MORE ON 2013 BIOMONITORING STUDY

Here are a couple of further thoughts or ideas relating to the now biannual Biomonitoring Study. This study occurs in the late spring/early summer and involves clams and leeches bioaccumulating toxins from the water and sediments of Canagagigue Creek for only a three week period. After the three weeks the clams are removed and their tissues tested for the presence of DDT, Dioxins/Furans. The leeches are tested for chlorophenols only in their tissues. There are at least two problems that I see with this methodology and that is the short time span of only three weeks and the other is the time of year. I am beginning to see a pattern with both the downstream testing of soils and sediments for DDT and Dioxins as well as with this biomonitoring study of clams done in late spring. In other words if there is a spring scouring of sediments during high flow season (March/April) then most likely DDT and Dioxin/Furan presence is temporarily reduced. The fact that these toxins are most likely being moved downstream to be enjoyed by wildlife and humans on an annual basis is another issue that needs to be addressed.

As was mentioned in last Thursday's posting here; these toxins continue to leave the Chemtura site. It is recognized that they are leaving in reduced quantities from the past but that only is evidence that source removal is the way to go in addressing these issues versus decades more of questionable hydraulic containment. Chemtura and consultants have never been particularily forthcoming on the transport mechanisms of DDT and Dioxins. They have long argued that they can not flow in groundwater. The evidence does not fully support their position. CPAC need an honest, unbiased peer review around this report and numerous issues arising from it. As long as the Ontario M.O.E., Chemtura, Region of Waterloo and Woolwich Council think otherwise then it is clear that none of them are interested in the truth. They are still interested in short term politics versus the long term health of the environment and all living things in it.

ELMIRA INDEPENDENT EDITORIAL: "CLARITY NEEDED"

Gail Martin, editor of the Elmira Independent, wrote this Editorial last Thursday namely "Clarity needed". The previous week we the public as well as CPAC and SWAT learned that there are no written specifics surrounding Chemtura Canada's 2028 deadline for restoring Elmira's groundwater. We learned that there is absolutely no mention of whether the Bedrock Aquifer is considered part of the Elmira Aquifers and thus included in the remediation process. That the Bedrock Aquifer is highly contaminated with NDMA is undisputed. What appears disputed is whether it will be addressed in a timely fashion.

Secondly Gail Martin has rightly pointed out that Chemtura's attempts to do pilot testing of ISCO or In Situ Chemical Oxidation have to date been unsucessful. ISCO is a type of source removal of contaminants via chemically breaking them down. What Gail only briefly touched on was the plan, now a year old, to triple the pumping rates of off-site wells allegedly in order to speed up the cleanup of the Elmira Aquifers. Again to date no progress has been presented. There are major issues and studies required and while the consultants to Chemtura, Conestoga Rovers, may be doing them, that is unacceptable. When it comes to tripling the volume of mostly remediated groundwater to the Canagagigue Creek; an independent study needs to be done. Mostly remediated groundwater in moderate quantities is a far cry from even better cleaned groundwater at three times the volume. Simply exporting the contamination from Elmira's Aquifers down the Canagagigue Creek to be shared with Kitchener-Waterloo is not the solution.

ELMIRA INDEPENDENT CHALLENGES CHEMTURA

This week's edition of the Elmira Independent has two articles as well as an Editorial by Gail Martin all dealing with last week's Chemtura Public Advisory Committee (CPAC). The titles are "No cleanup target defined for Chemtura" on pg.1, "Chemtura advised to take lessons from Alberta industry" pg.3 and the Editorial on pg.4 titled "Clarity needed".

The no cleanup target refers to the lack of specicivity around how many aquifers need to be at drinking water standards by 2028. Sebastian Seibel-Achenbach and Graham Chevreau raised the issue concerning the Bedrock Aquifer in Elmira. Yours truly had read NDMA concentrations greater than 5,000 parts per trillion in this aquifer. With a drinking water standard of only 9 ppt, one can see the huge problems ahead. Conestoga Rovers gave CPAC the vague response that they were currently focusing on the Municipal Aquifers and that was adequate to address the deeper Bedrock aquifer. CPAC made it clear that the targets for 2028 needed to be clearly spelled out now as ignoring the Bedrock Aquifer issue until then was a grave error.

Regarding the pg. 3 article Pat McLean pointed out that Chemtura had broken promises that they had given in order to receive their last verification under *Responsible Care. These promises included focus groups, community newsletters and an updated, ongoing website. The irony here is that it was Pat McLean herself who handed Chemtura their last verification against the wishes of CPAC and their representative Dr. Dan Holt. The locals did not believe Chemtura remotely deserved this verification but with representatives from Scarborough and Guelph combined with Pat McLean's vote they got it. Her hypocrisy and ignorance of the facts is stunning as is her support for this company. By the way the last broken promise of Chemtura's has to do with fenceline monitoring of their air emissions. This is a pet project of Pat's and as long as she and her colleague keep giving concessions and kudos to Chemtura they will keep accepting them. Afterall the only price they have to pay is broken promises.

2013 BIOMONITORING STUDY USING CLAMS AND LEECHES

This study used to be annual and now it's only every two years. It's been going since the mid 90's and the parameters being examined for biological uptake are chlorophenols (leeches), DDT and Dioxins into clams. We at CPAC and SWAT received this study probably back in September and as there have been really only two improvements namely in 1997 (upper aquifer containment) and 2006 (excavation of island and creekbank); it's difficult to jump into this report. Nevertheless I am refreshing my memory as well as seeing a few anomolies in this year's report to date.

As expected the big drop in chlorophenols in leeches occurred after the south-west corner of the Uniroyal/Chemtura site was hydraulically contained in 1997. Chlorophenols flow readily in groundwater and were being discharged via groundwater from the south-west ponds namely RPW 5,6,7, & 8. The M2 area a former Town of Elmira dump also used by Uniroyal was also a source. Similarily DDT and Dioxins had preferentially bonded with soils and sediments in the south-west area including a small island in the Canagagigue Creek. This excavation and removal of soils and sediments also has greatly reduced the uptake of them by clams put in the creek in cages every second summer.

Here is where it gets interesting. Chlorophenols, DDT and Dioxins and Furans are still being discharged into the creek from Chemtura and being absorbed via clams, leeches and probably many other organisms moving up the food chain. Also of interest is the relatively higher quantities being found at Station 17 downstream past the Chemtura property line. This data combined with the recently found high concentrations of DDT further downstream in the Canagagigue sediments may actually force the Ontario Ministry of the Environment (M.O.E.) into action. Their long held excuse for not ordering more on-site source removal has been that everything is contained. This is absolute rubbish and the M.O.E. know it. That site, while improovements have been made, nevertheless has never stopped discharging its' toxic contaminants into the natural environment including air, groundwater and surface water.

CITY OF WATERLOO WASTEWATER PLANT DELAYS

While sewage treatment is hardly the sexiest of environmental topics nevertheless it is of huge significance. The fact that the City of Waterloo plant is four months behind schedule; in the long run should not be significant. Far more significant are updates and improvements that aren't even scheduled yet. If and when the time comes that all sewage in Waterloo Region receives tertiary treatment prior to discharge to surface bodies of water, that will be a day worth bragging about.

Right now there are gaps in treatment capacity and quality. Emergency backups for power and holding capacities still require attention. Every single year there are spills and bypasses from our wastewater facilities into receiving bodies of water. That the Ontario Ministry of the Environment authorizes these bypasses during heavy rain and or other treatment plant emergencies does not justify them. More money should be funnelled towards the necessity of keeping our Heritage River, the Grand, clean for the future . This may delay or even end various "legacy" projects that our politicians want for their self aggrandizement, but so be it. A prime example is the LRT. Put that money instead into infastructure and sewage treatment. Future generations will thank us. Today's Waterloo Region Record story is titled "Waste water plant delays costing another $1.2 million".

ENERGY SOURCES FOR ONTARIANS

There was an interesting article in the Waterloo Region Record last October 31/13 titled "Making wise energy investments for Ontario". This article was written by Tim Weis and Jeff Harti of the Pembina Institute. While they applaud Ontario's decision not to build more nuclear reactors they criticize the plan to spend billions refurbishing old ones. They claim that nuclear refurbishment is extraordinarily time consuming and expensive. Recent headlines do indicate that all Ontario residents are paying through the nose for their electricity.

Part of the calculations involve forecasts of future demand. Apparently the "new economy" ie. less heavy manufacturing and more high tech has resulted in a huge drop in electricity demand by what manufacturing we have left in Ontario. These two gentlemen are suggesting further going down the road of energy conservation as well as renewable energy alternatives.

FURTHER TO LAST THURSDAY EVENING'S CPAC MEETING

First huge point. Pat Mclean appeared as a Delegation to CPAC and she was treated with courtesy and respect which in my opinion she does not deserve. She has shown a politician's willingness to throw colleagues and serious environmentalists under the bus when it suits her purposes. She did this only partly by ganging up with the former CPAC on Dan and Vivienne at a meeting at the public library to which they had been invited a couple of summers back.

The CPAC Terms of Reference used to be totally ridiculous. Now they are merely hypocritical as our Woolwich Council pick and choose which items to either enforce or not. The most asinine terms deal with membership. The document states that best efforts will be made to invite and include environmental groups in Elmira/Woolwich. There are two groups which have led the aquifer cleanup charge since 1989 and they were specifically in mind when that term was included back in 2000. APTE were specifically excluded by this Council in the spring of 2011 as Mayor Todd Cowan had advice from a number of experts (myself included) that their leadership had strayed dramatically and politically from the path necessary to rehabilitate the Elmira Aquifers. The Elmira Environmental Hazards Team (EH-Team) via myself were put on CPAC in the spring of 2011 only to be removed shortly thereafter as the Mayor and Councillor Julie Ann Herteis sufferred hissy fits. This past summer Mayor Cowan reversed himself and along with Alan Poffenroth voted to put me back on CPAC, at CPAC's express wish . Councillors Bryant, Herteis and Bowman voted no. Hypocrisy, stupidity, pettiness and politics go hand in hand with this Council. The politics refers to the apparent voting block between Mark Bauman and Bonnie Bryant. This may be to counteract the Julie Ann Herteis/ Todd Cowan voting block.

Steve Quigley of Conestoga Rovers, longtime consultants to Uniroyal/Chemtura reminded me why I stay on top of things technically. I have found over two decades of dealing with polluters, the Ministry of the Environment (M.O.E.), consultants and other assorted experts that when pressed they often automatically resort to bullshit. They attempt to intellectually intimidate honest and involved citizens. Long ago I decided to even up the playing field by learning and memorizing everything I could in order to meet them head on in discussions, debates and arguments. It wasn't nearly as hard as I expected because they don't have either the truth or facts on their side. This time Steve Quigley tried to use the old excuse that there was a thick aquitard below the south-east corner of Chemtura's site which prevented deep penetration by DDT, Dioxins, solvents and other nasty toxins. I called Steve on this by pointing out that CRA's own reports showed otherwise. There is little or no aquitard between the Upper Aquifer (UA) and the Municipal Aquifer (MU) in the south-east corner. Steve was left sputtering which has happened often enough that he should no better by now than to be resorting to inaccurate technical arguments to back his client's position.