CHEMTURA FROM THE FRYING PAN INTO THE FIRE?

I mentioned recently that CPAC are quite enjoying how the Chair of TAG has been publicly condemning the gross failures of the Elmira cleanup. This has been an unexpected bonus and pleasure after Woolwich Council in their infinite bias and stupidity decided that the self serving polluter responsible for destroying Elmira's water needed to be relieved of any form of direct citizen accountability. The fact that part of the alternative arrangements more suitable to Chemtura's wishes are now jumping on the CPAC bandwagon regarding discharges to the creek, off-site cleanup failures and on-site intrangience around LNAPLS and DNAPLS is hilarious.

I give CPAC and SWAT credit for not showing up at Council meetings and taunting Council with I told you so's. Maybe this is why our still new Council are changing the rules yet again to cover themselves from criticism they've earned. The new Procedural By-laws are just another example of an incestuous group of self serving politicians and bureaucrats looking out for each other at the expense of taxpayers. Really the problem is not a few critics, albeit many regarding the Breslau sale of parkland, it is the Council themselves. Their solution is so Woolwich typical. Blame the citizens they are supposed to be serving. Blame the messengers.

This Thursday afternoon at 4 Pm. RAC (Remediation Advisory Committee) meet in Council Chambers. Part of the Agenda will be their examination of recommendations from TAG (Technical Advisory Group). This will be RAC's first opportunity to step up and do the right things. The recommendations from TAG include that RAC advise the Ministry of the Environment to initiate suspended sediment sampling asap and that signage and fencing be installed downstream to the Grand River, for the hot spots in the Canagagigue Creek.

TAG will also recommend that RAC advise Chemtura to seek external advice on future ISCO (In Situ Chemical Oxidation) pilot tests for example from the University of Waterloo or from Geosyntec. Chemtura should also be advised to begin multi-level monitoring wells to monitor their groundwater quality. Finally Chemtura should institute a program of annual performance assessment of remediation by a team of outside experts.

It is my opinion that these recommendations from TAG to RAC indicate a huge vote of NON-CONFIDENCE in the years of work of the Ontario M.O.E., Chemtura and CRA. Based upon the glacial speed of these three groups I expect we will see some of these recommendations become actions within five years or so. The question is will Chemtura have packed their bags and run for home by then? Imagine that, a host country seriously expecting them to clean up their mess. Unheard of when there are still hundreds of third world countries around the world willing to donate their environment and health of their citizens to the wishes of chemical companies.

ONE WOOLWICH LIAR IS MEETING HIS WATERLOO, ARE OTHERS NEXT?

Over the last year I have been asked my opinion as to whether Todd Cowan "stole" expense money. My answer has been that I don't know if he's a thief but I do know he is a liar. Possibly a pathological liar whose motive often isn't for personal gain but more for self agrandizement or even to simply get his way. If you aren't winning an argument then make up the facts and claim that you are 100% certain of them. Todd deserves credit for being the catalyst that is still destroying the myths and falsehoods surrounding the "cleanup" of the Elmira Aquifers. He deserves the discredit he is currently, publicly receiving for his apparent abuse of the expenses system designed to legitimately reimburse Woolwich politicians for their expenses on behalf of Woolwich citizens.

I received this morning a copy of an e-mail suggesting that Dick Jackson did not suggest signage and fencing for the length of the Canagagigue Creek because of the known DDT and Dioxin/Furan contamination in both the Floodplain and the creek sediments. While a number of known prevaricators were involved in these e-mails, I have zero reasons or evidence to include Mr. Jackson within that group. His response seems to be that he said (or meant to say??) that any "hot spots" along the length of the creek should be signed and fenced.

I wrote what I heard back at the November 5/15 meeting. Knowing the dishonesty and self serving nature of some Woolwich Township senior staff and politicians, I know that access to the tapes of meetings in Council Chambers is not available for honest citizens. That said let me also suggest the following: Could Dr. Jackson's clarification of what he said be somewhat akin to a homeowner putting signage and fencing across one end of his swimming pool because he knows his four year old child routinely pees as soon as he enters the water?

I mean really Dr. Jackson, you have indicated that the entire length of the creek needs professional, grid pattern testing to really know where the hot spots are. And yes as of right now we do have data (very old) that there is contamination in both the sediments and floodplain at specific sample points, extending the length of the creek (Jagumagi & Bedard 1995-96). If I misunderstood what you said then I apologize but I think you can understand how easily that misunderstanding occurred based upon the known facts of the situation.

Regarding other Woolwich liars meeting their Waterloo, I am of course referring to the abortion that has been the Elmira "cleanup". Probably eight to ten years ago I was publicly stating that "the cleanup is a sham". I also stated publicly that Conestoga Rovers, Chemtura's long time consultants were "client driven". I have wondered about the recent sale of CRA to GHD, whoever or whatever they are. The timing is interesting. All I know is that I would not want to be senior staff at CRA as Dr. Jackson continues to criticize their apparent incompetence. References to MLS (multi level sampling) being the industry norm for decades certainly raises concerns about CRA's professionalism. References to their failure to analyse DNAPL samples, contaminants in suspended sediments and much more are providing a clearer picture as to how Elmira residents have been ill served by my favourite partners in pollution namely Chemtura/CRA and the M.O.E..

Right now CPAC (Citizens Public Advisory Committee) and SWAT are fully enjoying this public thrashing at TAG meetings of the power brokers in charge of the twenty-six year deception. That said keep in mind as to how these committees were set up by Councillor Bauman and mayor Shantz. TAG can be scrupulously honest and forthright but can only make recommendations to RAC (Remediation Advisory Committee). Also to date the Woolwich Observer shockingly have not stepped up to fill this glaring hole in important, local coverage. Will we see as early as this Thursday (Dec. 3) at 4 pm. in Council Chambers how RAC will handle TAG's recommendations? Will the politicans and bureaucrats represented on RAC come to Chemtura's defence as they have in the past? Will they represent their interests rather than those of the public?

DICK JACKSON DISMANTLES CHEMTURA "CLEANUP"

First off Woolwich Observer, have you been subverted? Where are you? Your community needs you to cover these TAG and RAC meetings especially now. You could have helped this community understand the corruption of Chemtura and the M.O.E. over the last five years even though the Elmira Independent covered all the CPAC meetings. Now you are the ONLY LOCAL newspaper in town.

Mr. Jackson led five TAG members plus four CPAC/SWAT members in the audience as well as two more through a tutorial dealing with both Off-site and on-site cleanup. One of those in the audience was Eric Hodgins, hydrogeologist for the Region of Waterloo. Dick Jackson went out of his way when describing the various and multiple technical failures over the last twenty-five years not to mention by name Conestoga Rovers now known as GHD.

Dick described in detail "asymtotic" trends whereby groundwater contaminant concentrations decrease in a linear fashion only until the lower contaminant concentrations start drawing out contaminants that have diffused into aquitards or other lower permeability zones. These diffused contaminants will then back diffuse into the groundwater thus greatly slowing the decreases due to pumping and treating. This is the huge problem facing Chemtura/M.O.E./CRA at the present.

Regarding the field testing done by CRA over a year ago for ISCO (In Situ Chemical Oxidation), Mr. Jackson suggests that the "strategy was good", but "the tactics poor". He further stated that the parties responsible both "poorly understood" and "poorly controlled" the testing held near pumping well W3. He further stated that it was "unforgiveable" that they did not seek professional help for the field test.

Mr. Jackson was particularily upset with a sentence in CRA's report to the effect that Chemtura must needs wait for new and emerging groundwater remediation technologies in order to improve their cleanup time. Dr. Jackson suggested that he would be ashamed to write something like that on a report. It simply isn't accurate.

Regarding the 2012 turnaround by Chemtura and their hired help Dr. Jackson commented on the lengthy turnaround time until now. He stated that it took "3 1/2 years to implement after the lights went on." Referencing a commonly known in the industry geological fact regarding sedimentary aquifers Dr. Jackson suggested that Chemtura's consultant has just figured this out recently.

Dr. Jackson has also clearly indicated his skepticism/concerns that the 2028 cleanup is likely to happen. He feels that Chemtura and the Ministry of the Environment "underestimated" the extent of the contamination held in the aquitards (clay & silt low permeability zones).

Getting back to a now new proposal for ISCO testing in 2016 Jackson again referred to the last field trail as "not my idea of engineering". And on it went with criticism regarding MLS or multi level sampling which apparently has been the norm in North America and Europe for many decades but not at the Chemtura site in Elmira. Yours truly provided a Delegation to the old CPAC back in 2009 or 2010 on MLS but as usual it was ignored.

One of TAG's recommendations to RAC will be that RAC advise Chemtura to "get some help". In other words outside independent experts are required for a number of technical initiatives. To date Chemtura have been relying solely on advice from one source only and it's not working.

Last night was stunning. Even the brand new TAG members understood the enormity of what Dr. Jackson was telling them. It is not business as usual if we are to restore the Elmira Aquifers, remove hot spots on site and stop sending DDT and Dioxins down the Canagagigue Creek.

RECOMMENDATIONS OF THE REMEDIAL ACTION PLAN DESIGN REVIEW (Sept. 25/15)

My post on Tuesday (Nov. 24) indicated that I found the numerous Scenarios for off-site pumping to be bizarre. Essentially I could not fine one Scenario that even came close to reducing the entire Elmira Aquifers to or below Ontario Drinking Water Standards (ODWS) for NDMA and Chlorobenzene. With eleven different Scenarios available for each chemical and in each of the Municipal Upper (MU) and Municipal Lower (ML) Aquifers, there certainly was significant differences in the size and location of the plumes. That said the Recommendation provided by GHD (CRA) is that pumping Scenario 11 is the one to go with.

Scenario 11 incorporates the existing off-site wells namely W4, W5A/B and E7. Well W3 has been replaced by W3R (R for replacement). It is immediately beside the old well. New off-site wells include W6A, W6B and W9A. The text on page 48 states: "Scenario 11 achieves the best overall reduction in initial mass and initial MU/ML off-site area above ODWS for NDMA and chlorobenzene.". In other words Scenario 11 removes the most contaminant mass and shrinks the area of the plume the most; and that's it folks. No more bragging about achieving drinking water standards for all contaminants in all aquifers apparently.

Also when one looks carefully at the numbers involved, something is amiss. The total off-site pumping is approximately 106 litres per second. Depending on which constantly changing numbers you use as the current pumping rates, that is a skinny doubling of the pumping rates. In fact the pumping rates for the last year have been very good, historically speaking, and have averaged around 60 l/sec. In other words this new plan isn't really even a doubling of the rate.

Then look a little more carefully. This new pumping Scenario includes Well E7 at 30.9 l/sec. We were told this past summer and fall that well E7 was going to be shut down and now here they have it back in business and pumping hard. Which is the truth? Also W3R is scheduled to pump an astounding 37.9 l/sec. I don't believe this new well has proven itself capable of those numbers as yet. Also no mention of In Situ Chemical Oxidation. This form of source removal should be used at hot spots to quickly reduce contaminant mass and make the groundwater pumping both more effective and more timely. To date we have no proof of either Chemtura's commitment to use it or that it will be effective for both NDMA and Chlorobenzene if they do decide to go with it.

Both my predictions from years ago and CPAC's since 2012 are now accepted as accurate. Even with this proposed major increase in off-site pumping rates; things are not looking good for 2028.

MINUTES OF NOVEMBER 5, 2015 public TAG MEETING

O.K., O.K. so I can't resist criticizing the very first Statement titled "Disclosures of Pecuniary Interest". Firstly at least two TAG members have pecuniary interests and secondly the text after the title states: "All disclosures made by TAG members indicated that they had no pecuniary interests to declare and therefore that no conflicts of interest exist.". Really? So now pecuniary interests are the only possible conflicts of interest? Therefore why not make the direct declaration that each member does not have any conflicts of interest?

page 3-4: Dick Jackson clarified that the M.O.E. messed up in their presentation by having labelled some of their slides as floodplain samples. He has confirmed that all samples were from the sediments in the bottom of the Canagagigue Creek. He also stated that we can not assume that the contamination seen in 1995-96 is the same contamination that we are seeing now at Station 21 (New Jerusalem Rd.). This is due to the M.O.E. and Chemtura failing to measure suspended sediment hence we have no idea of the level of sediment transport. Once again the allegedly responsible parties have been measuring the wrong thing by measuring dissolved contaminants in water versus contaminants in the suspended sediments in the water.

page 4: Dr. Jackson advised that "The difference in numbers reflects the huge variability in organic matter in the sediments throughout the creek.". Dick also stated that "There are five or six samples at the location, but they were not taken on a vigorous grid pattern which is the way the protocol is written by CCME (Cnd. Council of Ministers) and other organizations.". Finally Dick states that the samples were taken from the wrong location namely on the outside bank of the creek versus the inside bank where the sediments would mostly have been deposited. WOW!

Dr. Dick Jackson on page 4 also stated as I indicated a few weeks ago that the creek should be both posted with signs and fenced off. He does not know why the M.O.E. included two other contaminated sites with allegedly higher concentrations of Dioxins. Dick stated that they are both poor comparisons when one compares the ratio of the surface area of sediment to the volume of water available in the creek. Lastly Dick noted how high the organic carbon is at 9% which he referred to as the glue that holds hydrophobic compounds such as DDT, Dioxins and Furans.

Dr. Jackson has made it very clear that despite testing being done both twenty years ago and over the last few years we do not have remotely enough data to know where we need to remediate.

page 6: Dr. Jackson has indicated that the huge variabilty in creek flow is the cause of erosion of creekbanks and sediment transport. Again in referencing a report on clams and leeches Dr. Jackson is at a loss as to why CRA has not conducted suspended sediment sampling. I am beginning to wonder if Dr. Jackson's repeated comments that he does not know why the various authorities have not done what they should have is a euphemism for something harsher.

page 7: Susan Bryant indicated that the argument with how CRA has conducted their sampling has gone on for years. She referenced their procedure of spinning the sample in order to remove suspended sediments. I also recall them referring to a "field filtering" process in order NOT to include suspended sediments in their samples. A skeptic might begin to think that Chemtura/CRA/M.O.E. are a bunch of crooks and liars. Of course Dr. Jackson would never use such language no matter how accurate it was.

Overall these Minutes are of very acceptable quality. Perhaps the TAG secretary is again receiving assistance on the side to do her job as she did with the CPAC Minutes.

FURTHER CHANGES, CLARIFICATIONS ETC. IN OUR HYDROGEOLOGICAL UNDERSTANDING OF THE ELMIRA AQUIFERS

Starting on page 18 of the Remedial Action Plan Design Review (Sept. 25/15) we learn that the contaminant plumes have stratified ie. they are not all one heterogeneous concentration of NDMA for example from the top of the Municipal Upper Aquifer down to the bottom. Using VAS (vertical aquifer sampling), CRA (GHD) have determined that there is a corelation between increasing depth and increasing contaminant concentrations in many monitoring wells.

page 20: "Both NDMA and Chlorobenzene concentrations increased with depth, and the greatest concentrations occur in the VAS collected from 29.9 m bgs (at the base of the MU). This corresponds to a coarse basal layer of gravel observed in this portion of the MU.".

page 22: "There were ten locations where NDMA was detected in more than one of the MU VAS and at eight of these locations NDMA concentrations increase with depth. Chlorobenzene was detected in the MU VAS at six locations and the chlorobenzene concentrations increase with depth at all but one location." "Therefore plume stratification appears to occur where sufficient aquifer thickness exists and when stratification occurs concentrations tend to increase with depth.".

page 23: The suggestion is made that "Together W5A, W3 and E7 contained the limits of the NDMA plume in the Bedrock, as shown on Figure 2.17.". A few years back I'd have expressed my disbelief that the Bedrock Aquifer was remotely "contained" at all. Indeed W5A pumps in the ML (municipal lower) and there is no Aquitard (lower permeability zone) between the ML and the Bedrock Aquifer. E7 has had a significant LAT (lower aquitard) between the ML and the Bedrock on CRA's subsurface cross-section maps for most of the last twenty-five years. However of late that LAT has been being interpreted as much thinner. Finally W3 still gives me huge problems. It pumps in the MU (municipal upper) and there is no ML present plus there is a huge LAT between the MU and the Bedrock Aquifer. This should isolate pumping in W3 (MU) from having an effect upon the Bedrock Aquifer.

pages 32 & 33: These pages discuss contaminant penetration into the aquitards. The depth of penetration is a function of the dissolved contaminant concentrations with lower concentrations penetrating approximately .5 metre and higher concentrations up to a metre into the Aquitard.

Page 34: In locations on the Chemtura site where the UAT (upper aquitard) is less than a metre thick essentially high concentrations of NDMA and chlorobenzene are going clear through the UAT from the UA (upper aquifer) into the MU (municipal aquifer).

page 36 : We are advised that there are eleven different pumping scenarios from the Base Case Scenario to adding one or more of the new pumping wells in sucession. These new pumping wells include W8 (Yara), W9 (west and slightly south of W8), W6 (Oriole Parkway east of Arthur St.) and W7 on Sandpiper Place.

Figures 4.1 to 4.8 I can only describe as bizarre. These are a series of the different pumping scenarios both in the MU and the ML for both NDMA and Chlorobenzene individually. For example Figure 4.1 is titled "Base Case To Scenario 7 2028 Simulated NDMA Concentrations In MU". Figure 4.2 is titled "Scenarios 8 To 11 2028 Simulated NDMA Concentrations In MU". These certainly appear to be CRA's (GHD) own computer predictions as to which of the various pumping Scenarios will achieve aquifer (MU & ML) drinking water standards by 2028 first for NDMA and then for Chlorobenzene.

This is where it gets bizarre. I downloaded all eight maps and I'm studying them. The drinking water standard for NDMA is .009 ppb and for Chlorobenzene is 80 ppb.. Now unless CRA has mislabelled these maps' contour lines or they have lost some clarity in being downloaded and printed out, then the results are pathetic. I will be going back and rereading the maps on my computer screen but what I'm reading in my downloaded maps basically states that no scenario (of 11) will reduce NDMA to .009 ppb or less for all the Elmira aquifers and Chlorobenzene appears to have possibly one or two scenarios alone in the ML which will reduce Chlorobenzene concentrations to 80 ppb. or less for the whole ML.

As I said bizarre. Further reading will continue.

MORE ON THE REMEDIAL ACTION PLAN DESIGN REVIEW - Sept. 25/15

It's not all bad news. Further plume delineation of the off-site northwest Municipal Upper NDMA plume indicate that it is smaller than originally thought. Monitoring well results from pages 13 & 14 show Non Detect results for NDMA at new wells located very close to OW60 the hot spot for NDMA. This well is located in the residential area just north and west from the old Shirt Factory on Park Street. Similarily the extent of the MU NDMA plumes around new pumping well W6B on Oriole Parkway and around W9, the former apple orchard on Union St. have also been reduced due to new groundwater monitoring results.

The Municpal Lower aquifer has two separate NDMA lobes. One is on the Yara (Nutrite) property on Chemtura's western border and the other is further south starting from just behind the old Varnicolor Chemical site on Union St. beteen First and Howard Ave. It then runs southwards down towards Oriole Parkway. The NDMA results on the Yara property are astonishingly high as in 300-340 parts per billion. These results are frankly horrific when the drinking water standard is .009 ppb. The NDMA results in the ML in the second plume are much lower in the 2-6 ppb. range yet still hundreds of times greater than the drinking standard. These plumes do not appear to be much different than originally determined.

page 16: Chlorobenzene in the Municipal Upper Aquifer now appears to contain more mass than originally expected based on the latest monitoring results. Again the chlorobenzene results around OW60 (north-west of Park St.) are consistent with the known low chlorobenzene results in that area. Both pumping well W3 and monitoring well CH38 on Orilo Parkway had few surprises in this latest review. Chlorobenzene concentrations are below drinking standards at CH38 and still above them at W3. New pumping well W6B located west of CH38 on Oriole Parkway also is below the drinking standard. The new well (OW 171) between W5A/B and W4 behind Varnicolor is the well whose concentrations indicate greater mass than expected.

page 17: Here we also see indications of greater chlorobenzene mass in the Municipal Lower (ML) than originally thought even as late as the 2012 report. This is not good news and further indicates the difficulty in achieving cleanup by 2028. All the other chlorobenzene results indicate very high concentrations as expected, including hundreds and thousands of parts per billion in the ML.

page 17 & 18: Chemtura and consultants are still claiming a lack of chlorobenzene in the Bedrock Aquifer. Frankly based upon the direct connections with it due to lack of competent aquitards I find that result unlikely. Whether dissolved or free phase, I expect at some point we will suddenly "discover" chlorobenzene in the Bedrock.

All in all so far in this report I am smelling lots of excuses. It makes me wonder yet again how Chemtura/CRA/M.O.E. could have been so confident of success over the last fifteen years based upon allegedly incomplete hydrogeological information. The other problem of course is even after they "learn" more there is such a long turnaround time to make significant improvements in their remediation efforts. It's now over three years since they identified the need to triple the off-site pumping and do some off-site source removal via In Situ Chemical Oxidation (ISCO) and neither is up and running yet.