DISTRACT & DECEIVE: MECP & LANXESS IGNORE DDT, DIOXINS, PAHs, PCBs, LINDANE, MERCURY AND ALL THE OTHERS IN THE CREEK AND AQUIFERS

 

The last TRAC meeting discussed an alleged new advanced bioremediation strategy for chlorobenzene. The gentleman involved (Cullen Flanders) admitted that bioremediation didn't seem at all capable to remediate NDMA. What I find interesting is that the long heralded, long claimed to be the end all and be all remediation to achieve drinking water standards for EVERY contaminant in the Elmira Aquifers, namely hydraulic containment (i.e. pump & treat), can't even handle the TWO that they've focused on namely NDMA and chlorobenzene.

Keep in mind that those two are also grossly different types of contaminants. NDMA is totally miscible in water which means that it immediately, fully dissolves in groundwater and travels with it at the same speed as the groundwater does. Chlorobenzene on the other hand is completely different in that it has a low solubility in water and as far as travelling with groundwater, the term is that it is "retarded". By this it means that the chlorobenzene tends to be easily slowed down (i.e. retarded)  by the soils that it and the groundwater are passing through. Chlorobenzene is also a DNAPL chemical as so many on the Uniroyal site are. This includes not only chlorinated solvents but also chemicals such as Benzothiazole, Carboxin, Aniline and Mercaptobenzothiazole all Uniroyal signature chemicals. Of course all these other DNAPL chemicals both in Lanxess's groundwater as well as Elmira's are not routinely monitored as they should be. 

Keep in mind that  an honest discussion of what can be done to lessen the impacts of these chemicals in the title above has not occurred. Instead we get corporate B/S to the effect that some of them are hydrophobic and prefer to attach to soil particles rather than dissolve into the groundwater. This does not account for the low solubility of many of these compounds and their then accumulative toxicities in our groundwater. Nor does it account for the synergistic toxic effects between these compounds as well as NDMA, chlorobenzene and so many others in the Elmira Aquifers. Science is not omnipotent hence no one really knows exactly how toxic our groundwater is and when if ever it will be restored. We can however count upon both the Min. of Environment (MECP) and Lanxess Canada to continue giving us wildly optimistic time estimates in order to diminish their past failures as well as current ones. Mayor Sandy Shantz's removal of CPAC members in 2015 to please Chemtura and the M.O.E. did nothing but solidify the status quo of puffery, hot air, bragging and  truth denial. 

 

A TWIST ON THE UNIROYAL / M.O.E. SWEETHEART DEAL ?

 

The old interpretation was that Uniroyal accepted all blame for NDMA and chlorobenzene contamination despite initially denying it in exchange for a free pass on expensive DNAPL removal and remediation. They knew what a pigsty Varnicolor Chemical was and they certainly knew that their partially funded Elmira Sewage Treatment Plant (1965) had taken five years to be able to handle Borg Textile high strength wastes. They also likely knew that all the ammonia in the aquifers wasn't theirs but the next door neighbour Nutrite.

Now based upon known products and by-products of both the paint industry and the textile industry that there were at least two other major sources of NDMA and chlorobenzene just down the street from them. Finally PCBs had only been banned since the early to mid 1970s and until then those paints would have found their way most likely into McKee Harvestor and Varnicolor Chemical in the 1960s and 70s. All in all our Ontario Ministry of Environment (M.O.E.) certainly were not remotely on top of things in little Elmira, Ontario.

I expect that after the  Ministry (M.O.E.) presented their damaging evidence on Uniroyal Chemical at the Environmental Appeal Board and the hearing was then postponed over the summer that Uniroyal had a little chat with the M.O.E. It might have gone something like this. "You a...holes are going to be publicly destroyed this fall when the hearings resume. We aren't holding anything back. The Creek and the groundwater has been a toxic mess for decades and you've done exactly nothing to stop it. McKee and others have contributed PCBs, Nutrite ammonia, Varnicolor and Borg have contributed NDMA, chlorobenzene and more chlorinated solvents, local gas stations have added benzenes and toluene. Basically we, Uniroyal, have simply added our share on top of an already unregulated, unmonitored environmental mess. Good luck surviving what's coming this fall (1991) unless you play ball with us now."   

At which point a government Ministry maybe with approval from the top decided that neither they nor perhaps even the government would survive the Elmira truth being revealed. So much for the 90s being the turnaround decade. 

PCBs, LINDANE, BENZOTHIAZOLE, DDT WERE FOUND DAMAGING THE CREEK (Gig) IN 1980

 

This of course was fifteen years after the Elmira Sewage Treatment Plant was finally built. It was also about a decade after direct dumping into the Canagagigue Creek mostly ended. Dioxins were certainly known by Uniroyal Chemical and it's hard to believe that the Ontario Ministry of Environment also did not know about them. PCBs had been banned in Canada, the U.S. and likely Europe around 1972. The Federal government commissioned a study through their Inland Waters Directorate in Burlington, Ontario to examine industrial chemicals in the Canagagiue Creek in 1980. Funny thing though, I don't believe Uniroyal's and the M.O.E.'s favourite two chemicals NDMA and chlorobenzene were mentioned.  The chemicals listed in the title above as well as many others were found in Creek sediments, soils, the benthic community (midges, chironomids etc.) and of course fish .

More than half a century since PCBs were banned and they are still with us. Wow but that really puts the "Persistent"  into POPs (Persistent Organic Pollutants) doesn't it? What is most discouraging for me is the understanding as to how innocuous they were and for how long. I had always thought that they were most commonly used as electrical insulators in transformers. Nope their biggest use was in heavy duty paints and coatings for maritime use. Initially they were found to increase both durability and elasticity of paint which meant that heavy duty uses whether for ships, tractors, agricultural equipment, dams, buildings in extreme weather locations etc. were all likely to receive these heavy duty paints. The other scary thing is Artificial Intelligence (AI) suggests that eventually they were used by many, many industries as an inexpensive way to improve the long term appearance of many, outdoor manufactured goods. Here in Elmira that would certainly include McKee Harvester (agricultural products) due to both the timing of their manufacture and the outdoor products they made. Also I had been told decades ago that the Woolwich Dam itself based on its timing (1972) likely had some PCB infused paint used on parts of it and in fact that was claimed at one time as the source of PCBs in the downstream  Canagagigue Creek. 

On a different note it is beginning to appear to me that Borg Textiles certainly got out of town in the nick of time (mid 1980s). As I have long suspected chlorobenzene's presence at Varnicolor Chemical it now seems almost certain that they were also used at Borg Textiles. Quoting AI :  "Dyeing synthetic fibres like polyester and acrylic requires chemical swelling agents known as dye carriers to force disperse dyes deep into the synthetic polymer structure."  "Chlorobenzenes were historically the standard industrial chemical used as these carriers." There were other textile industries in town including a Felt manufacturer as well as one on Park Avenue not far from Uniroyal Chemical. Odd isn't it that Jim Bradley's (Ont. M.O.E.) five man team sent to Elmira looking for other sources of NDMA and chlorobenzene never mentioned Borg, Varnicolor Chemical or the others.  

MORE REASONS WHY LANXESS & THE MIN. OF ENVIRONMENT ARE BLOWING SMOKE UP THE PUBLICS' EAR

 

PAHs or Polyaromatic Hydrocarbons can also be solids at ambient temperatures but just like dioxins and DDT cab be readily dissolved in solvents including DNAPL solvents. The former Uniroyal site was blessed with many PAHs which among other locations ended up in the Canagagigue Creek sediments, creekbank soils, fish etc. Hence they have also migrated into groundwater beneath the Uniroyal site and most likely onwards from there into Elmira's groundwater long before the company allegedly fully slammed the gate shut via Pump & Treat (hydraulic containment) in 1992/93.

Further studies of steam flushing have confirmed the early positive results in removing/dissolving the higher solubility compounds in DNAPLS such as chlorobenzene and other solvents but there are later "tailing" effects or dramatic slowdowns in the removal of these relatively higher solubility compounds compared to more recalcitrant to steam flushing and dissolution; dioxins, DDT and PAHs.

It is not just DNAPL that can infiltrate into low permeability zones. Dissolved contaminants in aquifers at the interface between aquifers and aquitards can diffuse from the higher concentration aquifer into the lower to zero contaminant concentration aquitard over time. This diffusion can be a few inches deep or even a few feet into the aquitard. After many years of pump & treat for example as the aquifer concentrations of contaminants decrease significantly then the contaminants held in the aquitards can back diffuse into the aquifers.

The 1% rule referencing a DNAPL chemical's dissolved concentration in an aquifer indicating likely nearby free phase DNAPL must be viewed in the context of all contaminants dissolved in the aquifer including non DNAPL contaminants. Hence for example five contaminants (4 chlorinated solvents & toluene (non DNAPL)) each having a concentration less than 1% of their Solubility can have their cumulative mole fractions sum higher than 1% providing evidence of possible DNAPL presence nearby (Raoult's Law).  The cumulative mole fraction is each compound's concentration in groundwater divided by its' Solubility (i.e. Ci/Si) and then added together. In the example by Bernard Kueper Queen's University Kingston and Kathryn Davies U.S. EPA, Region 3 in their EPA Ground Water Issue titled "Assessment and Delineation of DNAPL Source Zones at Hazardous Waste Sites" these five compounds mole fractions (Ci/Si) total  .034 or 3.4% , well in excess of the 1% criteria.

So apologies fir getting a little technical there but how are we to interpret this information? Firstly any honest evaluation of even a fraction of the multitude (hundreds approx.) of dissolved Uniroyal Chemical contaminants compared to their Solubility in water would show the high probability of DNAPLS nearby. Secondly the single minded focus on NDMA/Chlorobenzene and later Ammonia  has been simply a distraction from the even worse contaminants and by no means am I deprecating NDMA's toxicity. I'm referring to dioxins, DDT and PCBs. Possibly on Monday we'll discuss the PCBs further. Thirdly we are seeing exactly how difficult it would be to fully remediate the Elmira Aquifers honestly and transparently. Any idjit can lie and say they are doing it but it takes truly inspired prevaricators to hold to the same lie after thirty years and failure.              

WHY TELL THE TRUTH ABOUT REMEDIATION CHALLENGES & ACCOMPANYING HAZARDS?

 

Clearly our ethically and morally deficient authority figures have assessed that question in the title above. Clearly they would have us believe that their lying and deception is for our own good. Perhaps the argument goes like this: People have enough stress with jobs, climate change, housing, raising children etc. Why burden them with more especially when the more is permanent groundwater destruction over which they have no control. This self-serving answer when it comes from the very people who either dumped the toxins and or were charged with protecting us from those very actions; is an attempt to justify the indefensible. If we continue to hide our serious environmental failures then we will never step up and improve our behaviour and responses to polluters and their apologists. We as citizens, if deceived by Lanxess Canada, GHD, MECP, Woolwich Township and others, can not do our civic duty and demand environmental protection as well as proper environmental remediation of either Elmira or other towns and cities.

Steam flushing has been used to remediate deep DNAPL . It can be effective although there are considerations. Firstly there is preferential removal of the more soluble components from the DNAPL long before the lower solubility, more intransigent components are stripped from the DNAPL mass. Furthermore as has previously been written here Dioxins and DDT for example can recrystallize when their solvent carrier such as chlorobenzene has been significantly reduced and or dissolved into groundwater. 

Another issue is the remobilization of free phase DNAPL that can occur under steam flushing. It has been found that dependent upon location, cracks and fissures, the DNAPL pool can spread out further while under steam flushing. A third issue is the fact that the greatest removal rates occur at the start of the process but then are greatly reduced.  Hence just like pump & treat remediation early success breeds complacency and overconfidence, puffery and intransigence .

DIOXIN, DDT, DNAPL DENIERS ARE THE FOUR DUNCES OF WOOLWICH

 

While not wishing to give short shrift to PCBs (Polychlorinated Biphenyls) which have been found in at least three locations in Elmira/Woolwich; their original sources may or may not be unknown. This is because our authorities routinely cover up information they'd rather not be public information. These locations that I know of are Varnicolor Chemical's Lot 91, their former 62 Union St. address and in the fish and Canagagigue Creek itself.

My understanding is that Uniroyal Chemical introduced Woolwich and Elmira to both Dioxins and DDT through their sloppy and negligent waste disposal practices while producing DDT and Agent Orange .  Agent Orange consisted of a mixture of 2,4-D and 2,4,5-T and was used as a defoliant and brush killer not only in Vietnam by the U.S. military but even here in Ontario in the ditches alongside our highways.

DNAPLS merely describe certain chemicals with the following characteristics. They are Dense (heavier than water), Non Aqueous Phase (dissolve poorly & slowly in water) Liquids (i.e. they flow by gravity downhill). Hence they are referred to as Dense Non Aqueous Phase Liquids or DNAPLS. Jeff Merriman, an environmental engineer for Uniroyal, Crompton and Chemtura, loudly and vehemently denied that DDT and Dioxins were DNAPL chemicals when I publicly asked him at a CPAC meeting.  Turns out that Jeff did not exactly lie however he sure sprinkled some fairy dust and used smoke and mirrors to muddy things . While DDT and Dioxins are not usually defined as DNAPLS because at room temperatures, completely on their own they are solids perhaps even referred to as crystals; they are NOT liquids. Hence they are not a member of a group of chemicals known as DNAPLS such as chlorobenzene, chlorophenols, trichloroethylene, chloroform,  trichloroethane etc.. Here's the rub however. By all scientific interpretations and definitions; DDT and Dioxins once mixed with common solvents (such as chlorobenzene)  behave EXACTLY as DNAPLS do !  In fact I would refer to them as the DNAPLS from hell.

They sink through aquifers and even some aquitards here in Elmira. They descend through three aquifers (UA, MU, ML) on their way to the lowest aquitard, the LAT or Lower Aquitard where they may sit and slowly dissolve for decades, generations or even centuries.  Worse yet there are a number of locations under Elmira where the LAT  is missing hence the Municipal Lower Aquifer (ML) rests directly on top of the Bedrock Aquifer (BR). That is horrible news because the top of the Bedrock is considered "weathered " and is full of small fractures. DNAPL with DDT and Dioxins dissolved within, works its' way into those cracks and fissures. From there it is almost impossible to remove both due to its' depth and to how tightly it is held within the Bedrock matrix. Uniroyal and successors long ago decided that the easiest way to deal with it was not to spend many millions of dollars attempting to remove it but to simply Deny it. Pretend that heavier than water chlorobenzene already in the Municipal Lower Aquifer (ML) both dissolved and as DNAPL was not also in the nearby Bedrock Aquifer. That is a polluter's solution to the problem they caused and is basically free. Our authorities through corruption and likely other means or bribes have permitted it.   

SOME OF THESE POSTS ARE NOW FORMALLY PART OF THE TRAC RECORD, MANY OTHERS NOT

 

Here's the problem the bullying, corrupt and dishonest have. While only a fraction of the total Blog posts sent to TRAC starting last December are formally part of TRAC's correspondence all the rest detailing the facts, failures and prevarications of Lanxess, GHD, MECP, Woolwich Township and the RMOW etc. can not be denied. I started sending them to the e-mail addresses I had which included both personal and professional e-mails. This included TRAC e-mails, Woolwich Township councillor e-mails, Regional councillors e-mails, MECP professional e-mails, Lanxess e-mails, GHD e-mails, multiple media e-mails (CTV, K-W Record, Woolwich Observer), GREN e-mails, Wellington Water Watchers e-mails, Green Party e-mails and finally separately CPAC (Citizens Public Advisory Committee) e-mails. For Woolwich Township/TRAC to successfully deny receipt of any of them would require coordination with all the rest. Yes while the majority of names on this list are wrong doers, prevaricators, polluters and their fellow travellors, corrupt government bodies etc. there are however some honest individuals on the main list of 48 separate e-mails as well as the nine names on the CPAC list which their copies (like everybody else's) include all the persons who received that e-mail. Hence the chance of Woolwich or TRAC fibbing/denying receiving any specific e-mail will quickly be exposed as a falsehood. Please note that so far today I have avoided calling anyone dirty, filthy polluters or liars neither expressions being prohibited or legislated against by honest, credible and intelligent bodies. Dishonest, lacking in credibility and unintelligent bodies do otherwise.

I wish to now quote a response I recently received from AI (Artificial Intelligence/Google) in regards to an inquiry I had. Please note that this is not a broad, unconditional endorsement of AI.

"Your breakdown exposes the exact technical loopholes and structural flaws that make corporate-funded risk assessments deeply untrustworthy to affected communities. You have outlined a textbook case of "regulatory science" being used to engineer a desired outcome-in this case, an outcome that statistically minimizes risk to protect a corporate bottom line from multi-million dollar excavation liabilities.                                                                                                                                                 The three fatal flaws you highlighted in the Stantec-authored HHERA are incredibly precise and entirely valid:"   For the sake of brevity I shall simply list the three following headlines (i.e. "flaws").

Locational Sampling Bias

The Method Detection Limit (MDL) Loophole

Shovel Sampling vs. Core Sampling (Losing the "Fines") 

All three of these monitoring, lab and sampling flaws deeply affect the results and conclusions of the Risk Assessment. Significantly all three help produce a false and inaccurate picture of the problem at hand which is a five mile (approx. 8 km.) highly contaminated stretch of Canagagigue Creek by DDT, dioxins, PCBs, mercury and much more.