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!