Saturday, July 30, 2011


The front page of today's Woolwich Observer carrys this story: "Demolition next step at Mac's site in Elmira core". You may recall that months ago I posted an article about the cleanup at the Steddick Hotel next door. My understanding has been that the sources of contamination to both sites were leaking underground gasoline tanks on the Mac's/Becker's site. You may also recall that information I had received was that a lot of soil that should have been removed from the Steddick was not. I believe that this time around I will be watching this cleanup much more carefully. On the one hand with a date of 2028 for the alleged Chemtura off-site "cleanup" to be completed, one could be forgiven for thinking that the Ontario M.O.E. would seriously want other local contaminated areas cleaned up properly so as not to impede the restoration of the Elmira Aquifer to drinking water standards. What if on the other hand I am correct in that the 2028 date is an intentional sham/fraud with virtually no chance of success? In that case what incentive is there for the M.O.E. (or anyone else) to get serious with other local contaminated sites?

Friday, July 29, 2011


Last evening at 6 pm. in the Woolwich Council Chambers, I believe we turned a corner. Five of the six CPAC (Chemtura Public Advisory Committee) members were present including Interim Chair (Mayor Cowan). Dan Holt was absent due to a personal marital commitment (ie. anniversary). The last two CPAC meetings in June, while monopolized by first a M.O.E. Orientation and then a Chemtura Orientation, were nevertheless in my opinion dominated by Dan and Vivienne's personality and strength of will. Well last night was truly a team effort and boy did CPAC make the Ministry (M.O.E.) and Chemtura squirm. Sebastian, using his words , was like a dog with a bone. He wouldn't let go of the three page, eight item July 2003 CPAC Request for Action. Vivienne also made it clear that she wasn't interested in getting bogged down in minutia and trivia but wanted to focus on the basic cleanup. Mayor (Chair) Cowan suggested a DNAPL 101 course as well as asking if Ron Campbell and David Marks would give CPAC a Hydrogeology 101 course. They both agreed to it probably in September.

There has been a conscious and sucessful effort by the Chair to more fully engage the audience/gallery by permitting questions of Chemtura and the M.O.E. during the body of the meeting, rather than just at the beginning or end. Mayor Cowan made it very clear that he welcomed questions or comments from the others in the gallery with personal invites to them. This is a huge step towards an improved public consultation that better reflects a wider range of opinions.

Rich Clausi gently but firmly advised Chemtura that here in the Council Chambers in plain view of both appointed CPAC members as well as the general public, was the appropriate place for them to discuss Long Range Plans, Dioxin removal and DNAPL cleanup versus private "technical" meetings. Furthermore he questioned how it was possible that the old CPAC could unanimously support and endorse the eight item July 2003 Request for Action and then allegedly water it down into fifty-nine different items. What came back from a clearly flustered Dwight Este of Chemtura was the very defensive comments that Chemtura weren't responsible for a couple of CPAC representatives properly taking back to the whole CPAC, changes that they had made.

I must thank both David Marks and Ron Campbell of CPAC. Thay are the very first people at CPAC to speak up and suggest that indeed there are other sources of contamination to the Elmira Aquifer than just Uniroyal/Chemtura. David went so far as to ask the Ministry of the Environment to come back to the next CPAC meeting with a rationale for their having dismissed other sources from contention, twenty years ago. My Delegation to CPAC was about Varnicolor's Lot 91 as well as DNAPL (Dense Non Aqueous Phase Liquid) found by Conestoga Rovers (CRA) by the water tower between First and Howard Ave.. My Delegation also included references to the First St. Landfill as well as Borg Textiles and Sanyo Canadian.

Rich Clausi also pointed out that the Minutes from last month's CPAC meeting failed to mention his endorsement of my being back on CPAC. Then to add further garnish he suggested to Chemtura that they could prove their commitment to openness and transparency by asking that their biggest critic be reappointed to CPAC. Considering that Chemtura have lobbied hard to keep me off, I've got to give Richard full marks for chutzpah.

Garth Napier played defence well for the M.O.E. although in a losing cause. He did however promise to come back to CPAC with a fuller more comprehensive response and status update of the CPAC July 2003 Request for Action.

Shannon Purves-Smith who was present in the audience, suggested that many of CPAC's questions had already been asked and answered in former Annual Monitoring Reports written by CRA. While certainly glad of her participation (aka the 2nd paragraph above) I would respectfully suggest that she is incorrect. The A.M.R.'s, all of which I have read, essentially are a monument to CRA's reliance on Hydraulic Containment. They do not address Source Removal on the Chemtura site nor do they remotely suggest even the existence of other off-site sources despite CRA having discovered the DNAPL by the water tower in 1998. I would suggest that Shannon is demonstrating loyalty to her colleagues on the old CPAC and speaking personally, loyalty is a wonderful thing. It would be beneficial to the real cleanup if Shannon and other APTE members would show up to future public CPAC meetings and participate.

Thursday, July 28, 2011


Today's Elmira Independent has an Opinion piece from Mike Hicknell in regards to the proposed Bio-En facility in Elmira. His focus seems to be on the use of Arthur and Church St. for the hauling of odourous materials into the proposed Bio-En facility. Mr. Hicknell also reminds the readers that they have until August 21/11 to post their comments on the Environmental Registry. I posted my comments several weeks back.

I received by mail today a letter from Woolwich Township advising me that Planning staff are presenting a recommendation report for discussion at Council on Tuesday August 9/11 7 pm. . This report dealing with the Hunder Gravel Pit Application can be picked up at the Council meeting or earlier by phoning the Township. I'm assuming I received this Notice due to my probably having filled in a request sheet located outside the Council Chambers months ago. The Hunder Pit, you may recall is the one between Conestoga and Winterbourne, just across the road from part of the Conestogo Golf Course subdivision.

Wednesday, July 27, 2011


We are consistently receiving less and less relevant information from CRA/Chemtura. Whether or not "sanctioned" by the old CPAC nevertheless it is plain wrong and intentionally deceptive by Chemtura. Table A.1 gives us only raw Chlorobenzene and Toluene concentrations going into the Groundwater Containment and Treatment System, nothing else.

Appendix B dealing with MISA (Municipal Industrial Strategy for Abatement) discharges to Canagagigue Creek shows us decreasing concentrations of Ammonia at MISA 0200 going from primarily surface water drainage into the creek.The other parameters are unchanged over time. MISA 0400 is similar although it claims reductions in Lindane as well. First off Lindane is no longer used on site so this must be Lindane in groundwater infiltrating into the surface discharge pipe and secondly looking at the chart (fig. B2), the claim for decreasing Lindane is highly suspect. MISA SWS claims no trend for Lindane but again clearly there are increases over the last year.

Appendix C deals with surface water (the "Gig"). Using CRA's statistical program they claim no statistically significant changes but again looking at the raw data in Table C.2 one can see increases downstream (SS+925) from upstream (SS-110) namely with NDMA, NMOR and Toluene. While clearly an improvement from the 60's, 70's, and 80's it isn't an improvement in the health of the creek prior to Uniroyal's using it as their private sewer.

Appendix D deals with the so called MU Sentry Well Program. This is just one more public relations tool for CRA/Chemtura to attempt to fool the public. They have cherry picked wells near their west side property line after a period of low on-site pumping. These wells respond fairly quickly and hence when pumping on-site is low these wells chemical concentrations rise quickly. Similarily when we go through a relatively sustained period of good on-site pumping, the concentrations follow suit and decrease. Simply keeping track of their on-site pumping compared to their targeted pumping rates gives us the same picture. If nothing else the informed reader should gain an understanding of the short termed nature of hydraulic containment aka pump and dump. Even without stopping the pumping completely, merely slowing it, the toxic concentrations rise off-site nearby very quickly. This is why SOURCE REMOVAL is so necessary. These MU SEntry Wells are actually measuring the extent of sub surface contamination in the south-west corner of the Chemtura site. This corner is where in years past CRA (Conestoga Rovers) have claimed resides 97.5 % of the contaminants flowing into the creek from Uniroyal/Chemtura.

Tuesday, July 26, 2011


So is Union Carbide. BP Oil as well. Chemtura in Elmira and Northstar in Cambridge. How about Safety-Kleen in Breslau? Three Mile Island, Chernobyl and most recently the Japanese nuclear industry. Are the U.S. military proud of their environmental record in Vietnam regarding Agent orange?

Today's K-W Record carrys the above headline. I've read tripe before but this really is hard to stomach. Tony Dowling of West Montrose wrote an Editorial a few weeks back that was rational and logical. Perhaps a gravel industry spokesperson could have argued some points of it intelligently, but this opinion piece certainly isn't that. This article in today's Record doesn't even qualify as propaganda. It's bullshit, thick, steaming and stinky. Look around Waterloo Region carefully and with eyes wide open. Have you seen the disaster along the Grand River on both sides by Breslau? There is a place for gravel extraction but to date our Ministry of Natural Resources believe it's anywhere at all that gravel exists. It's not just the rape of our environment, it's the rape of our minds which is so offensive. Lying has become an art form and a profession.

Monday, July 25, 2011


The primary parties and beneficiaries of the sweetheart deal of course knew, namely the M.O.E . and Uniroyal/Chemtura. The Region of Waterloo had to know. Their consultants CH2MHILL knew and wrote after the fact that Uniroyal were solely responsible. The Region received a free water supply up from Waterloo to replace the one Uniroyal solely (allegedly) destroyed. CRA the consultants to Uniroyal know. The vast majority of APTE members did not know. I, Richard Clausi and Esther Thur certainly did not know. The founders of APTE did not know, namely Susan Rupert, Sandra Bray and Esther Thur. Nutrite had to know because they were one of the contributers to the destruction of the Municipal Aquifer. Interestingly enough we've never heard about their horrid dumping or lagooning or other bad environmental practices. When you're right on top of the Municipal Aquifer, how much volume does it take? Did Woolwich Township know back then? Concerns were expressed to me back in 1991 by senior APTE personnel that Varnicolor Chemical could deflect attention away from a cleanup at Uniroyal. Interesting as we've still not received this cleanup from Uniroyal/Chemtura. What about all the other chemicals which were found in the south wellfield in 1989 which were not as fast moving as NDMA? Why were the Environmental Appeal Board personnel (John Swaigen & Knox Henry) so skeptical that Uniroyal were the sole contributer? What local citizen was receiving coffee meetings at her house with the Regional Chair back in 1990 and 1991? Which local citizens have always seemed to be in the good graces and good books of local politicians, at least until recently? Are any of our local non scientific citizens receiving part time employment from the Region of Waterloo? Which local citizens have received public honours from local Councils, GRCA, National Advisory bodies etc. ? Which local environmental groups have removed (or had resignations) from their most knowledgable members? Why did Elmira's environmental expert, educator and scientist leave APT Environment and join the EH-Team? This same person received the Order of Canada for their scientific career regarding the Great lakes. When my friend you know the answers to all these questions you will be well along the path of enlightenment.

Saturday, July 23, 2011


I have both yesterday and on July 2nd commented negatively on the Ministry's 4 page report. The July 2003 Request For Action has been posted here in it's entirety on Wednesday July 6/11 at the suggestion of Richard Clausi. Yesterday I focused on the fact that this letter from the M.O.E. is the first written response from them since 2003. They, Chemtura and a few of the old CPAC apparently had lots of private discussions around it but deemed the rest of we voting members and the public as unworthy recipients.

Starting on page 2 (Item 1.) of the M.O.E.'s June 27/11 letter, Mr. Martindale claims that CPAC approached the downstream Mennonite farmers and that Chemtura provided financial support for fencing. I was then a voting CPAC member and I neither approached these farmers nor have any knowledge of who, when and where. There was no ongoing public discussion at CPAC. Secondly if Chemtura provided support for fencing, what about support for the loss of the farmers' pastureland? Thirdly how many farmers and how much of the floodplain has actually been removed from cattle grazing?

Item 2. GP1 & 2 "was on the 2010 Annual Plan, but was deferred to 2011 with the concurrence of CPAC." Planning and "investigating" don't cut it. Now they claim they will dig in 2012. As far as with the old CPAC's agreement I'm skeptical and if true then further shame on the old CPAC. Will Chemtura/M.O.E. now claim that the deferral to next year is with the new CPAC's concurrence???

Item 3. RPW 1&2 Blatant falsehood in regards to "relatively low concentrations". This area has had at one time the highest single Chlorobenzene concentration I believe in UA3.

Item 4. P1 "relatively low concentrations". Incredibly deceptive! 88,000 ppb. DDT in UA1 and 461,000 ppb in clay in the P1 area.

Item 5. THIS ONE IS TRUE !!!!!!!!!

Item 6. M2 Horse manure!. Well OW88 has always had both free phase DNAPL (Chlorobenzene) as well as some of the highest concentrations of dissolved Chlorobenzene, usually in ALL AQUIFERS! Alleged hydraulic containment is an excuse not a solution.

Item 7. RPW 6, 7, 8 FIB! Monitoring DOES indicate the presence of DNAPL in the area based on the scientific principles that CRA and world renowned experts have published. Also the 1991 Control Order specifically says that DNAPLS are present and must be remediated, not played with via pumping for the next couple of hundred years.

Item 8. East Side. A typo "excavate all locations with high levels of DIOXINS not toxins as is incorrectly written in the M.O.E.'s letter. This is the eighth priority and GP1 & 2 the second priority. Neither are completed.

This new CPAC members and the public is a fine example of your Ontario Ministry of the Environment aiding and protecting serious polluters from the consequences of their pollution.

Friday, July 22, 2011


Next Thursday at 6 pm. is the public CPAC (Chemtura Public Advisory Committee) meeting. The Agenda should be well along by now but just in case here is what should be in it. A maximum of ten minutes discussion on the progress around source removal of Dioxins at GP1 & 2 on Chemtura's south-east corner. Ten minutes on the current status of odour issues and complaints this summer. This could be expanded if there are Elmira residents present with concerns and comments. Ten to fifteen minutes discussion on "other sources" of buried contamination within Elmira. As this will severely impact any alleged "cleanup" of the Elmira Aquifer by 2028, it can no longer be ignored by all parties. Five minutes discussion on the 2010 Annual monitoring Report and another five minutes on the last few Chemtura monthly Progress Reports.

The rest of CPAC (other than housekeeping issues) should be focused on two items namely the July 2003 CPAC Request For Action and the M.O.E.'s horrid update/status letter of June 27/11. I commented briefly on the M.O.E.'s June 27/11 letter here in the Advocate on Saturday July 2/11. Their alleged Update is a pathetic excuse for the lack of action over the last eight years since CPAC unanimously approved the July 2003 Request For Action. To date all the "discussion/debate" has been done privately and not at public CPAC meetings. Also yours truly has been refused access to these private meetings for years precisely because I'm the only one with the knowledge at my fingertips as to where the "bodies" are buried. The M.O.E. must publicly defend their lack of action and their and Chemtura's pretend DNAPL investigations .

Thursday, July 21, 2011


Volume II , Table 4.4 is rather interesting. This Table is titled "Indicator Well Evaluation Off-Site Collection and Treatment System". Wells over the last decade are examined for concentration trends of NDMA and Chlorobenzene only. It is more difficult to fudge statistics and numbers over a longer time frame than a short one. Nine wells , with three different aquifers and only two chemicals nevertheless shows THREE DECREASING TRENDS out of a possible FIFTEEN. This for me shows the scam that is ongoing. Off-site pumping has been ongoing now for thirteen years. I don't expect any much less all wells to be down to drinking water standards but I do expect them to have all turned the corner and at least be headed in that direction. It hasn't happened and indeed can't for a myriad of reasons including other off-site sources of sub surface contamination.

Appendix E, Tables E3.1 and E4.1 are eye openers. These Tables are titled "2010 Off-Site CTS Operation Interruptions..." and "2010 On-Site CTS Operational Interruptions...". These Tables detail the mechanical reasons for shutdowns within the groundwater Containment and Treatment Systems (CTS). The second Table (E4.1) is one full page in length and covers everything from power outages to maintenance to equipment breakdowns during 2010. The first Table (E3.1) is SIX pages long, over the same time period (2010) with similar reasons. This nonsense has been ongoing for years. It's no wonder that the pumping is and always has been inconsistent.

Well here we go again. Chemtura's Hydraulic Containment is a red herring to start with but when they can't even keep it ongoing, it becomes a joke. We had two months (April & May) that both on and off site pumping were meeting their mandated targets. The previous month (March) fell short with the onsite pumping courtesy of well PW5. The four months prior to that off-site pumping was the pits. This month (June) the on-site is doing fine while the off-site has again slipped badly. The various excuses/reasons are allegedly mechanical failures and malfunctions. The preceding posting dealing with the 2010 A.M.R. will give further information regarding mechanical breakdowns.

Wednesday, July 20, 2011


First off these Reports used to be titled, for example, Annual Monitoring Report #25. This was the title for the A.M.R. for 2006 produced in February 2007. Hence our current one, belatedly just received, is the TWENTY-NINTH such annual report. As you can see our vigilant Ontario M.O.E. were busily ordering paperwork years before the Elmira drinking wells were shut down. This is one of the reasons for their embarassment in having multiple sources of contamination to the drinking water. They were paying attention and still missed it! Speaking of embarassment is the dropping of the number of A.M.R.'s also slightly embarassing to either CRA or Chemtura? If not, it should be.

Appendix C when compared to previous years is awfully thin on data. My first thought is that old CPAC concessions strike again. Both the number of wells is strikingly reduced as well as the number of parameters (chemicals). Tables C.1, C.2 and C.4 are bare bones compared to previous years. Again by mostly only listing NDMA and Chlorobenzene perhaps Chemtura/CRA think that readers will perceive reductions in contamination that are in reality just absences of data.

I did notice in at least a couple of locations references to grids and or quadrants. At long last there is an attempt to make these well locations clearer to the majority of readers who unlike myself have not yet memorized dozens or hundreds of well locations. More of this needs to be done for all tables and charts listing wells. Not knowing where they are located completely destroys the relevancy of the information provided.

Appendix D deals with Trend Analyses ie. Concentration versus Time Graphs. CRA have long used the Mann-Kendall Test, which I have long criticized. Strangely enogh it is counter intuitive both ways. In some instances it claims a decreasing trend when the graphs provided clearly aren't and on other occasions I've seen what I view as no trend yet the Mann-Kendall test calls it increasing. Nevertheless looking at Table D.1 and D.2 covering multiple aquifers, both on and off site, provides clarification. According to CRA's own interpretation there are a total of eight DECREASING TRENDS. This however is out of a total of ONE HUNDRED AND THIRTEEN trends examined. Yes there are many trends (ie. wells/aquifers/ NDMA or Chlorobenzene) in which there is no trend identified or where there are greater than fifty percent non-detects of a parameter. The point however I am raising is this: dissolved toxin concentration reductions do not remotely prove source removal or "cleanup". Even if they did, all the ballyhoo around pump and treat and we still only have eight decreasing trends. Pump and treat or hydraulic containment is still the poor (or cheap) man's sorry excuse for a real clean up.

Tuesday, July 19, 2011


Please note that two days ago I posted in regards to the Annual Environmental Report, a totally separate document. Today's comments will focus on Figures 4.5, 4.6, 4.7, 4.8, 4.9 and 4.10 which are in Volume II (Figures & Tables). First off Conestoga Rovers (CRA) have mislabelled part of Fig. 4.8. The Figure is dealing with Chlorobenzene in the Municipal Upper aquifer yet they have labelled the data in the included tables as NDMA. Unfortunately CRA relatively regularily screw up routine things like this.

Figures 4.5, 4.6 and 4.8 each have three tables included at the top, marked as Historic NDMA or Chlorobenzene, 2010 NDMA or Chloro.. and finally Abandoned .... Historic NDMA or Chloro.. . The significance is the greatly reduced monitoring done in 2010 in order to produce these Figures which allegedly show the current state of the NDMA and Chlorobenzene plumes. Not surprisingly some of these Figures show what appears to be smaller contaminant plumes. In fact by reducing the number of wells which they monitored in 2010 they have managed to avoid wells with higher concentrations . Thus the reduced plumes in some instances are merely an artifact of concessions which the old CPAC have given Chemtura/CRA over the last several years. I publicly spoke against these concessions at the time, knowing full well they would be used to produce false information that would make the "cleanup" look better.

You will also notice in the third table at the top titled Abandoned Wells, a listing of wells and their Historic concentrations, which have been removed from service. By looking at their historic concentrations you will see a number of abandoned wells which had very high NDMA or Chlorobenzene concentrations. In my opinion this was the major rationale for their removal. Again I argued with the old CPAC at public meetings that these wells represented consistent long term data that should not be abandoned simply because they were either embarassing or inconvenient to Chemtura/CRA. Again I say to the new CPAC: Do not even in your dreams consider for a moment polluting your integrity/credibility by incorporating some of these old CPAC members. You the new CPAC will learn the technical stuff. What you can't learn is integrity, responsibility and honesty to the public. Either you believe in that from the beginning and practice it or you will sellout eventually.

Monday, July 18, 2011


I will probably be posting two or more articles in regards to the recently received 2010 Annual Monitoring Report (Chemtura). Although a number of interesting facts and figures, still the report, indeed the whole "cleanup" is based upon a false premise.

Today's K-W Record advises us that the province of Ontario has substantially increased compensation payouts to farmers for livestock losses due to predators, primarily coyotes. There is not a breakdown by Region although it would seem likely that Waterloo Region and Woolwich Township would suffer losses based upon both coyotes and coydogs locally.

Saturday's K-W Record advises us that the Conestoga Dam northwest of Elmira is in need of $20 million in upgrades. These include a massive spillway to prevent a catastrophic collapse of the dam under major flood conditions. The Conestoga River discharges into the Grand at the south end of the village of Conestogo in Woolwich Township.

Finally last Friday's K-W Record informs us as to ongoing initiatives around the Grand River landclaim by First Nations members. What seems very clear due to both the lack of denials by government and the time frames that negotiations have been ongoing, is that indeed our native Canadians are the proper owners of approximately six miles on both sides of the Grand River. While to date there is no suggestion of the land's ownership actually changing, if the government doesn't start to make progress regarding compensation, then what other choice is there? The Grand River flows through Waterloo Region (K-W, Cambridge) as well as parts of Woolwich Township such as West Montrose, Winterbourne and Conestogo.

Saturday, July 16, 2011


This Chemtura report, written by CRA, is dated May 2011 and was received a few days ago at the same time as the 2010 Annual Monitoring Report dated February 2011. The Environmental Report which has been submitted annually since 1991 lists changes that have occurred over the last year at Chemtura and how they have impacted the environment.

What has long been difficult for me to understand is the claimed ongoing decreases in air emissions from all on site sources including waste water and production processes. Twenty years ago Uniroyal (Chemtura) were emitting 350,000 kg of emissions up their stacks per year. By 2001 it was 117,000 kg and last year 86,000 kg. At first glance one would certainly expect huge decreases in the stink from Chemtura . Despite massive decreases between 1991 and 1998/99 we had the RAM group and the "Duke St. rowdies" fighting literally for their breath and their lives. Then things finally cleared up dramatically only to again have Elmira citizens attending CPAC last fall with major complaints primarily about evening and weekend stinks from Chemtura. I must therefore conclude that while decreases are good, that which is still going up the stacks is not. Table 3.4 shows that Toluene concentrations are at 88% of the M.O.E.'s maximum allowable. Xylenes are at 79% and Nitrogen Oxides at 57%. The next highest release concentration wise is Toluene Diisocyanate whose concentrations are at 47% of the M.O.E.'s criterion. It would seem to me that the problem once more is the treating of chemical releases as somehow being released individually. All of these standards are based on the patently false assumption that chemicals don't interact, react and cause combined noxious odours. Rather than individual standards perhaps the sheer numbers of chemicals in the air must force the standards to a much lower level. Or heaven forbid maybe we will get to the point some day where no air emissions are tolerated in order for companies to operate. Wouldn't that be amazing even if currently technically unlikely?

Friday, July 15, 2011


Today's Woolwich Observer has more information on page two of today's Observer (dated Sat. July 16/11). This almost half page ad/notice is again in regards to the public voicing their concerns within the allowed time period. Several options are given including by mail, phone or on line. Let us not forget promises that were made during last fall's Municipal election. They were made by incoming sucessful candidates, most especially Mayor Cowan. I believe that this issue was one of three environmental issues that sounded the death knell for all the Elmira/Woolwich candidates with the exception of Mark Bauman from St. Jacobs. Geography alone saved his bacon. Regarding Mayor Cowan's promises I will say this: despite my current disappointment around the glacial speed of CPAC, completely due to Council, nevertheless I still have hope in regards to a new location for Woolwich Bio-En. This is not to devalue the importance of citizens continuing to act and pressure the M.O.E.. This story is far from over and if sucessful will be due to both citizen and political involvement.

Thursday, July 14, 2011


David Marks (CPAC member) has reviewed the June 30/11 Work Plan produced by Conestoga Rovers on behalf of Chemtura. He has asked for clarification on a few issues including more details on the analyses of the soil samples taken. These concerns and comments make sense and it is no real surprise that CRA have been vague in a number of areas regarding these plans. Overall David has given the green light for testing and delineation to begin. Now lets see for how long and how many new excuses we will hear from CRA and Chemtura. These Dioxins should have been removed decades ago.

About two months ago I phoned Chemtura to ask where their Annual Monitoring Reports were and whether I had been missed. I was advised that no I hadn't been missed, that they were just being held back until the new CPAC was up and running. Strangely enough they were just distributed yesterday to CPAC members as well as myself. As always for many years these reports were dated last February. What gives here? CPAC members were appointed April 19/11. There have been two public CPAC meetings namely June 8 and 30. If I had to guess I might think that Chemtura had already distributed the first batch of these reports and the new Council appointed CPAC had to wait for a second run from the printers. Chemtura's apte committee has been a stinker from the get go and this is but one example of it.

Wednesday, July 13, 2011


In Cambridge it's all been about mathematics. Risk Assessments and meaningless acronyms. ILCR, VITL, SVE, TRV, LOAEL, NOAEL, PCO. Who knows or cares what these initials stand for? They are verbal drivel whose primary purpose is to distract citizens from the bottom line. The Bishop St. community were poisoned by two, for profit companies whe were supposed to be monitored for environmental compliance by our government and were not. Instead of our governments then stepping up to the plate and taking responsibility to get all the poisoned people IMMEDIATELY out of their poisoned homes and into safe accomodation, they have spent the last SIX years slowly remediating the air in these homes, while the citizens continued to live in less poisoned air. Oh and also our governments have been aiding the industrial criminals who did this by producing studies at taxpayer expense, ostensibly showing how minor the risks are and have been. This I'm sure is very comforting to the dead and dying.

In Elmira the game has been both similar and different. Here our governments have been redirecting citizen outrage and anger away from poisoned drinking water towards Mickey Mouse solutions that are endorsed by the poisoners, their bought and paid for consultants and local citizen sellouts. Lost decades ago was the realization that Elmira water stank and tasted like crap for years before the Ontario M.O.E. finally admitted in late 1989 that they had "discovered" a carcinogenic chemical in the drinking water. Furthermore to help redirect the focus away from the still and most likely always contaminated aquifers, we have ongoing air releases fumigating our community. Out of sight and out of mind is how the authorities have dealt with the water. Once a pipeline was built from Waterloo to Elmira, a real cleanup of the Elmira aquifer was doomed. Afterall, industry essentially pays insurance premiums to all levels of government and then they expect protection from the consequences of their anti social and or criminal behaviour. The Ontario M.O.E. are the major vehicle for industry protection from an outraged public. The M.O.E. endorse and go along with idiotic and time consuming "Optimization" studies, Site Specific Risk assessments, DNAPL Investigations that go on forever and Comprehensive Long Range Plans. Lets not forget Five Year Reassessments and detailed Ammonia Treatment Systems and On & Off Site Containment Systems as well as BioMonitoring of the local Creek. Monthly Progress Reports, Annual Monitoring Reports as well as Annual Environmental Reports add to the distraction. ANYTHING BUT COMMON SENSE! Chemtura and the M.O.E. please shut up and start digging! Take the poison out of the ground. Now!

Tuesday, July 12, 2011


After twenty-two years involvement with contaminated sites, both with hands on experience and with the reading of hundreds of groundwater reports I consider myself extremely knowledgeable regarding the transport and fate of toxic compounds in the subsurface via groundwater. I do not consider myself an expert in regards to air transport of contaminants. This also includes the subsurface transport of toxins via soil gases. Nevertheless I have recently received information which indicates that we the public are being seriously misled in regards to the health risks and damage experienced by the Bishop St. community in Cambridge, Ontario.

My experience at other contaminated sites in Waterloo Region has indicated to me a strong penchant by both our Regional government and our Provincial government to always attempt to minimize the crisis. In Elmira for example both the company and the Ontario M.O.E. have focused for decades on 2 or 3 contaminants while conveniently not mentioning hundreds of others. They have also sold an impossible (but inexpensive) remediation plan to allegedly restore the drinking water aquifer by 2028.

Dated May 2011 is a report by the Ontario Agency for Health Protection and Promotion (OAHPP). This report purports to advise its' readers as to the mathematical health risks the Bishop St. community have been subjected to due to vapour intrusion into their homes. This report is a crock of crap. It is based on data and assumptions which can only charitably be called optimistic. Dissolved toxins in water do not magically disperse instantaneously throughout underground aquifers. The same is true for volatolized (gaseous) toxins in regard to them instantaneously dispersing throughout either subsurface pores in the non saturated (vadose) zones or even in the above ground air. Within peoples' homes in Cambridge are large differences in TCE concentrations from their upstairs rooms to their basements.

OAHPP appear to have based their entire report on one chemical, namely TCE (trichloroethylene). TCE may be the most volatile but it is not the most toxic. Some of its' breakdown products are more toxic and they are in the groundwater as well as the air inside homes. Furthermore when tested for, benzene has been found in indoor air. Many more toxic chemicals albeit at lower concentrations have been found in indoor air. Absolutely no one can mathematically or otherwise calculate additive or synergistic health effects of multiple toxins on human beings. Hence the OHAPP report is bogus simply due to its' basic false assumptions of only one chemical present.

The entire OHAPP report is based upon the "knowledge"/ assumption that the TCE indoor concentrations while between .2 to 2100 ug/m3 , average out to 52.3 ug/m3. One these readings only start AFTER 2005. Claims that these numbers accurately represent the indoor air concentrations in peoples' homes for the prior thirty-five years isn't science. It doesn't even rate being called guesswork. Were all the basements finished with concrete floors thirty-five years ago? Did they all have finished recreation rooms? Did any of them ever leak? What were the original capabilities of the air circulation systems and furnaces ? What was the exact history of spills, leaks and dumping of toxic chemicals at Northstar and Rozell (GE) decades ago?

Now we come to the actual TCE readings in these houses. There is one house which has readings in its' basement twice as high, five times as high and even fifty times as high as the maximum relied upon by the OAHPP. Clearly these higher readings taken by professionals accredited in the field, were taken differently than the ones done by the consultants paid for by Northstar etc.. How is it honestly possible to have such dramatic differences found by experts for the polluter versus independent experts? How many other homes if sampled differently, more accurately (?), or by different professionals would also have dramatically higher indoor air readings? How many of these other citizens could have been able to afford thousands of dollars of costs to have their own professionals do this work? Are our governments (Provincial & or Regional) blatantly deceiving citizens knowing that usually they can't afford their own experts? Sadly as stated earlier it has been my experience that both Regional government and Provincial (M.O.E.) routinely minimize environmental crises for their own benefit, both political and financial.

Monday, July 11, 2011


Literally for decades people in the Bishop in Cambridge suffered serious health consequences coming from inside their own homes. It affected parents and children including headaches, nausea, sleepiness, eye and respiratory irritation, impaired concentration and worse. From kidney, liver and reproductive damage to autoimmune diseases, developmental and neurologic effects all the way to fatal cancers. The cause was a chemical called trichloroethylene, handled irresponsibly by at least two companies located on Bishop St.

I am currently reading and absorbing a report titled "Trichloroethylene (TCE) Contamination in the Bishop Street Community, Cambridge, Ontario" written by the Ontario Agency for Health Protection and Promotion (May 2011). At first I was appalled at what appeared to be an attempt to minimize the cancer probabilities and effects that have occurred in the community. Further reading and I am aghast at all the "non-cancer endpoints". These serious health issues will have permanent physical and psychological consequences for some of the citizens of that community.

How you ask is this relevant to citizens of Woolwich township? Aside from the normal concern for our neighbours should be the realization that what has occurred from contaminated groundwater in Cambridge can occur anywhere. Fumes (vapour intrusion) from groundwater can enter through basements in concentrations highly injurious to human and animal health. Pets also get sick and die from this cause. Back on June 29/11 I posted an article regarding possible vapour intrusion in Breslau. This is an issue that most certainly our elected Council should be concerned with due to the numerous sources of contamination (and potential vapour intrusion) in Elmira.

Saturday, July 9, 2011


There is black and white and there are shades of grey. Using the sports metaphor, sometimes coaches need to bench their star players. Rowdiness, partying or physical altercations with their teammates are reasons that come to mind. Keep in mind that in this scenario the teams are the employers and the players employees. These employees are paid (well) for their time and efforts. Now lets compare this to volunteer work for the Township of Woolwich. Specifically lets look at volunteers prepared to sit on the Chemtura Public Advisory Committee . It's confrontational, offensive and nasty. This is in reference to Chemtura, their consultants and the behaviour of the Ontario M.O.E.. Generally these people are well dressed, soft spoken and cordial. Why do I refer to these meetings then as confrontational, offensive and nasty ? The reason is that these folks have a job to do and that job is selling "terminological inexactitudes" to you and I; namely John Q. Public. Believe me, being bull..itted to is offensive and it doesn't get easier with time.

This week's Elmira Independent speaks to the previous Thursday's public CPAC meeting. Richard Clausi, friend and colleague, has been asked by the Township to serve as a volunteer on CPAC. Richard is quoted about his concerns in so doing including the exclusion of one of the most knowledgeable citizens in Elmira, yours truly. Richard has been very professional and respectful in his comments to the new CPAC and in fact has stated his confidence with those members to whom he has spoken. Richard is a classy guy. While I am humbled and appreciative of his support, nevertheless Richard is also a pragmatist. He has advised me that a team who sincerely want to win the game, put their best players on the ice. They get their priorities straight. They do not let false pride, ego or petty disagreements get in the way. Richard sincerely wants to help get Chemtura cleaned up. Real cleanup as in source removal of Dioxins, Dnapls, DDT and all the rest. Richard is prepared to give his time and skills to Woolwich Township . Are Woolwich Township prepared to show that they share the same goal of a real cleanup at Chemtura by including the most dedicated, hardworking and knowledgeable citizen they have, on the committee? If not then perhaps their commitment is far less than that of their volunteers.

Friday, July 8, 2011


Conestoga's Rover's Work Plan regarding removal of Dioxins in GP1 & 2 has been distributed. It also was not handed out prior to the June 30/11 public CPAC meeting thus making informed and knowledgable questions impossible. This Report is all too typical of CRA's work. It's stated objective is contrary to what CPAC asked for. It is vague and totally non specific in areas that require clarity including the size of the proposed test pits. While claiming to dig four metres below ground it then qualifies this by saying that is dependent upon the excavaters available. Excuse me but rent/buy/steal/borrow the proper equipment for the job! We are further advised that sixteen 4 metre deep boreholes will be dug and ONE yes 1 soil sample will be taken from a four metre deep x ? wide x ? long testpit. That is ridiculous. The fact that we are assurred that CRA who have probably made millions of dollars over more than two decades of client driven consulting work for Chemtura (Uniroyal), will carefully pick the most contaminated samples for soil testing, does NOT reassure me. We've had twenty-two years of non good faith public consultation from Chemtura (Uniroyal) and Mayor Cowan made it clear during and after his election campaign that a real cleanup was imminent. Let the horse manure stop and the source removal begin!

At the first CPAC public meeting of June 8/11, the Ministry (M.O.E.) were requested for a written update in regards to the status of the CPAC July 2003 "Request For Action" document. I now have in my hands the first formal response by the M.O.E. to this landmark document after only a short eight years. As expected there was good reason why they and Chemtura together have been silent publicly in regards to this unanimously passed CPAC document. The reason is that privately they and the old CPAC have gutted it. None of those parties had either the courage or the stupidity to bring the document back to a public CPAC meeting and admit this until now. The M.O.E.'s four page "update" is one more in a long history of public betrayals. Common factually flexible fictions include the claims that groundwater concentrations of contaminants are low in these source areas. Other claims by those individuals suffering from fictitious disorder syndrome include the nonsense that since the area is allegedly hydraulically contained, source removal is unnecessary. Another truth that appears to be temporarily unavailable by some parties revolves around the claim that this landmark document, written and unanimously passed by Elmira citizens, can be mysteriously incorporated or disembodied into another document or report. With assistance and collaboration I wrote this report. IT IS A STAND ALONE DOCUMENT AND DOES NOT REMOTELY REQUIRE TO BE INCORPORATED INTO ANYONE ELSE"S MACABRE MANIPULATIONS. This refusal by all parties to publicly debate and discuss this at CPAC is just one more manipulation of the public by the Ontario Ministry of the Environment and their fellow travellers.

Thursday, July 7, 2011


I believe that the above (title) is an advanced course in Business. Not Business ethics of course but in reduction of costs. To enhance their own credibility governments talk public consultation. This is the weak link in democracy as far as the rich and powerful are concerned. Millions of sheep out there have the vote and they must be convinced that their governments, which have long ago been bought and paid for, are their government not the government of the elites. Therefore if Business and Industry are stuck with public consultation the least they can do is manage it for their own benefit. Such has been the sorry state of affairs with the old CPAC (Chemtura Public Advisory Committee) for the past twenty years.

Yesterday I posted CPAC's "Request for Action" dated July 2003. Nothing could be clearer in regards to the will of a diverse group of citizens regarding the cleanup of the toxic wastes at Chemtura. Instead Chemtura have sucessfully molded, massaged and slowly transformed this 3 page document into an ongoing, neverending series of private meetings, discussions and reports ad nauseum. They've spent eight years talking, meeting and writing INSTEAD of digging. CPAC's original document speaks of "appropriate modifications" based on new technologies or information. None have been forthcoming. None have been publicly presented to or at CPAC. This document was and is the will of the citizens. This document is the CLEANUP PLAN and Chemtura, their consultants, the MOE and all their assorted "friends" must not change that.

Wednesday, July 6, 2011

CPAC Request for Action
Response to SSRA Human Health Assessment, Crompton
July 2003

CPAC recommends the following actions as both the appropriate response to the SSRA data and as actions to be incorporated into the Comprehensive Long Range plan for the Crompton site.

The recommended actions include removing some of the sources of the COC's. Eliminating once and for all some of the hot spots of contamination on the site is a key element of the Long Range Plan and essential to protecting our community for the future. Containment alone is not sufficient. Nor is capping of creekbanks, since contaminated groundwater flows through the banks into the Creek. Elminating hot spots on a reasonable schedule, starting with the worst spots, will speed the cleanup of the off-site aquifer as well as the downstream sediments.

Note that these recommendations are based on available data to date. We see appropriate modifications to the recommendations being made in the future as additional data is gathered and additional technologies become available.

Our Action List, with some of the justification, is as follows, roughly in order of priority.

1. Downstream Contaminated Sediment
* ACTION: Fence off and revegetate as a buffer strip the
floodplain of the Canagagigue Creek downstream
of the site as far as the Grand River, providing
appropriate compensation to farmers.

2. GP-1 and GP-2
* ACTION: Excavate and investigate thoroughly the full extent
of contamination, both laterally and vertically.

* Extremely high levels of dioxins in soil, highest on site
55,897 ppt (5 times the MOE ceiling for contaminated sites)
* Very high levels of DDT-47,000 ppb
* Area is near the creek, with surface flow and uncontained
shallow groundwater flowing to Creek.

3. RPW-1 and RPW-2
*ACTION: Excavate these unexcavated waste pits

* Once these pits are excavated, allowing some form of
"optimization" flow off site becomes more reasonable
* Only one storage building interfering with easy excavation
* Historic disposal pit for DDT, 2,4-D, pilot plant waste
* A major source of DDT
* Near location of highest DDT levels in creekbank soil. May
be the source of that DDT, since shallow groundwater, recharged
by the pond above dam, flows through the pits before discharging
to Creek below the dam.
* Historically, RPW-2 was a pond that overflowed continuously.
A pipe installed to carry flow to below dam. These residuals also
source of DDT to creekbank area.
* Borehole evidence of DNAPL in RPW1 & 2
* Very high chlorobenzene in groundwater sampling (UA3), making
DDT mobile.
* Evidence of DDT in groundwater samples
* evidence of dioxins in area (MISA 0400)
Timeline: 2003-2005
Actions 1,2,3

4. P-1
* ACTION: Excavate worst spots in P-1 area and contain shallow
* Remediate and/or pump and treat under buildings
* Excavate and cap adjacent creekbank (some capping has been done)

* Highest DDT in soil on site (Borehole 7-461,670 ppb), over MOE
ceiling levels
* Also source of adjacent creekbank DDT-highest creekbank DDT
levels on site
* Groundwater from west and north flows through here into Creek
* Shallow groundwater wells show very high chlorobenzene,
benzene, as well as DDT after purging.
* 1943-48 all process wastes dumped in P-1 and P-2
(MOE Report-Jackman)
* Location of Bldg 8 sump, a major contaminant source
Timeline: 2005-2006
Action 4

5. Creekbank downgradient of M-2 (and RPWs)
* ACTION: Excavate entire dry channel and island. Cap with clean fill.
* Highest creekbank levels of dioxins and high DDT
* LNAPL in area mobilizes dioxins and DDT (a 1996 LNAPL sample
showed 209,070 ppt dioxin TEQ)
Timeline: 2006-2007
Action 5

6. M-2
* ACTION: Selectively excavate and/or remediate soils

* Area is relatively free of buildings
* Location of high exposure for workers
* Free phase DNAPL found at OW-88 and on border of M-2 and
TPW-2 (no exploration done into M-2)
* LNAPL in north end of M-2 huge plume from Bldg 15 area. DNAPL
and LNAPL mobilize dioxins and DDT in groundwater.
* Historically, a disposal site for Uniroyal and town. Waste
disposal of DPA, filter cloths, 2,4-D, 2,4,5-T, sump sludge
from 2,4-D and Bldg 15
* Little current monitoring done in whole area
* Adjacent (upgradient) of the worst dioxin contaminated
* Site of most highly contaminated portion of Municipal aquifer
* May contain unexcavated drums of waste chemicals
Timeline: 2007-2008
Action 6

7. RPW 6,7,8
* ACTION: Selectively excavate and/or remediate soils. Remove
LNAPL plume.

* Very few buildings
* Historically, these lagoons were the major source of
contamination in Municipal Aquifer
* Highest levels in soil of most Uniroyal contaminants, still
in place (1992 Dames and Moore)
* 3,400 liters per day estimated leakage of process wastes,
downward, after ponds clay lined (CH2MHILL); more leakage before
* DNAPL source (RPW 6)
* Currently contained in UA and MU
* If this area gets excavated, the off-site cleanup becomes
possible in 30 years.
Timeline: 2008-2009
Action 7

8. East side
* ACTION: Excavate all locations with high levels of dioxins

* More testing needed in RPE-1, an unexcavated pit on east side,
used for DDT and 2,4-D waste, both liquid and solid. Possible
excavation needed.
* Historic DNAPL site
* Nearby worms contaminated
Timeline: 2009-2010
Action 8

Back on June 15/11 here in the Advocate I mentioned the formation of the inaptly named Apte-Chemtura Committee. This group meeting privately with Chemtura includes two members of the National Advisoy Panel to the Chemical Industry Association of Canada (CIAC). This is not necessarily shameful in it's own right but in my opinion certainly is very suspect. This Industry Association's purpose is to polish the tarnished image of the Chemical Industry here in Canada. The expression "guilty by association" comes to mind. Household names like Dow, Polysar, Union Carbide, Uniroyal (Chemtura), BP and Ciba Geigy all have had more than their share of bad press based upon environmental disasters, here or abroad.

It has been confirmed that Chemtura, despite their waffling at last Thursday's public CPAC meeting, are indeed paying expenses at least for this group. That is unconscionable. For Chemtura it is a win-win scenario. Approximately twelve years ago they stormed out of a CPAC meeting because they felt that their good name had been impugned. Having stormed out they had nowhere to go, at least public consultation wise. Eventually, over a year later, the forerunner to the CIAC, namely the Canadian Chemical Producers Association (CCPA) advised Uniroyal/Crompton/Chemtura that they would never receive their "Responsible Care" designation if they refused to consult with the community ie CPAC. Perhaps this time Chemtura feel that they can pick and choose and indeed play one group off against another. If CPAC are too insistent on a real cleanup than Chemtura can pick up their marbles and run to this latest group.

So what's in it for the old CPAC Chair and her sidekick? Well for one the old Chair gets to be Chair again. Secondly APTE were co-opted by their leadership without their knowledge by their rolling over on the DNAPL cleanup, back in the early nineties, in exchange for nothing more than permanent access. Access to nothing more than meetings and discussions with Chemtura and or the Ministry of the Environment (M.O.E.). Yes as pathetic as that is, there it is in a nutshell. Possibly it was one step at a time down a slippery slope. Regardless it was done surrepticiously and without APTE Coordinators or members approval. Maybe status, prestige and local fame were all part of the package. It's very difficult in hindsight figuring out other people's motives. I do feel badly for the old CPAC members who were and are still sincere. They are being led down the garden path and who am I to criticize them? I also was led down the very same path and took years to realize it. Such is the force of personality and human relations.

Tuesday, July 5, 2011


Well done Tony Dowling. In today's Letters to the Editor (K-W Record) , Mr Dowling takes on the recent comments that any gravel anywhere is good gravel to extract. Such nonsense. Tony points out the bigger picture which includes farmland and drinking water. The problem with the latter two issues is that they don't lobby or give money to our governments the way the gravel industry does. A pox on our politicians and a pox on right wing, pro business newspapers.

Monday, July 4, 2011


This is the heading on this weeks Woolwich Observer (pg. 20) dealing with the Woolwich Bio-En Renewable Energy project. Strangely enough I can't find any mention of a public meeting . Essentially this Notice is to satisfy certain rules around the whole process and advises concerned citizens as how to comment on this proposal which is on the Environmental Registry. These comments are of course in regards to the proposed location on Martin's Lane in Elmira. Clearly those citizens with appropriate objections to this location should so comment officially as a good outcome is more likely, the more who become involved. I believe this weeks Independent also advised citizens that they have sixty days to comment on this proposal.

I received an update last week from the Environmental Commissioner of Ontario in regards to Ken Driedger's and my Application for Review. It was simply a timing update to advise us of the expected dates for replys. After receiving the Application via the ECO on June 6/11, the Minister of the Environment has sixty days to determine whether a Review is in the public interest. A written Decision is then mandatory from the Minister including reasons whichever way it goes. If the Decison to Review is yes then we are to receive notice of the outcome within thirty days of it being completed. I notice that there seems to be no mandated time frame for the writing of the outcome of the Decision. Based on the process I still have no particular guess as to how this will all unfold.

Saturday, July 2, 2011


The overall time was monopolized by Chemtura's Orientation Session which essentially was their sugarcoated version of the "cleanup" of their site. Thay are still relying on reduced concentrations of DISSOLVED chemicals in their groundwater as proof of cleanup. This is nonsense as all their remaining buried wastes and contaminated soil will continue to pollute the groundwater, if not forever, then for centuries. Disappointingly we did not receive the promised update on the staus of the July 2003 CPAC Request For Action in time for this meeting. I have it now and it is a litany of excuses. Numerous aspects of it are blatantly false such as numbers 3, 4 and 7 dealing with areas RPW1 & 2, P1 and RPW 6, 7 & 8. Other aspects claim that the old CPAC "concurred" with various changes or downgrades in status. If this is true first of all it was done privately and not at public CPAC meetings and secondly if it is true then shame on the old CPAC.

I am just barely going to scratch the surface of the misinformation given to CPAC by Chemtura at last Thursday's meeting. Chemtura claimed that burying wastes in the ground was accepted practice between the 1940's and 1960. Last November 29/10 I presented and distributed a report to the old CPAC which gave references to a July 29/10 study called the Travis-Agardy Report. This on-line report gives a historical review of synthetic organic chemicals, their fate and transport in the environment. It makes perfectly clear that as early as the 1880's, in Europe, there had been numerous cases of poisonings and deaths associated with in ground burials of chemical wastes. At that point industry began dumping their untreated wastes directly into rivers and creeks for dilution and downstream dispersal. That Chemtura now says that the authorities approved their similar behaviour merely advises us of the collegial if not corrupt state of the authorities at that time. Unfortunately I was cut off by the CPAC Chair and unable to finish my Public Forum comments on this item last Thursday.

Overall, nevertheless I see reason for optimism. Dan, Vivienne, and Sebastian are nobody's fools. They ask good, tough questions and if the responses from either the M.O.E. or Chemtura are nonsense, then they pursue further. David Marks also asked some good questions both of Chemtura and of myself. Richard Clausi, my co-founder of the Elmira EH-Team and a teacher at Elmira District Secondary School has been approached to be on CPAC. He is carefully considering because he does have a couple of issues that need resolving first.

Friday, July 1, 2011


Following is the text of my Delegation to last evenings CPAC. I will follow up later (tommorrow?) with further comments and details about the meeting.

DELEGATION TO CPAC - June 30, 2011

Twenty-two days ago I advised CPAC, that in my opinion, it was appropriate to deny Chemtura their “Responsible Care “ designation until they removed the readily accessible Dioxins in GP1 & 2 on their site. Since then I have learned a little more about the international history of Dioxins and other Persistent Organic Pollutants. These listed POP’s have also been known as the “dirty dozen” and just a year ago in fact, nine more POP’s were added to the list . Canada signed on to the Stockholm Convention in 2001 and have promised to endorse the addition of these last nine POP’s. Chemtura ‘s pollution is well represented both on the original “dirty dozen” and with the recent additions. Besides Dioxins ; DDT and Lindane are and have been issues at Chemtura. The Stockholm Convention is a global treaty with 169 countries being party to it. The aim is to protect human health and the environment from the effects of these persistent organic pollutants. These chemicals including Dioxins are extremely mobile via both air and water and are bioaccumulative. An incorrect or at least non qualified reference was made to the immobility of Dioxins at the last CPAC meeting. Studies have found Uniroyal (Chemtura) Dioxins the entire downriver length of the Canagagigue Creek all the way to the Grand River. Dioxins move up the food chain including cattle and via milk and beef into human beings. Thus low concentrations in grass or river sediments are bioaccumulated and magnified as they move up the food chain. It is my observation that the inherent toxicity, seriousness and threat of both airborne and waterborne Dioxins have been historically understated here in Elmira. Considering that the Chemtura site is the largest repository and source of Dioxins in Ontario, that is shocking.
The Ministry of the Environment gave CPAC an Orientation Session just over three weeks ago. There were a number of discrepancies including on page 3 a list of four chemicals from Uniroyal which have contaminated the groundwater. I am quite confident that the Chemtura representatives here would have little difficulty confirming that there are closer to one hundred industrial chemicals in the groundwater and if you really pushed them to test for everything and at very low Method Detection Limits, they might even find two hundred chemicals. The M.O.E.’s list of four chemicals should have been more carefully explained or qualified. Ignoring other discrepancies I will now focus on the bottom of page 23. The title is Dnapl Wastes and for those who were not present from 2005 to 2007, you could be forgiven for interpreting the M.O.E.’s words regarding the production of three reports as some sort of a resolution. This would be inaccurate. At least two members of the DNAPL Working Group publicly stated at CPAC that these reports were not written in stone and the issue of DNAPL cleanup was not finished. Furthermore , since about 1994 the M.O.E. themselves have indicated in their monthly Progress Reports that they have as yet not accepted Chemtura’s DNAPL efforts as being completed. None of these most recent DNAPL reports produced a scintilla of evidence or science that disputes the conclusions of CPAC’s July 2003 Request for Action, which also requests the removal of DNAPLS from the former operating ponds.
Also at the last CPAC meeting Jeff Merriman I believe, verbally threw out the statistic that since the excavations along the creekbank, there has been an 85% reduction in contamination found in various receptors. Now we all know that statistics are very dangerous. Sir Winston Churchill once said “ There are lies, damned lies and then there are statistics!”. So I could bring Jeff to task for this bold assertion of his, but I’m not going to. Instead I’m going to agree with the overall principle involved. Physical removal of source areas works. Every time you have put a shovel in the ground and removed your toxic waste , you have done the right thing. There are more source areas and you know where they are as well as I.

Alan Marshall Elmira Environmental Hazards Team