THIRD WORLD ENVIRONMENTAL NEGLIGENCE IN ELMIRA

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

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

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

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

CHEMTURA & ONT. M.O.E. STONEWALL

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

WAYNE GRETZKY, INTERCEPTOR TRENCHES & STICKHANDLING

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

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

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

CHEMTURA ARE GIRDING THEIR LOINS AND PREPARING THEIR EXCUSES

CPAC's November meeting is this coming Monday evening (Nov. 24/14) at 6 pm.. Chemtura and their partners in pollution have some serious explaining to do which however may prove very difficult. As has been stated many times the presence of a groundwater interceptor trench or any other subsurface works on the east side of their site is not a requirement or prerequisite for the data now available regarding leakage and overflow of liquid toxic wastes off their eastern property line. Peter Gray's (MTE) report is a stand alone document as is the Stroh Drain information discovered this past May. Both make it very clear that Chemtura's liquid wastes have flowed inappropriately onto their neighbour's property and from there via the Stroh Drain into the downstream Canagagigue Creek.

The evidence continues to mount as was presented last evening to CPAC & SWAT at their Working Session prior to next Monday's public meeting. I found one of many pieces of the puzzle in Conestoga Rovers & Assoc. Annual Monitoring Report No. 28 (2009) on pages 136 and 137. "Flexible, black plastic 2-inch diameter pipes oriented north-west to south-east were encountered approximately .5 to 1 m bgs (below ground surface) in test pits TP15-09, TP13-09,TP17-09 and TP18-09. CRA noted the presence of some water and soil in some of the pipes and some grey or black staining near some of the pipes. Chemtura does not have any record of these pipes or what their purpose was. There were never any chemical manufacturing activities on the east side of the site. The pipes may have conveyed liquid wastes or controlled drainage in areas where historic waste disposal occurred."

CRA's last sentence is a bombshell. Keep in mind these test pits encircle monitoring well OW42 which is just barely inside (ie. upgradient or east) the readily apparent line, scar or trench. There should not have been any conveyance of liquid wastes or controlling of drainage via pipes beside RPE-5. If there was it has not been explained clearly to CPAC and it desperately needs to be done. The impression already is that there has been inappropriate flow of toxic liquid wastes onto the Stroh property. Were these pipes assisting that inappropriate flow or were they somehow trying to mitigate that off-site flow?

Further issues abound. These pipes are located directly between a possible groundwater interceptor trench and a toxic waste pit which handled pesticides including DDT as well as Agent Orange waste streams. Both black and grey stained gravelly fill were also found in the area as well as the black and grey staining found near the pipes mentioned in the preceding paragraph. What exactly does it take to get the Ontario Ministry of the Environment to act? Are the contaminants just mentioned as well as DNAPLS which went through the bottom of these pits still leaking and draining off-site? The public need a champion to protect both the environment and the health of neighbours. The M.O.E. have abrogated that role a long time ago.

CHEMTURA OCTOBER 2014 PROGRESS REPORT

The good news to report is that the off-site pumping rates for the month of October all achieved their reduced pumping targets. That is exactly one month in a row and signifys something indeed when they have been stumbling while their performance expectations have been continually dropping. If and when they ever achieve the promised tripling (Ha!) of their off-site pumping target rates it will be indeed a miracle if they can string two or three months together in a row based upon their poor pumping history. On-site pumping was a tad more problematic as their pumping well PW5 was down for maintenance. Hence PW5 achieved 1.8 l/sec while the target is 2.0 l/sec.

This Progress Report has considerable data regarding various wells and boreholes being installed both in support of the promised enhanced off-site pumping as well as regarding the historically high NDMA concentrations found west of Chemtura in well OW60. Other wells installed in the area have to date not found NDMA at those elevated concentrations. I am beginning to think that when the smoke clears we are going to end up with some backyard commercial mechanic or even a do it yourselfer who's been dumping motor oil and or hydraulic fluid for years into a hole in his backyard. Stranger things have happened.

From MISA discharges to very little odd in the surface water of the "Gig" there is very little change since last month. BEHP (a phthalate) is still entering the Chemtura property in the "Gig" at higher concentrations than it is leaving downstream. How weird is that?

MEMORIES ARE A TRICKY THING ESPECIALLY IF YOU HAVE A JOB OR FINANCIAL BIAS

Many times Jeff Merriman, environmental engineer at Chemtura in Elmira, has regaled us with his allegedly first hand observations during on-site remediation efforts. I have been quite pleased to look up the written records of those same remediations and prove Jeff incorrect. Interestingly, every single time, Jeff's alleged observations have always been of benefit to his employer, Chemtura Canada. Just sayin! Recently Graham Chevreau and Ron Campbell have indicated their dismay at what they refer to as Jeff's "calibrated" eyeballs. Apparently Jeff is able to determine the extent of soil contamination by visual observation thus negating the need for lab chemical soil analyses.

Today I was doing some light reading through the Annual Monitoring Report #12 (1993). It describes in glowing detail from page 63 to 66, including chemical analyses in Tables, the results of the partial excavation of TPW2 in 1993. Contrary to what Jeff has advised this current CPAC, hard tars were not the only type of NAPLS found. There were hard tars, soft tars and free flowing LNAPL as well. These tars were analysed and were a cornucopia of Uniroyal Chemical signature chemicals including Dense Non Aqueous Phase Liquids. Also leachate tests were performed on both the hard and soft tars and while there were different toxic chemicals released in water, both tars did leach into the water. Chemicals included 2,4-D and 2,4,5-T the components of Agent Orange.

Therefore Jeff as once again your memory is so bad perhaps in future rather than sharing it you could instead provide written documentation backing up your self serving claims. Thankyou.

SAFETY-KLEEN EMERGENCY DRILL

Today from 9 am. till 11 am. an emergency exercise will be underway in Breslau supposedly dealing with the crash of an passenger aircraft. Similar to Elmira, Breslau also have their own emergency siren. Isn't that comforting? You don't happen to think that that is just for show do you? Here in Elmira the siren gets tested every Saturday at noon sharp. We have had our share of explosions, fires, fugitive air emissions and more. The big one is still coming.

Breslau only wish that when, not if, it happens to them that the emergency will be over in just two hours. Many people don't remember that there was a small plane crash and fatality way back in the 60's when the place was called Breslube. To have that industry near residential homes is crazy and to have it located next to a growing airport is just nuts. Makes you wonder why Woolwich or anywhere in the Region have planning departments, doesn't it? This small article was in Tuesday's Waterloo Region Record.

IDIOT BUREAUCRATS VERSUS COMPETENT TECHNICAL PEOPLE RUN THE M.O.E.C.C.

A letter dated November 4, 2014 was sent by the Ontario Ministry of the Environment to the Township of Woolwich, in response to CPAC's October Resolution and Council's endorsement thereof. This letter was of course then appropriately distributed to CPAC and their SWAT sub-committee of which I am a member. I don't know whether to laugh or cry at the sheer stupidity, nonsense and woeful ignorance displayed in the letter. Then of course there is also the rudeness and disrespect inherent in the letter. It is clearly attempting to put Council on the defensive by suggesting they don't know what they are talking about and they are are not up to date on current issues. Also of course is the question as to which M.O.E. idiot actually wrote the letter. Talk about gutless wonders! There is a scribbled signature, nothing typed, that could be anything from Ilich to Wich then another handwritten word that could be "for". Beside that is the typed name of Mili New Director West Central Region. Hence we are to believe that the new director with all of thirteen months of experience in the M.O.E. has some nameless, anonymous mandarin writing a letter on her behalf to a municipality hosting the most contaminated site in the province. A municipality requesting assistance and action from the M.O.E..

We are incorrectly advised that the M.O.E. sampled downstream in the Canagagigue Creek during 2013 and 2014. The facts are that it was initially sampled in this latest round in 2012 and those DDT results were horrific. Horrific as in far worse than the original round in 1995-1996. Secondly the M.O.E. have graciously stated that they "...are willing to consider the grounds for CPAC's assertion of reasonable and probable grounds for more investigations...". Well bully for you! They then suggest they are willing to consider whether the MTE Report could withstand the rigours of a legal challenge. Really! How about you idiots for even five seconds considering whether Conestoga Rover's client driven reports "...could withstand the rigours of a legal challenge.".

The M.O.E. are informing us that Chemtura were requested to proceed with planning "...a soil sampling project on the east and south borders of their property.". This plan will be most likely a Conestoga Rovers & Associates Plan or CRAP for short.

WE LIVE IN INTERESTING TIMES

Last Friday I posted about the line, scar or trench running across the Chemtura site clearly visible by the Google earth satellite. Indeed there are three of them visible with two joining together and continuing southwards and then eastwards over to the Stroh property. Suddenly Peter Gray and the MTE Report carrys even more significance than Chemtura originally feared.

Since last Friday more evidence and facts have appeared. One, Jeff Merriman of Chemtura has claimed the obvious; namely that there is a fence across their property running north to south. He further states that the newest segment of the fence was installed in 1999 "to control access" presumably via the roadway running from the west side of their property across the creek to the east side. The second news relates to the Stroh Drain running parallel to the Chemtura property and within twenty feet of it at spots. Clarification has been received regarding agricultural drainage on the Stroh property and where it is located. Suddenly the north-south pipe discharging liquid into the top end (ie. north end) of the Drain is taking on a huge significance.

I listed the numerous possibilities that the line, scar or trench could represent in last Friday's posting including the
possibility that it represents nothing of significance. Several CPAC and SWAT members have expressed their skepticism regarding the opinions of Steve Quigley (CRA), Steve Martindale (M.O.E.) and Jeff Merriman (Chemtura). Looking at a huge map that I have of the site combined with the historical knowledge of discussions around the south-west Upper Aquifer Containment and Treatment System plus considerable further knowledge, I believe that on the balance of probabilities Chemtura have installed a form of drain to collect some of the contaminated shallow aquifer (SA or UA) and to divert it off-site on the east side. There at a minimum via dilution, natural attenuation and perhaps even wetland enhanced degradation, this contaminated flow eventually makes it way into the Canagagigue Creek, well downgradient of the Chemtura site.

If this is the case then it is no wonder Chemtura and the M.O.E. are running scared. While the environmental impact to the natural environment can and will be debated for a very long time; it is the immediate hit to three parties credibility
that terrifys them. Chemtura, the Ontario Ministry of the Environment and Chemtura's consultants Conestoga Rovers are up to their necks in it. In the twenty-five years since the drinking wells were shut down in Elmira there has been exactly zero mention of any manmade plumbing works or shallow groundwater control or treatment of the east side. Unless or until Chemtura and fellow travellors speak up forthrightly and completely; then my belief persists. Calling it a fence and claiming the issue is closed isn't going to cut it.

CONTROLLED ENVIRONMENTAL DESTRUCTION VERSUS UNCONTROLLED ENVIRONMENTAL DESTRUCTION

Bizarre and absurd are appropriate words to describe the desperate stickhandling of Jeff Merriman, environmental engineer at Chemtura. A CPAC member has pointed out what in hindsight may be the most ridiculous statement of the year, despite tons of eligible whoppers already. Jeff and Steve Quigley of Conestoga Rovers were unhappy with the MTE Report presented a week ago last Thursday by Peter Gray. Now they already had a chip on their shoulders as they had been unable to obtain a copy prior to the meeting and thus be able to better attack the report. While they have indulged for decades in refusing to release reports ahead of time to CPAC, they sure think that their exalted status should permit them better treatment.

I referred to references in a number of reports including Peter's (MTE) report detailing "overflow" of toxic liquid wastes from Uniroyal's eastern pits namely RPE 1-5. This "overflow" went west, south and east, hence off Uniroyal's property onto the neighbouring farm. Keep in mind while RPE 1-5 are almost sitting on the property line, three other toxic pits namely BAE-1, RB-1 and RB-2 literally are sitting exactly on the property line. Yes that situation is beyond ridiculous but never fear Chemtura have raised ridiculous to new heights.

In an effort to deny "overflow" Jeff again shared with us his story of the past Indusrial Relations Manager, Harry Soehner, advising that Uniroyal staff on a somewhat regular basis would either open or breech these toxic ponds to intentionally let their contents flow onto the bare ground and run downhill across this permeable ground surface for hundreds of metres south into two former gravel pits, namely GP1 & 2.

Therefore in its' essence Chemtura's environmental engineer has advised CPAC, the public and Mayor-elect Sandy Shantz as well as Councillors-elect Merlihan, Hahn and L. Shantz that it's O.K. for Uniroyal/Chemtura to wilfully destroy the natural environment as long as it's done in a controlled fashion. Thank you Jeff for that insight.

MORE PHONY PUBLIC CONSULTATION - WEST MONTROSE & CONESTOGO WATER SUPPLY

Yesterday's Woolwich Observer carrys an ad for a public consultation meeting about the Environmental Assessment of the Conestoga Plains Water Supply System. It is my understanding that the completed EA of the West Montrose water supply was inherently bogus. This occurred by the usual methods of giving the public either inaccurate information or essential non information. Also subjective weighing of options was simply to promote the Region of Waterloo's already arrived at conclusion. Unfortunately as I recall West Montrose residents were advised that Conestogo had high quality water in abundance and hence they could hook into their supply via a new pipeline. Now we learn that Conestogo's quantity and quality really aren't that good don't you know; so golly gosh we're going to abandon the Conestogo wells in favour of hooking into the Region's Integrated Urban System via a pipeline to St. Jacobs. This IUS system is a blend of Grand River water and wells throughout Waterloo, Kitchener and Cambridge of various qualities. I suppose the good news is that this blending of many dozens of wells plus river water does tend to dilute the various industrial contaminants that are in the raw (& finished) water from wells throughout the region. The public meeting will be held at the Conestoga Golf & Country Club on Thursday November 20, 2014 from 5:30-7:30 pm..

IT'S A BIRD, IT'S A PLANE, NO IT'S SUPERDITCH !

There are a number of options around the line, the scar or the trench obvious in Google Earth satellite photos of the Elmira, Chemtura property. One option is that it is essentially of little or no significance. Hey it's an option. Maybe it is a fence left over from literally 75 to 100 years ago although it's shape, purpose and location seem to make that unlikely. Jeff Merriman of Chemtura has been talking about the deceased and strongly pro Uniroyal former Industrial Relations Manager Harry Soehner; who allegedly advised him that "furrows" were ploughed to divert overflowing liquid wastes from the east pits due south into the former gravel pits GP1 & 2. Bad news Jeff. That really doesn't help your case. What an incredibly ridiculous and environmentally damaging action that was. These were toxic wastes of the NDMA, Dioxin, DDT and solvents category all mixed together. They would have contaminated the air, the soil and the groundwater every step of the several hundred metres south from RPE1 down to GP1.

If it was an attempt to either block contaminated groundwater from entering the downgradient Canagagigue Creek or to even partially treat this contaminated groundwater; then why the secrecy and frankly lying about it? If it is a barrier wall then is the contaminated groundwater being collected for treatment? Is it being treated on site or is it being treated at taxpayers' expense at the Elmira wastewater plant? Or is it simply being diverted into the joint wetlands on the east side of the site to be "remediated" by the cattails and bulrushes? Is it even possible that it is a collector trench which is diverting groundwater from Chemtura's property directly (or indirectly) into the Drain on the Stroh property?

Conestoga Rovers, Chemtura's very long time consultants, like to brag about their expertise on line. This includes articles, surprise, surprise about sites where they have installed collector trenches, Permeable Reactive Barriers, barrier walls with funnel and gate PRBs and various other technologies to either divert, collect, or treat contaminated groundwater. CRA are also very big on the advantages of Natural Attenuation of leachate escaping from landfills. This essentially is the do nothing, spend nothing alternative. In other words this is similar to Uniroyal's behaviour of burying toxic wastes in the ground and praying that the ground itself would "nuetralize" the toxins. We have all seen how well that worked for them and not so well for us.

Ontario Ministry of the Environment you have to step up whether you want to or not. These above questions need answering and soon they will be coming from all quarters. Both you and Chemtura have many reasons to hang your heads in shame. Get out in front of this issue and tell the truth whether it's a minor indiscretion, no indiscretion or the biggest one of a series of whoppers.

ELMIRA INDEPENDENT'S WRITEUP OF LAST WEEK'S CPAC MEETING

Today's front page headline in the Elmira Independent is ""High potential" for offsite contamination". Gail Martin's story describes last Thursday's Chemtura Public Advisory Committee (CPAC) meeting including the presentation by Peter Gray of MTE Consultants. Gail quotes Peter as saying "Based on all of this, I think there is a high potential that groundwater and soil east and south of the site could have been impacted by leakage of the east-side pits". Gail advises that this is quite significant because it could empower the Ministry of the Environment to lay a Control Order on Chemtura, ordering them to clean up the adjoining Stroh and Martin properties. While that is always a possibility most likely the M.O.E. will do what they always do which is hold private backroom meetings with Chemtura and play "Let's make a deal".

This MTE Report is part of the basis for CPAC's October 14/14 Resolution endorsed and accepted by Woolwich council. This Resolution requesting a formal, comprehensive investigation of the soil and groundwater east of Chemtura, allegedly is currently being reviewed by the M.O.E..

There was also significant discussion and questioning around the Drainage ditch on the Stroh property which runs parallel to the Chemtura property line and then discharges into the Canagagigue creek after passing the Martin swimming pond. After that further questions arose from myself in regards to the line, scar or trench on the Chemtura property which runs from north (Church St.) to south and then jogs east to the Stroh property line.

Gail also mentioned the presence at the meeting of incoming Woolwich Councillors Larry Shantz, Scott Hahn and Patrick Merlihan. Mayor-elect Sandy Shantz also attended the meeting.

This CPAC's term runs until April 30/15 due to the delays in getting started caused by Mayor Cowan and Councillor Herteis. These delays and ensuing behaviour by that pair ended up causing the departure of Lynne Hare, Julie Anne Herteis and myself. Hence Council to their credit added on six months to the end of CPAC's term to give them their full four years plus I understand that this extension will permit a more seamless overlap and continuation of future CPAC's after municipal elections as well.

JEFF & DWIGHT WHERE YOU AT? BLOOD IS IN THE WATER

O.K. O.K. I admit I'm human and every now and then have to poke a little fun at Chemtura's chief spokespersons. They had advised me publicly at last week's CPAC that it wasn't their head office U.S. on the Elmira Advocate every day, it was them. Interestingly my Statcounter program hasn't picked them up since then. Wow are these guys so concerned with appearances (yes!) that they've changed computers or networks or whatever it takes not to have Chemtura show up on my stats? Rest assurred I know you and the Ministry of Environment are still reading. Regarding Steve Martindale (M.O.E.) none of us are perfect and have never made mistakes. If it helps you any I understand the pressures and difficulties you are under and that 99 1/2% of the time you behave admirably despite that. You whispered in my ear on your way out of the meeting last Thursday and I accept and thank you for those words.

There is indeed blood in the water right now both for M.O.E. credibility and Chemtura's and even perhaps Chemtura's longtime consultants. Steve Quigley didn't look so good to me and others with his nonsense about non existent upper aquifers. Keep in mind the MTE Report by Peter Gray has now been distributed as well as being on the township's website in its' entirety. Therefore read it carefully and criticize it even more carefully because it is partly based upon reports produced by the partners in pollution Chemtura/CRA/M.O.E.. Or as one CPAC member advised me yesterday are we to now assume that all reports from these three are only honest and accurate on alternating months? In the alternative are we to assume that they are literally riddled with lies and deceptions from cover to cover and therefore we can not rely or quote them at all? Peter Gray used many published reports by allegedly professional engineers, hydrogeologists and other experts. While your criticism smacked of desperation and habit last Thursday you should have held your comments until you'd read his report carefully. What's the matter you buggers? Don't you appreciate being treated in the exact same fashion that you've treated me, CPAC and the public for the last quarter century?

Looking forward to our next tilt. Billy B., George K. and Josef O. are gone. You could replace Dwight and Jeff as well for what good that would do. The only way you will earn either respect or trust is to start speaking the truth.

THE UNIROYAL TRIALS - WILL WOOLWICH BE ASKED WHY THEY CONSTANTLY HANDCUFFED CHEMTURA'S STRONGEST CRITIC ?

Despite the above title, today's posting as advertised yesterday, will focus on the line, scar or trench running north to south and then east across Chemtura's property, east of the Canagagigue Creek. The title refers to past Woolwich Councils penchant for pleasing Chemtura and the Ministry of the Environment by keeping their strongest and by far most knowledgable critic off of the Chemtura Public Advisory Committee. That said, as was posted last Wednesday (Good Riddance to Bad Rubbish), this last Council kept me off because the Mayor lied. While I know he had been under considerable pressure from both Chemtura and the M.O.E., only the M.O.E. (Bill Bardswick) have been stupid enough to admit it. Therefore Mayor Cowan may have succumbed to that pressure or else he just let his pettiness and personal intolerance of criticism have free rein .

At last Thursday's public CPAC meeting Lisa (CPAC Secretary) put up an overhead aerial view of the Chemtura site which clearly showed a huge line, scar or trench running across their property. This line etc. actually has two obvious arms which split apart south of the road that runs across the Canagagigue Creek from the west side of their site to the east side. This road ends up just below (south) the Envirodome. While these two "arms" were clearly seen by all who attended there is actually a third limb which is separate and runs parallel to the creek from above the on-site dam to below it and ends above (north) this same west to east road. Steve Quigley rather quietly and feebly suggested that these lines etc. are fences. First of all there were no "fences" in the 1955 or 1968 aerial (satellite?) photos included in their March 2012 Former Gravel Pit Investigation report. The line etc. is there in their 2010 photo. Jeff Merriman suggested that they were "farm fences". On the assumption that Chemtura have not in recent years suddenly decided to graze cattle on their contaminated property this seems unlikely. Also as there have not been livestock grazing on that land in at least 75 years it also seems unlikely. Finally there was no north-south fence running across that property back in 1991 when I, my binoculars and a bird book walked that area. If there had been I would have had to climb it and I climbed no such alleged fence.

It is possible that a "farm fence" can have a purpose other than containing livestock, groundhogs or even excluding coyotes, wolves and wild dogs. Most likely that purpose at Chemtura is to delineate exactly where constructed sub-surface works are located so as not to damage them with the occasional heavy earth moving, grading and excavating equipment used on the east side. Keep one thing clearly in mind and that is that there is good reason to suspect that these possible manmade constructed works are part and parcel of the proven Stroh Drain and the recently proven flow of groundwater and toxic liquid wastes off the eastern Chemtura border. The Peter Gray MTE Report made this off-site flow clear. Nevertheless the proven elements of leakage and overflow and then discharge into the Canagagigue Creek are not dependant upon this possible Trench etc.. It could simply be the cherry on top of the final destruction of any credibility or long claimed morals or ethics around the environment or human health the company pretend they have.

Engineered wetlands were proposed by Chemtura years ago to assist in remediating their contaminated groundwater. Similar to their ridiculous suggestion of "land farming" of toxic wastes; these engineered wetlands were given short shrift by CPAC. It is possible that Chemtura went ahead quietly without support or approval and constructed a method to deliver contaminated groundwater to their east side to be "remediated" by the combined Stroh/Chemtura wetlands. The fact that the line, scar, trench etc. encapsulates all the south and west groundwater flow from the east side pits and ponds makes me extremely suspicious. There are also other remediation technologies possible including either PRB's (permeable reactive barriers), biological barriers and even the famous Waterloo Barrier invented at the University of Waterloo.

Chemtura and the M.O.E. once again, after last May's discovery of the Stroh Drain, owe CPAC and the public an explanation. While both have publicly claimed they had no knowledge of the Drain, that seems ridiculous due to the recent verbal and written comments by the M.O.E. that they did a site tour of the property between Chemtura's south-east corner and the Martin swimming pond located in the floodplain of the "Gig" and did not find any possible contaminant pathway. Now they both claim they have no knowledge of a relatively recent line, scar or trench running two thirds of the length of Chemtura's property on the east side. Such utter rubbish.

MORE ON LAST THURSDAY'S CPAC MEETING

Tomorrow I will be spilling some of the beans regarding Chemtura's scar, line, trench or fence running from Church St., south and east over to their neighbour's property. Today I will mention items such as Peter Gray of MTE Consultants and his presentation Thursday evening. Peter stated that the driver of both shallow groundwater and surface water flow is the topographical high in Chemtura's north-east quadrant. Contrary to Chemtura and Conestoga Rovers' groundwater and surface contours, all the rain and overflow from the former pits does not simply flow west and south. There is a radial flow that distributes both rainfall and toxic liquids to the east as well.

Jeff Merriman of Chemtura as usual rose to their defence and quite comfortably BS'd that referring to the eastern pits as having "overflowed" was inaccurate. I pointed out that Jeff wasn't there prior to 1988 and hence he had no first hand knowledge of that matter. To further sink his leaking ship I quoted the 1991 Environmental Audit written by Chemtura's consultants (CRA) which stated that yes the pits did "overflow".

Mayor-elect Sandy Shantz asked an important question when she inquired as to where are we today regarding this eastern side of Chemtura's property. Graham Chevreau, Rich Clausi and myself responded by advising Sandy that CPAC had asked for a comprehensive investigation of this area that would include testing and monitoring of soils and groundwater. To date the only knowledge we have is that downstream of the discharge of the Drain from the eastern side we have ridculous levels of DDT and Dioxins in the Canagagigue Creek.

Steve Martindale (M.O.E.) asked whether Peter Gray's MTE report gives reasonable and probable grounds for the M.O.E. to investigate the private property involved. For any honest third party the answer is a clear yes however we are not dealing with honest brokers when we deal with the M.O.E.. Councillor-elect Larry Shantz asked if CPAC had had any contact with that property owner to which the answer was yes.

Jeff M. revealed some interesting information. He advised that Chemtura had removed 46,000 tonnes of toxic wastes from RPE 4 & 5 back in 1993. That quantity puts the Love Canal in New York to shame as they only had 28,000 tonnes buried there. Jeff also carefully qualified his comments about allegedly all wastes having been removed. He added the wotds all wastes "that were accessible" and all wastes "to the extent practical".

Ron Campbell of CPAC supported my line of questioning about the line, trench or scar visible on Chemtura's property. I had suggested that any fence present might simply have been put there afterwards to delineate and mark what was under the ground's surface. Sebastian Seibel-Achenbach (CPAC) also asked Jeff to respond to my questions. Jeff M. basically got quite upset suggesting that it was an interrogation and that he shouldn't be put on the defensive like that. Well I suppose if you're a well paid apologist for a thrice convicted polluter who has shut down a town's water supply; occasionally you're going to be put on the defensive. Sorry Jeff if I offended your feelings.

Once again a number of requests for information to both Chemtura and the M.O.E. including CPAC Motions, Financial Assurance and Chemtura funding of CPAC were not fully answered with more delay being the answers. This included the further testing of the Canagagigue Creek last summer with results expected sometime next summer. The M.O.e. and Chemtura continue to run out the clock.

The M.O.E. has bluntly refused to hand over certain cleanup expenses to CPAC as requested. Ron Campbell questioned this as it's taxpayers money being spent. Also councillor-elect Patrick Merlihan had questions on the matter.

We then got into the awful, terrible Elmira Advocate Blog/website which you are currently reading. I was thrilled to learn that the Assistant Director of the west central region M.O.E. is such an avid reader. Good morning A.D. and have you sacrificed any part of the natural environment, already this morning, to benefit your corporate clients? No? Good for you. I thank CPAC and SWAT members who expressed their shock and disgust regarding the M.O.E.'s anti democratic and anti free speech stance. This included Vivienne, Dr. Dan, Sebastian and Richard C.. I was also advised that Steve Martindale (M.O.E.) reads my Blog three times per week as well as the Elmira Independent regularily. Jeff M. and Dwight Este (Chemtura) also proudly advised that they read the Elmira Advocate five days a week. Wow with support in both high and low places I can hardly restrain my enthusiasm each morning when I am posting.

Clearly my questions regarding the Drain on the Stroh property upset Jeff and Chemtura. The questions however regarding the possible Trench running down the eastern side of their property sent Jeff over the moon. He was shocked and upset and whether my line of questioning was too close to comfort to being a courtroom interrogation, I suggest that Jeff might want to get some practice at it. The late Pat Potter of the Dunnville Environmental Hazards Team believed that some day the Uniroyal Trials would begin.

WILFUL NEGLIGENCE & THE CHEMICAL HITS JUST KEEP ON COMING

This post was planned to be both about Thursday evening's CPAC meeting as well as about yet another belated document (6 pages), downloaded from a computer database, presented to us at that same meeting. I presume it would have taken them perhaps ten minutes to actually download and print these chemical results for three wells on the Stroh property to the east of Chemtura. The wells are CH57, CH19 and CH22. The first two are the closest to Chemtura with CH57 in the north and CH19 in the south. CH22 is farther east than the others and may possibly even be on the next door (east) neighbour's property (Mr. Shuh). These contaminant results are all from 1990-1991 with the exception of some Non-Detects in well CH19 on pages 2 & 3 dated 2010. More interesting is that wells CH19 and CH22 are screened in the Municipal Lower Aquifer. This means that they are the third aquifer down from the surface with likely at least two aquitards (clay & silt) in between them and the surface. Also of interest are the very high method detection limits (MDL) that occur for crucial contaminants in all three wells. These crucial contaminants include mercaptobenzothiazole and aniline which are Uniroyal/Chemtura signature compounds. Finally well CH57 is screened in multiple aquifers including the shallowest one whether called the UA (upper aquifer) or SA (surficial aquifer). Unsurprisingly Chemtura have not shared with us the results from the shallow aquifer at this well located extremely close to the former northern toxic waste pits RPE-1 & 2 as well as IR-1. CH57 results are from the deeper, protected MU (municipal upper aquifer).

The results are upcoming and I hope you ask yourselves why detected compounds both above and below drinking water standards have not been tested for since 1991. I hope you ask yourselves why there are virtually no results from shallow wells (including CH57) east of Chemtura's site despite massive contamination found in shallow wells right on their property line such as OW37 and others. I hope you ask yourselves why some of the MDLs are as high as 500 parts per billion (ppb) whereas others are literally tens of thousands of ppb lower. Mayor-elect Shantz while I know you are a friend, nevertheless I hope you ask yourself how is it possible that I and informed others are able to sit in the same room with such a group of manipulaters and deceivers? You may think we are not exercising the same control as you and some Chemtura fellow travellors demonstrate. That is not accurate. Our control is a thousand times greater because our knowledge and understanding
of whom we are dealing with is a thousand times greater.

One final discrepancy in CRA's latest attempt to produce a professional document is that they have not included a legend to advise what the letter i stands for after a result or the letter l . This keyboard character * is also used without explanation. The usual interpretation when the letter j is used after a result is that the result is a detection but the quantity/number is approximate.

NDMA is positively identified in well CH19 in the ML aquifer at 3 parts per trillion (ppt). It is approximately found at
7 and 8 ppt as well. That is there is an i after those results. Phenol is positively identified at 80 ppt. as is butyl benzlphthalate at 100 ppt. and Di-n-butylphthalate at 290 ppt.

NDMA is approximately found at 25 ppt in well CH22 in the ML aquifer in March 1990. It is also positively found at 2 ppt in January 1991 and at approximately 6 ppt in July 1990. Di-n-butylphthalate is also positively detected at 150 ppt.

NDMA is found at approximately 2 ppt. in well CH57 in the MU in 1990. However Butyl benzlphthalate, Di-n- butylphthalate and pyrene are all positively identified at 180, 490 and 20 ppt. respectively.

These are generally low results however as earlier indicated they are in locations where they should not be found at all. They are on private property off-site in much deeper aquifers protected by aquitards and yet they are still detected. Imagine if shallow testing had occurred or had been reported in these off-site locations east of Chemtura allegedly upgradient of surface and shallow groundwater flow. Peter Gray (MTE) says they are downgradient and the results prove him correct.