FOLLOWING UP ON YESTERDAY'S "SOURCE REMOVAL" POSTING

Chemtura are between a rock and a hard place technically and factually. However as Dr. Dick Jackson has clearly pointed out the bottlenecks and lack of cleanup are not technical issues, they are public policy issues. Public policy as in the people in positions of authority including politicians are unwilling or unable to do their jobs. This would include incompetence and general ignorance on the issues as well as relatively knowledgeable politicians who like their jobs and aren't willing to take career risks for the sake of either the environment or what they see as others human health. Even "professional" bureaucrats whether at the Region of Waterloo or the Grand River Conservation Authority (GRCA) are either indirectly controlled by municipal, regional or provincial politicians or they themselves such as voting GRCA members are career municipal politicians. The last thing career politicians ever wish to do is to alienate or antagonize powerful people and institutions. That is the quickest road to political suicide.

Here in Elmira, Ontario we have needed our local municipal Council to step up, confront the Ministry of Environment and demand proper cleanup of the Uniroyal/Chemtura property. While there has been the odd former councilor over the last thirty years who individually on a Woolwich Council would have done the right thing, they have been consistently outvoted with the exception of the 2010-2014 Woolwich Council. While that Council had it's own problems, particularily Mayor Cowan, nevertheless they were not in anybody's pocket, especially Chemtura's.

All parties know where Source Removal needs to be done both on the Chemtura property and just off-site, both on the west side (Yara/Nutrite) and on the east side primarily the Stroh property although also likely grossly contaminated sediments in the Stroh Drain where it passes through the Martin farm.

The Stroh property cleanup not only includes the north-west side of the Stroh property next to Chemtura's east side pits (RPE 1-5 etc.) but also much further south in the low lying areas prior to the building of the Stroh Drain. To date Chemtura and GHD their consultants have done their utmost to avoid sampling these areas despite recommendations from both CPAC and TAG to do so.

The Martin property requires soil and sediment testing the length of the Stroh Drain as it passes through on it's way to the Canagagigue Creek. As Sebastian Seibel-Achenbach of both TAG and CPAC, as well as myself and two gentlemen from MBN Environmental have walked up the Stroh Drain through the Martin property; we have an excellent idea of where sediments have been deposited and collected over the decades.

The on-site source removal of course includes both free phase and residual DNAPL removal. While Wilf Ruland has been a major disappointment to me over the years primarily because of his failure to stand up to CRA and the M.O.E., nevertheless I was pleasantly surprised by both he and Jaimie Connelly's (M.O.E. hydrogeologist) digging in their heels in letters which were released to CPAC (approx. 2011-12) several years after being distributed to some of the stakeholders at the time. While I was a voting CPAC member at the time those letters were written, they were suppressed such that I did not receive them.

Cleaning up the Canagagigue is absolutely necessary. However do we really want to clean the creek BEFORE we fully stop the ongoing flow of persistent organic pollutants and more from the Chemtura site, into the creek? Only part of the west side of the creek and its' banks has been remediated or stabilized. Much more needs to be done there. The amount of creekbank stabilization or removal on the east side may be a function of how much contamination has flowed via ground and surface water. Keep in mind that hydrophobic POPs (persistent organic pollutants) are readily mobilized by solvents and Uniroyal discharged millions of gallons of solvent laden waste waters. Chemtura's difficult question is whether or not to admit how much from the east side flowed west directly into the creek versus how much they successfully diverted south and east to eventually go into the creek further downstream.

SOURCE REMOVAL - THE DIRTY WORDS CHEMTURA CANADA MOST HATES

Over the last week I have been posting about the toxic contaminants in the Canagagigue Creek sediments and immediately nearby floodplain soils. I have indicated both the unscientific, essentially mickey mouse sampling dates, locations and parameter choices. I have also advised of a very few specific contaminant concentrations and their locations in the creek, outside the creek (very little testing) as well as their distance downstream from the Chemtura facility here in Elmira. Just for clarity my concerns are for not only the "natural" environment including sediment dwelling organisms, fish, birds, reptiles and mammals further up the food chain but also for human beings either fishing in the creek, living beside it and children playing in and around it. Finally there are other life forms which have been affected by the toxic contamination in the Canagagigue Creek and that is domesticated animals. With my own eyes this year (2016) I have seen cattle crossing the creek, stirring it up and drinking from it. So much for the bull manure we at CPAC have been told for many years about cattle being fenced away from the creek. Just more lies from Chemtura and their friends in both high and low places. These cattle of course are used for both commercial milk production and also human consumed beef.

All these Persistent Organic Pollutants (POPs) plus other classes, contrary to Chemtura, their consultants and the Ministry of Environment's advice are not stablized. They are not locked up in the soil. They are not biologically unavailable. They have been intentionally drained via both groundwater and surface flow from the east side retention pits (RPE 1-5 & more) southwards and slightly eastwards onto the Stroh and Martin properties. Here a fraction of them have been temporarily stored both at ground surface and deeper, chemically attached to soil particles. These chemical bonds are a function of soil type as well as of Total Organic Carbon (TOC) in the soils.

Why are these toxic "sinks" still able to mobilize? Partly it's because of normal, ongoing surface water flow and runoff. The biggest problem however is the coming 100 year flood. As Dr. Jackson has advised; with climate change, it's not if it's when. In fact there is a map of the 100 year floodplain dated May 2012, in a Conestoga Rovers (Chemtura's consultant) report titled "Scoped Environmental Impact Study" dated May 2013. This map clearly shows that not only is a huge area of former waste disposal ponds submerged on the west side of the creek but also but for one high ridge of land the entire south-east corner of Chemtura including the Stroh Drain and the surrounding soils is also going to be submerged and scoured by the rampaging Canagagigue creek. These submerged soils include the most likely repository of Dioxins/Furans, DDT, PCBs and other POPs.

All of this will end up downstream most likely for many miles on both sides of the Canagagigue as well as on both sides of the Grand River. Is this bad luck or was this forseen a very long time ago Did the Ontario M.O.E. and Chemtura count on downstream flushing from the getgo to help clean the Chemtura site in Elmira

ONE NEONICOTINOID BEING BANNED BY CANADIAN GOVERNMENT

I would call it a classic case of leading from the rear. Our federal government have publicly decided that they will phase out imidacloprid over the next three to five years. Health Canada stated that "Based on currently available information, the continued high volume use of imidacloprid in agricultural areas is not sustainable". This and other neonicotinoid pesticides have been blamed for many years by scientists and others for mass bee dieoffs. The federal government also stated that new mitigation methods introduced in 2014 greatly reduced bee kills from neonicotinoid treatment of corn and soybean crops.

A Toronto based environmental group, Environmental Defence has stated that the three to five year phase-out period is too long. Health Canada are also beginning "special reviews" of two other neonicotinoids namely clothianidin and thiamethoxam.

Og great interest to me is that Health Canada's 2014 review of neonicotinoid pesticides also found that "scientific research shows long-term effects on pollinators can result from sub-lethal exposure levels. Sub-lethal exposure levels are lower levels of exposure that do not result in immediate mortality.". This is the elephant in the room for me regarding the multitude of pesticides, solvents, persistent organic pollutants and other toxic contaminants in the Canagagigue Creek sediments, soils and water. While the soluble (dissolved) contaminants have been greatly reduced over the last fifty years the rest have not. Whether all these toxins are above or below various criteria and alleged safe concentrations is irrelevant. They all have some deleterious effect upon lifeforms in and around the creek including human beings whether or not they can be scientifically measured and or proven.

Today's Waterloo Region Record carries this story titled "Feds move to ban common neonicotinoid insecticide".

SPECIFIC CHEMICALS & CONCENTRATIONS IN THE CANAGAGIGUE

The last few days I've been commenting on inconsistencies and non scientifically rigorous sampling for contaminants in our local creek. Today I will be giving just a few specific chemicals and their locations in the creek from Chemtura Canada (Uniroyal) in Elmira all the way down to the mouth of the creek where it discharges into the Grand River five miles away. That discharge is approximately 1/2 a mile downstream of West Montrose.

These following results are from Tables 3, 4 & 13 in the Ministry of Environment Memorandum released to TAG (Technical Advisory Group) dated October 31, 2016. The time frame for the sampling was 2014 and 2015.

DDT & Metabolytes in creek Sediments at Station #23 (Jigs Hollow Rd.) just upstream from the Grand River. 321 parts per billion (ppb). The LEL or Lowest Effect level is 7 ppb and the site specific SEL or Severe Effect Level is 540 ppb.

Dioxin Toxic Equivalency Quotient (TEQ) in creek sediments at 750-B, the south end of Chemtura's property. 38.48 parts per trillion (ppt). The sediment criteria is 21.5 ppt. A little further downstream past Chemtura at Station #20 the Dioxin TEQ is 63.66 ppt.

Dioxins in sediments further downstream at the New Jerusalem Rd. Station #21 are 182.27, 722.70 and 1,689.15 ppt. TEQ. The three samples represent increasing depths into the creek sediments. Keep in mind the criteria is 21.5 ppt TEQ.

Lindane (gamma hexachlorocyclohexane) (pesticide) was also found at location 750 (Chemtura) at 2 ppb. with a criteria (LEL) of 3 ppb. A quarter mile downstream it was found at 8 ppb. well above the Lowest Effect Level (LEL).

Aldrin (pesticide) was found at Station #21 (New Jerusalem Rd. at 2 ppb. which equals the LEL.

DDT & Metabolytes were found at Station #20 at 851 ppb. with a site specific Severe Effect Level (SEL) of 324 ppb. They were also found at Station #21 at 498 ppb. with a site specific SEL of 288 pbb.

Heptachlor Epoxide/PCB(74) was found at 3 ppb in the creek sediments at FP-9. This location is just upstream of the Grand River. The LEL is 5 ppb. At the same location DDT & Metabolytes were found at 133 ppb. While well below the SEL keep in mind the Lowest Effect Level (LEL) is but 7 ppb.

Dioxins were found at the next upstream location (FP-8) at 10.2 ppt. While below the criteria of 21.5 nevertheless they contribute to the toxic load all the way down the creek to the Grand River.

PAHs (polycyclic aromatic hydrocarbons) were only tested for in sediments at Chemtura and very nearby downstream sites. Benzo perylene exceeded the LEL of 170 ppb with a reading of 180 ppb. both at Chemtura and 1/4 mile downstream. Total PAHs at the same two locations were around 3,000 ppb. with the LEL of total PAHs being 4,000 ppb..


These sampling results are but a tiny proportion of all the chemicals and their concentrations found in the Canagagigue Creek and downstream Floodplain soils. The entire creek is contaminated both in the creek sediments and the floodplain soils all the way down to the Grand River. That this has not been remediated after more than half a century of knowledge is disgraceful. Thank your Ontario government and specifically the Ontario Ministry of Environment and Climate Change (MOECC).

POLYCYCLIC AROMATIC HYDROCARBONS IN THE "GIG"

Following the trend of inconsistency throughout the nearly five years of Canagagigue Creek testing, we have the example of Polycyclic Aromatic Hydrocarbons or PAH for short. They were sampled in July 1995 up and down the creek in the sediments only. This sediment testing took place from slightly above Uniroyal Chemical down as far as Station #23 (Jigs Hollow Rd. #46) just above the Grand River. Sixteen different PAHs were tested for and while none were found upstream of Uniroyal Chemical all but one were found downstream at various sampling locations. Yes that is fifteen out of sixteen parameters sampled for were detected. The concentrations vary from Trace amounts at 40 parts per billion (ppb) up to 7,800 ppb. for Fluoranthene. Keep in mind that the Method Detection Limit was fairly high in these 1995 samplings. In comparison the only other sampling of PAHs took place in 2015 and there were Trace amounts detected as low as 4.2 ppb.

In comparison the 2015 sampling was also in sediments only versus sediments and floodplain soils as were most of the other parameters tested in 1995-96. The failure to consistently measure all parameters in all the same locations over time is one of the huge failures in the Ministry of Environment's Canagagigue studies. While broad generalizations can be made when comparing data I believe that actual statistical conclusions are nearly impossible to make. That said the 1995 PAH sediment data did at least go as far down the creek as Station #23 very close to the Grand River. This is in contradiction to the 2015 data which only geographically covers the south end of Chemtura and then as far downstream as one of the Station #21 locations (ie. New Jerusalem Rd.).

The 2015 data indicate that all 20 parameters were detected (versus 16 parameters in 1995) albeit five were at Trace levels. As difficult as it is to compare geographically it appears as if the total concentrations of PAHs are slightly higher in 2015 than in 1995.

While I believe that statistically significant trends are almost impossible to conclude I doubt that that will stop the M.O.E. from doing exactly that. They have a new TAG (1 year +), a brand new Chair of TAG and proven, experienced, technically competent citizen stakeholders (CPAC) that have been marginalized, excluded and refused the right to ask questions and make comments during public meetings. This should be a walk in the park for the partners in pollution namely Chemtura and the Ontario M.O.E.. Real public consultation it is not.

M.O.E. INTENTIONALLY OBSCURING CANAGAGIGUE DATA

Outrageous and blatant best describes the Ministry of Environment's handling of the Canagagigue Creek studies. Incompetent is also a possibility albeit the Ministry's history of deceit makes the former more likely. Last spring or summer the M.O.E. had promised the final 2015 data and report by October 31/16. Dr. Jackson after advising that the roadblocks to progress were not technical they were public policy (politics); resigned as Chair of TAG effective December 31/16. This should have given him two months to study and comment on the Ministry's final conclusions regarding the contamination in the creek. Lo and behold on October 31/16 indeed another report was produced by the M.O.E. with both more data from 2014 and data from 2015 however we were advised that the final, final report isn't until February 2017, two months after Dr. Jackson is gone. It allegedly will also include more data on bio-accumulation and possibly further contaminants in fish tissues. Nicely played M.O.E..

Last Saturday I posted that the M.O.E. studies are sketchy. Further to that the M.O.E. have a bag of tricks which they employ to dissuade citizen participation and critique of their work. It includes issuing reports either the day of or after they have been presented publicly by M.O.E. personnel. This makes intelligent questioning of reports and data impossible in a timely manner.

The scientific validity of their studies are questionable. If you want to examine toxic contaminants over time in a creek then you attempt to minimize other variables as much as possible. Hence if you take ten samples at ten different locations in year one then subsequent years you would sample the same parameter at the same location hopefully around the same time of year. The same time of year is to reduce seasonal variability due to temperature, spring floods etc.. The M.O.E. absolutely have not done that. Their locations change constantly including skipping from floodplain soils in 1996 to alleged floodplain sediments in 2012 (1 location) and 2015 (several locations). To date the M.O.E. have failed to explain how or why sediments in the bottom of the creek should be labelled as floodplain locations ie. FP-1,2,3,4 etc..

Sediment locations Station #22 and #23 were skipped in 2012 and 2013 with no rationale given. Floodplain soils (FP-1 to FP-10) were skipped entirely after 1996 with the exception of FP-5 & 6 in 2012. This is not remotely a scientifically valid study. It is an intentionally obtuse, confusing, hide the forest with the trees attempt to swamp citizens with data that cannot readily be compared from year to year. It is for the purpose of thinning out public criticism and allowing the M.O.E. and their buddies Chemtura to interpret the data absolutely any way they wish without opposition.

Professional con artists would refer to this as the long con. Indeed professional thieves could take lessons from the M.O.E. in regards to duping the public albeit professional thieves steal money and valuables (jewelry etc.) whereas the M.O.E. steals our health and lifespan.

MINISTRY OF ENVIRONMENT CREEK STUDIES (the "Gig") ARE SKETCHY

Partly they are poorly written. This I pointed out to M.O.E. Biologist Mike Spencer back in 2012 and 2013. He came to CPAC to explain what he had done in these studies examining Dioxins/Furans and DDT in the Canagagigue creekbed sediments and floodplain soils. Terminology and definitions were inconsistent from report to report. For example I've lost count of the times in these numerous reports (1996, 2012, 2013, 2014 & 2015) when "sediments" and "soils" have been used interchangeably and confusingly. Also I have seen conclusions stated by the M.O.E. in these reports that I feel are not well supported by the data. For example they state that the deeper sediments in the creek have higher concentrations of contaminants. This is at best a generalization as in fact there are a number of contrary examples. Scientific consistency is a problem throughout as well. Many sediment samples go from 0-10 cm and then 10 to 20 cm only to have the next sampling round be 0-12 and 12-24 cm. for example. That is not scientifically rigorous whatsoever.

Sample locations also vary over these studies. Any study allegedly comparing data over time should have as much as possible other variables consistent. Hence DDT sampled at Station #21 in the creek sediments should use the exact same location for each and every different sampling round over the years. This has not occurred. Station #21 started off downstream of the New Jerusalem Rd. bridge in 1996 then moved upstream. Then it changed from one location to three different ones being sampled albeit close together. A skeptic could easily conclude that the samplers realized that a nearby location consistently had much greater deposition of sediments on an ongoing basis hence they moved to where they knew they would get higher concentrations of DDT and Dioxins all in the hopes of minimizing the eventual dollars Chemtura needs to spend to "clean up" the creek. This is done via a sampling bias that magnifys the number of concentrations of toxins requiring cleanup closer to the Chemtura site and minimizes the concentrations found downstream which exceed the applicable criteria. Of course when citizens are dealing with an inherently dishonest and corrupt M.O.E. these doubts are exacerbated.

The number of sediment sampling locations has always been problematic. Station #21 is located at New Jerusalem Rd., Station #22 at Northfield Dr. and Station #23 at Jigs Hollow Rd.. In other words we have but three sediment sampling stations spread over a creek distance from Chemtura to the Grand River of over 7 kilometres (5 miles). Making the huge and unrealistic assumption that these three sites are representative of the whole seven kilometres of creek is sketchy at best. Then when we look carefully at the amount of sampling for the two furthest downstream we find that they have been sampled far less than Station #21. Station #21 was sampled in each of the five sampling years. Stations #22 and #23 only in 1996 and 2014. You of course will never find what you do not look for. Finally think about this. If we assume that these three sites are representative of seven kilometres of creekbed then we must understand that the entire creek is contaminated not just the miniscule area around each sampling location. Hence the entire creek needs to be cleaned up.

Suggestions that both Dioxins and DDT are at higher concentrations closer to Chemtura are borne out at some locations, sometimes. Unfortunately they are also contradicted by the data sometimes. DDT for example back in 1996 was found at the highest concentrations in the sediments just downstream of Regional Rd. #22 (Station #22). It was also found at the highest concentration in the floodplain soils upstream of Station #22 albeit closer to Stn. #22 than #21. Similarily Dioxins were found at the highest concentration in floodplain soils upstream of Station #22 and the second highest of these ten sample sites was upstream of Station #23 midway between Stn. #22 and #23. Dioxins were also found at higher concentrations in 1996 in the creek sediments at Station #22 and #23 than at Stn. #21. All this begs the question as to why the sampling focus on Station #21 since then unless it is to simply be able to sell a small cleanup to Chemtura and to bamboozle the public.

Sampling bias also includes what parameters are tested for. Dioxins and DDT have been relatively consistent in their sampling. The "dirty dozen" pesticides from the Stockholm Convention have not. Endrin, aldrin, BHC, heptachlor, endosulphan, chlordane etc. tested for in 1996 have not been tested for since. *** [Oops! 7:08 pm. They weren't tested for in 2012 and 2013 but were sampled for in 2014 and 2015] My bad. Similarily PAHs (polychlorinated aromatic hydrocarbons) were tested for in 1996 and again but once recently. PCBs have only had a few types tested for and found twice in the creek. What about all the others? What about testing for them as often as Dioxins and DDT? All of these sampling biases and failures serve to minimize the human and environmental health hazards in the creek thus allowing the M.O.E. to order (ha! negotiate) a much smaller cleanup.

In the first paragraph I had referred to the M.O.E.'s claim that the concentrations of contaminants are higher in deeper sediments. They also now are publicly advising downstream landowners that these deeper sediments are not biologically available to wildlife and humans. Both these statements are not borne out by the facts. There are many results in both the sediments and the floodplain soils where shallower samples are either higher than deeper ones or at worst extremely close in concentration. Perhaps another significant factor (variable) might be the time of year that sediment samples are taken. Again however the M.O.E. have not been rigorous in keeping their sampling dates consistent. That said what used to be the biggest flooding time of the year namely the spring freshet may have been supplanted by climate change induced more vigorous storms throughout the year. Regardless one would expect that heavier rain events would result in greater flushing of sediments and greater mobilization of deeper sediments along with their being transported downstream and into the Grand River.

I have found one striking (to me) fact while studying this data. To my surprise flooddplain soils generally appear to have much higher concentrations of both Dioxins and DDT than do creek sediments. At least in the original M.O.E. Jaagumagi and Bedard study (95-96) they did. From that point on things get confusing courtesy of the M.O.E. apparently using the same alphanumeric descriptions for Floodplain (FP-1,2,3 etc,) SOIL locations AND for Floodplain SEDIMENT locations. What the bloody hell! This refers back to my first paragraph where I referred to Soils and Sediments terminology apparently being used interchangeably. Well maybe they aren't. I believe I've just had a small epiphany. This may well be the M.O.E. intentionally or possibly stupidly muddying the waters so to speak. Keep in mind I believe I raised this issue with Mike Spencer (M.O.E.) regarding the 2012 study. Only three Floodplain sites were sampled for soils namely FP-1, FP-5 and FP-6. FP-1 appeared to be tested for Sediments rather than soils which was why I asked Mr. Spencer what was going on. His answer was inadequate and unclear, whatever the reason. Then there were no Floodplain sites tested in 2013. Lo and behold the 2014 study also seemed to be conflating ( mixing up) Soils and Sediments in reference to what had been Floodplain Soil locations namely FP-1,2,3,4 etc.. Also keep in mind that by the time we received the 2014 results (Sept. 2015) Mayor Shantz and Councillor Bauman had removed CPAC and myself intentionally from being able to either speak or ask questions at public meetings involving Chemtura or the Ontario M.O.E.. Anyhow as of now I believe that they are indeed sampling sediments in the creek while using Floodplain names ie. FP-1,2,3 etc.. Talk about a bait and switch.

Hence there are three issues. Firstly if indeed Floodplain Soils downstream have not been tested for since 2012 but rather those locations have been changed into sediment testing locations then this is a huge sampling bias against floodplain Soils. Those downstream results were much higher for both Dioxins/Furans and DDT than the sediment results in the 95-96 sampling. Therefore by eliminating them and focusing only on sediment results downstream, the M.O.E. have artificially once again focused attention only upon lower concentration sediment sites probably in an attempt to pretend that the downstream is not a problem. Secondly if indeed as was clearly demonstrated in the 95-96 sampling; the downstream Floodplains are much more contaminated with Dioxins/Furans and DDT then they are also likely much more contaminated with PCBs, PAHs and Persistent Organic Pollutants (dirty dozen etc.). Finally (thirdly) this raises the question. How can floodplain Soils all the way down the creek have higher concentrations of contaminants than the creek which is the initial source to the Floodplain soils? The answer may be extremely troubling. The bulk of the contaminants via suspended sediments are constantly travelling down the creek and discharging into the Grand River. The Floodplain soils are only "enriched" after flooding in the creek has carried contaminated suspended sediments over the creekbanks and deposited them on the floodplains. In other words the creek sediments are constantly being resuspended into the water column during high flows and moving all the way down the creek. The Floodplain soils on the other hand are not being either eroded or resuspended nearly as readily or often. They are more stable plus they are not nearly as often submerged or in contact with heavy flows of water as the sediments in the bottom of the creek are.

This may be why Dr. Richard Jackson has been so insistent upon suspended sediment testing in the creek and why the M.O.E. have been so reluctant to do so. If indeed the bulk of the contaminated sediments are constantly being transported downstream then that magnifies the obvious size of the problem of their ongoing discharge from the Chemtura site as they are constantly being refreshed and redeposited in the creek . Secondly it puts in perspective the fact that our heritage river, the Grand, may well be displaying "adverse effects" from the mouth of the Canagagigue Creek for who knows how far downstream. This may be a can of worms that the M.O.E. do not want to open.

These reports spread over five years, as the final complete report is due in February 2017, I believe are intentionally obtuse, difficult, poorly written and misleading. Dr. Jackson likely could have cut through the final report due next spring but he is retiring at the end of December 2016 and we will have a new Chair of TAG. Meanwhile yours truly and CPAC are intentionally excluded from full participation in both TAG and RAC meetings. No pointed and embarrassing questions for Chemtura, GHD or the Ministry (M.O.E.). No verbal Delegations to TAG and but four times a year can we address RAC. This has been the purpose of getting rid of CPAC as full partners and stakeholders in this very public environmental disaster. After Dr. Jackson is gone there will be exactly zero stakeholders with even a tiny fraction of the knowledge, expertise and history as CPAC and myself have.