THE INVISIBLE VICTIMS OF DIOXIN IN ONTARIO

The following is one of the 4,000 records provided to the Fact-Finding Panel on Herbicide 2,4,5-T. It is on-line and can be accessed by googling "Welcome to Ontario 2,4,5-T Records Online".



March 24, 1980

Dear Sir:

I am writing to you because of my concern over the decision of the Ontario Government to lift the ban on spraying underbrush in the cottage areas with 245T or dioxin. The Ontario Hydro is apparently preparing to spray in the Chandos Lake area near Apsley.

My father bought property on Chandos Lake in 1924 and we have used the cottage on this land ever since. In 1949 I spent two months in the summer there with our two young children in order to escape the heat of a tiny city Apartment. The Ontario Hydro had cut through our maple sugar bush just 40 feet behind the cottage without any permission a few years previously. During this summer of 1949 the raspberry bushes came up in profusion on the hydro cut in many areas. We picked and ate raspberries for several weeks and even froze some. I learned later that the hydro had sprayed the hydro cut with 245T that Spring or previous Fall. Many people were furious as they noticed the drop in bird population. I had become pregnant in August that Summer and in October had a miscarriage. I knew not why. I had had two previous full term pregnancies and produced two very healthy babies. I became pregnant several months later and at eight months a badly deformed baby was stillborn. It was not until a few years later when I heard on a C.B.C. Farm Broadcast that the spraying of 245T was banned from highly populated areas because of birth defects that I realized why I had had this traumatic experience. Neither my husband nor I have ever smoked or drank and I had never taken drugs or anti-nausea pills of any kind during any of my pregnancies. We were living in Windsor, Ont. at the time and a stillborn death there would not be linked with the Chandos Lake area.

I went through six years of hell until my third child was born strong and healthy, but I was still fearful of having another pregnancy. As a further follow-up to this, my daughter who loved to pick and eat berries with me, has never had a proper menstrual cycle and cannot have her own children. She has had many examinations to determine the cause of this but the Doctors cannot find any reason whatsoever. In every other way she is physically and mentally exceptional having excelled in sports as well as scholastically. The son of one of our cottage neighbours lives in a wheel chair because of a spinal injury he was born with. His mother was with me for a week that same summer. His grandmother has since died of leukemia. Now I know that the "experts" will say there is no scientific proof that 245T is responsible for what I went through, but I have heard of many law suits being won on less evidence. Maybe I should have brought suit against the Hydro years ago, but I could not have faced this experience.

I do hope you can bring pressure to bear on the Ontario Government and Ontario Hydro to forbid the spraying in any area of our country. Hopefully this letter will further the case against spraying 245T. After all people take their children, as I did, to the country in the summer to avoid pollution. And for what? Surely the cottagers should be allowed the peace of mind when in the bush to feel confident that their children and grandchildren can eat the wild straweberries, raspberries, and blackberries etc. that come up so quickly after a clearing is made.

I think we should encourage the young people to do the underbrushing on the hydro cuts as we have been doing behind our cottage ever since. The hydro can come in and cut large branches of trees that pose a danger to the wires but under no circumstances should they be allowed to do any spraying at all not even by the so called "controlled" spraying by experts.

Sincerely



Birth defects, reproductive problems and spina bifida are all recognized consequences of exposure to 2,3,7,8 TCDD (dioxin). The Ontario Ministry of Natural Resources, Ministry of Transport and Ontario Hydro all were concerned with the health of their (male) workers applying these herbicides. I wonder how many wives and families were damaged by exposure to clothing etc. worn by these same workers. None of this whether in Vietnam, Canada or the U.S. had to happen. Corporate greed and stupidity enabled by morally bankrupt governments protecting corporate interests led to this disaster.

SCIENCE, POLITICS & MONEY. THE LAST TWO USUALLY TRIUMPH OVER THE FIRST

I have been going through a website which purports to be "Welcome to Ontario 2,4,5-T Records Online". Firstly I see nowhere near the 4,000 plus records that supposedly were made available to the Facy-Finding Panel in their Report released in June 2013 in the Ontario legislature. Secondly the opening page lists all the exceptions and deletions in records that occurred allegedly under the Freedom of Information and Protection of Privacy Act as well as under the Copyright Act. Personally I give those allegedly legal reasons very little credibility because my experience and others with FOI is that it is legislation, only in name, to assist citizens to access government data. Finally as indicated, the opening page also indicates numerous records have been blanked out or deleted as allegedly being "Not Relevant". Indeed many of the listed records are simply blank pages. Obviously very unimpressive.

To date I have downloaded about a dozen of what appeared to be the most interesting records. Lots more to go. One is a letter dated February 14, 1966. It simply is a Memo to "All Area Managers, Central Region" asking for their pesticide requirements for the upcoming 1966 season. It is under the subject Forestery- Brush and Weed Control chemicals. The first two chemicals are Brushkill, 2, 4-D & 2,4,5-T mixed followed by Brushkill, 2,4,5-T (For Resistant Brush). It is my understanding that Brushkill is one of the brand names for Uniroyal Chemical's products produced here in Elmira, Ontario. The other name is Brushbane .

There are three records I've seen to date which indicate a strong counteroffensive to honest efforts to determine human health effects caused by Agent Orange, 2,4,5-T and Dioxin (2,3,7,8 TCDD). The first is a December 22, 1969 letter to Dr. Lee A. DuBridge, Science Adviser to the President (U.S.). It is critiquing a Report titled "Teratogenic Evaluation of 2,4,5-T" and clearly this multipage critique written by Glenn Klingman, President of the Weed Science Society of America, is self-serving. Just as clearly this Weed Science Society of America is some kind of chemical industry lobby group. Mr. Klingman has cc' d the following chemical manufacturers namely Diamond Shamrock, Dow Chemical, Hercules, Hooker Chemical and Monsanto.

There is also a letter dated February 26, 1970 from a Donald Grant, Director of Medical Services presumably for Ontario Hydro. He has sent it to Mr. J.E.F. Winter, Chief Forester of Ontario Hydro. This letter references a number of newspaper articles from both Canada and the U.S. warning of the health hazards of 2,4,5-T. Mr. Grant quite brusqely sweeps aside those public concerns as he states "The herbicide spray program for brush and weed control within Ontario Hydro should be continued without fear of harmful effects to our employees or the public.".

The third letter dated February 23, 1972 is from Dow Chemical of Canada, Sarnia Ontario. It is written by a Mr. Wiffen and sent to a Mr. J. VanRees presumably also of Dow Chemical. It is advising Mr. VanRees regarding his presentation to Ontario Hydro about 2,4,5-T and Dioxin! Two sentences many pages later state "...of the fact that there is a growing preponderance of scientific evidence and regulatory opinion attesting to the safety of 2,4,5-T to health and the environment." This is followed by "...discussion of 2,4,5-T and estimates of hazard from registered uses of the commercial herbicide quickly turns to the conjectural aspects about 2,3,7,8 tetrachlorodibenzodioxin (TCDD)."

Tomorrow's posting will show other records indicating the opposite of what these three persons were trying to get across to decision makers and some of those with vested interests in keeping 2,4,5-T on the market.

THE ONTARIO FACT-FINDING PANEL DISCUSS INTERPRETATION ISSUES IN HEALTH STUDIES

Epidemiological or health studies of human beings exposed to a particular chemical or physical irritant of some nature are extremely unlikely not to have some major issues. These include having a large enough group of people to make a statistically valid comparison. They include having a group of individuals exposed to the item of concern, such as TCDD, and then being able to compare their health to a relatively equal group of individuals who have not been exposed. By a relatively equal group we mean of similar age, similar genetic background , similar diet, similar overall health originally etc..

Other issues in this study would include the impossibility of having perfect knowledge. How many of us can remember an exposure say to an on the job solvent that occurred twenty-five years ago? Yes if you collapsed at the time due to an acute exposure you probably would remember. Otherwise not. How many of us have been exposed to a chemical and not even known it? This exposure could be via air, food or water. Therefore determining who is in the control group allegedly not having been exposed to the chemical of concern is a difficulty.

The Panel discuss at length problems with exposure assessment. "Even the most comprehensive and high-quality epidemiological studies typically have monitoring information on exposure for only a few points in time for some of the study population, which must be used to represent the exposure history of the entire population. Thus for most of the timeframe covered by any epidemiological study, exposures must be estimated or extrapolated, from a relatively small amount of monitoring data...". Thus exposure misclassification can lead to either false negative conclusions or to false positive conclusions regarding associations between TCDD and health.

The Panel then states "Clearly, exposure misclassification can and probably does have a powerful effect in nearly all observational epidemiology studies. What's more, it typically drives relative risk estimates towards the null.". Also disease misclassification can and does occur. Current medical records are considered for example a much better indication of cancer presence than death certificates listing the cause of death.

Confounding is a huge issue which can only be somewhat mitigated in these studies. Obesity and smoking for example are risk factors for many diseases. Suggesting that a persons' cancer is caused by exposure to a single large exposure to TCDD may not reflect a lifetime of smaller exposures to TCDD through foods and inhalation. Similarily suggesting that exposure to TCDD through annual road spraying wasn't large enough to cause their cancer probably is ignoring their previous exposures to TCDD by eating fish downstream of Uniroyal Chemical or even through exposure from spraying of nearby Ontario Hydro power lines. To date I have seen no suggestion that this study has considered multiple exposures to 2,3,7,8 TCDD and or 2,4,5-T from many other known sources in our environment. In other words it is not accurate to separate out Ontario government causes of TCDD exposure and suggest that they haven't added to citizens toxic burden.

Another well recognized confounding variable is known as the "healthy worker effect". In essence the Panel are focusing on workers exposed to 2,4,5-T and TCDD and comparing them to the general population. However the forestry and Hydro workers as a group are probably healthier (at least initially) than the general population in order for them to be working full time. Also the general population includes the very elderly who are more likely to have serious other health issues.

The Fact-Finding Panel concluded that as much as possible the studies they reviewed all considered possible limitations of epidemiological studies. While that is mildly comforting that is all it is. While I'm not suggesting any flaws specific to the Panel's work, I am suggesting that the whole field of risk assessment is fraught with information difficulties, assumptions and extrapolations. Perhaps the mathematical models and calculations are the best we've got. Perhaps the best we've got is significantly underestimating the effects of Ontario's poisoning of the environment. Perhaps not. It was still incredibly stupid for an incredibly long length of time.

THRESHOLD VERSUS NON-THRESHOLD CARCINOGENS

"A non-threshold carcinogen is usually genotoxic and is presumed to have no safe dose. A threshold model is based on the assumption that developing cancer requires a minimum level of exposure (the threshold), below which no cancer will develop."

In 2006 the U.S. EPA asked the National Research Council (NRC), part of the National Academy of Sciences (NAS), to review the 2003 version of the U.S. EPA assessment of the health effects of TCDD and related compounds. While they agreed with the EPA's findings on a number of matters they did however find "...that the EPA's decision to use only the non-threshold model for extrapolation was not adequately supported and recommended that U.S. EPA use both threshold and non-threshold models to extrapolate risks at lower levels.".

There have been studies and assessments by Health Canada, the Canadian Council of Ministers of the Environment (CCME) and numerous other studies by individual scientists over the decades. Most of the results have been supportive while some studies have been less supportive of particular findings. For example some studies show a clear association of TCDD with diabetes, others less so. One study strongly stated that their review indicated that "...results were consistent for an association with defective brain development in infants.". Also some studies believe that there is a strong association between ischemic heart disease and TCDD and a weaker association between TCDD and all cardiovascular disease.

The loopholes for both government and industry to avoid accountability for their culpabilty in the pain, sufferring and death of hundreds of thousands to millions of Canadians are immense. These studies are at the population level not the level of the individual. Therefore for an individual to sue for damages for the pain and sufferring or loss of a loved one, especially in Canadian courts, is almost hopeless. An example would be an individual exposed by highway spraying by the Ontario Ministry of Transport through the 50s, 60s and 70s. To find out for example half way through the trial that the individual involved also was exposed to TCDD by a parent living beside Uniroyal Chemical in the 40s and 50s would be a confounding variable. Which exposure (or both) did the damage?

Again while I am still reading this report by the Fact-Finding Panel, to date I find it very disturbing. The Panel have indeed found evidence of gross negligence by our political authorities while carefully not using those words or terminology. They have indicated the current scientific understanding regarding TCDD (especially 2,3,7,8 TCDD) and it is horrific. Again their language is much more nuetral and put in medically correct terms. My confidence in the basic commonsense and integrity of our political leaders past and present continues to plummet.

MERRY CHRISTMAS & A HAPPY NEW YEAR

VARIOUS SCIENTIFIC STUDIES OF 2,3,7,8 TCDD (DIOXIN)

Many national and international agencies and institutes have studied the health effects of exposure to 2,4,5-T and 2,3,7,8 TCDD. Also individual scientists have also performed reviews of the scientific literature. Unsurprisingly there is not 100% agreement on each and every health effect, threshold level, and final outcome of exposures. This is due to differences in human response to simialr exposures as well as confounding factors such as prior unknown exposures, different lifestyles, genetic background and overall prior level of health. Studies include both experimental animal studies with controlled doses and then extrapolations to humans as well as epidemiological studies looking at past human exposures. There have been world wide a number of catastrophes and exposures with the whole gamut of minor to horrific health effects following.

The literature reviewed by the Fact-Finding Panel in Ontario indicated a number of possible diseases caused by exposure to 2,4,5-T and 2,3,7,8 TCDD,. In total they include cancer, heart disease, neurological conditions, reproductive and immunological conditions, endocrine function and skin conditions. Some of these better known reports and studies include

IARC (International Agency for Research on Cancer) Three studies in 1977, 1987 and 1997. The first was inconclusive, the second linked chlorophenoxy herbicides, including 2,4,5-T, to soft tissue sarcoma, non-Hodgkin lymphoma and Hodgkin disease. The 1997 study stated that 2,3,7,7 TCDD was carcinogenic to humans and caused excesses for non-Hodgkin lymphoma, lung cancer and all cancers combined.

WHO (World Health Organization) in 2003 examined chlorophenoxy herbicides found in drinking water. They found evidence of associations with miscarriages and birth defects in some but not all studies. They also found limited evidence of an association with non-Hodgkin lymphoma.

IOM (Institute of Medicine) is part of the well respected U.S. National Academy of Sciences (NAS). In 2012 in studying Agent Orange and Dioxins they found sufficient evidence of soft tissue sarcoma including heart, non-Hodgkin lymphoma and leukemia. They also determined there was sufficient evidence to include Type 2 diabetes and spina bifida as effects. There was only limited evidence of heart disease and hypertension being caused by Agent Orange and dioxins.

NTP (U.S. National Toxicology Program) In a 2011 study they determined that TCDD was a known human carcinogen and caused excesses of non-Hodgkin lymphoma, lung cancer and in fact all cancers combined.

It is essentially impossible to categorically prove beyond any doubt, ahead of time, that exposure to certain chemicals will sicken and kill human beings. What we should always be aware of is the purpose of insecticides, herbicides and fungicides. That purpose is to kill other life forms. In the history of the human species on this planet, there is a terrible irony in our willingness, for profit, to kill other species that allegedly harm mankind; while cheerfully sacrificing a certain number of our own species. For profit.

ONTARIO'S "WEEDLESS" TOWN, ELMIRA

How many Elmira and Woolwich residents recall those ads in the 60's extolling the virtues of mass spraying throughout Elmira, Ontario? How many Elmira residents have died prematurely as a result after sufferring various ailments including cancers? Esther Thur of Elmira and the Elmira Environmental Hazards Team attributed her multiple bouts of cancer to Uniroyal Chemical.

The Fact-Finding Panel on Herbicide 2,4,5-T have stated that in 1978 Ontario municipalities used 90,000 kg. of Agent Orange, half of which was 2,4,5-T (ie. 45,000kg). The combined use of 2,4,5-T by the MNR, MOT and Ontario Hydro that year was half of that or 23,000kg. The Panel did not allegedly have data to show if those numbers were representative of the entire 1950-1979 era for either total useage or proportional useage between the province and municipalities. Regardless in one year alone (1978) Ontario municipal and provincial governments doused nearly 70,000 kilograms (150,000 pounds) of 2,4,5-T on unsuspecting Ontarians.

The Panel also claim that they do not know which manufacturer or suppliers provided Ontario with 2,4,5-T. As we manufactured it right here in Elmira, Ontario I've got one candidate in mind. The Panel bless their pointed little heads at least have indicated that they are satisfied that the 2,4,5-T used in Ontario did indeed contain the same Dioxin contaminant as that purchased by the U.S. military for use in Vietnam. That again was purchased both in the U.S. as well as from Uniroyal Chemical in Elmira, Ontario.

The Panel have also indicated clearly that while there were standards, policies, practices and guidelines regarding the spraying of pesticides at the time, they (the Panel) "could not determine the extent to which they were followed or enforced". Stories by survivors indicate that students were on the ground holding balloons allowing Ministry of Natural Resources pilots to spray from the air, thus soaking the students as well. That hardly bodes well for ground spraying procedures to be any more professional or careful.

The Panel discuss the difference between Threshold and Non-Threshold (one hit model) levels or risks. Essentially the Non-Threshold hypothesis states that zero risk is only possible with zero exposure. This theory feels that exposed populations are at risk at any level of exposure to carcinogens particularily genotoxic ones which damage DNA. The Panel state that historically the Threshold approach has not been used to estimate risks from carcinogen exposure
"...but more recent advances in risk assessment science have led the scientific community to discuss integrating the Threshold and Non-Threshold models for the risk assessment of carcinogens.".

Clearly uncertainty abounds. I wonder when the last human being is left whether the long deceased scientific community will have the data they require to unequivocally state that Dioxins are lethal eventually to everybody.

READING THE FACT- FINDING PANEL'S REPORT ON HERBICIDE 2,4,5-T

Following are some of my concerns regarding the 2,4,5-T Report. The Panel concluded that TCDD (Dioxin) had only indirect carcinogenic effects and a general lack of mutagenicity. Hence "...the threshold model was appropriate for application to 2,4,5-T and its contaminants.". They also claim that "...a tolerable intake could be established for TCDD on the basis of the assumption that there is a threshold for all effects, including cancer...".

"The re-creation of exposure events that occurred decades ago is rife with unknowns and uncertainties. As such, many decisions were made along the way that influenced the outcome of the assessment.". Finally "Each of the decisions and input variables contain some element of variability and uncertainty, which can effect the final results and conclusions.". Well isn't that just dandy. Basically on page four the Panel are advising readers that the whole process is no more than educated guesswork, at best. At worst it is scientific mumbo jumbo hiding the provincial government's culpability in the poisoning of Ontario citizens. Then at the end of the same paragraph they have the brass to suggest however that due to allegedly using assumptions that overestimate risk, that their assessment errs on the side of safety. There is an old joke about when you ASSUME you make an ASS out of U and ME.

The first poor assumption in the report (pg. 5) deals with contaminated clothing of the employees applying the herbicide. "Exposure to contaminated clothing was possible for several receptor groups, but because the panel thought it to be less likely and less easily quantifiable it was not included in the mathematical modelling.". Wow! I find that mind boggling!

Also on page 5, "Although the panel assessed and documented the evolution of pesticide use standards and regulations in Ontario, it could not determine the extent to which practices intended to protect the general public or to protect workers involved in pesticide handling, mixing, loading and application were practiced, monitored or enforced.'. Again that is another vital piece of information missing from the equation.

Page 6 informs us of the only slightly hypocritical and uninformed knowledge level as early as 1954. " herbicides are known to be non-toxic to man and animals but operators should minimize breathing in the mist, or having it contact their faces.". So which is it? Non-toxic or dangerous enough you shouldn't even get it on your skin?

We are also informed that other provincial government departments used 2,4,5-T but the MNR, Min. of Transport and Ontario Hydro used the most. Allegedly, according to the Panel, private and municipal use was much greater than that of the province of Ontario. I find that rather strange as the Panel claim that they did not study or evaluate anything but provincial use so how did they determine that private (farmers) and municipal use was far in excess of provincial use?

Page seven has a ridiculous paragraph claiming that "None of the bystander exposures to 2,4,5-T for Ontario Hydro, MNR and MTO exceeded the benchmark level." Unfortunately the very same paragraph suggests otherwise. It appears as if the Panel's Report is playing with words and being intentionally obtuse.

The report while admitting some occupational exposure above safety standards is very carefully doing its' best to minimize admitting any possible exposure of bystanders or the general population. Even when they admit to exposure levels above the manmade calculations based upon assumptions; they still only state that people's health "could" be affected.

Once again I see politics doing its' best to use science and scientific limitations to avoid responsibility towards citizens. The fact is that our governments authorized distributing toxic substances including Dioxins throughout Ontario and now they are trying to avoid responsibility for so doing. To date my opinion is that this Report is a classic government attempt to avoid blame that rests squarely on their shoulders. Spending billions of dollars on health care is just dandy but that does not justify our provincial government weasel wording and stickhandling their way out of greater responsibilty towards their citizens.

AGENT ORANGE USE IN ONTARIO PROBED - SORT OF

Following are three on-line news reports concerning the Fact-Finding Panel commissioned by the Ontario Government in 2011 to look at the useage of Agent Orange/2,4,5-T by the Ministry of Natural Resources (MNR), Ministry of Transport and Ontario Hydro from 1950 until 1979. Coincidentally or not 1950 is the startup date for manufacture of 2,4,5-T at Uniroyal Chemical in Elmira, Ontario. I am not aware of other manufacturers of that product in Ontario at that time.

The March 26, 2011 Niagara Falls Review has an article titled "Toxicologist fires back at critics, says Agent Orange isn't focus of probe". The toxicologist was the recently named Chair of the Panel, Dr. Leonard Ritter. The NDP suggested that he was in a conflict of interest position as he had worked for Health Canada as a toxicologist from 1979 until 1993. What I find more worrisome are Dr. Ritter's disingenuous quotes attempting to separate 2,4,5-T from the Dioxin impurity 2,3,7,8 TCDD which was part of it. "It's not like Agent Orange", "You can't compare it to Agent Orange. How is 2,4,5-T different from Agent Orange? Well it's like the difference between day and night. 2,4,5-T is half of Agent Orange. It's not similar at all.". Wow if there aren't some outright lies in all of that there certainly is some heavy duty stickhandling involved. Those weird, peculiar and inaccurate quotes by Dr. Ritter before the probe even got started should have ended his Chairmanship right then and there.

Sunday, June 23, 2010 the on-line story refers to the Timmins Press and M.P.P. Gilles Bisson. This was after the Report from the fact-Finding Panel was presented at Queen's Park by the Ministry of Natural Resources. Mr. Bisson represents Timmons-James Bay in the Ontario legislature. He takes the government, the MNR and the Panel to task for what they did not do. They did not look at the individuals sufferring from cancers and more who were directly exposed to 2,4,5-T in the 50's, 60's and 70's. They did not indicate the cause and effect nature of Dioxin (2,3,7,8-TCDD) and cancer. They did not make it easier for the exposed and sick workers involved in the spraying to be able to access Workers Compensation. Mr. Bisson also suggested that by naming municipalities in the Report as using more 2,4,5-T than the province, the Province and panel are simply trying to deflect blame from the province onto cities who used the herbicide.

The third on-line news report was from Global News also after the report was released. It states that the MNR Minister David Orazetti has stated that workers who think that the herbicide made them sick should file WSIB (compensation) claims. He also however states that "...they will need medical evidence to prove their illness came from exposure to 2,4,5-T.". Basically this Report did not make a direct link between elevated exposures, much less any exposures, and getting sick. What the province have done is made it necessary to reinvent the wheel here in Ontario. These claims have been substantiated by returning U.S. servicemen who handled the very same product in Vietnam. Dioxins cause cancer and so much more. Except not so much in Ontario unless you can prove it all over again.

What I find surprising is how little media attention this issue received. Here in Waterloo Region I heard absolutely nothing when this report was released in Toronto. Did our local Kitchener paper not carry this story? Also part of the extremely limited media coverage might have been the sucessful deflection from extensive Agent Orange use in southern Ontario to the impression it was a northern Ontario employee/employer issue only. Once again our professional politicians have shown where their skill sets lie.

AGENT ORANGE USE IN ONTARIO

There is an old joke about prettying something up being comparable to putting lipstick on a pig. That's what I'm seeing so far in the Fact-Finding Panel's report on 2,4,5-T useage in Ontario. Like literally dozens to hundreds of reports I've read the raw data is very interesting but the conclusions and inherent assumptions are a little terrifying.

The Panel has accepted that there are Threshold values for 2,3,7 8 TCDD (Dioxin). They state that they are following standard scientific belief on this matter. Wow. I've done a lot of reading on this worst of the worst Dioxin and my understanding is that it is similar to NDMA in that there is no safe level, period. Also I have to recheck but I believe that they stated that 2,3,7,8 TCDD is not mutagenic. Again I have to say Wow to that. Based on the damage to successive generations that seems very unlikely to me.

Tuesday of this week I posted here some of the details on this Fact-Finding Panel on Herbicide 2,4,5-T. Their Report came out, very quietly it seems to me, in 2013. They suggest that concerns first arose in the early 1960's but it wasn't till 1979 that Ontario stopped using 2,4,5-T. The federal government deregistered it in 1985. The timing of concerns seems appropriate as Vietnamese civilian victims emerged fairly quickly after the spraying started there. The timing of deregistering and stopping use here in Canada however was much less appropriate.

One of the Figures plus text indicates that 90% of the roads and highways in southern Ontario were sprayed on an annual basis for over a decade. At the same time the Panel are suggesting that yes workers involved were exposed above a certain Threshold and thus could have legitimate health damage due to Ontario government (MTO) activity. They are however suggesting the unlikelihood of much larger populations having been adversely affected. Is it possible that the purpose and outcome of this study was pre-ordained to deflect government liability towards its' citizns? Is the current 40-45% of the population expected to have cancer in their lifetimes related to some of these government initiatives?

MORE CRITICISM OF THE ENVIRONMENTAL INVESTIGATION OF BURIED DRUMS IN GUELPH

I posted twice here a little over a week ago regarding the investigation of the buried drums found during the Paisley Clythe Watermain construction in Guelph. My comments then centred on both air emissions and a lack of groundwater monitoring. The lack of groundwater monitoring is a blatant deal breaker. I expressed skepticism fairly early on that an alleged lack of ability to find groundwater seemed unlikely. The fact is that I was correct. I must conclude that the failure/refusal to do groundwater monitoring was intentional and purposeful. It would seem likely that the purpose was to be able to claim that the contamination had not spread as well as to be able to maintain the fiction that there was no public health risk.

The text of the November 2014 report by the MMM Group states on pages three, four and five that groundwater was not sampled allegedly because borehole 7 (BH7) was dry and because there was insufficient groundwater accumulation in the test pits to do so. The Test Pit Logs however near the end of the report tell a different story. Test pits 3A, 4 and 5 all had groundwater seepage in them. Test Pit 5 had the infiltration start at 2.0 metres below ground surface and the excavation ended at 2.0 metres below ground surface (mbgs). Test Pit 4 had groundwater seepage start at 2.5 mbgs and the excavation ended at 2.8 mbgs. Test Pit 3A had the following text written on its' Log "Test pit terminated at 2.25 mbgs due to groundwater seepage into bottom of test pit."

I am hard pressed not to suggest that this is either bogus or a coverup. I have read far too many technical reports over the decades, albeit not from these consultants, to be shocked by what appears to be a serious avoidance of the truth.

THE ART OF DECEPTION & CONCEALMENT

Suggestion and interpretation are huge factors in deception. Also verbal additions to written documentation can intentionally lead people astray. I have reread documents for the sixth and seventh time, years after the fact, and picked up nuances and information I missed the first time. The English language doesn't always clearly elucidate the intended meaning.

For example the vast bulk of maps of the Chemtura/Uniroyal property show GP1 as generally in the south-east corner, positioned diagonally. I had no idea why it was in that position contrary to the orientation of all the other eastern pits. I did notice that from time to time on various maps there did seem to be small differences in its' position whether further north or south or even further east or west but it was difficult to tell because the only nearby landmark was GP2 which lies horizontally, parallel to Chemtura's extreme southern boundary.

Upon rereading two old reports (1991 & 1985) things begin to make more sense. Both reports, one done by Conestoga Rovers and one done by the Ontario M.O.E. refer to overflow from the eastern pits draining into a gravel pit (GP1), singular. There is no mention of GP2. Further study of Conestoga Rover's topographical contours also raised both questions and answers. The questions were why did they have the same numerical contour line on both the Chemtura and Stroh property approaching each other and then stop an inch apart on their map, right at the border between the properties? The appearance to me was one of deception as if they did not want the reader to put the big picture together regarding overland flow from the Chemtura property onto the Stroh property.

As mentioned in the first paragraph verbal suggestions are important. Jeff Merriman of Chemtura has long talked about furrows, as has some of the older reports. Therefore subconsciously when looking at satellite or aerial photographs that is what one looks for. It took some time before the huge swales on the east side actually registered. These swales can be seen on Google Earth . They are located on the west side of the eastern pits and they drain due south past RPE5 and TPE2 into the wetlands of the south-east quadrant of the site. Also there is a very good aerial photograph showing these swales in the 1991 Environmental Audit. This photograph very well may show furrows as well based upon the timing.

The Terraqua Report (1987) was mentioned in the K-W Record by a hydrogeologist, shortly after the Elmira wells were shut down, as the report which should have set all the alarm bells ringing. Like a magician's sleight of hand, Chemtura have been talking and arguing about removal of solid wastes, when the real issue regarding transport of their persistent organic pollutants (Dioxins & DDT), has been the liquid discharge of hundreds of thousands of gallons per week into the natural environment including the Canagagiue Creek. This report tells us that the bulk of DDT and Dioxins were piped across the creek over to the eastern pits where they both leaked and overflowed directly and indirectly into the Canagagigue Creek. Keep in mind that the word directly is somewhat subjective in these circumstances.

Throughout this entire twenty-five year process the Ontario M.O.E. have been supporting this misdirection and sleight of hand. One could be forgiven for believing that they felt their interests were also being protected by lying to the public.

DID UNIROYAL CHEMICAL IN ELMIRA SUPPLY AGENT ORANGE FOR USE THROUGHOUT ONTARIO?

A few years back the Ontario government through the Ministry of Natural Resources instituted a Fact-Finding Panel to determine where, when and how much 2,4,5-T was used by government departments and agencies in Ontario from 1950 until it was banned by the federal government in 1985. 2,4,5-T otherwise known as 2,4,5 Trichlorophenoxyacetic Acid was the major culprit in the mass poisonings which occurred in both Vietnam as well as in the bodies of U.S. servicemen who handled the chemical defoliant. The active contaminant in 2,4,5-T is a Dioxin specifically known as 2,3,7,8 TCDD (tetrachlorodibenzodioxin). This is the worst of the worst Dioxins and it is but one more unintended legacy of human arrogance, stupidity and greed.

It turns out that indeed the Ministry of Natural Resources and its' predecessor the Department of Lands and Forests used 2,4,5-T extensively as did the Ministry of Transport plus Ontario Hydro. Whether on its' own or in mixtures 2,4,5-T was used as a weed killer along hydro transmission lines and highways. It was also used to kill tree species in northern Ontario considered inferior to and competing with both white and black spruce. Oh the hubris of human beings!

At the federal level our Canadian authorities were equally as guilty. Camp Gagetown in New Brunswick was used as a testing ground for the mixture known as Agent Orange. The U.S. military with Canadian approval sprayed large areas to test the efficacy of the herbicide prior to its' use in Vietnam. Lawsuits and settlements have flowed from that behaviour in recent years.

The Fact-Finding Panel led by Dr. Leonard Ritter of the University of Guelph had a very narrow mandate. For example they did not study the use of 2,4-D or 2,4,5-TP throughout Ontario. 2,4-D was the usual partner with 2,4,5-T in the manufacture of Agent Orange. 2,4,5-TP includes Propionic Acid along with the 2,4,5-T. Furthermore and this is most disturbing their focus was on provincial ministries and agencies. They did not look at either municipal use of 2,4,5-T nor private use. The private use would have been by farmers primarily using herbicides along their gravel roads and fences or on hedgerows between fields. That said the Panel did estimate that total useage of 2,4,5-T was much greater by Municipalities than it was by the provincial government agencies and ministries.

So to be very clear here folks the bottom line is that private industrial manufacturers profited directly from municipal and provincial government poisoning of the population of Ontario. Industry and government collusion is a well known fact. Less well known, beyond the financial fleecing of citizens, is the pain, suffering and death caused by industry/government collusion.

MORE *RESPONSIBLE CARE SCAMMING UPCOMING

You have to hand it to Chemtura Canada in Elmira, they are shameless. The last time around for their verification under *Responsible Care, they stacked the deck in their favour ahead of time and they still couldn't legitimately achieve it. This program which is under the auspices of the Chemical Industry Association of Canada (CIAC) is supposed to be about the ethics of *Responsible Care. For some companies it probably is but for Chemtura it's nothing more than public relations to offset their horrid attempts to control and manipulate public consultation in Elmira, Ontario. Last time out they lost the vote from their verification team but managed to talk the CIAC into a do over. They got their votes with one dissenting vote that time, namely Dr. Dan Holt, CPAC Chair. Elmira's own Pat McLean, a former Councillor, showed her loyalty to Chemtura by voting for them while mouthing platitudes about their future promises and commitments. As expected by honest, independent critics who aren't getting expense paid trips around North America as she is via the CIAC; Chemtura's promises have been the usual hot air.

The next *Responsible Care verification comes up this spring, possibly in February or March. Already Chemtura are playing games by not advising CPAC (Chemtura Public Advisory Committee) as to who the verification team members will be, even refusing to say whether CPAC will have major representation or not; unlike last time when they had but one vote. Several years back Chemtura scammed the CIAC by getting the Chemtura West Hill plant in Scarborough combined with the Elmira plant for verification. The purpose was to bring verifiers on the team that were handpicked by the company in West Hill. It certainly isn't as if the West Hill plant hasn't seriously offended their neighbours as well but their "public consultation" is more typical of the chemical industry by its' membership being determined by the company.

To the CIAC I say this. You are jeopardizing your credibility and the credibility of *Responsible Care by including rogue companies such as Chemtura Canada under the *Responsible Care umbrella. Further recent developments in Elmira will continue to undermine the remaining shreds of Chemtura's credibility. As previously posted here they have covered up and lied to the public, CPAC and Woolwich Township for more than two decades about their contaminated ground and surface water discharges off their property and onto their eastern neighbour's farm.

GREY SKIES ON CONESTOGA ROVERS' HORIZON?

CBC News has an on-line article describing the transfer of toxic wastes originally from Love Canal, New York State; being sent to Corunna (near Sarnia) for disposal. Apparently the toxic wastes had "temporarily" been stored in a small landfill a few kilometres from the infamous residential site built on top of a dumping ground for Hooker Chemical. Even decades after being excavated the wastes will require incineration at 1300 degrees (C or F ?) prior to being reburied in Canada.

Lest we feel that Canada just can't keep up to the big boys in toxic waste, rest assurred that Uniroyal/Chemtura Elmira, Ontario have also sent equally noxious, cancer inducing and toxic wastes for disposal to Corunna as well. Apparently the clay in that area is particularily thick which prevents the wastes from readily passing through and contaminating groundwater and further soils. The fumes coming from their incineration process I am less confident about.

Conestoga Rovers & Assoc. made their name originally at the Love Canal. Their money saving ideas for polluters are partly predicated upon hydraulic containment which was originally considered to be strictly a short term solution for stopping the spread of chemical contamination in groundwater. It saves money for polluters as they allegedly aren't required to excavate grossly contaminated soil, merely keep it on their own property versus spreading to the neighbours. Currently there are complaints from residents in or near the Love Canal that the toxins are spreading and negatively affecting them.

Similarily in Elmira, Ontario the Chemtura Public Advisory Committee have received a report from an independent consultant (MTE Consultants) suggesting that there has been both groundwater and surface water flowing across the eastern property border onto the neighbour's farm. Other issues include a recently discovered manmade Drain carrying contaminated water directly into the Canagagigue Creek. It is even possible that a currently unexplained line, scar, trench visible via satellite is a secret groundwater collection trench disposing contaminated water off site onto the same neighbour's property.

The common denominater is of course Conestoga Rovers. They have been involved with the Uniroyal/Chemtura site since the 1980's and became the principal consultants in 1992 after Morrison-Beatty were "consolidated", according to Dr. David Ash of Uniroyal at the time.

AN ODE TO PAT POTTER & ESTHER THUR

Esther Thur is best known for her efforts in collecting and maintaining the Uniroyal file at the Elmira library for many years. After her death the newspaper clippings and technical reports were sent to the library at Wilfred Laurier University. Somewhere in the process, her work, the vast bulk of which was done after she left APT Environment in 1994, was named the APTE collection. It is no such thing. It is the Esther Thur collection and she did the work on behalf of the citizens of Elmira and Woolwich Township. She sure as hell did not do it for the greater glory of Sylvia Berg or to enhance the Saga of Susan, which is how Dr. Henry Regier has characterized Bob Burtt's recent literary masterpiece.

Pat Potter was a sucessful and forthright environmentalist who lived her life dedicated to the cause. It was Pat and her husband Chuck who padlocked Uniroyal's gates two decades plus ago. It was Pat who coined the expression "The Uniroyal Trials". She believed that the time would come when owners and managers would be legally held accountable for the damage they had done to the Canagagigue Creek, Grand River, Elmira aquifers and all life within them.

Right now both Esther and Pat are smiling. It has taken twenty-five years of hard work, frustration and team work to get to where we are today. The frustration arises of course not just from the lying, deceit and manipulation of guilty parties including government parties but from the backstabbing and infighting practiced for two decades by a pair of citizens. Both Pat and Esther knew and advised me and others about who to look out for early on. So did Dr. Henry Regier. I simply did not want to believe that they were right all along. Well ladies when you are manipulating behind the scenes with no opposition, it's pretty easy to have your way. How much fun have you had the last five years after more people have learned what you are?

Chemtura's and the Ontario M.O.E.'s credibility are at rock bottom. They have been exposed as morally empty bags of hot air. The M.O.E. have enabled the joke of a "cleanup" to proceed and wasted two decades of time to really do a proper job. They have deceived and misled using technical consultants to bafflegab and confuse serious citizen concerns and criticisms. No longer will their psuedoscience and outright horse manure fly in this town. Rest easy Esther and Pat. Your battles and efforts have not been wasted. We are still here and we and the truth are winning.

"ACTION IS NEEDED ON STROH DRAIN"

The above title is the same one in a Letter to the Editor in today's Elmira Independent newspaper. Currently this week's Independent is not on line yet so I can't include a link to it here. While the title is not mine nevertheless it does to a certain extent capture at least part of my concerns as expressed in the Letter to the Editor. Unmentioned in my letter are the persistent organic pollutants (POPs) identified over the last couple of summers as not declining, as obviously expected by Mr. Karlos of the M.O.E.; but in fact increasing since the 1995-1996 testing. These POPs include DDT and Dioxins.

The Dioxins while numerous also include the very most toxic ones known as 2,3,7,8 TCDD (tetrachlorodibenzodioxin). This is the contaminant found in Trichlorophenols used in the production of 2,4,5-T. 2,4,5-T has been used as a herbicide on its' own as well as mixed with 2,4-D to produce Agent Orange. The U.S. military purchased this product from U.S. sources during the war on Vietnam as well as from Uniroyal Chemical in Elmira, Ontario. For a pacifist Mennonite community this has not been an easy fit. While undoubtedly some Uniroyal and Chemtura products are ubiquitous and clearly beneficial to society, others have been incredibly damaging. The human health damage and destruction are still occurring in multiple generations of both Vietnamese families as well as in the families of U.S. servicemen who handled Agent Orange and its' similar herbicides. Canadians have also suffered due to uses in Gagetown, New Brunswick as well as in northern Ontario where it was used on highway and railroad right of ways.

Action is needed on two or three fronts. The Ontario M.O.E.C.C. have been involved in a coverup with Uniroyal Chemical going back decades. They no longer have the moral authority to be involved in investigating and cleaning up a site that they have worked very hard at pretending is under control. The M.O.E. have lied and deceived the public, the public advisory committee and various levels of government for decades. They threw their lot in with Uniroyal Chemical back in October 1991 presumably to limit further damaging revelations of their own culpability and incompetence.

The east side of Chemtura/Uniroyal can not be ignored any longer. It must be properly investigated by an honest party, not the M.O.E.. Then it must be cleaned up to stop the ongoing discharges of DDT and Dioxins down the creek. An honest study of the health of several generations of downstream residents must be undertaken. Any suffering and damaged health remotely possibly caused by these and other Uniroyal/Chemtura waste products must be addressed, including financial assistance.

There must be both accountability and transparency. Guilty parties must be exposed and if appropriate prosecuted. The public need to know that their environmental protector, the M.O.E., have long ago been co-opted by industry. A massive housecleaning and shakeup would only be the start. And it must all be done publicly or we will be back doing the exact same thing twenty-five more years down the road.

THE OLD CPAC WENT ALONG TO GO ALONG

They were long co-opted. Some were knowingly co-opted, most probably were not. Susan Rupert (Gow) warned APTE almost twenty-four years ago that if they agreed to private meetings they would be co-opted. Pat McLean and Susan Bryant have long been advocates of just such a strategy. Both of them have been rewarded for their "flexibility" whether by Chemtura or by the Region of Waterloo. These rewards have included status, expense paid trips, awards, paid work and membership on the National Advisory Panel of *Responsible Care, a chemical industry initiative. Just to be clear I don't believe that Pat McLean went "rogue". I believe that her behaviour was exactly what the Woolwich Mayor wanted at the time.

Transparency and accountability are gone when the polluter advises what issues he does not want discussed at public advisory committees. The citizens committee is co-opted when some meetings are by invitation only. CPAC is co-opted when the Chair and her sidekick, who are privately benefiting from their co-operation with Uniroyal/Chemtura, decide to remove the biggest thorn and most knowledgeable citizen, myself, from CPAC. Both Chemtura and the Ontario Ministry of the Environment have also been lobbying for the past four years plus to keep me off of CPAC. This will continue not because the current CPAC aren't honest and strong but precisely because they are. I am a catalyst and I have proven myself willing to assist CPAC members with data, history and information to bring them up to speed quickly.

This past year has been extraordinary. The discoveries of deception and misinformation are incredible. The list of individuals and groups who are now willing to publicly state that they don't believe that Chemtura will clean up the Elmira Aquifers to drinking water standards continues to grow, including the Region and Township. Two experts in the field have written reports contradicting the long stated positions and opinions of Chemtura and their consultants, Conestoga Rovers. Dr. Gail Krantzberg (McMaster U.) and Peter Gray of MTE Consultants were hired by CPAC and have both weighed in on major cleanup issues. The latter's report is key in tieing all the other east side discoveries together including the Stroh Drain, possible collector trenches and increasing concentrations of DDT downstream in the Canagagigue Creek.

Chemtura and the M.O.E.'s desperation is clear to see. Their last minute boycott of the November CPAC meeting is but one example. Chemtura's changing positions and responses regarding the scar, line, trench on their property is yet another. The M.O.E.'s shameful "site visit" a couple of summers back in which George Karlos declared there was no reasonable pathway for contaminants to leave Chemtura's property and move towards or into the Martin swimming pond is beyond negligence. My expectation is that both parties will do what they do best. That is crow and brag about their self proclaimed "sucesses" and then run for the hills as they have been caught redhanded having deceived and misled Elmira citizens for decades.

ALLEGEDLY NO PUBLIC HEALTH RISK IN GUELPH FROM BURIED DRUMS

Well I've now gotten into the measurements of air contaminants from the area of the test pits and buried drums on Wellington St. in Guelph. The text of the report advises us that there are no exceedances of M.O.E. health standards by these various solvents, petroleum hydrocarbons and using their classification, aliphatic and aromatic hydrocarbons. So does this indicate no health risks to the public? Absolutely not for a number of reasons.

They do admit in the text that benzene is the highest concentration present in relation to M.O.E. health standards. Two benzene samples are at 74 and 79 percent of the AAQC or ambient air quality criterion. Benzene is a known cause of leukemia but rest assurred its' concentrations are below the magic number of 2.3 ug/m3. Notice I said that benzene was the highest concentration relative to the health standards. There are lots more chemicals present at higher concentrations than benzene but their health standards are significantly higher than benzene is.

Exactly how many other manmade toxic chemicals are present in the air surrounding this contaminated site? I've counted thirty-four to date. While as stated many are at higher concentrations than benzene none are closer to the health standard than benzene is. The problem is this: Can someone tell me the health standard for benzene at 79% of its' individual standard combined with say toluene at 2% or even benzene and iso-propyl alcohol at 1%? The answer is no. Then combine benzene at 79% of its' health standard with thirty-two other toxic chemicals and you have exactly zero knowledge as to the health effects.

These above test results were taken at monitoring sites near the test pit excavations. Air samples were also taken from the top of some buried drums as well as on the lip of the test pits. Some of those numbers were off the charts. Off the charts as of five, ten, twenty and twenty-five times higher than the applicable air standards. But rest assurred your health is safe because those numbers weren't the ones used to determine that your health is not at risk.

Keep in mind I've only spioken today about air emissions. No one can bury metal drums filled with toxic liquids in the ground for fifty to sixty years and tell me the contents haven't leaked. I've seen and smelled buried drums up here in Elmira at Varnicolor Chemical and other locations. They stink and they leak and they affect groundwater, soil, nearby creek sediments, the floodplain and the air. Dr. Gail Krantzberg (McMaster University) advised the Chemtura Public Advisory Committee that anything that Uniroyal Chemical ever discharged onto their site has moved whether by air, groundwater, surface water or even soil vapours.

TREATING THE PUBLIC WITH DISRESPECT

On Saturday November 22, 2014 the Waterloo Region Record carried the following story "No public risk in buried, leaking drums". The title is a misnomer, an exaggeration and a lie. I suspect that the writer of said article honestly doesn't know that both the title of his article and a significant quantity of the "opinion" expressed are nonsense. It is even conceivable that the technical expert being interviewed, gilded the lily, simply as a matter of course. Certainly local politicians are known to be very concerned about not unduly alarming the public. Hence their attitude is that if nobody is going to immediately drop dead in the street then of course any and all paid experts ever wanting further work from a city for example, had damn well better be reassuring that all is well. Even when it isn't.

I've downloaded most of the report dated November 2014 regarding the Paisley Clythe Watermain. It is not a reassuring document to anyone familiar with contaminated sites. As indicated fifteen chemicals exceed the soil concentration standards set out by the Ministry of Environment. That is not good. Further comments indicate that groundwater samples were not taken. That is weird. Allegedly groundwater was not present. Really? The site is within fifty yards of the Speed River and apparently very close to Howitt Creek and they couldn't find groundwater? Nonsense. Twelve of the chemical exceedances involve Polyaromatic Hydrocarbons (PAH). There are some very toxic compounds here such as Acenaphthylene, Benzo(a)pyrene and Dibenzo(a,h)anthracene. Furthermore the solvents ethylbenzene and xylene are quite capable of solubolizing and enhancing the mobility of these PAHs.

Based upon the high concentrations of these compounds in the soil, namely measured in parts per million when often contaminated sites are measured in much smaller parts per billion or trillion; this is serious contamination. Serious contamination that not only will have moved in groundwater but most likely has also been mobilized over the decades by floodwaters from the nearby creek and river. The public are being given the sanitized version here. At the very least the tiltle and article should have indicated some public risk, perhaps not exactly quantifiable. No public risk is simply beyond wishful thinking.

IS ELMIRA HOME TO THE LARGEST DIOXIN/DDT SINK IN CANADA?

We know where the wastes from these processes were dumped on site. We know courtesy of the MTE Consultants Report the probability that they flowed eastwards off-site onto the neighbour's peoperty. We know both the proximity of the Stroh Drain and where it discharges (Canagagigue Creek). We suspect there may be a collector/interceptor trench diverting groundwater off-site. We have the results from three separate Ministry of the Environment studies showing high levels of Dioxins and DDT downstream in the sediments (& floodplain) of the Canagagigue Creek. We know that Chemtura and the M.O.E. have gone to great lengths to deny this contaminant pathway off their site. We also know that they have studiously avoided serious testing of Chemtura's eastern and southern neighbours.

This is beyond a scandal. This is beyond a disgrace. While I hold very little hope that a multi national corporation are going to voluntarily do the right thing at this late date; it is the Ontario Ministry of the Environment who are the most in need of a house cleaning. They have protected the polluter for decades while permitting this ongoing discharge of toxic compounds to the environment and to both human and non human receptors.

IS M.O.E. CORRUPTION A SUBSET OF PROVINCIAL POLITICAL CORRUPTION?

The buck stops at the top. The Ministry of the Environment are simply one Ministry around the Cabinet table of the provincial government whether Conservative, Liberal or NDP. While one's gut, visceral reaction to the word "corruption" may be an image of cash in a brown paper bag being handed over (eg. Brian Mulroney & Karl Heinz Schreiber), in fact the dictionary also defines it as "riddled with errors". Hence if something is corrupt it could simply be extremely incompetent or inaccurate to the extreme. I also believe corrupt can be used to describe rotting flesh.

Corruption in the usual political sense also may have little or no immediate cash value. Hence the corruption around the Watergate scandal was all about political advantage and political survival. I do not believe that Richard Nixon had an immediate cash incentive to commit burglary at the Democratic headquarters.

Is blatant, bald faced lying a form of corruption? I believe that it is. It is an abuse of power to withold or falsify relevant and pertinent data from citizens who have put their faith in an institution (M.O.E.) which is supposed to represent their interests. It is corruption for a democratically elected government to intentionally, either directly or indirectly, mislead and deceive its' citizens for its' own interests.

By these definitions there is no doubt that the Ontario M.O.E. are corrupt. They have long believed that their interests including their public perception are more important than both protecting the public and honestly informing the public. In the case of Elmira, Ontario they have misled citizen stakeholders for over 25 years regarding their health and environmental security. The M.O.E. have blatantly lied regarding both Varnicolor Chemical and Uniroyal Chemical (Chemtura). These lies deal with both the severity of pollution, the environmental consequences thereof and the efficacy of remediation methods. Again these lies have been to the media, the general public, the Chemtura Public Advisory Committee (CPAC) and to Woolwich Council over the years.

The "cleanups" of both sites have been inadequate. They have lied from the beginning, assisted the companies in covering up and minimized the full extent of the environmental damage whether to the air, soil, groundwater (shallow or deep), surface water, wildlife or human life. They have counted on medical uncertainity as to the most likely causes of diseases such as cancer which can be triggered by industrial contamination of the air, water or soil. This has all been done in order to protect the M.O.E. from appropriate criticism concerning their behavior and incompetence and which would damage their reputation and credibility as protectors of the environment.

JIGS HOLLOW GRAVEL PIT CONCERNS CONTINUE

Last week's Elmira Independent carried this story "Councillors reject request to reaffirm Jigs Hollow agreement". The agreement was in regards to "...minutes of settlement that had been approved by Woolwich council in 2012, that places a holding symbol on the pit, restricting it to extracting aggregate above the water table.". Local resident Della Strooboscher had asked council to reaffirm their earlier decision as a means to make their intentions clear to incoming council. The Township's director of Engineering, Dan Kennaley felt that that action could prove to be counterproductive. As it now stands any attempt by the gravel pit proponent to get approval for below water table extraction would require two years of hydrogeological study by the GRCA as well as a public meeting before Council would change the zoning.

PUBLIC WOOLWICH BIO-EN MEETING LAST EVENING

Currrently these public meetings between Woolwich Bio-En and local citizens are being held every two months. The next one is February 3, 2015 in the Elmira public library. Last evening we were advised that the plant is currently operating between 65 and 70% of capacity. Regarding total truck movements, in and out of the plant, the highest daily total was 48. This compares well to the current mandated total of 80.

There was a discussion concerning the Ministry of Environment's inflexibility and bureaucratic complication of what should be a readily straightforward process to deliver produced gas to a neighbouring farm by a pipeline. This operation afterall is all about producing a fuel by using waste foodstuffs to produce bio-gas to fuel an engine to run a generator to produce electricity. The M.O.E. are looking at at least two separate assessments requiring permits prior to any such procedure going ahead. Michael Purves-Smith of the BFCC (Bio-Fuel Citizens Committee) believes that this is a legitmate idea and is willing to lend support to it.

Discussion then revolved around the Renewable Energy Act amendments being sought. While the gas line to the neighbouring farm seems to be out, a pipe delivering heat to the neighbouring pet food plant is a go. Similarily a pipe sending the bio-gas to a service staion eventually at the south end of Elmira is also looking good. This idea of selling gas as a fuel for use in vehicles is apparently being promoted by the provincial Bio Gas Association. Earl Brubacher advised that when these amendments are approved they will be posted to the Environmental Bill of Rights (EBR) Registry.

There will be some minor changes to the document showing total truck movements and loads produced each month. These will include showing the average tons per truck of incoming raw materials. The difficulties around building a transfer station in order for small loads to be combined into larger ones was mentioned. While truck to truck transfers are both quite normal and physically possible the M.O.E. prefer formal transfer stations such that small loads go into a tank first and then get combined and put into larger trucks.

I am finding these meetings short but informative and to date it must be said that the bio-gas plant is operating without undue stresses or problems with their neighbours. Whether this is due to the relevant technology, local expertise and or a positive willingness to communicate with the public; it is to the credit of all involved.

THIS IS YOUR MINISTRY OF THE ENVIRONMENT

ONE piece of the evidence regarding soil excavation and remediation at neighbouring properties to the former Varnicolor Chemical is as follows. Golder & Assoc. produced a hydrogeological report on Varnicolor Chemical in late 1991. Hindsight combined with nearly 2 1/2 decades of knowledge and experience since that time have moved me from a "newbie" in reading these reports to a lay person with complete confidence and ability to challenge professionals in the field when they either cut corners or knowingly fudge their interpretations. Hence when I reread the report, that which I had suspected decades ago, became a certainty.

The Golder Report has two shallow groundater contamination contour maps plus a third contour map showing soil gas or soil vapour concentrations. All three of these maps show one thing in common and that is that Golder essentially stopped the contamination contours at Varnicolor's property line. In other words due to a lack of shallow monitoring wells off of the site, Golder's and the M.O.E. pretended that Varnicolor's on-site contamination slammed on the brakes and did not cross the property line. A close examination of the soil gas contamination map shows this occurring on the west property boundary directly opposite where Motivair did their backyard soil excavation and installed a groundwater drainage system. Similarily the BTEX (benzene, toluene, ethylbenzene, xylenes) contamination map contours indicates probable off-site contamination in this shallow aquifer on the north, west and east sides of the varnicolor site. Finally the chlorinated solvents ( TCE, TCA, DCA, DCM) contamination contours also show off-site contamination to the east.

The other very deceptive practice is Golder's failure to look at anything other than the shallow or surficial aquifer. Despite a Control Order demanding a deeper hydrogeological examination this did not happen. This report could only have been accepted by the M.O.E. if they had given prior consent to Phillip Environmental who paid for the Golder study. This surficial aquifer allegedly flows due east. Again in hindsight we know there is a groundwater divide in the Upper Aquifer around Union St.. therefore this slightly deeper aquifer flows both east towards Canagagigue Creek as well as west and south towards the south wellfield (E7/E9).

This hydrogeological "trick" of pretending that contamination stops at a company's property line has been exploited unmercifully at Uniroyal/Chemtura as well. It as well depended upon false groundwater flow direction to achieve its' purpose of deceiving the public advisory committee and the general public. At Chemtura this occurred on the east side of their property permitting undetected and unrestrained discharge of highly contaminated surface and groundwater onto the neighbouring Stroh property.

PRETEND PUBLIC CONSULTATION - VARNICOLOR CHEMICAL REMEDIATION ONGOING

Three years ago the Ministry of Environment advised us at CPAC that 200 tonnes more of contaminated soil would be removed from the old Varnicolor Chemical site (Union St.) in Elmira. Almost five years ago they advised that deep monitoring wells had been ordered for the site - again. Two years ago they advised us that it would be only 5 tonnes removed plus they would be extending the groundwater collection system in order to collect more contaminated groundwater for treatment. This site had the top 4-6 feet excavated twenty plus years ago and a shallow groundwater collection and treatment system installed. It was suppoesd to require a decade of pumping and treating.

Well shocking as it isn't the M.O.E. have lied to us again. It probably was 200 tonnes and yes they have extended the groundwater collection system - offsite! Over the past several years surrepticious excavations of contaminated soil have occurred at neighbouring private properties to the former Varnicolor Chemical site. They include Motivair and the Elmira Theatre Company plus one more at least. Also included has been the earlier indicated extension of the groundwater collection system to off-site properties. "Surrepticious" is simply by the fact that the M.O.E. have intentionally kept those cleanups secret from myself and from CPAC even when formally asked for updates on the site.

Twenty-five years ago I blew the whistle on Varnicolor's intentional dumping of toxic liquid wastes on that site. Literally Rich Clausi, Susan Rupert (Gow), Ted Oldfield and I had to fight the M.O.E. tooth and nail to get them to do anything. First they denied pollution then they minimized it. They claimed nothing had left the Varnicolor site and that it had not gone into the deeper aquifers. They also ordered both shallow and deep monitoring wells for the site in a Control Order. The deep wells never happened as Control Orders apparently are more for public show than for pollution cleanup.

The M.O.E. continue to coverup pollution in Elmira. They initiated public consultation at Chemtura regarding the 2028 deadline to clean Elmira's Aquifers. The former Varnicolor site sits directly on top of those very same aquifers yet the M.O.E. refuses to cooperate with CPAC by providing data.

What promises did the M.O.E. make the purchaser of the Varnicolor site back in 1999? Did they mislead and manipulate a competent person into assuming ownership and maintenance of the pump and treat system with promises that after a decade they would issue him a Record of Site Condition and he could sell or subdivide his site? Did they blatantly lie concerning the organized system of mass toxic liquid dumping the former owner devised and used? The new owner has his own hydrogeologist advising him and over two years ago I phoned and told him that I would at no charge tell him what exactly had occurred on that site. It's time for him to look at legal options against the M.O.E..

THIRD WORLD ENVIRONMENTAL NEGLIGENCE IN ELMIRA

The surrepticious diversion of ground and surface water from the most contaminated site in Canada onto a neighbour's property is illegal. Hiring of consultants to deny this has occurred is merely exacerbating one's guilt. Extorting, blackmailing or even merely influencing the provincial environmental regulator to back your illegal behaviour further adds to Chemtura's culpability. The Ontario Ministry of the Environment have long ago been comprimised and co-opted.

Knowing that your downstream neighbours are primarily old order Mennonites who will not sue you for health damages that you inflict upon them is scurrilous. Knowing that cattle, producing milk and beef, graze in the floodplain of your chemical sewer is without conscience. Knowing that there is a homemade in ground swimming pool using surface water from your surrepticious diversion is beyond the pale. This swimming pond uses water from the Stroh Drain to top up their pool when the groundwater level drops. The most vulnerable human population, developing children, are exposed to persistent organic pollutants via this route. Even our Ontario M.O.E. are guilty of this crime as they rubberstamped an "investigation" of this pool, falsely declaring there were no contaminant pathways.

Let there be no misunderstanding of the far reaching consequences of this coverup. Last May I was scouting for locations for a CBC Documentary regarding Vietnam and Canadian sales to the U.S. military. The instant I spotted the Stroh Drain I immediately knew this was all wrong. There simply should not be an unknown drain/creek of that size and significance beside the Uniroyal/Chemtura property that the public advisory committee was unaware of. Further claims by Chemtura and the M.O.E. that they were also unaware of it are nonsensical and miles beyond negligence.

While this east side diversion and coverup have ramifications affecting downstream users including Grand River users; it also affects the cleanup of the Elmira Aquifers. This of course has already quickly been denied by Chemtura's environmental engineer. Much of Chemtura's contamination has flowed vertically downwards and contaminated the Municipal Upper and Lower Aquifers. These aquifers flow from north-east to south-west towards the former south wellfield. This east side diverted contamination off-site has also flowed vertically downwards into those very same aquifers. From off-site to the east and south of Chemtura this contamination merely adds to the loading of both Municipal Upper and Lower Aquifers flowing beneath Elmira towards the south wellfield. This further unknown (hidden) contamination will result in even longer timeframes to ever cleanup via inadequate pump and treat technology.

CHEMTURA & ONT. M.O.E. STONEWALL

What else can they do? They have obfuscated themselves essentially into non credibilty. Even strongly pro business Woolwich Councillors are becoming shocked at what they are seeing. Chemtura's latest claim that the line, scar, trench across their site is no longer a "farm" fence but is now a "wildlife" fence is typical. I'm sure that a post and wire fence, four feet high will stop dingoes, kangaroos and the occasional tiger roaming the wilds of Chemtura. It sure wouldn't stop deer, groundhogs, rabbits, racoons or other ubiquitous wildlife in the area.

It is possible that the first shifting of GP1's location was not done by a Chemtura consultant. Since that time however someone sharp on Chemtura's payroll recognized an opportunity when they saw one. An error initiated possibly honestly by a third party is a lot easier to hide behind than one you've committed yourself. Therefore when no one noticed the initial error it was no big deal on future technical reports to shift GP1 a little more westwards. Again no outcry or response. This is especially so when the vast majority of CRA reports do not have topographical (ground surface) contours on them. Therefore as you slowly shift GP1 to a more selfserving location on your maps, readers do not see the topographical or environmental significance of what you are doing.

The question (among others) was asked yesterday. What is the environmental significance of this shifting GP1 on maps produced by Conestoga Rovers on behalf of Chemtura? Perhaps the actual environmental degradation directly caused by a relocation on a map is little or none. What however is major is the plausible deniability inherent in the current map location versus the original map and most likely real location of GP1.

The ground surface topography determines the flow of surface water. The original location further east puts GP1 into a lowlying wetland area which obviously drains off-site into the Stroh wetland area. This off-site flow is exacerbated by the miraculous appearance around 1985 of the Stroh Drain running parallel to the Chemtura eastern properrty line and discharging further south into the Canagagigue Creek.

This is not to say that the current map location of GP1 lets them off the hook. What it does do however is give the appearance of less off-site flow especially when CRA (Conestoga Rovers) have extended the length of GP1 further south-east until it is almost touching GP2's eastern end. Visually it appears as if all the surface water is trapped or held in these two lowlying areas. It is not but it takes a serious look at the topographical contours to determine that.

Chemtura and the M.O.E. are currently holding their breath and hoping that Christmas and holidays will give them a respite. They are also most likely quietly lobbying the new Woolwich Council desperately looking for support. Those two parties desperately need to get rid of the current CPAC & SWAT and the sooner the better. There is a much more accomodating and acceptable group to Chemtura and the M.O.E. available. There are always citizens available with a less public interest/service agenda who will always be more acceptable to polluters and their fellow travellors (M.O.E.). Woolwich Council please do not disappoint the citizens whom you serve.

A PUBLIC INQUIRY INTO THE ONTARIO MINISTRY OF ENVIRONMENT IS LONG OVERDUE

The revelations and discoveries in 2014 will go down in environmental history as a watershed in understanding the collusion between polluting industries and their ostensible regulator, the M.O.E.C.C.. Currently three discoveries stand out and each one alone is devastating to the credibilty of the Ontario M.O.E.(C.C.). The Stroh Drain discovered in May 2014, the Peter Gray (MTE) Report detailing evidence of east side ground and surface water discharge and finally the possible on-site Interceptor/Collector Trench. The first two are proven matters, the third while unproven as yet, appears plausible on many levels, but is not required to buttress the first two.

One CPAC member used the word "coverup" three times last Monday evening in regards to the east side non examination. Another CPAC member in the Working Session has expressed his opinion that the line, scar, trench readily apparent in satellite and aerial photos over many years is indeed some form of manmade plumbing works, most likely a groundwater collector trench.

Last evening another peculiar discovery was made. Occasionally technical reports will indicate that there may well be undocumented waste disposal areas on the Chemtura site. Other reports will suggest that perhaps pits and ponds over the years were expanded and contracted in size as the demands required. Self serving rewriting of history occurs in all human endeavours and apparently pollution history is no exception. We have been advised that two gravel pits (GP1 & 2) were the lucky recipients of toxic liquid waste flowing overland in "furrows" or swales via allegedly controlled discharges from RPE 1, 2, 3, 4 & 5.

Chemtura allegedly voluntarily spent somewhere in the vicinity of $3 million scraping a foot of dioxin (2,3,7,8 TCDD) and DDT contaminated soil out of GP1 while not scraping GP2 in the summer of 2013. Also importantly they did extensive recontouring of the land surface in their south-east corner. Now it appears that the $3 million "cleanup" was smoke and mirrors. Over the years GP1 has been relocated on maps from its' position when it was indeed the location of choice and by design for east side liquid toxic wastes. A map from 1983 and one later indicates that GP1 is further east closer to the south end of the east side retention pits. Chemtura's consultants over the last twenty plus years have been slowly moving its' location westwards and even southwards on their maps until they actually have the one end of it a few metres away from GP2.

Why spend $3 million dollars to clean up the wrong location? Why would the Ministry of the Environment who published one of the mentioned maps permit this subterfuge? What are both parties covering up? What is the environmental significance of the original location? Uniroyal Chemical obtained an Indemnity from the M.O.E. on October 7, 1991 for known contamination on their site. What had the M.O.E. done contrary to the public interest and or the law that made them vulnerable to Uniroyal arm twisting? These questions are only the beginning of what a public inquiry could answer.

MONDAY NITES CPAC MOTIONS & CRITICISM OF M.O.E. & CHEMTURA

While the absence of Chemtura and the M.O.E. was noted at Monday nights' public CPAC meeting let me say that the glass was half full. Firstly the meeting was just under three hours. Secondly there were no outbursts of mock outrage or pill induced emotional outbursts from Chemtura and the Ministry of the Environment. Thirdly I believe that a twenty-three year record was set for honesty and truthfulness, and that's always a good thing. Therefore I thank Chemtura and the M.O.E. for their contributions to the glass half full.

The first Motion passed by CPAC dealt with *Responsible Care. Rich Clausi, Mark Bauman, Sebastian Seibel-Achenbach and Ron Campbell all spoke to the need for a letter to go to the Chemical Industry Association of Canada (CIAC) advising them that Chemtura appear unwilling to engage with the community whether formally appointed representatives or citizen stakeholders.

When Mark Bauman was leaving the meeting I misspoke by telling him that he had been doing good work of late. I hope that he heard my followup which was that he had been doing especially good work of late. While I have indicated concerns with where Mark's heart and mind have been in the past; there is no doubt that he has recently been unequivocal in his support for both CPAC and the truth and I am thrilled to see that.

Mayor-elect Sandy Shantz provided information regarding timelines for Freedom of Information (FOI) requests. This was in response to a discussion as to whether CPAC needs to go through the FOI process to get financial cleanup information from the Ministry that they are currently refusing to provide. This Motion was also passed.

CPAC have decided to send a letter in response to Steve Martindale's (M.O.E.) October 29/14 letter written to CPAC Chair Dr. Dan Holt. Steve's letter dealing with technical questions from CPAC to former Assistant Director George Karlos, was horribly responded to by Steve. The questions pertained to numerous issues on the east side including buried pits, DDT and also two north-western pits RPW1 & 2. Steve's answers were inaccurate and unfactual.

A second letter has recently been written/sent to Milli New the replacement for Director (west central region) Bill Bardswick. I had thought that the M.O.E. couldn't scrape the barrel much lower with Bill Bardswick however my opinion may be premature. Councillor Mark Bauman and CAO Dave Brenneman collaborated in writing the letter and Mark read it to CPAC etc. at this meeting. It was excellent. Essentially the M.O.E. letter written on behalf of Milli New was as inaccurate and unfactual as Steve's. Quite amateurish and disgraceful actually.

Graham Chevreau advised CPAC that the Region of Waterloo have funding available for environmental projects. The third Motion passed was in support of CPAC applying to the Region for support via this fund.

Ron Campbell discussed his interpretation of the lack of data on Chemtura's east side as well as the MTE Report. Ron stated that in his decades in the business he had not seen any locations with gross contamination found literally on a property line and then no followup investigation of the neighbouring property. This request for all soil and groundwater information in that location has not been satisfactorily responded to by either Chemtura or the M.O.E.. Ron actually used the word "coverup" on three separate occasions. It is this kind of forthrightness that is required to combat the deviousness and stickhandling of Chemtura and the M.O.E..

I expressed my opinion that the failure of Chemtura and the M.O.E. to respond at all to a very small technical report by Peter Gray (MTE) was significant. I believe that Peter's report is essentially bulletproof and the lack of criticism and objections to date are proof of that. Both parties will require extensive wordsmithing in any critiques or responses which they formulate. My expectation is that any such upcoming documents will be primarily hot air, deflection and distraction. These are truly their areas of expertise.

THE HORRIBLE EXTENT OF CHEMTURA & M.O.E. LYING & DECEPTION

To date more than 150 million pounds (77,000 tonnes) of formerly buried chemical sludges and solid wastes have been removed from the Chemtura site in Elmira. That figure is courtesy of Jeff Merriman, environmental engineer at Chemtura. That is but a small fraction of what has been dumped, leaked, spilled and overflowed on the site. The truly horrific damage has been done by the to date untotalled liquid chemical wastes disposed of in both lined and unlined pits and ponds on the site. Even the lined ponds had been estimated to leak 3,400 litres per day through the bottom. Last evening we were advised that the north eastern pits would be filled up one day and be empty the next as everything had gone through the bottom.

Two Ministry of Environment employees and one GRCA employee wrote a document in 1985 titled "A History of Uniroyal Waste Management at Elmira". There are two Tables outlining per building and even per specific Uniroyal product (rubber additives, herbicides & pesticides) the volumes of liquid chemical wastes per average production day. The total chemical production wastes averaged in the late 1960's, 173,800 Imperial gallons per day (IGPD). On a five day work week that is a little less than a million gallons per week being disposed of over decades into unlined pits and ponds. The lining took place in 1970 after Uniroyal wastes were still being pretreated in ponds prior to being pumped to the new Elmira Sewage Treatment Plant.

Last evening at the Chemtura Public Advisory Committee (CPAC) public meeting a total of three Woolwich Councillors were present namely Mark Bauman, also a CPAC member, as well as Mayor-elect Sandy Shantz and Councillor-elect Larry Shantz. That is an overdue scenario and quite frankly if there had been more councillors present, even intermittently, over the last couple of decades, Elmira and Woolwich would be much further down the road to a cleanup than we are.

After indicating the volumes of liquid chemical waste produced on a daily basis I explained via a two foot by four foot map where the overflowing eastern pits had been directed, on their west side at least, not by 'furrows" but by a swale southwards into the Chemtura wetlands. The overflowing eastern pits also discharged easterly onto the Stroh farm according to both Peter Gray (MTE) and other sources. From the top (north end) of the wetlands the surface flow of chemical wastes went three directions namely south-west into one wetland, south-east into another and finally nearly due south into GP1. In GP1 there is a low lying area which would have filled first prior to the surface flow continuing on southwestwards and off site onto both the Stroh and Martin property. Basically once the chemical wastes entered Chemtura's (Uniroyal's) south-east corner it was essentially funnelled off-site (south-east) via two higher elevation structures. The one is a topographical high or ridge on the north-east side of GP1 (gravel pit 1) and the other is the manmade gravel road on the south-west side of GP1.

Not only does the Conestoga Rovers topographical map prove where the surface liquid wastes flowed but the satellite photos presented on the Council Chambers screen also assist. Finally last May Dr. Dan, Viv and I walked the property and we came across another swale running south-east from the Chemtura south-east corner into a small stream that discharges firstly into the Stroh Drain and then into the Canagagigue Creek.

CPAC, Woolwich Council and the public have been lied to for decades by both the M.O.E. and Chemtura. The east side has never been hydraulically contained; liquid wastes have been intentionally diverted off-site (illegally) and allowed to drain further downstream into the Canagagigue Creek and from there into the Grand River. More will come tomorrow from last night's CPAC meeting.

THE FINAL NAIL IN CHEMTURA'S & THE ONTARIO M.O.E.'s CREDIBILITY IS TONITE

Is a Public Inquiry in the cards? How about a Royal Commission? Or why not business as usual and have the Ministry of Environment (M.O.E.) investigate both themselves and Chemtura's behaviour for the last thirty years? We have had thirty years of public deception, public lying and breeches of the public trust. Surely our shameless provincial government can ramp up one more time and attack the messengers (CPAC & SWAT) while defending the indefensible assault not only upon all life in the Canagagigue Creek but also upon our downstream Mennonite neighbours. They like us have been overwhelmed with both the verbal and written lies of the M.O.E.. They have believed that the Uniroyal/Chemtura site has been contained while in reality it has never stopped hemorrhaging contaminated ground and surface water onto their property and into their lives.

Three elements are at play. Each one stands on its' own and is a damning indictment of both Chemtura and the Ontario M.O.E.. The first one is the Stroh Drain. It has been seen by numerous CPAC members and its' existence is now admitted by both Chemtura and the M.O.E.. The owner has given us a timeline for its' construction. This Drain empties (admitted by Chemtura) the wetlands on both properties directly into the Canagagigue Creek. The second element is the MTE Report written by Peter Gray. It is short, concise and relys on text and Figures produced by Chemtura and M.O.E. staff and consultants. Chemtura and the M.O.E. have had a month to read and respond to it. Instead both parties have informed us in writing that they will not attend tonite's public meeting which they had previously agreed to attend. Peter's report advises that the evidence indicates both groundwater flow and overland flow of contamintated liquids from Chemtura's east pits have entered the Stroh property. The third element is the one that once it has reached the level of proof and certainty of the first two; may open the door to criminal charges in my opinion. This is the possible Interceptor/Collector Trench(s) running from north to south across Chemtura's eastern side discharging groundwater either directly or indirectly into the Stroh Drain. This final element based upon current evidence appears likely. Further investigation is required but not by the already proven guilty parties.

M.O.E. SEE A MOUSE - SPRINT, OVERTAKE, PASS CHEMTURA OUT THE KITCHEN DOOR

Today's title is a little takeoff on yesterday's posting title. Steve Martindale of the Ontario Ministry of Errors and Excuses and Corporate Collusion (MOECC) has advised our CPAC Support Specialist Lisa that the M.O.E. will not attend Monday's CPAC meeting. He has advised that allegedly they first learned of Chemtura's multi speed, multi reverse gear retreat via this Blog right here that you are reading. Once again I am so thrilled to hear that the Ontario Ministry of the Environment have found an honest, accurate source of environmental information from which they can hopefully learn and improve.

Steve M. suggests that his one page Attachment to Lisa will suffice as a standin for himself and other M.O.E. employees such as Jaimie Connelly. I believe that Jaimie's feelings would be seriously hurt if he knew that his professional expertise (hydrogeologist) could be summed up as follows: "The MTE report (Peter Gray) is being reviewed by technical staff. Review will be provided when available."

Jaimie is the technical staff. The MTE report is exactly 6 1/2 pages of text. Seriously 6 1/2 pages of text. I'm sure that Steve M. did not intentionally suggest that it takes Jaimie nearly one month (October 30- November 24/14) to read 6 1/2 pages. There are also Figures provided. Some are M.O.E. previously published Figures. The rest are Figures previously published by Uniroyal/Chemtura and M.O.E. consultants and hence previously reviewed by the M.O.E.. Oh my!

Regarding the possible Interceptor/Collector Trench that I raised and Jeff Merriman complained loudly about at the last public CPAC meeting; there is more. I've been talking about it the last three days here. Again apparently Chemtura and the Ontario M.O.E. are lovers because they sure aren't fighters. As long as local citizens are either bribed or coopted they come out to play. When an honest Chemtura Public Advisory Committee (CPAC) ask tough questions and wait a month for a response; Chemtura and the M.O.E. run for cover.

CHEMTURA SPRINTING FROM THE KITCHEN - THEY CAN'T STAND THE HEAT

Yesterday the boys of Chemtura advised CPAC that they can't attend Monday evening's scheduled CPAC meeting. Please keep in mind that all CPAC meeting dates are set by concensus so as to maximize the input from all parties including Chemtura and the Ministry of the Environment who pulled a similar stunt two months back. Apparently when sensitive noses are out of joint, non attendance without even the facade of an excuse, is standard operating procedure for polluters and their alleged regulators.

I have been posting here for many months that both Chemtura and the M.O.E. have fallen upon hard times. They are dealing with a CPAC that have open minds and question all the golden nuggets of information that fall from their lips. This is very difficult to accept for them. This Monday was Chemtura's opportunity, after a month to get prepared, to criticize, minimize or somehow undermine Peter Gray's MTE Report. I reread that Report yesterday and was looking forward to Chemtura's attempts. It was even possible that the M.O.E. might take a shot at it although I am doubtful. They at least know when they haven't a leg to stand on. I interpret Chemtura's fleeing as a sign of panic and surrender.

Back to the line, scar, trench. I recently presented to CPAC and SWAT a 1987 Groundwater Monitoring Report (1987 GWMR) that details Interceptor or Collector Trenches. The date is significant in that it is about seven years prior to the possible construction of such a Trench on Chemtura's east side. There has been machinery available, invented in Europe, to excavate, lay a collection pipe and then backfill gravel, all in one pass of the machine. With that technology an Interceptor Trench could be installed on the Chemtura site probably within a day or at most two. The estimated construction costs of such a Trench are approximately 30% lower than installing pumping wells for a pump and treat system. While these Trenches can be simply a preferential pathway of highly permeable gravel to stop the progress of contaminated groundwater they can also have pipes on the bottom of them to further collect and divert this contaminated groundwater. What I find fascinating is the possibilty of such a trench on the Chemtura site not even requiring sumps and pumps to move the groundwater. With the apparent start of the Trench at the extreme north end of the site and the apparent end of the trench much further south and east, gravity flow is quite possible. What a fabulous system to stop highly contaminated groundwater from the east pits , discharging into the Canagagigue Creek on site. The possible diversion off-site (east) and into the Stroh Drain for discharge much further downstream is an added bonus. The monthly on-site monitoring of Canagagigue Creek surface water would not pick up any of this discharge precisely because it is discharged so much further downstream. Oh be still my heart. Could they have done this?

MORE AMAZING COINCIDENCES SURROUNDING THE LINE, SCAR, TRENCH ON CHEMTURA'S SITE

There are three nearly parallel lines etc. running from north to south all on Chemtura's east side. Amazingly they line up extremely closely to from west to east; the start of Upper Aquifer 3 (UA3), Upper Aquifer 1 (UA1) and the end of or fade out of the Surficial Aquifer (SA). It is really uncanny how close those first two subsurface aquifers leading eastern edge lines up with what I refer to as Trench three and Trench Two. The Surficial Aquifer (SA) ends or fades out at the ground surface and there lo and behold is Trench One. The SA therefore, as we have been previously advised, discharges into the wetlands well north on Chemtura's property, upgradient from the Canagagigue Creek. It discharges essentially at ground level hence any possible interceptor trench or other constructed works would be very shallow and hence very vulnerable to damage from surface heavy machinery or digging. Again an amazing coincidence as this is the only one of the three lines, scars, trenches which has a post and wire fence running along it from Church St.; southwards past all the eastern pits where it then jogs south-eastwards over to the Stroh property line. Please don't be shy Jeff or Dwight. While I'm attempting to advise you in advance of this coming Monday's CPAC meeting as to the evidence and facts you are facing; I fully understand if you choose not to do the same. Ambushing CPAC with either facts, nonsense, Public Relations puffery, allegedly professional technical backup (CRA, MOE) etc., is all par for the course. Or if you want to release written statements of your position prior to Monday, allowing CPAC & SWAT the opportunity to check references or reports allegedly backing your version, that would certainly indicate greater transparency and confidence in your "facts". Otherwise I and others might just think that you are simply stalling for the two month hiatus between Monday's CPAC meeting and the next scheduled one for January 29, 2015.

WAYNE GRETZKY, INTERCEPTOR TRENCHES & STICKHANDLING

Interceptor trenches can also be known as collector trenches. They are excavated to a specific desired depth anywhere from a couple of feet to twenty-five feet (7 metres) below ground surface. They are then filled with highly permeable gravels which intercept groundwater flow and either collect it or redirect it. Usually they are used for shallow aquifers and can be as stated simply filled with gravel giving the groundwater a preferential flow path. They can however also be built with a pipe on the bottom of them with holes in the top to allow this groundwater to seep through a geotextile fabric into the pipe. This collected groundwater depending on circumstances can be gravity flowed away from for example a nearby creek or river or it can be collected via sumps and pumped to either a private treatment system or even into a municipal sewage treatment plant.

To date the only answer we've received from Chemtura and Conestoga Rovers is that the line, scar, trench visible from Google earth is really just a post and wire fence. I am confident that they can and will do better next Monday at CPAC. That said there is more evidence that a subsurface structure exists that they do not wish to damage or disturb hence the fence still sitting there twenty-one years after pits RPE4 & 5 were excavated and 75 years or more since cattle or sheep roamed the area.

Prior to the 1993 excavation of RPE4 & 5 a number of monitoring wells were constructed in the area of the line, scar, trench. OW3, OW4, OW42, OW43, OW37 and OW8s and OW8-4 were mostly built between 1981 and 1984. Approximately fifteen years after the December 1993 excavations, following on concerns raised by Wilf Ruland in his suppressed May 15, 2008 DNAPL Report, Conestoga Rovers did a test pit excavation around OW42 which is perhaps fifteen to twenty metres due west of RPE5. These excavations included multiple test pits (10) as well as multiple Boreholes (10). The highly visible line, scar, trench approaches OW42 on a diagonal from the North-west and passes by within 9-10 metres. It then turns and continues due south to the bottom of RPE5 where it again turns and heads south-east neatly encompassing RPE5, BAE1, and the two reburied drum pits RB1 & 2. Therefore we have multiple well nests built before the likely 1994 construction date of a possible interceptor trench plus twenty testpits and boreholes constucted in 2009 after the likely 1994 date. Amazingly each and every one has been located on both sides, within mere feet or a few metres of this line, scar, trench. That is a feat of stickhandling of which even Wayne Gretzky would be proud. Surely a redundant, easily removable ground surface fence would not determine where multiple test pits and boreholes should be located. A fence delineating subsurface pipes and drainage is another matter entirely.