Saturday, August 31, 2013


Yesterday's Waterloo Region Record carrys a disgusting picture which clearly shows what mankind is doing to the largest freshwater lakes in the world. The article is titled "U.S., Canada urged to reduce harmful algae blooms in Lake Erie". The picture shows an aerial view of part of Lake Erie's shoreline. It is a huge mass of swirling green off the shore and it is truly disgusting. Lake Erie is the receiving body for all of waterloo region's wastes whether agricultural (phosphorus), industrial, residential or sewage. In 2011 the algae bloom spread more than 160 kilometres from Toledo, Ohio to Cleveland. Fish kills are becoming more common in the western basin on both sides (U.S./Canada) of the lake.

As serious as this is, we are missing the point. Algae blooms can kill but they are visible. P.C.B.s, dioxins, pesticides and solvents also kill but they are invisible. Persistent organic pollutants (POPS) move up the food chain and bioaccumulate in fish and other species. All of these chemicals legally (most of the time) leave Waterloo Region streams and tributaries and move into the Grand River where they eventually discharge into Lake Erie. We certainly aren't the only culprits but at the same time we contribute our share to the degradation of Lake Erie and the planet. All the surface water testing in the world showing chemicals below PWQG (provincial water quality guidelines) is so much accumulated bullshit. Tiny but ongoing amounts in the parts per billion and trillion are very deceptive. They are moving downstream 24/7 and they do add up. They are killing wildlife and they are killing us. Look at the end result. Look at Lake Erie. Look at cancer wards in your local hospitals. We are spending trillions of dollars on end of the line health care. Money only to a certain extent can beat cancer. We will continue to spend trillions as long as we continue to pollute the air we breathe, the food we eat and the water we drink. And our politicians at all levels will continue their mindless mantra of growth, growth and more growth. Our environment and planet are dying.

Friday, August 30, 2013


Many CPAC meetings of late have figuratively left the wounded guilty parties in a dazed state by the end of the meeting. Last night was a little less painful than usual for the Ontario Ministry of the Environment and their partners in pollution, Chemtura. That being said truth as always was a victim however all CPAC members plus this SWAT team member worked hard to defend the truth against vested interests.

Even Councillor Mark Bauman seemed a little keener than usual to ask questions that could possibly reflect badly on Chemtura/M.O.E.. I used an overhead projector to show the chlorobenzene plumes in the Municipal Lower Aquifer beneath the former Varnicolor Chemical area. This plume has dramatically changed it's shape over the last fifteen years as pumping from W5A has drawn chlorobenzene eastward towards both CH70D as well as W5A. The purpose of my plume maps was to show that this area as well as the two further north west of Chemtura require special attention.

There was again considerable discussion surrounding Chemtura's imminent plans to slightly dig and mostly cap GP1 & 2 on their south-east corner. Ron, Vivienne and Mark all asked questions on this matter suggesting that more testing should have been done deeper and then the final decisions made. I suggested that the pumping well downstream of GP1 & 2 namely off-site well W5A had not been routinely tested for DDT or Dioxins. Jeff Merriman of Chemtura confirmed this.

George Karlos (M.O.E.) somehow convinced CPAC that they should give him the go ahead regarding downstream testing prior to all the current lab results being shared. In fact there will be a presentation at the next CPAC meeting in September first and then the results handed out from this spring's "confirmatory" testing. Also the soil results from the nearby farmer's swimming pond will be shared AFTER the presentation. This is a mistake but I guess you have to be burned over a period of years as I have been with promises of data that either show up late or never. Examples would be groundwater readings on both the former Varnicolor Chemical site on Union St. as well as on the old Lot 91 at the east end of Oriole Parkway.

There was also discussion on multiple sources of petroleum hydrocarbons in the Elmira Aquifers. Ron Campbell and other CPAC members were concerned about the focus on only three Chemtura chemicals namely NDMA, Chlorobenzene and Ammonia courtesy of both Chemtura and Yara (Nutrite). This discussion as well as later on when we learned that Chemtura bring in "flammable petroleum hydrocarbons" by railcar certainly had Jeff Merriman squirming. He has in the past had the gall to suggest that petroleum hydrocarbons are a non issue to Elmira's groundwater and to Chemtura.

Apparently the pilot tests of In Situ Chemical Oxidation are being reconsidered due to anomolies discovered in the two areas west of Chemtura. Well OW60 near Park and Queen St. has long held high NDMA readings. New wells were drilled in the backyard of this residence and the NDMA readings are extremely low while only being 15 yards away. Jeff agreed with me that this is very weird. Also the Municipal Lower Aquifer at CH44 on the Yara property now appears to be much smaller than originally thought based on recent new drilling. Obviously I would like to see all this data for myself as there could be some self serving psuedo science interpretations going on (or not- who knows?).

Getting back to the "flammable petroleum hydrocarbons " being transported by rail Dwight Este was asked by me for the common name of the PHC's. He refused to say which seems a tad unecessarily secretive. Hmm.

Last but not least I received a promise from George Karlos that Jaimie Connolly, M.O.E. hydrogeologist, would get me some literature references dealing with acetone allegedly solubolizing chlorobenzene. Currently my opinion is that this is junk science at best but if Jaimie comes through we will indeed see. This is of course relevant to the chlorobenzene DNAPL found just west of the old Varnicolor about 100' below ground. The next public CPAC meeting is on September 26, 2013.

Thursday, August 29, 2013


Earlier this week, CPAC & SWAT were informed of Chemtura's timetable in regards to their half assed cleanup of Dioxins and DDT in their south-east corner. Two former gravel pits (GP1 & GP2) were the overflow area for the east side pits decades ago. Steve Quigley of Conestoga Rovers (CRA) claimed at the last CPAC meeting in June that Dioxins are not liquids and hence couldn't flow. This is typical mealymouthed nonsense. The Dioxins and DDT were mixed in with LIQUID solvents as well as rainwater and indeed did flow as liquids from the uphill former east side ponds down to their south-east corner where they slowly soaked into the ground. From there they were spread far and wide to be shared with the Downriver Grand River watershed.

Jaimie Connolly M.O.E. hydrogeologist also shared some doozies with CPAC at the June meeting. When answering my question about free phase DNAPL possibly being a reason for unaccounted mass of chlorobenzene in the aquifers and aquitards he stated that oh no any DNAPL would have immediately dissolved into the groundwater. This was at the top of page 8 in the Minutes of the meeting and Dense Non-Aqueous Phase Liquids by definition do NOT readily dissolve in groundwater. Jaimie also inexplicably stated that (pg. 8) he knew of no issue with chlorobenzene in the Municipal Lower (ML) Aquifer beneath and near the old Varnicolor Chemical on Union St. That was a bizarre answer because only two pages earlier in the Minutes (pg. 6) both in the middle of the page and near the bottom Jaimie explains that there is a modelling issue due to high chlorobenzene in the ML aquifer.

There will probably be discussion around the M.O.E.'s downstream testing for Dioxins and DDT. At the moment it appears that at least two sets of data have not been handed out to CPAC/SWAT. This data concerns a swimming pond and soil tests done by it as well as further downstream testing to clarify the increased DDT results found in one of the 2012 sample locations. Strangely the M.O.E. seem to be awaiting some sort of go ahead from CPAC before doing more testing. This is weird on many levels. A year ago plus they refused to share their workplan with CPAC ahead of time. Their partial and limited data to date was presented pretty well verbally but very badly in writing. Quite frankly I found their written report confusing and downright deceptive in it's wording. These wording issues have been somewhat verbally sorted out but the written report is still very badly written. Yes the verbal clarifications helped but it's the written report that is the history. It needs fixing. As far as some kind of blessing from CPAC before the M.O.E. proceeds, that is just plain nuts under all the circumstances.

Wednesday, August 28, 2013


Yesterday's Waterloo Region record carrys this story "Agreement reached on Budd site plan". Basically this is a planning/legal story in which the City of Kitchener has come to an agreement with the new owners (Gary Ball etc.) to avoid a court battle and or an OMB hearing. Of interest to me once again is the following single sentence "Ball demolished older buildings and was cleaning up minor contamination.". Minor contamination. Really says who? Gary Ball? What is interesting is my post here in the Advocate almost exactly three years ago dated August 27, 2010. Apparently at that time the contamination was also allegedly no big deal. This is passing strange when you think of the decades Budd was on site, combined with their massive volumes of steel used in building car frames. Also when you look at the size of the site one has to wonder. There would have been huge use of paints, acids and solvents. Methinks the public may be getting a snow job here. If so eventually the residential neighbours, perhaps years down the road will find out the hard way. Why is it the tax paying public are always the last to find out? Believe me it's not an accident.

Tuesday, August 27, 2013


To date Chemtura/CRA are only publicly recognizing two of the historically high contamination, off-site areas. The two they are acknowledging are the north-west high NDMA contamination around well OW60 near Park St. and the other is the Yara (Nutrite) site on their western property boundary. It has high chlorobenzene in the Municipal Lower (ML) Aquifer. The two that they are doing their best to publicly ignore are the chlorobenzene contaminated ML aquifer beneath the old Varnicolor Chemical site on Union St. as well as the high NDMA readings near Industrial Dr. and Oriole Parkway beside the Sanyo property (CH38).

Keep in mind that in the case of most contaminated sites the highest dissolved concentrations start in the source areas on site and as the various plumes move farther from the site, the concentrations decrease. This is the norm. In the case of Elmira however despite the sweetheart deal concluded between the M.O.E. and Uniroyal on October 7, 1991 which saved Uniroyal millions of dollars in cleanup costs and which assigned all blame to Uniroyal for the destruction of the Elmira Aquifers; it just wasn't so. Nutrite had a hand as did Varnicolor Chemical, numerous gas stations and most probably two other sources. The M.O.E. certainly didn't want their incompetence with multiple polluters public knowledge hence they hid and lied about the truth. It was in Uniroyal's self-interest to do the same. Now twenty-five years later it's getting harder to keep up the facade as one informed citizen who reads and understands all the technical reports is slowly putting all the pieces together.

The two unacknowledged to date other source areas have had much higher than appropriate chlorobenzene and or NDMA concentrations for over two decades. Pumping wells W4 and W3 were located beside them in order to quickly reduce their concentrations and slowly decrease their contaminant mass. They have been but partially sucessful to date. Chemtura's newest "cleanup" plans involving tripling their off-site pumping rates as well as using in situ chemical oxidation will assist with the two acknowledged other areas. Until Chemtura/CRA acknowledge the two more southern source areas and address them appropriately; then their latest cleanup plan is doomed to failure.

Monday, August 26, 2013


The Chemtura Public Advisory Committee meets this Thursday at 6 pm. in Woolwich Council Chambers on Church St. Elmira, Ontario. The last meeting was on June 27, the evening before I had my hip replaced. On the Agenda will be a couple of presentations/discussions from the SWAT team and CPAC members. There is possibly also a presentation from the Ministry of the Environment in regards to their downstream sampling in the Canagagigue Creek. Apparently they did additional testing last November after their initial results showed issues with rising DDT levels. There were also additional samples taken around a nearby farm pond that is used for swimming purposes. Obviously either DDT or Dioxins (the toxic component of Agent Orange) would be horrific in a swimming pond. As of right now I haven't seen any of this more recent data (including last November) which is par for the course. It's one thing for the M.O.E. to hide behiind experts just like Chemtura, but not producing the data until the meeting is just plain ignorant. What a great way to avoid informed criticism.

Chemtura will be making themselves available for questions in regards to their monthly (July) Progress Report. They hopefully will also feel the sting of my Delegation near the start of the meeting. Chemtura and their behaviour have an awful lot to answer for including their years belated attempt to improve their cleanup of the Elmira Aquifers. I expect there will be also a pretty significant clarification as to the lack of support by Woolwich Township of both CPAC and of the cleanup. To say that local polluters in every municipality in Waterloo Region (and the rest of the country) have always enjoyed municipal council support is a huge understatement. Expectations were lifted with our new municipal council nearly three years ago but things have slowly drifted back to the status quo. Does anyone really think it takes from 1989 until 2028 (39 years) to restore an aquifer to drinking water standards? Even that date is considered unlikely by CPAC, the M.O.E. and the Region of Waterloo. The non cleanup can only be accomplished with the hidden support of the polluter at all levels of government over many decades. Heaven forbid that we embarass or antagonize such a powerful player within our community.

Saturday, August 24, 2013


First off let me be perfectly clear about the title. Henry is a friend and colleague and I am very, very lucky to be able to call him both. Therefore when I refer to him as a "character"; in my mind I'm saying that he is strong, intelliegent, blunt, hardnosed and painfully, circuitously honest to a fault. When Henry decides that someone is desperately in need of "correction" than he is just the fellow to administer the medicine. Two days ago I posted here about my sarcastic e-mail to Dave Brenneman, Chief Administrative Officer of Woolwich Township. I took David to task for his discourtesy and disrespect in not responding in a reasonable and timely manner ( 1 year & counting) to a request dealing with Elmira's groundwater contamination. David did respond with an apology albeit with a complaint about my first request for an update four months after the initial request.

Henry's 2 1/2 page response to David Brenneman is classic Henry. He flatters, he cajoles and he then performs a public chastising of the guilty individual. In no uncertain terms Henry makes it clear that pompous individuals in positions of authority have no monopoly on ethics or professionalism. Henry makes it abundantly clear that Elmira has been inundated with "suits" bearing professional designations that belie their inherent fraudulent intentions. He makes it clear that from municipal to provincial politicians, Elmira residents have been misled and deceived. These politicians have jumped onto the corporate bandwagon and have run interference for Chemtura and fellow travellors for years. Henry takes serious rounds out of the likes of Councillor Mark Bauman, Chemtura and the Ontario Ministry of the Environment.

As is typical however Henry holds out the olive branch at the end. Does Mr. Brenneman and Woolwich Council want to get on board with myself as well as the current CPAC and be ultimately known as doing the right thing? He feels there is still time for them to get at least an honourable mention if the desperately needed mid-course correction in the cleanup actually happens. Henry you are a genius and a friend and I thank you.

Friday, August 23, 2013


Yesterday's Elmira Independent (not on-line yet) has the following story "Biogas plant to begin operation in January". Essentially Gail Martin's story chronicles the hurdles that the Bio-Gas plant has faced to date as well as upcoming operational challenges. Frey Contractors are doing the construction and this is the third biogas plant that they have built.

There are extensive odour control systems in place although for the neighbours obviously the proof will be in the pudding when it's up and running. The community liason committee has met several times and I've been able to attend two of those meetings as a member of the public. I missed the meeting in July as it was shortly after I'd had my hip replaced and wasn't mobile yet.

There will be a public meeting on Tuesday September 10/13 in the Dodie Hummel Room (next to council chambers) at 7 pm.. This is an opportunity for all to get more first hand information on this soon to be in Elmira biogas plant.

Thursday, August 22, 2013


For twenty-four years I've been spending my time and quite frankly my money in the service of the environment and the citizens of Woolwich Township. I have also been involved in researching and studying numerous other contaminated sites throughout Waterloo Region. I have always stayed scrupulously to the truth and to facts that I could back up. For my troubles I have been threatened by our regional chair, publicly badmouthed twice by Woolwich Councillor Mark Bauman and kicked off of CPAC by the council of the day in 2008 and 2011. The Ontario M.O.E. routinely lie and attempt to undermine my credibility in their support of Chemtura Canada here in Elmira. So here is how I survive the disrespect, obfuscating, deception and outright lies of various "authority" figures. Every now and then I hit back hard. Following is an e-mail I sent this morning to David Brenneman CAO of Woolwich Township. David is on the receiving end of both his sins as well as those of Woolwich Council. This e-mail was sent to CPAC, SWAT, three council members and the Editors of our two local papers. While Chemtura have come right out and admitted they don't respond to data and concerns I've presented publicly because I'm not a CPAC member; I really do not see me tolerating Woolwich staff and council's similar behaviour much longer. Woolwich senior staff and council are complete hypocrites. They preach Codes of Conduct, respect and courtesy but their behaviour is the exact opposite. Councillors Bauman, Herteis and Mayor Cowan routinely treat Woolwich citizens with disrespect and discourtesy. That is the background for this morning's upcoming e-mail.

Dave Brenneman: I am still waiting, waiting, waiting,waiting,waiting. I know you're a busy fellow but don't you think a response to a request from a taxpaying citizen should be achievable in under a year? Last summer (2012) I e-mailed you a string of reports by name, date and author which referenced an investigation undertaken by Woolwich Township to discover the source of chlorobenzene flowing in the Howard St. storm drain in the mid 1980's. This location was directly between Borg Textiles on the south side of Howard Ave. and Varnicolor Chemical on the north side. The significance of all data referring to chlorobenzene use, handling and mishandling is of great importance to the restoration of the Elmira Aquifers to drinking water standards. I did have the temerity after only a few short months namely last November or December to ask you for an update on this matter. You were not particularily pleased with my request hence I decided to give you more time on the matter. Eight or nine months later and I have yet to receive an update, call, e-mail, acknowledgement etc.. Heck maybe you just plain forgot. Could you find time in your busy schedule to perhaps give me a response oh lets say by Labour Day (this year) ?

Sincerely impressed
Alan Marshall P.S. please make that response in writing. If you've lost or misplaced the data I sent you which literally took me many, many hours to unearth and discover, that is no problem. My time and effort is of little consequence compared to that of yours. Therefore as I have always done at my time and expense I will continue to work for free as in volunteer work on behalf of the citizens of Woolwich. This has been a pleasure for me due to the appreciation I've received from staff and most especially Woolwich Council over the years. All sarcasm aside I have been treated with courtesy and respect by the current CPAC members (less Mark B.) and hence I also hold them in great respect and esteem.

Wednesday, August 21, 2013


I received the July 2013 Chemtura Progress Report in the mail yesterday. There are a few surprises and a few more "adjusting the science according to your needs" moments. Off-site wells W5A & W5B have been problematic for CRA/ Chemtura since they started pumping in 1999. Almost immediately on-site containment went into the crapper as the minimal on-site pumping was undermined by the much greater off-site pumping dragging contaminants off-site. Oh by the way before I forget, my apologies to Chemtura Waterbury, Conn. USA. You guys are visiting my site most days between Monday and Friday and today you were on checking things out at 8:35 am.. Usually I have my new post up by then but as you can see I'm running late today. Sorry!

Anyhow the "adjusting your science according to your needs" is in relation to the relationship between off-site pumping well W4 (behind/west of Varnicolor Chemical) and wells W5A/B. W5B in the Municipal Upper Aquifer (MU) has had high but generally slowly decreasing Chlorobenzene concentrations for many years. Both W5A/B are located just off-site south-west of Chemtura and due south of Sulco. W5A in the Municipal Lower Aquifer (ML) on the other hand has had very low Chlorobenzene concentrations in the past and they have been consistently rising.

At one time in the Monthly Progress Reports, CRA claimed that a well between W4 and W5A/B (CH70) was experiencing rising concentrations of Chlorobenzene in the ML due to chlorobenzene being dragged from W4 towards W5A/B due to their pumping action. This made very little sense to me and when I questioned CRA about it at public CPAC meetings they claimed that despite the much lesser pumping rates at W5, it was overpowering the influence of W4. Well that response has recently changed as CRA are now telling the M.O.E. that in fact CH70D is experiencing increases in chlorobenzene due to migration from the north-east. This allegedly would be from the Yara site. How exactly these increasing concentrations of dissolved chlorobenzene are due to either pumping from the west (W4) or the east (W5A/B) is a mystery. Keep in mind there are dissolved concentrations of chlorobenzene in the ML on the Yara (Nutrite) site but to date the plume is not connected as far south as CH70D which is on the old Varnicolor property line.

Further "adjustments" include reducing the pumping rates at W5A/B because of the dragging action of chlorobenzene from W4 being replaced by oh we don't want to drag contaminants off the Chemtura site by pumping too much at W5A/B. This stickhandling could either be based on bad intent or on ignorance. Either one is a possibility.

Long story short this month's on-site pumping is within a whisker of meeting their target rates but off-site pumping is not. Be happy and don't worry however as CRA assure us that they have dramatically reduced their pumping rate at W4 on purpose. It used to be 11.4 litres per second but now it is 3.5 litres per second. They managed only 3.0 litres per second at W4 during July. Again don't worry this was because they've "reconfigured" well W4 to only pump from the ML instead of both the MU and ML. Therefore while CRA/Chemtura are talking about tripling their off-site pumping as part of their plan to achieve drinking water by 2028; in fact they've just reduced it. Only in Alice in Wonderland you say. P.S. There was little or no discussion/announcement ahead of time to CPAC or the public about this major change.

Tuesday, August 20, 2013


Politics is basically a form of sheltered workshop. They set their own hours, duties, schedules and stress levels. Similar to civil servants the longer they are in that environment the more they believe that that is reality and everything else is the anomoly. We all think that teachers get great money, summers off, lomg breaks at Christmas, March break, all statutory holidays and so much more but politicians make them look like pikers.

The worst of it is the mindset. Eventually even politicians who went in thinking about public service lose their way. Yesterday morning I saw it in action. We were discussing the lack of railway transparency through Waterloo Region and longtime Councillor Mark Bauman had all his arguments marshalled. One of the best was well there's a risk everywhere. It's not just in Waterloo residential areas, it's everywhere. I mentioned anhydrous ammonia being lethal and his response was well lots of farmers use it so it's on the roads everyday. My thought would be are they dumb enough to be driving with it through residential areas between one and five am. as the railroads are?

There was a greater clarification given in regards to the diamond shaped placards on the sides of rail cars. Allegedly those placards identify not only classes of toxins but in some cases specific names. We were told by Councillor Bauman that all you have to do is go on line and you can find the codes for the various chemicals. Really? If that's true then clearly the arguments about keeping things a big secret are specious as any so called "terrorists" under the age of fity will have figured that out by now. In other words the bad guys already know. The issue is the families and children living within the vicinity of rail traffic carrying toxic materials.

When the smoke clears, just like everything else it all boils down to money. If the public (ie. unwashed masses) find out the risks that they have been exposed to without their consent; they will demand greater safeguards. Those cost money for the rail companies and they expect protection from their bought and paid for politicians against the legitimate interests of the public. Once more into the breech Mark Bauman as you stand up for the rights of big business and corporations.

Monday, August 19, 2013


Last Saturday's Waterloo Region Record had the following story "Nestle, Ontario water deal under review". As is the norm our governments are not there to protect us the residents from corporations but in fact the exact reverse. Our Ministry of the Environment routinely runs interference between corporate thieves/polluters and citizens. The M.O.E. issue PTTW ie. permits to take water to various industries. Over in Guelph Nestle have been expanding their bottling operation and hence water removal for some time now. The M.O.E. had been looking for a clause that would limit their water extraction during times of drought. One would think that to be emminently reasonable which it is. Corporations however are not reasonable they are greedy. Even a semi-voluntary reduction would mean less profit. Hence we have a battle brewing which is going back to the ERT (Environmental Review Tribunal).

Saturday, August 17, 2013


I mean really guys. Your neighbours to the south namely Kitchener and Waterloo would like to know what's going through their cities on the way up to Sulco and most especially Chemtura. Instead of helping them, Mayor Cowan publicly states that those companies have already disclosed what is transported by rail. Really? Then why does your fire chief Rick Pedersen turn around and state that he does not receive that information nor has the township asked for it? Who's lying here folks? Oh wait a minute, for a politician being deceptive isn't exactly lying now is it? Chemtura's man, Councillor Mark Bauman
clarifys by stating that trains have industry coded signs advising what's in the railway cars. He states "Every train car and every transport truck is required to have a placard." "There are no secrets. Period." Really? So all the public and or Waterloo and Kitchener councillors need to do is sit by the tracks for the next year or so with the code in their laps and determine railcar by railcar what's being transported. Yeah Mark and Todd, that's really transparent and helpful. Today's Woolwich Observer has the story "Woolwich fine with current state of railway transparency".

Friday, August 16, 2013


Both our local papers have major stories about this rare citizens victory. The Elmira Independent's story is titled "Gravel pit application withdrawn" and the Woolwich Observer's story is titled "Withdrawal of gravel pit application a reason to celebrate". Essentially Capitol Paving have acknowledged that their pit application for beside both Grand River and the West Montrose Covered Bridge is dead and over. This has been an ongoing five year battle for the residents of West Montrose and Bridgekeepers. About a year and a half ago I predicted victory to one of my former neighbours in West Montrose
regarding their proposed pit. I have never had the same confidence with either the now done deal Jigs Hollow Pit nor even the Hunder Pit in Conestogo. Woolwich Council have done their duty to their citizens in regards to West Montrose but not in regards to Jigs Hollow outside Winterbourne. The Hunder Pit OMB hearing starts on September 3/13 and we will see if council sell them down the river or not. There is one big difference and that is the financial resources of the folks fighting the Hunder Pit. It truly is disgraceful in this country but that is the reality. They have raised substantial funds and will be a party at the OMB hearing on their own without the dubious "assistance" of the township. The Jigs Hollow folks had the facts and the truth on their side but council rolled over on them possibly led by the "experience" of Mark Bauman. His mantra is don't spend township money on lawyers. Really? Well I've got news for you Jack; that township ie.taxpayers money couldn't be better spent than on protecting the rights of township citizens.

Bridgekeepers, Tony Dowling and many others have won a huge victory as Gail Martin has indicated in her Independent Editorial titled "A mighty victory". Because of the grossly biased provincial Aggregates Act citizens normally get steamrolled by both councils and the Ontario Municipal Board. Gail is correct when she says that "...sometimes, the little guy can win, if he has science, reason and perseverance on his side.". There is one more component and that is numbers. All of West Montrose were united against the proposed gravel pit in their backyards. We the few citizens in Elmira still fighting Chemtura have perseverance, science and reason on our side. What we haven't had for the last fifteen years plus
is the obvious support of large numbers of Elmira residents. This was accomplished by lies from the Ontario M.O.E. (don't worry be happy, everything's under control) plus citizens had a misplaced confidence in the leadership of a once excellent environmental group (APTE) and sat back and left everything to them. This is not a criticism of APTE members which I once was because even after I and others left APTE, we too still had confidence in their leadership for many years. We were mistaken.

Thursday, August 15, 2013


Today's Elmira Independent carrys this front page story "Marshall denied CPAC bid". Three out of five councillors voted against the recommendation of their own committee of council. CPAC as a committee of council (or not according to Chemtura) were all appointed by council to this citizens volunteer committee. To ignore CPACs first hand experience with me as an active attendee and sub-committee member (SWAT) is quite revealing. Mark Bauman is a longtime council member with a history of pro business/pro development bias. When I say bias let's just say that he knows where the money and power are and it's not with individual citizens. He has been slowly exposing his pro Chemtura bias since he joined CPAC a year ago but will be hardpressed to get much CPAC support from here on, on anything. He was the sole CPAC member who spoke and voted against their nomination of me to CPAC membership. While outvoted four to one at CPAC; undeterred he went to Council fully determined to undermine the clear will of CPAC which he did. At council he had the support of an incredibly uninformed and hopelessly inept Julie-Anne Herteis. Her boneheaded comments at public council meetings are slowly becoming the stuff of legend. The surprise was councillor Bryant and it was either that she's been promised something in return (gravel pit support?) or she isn't the person I've been led to believe.

My thanks to Gail Martin who gave a plug to this Blog by giving its' full web address as well as stating " often holds blistering critiques of Chemtura, the Ministry of the Environment, as well as other organizations...". This is the reality. A CPAC member with their own voice both on CPAC as well as off of CPAC is a little too scary for Chemtura and their fellow travellors including Mark Bauman. Note the criticism of myself for years isn't that my facts are inaccurate or my research and understanding of the technical issues isn't spot on. The criticism is that I'm outspoken, blunt, controversial, abrasive etc.. So sad! Honest respectful debate between two parties of good faith is possible. It is however not possible when one party holds all the financial and political power and abuses that power unmercifully for over two decades. That abuse includes buying your own "experts" and being in bed with the so called regulater, namely the M.O.E.. The willingness of Chemtura/M.O.E. and some local politicians to lie, distort and manipulate knows no bounds. This current CPAC have figured out the political/financial dynamics and are acting as honest brokers to the public. For this; if Mark Bauman or a like minded politician are elected Mayor in October 2014, you can count on their removal and restoration of the old Chemtura friendly CPAC with the likes of Pat, Susan and others.

Wednesday, August 14, 2013


Today's Waterloo Region Record carrys this story "Lac-Megantic highly polluted: study". No kidding eh? Quoting Greenpeace in the article "This is one of the largest spills in Canadian history. It will take considerable effort to clean up.". A professor at Montreal's Ecole Polytechnique stated that "...the weight of the chemicals should have sent them sinking to the bottom of the Chaudiere River, so he's perplexed that they would have been detected in the surface waters in such a high volume.". This last comment is in line with my posting here in the Advocate back on July 29/13. I had suggested that crude oil was a DNAPL (dense non-aqueous phase liquid) and would sink to the bottom of the water body. It's interesting that the Quebec Environment Department are indeed attempting to minimize the perceived damage simply with their choice of words. In this article they refer to "light crude oil". Well why would I suppose they also haven't been captured by polluting industries a long time ago exactly as they have in Ontario?

Tuesday, August 13, 2013


Today's Waterloo Region Record are slowly honing their way into the meat of this issue. The story is "Kitchener asks railways to disclose hazards". Mayor Cowan is quoted as saying that both Kitchener and Waterloo Council need only call either Woolwich Township or perhaps Chemtura directly. Personally I wouldn't put much faith in Chemtura being forthcoming to either Waterloo or Kitchener. That said Mayor Cowan is clearly indicating that Elmira industries (presumably Sulco (CCC) and Chemtura) have been forthcoming with emergency responders in Woolwich Township.

The major point still being missed by everyone is more than which fire departments and which councils are in the know. Far more important are the people who live along those railway tracks carrying hazardous chemicals. They need to know whether or not they and their families are at risk. Reassurances that fire and emergency will know how to respond AFTER an accident is pretty hollow. If I lived anywhere near those train tracks and knew what they carry; neither my children nor future grandchildren would ever be sleeping overnite within spitting range of them. It's one thing if an informed decision to gamble one's life is made but it's an entirely different thing either to gamble someone else's life or not to know the facts upon which you are basing your gamble. These tracks are like Russian roulette and at some point the game will be lost with fatal consequences.

Monday, August 12, 2013


Last Saturday's Waterloo Region Record carried this story "Railway under pressure to reveal chemicals carried through area". Clearly the disaster in lac Magantic and near disaster in Calgary during their floods has raised concerns locally and across the country. In terms of sheer volumes and varietys of toxic cargoes, the irony is that the economic and manufacturing downturn has reduced the risk somewhat. However as long as companies are using solvents for cleaning metals and as long as printing companies are using inks and dyes there are safety issues. Then we have the paints and adhesives sector which also handles problematic chemicals.

Of immediate concern appears to be north Waterloo and the Goderich-Exeter railway. You will notice in Saturday's paper that Sulco also known as Canada Colours (CCC) was very forthcoming. They are both a *Responsible Care designated company under the Canadian Industry Association of Canada (CIAC) but more importantly embrace the ethics of *Responsible Care. Their next door neighbour in Elmira, Chemtura do not. Chemtura did receive their *Responsible Care verification at their last outing but it was hugely contentious. In fact the only way they got it after one local rep Dr. Dan Holt, the current Chair of the Chemtura Public Advisory Committee (CPAC), voted no; was by enlisting the aid of a former co-opted CPAC Chair as well as by using out of town representatives (Scarborough & Guelph). This company handles extremely toxic chemicals on an ongoing basis and that includes over the years horribly toxic chemicals such as parathion. Various isocyanates are still in use and years ago their general manager Dr. David Ash answered my question by stating that toluene diisocyanate which they use was more toxic than methylene diisocyanate that killed thousands in Bhopal, India. The good news he claimed was that TDI while more toxic than MDI was less volatile. In other words in case of a release or spill, in theory less would become airborne. Horribly reassuring isn't it?

Chemtura (formerly Uniroyal Chemical) plan their Worst Case Scenario disaster around the release of Anhydrous Ammonia. It is indeed volatile and there is a proposed kill zone around their plant in Elmira if the worst happens. Obviously if Ammonia is shipped in by rail and ruptures along the way you will probably have a similar kill zone in waterloo (or kitchener).

I do not expect either the railroads to cooperate and most positively why would Chemtura cooperate? They've made a game out of misinformation and junk science here in Elmira for twenty-four years in regards to their groundwater contaminants. As no legal or political authorities have confronted them so far why would they now? That will of course happen after the unthinkable but not before.

Saturday, August 10, 2013


This is the question most often asked of me in reference to Chemtura Canada in Elmira, Ontario. Obviously as per my last three postings here, as well as yesterday's front page story in the Woolwich Observer; Woolwich Council's bad judgement in denying my nomination to CPAC is the current hot button item. Personally I don't expect it to last even with next Thursday's upcoming possible Elmira Independent story on the same subject.

On Monday August 19/13 CPAC will determine their priorities and what will go on the Agenda for the Thursday August 29/13 6 pm. public CPAC meeting. The list quite frankly is endless due to the company's intransigence combined with their ongoing protection from the Ontario M.O.E.. Therefore major issues go on and on without resolution as far as the citizens are concerned. This is exactly how Chemtura & the M.O.E. like it. Examples of these unresolved issues certainly includes DNAPLS both on-site and off-site (OW57-32R behind Varnicolor) as well as the state of remediation of other sites sitting above the Elmira Aquifers. These would include Lot 91 at the east end of Oriole Parkway as well as the old Varnicolor site itself on Union St. The fact that CPAC are not automatically given the remediation reports and studies for these sites as well as the old Procast site is ridiculous. CPAC's mandate is the restoration of the Elmira Aquifers by 2028 and these sites and others (Voisin Motors, Beckers) are all relevant to the big picture cleanup. Talk about a public advisory committee being given the mushroom treatment for over twenty years by all levels of authorities.

Other newer items should include the remediation method known as self-sustaining smouldering combustion. Susanna has indicated an interest in presenting this. I am also hoping that I can convince Ron Campbell of CPAC to talk about his extremely interesting thoughts regarding the proposed cleanup of Dioxins and DDT at GP1 & 2 on the Chemtura site. There is lots more but this should keep things interesting. Here by the way is my prediction. Chemtura will only stay in town as long as they can sucessfully bamboozle the majority of the citizens. As realization dawns as to what they've gotten away with for so long here, their presence in Elmira will be less and less appreciated. At that point or at the point of having to spend some real money on a real cleanup; they will run for Bangladesh, Asia, China, Vietnam etc.. This is corporate 101 behaviour and these folks are all about the money.

Friday, August 9, 2013


Ignorance, bias (pro Chemtura) and pettiness were on full display at last Tuesday's meeting in council chambers. The title of Steve Kannon's story is "Council denies bid to return Al Marshall to CPAC". CPAC Chair Dr. Dan Holt had this to say "Alan brings a whole lot to the table in terms of his expertise and his knowledge of the history.". "CPAC endorses and stands behind Al. We were very disappointed with that decision- council did not honour our decision and wishes.". Even mayor Cowan was on board with my being reinstated to CPAC as he stated "We need to respect the wishes of CPAC. I'm going to take their recommendation.".

Yours truly was also quoted in the Observer article as follows "Basically CPAC members have gotten to know me, both in private and in public. They've seen me in action. They've seen me prick the balloon when Chemtura, CRA (Conestoga Rovers) or the ministry (M.O.E.) are misleading CPAC." Finally I was quoted as saying "I feel the process was a win-win for me. I was nominated by CPAC- I am totally pleased and feel vindicated.".

Thursday, August 8, 2013


How often in life are we given a chance to rectify an earlier error? Woolwich Council were given just that opportunity. Indeed it was laid out on a platter for them. Twenty-seven months ago they gut reacted to the crys of the Mayor and Councillor Julie-Ann Herteis about how they'd been done wrong by a nasty CPAC member. They then kicked said member (moi) off of CPAC without five minutes discussion, consultation or full presentation of the facts. They did not even ask any of the other CPAC members present at the meeting in the Councillor's Board Room, the previous night, as to what had occurred. If they had they would have gotten an entirely different picture of the behaviour of both Councillor Herteis and Mayor Cowan.

This time around Council had the advantages of time and opportunity to inform themselves of the facts. They had a written recommendation from their own handpicked CPAC members advising that they CPAC had confidence in yours truly and that I had been a strong supporter of CPAC and an extraordinarily well informed and knowledgeable critic of much of the nonsense that both Chemtura and the Ontario Ministry of the Environment (M.O.E.) are still trying to sell to the public. CPAC Chair Dr. Dan Holt had sent numerous e-mails to Council expressing his wish to be able to speak to them for the purpose of giving them advice, details and specific knowledge as to why all three nominees were excellent choices. Dan and CPAC recognized that Council might be reluctant to revisit their hasty decision of spring 2011 thus he and they did everything possible to make the decision a pragmatic, worthy one, without prejudice to anyone. Council's response to the Chairman of a committee of council was overwhelming silence.

Woolwich Council had a clear opportunity to base their decision on the merits of my CPAC membership. Instead they have once again made it clear that they hold ridiculous grudges for a long time. Councillor Herteis's motives are those of a hurt and spiteful child. Her inability to look beyond her pettiness and see what is in the best interests of Woolwich Township, is truly scary. She is one of only five councillors. Woolwich deserves better than this.

Councillor Bauman's motives are more complicated. In the best case scenario he is a strong advocate of capitolism and free enterprise. Councillor Bauman does carry with him the baggage of being a long time member of Woolwich Council under former Mayor Strauss. This council overall were very best friends with many polluting industries in town including Mayor Strauss's own in Elmira and Heidelburg (contaminated service stations & fuel depot).

Under the worst case scenario Councillor Bauman is Chemtura's man both on CPAC and on Council. He was the only CPAC member who voted against my CPAC membership. He did this via the scoundrel's refuge, namely in camera discussions. I was fortunate to have been a fly on the wall during those discussions. Both Chemtura and the Ontario M.O.E. have lobbied in the past to keep me off of CPAC. That is shameful but more shameful has been their success. Who has been carrying their message to Woolwich Council pray tell?

Mayor Cowan played Tuesday night's meeting with aplomb and relish. He 180 degrees reversed himself from as recently as this spring. Here in the Advocate on April 30, May 2 amd May 22/13 I posted comments regarding the Mayor and Woolwich Council's behaviour and or meddling in CPAC business. Mayor Cowan two evenings ago publicly stated that he supported my nomination to CPAC. He publicly stated that he supported CPAC's knowledgeable and honest nomination of myself. If this was sincere then credit should go to him for his reversal in attitude and his removal of disgusting conditions he wished to impose earlier upon my membership. On the other hand if mayor Cowan already knew the outcome of the vote and if he was posturing for the benefit of CPAC Chair Dr. Dan Holt, then shame on him. Perhaps he was even possibly posturing for me hoping that my postings here would reflect badly on Councillor Bauman and leave him unscathed.

Woolwich Council could have shown stature and professional leadership on this matter. They could have accepted the serious and sincere recommendation from their own committee of council. Instead for pettiness combined with a desire to please one of the worst polluters in Canada they dropped the ball. Although little Elmira are long past the 60's when Uniroyal employees dominated Elmira Council, perhaps their influence is still strong albeit more subtle.

I would like to publicly thank the Chemtura Public Advisory Committee for their support. I would like to especially thank Chair Dr. Dan Holt as well as CPAC member Vivienne Delaney who commented on yesterday's Advocate posting. Further thanks goes to the Cambridge Advocate who picked up yesterday's Elmira Advocate posting titled "Woolwich Council publicly expose themselves". Finally prior to reading either the Woolwich Observer or the Elmira Independent this week I would like to thank them both for their ongoing coverage of council meetings and their overall reporting.

Wednesday, August 7, 2013


Certainly our local newspapers have long ago taken the measure of our local council. The Woolwich Observer in particular have been far less than subtle in their disdain and contempt for Mayor Cowan. Last night's behaviour and decision making at council really has removed all doubt for those of us who had thought that perhaps this council had gelled and matured.

Council held an in camera meeting to discuss three nominees for CPAC membership. Susanna Meteer, Graham Chevreau and yours truly Al Marshall were nominated to full CPAC membership last May 30/13. Susanna and Graham are virtual unknowns to Council with the exception of councillor Bauman who attends CPAC public meetings. CPAC Chair Dan Holt e-mailed the councillors numerous times asking if he could advise them as to the characters and facts behind CPAC's choices. He wanted them properly informed and knowledgeable prior to their decision. They did not respond.

Here are the facts:

1) CPAC nominated me. They believe I am an asset to them.

2) CPAC are the informed body in regards to Chemtura, the Ministry of the Environment and groundwater contamination in
Elmira. Council members do not attend public CPAC meetings with the exception of councillor Bauman who has been there
half as long as the rest of the CPAC members.

3) Over the past 2 1/2 years I have proven myself both publicly and privately to the CPAC members. They respect my
knowledge and just as importantly my honesty. When I take a position contrary to Chemtura, Conestoga Rovers or the
M.O.E. and there is a dispute; I will do the digging and produce the newspaper article, research study or other data to
prove my position.

4) CPAC & SWAT were out last night to support my nomination (& Susanna & Graham). Viv was a little late while Sebastian,
Dr. Dan and Rich Clausi were present.

5) CPAC members were all handpicked by council in the spring of 2011. They include 2 PHDs and one professional in the
field. All members reside in Elmira with the exception of councillor Bauman. CPAC members attend public meetings and all
have proven themselves as capable, reliable and intelligent.

CPAC's informed and knowledgeable position was overuled last night by council's bad judgement. I won't speak to council's motives right now but I will say that their decision is not in the best interests of Woolwich Township. CPAC were entrusted to do the work in the trenches including research and discovery of possible new technologies to clean up the soil and groundwater contamination. Why would a poorly informed council go against the fully informed and honest wishes of their knowledgeable committee?

Yours truly is despised by the professional manipulaters who attend public CPAC meetings. With able assistance from all
of CPAC and recent exceptional performances by Ron and Susanna, I have been slowly dissecting their positions and so
called informed opinions. Chemtura and fellow travellors do not want me as a formal CPAC member because it will only add
to my stature and credibility in the community. Woolwich Council aided and abetted Chemtura last night. In so doing they
have exposed themselves to the further scrutiny of the media, the public and to CPAC members themselves. Council will not
look good in this light.

Tuesday, August 6, 2013


Jaimie Connolly's (Ontario M.O.E.) October 31, 2012 report is riddled with errors and unproven assumptions. Jaimie states in his fourth paragraph that "I had concluded that off-site detections of the compound 2-MBT likely occurred because acetone (which was used on site) acted as a cosolvent, facilitating it's off-site movement at high concentrations.". Firstly I dispute any such conclusion and would need to see when and where Jaimie allegedly made this conclusion. One of the reasons I am skeptical is because CRA went to the trouble of actually doing a study to determine if there was a relationship between extremely high groundwater concentrations of 2-MBT and either acetone or chlorobenzene as cosolvents. This whole issue of cosolvents had been originally raised by Dr. Henry Regier and certainly the groundwater concentrations on the Yara site of 2-MBT were extraordinary. There were concentrations of 1,364% and 4,250% of 2-MBT's stated lab solubilities.

CRA concluded after comparing the 2-MBT concentrations with current acetone and or chlorobenzene that there was not a relationship or causal effect with either of those two solvents. Jaimie then by an incredible leap states that there was, but worse yet twists the study into somehow stating that acetone was a cosolvent for chlorobenzene. Jaimie may be stating that that is his opinion but I'm stating that if you're going to leap blindly off a scientific cliff you should have at least some research or study to back you up. Jaimie does not.

The other issue is this. Acetone was considered as a cosolvent in the case of extraordinary groundwater concentrations of an almost insoluble compound namely 2-MBT. Jaimie now wishes to further compare apples to oranges by suggesting that acetone is a cosolvent to chlorobenzene. Please! Chlorobenzene is already readily soluble in water without any help from acetone or anything else. It's lab solubility is approximately 440,000 parts per billion. The groundwater concentrations while high behind (west) Varnicolor were absolutely nowhere near the ridiculous solubility concentrations of MBT. In fact chlorobenzene was barely at 1% of it's solubility in groundwater. This percentage is in the range of possible nearby presence of DNAPL and combined with evidence found by CRA, strongly indicated the presence of DNAPL and was indeed initially so suggested by CRA. For Jaimie then to categorically state "...the overall evidence is not indicative of DNAPL ocurrence..." is ridiculous. 1% groundwater concentrations combined with a sheen on the groundwater 100 feet below the surface, stained soil samples from 100 feet down, odours and finally CRA's and Chemtura's hiding from this issue literally for years tells the tale.

Add to all that both Conestoga Rovers (CRA) excuse riddled (oopsy we spilled something) August 29/12 memo added to Jaimie and the M.O.E.'s excuse riddled memo of October 31/12 and on the balance of probabilities there is DNAPL present and acetone is a pathetic red herring.

Monday, August 5, 2013


At a public CPAC meeting last fall I requested some information from Woolwich Township in regards to an investigation that occurred in the mid 1980's. The investigation involved ongoing discharges of orange coloured liquids in the Howard Street storm drains between Varnicolor Chemical and Borg Textiles. These discharges could be seen just east of Union St. as the drains were exposed on their way to the Canagagigue Creek. Testing of these liquids determined that at least some of them were comprised of chlorobenzene. This information I had found in a number of reports and I sent all the titles, dates, page numbers etc. to Woolwich Township who would already have had this info as they were the ones in charge of the investigation in the mid 80's. I posted about this issue and my request to Woolwich Township back on January 12, 2013 here in the Elmira Advocate. To date I have not received the courtesy of an update or response of any kind.

Why is this significant now you ask? Firstly CPAC's mandate is the restoration of the Elmira Aquifers to drinking water standards by 2028. The Elmira Aquifers cover several square miles and geographically encompass dozens of industries and service stations sitting above them. The list of known polluters is extensive including Varnicolor, Yara (Nutrite), Chemtura (Uniroyal) plus service stations such as the former Beckers, Voisin Motors and Gord's service station. The list of lesser known polluters is also extensive and includes the former Strauss Fuels, cleanup done in front of Martin's Pet Foods, Lot 91 at the east end of Oriole Parkway and more.

Last October 31/12 Jaimie Connolly of the Ontario Ministry of the Environment wrote a report in support of Conestoga Rovers & Assoc. pathetic denials of the presence of DNAPLS behind (west) the old Varnicolor site on Union St.. The CRA report was dated August 29, 2012. Jaimie's report in support of a hopelessly unscientific and unsound document was itself filled with errors, falsehoods and factually fictitious nonsense. I have posted details on these reports here in the Advocate on Novemebr 12, 13 /12 as well as on January 24/13.

Near the end of Jaimie's second page, Jaimie makes the following incorrect statement: "However I do note that there is no evidence that either the Borg or Varnicolor sites are source properties for chlorobenzene contamination.". This flies in the face of the discoveries and investigations done in the 80's which found chlorobenzene in surface water storm drains running between those two properties. Of significance is that Chemtura's extensive off-site chlorobenzene contamination is in the deeper Municipal Aquifers. On the Chemtura site of course it's in all their aquifers. As all groundwater contamination starts at the surface and slowly percolates downwards one can see the significance of surface chlorobenzene contamination between Borg and Varnicolor.

The significantly and historically elevated chlorobenzene concentrations plus physical discovery of DNAPL behind (west) Varnicolor at well OW57-32R are of great significance to both the attempted cleanup methodology as well as to the credibility of the M.O.E./Chemtura/CRA. For this reason their closing ranks and hiding behind erroneous psuedo science can not be allowed to stand. There is one final thought as to why those three parties are in full denial mode. If the free phase DNAPL and chlorobenzene didn't come from nearby Borg/Varnicolor then the really scary thought is that just like the massive contamination of Benzothiazole and MBT (& more) beneath Yara (Nutrite) that most likely gravity flowed from Chemtura westwards; then free phase DNAPL may well have flowed all the way from Chemtura, on the surface of one of the westward sloping Aquitards to just west of the Varnicolor site (ie. OW57-32R area). This also would destroy one of the planks (excuses) of the M.O.E. as to allegedly why they can't order Chemtura to do on-site source removal. The M.O.E. keep backing Chemtura's nonsense that everything is contained on site. That is unadulterated bull as nothing has been fully hydraulically contained permanently in any aquifer and DNAPLS gravity flow without regard to hydraulic (pump & treat) containment anyways.

Friday, August 2, 2013


Today's Woolwich Observer (dated tomorrow Aug. 3/13) has an excellent article spanning two full pages (6 & 7) titled "Making cover" with a sub-title of "Boosting Woolwich's tree cover, because just like us, the places we live benefit from more leafy greens". Trees for Woolwich was launched in 2011 and the Chair is Inge Rinne. Their mandate is 23,000 new trees to be planted by 2016. As challenging as that goal was it is becoming increasingly obvious as to the sheer necessity of increasing Woolwich's tree cover. Woolwich just like Kitchener, Waterloo and Cambridge are bracing for the invasion of the emerald ash borer. Ash trees throughout the Region are not likely to survive other than a very few which receive very expensive innoculations.

The Township of Woolwich are also very involved with new trees as they are a requirement in all new subdivisions. The township takes over ownership of them after two years during which the developers have been responsible for them. The township also asks homeowners to water trees occasionally, especially during dry spells. So far this summer we have been fortunate with more rain than usual during July. This article tells us all the myriad environmental advantages of trees including cleaning the air, providing shade and cooling and helping absorb heavy rains.

Thursday, August 1, 2013


The following Statement of Principles has not been formally uncovered as yet but eventually it will be. These Principles are based upon over twenty years of observing their public interactions.

1) Principles are for lesser mortals. We are pragmatists. Everything is negotiable.

2) Stakeholders exist in name only. The reality is that there is Uniroyal/Chemtura and there is the M.O.E.

3) Between the two of us we can control everything. The public, the media, local councils, CPAC are merely noise.

4) Private meetings between us will be the norm while vehemently denying same.

5) Public meetings are at best for show and at worst dog and pony shows to be tolerated.

6) Public documents such as Control Orders, Certificates of Approval etc. are primarily for show. The real agreements will
be bilateral and confidential.

7) When required and with prior notice we will support each others positions no matter how ridiculous and unsound.

8) Prearranged and privately negotiated falsehoods will be maintained in perpetuity until both parties agree to abandon
the. This especially includes DNAPL denial, Dioxin immobility and hydraulic containment efficacy.

9) Science is merely a tool in our arsenal. When necessary it will be abused unmercifully if it furthers our mutual goals.

10) These goals include supporting each others credibility and reputation. As informed parties know, we have lost both
decades ago; therefore we must be adamant and dogmatic on this issue.

11) Undermining opposition and sewing seeds of conflict amongst them is always advantageous.

12) The public are always to be praised publicly and ignored the rest of the time.

13) These Principles do not exist, have never existed and are to be denied at all times.

14) If despite 13) their existence surfaces please refer to 7) and 10).

15) God Bless government and corporations equally. We rule the world!