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. 

WOOLWICH TOWNSHIP ACTIVELY CONTINUE RUNNING INTERFERENCE FOR UNIROYAL/LANXESS & CENSORING OPPOSITION TO THEIR "CLEANUP" PLANS

 

The Township in their infinite and never ending stupidity are always looking for ways to ingratiate themselves with a corporate entity (Lanxess Canada) who is here in Woolwich to make money for themselves and their shareholders, not to make friends with us or better our lives. Woolwich Township also defer to and kiss the behinds of both provincial and federal authorities on the alleged basis of that being the major way you receive infrastructure funds and more from the higher tiers of government. Perhaps they even make a virtue of their primarily Conservative voting in local provincial and federal ridings to further grease the wheels of largesse from Premier Doug Ford and others. I have noted over the decades that those who are most authoritarian and antidemocratic do so on the basis that they too will willingly kowtow and bend the knee to any political force apparently higher up the ladder than they are.  In other words they are not hypocrites at least. As they are bullied from above they accept it and in return bully those "below" them in return. They aren't hypocrites as much as bullies and cowards.

TRAC is NOT an example of public consultation. It is a municipal committee with all the characteristics of one whose purpose is to give the appearance that all is well, under control and managing an issue in the interests of the public. Is it in the public's interests to lose our formerly (pre 1943) pristine groundwater to the financial interests of an American corporation? Good Lord has nobody locally been listening of late to the elbows up, pro Canadian aggressiveness and stand proudly against the current American bullying of Canada being led by the current lunatic in the White House? Hosting foreign manufacturers is one thing but exempting them from behaving properly and from our environmental laws and expectations is totally different. Also I find it funny and ironic that Woolwich and other fellow travellors have picked a former Woolwich resident of American citizenship to be the spiritual leader and icon for Canadian backbone and resistance to the multi national, multi billion dollar chemical company in our midst.

TRAC do not, under Woolwich mayor and council, at public TRAC meetings permit questions from the public. Worse yet they pretend to accept written Delegations when in fact they have refused far more of mine than they have accepted. Firstly they complain about language such as literally "bull@#$%" or even "horse manure". Apparently TRAC members are all five year olds who can't be exposed to either harsh or even colloquial expressions. Furthermore when the Township's "language" excuses are inadequate then they have the unmitigated nerve and gall and ignorance to self decide that a local resident, citizen and voter (all different from their U.S. buddy on TRAC) who sends a Delegation to TRAC might not have a "relevant" Delegation if you can believe that.    

Here is my elbows up response to that shite. Flock off Woolwich Township . Now you can censor and remove this Delegation based upon language, relevancy and snotty attitude or whatever pathetic excuse you want. Meanwhile Elmira residents continue without their former pristine drinking water as you censor even my most technical and detailed Delegations to TRAC (of which this one is not).     

ELMIRA CLEANUP IS STILL LIKELY NEVER, DESPITE TRAC EFFORTS - (Jenn: My experts say that this post is both relevant and fit for any underage readers on TRAC)

 

Cullen Flanders (Onterris) advised TRAC at last Thursday's public meeting that the pump & treat system did what it was designed to do. My response is bull#$%^ unless it was specifically designed to give comfort and solace to the public as well as to prevent either lynching or tar and feathering of those guilty of poisoning men, women and children for decades here in Elmira. Oh gosh that is exactly what it was designed for. No nuetral, unbiased experts ever advised Uniroyal Chemical and the Ontario Ministry of the Environment otherwise. 

Mr. Flanders also suggested to TRAC listeners that his words were his professional opinion only and that there is no certainty in hydrogeology. I beg to differ.  O.K. I can certainly see instances where 100% certainty would be very difficult as to what is the exact location, depth, weight and composition of all subsurface DNAPLS in Elmira, Ontario. On the other hand the state of the science of hydrogeology certainly was advanced enough in the 1990s to determine that there were DNAPLS both residual and free phase on the Uniroyal Chemical site then as well as probably some off their site.

Mr. Cullen Flanders also suggested that chlorobenzene is an easier target to remove than NDMA. Really? Then how come even the vaunted pump & treat system can't do it?  How come chlorobenzene with much higher concentrations albeit still only in the parts per billion range is still well above its' drinking water standard of 80 ppb (parts per billion) in both the Municipal Upper and Lower Aquifers? Does he perhaps believe any Lanxess  and their consultants who still deny DNAPLS exist or ever have off the Uniroyal Chemical site? Varnicolor also had DNAPLS ( & LNAPLS) on their site including chlorobenzene. Don't they count just because the Ministry and Uniroyal lied about being the sole  contributer to the destruction of the Elmira Aquifers for decades?

Sebastian of TRAC advised that the public must be clearly advised that achieving the Ontario Drinking Water Standards (ODWS) is not happening in the near future. I believe not ever until or unless the current folks in charge are all removed. Even then it is unlikely but slightly more possible. Tiffany Svensson (TRAC) suggested that TRAC and Lanxess were proposing a long term, new approach to remediation and agreed that achieving the ODWS is certainly not going to happen within the next four years. My response to that is this new approach needed to be done decades ago and if the amendments to improve biodegradation only work on dissolved chlorobenzene (versus chlorobenzene DNAPL) then it will be just as successful as rearranging the desk chairs on the Titanic was. If as I suspect the chlorobenzene DNAPL is now in the fractures of the Bedrock Aquifer then all bets are off.  

P.S. No sign of the MECP at last Thursday's TRAC meeting. Were they hiding quietly on Zoom? No idea and no loss wherever they were.

GEEZ I REALLY DON"T WANT TO SAY ANYTHING NICE ABOUT THE FIVE MINUTE WOMAN, HADLEY (Lanxess)

 

O.K. so here goes. She's nothing but a PR hack. She's a snake oil saleswoman and a con woman rolled into one. There I feel better. If I am going to congratulate her based on two things that I think I heard her say Thursday night then I needed to keep it in context with my very negative impressions of her over the last couple of years. 

Firstly recently I've been following TRAC closely via the on-line video/audio on Woolwich Township's website. Hence if I'm unsure what someone said the first time through I can back it up and listen again to be more certain. I'll have to wait until it's out on the Township's website for that. Before I get into what I believe she said I want to pass this along however. Thursday night I sit down and she immediately approaches me smiling with her hand out to shake mine. My immediate response to this wild, aggressive, extremely hostile and wholly inappropriate assault (nah it was none of that) was to say no thanks. She walked away. Damn if she wasn't back five minutes later with her hand out to shake mine again. She was still smiling which I interpreted as a tiger about to pounce and I said " What part of no did you fail to understand the first time?". Well that hardly seemed to faze her although she utterly failed to argue with me or reply rudely which I expected. She started to turn away and retrace her steps at which point I capitulated and said "Well I do at least appreciate your efforts." That was it. Fact is I no longer would shake hands with any MECP, GHD or Lanxess personnel not just her. Too many decades and too many lies, deceptions and manipulations.

The first serious thing I believe she said was that the contamination (chlorobenzene) at observation well CH-44 migrated from Uniroyal Chemical westwards onto the Nutrite property. Hallelujah ! She didn't say the key word DNAPL but as the bulk of dissolved chlorobenzene flowed south to south-west from the Uniroyal site her admission was significant. If it was. Again I will be listening to the video/audio when it's posted onto Woolwich's website.

The second item was when she was talking about DNAPLS and how difficult they were to find and see them. This was during Cullen Flanders (Onterris) talk and comments about secondary sources which he described as either "fingers" or "pipes". Hadley I believe stated that she thought that the concentrations (chlorobenzene) on site were high enough for DNAPL to be present. Hallelujah again!  These are the factual admissions necessary BEFORE  there is even the slightest hope of ever fully cleaning the Elmira Aquifers to drinking water standards. Again I will be checking the video/audio when it comes out for confirmation.

Lastly I have in the past suggested that TRAC are beyond hopeless. I have suggested that they are simply giving credibility to a hopeless cleanup process (pump & treat) etc. I have also vacillated and suggested that they are simply overmatched and outgunned by the experts and consultants hired by Uniroyal/Lanxess. That said they desperately need better informed and stronger members who will not defer to GHD/Lanxess when push comes to shove. A lack of historical knowledge is part of the problem despite the token presence of one very long time, former (non Canadian) community member. Sebastian asked Cullen Flanders whether or not NDMA which is dissolved in the Municipal Upper and Lower Aquifers was also in the Bedrock Aquifer or not. Mr. Flanders did not know so Sebastian asked the whole group if anybody knew. Stone silence. I waited. The silence grew with no responses until I finally, clearly spoke up from the gallery, in direct contravention of TRAC rules prohibiting public questions or responses. My response was of course NDMA is in the Bedrock Aquifer and has been  known and confirmed as such for decades. Good for Sebastian asking the question but quite stunning the lack of depth of important knowledge by all the TRAC members.