NOVEMBER 10, 2022 LETTER TO THE EDITOR

 

This letter to the editor (Woolwich Observer) was published over three years ago. As usual exactly zero response or comment from various guilty stakeholders in and around Elmira, Ontario. In one sense that is a good thing. The title put on my Letter To The Editor is "Uniroyal problems persist, but so too does inaction". I view the lack of response, whether verbal or legal, as both an admission as well as  a belated understanding that poorly crafted, weak denials can be worse than admissions sometimes.

My letter to the editor is a broad indictment of the system currently allowing polluters to run their own cleanups with little more than superficial oversight by the Ontario Ministry of Environment (MOE).  Afterall it was the Ministry's shoddy oversight in the first place that got us all into the Elmira Water Crisis and so many more around the province.  Yes certainly the Ministry have been underfunded and understaffed. That has always been an intentional situation by each and every provincial government for many decades ever since Bill Davis first announced the beginnings of that new Ministry. It was simply virtue signaling to the electorate that their government would include environmental preservation among their other poorly managed ministries such as labour and transportation. Make no mistake Mr. Davis most likely had to calm corporate fears of any serious attempt by the government to reverse many decades of corporate and industrial environmental abuse and damage .  

This is the trick of governance. You must appeal to the masses publicly and tell them what they want to hear while at the same time quietly assuring the much, much smaller but powerful elite and wealthy that you will not change the status quo which they love so much. 

My letter focuses on technical reports produced by client driven consultants on behalf of the polluter (Uniroyal/Lanxess).  It also focuses on the Sept. 1, 2022  MOE report titled " Sediment and forage fish monitoring results from September 2020 in Canagagigue Creek".  Finally I focus on the long denied but blatantly obvious conflicts of interest in the entire remediation system here in Elmira. 

REGION OF WATERLOO: "THAT'S MY STORY AND I'M STICKING TO IT"

 

Luisa D'Amato's Opinion column today is titled "Region reveals the purpose of pumping water from Wilmot Centre wellfields".  Well in fact I would suggest that what the Region have done is not so much revealed anything as much as their own stubbornness. At least one local citizen, Samantha Lernout, may have expressed doubts as well when she said "You don't run an experiment and not tell people". If seven years of pumping water from Wilmot to Kitchener-Waterloo is merely a test then I wonder what the last many decades of pumping groundwater from the Waterloo Moraine should be referred to .  

I would also like to see the Region offer copies of these alleged hydrogeological reports claiming lots of available water in the Wilmot Centre wellfield to both individuals and citizen groups. It is conceivable that there is plenty of water at the same time as some residents' and businesses' wells are running dry. Factors include the depth of the wells running dry as well as their proximity to regional pumping wells. A high volume pumping well does produce a large cone of influence whereby water levels within half a mile or so of these wells can be seriously lowered while the rest of the aquifer water levels remain as high as ever. Another term for the resulting cone of influence is drawdown. Again a high volume pumping well can seriously lower nearby water elevations by several metres while having minimal effect or no effect on wells one or two miles away.    

FROM THE LOCAL NEWSPAPER ARCHIVES OF JUNE 30, 2022

 

The title of the article in the Woolwich Observer is "Community experts say Lanxess is not doing enough  to address contaminated hotspots in Canagagigue Creek". Susan B. and Tiffany Svensson , Chair of TAG (Technical Advisory Group), both are quoted as stating that Lanxess and their hired Risk Assessor (Stantec) are taking shortcuts. First of all this whole thing about "hotspots" has been beaten to death by all parties.  These alleged "hotspots" are basically very convenient locations for consultants, engineers and contractors to access the Creek both for monitoring /sampling purposes as well as for possible remediation. They are magically located right at the intersection (bridges) of New Jerusalem Rd. and the Canagagigue (Gig) , followed by miraculously the next downriver bridge at Northfield Dr. again followed miraculously by the last bridge over the "Gig" at Jigs Hollow Rd. (#46). Of course extensive sampling at those three locations has resulted in more exceedances there than in other less sampled locations.

Now the two TAG reps are not incorrect when they state that there are large exceedances of health criteria at those three spots. But seriously if there are exceedances miles downstream at Northfield Dr. and Jigs Hollow Rd. do you really think that there aren't lots of other exceedances upstream closer to the source namely Uniroyal Chemical? In my opinion TAG members were trying to be accommodating and compromise with Lanxess and the Ministry of Environment by suggesting/agreeing with the three "hot spots" claims. This has been the huge failure of citizens in general and UPAC, CPAC, RAC & TAG (now TRAC) and most definitely Woolwich Township. They have all been terrified of confronting the polluter. It's as if they believe that they can somehow be criminally charged for holding the polluter and his kid gloved regulator to account for their gross negligence which has resulted in both serious health issues and shortened lifespans for some Elmira residents.

Four years later and Lanxess continue to uphold their predecessors skills at perpetual delay. If the locals don't immediately accommodate the polluter's plans then the company's response is to do nothing. Every dollar they put off spending today is less money down the road both due to devaluation of that money as well as due to ongoing discharge to groundwater, air and the Creek. I expect that another one hundred years of delay while costing both downstream human beings and the environment health impairments will greatly reduce Uniroyal on-site contamination. Yes it's merely been shifted including as far as Lake Erie but if we're feeling bad about that we can always put a straw (pipeline) into the lake and suck some of the toxins back up here for consumption. I think that is referred to as political closed loop recycling. 

HAVE FAITH IN YOUR GOVERNMENT, WHAT IS THE WORST IT CAN DO?

 

I suggest that possibly as much as tonnes of contaminants have now been spread far and wide. I further suggest that they continue spreading on a day to day basis. I mean why wouldn't they? Any alleged proof otherwise is that of sycophants, co-optees, fellow travellors, client driven credentialed experts, self-serving credentialed experts who don't want to mess up their financial gravy train with the Ontario Ministry of Environment and finally politicians. Yes I suppose it is possible for a few honest people to be fooled by all the aforementioned. Maybe it's especially possible for honest and uninformed people to be fooled by all the other folks mentioned.

Yesterday Luisa D'Amato of the K-W Record suggested that "Anger deepens in Wilmot over water". While I believe that she is correct I also think that that very same anger is throughout the Region of Waterloo.  Developers and builders are angry about losing future revenue streams. Everyday, informed citizens are angry about the power and influence of those same builders and developers being the tail that is wagging the dog. How nice to be able to step to the front of the water line it must be for them. The Townships of Woolwich, Wellesley and North Dumphries must also be angry as they understand that their water really isn't theirs according to the Region. All the Region has to do is start pumping those township aquifers until they dry up. Maybe they already are doing so . 

Meanwhile in Woolwich their politicians who have gone with the flow for decades may actually just be starting to regret their laissez faire attitudes. Laissez faire attitudes generally mean to let it happen or leave it to do it's own thing. That has been what most Woolwich Councils have done with others stepping in and putting a thumb on the scale to ensure that temporary momentum by citizens remains temporary. That is what Sandy Shantz did back in 2015 to bail out both Chemtura Canada and the Ont. Min. of Environment (M.O.E.). They were both taking a verbal and psychological bashing by informed citizens who had run out of patience with their decades long delay and intransigence. In the mindsets of polluters and corrupt politicians mere telling of the hard to hear truth equates with rudeness, terrorism and bullying .   

Why right now would Woolwich politicians be having regrets? Simple. In good times when everyone was bragging about both the quantity and quality of the water supply here, nobody was too upset that K-W had a pipeline supplying water going up to Elmira. Now during major concerns over the quantity of water available to the cities especially, many will soon if not already resent water being pumped north. Why they wonder shouldn't it be being pumped south to the high population cities?

It won't surprise me if Lanxess Canada and the M.O.E. don't cook up a batch of silly juice and try to sell it as complying with requests and demands for water to go from the townships to the cities. Of course the "silly juice" that these two misanthropes cook up could really be something else again. Have you ever tasted water imbued with NDMA, chlorobenzene and a little more? We in Elmira have but it won't hold a candle to water enhanced with NDMA, chlorobenzene, ammonia, dioxins, polyaromatic hydrocarbons, toluene, benzene and multiple chlorinated solvents.  Try it you'll like it! Trust your government all the way to the grave.   

REGION OF WATERLOO'S REPUTATION MAY GO DOWN THE TOILET...IF THERE'S ENOUGH WATER THAT IS

 Or put a little differently by Samantha Lernout of Citizens for Safe Groundwater "I've lost complete faith in their ability to manage water".  This comment is in Luisa D'Amato's Opinion piece in today's K-W Record titled "Anger deepens in Wilmot over water". Personally I would suggest that while the Region of Waterloo have a long history of saying the right things publicly and indeed of some innovative planning decisions over the decades nevertheless when push comes to shove regional councillors  are and always have been a bunch of environmentally illiterate twits with a self-serving fascination for money, power, authority, economic growth at ALL costs and legacy projects. This is why I worry that they will latch onto the Lake Erie pipeline just like native born leeches latch onto their prey.

Apparently to date the Region have not shared groundwater elevation levels (i.e. metres above sea level-masl) with local councils. What a great way to keep everybody else in the dark while you make up your own numbers. The report on the groundwater elevations for the Wilmot Centre Wellfield has been delayed until April 8/26. Even then the fibbing has not yet ceased as the region apparently still claim that the surreptitious pumping of Wilmot's water since 2019 was only for "testing" purposes. I'm thinking that if I ever get caught robbing a bank my excuse will be that I was only "testing" their security. See how far that gets me.

Another article by Bill Jackson titled "Waterloo Region asks for provincial moratorium on water-taking permits" advises that the Motion put forth a month or so ago by a regional councillor (Barry Vrbanovic?) has actually been passed. That Motion was to direct 50% of all new water capacity to support new development in the region. Geez does that not make abundantly clear how weakly regional councillors prioritize water for everybody over more profits for the development and building industries? That Motion is a direct result of lobbying by those industries and how quickly councillors respond to them versus to all the rest of us who really by now just want to flush our politicians down the toilet if only we had the water to do so.

 

THE RISK ASSESSMENT OF THE CANAGAGIGUE CREEK IS BUT ONE MORE IN A LITANY OF PSUEDO SCIENTIFIC ENVIRONMENTAL STUDIES IN ELMIRA, ONTARIO

 

In the past Conestoga Rovers (CRA), on behalf of Uniroyal Chemical, Crompton & Chemtura, were accused of writing Conclusions and Recommendations to reports that simply did not reflect the data and findings of those reports. In other words CRA would cherry pick items here and there within the reports of little significance and arbitrarily pretend to believe that they had far more weight and significance than they did. This was but one of their methods during DNAPL studies done in the late 1980s and early 1990s. They were actually accused by a consultant (CH2M HILL) for the Region of Waterloo of intentionally sampling for DNAPLS in the least likely locations to find them and then claiming "see there aren't any DNAPLS here."

Similarly monthly Progress Reports showing reduced on-site pumping might be acknowledged as a temporary mechanical breakdown easily fixed yet month after month and year after year the trend continued to decrease. Also there was never any acknowledgement of public verbal promises made by  Chemtura staff regarding the Tripling of off-site groundwater pumping in the monthly Progress Reports. Neither a tripling nor even a Doubling ever occurred and yet not a peep in those monthly reports as they bragged about exceeding their old off-site Target pumping rate by five or six litres per second (i.e. from 53 l/sec to 58 l/sec).

Now Lanxess continued that fine tradition with their Risk Assessment (RA) of the Canagagigue Creek. Apparently they can manipulate various assumptions throughout the RA process in order to conclude that despite many, many exceedances of health criteria for multiple contaminants both in Creek sediments and soils; not to fuss as the RA claimed "...no unacceptable risks...". There were also issues with floodplain soils as well and don't get me started on amateurish sampling of Creek sediments using shovels instead of professional core samplers. Along with these polluter self-serving failures were the locational sampling biases that failed to properly sample the majority of the five miles of downstream Canagagigue Creek all the way to the Grand River.

All in all unethical and dishonest junk science, psuedo science and wishful thinking science alone will not succeed. It also takes a combination of either stupidity, laziness or dishonesty by sitting politicians at the municipal, regional and provincial levels. Woolwich Township and Waterloo Region, fortunately for polluters, are blessed with an abundance of these. 

 

TYPO CLARIFICATION REQUIRED REGARDING METHOD DETECTION LIMITS HIGHER THAN HEALTH CRITERIA

 

Oops to err is Uniroyal like, to forgive divine. Gee I hope I haven't offended any Uniroyal lovers still alive in Elmira.  If I have then I guess I'll just have to live with it. By the way I bumped into former councillor Julie-Anne Herteis last evening.  She appears well and did not seem to still be mad at me for unkind things I may have said about her while she was a Woolwich councillor.  That's good because while sitting politicians are fair game, retired or those moving forward in life are not.

The typo is an easy one to make when we are discussing health criteria concentration numbers of toxins along with laboratory Method Detection Limits.  In yesterday's post I started off O.K. in my first paragraph stating that both the authors of a recent report and the Editor of Environmental Science magazine stated in their Summaries that "...analytical limits are far too high for detecting many chemicals, especially pesticides." Then however near the end of my second paragraph darn if I didn't reverse the word higher and use the word lower. Maybe that's not so much a typo as a brain fa*t? 

Here is an example. If you have a chemical with a health criteria concentration of  .5  ug per litre  (.5 ug/l) i.e. half a microgram per litre of water AND a laboratory Method Detection Limit however of 1 ug per litre ( 1 ug/l)  i.e. one microgram per litre then you have a problem because  the laboratory measuring the particular chemical can only measure as low as one microgram of that chemical per litre of water. Therefore the chemical can be above it's health concentration in drinking water (say for example three quarters of a microgram of chemical per litre of water)  however it is assigned a concentration of ND or Non Detect because the lab either don't have the equipment to measure that small or the appropriate process/method to do so. Also sometimes it can also be a matter of cost. Certain labs may charge extra for doing more expensive and difficult very low concentration analyses of a chemical.

Therefore this can be a legitimate limit on determining the toxicity of some chemicals in various mediums whether water, soil air etc. Or on the other hand it can be a very convenient method of weaseling out of showing exceedances of health criteria by toxic chemicals thus reducing expected cleanup costs. Unrepentant polluters lacking in ethics have become adept at this kind of gamesmanship just as regulators and credentialed public advisory committees have learned to look the other way in reports evidencing this kind of data.