THE RISK ASSESSMENT OF THE CANAGAGIGUE CREEK IS BUT ONE MORE IN A LITANY OF PSUEDO SCIENTIFIC ENVIRONMENTAL STUDIES IN ELMIRA, ONTARIO

 

In the past Conestoga Rovers (CRA), on behalf of Uniroyal Chemical, Crompton & Chemtura, were accused of writing Conclusions and Recommendations to reports that simply did not reflect the data and findings of those reports. In other words CRA would cherry pick items here and there within the reports of little significance and arbitrarily pretend to believe that they had far more weight and significance than they did. This was but one of their methods during DNAPL studies done in the late 1980s and early 1990s. They were actually accused by a consultant (CH2M HILL) for the Region of Waterloo of intentionally sampling for DNAPLS in the least likely locations to find them and then claiming "see there aren't any DNAPLS here."

Similarly monthly Progress Reports showing reduced on-site pumping might be acknowledged as a temporary mechanical breakdown easily fixed yet month after month and year after year the trend continued to decrease. Also there was never any acknowledgement of public verbal promises made by  Chemtura staff regarding the Tripling of off-site groundwater pumping in the monthly Progress Reports. Neither a tripling nor even a Doubling ever occurred and yet not a peep in those monthly reports as they bragged about exceeding their old off-site Target pumping rate by five or six litres per second (i.e. from 53 l/sec to 58 l/sec).

Now Lanxess continued that fine tradition with their Risk Assessment (RA) of the Canagagigue Creek. Apparently they can manipulate various assumptions throughout the RA process in order to conclude that despite many, many exceedances of health criteria for multiple contaminants both in Creek sediments and soils; not to fuss as the RA claimed "...no unacceptable risks...". There were also issues with floodplain soils as well and don't get me started on amateurish sampling of Creek sediments using shovels instead of professional core samplers. Along with these polluter self-serving failures were the locational sampling biases that failed to properly sample the majority of the five miles of downstream Canagagigue Creek all the way to the Grand River.

All in all unethical and dishonest junk science, psuedo science and wishful thinking science alone will not succeed. It also takes a combination of either stupidity, laziness or dishonesty by sitting politicians at the municipal, regional and provincial levels. Woolwich Township and Waterloo Region, fortunately for polluters, are blessed with an abundance of these. 

 

TYPO CLARIFICATION REQUIRED REGARDING METHOD DETECTION LIMITS HIGHER THAN HEALTH CRITERIA

 

Oops to err is Uniroyal like, to forgive divine. Gee I hope I haven't offended any Uniroyal lovers still alive in Elmira.  If I have then I guess I'll just have to live with it. By the way I bumped into former councillor Julie-Anne Herteis last evening.  She appears well and did not seem to still be mad at me for unkind things I may have said about her while she was a Woolwich councillor.  That's good because while sitting politicians are fair game, retired or those moving forward in life are not.

The typo is an easy one to make when we are discussing health criteria concentration numbers of toxins along with laboratory Method Detection Limits.  In yesterday's post I started off O.K. in my first paragraph stating that both the authors of a recent report and the Editor of Environmental Science magazine stated in their Summaries that "...analytical limits are far too high for detecting many chemicals, especially pesticides." Then however near the end of my second paragraph darn if I didn't reverse the word higher and use the word lower. Maybe that's not so much a typo as a brain fa*t? 

Here is an example. If you have a chemical with a health criteria concentration of  .5  ug per litre  (.5 ug/l) i.e. half a microgram per litre of water AND a laboratory Method Detection Limit however of 1 ug per litre ( 1 ug/l)  i.e. one microgram per litre then you have a problem because  the laboratory measuring the particular chemical can only measure as low as one microgram of that chemical per litre of water. Therefore the chemical can be above it's health concentration in drinking water (say for example three quarters of a microgram of chemical per litre of water)  however it is assigned a concentration of ND or Non Detect because the lab either don't have the equipment to measure that small or the appropriate process/method to do so. Also sometimes it can also be a matter of cost. Certain labs may charge extra for doing more expensive and difficult very low concentration analyses of a chemical.

Therefore this can be a legitimate limit on determining the toxicity of some chemicals in various mediums whether water, soil air etc. Or on the other hand it can be a very convenient method of weaseling out of showing exceedances of health criteria by toxic chemicals thus reducing expected cleanup costs. Unrepentant polluters lacking in ethics have become adept at this kind of gamesmanship just as regulators and credentialed public advisory committees have learned to look the other way in reports evidencing this kind of data. 

  

  

LIMITATIONS OF AQUATIC MONITORING ALSO LIMIT AQUATIC RISK ASSESSMENTS

 

Last year a scholarly article was published in Environmental Science Magazine titled "Limitations of chemical monitoring hinder aquatic risk evaluations on the macroscale". This was a very large study of decades of monitoring data from across the United States.  Both the Editor and the authors included a Summary or Abstract if you will. Each essentially said that despite decades of monitoring, less than 1% of chemicals with possible toxic effects have the proper data required for risk assessment. The second statement from both parties was that analytical limits are far too high for detecting many chemicals, especially pesticides. Thirdly both advised that these limitations have biased risk perceptions and I would add risk assessments.

If none of this rings any bells than you have not been keeping up with the risk assessments done by Uniroyal Chemical/Chemtura and later on by Lanxess Canada who are only too keen not to spend another nickel on cleaning up the Canagagigue Creek after spending millions (?) on lobbying, bribing?, monitoring and persuading politicians and credentialed TAG/TRAC members that all is well.  I have long said that risk assessments are mathematical models filled with assumptions that can be favourably bought by polluter clients for a fraction of real cleanup costs. When as it turns out these monitoring data are also woefully incomplete including laboratory detection limits of toxic chemicals higher than their mandated health criteria; then what you have is not a risk assessment it is actually a get out of jail free card produced by well educated, intellectual prostitutes all pretending to rely on the "professionalism" of others. 

Mention is made of both DDT and Dioxins as are present in the Canagagigue Creek, courtesy of Uniroyal Chemical and Lanxess Canada, accompanied by warnings as to their enhanced toxicity.  

 

WONDERING WHY LUISA D'AMATO (K-W RECORD) HASN'T REPEATED HER COMMENTS ABOUT OUT OF SERVICE, CONTAMINATED WELLS

 

It was all of once. I have the article on a pile of articles dealing with the recent Waterloo Region Water Crisis.  Ms. D'Amato mentioned out of service wells including the Greenbrook Wellfield, Parkway and Woolner/Pompeii Wellfields. All three have past contamination problems and most likely present ones if they reactivate them. Recently I mentioned the benzene plume emanating from the Ottawa St. Landfill and drawn via pumping towards the Greenbrook Wellfield on Stirling Ave. near Homer Watson Blvd.  I believe that mention was also made years ago of 1,4 Dioxane being in some of those wells. Then Luisa herself had advised of contamination (TCE) at the Parkway wells and finally the river wells from the Woolner and Pompeii Wellfields have lots of solvents and goodies from the Safety-Kleen site formerly known as Breslube and Forsythe. 

Before continuing on about fixing the out-of-service wells listed above I want to mention Luisa's following statement in her Opinion piece in today's K-W Record titled "Why water pipeline to Lake Erie is not a good idea". That statement is "...that underground water supplies in Wilmot have almost been pumped dry in an attempt to keep supplies up." Have I missed something? Yes I understand that various private wells on the west side of Kitchener and or between Petersburg and Baden have been going dry. I had hoped/presumed that these wells water levels were being drawn down by Region of Waterloo and City of Kitchener excessive pumping but that is a whole lot different than suggesting that water supplies in Wilmot have almost been pumped dry. Good Lord if Wilmot Township which is also home to a significant part of the Waterloo Moraine is as a whole going dry then we are all in serious, immediate trouble.

Back to the out-of-service wells.  The Region of Waterloo are masters of the weasel worded descriptions as to why wells were shut down.  Unfortunately they are also masters of protecting and constantly insulating dirty, industrial polluters from the full consequences of their environmental negligence.  This means never pointing out which specific companies and corporations have mostly singlehandedly contaminated regional drinking wells. "Fixing" these wells does not mean new pumps, wellheads, piping etc. Nor does it mean drilling a new well beside the old one or even simply drilling deeper hoping to go by the contaminated sub-surface zones (soils). It would mean costly remediation possibly including excavation that should have been done decades ago and wasn't. 

Now all of this is moot if the Region are desperate enough to mix in solvent contaminated water with cleaner water in order to dilute it.  Oh but wait! They are that desperate. They've been doing that with the TCE (trichloroethylene) at the Middleton Wellfield in Cambridge for many decades. I believe there are also other wells in the Region that are "managed" in similar fashion. 

RUBBING OUR AUTHORITIES NOSES IN THEIR WATER FAILURES

 

The sentence below was on my latest e-mail in the Subject column sent yesterday to Woolwich Council, Waterloo Region Council, MECP, Lanxess, K-W Record, Woolwich Observer and TRAC . 

"Don't you wish you'd listened recently and decades ago to Esther, Richard, Henry, Viv, Ron, Graham, Dan, Sebastian & myself about Elmira's water ?"

There are and were other honourable mentions such as Sadi, Barb, Mary, Randy, Shannon, Kenneth, Pat, Chuck, Susan R., Steve and others who stepped up over the years and decades. 

The point of the quote above is that if the guilty parties (councils, MECP, Uniroyal/Lanxess ) had done their duty, both moral and legal, then we would have Elmira folks drinking Elmira water  and not taking water from the three cities via a pipeline. Unfortunately the guilty parties instead of looking ahead to the obvious time when our finite water supplies became stretched were more concerned with coddling a chemical company who provided some jobs and some tax money. 

Yes I could agree that Lanxess Canada are less culpable than Uniroyal Chemical who both buried toxic wastes,  lied about them, lied about remediation options, lied about DNAPLS, lied about Dioxins and just about everything else involved. Uniroyal and Chemtura also participated in pressuring Woolwich Council into who they wanted on UPAC, CPAC, TAG etc. as well as who they wanted off. None of the successor companies to Uniroyal have shown any interest in properly cleaning up Canagagigue Creek to their utmost shame. 

Citizens stepped up and informed themselves. They spent countless hours attending mostly dog and pony shows orchestrated by the polluter and Woolwich Council. Citizens read reports and made good suggestions the vast majority of which were either ignored or laughed at and treated with disrespect. Well you sh**heads congratulations! 

We have neither our groundwater restored nor the Creek properly cleaned up. That's all on you as you've run the show from day one.   

DEVELOPERS & HOMEBUILDERS NOT CONCERNED ABOUT PROFITS ($$$); IT'S ALL ABOUT HUMAN SUFFERING

 

Furthermore to my title above I must inform readers that I am smarter than Bill Gates, stronger than Arnold Schwarzenegger ever was, and better looking than either Brad Pitt or Tom Cruise at their best. In other words my title above employs literary exaggeration to the maximum.

Today's K-W Record carries the following article by Bill Jackson titled "Case being made to give small developments green light amid water shortage". The usual suspects are quoted by the reporter such as Larry Masseo and Ryan Mounsey. The former representing the Waterloo Region Homebuilders' Assoc. stated that his association is not in agreement with the region "in terms of the extent of the seriousness of the issue at this point,".  Nowhere in this article does his position seem to be backed with data supporting his opinion.  Mr. Mounsey also advises in one statement that he only works with developers "...that have small infill, gentle density housing with a modest - the smallest - impact" on water useage. Then he advises that these clients range anywhere from one lot to 1,400 units for a total of 2,500 units in the Region of  Waterloo. In my opinion adding 2,500 units (approx. 5,000 people ?) all requiring water on a daily basis is significantly exacerbating the water shortage. 

At the moment operational resiliency within our water system will not be restored until 2027. Until or unless that determination is changed the ban on new building permits should remain. This coming Wednesday regional council are to revisit staff recommendations to add capacity to the system from wells in Wilmot Township as well as to have regional council ask the province to halt water taking permits for golf courses, gravel pits and other large industrial/commercial enterprises. Depending upon the results of those two recommendations the ban on new building permits might need to be extended even further down the road. It is conceivable that neither Wilmot Township nor the Doug Ford government may be in the mood to comply to the requests.

INTERESTING CHOICES & OUTBURSTS BY PREMIER DOUG FORD

 

This post today is supposed to be about Susan Koswan's excellent Opinion piece in today's K-W Record titled  "Water and nature need protection from politics".  Essentially the politics she is describing are the politics of our current Conservative government led by Doug Ford. I am of two minds right now. Or maybe even three or four. Yes Doug Ford and his merry band have been awful for the environment and Ms. Koswan  clearly describes his gaffes, errors and plain bad thinking and behaviour on the environment file. 

Meanwhile back on the first page there is Doug Ford blustering about how a homeowner recently shot one of four home invaders. Four on one in the middle of the night is hardly a fair fight especially as at least one of the home invaders was caught on video with a gun in hand. Undaunted the homeowner shot one of them and they all fled. Doug Ford meanwhile was quoted as saying that the homeowner should have shot him a few more times for good measure.

Doug of course is pandering to the public's discomfort with firearms legislation that essentially for decades has stated that citizens may own guns to shoot unarmed animals and or harmless paper targets that have never attacked anybody. But by God any use of a firearm to defend oneself from physical attack is beyond the pale. Under no circumstances are Canadian citizens supposed to have the right to readily and quickly defend themselves from robbery, assault or worse. Being even blunter I expect that our police, prosecutors and courts will cheerfully advise women that mere rape also doesn't justify shooting someone. For our justice officials that would be a case of using disproportionate force to defend oneself. Well! Let me simply suggest that if any of either Harvey Weinstein's or Frank Stronach's alleged victims had been armed, their criminal activities would have been nipped in the bud.

So I like Dougie for standing up to the stupidity of our judicial system and the temerity of all participants within it to expand the legal rights of citizens to defend themselves from unprovoked attacks. At the same time I am appalled at his biased and self-serving environmental behaviour in this province. He is a one man environmental wrecking machine and needs to be cut down (only at the polls please).