TRAC ARE WAY PAST OVERDUE TO WALK AWAY

No criteria. No red line. No benchmark. Mostly nothing except perhaps history to show citizens, the public and TRAC members how much pumping is absolutely required to keep Uniroyal Chemical's contaminants from flowing off-site via groundwater. GHD and Lanxess mutter about circumstances and varying conditions. They suggest that it takes several geniuses plus a pinch of fairy dust in order to determine the amount of on-site pumping required in the Municipal Upper Aquifer to contain their site.

Bull**it says I !  All anybody has to do is assemble the on-site pumping data from the last three or four years and compare it to each month's off-site pumping. The two are related in that from the very beginning we were told that the vastly higher off-site pumping will challenge the on-site pumping by drawing down the off-site aquifer's elevations and tend to draw on-site groundwater off-site. It's all about the relationship between the two numbers.

In 2022 eight months exceeded 4.0 litres per second on-site pumping with the four months below 4.0 averaging  3.6 litres per second (l/sec). 

The same year total off-site pumping exceeded 55 l/sec for eleven of the twelve months which is quite high historically

In 2023 four months met or exceeded 4.0 l/sec on-site pumping with the remaining eight months averaging   3.7  l/sec.  

The same year total off-site pumping exceeded 55 l/sec for eight months and was between 24.6 and 55 l/sec for the rest.

In 2024 zero months exceeded 4.0 l/sec on-site pumping with twelve months averaging 3.4 l/sec.

The same year total off-site pumping exceeded 55  l/sec for five months with the remaining eight months averaging 37.4 l/sec.   

To date in 2025 zero months met or exceeded 4.0 l/sec on-site pumping.

This year (Jan.-March) total off-site pumping has exceeded 55  l/sec. for two of the three months and the third month was at 41.1  l/sec.

The conclusions are obvious. Lanxess are reducing both on-site pumping dramatically the last four years at the same time that off-site pumping has also been reduced albeit less dramatically.

So are they intentionally wimping out on all pumping and treating to save on costs and or are they intentionally reducing on-site pumping more in order to drag contaminants off site that if treated will be treated partially at taxpayers' expense versus all their own expense?

HISTORICALLY SPEAKING LANXESS & WOOLWICH TOWNSHIP SUCK

 

November 29, 2018 we have an article in the Waterloo Region Record advising us that two documentary makers, Michael Heitman and Bonita Wagler were both treated shabbily and cut off at the knees by Lanxess Canada. They had with permission from Chemtura interviewed employee Jeff Merriman an environmental engineer as part of their documentary. Now literally at the last moment the new owners, Lanxess Canada have rescinded their permission for both the Merriman interviews as well as any filming done on their property. Once again we see corporate muscle being abused to keep the public in the dark so as to perpetuate the corporate story versus the more honest one.

Then in the Woolwich Observer on December 26, 2018 we have a cartoon describing Woolwich Council's "terror" or at least trepidation at the upcoming Election Expense Reports mandated by the province of Ontario. Of course the law means nothing when it is conveniently ignored by the majority and when enforcement is non-existent. Yours truly with help from Rich Clausi and Dr. Dan Holt brought half of Woolwich Council up short at the end of the 2014 municipal elections when three councillors (including mayor) failed grossly to comply with the MEA (Municipal Elections Act. Enforcement entailed a lot of jumping through hoops and loops down at courts in Kitchener which I did including properly going through a Justice of the Peace. Imagine my surprise when an idiot prosecutor (Fraser Kelly) turned around in court and blamed me for errors in the paperwork  that I had vetted at every step of the process. This was nothing but pure, unadulterated political and legal "fixing" in order to protect mayor Shantz's career and future use to those in charge.

TRAC PATIENTLY ? WAITS AND WAITS AND WAITS.

  TRAC and the public should have known decades ago what the MECP and Chemtura/Lanxess plans for the downstream Creek were. No such luck even after the completion of the highly bogus HHERA (Human Health & Ecological Risk Assessment).  Lanxess and the MECP are keeping citizens, the public and most (not all) of TRAC on a string. Vague references to some "hot spot" removal downstream in light of broken promises over the last 3  1/2 decades isn't acceptable.

Then we have suggestions that a new Control Order/ECA or some other instrument will address the failure to achieve drinking water standards for either NDMA or chlorobenzene (and likely lots more) . This new Order from the Ontario Min. of Environment will do little or nothing. We don't even know what the new date for cleanup is supposed to be much less how they are going to achieve it. There are lots of new and old excuses right now suggesting the impossibility of reducing NDMA especially down to it's very low drinking water standard of .009 ppb (parts per billion).  Very little is being said about the chlorobenzene failures in both the Municipal Upper and Municipal Lower Aquifers. This is likely based upon the word DNAPL having been surgically removed from their vocabularies either at birth or upon graduation.

On-site source removal is also very unusual to hear raised or discussed at TRAC meetings. It's almost as if all prospective new members have to give a pledge of allegiance to Lanxess, GHD and the Ministry (MECP).  It really is bizarre how with but one exception (Sebastian) no TRAC members ever raise any of the really touchy, difficult issues. Yes I will concur that they have asked appropriate questions regarding inadequate on and off site pumping rates however they need to get their backs up when the guilty and in charge parties fail to properly answer them.

Then there is the Stroh property/farm. While agreeing after decades of lying that some ground and surface water flowed eastwards onto the Stroh farm, Lanxess and earlier owners did a coverup job along the eastern border between the company and Stroh. Their monitoring whether soil, sediment, or groundwater was pathetic. Picking and choosing your way on a contaminated property to avoid hits is child's play for client driven consultants. Hiding facts and discriminating against citizens wishing to both speak publicly to TRAC and to ask them questions is the behaviour of  undemocratic, dishonest skunks. A superb lack of decency, ethics and morals knowingly aided and abetted by all levels of governance. They made a deal not in the public interest and they are sticking to it until they don't.

POSSIBLY THE ONLY GOOD THING MARK BAUMAN EVER DID REGARDING CPAC?

 

It was a metaphor for the Elmira Aquifers. We called Mark Mr. Flip Flop because his opinions always matched the group he was with at the moment. Nice politics. This was somewhere between 2011 and 2014 that Mark advised us as to his belief in Source Removal. What!!  Or maybe he was beginning to realize that Pump & Treat while less expensive was also decades less timely.  Maybe he really did not understand how anybody could agree to long term (decades) of pumping versus so many other much faster and more effective methodologies. 

Mark suggested that we think about a sandbox in a children's playground. The sandbox has never been covered allowing dogs albeit mostly cats to use it as a litter box. So now for the health of the children you need to remove the cat and dog feces. Would you prefer a concentrated effort involving many people and many scoops going through the sandbox sifting for the cat and dog leftovers?  Or would you like to see a hose inserted at one end of the sandbox which is also slightly elevated at the same end allowing the water to gradually flow through the length of the sandbox while also picking up some of the dog and cat discards? At the downgradient end of the sandbox the hose would poke through and the now contaminated liquid contents could be collected for treatment.

I would think that the sifters with proper effort could likely remove over 90% of the cat and dog crap in a day or two whereas simply pumping water through the sandbox would take weeks or months to actually dissolve the you know what in order to remove 90% of it. The proper choice is obvious to the point that it actually makes the Elmira technology of "Pump & Treat" look stupid. 

ANCIENT ELMIRA HISTORY ALBEIT NOT FROM A SPECIFIC NEWSPAPER ARTICLE

 

Actually I'm going to amend that somewhat.  I fully believe that the Elmira Independent did write an article  specific to this discovery way back in 1992 at a public UPAC meeting. Even then Uniroyal and fellow liars were denying any free phase DNAPL on their site. This of course was an idiotic claim when you looked at the number of chlorinated solvents dissolved in the on-site and off-site groundwater. Clearly significant volumes of numerous chlorinated solvents (chlorobenzene, chlorophenols, trichloroethylene, trichloroethane, chloroform etc.)   had been discharged to the natural environment on the Uniroyal site over a period of decades. 

Bob Hillier, a MOE hydrogeologist, appeared at a UPAC meeting with a small glass jar that appeared to have dirty water in it with about two to three inches of a black goo on the bottom. The black goo was free phase DNAPL which had been extracted from on-site well OW-88  screened in the deeper Municipal Aquifer. This finally shut up the DNAPL deniers at least for a while despite the appearance of Frank Rovers which I wrote here about earlier.  One of the founders of Conestoga Rovers (CRA) he had told UPAC at a public meeting that there were both free phase and residual DNAPL distributed throughout the site. In fact in July 2003 based upon both my research as well as the Soil & Water sub-committee of then CPAC (Crompton Public Advisory Comm.) we submitted a 3-4 page list of where various wastes including DNAPLS (both kinds) were located on the site in various waste pits and ponds. This Soil & Water sub-committee consisted of myself, Dr. Henry Regier, Fred Hager and Susan Bryant.

Since that date both on and off site pumping have caused greater groundwater flow helping in the normally very slow dissolution of free phase DNAPL. It might even be possible in off-site areas of the Elmira Aquifers that smaller deposits of DNAPL have been essentially reduced from free phase to residual DNAPL (i.e. not saturated in the sub-surface but merely filling some pore spaces between soil particles). Of course the professional liars in charge including the now MECP  have kind of shot themselves in the foot as how can they now brag that they've reduced free phase DNAPL mostly off-site with their sometimes very high pumping rates which speed up the DNAPL dissolution process, after having claimed for decades that they never had the DNAPL there in the first place?

These are the very relevant facts and data now totally lost at TRAC as Susan joined the DNAPL Deniers Club early in 1994 as she and a fellow APTE coordinator sought to ingratiate themselves with Uniroyal Chemical. With Susan and Pat M. in charge at CPAC in 2003 this document slowly faded from memory and relevance much to Crompton and following corporate owners appreciation. Now today in 2025 consultants such as Joe Ricker (WSP) are at a loss for very high chlorobenzene concentrations allegedly appearing out of nowhere in several monitoring wells.  This is no more than either free phase or residual DNAPL originally from the area of well OW 57-32 near the former W4 pumping well  on Howard Ave. Different pumping wells today have altered the flow direction of this chlorobenzene as the plume bounces back and forth between the effects of  W4 (then) and W5B and W3R now (or at least when they are up and pumping).     

At this point in time I do not know if Susan is even capable of remembering significant dates, times and events from decades ago. Or if she even wants to.

JOE RICKER (WSP) SAYS THAT THE ELMIRA CONTAMINANT PLUMES HAVE SHOWN "REALLY GOOD PROGRESS"

 

"Joe". Who is this again? Oh right he works full time for a consulting firm by the name of WSP who currently have some contractual obligations to Lanxess Canada. These contractual obligations are to use either Joe's or WSP's credentials in order to publicly gain support for the current non-cleanup of either the Uniroyal Chemical/Lanxess site in Elmira or of the downstream Canagagigue Creek which they have also polluted.

1) There are excellent plans and ideas occasionally used to address non-existent problems. 2) There are also excellent plans and ideas used to address existent problems which regardless do not work. 3) Then there are excellent plans and ideas used to address the symptoms of existent problems which either do or do not succeed. I would put hydraulic containment known as pump & treat technology in the category of both 3) namely plans and ideas used to address the symptoms of existent problems which have both succeeded somewhat AND have failed big time.

How can this be? Well groundwater concentrations of specific contaminants in excess of the Ontario Drinking Water Standards (ODWS) are the symptoms of a long history of dumping toxic wastes both on site, in unlined ponds, later in lined ponds as well as both directly and indirectly into the Canagagigue Creek.  I emphasize that the accompanying groundwater concentrations from toxic waste dumping, with or without government approval, are merely one of the symptoms of this immoral, unethical and only sometimes illegal behaviour. 

I also emphasize that Lanxess/GHD "scoping" of perhaps one hundred different contaminants in the Elmira Aquifers down to two (chlorobenzene, NDMA), courtesy of Uniroyal Chemical, is merely an artifice to assist the polluter not the environment. This is also true for the "scoping" done in the Creek soils and sediments which has reduced hundreds of contaminants down to two as well, albeit DDT and dioxins/furans.  

So if groundwater, soil and sediment concentrations off-site are symptoms then what exactly is the problem? The problem is the refusal by our authorities to acknowledge the severe environmental and human damage done in the past, present and future from on-site toxic chemicals that have not been either nuetralized, removed or remediated. Many years ago Dr. Gail Krantzberg of McMaster University spoke at a public CPAC meeting and her prognosis was grim. Eventually over time everything dumped, spilled, leaked or buried on the Uniroyal property in Elmira would migrate off site whether by evaporation, wind and dust, ground or surface water, soil vapours or other mechanisms physical or chemical. 

The sometimes claims of complete hydraulic containment are a fantasy. Admissions of "minor" groundwater discharges to either the Creek or to the off-site Elmira Aquifers are understated. Yes part of the reason for the failure to reduce NDMA, chlorobenzene and other less carefully monitored contaminants to drinking water standards is due to years/decades of failing to meet the companies own pumping criteria and recommendations. Other reasons include leakage from the former Uniroyal site likely in all aquifers which of course has exacerbated contaminants adhering to soils in the aquitards and then slowly diffusing back into the aquifers as the groundwater concentrations decrease after decades of even sporadic pumping. A lack of source removal on-site as well as source denial, particularly DNAPLS, both on and off site have further made success unlikely.  

So Joe, friends and fellow travellors feel free to keep pumping, stop pumping or do whatever you want as you have for decades but be sure to wait until all your local, citizen opposition are either dead or seriously enfeebled before you declare victory.  New toothless, paper tiger Control Orders, ECAs or other MOE/MECP documents won't be any more effective than they have been in the past. Paperwork only rarely can replace shovel work.  

THIS BLOG DOCUMENTS THE HISTORY OF LOCAL CORRUPTION REGARDING THE 1989 ELMIRA WATER CRISIS

 

 I have sent a copy of my Blog posting dated yesterday and titled "Hadley, Luis & Joe Spreading Bull**it At TRAC Last Thursday" to various disreputable persons around the Region. This includes Woolwich Council, some on Regional Council, Ministry of Environment (MECP) and Lanxess Canada. Now I have also sent a copy to various reputable persons which include local citizens, and possibly even a few local politicians. Dang I forgot the local media which kind of speaks volumes as to their interest generally over the last few years. O.K. yes occasionally the Woolwich Observer publish something on the still contaminated aquifers, Creek and Uniroyal site.

I believe that both history and research will one day look carefully at my Blog postings and realize exactly what they have as a written record of the triumph of corruption, deceit and citizen betrayal by both our local polluter and by pretty much all our local politicians. Once again a few powerful interests including our governments have sat down and privately and secretly negotiated deals that are not in the public interest.  If they were in the public interest all discussions and negotiations would be public. Alleged public consultation has been exactly that: alleged. Whether UPAC, CPAC, RAC/TAG or TRAC they've all been for show. Perhaps most of the TRAC members recognize that which is why nobody gets particularly excited about the nonsense, lies, drivel and gilded lilies  presented at  public TRAC meetings. 

For me it is about much more than unremediated environmental harm .  It is about sacrificing some people for the so called benefit of others. Why should Uniroyal/Lanxess shareholders be more important than Old Order Mennonites farming the lands downstream beside the Canagagigue Creek? Why should Elmira citizens die of cancers related to air and water discharges from Uniroyal Chemical when they could have been stopped, reduced and or mitigated decades earlier?