It is also amazing how many other bodies fell in line with the Ministry's bullsh.t. I've just re-reviewed five heavy duty reports dated 1985, 1987, 1990, Feb. 1991 and August 1991. The authors in order are MOE & GRCA, Terreaqua, Bob Hillier M.O.E., CH2MHILL and lastly Conestoga Rovers. The first report by Jackman (MOE), Ralston (MOE) & Smith (GRCA) seems to be the one to follow at least as far as Hillier (MOE-1990), CH2MHILL (Feb. 1991) on behalf of the Region of Waterloo and Conestoga Rovers on behalf of Uniroyal are concerned. Terreaqua written in 1987 for the MOE is much more independent and in my opinion professional, and honest, lacking in bullsh.t etc.
I've also reviewed today various hydrogeological reports regarding Varnicolor Chemical. Oh my but their groundwater contamination was extraordinary. So were the concentrations of toxic chemicals in their soils. We can of course further discuss concentrations of trichloroethylene in parts per million in their groundwater. We can also discuss toluene in parts per million which is about 1,000 times higher concentration than most discussion of groundwater which is only in parts per billion (i.e. 1,000 times smaller). Oddly extremely little chlorobenzene was found on their Union St. site. Was this because there was very little, which is odd for a paint and solvent recycler who graciously shared their wastes with the natural environment, or was it due to not sampling for chlorobenzene most of the time? What a coincidence that the two major compounds attributed to Uniroyal Chemical, including eventually by themselves as well, were mostly found in small quantities or not at all at Varnicolor. This of course is especially odd as other Uniroyal signature chemicals were found in shallow soils and groundwater on the Varnicolor site. There is also the small problem of "Digger Dave" Holmes. He wrote and signed an Affidavit which I did not see until years afterwards. It was dated December 6, 1989 BEFORE I made my formal complaint to the Ontario MOE about Varnicolor Chemical. His detailed and specific complaint about seeing solvents in the sub-surface while digging on the site along with several years of groundwater testing by Canviro showing solvent contamination did not deter the MOE from coming immediately to Varnicolor's defence when I went public.
There is of course the issue of NDMA on the Varnicolor site. This was always minimized via the use of higher Method Detection Limits as well as by very limited sampling. It also helped that NDMA flows at the speed of groundwater i.e. is not retarded in its' flow as most chemicals are. I believe that Varnicolor's contributions to NDMA in the Elmira Aquifers (MU & ML) occurred mostly prior to the late 1970's or mid 1980's. Above and beyond low levels of dissolved NDMA still in their groundwater in the early 1990s there were a couple of outstanding detections namely 9 parts per billion (ppb) in the soil approximately ten feet below surface as well as 14 ppb found in a sump on their site. The sump was a tank farm sump which is revealing.
There was a professional report published in 1977 indicating massive levels of NDMA on the Uniroyal Chemical site in their waste waters. This was twelve years before either Uniroyal Chemical or the Ontario MOE decided to test for NDMA in Elmira's drinking water. Drinking water that is obtained from the same aquifer as was located directly beneath Uniroyal with spots where there were toxic waste pits immediately above the aquifer and zero aquitard (low permeability soils) between. In February 1988 close to two years prior to the MOE announcing that NDMA was found in drinking wells E7 and E9, NDMA was found just off-site of Uniroyal in well CRA 3. This monitoring well was between Uniroyal and the south wellfield (E7/E9). Apparently neither Uniroyal nor the Ontario MOE thought to immediately test Elmira's drinking water for the highly carcinogenic NDMA. Allegedly at least they didn't.
Back to Varnicolor's Lot 91 located in the floodplain of the Canagagigue Creek and just south of Uniroyal Chemical. Massive soil contamination by toxic chemicals was discovered there after yours truly blew the whistle. Both heavy groundwater contamination and gross soil contamination in another area of very thin aquitard between the surface soils and the Municipal Aquifer (MU) below. No problem for the MOE. Just lie! Hell, eventually even PCBs were found in a buried drum on the site. Along with lots of other buried drums containing various solvents.
Then of course we have the issue of the rapid pace of very quiet on-site cleanup at the Uniroyal Chemical plant BEFORE the announcement of NDMA in the south wellfield. My goodness but weren't they fortunate to have been doing so much cleanup and in fact completing it just before the NDMA announcement by the MOE? In fact they removed tonnes of toxic wastes from both sides of the Creek on their site twice. Such exquisite timing for the second one. One of their reports however does mention that drums likely ruptured during earlier transfers from their old repository into the new. Gee I wonder if those ruptured drums may have also torn the plastic lining allowing yet more leakage into the natural environment? Oddly though they stopped this transfer in 1969-70 from pit BAE-1 into RPE 4 & 5 and actually reburied them again into two nearby pits designated as RB-1 & 2. RB was supposed to stand for ReBuried but personally I kind of think in reference to the environment that Royally Buggered is more accurate.
There is more but this is enough for readers to digest right now.
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