Friday, October 18, 2019


The TAG (Technical Advisory Group) meeting as usual will be held in Woolwich Council chambers on Church St. Following are my comments on yet another recently received written response from GHD, consultants to Lanxess Canada. GHD are responding to Tiffany Svensson's August 20/19 comments regarding "Contaminants of Potential Concern" as well as her comments on the "Draft Conceptual Site Model for the Canagagigue Creek. This letter/report is part of the Agenda for next week's TAG meeting.

As an aside: recently a concerned citizen commented here in regards to Tiffany's (TAG Chair) character, ethics etc. I believe that I responded in a generally positive, supportive way while at the same time not wholeheartedly endorsing her either for sainthood or for the world's best hydrogeologist award etc. This is because I have known her professionally only for just over two and a half years. I will add however that I am fast becoming a strong believer based upon her written comments and criticisms to GHD including this one about to be discussed. In my opinion her comments and criticisms in this report are accurate, technically sound, persuasive and probing.

TAG Comment 2 references the Stroh Drain and GHD have responded that yes they will be further assessing the Stroh Drain.

TAG Comment 3 advises that 23 different chemicals in soil samples on the Lanxess site were found to exceed various criteria yet only one of them was retained as a Contaminant of Potential Concern. GHD while using the 30 metres from the Creek rationale then suggests that that is not the only reason for dropping the other substances.

TAG Comment 6 relates to the longterm use of Lindane on site. GHD have indicated that lindane will be resonsidered as a Contaminant of Potential Concern.

TAG Comment 7 is a humdinger as I quote Tiffany: "So the final concluding statement is not accurate." This refers to GHD statements that most of the historical waste management units (HWMU) have been remediated plus they are hydraulically contained by the Upper Aquifer Containment System (UACS). Ms. Svensson disputes this and she is correct. "Closing" a HWMU is NOT remediating it! Also the UACS only contains the South-west corner of the site and as recently advised by MOE hydrogeologist Cynthia Doughty the UACS doesn't contain even the south-west corner all the time as it is supposed to.

TAG Comment 8 is in regards to toluene (in particular) mobilizing allegedly hydrophobic compounds such as DDT and dioxins. GHD denys that, claiming that concentrations of toluene in groundwater would have to be in the tens of thousands per million parts of water. They do not back up that assertion with anything and then they state that the presence of NAPL (non aqueous phase liquid i.e. toluene) has not been reported on site in the last ten years. Yesterday I sent Ms. Svensson a detailed report showing data that contradicts GHD's assertions.

In regards to the second report Tiffany is commenting on (i.e. CSM for the creek) TAG Comment 4 has Ms. Svensson again emphasizing that the Stroh Drain soils and sediments need to be exhaustively examined. Essentially GHD are agreeing at least for the moment.

TAG Comment 6 is in regards to a 1999 study about dioxins found in sheep and cattle from farms along the downstream Canagagigue Creek. Dioxins were indeed found in tissues and were particularly elevated in the livers of these animals. As usual little or nothing happened. GHD have responded that they will not be using or referencing this report in their Conceptial Site Model of the creek.

TAG & Ms. Svensson then comment on the 2017 Canagagigue Creek Sediment and Floodplain Soil Investigation. 338 sediment samples were taken by the shovel method and only 24 by the more precise and accurate core method. GHD had claimed that the bottom of the creek was too hard to enable the superior coring method to be used. The problem with the shovel method is that it does not capture the fines of the gravel etc. as the coring method does. As the DDT and dioxins are attached to these fines they are lost via the shovel method. In my opinion this totally negates the value of this sampling and is shameful. Combined with the equally ridiculously high Method Detection Limits (MDL) it successfully has reduced the concentrations of contaminants found in the sediments. Junk science forever here in Elmira folks.

Thursday, October 17, 2019


I now better understand many of Cynthia Doughty's comments and criticisms in regards to the two recently released to me (& presumably some others) reports done by Lanxess Canada both written somewhere around January 2018. Keep in mind as Ms. Doughty criticized, the one report had no date on it although it was allegedly issued in February 2018.

Both these reports are informative. Giving Lanxess the benefit of the doubt one could suggest that wow, at long last we have a serious framework to get this cleanup of the Elmira Aquifers back on track. Their January 2018 document titled "Clean-Up Framework for the Off-Site Municipal Aquifer", while short of details as Ms. Doughty has stated, nevertheless does in a general sense point the way forward from where we are right now which is looking at the Elmira Aquifers not being clean or potable in 2028 as ordered by the MOE/MECP. Secondly Lanxess appear to be taking the recommendations of Dr. Richard Jackson seriously. He had advised the hiring of Dr. Neil Thompson (U. of Waterloo) to assist Lanxess/MOE with Conceptual Site Models (CSM) for both the Elmira Aquifers (i.e. the total stratigraphy or sub-surface) and a CSM for the Canagagigue Creek. Finally I believe that Dr. Thompson was also supposed to assist Lanxess/GHD in the development of treatment alternatives for the Elmira Aquifers.

Here however is the downside to what I've been reading. Despite both these documents being worthwhile and necessary, the huge question for me is why are they twenty years late? Also why are we reinventing the wheel? None of these technologies are brand new. They've been around for decades and some of them could have been used decades ago here in Elmira bringing us so much closer to having our local aquifers restored. I personally suggested that ISCO (In-Situ Chemical Oxidation) be used here back in 2009. CPAC at the time, Chemtura, CRA, and the Ontario MOE all ignored my verbal and written information. This despite the fact that the MOE had already approved the use of ISCO down the road in Cambridge, Ontario to remove chlorinated solvents from the Bishop St. site of Northstar Aerospace.

Then again with the last CPAC (Chemtura Public Advisory Committee) from 2011 to 2015 we were treated to a mickey mouse attempt by Conestoga Rovers to do a field trial of ISCO near pumping well W3. Dr. Richard Jackson has since publicly commented on their efforts and his criticisms make my words seem nice in comparison.

I see belatedly some hope here although it is dampened by the three decades plus history of deceit by the parties in charge. How can any honest and unbiased person have any confidence in the words, verbal or written, of these parties? What they do or don't do weighs a thousand times heavier with me than what they will ever promise to do.

Wednesday, October 16, 2019


Last evening I received the two documents that I referred to here two days ago (Monday Oct. 14/19). Credit can be given to Lisa Schaefer, RAC & TAG Support Person, for her timely e-mailing of these two documents after I requested them. Obviously it seems that being a stakeholder and citizen with a very long history of active participation (30 years) in UPAC, CPAC, RAC and TAG as much as regressive public consultation allows (especially for RAC & TAG), and posting six days out of seven here for nearly the last decade combined with now having written the definitive book on Uniroyal Chemical, Elmira's groundwater contamination and the flawed process to remediate it, none of this automatically entitles me or any other involved citizen to receive major, foundational documents. Therefore clearly it is my fault for not having imagined the possibilities of these two documents being written and issued to other parties nearly two years ago and hence my having asked for them by name at that time using my superior psychic powers and unparalled experience. Shame on me.

On Monday I advised readers that Ms. Doughty (MOE) strongly criticized a number of items in the two reports issued/written in January and February 2018. With Item 12. she was particularly insistent that Lanxess and their consultants GHD would NOT be revising the remedial objectives for the Elmira Aquifers for any reason. While I have not read the fourty pages worth of these two new (to me) reports yet, I have however seen the first page of the one in which Lanxess are strongly hinting at doing exactly that. Hence Ms. Doughty's comments.

I have long forecast this happening. If Lanxess/GHD can't make the cleanup to Ontario Drinking Water Standards then they will "succeed" by adjusting expectations or criteria or the deadline or amending the Control Order or whatever they need to do in order to get the win. And when push comes to shove do you really think the Ontario Ministry of Environment, Conservation & Parks will put their foot down? Please.

Tuesday, October 15, 2019


On-Site Pumping i.e. Municipal Aquifer (MA) pumping on the former Uniroyal Chemical site (now Lanxess Canada)

Prior to any off-site pumping at all (started in July 1998), the on-site pumping was not competing against or pulling against any other pumping thus they were pumping at a small 2.4 litres per second on the site. After 1998 however and the start of off-site pumping, in order to prevent loss of on-site containment, greater on-site pumping was required. Generally the on-site total pumping in the MA was around 4.4 litres per second. By 2009 and after the disastrous lack of pumping in 2008, the on-site pumping was routinely around 5.3 litres per second. This allegedly was high enough to maintain hydraulic containment on-site despite the competing pumping off-site. Of course we had been promised 6.0 litres on-site by Jeff Merriman of Chemtura but that never happened.

By the end of 2014 a monthly average of 6.0 litres per second may have occurred a half a dozen times or so in the previous few years. Mostly however on-site pumping was a fairly respectable 5.6 litres per second. Both 2015 and 2016 maintained on-site pumping in the 5.7 to 5.8 l/sec range. Then in 2017 things started to slip slightly. By 2018 however and through 2019 to date pumping has regressed to the 4.7 to 5.1 l/sec range. Not good!

Off-site pumping was very poor especially late in 2007 due to the proposed ammonia treatment system (ATS). Until November 2008 and the completion of the ATS off-site pumping was disgraceful. The MOE/MECP moaned slightly but did nothing else. The year 2009 saw pumping rates for the first time exceed 60 litres per second for four of the twelve months. 2010 had five months exceed 60 l/sec. 2011 had three months exceed 60 l/sec however with the other nine months plummeting into the 30s to 40s l/sec. The first half of 2012 was very bad although then five of the last six months exceeded 60 l/sec. 2013 and 2014 pumping rates were all over the place with three months each year exceeding 60 l/sec and nine months being in the 40s and 50s l/sec.

2015 finally saw a stabilization in pumping rates with eight months exceeding 60 l/sec. Keep in mind the excuses/reasons and promises for the future were neverending from CRA/Chemtura as to what was going on. Regardless at 60 + l/sec average monthly pumping rates the companty was still miles away from the November 2012 promises to CPAC and the public of a tripling of the off-site pumping rates from 52 l/sec to approx. 150 l/sec. 2016 and 2017 off-site pumping rates by comparison were the best and most consistent ever. Ten months in 2016 and eleven months in 2017 exceeded 60 l/sec average monthly pumping.

The first eight months of 2018 were mediocre to poor with pumping rates finally again exceeding 60 l/sec for the last four months of the year. 2019 with the exception of February has been by comparison the best ever with monthly averages for the first time exceeding 70 l/sec in May and June and the other months to the end of August exceeding 60 l/sec.

Stating that pumping rates continue to rise and fall like a toilet seat is accurate. Also the fact that on-site pumping does not appear to be rising as off-site rates rise is problematic. Are we pumping greater amounts of past contamination out of the Elmira Aquifers or are we drawing on-site contamination off-site and then pumping it as well?

Monday, October 14, 2019


I am referring to Ministry hydrogeologist, Cynthia Doughty in the title above. Perhaps"unhappy" is a little inaccurate. She is however strongly criticizing two Lanxess Canada documents both issued in February 2018 (YES 18!!!!) and obviously written earlier.

Ms. Doughty begins by advising that the second document dealing with potential Enhanced Technologies for the Lanxess site in Elmira, Ontario is unsigned and with no company name (consultants?) provided. She is clearly unimpressed with that. The first document that she is commenting on is a Clean-Up Framework for the Off-Site Municipal Aquifer. That document "...refers to section numbers; however, there are no section numbers in the document." Again it is my interpretation that she is unimpressed with that kind of amateur hour (my words) effort.

I have a little (ha!) beef of my own. Having read both the titles of these more than a year and half old crucial documents to the ongoing and constantly behind schedule "cleanup" of the off-site aquifers and having carefully read Ms. Doughty's comments/criticisms, it is my belief that I have never received those two documents. Well if so that's yet one more indictment of what passes for public consultation these days in Elmira, Ontario. I have sent a polite e-mail to the TAG/RAC Support person (Lisa) asking her to send me (belatedly?) those documents.

Ms. Doughty is also clearly unimpressed with the details or lack thereof in these two documents. Her words include (Pg. 2)"Additional details would be necessary...", "Additional information should be provided.", (pg. 3) "Additional explanation is required...", "There is insufficient information provided...", (pg. 4) "Additional details are required...".

We are advised that Lanxess and their consultants GHD are considering additional extraction wells, injection wells, and directed groundwater recirculation, whatever that might be. Ms. Doughty also would like more details and timelines for this potential new remediation method. There is also a Flowchart provided in the first document that indicates that in-situ technologies are back on the burner to be considered. Truly amazing. Both myself in 2009 and Dr. Richard Jackson in 2016 tried to get Chemtura/CRA to take this methodology seriously.

These two reports as well as Ms. Doughty make references to the actual criteria to determine when the aquifers have achieved cleanup. The old CPAC (2011-2015) and particularly Sebastian Seibel-Achenbach and Dr. Dan Holt pushed the MOE/MECP hard for this information. The MOE/MECP once again gave a future date to present this criteria that is now long past without fulfilling their promise.

On the last page, item 12. of Ms. Doughty's critique she in no uncertain terms advises Lanxess that the remedial objectives will NOT be revised based upon remedial technologies selected. Similarly settling upon unambiguous cleanup criteria will NOT revise the remedial objectives.

It is clear that Ms. Doughty is not satisfied with Lanxess's efforts in these two documents. Only time will tell how much Lanxess improve upon them. As always the public are the losers when both guilty parties literally spend years talking back and forth about remediation that is already years behind schedule.

Saturday, October 12, 2019


Today's Waterloo Region Record's Editorial is a blunt in your face call to both our provincial and federal governments for real action regarding occupational health and safety issues as well as the compensation system for workers in this country. The Record acknowledge a small step forward with the most recent local 31 compensation cases being accepted but it is still far too little far too late. The Record are also advising that their preference is the gold standard, nation wide Royal Commission in regards to a public inquiry. Clearly the response for decades has been to minimize the effects of carcinogenic chemicals on the human body at local rubber factories in Kitchener-Waterloo such as Epton's, Uniroyal, B.F. Goodrich, Dominion Tire etc.

There is no shortage of studies indicating that Canadian workers have long been exposed to chemicals such as benzene, lead, asbestos, wood dust, diesel fumes etc. While many of our local industries have closed their doors and are no longer poisoning workers, can we be confident that it is not continuing either elsewhere or even here in different industries? The Record's Editorial is titled "Rubber workers' plight should inspire nationwide action".

Friday, October 11, 2019


Today's Waterloo Region Record carries the following story titled "Energy from trash? What's next for Waterloo's landfill". This story is written by Adam Jackson of the Waterloo Chronicle. Among many items, Mr. Jackson advises the readers about the existence of many closed landfills in Waterloo Region from Kitchener, Cambridge, Ayr, North Dumfries, and Woolwich Townships. He also advises of all the problems that have occurred at the former Ottawa St. Landfill site in Kitchener. At least that is he mentions the settling of garbage beneath the ground covering causing proken sub-surface pipes as well as damage to the skate park. He did not mention the horrific abandonment of homes around the landfill in the 1970s for decades due to methane leakage into their basements causing massive risks of fires and explosions.

Mr. Jackson as well as Region of Waterloo officials understate the environmental damages caused by our past burial of garbage. The fact is that improved methane collection as well as leachate collection from landfills does nothing to improve soil, ground and surface water contamination that occurred prior to any collection methods being implemented at most of these landfills. Also the fact is that not all of our former dumps have even been retrofitted (after the fact) with collection systems. They all should have been done so, decades ago. My opinion is that regional politicians would rather spend our money on sexy, vote getting projects such as the ION trains. Legacy projects to burnish political credentials usually do little for the general public.