Below is a Table from Jaimie Connolly (MOE hydrogeologist) dated May 2, 2008 presented to the MOE, Chemtura and CPAC. It shows how extremely reduced the Aqueous or Pure Phase Solubilities of various contaminants are in groundwater that has multiple different liquid contaminants dissolved in it
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O.K. a week ago I gave a little explanation as to my strategy. Today will be a little more. Politicians and other assorted riff raff are big on plausible deniability. Their attitudes are if you have a problem for gosh sakes don't aggressively go out and investigate it. If you can smell smoke there may well be a raging fire nearby and the less we know about that the more we can pretend it doesn't exist. So by my sending municipal and regional councils detailed and specific facts regarding the east side of Lanxess i.e. the Stroh and Martin farms , the harder it is for them down the road to plead ignorance.
It's the same thing with DNAPLS (dense non aqueous phase liquids). The more information and facts they have the harder it is for them to pretend that it is a complex problem beyond their reach. Or even more so that it is a complex problem that must be left to the credentialed experts i.e. Qualified Persons Coincidentally all the QPs are bought and paid for...oops I mean hired by the polluter and his fellow travellors. Names are not always necessary as they likely have mothers, families, children etc. and what some of them are doing is not illegal although it should be.
So I've been sending detailed facts and data to Woolwich Council, Waterloo Regional Council, Lanxess some, Ontario MECP some, TRAC some, and the media. Have you noticed how little interest the media have in Elmira these days? Are they waiting for another explosion and fire or something more dramatic like half of Elmira not waking up some morning?
By the way short of them surreptitiously adding the multi page report on chlorobenzene to last week's TRAC Agenda at the last possible moment, along with a brief description of the both short and long term groundwater pumping failures; there has been an awesome silence from our authorities in response to the facts being sent to them. Zero from the two councils, zero from TRAC, the media and the MECP. It is their non responses to an informed citizen's critiques and clarifications of their errors and misunderstandings that is the most damning of their actions and inactions. Clearly they know that my facts and claims are accurate and the very last thing in the world they ever want to do is to publicly discuss any of it. They are fearful, even terrified, as well they should be. Their day of reckoning is approaching and they know it.
Informed opposition to their "remediation" coverup continues. Informed opposition to their plethora of lies and deceptions involving groundwater, the former Uniroyal site, the Canagagigue Creek, other industrial sources of contamination in Elmira, the knowing and willful poisoning of Elmira residents for years will not end. Eventually they will be confronted en masse and what they do and don't do now will determine their eventual fates.
EPA - U.S. Environmental Protection Agency
USGS - United States Geological Survey
SOURCES:
"Effective Solubility Assessment for Organic Analytes in Liquid Samples, BKK Class 1 Landfill, West Covina California 2014-2016 USGS Open-File Report 2019- -1080"
"EPA Ground Water Issue Dense Nonaqueous Phase Liquids March 1991"
Page 8 EPA
"Organic compounds are only rarely found in ground water at concentrations approaching their solubility limits, even when organic liquid phases are known or suspected to be present. The observed concentrations are usually more than a factor of 10 lower than the solubility presumably due to diffusional limitations of dissolution and the dilution of the dissolved organic contaminants by dispersion. This has also been attributed to: reduced solubility due to the presence of other soluble compounds, the heterogeneous distribution of DNAPL in the subsurface, and dilution from monitoring wells with long intake lengths."
Page 2 USGS
"...the presence of DNAPL or mixed DNAPLs was considered unlikely based upon measured concentrations below the aqueous solubility threshold of 1 percent that is commonly used as a "rule of thumb" to screen for the presence of DNAPL, as described in the Draft Leachate Investigation Report ..."
"However, the 1- percent threshold for considering groundwater concentrations indicative of NAPL presence refers to effective solubilities rather than aqueous solubilities, when the NAPL may contain more than one compound ."
Personally I have been aware of the difference between Aqueous or Lab Solubilities and Effective Solubilities for at least the last twenty-five years. So have Conestoga Rovers and GHD and any other "experts" in the field. Oddly none of them spoke up at last Thursday's TRAC meeting as Allan Deal (GHD) verbally misrepresented the 1 % rule of thumb by suggesting that concentrations at or above 4,900 ppb (ug/l) were required to indicate DNAPL presence.
I think Sandy that either your "experts" are no such thing OR they find it beneficial not to criticize or dispute Lanxess and their client driven consultants. Keep on appointing polite, deferential people who will never say BULLSHI* even when they're up to their necks in it.
Alan Marshall EH-TEAM & more
The title above refers to yesterday's second last paragraph here where I discussed Mr. Deal's misleading of TRAC and the public by stating that the 1% rule indicated that chlorobenzene concentrations had to equal or exceed 4,900 ug/l (ppb.) to indicate possible DNAPL upgradient. That is nonsense based upon the multitude of dissolved chemical contaminants in Uniroyal/Lanxess's groundwater. Much lower concentrations based upon the EFFECTIVE Solubility would indicate DNAPL nearby.
Five minute wonder Hadley (Lanxess) advised TRAC that Lanxess are now thinking of recirculating treated groundwater into the Elmira Aquifers. This sounds the same as suggestions decades ago to "reinject" allegedly clean groundwater back into the aquifers. I'm skeptical and for good reason.
TRAC were advised that the MECP are not ready to finalize the Risk Assessment after all these years (of deception, delay and obfuscation-my comments). My guess is that they too are wondering if the public will be able to swallow the "no unacceptable risks" bulls**t Lanxess (Stantec) are selling.
Sebastian actually advised at Thursday evening's TRAC meeting that the pumping at on-site well PW4 was "woeful". He is correct yet for him to criticize Lanxess so harshly is music to my ears. That well is the MAIN well preventing the grossly contaminated on-site Municipal Upper (MU) from flowing off-site and recontaminating the Elmira Aquifers all over again. These excuses by Lanxess do not bode well for the promised pumping forever (in perpetuity) on the Uniroyal/Lanxess site.
One more of these excuses was presented by Allan Deal advising that an "engineering buffer" is built into the Target pumping rates. This is to suggest that the Target Rate is flexible and can be readily under achieved without consequences. One that is not what we were told decades ago and to this day the following sentence is written in the footnotes (1) below each month's (Progress Report )Table of Average Daily Pumping Rates : " GHD recommends that Lanxess maintain the target pumping rates greater than or equal to these rates." So quit making excuses and get your G.D. pumping rates back where they belong which is the long ago approved TARGET PUMPING RATES!!!
Apparently the Ontario MECP are writing some kind of tech report about the Risk Assessment. Whoopdy Do !!! Now it sounds as if Lanxess may share that report with the downstream farming families (Old Order Mennonites) first and then later with TRAC. Well the good news for Lanxess is that they will not get much if any opposition from either group.
Again Lanxess are terrified about both on and off site DNAPLS hence repeated attempts to either manufacture or enhance "evidence" that might suggest they don't exist and never did. Comparing chlorobenzene concentrations in wells PW4 (on-site) and W4 off-site is one example. Allegedly the chlorobenzene concentrations have been dropping in W4 and not so much in PW4. If this proves anything it is that the free phase DNAPL beside PW4 on-site at well OW88 is greater in mass and volume than the DNAPL found beside the Howard St. water tower in well OW57-32 which instigated W4 being located right there.
Thank you Mr. Deal for using Varrnicolor Chemical as a distraction to TRAC members. At the same time you have emphasized how Varnicolor were/are a source of contamination to the Municipal Aquifers in Elmira albeit allegedly only of six solvents including very toxic Vinyl Chloride, DCE and others. Also we are advised that after 35 years Varnicolor still is not fully remediated either, as the owner who tried to get a clean bill of health in 2016 from the MECP has given up on it.
I would characterize Thursday's TRAC meeting as an exercise in Dishonest Sincerity by GHD. Woolwich Township should be ashamed of their enabling this manipulation and deception of their citizens.
This is certainly accurate for the newer, younger Township councillors. They haven't got a clue albeit how could they? The CAO, mayor and former TAG Chair Tiffany Svensson are totally different. Unless all three are far stupider than I give them credit for, then they know full well what's going on and are a part of it. Last night's TRAC meeting was yet another case of the same two twits, Luis Almeida and Allan Deal strolling down the garden path with untrained amateurs in tow. Now the likes of Eric Hodgins (RMOW) and maybe one or two other professionally trained persons not so much. I suspect that this is the reason honest persons such as Katherina Richter and Dustin Martin walked away from TAG. The stench of complacency and bulls**t was too overpowering. Only one TRAC member last evening showed the slightest amount of common sense and outrage and that was Sebastian Seibel-Achenbach. He pushed hard against both Luis and Allan Deal's plethora of excuses and lies regarding Lanxess's major pumping reductions and failures especially on-site albeit off-site as well.
Agenda Item 5.1.2.3 discussed pumping rates. and as indicated above it was yet again excuse after excuse as to why over the last three to four years both on and off-site pumping has been decreasing. Decreasing by ridiculous amounts especially when we are told that they aren't going to achieve drinking water standards by 2028. Does an Olympic athlete after being told that he is shy of the Olympic standard, slow down? Does he coast when his coach tells him it's time to get to work ? That is exactly what Lanxess have been doing while making up excuse after excuse rather than getting to it and pumping MORE as they have promised to do in the past.
Then we get to what passes for an "investigation" by these clowns. CRA have been caught over the years fudging and pretending that they are doing scientific inquiry and studies. Dr. Richard Jackson (former TAG Chair) literally laughed at their so called "pilot testing" of ISCO (In Situ Chemical Oxidation). Both Morrison-Beatty's and CRA's DNAPL "investigations" were a farce intended to disprove the obvious which had even been admitted privately by Frank Rovers (CRA) that the site was filled with DNAPLS whether free phase or residual. Honest interpretations of the data showed the same thing.
Last night's "Chlorobenzene Source Evaluation " at TRAC was more of the same. Essentially Allan Deal (GHD) set out to "prove" that Dr. Neil Thompson of the University of Waterloo was wrong when he reported several years ago that there was an excess 1300-1900 kg. of chlorobenzene in the Elmira Aquifers. That "excess" was based upon Uniroyal Chemical records showing exactly how much chlorobenzene was used in production over the decades and how much chlorobenzene was discharged into the wastewaters dumped on site. Lanxess later reported that isotopic analysis proved that it was different chlorobenzene in parts of the Elmira Aquifers than what was discharged on the Uniroyal site.
Mr. Deal's "investigation" had four components to it of which he failed to share the results of the alleged "review of historic chlorobenzene users"; he installed one whole new monitoring well somewhere with a blurry map of where; he collected samples and analyzed them for VOCs and finally he collected samples for isotope analysis. Not a mention by Mr. Deal of Borg Textiles as a historic chlorobenzene user. What relevance was there for the new monitoring well? What did it prove or disprove? His analysis of samples for VOCs was irrelevant in that the samples were from Varnicolor Chemical and "are not COCs at the Lanxess site" which is a whole lot different than saying they are not on the Uniroyal/Lanxess site. COCs are Contaminants of Concern and chosen by Lanxess. Finally the isotopic analysis. What a pile of pus . Where were the samples whether shallow soils or groundwater from the other "historic chlorobenzene users" such as Borg.? No evidence was shared with the public five years ago from Dr. Neil Thompson (likely shared with Lanxess) and the repudiation of it by Allan Deal was presented with equally vague and weak evidence as far as laypersons and the public are concerned. Basically Mr. Deal proved nothing.
On page 16 of Mr. Deal's "Chlorobenzene Source Evaluation" he discussed solubility and the 1% rule. His written quote from the Environment Agency seemed accurate but then he verbally fudged it's interpretation by suggesting that 4,900 ug/l (ppb) was the concentration criteria suggesting DNAPL upgradient was possible. That is false as the lab solubility of chlorobenzene in water is 490,000 ug/l in pure water NOT NOT NOT in the grossly contaminated groundwater on the Uniroyal site. The real on site solubility is referred to as the EFFECTIVE solubility exactly as the quote indicates. Mr. Deal verbally misled TRAC and the public. Feel free to alter the recording to protect the entire, long term DNAPL coverup.
This is the third TRAC meeting and all three have been propaganda sessions. I left last night's meeting at the end of the alleged DNAPL/Chlorobenzene investigation. It's been decades of professional liars spewing junk science to generally spineless but sociable wimps. I'll catch up on the new Control Order and likely pretend, new remediation when the meeting is up on the Township's website. TRAC is also carrying on their anti-public behaviour in either denying them the right to ask questions or delaying it unnecessarily.
The tail is Lanxess and the dog is the cleanup. This perversion tells the tale of who is really in charge in Canada. It is corporations who are above the law. Why wouldn't they be? They lobby governments for laws, rules and regulations that are corporate friendly. They make all the major decisions behind the scenes. If political parties want major corporate donations whether above or below the table then they do what they are told. Or quoting Sebastian Seibel-Achenbach and others "He who pays the piper calls the tune."
The MIckey Mouse cleanup in Elmira since 1989 has been 100% under the control of Uniroyal Chemical, Crompton & Knowles, Chemtura and now Lanxess. Lanxess have given us significant groundwater pumping reductions both on their site and off-site throughout Elmira. They have given us a pathetic, biased Risk Assessment (R.A.) stating that there are no unacceptable risks in the downstream Canagagigue Creek from Uniroyal/Lanxess. Well of course they aren't unacceptable to Lanxess and their fellow travellors . Stantec who did the R.A. did so accepting the data from Lanxess/GHD at face value. It was biased data throughout the length of the Creek based upon improper sampling methods (shovels v. core samplers) and inflated laboratory Method Detection Limits (MDL) above government health criteria thus eliminating valuable data and health exceedances.
Who are Uniroyal/Lanxess's fellow travellors? First and foremost are the Ontario Ministry of Environment (MECP). Call them a captured regulator or whatever you will the government of the day has never given them the financial backing to successfully take on corporate giants in our courtrooms. Speaking of our courtrooms they are the playground of the rich and that too is no accident. The wealthy feel that they have a divine right to rule this country and have made certain that they and their friends are given status and respect within the judicial system which again political parties have molded to suit them and their friends needs, not yours or mine.
Further fellow travellors include municipal councils, regional councils, GRCA, and many more. All well off groups financially who have vested interests in maintaining the status quo. All of these groups will grudgingly follow mass citizen movements but they will never lead them or help them initially. Whether modest change or revolution none of these groups want change. Hence the inertia and lethargy by our authorities to step up and honestly address public problems, especially those that have been contributed to by our complacent governments and various authorities.
Some pits and ponds were emptied and backfilled in the 1980s BEFORE the announcement of NDMA in Elmira's drinking wells. I believe that our authorities were not at all taken by surprise but were fully cognizant that they had contaminated Elmira's drinking wells long before November 1989. In fact I fully expect that the lying sh**s knew that they had contaminated both the north wellfield (E2, E5, E8 etc.) as well as the south wellfield (E7, E9) probably no later than 1979.
On-site cleanup since the start of the Elmira Water Crisis in November 1989 has not been zero. In late1993 a few DNAPLS were removed from TPW-2 and RPW-5 and put into the Mausoleum or Envirodome along with the contents of RPE4 & 5. Then in 1999 the Mausoleum was emptied and the contents trucked to Corunna near Sarnia for burial in an alleged, secure hazardous waste site. Later on a few more DNAPLS were inadvertently found near RPE-3 and removed. There was also some excavations of creekbanks and part of an island in Canagagigue Creek in the early 2000s. I believe that there may have been some relatively minor further creekbank excavations on the north-west side of the Creek as well .
The problem with both the excavations in the 1980s as well as the 1993 excavations is that only visible surface wastes were removed. Jeff Merriman, a Uniroyal Chemical engineer, bragged to UPAC & CPAC that excavations stopped when they could no longer see or smell the contamination. Not exactly a serious scientific analysis especially considering the known leakage through the bottom of the pits (3,400 litres per day on the west side alone) according to CH2M HILL , consultants to the Region of Waterloo.
Now today in September 2024 Lanxess want us to believe that they are serious about doing remediation that could have and should have been done 25 or 35 years ago. They will also likely claim that the remediation today is so much better than it used to be. Really? Dr. Richard Jackson (TAG Chair) advised TAG and the public in late 2016 that there were no "magic bullets" i.e. new cleanup methods. Perhaps some of the numerous remediation methods have been fine tuned, chemical amendments added etc. . That in itself would be great but are we going to trust the professional liars (Lanxess & the MECP) to be in charge of that cleanup after the mess they have made together for the past 35 years? Secondly will they only cleanup the off-site Elmira Aquifers or will they actually clean up as well the former Uniroyal site itself to ensure that down the road negligence doesn't re-contaminate the Elmira Aquifers?
Or perhaps Lanxess and the Ministry (MECP) just want to talk about new remediation methods for the next 35 years. Talk alone is cheaper especially if you ignore the value of the environment and the lives of human beings and wildlife.
