BACK & FORTH COMMENTS BETWEEN CHEMTURA & THE M.O.E. DELAY ACTION

The collusion and back scratching are so ingrained that I no longer believe anything the Ministry of Environment say. Even when they "comment" on a Chemtura/GHD report and make suggestions that appear to be improvements I find myself looking for ulterior motives. I mean afterall they've burned their credibility to cinders long ago.

On December 13/16 Louis Almeida of GHD responded to M.O.E. comments regarding the 2016 Draft Off-Site Investigation Work Plan. It seems to me that to date this badly abused stakeholder, courtesy of an intentionally corrupt process, has not received all of these M.O.E. comments. The ones from M.O.E. hydrogeologist, Cynthia Doughty yes, others no.

The M.O.E. are suggesting that soil sampling should occur not just on a line 3 and 9 metres parallel to the property line between Chemtura and the Stroh farm but also within a meter of the property line. More soil samples is good but GHD are saying no. Then the M.O.E. make a totally asinine suggestion; one that I've seen before. Basically they suggest that if the 1 metre or less samples are non-detect then collected samples at 3 and 9 metres don't need to be analysed. This appears to be assuming, incorrectly, that the toxic contaminants have run in a perfectly straight line due east from the Chemtura property onto the Stroh farm. GHD actually reject this suggestion as well. Remind me again, who are the good guys and who the bad?

GHD are also proposing some test pits at the locations of their proposed off-site monitoring wells. They are attempting to delineate the extent of soil contamination emanating from Chemtura's east side pits. As previously indicated the number of parameters to be tested is inadequate.

There is a major bone of contention regarding test pit TP07-16 which was part of the Supplementary On-Site investigation near the eastern property line. The M.O.E. want this soil contamination delineated because many of the multiple parameters exceed the soil leaching guidelines. First off I'm not terribly impressed with these soil leaching guidleines in the first place. They seem to have been parachuted into the discussion after thirty years, right out of the blue. Secondly even though their exceedances have been mentioned as well in Cynthia Doughty's comments, GHD are simply denying those exceedances. WTF?

The M.O.E. want more parameters than Dioxins and DDT tested for east of monitoring well OW38-5(R). Dunh more parameters should be tested for at all the locations! GHD of course are saying no.

On page 6 GHD admit that their assumption is that the extent of off-site groundwater contamination is limited. They then state "If this is correct, the approach outlined in the work plan is appropriate and will provide the delineation described above.". O.K. so does that mean that if GHD's assumption is wrong then their work plan is inadequate?

And on and on. Is all of this back and forth actually improving the Work Plan? I don't see it. What I see are folks going through the motions, playing to the audience. I see two equally culpable parties delaying and game playing.