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
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