YEARS OF ABUSE OF AUTHORITY

WELL! Today's Waterloo Region Record carrys this story "Ombud suggests jail for secret meeting abuse". Boy do I have a candidate for the first Canadian politician to visit the inside of a jail for this particular offence. She is a long time Woolwich municipal Councillor and an unsucessful mayoralty candidate in the last election. Yup that would be our very own Pat McLean. I truly have never met a hypocrite of her magnitude. Pat was always very honest and clear that she had little or no scientific/technical talents or background; but boy did she understand policy and procedures. She was the penultimate expert on municipal rules, regulations, ethics and democratic procedure. ABSOLUTE HORSEFEATHERS!

I have been observing and participating in one of the Committees of Council namely CPAC (Chemtura Public Advisory Committee) since its' inception after the October 2010 election. While its' start was both very slow and very rocky, including the eventual loss of four CPAC members including myself; nevertheless I have been constantly pleased but surprised at the insistence of openess and transparency of this Committee of Council. This specifically includes making all CPAC meetings open to the public. I will give credit for this primarily to CAO David Brenneman. I will also give honourable mention to Christine Broughton (Clerk) although I am less sure of her role in this capacity.

It has been occasionally awkward and difficult when discussing strategy etc. to have meetings open to the public and the media; above and beyond those advertised generally on the last Thursday of each month. Nevertheless David Brenneman has advised that provincial law is very clear on the subject. Committees of Council must behave and follow the same laws as Council. Therefore there are only three recognized exceptions where Council (or committees) may go in camera. Those are 1) legal matters 2) land sales or acquisitions 3) personnel (employee) matters .

I am pleased to say that this Council and CPAC are to the best of my knowledge following the letter and spirit of the law. Past committees (CPAC) have not. Some of these violations are perhaps minor such as many private breakfast meetings at local restaurants. Mind you this is the very same thing that currently has the City of London in major hot water with the province.

Other violations by the past CPAC Chair, who allegedly knew better, have been egregious. They include by invitation only technical DNAPL meetings held at Conestoga Rovers offices on Colby Drive in Waterloo not to mention private meetings held between CPAC members and Chemtura staff at the plant in Elmira. Further violations might even include inviting some CPAC voting members to a private business meeting while excluding others. Yours truly was the excluded one.

Currently we have a breath of fresh air in Woolwich Township matters. Kudos to all responsible.

ONTARIO MINISTRY OF THE ENVIRONMENT ABANDONED ELMIRA LONG AGO

I guess as a long term knowledgeable Ontario Ministry of the Environment employee, one must ignore the corruption and look to one's own needs. In other words in an increasingly difficult job market, no matter one's convictions, one must look at their own responsibilities to family first. Whistleblowing is a notoriously bad career move. It surely does not pay the bills. Been there, done that and paid the price thank you very much.

There are good people in the M.O.E.. I've met them and I've read their work. They are however kept on a short leash. There are technical people including hydrogeologists who research, analyse and write accurate reports. Then most of the time they are given their next assignment. Occasionally they are trotted out to speak publicly to local citizens but only under very careful, non confrontational circumstances. I believe they are probably politically advised by their superiors as to what is absolutely verbotten to speak about.

Here in Elmira the citizens are generally left to the non-existent mercy of consultants paid for by the polluter, Chemtura. Years ago both the Region of Waterloo and the M.O.E. would technically challenge Chemtura's consultants, albeit with silk gloves on. Time, money and persistence have worn down technical challenges to Conestoga Rovers reign of junk science. Recently I have written here in the Advocate about the ridiculous series of reports written by CRA, in regards to probable DNAPL (dense non-aqueous phase liquid) found behind Varnicolor Chemical near the Howard St. water tower. This Thursday evening the Ontario M.O.E. for the second time, have promised to present a report on their findings, conclusions and comments. The likelihood that they will find fault with CRA or even acknowledge their pathetic written attempts to deny the obvious are between slim and none. They are so confident in their upcoming report that they have not sent it out in advance for the Chemtura Public Advisory Committee (CPAC) to read and study. In fact they haven't even had the courtesy to respond to Dr.Dan Holte's (CPAC Chair) request to receive the report in advance of the meeting. Thus once again it will be trial by ambush. Money talks and bullshit walks. The M.O.E. are the latter.

MY PRAYER

The Lord is my shepherd; I shall not want pollution.

He maketh me to lie down in contaminated pastures: he leadeth me beside the toxic
waters.

He storeth Dioxins in my soul: he leadeth me in the paths of hydrogeology for his
name's sake.

Yea, though I walk through the valley of the Canagagigue, I will fear no evil, for
thou art with me; thy rod and thy staff they comfort me.

Thou preparest a table before me at CPAC in the presence of mine enemies: thou
anointest my head with knowledge; my cup runneth over.

Surely goodness and mercy shall follow me all the days of my life: and I will dwell in
Woolwich Township forever.

CHEMTURA OPEN HOUSE

Yesterday's Elmira Independent covered last Saturday's events and festivities at Chemtura in Elmira. The article was titled "Chemtura opens doors to community". Both from the newspaper as well as talking to persons who attended it was as I expected a well organized and friendly event. The author of the article probably however has not endeared himself to Chemtura with his opening sentence namely "Chemtura is a company that has not had the most positive history with the town of Elmira.". Similarily his second last sentence read "Chemtura's open house allowed the community to catch a glimpse into an otherwise closed off and secretive facility.". Damn I like this guy!

Chemtura appear to have unlimited funds for consultants, lawyers and public relations firms (Sussex). Some day when they mature they might consider spending their money more wisely; say on source removal of DNAPLS, LNAPLS and Dioxins.

CHEMTURA ARE PREACHING TO THE CONVERTED

Ahhhh! So sad! According to yesterday's Elmira Independent Editorial "An uphill battle" it seems as if "most of the visitors were family members of staff at the chemical company...". Apparently the invited public to Chemtura's "Fall Day" last Saturday were less willing to forgive and forget. This is a good thing. One can forgive transgressions against oneself or the community when there is sincere repentance and an attempt to make things right. Neither has happened at Chemtura.

As Gail Martin says in her Editorial almost everything being done to clean up the mess Chemtura and their predecessors made has been mandated by the province; plus it's not working. Furthermore their ongoing fugitive releases of air emissions and their fires are never ending. Add to this their refusal to properly remove all the Dioxins and DDT in their south-east corner as well as managing to delay it for yet another year (2013) that which they promised to do (even inadequately) and you get the picture. The community "Fall Day" and further public relations efforts are just that : PR. They are trying to regain their certification under *Responsible Care with the industry association (CIAC). They are an irresponsible company hiding behind well paid consultants and the impotence of the Ontario Ministry of the Environment.

SEPTEMBER CHEMTURA PROGRESS REPORT

This report was received last week and as usual has lots of nonsense and plain rubbish in it. That being said there is more or less good news as well as the off-site pumping rates are generally much improved. In fact with the exception of well W5A which was down for three weeks for maintenance, I would suggest that all the other off-site wells' pumping rates were excellent. Finally !

Page 8 informs us that "...the operation of well E7 and off-Site well W3 generated a capture zone that contained the limits of the NDMA plume in the Bedrock.". This is very strange as not only are neither of these wells screened in the Bedrock Aquifer but both of them according to CRA's Schematic Conceptual Hydrogeologic Model have the Lower Aquitard (LAT) between them and the Bedrock Aquifer. I would suspect an honest mistake here except for CRA's proven talents at turning mud into gold.

Free phase LNAPL (light non aqueous phase liquid) was measured at .4 and .34 metres in thickness at two on-site wells. Chemtura are world leaders at observation and monitoring while doing nothing.

Appendix B advises us that the vast majority of MISA (municipal/industrial strategy for abatement) outlets to the Canagagigue Creek have "No Trend Identified". This means that the discharges of various chemicals continues to the Creek unabated although Chemtura are monitoring the situation closely. How sweet of them.

Table C.2 deals with surface water testing in the creek and we currently are down to only three chemicals in the creek whose mean concentrations are higher immediately downstream of Chemtura than upstream. These chemicals are ubiquitous to the Chemtura site and groundwater and are NDMA, NMOR and Toluene. CRA please continue telling CPAC and the public that your chemicals are no longer found in the "Gig" as it's always worth a giggle and a chuckle.

Last but not least we have Figure D.3 which shows us how much difference there is between the elevation of the creek and the immediate groundwater elevation. This purportedly is to give us confidence that the site is hydraulically contained in the south-west Upper Aquifer. Three of the six observation wells have groundwater elevations between .4 and .9 metre below the surface water in the Canagagigue. That is good. Unfortunately the other three observation wells have elevations below the surface water of between .04 and .16 of a metre. That is ridiculously low and does NOT guarantee hydraulic containment. It is my belief that the M.O.E. are intentionally permitting the Chemtura site to leak contaminants into the natural environment on an ongoing basis. They are a sick joke.

ONE LETTER TO THE EDITOR & ONE ARTICLE

The Letter to the Editor in today's Waterloo Region Record is titled "Good stewards". The article is titled "Trees near gravel pit to come down". Both clarify for me the financial conflict between the here and now and the environment we are leaving our children and grandchildren. The Letter to the Editor gives us a brief discription of the makeup and operation of our municipal sewage treatment plants. As the author points out removal of Estrogen (female hormone) is apparently cost prohibitive. Also the crossovers or "combined sewer systems" whereby rainfall gets included in the water going to our sewage treatment plants is difficult and expensive to fix after the fact. The author while pointing out the challenges and difficulties involved is very positive and supportive of the efforts being made. Fair enough although by not spending more money now we are essentially leaving both known and unknown environmental damage to future generations to live with and or repair.

The article deals with a decision by Cambridge Council to allow a developer to remove trees on the south-west edge of Galt. The trees while being described as scrub, nevertheless were a buffer between an operating gravel pit and a couple of hundred or more Fraserwood area residents' homes. Council split on this decision with the local councillor and three others in favour of not approving the removal of the trees thus jeopardizing the development and construction of twenty-six homes between the gravel pit and the older subdivision.

There are two issues for me. Firstly are we so desperate for land in Canada that we continue to build new homes beside chemical industries (Elmira), sewage treatment plants and gravel pits (Cambridge)? Clearly the answer is no. These locations are proposed by developers who will make money from these locations, end of story. Secondly Council are afraid of the big bad wolf, namely the Ontario Municipal Board. Yes the OMB have a horrid track record. Yes they are strongly biased in favour of developers, gravel pits etc.. Why wouldn't they be? The OMB members are appointed by the province. Developers are an ongoing source of political donations to Conservatives and Liberals alike. These developers don't contribute out of the goodness of their hearts or for esoteric political ideology. They contribute because they expect a significant return on their political investments which they do receive via friendly legislation and friendly appointments to various regional and provincial Boards etc. Meanwhile our locally elected councillors do their constituents no good by rolling over every time they see provincial political opposition. Once again we are for the sake of short term money, diminishing the quality of life of current homeowners. Our municipal councillors are clearly telling them that new anonymous incoming homeowners are more important than the existing ones. And oh yes keeping things smooth with the province and the OMB is also more important.

COURTS ARE RIDICULOUS, EXPERTS ARE ACCOUNTABLE

Today's Waterloo Region Record carrys this story on the bottom of the front page "Court convicts experts for failing to warn citizens of Italian quake". While I have often been appalled at decisions made by Canadian and American courts this decision at least reassures me that human stupidity knows no jurisdictional boundaries. I think to call it patently ridiculous is even an understatement.

Fast forward to Canada. Here we have a situation with much greater predictability. We are not discussing geological phenomena emanating from the bowels of the earth. Here in Elmira we are dealing with sand and gravel aquifers that occupy the top 100 feet of the ground's surface. We have been dealing with releases of toxic chemicals into the earth, their transport via natural groundwater flow and their resultant appearance in the citizens drinking water. After decades of concern, bad tasting water and expert study the citizens of Elmira were constantly reassurred that their water was fine to drink right up to the day that the south wellfield was shut down. That people were being poisoned for years is inescapable. That people have died from cancers caused by carcinogenic chemicals in their drinking water, NDMA being but one, can not be denied.

No one from the Ontario Ministry of the Environment was held responsible. No one from the M.O.E. went to jail. No engineers or hydrogeologists from Uniroyal/Chemtura's consultants were ever charged, convicted or sent to jail. Why not? The current situation and abuse of citizens continues. Hired experts by the polluter are producing junk science. Elmira citizens are at the mercy and integrity of experts being paid for and ordered by Chemtura Canada Inc. We have zero protection from again being exposed to toxic chemicals if and when they allegedly reopen our wells in 2028. Polluters and their Consultants are totally unaccountable to anyone. The M.O.E. aren't even good enough to be called a joke. CPAC, the committee of Woolwich Council are good people without financial resources. They are out muscled, out financed, out gunned and it's always been that way. Our media with the exception of the Elmira Independent have let their readers, the citizens of Elmira and Waterloo Region down. Coverage is practically non existent.

And all of this is exactly the way our politicians like it. They love pretend public consultation. They love pretend accountability. They love Elmira where the majority of citizens won't say "shit" when their mouths are full of it.

ORIENTATION/EDUCATION MEETING TODAY

I am told that today's CPAC Education meeting is a public one (9 am.) and that is why I'm comfortable posting about it ahead of time. While public, I'm not sure if it has been advertised as well as the usual monthly Thursday evening (6 pm.) public meetings. By the way the next regular CPAC meeting is Thursday November 1/12 as usual in the Woolwich Council Chambers. I believe that credit is due to Woolwich Township for being proactive and much more conscientious in ensuring that Woolwich business, even by its' committees is done in the public eye. There have been some notable and regretable situations recently, including the City of London, where municipal business has been done behind closed doors. There alas have been far too many prior years where municipal business via committee has been done privately, on private property. These private meetings while occasionally being "breakfast meetings" at a restaurant, similar to the London situation, have far too often been out of sight. They include, by invitation only, partial CPAC meetings at Conestoga Rovers in Waterloo and at Chemtura in Elmira.

Surprisingly, one would think, the greatest proponent and advocate for private meetings with Chemtura, CRA or even the M.O.E. has been a former long time Woolwich Councillor and Chair of CPAC. Perhaps it's been coincidence but I think not, that one of the main topics at these private meetings has been DNAPLS in, on, under and off the Chemtura site in Elmira. For years there was a DNAPL sub committee of CPAC which met at Conestoga Rovers offices on Colby Drive in Waterloo. While a formal voting member of CPAC (2000-2007) at that time, I was a member of this sub-committee. Considering I was by far the best informed and qualified CPAC member on the subject of DNAPLS at Chemtura, it would have been too obvious to exclude me. Also I had been involved with the "consolidation" of one of Uniroyal's consultants who had quoted a famous hydrogeologist, out of context, regarding a DNAPL issue. For this APT Environment gave me a modest award, autographed by their co-ordinating committee, dated September 1992.

At today's CPAC Orientation/Education meeting I have been asked to give a presentation on DNAPLS. As Yogi Berra once said "It's deja vue, all over again". My presentaion will give a generic overview as to what DNAPLS are and how they behave in the subsurface. It will vary substantially from the information that CPAC members and the public have been receiving from Chemtura/CRA over the last twenty-two years. I will also be exploring five documents related to the discovery of probable DNAPL behind Varnicolor Chemical and beside the Howard St. water tower in Elmira in 1998. I will be attempting to show not only the internal errors and inconsistencies within these five CRA documents but also the overall timing, and overall desperate attempts to deny the issue as well as the truth about it.

M.O.E. OFFERING TO DO SOME WORK AT CHEMTURA

Last Thursday's Elmira Independent informs us with this title "MOE looks at revisiting 1996 sediment study". Based on over twenty years of experience with the M.O.E., the first question I have is why. What's the catch? They are masters of distraction and deflection. They are also masters of political survival. Based on what they've done and not done here in Elmira they should no longer even be a provincial ministry. The fact that they are looking for some input or buy-in from CPAC is even scarier. These guys don't give a rat's butkus for real public input. Something stinks!

Following is a list of higher priority testing the M.O.E. can and should have done decades ago in Elmira. Do it first and then if you want to go back and retest sediment and floodplain soils downstream, fine.

Shallow and intermediate soil around and downgradient of the old Borg Textiles.
Upper Aquifer groundwater around and downgradient of Borg.
Intermediate and deeper soils at the old Varnicolor on Union St.
Upper Aquifer (not Surficial) groundwater at and downgradient of the old Varnicolor.
Shallow and Intermediate soil around Sanyo Canada.
Uper Aquifer groundwater around and downgradient of Sanyo Canada.
Shallow and intermediate soil and groundwater around OW60 - west & off-site of Chemtura

GP1 & 2 on the south-east corner of Chemtura require soil and groundwater testing below the water table. This includes the UA1, UA2, UA3 and MU.
There is an alleged natural swimming pool downgradient of GP1 &2. Confirm it and test it.

Finally based on the M.O.E.'s track record of incompetence and polluter bias they should not take one step without CPAC and public input. Exact locations and depths must be determined first prior to putting the shovel in the ground.

"ROUTINE" WATER SYSTEM MAINTENANCE IN ELMIRA/ST. JACOBS

Yesterday's Elmira Independent carrys this story "Routine system maintenance may affect local drinking water". We are advised that there will be watermain flushing "...to support the above maintenance work." In the Public Notice also in the Independent there is no indication of what the maintenance actually is. In however the above article written by Chuck Kuepfer, mention is made of rehabilitation of the water tank on Howard Ave. in Elmira. Any further maintenance is left to our imaginations. We are also advised that there could be low water pressure and or discoloured water. The Region does not advise drinking discoloured water. Apparently taste and odour are also concerns during this "maintenance" period running from October 15 until December 3, 2012.

This is where the rubber meets the road. Is there any reason to have doubts about the veracity of the Region of Waterloo in water matters? The unequivocal answer is yes. Is this based on long term deception by them and knowledge that the Region suffers from fictitious disorder syndrome? Again the answer is yes. Is it possible that this work on the Howard St. water tower, located exactly and directly beside observation well OW57-32R and off-site pumping well W4 is exactly what it is claimed to be? Absolutely.

It is a bit of a coincidence however that at the present time CPAC are pounding at the M.O.E/Chemtura gates regarding DNAPL found in well OW57-32R in 1998. It is indeed coincidental that Chemtura's consultants are writing absolutely ridiculous and desperate reports (Aug. 29/12 & Sept. 26/12) trying to overturn both their findings and others around this issue and the ramifications for the Elmira cleanup. Coincidences do occur. It's just unfortunate that our various governments can not be trusted to tell us the truth. Really, how do we know when they are being straightforward and when it's just more of the same?

COMMUNITY (PRAT)FALL DAY THIS SATURDAY

Man if those buggers could only sell brass, crass, chutzpah and bullshit they could stop manufacturing chemical products yesterday. The above title refers to a card I received in the mail yesterday; advertising A "COMMUNITY FALL DAY" at Chemtura this Saturday from noon till 3 pm.. "...free food and activities for the whole family". Honest to goodness, based on their track record I surely hope that St. John's Ambulance, firefighters and paramedics are out in full force this Saturday. I say this based on Chemtura's uncanny ability over the last two decades plus, to shoot themselves in the foot at the most (in)appropriate times.

Does anyone forget the fugitve air emissions of BLE-25 late in September 2010; just a few weeks prior to the municipal elections? How about the "pink spill" of Toluene? How about fire after fire? Anyone remember the chlorine cloud they released over Elmira? What's hopefully going to happen is that it being a Saturday with guests arriving, that they are bright enough to shut down their production for the day. Just don't count on it. I and others have toured the facilities before only to be greeted with strong chemical odours that our plant guides literally can't smell anymore. They've been exposed to the odours for so long that they no longer even notice them. Scary!

The bottom line is that Chemtura and fellow travellors (M.O.E. etc.) are hurting. They are taking a shellacking at public CPAC meetings, in the media and privately at the provincial level. Saturday's festivities are a desperate attempt to shore up their support locally, including getting verified under *Responsible Care by CIAC (Chemical Industry Assoc'n of Canada). Heck if they were offerring beer, nose plugs and a respirator they might even convince me to show up.

ELMIRA FAIRY TALES & TECHNICAL MISINFORMATION

Over twenty-three years Elmira citizens have been bombarded with self-serving information by our local polluters and their in-step political leadership. Whether being told by Wally Ruck of Uniroyal that "NDMA is not in our vocabulary" to "There is a solid impermeable clay barrier between our shallow contaminated aquifer and the deeper municipal aquifer."; the horse manure has been pungent, non stop and always entertaining. Today I will try and scrape a little of that manure away.

Chemtura and their consultants for decades have claimed that yes there is residual DNAPL (dense non aqueous phase liquids) on site but not free phase (pools). Residual DNAPL refers to "...disconnected blobs and ganglia of organic liquid, is formed at the end of a migrating DNAPL body." In other words, free phase (pools) DNAPL occurs first and residual follows. The claim that free phase no longer exists on site frankly is a ridiculous and self serving fallacy probably to reduce the demand for on-site cleanup. Afterall it would seem to be a relatively easy chore to go after pools of DNAPL rather than looking for the sparser trails that have followed it. All the technical, theoretical and practical evidence including samples of free phase DNAPL found on both sides of Canagagigue Creek is contrary to the company's position.

Chlorobenzene is a DNAPL chemical. It has a low solubility and is denser than water. It is also less viscous (thick) than water and like all chlorinated solvents is mobile in the subsurface. It sinks via gravity through sands and gravels although it can get delayed upon lower permeability surfaces such as clay and silts. Generally thinner and denser chlorinated solvents will migrate horizantly less than creosotes for examples which while also DNAPLS are generally thicker and less dense. Nevertheless clorinated solvents such as Chlorobenzene and other Chemtura DNAPL solvents have had lateral migration of "...tens to hundreds of metres at many sites." Both the Ministry of the Environment and Chemtura would like Elmira citizens to believe that their DNAPLS whether residual or free phase are all on their site.

For some time I believed that DNAPLS sunk straight down until they hit a clay Aquitard and then would flow in the direction that gravity pulled them. The actual rule of thumb is that "DNAPL must migrate sideways in order to migrate down." Free phase DNAPL has been found behind Varnicolor Chemical near the Elmira water tower on Howard Ave. I was convinced that it had to be from either Varnicolor which had both free phase LNAPL (light non aqueous phase liquid) and DNAPL or even possibly from the old Borg Textiles. Based upon my more recent understanding of subsurface flow, Uniroyal/Chemtura can not be entirely ruled out as the source. Indeed it would partly explain their recent bizarre pair of reports 'explaining" away this discovery by their consultants fourteen years ago.

Free phase DNAPL usually is not found at contaminated sites because of it's tortuous and meandering subsurface pathways. Also as indicated earlier it can pool both on Aquitard surfaces in depressions or in the middle of Aquifers on silt or clay lenses. There are numerous lines of evidence which will indicate both residual and free phase presence and Uniroyal/Chemtura have all of them. Plus it physically has been seen and removed from the subsurface on a number of occasions. Both types of DNAPL (residual & free phase or pools) contribute to long term groundwater contamination which will not be cleaned up by hydraulic containment also known as pump and treat.

The 1% rule refers to the presence of either type of DNAPL at a site if groundwater concentrations exceed 1% of the solublity of a particular chlorinated solvent. However this has been determined not to be 1% of the lab solublity of a solvent mixed into a litre of pure water. It is 1% of the effective solubilty which refers to the fact that the more dissolved contaminants there are in groundwater the lower the solubilities of each one becomes. Whether lab or lower effective solubilities; both Chemtura and Varnicolor Chemical exceed them. These are two truly horrendously polluted sites.

Another concern I have is that while residual DNAPL can not be mobilized by an artificial increase in hydraulic gradients, free phase can be. This may also be a reason for Chemtura's claims of no more free phase DNAPL. Essentially pump and treat technolgy while containing dissolved plumes can further mobilize free phase DNAPL which may have been precariously perched on a lower permeability surface. Relevant to the discovery of DNAPL at OW57-32R near the Elmira water tower in 1998; soil borings can be used to confirm the presence of either residual or free phase DNAPL. This would include discoloured soil, odours and iridescent sheens all of which were found at the time while drilling at the interface between the MU (Municipal Aquifer) and the MAT
(Municipal Aquitard).

Residual DNAPL will never flow into a monitoring or pumping well. Free phase DNAPL can be collected if there is a sump at the bottom of the well however I have never heard Chemtura make refernce to sumps specifically included at the base of wells located in probable DNAPL areas. Partial removal of DNAPL from above the Bedrock is probably the best case scenario. There has been enough testing and psuedo "investigations" done over the years including special DNAPL committees to have pinpointed many particular locations of either residual or free phase DNAPL. By the way when I say "special" DNAPL committees; I truly mean special as in deaf, dumb, blind and oops that could be viewed as politically incorrect. Let me just say that I attended them long enough to recognize how "challenged" they were. Enough said. Partial DNAPL removal, residual and free phase, would not necessarily immediately lower dissolved contaminant concentrations. What it would do however is reduce the time frame of restoration from centuries to decades. Thanks to our impotent and toothless Ontario M.O.E. we've already wasted two decades plus. Our children and grandchildren deserve better than what we are leaving them.

There are dozens and more scholarly DNAPL articles on line. I particularily would recommend "An illustrated handbook of DNAPL transport and fate in the subsurface" written by the United Kingdom Environment Agency in 2003. It is one of the clearest, most comprehensive and easiest to understand for both professionals and lay persons.

DNAPL RESEARCH RELEVANT TO CAMBRIDGE

Removal of or destruction of DNAPL (dense non aqueous phase liquid) in Bedrock is most difficult. The limestone and dolostone Bedrock in Waterloo Region is interspersed with both vertical and horizantal fractures. The issues at both the Middleton wellfield as well as the Bishop St. community are primarily due to the release of chlorinated solvents, which are one particular class of DNAPLS. Unlike creosotes, coal tar and PCB's; chlorinated solvents are generally less viscous meaning they flow more easily and quickly. They are also often denser. These two characteriastics tend to make them flow further deeper and much more quickly. Also their low viscosity helps them move through finer apertures and cracks in both overburden (sand, gravel, clay) as well as in the Bedrock.

Releases of Trichloroethylene and Trichloroethane at Rozell (GE) and Northstar have had horrendous consequences for nearby residents. These DNAPL chemicals have high vapour pressures and change from liquids into vapour in the very shallow unsaturated soil. Residual DNAPL above the water table actually breaks down into a vapour faster than DNAPL below the water table dissolves into groundwater. What I have found difficult to understand is the vapour phase of TCE (trichloroethylene) hundreds of yards downgradient from Bishop St. in the direction of the Grand River. It is my theory that TCE especially has gravity flowed through preferential pathways hundreds of yards from Bishop St. and the most likely preferential pathways would be the gravel bedding that storm sewers draining towards the Grand River are sitting in. This TCE then volatilizes into vapours along the way and migrates up and into basements and other structures.

Meanwhile back at the Middleton wells and their neighbour Canadian General Tower I have found the excuses of their consultants unconvincing. One of these excuses is that TCE is found dissolved in the groundwater at the Middleton wells in higher concentrations than at C.G.T.; therefore they claim that C.G.T. can not be the source. This is nonsense as the dense and very mobile free phase (ie. DNAPL) TCE has flowed downwards long ago and entered the Bedrock and further migrated towards the wellfield. At that point it is probably sitting as a pooled DNAPL in horizantal fractures and slowly dissolving into the groundwater. Meanwhile back at C.G.T. the shallower residual DNAPL has slowly dissolved in the shallow groundwater and discharged into the Grand River. Keep in mind that while contaminant plumes in sand and gravel aquifers are reasonably predictable in their flow direction and concentrations, contaminant flow directions in fractured Bedrock are notoriously difficult to predict. The cracks, fractures and apertures are not predictable.

It is of zero relief or help to affected citizens to know that firstly only DNAPL above the water table is turning into vapours and invading their homes. Similarily it is of zero benefit to know that this DNAPL breaks down faster above the water table than below. I have absolutely no idea how long it takes for these vapours then to naturally exit the shallow overburden although I would guess decades or longer. Additional problems exist with the TCE and TCA (trichloroethane) which enters the Bedrock. The welcoming fractures can be hundreds of metres deep and much wider than required to permit entry of chlorinated solvents including TCE and TCA. In fact TCE is one of the worst chlorinated solvents in Bedrock as it is very dense and very thin and mobile. It is my belief that with or without ISCO (in site chemical oxidation) the TCE will exist in the Bedrock for centuries or longer at both Bishop St. and the Middleton wellfield.

Getting back to ISCO which is being used at the Bishop St. disaster; it is my understanding that these injected chemicals oxidize or break down the TCE and TCA into water and carbon dioxide. In other words they separate the chlorine atoms from the hydrocarbons . Although this is definitely of long term benefit to the groundwater I see little or no benefit whatsoever to the removal or reduction of the vapour phase above the water table. Hence the backyard garden sheds pumping out the vapors from around basements must continue indefinitely. Indefinitely I suspect as stated earlier may be for decades.

This above information while specifically relevant to Cambridge also has some bearing on Elmira. Yes our Bedrock has about 100 feet or more of overburden soils, sands, gravels and clays above it. That being said our polluters are also world class and our Bedrock Aquifer is contaminated although not to the extent that Cambridge is. Here in Elmira although to a lesser extent than Cambridge; we have also managed to dump, spill and bury TCE and TCA. There must be vapour phase contamination in buildings on the Uniroyal/Chemtura site and I also wonder about buildings on and nearby Varnicolor Chemical. Probably tomorrow I will give some further details as to DNAPL behaviour and migration in overburden soils in Elmira versus in Bedrock.

A WATERPISTOL IN A THUNDERSTORM

The above title is as close as I can recall to a quote from Stan Berger a Ministry of the Environment lawyer back in the early 90's. His metaphor was describing in his opinion, the contaminant contribution of Varnicolor Chemical to the Elmira Aquifers. Stan was neither a hydrogeologist nor was he particularily well informed in groundwater matters. That being said, really no one was very well informed in regards to the hydrogeological conditions below Varnicolor Chemical. All we had were hints and glimpses and for most of us this was our introduction to contaminated sites. No wonder the M.O.E. felt that they could misrepresent, deceive and obfuscate and get away with it.

Uniroyal/Chemtura have never come clean to the public. Neither has the Ontario M.O.E.. Twenty plus years ago it was suggested to us that the Bedrock Aquifer was uncomtaminated. Eventually we were told that fast moving NDMA was in it and then finally it was admitted that Ammonia had entered that aquifer. Only 2 1/2 weeks ago a consultant for Conestoga Rovers suggested that chlorobenzene had not been found in the Bedrock Aquifer. I corrected him and gave him the reference from the 2011 Annual Monitoring Report. Just this morning while looking over a nineteen year old report I found numerous other man made chemicals in the Bedrock Aquifer in Elmira. My confidence of ever, much less 2028, cleaning up the Elmira Aquifers is waning.

I believe that the powers to be, in their myriad and possibly illegal private meetings; decided that the Elmira Aquifers were toast. They did this prematurely and without adequate information and or adequate oversight or peer reviews. They most certainly did this out of the public's view and then they colluded to sell a more acceptable story to the public. These premature and immoral decisions may well have permanently sealed the fate of this community ever again being able to drink from our own underground water supply. The reason is this. Some of Uniroyal's and Varnicolor Chemical's DNAPL chemicals were long gone through the overburden aquifers and down to the Bedrock. Others were not and this would include Chlorobenzene commonly found throughout Chemtura and Elmira. These decisions weren't just made by the M.O.E. and Uniroyal; they included our municipal and regional governments.

The M.O.E. have allowed Chemtura and their consultants to lead the public and the public advisory committees on a merry chase. The M.O.E. have colluded and covered up the truth in order to save themselves from their past errors (pre-1989) as well as their decisions since then. The cleanups at both Varnicolor and Uniroyal/Chemtura have been far too little, too late. They had gotten away with them by deceiving the public and the public advisory committees (UPAC/CPAC) for over twenty years.

The Varnicolor site was horrific and the M.O.E. had to be deaf, blind and stupid not to have known this prior to 1989. The Uniroyal site; when one looks at the groundwater concentrations plus the sheer numbers of toxic chemicals, may well be without peer. The numbers of DNAPL chemicals on both sites are shocking and serve to reduce their effective solubility in groundwater. M.O.E./Chemtura DNAPL "studies & investigations" are less than pathetic and have no credibility. They cheerfully misinterpret their own data as well as scientifically accepted principles at will.

There is only one thing left to do. Woolwich Township appear to be well along the road of transparency and honesty. The Region of Waterloo, recently appear to be testing those same waters with their toes. It is time for the Ontario government and the M.O.E. to finally come clean. Tell us the truth. Be honest! You will sleep better and who knows maybe you can usher in a whole new era of government honesty.

VARNICOLOR CHEMICAL UNDER MORE REMEDIATION

The past just continues to haunt those who lie and deceive. The Ontario Ministry of the Environment (M.O.E.) wrote a Control Order to clean up the old Varnicolor site on Union St. in Elmira and it contained the phrase "...a full aereal and vertical investigation...". The M.O.E. did this amidst huge public pressure which even included various media outlets calling for an investigation into M.O.E. corruption at the time. Myself, Rich Clausi and Ted Oldfield were constantly publicly humiliating them. I had an inside senior person at Varnicolor supplying me with information, literally on a daily basis. Whether it was secret M.O.E. raids (May 17/90) on Varnicolor , buried road tankers at the main site hooked up to their floor drain or even 45 gallon buried drums; I knew about it and the M.O.E. denied it publicly, only to be exposed as corrupt liars over and over again.

The M.O.E. never did the vertical investigation. I have since learned enough about DNAPLS (dense non aqueous phase liquids) to know why. Varnicolor contributed to the destruction of Elmira's drinking water aquifers. Their chemicals were in the south wellfield long before it was shut down. Simialrily will we ever know how long carcinogenic NDMA was in the south wellfield before it was first tested for and discovered? Currently the newest owners of Varnicolor are attempting to obtain a Record of Site Condition. It is my belief that the M.O.E. will require slightly more cleanup only prior to so issuing that document. They did a massive excavation twenty years ago albeit a shallow one. They have been pumping and treating the so called surficial aquifer on that site for twenty years. They have been studiously ignoring and praying that the deeper contamination including DNAPLS have moved off site and mingled with Chemtura's (Uniroyal) mess. From what limited evidence is available this seems to have happened. As of yesterday I saw the beginnings of more cleanup including a drilling rig on site. The M.O.E. have been asked by the Chemtura Public Advisory Committee (CPAC)for updates and details on these most recent remediation plans. The M.O.E. however have never felt themselves accountable to the public until or unless they figuratively have a gun held to their heads. Keep in mind CPAC's mandate includes assisting in getting Elmira's Aquifers restored to drinking water standards by 2028. This is difficult when the M.O.E. refuse to provide information about other known polluters sitting atop those very same Elmira Aquifers.

REGION WRITES OFF THE ELMIRA AQUIFERS

First off a week ago I posted here that I didn't know how the Elmira Indepndent could have missed writing about the stunning comments made by Eric Hodgins of the Region of Waterloo. Well it turns out they didn't miss them, they just postponed them until this week. The front page story in yesterday's Elmira Independent is titled "Elmira will need new wells, after groundwater restored".

Once again we see why Eric gets the big bucks at the Region of Waterloo. His technical competence I'm sure is O.K. but mostly he's a team player with a knack of speaking carefully ie. weasel words. Eric did not specifically criticize any company or level of government. He did not specifically say "Of course the Elmira Aquifers are toast forever". Gail Martin quoted Eric as saying that when the aquifers are restored "There would be water available, but we wouldn't put any resources into finding that now, until the remediation is complete." Eric also said that monitoring as well as an environmental assessment would be needed before any new wells could be brought into the Elmira drinking water system. Everything in his statements suggest a hands off policy by the Region towards doing, planning or spending a single red cent until AFTER the Elmira aquifers are restored.

Point one I was not surprised by the knowledge that wells E7 and E9 were sold many years ago to Uniroyal/Crompton. That little tidbit was not kept hidden from the public. What did surprise me was Eric admitting anything whatsoever about the Region and their non plans for the Elmira Aquifers. I believe that under directions from his political masters, he is attempting to shift the public perception that the Region supports the ongpoing M.O.E./Chemtura "cleanup". In other words the Region have seen Woolwich Township supporting CPAC's Resolution versus the status quo and hence the Region wish to distance themselves as well; from the upcoming public relations disaster awaiting the M.O.E/province/Chemtura.

Lastly yours truly has had a Letter To The Editor published. It is titled "Speaking the truth" and applauds both the young CPAC and the young Woolwich Council for their leadership in exposing the current sham of a cleanup. My interpretation, necessary due to Eric's exquisitely and painfully chosen words, is that Woolwich Council and the Region are leaving the mess in Elmira; instituted by the province (M.O.E.), to be cleaned up by the province. Looks good on the remaining parties to this scam.

EMERGENCY EVACUATION DRILL PLANNED FOR CHEMTURA

There will be some unusual activity tomorrow at Chemtura in Elmira and this is just a heads up for neighbours and residents not to be surprised. I will be quoting some e-mails below to clarify.

"We will be conducting our evacuation drill and we'd like to inform our nearby neighbours through the CAN system. The testing will be conducted this Friday October 12th between 10:00 and noon. "

"This is a message from Chief Kieran Kelly on behalf of Chemtura. On Friday, October 12th, Chemtura will be conducting emergency evacuation drills. The drills are scheduled to be conducted between 10:00 am and noon. Near neighbiours may hear emergency alarms and paging coming from the Erb St. plant. Employees will also be evacuated to the plant's parking lot as part of the drill. If you have any concerns please contact Chemtura directly. Thank you."


Totally irrelevant to the above Public Notices & e-mails released for the purposes of not alarming the public unduly; I too would like to alarm the public, although also not unduly.

Over a decade ago when Uniroyal were regularily fumigating the Duke St. residents it was determined that their consultants were using an outdated air modelling system which understated the extent and quantity and effects of their air emissions. Just recently despite long criticisms by myself of their trend analyses being used to allegedly indicate trends in groundwater contaminant concentrations; it has been suggested that the analysis they are using is about thirty years behind more modern and up to date methodologys. The method they use is referred to as the Mann-Kendall test and I've been advised that it is a "non-parametric test" with "reduced ability to detect trends". In other words rather than use the most current statistical methods they are relying on second best.

OUR MEDIA HAVE SEIZED UPON THE GRAND RIVER SEWAGE PROBLEMS

Again today's Waterloo Region Record are carrying an environmental story regarding our heritage river, the Grand. The story is titled "More barely treated sewage getting in Grand". Isn't that just yummy. Makes me want to go swimming right now (NOT).

"In 2011, the amount (sewage) more than tripled from 2010; was a whopping 38 times more than in 2009; and was more than four times the amount discharged in 2008.". These comparisons are of the amounts of partially treated human sewage being discharged into the Grand River from Waterloo Region Sewage Treatment Plants. By the way Ken (Seiling), calling them Wastewater Treatment Plants doesn't make the stink any less.

The Region claim that heavy rains are the cause for bypasses allowing untreated or partly treated sewage into the river. I find that very strange as storm water from street manholes and paved over cities is supposed to be kept strictly in storm sewers for discharge to creeks and rivers; not to sewage treatment plants. Here in Elmira we've been working hard for years making sure any crossovers in sewers are eliminated including roof drains or sump pumps being sent to storm sewers versus sanitary sewers.

The bottom line is that all our municipalities have been flogging development of all kinds whether residential, commercial or industrial. I've got news for you folks. Our politicians have long given lip service to sustainable development only. We have too many people, cars and industries for our environment to handle. This is the cost of economic growth, namely environmental degradation. It is not and never has been sustainable and that's here in Canada. God help the rest of the world. Pretty clearly my initial enthusuasm was premature regarding multi million dollar sewage enhancements as we see once again that our politicians are playing catch up with these upgrades.

WE CONTINUE TO DESTROY OUR ENVIRONMENT INCLUDING THE GRAND RIVER

The timing is quite superb. Back on September 3/12 I wrote here about multi million dollar upgrades to the Kitchener Sewage Treatment Plant and then again I posted an article dealing with upgrades to the Waterloo Treatment Plant on September 17/12. In those postings/articles while praising the political decision to spend taxpayers money to help our environment and Grand River; I also asked the obvious question. Are we being proactive here or merely reacting to degradation that's already happened? Well as an environmental colleague recently reminded me; politicians are highly reactive. If it isn't broken yet or in crisis they have hundreds of pet projects that are much more alluring and sexy than sewage treatment. Sure enough today's Waterloo Region Record tells the tale namely "Researchers blame fish mutations on local sewage".

These mutations are being blamed on estrogens in pharmaceuticals that are not removed from waste water by our sewage treatment plants. Interestingly as I've mentoned here before our regional annual drinking water reports also do not report on the presence of pharmaceuticals and many other chemicals. There are literally thousands of chemicals which may find their way into either the Grand River or groundwater which are either not tested for, or not reported on to the public. Many of these will indeed be removed from water via treatment but if we the public don't see more comprehensive listings of chemicals tested for, then how can we have confidence in our water?

PUBLIC GARBAGE MEETING IN ELMIRA ON OCT. 23/12

Saturday's Waterloo Region Record carys this story "Where will our garbage go?". Essentially the Region of Waterloo wish to hear from the public in regards to waste disposal after the local Erb St. Landfill is full, allegedly in another twenty years. It seems to me that back in the 70's this Landfill only had a life expectancy of 20 -25 years. Some of the time stretching has been due to waste diversion/recycling and some has been due to simple physical expansion of the perimeter of the Landfill. Regardless its' location was never a particularily good one simply due to the proximity to the St.Agatha aquifer. This was realized of course after leachate unsurprisingly was found to be leaving the site. Since that time there have been engineering attempts to collect the leachate but it would have been superior to design the landfill properly in the first place.

There are a series of public meetings planned with the closest one being at the Lions Hall in Elmira on Tuesday October 23/12. It is certainly fair to say that the Region of Waterloo have made huge strides in their handling and reduction of garbage needing disposal/burying. That being said I truly wonder if these public sessions are really for the purposes stated. Maybe as much as anything they are to educate the public that garbage is an issue and that we all are part of the solution. I expect to attend the one in Elmira and hope to see some innovative plans for future waste disposal including of course enhanced Reduce, Reuse, Recycle.

PUBLIC DECEPTION 101

Conestoga Rovers & Associates declared in their June 1998 Uniroyal Progress Report Appendix D (pg. D-2) that they had observed material which "...may indicate the presence of a dense non aqueous phase liquid (DNAPL) in the vicinity of OW57-32R.". They also went on to explain the reasoning and circumstances which led them to this statement. Their reasoning, logic and U.S. EPA criterion presented were all consistent with the hard data and facts which they had.

This smoking gun, game changing discovery was buried. It was not presented to UPAC or CPAC as it should have been. This behaviour by CRA, Chemtura and probably the M.O.E. has occurred before. I do not know how many times before because I most probably haven't caught them every time. I caught them red handed in 2004, again buried in a monthly Progress Report, abandoning their alleged hydraulic high at well CH44 (Nutrite) which they had shamelessly used literally for years to pretend Municipal Upper hydraulic containment on the Uniroyal site. My former friend and colleague Susan Bryant dubbed this revelation the "phantom mound".

This smoking gun, off Uniroyal site DNAPL discovery was unearthed by me ELEVEN years later. Yes I am embarassed that I missed it the first time around and my only excuse was that I was embroiled in a financial life and death battle with Uniroyal's "partners in education", the Waterloo Region District School Board. The legal and court battles lasted seven years from 1996 -2003. I made this discovery by rereading old Uniroyal/Chemtura documents in the summer of 2009. I made presentations and delegations to the old CPAC to no avail. They blatantly refused to ask any questions or make any comments. They stood united with the two partners in pollution, the Ontario Ministry of the Environment and Chemtura. I was allegedly speaking publicly yet I was being stonewalled by Chemtura, the M.O.E. and the old CPAC.

Finally August 29, 2012 Chemtura's consultants CRA, responded for the first time. The M.O.E. have also promised to respond, but lacking CRA/Chemtura's confidence, cockiness and thick skin have to date failed to do so. CRA have used the "oopsy" defence. Some unknown, invisible, shadowy phantom "inadvertently" spilled a petroleum/oil product into the drilling mud up at the surface. As bad as that nonsense is they've compounded their pathetic excuse by the use of junk science and misinterpretation of data. They have also brought in a side issue in an attempt to defend their nonsense. A detection of petroleum hydrocarbons by Peritus Environmental, consultants to the new owners of Varnicolor Chemical, was initially confirmed by Conestoga Rovers, only to be denied by Jeff Merriman of Chemtura when I raised the issue at CPAC. CRA have followed up with a Memorandum dated September, 26/12 and it's as big of a stinker as their May/June 1998 Progress Reports and their August 29/12 Memorandum. The August Memorandum incorrectly and inaccurately states "Furthermore, the lack of TPH (total petroleum hydrocarbons) detections in groundwater samples collected from monitoring wells in the vicinity of OW57-32R suggest TPH is not widespread in groundwater." CRA appear to be bolstering their "inadvertent" oil spill excuse by stating that the TPH had to come from the surface versus from the groundwater/soil 100 feet below ground. CRA's followup September 26/12 Memorandum puts the lie to that. Their September Memorandum actually confirms the presence of petroleum hydrocarbons including some of the exact ones detected in the drilling mud fourteen years ago. It is my opinion that CRA are finished here in Elmira. Please pack your bags and look for greener pastures. You have no credibility with me and other honest, informed citizens.

PSUEDO SCIENCE, JUNK SCIENCE And CRAP

CRAP is an acronym that I have coined which stands for Conestoga Rovers & Associates Plan. It is not intended to be a compliment particularily. The title above refers to CRA's September 26, 2012 Memorandun dealing with CH-70D groundwater results. As promised in last Wednesday's Advocate I have enlisted the assistance and opinions of two experts, both of whom are in their final year as PHD students. One is finishing his PHD in Chemistry, the other in Biology. Both have extensive experience working with gas chromatographs and mass spectrometers.

Both are critical of CRA's Report. This includes comments such as they wouldn't dare to submit a report like this (of this quality) to their superviser. Secondly they have indicated that the text of the Report misinterprets the data presented. Thirdly there is essential data available that CRA have simply failed to provide to the readers. This data is absolutely necessary for CRA to make their case.

I am advised that in fact the data that CRA have provided actually proves the opposite of their conclusions. According to the two published scientific experts CRA's evidence indicates clearly that despite their text, there are petroleum hydrocarbons found in the groundwater samples taken at CH-70D, exactly as Peritus Environmental AND CRA originally stated. Thank you Conestoga Rovers.

WIND FARMS ARE HERE!

There is a Notice of Public Meeting in today's Woolwich Observer. Conestogo Wind Power Partnership (CWPP) will be holding this meeting at the St. Clements Community Centre and Arena on Wednesday November 7, 2012 from 6-8 pm.. This public Information Centre is being held to present the proposed power line routing and the location of the project substation within the Township of Wellesley. The map included in this public notice is typical of newspaper maps and is nearly illegible. My guess is that the actual turbines are being located south of Hwy #86 and the town of Listowel and possibly just a tad east of Listowel. Again the map is lousy.

Further details of the Project Description Report are provided at the Township of Wellesley municipal office starting today as well as at the public libraries of Listowel, Atwood and Monkton. Numerous authorities have finally admitted that there is a lack of peer reviewed science regarding human health issues associated with nearby wind turbines. The most recent criticism has come from the Environmental Commissioner of Ontario in regards to deaths and injuries to migrating birds and bats. I expect however that under the REA (Renewable Energy Act) that this project like all the other wind farms will proceed undeterred by the lack of knowledge of human health risks posed to nearby neighbours.

TWO MAJOR POINTS UNDERPLAYED

This week's Elmira Independent carrys the following story "CPAC updated on groundwater cleanup". The two major points that were understated are "While the majority of wells are showing no trend...". This is a huge matter. Off-site wells are supposed to be cleaned up to drinking water standards by 2028. After fourteen years of pumping and treating, the majority of wells are not showing decreasing chemical concentration trends according to Chemtura's consultants Conestoga Rovers. What exactly does anybody need to spell FAILURE?

Secondly Alan Deal of CRA was quoted as saying "...we do need to pump more". Good Lord, do you think? Sebastian Siebel-Achenbach pointed out that extraction wells W3 and W4 have rarely met their targeted pumping rates allegedly required to clean up the Elmira Aquifers.

Finally we have the major issue of Eric Hodgins of the Region of Waterloo. He unequivocally made it clear that the Region of Waterloo have zero expectations for any future use of the Elmira Aquifers for drinking water purposes. This bombshell and 100% turnaround by the Region was not mentioned in the Independent's story. This I do not understand.

A DOSE OF COMMON SENSE FROM THE ENVIRONMENTAL COMMISSIONER

Well done Gord Miller, Environmental Commissioner of Ontario. Today's Waterloo Region Record carrys this story: "Ban wind power along migration routes, environmental watchdog says". Mr. Miller has released his Annual report and while overall still a supporter of wind power he believes that the province have not been doing their due diligence in regards to negative effects upon wildlife. Specifically he suggests that migratory bird routes as well as bat migration routes are not being given proper consideration. Quoting Mr. Miller "The province's efforts to increase the use of wind power must be balanced against the equally valid goals of protecting Ontario's wildlife and natural environment".

Naturally opponents of windpower due to it's probable/possible negative effects upon human beings are very pleased with the environmental commissioner's stance. Clearly our provincial politicians have leapt into renewable energy, which is a good thing in and of itself, with both eyes and ears firmly closed to problems associated with it. To my mind this is what democracy and minority governments are all about. We the public are receiving both the pros and cons and both must be acknowledged and planned for by our authorities.

PUTTING IT IN PERSPECTIVE

The most important documents dealing with the DNAPL found in May 1998 behind Varnicolor Chemical (& across the street from Borg) are the May and June 1998 Uniroyal Progress Reports as well as CRA's August 29/12, 6 page report. The side issue concerning whether or not petroleum hydrocarbons were found at CH-70D this past spring and summer is exactly that: a side issue. The timing certainly was interesting as it first appeared that both Peritus Environmental as well as Conestoga Rovers had detected petroleum hydrocarbons at this nearby well (on varnicolor's west property line). This of course would undermine CRA's claim that as there were petroleum hydrocarbons found in the drilling mud but allegedly not in nearby wells (groundwater); therefore the petroleum hydrocarbons may have been introduced "inadvertently" at the surface.

I have already commented on CRA's September 26/12, 7 page report suggesting that both Peritus and CRA erred initially in identifying petroleum hydrocarbons. I find that document self serving and logically inconsistent. For example you can't be taken seriously when you say "There are no "fuel type" hydrocarbons in this sample (fig. 4)" and at the same time have identified benzene, toluene, ethyl benzene and xylenes in that same figure. Furthermore you can't state that "GC/MS analysis confirm that chlorobenzene is present in the CH-70D samples and the only compound eluting in the CCME F1 hydrocarbon range." when your own figure clearly shows ethylbenzene eluting (coming off) in the same F1 range as chlorobenzene.

Essentially the message that I am receiving from CRA after the fact is the same one a former CPAC colleague used to advise: "Adjusting the science according to your needs.". That being said I have always had an open mind and am continuing to pursue professional technical chemical advice. That would be of course unbiased and honest technical advice. Both GC FID (flame ionization detector) and GC/MS are well known and well respected analytical methods within the industry. I will be sharing here the professional comments in regards to either the likelihood or even possibility of not once but twice, chlorobenzene being misidentified as petroleum hydrocarbons. Keep in mind whichever way this goes; petroleum hydrocarbons being detected or not at well CH-70D fourteen years after the discovery of DNAPL at OW57-32R, is not the defining issue. If CRA's September 29/12 report is sketchy that would however add weight to the evidence against their position on DNAPL.

THE REGION OF WATERLOO HAVE ABANDONED THE SINKING SHIP

Last Friday here in the Advocate I wrote about a senior Region of Waterloo manager who stunned the room with his comments concerning the Elmira Aquifers. This took place at the monthly CPAC meeting and was in response to e-mails that had been going back and forth from Ron Campbell of CPAC (& SWAT) in regards to information he'd received from the GRCA. The Grand River Conservation Authority made it clear that the two Elmira wellfields (north & south) absolutely were not being included in the Source Protection Plans that are mandated by the province. We at CPAC had already begun to smell a rat when yours truly pointed out that both a former known polluting business (Voisin's) and a truck repair with fuel depot were located next door and a hundred yards away respectively from the south wellfield.

Eric Hodgins of the Region of Waterloo has always been very careful with his choice of words. Some including me might even refer to his choice of wording as weasel words. Eric knows where his bread is buttered and he said absolutely everything necessary to loudly and clearly get the message across that the Elmira Aquifers will not be supplying drinking water to the Region of Waterloo now or in the future. He did not condemn the ongoing "cleanup". He did not specifically say "2028 is bullshit". He did not say that the Ontario Ministry of the Environment, Chemtura and their consultants are first class liars. He didn't have to based on everything else he did say. One of our CPAC colleagues has since referred to this public statement by a senior regional spokesperson as a "gamechanger".

This is a huge turnaround by the Region. For twenty years plus they have fully endorsed the collusion and coverup between political bodies at the municipal, regional and provincial level. They have vigorously supported the lie that the Elmira Aquifers were "resting". They have stood behind former Woolwich Councils, the M.O.E., Chemtura and their consultants. After they received their water pipeline from Waterloo to Elmira they only offerred token and occasional mild criticism of the aquifer "cleanup" plans. The Region of Waterloo finally ceased attending years ago, any of the public CPAC meetings. Eric Hodgins attended a private Woolwich Council meeting with yours truly present, three years ago. As my friend and colleague Henry remarked, Eric was there in his role as "designated denier". Indeed Eric vehemently denied any possibilty of other sources of serious groundwater contamination within Elmira.

My interpretation is that the Region see that Woolwich Township through their adoption of CPAC's Resolution condemning the "cleanup" and denying the 2028 deadline have opted out of the two decades plus coverup. The Region have decided that they no longer think that the public deception is viable. The Region have decided that their best chance of survival rests with leaving the sinking ship of lies sooner than later. Two down one to go. The Township and now the Region have jumped ship. They are telling the province (M.O.E.) that they are on their own in defending Chemtura and the non cleanup of the Elmira aquifers.

CONSULTANTS CAN AND DO DECEIVE

I'm told there is some sort of ethical considerations involved whereby engineering consultants are supposed to have a duty in relation to the public interest. I have from time to time over the last twenty-two years been surprised by information and data that was released to the public that clearly was not in the interests of the consultant's client. At the same time I have been absolutely appalled at misinformation, deceptive practices and incredibly self serving interpretations of data etc..

The latest examples are in regards to the fourteen year old discovery of DNAPL at OW57-32R. It took me three years of publicly requesting comments from both the Ontario M.O.E. and Chemtura to get an acknowledgement from Chemtura and their consultants CRA (Conestoga Rovers) that yes in 1998 they discovered something unusual enough while drilling OW57-32R that they "investigated" it and wrote up their findings in the May & June 1998 Uniroyal Progress Reports. As of this date, despite recent promises from the Ontario Ministry of the Environment, we have virtually NOTHING. This possible/probable DNAPL is relevant to the entire cleanup of the Elmira Aquifers promised for 2028, yet to date the M.O.E. have not graced us with an opinion, comment or even an acknowledgement that they were aware of this issue.

Naturally enough the long suffering public view this cowardice in a negative light. Naturally enough this behaviour only adds fuel to the fires feeding upon "sweetheart" deals, "phantom mounds", bogus DNAPL "investigations", and bait and switch deals whereby a public November 4/91 Control Order is waved about as the cleanup bible only to learn twenty-one years later that a never released to the public, October 7/91 "sweetheart" deal supercedes it.

The CRA/Chemtura story in their August 29, 2012 six page Memorandum is an embarassment. Similarily their June 1998 Progress Report Appendix D is a whitewash. It is literally riddled with the most amateurish errors possible. It is extremely poorly organized and the various samples are misidentified repeatedly. It was either written by a Grade 7 science student (on a bad day) or it was intentionally written poorly to make it difficult to follow. With virtually zero evidence CRA claim "The source of TPH (total petroleum hydrocarbons) in the drilling mud could be lubricant or some other petroleum-based product used on the drilling rig and inadvertently introduced into the drilling mud.". This "...could be...inadvertently introduced...." is not science it is wishful thinking. Calling this "investigation" both in 1998 and in 2012 Mickey Mouse, is an insult to a wonderful cartoon character.

CRA/Chemtura have followed this up with some incredible stick handling around the recent discoveries of petroleum hydrocarbons in nearby well CH-70D. To bolster their claims of inadvertent introduction of petroleum based product to the drilling mud at the surface versus from where they first claimed it came from (30 metres down at the base of the Municipal aquifer) they have suggested that they went looking unsucessfully for petroleum hydrocarbons in nearby wells. This is nonsense heaped upon nonsense. The Elmira Aquifers have been inundated with petroleum hydrocarbons from multiple sources. This includes Uniroyal/Chemtura, Varnicolor Chemical and numerous gas stations around town which the public over the last few years have been witness to their excavations and cleanups. Furthermore petroleum hydrocarbons have been introduced to the Elmira Aquifers in a dizzing array. Not just the lighter petroleum hydrocarbons associated with gasoline (C6-C16) but also the heavier extractables associated with hydraulic oils and crankcase oils have been dumped or leaked. BTEX (benzene, toluene, ethylbenzene, xylenes) which are SOME OF the lighter components have been dumped and spilled in vast amounts but along with them have been other lighter gasoline compounds (C6-C10 non-BTEX). Varnicolor Chemical were known to spray gasoline compounds on their gravel yard as a dust suppressant. Their former Chief Chemist, Burt Nalliah, so testifed in a legal Affidavit.

Finally we have plume maps of chlorobenzene in both the Municipal Upper and Municipal Lower aquifers both on and off the Uniroyal/Chemtura site. I made some of these available to the young CPAC a long time ago. These would be an example in my opinion of CRA providing data that does not back up their client's and the M.O.E.'s position as mentioned in the very first paragraph. These plume maps from the late 90's and early 2000's make a compelling case for a second major source of chlorobenzene to the Elmira Aquifers despite Chemtura/M.O.E./Region denials. This second source would be DNAPL in the vicinity of OW57-32R as well as the strategically placed nearby pumping well W4. This Chlorobenzene is likely from either the former Borg Textiles or from Varnicolor. If it is from Varnicolor then we have a full blown scandal and coverup of epic proportions as allegedly Chlorobenzene was never found on the Varnicolor site twenty years ago. Is it any wonder that the M.O.E. are taking their time on this? Fourteen years and adding and they have said NOTHING to the public. Could there be some early retirements in the offing? IF there was intentional misrepresentation and or fudging of reported data could M.O.E. officials be held accountable legally? Stay tuned folks!