POLYCYCLIC AROMATIC HYDROCARBONS & PESTICIDES OTHER THAN DDT

Yesterday I wrote here about Contaminants of Potential Concern (COPC) and how they had been scoped, thinned, minimized and reduced to a tiny fraction of the total number of contaminants in and around the downstream Canagagigue Creek. Today I've been looking at Table F.2 and E.1. There are issues with them. Table F.2 is titled "Reevaluation of COPC-Canagagigue Creek". First of all the sampling appears to be done in such a fashion as to make comparison over time in the same locations impossible. Secondly even if they were in the same locations twenty years apart there are problems. If the source of fresh contamination has either stopped or even been significantly reduced then one would expect to see concentrations in sediments reduce over time as they are flushed further downstream year after year during spring high flows and also floods after heavt rainfalls at other times of the year. So what and why are we comparing here? ........................................................................................................... Table E.1 includes several Uniroyal Chemical former pesticides they manufactured. As there allegedly is no screening criteriaa Site-Specific Background Threshold Value (BTV) has been manufactured. Maybe this is a real thing and maybe it's just more junk science from Lanxess. Who's to know with Uniroyal Chemical's successors over the decades? Anyways many of the pesticides have sediment concentrations greater than the BTV. Regardless every single one is eliminated as a COPC by Lanxess. Isn't it just grand being in charge of your own cleanup? These pesticides include Endosulfanl & ll, Endosulfan sulphate, Methoxychlor, Nonachlor cis and trans. .................................................................................................................................. There are also some peculiar failures to sample certain chemicals at appropriate locations. Many PAHs (Polycyclic Aromatic Hydrocarbons) seem to have been completely missed in Reaches 1,2 and 3 which are all the downstream reaches from the Uniroyal/Lanxess stretche of the creek (i.e. Reach 4). Both selective timing and locations can grossly bias results especially if that's exactly what those in charge want to do.

COPC AND OTHER BIZARRE/DISHONEST? DECISIONS WITHIN THE CREEK RISK ASSESSMENT

First of all is this as stated a "Canagagigue Creek Risk Assessment" or is it solely a Uniroyal Chemical caused Creek Risk Assessment? Those two are a world apart. Lanxess Canada claims/alleges that Uniroyal Chemical is NOT responsible for PCBs, mercury or PAHs (Polycyclic Aromatic Hydrocarbons) found in the Creek both above and below health criteria. Does Lanxess and every other corporate owner of this Elmira site lie? Dunh...let me count the ways over the last thirty plus years. The answer is yes. However on this particular issue I don't know although the real question is are we doing a Creek Risk Assessment to determine the health & environmental risks to humans and other life forms from all contaminants present or only those that we can prove came from Uniroyal Chemical? In other words would for example the local residents down the Creek be pleased to know that their cancers and other diseases are caused by different industrial polluters than Uniroyal Chemical? Would that ease their suffering somehow? I doubt it. This should be a complete Risk Assessment of the Canagagigue Creek not of allegedly just Uniroyal toxins that are present in great amounts. .................................................................................................................................. Even Uniroyal's long list of solvents, pesticides, dioxins etc. are not remotely included in this Risk Assessment (RA). They have scoped/removed literally hundreds of toxic contaminants from consideration based upon what I perceive as frivolous and self-serving criteria and rationales. A figure of 150 different chemicals present is in the report somewhere I believe. Oddly, the rationales for exclusion given on Table D.1 Appendix D are not consistent. For example both mercury and PCBs have at least one "Not site related" rationale given but different rationales dependent upon where the sample was taken. Bizarre. Regarding PAHs they appear to blame "Elevated detection limits>screening level" in many parts of this Table which seems to me to be nonsensical. No where in this Table have I seen the claim that PAHs are not a Uniroyal compound whereas it does say so in the text. What the hell? ................................................................................................................. Overall COPC (Contaminants of Potential Concern) are a real concern of mine. Willy nilly exclusion of toxic chemicals in the natural environment including Lanxess site soils, downstream creekbank soils and floodplain soils is ridiculous. Don't even get me started on the asinine sampling biases in most of the analytical data. Yes Susan Bryant suggested that Lanxess should remove grossly contaminated soils and sediments downstream however just look at the number of samples taken in only two or three places (coincidentally nearest roads & bridges providing easy sampling access) versus the very few samples taken in less readily accessible locations. Is it any wonder that far more high concentrations were found near the New Jerusalem and Northfield Dr. bridges when they were samled so much more often than other locations? I don't think so. This entire RA project is and always has been a crock and a sham and I've said so consistently here in my posts for years, report by report filled with errors, omissions and junk science.

TAG CONTINUES TO STICKHANDLE CAREFULLY WITH LANXESS/GHD/STANTEC

So do I celebrate TAG's appropriate concerns and criticisms as ever so carefully expressed last evening at the virtual Technical Advisory Group meeting or do I condemn their bullsh.t flattery and stroking of Lanxess, GHD and Stantec egos? Both I guess. The Draft Risk Assessment (HHERA) for the Canagagigue Creek was presented by Loren Knopper of Stantec and it was an unmitigated piece of garbage. In fact I was wearing as usual my UBC (Univ. of British Columbia) sweatshirt and hoping that somebody/anybody would ask me what the letters stood for. My response was going to be either "Utter Bull Crap" or "Unusually Bad Crap". Alas other than the short on-line social time prior to the meeting, yours truly and other non approved persons by Lanxess/MECP/Woolwich Twn., are not allowed to speak. Disgusting and contemptible and it will be the most blatant and obvious failure of public consultation and this entire process eventually. .............................................................................................................. First of all as indicated in the HHERA (Risk Assessment) the Stroh property is indeed part of the "Study Area" according to Mr. Knopper. He also pointed out that there are/were 150 different Uniroyal chemicals initially considered. The fact that they narrowed them down to only four COPCs (Contaminants of Potential Concern) for the study is in my opinion a triumph of scoping, bizarre logic, self-serving psuedo science and world class puffery. Mr. Knopper confirmed that as long as PPE (Personal Protective Equipment) is used on the Uniroyal/Lanxess site (Reach 4) then all human health risks are ACCEPTABLE the length of Canagagigue Creek all the way down to the Grand River. Regarding the Ecological Risk Assessment things are merely slightly more tenuous as Reaches 1-4 are fine (i.e. Acceptable) for everything except birds and mammals. Hence reptiles, fish, amphibians, invertebrates allegedly will not be harmed by major exceedances of DDT, dioxins/furans/PCBs, mercury, beta-BHC, lindane etc. anywhere in the creek. Well sort of: the Risk assessment is ignoring excessive levels of PCBs, mercury and PAHs in the creek because allegedly they are not from Uniroyal Chemical. Yes they are in the creek but don't worry critters or humans, if you get sick or die from them it doesn't count against Uniroyal/Lanxess Canada. Isn't that just wonderful? Birds and mammals it is admitted may have some Unacceptable risks in Reaches 3 and 4 which are respectively closest to the site and the site itself (Reach 4). ........................................................................................................................... Sebastian (TAG & CPAC member) expressed concern with the lack of analytical data from the Stroh property. Two locations for sediment samples in the Stroh Drain accompanied by two soil sample results provided by myself with zero explanation/confirmation as to when, where and how they were collected. Mr. Knopper stickhandled around this very serious and appropriate concern. Sebastian also expressed interest and surprise regarding the alleged 48 pg/g (ppt) human health criteria stated in the report. After more than thirty years studying and attending public meetings on this site, that number/criteria was also news to me. Mr. Knopper defended it. Wilson Lau advised that the fish tissue results from several years ago were taken from lean tissues and thus not representative of where the bulk of dioxins in particular end up which is in fatty tissues as well as in the liver. Dr. Knopper suggested that humans only eat the lean tissues so all was well. ReallY? Are animals and predators of fish (including hawks, ospreys etc.) equally as discriminating? Wilson also had diffidulty following the rationale regarding garden produce, limited crossing time of cattle in the creek and lack of exposure to the creek of free range chickens. .......................................................................................................................................... Susan Bryant asked if there was any consideration in the Risk Assessment of pre-existing body burden of dioxins of residents along the creek. The answer was no as well as the fact that the Risk Assessment did not assess infants exposure to these chemicals through mothers' milk. David Hofbauer suggested that there actually was significant fishing in the Canagagigue Creek particularly from foot bridges in Reach 1 and 2. Ms. Bryant also asked about the very high concentrations of DDT and dioxins found in Reach 3. Mr. Knopper confirmed that in fact "statistical outliers" equaled "hot spots" in the creek. Susan suggested that these high concentrations (and toxicity) got washed into the other lower concentration data thus reducing its' obvious significance. This was similar to Wilson's comments right at the end of the meeting that "...dose averaging was a problem." Also a short duration exposure could be spread out over a long time in the various calculations. This also was not good or necessarily accurate. ................................................................................................................................. Susan B. also pointed out that Ramin Ansari of Lanxess had at one point advised that the end goal of the Risk Assessment was that it had to be acceptable to the local community. Susan suggested that leaving deposits of high concentration contaminants behind would NOT be ACCEPTABLE to the community and thus more removal needed to be done downstream. She also advised that the assumptions in the report that the land use (agricultural) would not change was "highly questionable". Sebastian Seibel-Achenbach pointed out clearly that there have never been ANY Health Studies done along the creek. The inference was clear that a Risk Assessment that has zero data regarding long exposed multi-generational local residents health is not good science or good anything. ....................................................................................................... TAG wil be sending written comments to Lanxess/MECP/Stantec etc. Unfortunately they will be far too diplomatic and far too deferential to likely persuade Lanxess to change anything.

OTHER ENVIRONMENTAL ASSAULTS UPON ONTARIO CITIZENS

Firstly the virtual TAG (Technical Advisory Group) is tonite at 6:30 pm. The main Agenda item is Lanxess's self-serving, bought and paid for, deceitful HHERA (Human Health & Ecological Risk Assessment). Much of the analytical dta has been fudged, and deceitful by all means possible. When the proponeent is absolutely shameless they can explain away anything and make bad analytical results sound like successes. The Canagagigue Creek was and is a toxic cesspool that Lanxess and fellow travellors have dressed up, painted pink and using world class puffery advised the public that health risks to human beings and wildlife are ACCEPTABLE. ........................................................................................................... Today's Woolwich Observer carries an article written by Justine Fraser titled "Coalition launches province-wide campaign for moratorium on gravel pits". The campaign is titled "DAMN" or Demand A Moratorium Now. The Reform Gravel Mining Coalition is calling for a moratorium on gravel mining in Ontario and the co-chairs are Graham Flint and sarah Harmer. Among other points they are raising is that Ontario is licensed to produce more than thirteen times more gravel every year that is actually used in the province. The gravel industry are also authorized to pump 4.6 billion litres of water a day which fortunately they don't do and don't need to do. It's simply ridiculous. The campaign is hoping that a moratorium will allow a pause in mining while an independent panel brings alternatives to the negotiating table. Currently there are more than 2,500 signatures on a petition that is circulating in support of the proposed moratorium.

"ENVIRONMENTAL RACISM MUST STOP" - RECORD ARTICLE LAST THURSDAY (Feb. 17/22)

The article was an Opinion piece by Susan Koswan and focused on long-term drinking water advisories. She particularly and appropriately was offended by drinking water advisories that remained in effect over a decade and longer. Ms. Koswan pointed out the greater likelihood of these occurring in Black, indigenous and poor communities in general. Her concerns also included Ontario's infamous "Chemical Valley" in the Sarnia area home to many including the Amajiwnaang people. While I agree with everything Ms. Koswan wrote I'm going to point out an even closer to home example of "environmental racism". ............................................................................................... Right here in Elmira we have 27 farming families located along the Canagagigue Creek downstream of Uniroyal Chemical/Lanxess Canada all the way to the Grand River. Most, nearly all, are Old Order Mennonite families. While their religious beliefs generally make them good neighbours and excellent citizens unfortunately they can also leave them vulnerable to the very same environmental racism inflicted upon Black, indigenous and poor families across Canada. Old Order Mennonites do not believe in going to Court to address grievances and assaults upon their health. This I believe was a huge incentive for Uniroyal Chemical to locate along the Canagagigue Creek in Elmira. They knew beforehand that they had a potential sewer located in the middle of their property. The only fly in the ointment was how aggressive the downstream farming residents would be as Uniroyal turned their beautiful creek into a chemical sewer. Imagine their glee upon learning that non-violent pacifists with a bias against settling issues in court would be their downstream neighbours. ...................................................................................................................................... The result is history and it is a shameful history of environmental destruction of a watershed as well as of the local drinking water aquifers. Note well that a drinking water pipeline from Waterloo quickly restored the rest of Elmira citizens' drinking water. Far too many non Old Order Mennonites would have crucified Uniroyal and all local politicians otherwise. The creek however has suffered since the mid 1940s and continues to suffer. The so called Risk Assessment of the Canagagigue Creek is a sham and a shame and glosses over more than seventy years of damage that still affects lifeforms in the creek and nearby humans. Small wonder when our authorities cheerfully allow the responsible/irresponsible corporate entity to be in charge of the investigation, Risk Assessment and final cleanup. All the rest including alleged public consultation is window dressing and greenwashing.

DAVID VERSUS GOLIATH ONLY GOLIATH'S WEAPONS ARE MONEY, WORDS, CREDENTIALISM, POLITICS, ASSUMPTIONS, PERVERSE LOGIC, TIME & IMMENSE QUANTITIES OF HORSESHIT

Brass and chutzpah. I forgot those in the title above. Oh and also confidence that nice Canadians won't too seriously point out that the Emperor is not wearing clothes. That might afterall be rude. Fortunately I'm not always nice and am sometimes rude when dealing with the likes of Lanxess and friends. ........................................................................................................................ Way back when Dr. Henry Regier referred to an earlier (2004?) Risk Assessment done on the Uniroyal site as being "Greenwashing". That pretty much describes it to a T. ................................................................................................................................. "I am in awe of the recent Draft Risk Assessment (R.A.) for the, downstream from Uniroyal/Lanxess, Canagagigue Creek which was written by a reputable company (Stantec) on behalf of the owners of one of the worst contaminated sites in Ontario if not Canada. Using analytical data which Stantec clearly point out they ASSUME is accurate as it was collected by CRA/GHD under contract to Uniroyal/Lanxess; Stantec have concluded based upon assumptions, unusual logic, wishful thinking and all missing or unavailable data being interpreted as helpful to Lanxess's interests that all is well/acceptable in the Canagagigue Creek from Uniroyal/Lanxess down to the Grand River, five miles away, with perhaps only minor issues right on the Uniroyal/Lanxess property. All the detections of toxic chemicals both above and below provincial or federal criteria have been sucessfully, verbally and in writing remediated, repudiated, denied and ignored in accordance with the corporate principles of Lanxess and their fellow travellors." ........................................................................................................................ My condolences to all lifeforms, human, wildlife, reptiles, mammals, birds, fish, and invertebrates that have suffered and or died from toxic exposures and uptake. Your mostly undocumented sacrifce over the last seventy years has significantly increased the profits paid to shareholders of this mighty corporation and we must never forget that corporate life is and always has been far more important than real lives.

OUR SOCIETY PERMITS THE WEALTHY & POWERFUL TO POISON THE REST OF US INCLUDING CHILDREN IN ORDER TO SAVE THEMSELVES MONEY

Think about it. Downstream farm children played in the Canagagigue Creek, caught crayfish, frogs and fish. Cattle waded in the Creek, stirred up toxic sediments and then drank the water. The same cattle ate grass from the contaminated floodplains. The adults and children drank milk from these cows. Children also swam for generations in the manmade in ground excavated Martin swimming pond. That pond was fed by both ground and surface water and the surface water came directly from the contaminated Stroh Drain. The flow from the Stroh Drain could be increased via adding a board to increase the level and volume of water diverted into the pipe going to the Martin pond. There has never been a formal Health Study done on either the 27 downstream, mulit-generation Mennonite farm families nor on Elmira residents as well. ....................................................................................................... None of this matters to corporate Uniroyal Chemical or their successor Lanxess Canada. Uniroyal and a multitude of corporate successors have always been treated with kid gloves by Woolwich Councils. Our local councils curried favour with the world class chemical polluter in concert with the province of Ontario (MOE/MECP) providing political cover for the companies anti-social and likely criminal activities. If in fact what they have done is not a criminal offense then the shame lies again with the province and their entire judicial system. ........................................................................................................... To add insult to injury it is the very same corporate bodies who are given their own redemption on a platter. It is Uniroyal/Lanxess who decide whether or not their admitted and long proven dumping, draining, spilling and overflowing highly toxic wastes have caused UNACCEPTABLE risks to others. UNBELIEVABLE! Where else in our society are the responsible parties for physical assaults, poisonings, diseases including cancer, immune and reproductive system diseases, diabetes and more given the complete control of investigations, risk assessments and final remediation? NOWHERE! Environmental assaults kill and maim both human beings and wildlife yet we turn a blind eye to their sufferings. ......................................................................................................................................... If a drunken driver maims and kills an innocent citizen do we permit that driver to control the process that follows including buying himself out of trouble? Of course not. But here in Ontario, Canada we permit wealthy, sober, cost cutting polluters to do much worse and then hire who they want (CRA, GHD, Stantec), provide extremely sketchy and incomplete analytical data and then their hired guns ceremoniously and pompously declare ALL HEALTH RISKS TO HUMAN BEINGS ARE ACCEPTABLE. Fuc. you they are not acceptable other than to sociopaths, psychopaths, intentional polluters and the worst criminals. Oh and maybe to our perverted JUDICIAL SYSTEM & LAWS.

AS PREDICTED HERE OVER THE LAST FOUR YEARS THE CANAGAGIGUE RISK ASSESSMENT IS A PILE OF HOT STEAMING HORSE MANURE

Multiple computer files and literally many hundreds of pages in length, The "Draft" Human Health & Ecological Risk Assessment is a mathematical conglomeration of bandaids, tortured logic, wilful blindness, acute deafness, amendments and grotesque and blatant deceit. As expected and predicted it was undertaken at extravagant length, cost and wasted special citizen serious input and attempted improvement. The two part Risk Assessment, namely Human Health RA and Ecological RA is almost equally biased and bad with the edge going to the Human Health Risk Assessment sanctimoniously advising that the risks to Human Health in all four Reaches of the Canagagigue Creek (Lanxess to the Grand River-5 miles) are ACCEPTABLE! Wow. Also the HUman Health risks arising from the studiously ignored and excruciatingly avoided Stroh Drain, Ditch & Berm (SDDB) were also concluded to be ACCEPTABLE! ................................................................................................................................. The Ecological RA was a little different. Basically we are advised that birds and mammals further downstream are of zero concern to corporate America. God who would have possibly thought that? Testimony a few decades ago at the Environmental Appeal Board hearings from a local trapper as to the condition of pelts and hides from animals living in and around Uniroyal Chemical has long been forgotten although of course the current crop of TAG members never did know about it in the first place. Allegedly Lanxess are willing to admit that Reach 4 (their site) and the next immediate Reach (3) might be a problem for birds and mammals. Awfully white of them, that. However reptiles, amphibians, soil and sediment invertebrates are SOL. It has been determined by these Environmental Racists that all risks to these life forms throughout the length of the Creek all the way to the Grand River are ACCEPTABLE. Oh and similarly the risks for the area that the wealthy supremacists call 6670 Line #86 (i.e. Stroh Drain-SDDB) are also ACCEPTABLE for these lifeforms. .............................................................................................................................. When you've dealt with professional liars and manipulators for decades it becomes easy to know that leopards don't change their spots. It's all about the long con, delay, delay and more delay until you've worn down both memories and opposition. There is so much wrong with this entire process throughout. Maybe Risk Assessment can be done even partially honestly and scientifically but NOT with these swine in charge of it. They, as usual, have bought and paid for exactly what they want which is a Mickey Mouse scoping and minimizing of human and environmental damage caused by their decades of reducing their waste costs by wilful poisoning of both the natural environment and of nearby human beings. Is it possible that three decades ago local politicians (municipal & Regional?) had their palms greased in order to deny an unbiased and honest Health Study of Elmira and area residents? Or did they simply threaten to leave town and leave Woolwich Township in the lurch if they pushed too hard for reparations?

NEXT TAG MEETING TO DISCUSS DRAFT HUMAN HEALTH ECOLOGICAL RISK ASSESSMENT (HHERA)

Well first of all the virtual meeting is next Thursday (Feb. 24/22) at 6:30 pm. To attend (but good gosh no you can't speak, ask questions or make comments) phone or e-mail Lisa Schaefer at 519 6691647 (X 6112) or at lschaefer@woolwich.ca . You will be regaled by some talking heads who especially if not TAG members will use a ton of acronyms, long words and unlikely logic to explain what dozens of people over several years have been doing to give some semblance of credibility and science to a self-serving pile of steaming hot horse manure. Lanxess are paying a lot of money in order to be able to "prove" that they are environmentally responsible and going to clean up their decades old messes in and around Elmira. Of course literally tons of their toxic wastes has already volatolized, leaked, flowed and been dumped off their site onto public and private property. Rest assurred however those inconvenient truths will not see the light of day in any of the final and formal documents if at all possible. ........................................................................................................................ First of all public consultation has been pathetic. There has been no real public consultation whatsoever since September 2015 and even before then it was constrained by illegal and immoral political and corporate activities. Every means possible to make back and forth discussion impossible with some of the most qualified, experienced and dedicated local stakeholders (citizens, residents, taxpayers etc.) have been sucessfully employed. Corruption, deceit and lying were and are the tools of the polluter and fellow travellors whether local politicians or a few citizens. ............................................................................................................ Secondly much of the raw data from the Canagagigue Creek was less than a joke. Criticism from CPAC, TAG and even the Ministry of Environment resulted in bandaids, mickey mouse "fixes" and adjustments and amendments that should not have occurred. If a submarine is repeatedly sinking do you simply start shutting hatches, screen doors and valves one at a time until you stop drowning people or do you scrap the entire technological and mechanical mess and start over from scratch? If the dying people and wildlife are in and around Elmira you just ignore them and push on ahead to attempt to complete a partial and inadequate cleanup based upon GIGO i.e. GARBAGE (data) IN GARBAGE OUT .

ELECTROHOME (SHANLEY ST.) CLEANUP: FOR REAL OR TYPICAL MICKEY MOUSE CLEANUP?

How many times have I read effusive descriptions of "world class" cleanups and the like, yet not a remediation report in sight? Today's K-W Record article by Liz Monteiro titled "Eight story apartment building setr for former Electrohome site" actually doesn't even mention the fact that the former Electrohome site was contaminated. Contaminated with trichloroethylene among other toxic substances and solvents. The article does describe the process of incorporating local residents' concerns and opinions into the redevelopment plans. Yes in today's housing shortages and high costs more housing is a good idea. I hope. It kind of depends on just exactly how much and how well the cleanup was done. ............................................................................................................................ Make no mistake regarding the seriousness of the problem. Do you recall the movie "A Civil Action" with John Travolta? Same toxic solvent involved namely trichloeoethylene or TCE. What is worse is that TCE can be either in dissolved form in the groundwater or in free phase form known as DNAPL or dense non aqueous phase liquid. Most likely it is in both forms simultaneously. Basically the free phase DNAPL dissolves very slowly in the sub-surface over decades and centuries and pollutes the groundwater to well above health standards. Then a process known as vapour intrusion can occur whereby the fumes enter through the basements into homes and the inhabitants end up breathing the fumes for decades. That is what happened in the Bishop St. community in Cambridge, Ontario where three hundred homes were affected and many residents and generations sufferred the serious health consequences. ..................................................................................................................................................... New tenants beware. Ask for copies of the cleanup plan and then find an expert willing to interpret it for you.

TOXIC LEVELS OF DIOXIN (AGENT ORANGE) HAVE EXISTED IN ELMIRA AND DOWNSTREAM CANAGAGIGUE CREEK FOR AT LEAST SIXTY YEARS

Exactly how do our governments, mandated to protect citizens, get away with such negilgence? Why are protesters blocking roads and bridges in Ottawa and Windsor, not doing the same here in Waterloo Region? Uniroyal Chemical has literally gotten away with murder/manslaughter. How many Elmira and downstream residents have been sickened (cancer & more) and died from intentional discharges of toxic chemicals in the last sixty years plus? Note I said intentional discharges, not necessarily illegal discharges as our governments were actually complicit in this mass poisoning whether by selective enforcement of laws, non-enforcement or of very careful loopholes in those lasw allegedly protecting citizens. .......................................................................................................................... At one time dioxins were considered a non-threshold chemical in that any amount or concentration was toxic to life and health. Somehow that appears to have changed as now there are criteria in drinking water, creek sediments, soils and as well in tissues of fish and wildlife. In a sense these criteria have legally permitted discharges of these toxins, at least up to the level/concentration of the mandated criteria. Now we get the bullsh.t that allegedly dioxins are legal as long as they don't exceed so many "excess" cancers or deaths per million of exposed population. Such unadulterated crap! ................................................................................................................. Dioxins can induce or exacerbate chloracne, diabetes, cancer, reproductive problems, birth defects, immune disorders, death and on and on. The legacy of multi-generations of civilians in Vietnam still sufferring from American military spraying of Agent Orange, produced in Elmira, Ontario as well as in many other North American factories, is undisputed. Agent Orange contains the impurity 2,3,7,8 TCDD (Tetrachlorodibenzo.p.dioxin) . This is the same impurity buried in the Love Canal by Hooker Chemical back in the 1950s and 60s. Hooker Chemical by the way supplied Uniroyal Chemical in Elmira with 2,4,5-T (trichlorophenol) which contained the impurity 2,3,7,8 TCDD. When 2,4,5-T was combined with 2,4-D, lo and behold Agent Orange was produced. ..................................................................................................... Just to be clear, government complicity and negligence far surpasses anything mentioned to date. Provincial governments in Canada had Agent Orange spraying programs to thin out "inferior" tree species in order to promote growth and harvesting of the more economical trees. Hydro right of ways were also sprayed with Agent Orange in Ontario and elsewhere to inhibit underbrush growth. Finally here in southern Ontario our highway ditches were also sprayed with Agent Orange in the 1960s and 70s for the same purpose. Some municipalities used it as well to limit underbrush along roads and hydro lines. So why are Canadians surprised that cancer rates are over 40% in adult populations? It is government propaganda that cancer rates are so high due to greater diagnosis etc. Our own governments, in their infinite stupidity, have assisted in poisoning our air, water and soils at the same time as they limit mandated cleanups around particularly high industrial sources of dioxins and so much more.

MY BOOK IS GAINING TRACTION

This could possibly be viewed as a a tad ironic. Oh well it could also be viewed as ironic that I have off and on for several years been involved with Dr. Dan Holt in speaking at local schools regarding the 1989 Elmira Water Crisis. There likely still are a few uninformed individuals who accepted at face value inaccurate comments made about me by a small group at a now long closed public school decades ago. In fact this latest publicity about my book (Elmira Water Woes: The Triumph of Corruption, Deceit and Citizen Betrayal) that has been published in a retired teachers' newsletter may be very fitting. Certainly I have nothing but praise and appreciation for my friend and colleague who submitted his review of my book to the Winter 22 issue of Experient. ........................................................................................................................ My book is on Amazon/Kindle and I believe it's actually in two different sections namely Environmental Law and Environmental Science. Twice it actually was the number one seller in it's category although that was based on sales over a very narrow time frame. Apparently one can read the first three chapters for free and from feedback that I have received it's been well received and appreciated. Past the first three chapters requires $9.99 being sent to Amazon which then gives you access to the entire book. I view my book through the lens of having been there literally for decades including major pre-advertised public meetings as well as regular monthly meetings between Uniroyal/Crompton/Chemtura, the Ministry of Environment (MOE/MECP) and local involved citizens and stakeholders. These public in person meetings, until Covid, were attended for decades by the media including the Elmira Independent, Woolwich Observer (1995-2005) and sometimes the K-W Record. ...................................................................................................................................... A large part of the book looks at evidence that conflicts with the official, political view. The book explores frankly quite blatantly bad and deceptive behaviour by municipal (mostly) and regional politicians as well as by our provincial ones. It explores how "do nothing" and "delay" are often the action of first choice of our politicians. Yes an appropriately outraged public can produce positive results but unfortunately when they are outraged with multi national, multi billion dollar corporations it is exceedingly difficult.

WHAT IS THE UPDATED STATUS OF METHANE CONTROL BESIDE THE BOLENDER LANDFILL?

Second question: When is the most likely time for methane vapour intrusion in homes to go boom? ......................................................................................................... Third question: What should have been done about this? ............................................................................................... .................................................................. Answer to the first question (in the title): Unsure due to Woolwivh Township's preferred communication methods which are 1) If at all possible ignore and do not answer. 2) If your back is against the wall then preferably lie until or if you see a good reason not to. U-Pull-It (autowreckers) were advised (a few years back) that the current methane probes and connected pump to release methane to the atmosphere was being replaced with a passive system that did not require a pump. In other words wind would blow a small turbine and draw the methane out of the ground that way. Of course if this has been installed as promised near the former Paleshi garage on Arthur St. n. it may have avoided that building going boom. On the other hand I am not aware of any further methane withdrawal near the east or south ends of the former Bolender landfill site. This is not good. ............................................................................................................................... Answer to question two: Firstly methane can travel either vertically upward through the sub-surface and be released into the atmosphere or it can also travel horizontally. This would explain high readings of methane on the former Varnicolor Lot 91 site just south of the First St. Landfill. Horizontal or lateral migration of methane is more likely in winter with snow on the surface of the ground. Whether frost in the top couple of feet of surface also discourages upward migration I am not sure although it seems likely. Therefore right now, as in February 12/22, it is quite likely that methane is migrating eastwards from the Bolender Landfill towards the residential homes just east of the now Bolender Park and Splashpad. Any open flame such as pilot lights could ignite it if the concentration exceeds the magic number which it certainly has in past monitoring probes. Oh and I nearly forgot that monitoring probes just north of the site by the pet food plant had high readings way back when. Who knows what they are now? .................................................................................................................................... Answer to question three: Well firstly Woolwich should not have defaulted to their Deny & Lie responses. Then Woolwich Council should have paid attention to the written recommendations that I submitted to them via a number of public Delegations. Thirdly at the very, very least they should have installed, free of charge, methane alarms in the basements of homes nearest the former Landfill site. Likely the reason that the methane has hung around so long is because of the poor installation job of the methane collection system way back in the 1980s. Full transparency is required if Woolwich decide to do the right and proper action even at this late date. Frankly I'm surprised that there hasn't already been an explosion. Perhaps a fire or two of unknown cause at the Pet Food Plant may not be quite as unknown as the public have been advised. Who knows?

METHANE ISSUES DISCUSSED IN TODAY'S WOOLWICH OBSERVER

The article is written by Steve Kannon and is titled "Where being gassy can come in handy". Apparently the federal government wants municipalities to reduce methane emissions from their landfill sites. The idea is that landfill methane emissions are responsible for almost a quarter of Canada's methane emisssions and reducing them will assist in overall reduction of greenhouse gas emissions which exacerbate climate change worldwide. The Observer article focuses on the Erb St. Landfill and the closed Cambridge Landfill both under Regional government responsibility. Also parts of the story advise that our local Bio-En facility here in Elmira is part of the solution as they are accepting organic materials (foodstuffs) diverted from regional landfills. .............................................................................................................. What is not mentioned is whether local (Elmira) closed landfills are also still producing and emitting methane into the atmosphere. I have read studies done on the former Bolender Landfill and was amazed at the volumes and concentrations well in excess of explosive levels that were present. Similarly the First St. Landfill was/is? a likely high producer of methane based upon methane gas readings taken at the former Varnicolor Chemical Lot 91 site located fifteen feet south of the former landfill. Lot 91 was put on a no development/excavation order due to those high methane readings in the subsurface. .......................................................................................................................... Overall Woolwich has demonstrated an ostrich like capability regarding explosive methane concerns in Elmira. Perhaps their plan or hope is for the methane to migrate upwards and discharge into the air rather than travel horizontally towards the former Paleshi (later U-Pull-It) buildings and wrecking yard. Also I'm sure they would rather that methane found on the east side of the site nearest homes discharge upwards into the air rather than into homes basements and contact pilot lights from fireplaces, furnaces and water heaters. If only hoping worked, Woolwich could solve all their problems inexpensively.

GRUDGING ADMIRATION : WOOLWICH TOWNSHIP/WATERLOO REGION VERSUS HAWK RIDGE HOMES INC.

THE Ontario Land Tribunal (OLT) is the successor to the much despised Ontario Municipal Board (OMB). Despised by citizens at least, much less so by developers, profiteers, schemers, aggregate companies etc. The OLT have scheduled a five day hearing for July 18/22 at 10 am. At the moment it is to be a disgusting virtual meeting making in person attendance by citizens and media impossible. I believe that technically Woolwich Township are going alone as the the OLT Case Name is Hawk Ridge Homes Inc. v. Township of Woolwich. That said both Sulco Chemicals Ltd. and the Region of Waterloo are also parties to the hearing and will present evidence and cross-examine witnesses etc. Sadly and glaringly Lanxess Canada have chosen several years back to drop out of the fight although frankly they are by far the biggest threat to the men, women and children who will end up living next door to them, across Union St. As I've written here before this entire plan is an abomination of money taking precedence over humanity. Literally many years ago Hawk Ridge were given expert evidence as to the risks to life and health involved in turning this location into residential housing. Clearly the profits to be made are such that even a many years long battle in which citizens, industries and two levels of government are on side has not changed the minds of the Hawk Ridge Homes shareholders, to their everlasting shame. ............................................................................................................................... Many years back there was an OMB hearing which Hawk Ridge lost, not due to the obvious life and health threatening presence of Chemtura (now Lanxess) but believe it or not due to the night time noise from shunting rail cars at both Chemtura and Sulco. Weird beyond belief to those of us who have spent the last thirty plus years learning about the inherent and ongoing threats and dangers of fugitive emissions, fires and explosions primarly from Chemtura although to a lesser extent from Sulco. .............................................................................................................. Woolwich Township current issues as listed in the most recent document released (Case No(s) OLT-21-001285) include noise as well as whether the proposed zoning bylaw amendment conforms to various sections of the Planning Act, Provincial Policy Statement, provincial growth plan, Regional Official Plan, Township of Woolwich Official Plan etc. The Region of Waterloo also raise noise issues and land use compatibility with a nearby waste water treatment plant and industrial facilities. They also are concerned with development adjacent to natural hazards as per the Provincial Policy Statement. Finally Sulco Chemicals raise issues about noise and land use compatibility including minimum recommended separation distances involving both noise and safety of the proposed subdivision from surrounding businesses. ................................................................................................. My heart goes out to individuals and families who eventually buy or rent homes at 36-38 Union St. in Elmira. No price is worth you or your families life and health. DO NOT BUY or LIVE in this proposed subdivision until or unless Lanxess and Sulco are gone. That said Sulco have shown honest efforts for many years to protect their neighbours from their industrial threats. Uniroyal/Crompton/Chemtura/Lanxess have not.

WOOLWICH COUNCIL MEETING FRONT PAGE NEWS IN THE K-W RECORD

I have to admit to being surprised by this story. Paige Desmond's front page story is titled "Council clashes over Woolwich budget" with a sub-title of "Councillors exchange barbs over Peel Street Bridge conversion, vote for 5.4 per cent tax hike". Woolwich Council consists of six members although one acts as Chair at each meeting. The overall initial impression I had was of a dysfunctional council which I have to admit made me chuckle because of my history with those twits. Lets see Councillors, Martin, Merlihan, Larry Shantz and Sandy Shantz were on Council when they tried to block Dr. Dan Holt and I from speaking at council about Chemtura and who also walked out on my Delegation, the incredibly stupid twits. As I recall neither Councillors McMillan nor Redekop were members of council at that time (2016 or 2017). Similarly the same foursome in 2015 also voted in favour of removing CPAC in exchange for a more company (Chemtura) friendly group based upon misrepresentations presented by Sandy Shantz and then councillor Mark Bauman. So no I have very little sympathy for them. ...................................................................................................... That said I reread the article. Hmm. It seems to me that there are some legitimate differences in opinion regarding spending on that council. I do not view that as a bad thing. In fact I'm more concerned when I see Woolwich Council appearing to be all in bed together on some issues almost as if they did most of their discussion and debate in private. It is my opinion that too much of that does go on. One fine example was that absolutely ridiculous pretend search for a temporary replacement for Scott Hahn when he resigned unexpectedly in early 2018. Julie-Anne Herteis was decided upon privately and then Council went through the ridiculous, deceptive and disgraceful game of having ten very qualified candidates jump through hoops and loops including a public speech to Council when they had already decided on the weakest but most pliable candidate in advance. They were confident that Julie-Anne would not rock the boat. Good God what a council. .............................................................................................................. I have wondered occasionally over the last several years if some of Woolwich's most stupid decisions have come back to haunt them. Certainly the attention of Kitchener-Waterloo's media has been on little Woolwich Township more since then. It is possible that the debates Monday at Woolwich Council including some internal acrimony really weren't all that newsworthy. I suspect that Councillor Merlihan is correct that a couple of Woolwich councillors are incapable of serious budget study due to either mental disinterest or in the other case too many responsibilities outside council activities. Rumours are that that would apply to councillors Martin and Redekop, the latter being fully engaged in honest, appropriate spiritual work outside his council duties. I also suspect that Monday's public conflict will calm down. It really doesn't look that good to the public even if some healthy debate is a good thing. The one quote from mayor Shantz actually put her in a positive light. Hmm I guess I have to live with that.

ISN'T THAT FUNNY?

The only party or guilty stakeholder who asked for a copy of the Pacific Rim Dioxin lab report was Lanxess Canada. Everybody else said NO they didn't want the free copy for a myriad of generally silly and poor excuses. Then I sent copies anyways to everybody except TAG (Technical Advisory Group) who had also turned down receiving a copy. Other than a single Region of Waterloo councillor (NOT Sandy Shantz), all the other refusing stakeholders did not acknowledge or confirm receipt of the e-mail copies of the Pacific Rim lab report I sent them. Weird. You'd almost think that they are ostriches. You know bury your heead in the sand and then bad things won't see or find you. Duhh! ............................................................................................................................................ To date TAG members and Chair have not changed their minds and started clamoring for a copy of the lab report just because everybody else has it. That said there are folks on TAG who have received it as they got it via membership either in RAC (Remediation Advisory Committee) such as Tiffany and Sandy Shantz or as regional councillors (Sandy again). Meanwhile they can falsely claim that they've never received it as long as they say "never received it as a member of TAG." Isn't tht silly? .............................................................................................................................. I guess this is somewhat an example of group think. Unfortunately however for the group, the leader, Lanxess seemed to miss the memo. Sometimes even the best of conspiracies founder on communications gaps.

INDEED THE TAG MINUTES ARE ON-LINE VERY QUICKLY

O.K. I can quibble about the difficulty in finding the TAG Minutes on the Woolwich Township website but in fact not only are they there but they are there quickly. In those Minutes Lisa Schaefer advised that they normally are put on-line within three weeks. In this case I went looking this morning, a mere ten days later, and in fact they are already up. Essentiallt one needs to look for Committees of Council to find RAC and TAG Agendas and Minutes . Also as the February calendar is up one has to find the arrow at the top left to backtrack one month to January. Lo and behold there are the Minutes for January 27/22. .................................................................................................. Overall they follow my posting of the Minutes on January 28 and 29 here in the Elmira Advocate. There are however greater details regarding failures of hydraulic containment in Lisa's Minutes particularly in Appendic C written by Linda Dickson. These are very well done. The bottom of page 2 of the main Minutes is in error however. It states that "...there has not been any evidence that suggests there is an off-site source of DNAPL." That is totally inaccurate. The particular example is free phase DNAPL (chlorobenzene etc.) found in off-site well OW57-32 located west of Varnicolor Chemical and north of Borg Textiles, very close to the Elmira Water Tower near Howard Avenue. There is also strong evidence of off-site DNAPL on the Yara property although it may be agreed that it isn't an off-site source if it came from Uniroyal Chemical, way back when. Of course this is but one more example of TAG members who din't come on the scene until eight to ten years AFTER much of the DNAPL discussions/investigations hence they have no knowledge of them. .......................................................................................................................................... The so called Technical Meeting of December 14/21 is but one more shining example of Woolwich Township hypocrisy. The very same Woolwich CAO then as now, David Brenneman, appropriately insisted with CPAC members (2011-2015) that private meetings were verboten. Private meetings of course were Pat Mclean's (CPAC Chair 2000-2011) bread and butter and she used them at will as they now seem to be back in style again. Various excuses always thrive whether it's "in the interest of time" or whether it's because they are so technical (i.e. "at a high level", "technical meetings" , "at a very high level". Gotta love the B/S. Page 5 of the Minutes also honestly describes the lack of knowledge of many TAG members in that the reading of the monthly Progress reports has been delegated to Linda Dickson and clearly most of the TAG members never read them. That is both sad and unfortunate. ..................................................................................................................................................... Overall the good news is the timeliness of these Minutes although I doubt that the general public will ever find them much less read them.

WHAT NEEDS TO CHANGE IN ELMIRA

Firstly some form of public inquiry is needed in order to separate our local politicians from their joined-at-the-hip stance with Lanxess Canada. Secondly the Ministry of Environment's collusion with Uniroyal/Crompton/Chemtura and lanxess needs to be exposed as well. Without those first two changes everything else is doomed as the guilty parties will simply regroup and go back to business as usual. This business includes lying, deceiving, and covering up all aspects of the alleged cleanup and remediation. Keep in mind that the coverup did not start in 1989 when the wells in Elmira were first shut down. The coverup likely started the day after Uniroyal Chemical were in production (1940s) as they both directly and indirectly dumped their toxic liquid wastes into the Canagagigue Creek which runs through the middle of their property. For God's sake how dumb did the local politicians have to be when they first learned that Naugatuck Chemicals (later Uniroyal) were purchaing that property. It was located generally downwind of the community with a sewer (creek) running through the middle of it. Sure as hell the chemical company knew what they were doing before they bought the property. ...................................................................................................................... Hydraulic containment as ordered in the November 1991 Control Order needs to be complete in all aquifers including the Municipal Lower (ML) and Bedrock (BR) aquifers. The shallow aquifer (UA) containment and treatment system needs to be extended both northwards on the west side of the site and fully installed on the east side where it is non-existent. DNAPLS, both residual and free phase need to be vigorously pursued and either removed or chemically nuetralized if that is possible. The groundwater treatment systems need to be upgraded in order to be able to reduce the discharge criteria (into the creek) for all compounds. Honest and serious soil and groundwater testing is required on both the east and west sides of Lanxess (Yara & Stroh/Martin properties). This must not then be followed by more decades of delay but rather immediate removal of highly contaminated soils is required including DNAPLs, dioxins/furans. DDT and more. ............................................................................................................. Source removal has been the dirty word for the group of chemical companies owning this site since 1989. Too bad. You bought a mess and all the illegal reassurances in the world from local powerbrokers was at your own risk. We have the technology to clean up this site immeasurably but no serious attempts have been made. No the site will never be pristine but instead of intentionally letting everything ooze, leak and flow off-site over many decades it can be greatly improved. This includes downstream removal of dioxins/furans, DDT, PCBs, endosulfan, lindane, mercury and more. It has always been the will that has been missing. The way is the easy part in comparison.

USELESS MINISTRY OF LABOUR & LOCAL BLACKLISTING EMPLOYERS

Cowardly, vicious, cruel, petty and ignorant. Those are just a few appropriate names for some local Elmira, Ontario employers. ESG Plastics (now in Listowel), Krums and Elmira Forest Products (also left town). Perhaps not in the same category might be the former Martin Pet Foods later Heinz but still with some questionable employee treatment. The first three companies needed full time help, interviewed applicants, hired myself based upon a good reference or two and then watched me work hard every day, arrive on time, get along with everyone and then fired me without notice, cause or complaint. Except ESG who made up sh.t. Oh you are having difficulty with the electronic board controls bullsh.t. Excuse me but there are four or five buttons and during the course of six weeks employment I'd been told to use that board all of once and did so. Such crap. Gutless wonders combined with lying ass.oles. Yes that is the state of non-union employment in Ontario. No legitimate cause or reason required and if under three months employment no separation pay required. That includes if the employee has left his previous employer to start work for more money, shorter commute, better hours etc. ...................................................................................................... Why would a local employer hire someone (away from another employer), make it clear that they are satisfied with the new employee and then suddenly state that they no longer need them? If it happens once it is stupidity. If it happens twice it might be coincidence but is still very odd. But when it happens three times all within the town of Elmira then it becomes obvious. Blacklisting: I sent my former employer in Elmira (Varnicolor Chemical) to jail for his crimes against the environment. Crimes he had ordered me to participate in. Bad move there. Was it through the BIA (Business Improvement Assoc.)? Was it connected to the Chamber of Commerce? I don't know but it sure as hell has affected me. My natural respect for authority has been diminished and rightfully so. Hell I even had another employer in Elmira, Marcel Roy, after he bought Pilgrim's Provident (domicillary hostel), refuse to pay me statutory holiday pay for working the holiday. I went to the Ontario Ministry of Labour who ordered Marcel to rehire me (I'd worked there for two years) and he then attempted reprisals against me which ended up with the Ministry awarding me $6,500 . Not a red cent of that award was ever paid which certainly tells me how impotent the Ministry of Labour either are or want to be. .............................................................................................. Just to clarify I was a parent of two children and helping support them during these attacks on my employment by yellow, gutless employers who didn't even have the courage to ask me why, how or what. They simply lied and hid behind the pathetic labour laws in this province. I both can look in the mirror and sleep well at night. Can those gutless filth say the same thing?

IMMATURE HIGH SCHOOL BOYS IN POSITIONS OF AUTHORITY, PRO AGGREGATE POLICY & ANTI - O'TOOLE SELF IMMOLATION

Yes I'm referring to the article in today's Waterloo Region Record describing the Angie Rivers ongoing police hearing. Geez the male superviser was insulted because he heard rumours about his female subordinate's sexual activities and they didn't include him. Are we talking about high school or are we talking about an allegedly professional police force here? Sometimes it's really difficult to know one way or the other. What a damning indictment about police culture and police immaturity. Not to mention leadership! Who the hell is running the show, the rank and file or the senior management team? I know that the Canadian military has similar problems as likely do most male dominated professions including public works departments etc. What an indictment of the males behaving badly AND the males supposedly in charge. ............................................................................................................................ Changing stride we have another article in today's Record by Paige Desmond about the proposed Hallman Pit. A Wilmot councillor is basically saying that municipal councils have become rubber stamps in that they are expected to approve zone changes because the province is so pro new gravel pits and pro the aggregate industry. .......................................................................................................................................... And finally we have the Conservative Party caucus in Ottawa turfing yet another party leader. Wow! This one lasted all of seventeen months before his likely very practical and appropriate vision got him the boot. Geez I'm no Conservative but come on guys I don't see how blowing up the party (again) is going to provide the very needed opposition to Justin T. and friends.

HALLMAN PIT - ONE MORE REASON THAT CITIZENS APPROPRIATELY DISTRUST THEIR GOVERNMENT

The article in today's Waterloo Region Record is written by reporter Paige Desmond and is titled "Staff says Wilmot council should OK rezoning for Hallman Pit". So here again we have a totally unecessary gravel pit operation that will reduce the quality of life for the neighbours and local residents simply because the stupid, dishonest politicians long ago passed legislation that is blatantly disrespectful towards current property owners and blatantly biased towards gravel pit owners and operators. Those same owners and operators of course funnel sums of money towards the Liberal and Conservative parties in Ontario and that's all the incentives the politicians require. This is government for the (wealthy) people by the (wealthy) people at the expense of the 90% of the rest of us. And those idiot politicians in Ottawa and Toronto don't understand why they have lost so much respect and authority among ordinary citizens. ................................................................................................................ There are seven other gravel pits across the road from this new proposed one. In total there are nine gravel pits along Witmer Rd. And guess what? They've been there for decades disturbing local residents, wildlife, ground and surface water. Some are abandoned, some are "rehabillitated" and some are active intermittently. What the bloody hell nonsense is that? Oh and this new proposed pit is on prime agricultural land that will NOT be restored to its former agricultural capacity. Prime agricultural soils require decades to centuries of in place location to attain that quality. Excavation, disbursement and eventual replacement of soils years later does not equate with the prime designation the soils currently have. ....................................................................................................... I only hope that I live long enough to actually see an honest to God mass citizen revolt against our pathetic governance in this country. Nothing else is likely to ever even come close to reversing the trend of the last fifty years. My fear is that those undemocratic, deceitful and dishonest trends will survive and expand.

WELL NOW DO WE HAVE A HUGE PROFESSIONAL BIAS ON TAG AGAINST LAY CITIZENS?

I'm trying to figure out why TAG last Thursday would intelligently discuss the four DNAPL letters written in 2006/2008 by hydrogeologists Wilf Ruland and Jaimie Connolly but steadfastly ignore written reports and Delegations from myself. Eureka maybe it's not as personal as I thought. Keep in mind none of the "professionals" on TAG have ever seen myself, Dr. Henry Regier, Rich Clausi or Esther Thur go head to head with hydrogeologists from Conestoga Rovers or the Min. of Environment and put them in their place. Similarly while 2011-2015 CPAC had environmental professionals on board often it was the academic (such as Dan & Sebastian) and other lay citiens (Vivienne etc.) who took company and Ministry "experts" out to the woodshed for a course in common sense. Simple arguments by hydro G folks in the past have been shot down with ease by informed and intelligent citizens including claims that in such and such location there are no "windows" i.e. openings through the aquitard. We would simply respond that if that is so then why are the concentrations that are so high in the shallow aquifer right there just as high as those in the municipal aquifer directly below it? And on and on. Citizens sucessfully took on the company and Ministry "experts" for twenty-five years before the latest group of hotshots got appointed to TAG by the guilty parties. ............................................................................................................... DNAPLS are another prime example. Yours truly was responsible for hydrogeologist Brian Beatty being "consolidated" by Uniroyal Chemical as stated by Dr. David Ash, General Manager. Prior to widespread useage of the Internet (1992-93) I went to the University of Waterloo library and discovered Mr. Beatty's very flexible use of the 10% Solubility rule regarding presence of DNAPL. Similarly Esther shot down "expert" opinion by Uniroyal consultants and others regarding allegedly harmless or merely odourous air emissions from the company. Her husband and other employees of the Elmira Furniture company used to be sent home sick when Uniroyal Chemical's (next door) air emissions were at their worst. And on and on yet these young, intelligent and basically honest citizens now on TAG haven't a clue as to the number of times local, lay citizens shut down and shut up the plethora of lies and bullsh.t coming from the credentialed suits and other bought and paid for intellectual prostitutes brought to Elmira to deceive the citizens.