Saturday, October 15, 2016

MORE SPECIFICS ON THURSDAY EVENING'S TAG MEETING



Thank You Sebastian for your opening question to Dr. Jackson, Chair of TAG (Technical Advisory Group). You asked why TAG members were only asked to declare pecuniary conflicts of interest. Firstly there appears to be no distinction as to whether members are declaring current or past pecuniary conflicts and secondly there are many other conflicts of interest other than pecuniary ones. Dr. Jackson clearly was surprised by your question and was unable to give what I would refer to as a considered response. Two TAG members have serious conflicts of interest whether still pecuniary or not although they certainly have been.

Dr. Jackson was all over Chemtura and their consultants (GHD) due to the "Gap" along Chemtura's south-east property line. He referenced a 210 metre gap between soil samples and a 350 metre gap between monitoring wells OW38 (northerly) and OW15 (southerly). My refernce to the "Gap" usually encompasses a 175 metre stretch parallel to the Stroh Drain where it is closest to Chemtura's eastern property line. This area is the crucial low lying location where Uniroyal's liquid wastes are most likely in large volume to have left their property and crossed over to the Stroh property.

Astoundingly TAG had the M.O.E. response to GHD's Off-Site Investigation Work Plan a couple of weeks prior to having the actual Work Plan itself. Of course other stakeholders such as myself and CPAC still don't have the M.O.E.'s comments about Chemtura's proposed investigation of the Stroh property.

Joe Kelly spoke positively about these M.O.E. comments. He feels the M.O.E. did a good job in pointing out unclear parts of GHD's Work Plan as well as other problems. Sebastian suggested deeper test pits rather than the usual 15 cm. (6 inches) only. As another hydrophobic compound (P.C.B.) was found in the Supplementary Investigation last summer, eight feet below ground surface, Sebastian's comments are right on the money.

Dr. Jackson suggested the possibility/probability that overflow or drainage from the closest east side pits, RPE-5 and BAE-1, likely discharge into the Stroh Drain. Hence the sediments in the bottom of the Drain, at the very least, will be contaminated. Dr. Jackson also kindly indicated to TAG that I had given him some helpful input and information recently. Dick (Dr. Jackson) again reminded all that it has taken the M.O.E. thirteen months to date to produce a report from data that they shared with TAG back in September 2015. Even for the M.O.E. that is pretty bad. Dick further made comments as to the so called fencing off of the creek to cattle many years ago as he mentioned that the "cattle were free to cross and drink as they go" at the New Jerusalem site. Indeed I now have pictures of that location as well as of the Northfield Dr. crossing area.

It was pointed out that criteria for Dioxins were exceeded in Tables 1,2 and 8 in the floodplain area on the north side of the creek upstream of New Jerusalem Rd.. David Hofbauer of TAG asked "Do they trigger further action in the M.O.E. world?". He then stated that the criteria and Tables were "geared towards property transfer" and that banks are the biggest users of these Tables (ie. mortgages, liability concerns) . He further suggested that the farms between Chemtura and the Grand River could not be sold because of the known contamination of the creek and floodplains. Susan Bryant suggested that the Old Order Mennonites were more likely to simply pass the farms on to the next generation rather than sell them. She also pointed out that the EPA's 2003 review of Dioxins stated that they were a Non-Threshold toxin which means that there is no safe level for them hence all these criteria were sketchy.

There was discussion between David H., Sebastian, Linda Dickson and Dick Jackson regarding the M.O.E.'s latest criteria of 48 pg/g or parts per trillion (ppt). It appears as if the lower criteria of 13 ppt is for mammals and birds whereas the higher criteria of 48 ppt is for soil contact by human beings. Both David and Dick made it clear that the M.O.E.'s proposed Human Health Risk Assessment (HHRA) will ignore harm to birds and critters with the higher criteria. Dick also pointed out that "there is no boundary between creek sediments and the floodplain". In other words the contaminated soils on the floodplain are all coming from the contaminated creek sediments during flooding episodes.

Sebastian may have started the discussion but other TAG members chimed in regarding TAG being played, intentionally delayed by the M.O.E. and overall the issues going around in circles for years. Much of this part of the discussion I posted about yesterday here in the Advocate. Dick referred to it as "running into a wall of public policy indifference and bureaucratic lethargy.". Wow I am going to miss him after his December 31/16 retirement. Further comments by Dick include "TAG's technical arguments are sound" and in reference to the Ontario M.O.E. he said "there is not a matter of good faith here." Lastly he and others said "The HHRA is unlikely to be helpful in cleaning up the creek.".

Interestingly that despite the "cringeworthy" setup of TAG (& RAC) I do see some gentle relaxing of Sandy's draconian and disgusting rules prohibiting either questions or comments from other stakeholders and concerned citizens attending TAG meetings. Dr. Jackson (Dick) recognized and permitted a comment from audience member Viv Delaney as well as once again allowing Sandy Shantz to address TAG and the public. Furthermore yours truly again twice briefly added some facts to the mix from the gallery without being hassled or threatened by Sandy.

Lastly Dick Jackson suggested that he would like Hatfield consultants to do an independent Risk Assessment of the creek as they are recognized international experts on Dioxin contamination. Dick also suggested a trip to the Environmental Commissioner regarding technical evidence that the M.O.E. are violating Ontario law.

Once again no media present to record this excellent meeting. Shame on the pack of them and yes I do sorely miss Gail Martin and the Elmira Independent since their closing.




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