Dr. RICHARD (Dick) JACKSON'S SPECIFIC TECHNICAL CRITICISMS OF THE ELMIRA "CLEANUP" FROM 1989-2015

AN OPEN LETTER TO THE MAJORITY OF HONEST, INTELLIGENT TAG MEMBERS .................................................................................................................................... I expect that either later today or perhaps this weekend that I will send this posting on to the TAG Chair, Lisa (Support services), and the majority of TAG members. Dr. Jackson was by far the most environmentally experienced and knowlegable person ever to hold the Chair's position with either CEAC, UPAC, CPAC, or TAG. Just as importantly, or more, Dr. Jackson felt zero need to be deferential to credentialed expert deceivers, consultants, Ministry of Environment, Chemtura etc. He simply refused to allow self-serving "facts", drivel, or psuedo science to roam freely within the Technical Advisory Group (TAG) while he was the Chair (Sept. 2015- Dec. 2016). Yes he was not the sole "good" Chair. There were others including Dr. Dan Holt (approx. Jan. 2012-Aug. 2015). Possibly Dr. Murray Haight deserves recognition although I admit that his Chairmanship of CEAC was prior to my involvement. ............................................................................................................................................... Media coverage of TAG during Dr. Jackson's tenure as Chair was essentially zero. That said I do recall one Woolwich Observer reporter present for a TAG meeting or two. The Elmira Independent covered ALL UPAC and CPAC meetings from January 1992 until July 2015 when they shut down. They did a generally excellent job of accurately covering who said and did what at those meetings. Since their departure, media coverage of TAG meetings has been generally non-existent. The Independent's coverage included Bob Verdun as well as Gail Martin with reporters such as Roddy Turpin (early days), Shirley Rennie, Julie Sawyer etc. The lack of media coverage of TAG has been wonderful for the MOE/MECP, CRA/GHD, Chemtura, Lanxess, Woolwich Township and disasterous for the public interest in and around Elmira, Ontario. .......................................................................................................................... In his short tenure Dr. Jackson exposed failings, lies and incompetence among the Ministry of Environment (MOE), Uniroyal Chemical, Crompton and Chemtura. He was extremely blunt with those parties and while he bluntly criticized many aspects of the work that Conestoga Rovers did over the decades he usually referred to them simply as the companiy's consultants i.e. he avoided naming them. Much of Dr. Jackson's technical criticisms made at public (Woolwich Council Chambers) in person meetings were reported the next morning here in the Elmira Advocate blog. They were also incorporated into my book "The Elmira Water Crisis: The Triumph of Corruption, Deceit and Citizen Betrayal" (2019). That book is available on the Waterloo Region Advocate on-line Blog and as well was on-line from 2019 until a few months ago at the Cambridge Advocate Website. Chapter 20 in particular decribes Dr. Jackson's words of disgust and contempt for the decades long failures to do a proper cleanup in Elmira. ........................................................................................................................................ Dr. Jackson also criticized the MOE for their blunt refusal to post warning signs regarding the eating of fish in the Canagagigue Creek. He advised that he would have confidence in a dioxin report for the creek produced by Hatfield Consultants but by the MOE "...not so much". Finally he supported cleanup via Source Removal when he stated in regards to the partial island and creekbank excavations along the creek on Crompton's property that "source removal works". ................................................................................................................................... ................................................................................................................................... Dr. Jackson lambasted CRA and friends for their decades belated understanding of the basal gravel unit at the bottom of the Municipal Aquifer in Elmira. That unit was a preferntial flow pathway for groundwater and contaminants and should have been targeted by pumping wells from the beginning. ......................................................................................................................................... He lambasted the guilty parties (MOE, Chemtura CRA etc.) for their utter failure to test for contaminants in suspended sediments in the creek ("Gig"). In fact he suggested that CRA threw out the baby while saving the bath water in that they filtered out the suspended sediments and then tested the creek water alone. ............................................................................................................................................... He (Dr. Jackson) actually laughed at the pathetic attempt to use In Situ Chemical Oxidation (ISCO) as part of the Elmira Aquifer cleanup. He suggested that what they did "...was not engineering..." and that they should have consulted experts and professionals before doing it themselves. ....................................................................................................................................... Water reinjection into the Elmira Aquifers in order to speed up the cleanup was arbitrarily rejected by Uniroyal and their consultants back in the 1990s and should not have been without serious study and thought according to Dr. Jackson. ............................................................................................ DNAPLS DNAPLS & DNAPLS: Dr. Jackson weighed in upon the longterm DNAPL coverup on the Uniroyal site. He stated that the groundwater concentrations at various wells near the eastern border clearly indicated the presence of DNAPLS (dense non aqueous phase liquids). Dr. Jackson also strongly criticized Chemtura and CRA for refusing to analyse the components of DNAPL material found around 2011-12. Myself and CPAC argued to have the samples analysed for their components but Woolwich Councillor Mark Bauman along with new CPAC member Susanna Meteer disagreed giving Chemtura the excuse they needed to ignore CPAC's overall reccommendation. ............................................................................................................................. Dr. Jackson came right out and stated that pump and treat is "...not sufficient." Basically contaminants from groundwater diffuse into aquitards and less permeable zones where over decades as the groundwater concentrations decrease there is "back diffusion" from the aquitards etc. into the groundwater. This initial diffusion and later "back diffusion" was greatly underestimated by Uniroyal/Crompton/Chemtura, CRA etc. hence the "cleanup" was not pursued vigorously enough. ............................................................................................................................................ Yours truly had made presentations to CPAC (2009) in regards to both ISCO and MLS or Multi Level Sampling. CPAC under the friendly thumb of Chemtura, Pat and Susan ignored my citizen Delegation to them. Dr. Jackson wondered why MLS was not used decades earlier on the Uniroyal site and throughout Elmira. ............................................................................................................................................ Dr. Jackson criticized the MOE's plans to test YOY (young of the year) fish in the creek for contaminants as he felt that those fish had neither the time nor the fat content to uptake most contaminants. ...................................................................................................... Dr. Jackson advised that the "...Stroh Drain may be pulling groundwater eastwards and directing it southwards." This was also the concern of Peter Gray from MTE consultants in his report to CPAC (2014). ..................................................................................................... Dr. Jackson expected a major blowup regarding the creek with the Ontario Ministry of Environment. He advised the public at a TAG meeting that there would be "...a confrontation with the MOE in the next few months regarding the downstream Canagagigue Creek." If that happened it was after his resignation and it was done behind the scenes privately. .................................................................................................................................................. Sebastian, Linda D. and David H. I believe were present during Dr. Jackson's tenure as Chair of TAG. It might be helpful if they were to examine both their memories and any notes they may have taken at the time. Woolwich Township are the proud owners of UPAC, CPAC, TAG Minutes. Years ago they refused to provide them to current CPAC members when requested. Also as long as Minutes were taken by Township employees a certain "softening" or even omission of harsh/critical comments sometimes occurred in the finished Minutes provided to UPAC/CPAC members months later. ............................................................................................................ .............................................................................................................. Sincerely Alan Marshall (CPAC & EH-Team member)