Monday, April 27, 2020


Well why would we expect anything less from that company? From Dominion Rubber, Uniroyal, Crompton, Chemtura or now Lanxess; whatever their name and presumably wherever their location they are leaders: just not leaders in ethics, transparency, accountability, or understanding that the public who live and work near their facilities are stakeholders with rights. Yes I know that they and every other industrial concern have worked and paid for political influence via lobbying and donations and they have been successful in obtaining a favourable to themselves, legislative environment.

Last Friday I posted here an article titled "Is that rotten fish I smell or is it simply disgust at the "Lets make a deal" cleanup criteria of the Ontario M.O.E.?" In the last paragraph I suggested that there appeared to be some procedural problems as to date I had been unable to locate either the Phase Two Environmental Assessment (EA) nor a Remedial Action Plan for the Chemtura site in Guelph. Well that still stands however I have been able to locate (damn-in my own files ) an April 10, 2017 report from Peritus Environmental titled "Summary of SubSurface Investigations 120 Huron St. and 0 Oliver St., Guelph, Ontario. Those two addresses of course are the Chemtura Canada addresses in Guelph. This "Summary" does advise that GHD consultants on behalf of Chemtura did produce both a Phase One and a Phase Two EA, both dated 2008. This is a little odd as the Phase One EA that I have produced by GHD is dated December 2007. Oh well it's at least close, date-wise. Keep in mind that Peritus are the company that did the Risk Assessment (RA) in 2016 on behalf of the former Varnicolor Chemical site in Elmira, now known as Elmira Pump. I was promised the completed RA and as yet have not received it. Elmira Pump assure me that the Ontario MOE/MECP are to blame as they desperately want it in order to obtain a Record of Site Condition (RSC) from the MOE in order to sell part of the site for above ground commercial storage. I am disappointed with this document from Peritus. It's likely not any worse than anybody else's but I, through my wife, know the owner/founder. I've actually had him in my home four years ago giving myself, my daughter, Dr. Dan Holt and Rich Clausi a tutorial in regards to the Draft RA. I found the RA quite acceptable. Also keep in mind that GHD (formerly CRA) are the decades long consultants to Uniroyal and all their later iterations.

I don't care for gilding the lily. I don't like reports whose text does not scrupulously adhere to the data found and presented. One minor example are sentences such as the following: "The GHD investigations concluded that all soil and groundwater samples satisfied the applicable Ministry of the Environment and Climate Change (MOECC) generic Site Condition Standards (SCS) ...with the following exceptions:...". I swear to God they then on the next page list volatile organic compounds, BTEX compounds, metals, semi-volatiles, and pesticides both in soils and groundwater. What the hell! There is also simply too many references to things like "low level concentrations" of contaminants either in soils or groundwater. "Low level concentrations" my old and wrinkled butt! Soils are HIGHLY contaminated with multiple different metals, some above criteria such as lead, zinc, cadmium, mercury, and with lots more toxic metals below criteria such as arsenic, barium, chromium, cobalt, copper and vanadium. Other soil exceedances include acenapthylene, anthracene, benzo(a)pyrene, fluoranthene, phenanthrene and numerous others. Groundwater is the same with some contaminants above criteria such as toluene, vinyl chloride, trichloroethylene, DCA, DCE, some petroleum hydrocarbons, dissolved metals (chromium, cobalt, copper, lead, selenium, vanadium, zinc), and NITROSOAMINES such as NDMA above criteria with NDEA, NDBA, NMEA, NMOR present below criteria. Other Volatile Organic Compounds present but below criteria include benzene, carbon disulphide, dichloroethene (DCE), ethylbenzene, xylene, methylnapthalene. Finally there are other toxic compounds in groundwater present which do not as yet have criteria such as methylphenol.

It is my opinion based upon technical reports written by Chemtura's consultants that this site was a disgusting, contaminated mess for decades. It is difficult to believe that zero residential neighbours were not impacted. It is only fair to also add however that some of this contamination may have been present prior to Chemtura's (Uniroyal) alleged purchase in 1988. Apparently there is evidence of much earlier occupation of the site by Uniroyal (1971) and perhaps even Dominion Rubber earlier than that. Other industrial companies also occupied the site.

Lastly there were serious excavations ongoing a couple of years ago. How much they cleaned up I currently do not know.

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