INTERESTING BUT STRANGE CPAC MEETING LAST EVENING

Following is the text of my Delegation to last evenings CPAC. I will follow up later (tommorrow?) with further comments and details about the meeting.



DELEGATION TO CPAC - June 30, 2011

Twenty-two days ago I advised CPAC, that in my opinion, it was appropriate to deny Chemtura their “Responsible Care “ designation until they removed the readily accessible Dioxins in GP1 & 2 on their site. Since then I have learned a little more about the international history of Dioxins and other Persistent Organic Pollutants. These listed POP’s have also been known as the “dirty dozen” and just a year ago in fact, nine more POP’s were added to the list . Canada signed on to the Stockholm Convention in 2001 and have promised to endorse the addition of these last nine POP’s. Chemtura ‘s pollution is well represented both on the original “dirty dozen” and with the recent additions. Besides Dioxins ; DDT and Lindane are and have been issues at Chemtura. The Stockholm Convention is a global treaty with 169 countries being party to it. The aim is to protect human health and the environment from the effects of these persistent organic pollutants. These chemicals including Dioxins are extremely mobile via both air and water and are bioaccumulative. An incorrect or at least non qualified reference was made to the immobility of Dioxins at the last CPAC meeting. Studies have found Uniroyal (Chemtura) Dioxins the entire downriver length of the Canagagigue Creek all the way to the Grand River. Dioxins move up the food chain including cattle and via milk and beef into human beings. Thus low concentrations in grass or river sediments are bioaccumulated and magnified as they move up the food chain. It is my observation that the inherent toxicity, seriousness and threat of both airborne and waterborne Dioxins have been historically understated here in Elmira. Considering that the Chemtura site is the largest repository and source of Dioxins in Ontario, that is shocking.
………………………………………………………………………………………………………..
The Ministry of the Environment gave CPAC an Orientation Session just over three weeks ago. There were a number of discrepancies including on page 3 a list of four chemicals from Uniroyal which have contaminated the groundwater. I am quite confident that the Chemtura representatives here would have little difficulty confirming that there are closer to one hundred industrial chemicals in the groundwater and if you really pushed them to test for everything and at very low Method Detection Limits, they might even find two hundred chemicals. The M.O.E.’s list of four chemicals should have been more carefully explained or qualified. Ignoring other discrepancies I will now focus on the bottom of page 23. The title is Dnapl Wastes and for those who were not present from 2005 to 2007, you could be forgiven for interpreting the M.O.E.’s words regarding the production of three reports as some sort of a resolution. This would be inaccurate. At least two members of the DNAPL Working Group publicly stated at CPAC that these reports were not written in stone and the issue of DNAPL cleanup was not finished. Furthermore , since about 1994 the M.O.E. themselves have indicated in their monthly Progress Reports that they have as yet not accepted Chemtura’s DNAPL efforts as being completed. None of these most recent DNAPL reports produced a scintilla of evidence or science that disputes the conclusions of CPAC’s July 2003 Request for Action, which also requests the removal of DNAPLS from the former operating ponds.
Also at the last CPAC meeting Jeff Merriman I believe, verbally threw out the statistic that since the excavations along the creekbank, there has been an 85% reduction in contamination found in various receptors. Now we all know that statistics are very dangerous. Sir Winston Churchill once said “ There are lies, damned lies and then there are statistics!”. So I could bring Jeff to task for this bold assertion of his, but I’m not going to. Instead I’m going to agree with the overall principle involved. Physical removal of source areas works. Every time you have put a shovel in the ground and removed your toxic waste , you have done the right thing. There are more source areas and you know where they are as well as I.


Alan Marshall Elmira Environmental Hazards Team