FREE PHASE DNAPL vs. RESIDUAL DNAPL - LAST NIGHT"S CPAC DELEGATION

Today's posting is only going to cover one aspect of last night's Chemtura Public Advisory Committee. That would be my Delegation to CPAC in which I presented a couple of pages with illustrations of subsurface DNAPL. Dense Non Aqueous Phase Liquids have a density greater than one (hence they sink through groundwater), form a separate phase from water in the subsurface and only very slowly dissolve, sometimes over decades or even centuries. The two pages and illustrations came from a 2003 report written by Drs. John Cherry, Beth Parker and two other colleagues from the University of Waterloo. They clearly show how subsurface DNAPL weathers over time. It starts as trails (or tails) of residual DNAPL which follow pools of subsurface DNAPL known as free phase. These free phase pools can be only one or two pools sitting on a lower permeabilty surface such as a clay aquitard or they can be multiple pools dispersed downwards throughout the aquifer with tails of residual DNAPL connecting them. Over time moving groundwater slowly dissolves both residual and free phase however the residual being a much smaller quantity and with more surface area exposed and surrounded by groundwater, dissolves more quickly. Hence as the text and figures illustrate over time the residual trails (tails) disappear entirely leaving only the pools of free phase DNAPL behind.

The significance of this on the Chemtura (Uniroyal) site in Elmira, Ontario is huge. All parties back in 1993 agreed to a set of written DNAPL Principles which clearly state that free phase DNAPL when found must be removed. This only makes sense if the Chemtura site is ever going to be removed as a threat to the Elmira Aquifers. Chemtura's consultants since then have jumped through hoops and loops and contorted themselves and reality beyond belief in their attempt to show only residual DNAPL on their site versus free phase. To date our esteemed Ministry of the Environment have carefully kept themselves out of this argument with only occasional lapses. Their hydrogeologist in 2006 suggested in writing that free phase DNAPL from the Chemtura site has flowed off-site onto a neighbour's property, where of course it has grossly contaminated their groundwater.

More on the rest of the meeting tomorrow.

PUBLIC CPAC MEETING THIS EVENING

This evening at 6 pm. in Woolwich Council Chambers will be the monthly Chemtura Public Advisory Committee meeting. For those unfamiliar the chambers are on the second floor and the Woolwich Township building is on Church St. across from the LCBO approximately one block from the major downtown intersection of Church and Arthur st.. While the Agenda looks pretty routine I expect there will be some very interesting moments nevertheless. I have a couple of questions for Chemtura about their November and december Progress Reports. I also will have a request for information/documents from the Ontario Ministry of the Environment. This request while routine will probably in all likelihood be denied or an answer delayed by the M.O.E..

Two other possible issues may revolve around the history of the north wellfield in Elmira and the process required in order to appeal the recent council decision to exempt a gas station from the prohibition on underground tanks near the former south wellfield. I've already sent an e-mail to Councillor Bauman asking him for input on this matter. He has also promised to give me this evening a copy of his speech to council in which he decided to be the only councillor voting against the by-law exemption. For this he deserves credit.

GRAVEL PIT APPLICATIONS JUST KEEP ON COMING

Today's Waterloo Region Record carrys this story "North Dumfries group has just eight weeks to make their case against gravel pit". They've apparently run into some snags with two expert witnesses no longer available to help their case plus their lawyer just resigned after their toxicologist was not permitted to testify due to procedural matters. Board Chair Jyoti Zuidema stated "Come hell or high water, the meeting is going ahead". She also stated "No more delays". Well I wonder how much time she will be taking when the hearing is over to render her decision. Here in Woolwich Township we had a month long hearing over the Hunder Pit located between Conestogo and Winterbourne. The hearing finished late last October and we are still waiting for the Decision from the Ontario Municipal Board.

I posted here in the Advocate how unfair, time consuming and expensive the entire process was, to all parties. Interestingly while the Hunder Pit has not named an operator, the latest new pit in Woolwich (Jigs Hollow Pit) just downriver a few hundred yards is a cooperative effort between Kuntz and Preston Sand & Gravel. Although there are many health and environmental reasons to object to a pit next to residential neighbourhoods my recollection is that economic demand and or need for a pit in that specific location is not even on the table. With 30 plus gravel pits already located in North Dumfries it does seem a bit unecessary for yet another. I sincerely hope this residents group have contacted Gravel Watch (Ontario) and received advice and tips as to what they need to bring to the OMB hearing.

TRAIN TANK CARS AND THE TRANSPORTATION SAFETY BOARD

Last Friday's Waterloo Region Record carried this story: "Safety Board: tank cars must be safer". Recent derailments include Lac Megantic, New Brunswick and even a minor derailment in Waterloo a year and a half ago. Of course there have been many more across North America in the last year but these three are the most serious and or close to home. Our local issue here in Woolwixh Township has been in regards to rail contents travelling through Kitchener-Waterloo and up to Elmira. I have mentioned here in the Advocate both Sulco (CCC) and Chemtura transporting dangerous cargos and last October I listed Chemtura's list of toxic chemicals by name.

What is astonishing is that the Transportation Safety Board (TSB) recommended "immediate action" in upgrading tankcars nearly twenty years ago and nothing has been done. This time they held a press conference in concert with the U.S. National Transportation Safety Board who believe there could be a "major loss of life" if new safety measures aren't taken. Besides stronger railcars the TSB also recommends twice-yearly track inspections, slower train speeds and track sensors to detect faulty railcar bearings. Of course these changes come at a cost and it seems as if both our industries and governments are keener to pay the costs after a catastrophe rather than before.

LESSONS ONTARIO & CANADA CAN LEARN FROM THE CHEMICAL SPILL INTO WEST VIRGINIA'S ELK RIVER

A local CPAC member e-mailed me this on-line report written by "Jon Devine, Senior attorney, Washington, D.C." . It is titled "What the West Virginia Chemical Spill Teaches Us About Clean water". First off the chemical involved is 4-methylcyclohexane methanol (MCHM) and not only have I never seen it before but I'm quite confident that it is a chemical that neither our Ontario Ministry of the Environment, nor our Region of Waterloo have ever tested for in groundwater, surface water or especially in drinking wells.

This report has four major recommendations all of which reflect current glaring weaknesses in our legislative protections. When I say "our" I mean all of North America. These weaknesses are not so much unintentional as they are the result of lobbying by chemical industries and their right wing political friends. The Republicans are particularily focused on south of the border but their Conservative counterparts here in Canada are of a similar mindset.

1) "Protect All of Our Waterways" The U.S. Clean Water Act apparently doesn't currently protect all surface water bodies that may eventually lead to water bodies supplying drinking water. Here in Ontario we give token protection only to rivers and streams running into the Grand River which supplys numerous downstream communities with drinking water. Our federal government have been missing in action here in Elmira in regards to the Canagagigue Creek and ongoing discharges into it. This also applies to chemical discharges into the Grand in both Kitchener and Cambridge, Ontario.

2) "Develop Spill Prevention Requirements for Chemicals Comparable to those for Oil" Oil proucts have numerous regulations regarding spill prevention and control whereas chemical facilities not so much. This I believe may actually be better handled here in Ontario. Things like secondary containment have been the standard for some time although enforcememt of tank farm maintenance is clearly lacking when one looks at groundwater contamination beneath and downgradient of chemical tank farms in Elmira, Ontario.

3) "Make Facilities with a Likely Release Accountable" There is a loophole whereby companies who do not have a regular discharge of hopefully treated wastewater are not required to have permits. A expanded permitting review is necessary for these facilities which only occasionally discharge or which are subject to discharge only during a spill incident. This report states that the current political climate in the Republican-led House of Representatives makes this expansion of regulations difficult or unlikely.

4) "Provide Adequate Resources to Inspect Facilities and Prosecute Lawbreakers" The company responsible for the chemical release in West Virginia are known as "Freedom Industries". They were apparently rarely visited by environmental officials. The West Virginia Department of Environmental Protection does not have a respected record of enforcement. Also the EPA due to budget constraints are looking at so-called "Next Generation Compliance strategies". This sounds suspiciously like Ontario's voluntary compliance system although the EPA call it more partnership with industry. "Rather than retreat on enforcement, Congress should fund, and EPA should invest in, enforcement approaches that have proven to curb pollution.".

The bottom line the world over is that even with enhanced environmental legislation, sympathetic "fellow travellors" can avoid enforcement through budget underfunding, intentional loopholes and political stickhandling even when polluters are caught redhanded. Constant vigilance by citizens of our political and environmental authorities is very difficult to achieve and they know it and continue to abuse it.

BOLENDER PARK LEGACY IN ELMIRA

Yesterday's Woolwich Observer advises us of the need for a new staff position in the engineering department. The title of Steve Kannon's story is "New staff position added as council approves engineering and planning budget". In hindsight what should not have been a surprise is the interesting information that there is a long-time gas collection system having been operated in conjunction with the Ministry of Environment. According to both the engineering department and our CAO Dave Brenneman there is hope that the methane gas collection system can be eventually decommissioned. The word "methane" is not in the article but it is by far the most common and most likely gas being emitted from this site and many other landfill sites.

The big falsehood put out there by municipalities and even the Ministry of the Environment is that methane is a direct result of rotting organic garbage. Organic as in food and vegetable matter. Hence they would have the taxpayers believe that methane is both natural and expected and more importantly solely the result of proper use of a municipal landfill. The truth is a little more complicated and examples abound. The Ottawa St. landfill (ie.McLennan ski hill) is an example in Kitchener. There the methane was so abundant that houses had to be abandoned and Canada Mortgage and Housing had to take possession. What is conveniently ignored is that industry were cheerfully dumping their solid (legally) and liquid (illegally) wastes into the Ottawa landfill plus any others they could get away with. There was a big scandal in the early 90's with the Region of Waterloo's lack of oversight as Varnicolor Chemical cheerfully dumped drums filled with solvents into both the Ottawa and Erb St. landfills, illegally.

Closer to home Bolender Park was a destination for some of Uniroyal Chemical's wastes at one time. Highly unlikely that Varnicolor also didn't take advantage of that opportunity. Just downriver from Bolender Park and Uniroyal (Chemtura) we had Varnicolor's infamous Lot 91. Now here is the smoking gun as far as methane gas being produced by industrial wastes and especially by liquid wastes. Severin Argenton dumped liquid wastes (solvents) en masse into this site. He also buried drums with both liquids and solids in them. He did however have standards. P.C.B.'s were OK but kitchen food wastes were not. There was no dumping of household, municipal type garbage. Yes there were chunks of concrete, steel re-bar and maybe the odd chunk of asphalt but no food waste. In the late 90's testing on Lot 91 was reported in our local papers. Methane gas was at explosive levels and council were advised by experts to never permit any kind of building on this site with a basement. My recollection of the explosive levels of methane gas were in excess of 50 parts per million. There is no methane collection system on this site. As with so much of our industrial pollution the "solution" is just to let it go. There aren't nearby homes or industries as there are closer to Bolender Park. In fact what there is is the former First St. Landfill where the Region's Transfer Station currently is. It's probably a source of methane and more in its' own right.

WOOLWICH COUNCIL REVERSES AN ELMIRA GROUNDWATER PROTECTION BY-LAW

Following is an e-mail that I sent to CPAC (Chemtura Public Advisory Committee), SWAT (soil, water, air & technical), the Elmira Independent, Woolwich Observer and Waterloo Region Record. It is in regards to a group of poorly informed councillors allowing underground fuel tanks within seventy metres of an excellent past wellfield and allegedly a possible future drinking water wellfield.



Today's Waterloo Region Record "Underground fuel tanks to be allowed at Elmira site". Many stated and unstated issues surround this decision. Firstly that the K-W Record even find it newsworthy that Woolwich Council have reversed a groundwater protection by-law is significant. Secondly the very tired and worn out claim that Elmira has these impervious clay barriers to drinking well contamination is hilarious. Let's see now, all the clay from Chemtura to the south wellfield didn't stop the south wellfield being contaminated plus every single aquifer throughout Elmira; however a tiny bit of clay (UAT) at the south end of town will do the job. P.S. there is no existing MAT or LAT by wells E7/E9. Thirdly the second last paragraph states "Officials say it's unlikely these wells would ever be returned to the drinking water system, even if groundwater is cleaned up by a 2028 deadline." Hmm, these wells are located in a very thick area of the MU and ML aquifers with abundant water available. Also our good friends CRA/M.O.E./Chemtura tell us the aquifers will be restored. Is somebody misleading the public here? Fourthly the second paragraph states "Woolwich Township councillors agreed Tuesday to lift restrictions prohibiting underground tanks... .". While it doesn't specifically state that Councillor Bauman voted in favour it appears that he did. Finally quite clearly is the fact that Woolwich Council put more weight on input from the likes of CRA, MTE, GRCA and the Region of Waterloo than on input from their own committee of council (CPAC) as well as representations from Susan Bryant. I view this as weak, uninformed minds depending on credentials; even the credentials of proven client driven consulting companies. That is a very sad state of affairs.
Alan

RAIL CONTENTS TRANSPARENCY STILL LACKING

To date Waterloo Region has been very fortunate in regards to having only had minor train derailments to date. The problem of course is that Kitchener, Waterloo, Cambridge and Elmira have and do ship some incredibly nasty stuff. Today's Waterloo Region Record advises us that while the Federation of Canadian Municipalities are pushing the Feds for better liability and cleanup insurance requirements; they are also on the secrecy bandwagon. It's kind of ironic and hypocritical to watch the municipailites yell at the railways and the federal government for transparency as to the contents of railcars while at the same time being perfectly satisfied if they are in the know while excluding those citizens living along the rail lines. The Record's story is titled "Rail disaster liability changes urged".

The Federation is appropriately requesting that all flammable goods be classified as "dangerous". After Lac Megantic this seems to be an obvious start. The one thing that I am reading into this article is the appearance that the municipalities may be more concerned about the financial implications to the municipalitiees rather than the probability of deaths and injuries. Yes improving the financing of cleanups is important but how about also pushing harder for stricter standards on the railcars as well as better monitoring of all safety aspects dealing with the transportation of dangerous cargo.

SAME DISGUSTING MESS BUT TWO DIFFERENT CLEANUPS

One of the reasons I find the time investment in studying other contaminated sites worthwhile, whether in Waterloo Region or even further away, is in order to gain perspective as to what are normal practices, normal cleanups etc.. Also I have often found amazing similarities in things like the responses and reactions of the public and of local politicians to contaminated sites. Industry as well have standard operating procedures in responding to accusations, allegations and even overwhelming proof of their behaviour having caused social harm.

Ciba-Geigy grossly polluted Toms River, New Jersey. So did Union Carbide albeit more indirectly. They had a middleman who took their drummed toxic wastes and illegally dumped them behind a farm. Then Union Carbide did the five minute cleanup at first leaving the bulk still in the soil. Later source removals of drums, contents and soil were much too late to stop a contaminant plume a mile long, 400 feet wide and 150 feet deep which impacted the Parkway Wellfield. Ciba-Geigy also did everything possible to avoid a proper cleanup including dumping their liquid toxic wastes directly into the Atlantic Ocean. Eventually they did excavate on site and use thermal desorption to clean their contaminated soil. This was after the Holly Wellfield was contaminated in the 1960's allegedly only by their direct dumping into the Toms River. I would very much like to see some hydrogeological evidence of the state of the aquifers between the Ciba site and the nearby Holly Wellfield. Personally I am skeptical as to the lack of evidence pointing to groundwater contamination rather than just the infiltrating Toms River getting into the Holly wellfield.

The Ciba site alone had a $92 million excavation and thermal desorption program. They also had 37 recovery wells on-site and nearby; pumping 2,000,000 gallons per day. This pump and treat AFTER source removal is to run from 1996 until 2025. Also the treated groundwater is not being dumped back into the badly abused Toms River, rather it is being reinjected on-site. In comparison Chemtura have done minimal source removal including the recent Gp1 & Gp2 surface dioxin & DDT removal. In November 1991 the Ontario Ministry of the Environment named specific readily accessible locations on their site which had DNAPLS (dense non-aqueous phase liquids) in the subsurface. Unfortunately the month previous the M.O.E. in a private Settlement gave Uniroyal an Indemnity for those very same subsurface toxins. The current pump & treat system comprises two on-site municipal aquifer wells and five off-site municipal aquifer wells for a total of less than half of what Ciba are pumping. Chemtura (Uniroyal) also dump their mostly treated groundwater into the badly abused Canagagigue Creek. The time frame here in Elmira is 1998 until 2028 allegedly.

Elmira, Woolwich and Region of Waterloo citizens were promised a real cleanup. Instead a conspiracy involving all levels of government was and is unfolding. Chemtura toxins continue to leak and move off-site whether by groundwater, STP discharge, surface water discharge and air discharge. This is the Elmira cleanup and it's taken serious, secret negotiations between government and Chemtura to make it so. The losers are the environment and the health of citizens.

CHEMTURA CANADA PROGRESS REPORT - DECEMBER 2013

Firstly with the recently reduced pumping rate at pumping well W4 (11.4 down to 3.5 l/sec) both the on and off-site pumping/extraction wells met their target pumping rates for December. The Containment and Treatment System (CTS) discharge effluent all met their Effluent Limits although both nitrosomorpholine (NMOR) and Toluene exceeded their Effluent Objectives.

We are advised on page four that a new well (OW171) has been drilled northeast of W4 and that both soil and water samples have been taken. There isn't much point in drilling a well if you aren't going to sample it and likewise advising us that you've done so but not providing the results is a little strange. Is this going to be but yet another example of non cooperation between Chemtura, their consultants and CPAC or are they going to provide the sample results at the upcoming public CPAC meeting(Jan. 30/14) ?

We are advised on page five that there was a loss of containment at one of the upper aquifer wells during December. This system (UACTS) is to keep the groundwater levels below the surface water levels of Canagagigue Creek hence stopping contaminated discharge into the creek. Table A.3 gives us the concentrations of numerous chemical compounds within the groundwater. The two most outstanding ones were Toluene and NDPA (nitrosodiphenylamine). Toluene concentrations varied with 30,000 , 110,000 , and even a ridiculous 780,00 ppb. NDPA varied from 8,300 to 18,000 ppb. NDPA is simply DPA (diphenylamine) combined with a nitroso molecule. DPA is also known as benzidine and been a known cause of bladder cancer for decades.

Attachment B gives us information regarding what are known as MISA discharges. MISA stands for Municipal industrial Strategy for Abatement. These are allegedly surface water discharges from Chemtura into the Canagagigue Creek. Unfortunately they also pick up infiltrating contaminated groundwater. Unfortunately over the decades there has been very little improvement in the quality of these discharges to the creek. Lindane, ammonia and carboxin are examples of this neverending small quantity discharges.

Attachment E deals with a set of off-site sentry wells that Chemtura use and abuse (the data). Figure E.4 is especially egregious as it purports to show a decreasing trend in both Chlorobenzene and in NDMA. The trend is very slight whereas the actual concentrations are remarkably high for both chemicals, twenty-four years after Chemtura's (Uniroyal) pollution was finally proven to have destroyed our local water supply.

All in all a remarkably glib, superficial and all is happy monthly "progress" report again.

A WHO'S WHO OF HYPOCRITES

Last Friday I posted here that I would be taking Councillor Mark Bauman to task at a meeting this Monday morning in regards as to whether he voted in favour of or against underground gas tanks on Earl Martin Drive next to the former south wellfield. Well the discussion proved to be very interesting. While Woolwich Council had received advice against permitting an exemption to their by-law prohibiting underground gas tanks around the south wellfield from both CPAC and Susan Bryant; they had a who's who list of folks speaking in favour. CRA were mentioned. Their hypocrisy is relatively minimal as they are front and centre bought and paid for consultants to Chemtura Canada. The Region of Waterloo, MTE and the Province of Ontario are a little different. I'm going to go out on a limb and suggest that MTE might be speaking on behalf of their client who wishes to have underground fuel tanks. Fair enough. The M.O.E. are involved via legislation after the Walkerton Inquiry to be promoting Source Protection Plans for municipalities. This has included paying municipalities to assist them with costs involved in protecting groundwater. The Region of Waterloo are beyond the pale. Their hydrogeologist apparently has advised Woolwich to go ahead and bury gas and diesel tanks next to the former south wellfield. Keep in mind the official position from the Province and Chemtura is that Elmira's groundwater will be potable by 2028. Therefore burying fuel tanks less than 100 metres away is insanity.

After listening to Councillor Bauman's explanation of all the advice that Council received; while the decision is still a bad one, at least one can better understand the reasoning behind it. CPAC to their credit all advised, challenged and hopefully persuaded Councillor Bauman to rethink his position. Woolwich Council years ago took the proactive step of prohibiting underground fuel tanks near the south wellfield after they lost their local water supplies to manmade contamination. Making exceptions/exemptions to that prohibition is very bad environmentally and contrary to all that we've learned since the Elmira and Walkerton disasters.

SAME WOOLWICH COUNCIL - DIFFERENT RESULT

Now that's timing. Yesterday's Woolwich Observer advises us that Woolwich Council have agreed to a one time funding of $10,000 to the Chemtura Public Advisory Committee (CPAC). Furthermore it seems that Councillor Mark Bauman has been responsible for extracting these funds for CPAC. CPAC need to be able to hire independent experts or peer reviewers to counter the hopelessly client driven reports coming from Chemtura's long time consultants. Councillor Bauman also called upon Chemtura and especially the province of Ontario to match the municipality's contribution.

While I am in agreement that this funding is a very good thing, there has always been an unfortunate side to relying strictly on professional peer review and criticism. Citizens are more than capable of common sense and in understanding consistency in the pronouncements of Chemtura's "experts". The problem is one of credentialism. CPAC members have been right on the money with their understanding of the utter failures of Conestoga Rovers plans, decisions and frankly wishful thinking around the cleanup of the Elmira Aquifers. This problem of credentialism is basically the ignorance of politicians on any of these matters and thus rather than having to learn and think for themselves they'd rather rely on credentialed experts. Hence while the citizens who put in the time and effort become discriminating enough to sieve the wheat from the chaff; the politicians simply aren't, can't or won't.

This is not to criticize a good thing here. Councillor Bauman if I'm going to take you to task for your occasionally playing both sides of the fence and occasionally supporting Chemtura and the M.O.E. inappropriately, then I will also sincerely congratulate you when you get it right. Well done on this Mark Bauman.

WOOLWICH COUNCIL GETS IT WRONG AGAIN

Yesterday's Elmira Independent has a story titled "Tanks Approved". This is a very disappointing and short sighted decision by our Council. Appropriate concerns were raised by resident Susan Bryant at Council which should have caused Councillors to give their heads a shake. A further reminder should have been the $30,000 in Source Water Protection money they recently received from the province. Finally here in the Advocate the reasons not to put buried tanks beside the former, and who knows absolutely, perhaps future south wellfield were posted on November 8/13 and December 24/13.

The Independent article states "Conestoga Rovers & Associates, the consulting firm that works with Chemtura indicated that any leakage, if it were to occur, would have no impact on the cleanup of Elmira's groundwater." "No impact" is unadulterated rubbish. Ask the village of Bamberg if leaking gasoline affected their groundwater. Ask the village of Heidelberg who have watched a decade of ongoing remediation trying to cleanup gasoline and diesel from our former Mayor's gas station. Ask Chemtura (& CRA) how sucessful they have been removing LNAPL ie. light non aqueous phase liquids from their groundwater. The components of gasoline namely Benzene, Toluene, Ethyl Benzene and Xylenes are known as LNAPLS as they float on the surface of the groundweater.

Kind of ironic isn't it how Chemtura advise the Chemtura Public Advisory Committee (CPAC) how difficult it is to remove LNAPL from their site but how there will be "no impact" if it leaks beside the former south wellfield. And our council are just plain stupid to believe CRA. My question is what did Councillor Mark Bauman advise council to do. I will see him Monday at a working session of CPAC and if he vouched for CRA's consistency or accuracy; he will hear and read about it.

MORE ON ELMIRA'S LONG GONE NORTH WELLFIELD

The first Saturday of this month I posted here in the Advocate an article suggesting that Elmira's north wellfield may have been contaminated for many years prior to NDMA being found in the south wellfield in November 1989. Two other points should be added to that analysis. Firstly the south wellfield has been pumping to waste for over twenty years now. The rate is 26.5 litres per second which translates to about 300 gallons per minute or 18,000 gallons per hour or 432,000 gallons per day. This treated waste discharges into Landfill Creek and then into the Canagagigue Creek. If the north wellfield was not drawing contaminated water from Uniroyal/Chemtura due to the majority of the plume moving southwards via both natural groundwater direction combined with major southern pumping; then there would be no reason not to use these northwern wells to at least augment our water supply. Lest we forget Elmira's population has dramatically increased at the same time as the whole Region of Waterloo have been on lawn watering restrictions for many years. We need the water and I'm sure Waterloo who have been supplying us with their water for many years could use that water themselves. Secondly there is a water supply method variously referred to as "musical chairs" and or as "whac-a-mole". The latter expression is on page 240 of the book "TOMS RIVER" by Dan Fagin. The former is one I've used in reference to the games I see occurring with Cambridge's drinking wells. Essentially one either dilutes a contaminated well with other cleaner wells or one takes turns pumping multiple wells until the contaminant plume has been drawn towards the current well(s) being pumped. Those wells are then shut down and others started up thus pulling the plume back towards themselves.

This second method as stated I believe I have seen when looking at drinking wells being shutdown for weeks and months or longer in Cambridge, Ontario. Then they are started up and other wells shut down for extended periods. In the case of Toms River, New Jersey the water company with state and municipal knowledge played that game with Trichloroethylene (TCE) without advising their citizens and customers. In a nutshell if one set of politicians can persuade themselves that their citizens don't deserve the truth or they might correctly interpret this game as a desperate ploy to avoid accountability for water pollution then another set here in Elmira could have done the same.

DO YOU REALLY THINK YOUR TAP WATER IS SAFE?

Do yourselves a favour this spring when the Region of Waterloo releases their Annual Drinking Water Report. Order yourself a copy or download it from on-line. Our local paper usually carrys an ad from the region each spring both advertising this report as well as bragging about how good the drinking water is.

First off every year there are detections of low level solvents in various wells primarily in Kitchener, Waterloo and Cambridge. These chemicals (usually TCE) are typically below our Ontario Drinking Water Standards. They are however not necessarily below the standards of other jurisdictions especially the U.S.. Secondly the list that the region (& other jurisdictions) test for are not extensive. Add them up and see if you even get 100 industrial chemicals being tested for. This figure isn't so hot when you realize that every single year hundreds of different chemicals are being discovered and or produced in labs across the country. Finally check to see if NDMA is on the region's list. It has been found in the past in cambridge drinking wells and to this day Elmira's wells are shut down because of it. Then start looking for ubiquitous chemicals from leaking gas station tanks. Things like benzene, Toluene, Ethyl Benzene and Xylenes. Are they routinely tested for and the results published? i don't think so.

I have recently read a book titled "TOMS RIVER" written by Dan Fagin. This book describes horrific pollution in Toms River, New Jersey courtesy of Ciba-Geigy and indirectly Union Carbide. The National Toxicology Program (U.S.) "Report on Carcinogens" in 2011 lists 246 compounds that are carcinogenic alone. Pg. 519 footnote #10. Cancer is but one end point of toxins in our water. Of these 246 compounds how many of them are being routinely tested for and reported by the Region of Waterloo?

The Parkway Wellfield in Toms River had 122 unidentified industrial compounds in it unrelated to what they were looking for, namely styrene acryloniterile trimer (SAN). Pg. 381 See if you can find SAN much less the unidentified compounds in the region's drinking water testing.

"Still others seemed to be new molecules that formed when compounds mixed during their mile-long underground journey from Reich farm to the wells.". Pg.379

Maybe our drinking water is safe. Personally I doubt it and if either the province or the region want to prove it is, they've got a long ways to go.

A COUPLE OF CHEMTURA'S TOXIC CHEMICALS

Last October over a four day period I listed chemicals which Chemtura have been recently using in various production processes. Many of these are common everyday solvents or other chemicals whereas there are also a few more unusual ones. Keep in mind that whether tested for in surface water, groundwater, drinking water, soil or air; none of them are rated as health hazards in combination with each other. Each and every chemical compound has its' health effects determined individually. This of course completely ignores the reality of multiple simultaneous exposures and probably greatly reduces the apparent toxicity of air, water and soil releases.

Aniline also known as aminobenzene is ubiquitous on the Chemtura Canada, Elmira, Ontario site. We have been advised over the years that it was dumped in lowlying areas along the creekbanks of the Canagagigue creek. The purpose was to elevate the creekbanks and reduce annual spring flooding in and around the production buildings.

Diphenylamine is commonly found in air and water discharges. It is also found in another form in groundwater and that is as NDPA or nitrosodiphenylamine. Its' more famous cousin is NDMA. Diphenylamine has another name and that is benzidine.

Styrene is discharged into air and water and indeed was found in the south wellfield at low concentrations in 1989. Styrene is considered to be a carcinogen. It is also a component of styrene acrylonitrile trimer also known as SAN.


"...in 1921, the Geneva-based International Labour Office had examined the accumulating evidence about dye manufacture and bladder cancer and had identified benzidine and BNA as the most likely suspects, urging manufacturers to adopt "the most rigorous application of hygenic precautions."". Pg 182 TOMS RIVER by Dan Fagin

As mentioned in yesterday's posting "aniline tumours" were recognized as long ago as 1895 in Germany. They were diagnosed as bladder cancer.

Science and medicine are not remotely magic bullets. Causation of illness is way down the list of priorities for our health care system. The science of epidemiology is still in its' infancy. Occupational settings have been thoroughly and sucessfully investigated and science has been able to pinpoint specific chemicals and specific illnesses. As per the overall theme of "TOMS RIVER" however it is much more difficult to pinpoint either air or water sources hundreds of metres oe even a couple of miles away and then categorically say that 1) there is a disease cluster at such and such a confidence level and then say that 2) categorically this company and this improper disposal location and this chemical have caused this illness in the population. Corporate polluters have long hidden behind this feebleness of epidemiological studies.

"HISTORIC POLLUTION" THE BATTLE CRY OF THE UNREQUITED POLLUTER

Uniroyal Chemical claimed it and still does. Varnicolor Chemical did not. Ciba-Geigy in New Jersey and Breslube/Safety-Kleen in Breslau both claimed it was so. The big lie is that science, government and industry didn't know it was dangerous to bury toxic wastes in the ground. This excuse covers both liquid and solid wastes in the 1940's, 50's, 60's and even 70's. A couple of years back I presented as a Delegation to the Chemtura Public Advisory Committee (CPAC) in which I gave a brief history of toxic waste disposal in Europe back at the turn of the century. That would be the turn from the 1800's to the 1900's. Following are some more details including direct river discharge.

Basel Switzerland 1865- "The city also sued Muller-Pack on behalf of the poison victims. In March of 1865, after eight months in court, he was found guilty of gross negligence. Muller-Pack was ordered to pay a large fine and compensate the victims as well as nearby property owners for the loss of their property values. He even had to deliver clean drinking water to the neighbourhood." Pg. 15 TOMS RIVER by Dan Fagin

"Even more ominously, physicians were noticing a new kind of illness they called "aniline tumours"." "In 1895 he diagnosed bladder cancer in three of of the fourty-five dye workers he examined...". "By 1906 he had documented thirty-eight similarily stricken workers in Frankfurt, and other doctors in Switzerland and Germany were making similar observations." Pg. 17 TOMS RIVER

"...the fouling of one of America's great rivers (Ohio) became a regional scandal and the subject of four congressional hearings between 1936 and 1945." Pg. 20 TOMS RIVER

The big pharmaceutical and dye companies started in Germany and Switzerland in the mid to late 1800's. They buried wastes on land and then they dumped them in the Rhine and other rivers. They moved to North America both to avoid their domestic tariffs as well as to be able to start over and pretend they had no knowledge of the death and mayhem their wastes caused. From big cities like Cinncinati they moved on to smaller more rural areas like Toms River, New Jersey. Here in Canada they operated locally in Kitchener-Waterloo and Cambridge in textiles, dyes, pesticides, rubber additives etc.. Moving to small towns like Elmira was a natural. Jobs were needed and local politicians were naive at best and wilfully blind at worst.

HEIDELBERG GAS STATION CLEANUP CONTINUES

I posted here in the Elmira Advocate some concerning news way back on July 31, 2012 . I had been examining via the Region of Waterloo website plus other documents the distribution and source water systems for Heidelberg Ontario. Heidelberg is indeed part of Woolwich Township whereas their neighbour St. Clements are part of Wellesley. My concerns were raised both from verbal information I had received as well as by a site visit I made to the former gas station located on the main intersection of Heidelberg.

Well today I received more information which confirms that which I had suspected from my site visit. The original leakage was bad enough that there was and is free product gas and or diesel fuel floating on the surface of the water table. While this may not be an extraordinary situation for a former gas station; my concern is for both the local drinking wells as well as for possible vapour intrusion into homes literally located just across the street from the station. After all these years I sincerely hope that the Region of Waterloo have found an alternate source of drinking water as any in town wells probably aren't that far away. Secondly while I had to doublecheck my data it does appear that gas and diesel components are indeed volatile and hence could volatolize into a gas. Particularily benzene, similar to past issues in Bamberg Ontario, would be a concern.

ALLEGED FUEL TANK ISSUES ADD TO SEWAGE SPILLS AND BYPASSES

I have on a number of occasions here in the Advocate given the stats for sewage spills and bypasses from various Waterloo Region sewage treatment plants. Add to that occasional alleged fuel tank spills from vehicles and it becomes a horrid way to treat our national heritage river, the Grand. Most recently (yesterday) we are advised of a 100 litre spill of diesel fuel into the Speed River in Guelph. Interestingly there was also a 200 litre spill of diesel fuel from a truck with a ruptured tank in December 2012, also in Guelph and into the Speed River. The Waterloo Region Record story yesterday is titled "100 litres of diesel spilled into Speed River, officials say". What I find very peculiar is the claim in yesterday's paper that "...an unknown vehicle's fuel tank burst, provincial and city officials have confirmed.". The vehicle a year ago hung around and fessed up. This time it's an "unknown vehicle" so how does anybody know its' fuel tank burst or that it was even from a vehicle? Diesel fuel can be used in all kinds of construction equipment, generators, heaters etc.. Perhaps our "provincial and city officials" are being just a tad less than transparent here?

JUXTAPOSITION OF TWO RESOURCE/ENVIRONMENTAL ARTICLES IS HILARIOUS

Today's Waterloo Region Record has a story on page A3 titled "CN Rail chief calls for tighter regulation after latest incident". They also have an opinion piece by Gwyn Morgan in the same section titled "Investment in resources being stymied by vocal minority". The opinion piece by a self professed business leader and director of five global corporations is filled with exaggerated right-wing rhetoric including "environmental zealots", "strident knee jerk opposition" and my favourite "Canadian environmental standards rank among the world's best". Sorry Gwyn but I've been dealing with federal and provincial environmental standards and regulatory bodies for almost a quarter of a century and they rank with the world's most hypocritical and incompetent.

The first article decribes yet another train derailment, this one in New Brunswick. Yes it also involves crude oil and it is on fire. There will be nasty air pollution and most likely nasty groundwater pollution unless things are frozen enough that they can clean it up before it soaks into the ground. Interestingly the rail companies, politicians and other stakeholders are all clamoring for both U.S. and Canadian regulators to step up and demand improvements to rail cars being used to transport hazardous chemicals including crude oil. These regulators of course include those that supposedly are enforcing some of the world's best environmental standards. Maybe not so much afterall Gwyn.

WOOLWICH BIO-EN CLC MEETING

Last evening in the Woolwich Recreation Centre the Citizens Liason Committee meeting took place. Earl Brubacher, as usual chaired, and there was considerable discussion around construction and ongoing inspections. There is some remaining work to be done with painting, piping, electrical work, the water tower and the gas dome. That said nevertheless things are primarily on schedule. There was a long listing of all the various bodies involved in inspecting the new building and processes including the TSSA, CSA, the Township, MOE, Hydro 1, Waterloo North Hydro, Ontario Power Authority, and even the CFIA among more.

There was discussion in regards to the two operators who will be doing the bulk of the work when things are up and running. Their training has been quite extensive including expert instruction by other skilled operators. January 10 will be the formal commissioning day for the plant. While the digester takes two or three days to fill and fifteen days to heat it probably won't be until May that the methane content is high enough to actually begin burning it to produce electricity.

There was some discussion surrounding the committee's unsucessful attempt to get funds from the township for future possible peer reviews or other technical reviews. Chuck Martin interpreted Council's negative response as them requiring more specific dollar values for specific clearly stated technical projects. Chuck will make inquirys as well as to the mechanics of setting up a Letter of Credit. Bob (Gray?) asked about berming or trees between Woolwich Bio-En and the neighbours. Apparently our recent storms took a significant number of trees down that were assisting in that capacity. Earl suggested that there are some berms and possibly trees already included in the final grading/landscaping plans for the site.

Hindsight being 20-20 when they were discussing costs for consultants for technical reviews I should have suggested they contact Dwight Este or Jeff Merriman of Chemtura for some ballpark figures. Chemtura over the years have funded CPAC to hire the odd consultant here and there such as RWDI, air experts out of Guelph, and most recently Dr. Gail Krantzberg from McMaster University.

The next public CLC meeting is on Tuesday March 4, 2014 at 7 pm. I presume it will be back in the new (& recently repaired) Rec Centre.

PUBLIC MEETING OF WOOLWICH BIO-EN THIS EVENING

The venue for this evening's meeting will be the Woolwich Rec Centre and the time is 7 pm.. Bob Jonkman's Stop The Stink website has the Agenda for this evening. Back in November we had been advised that late January was their proposed startup but whether that has been affected by the incredible weather of the last few weeks I don't know. This meeting is part of the negotiated settlement with the Environmental Review Tribunal and involves the Citizens liason Committee and the company meeting on a regular basis. The list of citizen participants is again on Bob's website.

I personally have attended several meetings and have been very impressed with the willingness of all participants to be straightforward and honest. This bodes well if there are any operating problems in the future as the good will being currently generated should assist in helping to amicably resolve any future issues. As a veteran of the Chemtura/CPAC wars I can advise that the Bio-En meetings are night and day different. The company appears genuinely responsive and responsible and unlike their Chemtura counterparts, Woolwich Bio-En give every impression of not trying to hide awkward or difficult news. Kudos to them.

CHEMICAL COMPANIES DECEIVE AND GOVERNMENT OVERSIGHT IS WEAK

I'm currently reading "Toms River" by Dan Fagin. This book chronicles the horrors of chemical pollution that occurred in Toms River, New Jersey from 1952 onwards. The leading polluter was Ciba-Geigy with only honourable mention to Union Carbide who allowed their toxic waste in drums to be removed by a small entrepreneur whose idea of hazardous waste disposal was to surrepticiously bury drums illegally at the back of a local farm. Yes this is the same Union Carbide who were responsible for 8,000 or more deaths in Bhopal, India in 1984. Yes this is the same Ciba-Geigy now known as Novartis who falsely claimed that they'd had but a single spill of Dinoseb on their property in Cambridge, Ontario back in the 90's. They also claimed a year or two prior to their chemicals being found in the deeper municipal aquifer that it would take a hundred years for their chemicals to reach that deep due to a wonderful clay aquitard inbetween. Not surprisingly both municipal and regional governments did not dispute this nonsense. Nor of course did the Ontario Ministry of the Environment. Yours truly estimated ten years was a more likely scenario and I overestimated by about eight years. Shame on me.

I have previously read books such as Chemical Nightmare (Jackson & Weiler), A Civil Trial (TCE in Woburn, Massachutsets), Silent Spring (Rachel Carson) and far too many hydrogeological reports for the Northstar Aerospace contamination in the Bishop St. community in Cambridge, Ontario. The rest of the list here in Waterloo Region is far too long to enumerate now. There are however so very many commonalities. Firstly polluters lie like dogs. Secondly they have ingratiated themselves into the community both with jobs, charitable donations and political involvement. Thirdly they are invariably insulated, supported and protected from legitimate criticism by the local power structure. Afterall they pay taxes and employ locals. Fourthly the provincial/state environmental authorities lack serious enforcement capabilities. Again they are the creation of these same political bodies who are very long on appearance and very short on seriousness. This lack of seriousness includes intentional inadequate budgets as well as managers who do as they are told by the heads of their agencies and their political masters.

Pollution is simply a form of corporations externalizing their costs. In other words a corporation has a competitive advantage when they can either minimize their waste disposal costs or even essentially reduce them to zero. They do this by inflicting their relatively initial small waste disposal costs upon society who end up paying much greater costs through remediation, health and environmental damage. This infliction upon society is usually done with typical CIA "plausible deniability". We (the polluter) didn't know. We didn't intend to hurt anybody/anything. Generally speaking these claims aren't even good enough to be called wishful thinking. They knew even back in the 60's because some of them have pollution histories going back to the turn of the 20th century. Companies like Ciba polluted in Switzerland, Germany and other European countries before coming here. There is a pattern of geographical industrial/chemical pollution starting in Europe progressing to North america and then moving on to Asia and third world countries around the world. It's all about lower labour costs as well as much lower or zero environmental costs. The chemical industries sins have caught up with them wherever they operate. They however and their supporters think that they can reinvent the wheel each and every time they relocate. They feel they somehow deserve the benefit of the doubt simply because they have moved. And the whole disgusting, lieing, deceiving mess starts anew.

There are companies who adhere honestly to the tenets of the Chemical Industry Association of Canada (CIAC). There are many who do not and they are members nevertheless. For them it's essentially nothing more than public relations. The CIAC allow recalcitrants in their midst on the hope that being "under the tent" is better than not. They hope that the likes of Chemtura for example will improve simply by rubbing shoulders with more ethical and honest companies.

Last but not least is the effect of support from the local power structure here in Elmira, Ontario. This includes the likes of former Woolwich councillors sitting on Sulco's (CCC) citizens liason committee. Ruby Weber and Pat McLean sucessfully lobbied to remove comparisons with Chemtura in a *Responsible Care study written by a Mcmaster University graduate student. His draft report for the CIAC basically pointed out how superior Sulco (CCC) were to their neighbour Chemtura as far as following the rules and spirit of *Responsible Care. His final report sadly dropped that comparison.

HYPOTHETICALLY SPEAKING

Here in Elmira, Ontario I have a list of my ten favourite lies that the public have been told about our groundwater contamination caused by Uniroyal/Chemtura (& others). These lies are from the partners in pollution namely Chemtura and the Ontario Ministry of the Environment. Perhaps an honourable mention should go to Chemtura's devoutly client driven consultants, Conestoga Rovers, as well. In a sense CRA could be viewed as more of the bad guy as they are often the spokespersons for Chemtura on either contamination or "cleanup" issues. Or one could argue conversely they are merely doing their duty to their client, Chemtura.

Regardless of the varying culpability in matters incredible; what can be confidently stated is that from time to time over the last twenty-four years, here in Elmira, we've repeatedly been fed a diet of farm animal manure. These expressions of unlikely truths have destroyed our naivite and forever obliterated our blind trust in government or corporate ethics. Therefore on that basis I am prepared without guilt, remorse or further thought to present a possible nasty or even downright horrible scenario for the contemplation of Elmira Advocate readers. I emphasize at this point in time the evidence for this scenario is thin and circumstantial at best. Nevertheless here goes.

My recollection is that the north wellfield in Elmira was drilled in the 1940's and 50's with possibly one well as early as the 1930's. The south wellfield in contrast was drilled in the early to mid 1970's. The south wellfield was shut down in November 1989 allegedly upon the discovery of a highly carcinogenic compound, NDMA, in wells E7 & E9. What received spectacularily short shrift were the other toxic industrial compounds already known in these two wells namely cyclohexylamine, xylene, styrene and perhaps even a dash of toluene. NDMA was the biggie and the alleged thunderbolt requiring emergency shutdown. Again my recollection is that the north wellfield (E2, E5, E5A, E8) kept on supplying water until it too became contaminated with NDMA, allegedly. The interesting point is that after the south wellfield, one mile away and hydraulically downgradient from Chemtura was shut down; it only took approximately a year for the plume to be drawn into the north wellfield thus shutting it down as well. Keep in mind that the north wellfield while technically upgradient from Chemtura is only a few hundred yards/metres away.

So the north wellfield was pumping water for the drinking pleasure of Elmira citizens from Uniroyal Chemical's start in Elmira during the second World War until it was shut down in the very early 90's. The multiple contaminant plumes were shifted southwards after 1970 once the south wellfield was pumping and drawing these plumes towards themselves. All it took was between fourteen and nineteen years to royally bugger the further away south wellfield, thank you very much Uniroyal Chemical. All it took was approximately a year of the south wellfield shut down to royally bugger the north wellfield, thank you very much Uniroyal Chemical.

So here's the question. 1940's until 1991 the north wellfield was pumping. Half a century of pumping with only fourteen to nineteen years of the south wellfield drawing contaminated groundwater away from the north. Shut down the south in 1989 and in a year or so the north is contaminated with NDMA. DOES ANYBODY SERIOUSLY BELIEVE THAT THE NORTH WELLFIELD WASN"T CONTAMINATED LONG BEFORE 1991 ???? Do Elmira citizens believe they were drinking clean water during the 50's, 60's and 70's??? Do Elmira citizens remember the taste and odours in their drinking water in the late 70's and 80's???

In Tom's River New Jersey, Ciba-Geigy contaminated the drinking wells in the mid 60's. The public did not find out the truth about that for a quarter of a century. Are Canadian corporations and governments inherently more forthright and honest than American ones? Call me skeptical.

WOOLWICH TOP NEWS STORIES IN 2013

O.K. to clarify the title I'm actually only going to refer to local environmental news stories in Woolwich Township. Also I'm going to focus on those presented in the Elmira Independent versus those in the Woolwich Observer. The reason is that to my consternation the Woolwich Observer almost completely ignore any Chemtura or CPAC news. The exception is when either of these subjects occur publicly at Council meetings. Therefore while there are several references to Chemtura newsworthy items in the Independent, there are zero in this year's Observer. Do not get me wrong. I read both papers religiously every week and have great respect for Steve Kannon's opinions/editorials. It goes without saying that the Independent's commitment past and present to informing the community on Chemtura/CPAC issues has been nothing short of fantastic.

Gail Martin of the Independent reminds us of the controversy surrounding Chemtura's receipt of their *Responsible Care verification back in the spring. Also she advises us in May of the rediscovery of DDT (& Dioxins) downstream in the Canagagigue Creek. In June residents were told of Chemtura's plans for off-site source removal via In-Situ Chemical Oxidation (ISCO). In July Gail reported that the hydrogeologist for the Ontario Ministry of the Environment (M.O.E.) had serious concerns as to whether Chemtura's more aggressive cleanup plans couls do the job by the 2028 deadline. In October (2013) we again saw M.O.E. tests indicating higher than expected DDT levels in the downstream (from Chemtura) Canagagigue Creek. At the end of the month the Independent reported the problems that Chemtura were having with ISCO "...after two potential test sites fell through.". Finally in December 2013 the public learned that the cleanup target of Elmira's groundwater by 2028 is very vague. There are no hard numbers, no lists of chemicals and especially worrying not even a clear definition as to which aquifers must meet the drinking water standards mandated for 2028. Or are they mandated by today's standards? Who knows?

In passing, the Independent's (& Observer's) Year in Review also includes other local environmental issues such as the Woolwich Bio-En gas plant as well as local gravel pits; including West Montrose, Jigs Hollow (Winterbourne) and the Hunder Pit (Conestogo).

A BRIEF OVERVIEW

The east side of Elmira along Union St. used to be called the mini chemical valley. This was a reference to the much larger petrochemical valley in and around Sarnia, Ontario. Every five or ten years there will be a media update on how things are going in that area. Overall there is only one direction and it is a negative one. The air is bad, the groundwater is bad and local residents have a plethora of varying health issues. One of the most recent is in regards to the imbalance in gender of newborn babies.

The companies along Union St. at one time included Uniroyal (Chemtura), Nutrite (Yara), Sulco, Varnicolor Chemical, Borg Textiles. Procast (Linkbelt) was located just a block or two to the west of Union St. All that is left of those would be Sulco and Chemtura. Apart possibly from zoning the question might be why were they all located on the east side of town. The answer has to do with air and water. The prevailing winds here are from west to east hence any smelly industries on the west side of town would share their odours constantly with the rest of town. Secondly companies discharging coloured air emissions would be all too easily seen by the whole town if they did so from the west side. This of course can be mitigated with night time emissions which has been used by both former foundrys further south (Bonnie Cresent) as well as those which harassed the "Duke St. rowdies" in the late 90's, courtesy of Uniroyal (Chemtura).

The other reason for location on Elmira's east side has to do with the presence of Canagagigue Creek. Keep in mind summertime flows used to be extremely low hence the building of the Floradale (Woolwich) Dam in 1974. This provided a steady flow of water helping to dilute Uniroyal's (Chemtura) contaminated groundwater emissions. Also quite obviously the building of the Elmira Sewage Treatment Plant in 1965 was on the east side, also for odours as well as for treated effluent discharge to the creek. I do not know whether Sulco or Nutrite used the creek for toxic discharges although certainly Nutrite's ammonia shallow groundwater contamination must have discharged there. Similarily Varnicolor Chemical had both a sophisticated as well as a blatant dumping operation going on, on their former Lot 91 at the extreme east end of Oriole Parkway. Finally there is Borg Textiles. My suspicion is that they got away with environmental murder without ever getting caught. These suspicions are based upon documentation from the Grand River Conservation Authority back in the 80's identifying them as having knocked out the bacteria in the Sewage Treatment Plant with their toxic discharges. Finally jugs of Hoescht Dyes have been found in an unusual dumping location in Woolwich Township. Last but not least is the inherent nature of the textile and dye industry. Dyes are synthetically manufactured from various coal tar components. I would very much like to hear from former Borg Textile employees in regards to any on-site liquid waste water treatment etc..

And there it is. Small town Elmira was at one time a virtual hub of chemical manufacturing and useage. By the way there were other textile industries besides Borg in town. They have been long gone for a very long time. It is my belief that some of these industries along with leaking gas stations have added to Uniroyal's permanent "enrichment" of our soil and groundwater.