So called professional consultants (GHD) only write such drivel and nonsense when they are assured that serious and knowledgeable critics are not allowed the opportunity to straightforwardly address their inaccuracies.
Nov. 19/24
FURTHER COMMENTS & OBSERVATIONS
REGARDING LUIS ALMEIDA'S SOMEWHAT HOPELESS NOV. 14/24 LETTER TO
TIFFANY SVENSSON
In TRAC Question 1, TRAC requested
topography information and flow path info for historic waste
management units. The first effort by GHD was pathetic whereas the
second was mostly non-existent. Let me advise Luis thusly: Good
ground surface contour lines, i.e. topographical information is
required to confirm/prove flow paths of rainfall, liquid toxic wastes
etc. These topographical lines show the flow direction via gravity
flow. Your provided map is crap! It fails to show all the east
boundary/border topographical lines i.e. from north to south along
the property line/border. You have focused on contour lines only at
the south end of the site despite leakage and migration from the most
northern pit (RPE-1) plus all the rest (RPE-2-5) based on Region of
Waterloo and GRCA topographical maps which you have used in your past
reports. Secondly some of your contour lines are not identified by
elevation and others have soil sampling locations inconveniently
placed on top of contour elevation numbers making them illegible.
Finally of the contour lines I can read not all match the ones that I
used several years ago from your published maps labelled as Region of
Waterloo or GRCA sourced.
Luis suggested that there was a ditch
or swale on the west side of the pits parallel to the Creek. While I
don't dispute that some of the overflow, spillage etc. from the east
side pits may well have found it's way into that ditch/swale
unfortunately you have not indicated where that miraculous and
helpful ditch/ swale starts or stops. Also just because liquid wastes
are overflowing from all five east side pits doesn't mean that it all
flowed out of the west side of the pits and found your ditch/swale.
These five pits were partially in ground and partially above ground
by your own maps and figures. Liquid contents overflowed in all
directions including onto the Stroh farm. Contour lines indicate that
the pits were higher than the Stroh property the length of the
property line and liquids would flow eastwards not just westwards.
Finally your wonderful ditch/swale did NOT run directly into either
GP-1 or GP-2. It ended north of the two gravel pits at the swampy
area that already had standing water/liquids in it. From there any
flow in the west side ditch/swale spread out and again gravity
flowed via ground surface contours south-east through the so called
”Gap” area and onto the Stroh farm where it met other migrating
liquids that had flowed almost due south on the Stroh property. The
1983 Stroh Drain, Ditch & Berm (SDDB) was built for two purposes
namely to drain the swampy area on both properties and secondly the
Berm was to weaken the force of the flooding Canagagigue Creek which
had been eroding contaminated soils from a very low lying area
slightly further east on the Stroh property where much of the
migrating toxic liquid wastes settled.
Luis keeps referring to the Gap area as
topographically high. Ridiculous! The name “Gap area” refers to
Chemtura/Lanxess intentionally failing to take soil samples in 2015
at the LOW LYING former swampy area immediately north of where the
north-west to south-east diagonal ridge of high ground sits. Then
when soil samples were actually heaven forbid taken on the Stroh farm
at an amazing depth of 15 cm. or 5.9 inches in 2018, the 2015
stupidity (?) of taking soil samples on the entire perimeter of the
Uniroyal/Lanxess east side property EXCEPT for the one low lying area
that many of us toured, saw and walked on in 2019 was rectified via
the addition of SS20 and SS21. Now of course even then Lanxess had to
play games by including parts of the high ground at the southern end
of SS20 leading to the high ridge of ground. Hence “the GAP” is
merely a 2015 sampling gap and failure of Uniroyal/Lanxess that Luis
and others have appropriated in an attempt to undermine finding
higher concentrations of dioxins and DDT compounds by intentionally
sampling the high ground exactly where everybody knows flowing
liquids would not have travelled over.
By the way aerial photography actually
did expose part of the flow path from the Uniroyal property to the
Stroh property . It was both the 1955 and 1968 maps in a March 2012
CRA Report regarding the Gravel Pits that showed an arc if you will
of bare ground running through the LOW LYING GAP from Uniroyal over
to the Stroh property exactly where the SDDB was later built to join
up with Martin Creek and then the Canagagigue Creek. I notice that
Luis failed to mention the 1968 aerial map which a generous person
would not call an intentional lie. My generosity however failed me
after about the 137th lie from Uniroyal/CRA or wait a
minute was it the 371st lie? This is another advantage of
delay. Memories tend to weaken. Good news however Luis did mention a
1955 map which however like the rest he mentioned was not shown.
Luis really is confused. He claims that
soil sampling locations S-17 (02) and SS09-15 are within the Gap
area. They are not! Also he claims that previously mentioned SS20 is
within the Gap area when only the most northern part of that specific
area is. Furthermore his Table 1 shows a TEQ (i.e. Total dioxins)
criteria of 99 pg/g or parts per trillion (ppt.). Now it turns out
that this TEQ criteria is based upon MECP Table 2 criteria whereas
most of the time we use MECP Table 8 criteria. I checked the 2017 and
2020 Canagagigue Creek Soil and Sediment reports and indeed Table 8
was used likely due to the samples being taken within 30 m. of
surface water. Perhaps Luis would like to amend his criteria for soil
samples taken within 30 m. of the Stroh Drain, Ditch & Berm
(SDDB). When it comes to the soil samples along the Uniroyal eastern
property line they all appear to be based upon Table 2 criteria which
is likely O.K. for the further north soil samples but not appropriate
for soil samples taken just across the property line from the
constantly flowing SDDB.
One other small problem for Luis is
that he's gotten his soil units wrong. DDT compounds (i.e. DDD &
DDE as well) have always been in units of micrograms per gram or
parts per million. He's got them in his personal Table 2 as picograms
per gram which is parts per trillion. This basically is saying that
all the DDT compounds are one million times smaller than they
actually are by CRA/GHD earlier reports.
Again Luis somewhat oddly is claiming
that the former gravel pit investigation included the Gap area. Well
if he persists in believing that the high ground at the south end of
SS20 is part of the GAP area (it isn't) then maybe he might also want
to claim that Uniroyal Chemical contamination did not leak off-site
because Uniroyal secretly bought the Stroh farm fifty years ago. See
where I'm going with this? Professional have an answer for
everything. Oh and just to upset Luis a tad more the “...surface
water drainage area located at 6670 Line #86” is both a surface
water drain as well as a groundwater drain. The groundwater is
upgradient on the Uniroyal/Lanxess site and is somewhat diverted by
the below ground surface SDDB (P.S. It's deeper than it looks and
intersects shallow groundwater!)
Luis also talks about an independent
Elmira community member who collected soil/sediment samples. That
also is in error. There were two Elmira community members of which
you know both and of which I am but one. Is Luis taking a shot here
at SSA by inferring that he isn't independent or did he not know?
Secondly we did not collect soil /sediment samples we collected soil
samples properly, logged them, and sent them for analysis. I have
seen other GHD reports claiming that our samples were soil/sediment
which certainly is no more bizarre than so much of what they claim. I
wonder why however they would not simply have asked the question? Ah
yes I forget. I'm on mayor Sandy's, Lanxess, MECP naughty list. It
really is unconscionable for any commoners without certified brown
nosing credentials (i.e. cleared by Sandy, MECP, Lanxess) to offer
opinions contrary to those bought and paid for by our world class
polluters.
Moving along in increasingly better
humour I must also add that of the lowly, miserable and cheap,
minimal sediment sampling in the SDDB two hits stand out. DDD was
significantly above the Table 8 health criteria and dioxin TEQ was
found at a concentration of 24.4 parts per trillion (ppt) with a
Table 8 (within 30 m. of surface water) criteria of .85 ppt. That is
about 36 times higher than the criteria yet all the Queen's's men and
all the Queen's horses couldn't get their crap together and decide
that an honest, full investigation was required. Afterall you could
still upgrade three roads on the west side of Elmira for a truck
bypass while cleaning up the Stroh and Martin contamination on the
east side.
You know there are still four more
questions ahead of us but as a senior, senior citizen I'm getting
ready for my nap. Congratulations to all the dishonest and corrupt
parties over the decades who have stalled and delayed so successfully
for so long. Some of the original citizen critics such as Esther Thur
and Pat Potter are dead and others are suffering the ravages of time.
Continue to keep me from speaking on an equal basis with others so
far less knowledgable and competent and soon I too will be no longer
capable.
Alan Marshall Elmira Environmental
Hazards Team plus numerous others still vertical
