Following is the speech I presented publicly last week at the Rural Roots venue following the showing of the Documentary "Toxic Time Bomb" by Sheba Films. Again kudos to the owner Roger Jutzi, organizer Sadi Goertz, Master of Ceremonies Rich Clausi.
FEB. 21/24
Elmira's Environmental Awareness Event
One company has been in full charge
and full control of the failed Elmira cleanup. That is the polluters
themselves namely Uniroyal Chemical and then their corporate
successors which currently is Lanxess Canada. The Ontario Ministry of
Environment are the alleged regulators. They have proven to be
pathetic and wholly incapable of protecting Elmira's environment and
citizens.
Since 2012 local residents known as the
Citizens Public Advisory Committee (CPAC) have advised both Woolwich
Township and the public that the 2028 mandated deadline for clean
groundwater in Elmira was not going to happen. Uniroyal/Chemtura, at
the time, along with the Ministry of Environment denied that.
Chemtura six months later advised that in order to meet the deadline
they would have to TRIPLE the amount of groundwater pumping and
treatment in Elmira. This of course never happened, or even close.
Somewhere around 2017 the new owners Lanxess began to suggest that
the 2028 deadline could not be met.
Multi national, multi billion dollar
corporations do not like to admit failure, especially publicly.
Currently they along with other parties such as the Ministry of
Environment and Woolwich Township are in CYA mode. This Cover Your
Astuteness includes suggestions for a new source of drinking water as
well as a new Order from the Ministry of Environment. It's not as if
any of the old Orders have done much good to date.
The parties have recently been trotting
out various excuses for trial runs. One of these is to blame a
chemical process known as Diffusion. Essentially as the groundwater
concentrations of at least 100 different chemicals such as NDMA,
chlorobenzene, ammonia, toluene, xylene, styrene, benzene got higher
and higher in the groundwater some of the chemicals began to
“diffuse” i.e. move into the clay and silt aquitards and bond
with the soils. Decades later after 26 years of up and down, erratic
groundwater pumping as groundwater concentrations of contaminants
began to decrease those bonded chemicals in the soils are starting to
be released back into the groundwater. Sometimes this process is also
referred to as “rebound”. All of this is common knowledge among
hydrogeologists yet the guilty parties pretend it's a surprise to
them.
Another excuse being used today is that
NDMA is so toxic that its' health criteria is measured in parts per
trillion. The majority of toxic chemicals have criteria in the parts
per billion which is a thousand times larger than parts per trillion.
Hence 35 years after NDMA was allegedly discovered in Elmira's
groundwater the parties are now advising that contrary to what they
told us back in the 1990s up until recently, that gosh nobody can
successfully remediate groundwater via pumping & treating down to
that tiny concentration. Again a complete reversal of what they told
us for 25 years plus.
Here are a few specific examples of
“adjusting the science according to your needs”. In order to
pretend that contaminated groundwater is hydraulically contained, a
polluter requires an observation well or two that have their well
screens able to draw in water from two different aquifers
simultaneously. This is best accomplished by having your observation
well located very close to a “window” between the two aquifers.
This “window” is actually an area where the clay or silt
aquitard, which slows groundwater flow vertically between aquifers,
is thin or even totally absent allowing the higher and lower aquifer
to be in direct contact. Then an alleged lower water elevation
reading will give a much higher reading based upon the water
elevation of the connected upper aquifer. This higher reading can
then be intentionally misinterpreted as showing the direction of
groundwater flow being the opposite of what it truly is.
More specific to the Canagagigue Creek
is the following. Dioxins, DDT compounds and PCBs tend to migrate
within living bodies to the fattiest areas. This is true for wildlife
as well as human beings. In the case of fish the highest
concentrations of these contaminants are found in both the liver
(which attempts to filter them) and in the belly or other fatty
areas. So guess exactly where the Ontario Ministry of Environment
sample fish they have collected for analysis? Skinless, lean dorsal
fillets are preferred.. Absolutely no fatty areas or livers.
Next we have one of my favourites.
Normally core samplers, which are hollow tubes, are pushed into the
bottom of creeks and the sediment samples are then held inside the
core sampler as it is lifted clear of the water and set down on a
table. The core sampler is opened up and there is the sediment sample
in one long piece representing various depths below the bottom of the
creek bed. Not so here in Elmira. It appears that Lanxess Canada and
their consultants have again “adjusted the science according to
their needs.” They have replaced core samplers with ordinary
shovels. According to the Ministry of Environment's recent December
critiques of the Draft Risk Assessment, this has occurred with most
of the sediment samples taken in the Canagagigue Creek and presented
in their Soil & Sediment Investigations. Therefore keep in mind
that outside of living bodies DDT and dioxins tend to bond with soil
fines. Hence fine sediments are the normal location to find these
chemicals. Shovels however are used allegedly to break through
“armouring” on the bottom of the Creek. Certain areas have stones
and cobble on the bottom versus fine sediments. Regardless when you
draw a shovel up from the bottom of the Creek through the water
column the fines are washed away and only the stones, cobbles and
coarse sediments are left. A polluter's paradise yet again.
Finally we have the use and misuse of
Method Detection Limits (MDL). Basically laboratories have a lower
limit concentration that they are able to consistently and accurately
measure with the equipment at their disposal as well as other
factors. The key is to always be able to measure at least as low as
the health criteria of a contaminant. For example if benzene in water
has a MDL of 4 parts per billion (ppb) and the Ontario health
criteria is 5 ppb then any and all exceedances in water samples of
the 5 ppb criteria will be detected. However if the MDL at the lab
for whatever reason is 7 ppb. then any exceedances in the water
sample of the health criteria from 5 to 7 ppb. will be shown as
Non-Detect @7 ppb. Therefore what a wonderful method to both decrease
the number of exceedances as well as of detections of a contaminant.
I mentioned that the lowest limit that a lab can accurately and
consistently measure is a factor of the equipment they are using as
well as other factors. Those other factors can be “matrix
interference” which simply means that the more other contaminants
are mixed in the sample the more difficult it is for the lab to
measure at it's lowest possible concentration. Or another factor is
simply cost. The lab will charge a higher fee per sample if the
customer wants to measure the absolute smallest concentrations
possible. Think about that. If Lanxess want to save money they simply
ask the lab for a higher number MDL . This costs them less plus
produces more Non-detects and less exceedances of criteria.
These higher than necessary MDLs are
enormously detrimental as they distort the data presented in the
report. The MDL issues effect Sediments much more than they effect
Soil samples. Basically Sediment criteria are much smaller than Soil
criteria and hence detections and exceedances can be covered up much
easier when the Method Detection Limits are for example .02 parts per
million (ppm) which is considerably higher than the criteria for
Lindane, DDD, DDE, DDT. In other words those contaminants in
Sediments are the ones whose detections are most negatively affected
by much too large MDLs.
There are two more significant
matters which I would like to bring to your attention. The first is
the fact that despite numerous requests decades ago there has never
been any health studies done of either Elmira residents or of
downstream Canagagigue Creek residents. My understanding is that
there are 22 families living along the downstream Creek from
Uniroyal/Lanxess as far as the Grand River over five miles away. I am
shocked that a third party can produce an alleged scientific document
assessing health risks to these residents while studiously ignoring
health data that exists and is in the possession of our medical
authorities. Our Old Order Mennonite neighbours also use the same
health system that we do involving doctors, nurses and hospitals and
I do not believe that their opting out of OHIP and paying cash
instead, somehow makes their health records invisible to the
appropriate authorities especially in light of the risks to their
health from exposure to dioxins, DDT, mercury and PCBs.
The second significant matter is in
regards to the fact that even honest science versus the quite frankly
junk science, that Lanxess and their consultants have passed off on
us, is unable to give us all the answers we would like. To date
science has not been able to determine health criteria for either
multiple contaminants simultaneously or for multiple routes of
exposure simultaneously.
The multiple contaminants
simultaneously refers to not just the four contaminants I listed in
the previous paragraph but also literally the hundreds of others that
Uniroyal/Lanxess have discharged over the decades. The multiple
routes of exposure means exposure by breathing and inhalation
combined with skin exposure to soils and sediments as well as
ingestion of contaminants whether through milk or beef consumption
from cattle grazing on contaminated Floodplain soils.
Now to get really serious think
carefully about what our local downstream residents have lived
through for the last 75 years and longer. They and their children and
grandchildren have been exposed to the prevailing winds bringing
solvents, dioxins, DDT and much more to them from Uniroyal/Lanxess as
well as being exposed to more than 75 years of eating contaminated
food from their own chickens and cattle combined with skin contact
with chemicals attached to soils that end up in their gardens and
childrens' sandboxes. I repeat there is absolutely no way for science
to be able to determine health criteria for multiple simultaneous
chemical exposures nor is there any way for science to determine
health criteria for multiple simultaneous routes of exposure such as
dioxin fumes in the air combined with handling dioxin contaminated
soils combined with eating dioxin contaminated beef, chickens or
fish. Then add in breathing benzene fumes, handling dioxin
contaminated soils and eating DDT contaminated beef, chicken, eggs,
milk and fish. And now for the final insult to our downstream
neighbours, some non-medical, very well paid by Lanxess, folks in
three piece suits are telling them that there are no unacceptable
risks to their health.
Prior to giving you some “Where do we
go from here?” suggestions I would like to briefly summarize.
Uniroyal Chemical's on-site cleanup did not follow the Ministry of
Environment's Control Order. DNAPLS or Dense Non Aqueous Phase
Liquids in particular were covered up using grotesque manipulation
and deception by the company with the Ministry enabling the coverup.
On -site pumping and treating has generally failed over the years to
achieve the company and their consultants Target pumping rates
although they've now changed their story and state that gosh they
were only suggestions and actually pumping at those Target Rates is
optional.
So where do we go from here and what
needs to be done? Dishonest brokers can no longer be in charge of the
cleanup of Elmira and the Creek. This includes Lanxess Canada, the
Ministry of Environment and Woolwich Township. The RAC & TAG
committees are being shut down in favour of a committee called TRAC.
Unfortunately while a rose by any other name can smell as sweet,
nevertheless a horse apple by any other name still stinks. Changing
names is the equivalent of rearranging the deck chairs on the
Titanic. Other cleanup technologies in particular those involving
source removal need to be seriously considered versus the usual lip
service they get..Take the current biased and dishonest Risk
Assessment of the Creek and throw it in the garbage. That's all it is
worth. Real cleanup of the Creek needs to be done. Finally citizens
be skeptical. You've been lied to for decades regarding the Elmira
Water Crisis and that won't change over night. Ask for evidence and
independent proof from Council and others. If our local media write
stories about this meeting, TRAC or cleanup, please read those
stories carefully!
Thank You for your attention.
Alan Marshall
.