TRAC & WOOLWICH TWN. GIVE YOUR HEADS A SHAKE! ENVIRONMENTAL COVERUPS & PHONY CLEANUPS ARE THE NORM, NOT THE EXCEPTION

 

I'm also going to add that government communications with the public are also usually disingenuous and misleading if not outright dishonest. Those communications have gotten so shoddy in both quantity and accuracy that it's now to the point that government's hiding secrets will look citizens in the eye and tell them "Sorry we can't clarify this or explain why because we have been forced at gunpoint/torture or worse to sign NDA's (Non-Disclosure Agreements)". The "or worse" for politicians simply means that they are afraid that they might get kicked out of office at the next election if they honestly tell why they have taken an action such as say spending $55 million dollars assembling and removing from production 600 acres of prime farmland in Wilmot Township. 

One of the biggest political lies is that there are no negative health effects from environmental spills and accidents. With one hand behind their backs and two fingers crossed they can honestly (in their wee minds) state this because knowing that all of us are mortal anyways they can justify the lie by telling themselves that those folks were on their way out regardless and if not from mercury, nitrates, TCE, NDMA,  vinyl chloride, smoking or drinking they are going to die anyways either from time or something else. Examples abound including the train derailment in East Palestine U.S.A. two or three years ago, Grassy Narrows mercury poisoning for the first decade after it went public, Agent Orange damages in Viet Nam and to American servicemen, trichloroethylene (TCE) via vapour intrusion in the Bishop St. community in Cambridge causing cancers and death, and many premature deaths in Elmira, Ontario both from Varnicolor Chemical and Uniroyal Chemical including a foreman at Varnicolor already diagnosed from solvent poisoning prior to the shutdown at Varnicolor and then his subsequent employment at Uniroyal. 

The vast majority of cleanups promised are the Cadillac cleanups whereas the reality is simply Volkswagon Beetle cleanups. This most certainly includes the Varnicolor Chemical "cleanup" back in the mid 1990s which was supposed to then require ten years of shallow pump & treat (hydraulic containment) however by 2016 the pumping was still going strong and only in 2024 were we finally told that yes indeed Varnicolor Chemical had contributed half a dozen toxic chlorinated solvents to our deeper municipal drinking aquifers after thirty-five years of government lying (M.O.E.) and coverup. In fact M.O.E. lawyer Stanley Berger back in 1991 at the public Environmental Appeal Board  hearings in Elmira actually stated that Varnicolor's pollution compared to Uniroyal was like a water pistol in a thunderstorm. The same dishonesty has been going on with the Uniroyal "cleanup" from day one with all government tiers claiming success by the mandated 2028 cleanup for twenty-five years (1993-2018) and only admitting failure AFTER the 2011-2015 Citizens Public Advisory Committee (CPAC) publicly advised Woolwich Council and the M.O.E. that it absolutely wasn't going to happen on time or even close. Now even the most blatant truth challenged parties agree, and the excuses with help from a few misguided citizens, are in high gear.       

HOW MANY MORE UNKNOWN LIES & DECEPTIONS ARE THERE CONCERNING THE UNIROYAL/LANXESS SITE?

 

How can one look at a map of the Uniroyal Chemical property (plus pits & ponds) and not be appalled? It is absolutely shocking how much of the site was taken up with toxic waste disposal. There were approximately twelve different pits and ponds of various sizes on the west side of the Canagagigue Creek and another twelve to fourteen on the east side of the Creek. The west side waste pits/ponds included RPW-1, RPW-2, P1, P2, RPW-3, RPW-4, RPW-5, RPW-6, RPW-7, RPW-8, M2, TPW-1, TPW-2. The east side had  IR-1, IR-2, RPE-1, RPE-2, RPE-3, RPE-4, RPE-5, TPE-1, TPE-2, BAE-1, RB-1, RB-2 and allegedly GP-1 & GP-2. At least these are the ones that I know of and that have documentation as to their size, location and contents. 

Uniroyal's intent was obvious with Pits and Ponds on both sides of the Creek through their property. None of these pits were covered from the elements so especially during rainstorms any pits that weren't already full and overflowing from the known 165,000 gallons of liquid wastes per day transported just to the east side alone, quickly would be. Surface drainage from the site ran into the Canagagigue Creek. This was not an accident. The Creek's water quality plummeted and many species in and around the Creek disappeared.  Where was the Ontario Ministry of Environment? How about the Ministry of Natural Resources? Maybe just like at Varnicolor Chemical down the road (Union St.) they were sitting in the office enjoying a licensed refreshment. 

What may have been an accident was the gross contamination of the multiple aquifers beneath the Uniroyal site.  Afterall the company knew that the shallow aquifer (UA) discharged directly into the Canagagigue Creek so likely they hoped/expected that the bulk of their liquid wastes simply would flow into the Creek just as the surface flows did. Also it is possible that the environmental savages did not know about the "windows" allowing direct flow into deeper aquifers that were between the UA (Upper Aquifer) and the Municipal Aquifer (MU) .  Or maybe they did and they just didn't care.

The Region of Waterloo didn't start using the Grand River for drinking water until the 1990s. I thought that that was pretty dumb at the time and still do. This most likely was because they had been told that on-site direct discharge to the Canagagigue Creek had ended around 1970. What a shocker later on after Cryptosporidium deaths made it clear that local farmers were still grazing their cattle in both the Grand River as well as its' tributaries such as the "Gig", the Conestogo and others. Then of course there were little problems such as multiple landfills without leachate controls, both legal and otherwise, along the Canagagigue that had accepted Uniroyal and Varnicolor Chemical wastes. 

We now know that there were multiple other potential industrial sources of chlorobenzene in Elmira located close to the corner of First and Union St.. I expect that we will eventually learn that the same occurred with NDMA but it's more politic not to reveal that for a little while longer. This is embarrassing information to the former M.O.E. (now MECP) who cut a sweetheart deal with Uniroyal Chemical. That deal had Uniroyal (falsely) admit to be the sole source of NDMA, chlorobenzene and ammonia in exchange for not having to properly clean up DNAPLS both on and off their site as well as for not ratting out the M.O.E.'s cooperation/incompetence in stopping their grotesque pollution sooner. One other recent admission from Lanxess Canada and consultants was that Varnicolor Chemical contributed half a dozen chlorinated solvents to Elmira's Municipal Aquifers albeit allegedly not chlorobenzene. Do you think this decades late admission is related to the Ontario Ministry of Environment's reneging on a public promise made to APTE, the Varnicolor Liason Committee (Rich Clausi, Ted Oldfield & myself) to fully examine Varnicolor horizontally and vertically back in the mid 1990s? They did neither as the still non public cleanup done at Motiveair Inc. behind Varnicolor would indicate along with the belated deep Municpal Upper Aquifer contamination admission.

Corruption stinks and the stench from the MECP is still overpowering! 

HYPOTHETICALLY OR NOT IS THIS WHAT OCCURRED BETWEEN THE ONT. M.O.E., UNIROYAL CHEMICAL, WATERLOO REGION & WOOLWICH TOWNSHIP FROM 1989-1991 ?

 

Everyone was hissy with everyone else at least in private. Blame was cast back and forth between Uniroyal and the Min. of Environment and the other two political tiers piled on. Then Uniroyal and the Ontario M.O.E. basically told the Region and Township to bugger off. And they did. No running to the courts. No running to the media to badmouth Uniroyal or the M.O.E.. The biggest bullies are also usually the biggest cowards and neither the Region nor the Township wanted to be on the bad side of the province and their variety of infrastructure grants and more. Even the realization of poisoned tap water in Elmira was more acceptable than losing out on millions of dollars of infrastructure grants (roads, sewers, water pipes, bridges, etc.) which eventually would have cost both regional and municipal councillors their jobs as councillors.

So once the polluter and their regulator had flexed their muscles and told the Region and Township to take a hike and they had; the die was cast. Two years later the M.O.E. and Uniroyal announced a bilateral agreement between themselves that totally bypassed the Township, the Region and local citizens who had organized and gotten  party status at the Environmental Appeal Board. The October agreement ended up as a November 1991 Control Order laid on Uniroyal Chemical.  The other parties both political and citizens were left in the dust. Now with admirable cowardice and a wish to ingratiate, the two political groups complained only mildly and begged to be let back in to the fold and Uniroyal file. The citizens group leadership knew where they wanted to go and how to do it. They too made commitments that got them invited to the pending January 1992 initial UPAC (Uniroyal Public Advisory Committee) meeting. 

Woolwich Township offered to organize regular public meetings (i.e. UPAC). They offered to present a united front to the public. A united front that the Ontario M.O.E., in negotiations with Uniroyal Chemical, was happy with. Similarly Waterloo Region also wanted to be part of the initial UPAC public meetings. Their support for the M.O.E.'s and Uniroyal's direction might be less enthusiastic than the Township's as they pressed for a somewhat better cleanup. Both the Township and the Region also received money from Uniroyal Chemical towards their increased environmental and legal costs incurred during the first two to three years of the water crisis. 

It was business as usual especially with local citizens getting scr*wed the most, including by their own.    

MONEY IS THE ROOT OF ALL EVIL - JUST ASK CONESTOGA ROVERS & ASSOC.

 

As soon as I saw the phrase Conestoga Lands Inc. in reference to the proposed zoning change and breach of the country side line on Bridge St. in Waterloo, Ontario I smelled something rotten in the air. Was it possible that a (in my opinion) rotten company, long ago merged with a bigger maybe less rotten firm, could still be spreading their anti social, anti environmental actions upon unsuspecting citizens? Well now that is a tricky question. I did a little bit of research trying to find out if the developers behind this proposed industrial site located beside Martin Grove Village in north Waterloo were indeed the former Conestoga Rovers & Associates (CRA) who made their initial claim to fame with the Love Canal disaster in the United States.

Well things get a little murky here. First of all CRA merged with GHD an Australian engineering firm around 2015 or so and carried on in name as GHD. CRA employees and shareholders were given shares in GHD and many (most ?) carried on with the new group. That being said the reference to CRA Lands Limited does refer to my least favourite engineering firm who are multiple winners of the MACHO Award.  They were presented with this award for their work with Uniroyal Chemical in Elmira and the award name stands for Memorial Award for Creative HydrogeOlogy. 

Now here's the rub. According to Google/AI,  CRA Lands Limited while referring to lands formerly owned by Conestoga Rovers & Assoc. are actually owned by a group of land developers. Maybe they thought that CRA had a good reputation environmentally or perhaps a good reputation as engineering consultants. I think it would be fair to suggest that dirty, rotten, polluting industries just love companies like CRA who give them the veneer of scientific oversight in their environmental decision making. Of course my harsh comments concerning dirty, rotten, polluting industries are a result of my working with/against CRA in Elmira for a couple of decades at least as they psuedo scientifically and drastically reduced  Uniroyal Chemical's cleanup costs.  

Now I don't claim to be any kind of land expert but it appears as if CRA Lands Limited and CRA Lands II Limited are controlled by Cook Lands Group. This company, again according to AI, is owned and operated by "...local Waterloo developer Ian Cook, founder of Cook Homes Limited,...". So here we appear to have once again the tail wagging the dog as home builders and developers are attempting to expand the hard country side line in order to obtain more lands to build profitable for them homes. 

I guess that I am less appalled because it isn't CRA directly behind this attempt to crack the countryside line; but only slightly less appalled. With Woolwich Township's penchant for sleeping with polluters and their fellow travellors, I expect smooth sailing for anybody riding on CRA's coattails.   

I REVIEWED PAST MEDIA STORIES ABOUT ELMIRA- SO DISAPPOINTING

 

And so inaccurate. I guess that's not too surprising. They took an educated guess and guessed wrong. They've backed the wrong horse and aren't going to admit it now. There was a large article in the Record last November with a number of pretty obvious errors in it. I contacted the Record in writing with specifics and details and basically got nowhere. They weren't interested in having to change any part of the narrative, accurate or inaccurate. I might add that there is a good comment published on yesterday's Blog posting regarding what appears to be Lanxess's intentional leakage and even pumping of contaminated groundwater pulling it off the Uniroyal/Lanxess site into the Elmira drinking water aquifers. 

Overall media coverage has been pathetic for years despite ongoing RAC & TAG meetings later followed by TRAC meetings. My initial name for TRAC was "Totally Rotten & Corrupt" but I have softened that to "Too Reticent and Compromising". Either one works for me although the second is politer and acknowledges that there are at least a couple of members whose intentions are good. The rest know what the game is and are fine with going through the motions and providing the Ministry (MECP), Lanxess and  Woolwich Township with the cover and credibility they require. Following is the verbatim Comment from yesterday's Blog posting:

 AnonymousAugust 19, 2026 at 9:08 PM

Yesterday's Analysis is SHOCKING!!! "By pumping less on-site and more off-site they are intentionally losing on-site hydraulic containment. This means that they are purposefully drawing contaminants off their site where they Lanxess only pay 50% of those cleanup costs versus 100% of all on-site treatment costs." so they drained the surface with ditches and swales and trenches into the river AND the parts of the Aquifer that were most contaminated they are attempting to just flush away downstream as well. Wow that is so environmentally mindboggling.

Reply

alan August 20, 2026 at 10:47 AM

TRAC whether you know it or not your mandate includes enhancing not undermining the cleanup of Elmira's groundwater. Your willingness to be led around by the nose on matters of Agenda and Discussion items is disgraceful. Your naivety and trust in corporate Lanxess and the corrupt MECP has and will continue to damage the environment as well as the health of all inhabitants, human and wildlife.

TRAC THIS IS ALSO YOUR RESPONSIBILITY TO BE MONITORING & INSISTING UPON COMPLIANCE FROM LANXESS CANADA

 

Look it's one thing to be a cheerleader versus a watchdog but at some point you have to insist that Lanxess comply with their Control Orders, Environmental Compliance Agreements, MISA requirements and other mandated conditions affecting Elmira's groundwater cleanup as well as the cleanup of the Canagagigue Creek. Yesterday we discussed their failure to maintain the balance between on and off-site pumping necessary to ensure hydraulic containment in both areas. 

Again I have the data going back to 1997 at my fingertips showing the volume of pumping from the UACS (Upper Aquifer Containment & Treatment System). Each month I transfer the pumping results from the ongoing Progress Reports onto one individual page for the year thus reducing 12 monthly reports pumping information for all containment systems to a single page. Now if Lanxess Canada had made some sort of breakthrough several years ago that magically reduced the required amount of pumping and treating of groundwater, they certainly haven't publicly made a big deal of it. In fact for many years the Target pumping rates for each well along with the actual pumping that particular month were discussed in detail. Uniroyal, Crompton and Chemtura were occasionally balancing and adjusting based upon water level conditions ("Gig") and other factors which they openly and properly discussed with the UPAC and CPAC committees. We were often advised that short term reductions were not necessarily a problem however the Target pumping rates were carefully set in order to maintain the necessary hydraulic containment and avoid loss of contaminants from on-site either to off-site groundwater or for the leakage of contaminants from the on-site Upper Aquifer to the discharge point into the Canagagigue Creek.     

Above and beyond the committee members themselves is the fact that all actions and particularly changes from past practices are to be discussed at the public RAC/TAG and now TRAC meetings. When pump & treat is the primary remediation method it is of particular public interest to discuss rationales for any changes in pumping regimens, especially reductions. This has not been done either for on-site Municipal Upper Aquifer (MU) pumping or for on-site shallow groundwater (i.e. Upper Aquifer-UA) pumping. The pumping rates have simply been getting lower and lower over the last several years with no public discussion involved. Whether or not I have been able to stomach in person attendance at these alleged public meetings the fact is that I have watched and listened to them in their entirety via their on-line presence. I have also written critiques of each and every one afterwards. Perhaps there are implications to these Lanxess Canada, MECP and TRAC UA pumping failures somewhat similar to the implications I wrote about yesterday concerning the Municipal Upper Aquifer (MU) pumping failures.

ARE LANXESS & THE MECP INTENTIONALLY SABOTAGING THE ELMIRA GROUNDWATER CLEANUP?

Why would they do that? Money obviously is the most likely culprit. Have they figured out that if they can't reach the 2028 Elmira groundwater cleanup deadline then they may as well cut back on pumping and treating in order to save themselves money? But wait a minute! Their off-site (i.e. beneath Elmira vs. beneath their site)  pumping figures don't reflect that. In fact they are pumping as much or more off-site than they've ever pumped. Ahh! The dirty, slimy, rotten so and so's! Notice here that I have not named Hadley, Lou, Jason or Lubna or anybody else from Lanxess/GHD/MECP as specifically being the "...dirty, slimy, rotten so and so's."  That could be construed as either rude or disrespectful and heaven forbid I'd never want anybody to suspect that I have zero respect for professional liars, especially those on the taxpayers' payroll, who would dissemble or deceive their true employers.

So what are the poor, misguided, obviously soul and ethics damaged folks at Lanxess doing? Well simply by looking backwards, something I challenge TRAC to do now and then, one can learn the answer. Since 2019 Lanxess, right in front of the Ontario Ministry of Environment (MECP), are significantly cutting back on their on-site Municipal Upper Aquifer pumping. Now keep in mind they've already achieved permission not to have to maintain 100% hydraulic containment on their site as they were originally ordered to do. The sad theory is that contaminants that escape from their north-west property boundary allegedly are recaptured by either on-site PW4 or off-site W5 A/B. This scheme supported by CPAC, APTE and the MECP at the time appears not to worry that they (Uniroyal/Crompton) have increased contamination for private property owners along the west side of their industrial site. This concession saved the company money just as their unilateral/bilateral decision starting in 2019 to cut back on pumping the most heavily contaminated and hence most expensive pump & treat on-site area did so. 

Way back in time, before RAC/TAG & later TRAC came along, one Jeff Merriman from Chemtura promised CPAC that on-site pumping (PW4 & PW5 at the time)  would average 6.0 litres per second in order to assure full on-site hydraulic containment. Averages probably for a while were closer to 5.8 or 5.9  litres/sec but they were at least close. Then under Lanxess Canada they started to fall and continued to do so. Now certain honest, albeit softly misguided individuals currently on TRAC such as Sebastian do not have the full past pumping  regimens of all pumping wells at their fingertips as I do. Most certainly neither does Susan Bryant who does not share Sebastian's attributes of honesty and being only softly misguided. Hence TRAC mostly composed of citizen members with less than five years experience  have simply ignored both on and off site pumping rates because they have nothing to compare them to despite 34 1/2 years of on-site pumping and more than 28 years of off-site pumping. All the data are in the monthly Progress Reports although that's too onerous for volunteers to dig through as I have.

So in the short term Lanxess cut back on their most expensive pumping and treatment costs AND guess what? By pumping less on-site and more off-site they are intentionally losing on-site hydraulic containment. This means that they are purposefully drawing contaminants off their site where they Lanxess only pay 50% of those cleanup costs versus 100% of all on-site treatment costs. We the taxpayers pay the other 50% of the off-site costs. This of course also lengthens and stretches out  the time needed to fully and properly remediate the (off-site) Elmira Aquifers.

I call this at the least gamesmanship and at the worst fraud. Certainly it also shows gross disrespect of Elmira citizens and all citizen taxpayers. Not a peep out of RAC/TAG or TRAC because mayor Sandy Shantz intentionally eliminated those of us on CPAC in late 2015 with the knowledge and honesty to oppose this deception and gamesmanship.