AUGUST 26/07 CRITIQUE OF CRA'S DNAPL INVESTIGATION REPORT

There have been many different critiques of Conestoga Rover's various DNAPL plans and investigations during the last twenty years. They have included critiques by APT Environment, the Elmira Environmental Hazards (EH) Team, the Soil & Water sub-committee of CPAC, Citizens Environmental Consulting, the Region of Waterloo and the Ministry of the Environment. Yours truly has been involved in the researching and writing of many of these including APTE, EH-Team and the Soil & Water sub-committee.

By August 26, 2007 I had had way more than enough of CRA's blatant bullshit. They would receive serious critique's and sometimes respond to them clearly and competently. Other responses were simply for show so that at a later date they could say "See we responded to each and every point of concern" when in fact they did no such thing. My critique of August 26, 2007 was the culmination of a years long coverup of DNAPL issues by Chemtura and CRA. That critique was harsh and included terminology such as client driven, nonsensical, misleading, misrepresentative, psuedo science, deceit, falsehoods and bullshit. It also included however a grand total of nine pages of referenced, specific criticisms of their so called investigation. It quoted passages from their report as well as passages from the Region of Waterloo's critiques and the other critiques mentioned above. A face to face meeting with Doctors J. Cherry and B.Parker from the University of Waterloo giving their world renowned opinions and positions on DNAPL was included.

I have just reread my August 26, 2007 nine page report. I stand by every word and criticism of CRA's DNAPL Report. While CRA reference various comments/concerns from the other parties above in their reports, they have never acknowledged or responded to this one. They have responded to Soil & Water critiques, APTE and others but never to this most specific, targeted assault upon their client driven, junk science DNAPL Report.

Also having recently read Jaimie Connolly's May 2, 2008 letter giving comments upon CRA's August 2007 DNAPL Report has been an eye opener. Wheras Wilf Ruland (CEC) has occasionally written critiques a few weeks after M.O.E. critiques, borrowing heavily from them (April 21,2006 & May 15,2008) ; my August 26/07 critique supercedes Jaimie's by eight months. Jaimie raises exactly the same criticism of CRA's Effective Solubilty calculations in his report as I did eight months earlier. Perhaps this alone is embarassing to CRA. Afterall it does not suit their purposes to ever have to acknowledge that there is a citizen knowledgable enough on DNAPL matters to pick out flaws in their reports before the experts (M.O.E. etc.) weigh in. I will shortly be sending my 2007 report to all CPAC and SWAT members.

IN-SITU CHEMICAL OXIDATION (ISCO)

At last week's Chemtura Public Advisory Committee (CPAC) meeting in Elmira, Steve Martindale of the Ministry of Emvironment (M.O.E.) handed out a four page phamplet produced by the U.S. Environmental Protection Agency (EPA). Steve was responding to questions about examples of ISCO successes or failures. The four most common ISCO chemicals were described including the chemical reactions involved in the subsurface. Essentially all of them have large amounts of oxygen and they combine with hydrocarbon contaminants present in the subsurface to produce water (H2O) and various other intermediates.

Permanganates, Fenton's Reagant, Ozone and Persulfate are the ISCO chemicals. They each have different strengths and weaknesses including different organic (carbon based) chemicals which they work best upon . Table 2 was very interesting as it described the various hydrocarbons and their reactions with the various ISCO chemicals. One example is chlorinated ethenes which would include Trichloroethylene (TCE). Potassium Permanganate (KMNO4) was used in the Bishop St. community of Cambridge several years back. According to Table 2 all four ISCO chemicals have excellent results on TCE. We were advised by Steve Martindale that Permanganate (KMNO4) however had only mixed results in Cambridge. I can see but two possible reasons for that. Firstly the TCE from Northstar (Bishop St.) is in the Bedrock which may have inhibited its' effectiveness. Conversely the "mixed results" may not reflect success on TCE so much as failure with the other contaminants present, specifically Trichloroethane (TCA). Table 2 makes it clear that for whatever reason none of the four ISCO chemicals have had much success with TCA.

Table 2 does not mention NDMA which allegedly is one of the contaminants it is being used to reduce/destroy in Elmira. N-Nitrosodimethylamine (NDMA) is a hydrocarbon as it includes dimethyl or 2(CH3). NDMA also has abundant Nitrogen in it of various forms as in Nitroso (NO), Nitrogen (N) and finally amines (NH2). Nitrogen including fertilizers are a component of various explosives. While explosives are mentioned in Table 2 as a chemical group which ISCO can destroy, frankly I am skeptical that NDMA is remotely classified under that group. Ammonia is another major contaminant in Elmira which is Nitrogen based (NH3). It is not a hydrocarbon by any definition. It is an inorganic chemical. To date no comments have been forthcoming from Chemtura and their acolytes regarding any possible breakdown of Ammonia.

What is very clear via Table 2 is that chlorobenzenes are an excellent candidate for ISCO treatment with three of the four ISCO chemicals. Interestingly the one ISCO chemical that is ineffective is permanganates (MNO4). Conestoga Rovers advised us early on that they wouldn't be using KMNO4, not due to its' ineffectiveness but due to discoloration of the groundwater and the Manganese precipitate leftover as part of the reaction. Odd?

GRAVEL PITS, PERSISTENCE & TENACITY IN WOOLWICH TOWNSHIP

In the Elmira Independent edition of April 18/14 the following article was published "Gravel Watch Ontario sounds alarm". This week on April 25/14 Gail Martin, Editor of the Independent, wrote this Editorial "Persistence is rewarded". The first story advises that Gravel Watch have read the most recent updated Provincial Policy Statement (PPS) and that an item has been slipped in without consultation or previous discussion. The item is a promotion of aggregate recycling "wherever feasible". This would mean the grinding up of used asphalt and concrete in order to reuse their components. In theory this is a good thing as it would reduce the quantity of sand and gravel currently being extracted from pits and quarries. The problem is that one it could keep individual pits and quarries open years longer and secondly the noise and dust produced are health hazards. Particulate matter can be hazardous intrinsically when it has petroleum products in it (asphalt) or silicates (concrete). It can also simply be an irritant and hazard to the lungs when dust (sand/gravel) are inhaled.

Gail Martin's editorial praises the persistence of Woolwich Township volunteers. This includes those who fought against the Hunder Pit for seven years as well as those who have fought Uniroyal/Chemtura and the Ministry of the Environment (M.O.E.) for twenty-five years. Gail suggests that many of the volunteers from the 1989 water contamination scandal who were involved then are involved now. Not so much actually. I and Rich Clausi are still involved directly through the current CPAC's Soil, Water, Air & Technical (SWAT) sub-committee. Dr. Henry Regier is currently on SWAT although he moved to Elmira in 1999. By the way our favourite local polluter Chemtura dislike that acronym (SWAT) as it gives an impression contrary to their contrived public relations plan namely that everything is under control. It isn't.

There is one other who's been around since 1989 and that would be Susan Bryant. After personally denouncing the new CPAC in an incredible act of sour grapes; she has aligned herself closely with the polluter, Chemtura. The name of the group is the APTE Chemtura Committee (ACC) and consists of private, by invitation only meetings. Similar to the long discredited M.O.E., Susan allied with a former local politician, are ostensibly pushing Chemtura to do better. Of course certain subjects are taboo (DNAPLS) because Susan without specific knowledge of APTE members and co-ordinaters, sold the farm in October 1991. She went along with the private sweetheart deal and Indemnity between Uniroyal and the M.O.E. dated October 7, 1991. This deal aborted the ongoing Environmental Appeal Board hearings .

Other incredible environmental volunteers would be those involved with the West Montrose gravel pit (Bridgekeepers) as well as those who fought against the Jigs Hollow Pit (Lynne Hare, Jan & others). There is also a group of volunteers keeping a close watch on the recently opened Woolwich Bio-En. Keep in mind our current CPAC members are very active and openminded. Most importantly they are unpaid volunteers without perks for their efforts. Amusingly the former politician mentioned who is woefully, technically lacking, is receiving expense paid junkets around North America courtesy of the chemical industry and probably upon the initial recommendation of Chemtura. She is neither well informed nor a volunteer. She is however an opportunist of the first order.

MY NOTES FROM THURSDAYS CPAC MEETING

As promised here are further notes on the Thursday April 24/14 public CPAC meeting. I will be skipping over both my Delegation as well as some of my comments and criticisms around the 2013 Annual Monitoring Report as I've posted about them already.

Under 6.1 on the CPAC Agenda Vivienne Delaney referred to Steve Martindale's (M.O.E.) comments from last month about nearby municipalities drawing drinking water from contaminated aquifers. Steve responded by saying yes that he's aware of at least one well in Kitchener and one in Guelph which is drawing water from contaminated aquifers. Steve emphasized however that the wells are located upgradient of the contamination and hence presumably O.K.. In my opinion that is both wishful thinking and only an excuse.

Under 6.1.3 Sebastian Seibel-Achenbach read a detailed e-mail from Rich Clausi (SWAT & EH-Team) regarding the ongoing discussions between the School Board, Chemtura, Sulco and the *Responsible Care program. These are to introduce an environmental designation/certification for students into Elmira & District Secondary School.

Vivienne requested of Chemtura more information regarding the next Verification for Chemtura under *Responsible Care. She wanted to know criteria etc. as to who the local representative as well as the verifier will be. Josef Olejarz of Chemtura stated that they have no answer yet. I asked when the Verification was occurring and was told it would be next year. Hmm!

George Karlos of the M.O.E. stated that his new goal is to get the Work Plan for downstream monitoring to CPAC prior to the May meeting. He confirmed that the testing in Canagagigue Creek will occur this summer. The goal is to test for DDT and Dioxin at about the same time of year (June) and at about the same locations.

Steve Martindale discussed examples of In Situ Chemical Oxidation (ISCO) that have been done locally including Safety-Kleen in Breslau, Northstar and General Electric (Allen-Bradley) in Cambridge. Safety-Kleen's ISCO known as Fenton's Reagant has been ongoing for quite a while according to Steve. This of course puts the lie to longtime fellow travellors including the Region of Waterloo who have long denied any environmental impact on the downstream and closed Forwell & Pompeii Wellfields. Steve advised us that the ISCO in Cambridge in the Bishop St. community (ie. Northstar) had "mixed results" only. To me this indicates the absolute necessity of the longterm useage of the backyard sheds pumping and treating air from around basements in the community. What a disgrace by all allegedly responsible parties.

Also of interest is the fact that there is no history of NDMA being destroyed by ISCO. Well, well, well. As I've long suspected it will be needed for breakdown of chlorobenzene both dissolved and according to hydrogeologist Jaimie Connolly and colleague (April 24,2006); also residual and free phase. The disolved chlorobenzene will be directly broken down chemically wheras the DNAPL will be indirectly so by the increase in its' dissolving into the groundwater. Therefore either the whole notion of ISCO's use for NDMA is bogus or CRA are making history by using it in Elmira.

Alan Deal provided us with CRA's annual dog and pony show aka the 2013 Annual Monitoring Report regarding alleged major gains in the cleanup of Elmira aquifers. He claimed as usual that there were "incremental improvements" from 2013 over 2012. Of course I pointed out CRA's own chlorobenzene plume maps (Fig. 4.8, 4.9) for the Municipal Upper and Lower Aquifers clearly showing the plumes had expanded between 2012 and 2013. Strange how CRA and Chemtura can't stand my guts, isn't it? Never lacking an excuse they suggested irrelevantly that well the higher concentrations within the plume had at least been somewhat reduced. They also trumpeted the usual crap about more decreases in concentration than increases while pointedly ignoring the majority of off-site wells that simply have no trend up or down.

Oh be still my skepticism! Is it an election year? Is the Pope Catholic? Councillor Mark Bauman did two things on Thursday evening. He asked excellent questions around the efficacy of hydraulic containment and he seemed to be supporting my claims regarding deception around chlorobenzene in the Bedrock Aquifer. He pressed CRA about their complete lack of monitoring wells in the Bedrock below the highly contaminated Municipal Lower Aquifer. Perhaps anything is possible and Mark has had an ephinany. Time will tell. Mark also suggested the use of tracer dye to test if groundwater is leaving Chemtura's site. Interesting.

Pat McLean and Susan Bryant have been taking turns alternatively attending public CPAC meetings of late. Clearly there was some embarassment involved during the last *Responsible Care verification sessions when Pat was asked and weakly suggested that while she wasn't attending CPAC meetings she had/would send her representative Susan. Susan has been co-opted ever since she and Sylvia Berg of APTE sided with the Region of Waterloo and the other parties to the Environmental Appeal Board hearing in October 1991 and didn't request the EAB to continue on with their hearing. The information about Uniroyal's Indemnity for known contamination (DNAPLS etc.) was neither taken to the APTE membership (including myself) nor the APTE co-ordinaters including Richard Clausi and Esther Thur. Decades later that Indemnity and acceptance therof by Susan and Sylvia explains everything about APTE's failures to take a hard line on DNAPLS.

There are two more interesting points that came from Chemtura on Thursday. Firstly they have sold their Crop Protection business. They claim that it will not affect their current operations, commitment to *Responsible Care and cleanup of Elmira's groundwater. This is their usual puffery and horse manure. *Responsible Care for them is no more than cheap public relations. I view this sale as the beginning of the end. They've been delaying and stalling for twenty-five years with the M.O.E. enabling them. They are going to cut and run, probably sooner than later.

Secondly they have advised that there are three areas in their south-east corner (GP1 & 2) that after last summers' "cleanup" still have concentrations of Dioxins and Furans above the Ecological Risk Criterion. They will be going back in and removing more material in late summer this year. Typically when individuals or groups (M.O.E.) have sold the farm they tend to hang a little tougher on the remaining areas up for discussion. Thus the M.O.E. even, can't justify the pathetic one foot scraping of soil of the DDT and Dioxin contaminated GP1 & 2.

Under New Business I added information to Steve Martindale's enlightening conversation and quasi attempted reneging about municipalities drawing drinking water from contaminated aquifers. I advised that the 2013 Annual (Drinking Water) Reports produced by the Region of Waterloo show Trichloroethylene (TCE) in Waterloo's drinking water between 1 and 2 parts per billion courtesy of the William St. Wellfield. Similarily there is TCE in Cambridge drinking water between 1 and 3 parts per billion courtesy of the Middleton wellfield. Clearly nearby municipalities are drawing water from contaminated aquifers and the wells are NOT all upgradient of these contaminated areas.

*RESPONSIBLE CARE ETHICS & CHEMTURA CANADA

That title above is a joke. The words simply don't belong together. By the way it's not that I'm particularily sold on *Responsible Care however my colleague claims that it is working well at Canada Colours (Sulco) here in Elmira, Ontario. Let's count the lack of ethics from this bunch just recently. One I e-mailed some questions regarding the upper aquifer containment & treatment system to Jeff Merriman of Chemtura last February. No response so I e-mailed a second time. I received a "I'll do it as soon as possible" reponse. Still no go. Last evening before CPAC started I again reminded him. Oh he's been busy he'll get back to me. Two since January I've been politely asking either Chemtura or the Ministry of the Environment to send me a copy of two letters written in May 2008 from Jaimie Connoly and Wilf Ruland. Both these bodies have been using these letters as backups to their claims that these two hydrogeologists have recanted their opinions that free phase DNAPL has flowed from Chemtura over to Yara (Nutrite). This is a big deal but they won't provide backup although last evening they did finally promise to provide the letter from Wilf as CPAC & SWAT have finally been given Jaimie's letter. Third has to do with Chemtura's longtime consultants. Years ago I awarded Conestoga Rovers the MACHO Award. This is a wooden statuette engraved as the Brian Beatty Memorial Award for Creative HydrOgeology. Mr. Beatty is a former hydrogeologist who worked on behalf of Uniroyal Chemical. Well last evening they outdid themselves as per my earlier posting of today. Creative hydrogeology is a beautiful thing if your goal is to deceive.

Back to Jaimie Connolly's letter. Jaimie's May 2, 2008 letter recants his position on DNAPL flowing from Chemtura to Yara and oh so much more. This is why they wouldn't provide it. Jaimie categorically states that source reduction of contaminants is required on the Chemtura site. This is a hand grenade to CRA, Chemtura and the M.O.E. and a major boost to CPAC's 2012 Resolution. Well done Jaimie. Jaimie then goes on and advises that Conestoga Rovers (CRA) messed up their calculations of Effective Solubility in their August 2007 DNAPL Investigation Report. Finally Jaimie advises (as Ron Campbell of CPAC has) that DNAPL chemicals under the influence of hydraulic containment; whose dissolved concentration is not being further reduced; probably are present as a non aqueous phase liquid (NAPL). In a court of law they refer to the exchange of documents as Discovery. Apparently with a convicted polluter of questionable ethics it is to be avoided wherever possible.

Last evening at the public CPAC meeting I as usual was a Delegate. I congratulated CPAC about their class and integrity. I also congratulated Steve Martindale (M.O.E.) for his breathtaking sincerity and honesty. I praised Jaimie Connolly (M.O.E.) for most of his May 2, 2008 letter. I criticized the former Chair of CPAC for ensuring that the by far best informed citizen stakeholder on DNAPL issues did not receive Jaimie's letter back in 2008. I strongly criticized Figure 4.10 in CRA's 2013 Annual Monitoring Report. All the CPAC members present contributed heavily throughout the evening and I hope to elaborate further, possibly tomorrow.

DID CONESTOGA ROVERS DEFRAUD THE PUBLIC?

Good question under the circumstances. Have they crossed some imaginary ethical line that either their professional body or someone else would find abhorrent? I haven't the foggiest because in twenty-five years I've never seen anything even remotely approaching an ethos or a moral imperative that they must follow. I contrast this with for example the *Responsible Care program of the Chemical Industry Association of Canada (CIAC). Heaven forbid has the company crossed a legal line regarding this exposure of creative hydrogeology at last night's Chemtura Public Advisory Committee (CPAC) meeting? Again I'm not a lawyer hence it's pretty difficult for me to say. I may well think that they have committed a fraud upon the public with their misinformation and deception but is that by definition legal fraud?

Figure 4.10 in the 2013 Annual Monitoring Report is a stinker. It is titled 2013 Chlorobenzene Concentrations Bedrock Aquifer. If perhaps the company just put this diagram of their site and the rest of Elmira into their report without comment, I wouldn't have been so offended by their misrepresentation. Instead they have flatly stated that there is "No chlorobenzene plume in the Bedrock". Talk about waving a red flag in front of a bull. As I explained to CPAC, the public and the media present last night, Conestoga Rovers position on chlorobenzene in the Bedrock aquifer goes beyond amateur hour. I compare what they have done intellectually with the "salting" of gold mines in ages past.

They have presented monitoring data mostly eight and nine years old and in fact in most instances fourteen years old as representing the current status of one of the major Chemtura signature contaminants, in this the deepest aquifer on the site. While both in the text and in other Figures they admit and confirm the presence of both NDMA and Ammonia in the Bedrock, they are refusing to do the obvious with Chlorobenzene. Even if that was all they had done, their unethical behaviour is disappointing. Instead their deception is much greater. All appearances and common sense point to them as having intentionally positioned Bedrock monitoring wells in locations so as to avoid discovering chlorobenzene. Their on-site Bedrock wells are positioned where there is no overlying Municipal Lower Aquifer (ML). What there is however is a substantial clay aquitard which protects the underlying Bedrock Aquifer from contamination. Reversely off their site is a large open area just north of First St. and ending south of Oriole Parkway in which they do not have a single Bedrock well. Why not you ask? This area exactly corresponds to the overlying highly contaminated Municipal Lower Aquifer without any clay aquitard between the two. In other words high concentrations of dissolved chlorobenzene are in direct contact with the underlying Bedrock Aquifer. And we are supposed to believe the Bedrock doesn't have chlorobenzene in it?

The ramifications of this suppressed information are overwhelming. Chlorobenzene is a DNAPL chemical. Are they afraid of even more damning information surfacing regarding free phase Dense Non-aqueous Phase Liquid (DNAPL) on their site? Has the free phase DNAPL found in OW57-32R in this open area between First and Howard Ave. possibly moved not only through the window in the Municipal aquitard (MAT) but then gravity flowed downwards into the Bedrock? If this is the case then the cleanup of the Elmira Aquifers is doomed categorically. Chlorinated solvents in the tiny fractures in bedrock are nearly impossible to remove. Unlike Cambridge where the bedrock is near the surface, in Elmira it is over 100 feet down in most areas.

Another possible ramification is this. Has Conestoga Rovers vaunted hydraulic containment merely drawn contaminants constantly deeper into the subsurface? There were concerns by CEAC (Citizens Environmental Advisory Committee) in the 80's that pumping the Municpal Upper Aquifer (MU) would draw shallow contaminants deeper. Since then not only has MU pumping been ongoing but so has major pumping in the Municipal Lower Aquifer (ML). I have recently seen an example where the highest concentration of NDMA is not in either the overlying MU or ML but instead in the Bedrock. This is not good.

More on last night's meeting will be forthcoming.

CPAC MEETING TONITE & PHASING OUT OLD RAIL TANKERS

Tonight at 6 pm. in Woolwich Council Chambers, the Chemtura Public Advisory Committee will hold their monthly meeting. On the Agenda will be a discussion of the next *Responsible Care verification for Chemtura. If you will recall the last one was a nothing short of a travesty with Chemtura getting a "do over" after initially failing. Later in the meeting Conestoga Rovers on behalf of Chemtura will be doing their annual dog and pony show aka presentation of last year's (2013) Annual Monitoring Report. Calling it a dog and pony show is of course disrespectful but after decades of sitting through them I should be excused. I suppose I could more gently refer to them as advanced examples of extreme puffery. Come one, come all this is a public meeting and as Earth Day was only two days ago, do yourselves a favour and learn how corporate polluters pull the wool over the public's eyes.


Today's Waterloo Region Record carrys this story "Ottawa phasing out old rail tankers". Just in the nick of time you say? Well let's not forget last summer's Lac Megantic disaster. Let's not forget the next several leaks, fires and explosions. Afterall you don't replace aging infrastructure overnight. Experts in the field are actually laughing at Ottawa's three year timeline. These inadequate tankers have been so for decades but when governments are focused on short term goals such as winning the next election; well they can be forgiven for Canadians losing their lives all in the name of the next Conservative majority. Thank God our politicians have their priorities in order.

YESTERDAY WAS EARTH DAY

Last evening I spoke as a Delegate to Woolwich Council, in the Council Chambers in Elmira, Ontario. I was the only Delegate speaking even remotely on environmental matters or regarding Earth Day. My message, with but a couple of exceptions praising the current Chemtura Public Advisory Committee (CPAC) and Woolwich Council for two positive Decisions; was essentially a discouraging one. The last sentence in my Delegation was as follows: "When the one side in any dispute has lawyers, consultants and millions of dollars and the other side only the truth; guess which one gets consistently hammered?"

Last Monday's Waterloo Region Record carried this article/opinion "Four years after oil spill, BP's stalling tactics are shameful". This article was written by David Yarnold the CEO of the National Audubon Society. BP pled guilty to criminal negligence which immediately caused eleven human deaths and currently immeasurable loss of wildlife. Their lawyers are playing the stalling game to avoid beginning massive payments of $18 Billion to attempt to repair and restore the environment. To date BP has paid for the immediate cleanup of their 170 million gallons of oil spewed into the Gulf of Mexico. The massive judgement against them is in addition to "...14 criminal counts ranging from lying to felony manslaughter." I would like to know how many BP executives who made the decisions prior to the spill will ever see the inside of a jail cell. Logically one would think that felony manslaughter would put a person in jail. In the case of a drunk driver injuring another party it probably would. But these are corporations who buy and sell politicians like chewing gum. Laws are made to protect both society and unfortunately to protect guilty corporate executives.

This is the reality of environmental protection and cleanups in North America. Money and politics rule and both are dirty and corrupt. In that sense nothing has changed since the first Earth Day in 1972.

HUNDER PIT APPLICATION DISMISSED BY OMB

Last Saturday's Woolwich Observer carrys this story "OMB rules against Hunsberger pit". Hunder Developments have 30 days from the April 14/14 Decision to launch an appeal if they so decide. I wish to raise a couple of points. Firstly why did it take the Chair six months to write a nineteen page Decision? The answer to that is obvious. It didn't take six months to write nineteen pages. In my opinion it took six months to talk, negotiate and convince somebody or somebodies that turning down this Application was in their best interests. Secondly the potential ramifications of the Chair's (Mrs. Schiller) comments about the inadequacy of "voluntary compliance" embedded in the Aggregate Resources Act are immense. At least one other provincial Ministry, namely the Ministry of the Environment rely upon voluntary compliance. Don't get me wrong here. Voluntary compliance is a joke, a sham and giving it to either convicted or unconvicted polluters is, as far as I am concerned, an act of governmental corruption. Therefore while Mrs. Schiller is 100% correct in her conclusions I simply don't believe that she was ever appointed or paid to so be. The testimony at the hearing was that on average each gravel pit in Ontario receives an inspection from a Ministry of Natural Resources officer, once every five years. Hence the so called voluntary compliance. Citizens basically are treated as witless money pits, keeping governments and their friends in comfort.

BACK TO CAMBRIDGE DRINKING WATER

O.K. I've been back on-line searching for standards and guidelines regarding chlorine and or chloramines in drinking water. There is a hard maximim number for chloramines in your tap water and it is 3.0 mg/litre or 3 parts per million (ppm). A synonym for chloramine concentrations is combined residual. Free chlorine residual refers to chlorine on its' own ie. not combined with nitrogen producing a chloramine. A hard standard for free chlorine is more difficult to ascertain. I have read that it should also not exceed 3.0 mg/l although the U.S. Environmental Protection Agency have set a maximum standard of 4.0 mg/l. Research has indicated that chlorinated water raises bad cholesterol levels in humans and has been implicated in increased risks of bladder cancer. Chlorine exposure occurs not only by drinking tap water but also significantly via showering in chlorinated water. Swimming pools are also a concern and serious/competitive swimmers have higher health risks due to chlorine exposure even at below maximum permitted concentrations. One reference states that most municipalities maintain their free chlorine residuals between .2 and 2.0 mg/l and another suggests between .04 and 1.0 mg/l, both well below the EPA's standard of 4 mg/l. It is with this information that I will now give further 2013 Annual (Drinking Water) Reports produced by the Region of Waterloo, for various wells and systems in Cambridge.

Well G4 (Galt) on the west side of the Grand River has Sodium levels of 92.1 mg/l well above the recommended although not mandated levels of 20 mg/l. Turbidity (cloudiness) of the water is 1.92 NTU above the standard which varies between .1 and 1.0 NTU (Nephelometric Turbidity Units). Trihalomethane (THM) results which are the major concern in chlorinated drinking water are not published in these reports although they do state that the two tier distribution system is operated by the City of Cambridge; telling me that the City probably have that data but aren't sharing it. The maximum chlorine (free) concentration was a ridiculous by any standards, 4.29 mg/l .

Heading north and east, well G5 has a ridiculous Sodium reading of 152 mg/l. Low sodium diets relate to high blood pressure and other heart problems. THMs again are not published although with a maximum of 3.7 mg/l chlorine (free) they should be as they are produced by chlorine. Nitrates are also high although well below the drinking water standard of 10 mg/l. These too relate to heart and blood pressure issues.

Well G6 south of Ciba-Geigy has high Sodium levels of 51 mg/l, no THM readings and a low level of the industrial contaminant Metolochlor (.68 ppb) in the drinking water. At least metolachlor was low when it was measured back in 2011. Why they aren't testing it at a minimum of annually is beyond me. Free chlorine is at an astounding maximum of 4.99 mg/l. That this doesn't even generate an Adverse Effect Report under Subsection 18(1) of the Safe Drinking Water Act or Schedule 16 of Ontario Reg. 170/03 is also beyond me.

Well G9 is at the south end of town near Allen-Bradley. Sodium levels are a very bad 123 mg/l plus they have a significant trichloroethylene (TCE) problem at 1.6 parts per billion (ppb). The current Canadian standard is 5.0 ppb with some U.S. jurisdictions considerably lower. The TCE results also are from 2011 and whether legally complying timewise or not (I'm doubtful), the lack of updated results is shameful. Chlorine (free) maximum concentration is 3.47 mg/l which while legal in the U.S. is still well above accepted practices and is dangerously high.

Well H3 in Hespeler has very high Sodium at 94.7 mg/l and above standard Turbidity at 1.99 NTU. The maximum chlorine (free) residual is a more reasonable 1.99 mg/l. The bad news is that this well was shut down for 50 weeks last year raising the obvious question, namely why?
Well H4A is a new well connected into the H4 well supply. It has an unbelievable Sodium reading of 226 mg/l and an unacceptably high, although legal, free chlorine residual reading of 2.82 mg/l. Well H4 was off-line for the whole year. Again very disturbing but no explanation given.

Hespeler well H5 was off-line for 25 weeks last year also with no explanation given. The maximum free chlorine residual was 4.86 mg/l and again no THM levels are published here. THMs cause cancer which is why they are regulated and if free chlorine residuals don't have a hard Canadian standard they should have. This water is dangerous to your health.

Well P9 is located just north of Ciba-Geigy (Novartis). Sodium is at 94.3 mg/l which is bad but again free chlorine is at a way too high maximum of 4.99 mg/l. The question is why. Total Coliform levels are low and E.Coli is zero. Turbidity is also good. Therefore why are they chlorinating the daylights out of this water? Are they incompetent or are they trying to hide (or treat?) other problems such as taste, odour or chemical? Last but not least this well was off-line for 19 weeks last year. In times of water restrictions and low rainfall shut down wells signify serious trouble.

Finally Well P15 is located very close to Well P9. It was also shut down for 19 weeks last year without explanation. Sodium readings were 85.8 mg/l and free chlorine was at 3.95 mg/l. Turbidity and bacteria levels were low again raising the question about high free chlorine levels. Industrial and agricultural chemical testing was last reported in 2011. Something is amiss in this and other Cambridge wells with all these shutdowns.

Cambridge both from vital data given as well as vital data absent, your well supply is badly comprimised. All these various drinking standards are based upon the wholly unreasonable assumption that there is at most only one health related contaminant at a time in the drinking water. Absolutely nobody can positively state that these various combinations of issues including, sodium, nitrates, THMs, free chlorine, chloramines in other wells and low levels of solvents are not damaging people's health. Speaking of chloramines there lack of use in these wells in this posting is strange. They are far more commonly used in the rest of Waterloo Region than chlorine alone. To put it bluntly the drinking water standards currently in use are the product of science, health requirements and most terrifying, industrial/business lobbying. The U.S. EPA have been upfront about this issue. Here in Canada we try not to alarm our citizens with disturbing truths.

FURTHER THOUGHTS ON THE OMB/ HUNDER DECISION

I've gone back over my postings of last September and October regarding the hearings dealing with the proposed Hunder Pit. A few things come to mind. Firstly the lawyer for the Conestogo Winterbourne Residents Association made an express point early in the hearings that his client was not looking for better terms and conditions, they were looking to stop the pit cold. Fair enough and not too surprising. However at the end of the hearing somewhat to my surprise he suggested to the Chair that if the pit were approved, his clients would really like the pit not to extend across Hunsberger Rd.. He and his clients felt that these extra phases would really have the worst impacts for the residents. Again fair enough in that comprimise is often necessary in the real world. Nevertheless I believed then and now that Mr. Paton was a realist and he could clearly see which way things were going.

There was a shocking development in regards to the traffic expert who testified on behalf of the Township. This gentleman was very clear in his testimony that the proposed new gravel truck traffic would negatively impact an already problematic traffic intersection at Crowsfoot Corners. He gave his testimony both factual and opinion, confidently and clearly. Then you could have heard a pin drop after he answered the final question. The question was therefore would you recommend against the proposed Hunder gravel pit being approved. His reply "No". I felt then and now that this was the low point in the respondents' case against this pit being approved.

My heart and ethical part of my brain started unequivocally on the side of all the opponents to this proposed gravel pit. During the course of the hearing two things happened. One I disciplined myself to focus on the evidence being given and the appropriate weight it should receive in light of the Aggregate Resources Act (ARA), the Provincial Policy Statement (PPS) and Woolwich Township's Official Plan (OP). In terms of ethics, right and wrong I would rate those three documents as the OP first and the ARA last. Unfortunately it appeared to me that all parties agreed that in legal terms the ranking was the complete reverse. The ARA is the overiding, penultimate legislation. The municipal Official Plan (OP) while relevant nevertheless carrys the least weight. Based upon this I believe that the Hunder Pit position won the hearing.

The second thing that happened was that I engaged in numerous conversations with the applicant, Bob Hunsberger. I started the conversations by firmly putting my foot in my mouth and taking a strong anti gravel position on the very first day with him, not knowing he was the applicant. Well obviously he was not very impressed but nevertheless held his emotions in check while advising me that I was dead wrong. Discussions ensued which turned out to be very frank from both parties. I won't presume to suggest that I persuaded him to shift his position at all but I will admit that he sucessfully persuaded me that his position not only had merit but that he was a firm believer in following the laws of the land and that was both the proper and moral course. In other words he believed that all applicable legislation, rules and policies were 100% favouring what he wanted to do. He also felt that he had bent over backwards, well above and beyond the minimum requirements, to mitigate adverse and unacceptable impacts to his neighbours. I believe that indeed Mr. Hunsberger did meet all legal requirements of him plus more. He is concerned about his neighbours as well as of himself and his family.

Where does this leave us? In my opinion as stated six months ago here in the Advocate I felt that the pit would be approved, albeit with three or four very strong conditions that would not please the applicant. The current reality is that the proposed gravel pit is denied. IF the applicant Mr. Hunsberger decides to appeal this OMB Decision, I believe that he has numerous very strong legal grounds to do so. Notice that I am differentiating the legal grounds versus the moral grounds. Ultimately I still believe that this pit should not be located where currently proposed. However I also believe that the applicant is in the legal right. For me this conundrum neither is surprising nor does it shock my sensibilities. One practical solution, other than years of financial drain, stress and making the lawyers wealthy, is negotiation. All parties need to seek a solution which may include no gravel pit but does include a recognition that the applicant fairly relied on the laws of the land (as crappy as those laws may be in my opinion) and he also relied upon advice from both private and governmental sources advising him that he was in the right. Thus he has spent huge sums of money persuing what he believed were his rights. The alternative of court action may be far worse for the C-W residents.

HELL HAS FROZEN OVER IN WOOLWICH TOWNSHIP

Today's Waterloo Region Record carrys this headline "Gravel pit project appeal dismissed". I received the news and a copy of the nineteen page Decision yesterday. My initial response prior to reading it was that hell has frozen over in that the Ontario OMB has sided with citizens who would have been subject to "unacceptable impacts"; albeit a very subjective condition. This isn't the first time the OMB have sided against a gravel pit development but it's damn close. After reading the Decision carefully my opinion now is are we somehow living in a parallel universe and or has someone at the OMB just sufferred a stroke?

The Decision mentions four major areas of contention namely visual impact, rehabillatation of agricultural land, transportation impacts and noise impacts. Holy crap but the hearing Chair and Vice Chair of the OMB (Susan Schiller) found in favour of Hunder Developments on visual impacts and against them on the other three. The newspaper article written by Greg Mercer correctly indicates that the Chair in her Decision accepted that the "...voluntary compliance approach embedded in the Aggregate Resources Act (ARA) to protect the nearby community from negative effects." wasn't good enough. Holy Crap that is a slap in the face not only to the Ontario Ministry of Natural Resources but also to our dearly beloved, here in Woolwich, and hopelessly pathetic Ministry of the Environment. Does anyone seriously think that this Decision will go unappealed? Even with a provincial election looming the last thing either Liberals or Conservatives want is honest, unbiased legislation combined with a nuetral Ontario Municpal Board. Chaos could reign if citizens actually could present arguments to a government appointed panel while sitting on a level playing field. The Environmental Review Tribunal would be next and if allowed could annihilate what little credibility the M.O.E. have left.

This proposed gravel pit wasn't appropriate from the very beginning. Unacceptable impacts were a given yet other gravel pits in Ontario with unacceptable impacts proceeded without a hitch past and through the OMB. Looking at this Decision from the proponent's view, they must be appalled. Whether advice from the OSSGA (provincial gravel assoc'n), their lawyers, consultants and indeed from the MNR; they were assurred that the overwhelming majority of proposed pits are approved most especially if they've dotted their i's and crossed their t's throughout the process. That process includes public consultation, repsonding to it and producing voluminous reports and rewrites pointing out mitigation methods and how the impacts would be made acceptable. The process set up by the province is lengthy, expensive and inherently unfair to all parties. It has been essentially a show to pretend that the legislation itself isn't biased. Firstly honest, unbiased legislation is required followed by an incredibly streamlined and honest process. In the short term taking a direct shot at the overarching provincial legislation (ARA) is either incredibly brave or intentionally foolhardy, opening the door to an obvious appeal.

What is the game here? In the short term the Liberals look good while crapping on the OSSGA, the MNR and the local proponent. In the long run after they figure they might win the election will they then reverse the Board's Decision on appeal? Stay tuned.

A LITTLE MORE REGARDING CAMBRIDGE WATER

Back on March 1 and 3 I posted here regarding Cambridge's Annual (Drinking Water ) Reports. My focus was on industrial contamination, high Method Detection Limits, glaring data gaps including years between published test results and a lack of explanation and transparency for the multitude of drinking wells shut down for long periods of time. Today I'm going to look a little more carefully at microbiological problems and issues in these wells. Also just for the record the provincial Safe Drinking Water Act (SDWS) does allow 36 months between publishing test results for industrial chemicals and solvents. I find this beyond asinine but there it is. The exception deals with increased reporting requirements when an industrial contaminant is detected and I'm not seeing that happen.

The Middleton Wellfield last year had 129 detections of Total Coliform bacteria and 12 detections of E.Coli bacteria out of 1,261 samples in their raw water. Considering the volumes of water pumped and the closeness to the Grand River I don't believe the Total Coliform detections are too surprising. The E.Coli on the other hand are more serious. There are, other than West Montrose, almost zero E.Coli detections in the rest of the Region. Other problems include high Turbidity namely 1.991NTU and Chlorine (free) at 3.80 mg/litre. Both of these exceed the provincial standards. Both Sodium at 140 mg/l and Trichloroethylene are way too high. The TCE even after the new Advanced Oxidation Process (AOP) had one reading of 3 parts per billion (ppb) and numerous ones between 1 and 2 ppb. This is very strange.

The Pinebush Well System (P10, 11, 17) has high Turbidity and high free chlorine at 4.98 mg/l. Because of the high free chlorine I would really like to see some of their readings for by-products of disinfection such as Trihalomethanes (THMs). These are not given in this report.

The Shades Mill Wellfield has acceptable bacteria raw water readings however high Turbidity which is not good as it can protect bacteria from disinfection. One of the four wells was off-line for 47 weeks which also doesn't bode well.

Further wells and bacterial concerns will be discussed shortly.

TWO UPCOMING PUBLIC EVENTS

In a perfect world, which never has and never will exist as long as human beings are in charge, one could solve all problems through quiet discussion, agreement on the obvious facts and then a meeting of the minds possibly including some comprimises to sweeten the agreement. In regards to Uniroyal/Chemtura in Elmira it's always been about money, power and influence. If they had been dealing with strong, publicly motivated politicians at the municipal, regional and provincial levels their wiggle room would have been substantially minimized. Unfortunately that has not been the case. Individual politicians of good character have always been vastly outnumbered by the rest. This is why we live in the world that we do.

Therefore other directions need to be pursued to exert pressure on recalcitrant polluters, politicians and their assorted fellow travellers. These fellow travellors are motivated by self interest and unfortunately as has occurred in Elmira and elsewhere, also includes co-opted private citizens. This is where the media, including both their positive and negative characteristics, come into play. They help shape public opinion and knowledge. Ultimately however it's all about the public. If they truly deep down don't care one way or the other then all is lost. This is often the goal of politicians and polluters. Give the public no reason to care. Lie to them that all is well. Pretend that everything is under control. Use any and all manipulative means to pursuade a very busy public with lives, jobs and children that they really shouldn't commit their time and effort to being watchdogs of the public interest.

40% of our population will have cancer in their lifetimes. As I posted yesterday this is due to the air you breathe, the water you drink and the food you eat. Is this really acceptable to you? Dioxins are now ubiquitous in milk. Fourteen years after the Walkerton water tragedy, contaminated source water is common throughout Waterloo Region. Chemicals as additives in food are now the norm. Our air here is better than Toronto or Hamilton and certainly better than in third world developing countries including China. But it's still polluted and all air is connected.

One week from today I will be a Delegate at the televised Woolwich Council meeting (7 pm.) speaking about the "progress" in cleaning up the Elmira Aquifers and the Chemtura/Uniroyal site itself. A week from this Thursday in the same Council Chambers (6 pm.), the Chemtura Public Advisory Committee (CPAC) will hold their monthly meeting. Attend in person or watch the Woolwich Township televised meeting live on Rogers cable TV (channel 20 ?).

IT'S THE FOOD YOU EAT, THE WATER YOU DRINK & THE AIR YOU BREATHE

The current statistics are approximately 40% of Canadians will get cancer at least once in their lifetimes. No longer can governments and other apologists suggest that it's smokers and drinkers who are the prime candidates. Yes they are right about one thing. Cancer is all about lifestyle. If you breathe air, drink water and eat food you are at risk of getting cancer. Saturday's Waterloo Region Record carried this story "Subway says "yoga mat chemical" will be out of bread soon". The chemical being used as a bleaching agent and dough conditioner is called azodicarbonamide. This chemical among other things is used in the production of yoga mats and is not approved in other parts of the world. Here in Canada it's all about corporate benefits and profits. If you can make better looking, faster products that don't cause immediate sickness then it's O.K.. Any serious health issues down the road will be handled by our health care system. Funny thing is I don't remember ever making that kind of agreement with anyone. I also don't remember ever being asked by politicians during election campaigns if those tradeoffs, namely short term profits versus later sickness, were acceptable. Only in Canada you say?

REVISITING KITCHENER'S WATER SUPPLY

Back on March 7/14 I posted my observations of the Kitchener Water Supply System. There were numerous concerns which after new information and after rereading the numerous Reports I can see requires an update. Firstly Grand River water supplied nearly 50% of the water used in the Kitchener distribution system last year. As this allegedly is an IUS or Integrated Urban System this water may have also ended up in Waterloo or Cambridge. This is not a plus for those cities. Grand River water is very expensive to treat because compared to groundwater it is very dirty. It has been enriched by Sewage Treatment Plants upstream in Fergus and in Waterloo. I believe (and desperately hope) that Kitchener's Sewage Treatment plant is downstream of the Hidden Valley water intake which is pumped to and treated in the Mannheim Water Treatment Plant. Even Cambridge, downstream of the Kitchener Sewage Treatment Plant, should hope so if they are being sent Kitchener water.

The volumes of water from multiple sources are surprising. By far the largest (& dirtiest) is the Grand River. Next is a single well (K26) at the Mannheim Village Wells. It is less than 1/6th the volume of Grand River water. Behind it is the Parkway Wellfield slightly enriched with trichloroethylene, significant Nitrates, chloramines and ridiculously high Sodium levels. Trihalomethanes (THMs), NDMA and haloacetic Acid concentrations are not given. Both the Greenbrook Wellfield and well K25 in the Mannheim Village wells are next. The Greenbrook Wellfield is currently shut down hopefully only temporarily due to the explosion a couple of weeks ago. It has significant chloramines, high Turbidity and no results for 1,4 Dioxane which shut it down for treatment upgrades a few years back. Both NDMA and 1,4 Dioxane results should be given and are not. Also of interest is the fact that none of the wellfields are approaching their permitted pumping rates. Odd.

Pages five and six of the Mannheim System indicate information that I have not seen at any other wells. Basically there are concentrations given for both chloramines (as in monochloramine) and dichloramines. The first has one chlorine molecule the second has two and is more dangerous to human health. I had read that when you have chloramines you will also probably have some level of both dichloramines and trichloramines; both which are more toxic than even just (mono)chloramine. Chloramines while below the Ontario Drinking Water Standard (ODWS) are routinely present at above 50% of the standard. THMs while averaging 24.3 parts per billion (ppb) have a highest reading of 49.5 ppb. The ODWS is 100 ppb. What really caught my eye were the bacteria readings from the Grand River. Of course the Region have somewhat changed the methodology making comparisons difficult (or not). Well water often has a raw water reading for bacteria (present/absent) and then a filtered raw water reading called MF for Membrane Filter. The Mannheim System Report has this for their well water whereas for the river water they haven't included raw values (present/absent); only filtered values (MF). These surface/river MF values are 0-2500 for E.Coli Or Fecal Results and 10-120,000 for Total Coliform Results. While I find these maximum results (ie. 2500 & 120,000) astonishing I also wish they had advised the total numbers of present versus absent bacteria results as they do for most well water (ie. groundwater).

Most of the raw or source water used for drinking water in Waterloo Region is treated with only one or two chemicals namely sodium hypochlorite (producing chlorine) and ammonium sulphate (producing chloramines). There may be various filtration methods to reduce Turbidity and some wells have methods to reduce iron and manganese. A couple of very badly industrially contaminated wellfields including the Middleton Wellfield in Cambridge have an Advanced Oxidation Process (AOP) which uses ozone and ultraviolet irradiation (UV) together. Keep in mind that some seniors died back in the 90's courtesy of cryptosporidium in Grand River water prior to the region ozonating that water. This is the problem with using comprimised source water and then treating the daylights out of it. Vulnerable segments of the population can not withstand the treatment given to contaminated water. The Mannheim System uses the following treatment chemicals namely "Chlorine gas, 12% sodium hypochlorite, anhydrous ammonia, polyaluminum chloride (coagulant), polyelectrolyte (filter aid), liquid oxygen (LOX), ozone, ultraviolet (UV) irradiation, calcium thiosulphate, granular activated carbon, 20% ammonium sulphate."

DAMNING WITH FAINT PRAISE

Yesterday's Elmira Independent carrys a Letter to the Editor from Dr. Henry Regier of Elmira. Henry is a friend and colleague for whom I have the highest respect. To this day I remain in awe as to how he could verbally skin alive assorted and sundry psuedo professionals and credentialed sellouts. While I would spend 60 seconds criticizing a technical report causing great offense, Henry was able to spend ten minutes tearing it down, blasting its' authors technical and moral abilities and then be thanked at the end of his assault. Henry's early retirement from the Chemtura Public Advisory Committee (CPAC) was a loss to myself, the community and honest, informed promotion of the natural environment.

The title given to Henry's Letter is "Damning with faint praise". Basically Henry is not pleased with what he sees as thinly veiled criticism of CPAC by Independent Editor Gail Martin. Gail referred to "...chasing rabbit trails that led nowhere..." to which metaphor Henry jumped all over. The overall theme of Gail's Editorial I found to be quite complimentary of CPAC and indeed I so posted a few days ago. Nevertheless I too spotted the same criticism of CPAC as Henry did. I view myself as a very strong supporter of this current CPAC primarily because they have convinced me that they are the real deal. Their hearts and minds are in the right place and their ever growing knowledge base is a plus.

There is a dichotomy I believe in my support of this CPAC but not the last one. I have posted here in great detail my damning with loud criticism of the old CPAC. I think that Gail Martin also has a dichotomy in her support of the old CPAC and her concern as to how they were dumped en masse by the new Woolwich Council in 2010. Therefore she still views this CPAC through darkened lenses. Here however is the good news. Unlike the Woolwich Observer Gail Martin and the Elmira Independent attend each and every public CPAC meeting. Despite whisperings in her ears from a couple of former CPAC members, still in the stomach churning throes of sour grapes; she is her own person. She may hear background whispers but she sees the CPAC members asking the hard questions and expressing their disbelief at some of the fairytales being sold by Chemtura and "...their hired guns and regulators.". Gail is a good reporter, editor and even more importantly person. This is not faint praise from me.

REVISITING ELMIRA / ST. JACOB'S WATER

Back on March 6, 2014 I posted about the water coming up from Waterloo via pipeline to St.Jacobs and Elmira. Since then I've discovered new data. Firstly the majority of Waterloo water is produced by Well W7 in the Erb St. wellfield. Secondly the writeup of wells being off-line was very deceptive in the 2012 Annual Report. It turns out that well W6B was off-line for eleven months in 2012 and well W6A for two months namely November and December 2012. Then in 2013 well W6A was off-line for the whole year thus a consecutive fourteen months. Well W6B appears to have been pumping throughout 2013 after it's eleven month "rest" in 2012. To me this is shades of the "musical pumps" which occurs in Cambridge on a regular basis. Further to this "managing" of wells, particularily ones located near groundweater contamination, a M.O.E. representative was quoted in the March 27, 2014 Chemtura Public Advisory Committee (CPAC) Minutes as stating that nearby municipalities do pump drinking water from contaminated aquifers although they keep a close eye on them. This is an absolutely breathtaking revelation and one that needs to be shared with all citizens. This is repugnant and disgraceful and all the more so when the Region of Waterloo advise their citizens of the top quality of their water.

The William St. wells have spectacularily high Sodium levels namely between 171 and 223 mg/litre. The M.O.E. are informed every five years of concentrations higher than 20 mg/l. Yes they are ten times higher! During 2013 on six occasions the William St wells were found to have chloramines above the drinking water standard of 3 mg/l (parts per million). Chloramines produce toxic by-products of disinfection including NDMA a known carcinogen. Nitrates are also high although not above the drinking water standards. Trichloroethylene is a constant in these wells although also below the drinking standards. Turbidity was O.K. in 2013 although it was too high in 2011 and 2012 in the raw water. High turbidity can prevent proper disinfection of bacteria and may be the cause for higher than needed chlorine and chloramine in the treated water. Well W3 has been off-line for several years without a proper explanation. Maybe it's being pumped to waste or maybe it's shutdown because it has even higher levels of trichloroethylene in it. We simply do not know. TCE is also a very potent carcinogen.

The point with these wells is that they have multiple contaminants albeit at allegedly low levels. The other point is that absolutely nobody anywhere can honestly tell you that this water is safe to drink. All drinking water standards are based upon the unrealistic assumption that only one contaminant at a time is in the water. The Region may or may not be operating illegally with these and other wells. I do not know but suspect the Ontario M.O.E. are hand in hand with their stickhandling. What I do know is that this water is not safe or healthy for you.

REVISITING THE MARYHILL WATER SYSTEM

Firstly a status update on the West Montrose water system. A week ago today I had a sit down meeting with Dan Kennalley and Woolwich Councillors Bauman and B.Bryant. I agreed to sending them a list of questions to be forwarded on to the Region of Waterloo. This I did very late Friday afternoon with a total of three pages of questions. Probably today or tomorrow I will send an e-mail asking the Councillors whether they've sent them on and if there's been any response whatsoever.

Back on March 8/14 I posted here about the two water systems in the village of Maryhill (Woolwich Township). While I mentioned troubling issues concerning chloramines in the one system I wasn't terribly specific. Since that time I have been doing my homework regarding bacteria and disinfection methods for municipal drinking water. I have since posted a few articles in regards to West Montrose and the very serious state of their water supply. Today I am focusing on the Maryhill Water Supply System not the Maryhill Heights System. Wells MH1 and MH2 have had increasing levels of chloramines in the last five years. While they are in a Table titled "...parameters that exceeded half the standard..." this is a very deceptive heading and possibly intentionally so. In fact their chloramine concentrations regularily exceed Ontario's Drinking Water Standards (ODWS). While they don't have as many exceedances as West Montrose do, nor as many detections of Coliform in their raw water; it appears as if their chloramine concentrations are even higher than West Montrose's. The standard is 3.0 mg/l or 3 parts per million. In the last few years they've had many concentrations above 4 mg/l and as high as 4.99 mg/l.

The Maryhill System has a different method of filtering their raw water than West Montrose's. Oddly West Montrose has Turbidity readings for both their raw water and their post filtered water. Maryhill do not. They have one reading (raw) and it is far in excess of the drinking water standards for Turbidity (ie. murkiness, lack of clarity). Turbid water can protect bacteria from disinfection by chlorine/chloramine and my suspicion is that this is why the Region are overchlorinating the water. Both high chlorine and chloramines can lead to products of disinfection including NDMA in the treated water. West Montrose are currently receiving a new disifection system (UV irradiation) with a whole new source of water a couple of years away. Maryhill deserves the same upgrades.

JAIMIE CONNELLY'S (M.O.E.) DNAPL LETTER OF MAY 2, 2008

A week ago here in the Advocate while discussing Jaimie's letter I advised readers about Jaimie's comments concerning source removal versus hydraulic containment as well as Dense Non-Aqueous Phase Liquids mobility in the subsurface based upon its' thickness (viscosity). Today I will discuss other issues he raised in his ten page letter. Keep in mind this letter was kept hidden from myself by the old CPAC Chair as well as by Chemtura/CRA and the M.O.E.. Afterall they knew damn well I would raise it at CPAC if I had it and they made certain never to mention it themselves until I attacked them over Jaimie's April 3, 2006 DNAPL letter. Meanwhile we are advised in the March 27, 2014 CPAC Minutes by Steve Quigley of CRA that hydrogeologist Wilf Ruland wrote a May 15, 2008 letter. This letter similar to Jaimie's May 2, 2008 letter allegedly reverses his position on the presence of off-site DNAPL on the Yara property. Again this letter was not distributed to the Elmira stakeholder who has attended more CPAC meetings over more years than virtually any other, namely me. Public consultation was always intended to be seen but preferably not heard from. It also helps imeasureably if the guilty parties are able to sucessfully co-opt some of the locals.

Jaimie's letter at paragraph 12 states "...that DNAPL is not likely present in the off-site M2 area." Then at paragraph 15 Jaimie states "...the locations of many of these elevated detections suggested a degree of DNAPL movement which seems unlikely." Hmmn! "unlikely" and "not likely"; it seems likely to me that Jaimie wouldn't bet the farm on either scenario just yet. Later in his letter he suggests an alternate theory involving acetone as a co-solvent but here again the proof isn't yet available so he recommends some bench scale testing of this theory. I wonder why I suspect that this has been done, written up and there's yet another letter out there I haven't seen? I do know that in CRA's August 2007 DNAPL Report (Appendix B), which Jaimie is commenting on, that co-solvent effects of acetone upon MBT (mercaptobenzothiazole) could not be substantiated.

At paragraph 17 of his letter Jaimie indicate that CRA's Effective Solubility calculations were done incorrectly. He then does the calculations which clearly show how dramatically the solubilities of solvents in groundwater are reduced by the presence of multiple compounds. Some organic solvents have their solubilities reduced by a factor of ten and others are reduced hundreds and even thousands of times from their lab solubilities. This is stunning information which multiplies the weight of the 1% solubility rule incredibly. Afterall if chlorobenzene concentrations in groundwater are 3% of their lab solubilities but 100% of their effective solubilities then you have DNAPL nearby and if these concentrations go on for years then it is most probably free phase DNAPL.

In paragraph 1 Jaimie takes a serious round out of CRA's oft repeated nonsense that declining concentrations of DNAPL chemicals here and here means there is no DNAPL present. Jaimie states "Where concentrations stabilize at elevated levels in spite of this flushing action, that is likely indicative of NAPL presence or else a large mass of adsorbed or solid contamination.".

Jaimie disagrees with CRA's conclusions in his paragraph 4 and 5 that DNAPL does not exist in RPW7 and M2.

Jaimie feels in his paragraph 9 that NAPL is present at or near the main tank farm and should be further investigated. he also has concerns with high chlorobenzene concentrations found intermittently on the east side at OW70 and OW72. These concentrations suggest to him the possibility of mobile DNAPL.

This document similar to the October 7, 1991 "sweetheart" deal aka Settlement Agreement with Uniroyal should have been distributed widely and was not. They both taint Chemtura, the M.O.E. and their fellow travellors. I guess when the facts are against you, deception and manipulation are your best friends.

ELMIRA INDEPENDENT COVERAGE OF CPAC MEETING

Last Friday's Elmira Independent carried this story "In-situ remediation project moves forward". Currently after two allegedly unsucessful locations to pilot test chemical oxidation, Chemtura believe they have found one. It is on Industrial Drive south of Oriole Parkway. There is a well named CH38 on the Sanyo Canada property that has had extremely high NDMA readings for more than two decades and it is this area and southwards near pumping well W3 that may be treated with ISCO. ISCO or In-situ chemical oxidation does exactly what its' title implies. It oxidizes other chemicals. In the case of carbon based (organic) chemicals such as chlorobenzene (C6H5Cl) it reduces the contaminant (chlorobenzene) by joining oxygen (O2) with the carbon to produce carbon dioxide (CO2) and as well adds oxygen to hydrogen (H) to make water (H2O). Allegedly it can break down NDMA (CH3)2 NNO or C2H6N2O similarily. While I am a little skeptical about this I will investigate further before expressing too strong of an opinion.

There was a second article in the Independent titled "MOE plans DDT study". It is fair to say that the initial studies in 1996 should have been followed up in a timely and scientifically valid method and were not. This is part of the reason that I am suspicious of what is belatedly happening now. It is interesting that as the Chemtura Public Advisory Committee (CPAC) gain traction on the cleanup of the Elmira Aquifers; the M.O.E. appear to be changing channels and direction. Over the decades the M.O.E. have done this before when Chemtura (Uniroyal) were under pressure.

RECYCLING IN GRAVEL PITS & HIGH PRAISE FOR CPAC

The Woolwich Observer carry this story in yesterday's paper "Toxic recycling to become more common at gravel pits, watchdog group warns". Meanwhile Thursday's Elmira Independent carried an Editorial by Gail Martin that really caught my eye titled "Making good things happen". While these two topics aren't remotely related I'm including both of them today because it's just not that often that two different important local environmental stories are in the media.

Ontario's Provincial Policy Statement (PPS) for 2014 has thrown a last minute curve at gravel pit activists. Without public consultation it has included the promotion of recycling facilities in pits and quarries. This was one of the issues at the Jigs Hollow Pit and was opposed unsucessfully to the end by at least one Woolwich Councillor, namely Bonnie Bryant. The issue of recycling concrete and asphalt is this. Asphalt above ground on dry land is essentially innocuous. When submerged as occurred in Teviotdale on the Berendsen farm it will leach various petroleum hydrocarbons into the groundwater and nearby wells. The Ontario government, Ministry of Transportation and Ministry of Environment threw the Berendsen family to the wolves. The government buried the asphalt in a swamp and then lied unmercifully for years while the Berendsens' cattle died. There are also huge issues with asphalt and concrete being ground up and or crushed. Air emissions especially of silicates from concrete are extremely hazardous. Again shame on our provincial Liberal government for sneaking this into the PPS surrepticiously.

Gail Martin of the Independent has written an Editorial praising the efforts of the volunteers on the Chemtura Public Advisory Committee. Associated with CPAC is the SWAT subcommittee (Soil, Water, Air & Technical) of which I am a member and which I hope she is including. The issue at the moment is the decision by the Ontario Ministry of the Environment to do another study of creek sediments and floodplain soils downstream of the Chemtura site, in the Canagagigue Creek. Gail is very optimistic that good information will come from this M.O.E. study and indeed it is worthy because more or fresh Dioxins and DDT found downstream will pressure the M.O.E. to order more cleanup of the Chemtura site. The M.O.E. have oft used the excuse that they can't order on-site cleanup unless contaminants can be proven to still be leaving the site. This argument is pathetic on all levels but is bolstered by the fact that 99.5% of all studies and reports are done by Chemtura's highly paid for decades, client driven consultants. Who wouldn't want the Chemtura gig and the guaranteed lifetime income stream associated with it? Lifetime that is if you behave.

Therefore I hope that Gail's optimism is correct and my pessimism based on the M.O.E.'s history is wrong. There are a thousand ways to jigger scientific studies and the partners in pollution on this site know them all. Allegedly CPAC will have input into the Work Plan produced prior to the study. That Work Plan may require as much study or more than the final results.

WATER TREATMENT IS DANGEROUS IN MORE WAYS THAN ONE

Well if nothing else Waterloo Region residents are getting a basic lesson in both Chemistry and peripherally in water treatment. The slogan "Better living with Chemistry" is a public relations ploy that of course is only half truthful. At the Greenbrook TREATMENT PLANT and Pumping Station, a Chemistry 101 experiment blew up literally. Housewives my wife assurred me, possibly a tad condescendingly, all know never to mix bleach (chlorine) with Ammonia. Why you ask by the way did I capitolize the above words "treatment plant"? I did so because between yesterday's and today's articles in the Waterloo Region Record I can't find the words "treatment plant" in reference to Greenbrook. Very strange. Am I reading too much into that? Does the Region think that citizens are so incredibly dumb that they can't figure out what chlorine and ammonia are used for? That maybe just maybe they aren't being used to wash the floors or toilets?

Both chemicals are used at Greenbrook as part of the disinfection of water. In other words they are used to kill bacteria. There are other chemicals used including hydrogen peroxide. As well Ultraviolet (UV) irradiation is part of an Advanced Oxidation Process used to remove 1,4 Dioxane a toxic chemical whose source I believe is the former Ottawa St. Landfill. Prior to its' disposal in the former landfill it came from private companies including Varnicolor Chemical in Elmira.

Therefore the point is this. Mere storage of toxic and reactive chemicals is dangerous in the first place. More dangerous however is the use of toxic chemicals in water treatment. Chlorine and ammonia combined form chloramines. Either chlorine or chloramines KILL bacteria. Think about pesticides and herbicides for a moment. DDT, 2,4-D, 2,4,5-T are all poisons by design. They kill either insects or vegetation. Unfortunately they also have killed birds, wildlife and humans via impurities within themselves (dioxins in Agent Orange). Chlorine and chloramines chemically react in drinking water and produce Trihalomethanes, Haloacetic Acids, Cyanogen Chloride, NDMA and the list goes on. These unintended by-products of disinfection won't kill as fast as E.Coli (0157) bacteria for example. But they will kill given enough time and even the slightest lack of extreme vigilance in water treatment. Whether human error as occurred on Wednesday or mechanical failures; water treatment is dangerous to our health. Today's Record article is titled "Pump station explosion inquiry in "early stages".

HAS NDMA BEEN PRODUCED FOR YEARS AT THE WEST MONTROSE WATER TREATMENT PLANT ?

There are numerous scholarly research papers published linking NDMA production with public water treatment using chloramines. Indeed this is the reason there is a formal drinking water standard of 3 mg/litre (parts per million) of chloramine in treated drinking water. The chloramine helps kill bacteria from the treatment plant to the taps in our homes but above 3 mg/l it is dangerous. Chlorine actually kills most of the bacteria from the wells (raw water) and into the treatment plant. Ammonia via ammonium sulphate is added to the chlorine present to produce chloramine which lasts longer in the distribution system than chlorine. Chloramine also produces fewer Trihalomethanes (THMs) than chlorine which is a good thing. Unfortunately chloramine produces other toxic by-products of disinfection including NDMA. Agencies with on-line research articles on this subject include the U.S. Environmental Protection Agency (EPA), the National Health Service (U.K.), Wikipedia, and the World Health Organization.

I distributed the article from the World Health Organization via e-mail yesterday to Woolwich Township, two Councillors (B.Bryant & M. Bauman), CPAC, SWAT, three local newspapers and one West Montrose resident. I also left a phone message with two other West Montrose residents. This article indicates that NDMA concentrations have been found in drinking water distribution systems using chloramine; far in excess of any levels measured at the treatment plant itself. To date the Region of Waterloo have not shared any of their NDMA test results for West Montrose with the residents or the public via their Annual Drinking Water Reports. The WHO article also indicates that NDMA is both carcinogenic and genotoxic.

The information I received Wednesday afternoon claims that currently the West Montrose treatment plant is shut down while being converted from chlorine/chloramine treatment to Ultraviolet irradiation. My understanding is that UV does not produce THMs or NDMA therefore this certainly appears as a step in the right direction. The obvious question however is why scrap the current system for a temporary fix of a couple of years? The Region are in the process of deciding on a totally new source of water for West Montrose. Based upon long standing bacterial contamination of the raw water, this decision is overdue by at least ten or fifteen years. Temporarily replacing the current system with a totally different disinfection system speaks to the Region's belated acknowledgment that THMs and possibly NDMA among other toxic by-products, are a serious health issue.

THE REGION OF WATERLOO'S DECEPTION IS COSTING LIVES

Can that above title be proven beyond a reasonable doubt in our court system? I would say yes given two conditions and those are unlimited funding and a scrupulously honest judge. The second condition is more likely than the first. The first I would indeed suggest is impossible.

Yesterday afternoon I had my information sharing sitdown with Woolwich Township. I will admit that I had doubts that the meeting would be valuable especially since the Engineering & Planning Director had reported back to Council at the public Council meeting the evening before. His information was based upon alleged facts given to him by the Region of Waterloo. In attendance were Councillors Mark Bauman and Bonnie Bryant as well as Mr. Kennalley the E & P Director. Both Councillors (especially Mark B.) have been on the receiving end of criticism from me here in the Advocate over the last few years, therefore they knew going in that short of personal exchanges/confidences; everything else was up for public distribution. Both Councillors were informed, serious, concerned and apparently eager for more technical information about the West Montrose water system and associated problems. Neither they nor I were disappointed.

While we focused on West Montrose, other Woolwich Township water problems were at least briefly mentioned. These included the Trichloroethylene contaminated water from the William St. Wellfield in Waterloo coming up to Elmira, chloramines in Maryhill's water, and the longtime presence of petroleum hydrocarbon contamination in the natural environment in Heidelberg. Regarding West Montrose I was able to show the Councillors and Director some of the inconsistencies in regional reporting of Adverse Incidents. For example one incident of a high Turbidity (cloudy, discoloured water etc.) reading caused a Boil Water Advisory in West Montrose yet subsequent worse readings over the years weren't even reported as Adverse Incidents. Similarily the language in the Annual Reports is deceptive and not remotely clear or transparent. Even the reporting of Adverse Incidents which specifically refers to contraventions of the Safe Drinking Water Act are not so stipulated. The lack of any drinking water standards means these Reports are not stand alone reports as so much vital information is missing. I pointed out that the E.Coli and total Coliform detections in the raw water are in a class all their own and this is a very bad thing. Also exceedances of the Safe Drinking Water Act by chloramines are minimized by the Region not saying exceedances, not giving the exact numerical value and not telling us what the standard is. I believe all three Township officials left this meeting with a much improved understanding of how we all have been kept in the dark by the Region of Waterloo.

Information from Tuesday's council meeting was shared with me as I was attending a meeting of the Woolwich Bio-En Citizens Liason Committee at the same time as Council was in session. It is stunning. I was well aware that water tankers replenish the water reservoir on Tallwood Dr. in West Montrose. The public were advised Tuesday evening by Mr. Kennalley that the entire West Montrose well system has been shut down entirely for the last month and that water tankers are currently the sole source of water for the community. Nowhere in the Region's Annual Reports for the last ten years does it ever mention the necessity for diluting, supplementing or entirely replacing West Montorse's water supply. These tankers have augmented/diluted the water supply at the rate of four tankers per day during the warmer summer months and two tankers per day during the rest of the year. Further we were advised that while a brand new source of water is two to three years away (from K-W) via a pipeline; the current water treatment system using chlorine and chloramine is being scrapped. In fact a whole new system using Ultraviolet radiation is currently under construction thus necessitating the shutdown. Finally after more than a decade of being in charge of a water system with badly contaminated source water, the Region have gotten serious. Of course the new disinfection system still will be dealing with badly contaminted raw water and of course the Region of Waterloo would rather cut off their own arms than admit to serious and potentially deadly health issues over the years in West Montrose.

In my opinion the lying and deception are of a criminal magnitude. Year in and year out the Region of Waterloo have publicly and repeatedly advised the residents of West Montrose that their water was safe, secure and healthy. All three are blatant lies. Whether via the risk of bacterial contamination or the ongoing exceedances of health standards by the by-products of disinfection; West Montrose residents have been put in harms way by regional officials untruthfulness. West Montrose is not the only community in the Region of Waterloo who have sufferred due to contaminated water but it is decades overdue for all our authorities to tell us the uncomfortable and personally inconvenient truth.

LAST EVENINGS WOOLWICH BIO-EN CITIZENS LIASON COMMITTEE MEETING

Last evenings meeting at the Rec Centre in Elmira had a few more bodies in the visitors chairs than usual. By the way the next meeting is scheduled for 7 pm. Tuesday May 6, 2014 at the public library. The previous meeting in early March had raised some concerns which caused CLC member Michael Purves Smith to bring a page of questions to this meeting. They dealt with Water, Biological feedstock materials, methane gas for vehicle use, possible expansion of the facility and potential increases to truck traffic.

The first question received a simple no there would be no increase in municipal water use occasioned by the requested amendments to the Renewable Energy Act (REA).

In regards to biological feedstock sources both Earl Brubacher and Chuck Martin emphatically stated there would be no human or medical wastes involved at the facility. The requests for mushroom wastes etc. is needed because the M.O.E. require upfront specific feedstocks in writing. Generalized food wastes isn't adequate for them. ICI or industrial, commercial and institutional wastes are simply cafeteria food wastes etc..

The proposed use of methane gas as a fuel for trucks will not require any changes to their infrastructure. Impurities will need to be removed from the methane such as CO2, hydrogen sulfide, ammonia and particulates. This is a demonstration project that was brought to Woolwich Bio-En by the Bio-Gas Association. It is a pilot project and is also a form of public relations for the Association. There is an existing pipeline in town which can be accessed near the Woolwich Bio-En plant and the gas can be removed at the south end of town at the proposed retail outlet.

Chuck Martin suggested that if and when Bio-En required more gas production they would probably build a second plant. Meanwhile that is highly unlikely because currently the Ontario government are not offerring any power from gas contracts whatsoever . There was a long discussion on truck traffic which included Bob Jonkman, Michael Purves Smith, Vivienne Delaney and numerous CLC members. Gerry Heiduburt contributed to this and other discussions around technical process matters. Michael's understanding was that 80 total truck movements per day was the agreement. Chuck explained that under ordinary production they would be having substantially less than that but would be pushing up against the 80 maximum if and when they had a problem and were forced to empty their system out. In fact Chuck feels that Michael's estimate of normal use of fifteen trucks in and fifteen out per day is high. Chuck believes that when all is working properly and there are no breakdowns or serious production issues they can get away with perhaps only seven trucks in and out per day for a total of fourteen or fifteen truck moveents. Incoming trucks and associated odours were also discussed. It appears that plant odour suppression systems are "robust". All parties agreed that incoming trucks must be closed or covered and if the covering is only a tarp; regular odours will not be tolerated including by Woolwich Bio-En.

In regards to paper sludge from paper mills I raised a question about chlorine being mixed in. I was assurred that all incoming feedstocks require testing prior to delivery. In fact salt (NaCl) or chlorine would be harmful to the bacteria in the Digester and won't be accepted. Apparently sources are tested annually or every 1000 tonnes whichever comes first.

The engines have been tested on natural gas and they will be tested using the methane gas produced, in about six weeks. We were advised that while there is no minimum power production demanded by the Ontario power Authority nevertheless all electric power produced must be sold to them. Overall the entire bureaucratic process has been onerous and in hindsight Chuck was skeptical if he would have gone ahead eight years ago if he knew the extent of red tape necessary.

PARTNERS IN POLLUTION'S CREDIBILITY TAKES A HIT (CRA, Chemtura, M.O.E.)

Since last Thursday evening's public CPAC meeting two documents have miraculously been produced from Woolwich Township's archives. The first is the CPAC Minutes of April 24, 2006 and had been properly distributed eight years ago. The second is a May 2, 2008 letter from Jaimie Connolly (Ministry hydrogeologist). It was not properly distributed to all the longterm stakeholders including myself. Funny thing is Woolwich Council had just given me the boot from CPAC a couple of months earlier and CPAC Chair Pat McLean was in charge of distribution. What she lacked in technical knowledge and ability she made up for with political shrewdness.

Jaimie Connolly's letter will haunt Chemtura/CRA for many years. Their refusal to produce it upon request from me at public CPAC meetings is also relative to their ongoing verification plans with the Chemical Industry Association of Canada. Refusing to produce documents that you are relying on to make a hydrogeological point because it hurts your position on other points is not the *Responsible Care way. Ethics and transparency are not to be doled out just to your supporters but to all stakeholders.

Jaimie's letter speaks to the varying thickness (viscosity) of DNAPL chemicals. These Dense Non-Aqueous Phase Liquids gravity flow downhill with no regard for either groundwater flow direction nor for nearby pumping wells (hydraulic containment). Some of Uniroyal/Chemtura's DNAPL has been thin and very mobile and most of it has long ago flowed to low points on top of aquitards or low permeability zones. The thicker DNAPL sometimes described as motor oil consistency or even as tars will move much more slowly. Keep in mind the thusly described DNAPL at TPW2 in 1993 wasn't all removed and yet was no where to be found during the drum removal excavations from there a couple of years ago. It clearly moved! Therefore the M.O.E.'s longtime excuses that they can't order on-site cleanup due to containment is clearly specious. Not only is groundwater moving off site by design in the north-west Municipal Upper Aquifer under the Optimization plan but it is also leaking from the shallow aquifer into the Canagagigue Creek in areas where there are no pumping wells. The Municipal Lower and Bedrock aquifers are also not contained on site. Finally as stated earlier DNAPLS have and will continue to gravity flow off the Chemtura site whether Jaimie agrees in 2006, disagrees in 2008 or comes around again at a later date.

Of course for me Jaimie's biggest revelation is on the second last page of his May 2, 2008 letter. This is why the partners in pollution wouldn't release Jaimies's letter. All's fair in love and war and for years they had a friend as Chair of CPAC. The benefits to both parties were significant. They knew that if I had had that letter I would have trumpeted Jaimie's revelations years ago. Jaimie unequivocally makes it clear exactly as the young CPAC did in 2012 that hydraulic containment on its' own is inadequate to clean up the off-site aquifers. Source removal or reductions in source concentrations are vital!

The April 24, 2006 CPAC Minutes have a detailed discussion of DNAPL issues and proposed source removal. I also discussed In-Situ Chemical Oxidation (ISCO) in those Minutes relative to trichloroethylene removal from the Bishop St. community in Cambridge. Chemtura/CRA/M.O.E. were asked by me eight years ago whether ISCO could be used in Elmira. This is not by far the first time citizens have proposed solutions that were disparaged by the experts (CRA/Chemtura/M.O.E.) only to be embraced years later. Again on page two the Ministry of the Environment and Jaimie proclaim their support for source removal/remediation versus relying solely on hydraulic containment (ie. pump & treat). Therefore source removal has been requested/demanded in July 2003 by CPAC, 2006 by Jaimie C. & the M.O.E., 2008 again by Jaimie C. and finally in 2012 by the CPAC Resolution. Twenty-four years to date of screwing around folks. Less talk and more action! Chemtura shit or get off the pot! Either clean up properly or get the hell gone so somebody else can clean up your mess!