CPAC GENTLY PUSH, CAJOLE CHEMTURA INTO DOING THE RIGHT THING

Last night's CPAC meeting in Woolwich Council Chambers was another gamechanger. CPAC through reason, quiet confidence and persuasion are slowly digging the ground out from under Chemtura's decades plus non cleanup plans. From the Chair Dr. Dan Holt to Sebastian, Ron, Vivienne and Councillor Mark Bauman they are working together as a team and logically undermining the shaky foundations of the Chemtura/M.O.E./CRA longterm psuedo cleanup.

Ron Campbell expressed it well when he referred to both the on-site as well as the off-site pump and treat programs as actually both being nothing more than containment programs. This is not the position of the polluter and their alleged regulator, the Ontario Ministry of the Environment. Ron also pointed out that back on October 7, 1991 , then Ontario Environment Minister Ruth Grier promised the public via a Press Release that ALL buried wastes would be removed. This is also what the November 4, 1991 Control Order demanded. Unknown to the public, until recently, the M.O.E. on October 7, 1991 had negotiated a private deal with Uniroyal (Chemtura) giving them an Indemnity for known contamination once they had removed two east side consolidation pits (RPE 4 & 5).

Sebastian got the ball rolling with a request that the M.O.E. do a cost benefit analysis of continuing their financial contributions to the off-site pump and treat versus putting some of that money towards source removal. Mark added that "...continually sucking out of the ground..." seemed like a waste of money. Steve Martindale of the M.O.E. defended their position by stating "...kill a contract, go to court...". He was referring to the November 4, 1991 Control Order. At that point I clarified the discrepancy between the Control Order and the private October 7/91 Settlement Agreement/Indemnity.
The Control Order specifically named the west side ponds (RPW 5,6,7 & 8) as having DNAPLS beneath them and requiring source removal.

Dr. Dan asked a very simple question of George Karlos of the M.O.E. namely would he drink water from the Elmira Aquifer when Chemtura's site was still heavily contaminated. George moved up several notches in my opinion when he honestly stated no he wouldn't. Mark Bauman also put them on the hotseat by suggesting eventually Chemtura will leave and put the Ontario taxpayers on the hook. Therefore the M.O.E. should partner with them now and remove what on-site source contamination they can. Sebastian also put things into perspective when he used Chemtura's words back at them and suggested that they Chemtura would not be pumping on-site in perpetuity. The reality is that companies wind up, fold, go bankrupt eventually and when Chemtura head back to the States, they'll leave their on-site mess behind.

Once again I was very pleased with Mark's contributions last evening. He asked whether In Situ Chemical Oxidation worked on breaking down NAPLS which it does. He further suggested that a combination of shallow excavation and ISCO could be workable to remove DNAPLS as well as dissolved contaminants. Both Ron and Sebastian kept on the theme of pumping "in perpetuity" being a poor plan. As Sebastian indicated at some point on site sources will leak and in fact historically that's exactly what has happened. Ron pointed out how much worse the on-site contamination is compared to overall off-site. He also reiterated CPAC's position that they would like a professional technical consultant to assist SWAT and CPAC with detailed peer reviews of Conestoga Rovers reports.

It appears as if Chemtura don't like the present public set up of CPAC meetings. They initially proposed private technical meetings like they've had in the past. Councillor Mark Bauman jumped on that fairly quickly and appropriately said CPAC would not be sitting down privately with Chemtura. Chemtura also made it clear that they would be in charge of the meeting and that "...the smaller the better..." when it comes to who speaks. This matter will be further discussed here this coming Monday.

CANCER RISKS DUE TO CHEMICALS IN LOCAL INDUSTRIES

Today's Waterloo Region Record carrys this story "Former Goodrich worker warned others of cancer risk". Campbell Robertson died Saturday of bladder cancer which the Workplace Safety and Insurance Board (former Workers'Compensation) blamed on his relatively brief time working at BF Goodrich in Kitchener. The rubber industry use a wide array of carcinogenic chemicals in their processing of rubber into various products. Company names mentioned in the Record's article include Dominion Tire, Epton Industries, Uniroyal and Canadian Consolidated Rubber.

One of the chemicals mentioned in this article is betanaphthylamine which is an antioxidant used to prevent the rubber from breaking down prematurely. It has been banned since the 1970's for use in factory production. Unfortunately various naphthylamines and other carcinogenic compounds that were used in local industry can end up not only in the air but also in the ground and groundwater. Elmira has a who's who of carcinogenic compounds from various sources still so located. Also just to put things in perspective bladder cancer was being diagnosed in Germany back in the 1880's amongst workers at Hoescht Chemicals. There chemicals similar to those used in the rubber industry were being used in the dyes and pigments industries.

The former Varnicolor has significant quantities of naphthalene in their groundwater. Naphthalene is essentially two benzene rings joined together. Naphthylamine would consist of an amine joined to naphthalene. Amines are one of the building blocks to our NDMA found throughout Elmira with the A in NDMA standing for Amine.

Getting back to Elmira reminds me of one of the longstanding excuses used by Chemtura. During the late 90's when they were fumigating the citizens on Duke St. during the night; they insisted that the fumes weren't toxic they were simply odourous. Basically they were saying that these fumigations won't kill you, they are simply unpleasant odours. I wonder if the same excuses were used by either BF Goodrich or any other companies when workers complained of smells and other symptoms?

Many of these manmade chemicals are highly toxic. Some of them eventually get banned after the fact. Health effects can be immediate or down the road. One thing you can count on and that is that citizens and workers have not and will not receive adequate information early enough to protect themselves and their families.

TOMORROW EVENING IS THE PUBLIC CPAC MEETING

The Chemtura Public Advisory Committee (CPAC) meets tomorrow evening at 6 pm. in the Woolwich Council Chambers on Church St. in Elmira. Usual participants include now five CPAC members appointed by the municipal council, Chemtura usually with three present, two or three SWAT (soil, water, air technical) team members including yours truly, the Ministry of the Environment with one to three present, the media usually being only the Elmira Independent and finally any members of the public which can be from one to half a dozen.

It has become much more apparent over the last few years that the true purpose of the Ontario M.O.E. supporting a public advisory committee was basically public relations. This is also why Chemtura have been there mostly consistently since 1991 or so. The real business was done privately with Settlement Agreements, Indemnitys, Orders and other behind the scenes meetings and documentation. The public advisory committees were meant to be nothing more than foils for the dissemination of propaganda from the polluter and alleged regulator. This is relatively easily achieved by giving CPAC the mushroom treatment ie. keep them in the dark and cover them with shit. This has been ongoing since the beginning. It is literally years and decades after the fact that gamechanging Orders, Indemnitys and Agreements reach the public venue. All of this is why Chemtura are so enraged with the current CPAC who understand what they are doing and are not cooperating with this agenda.

Chemtura perhaps via a suggestion from the Chemistry Industry Association of Canada (CIAC) are promoting private "mediation" sessions with a couple of CPAC representatives. CPAC, always courteous and respectful, appear to be willing to waste their time on this fruitless exercise.

Tomorrow night will feature discussion around the so called five year updated groundwater plan. The SWAT team have looked this over and will comment. The M.O.E. are supposed to comment on downstream testing of DDT and Dioxins in the Canagagigue Creek. As expected and contrary to CPAC's request it looks as if they and SWAT will not receive this technical data ahead of the meeting. If so this will follow two decades plus of the previously mentioned mushroom treatment. Chemtura will be presenting their Monthly Progress Report (Feb.) which usually is no more than a cheerleading attempt to justify their non cleanup. They will also hopefully be answering a long list of questions presented by the SWAT team, mostly pertaining to their alleged tripling of their off-site groundwater pumping. This plan including potential off-site chemical oxidation (source removal) is in response to CPAC's and Woolwich Council's Resolution of last spring condemning the two decades plus pump and treat program promoted by Chemtura and their partner, the Ontario M.O.E..

The public are encouraged to attend and provisions are available for them to speak as delegates or ask questions through the Chair during the meeting.

HONEY BEES AND INSECTICIDES

Despite an environmental tragedy in regards to a massive bee kill; there is a positive in the mix. Farmers and beekeepers are talking and attempting to find a solution . Yesterday's Waterloo Region Record has this story "Beekeepers meet with farmers to discuss how to avoid "bee kills". The following groups have been holding discussions since last fall namely the Ontario Beekeepers Association, Ontario Federation of Agriculture, Christian Farmers Federation of Ontario and Grain Farmers of Ontario. The concensus seems to be that insecticide dust released from seeds is highly toxic to bees. Apparently when the seed is handled during the planting process a dust can come off of it and be blown into the air. Also as the seeds are pretreated it pretty well removes the option of not using the insecticide if the individual farmer has reason to believe that a particular field isn't suceptible to particular insects.

While this cooperation is an excellent way to go nevertheless one must not forget past failure with insecticides such as DDT and thinning of birds' eggs or even of herbicides such as Agent Orange and the human health costs. Rachel Carson said it well when she stated that these are poisons we are producing and human intelligence is sometimes overuled by the profit factor. I'm not a farmer but clearly under certain weather and soil conditions, pests will thrive and cause crop damage. They must be controlled but hopefully not at the expense of the farmers' neighbours.

CHEMTURA FEBRUARY 2013 PROGRESS REPORT

This monthly report has a couple of surprises this month. The front page has a "noteworthy items" section which advises that the Canagagigue Creek "...contained a detectable concentration of toluene (34 ug/l)...". This is a huge understatement as a detectable concentration normally refers to a concentration just above the detection limit which is in the area of .2 ug/l. Secondly while advising us of this toluene concentration in the surface water of the "Gig" they mysteriously ignored an even higher concentration that is in the middle of a Table in the middle of the report. This would be Table C.1 and is Acetone at approximately 86 ug/l. The very next table (Table C.2) is the one that routinely shows downstream arithmetic means higher than upstream ones for usually NDMA, NMOR, Toluene and or Ethylbenzene. This month, rather strangely at first blush, we do not have Toluene with a higher downstream arithmetic mean than upstream. This is unusual and doubly so as we have such a high concentration found upstream in Table C.1 . NDMA and NMOR are as usual higher downstream than up and this particular question was put to Chemtura at the last public CPAC meeting. They have indicated that they will repond to it at this Thursday evenings (6 pm.) public CPAC meeting held in the Woolwich Council Chambers.

There are some conclusions which could be reached from this data. Firstly slugs of contaminants move through groundwater on their own timetable. Secondly once a month testing is by no means conclusive. It is literally hit and miss. Thirdly the dilution factor in surface water is immense. Years ago when surface water testing routinely was showing six to ten chemicals in the "Gig", the quantity of contaminants in the groundwater discharging to the "Gig" had to be huge in order to be caught regularily by testing and after dilution in the creek.

The pump and treat system has for a number of months been performing way above its' historical averages. During February the on-site pumping at PW4 and PW5 was excellent. Keep in mind that the word excellent rarely appears in any of my postings dealing with Chemtura. The off-site pumping for wells that have been very problematic over the years namely W5A, W5B, W3 and W4 met or exceeded their targeted pumping rates. This also rates at least an "attaboy". Old reliable namely well E7 at the extreme south end of Elmira has spoiled this month's picture. It has pumped at a massive 26.5 litres per second for years and done so with excellent reliability. This month it fell to 20.8 l/sec. Hopefully this problem has been rectified and "old reliable" can get back up to speed.

While hydraulic containment is not the answer on its' own for restoring Elmira's groundwater; nevertheless it is a component and it would behoove Chemtura to continue their efforts to maintain their pumping rates on all their wells.

MODERN TOXIC WASTE DISPOSAL AT CHEMTURA

Yes I'm still on Chemtura's 2012 Annual Monitoring Report that came out this week. Page 82 advises us that between 2011 and 2012 Chemtura, while in the process of digging a trench in their south-west yard (M2), came across and removed 290 buried drums. Most of these would have been buried with their toxic contents back in the fifties and sixties. Contrary to mythology the human race had full knowledge at that time that this behaviour was extremely damaging to the environment as well as to human and animal life. The purpose of burying these drums was out of sight and out of mind. They have sat there rusting away and draining their contents into the ground and groundwater for over fifty years. Our wellfields were shut down almost twenty-five years ago, yet these readily accessible and shallow drums were permitted to drain their contents even while the Ontario Ministry of the Environment stood idly by. It's been a decade since local citizens requested in writing that they be removed. Shame on Chemtura and the M.O.E..

On another note on the very next page (83) we learn that surprise, surprise Chemtura have just found xylenes and toluene in wells that they haven't been found in before. That these wells are downgradient from the highly contaminated, including non aqueous phase liquids, Main Tank Farm (MTF) is not a surprise. Years ago we learned of this subsurface contamination and Chemtura and the M.O.E. did what they do best which is talk about it and "monitor" it. By the way xylenes and toluene are both petroleum hydrocarbons and courtesy of Chemtura and multiple neighbours they have shared them with Elmira's groundwater for decades.

Chemtura have claimed that they remove buried wastes as they come across them. Back in 2004 their general manager publicly claimed that they didn't still have buried wastes. In that sense at least the conversation is slightly improving.

PETROLEUM HYDROCARBONS IN ELMIRA'S GROUNDWATER

Traces of petroleum hydrocarbons were in Elmira's south wellfield back in 1989. Massive quantities were in the soil and groundwater beneath both Varnicolor Chemical and Uniroyal back in 1989. Varnicolor of course was closer to the south wellfield than Uniroyal and did not have a creek running down the middle of their property to flush away their toxic sins. Currently we still have free phase petroleim hydrocarbons on the Chemtura site allegedly hydraulically contained. Specifically toluene has been under the surface of their property floating on the shallow water table and was first belatedly reported to UPAC (Uniroyal Public Advisory Committee) back in the mid 90's.

Last summer and fall we were treated to psuedo science extraordinaire by both Chemtura and the Ontario Ministry of the Environment (M.O.E.). They claimed that there weren't free phase DNAPLS behind (west of) Varnicolor 100' below ground. They also claimed that stained soil, odours and iridescent sheens brought up by the drilling rig from 100' below ground were most likely the result of a spill of oil/fuel into the mud recirculation tank sitting on the surface. Chemtura backed this groundwater terrorist/ninja theory by claiming that petroleum hydrocarbons are not in nearby wells or widespread in the Elmira aquifers. Boy that's almost as good as the M.O.E. claiming that essentially non-existent acetone in the Elmira Aquifers has acted as a co-solvent to increase the solubility and hence concentrations of chlorobenzene in the vicinity of OW57-32R which is due west (behind) of Varnicolor on Union St..

Chemtura's 2012 Annual Monitoring report Appendix C, Table C.4 has some interesting pages dealing with groundwater results produced by Peritus Environmental last year. They examined wells essentially surrounding their clients property, the former Varnicolor Chemical. These wells included CH43 to the south, CH69 to the east, CH70 to the west and OW56 to the north. CH70-D in the Municipal Lower was correctly quoted by CRA/Chemtura as having 1,150 parts per billion (ppb) of petroleum hydrocarbons and chlorobenzene at 1,480 ppb. Interestingly Chemtura/CRA went to great lengths to dispute these findings of Peritus claiming that there were not petroleum hydrocarbons, only chlorobenzene. This included reorts dated August 29/12 and September 26/12.

I am not sure why CRA/Chemtura would reproduce this allegedly inaccurate information in their Annual Monitoring Report. Also very strange is this quote from their August 29/12 report "Furthermore, the lack of TPH (total petroleum hydrocarbons) in groundwater samples collected from monitoring wells in the vicinity of OW57-32R suggest TPH is not widespread in groundwater.". This is very strange because Table C.4 has petroleum hydrocarbons detected in every well surrounding the old Varnicolor site and very close to OW57-32R.

There are also nine or ten other specific compounds detected by Peritus in these wells that are recognized components of gasoline or jet fuels, both handled by Varnicolor Chemical. Also interesting is that the math all adds up. The petroleum hydrocarbons are broken down into the various carbon fractions namely F1, F2, F3 and F4. Further the F1 fractions are broken down as to with or without BTEX chemicals which are benzene, toluene, ethyl benzene and xylenes. These four chemicals are also detected individually and as I stated the math all adds up. These readings from Peritus are accurate and I would love to know if CRA/Chemtura ever advised Peritus Environmental that they were publicly disputing their information last fall and now reproducing it unchanged in their own report.

I have in detail here in the Advocate given my opinion as to both Chemtura's and the Ontario M.O.E.'s position regarding DNAPLS at OW57-32R as well as their opinion on petroleum hydrocarbons in the Elmira aquifers. This I've done on the following dates: Aug. 6/12, Aug. 31/12, Sept. 28/12, Sept. 29/12 and Nov. 3/12.