Tuesday, July 28, 2020


Maybe I've gotten spoiled with a number of excellent reviews/critiques done by Cynthia Doughty, hydrogeologist for the Ontario Ministry of Environment. Some of them have been regarding past Annual Monitoring Reports (AMR). Hence when I read her four page review (dated July 15/20) of the 2019 AMR for Lanxess Canada (Elmira) I was somewhat underwhelmed. At first read it didn't seem to have the pizzaz, the punch, the blunt criticism of her earlier critiques.

I've now reread it. Possibly Lanxess/GHD have taken some of her earlier comments and criticisms to heart and have produced a clearer, better product. Regardless here is what she is advising them and us. Lanxess are currently involved in doing an evaluation of periodic losses of containment of their Elmira site. Ms. Doughty will report on their evaluation at a later date.

The 2019 AMR advises us that off-site pumping W9 will not be up and running prior to early 2021. While Ms. Doughty does not comment on that I will. It is beyond crap. The claim that W9 has been down since October 2019 is also crap. That well was scheduled to be up and running closer to 2017 than in 2019. The separate Trojan treatment system has been a bust from the get go. It is being finally scrapped and well W9 incorporated into already existing treatment trains.

Ms. Doughty advises GHD that their claim that two Upper Aquifer pumping wells are solely screened in Upper Aquifer 1 (UA1) is incorrect. She states that in fact they are either partially or fully screened in Upper Aquifer 3 (UA3) which has important hydraulic containment implications for the creek ("Gig").

On page 3 of her comments, Ms. Doughty advises that GHD's text does not correspond accurately with the facts in regards to pumping failures by on-site pumping well PW5. For me this is just shades of Conestoga Rovers and their overly optimistic conclusions in their past Uniroyal/Crompton/Chemtura reports.

Also on page 3 Ms. Doughty suggests that GHD (Lanxess's consultants) have failed to clearly indicate how well the Off-Site Containment & Treatment System (OSCTS) along with the E7 pumping well, succeeded in achieving off-site containment over the entire year (2019). She suggests that the best they did was to prove that they had full containment on December 5, 2019 perhaps leaving the readers with the impression that the rest of the 2019 year was good. That is not adequate according to Ms. Doughty.

Readers please keep in mind that the on-site pumping systems (shallow & deep) are strictly for the purpose of stopping the spread of Uniroyal/Lanxess contamination off-site throughout Elmira and possibly further. The off-site pumping systems however are both for containment and for mass extraction of those contaminants such that eventually Elmira's aquifers will be restored to drinking water standards. The shutdown of Elmira's wells was in both 1989 and 1990 and the current suggested date for cleanup is two to three decades past the provincially mandated date of 2028. Reliance on hydraulic containment only has been a much too slow process as citizens have long argued. Both on and off site source removal of hot spots should have been done twenty to twenty-five years ago to help speed up the cleanup.

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