MY FORMAL PRESENTATION/DELEGATION TO SEPT. 29/11 CPAC MEETING

My "Delegation" to CPAC was in response to the M.O.E.'s attempt at clarifing their first inadequate response to CPAC's insistence upon following the July 2003 Request For Action. This second attempt by the M.O.E., while marginally better than their first, still has major issues with accuracy and credibility. Here it is:



DELEGATION TO CPAC MEETING OF SEPT. 29/11

Status of 2003 Action Item List (Additional Information) promised by Garth Napier, Ontario Ministry of the Environment, signed by Steve Martindale, M.O.E.

RPW-1 & RPW-2 “Oct 28/08 DNAPL Tech Committee meeting…” By this date all of these private DNAPL technical meetings were being held at Conestoga Rovers offices in Waterloo, by invitation only. Yours truly and the unwashed public were excluded. “OW89-22 at 440/410 ug/l which is over ODWS but not as high as other parts of the plume”. The ODWS (Ontario Drinking Water Standard) is 80 ppb. This is cherry picking numbers and I can do it as well as you can. 2006/2007 OW82-9 in UA3 of RPW2 had the highest UA3 readings of Chlorobenzene on the Chemtura site namely 7,800 (ppb.) ug/l. Criteria for the presence of DNAPL is approximately 4,000 ppb.
“OW37 pesticide/herbicide levels very high in 1991. Drums and RPE4/5 excavations reduced contamination in areas…” . I can’t really even speculate what you are doing here . This well and those pits are on the east side of the creek and have no relevance to RPW1 & 2.
P1 At the last CPAC meeting I indicated extraordinarily high levels of DDT in the soil in P1. Thank you for confirming that . Also thank you in your “Further Information” for indicating that there were “elevated levels here of DNAPL in UA3”. The P1 area may be hydraulically contained in the Municipal Upper aquifer but it is not contained in either UA1 or UA3. Both these aquifers discharge horizantly into Canagagigue Creek and are part of the reason for very high DDT and other contaminants originally in the creekbanks and sediments. Your further comments that “possible sources for the contamination (chlorobenzene) are leaks from UA3, or the movement of the northern contamination plume as it is drawn south to PW4 or Pw5. “ may have merit. This “…northern contamination plume…” would be the one coming from the RPW1 &2 area due north which you have dismissed as only needing further monitoring.

M2 You advise us that “M2 is priority area (UAT and UA2 aquitards thin) but not short term priority.” This is a wee bit of an understatement perhaps? Both free phase LNAPL and DNAPL have been found in M2. The LNAPL is from beneath Building 15 and at one point in time was estimated at 10,000 gallons or more. The DNAPL was found in 1991 by hydrogeologist Bob Hillier of the M.O.E.. in well OW88, and presented to UPAC publicly in a glass jar. Furthermore it was found again in December 1993 on the border of TPW2 and M2 and was left where it lay because David Ash & company (Uniroyal) said it wasn’t their problem in M2. I am certainly reassured that M2 is a priority area for the M.O.E. now.

RPW6,7,8 As mentioned by me on July 28/11 CRA, consultants to Chemtura/Uniroyal have long claimed that shallow aquifer containment in one quadrant only of the site is O.K., because 97.5% of the contamination is there. There being the south-west quadrant containing RPW5,6,7,8 and M2. In your “Further Information” regarding RPW6 you state “UA3 monitoring shows the UA3 area is impacted, but does not indicate a source”. Wow this is a real puzzler. Two sentences earlier you state “RPW6 was formerly a waste retention pond which was excavated to the top of the underlining clay liner in 1989”. Perhaps Steve or Garth if you had read our July 2003 Request For Action a little more carefully you might have noticed the following statement “3,400 litres per day estimated leakage of process wastes, downward , after ponds clay lined (CH2MHILL); more leakage before lined. “. For further reference CH2MHILL who were consultants to the Region of Waterloo in the early 90’s claimed that they got their figures from Brian Beatty of Morrison & Beatty, consultants to Uniroyal Chemical.

This will suffice for now. Maybe the Ontario M.O.E. for their third attempt would like to do a straight on, point for point critique of the detailed rationale included in our July 2003 Request For Action. This would be the first time that either the M.O.E. or Chemtura have done so.

Alan Marshall Elmira Environmental Hazards Team