IRONIC TIMING- I LIKE THIS MOE EMPLOYEE

His name is Abdul Quyum and he is a hydrogeologist. His chances of serious advancement to any kind of a senior management position within the MOE are likely between zero and nil, unless of course he changes his attitude. The MOE have preferred low intellect, barely competent folks along the line of Bill Bardswick. Loyalty first, brains and honesty way down the line. That's their kind of a company man.

Mr. Quyum has written a review of Lanxess's Annual Monitoring Report for 2017 and he hasn't held much back. Rest assured that Lanxess, just like Chemtura, Crompton and Uniroyal in the past, will be yelling loud and clear at the MOE about that. In polite company (ie. corrupt organizations) like the MOE, courtesy and respect are uppermost and truthful bluntness is anathema.

On page 2 Mr. Quyum suggests that there may be non-compliance issues with the ECA (Environmental Compliance Approval?) in regards to groundwater monitoring and containment in the upper aquifer, in the south-west corner of the site.

On page 3 he suggests that the municipal upper groundwater allowed to migrate off-site in the north-west may only be partially recaptured by pumping well PW4 which is unacceptable.

On page four Mr. Quyum advises that he does not support proposed changes in groundwater monitoring and he is opposed to contaminant concentration contours plotted from different sampling events. That should be obvious even to CRA and Lanxess.

On page 5 he suggests that NDMA has been migrating off-site in the south-east corner near OW105d and Ow 16i. That's a no-no.

Pages 5 & 6 are stunning. Mr. Quyum is making it clear that all the off-site chlorobenzene likely is not from Uniroyal/Lanxess and that can be confirmed with isotope analysis. Of course this could have been done many years ago but that would likely have destroyed the MOE and Uniroyal narrative supporting Uniroyal's sweetheart deal. Also Mr. Quyum's chlorobenzene comments are in line with Neil Thompson's (U.Of Waterloo) comments about excess chlorobenazene in the Elmira Aquifers in his CSM (Conceptual Site Model).

Page 6 & 7 have interesting comments about the inadequacy of DNAPL monitoring in the Annual Monitoring Report. That's hardly news again to those citizens who have followed the tortured and convoluted DNAPL thirty year coverup on this site.

Lastly Page 8 advises us that there are issues with the Mann-Kendall method used for Trend Analysis of contaminant concentrations. This lay person has known that for decades. The Mann-Kendall method misses all kinds of trends whether up or downwards in contaminant concentrations.