THE "SDDB"

I and one or two others over the last thirty years have been in a position to be able to coin original phrases regarding the Elmira Water Crisis. Wally Ruck of Uniroyal did it with his early and infamous "NDMA is not in our vocabulary." quote. Susan Bryant did it with her "Adjusting the science according to your needs" in reference to Conestoga Rovers on behalf of Uniroyal Chemical. I have over the decades coined phrases such as describing the Ontario Ministry of Environment as "partners in pollution" with Uniroyal and their successors. I also felt no difficulty in naming the Stroh Drain as exactly that based upon my being the first member of the public to discover, photograph and make public the existence of this extraordinarily relevant, topographical feature immediately beside the Uniroyal/Lanxess east side property line. This past spring after further discoveries and revelations based upon the April 11, 2019 site tour as well as new, more accurate flood line maps from GHD, I renamed the Stroh Drain the Stroh Drain, Ditch and Berm (SDDB).

As I mentioned yesterday it certainly appears as if Lanxess through their cozy relationship with Woolwich Township's mayor (pretend) have called a timeout. Even with hand picked citizen representatives by the mayor (pretend) it seems as if Lanxess and their consultants GHD are feeling the heat. This is based upon the inherent intelligence, honesty, and decency of most of the TAG members including their Chair. Have no doubt that the Chair, whether paid directly or indirectly (i.e. Lanxess) by Woolwich Township must follow orders. This is the old "He who pays the piper, calls the tune" scenario and is well loved by politicians and others of similar ilk. That said it is my hope (and belief) that Tiffany Svensson has a line in the sand that she will not cross because both pretend mayors and multi national, multi billion dollar corporations usually do not.

TAG's first Chair, Dr. Richard Jackson, had a line in the sand and he made it clear to TAG and the attending CPAC and public what it was. The minute he understood that the Elmira cleanup problems were not technical ones but were "public policy" issues, he submitted his resignation. Ms. Svensson to date is willing to continue pushing for cleanup improvements both to the Elmira Aquifers and to the Canagagigue Creek despite knowing that governance will and backbone are historically lacking. She has the advantage over Dr. Jackson in that she is leading a now more experienced group of TAG members versus the brand new folks who started with inherent belief and confidence in the MOE (MECP) and who certainly early on were reluctant to rock the boat until they had more knowledge and experience with our local situation. Therefore her response to "public policy" failures will be somewhat dependent upon how much support TAG members continue to give her. Without that strong support she is putting her neck on the chopping block and our local powers have shown their love of using the chopping block even on informed and honest Woolwich volunteers (i.e. CPAC).

IT'S STILL ALL ABOUT THE STROH DRAIN

I've recently been refreshing my memory regarding TAG meetings held in January and February of this year. Boy there was a significant amount of deflection and distraction going on by Lanxess and GHD. I posted here a number of articles describing those TAG meetings as well as the May 9, 2019 TAG meeting. Those postings were January 25, March 1, May 10 and 11, 2019.

Also between these TAG meetings was the April 11/19 site tour. I have already stated here that I believe that tour was a disaster for Lanxess and a big reason why TAG is currently on hold until August 1 and RAC until September 5. It is just like in the bad old days at CPAC between 2000 and 2008 when Pat Mclean would arbitrarily shut down public CPAC meetings either for her or Crompton/Chemtura's convenience. Well convenience was only part of the reason. When things, credibility wise, weren't going particularly well for the polluter they tended to space out the meetings more. This allowed greater time for the guilty parties to rethink and reshape their position and for citizen volunteers to forget the specifics and details of their criticisms and concerns.

Various suggestions and comments from Lanxess and GHD regarding the Stroh Drain, the "Gap" area, the topography and hence the final destination of past overflowing east side pits (RPE 1-5) border on the absurd. Those ridiculous, illogical and even ill conceived excuses are exactly that: excuses. Some of their suggestions regarding sampling locations are just as bad. Now if all evidence and logic points to a "sink" of dioxins/furans and DDT in area "A" then instead of actually sampling Area "A" let's instead move upgradient and test there where we think these contaminants travelled on their way to Area "A". We'll call this area "B". Or in the alternative let's move several hundred metres downstream in the Stroh Drain and test the water, sediments and creek soils there. We'll call that area "C". Therefore if we find anything untoward or suspicious at Area "B" or "C" then maybe we'll go back and take a look at Area "A" after all. This is the kind of Catch 22 gamesmanship and nonsensical logic that has plagued the Elmira cleanup for the last thirty years.

NON-COMMUNICATION

Chemtura and CRA made their brag at CPAC in November 2012. They were going to TRIPLE the volume of off-site pumping and treating of the municipal aquifers. Now they did suggest that further study of matters such as ground subsidence and depletion of the aquifers was necessary. To date I can advise that in the last seven years not one public word of either matter has ever been brought forward to CPAC, RAC, or TAG by Chemtura/Lanxess or Conestoga Rovers. It's as if those particular matters/concerns have simply dropped off the face of the earth.

Months to a year or two later Jeff Merriman of Chemtura began talking about DOUBLING the amount of pumping and treating of the municipal aquifers underneath Elmira. As stated, there was still zero mention of ground subsidence or depletion of the aquifers due to greatly increased groundwater pumping. Mr. Merriman also failed to clarify why the promised tripling of pumping had suddenly become a mere doubling. You know it's almost as if Chemtura had been speaking privately to somebody outside of the purview of public CPAC meetings. Somebody perhaps who was no longer a formal representative of Woolwich citizens but whom Chemtura and the MOE still relied on to make deals. Somebody or bodies who set up a group outside of the formal CPAC to talk to Chemtura, CRA, and the MOE. A shadow committee if you will. This sounds an awful lot like the ACC which stands for APT Chemtura Committee which was set up after the new Todd Cowan council bounced Susan Bryant and Pat McLean from CPAC in 2011. The ACC met on the Chemtura site and discussed environmental and cleanup issues in Elmira.

Whether it was the CPAC Chair Pat McLean not passing on all information she received to voting CPAC members such as myself from 2000 to 2008 or her and Susan making deals on their own with Crompton/Chemtura/MOE behind CPAC's back during the same time period, it was counter productive. From the lack of communication from the company and MOE to CPAC members also between late 2010 to September 2015, it has since become clearer that communications with the public were being sidelined and sidetracked. This example regarding pump and treat promises falling into the void never to be heard from again is but one such item.

This is why all UPAC and CPAC meetings were to be held in public. These public meetings were also attended by the media (Elmira Independent) from 1992 until July 2015. This is exactly why individuals allegedly representing UPAC or CPAC should never have been communicating privately outside the UPAC/CPAC forum with Uniroyal/Crompton/Chemtura or Lanxess. Finally this is why the company and the Ministry of Environment should never have been sitting down publicly with CPAC from 2011 to late 2014 while also holding private, by invitation meetings only, on their property with the ACC. This gave our local polluter and their lapdog regulator far too much wiggle room on issues. On each matter they and they alone chose which citizens they wanted to go along with. This was an intentional undermining of formal, public consultation. In fact it made a mockery of true public consultation and at the end of the 2010-2014 term of Council (and CPAC), our world class polluter chose which type of "public consultation" they preferred. Obviously they preferred the Mclean/Bryant version where everything is done in private and even small corporate or government tokens of appreciation to the deal makers are acceptable.

CHEMTURA LAST DITCH PUFFERY REGARDING 2028 DEADLINE

Well we've gotten rid of Josef Olejarz of Chemtura and his nonsense as stated in the Woolwich Observer on December 15, 2012 namely "Our intention is to meet the deadline. We have no reason to believe we won't meet the deadline." Unfortunately that still leaves lots of client driven consultants not to mention the ever loyal (to their "clients") MOE (MECP).

At a CPAC meeting a few days prior, Chemtura and their consultants, CRA, unveiled a 3D model of the groundwater under their site and under Elmira. Of course they had had this model for several years and just decided to share it with the public and CPAC in December 2012. Also we learned that as part of the payoff (my opinion) for past cooperation they had years prior given a copy of this 3D computer model to Susan Bryant. She had not shared it with either CPAC, UPAC, her colleagues, the public, and probably not with her fellow APT members if any other than Shannon Perves Smith still exist.

Dr. Dan Holt addressed Woolwich Council and it absolutely incensed Chemtura. Dwight Este of Chemtura denied that the verification team from the Chemical Industry Association of Canada (CIAC) had rejected Chemtura's latest attempt to be reverified under *Responsible Care. Dr. Holt had advised Council that a discussion among the verification team members made it clear that they were not satisfied with Chemtura's efforts and public outreach. While accurate, nevertheless the verification team members including Pat McLean reversed themselves and gave Chemtura their verification. For me this was the final straw with the CIAC. I felt that like their predecessors the CCPA they were no more than a public relations facade, promoting Canadian chemical companies so called outreach and dialogue with the public. It was all a sham.

STORM WATER POND OUTLET STILL NOT COMPLETED

In fact, despite the ongoing rain received as recently as last evening, the subsurface outlet hasn't even been started. Despite the fact that there were severe weather warnings issued for the Cambridge area yesterday evening and overnite, the GRCA (& MOE (MECP)) apparently are satisfied to allow muddy water to bypass the intended outlet area and discharge into the reservoir outside of the boom that is floating in the water to catch silt and sediment. What a way to run a railroad folks.

The boom is located appropriately to catch muddy discharges as the storm water gravity flows to the Lions Trail and presumably then flows across it to discharge ten feet down the slope into the Woolwich Reservoir. The problem is that the muddy discharges are not flowing directly across the Lions Trail and directly into the Reservoir. Instead as the trail itself is on a slope the muddy water is turning ninety degrees to the right (north-east) and flowing down the trail back towards the dam itself. Eventually it finds its way down the slope into the Reservoir well away from the sediment and silt containment booms. Oh well at least the booms look nice and allow the GRCA to pretend that they've done everything possible.

My guesstimate is that we are getting very close to this situation having been ongoing for about two months now. This despite my having sent a number of e-mails to both the GRCA and the MOE (MECP). Oh well as they've demonstrated for decades now, toxic solvents and more being discharged into our public water bodies by various corporate entities don't get them very excited so why should silts and sediments?

HUMAN HEALTH STUDIES LONG REFUSED SO WHAT ABOUT ANIMAL STUDIES?

Out of sight, out of mind. Contaminated deep aquifers under Elmira can't be seen, smelled nor the water consumed anymore. Hence for most , no problem. The contaminated soils, sediments and water in the Canagagigue Creek on the north and east sides of town are rarely seen by locals. The vast majority here in town do not swim or fish in the creek, especially with the warning signs posted on the bridges crossing the creek between here and the Grand River just downstream from West Montrose. Fish studies have been done and they are very bad news. But hey, fish aren't cuddly and if we aren't eating them then who cares?

Well for starts the wildlife in and along the Canagagigue Creek downstream of Elmira care. Fortunately for the provincial Ministry of Environment as well as municipal and regional politicians, they don't vote. Many animals scavenge on dead fish. Others predate upon them such as herons, hawks, eagles, mink, muskrat, raccoon. Perhaps the odd hungry coyote or fox makes the occasional meal from a fish found in shallow water. Certainly this month carp can be readily seen and heard splashing in the shallows as they spawn and are vulnerable to being caught and eaten.

All the dioxin, DDT, PCBs and mercury then move up the food chain. These toxic chemicals will negatively affect wildlife as much or more than they affect human beings. Birds of prey suffer egg shell thinning from DDT exposure which resulted in the prohibition of DDT. The current levels in creek bank soils and creek bottom sediments far exceed both provincial and federal criteria. The concentrations in fish in the Canagagigue Creek also far exceed tissue residue guidelines (TRG) designed to protect consuming wildlife. Isn't it far past time to determine how far up the food chain these toxins have travelled? Isn't it far past time to determine the ongoing damage to wildlife from our collective failure to remove these contaminants from the natural environment?

I'm sure that Lanxess and the MOE wouldn't object. After all they could spin these studies out literally over a minimum of five years and possibly even for ten years. This would give them yet another excuse to keep the shovels out of the ground and refuse to start the decades overdue cleanup of the Canagagigue Creek.

FURTHER QUESTIONS, SOME CLARIFICATIONS REGARDING SURFACE WATER RESULTS

Questions first. Why the inconsistency in format, month to month, in Table C.1 in these monthly Progress Reports? Some months five Volatile Organics (VOCs) are allegedly sampled and other months thirteen are. Similarly some months thirteen Base Nuetral Acid Extractables (BNAs) are sampled and other months only seven. Pesticides and herbicides the same thing. One month it`s only Lindane and the next month supposedly eight pesticides are sampled although as with the VOCs and BNAs the specific compounds names are not listed. That`s a little bizarre. Also why are the detection limits (RDL) and provincial water quality objectives (PWQO) listed in some months and not in others. Is there actually a rationale for these ongoing changes in format or is it simply to keep citizen readers confused and unable to understand what is going on in surface water. The last question I have is why does the January 2019 Lanxess Progress Report refer to Table C.2 in the text but in fact it isn`t included in Appendix 2. In fact it`s nowhere to be found.

A possible clarification. It would be nice if each and every month at the bottom of Table C.2 if the authors would advise how Non Detects are calculated as numerical concentrations. I suspect that this may be part of the reason that some of the numbers stay the same over long periods of time as well as having identical concentrations with other compounds. In other words if the detection limits are identical and two different compounds are both non-detect then possibly their published concentrations in Table C.2 could end up being the same. Quoting Cochran`s statistical test or the Behrens-Fisher test isn`t that helpful to ordinary citizens.

One item that readers need to understand and that is that surface water can and does hide a number of contaminants simply by the volume of flowing water involved. It`s also important to understand that that volume of water can and does change dramatically directly related to recent precipitation. Therefore all non-detects at a flow rate of 2000 litres per second as during spring runoff really doesn`t tell us much as `dilution is the soultion to pollution` still in Ontario. Even at 400 litres per second flow a small amount of contaminant released into the Canagagigue Creek is unlikely to be measured unless the timing and location of the release and subsequent measurement are equisitely in tune. Measuring surface water but once a month allows an awful lot of water to flow downstream unmeasured (i.e. 400 litres per second X 60 seconds per minute X 60 minutes per hour X 24 hours per day X 30 days per month). Sometimes we get lucky and catch the contaminants, most times not.