations are based on honest science and reflect how toxic to human life many industrial chemicals are. Mr. Siegel also references what he calls “bleeding out” as contaminants diffuse back into clean water after remediation ends. This phenomenon has also been long referred to as “rebound”. Preferential flowpaths are also a major issue. Back to Dr. Jackson of TAG who publicly excoriated Chemtura/CRA and the Ontario M.O.E. for their decades long failure to recognize and act upon the basal gravel unit at the bottom of the Municipal Aquifer. That coarse gravel unit was a major preferential flowpath that should have been targeted for pumping and was not. ............................................................................................................................... Lastly we have decades of citizen input including other informed suggestions for cleanup technologies. Those were either ignored or dismissed out of hand with little to no intelligent rationale provided. Yours truly first suggested to CPAC and Chemtura around 2009 that ISCO had provided solid results at the Northstar Aerospace facility in Cambridge. That was dismissed out of hand until the previously mentioned amateur hour attempt at Uniroyal/Chemtura. In 2003 CPAC's Soil & Water sub-committee provided a three page list of specific locations and contaminants on the Uniroyal site that were shallow and easily accessible. Again yours truly did the bulk of the research for this project that was accepted by CPAC and presented to Crompton/Chemtura, the M.O.E. and other stakeholders. A couple of locations were many years later partially (only) excavated by Chemtura. ............................................................................................................................................. I think that the merit of Mr. Siegel's article lies in his straightforward grasp of the difficulty in successfully achieving long term cleanup of contaminated aquifers. Of course this difficulty should not be used by polluters as their excuse to do the cheapest and least effective cleanup possible as Uniroyal/Crompton/Chemtura/Lanxess have done and are doing all with the support of the Ontario Ministry of Environment. Furthermore the various corporate polluters and their plethora of fellow travellors, stakeholders and partners in pollution should never have been in a position politically to pick and choose young, inexperienced and highly amenable to career pressure, members of the public, no matter how well motivated, to sit on citizen committees allegedly overseeing the cleanup. They also should never have been permitted to cast vetoes with our local uninformed and or biased councillors in order to eliminate proven, experienced, knowledgeable citizens such as the last CPAC in 2015. .................................................................................................................. Jaimie both your responses to TAG and your submission of Dr. Siegel's article are praiseworthy. Neither however remotely exonerate the ongoing cleanup failures of the polluter and its successors. Uniroyal/Crompton/Chemtura/Lanxess own the failure to remediate the Elmira Aquifers to drinking water standards. They also own the failure to clean up the Canagagigue Creek soils and sediments from their site to the downstream Grand River or further. As an avid participant and stakeholder for the last thirty-three years what I view as the worst behaviour is the ongoing and incessant lying, probably less so by the current owner, your employer. Even after Woolwich Township and CPAC announced in 2012 that the 2028 cleanup deadline was dead in the water, Chemtura like their predecessors kept on lying and denying. Currently Lanxess are mathematically manipulating extreme DDT and dioxin concentrations downstream as being acceptable risks. They are NOT! How dare they pretend that it is O.K. to both poison their neighbours, livestock and wildlife fifty to seventy-five years ago and it is now O.K. to continue to deny it and not fix it. ....................................................................................................................................... Sincerely Alan Marshall CPAC & EH-Team member