STROH COVERUP BECOMING CLEARER TO TAG: LANXESS/MECP CONTINUE THE DELAY GAME

Three TAG members in particular spoke truth to power last evening. They were Sebastian Seibel-Achenbach, Dustin Martin and finally Susan Bryant who set Ramin Ansari (Lanxess) straight as to how many decades the environment, Woolwich citizens and downstream residents have been waiting for a cleanup of the downstream Canagagigue Creek. Lanxess is in no hurry as each day, week, month and year that goes by means more Uniroyal Chemical contaminants have left their property and while some become entrenched and entrained en route, others flow far enough downstream during high water flows especially that they can no longer be attributed to Uniroyal/Lanxess. The delays of the last thirty years have likely saved the corporate owners of the former Uniroyal Chemical, hundreds of millions of dollars in cleanup costs all under the lacklustre watch of the Ontario Ministry of Environment (MOE/MECP). ........................................................................................................... Last night's TAG meeting was far better than the previous one. First of all both Lanxess (Ramin) and the MECP (Jason Rice) were present to both listen and learn as well as to add information. Their repeated absences have helped make a joke out of public consultation which is exactly what Woolwich Township, the Region (likely) and the province (Ontario) want. A number of issues from the MECP responses to Lanxess were raised such as the limited sediment data supposedly particularly in Reaches three and four (nearest the Lanxess site). Some of this undoubtedly is due to the ridiculously high Method Detection Limits (MDL) which can show concentrations of DDT and dioxins/furans at above the provincial or federal criteria as being Non-Detect (ND) which is outrageous. So called Background readings from Bolender Park Landfill were publicly stated by TAG members to be inappropriate due to Uniroyal Chemical waste and others being deposited there in the 1960s. I was smiling sweetly at pretend mayor Sandy Shantz during those exchanges as she and her council have publicly lied and minimized problems about that in-town landfill. Two other issues include the MECP's insistence that the Magnitude of contaminant Exceedances must be seriously considered as part of the criteria for designating Contaminants of Potential Concern (COPC). The other is a phony reference to the U.S. Environmental Protection Agency (EPA) regarding a supposed 5% frequency rule which Lanxess now admit was in error. This "error" again, as always, favoured consultant GHD's client, Lanxess Canada. ................................................................................................................................... There was one other issue. I and others have known that Uniroyal/Lanxess's vaunted on-site hydraulic containment has never complied with the 1991 MOE Control Order which demanded 100% hydraulic containment in ALL ALL ALL aquifers. That stated I was surprised to hear the following statement go unchallenged namely that 500,000 litres of uncontained (but contaminated) Upper Aquifer water flow into the Canagagigue Creek every day. WOW! TAG by the way supports the numerous comments and criticms regarding the COPC and Conceptual Site Model (CSM) reports done by Lanxess Canada ........................................................................................................................... The next report discussed concerned the East Side Off-site Groundwater Evaluation. This was supposed to be a comprehensive study of groundwater, both shallow and deep, on the Stroh farm to the immediate east of the Lanxess property. Fundamentally it was no such thing and both Sebastian and Dustin Martin made that very clear. Sebastian asked why the report gave exactly zero answers as to why and how NDMA for example was found 240 metres east of Uniroyal/Lanxess even in one instance above the Ontario Drinking Water Standards (ODWS). There was no response or answer from Lanxess or the MECP. Keep in mind that the Stroh farm is allegedly cross-gradient if not up-gradient from the groundwater flow direction at Lanxess. Sebastian also pointedly indicated that just like the past soil samples, there is a huge gap in groundwater monitoring wells and hence results in the southern 300 metres of the Stroh property being uninvestigated and unknown. In other words: "YOU WILL NEVER FIND WHAT YOU REFUSE TO TEST FOR". Ramin made an interesting comment to the fact that normally they do soil sampling first to see if there is an issue prior to installing monitoring wells and then sampling them. Well soil samples are exactly what I and CPAC (and Sebastian) have been asking/yelling for for the last SEVEN YEARS. Dustin Martin made it clear that the Lanxess/GHD report only half accomplished it's goal. It did not answer the important questions nor did it fully delineate the groundwater either shallow or deep. He also interestingly advised that aquitards (i.e. less permeable clay & silt) usually have higher vertical flow than horizontal flow of groundwater. There is high contamination levels in some aquitards and he referenced well OW7-29 in the north and OW8 much further south which intersected the Municipal Aquifer (MU) yet the MU was shown as not continuing further north. Dustin actually used the word "deceiving" to decribe that on the map provided by GHD. .............................................................................................................................. Tiffany Svensson (TAG Chair) advised that a couple of results (soil/sediments) from somewhere along the Stroh Drain were not yet available. HA! She also suggested some kind of a further "Technical Meeting" to discuss these problems with GHD & Lanxess. Those discussions need to be public but forget that as much as Lanxess and the MECP are concerned. TAG haven't learned yet about the ability to abuse private meetings via numerous methods including keeping some results/conclusions "confidential". .................................................................................................................................. Be still my heart but Ramin is claiming that this Risk Assessment (RA) of the Canagagigue Creek is voluntary. PLEASE! Such utter bulls.it which thankfully Jason Rice later clarified. The MECP asked Lanxess to do this RA a while back and if they did not do it the MECP would issue a Control Order demanding they do so or if they abort it prior to doing necessary cleanup, the MECP will do the same. Ramin also publicly promised that if intrusive action such as excavation, dredging or armoring (creek banks?) is necessary that Lanxess will do so. Unfortunately there are a thousand weasel words and weasel steps between here and there. Allegedly "conservative values are used regarding toxicity values. Bulls.it again! There are no scientifically defensible values for simultaneous multiple exposures to toxins. It's all about one value per toxic compound regardless of how many there are. Secondly it's all about "acceptable" risks. This is a mathematical calculation in which one wealthy and informed party tells another one living in and around the risk that it's an acceptable risk by pretending that an individual only has a one in a hundred thousand or one in a million risk of coming down with cancer. Beyond supreme bulls.it. .............................................................................................................. Katharina Richter reported well on the 2020 Annual Monitoring Report (AMR). Covid excuses abound as to why I and presumably others who have received hard copies of this report for decades did not get one this year. Katarina expounded upon pumping wells both on and off site that are currently not working properly and why. Regardless it just pushes the final cleanup of the Elmira Aquifers further and further down the road. I believe that Dr. Richard Jackson suggested that 2050 or 2060 might finish the job. Linda Dickson also spoke to the February Progress Report. Linda also advised as to the ongoing problems with pumping wells both on and off the Lanxess site. ......................................................................................................................... My memory from last night's meeting is nagging at me about some comments regarding "redefining" the goals of the cleanup of the Elmira Aquifers. This is par for the course when after decades of promises otherwise, the guilty parties can't/won't fulfill their promises. Hence as they are in charge of the "cleanup", they simply redefine the goal or endpoint. Talk about unaccountable. Talk about shameless.