FOLLOWING UP ON YESTERDAY'S "SOURCE REMOVAL" POSTING

Chemtura are between a rock and a hard place technically and factually. However as Dr. Dick Jackson has clearly pointed out the bottlenecks and lack of cleanup are not technical issues, they are public policy issues. Public policy as in the people in positions of authority including politicians are unwilling or unable to do their jobs. This would include incompetence and general ignorance on the issues as well as relatively knowledgeable politicians who like their jobs and aren't willing to take career risks for the sake of either the environment or what they see as others human health. Even "professional" bureaucrats whether at the Region of Waterloo or the Grand River Conservation Authority (GRCA) are either indirectly controlled by municipal, regional or provincial politicians or they themselves such as voting GRCA members are career municipal politicians. The last thing career politicians ever wish to do is to alienate or antagonize powerful people and institutions. That is the quickest road to political suicide.

Here in Elmira, Ontario we have needed our local municipal Council to step up, confront the Ministry of Environment and demand proper cleanup of the Uniroyal/Chemtura property. While there has been the odd former councilor over the last thirty years who individually on a Woolwich Council would have done the right thing, they have been consistently outvoted with the exception of the 2010-2014 Woolwich Council. While that Council had it's own problems, particularily Mayor Cowan, nevertheless they were not in anybody's pocket, especially Chemtura's.

All parties know where Source Removal needs to be done both on the Chemtura property and just off-site, both on the west side (Yara/Nutrite) and on the east side primarily the Stroh property although also likely grossly contaminated sediments in the Stroh Drain where it passes through the Martin farm.

The Stroh property cleanup not only includes the north-west side of the Stroh property next to Chemtura's east side pits (RPE 1-5 etc.) but also much further south in the low lying areas prior to the building of the Stroh Drain. To date Chemtura and GHD their consultants have done their utmost to avoid sampling these areas despite recommendations from both CPAC and TAG to do so.

The Martin property requires soil and sediment testing the length of the Stroh Drain as it passes through on it's way to the Canagagigue Creek. As Sebastian Seibel-Achenbach of both TAG and CPAC, as well as myself and two gentlemen from MBN Environmental have walked up the Stroh Drain through the Martin property; we have an excellent idea of where sediments have been deposited and collected over the decades.

The on-site source removal of course includes both free phase and residual DNAPL removal. While Wilf Ruland has been a major disappointment to me over the years primarily because of his failure to stand up to CRA and the M.O.E., nevertheless I was pleasantly surprised by both he and Jaimie Connelly's (M.O.E. hydrogeologist) digging in their heels in letters which were released to CPAC (approx. 2011-12) several years after being distributed to some of the stakeholders at the time. While I was a voting CPAC member at the time those letters were written, they were suppressed such that I did not receive them.

Cleaning up the Canagagigue is absolutely necessary. However do we really want to clean the creek BEFORE we fully stop the ongoing flow of persistent organic pollutants and more from the Chemtura site, into the creek? Only part of the west side of the creek and its' banks has been remediated or stabilized. Much more needs to be done there. The amount of creekbank stabilization or removal on the east side may be a function of how much contamination has flowed via ground and surface water. Keep in mind that hydrophobic POPs (persistent organic pollutants) are readily mobilized by solvents and Uniroyal discharged millions of gallons of solvent laden waste waters. Chemtura's difficult question is whether or not to admit how much from the east side flowed west directly into the creek versus how much they successfully diverted south and east to eventually go into the creek further downstream.