So called professional consultants (GHD) only write such drivel and nonsense when they are assured that serious and knowledgeable critics are not allowed the opportunity to straightforwardly address their inaccuracies.
Nov. 19/24
FURTHER COMMENTS & OBSERVATIONS REGARDING LUIS ALMEIDA'S SOMEWHAT HOPELESS NOV. 14/24 LETTER TO TIFFANY SVENSSON
In TRAC Question 1, TRAC requested topography information and flow path info for historic waste management units. The first effort by GHD was pathetic whereas the second was mostly non-existent. Let me advise Luis thusly: Good ground surface contour lines, i.e. topographical information is required to confirm/prove flow paths of rainfall, liquid toxic wastes etc. These topographical lines show the flow direction via gravity flow. Your provided map is crap! It fails to show all the east boundary/border topographical lines i.e. from north to south along the property line/border. You have focused on contour lines only at the south end of the site despite leakage and migration from the most northern pit (RPE-1) plus all the rest (RPE-2-5) based on Region of Waterloo and GRCA topographical maps which you have used in your past reports. Secondly some of your contour lines are not identified by elevation and others have soil sampling locations inconveniently placed on top of contour elevation numbers making them illegible. Finally of the contour lines I can read not all match the ones that I used several years ago from your published maps labelled as Region of Waterloo or GRCA sourced.
Luis suggested that there was a ditch or swale on the west side of the pits parallel to the Creek. While I don't dispute that some of the overflow, spillage etc. from the east side pits may well have found it's way into that ditch/swale unfortunately you have not indicated where that miraculous and helpful ditch/ swale starts or stops. Also just because liquid wastes are overflowing from all five east side pits doesn't mean that it all flowed out of the west side of the pits and found your ditch/swale. These five pits were partially in ground and partially above ground by your own maps and figures. Liquid contents overflowed in all directions including onto the Stroh farm. Contour lines indicate that the pits were higher than the Stroh property the length of the property line and liquids would flow eastwards not just westwards. Finally your wonderful ditch/swale did NOT run directly into either GP-1 or GP-2. It ended north of the two gravel pits at the swampy area that already had standing water/liquids in it. From there any flow in the west side ditch/swale spread out and again gravity flowed via ground surface contours south-east through the so called ”Gap” area and onto the Stroh farm where it met other migrating liquids that had flowed almost due south on the Stroh property. The 1983 Stroh Drain, Ditch & Berm (SDDB) was built for two purposes namely to drain the swampy area on both properties and secondly the Berm was to weaken the force of the flooding Canagagigue Creek which had been eroding contaminated soils from a very low lying area slightly further east on the Stroh property where much of the migrating toxic liquid wastes settled.
Luis keeps referring to the Gap area as topographically high. Ridiculous! The name “Gap area” refers to Chemtura/Lanxess intentionally failing to take soil samples in 2015 at the LOW LYING former swampy area immediately north of where the north-west to south-east diagonal ridge of high ground sits. Then when soil samples were actually heaven forbid taken on the Stroh farm at an amazing depth of 15 cm. or 5.9 inches in 2018, the 2015 stupidity (?) of taking soil samples on the entire perimeter of the Uniroyal/Lanxess east side property EXCEPT for the one low lying area that many of us toured, saw and walked on in 2019 was rectified via the addition of SS20 and SS21. Now of course even then Lanxess had to play games by including parts of the high ground at the southern end of SS20 leading to the high ridge of ground. Hence “the GAP” is merely a 2015 sampling gap and failure of Uniroyal/Lanxess that Luis and others have appropriated in an attempt to undermine finding higher concentrations of dioxins and DDT compounds by intentionally sampling the high ground exactly where everybody knows flowing liquids would not have travelled over.
By the way aerial photography actually did expose part of the flow path from the Uniroyal property to the Stroh property . It was both the 1955 and 1968 maps in a March 2012 CRA Report regarding the Gravel Pits that showed an arc if you will of bare ground running through the LOW LYING GAP from Uniroyal over to the Stroh property exactly where the SDDB was later built to join up with Martin Creek and then the Canagagigue Creek. I notice that Luis failed to mention the 1968 aerial map which a generous person would not call an intentional lie. My generosity however failed me after about the 137th lie from Uniroyal/CRA or wait a minute was it the 371st lie? This is another advantage of delay. Memories tend to weaken. Good news however Luis did mention a 1955 map which however like the rest he mentioned was not shown.
Luis really is confused. He claims that soil sampling locations S-17 (02) and SS09-15 are within the Gap area. They are not! Also he claims that previously mentioned SS20 is within the Gap area when only the most northern part of that specific area is. Furthermore his Table 1 shows a TEQ (i.e. Total dioxins) criteria of 99 pg/g or parts per trillion (ppt.). Now it turns out that this TEQ criteria is based upon MECP Table 2 criteria whereas most of the time we use MECP Table 8 criteria. I checked the 2017 and 2020 Canagagigue Creek Soil and Sediment reports and indeed Table 8 was used likely due to the samples being taken within 30 m. of surface water. Perhaps Luis would like to amend his criteria for soil samples taken within 30 m. of the Stroh Drain, Ditch & Berm (SDDB). When it comes to the soil samples along the Uniroyal eastern property line they all appear to be based upon Table 2 criteria which is likely O.K. for the further north soil samples but not appropriate for soil samples taken just across the property line from the constantly flowing SDDB.
One other small problem for Luis is that he's gotten his soil units wrong. DDT compounds (i.e. DDD & DDE as well) have always been in units of micrograms per gram or parts per million. He's got them in his personal Table 2 as picograms per gram which is parts per trillion. This basically is saying that all the DDT compounds are one million times smaller than they actually are by CRA/GHD earlier reports.
Again Luis somewhat oddly is claiming that the former gravel pit investigation included the Gap area. Well if he persists in believing that the high ground at the south end of SS20 is part of the GAP area (it isn't) then maybe he might also want to claim that Uniroyal Chemical contamination did not leak off-site because Uniroyal secretly bought the Stroh farm fifty years ago. See where I'm going with this? Professional have an answer for everything. Oh and just to upset Luis a tad more the “...surface water drainage area located at 6670 Line #86” is both a surface water drain as well as a groundwater drain. The groundwater is upgradient on the Uniroyal/Lanxess site and is somewhat diverted by the below ground surface SDDB (P.S. It's deeper than it looks and intersects shallow groundwater!)
Luis also talks about an independent Elmira community member who collected soil/sediment samples. That also is in error. There were two Elmira community members of which you know both and of which I am but one. Is Luis taking a shot here at SSA by inferring that he isn't independent or did he not know? Secondly we did not collect soil /sediment samples we collected soil samples properly, logged them, and sent them for analysis. I have seen other GHD reports claiming that our samples were soil/sediment which certainly is no more bizarre than so much of what they claim. I wonder why however they would not simply have asked the question? Ah yes I forget. I'm on mayor Sandy's, Lanxess, MECP naughty list. It really is unconscionable for any commoners without certified brown nosing credentials (i.e. cleared by Sandy, MECP, Lanxess) to offer opinions contrary to those bought and paid for by our world class polluters.
Moving along in increasingly better humour I must also add that of the lowly, miserable and cheap, minimal sediment sampling in the SDDB two hits stand out. DDD was significantly above the Table 8 health criteria and dioxin TEQ was found at a concentration of 24.4 parts per trillion (ppt) with a Table 8 (within 30 m. of surface water) criteria of .85 ppt. That is about 36 times higher than the criteria yet all the Queen's's men and all the Queen's horses couldn't get their crap together and decide that an honest, full investigation was required. Afterall you could still upgrade three roads on the west side of Elmira for a truck bypass while cleaning up the Stroh and Martin contamination on the east side.
You know there are still four more questions ahead of us but as a senior, senior citizen I'm getting ready for my nap. Congratulations to all the dishonest and corrupt parties over the decades who have stalled and delayed so successfully for so long. Some of the original citizen critics such as Esther Thur and Pat Potter are dead and others are suffering the ravages of time. Continue to keep me from speaking on an equal basis with others so far less knowledgable and competent and soon I too will be no longer capable.
Alan Marshall Elmira Environmental Hazards Team plus numerous others still vertical
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