PUBLICLY CALLING OUT RAC & THE OTHER GUILTY PARTIES

Following is a copy of the written Delegation spoken to RAC (Remediation Advisory Committee) last Thursday evening. I bluntly advised that the Elmira cleanup has been handled corruptly. They and others received their written copies yesterday. .................................................................................................... ................................................................... ............................................................Oct. 7, 2021 ................................................ RAC ............................................................................................................. ......................................................................................... I'm here today to give you a little history as well as update regarding the Stroh Drain, Ditch & Berm (SDDB) which was constructed in 1983. The 1980s were a time of desperate cleanups for Uniroyal and not only because of the Ministry of Environment 1984 Control Order. The day of reckoning was on the horizon and Uniroyal were in the process of consolidating chemical wastes as well as closing some west and east side pits and ponds. They had a visual mess on their south-east corner and it extended to the even lower lying area across the property line onto the Stroh property. In August or September 1983 when the water table was low, excavations began. The ostensible purpose was to drain the swamp. This swampy area has been marked as such by Conestoga Rovers on maps (April 2013 Dwg. C-02 A. Loney) plus the draining of the swampy area was confirmed at a public CPAC meeting by Jeff Merriman of Chemtura. ............................................................................................................ I believe that the Stroh Drain, as incredibly necessary as it was to get rid of the foul contaminated ground and surface water, served other purposes. The Canagagigue Creek when in full flood took a shortcut across the Uniroyal and Stroh properties, gouging and eroding soils as it went. It then flushed and deposited these soils into the Canagagigue Creek where they ended up in sediments, creekbank and floodplain soils to be shared with downstream Old Order Mennonites among others. ........................................................................................................................ Not only did the Stroh Drain lower the water table but with the contents of the excavations all piled on the east side of the Stroh Drain, a major Berm was constructed. To this day that Berm is much higher than the surrounding lands which while still vulnerable to flooding, are less prone to major soil erosion than they were before; as the force of the flooding Canagagigue Creek is deflected southwards away from the low lying area that is the likely repository of dioxins/furans, DDT and more. I expect that this was a negotiated deal between Uniroyal Chemical and the Ontario MOE that was then presented to Mr. Earl Stroh as the SDDB was built on his land. The Grand River Conservation Authority have since helpfully provided flood maps of the area showing how the Drain, Ditch and Berm may lessen the force of the flooding creek. .................................................................................................................... Currently I am aware of five separate but overall buttressing pieces of evidence that suggest large scale flow of Uniroyal contamination onto the next door Stroh farm. Firstly is the surficial soil samples showing both dioxins/furans and DDT in excess of soil criteria on the Stroh farm, along the property line with Uniroyal. These soil samples were taken in soil that has been in constant use growing crops during the fifty-one years since most but not all of the overflowing east side ponds were removed from service. Despite tillage, wind erosion and possible crop uptake, they still had DDT and dioxin exceedances. Secondly there has been NDMA discovered in a deep aquifer 240 metres eastwards and cross-gradient by groundwater flow but down gradient by surface water flow. Thirdly we recently were advised that both DDD and dioxins/furans were found in the sediments of the Stroh Drain by Lanxess's consultants, GHD. Three of the four detections exceeded the criteria for dioxins/furans in sediments. Fourthly we have the topographical maps kindly provided by Conestoga Rovers, Ministry of Environment, Region of Waterloo etc. They clearly show that overflowing wastewaters from Uniroyal's east side pits/ponds would readily have ended up in the low lying bowl shaped area on the immediate east side of the north end of the Stroh Drain. ............................................................................................................. Keep in mind that each and every piece of evidence adds to the overall conclusion of toxic contamination on the Stroh property. Also I repeat these various pieces of evidence, whether soil, sediment, groundwater or topographical contours are not in competition with each other. Rather they are supportive of each other. ............................................................................................................................. In regards to soil samples it is common to have very high concentrations greatly in excess of the criteria for dioxins with very nearby soil samples having much lower concentrations. Clearly soil contamination, unlike water contamination, does not tend to mix together as readily. .............................................................................................................. Far too often citizens have been forced to step up to do the job that our authorities inappropriately, improperly and sometimes illegally refuse to do. Varnicolor Chemical was the poster child for Ministry of Environment corruption in Elmira. Local citizens have been forced to step up to fill the research and enforcement chasms knowingly ignored by our various authorities. ...................................................................................................................... There are two very important points left. Despite assurances of full disclosure, the Stroh Drain, Ditch & Berm were kept secret from UPAC, CPAC and the public for decades by Uniroyal, Crompton, Chemtura and the Ministry of Environment. I was heavily involved with the Uniroyal Public Advisory Committee and CPAC from January 1992 throughout the next twenty-three years. In 2014 I personally discovered the Stroh Drain while on a walkabout looking for shooting locations for Merit Motion Pictures who were doing a Documentary. .............................................................................................................................. Secondly since that time Chemtura, Lanxess, CRA, GHD and the Ontario Ministry of Environment have flatly refused to take any soil samples in and around the Stroh Drain, especially the north end. They have bullfrittered, bafflegabbed, prevaricated and quoting a TAG member been absolutely “snakebitten” each and every time the issue has been raised or suggested. ........................................................................................................ This is unconscionable especially considering that Uniroyal Chemical literally buried toxic wastes such as dioxins, not close to the Stroh property, but by their own maps literally touching the property line. Now with the known separate but supporting pieces of evidence the truth about the Stroh property is clear to honest brokers. Further truth is that Denial and Delay by self-serving parties has ruled the Elmira cleanup since 1989. The truth is that Denial & Delay have intentionally led to migration and Dilution of Uniroyal Chemical's toxic wastes. The truth is that Woolwich Township have fully captured the public consultation process to the point that most opposition are relegated to speaking to you RAC, all of what, once a year? The truth is that Uniroyal and corporate successors have knowingly delayed, hoping that their toxins would leave the site and lessen the extent and costs of any future on-site cleanup. The recent article in the K-W Record advising that the planning process is capable of protecting the public is naive and disingenuous. Dependence on the planning process literally “down the road” simply justifies and excuses further delay and resulting human, livestock and wildlife exposure to Uniroyal toxins. Shame on all the guilty parties over the last 32 years plus and counting. .............................................................................................. .............................. Alan Marshall CPAC & EH-Team member