MINISTRY ABANDONS ALL PRETENSE OF CREDIBILITY

The Ontario Ministry of the Environment (M.O.E.) are now publicly advising TAG (Technical Advisory Group) that they do not have provincial sediment quality guidelines which would enable them to order a cleanup of the Canagagigue Creek by Chemtura Canada. Yes they acknowledge the existence of Canadian Sediment Quality Guidelines but when asked why those are not acceptable they simply respond because they aren't provincial guidelines. As of yesterday I have made available the fact that these Canadian Guidelines actually include on page 4 a reference to the contamination in the Canagagigue Creek as well as the name of the study done by Bedard and Jaagumagi in 1995-96 titled "Sediment and Biological Assessment of Canagagigue Creek at the Uniroyal Chemical Ltd. Plant, Elmira, Ontario. 1995-96". In other words the Canadian Guidelines are actually built upon the ground breaking study done right here in Elmira, Ontario in the very same creek that our M.O.E. claims it has no provincial sediment guidelines for.

This 1995-96 study includes a biological assessment of the uptake of contaminants including Dioxins.Furans and DDT in the benthic community as well as in fish species. The conclusion is that indeed these contaminants are available and are being absorbed and bioaccumulated within lifeforms in the creek. Also of interest is Appendix A of this report. It is titled "Provincial Sediment Quality Guidelines". Isn't that interesting? Some of the other potentially dioxin like contaminants present in the creek include PCBs and HCB (Hexachlorobenzene?). To date no effort has been made to determine how significant their contribution is to the total toxic effects of Dioxins/Furans.`

George Karlos, Deputy Director of the West Central Region of the M.O.E. advised CPAC in 2012 that they the M.O.E. were going to do another study of the creek, its' sediments and floodplain soils. They would also two years later do testing on fish and compare the results to their Tissue Residue Guidelines (TRGs). The first report was titled "Canagagigue Creek 2012 Downstream Sampling March 28, 2013". The second report was titled "Canagagigue Creek 2013 Additional Sediment Sampling at Stn 21S and Soil Sampling at Martin Pond Berm September 26, 2013". The third report was titled "Canagagigue Creek: Sediment and fish results from 2014 and update on sampling conducted in 2015 September 30, 2015".

Guess what? All three of these reports are filled with references to and comparisons to various criteria and guidelines. They include ISQG - Interim Sediment Quality Guidelines, NEL - No Effect Level, PSQG - Provincial Sediment Quality Guidelines, SEL - Severe Effect Level, LEL - Lowest Effect Level, Canadian Interim SQG and Canadian Probable Effect Level - PEL. Not a peep out of the Ministry that they have no criteria or guidelines. In spots they make comments such as "Could not validate 2012 SEL results", "2013 results did not exceed PSQG SEL" etc. as well as "Exceedance of PSQG SEL is expected to impair benthics".

The 2014 Report states (pg.8) "Data compared to historical data and appropriate guidelines for assessing potential impacts" and then lists Sediment Guidelines including both Provincial and Federal (CCME) Guidelines. It also then lists Fish Guidelines namely "Federal (CCME) tissue residue guidelines (TRG) (Young of the year fish). There are both exceedances as well as samples below guideline levels. The point is the blatant and grotesque hypocrisy of the Ontario M.O.E. to now in 2016 suggest that they don't have appropriate guidelines to base remediation decisions upon after confidently proclaiming them and their use in 2012, 2013 and 2014.

One key component requiring remediation of a site is being able to prove adverse effects ie. adverse environmental effects upon lifeforms. We have had overwhelming evidence of that over the last twenty years and in fact DDT for example has been found at much higher adverse levels in 2012 and 2014 than it was twenty years ago. There is no technical excuse for not ordering a cleanup of the Canagagigue Creek. There is only political corruption standing in the way.