Monday, April 30, 2012


The Editorial in last Saturday's Woolwich Observer written by Sebastian Seibel-Achenbach is a well written factual account of his concerns with Woolwich Councils' apparent lack of support for the BFCC (BioFuel Citizens Committee). Reading between the lines I believe that Sebastian is hopeful that Council will reconsider and give at least moral support to this group who are willing to put both their time and money where their mouths are. The title of his Editorial is "Council should back biogas fight" (pg. 10).

Sebastian is also a member of our new CPAC (Chemtura Public Advisory Committee). His Editorial should have absolutely zero bearing on our Councils' response to CPAC Chair Dan Holt's presentation to them tomorrow evening at 6 pm.. Chair Dan Holt will be presenting a CPAC Resolution to Woolwich Council (Committee of the Whole) for their approval and ratification. This resolution was passed unanimously by CPAC last Thursday evening, including of course by Council member Mark Bauman. This Resolution is the key to turning around the sham cleanup orchestrated by the two guilty parties over twenty years ago. These two guilty parties are the Ontario Ministry of the Environment and Uniroyal/Chemtura. To protect each others' money and credibility they signed a sweetheart deal between themselves allegedly absolving each other of blame/guilt/liability. The corporation kept hundreds of millions of dollars and the M.O.E. avoided further appropriate public condemnation for their gross failures and negligence. The loser in all this as usual were the public who have been paying the freight for the cheapest, least effective "cleanup" possible. Woolwich Township citizens appointed to the new CPAC, both experts and non experts alike, have seen through and cut through the smoke and mirrors presented by Chemtura and the M.O.E. at public CPAC meetings. Tomorrow night Woolwich Council (Committee of the Whole) will have the opportunity to show their ongoing support and confidence in their handpicked CPAC.

Saturday, April 28, 2012


Following are the verbatim words of the Chemtura Public Advisory Committee's (CPAC) Resolution. They are in my opinion a stunning carte blanche rejection of not only the past and present cleanup strategy but of also the M.O.E., Chemtura and their consultants Conestoga Rovers & Assoc..

WHEREAS the Chemtura Public Advisory Committee (CPAC) is a committee of Council charged to act on behalf of the Township of Woolwich in a public advisory capacity working to ensure that the Elmira Municipal aquifer is cleaned up (remediated) so that the water quality meets the Ontario Drinking Water Quality Standards by the year 2028;

And WHEREAS CPAC is of the opinion that the 2028 water cleanup deadline is unattainable under the current remediation regieme;

AND WHEREAS chemicals at the Chemtura canada Co./CIE have and continue to cause ongoing contamination of the Municipal aquifer and further more have the potential to migrate into the streams and rivers which lead into the Great Lakes basin;

AND WHEREAS CPAC has agreed that since the pump and treat system on its own cannot ensure an appropriate level of protection to human health and the environment or complete the cleanup of the Elmira Municipal aquifer and Private Sector and provincial funding is needed to ensure this source removal work will be completed;

NOW THEREFORE the number one priority needs to be placed on the removal of source areas of contamination, be it resolved that CPAC requests the Township of Woolwich Council request the Ministry of the Environment to conduct a review of the funding formula set out in the October 7, 1991 Settlement agreement between the Ministry of the Environment and Chemtura Canada Co./CIE to allocate additional funding for CPAC to conduct associated studies which would include, but not be limited to, costs for consultants, legal counsel, other experts as required to assist CPAC in its duties to ensure that Chemtura canada Co./CIE and the Province satisfy all of the requirements in ensuring that the source removal activities are completed in a timely manner;

AND FURTHERMORE be it resolved that CPAC requests the support of the Council of the Township of Woolwich in terms of asking the Province to immediately establish a trust fund that will be utilized if and when the 2028 deadline for cleanup of the aquifer is not met;

AND FURTHER that this resolution be forwarded to The Homourable Jim Bradley, Minister of the Environment, Gord Miller, Environmental Commissioner for Ontario; Harold Albrecht MP, Kitchener-Conestoga; Mike Harris, MPP Kitchener-Conestoga; The Region of Waterloo; and to all municipalities in Ontario for support

Friday, April 27, 2012


I will admit that strength and power can go hand in hand with a velvet glove. Last evening the Chemtura Public Advisory Committee (CPAC) spoke calmly and quietly but with incredible force. They listened to a presentation from Dr. Gail Krantzberg first in which she indicated that in her experience the concentrations of contaminants in groundwater in Elmira is unprecedented. She indicated that in her discussions with CPAC it was clear that they would not support leaving any source of contamination in the ground. Further she indicated that Pump and Treat technology south of the border was in disfavour with the regulatory agencies because it simply doesn't accomplish the cleanup job. Whatever time frame the experts gave was never accurate and always downplayed the time and expense necessary. In most cases they still don't know the end date for cleanup because it hasn't been accomplished. She gave an example of a scenario where pump and treat (hydraulic containment) might work and that is where the contaminants are inaccessible for removal such as fractured bedrock yet the source area is well defined and very limited. Neither of these conditions exist by the way at the Chemtura site or within the Elmira aquifer. After her presentation Dr. Krantzberg was asked questions by her audience. CPAC members, Dr. Henry Regier and myself asked her questions as did the M.O.E. and Chemtura. Dr. Krantzberg easily handled what I felt were trick questions from Chemtura meant to weaken her position and opinions.

My suggestion that the Ministry of the Environment and Chemtura trembled when CPAC spoke is a subjective one. My personal experience is that yes one honest individual can make a difference, however the powers that be are truly terrified of multiple citizens standing up as they did last night and clearly saying enough is enough. Although I am speaking of CPAC's quiet assurance and confidence I also must thank Henry Regier and Richard Clausi. Literally off and on for years I've felt like a voice in the wilderness at the old CPAC, speaking aginst preposterous and illogical claims by Chemtura and their hired consultants. Henry and Richard especially have been able to attend regularily since the new CPAC changed the timing to the evening away from the 9 am. start time.

Honourable mention needs to go to Woolwich CAO David Brenneman. I have been very concerned over the last year with the influence exerted upon CPAC by Woolwich Township. Well last evening both the newest CPAC member, Councillor Mark Bauman and CAO Dave Brenneman did exert influence, either directly or indirectly, but it was all positive. Dave Brenneman has been deeply involved in the drafting of a groundbreaking CPAC Resolution. This Resolution will be presented to Woolwich Council for their ratification this coming Tuesday evening. This document was presented jointly by a number of CPAC members after they had first commented negatively towards Chemtura's grossly inadequate Dioxin "cleanup" plans .

This Resolution is based upon input from many sources including the 2003 Request for Action, researched primarily by yours truly and passed unanimously by the old CPAC. It is also clearly based upon input from Dr. Krantzberg as well as upon the environmental experience of CPAC members Ron Campbell and David Marks. Finally it is based upon the common sense and discerning talents of the other four CPAC members Dan Holt (Chair), Vivienne, Sebastian and Mark. This resolution is asking Woolwich Township to endorse going to the Province of Ontario both for cleanup money as well as for money to hire consultants, lawyers and other experts. Just as importantly in my opinion it is telling Woolwich Council and the world at large that the current M.O.E./Chemtura "cleanup" by 2028 WILL NOT HAPPEN. It is telling everyone that pump and treat as a cleanup remedy is inadequate and incapable. It is telling us that Chemtura's chemicals that are in their groundwater are still leaving their site and polluting the Grand River and eventually Lake Erie. Finally it is telling all that will listen that SOURCE REMOVAL is the only way to ever restore Elmira's drinking water aquifers.

I have been waiting for twenty years for CPAC to stand up on their hind legs, confront the powerful and speak the blunt unvarnished truth. THANK YOU CPAC!

Thursday, April 26, 2012


It starts at 6 pm. in the Woolwich Council Chambers on Church St. in Elmira, Ontario. As is usual I will be a Delegate to CPAC and will be speaking on matters primarily dealing with the failure of the pump and treat psuedo cleanup plan. I will also mention CRA/Chemtura's pathetic proposal for removal of Dioxins and DDT etc. on the south-east corner of their site. Both Chemtura and the Ontario Ministry of the Environment present their usual propaganda which primarily is a filler and attempt to run out the clock. One item of interest is the peer review done by RWDI of Guelph. They have peer reviewed a proposed site wide Certificate of Approval (Air) for Chemtura. The entire process around this proposal has been tainted from the getgo and I sincerely hope that CPAC are not distracted by other important issues and let this one slide by. That would be a serious error in judgement.

Item 6.3 on the Agenda is a presentation by Dr. Gail Krantzberg of McMaster University. She was hired by CPAC (Woolwich Township) to assist CPAC in setting priorities. Following her remarks CPAC will comment on their position relative to the proposed Dioxin and DDT cleanup in GP1 and GP2. I'm expecting CRA/Chemtura to be unhappy with what they hear. CPAC also have a "Resolution for discussion" which will set out their goals and reflect comments made by Dr. Krantzberg. I have for a number of years been taking the old CPAC to task for their talents at making concessions to Chemtura. They have done so with negligible return or quid pro quo that would benefit the public. I believe that it will shortly be obvious that the new CPAC do not share the same passion for sucking up to Chemtura as the old one did.

Wednesday, April 25, 2012


Congratulations to Jeff Merriman, Environmental Engineer with Chemtura Canada, in Elmira Ontario. Jeff has publicly announced that Chemtura's unwritten policy is to remove wastes on their site whenever and wherever they find them. This is a huge relief to those of us who were beginning to doubt either Chemtura's will or their sincerity. Clearly this will apply to the Dioxins and DDT on the east side of their site as well as the DNAPLS on the west side. This will also give the company the glorious opportunity to put their money where their mouths' are. They claim that there isn't any sweetheart deal. Really? I say it exists and is the primary reason you, your hired consultants and the Ontario M.O.E. have done nothing but play games with neverending DNAPL "investigations" on the west side of your site.

This most recent Chemtura Progress Report-March 2012 describes on page 10, section 7.0 efforts surrounding the LNAPL (light non aqueous phase liquids) plume. This plume was discovered in the very early 90's but UPAC were not advised for a couple of years while Uniroyal checked with their lawyers. UPAC were outraged and tore strips off both Uniroyal and the M.O.E. This plume consists mostly of Toluene and literally has thousands of gallons of free product beneath the ground surface. One of their probes found LNAPL in the subsurface at a thickness of .32 metre just last month. Here Jeff is a longstanding subsurface waste which you've known about for seventeen to twenty years. Perhaps you simply forgot about it what with everything else that needs cleaning up.

Tuesday, April 24, 2012


"On Saturday May 5th there is an event called "Connect the Dots Waterloo" at the First United Church at 16 William Street from 1:30-4 pm to inform Waterloo's residents about local Climate Change impacts and ways we can stay safe and build a more resilient community. There will be lectures, displays and more including a presentation regarding climate change impacts on Waterloo's homeless."

Louisette Lanteigne
Event Coordinator
Connecting the Dots Waterloo


When one is dealing with serious matters it is necessary to seek out moments of humour. Twenty-three years of being involved with toxic contamination of Elmira's air, water and soil could suck the humour and appreciation thereof, right out of a person. Therefore in that light I wish to share some following comments with you.

Hardy Wong was the name of the Director of the M.O.E. West Central Region. Hardy was perceived as having sold out the residents of Elmira. He became known as Hardly ever Wrong.

Pump and Treat technology was quickly renamed Pump and Dump by APT Environment back in the very early 90's.

UPAC or Uniroyal Public Advisory Committee was renamed Uniroyal Pollution Appreciation Club by Glenys McMullen of APTE also in the early 90's.

Richard Clausi in explaining how he and I obtained photographs of semi-buried 45 gallon drums on Varnicolor's Lot 91, without trespassing, claimed that we used APTE's Full Aerial Response Team or FART for short.

David Ash of Uniroyal decided that an embarassing incident of alleged misrepresentation of another expert's work by a consulting firm working for Uniroyal required Uniroyal to sever their professional ties with them. Hence David Ash advised UPAC that so and so had been "consolidated". Poor old David Ash himself was then "consolidated" a few years later after another fire at Uniroyal.

Susan Bryant coined the phrase "phantom" mound to describe a non existent hydraulic high or hydraulic mound that CRA used for years to claim on-site hydraulic containment.

Then of course who could forget when the Ministry of the Energy and the Ministry of the Environment were combined into one ministry namely the M.O.E.E.. It was so much fun referring to them from that point on as the Ministry of Errors and Excuses.

Last but not least was my good humoured portrayal of Conestoga Rovers and Associates. We were always being presented with their plans or programs. Hence I would refer to it as Conestoga Rovers & Associates Plan or CRAP for short.

Monday, April 23, 2012


One of the items on the Agenda for this Thursday's public CPAC meeting (6 pm.) is Chemtura's remediation plan for GP1 and GP2. These gravel pits were used back in the sixty's as the overflow destination of liquid toxic wastes which had been dumped into the east side pits at the then Uniroyal Chemical. These pits were the repository for tars, sludges, used solvents and wastes from all Uniroyal processes including DDT and Agent Orange production. Keep in mind that the two consolidation pits, RPE 4 & 5 were ordered excavated in the Settlement Agreement (sweetheart deal) of October 7, 1991. The M.O.E. and others flatly blamed these pits as contributing to the destruction of the Elmira Municipal Aquifer.

CRA on behalf of Chemtura wrote a work plan dated July 28, 2011. It is included as Appendix A in their report "Former Gravel Pit Investigation", March 2012. On page 13 in Appendix A CRA state " CRA will submit approximately 19 soil samples from intervals that are most likely to represent the most conservative conditions (ie. locations with the greatest contamination). I herein accuse them of failing to do this. Their test pit excavations are detailed in Appendix D. Eight of them are a whopping 1 metre (3 feet) in depth. The deepest pit is 2.13 metres .

Now lets go back to Appendix A, the Work Plan. Pages 8 & 9 have a Table titled "Summary of Key Soil Quality Observations in Stratigraphic logs". Borehole stratigraphic logs are simply a detailed observation of the soil removed when a borehole is drilled. The soil is laid out in order of its' removal from the subsurface so that scientists can correlate contamination to exact depths. These boreholes are from the following observation wells all in the south-east corner of the site, nearest to GP1 & 2. Starting from the top of the Table, I will quote parts thereof.

OW24-12 "Black stained sand and silt from 2.75 mbgs to 3.7 mbgs." (metres below ground surface)
OW15-7 "Strong chemical odours and elevated PID readings (50.2 ppm) from 3.3 mbgs to 5.5 mbgs."
OW69-13,8,3 "Strong odours from 4 mbgs to 5 mbgs."
OW146-3 "Chemical odours from 2.2 mbgs to 2.5 mbgs. Black stained gravel from 2.2 mbgs to 2.5 mbgs."
OW145-4 "Strong chemical odours from 1.2 mbgs to 2.5 mbgs." By the way the two nearest testpits (TP 18 & 19) were only excavated to 1 mbgs.
OW16-10 "Strong chemical odours and elevated PID reading (52.8 ppm) from 3.0 mbgs to 3.8 mbgs."
OW16-3 "Strong chemical odours from .7 mbgs to 3.5 mbgs." Again the nearest testpits were all of 1 metre in depth.
OW144-3 "Strong odours from 3.0 mbgs to 4.9 mbgs."

A skeptic could be forgiven for thinking that CRA have used their work plan as a blueprint for avoiding the worst contamination in GP1 & 2 as well as in the entire south-east corner. It appears that unsurprisingly the liquid contamination has moved vertically downwards into the ground and is much worse deeper than shallower. Removing the top .3 metre of soil is strictly a cosmetic fix and in my opinion is a typical CRA/Chemtura/M.O.E. pretend cleanup.

Saturday, April 21, 2012


The March 2012 Chemtura Progress Report came out yesterday. I'm seriously beginning to wonder when they are going to throw in the towel and honestly rename it the Monthly Failure Report. The UA or Upper Aquifer (shallow aquifer) had hydraulic containment problems allegedly due to what CRA refer to as creekbank storage effects. This is not to mention of course that the UA containment system even on a good day is only hydraulically containing the south-west quadrant of the groundwater discharge to the creek. The other three quadrants discharge directly to the creek. The pumping rates are also down for the MU (municipal upper) aquifer which is supposed to contain that aquifer from leaving the Chemtura site and then further contaminating the rest of the Elmira aquifer.

The real disaster continues to be the off-site pump and treat system. It has always been sub par compared to CRA's computer modelled required pumping rates needed to clean up the Elmira aquifers. I predict that the day will come when Conestoga Rovers and the Chemtura site will be the classic case example of the failures of hydraulic containment (ie. pump & treat). I further predict that University level courses dealing with environmental issues will point and snicker at the illogic and stupidity of trying to clean up heavily contaminated sites using pump and dump (oops pump and treat) technology. In the recent past Chemtura have sucessfully pumped their off-site system for three months while failing to achieve their own pumping requirements fourteen times! Some of these below required pumping levels are at least close but many others are not. Over the long term since off-site pumping began in 1998 the story is equally horrid. They have sucessfully pumped the off-site wells for a total of two years since 1998. Out of a possible fourteen years of off-site pumping they've achieved two successful years and fourteen below their targeted pumping rates. Oh and by the way we are now into year fifteen and they have horribly failed in January, in February and again in March 2012. Not even close so far this year.

Keep in mind how your Ontario Ministry of the Environment (M.O.E.) have responded to this: They have said NOTHING and they have done NOTHING! At least they are consistent in their protection and shielding of our favourite local polluter.

Friday, April 20, 2012


Both our local papers have put the latest Biogas stories on their front page this week. As of five minutes ago I couldn't find the Elmira Independent's "Biogas opponents launch appeal" on-line however the Woolwich Observer's story "Citizens want support in biogas fight" is on line. Also on the front page of the Observer is an article dealing with the Jigs Hollow (Kuntz Pit) Pit titled "Woolwich seeks more answers ahead of gravel pit OMB hearing".

Both papers have covered Monday evening's protest outside the Woolwich Township building as well as the Delegation presented inside by Vivienne Delaney and Michael Purves-Smith. The Independent suggested there were 80 protesters present and the Observer suggested more than 50. O.K. so technically you were both right but as I manually counted heads the Independent are more right. The BFCC (BioFuel Concerned Citizens) were asking Woolwich Council for support and although they received promises of moral support and further efforts to pursuade the province, concrete commitments were not available on Monday night. Both Mayor Cowan and Councillor Bauman were guarded in regards to solid promises.

As mentioned earlier here in the Advocate, Lynne Hare and Jan Huissoon continue their efforts and research into issues around the Jigs Hollow Pit. They continue to dig deep and come up with new information relevant to the impacts upon local citizens of this proposed pit. They are a fine example of citizen activism in action.

Thursday, April 19, 2012


According to our local, notorious world class polluter, they stopped dumping them into the ground in 1963. This was when their production of Dioxin contaminated herbicides ended. A mere half century later the company are poised (sort of) to clean them up. Over fifty years of Dioxins in the air, the soil, groundwater and the creek are going to be addressed again. Seven years ago DDT and Dioxins were removed from creekbanks and sediments on site. This time two former gravel pits which were intentionally used to handle liquid runoff from the east side pits will be addressed.

All signs are positive that Chemtura and their consultants will attempt to buffalo CPAC as they have so sucessfully done in the past. With notable exceptions including Dr. Henry Regier and myself this was resisted. Furthermore as this was considered "new" evidence when it was confirmed in 2002, some older CPAC members were also willing to dig in their heels and demand more. Old contamination such as west side DNAPLS of course was covered by the M.O.E./Uniroyal sweetheart deal. Chemtura are claiming that this cleanup is "voluntary" because there are no off-site receptors. Their logic is perverse and self serving and only the Ontario Ministry of Environment are corrupt enough to accept it. Chemtura and their consultants wish to use a combination of capping and soil excavation to the remarkable depth of .3 metre (1 foot) to remedy this environmental tragedy.

How do they justify a minature cleanup versus the real deal? First of all they take very few soil samples and all at shallow depths. Secondly they do the same with groundwater testing. They sample wells in UA1 (upper aquifer 1) but not in the deeper UA3 (upper aquifer 3). Then with cherry picked sampling they can jump to incredibly inaccurate conclusions which remarkably save them millions of dollars in cleanup costs. Did you really think that polluters pay consultants big dollars because they want to do the right thing? Hardly! If the consultant isn't finding and interpreting data which saves the polluters big money then that consultant better look elsewhere for business.

CPAC (Chemtura Public Advisory Committee) is one week away namely Thursday April 26/12, 6 pm. in the Woolwich Council Chambers, Church St. Elmira, Ontario. I expect great things from our CPAC under the new Chairmanship of Dr. Dan Holt, ably assisted by five other community members.

Wednesday, April 18, 2012


Kudos for both persistence and hard work must go to Lynne Hare and Jan Huissoon. They were both back at Woolwich Council Tuesday night as delegates to update Council on the latest news around the proposed Jigs Hollow Pit. Their delegation followed the BIOFuel Concerned Citizens delegation and it included slides and pictures to enhance and clarify their points. The major point that I took from the presentation was that Council have more control and authority over certain proposed aspects of this pit than they or anyone else initially realized. These aspects are the proposed recycling of concrete and asphalt. Gravel extraction may be primarily the province's purview but recycling appears to be that of the local municipality. With that in mind Jan and Lynne showed slides of a concrete recycling facility while in operation. It was incredibly dusty and would create airborne particulate as well as noise.

Tuesday, April 17, 2012


Many people can and should take credit for last evening's demonstration of solidarity and democracy. CTV news (CKCO-TV) at 11:30 last night said that 85 people were involved in the protest. That sounds about right because I had done a headcount earlier in the evening and counted 78 adults. The children being shorter and in the crowd were harder to spot. Including them in the count is appropriate because as speakers suggested the increased truck traffic and diesel fumes will negatively affect everyones' health including and especially childrens'. So with kudos to 85 people I'm also going to mention Michael Purves-Smith, Vivienne Delaney and Dan Holt. Michael and Vivienne spoke to the crowd marching and protesting at the front of the Woolwich Township building on Church St. and Dan was there as well as speaking to numerous individuals at the start of the protest behind the Township building.

Many stawarts of the BioFuel Citizens Committee (BFCC) made it to the protest and stood up to be counted as did numerous other Elmira citizens in support. The basic message was one of protest against the Ontario Ministry of the Environment. As per a large banner (mine) first hung at the back and later out front "Min. of Environment Public Consultation Is A Joke". The M.O.E. are experts at pretend consultation. Woolwich Council and mayor have spent countless hours finding a better alternate location in Woolwich, they were encouraged to do so and then the M.O.E. totally ignored this option and approved the Martin's Lane location. This was a betrayal of the first order by the M.O.E. and sadly typical of their behaviour.

Further kudos go to Councillor Poffenroth who came outside and spoke with us prior to the Council meeting. His presence and moral support was appreciated. Inside Vivienne and Michael spoke to Council about health issues, traffic issues and democratic issues. They received a round of applause from the dozens of supporters who followed them into Council chambers. Last night's message also was one of perspective. As is too often the case, this entire proposal is simply about a small group milking the system at the expense of the many. The Ontario government's rules around renewable energy need a lot of improvement. Taxpayer subsidized, allegedly "green " energy at the expense of both the health and quality of life of many, for the financial benefit of a few investers is just plain wrong.

Monday, April 16, 2012


The local media are picking up on this story for three reasons. It's environmental, it's controversial and it's new. CTV carried the story plus interviews last evening. The interviews were with local resident Michael Purves-Smith, Mayor Todd Cowan and proponent Chuck Martin. This evening's protest in the Woolwich Township building's parking lot was also advertised although they suggested 5:30 pm. whereas my understanding is it will be closer to 6:15 pm.. I would describe the CTV story as informative and as good balanced reporting. Saturday the Waterloo Region Record carried the same story on the front page of their local section namely: " Green energy plant gets green light". Numerous issues include the province having removed municipal zoning and control rights as well as the province apparently ignoring an excellent alternate location in Woolwich Township that would have relieved local concerns over odours , health issues and heavy traffic.

Dan Holt in the Record story alluded to the issue that strikes a chord with me. It is the trust issue or more precisely lack of trust issue. Local Elmira residents are advised that the Ontario Ministry of the Environment will monitor and enforce odour and environmental issues. Really? Since when? Elmira has a half century plus history of environmental degradation of all kinds and quite frankly throughout that period the M.O.E. and their predecessors have walked hand in hand with each and every local polluter. The M.O.E. have and deserve zero trust from this community based on their overwhelming sellouts to industry and coverups of pollution. Whether Rothsay Concentrates, Scavenger Recycling, Chemtura Canada or Varnicolor Chemical, the M.O.E. local history includes sweetheart deals, tipoffs to industry and criminal charges against their employees. M.O.E. assurances are nothing but smoke and mirrors.

Saturday, April 14, 2012


I have now completed reading Conestoga Rovers March 2012 report titled "Former Gravel Pit Area Investigation". I am now slogging through the much thinner "Remedial Options Evaluation". It is much less technical and objective and much more subjective. Hence I'm finding it difficult going without the use of rubber boots and a shovel.

There are a number of items with which I take issue. First of all the consultants remind us that much of where they are now is based upon their 2003 HHRA or Human Health Risk Assessment report. They appear to be speaking of this report as if it had some universal credibility and recognition. It did not. It was riddled with errors and inconsistencies and unrealistic assumptions. It was presented to CPAC and heavily criticized most strenuously by Dr. Henry Regier and myself. There were other CPAC members who also criticized it. Henry went so far as to make a trip to Hamilton to discuss his technical concerns and questions with Ministry (M.O.E.) bureaucrats. Henry has written repeatedly about the response he received and that it was not satisfactory. I wrote numerous criticisms as well which were essentially ignored or deflected.

This Remedial Options report also appears to make a big deal out of groundwater concentrations which are below the Ontario drinking Water Standards (ODWS). This is a deflection as very few to zero humans are directly drinking water from the Canagagigue creek. It is also much more significant that DDT and Dioxins are bioaccumulative. Thus even very small concentrations in water for example that are ingested move up the food chain and magnify over time.

CRA conclude that the only receptors to their Dioxins in the south-east corner are shrews and human trespassers. This is nonsense. Both Dioxins and DDT are found either in creek sediments or floodplain soils all the way down the creek as far as the Grand River, five miles away. These floodplain soils are grazed upon by cattle who uptake the DDT and Dioxins and transfer them into their milk. From there we get to enjoy Chemtura's pollution first hand.

Conestoga Rovers (CRA) repeatedly claim that their Dioxins and DDT do not leach into groundwater. To date I see zero evidence backing this claim other than their bald assertion. The evidence points to low level Dioxins in the groundwater and the flow is uncontested directly to the creek. Then there are Dioxins downstream in the creek. Maybe there will be a surprise twist however after decades of reading CRA's literature, usually the plot and narrative fizzles out before the end.

Friday, April 13, 2012


The Bio Fuel Citizens Committee are planning a protest to be organized in the parking lot of the Township building on Church St. in Elmira. Between 6:15 and 6:30 would be ideal prior to the start of the televised Council meeting Monday at 7 pm.. Signs and placards are welcome and the purpose is to demonstrate the level of opposition to the M.O.E.'s recent decision to proceed with the proposed location on Martin's Lane in Elmira.


Both local papers here in Woolwich Township are carrying stories regarding appeals of the Ministry of the Environment's decision to go ahead with the Martin's Lane location in Elmira. The Woolwich Observer aren't on line yet so I don't have a link to their story (pg.3) titled "Citizens' group to challenge biogas". The Elmira Independent have both a story and a Letter to the editor. The story is "Township decides against biogas appeal" and the Letter to the editor is titled "Biogas plant should be appealed". For any skeptics who wonder if indeed Woolwich Council and the Mayor were led down the garden path by the Ontario M.O.E. let me offer this observation. I've been dealing with the M.O.E. for twenty-three years and their strong suit consistently has been obfuscation, deception, backroom deals and psuedo consultation. Their behaviour did not remotely surprise me.

The best and only way to deal with professional @#$%^&*# is by public humiliation of them. Citizens need to confront them about their alternative realities and their credibilty gaps. They need to be publicly confronted when they talk about consultation with citizen groups while at the same time issuing Amended Control Orders and sweetheart deals privately. Councillor Mark Bauman also raises the issue of the M.O.E. lack of enforcement of environmental laws and standards. Historically the M.O.E. have been long on talk and short on action in Elmira in regards to horrible odour issues over the years.

Here are some important dates for citizens to mark on their calendars regarding the appeal to the Environmental Review Tribunal (ERT). May 8/12 is the preliminary hearing. June 1/12 is a status update teleconference. June 5/12 is the start of the formal hearing. Believe it or not citizens are supposed to have their initial disclosure of evidence prepared by April 24/12. Citizens I'm telling you here and now that justice is not to be found or expected at the ERT . If it happens count yourself lucky. If it doesn't happen, don't be surprised or shocked.

Thursday, April 12, 2012


This vital information was in regards to the Settlement Agreement or "sweetheart deal". It is my belief that the new CPAC, who with open minds have examined the Settlement Agreement; understand that it is the overiding and controlling document. It releases Uniroyal/Chemtura from liability for known contamination in 1991. The wording in the document is contamination that the M.O.E. and Uniroyal are "presently aware of". There is no mistake, despite the protests from the M.O.E., Chemtura and Susan Bryant; it is a sweetheart deal. The M.O.E. got the focus of the public off their incompetence and gross negligence and Uniroyal/Chemtura were excused from hundreds of millions of dollars of cleanup on the west side of their site. To sweeten the deal, Uniroyal accepted 100% of the blame for the shutdown of the Elmira wellfields thus relieving the M.O.E. of more blame for their oversight failures with even more local companies. It was a win-win scenario for the M.O.E. and Uniroyal. The public of course got screwed.

Not only was the "sweetheart deal" witheld from the public by all six signatories and parties to the Environmental Appeal Board hearings; it was also witheld from the majority of APTE members and coordinators. The six parties were Uniroyal and the Ministry of the Environment (M.O.E.) of course but also the Township (Woolwich), the Region (Waterloo), Nutrite and APT Environment. I have spoken with some former APTE members and coordinators. There was zero knowledge of any Release or Indemnity being given to Uniroyal by the M.O.E.. That a couple of other APTE members were in the know is entirely possible. I was a member at that time and I also certainly was not advised then or later. APTE's own lawyer at the hearings had no knowledge of an Indemnity being given to Uniroyal.

When the conspiracy thickens is in the years after the sweetheart deal. At CPAC we discussed in depth all the "hot spots" on both sides of the creek running through Uniroyal/Chemtura. In July 2003 CPAC passed a Motion requesting source removal of among other contaminants, DNAPLS (dense non-aqueous phase liquids) which were on the west side of the creek; underneath the former operating ponds (RPW 5,6,7,8). Then CPAC sat and waited. A DNAPL technical sub committee was formed. In 2007 four of us went and spoke with preminent world experts on DNAPL at the University of Waterloo. Still nothing happened at CPAC including the other three persons ever speaking about the gamechanging information we received at the U. of Waterloo. Keep in mind that Esthur Thur, Richard Clausi and I all left APTE in January 1994 precisely because of their refusal to object to the M.O.E.'s acceptance of a grossly flawed DNAPL report produced by Uniroyal. I was the only person on the DNAPL technical sub committee in 2007 objecting to the psuedo science and plain nonsense being spouted by Chemtura and the M.O.E.. For this reason it was deemed necessary by my former colleagues to remove me from CPAC. My appeal of a Certificate of Approval was the red herring they had been waiting for. I of course had no idea then as to what their motivation was.

My former friend and colleague had sat through years of DNAPL discussion and sub committees ostensibly to clean them up, with full knowledge that Chemtura were indemnified from all liability for them. The Ontario M.O.E. and Uniroyal/Chemtura did the same thing. Which is more repulsive; that our government would lie and deceive us or our own neighbour here in Elmira? Honest work has been done on the old CPAC in regards to air issues, that I acknowledge. Former CPAC members worked diligently to better environmental conditions in Elmira by trying to remove Dioxins on the east side of the creek, which were discovered in 2002. That still does not excuse being part and parcel to a sweetheart deal in 1991 which was done to help a disgusting polluter and their supposed regulater; at the expense of the public's right to a full cleanup.

Wednesday, April 11, 2012


Frankly I was surprised when I was told this last evening. I was unable to attend Council meeting but got a phone call afterwards. Politically I felt that they had very little wiggle room. Mayor Cowan had come out very strongly against the proposed Elmira location for Woolwich Bio-En and most if not all of the Council appeared onboard. This decision can and will be interpreted both ways. One interpretation is that Council are being pragmatic and not throwing good money and effort after bad. Clearly Woolwich Staff had legal advice that there were few if any legal grounds to reverse the M.O.E. decision. The other interpretation is one of principle and conviction. If you believe strongly in your cause do you throw in the towel when things are going badly? Obviously the BFCC (Bio Fuel Citizens Committee) are not throwing in the towel. Will they win at the Environmental Review Tribunal? I wouldn't bet money on it but at the same time they are still defending themselves and their community. The one piece of advice I have given them recently is to show up in force at any and all hearings, pre-hearings and or mediation conferences. Citizens of Elmira and Woolwich Township you are getting the environment and provincial decision making that you yourselves are allowing. Stay home and do nothing and Elmira will continue to be a target for entrepreneurs looking to make a buck at your environmental expense.

Tuesday, April 10, 2012


Today is the deadline for an Appeal of the M.O.E. approval given to Woolwich Bio-En's location on Martin Lane in Elmira. Presumably at this evening's Committee of the Whole, Woolwich Township will advise as to whether or not they are going ahead with their appeal. Apparently the grounds for an appeal are primarily based upon human health issues which are notoriously difficult to prove, especially ahead of the proposed operation of a facility. Even if Woolwich Council receive legal advice contrary to filing an appeal, I suggest that the Councillors are between a rock and a hard place. Most of them campaigned on varying environmental issues including the Bio-En proposal to set up shop next to a residential subdivision. If I were to bet, I would bet that they are going to go ahead with an appeal. I would suggest that often in this world , on matters of conscience, one takes steps that have little or no chance of success. Not appealing pretty much guarantees failure.

Besides the issues of odour, noise and greater truck traffic through downtown Elmira is the issue of "energetics". This was brought to my attention very recently by some members of the Bio Fuel Citizens Committee (BFCC). Apparently the major reason that this proposed plant will be economically viable and a moneymaker for the proponents is because we the taxpayers are subsidizing it through our taxes. The cost of trucking the feedstocks into Elmira is not being borne by the proponent as much as it is being subsized by the taxpayers. Quoting Michael Purves-Smith "..I object to spending my provincial tax dollars on transporting 105,000 tonnes (70,000 in and 35,000 out) per annum, or about 350 tonnes every day except Sundays and holidays, of someone else's garbage through downtown Elmira and on past my house to a plant that will have, as located, a negative impact on the environment." Wow! That certainly adds salt to the wound when we realize that the project we are fighting , we are also helping to pay for.

More credit to the BFCC. They are putting their time, money and effort where their mouths are. For over twenty years I've stated that citizens working for free to protect their communities should have far more weight put on their opinions and facts that they present. Professional consultants are essentially no more than hired guns and their opinions should be so considered. The BFCC are appealing this decision of the M.O.E. .Whatever the result I applaud their convictions and their efforts to protect all elmira citizens.

Monday, April 9, 2012


Last Wednesday's Waterloo Region Record carried this story "Liberal wind-energy woes grow stronger". There are numerous lawsuites launched against the province both due to their moving ahead with wind energy farms as well as for cancelling them along lake Erie. SouthPoint Wind is suing for damages after a moratorium was placed on offshore wind farms by the province. Closer to home Mr. Ralph Coneybeare of Listowel has been protesting against the installation of wind farms near his home and business.

In response the provincial Liberal government are trying to give priority to the approval of new projects to communities who are supportive of the idea and location. this just makes good sense and perhaps is a belated good idea. To the best of my knowledge, as of the present, the science is not yet there to back up the claims of health problems arising from wind farms. This is not remotely a denial of the legitimacy of those claims because science by necessity is often asked to study and determine matters only after a problem has arisen.

Saturday, April 7, 2012


We all know the story of the boy who cried wolf. He lied for attention, he lied for various motives but the bottom line was he lied and when it was desperately important for people to believe him, no one did. This is why I've never understood politicians. Most of them are smart enough to only lie when they believe it's necessary, important and they won't get caught. The consequences of getting caught are that no one will ever believe you again even when you are being honest. The odd politician will lie frivolously and for very slight personal gain. They usually don't last long. Therefore what I am beating around the bush at, is this. I am beginning to realize that just because I know a specific politician is a liar, I must not assume that EVERYTHING coming out of their mouth is a lie. Dishonest people actually can be motivated to say and do the right thing. Politicians do tell the truth sometimes and should not always be assumed to be lying. Bad, dishonest politicians can still do good and should be complimented when they do so.

The strength of our new CPAC is constantly emerging. The less "technical" people on it are showing leadership and organizational skills far beyond their limited exposure to the Chemtura site and the two decades plus of municipal and provincial politics. The "technical" people are providing background documents and information relevant to the cleanup of the Chemtura site. Most recently CPAC members have circulated two documents of great import. The one is a GRCA map showing in detail exactly where the floodplain of the Canagagigue Creek is located through the Chemtura site. It is an eyeopener in that the entire south-east corner of the Chemtura site is floodplain and hence vulnerable to flooding and erosion in times of storms and heavy rain. This floodplain totally encompasses both the Dioxin laden GP1 and GP2 areas. The second document is a very good discussion around hydraulic containment. It is also known as pump and treat and certainly is not the panacea some cleanup personnel would like us to believe. Kudos to CPAC members for their ongoing educational hard work.

It has also been brought to my attention through logic and reason that I have been hard on a couple of Woolwich Staff members. Also there have been anonymous commenters here in the Advocate who have been very critical of the same persons. Although I am constantly reassessing and keeping an open mind on our politicians and civil servants I will absolutely not be deleting or censoring commenters who criticize them. Either you, other readers, or myself may offer a differing opinion if we wish. Getting back to certain senior Staff I have been receiving positive input and when confirmed, absolutely good things will be printed here about their efforts. Honesty, forthrightness and even good intentions should be rewarded publicly and this Blog/Website is not just about exposing the corrupt, it should also expose the good.

Friday, April 6, 2012


Page #11 of yesterday's Elmira Independent has this story: "Alternate location unlikely for biogas plant". I can't give you the readers a link to it as while it's in the hardcopy paper I can't find this article on-line. We are advised that the Appeal deadline is this Tuesday April 10/12 for Woolwich Township. I would expect some announcement at that night's Council meeting regarding whether they went ahead with the Appeal or not. We are also advised via the proponent, Chuck Martin, that two major issues make an alternate location unlikely. Those issues are time and the Ontario Power Authority. I believe that where there is a will there is a way. While the will is here in Woolwich, including Council, for an alternate location, that will seems sorely lacking at the provincial level. Shame on both the Ministry of Energy and the Ministry of the Environment.


That word is not in the Settlement Agreement also known as the "sweetheart deal". Yesterday's Elmira Independent articles, plural, while providing excellent coverage on multiple issues brought up at the first public CPAC meeting in four months, are mistaken in one aspect. The front page story is titled "Chemtura recommends capping of on-site waste" and the title at the top of page four is ""Sweetheart deal" discussed at CPAC". Garth Napier in his own words on page four is not a lawyer. What he is unfortunately is a front man for an inherently corrupt organization known as the Ontario Ministry of the Environment. The word used in the Settlement Agreement (pg. 15) is RELEASE. RELEASE essentially means an INDEMNITY or protection from action, as in all actions including Control Orders, Field Orders, prosecution under the Environmental Protection Act and yes civil lawsuits. Page #15 states that Uniroyal are released "...from all actions, causes of action, damages, claims, and demands whatsoever of which both Uniroyal and the province are presently aware...". Uniroyal were required to excavate two pits on the east side of their property and to build a pump and treat groundwater system. They were also ordered to "study" DNAPLS. All the rest involving hundreds of millions of dollars of cleanup on the west side, they were released from doing. In return the Ontario M.O.E. received a Release from Uniroyal. That is the heart of a sweetheart deal. Two guilty parties let each other off the hook, to their mutual advantage while the public interest gets thrown out the window. Thank you very much Ontario M.O.E. for selling out the public interest to protect your reputation and credibility. That agreement is exactly why we've had a non-cleanup in Elmira for the last twenty-one years. And also thank you to the six parties at the Environmental Appeal Board hearings who did receive copies of that agreement and did not advise the public. Shame on the pack of you.

More shame to Chemtura who continue to do as little as possible as suggested by Vivienne Delaney CPAC member: "The cheapest way to do it is what you are doing". This refers to the proposed Dioxin non removal on the south-east corner of their site. Conestoga Rovers claims that there is no off-site impact from their Dioxins. That is utter nonsense and wishful thinking combined with typical engineering arrogance. Some credit goes to Steve Martindale (M.O.E.) who while calling it his personal view does believe that the Dioxins should be removed not just covered over.

Gail Martin, Editor of the Independent, deserves much credit for giving this community issue involving our water supply and health so much time and space. I agree with her Opinion article that CPAC are way behind in attacking numerous Chemtura issues and failings. However it is less due to the complete turnover of CPAC membership as it is due to ridiculous and repeated delays and stalling by Woolwich Township right from the beginning. Seven months after the election (ie. May/11), I and CPAC were FIGHTING The CPAC Chair and Mayor just to get the first date for a public CPAC meeting. During the late summer and fall excellent progress was made only to be put on repeated hold unilaterlly by the CPAC Chair. He is gone and I expect not good things but great things from your CPAC from this point onwards.

Thursday, April 5, 2012


Man these guys haven't lost a thing. Tewnty years plus in reading reports from Conestoga Rovers (CRA) and they are still the masters. Their latest report is titled "Former Gravel Pit Area Investigation", March 2012. It refers to the Dioxins and DDT primarily that is in the south-east corner of their site, in and above the water table and extremely close to Canagagigue Creek. Their Figure 5.1 is a good example of why I chose the above title. A good debater can shift or channel a debate away from his weak areas and toward his strengths. Similarily a good consultant, in a report showing absolutely horrendous contamination of the worst toxin known to mankind (dioxin), can do the same. CRA are working very hard to minimize the extent of cleanup and hence the money expenditure by their client Chemtura. Therefore it is crucial to misdirect the readers. Figure 5.1 is in black and white except for yellow highlighted areas which show "Exceedance of Both Ecological And Human Health Based Cleanup Criteria". This information might be of the significance that the highlighting purports IF the Ecological Criteria were lower than the Human Health Criteria, but they are not. First of all there is only an Ecological Cleanup Criteria for Dioxins alone and it is thirty times higher than the Human Health Cleanup Criteria. Therefore it is nothing more than a red herring. Are we seriously cleaning up this site for the benefit of the shrews that CRA care for or are we concerned about human health? I'm sure it's all just a coincidence but the focus on areas that exceed BOTH the very high Ecological Criteria and the Human Health Criteria are all in GP1 and GP1 only. This red herring focuses attention (and they hope cleanup) on one much smaller area than the whole south-east.

So let's back away from the Ecological and focus on the much lower Human Health Criteria. But this time NOT just Human Health Criteria for Dioxins. CRA managed this by including the Ecological Criteria which just so happens to only apply for Dioxins not for DDT. There is no DDT Ecological Criteria on this Figure. Now if we look at the Human Health Criteria for BOTH chemicals, lo and behold every single test pit and data point in both GP1 and GP2 as well as the rest of the south-east area EXCEEDS the Human Health criteria. It exceeds the Human Health Criteria for BOTH Dioxins and DDT. Now that is the data that should be highlighted on this Figure (5.1). Go figure!

Wednesday, April 4, 2012


We've all heard of the duck theory. If it quacks like a duck, waddles like a duck and looks like a duck, then it probably is a duck. This theory also works for politicians, at least in the long run. The problem arises in the short run. Not only are politicians human and thus subject to human foibles but they are also often to a fault willing to comprimise. This is the case of yes it's a bad idea but I'll support it in exchange for your support on hopefully a bigger more serious issue.

Here in Woolwich Township we've had some recent setbacks. This would include the Hawk Ridge Homes proposed residential subdivision as well as the Bio-Energy proposed location on Martin's Lane in Elmira. The first is a horrible and ridiculous location and the second a totally unnnecessary threat to nearby long term residents. Still up in the air are all the proposed gravel pits. The Jigs Hollow Pit has scheduled an O.M.B. mediation session for May 8, 2012. The Hunder Development has scheduled an O.M.B. pre-hearing for April 16/12 10:30 am. in the Council Chambers. The West montrose Pit just seems to go on and on. I interpret that as Capitol Paving being in no hurry to take on the well organized and financed citizens who have now been mobilized and active for years.

Last but not least we have the ongoing non-cleanup of the Elmira Aquifers. This very sucessful sham and charade perpetrated by past municipal and current regional and provincial governments is being challenged by the citizens new CPAC. Make no mistake they are different from the old one. They don't have the baggage including past bad decisions. They also don't have past inappropriate promises and commitments to the M.O.E. or Chemtura that they need to honour. The slate was wiped clean with this new CPAC and they are focusing on the restoration of the Elmira Aquifers by 2028. There is way less ego and way more cooperation. Stay tuned for good things.

Tuesday, April 3, 2012


First off GP1 & GP2 stands for Gravel Pit 1 & 2. These are the locations at Uniroyal/Chemtura of the highest Dioxin concentrations in Ontario and possibly Canada. The expansion to Canada is based on the ever increasing concentrations that are being found there. Stratigraphy refers to the sub surface makeup of the ground. Just by the name (gravel pit 1 & 2) it's pretty obvious that we have sand and gravel present. GP2 is closest to the Canagagigue Creek and would be no more than sixty feet from it at it's closest point. Although there are literally dozens of reports over the years showing the sub surface stratigraphy of this area the easiest one for CPAC members to access might be the recently released (Feb 2012) 2011 Annual Monitoring Report Volume II Figures and Tables. Specifically Figures 2.5 and 2.1 are the pertinent ones. The only reason I'm including Fig. 2.1 is because Conestoga Rovers (CRA) as is their habit have made another boo boo on Fig. 2.5 by labelling UA as Upper Aquitard. For the last twenty-three years on this site, UA has stood for Upper Aquifer as it does in Fig. 2.1 . The significance of Fig. 2.5 therefore is that this stratigraphic Cross-Section clearly shows that the UA or Upper Aquifer is right at the surface on the east side of the Canagagigue where GP1 and GP2 are located. This also corresponds to the sand and gravel found in these gravel pits. Sand and gravel of course are the very best materials for groundwater to flow readily and easily through. Going back to Fig. 2.1 we can see that most of the rest of Elmira has an aquitard known as the SAT or Surficial Aquitard. Aquitards are made up of tightly compacted silts and clays and inhibit the flow of either surface water downwards or groundwater horizantly or vertically.

The significance of this stratigraphy is that solvents which mobilize Dioxins and DDT and which are on the Chemtura site in abundance are moving through this GP1 & 2 area and discharging into the creek. There is zero natural protection from an aquitard which would inhibit groundwater and contaminant flow. This area is also of low elevation and is floodplain which could easily mean surface water from the creek in springtime can rise and erode soils thus releasing more Dioxin into the Creek. Therefore the presentation by CRA at last week's public CPAC meeting was mainly wishful thinking. When CRA suggest that the only receptors are shrews and trespassers, they are ignoring the obvious. All the Dioxins found downstream in the Canagagigue came from both Uniroyal groundwater discharging to the creek as well as erosion of Dioxin laden soils in and beside the creek.

Monday, April 2, 2012


It never really made sense. Uniroyal Chemical geographically are the farthest chemical company, manufacturer and polluter from the south wellfield which is located beside Voisin Motors at the south end of Elmira. The general flow of all the aquifers shallow and deep is from north-east mostly south and slightly south-west. Between Uniroyal and the south wellfield we had Sulco Chemical, Varnicolor Chemical, Canagro, Borg, Sanyo Canada and Lot 91 (Varnicolor). Don't get me wrong here. Uniroyal/Chemtura are a dirty polluter of the most extreme kind. They however designed their "waste management" pits and ponds to effectively drain into the Canagagiue Creek. This worked so well that in the 60's and 70's the "Gig", for all intents and purposes, was devoid of life. They killed everything even microscopic biota. They leached vertically through the shallow aquifer and into the Municipal drinking water aquifer below. But the bulk of their toxins went downstream intentionally. Imagine Uniroyal's distress and outrage in 1989 to learn that nature had failed them. Their toxins allegedly had travelled all the way south approximately 800 metres (1/2 mile) to the south wellfield. Something was very wrong here.

Without naming names Uniroyal knew that other local polluters had been operating under the cover of their umbrella. Uniroyal had been on the radar of the OWRC (Ontario Water Resources Commission) and the Ministry of the Environment for decades. Uniroyal were so convinced that they alone were being singled out that they offerred a million dollars to go towards a technical study of ALL sources of groundwater pollution in Elmira. There were no takers. Uniroyal appealed the August 1990 Control Order which assigned all blame to them. At the Environmental Appeal Board hearing in the spring of 1991 Uniroyal's lawyers flatly stated that Varnicolor had contributed NDMA to the Municipal Aquifer. Then the EAB adjourned for the summer and the M.O.E. decided that a fix was in order before too much more damaging information came out. Damaging to the credibility of the Ontario M.O.E..

To this day there are ongoing and annually updated plume maps showing NDMA, Chlorobenzene and Ammonia plumes spread out across the town of Elmira. These plume maps show these chemicals in the Municipal Upper Aquifer, the Municipal Lower Aquifer and even NDMA AND Ammonia in the Bedrock Aquifer. Based on the flow direction of the groundwater (north-east to south-west) it can be interpreted as if everything starts at Uniroyal/Chemtura and heads to the south wellfield. The smoking gun of course would be plume maps in the shallow or Upper Aquifer. All contaminants are introduced at surface.They then leach downwards. Why have Uniroyal's consultants never produced Upper Aquifer plume maps for the Town of Elmira as they have for the other aquifers? The answer is obvious. Those plume maps would destroy the twenty-one year coverup and sweetheart deal between Uniroyal and the M.O.E.. The other dirty polluters in Elmira would be exposed as contributing to the destruction of our drinking water and they don't have an Indemnity like Uniroyal.