Wednesday, November 30, 2016

THINGS HEATING UP ON THE SCOTT HAHN FRONT



At the request of the conflict of interest prosecutor, also known (to me at least) as the out of town prosecutor, I have been interviewing likely prosecution witnesses for a trial if it happens regarding the Municipal Elections Act (MEA) charges laid against Woolwich Councillor Scott Hahn. While I am certainly in the dark as to what is and what isn't appropriate to discuss publicly prior to Mr. Carnegie making his decision to go ahead with the charges or not; I have to use common sense and hope that is adequate. Therefore I will not be discussing here specific testimony that these witnesses have indicated to me that they are prepared to state under oath in a courtroom. Similarily while naming the potential Crown witnesses is probably not a good idea; I think all parties involved in the MECAC hearings have a pretty good idea who at least some of them will be.

Obviously the purpose of these interviews is to be able to send this testimony to Mr. Carnegie ahead of time for him to determine its' strength and relevance to the charges. Hopefully he will after learning of their proposed testimony then interview these witnesses himself, whether in person or by phone. I already have an in-person interview scheduled with Mr. Carnegie to discuss all things relevant to these MEA charges against Mr. Hahn. As Mr. Carnegie has advised that there will be no more Adjournments after the January 25/17 court date, obviously he will have his decision made prior to that regarding advancing or not. I have been advised that there are but two criteria namely 1) Can a conviction against the accused be achieved? and 2) Is it in the public interest to proceed on these charges? The first is a slam dunk thanks to the $12,000 Forensic Audit. The second I and several witnesses also believe is obvious. The charges and circumstances are both serious and repetitive. If the Ontario legislature did not feel that the multiple Sections of the MEA that Mr. Hahn has contravened were not in the public interest than they would not have written and enacted the legislation in the first place.

Tuesday, November 29, 2016

HAVE ELMIRA PROPERTY VALUES PLAYED INTO LOCAL ENVIRONMENTAL CLEANUP DECISIONS?



I've certainly stated that our local Woolwich Councils generally do not have much to be proud of in regards to the lack of full cleanup of the Uniroyal/Chemtura site here in Elmira. Recently at a TAG meeting it was suggested that certain environmental criteria are more likely to come into play when properties are being sold and titles transferred. It was also explained that this was because banks and mortgage holders would not lend money for the purchase of contaminated properties and their accompanying liabilities. At that point another TAG member suggested that the contaminated properties in the downstream floodplain may have not triggered cleanups because they are primarily owned by Old Order Mennonites who are less likely to sell and more likely to hand their farms down to their children.

Regarding property values in the rest of Elmira I was amazed back in the very early 90's that there seemed to be absolutely no effect on real estate prices. To this day I don't think anyone in Elmira has lost money due to any alleged property devaluation based upon Elmira's well known contamination, primarily from Uniroyal Chemical. Whether Council intervention and go slow (glacial) and quietly behaviour has assisted this or not I do not know. Whether Council's avoidance of confrontation of either Chemtura Canada and the Ministry of Environment has helped avoid property value losses I do not know. At the same time I do not believe the efforts of the last Council which were far less tolerant of Chemtura/M.O.E. behaviour, has in any way slowed property inflation. Our current Council took a symbolic and more action by posting warning signs along the creek. I don't believe that that in any way affected real estate prices in Elmira.

A friend and colleague here in Elmira, Richard Clausi, has often suggested that the only way to seriously get the majority of Elmira residents up in arms environmentally, would be if half of them woke up one morning to find the other half had died during the night courtesy of Chemtura fugitive air emissions. I suspect that it would take something similar to negatively affect property values and that is a good thing. It does not however excuse Woolwich Council's lack of action over the last thirty years. It seems, granted in hindsight, that property values are highly resistant to degradation based upon environmental factors, even serious ones.

Monday, November 28, 2016

UPCOMING LOCAL ENVIRONMENTAL DATES & VENUES



The title doesn't specify but I'm looking at upcoming environmental dates dealing with Chemtura Canada here in this posting. There are other ongoing local environmental issues including the Jigs Hollow Pit also known as the Kuntz Pit.

A week from this Thursday on December 8th at 4 pm. will be a public meeting of RAC (Remediation Advisory Committee). It will as usual be held in the Woolwich Council Chambers. Yours truly has advised the appropriate folks that I will be a Delegate on behalf of CPAC in regards to the Ministry of Environment's multiple Canagagigue Creek studies. This has been agreed to in principle by CPAC (Citizens Public Advisory Committee) hence I simply need to get a rough Draft of my words to them ahead of time for final O.K..

The next two TAG (Technical Advisory Group) meetings will be held in Woolwich Council Chambers (6:30 pm.) on January 19/17 and then on February 16/17. Dr. Jackson unfortunately will have retired by then and we will presumably meet the new Chairperson. While I have major forebodings I will say that Dr. Jackson did express confidence in the new person at the TAG meeting earlier this month.

Lastly we have recently been advised that the "final" M.O.E.C.C. Canagagigue Report will be available sometime in February 2017. While it would both be nice and appropriate to receive it at least a week or more before the February 16/16 TAG meeting; I won't hold my breathe. This report will allegedly be looking at fish tissue residues, bio-accumulation and will focus on the more recent (2014 & 2015 ?) creek sediment data. Based upon the inconsistent and unscientific sampling done from 2012-2015 I fail to see how any conclusions or recommendations made by the Ontario Ministry of Environment will be much more than self-serving or Chemtura Canada serving.

Saturday, November 26, 2016

FOLLOWING UP ON YESTERDAY'S "SOURCE REMOVAL" POSTING



Chemtura are between a rock and a hard place technically and factually. However as Dr. Dick Jackson has clearly pointed out the bottlenecks and lack of cleanup are not technical issues, they are public policy issues. Public policy as in the people in positions of authority including politicians are unwilling or unable to do their jobs. This would include incompetence and general ignorance on the issues as well as relatively knowledgeable politicians who like their jobs and aren't willing to take career risks for the sake of either the environment or what they see as others human health. Even "professional" bureaucrats whether at the Region of Waterloo or the Grand River Conservation Authority (GRCA) are either indirectly controlled by municipal, regional or provincial politicians or they themselves such as voting GRCA members are career municipal politicians. The last thing career politicians ever wish to do is to alienate or antagonize powerful people and institutions. That is the quickest road to political suicide.

Here in Elmira, Ontario we have needed our local municipal Council to step up, confront the Ministry of Environment and demand proper cleanup of the Uniroyal/Chemtura property. While there has been the odd former councilor over the last thirty years who individually on a Woolwich Council would have done the right thing, they have been consistently outvoted with the exception of the 2010-2014 Woolwich Council. While that Council had it's own problems, particularily Mayor Cowan, nevertheless they were not in anybody's pocket, especially Chemtura's.

All parties know where Source Removal needs to be done both on the Chemtura property and just off-site, both on the west side (Yara/Nutrite) and on the east side primarily the Stroh property although also likely grossly contaminated sediments in the Stroh Drain where it passes through the Martin farm.

The Stroh property cleanup not only includes the north-west side of the Stroh property next to Chemtura's east side pits (RPE 1-5 etc.) but also much further south in the low lying areas prior to the building of the Stroh Drain. To date Chemtura and GHD their consultants have done their utmost to avoid sampling these areas despite recommendations from both CPAC and TAG to do so.

The Martin property requires soil and sediment testing the length of the Stroh Drain as it passes through on it's way to the Canagagigue Creek. As Sebastian Seibel-Achenbach of both TAG and CPAC, as well as myself and two gentlemen from MBN Environmental have walked up the Stroh Drain through the Martin property; we have an excellent idea of where sediments have been deposited and collected over the decades.

The on-site source removal of course includes both free phase and residual DNAPL removal. While Wilf Ruland has been a major disappointment to me over the years primarily because of his failure to stand up to CRA and the M.O.E., nevertheless I was pleasantly surprised by both he and Jaimie Connelly's (M.O.E. hydrogeologist) digging in their heels in letters which were released to CPAC (approx. 2011-12) several years after being distributed to some of the stakeholders at the time. While I was a voting CPAC member at the time those letters were written, they were suppressed such that I did not receive them.

Cleaning up the Canagagigue is absolutely necessary. However do we really want to clean the creek BEFORE we fully stop the ongoing flow of persistent organic pollutants and more from the Chemtura site, into the creek? Only part of the west side of the creek and its' banks has been remediated or stabilized. Much more needs to be done there. The amount of creekbank stabilization or removal on the east side may be a function of how much contamination has flowed via ground and surface water. Keep in mind that hydrophobic POPs (persistent organic pollutants) are readily mobilized by solvents and Uniroyal discharged millions of gallons of solvent laden waste waters. Chemtura's difficult question is whether or not to admit how much from the east side flowed west directly into the creek versus how much they successfully diverted south and east to eventually go into the creek further downstream.

Friday, November 25, 2016

SOURCE REMOVAL - THE DIRTY WORDS CHEMTURA CANADA MOST HATES



Over the last week I have been posting about the toxic contaminants in the Canagagigue Creek sediments and immediately nearby floodplain soils. I have indicated both the unscientific, essentially mickey mouse sampling dates, locations and parameter choices. I have also advised of a very few specific contaminant concentrations and their locations in the creek, outside the creek (very little testing) as well as their distance downstream from the Chemtura facility here in Elmira. Just for clarity my concerns are for not only the "natural" environment including sediment dwelling organisms, fish, birds, reptiles and mammals further up the food chain but also for human beings either fishing in the creek, living beside it and children playing in and around it. Finally there are other life forms which have been affected by the toxic contamination in the Canagagigue Creek and that is domesticated animals. With my own eyes this year (2016) I have seen cattle crossing the creek, stirring it up and drinking from it. So much for the bull manure we at CPAC have been told for many years about cattle being fenced away from the creek. Just more lies from Chemtura and their friends in both high and low places. These cattle of course are used for both commercial milk production and also human consumed beef.

All these Persistent Organic Pollutants (POPs) plus other classes, contrary to Chemtura, their consultants and the Ministry of Environment's advice are not stablized. They are not locked up in the soil. They are not biologically unavailable. They have been intentionally drained via both groundwater and surface flow from the east side retention pits (RPE 1-5 & more) southwards and slightly eastwards onto the Stroh and Martin properties. Here a fraction of them have been temporarily stored both at ground surface and deeper, chemically attached to soil particles. These chemical bonds are a function of soil type as well as of Total Organic Carbon (TOC) in the soils.

Why are these toxic "sinks" still able to mobilize? Partly it's because of normal, ongoing surface water flow and runoff. The biggest problem however is the coming 100 year flood. As Dr. Jackson has advised; with climate change, it's not if it's when. In fact there is a map of the 100 year floodplain dated May 2012, in a Conestoga Rovers (Chemtura's consultant) report titled "Scoped Environmental Impact Study" dated May 2013. This map clearly shows that not only is a huge area of former waste disposal ponds submerged on the west side of the creek but also but for one high ridge of land the entire south-east corner of Chemtura including the Stroh Drain and the surrounding soils is also going to be submerged and scoured by the rampaging Canagagigue creek. These submerged soils include the most likely repository of Dioxins/Furans, DDT, PCBs and other POPs.

All of this will end up downstream most likely for many miles on both sides of the Canagagigue as well as on both sides of the Grand River. Is this bad luck or was this forseen a very long time ago Did the Ontario M.O.E. and Chemtura count on downstream flushing from the getgo to help clean the Chemtura site in Elmira





Thursday, November 24, 2016

ONE NEONICOTINOID BEING BANNED BY CANADIAN GOVERNMENT



I would call it a classic case of leading from the rear. Our federal government have publicly decided that they will phase out imidacloprid over the next three to five years. Health Canada stated that "Based on currently available information, the continued high volume use of imidacloprid in agricultural areas is not sustainable". This and other neonicotinoid pesticides have been blamed for many years by scientists and others for mass bee dieoffs. The federal government also stated that new mitigation methods introduced in 2014 greatly reduced bee kills from neonicotinoid treatment of corn and soybean crops.

A Toronto based environmental group, Environmental Defence has stated that the three to five year phase-out period is too long. Health Canada are also beginning "special reviews" of two other neonicotinoids namely clothianidin and thiamethoxam.

Og great interest to me is that Health Canada's 2014 review of neonicotinoid pesticides also found that "scientific research shows long-term effects on pollinators can result from sub-lethal exposure levels. Sub-lethal exposure levels are lower levels of exposure that do not result in immediate mortality.". This is the elephant in the room for me regarding the multitude of pesticides, solvents, persistent organic pollutants and other toxic contaminants in the Canagagigue Creek sediments, soils and water. While the soluble (dissolved) contaminants have been greatly reduced over the last fifty years the rest have not. Whether all these toxins are above or below various criteria and alleged safe concentrations is irrelevant. They all have some deleterious effect upon lifeforms in and around the creek including human beings whether or not they can be scientifically measured and or proven.

Today's Waterloo Region Record carries this story titled "Feds move to ban common neonicotinoid insecticide".

Wednesday, November 23, 2016

SPECIFIC CHEMICALS & CONCENTRATIONS IN THE CANAGAGIGUE



The last few days I've been commenting on inconsistencies and non scientifically rigorous sampling for contaminants in our local creek. Today I will be giving just a few specific chemicals and their locations in the creek from Chemtura Canada (Uniroyal) in Elmira all the way down to the mouth of the creek where it discharges into the Grand River five miles away. That discharge is approximately 1/2 a mile downstream of West Montrose.

These following results are from Tables 3, 4 & 13 in the Ministry of Environment Memorandum released to TAG (Technical Advisory Group) dated October 31, 2016. The time frame for the sampling was 2014 and 2015.

DDT & Metabolytes in creek Sediments at Station #23 (Jigs Hollow Rd.) just upstream from the Grand River. 321 parts per billion (ppb). The LEL or Lowest Effect level is 7 ppb and the site specific SEL or Severe Effect Level is 540 ppb.

Dioxin Toxic Equivalency Quotient (TEQ) in creek sediments at 750-B, the south end of Chemtura's property. 38.48 parts per trillion (ppt). The sediment criteria is 21.5 ppt. A little further downstream past Chemtura at Station #20 the Dioxin TEQ is 63.66 ppt.

Dioxins in sediments further downstream at the New Jerusalem Rd. Station #21 are 182.27, 722.70 and 1,689.15 ppt. TEQ. The three samples represent increasing depths into the creek sediments. Keep in mind the criteria is 21.5 ppt TEQ.

Lindane (gamma hexachlorocyclohexane) (pesticide) was also found at location 750 (Chemtura) at 2 ppb. with a criteria (LEL) of 3 ppb. A quarter mile downstream it was found at 8 ppb. well above the Lowest Effect Level (LEL).

Aldrin (pesticide) was found at Station #21 (New Jerusalem Rd. at 2 ppb. which equals the LEL.

DDT & Metabolytes were found at Station #20 at 851 ppb. with a site specific Severe Effect Level (SEL) of 324 ppb. They were also found at Station #21 at 498 ppb. with a site specific SEL of 288 pbb.

Heptachlor Epoxide/PCB(74) was found at 3 ppb in the creek sediments at FP-9. This location is just upstream of the Grand River. The LEL is 5 ppb. At the same location DDT & Metabolytes were found at 133 ppb. While well below the SEL keep in mind the Lowest Effect Level (LEL) is but 7 ppb.

Dioxins were found at the next upstream location (FP-8) at 10.2 ppt. While below the criteria of 21.5 nevertheless they contribute to the toxic load all the way down the creek to the Grand River.

PAHs (polycyclic aromatic hydrocarbons) were only tested for in sediments at Chemtura and very nearby downstream sites. Benzo perylene exceeded the LEL of 170 ppb with a reading of 180 ppb. both at Chemtura and 1/4 mile downstream. Total PAHs at the same two locations were around 3,000 ppb. with the LEL of total PAHs being 4,000 ppb..


These sampling results are but a tiny proportion of all the chemicals and their concentrations found in the Canagagigue Creek and downstream Floodplain soils. The entire creek is contaminated both in the creek sediments and the floodplain soils all the way down to the Grand River. That this has not been remediated after more than half a century of knowledge is disgraceful. Thank your Ontario government and specifically the Ontario Ministry of Environment and Climate Change (MOECC).









Tuesday, November 22, 2016

POLYCYCLIC AROMATIC HYDROCARBONS IN THE "GIG"



Following the trend of inconsistency throughout the nearly five years of Canagagigue Creek testing, we have the example of Polycyclic Aromatic Hydrocarbons or PAH for short. They were sampled in July 1995 up and down the creek in the sediments only. This sediment testing took place from slightly above Uniroyal Chemical down as far as Station #23 (Jigs Hollow Rd. #46) just above the Grand River. Sixteen different PAHs were tested for and while none were found upstream of Uniroyal Chemical all but one were found downstream at various sampling locations. Yes that is fifteen out of sixteen parameters sampled for were detected. The concentrations vary from Trace amounts at 40 parts per billion (ppb) up to 7,800 ppb. for Fluoranthene. Keep in mind that the Method Detection Limit was fairly high in these 1995 samplings. In comparison the only other sampling of PAHs took place in 2015 and there were Trace amounts detected as low as 4.2 ppb.

In comparison the 2015 sampling was also in sediments only versus sediments and floodplain soils as were most of the other parameters tested in 1995-96. The failure to consistently measure all parameters in all the same locations over time is one of the huge failures in the Ministry of Environment's Canagagigue studies. While broad generalizations can be made when comparing data I believe that actual statistical conclusions are nearly impossible to make. That said the 1995 PAH sediment data did at least go as far down the creek as Station #23 very close to the Grand River. This is in contradiction to the 2015 data which only geographically covers the south end of Chemtura and then as far downstream as one of the Station #21 locations (ie. New Jerusalem Rd.).

The 2015 data indicate that all 20 parameters were detected (versus 16 parameters in 1995) albeit five were at Trace levels. As difficult as it is to compare geographically it appears as if the total concentrations of PAHs are slightly higher in 2015 than in 1995.

While I believe that statistically significant trends are almost impossible to conclude I doubt that that will stop the M.O.E. from doing exactly that. They have a new TAG (1 year +), a brand new Chair of TAG and proven, experienced, technically competent citizen stakeholders (CPAC) that have been marginalized, excluded and refused the right to ask questions and make comments during public meetings. This should be a walk in the park for the partners in pollution namely Chemtura and the Ontario M.O.E.. Real public consultation it is not.

Monday, November 21, 2016

M.O.E. INTENTIONALLY OBSCURING CANAGAGIGUE DATA



Outrageous and blatant best describes the Ministry of Environment's handling of the Canagagigue Creek studies. Incompetent is also a possibility albeit the Ministry's history of deceit makes the former more likely. Last spring or summer the M.O.E. had promised the final 2015 data and report by October 31/16. Dr. Jackson after advising that the roadblocks to progress were not technical they were public policy (politics); resigned as Chair of TAG effective December 31/16. This should have given him two months to study and comment on the Ministry's final conclusions regarding the contamination in the creek. Lo and behold on October 31/16 indeed another report was produced by the M.O.E. with both more data from 2014 and data from 2015 however we were advised that the final, final report isn't until February 2017, two months after Dr. Jackson is gone. It allegedly will also include more data on bio-accumulation and possibly further contaminants in fish tissues. Nicely played M.O.E..

Last Saturday I posted that the M.O.E. studies are sketchy. Further to that the M.O.E. have a bag of tricks which they employ to dissuade citizen participation and critique of their work. It includes issuing reports either the day of or after they have been presented publicly by M.O.E. personnel. This makes intelligent questioning of reports and data impossible in a timely manner.

The scientific validity of their studies are questionable. If you want to examine toxic contaminants over time in a creek then you attempt to minimize other variables as much as possible. Hence if you take ten samples at ten different locations in year one then subsequent years you would sample the same parameter at the same location hopefully around the same time of year. The same time of year is to reduce seasonal variability due to temperature, spring floods etc.. The M.O.E. absolutely have not done that. Their locations change constantly including skipping from floodplain soils in 1996 to alleged floodplain sediments in 2012 (1 location) and 2015 (several locations). To date the M.O.E. have failed to explain how or why sediments in the bottom of the creek should be labelled as floodplain locations ie. FP-1,2,3,4 etc..

Sediment locations Station #22 and #23 were skipped in 2012 and 2013 with no rationale given. Floodplain soils (FP-1 to FP-10) were skipped entirely after 1996 with the exception of FP-5 & 6 in 2012. This is not remotely a scientifically valid study. It is an intentionally obtuse, confusing, hide the forest with the trees attempt to swamp citizens with data that cannot readily be compared from year to year. It is for the purpose of thinning out public criticism and allowing the M.O.E. and their buddies Chemtura to interpret the data absolutely any way they wish without opposition.

Professional con artists would refer to this as the long con. Indeed professional thieves could take lessons from the M.O.E. in regards to duping the public albeit professional thieves steal money and valuables (jewelry etc.) whereas the M.O.E. steals our health and lifespan.

Saturday, November 19, 2016

MINISTRY OF ENVIRONMENT CREEK STUDIES (the "Gig") ARE SKETCHY




Partly they are poorly written. This I pointed out to M.O.E. Biologist Mike Spencer back in 2012 and 2013. He came to CPAC to explain what he had done in these studies examining Dioxins/Furans and DDT in the Canagagigue creekbed sediments and floodplain soils. Terminology and definitions were inconsistent from report to report. For example I've lost count of the times in these numerous reports (1996, 2012, 2013, 2014 & 2015) when "sediments" and "soils" have been used interchangeably and confusingly. Also I have seen conclusions stated by the M.O.E. in these reports that I feel are not well supported by the data. For example they state that the deeper sediments in the creek have higher concentrations of contaminants. This is at best a generalization as in fact there are a number of contrary examples. Scientific consistency is a problem throughout as well. Many sediment samples go from 0-10 cm and then 10 to 20 cm only to have the next sampling round be 0-12 and 12-24 cm. for example. That is not scientifically rigorous whatsoever.

Sample locations also vary over these studies. Any study allegedly comparing data over time should have as much as possible other variables consistent. Hence DDT sampled at Station #21 in the creek sediments should use the exact same location for each and every different sampling round over the years. This has not occurred. Station #21 started off downstream of the New Jerusalem Rd. bridge in 1996 then moved upstream. Then it changed from one location to three different ones being sampled albeit close together. A skeptic could easily conclude that the samplers realized that a nearby location consistently had much greater deposition of sediments on an ongoing basis hence they moved to where they knew they would get higher concentrations of DDT and Dioxins all in the hopes of minimizing the eventual dollars Chemtura needs to spend to "clean up" the creek. This is done via a sampling bias that magnifys the number of concentrations of toxins requiring cleanup closer to the Chemtura site and minimizes the concentrations found downstream which exceed the applicable criteria. Of course when citizens are dealing with an inherently dishonest and corrupt M.O.E. these doubts are exacerbated.

The number of sediment sampling locations has always been problematic. Station #21 is located at New Jerusalem Rd., Station #22 at Northfield Dr. and Station #23 at Jigs Hollow Rd.. In other words we have but three sediment sampling stations spread over a creek distance from Chemtura to the Grand River of over 7 kilometres (5 miles). Making the huge and unrealistic assumption that these three sites are representative of the whole seven kilometres of creek is sketchy at best. Then when we look carefully at the amount of sampling for the two furthest downstream we find that they have been sampled far less than Station #21. Station #21 was sampled in each of the five sampling years. Stations #22 and #23 only in 1996 and 2014. You of course will never find what you do not look for. Finally think about this. If we assume that these three sites are representative of seven kilometres of creekbed then we must understand that the entire creek is contaminated not just the miniscule area around each sampling location. Hence the entire creek needs to be cleaned up.

Suggestions that both Dioxins and DDT are at higher concentrations closer to Chemtura are borne out at some locations, sometimes. Unfortunately they are also contradicted by the data sometimes. DDT for example back in 1996 was found at the highest concentrations in the sediments just downstream of Regional Rd. #22 (Station #22). It was also found at the highest concentration in the floodplain soils upstream of Station #22 albeit closer to Stn. #22 than #21. Similarily Dioxins were found at the highest concentration in floodplain soils upstream of Station #22 and the second highest of these ten sample sites was upstream of Station #23 midway between Stn. #22 and #23. Dioxins were also found at higher concentrations in 1996 in the creek sediments at Station #22 and #23 than at Stn. #21. All this begs the question as to why the sampling focus on Station #21 since then unless it is to simply be able to sell a small cleanup to Chemtura and to bamboozle the public.

Sampling bias also includes what parameters are tested for. Dioxins and DDT have been relatively consistent in their sampling. The "dirty dozen" pesticides from the Stockholm Convention have not. Endrin, aldrin, BHC, heptachlor, endosulphan, chlordane etc. tested for in 1996 have not been tested for since. *** [Oops! 7:08 pm. They weren't tested for in 2012 and 2013 but were sampled for in 2014 and 2015] My bad. Similarily PAHs (polychlorinated aromatic hydrocarbons) were tested for in 1996 and again but once recently. PCBs have only had a few types tested for and found twice in the creek. What about all the others? What about testing for them as often as Dioxins and DDT? All of these sampling biases and failures serve to minimize the human and environmental health hazards in the creek thus allowing the M.O.E. to order (ha! negotiate) a much smaller cleanup.

In the first paragraph I had referred to the M.O.E.'s claim that the concentrations of contaminants are higher in deeper sediments. They also now are publicly advising downstream landowners that these deeper sediments are not biologically available to wildlife and humans. Both these statements are not borne out by the facts. There are many results in both the sediments and the floodplain soils where shallower samples are either higher than deeper ones or at worst extremely close in concentration. Perhaps another significant factor (variable) might be the time of year that sediment samples are taken. Again however the M.O.E. have not been rigorous in keeping their sampling dates consistent. That said what used to be the biggest flooding time of the year namely the spring freshet may have been supplanted by climate change induced more vigorous storms throughout the year. Regardless one would expect that heavier rain events would result in greater flushing of sediments and greater mobilization of deeper sediments along with their being transported downstream and into the Grand River.

I have found one striking (to me) fact while studying this data. To my surprise flooddplain soils generally appear to have much higher concentrations of both Dioxins and DDT than do creek sediments. At least in the original M.O.E. Jaagumagi and Bedard study (95-96) they did. From that point on things get confusing courtesy of the M.O.E. apparently using the same alphanumeric descriptions for Floodplain (FP-1,2,3 etc,) SOIL locations AND for Floodplain SEDIMENT locations. What the bloody hell! This refers back to my first paragraph where I referred to Soils and Sediments terminology apparently being used interchangeably. Well maybe they aren't. I believe I've just had a small epiphany. This may well be the M.O.E. intentionally or possibly stupidly muddying the waters so to speak. Keep in mind I believe I raised this issue with Mike Spencer (M.O.E.) regarding the 2012 study. Only three Floodplain sites were sampled for soils namely FP-1, FP-5 and FP-6. FP-1 appeared to be tested for Sediments rather than soils which was why I asked Mr. Spencer what was going on. His answer was inadequate and unclear, whatever the reason. Then there were no Floodplain sites tested in 2013. Lo and behold the 2014 study also seemed to be conflating ( mixing up) Soils and Sediments in reference to what had been Floodplain Soil locations namely FP-1,2,3,4 etc.. Also keep in mind that by the time we received the 2014 results (Sept. 2015) Mayor Shantz and Councillor Bauman had removed CPAC and myself intentionally from being able to either speak or ask questions at public meetings involving Chemtura or the Ontario M.O.E.. Anyhow as of now I believe that they are indeed sampling sediments in the creek while using Floodplain names ie. FP-1,2,3 etc.. Talk about a bait and switch.

Hence there are three issues. Firstly if indeed Floodplain Soils downstream have not been tested for since 2012 but rather those locations have been changed into sediment testing locations then this is a huge sampling bias against floodplain Soils. Those downstream results were much higher for both Dioxins/Furans and DDT than the sediment results in the 95-96 sampling. Therefore by eliminating them and focusing only on sediment results downstream, the M.O.E. have artificially once again focused attention only upon lower concentration sediment sites probably in an attempt to pretend that the downstream is not a problem. Secondly if indeed as was clearly demonstrated in the 95-96 sampling; the downstream Floodplains are much more contaminated with Dioxins/Furans and DDT then they are also likely much more contaminated with PCBs, PAHs and Persistent Organic Pollutants (dirty dozen etc.). Finally (thirdly) this raises the question. How can floodplain Soils all the way down the creek have higher concentrations of contaminants than the creek which is the initial source to the Floodplain soils? The answer may be extremely troubling. The bulk of the contaminants via suspended sediments are constantly travelling down the creek and discharging into the Grand River. The Floodplain soils are only "enriched" after flooding in the creek has carried contaminated suspended sediments over the creekbanks and deposited them on the floodplains. In other words the creek sediments are constantly being resuspended into the water column during high flows and moving all the way down the creek. The Floodplain soils on the other hand are not being either eroded or resuspended nearly as readily or often. They are more stable plus they are not nearly as often submerged or in contact with heavy flows of water as the sediments in the bottom of the creek are.

This may be why Dr. Richard Jackson has been so insistent upon suspended sediment testing in the creek and why the M.O.E. have been so reluctant to do so. If indeed the bulk of the contaminated sediments are constantly being transported downstream then that magnifies the obvious size of the problem of their ongoing discharge from the Chemtura site as they are constantly being refreshed and redeposited in the creek . Secondly it puts in perspective the fact that our heritage river, the Grand, may well be displaying "adverse effects" from the mouth of the Canagagigue Creek for who knows how far downstream. This may be a can of worms that the M.O.E. do not want to open.

These reports spread over five years, as the final complete report is due in February 2017, I believe are intentionally obtuse, difficult, poorly written and misleading. Dr. Jackson likely could have cut through the final report due next spring but he is retiring at the end of December 2016 and we will have a new Chair of TAG. Meanwhile yours truly and CPAC are intentionally excluded from full participation in both TAG and RAC meetings. No pointed and embarrassing questions for Chemtura, GHD or the Ministry (M.O.E.). No verbal Delegations to TAG and but four times a year can we address RAC. This has been the purpose of getting rid of CPAC as full partners and stakeholders in this very public environmental disaster. After Dr. Jackson is gone there will be exactly zero stakeholders with even a tiny fraction of the knowledge, expertise and history as CPAC and myself have.

Friday, November 18, 2016

LAST EVENING'S TAG MEETING



Well first of all CKCO-TV Kitchener came out to the Technical Advisory Group meeting and filmed it. At the end of the meeting they interviewed both Dr. Dick Jackson and myself (separately). Parts of the meeting and Dr. Jackson's interview was on the late news afterwards. I'm guessing that it will also be on TV at noon today.

TAG members stepped up last evening and sent a strong message to the Ontario Ministry of the Environment on a few different issues. Sebastian Seibel-Achenbach presented a letter to the M.O.E. recommending test pits be dug the length of the Gap, currently unsampled, along Chemtura's south-east corner. This is in reference to the Chemtura East Side Work Plan. He also wants monitoring wells installed there. TAG passed the Motion unanimously to send this along to RAC (Remediation Advisory Committee). Susan Bryant provided a document concerning the Canagagigue Creek and Floodplain Review. She pointed out several weaknesses and or inaccuracies in the report. Her Report via a Motion was unanimously agreed to be sent on to RAC as well.

TAG were not happy with a Notice to Residents sent to downstream landowners along the Canagagigue Creek. This item took up the majority of the time last evening and was appropriately featured on CKCO-TV. The M.O.E. claimed that "The levels of contaminants in most areas of the creek have decreased substantially since we first began monitoring the creek in the 1990s." They followed this with "The highest levels of contamination are buried under layers of sediment in the creek bed.". While the words lie or liars were not used certainly statements that the M.O.E.'s words were misleading and inaccurate were heard during the meeting and on television last evening. Dr. Jackson advised that the M.O.E.'s Notice to residents was "inappropriate and misleading".

TAG passed a Motion that they would first approach the M.O.E. to rectify and change their Notice to Residents and if they refused TAG would approach the Township and or the Region to write up their own Notice to residents to give them a more accurate version of the facts and of the health dangers in the creek.

David Hofbauer gave a report indicating under the Environmental Protection Act "adverse effect" seems to be the determination of when the Ministry (M.O.E.) must act. This "adverse effect" refers to adverse environmental and ecological effects. Human health is NOT the sole factor by a very long shot.

Dr. Jackson indicated that he is pleased with his proposed replacement as TAG Chair after December 31/16. That gives me some hope that TAG will continue on the right path. Dr. Jackson also advised that there will be as planned two different TAG members attending RAC meetings at the start of the new year.

RAC meets next in a public meeting on December 8/16, 4 pm. in Woolwich Council Chambers.

Thursday, November 17, 2016

PERHAPS A SECOND CONFLICT OF INTEREST?



Today's Woolwich Observer has a small news item at the top of page 5 titled Hahn case adjourned again. It correctly advises that Councillor Scott Hahn's Municipal Elections Act charges have been adjourned until January 25/17. It further states that the conflict prosecutor Michael Carnegie advised the court that he needs time to review the evidence against Hahn. That is also accurate as the conflict of interest prosecutor had not done so between the September 26/16 court date in which local prosecutor Alex Andres announced the appointing of a new prosecutor and this past Monday's court appearance.

I can advise that prosecutor Michael Carnegie is now actively reviewing the case and evidence in regards to Councillor Hahn's contraventions of the Act. I can also suggest that while the Observer's statement that MECAC "...found the transgressions did not warrant passing the case on to the court." is correct; it is not remotely complete. The Observer have a copy of the Forensic Audit and their failure to point out to the public the specific multiple contraventions of the law by Scott Hahn as well as the serious concerns expressed by the Auditors in regards to the truthfulness or not of Scott Hahn's alleged contributors and family members, is in my opinion a dereliction of their public duty.

While I am the first to acknowledge that overall, Councillor and Observer co-owner Pat Merlihan is one of the better and in my opinion more forthright Woolwich Councillors, nevertheless I have to ask the question. Is his presence on Council and his co-ownership of the Observer affecting the impartiality of the Observer on the Scott Hahn issue? Is this a conflict of interest?

Wednesday, November 16, 2016

JUGGLING SIMULTANEOUS PRIORITIES



Thank God I'm retired. There are days when being an activist is a full time job. Currently today I am sending e-mails to the media regarding the Technical Advisory Group (TAG) meeting this Thursday, communicating with the conflict Prosecutor out of London regarding Woolwich Councillor Scott Hahn's Election Act contraventions, writing this posting and also attending to family issues today.

Included in the above are trying to update myself on the recent plethora of released, long overdue Ministry of Environment reports and data regarding the Canagagigue Creek. Yesterday I attended a visitation for a recently deceased member of my wife's family. The number I was given and believe is approximately five hundred people showed up over the afternoon and evening to pay their respects. That is one advantage of being a good person while not participating in politics or environmental issues. Those subjects tend to polarize people combined with the media's somewhat fickle approach to citizen activists.

Tuesday, November 15, 2016

TECHNICAL ADVISORY GROUP (TAG) PUBLIC MEETING THIS THURSDAY



The Agenda for this Thursday's 6:30 pm TAG meeting is on the Woolwich Township website under Committees of Council. Just click on RAC (Remediation Advisory Committee) and follow the prompts. Item 3.2 is the East Side Work Plan Discussion and this will include a document provided by Sebastian Seibel-Achenbach. Item 3.3 is about the Canagagigue Creek and Floodplain Review and it will include a couple of October 31/16 letters from the Ministry of Environment as well as a document from Susan Bryant.

Most disgustingly we will again likely see how the CIAC (Chemical Industry Assocn. of Canada) enables polluters and other irresponsible chemical companies to obtain Verifcation under the *Responsible Care plan. The CIAC pay for Pat Mcleans sojourns around North America, all expenses paid. Pat while wholly and totally unqualified other than local political connections as well as corporate connections (Chemtura) was the local vote last time around which tipped the balance in Chemtura's favour. No surprise there at all. Scratch my back etc..

This will be Dr. Jackson's last TAG meeting due to his retirement on December 31/16. He will have one more RAC meeting to attend on December 8/16. He will be missed as he called a spade a spade and would not tolerate the heavy duty bullshit spewed forth by the Ontario M.O.E.. He particularily let Terri Buhlman of the M.O.E. know what he thought of her excuses, her stickhandling and her evasion of the facts.

Monday, November 14, 2016

JANUARY 25/17 WE FIND OUT IF THE CROWN WILL PROCEED WITH CHARGES AGAINST COUNCILLOR HAHN



First point of interest for me was the statement both in a prior to court meeting with the out of town Prosecutor and then in court itself that this new Prosecutor in this case is a conflict of interest Prosecutor. I was advised that anytime a local politician is charged with an offence it goes to an out of town Prosecutor. I am somewhat surprised by this. Secondly I have been promised that there will be no more adjournments; that the Prosecutor (Mr. Carnegie) will advise the court on January 25/17, 9 am. whether or not his office is prepared to proceed on the Election Act charges or not. This is good news I believe for all concerned.

For a person who has repeatedly been disappointed in our judicial system; its' processes, delays, priorities and final outcomes I am nevertheless cautiously optimistic with what I heard today. I believe that this case is black and white and that is based upon MECAC public meetings as well as the two Financial Statements produced by Scott Hahn as well as the August 11, 2015 Forensic Audit produced by Froese Forensic Partners.

CHARGES GOING AHEAD, CHARGES DROPPED OR ANOTHER ADJOURNMENT?



Accountability and transparency are supposed to be the hallmarks of democracy. Unfortunately here in Woolwich Township we seem to have neither. What we have is a good ole boys and girls club. The system and all its' components are insular with an us versus them mentality. This extended to the farce which is known as MECAC (compliance audit committee). They went through the motions pretending to protect the public interest while blatantly running interference for guilty local politicians. They then solemnly ran through a list of excuses/reasons for not proceeding on to court in Councillor Scott Hahn's case. None of their excuses/reasons were legitimate criteria for denying a judge the appropriate opportunity to determine Mr. Hahn's culpability regarding his multiple, proven contraventions of the Municipal Elections Act as per the Forensic Audit done by Froese & Partners.

I will be attending court this morning and will post here the results when I get back. I have been advised that the media will be present so probably there will be something in either the local papers this week and or on television.

Saturday, November 12, 2016

THE DRAFT OCTOBER 13 TAG MINUTES ARE OUT



I reread my posts here of October 14 and 15 in order to compare my thoughts of the TAG (Technical Advisory Group) meeting immediately afterwards compared to the Draft Minutes released earlier this week. Generally they are very close and that pleases me. Nevertheless I feel it is worthwhile to directly quote some comments by TAG members here again albeit from the official Draft Minutes. Keep in mind that these Minutes as well as Agendas are on the Township of Woolwich's website under RAC (Remediation Advisory Committee).

Regarding the hypocritical "Disclosures of Pecuniary Interest" early in each meeting's Agenda, Lisa Schaefer the "Recorder" has indicated that allegedly the Municipal Act only requires pecuniary interest to be declared and not other conflicts of interest. Whether or not this is accurate it is still improper and inappropriate for two TAG members to be sitting on this committee allegedly representing citizens when they both have been beneficiaries, financial and otherwise, of Chemtura's and fellow travellers
largesse.

I am some concerns with Dr. Jackson's and TAG's concerns regarding well OW-14. To my knowledge it is situated differently than the explanation in the Minutes would indicate. This is a typical example as to why the public should be routinely allowed to speak and ask questions in order to clarify possible errors for everyone's benefit.

Lisa has indicated that a member of the public (moi) stated that the ridge is 2.5 metres higher than the lowest area of the Stroh Drain. In fact the highest point of the ridge is 2.5 metres higher than the ground surface of the Stroh Drain. The water surface of the Drain is another metre lower and the bottom of the Drain may well be one or two more metres lower yet.

Overland flow of water would result in the trapping of pesticides and dioxins/furans (and much more) in the first fifteen centimetres of soil. Overland flow of waste water loaded with solvents is a different matter. The hydrophobic compounds would have penetrated the soil much deeper as indicated in recent discoveries of PCBs eight feet below ground.

TAG clearly indicated again that sediment transport sampling needs to be done. They also are stunned by the M.O.E.s dogmatic approach to ignoring exceedances of criteria both in the floodplain and in the creek sediments. The M.O.E. seems to be claiming that they need conclusive proof that there has been a negative effect on human health only. This is bizarre when one understands that the M.O.E.'s mandate is in regards to "adverse effects on the environment. This environment means water, air, soil, and all life form not just humans.

Now the quotes I mentioned earlier; "Further, at the last RAC meeting, the MOECC was clearly made aware of the TAG concerns regarding the lack of urgency they have with providing reports on a timely manner and taking any action."

This next quote is a humdinger: "TAG discussed the potential that the Township has exhausted all technical arguments and run into a wall of public policy and bureaucratic lethargy and as such, the only path forward is a media strategy or going to the Environmental Commissioner, which does not report to the MOECC but to Queen's Park.".

Further: "TAG also discussed whether a technical advisory committee was beneficial anymore to the Township as a technical case to the MOECC does not seem to move the need for action forward. Perhaps a group who focuses on public policy is what is needed going forward.".

Lastly: "TAG is concerned that the MOECC is stating that suspended sediment sampling does not help manage the problem. Federal law mandates that the Provinces monitor pesticide contamination and it is not at MOECC's discretion to decide whether or not to monitor suspended sediment.".

Readers: All of this bolsters the elephant in the room. That elephant is that the Ontario Ministry of Environment and Climate Change are fundamentally corrupt. Where do you think that corruption comes from other than from most senior provincial politicians. As our political parties are bought and paid for, they have their ministries doing their bidding all the while pretending to be working for the public interest.



Friday, November 11, 2016

ELMIRA DESPERATELY NEEDS AN HONEST BROKER



I believe we currently have such a person and that is Dr. Dick Jackson. Unfortunately he is retiring effective December 31, 2016. An honest broker could present all the different sediment quality guidelines, tissue residue guidelines as well as variables that effect toxicity in the Canagagigue Creek. An honest broker would look at the huge numbers of toxic chemicals in the creek sediments whether above or below various Interim Sediment Quality Guidelines, Lowest Effect Level, Probable Effect Level, Severe Effect level and be able to determine things such as the effect of total Dioxins/Furans, total PCBs, total Polycyclic Aromatic Hydrocarbons (PAHs), total DDTs and even total Persistent Organic Pollutants (POPs)on life forms in the creek. As all of these compounds are persistent and bio-accumulative they contribute to a toxic load both for life in the creek but also consumers of these life forms in the creek.

A number of these toxins are at or above Severe Effect Levels (SEL) in the creek in various locations. More are at Probable and Lowest Effect levels. It is the cumulative effect both within and without the creek which must be considered. The other huge point is the length of time that these chemicals have been affecting life forms. Back in the 1950s to 1970 perhaps all life was dead. Some of the solvents including chlorophenols, benzene and much more, effectively destroyed all life in the creek. As they have been slowly decreased in 1965 (sewage treatment plant) and then the UACTS (upper aquifer treatment system) in 1996 the most toxic loads of solvents have been greatly reduced. Life has returned although it now faces a slower death and health effects and these move up the food chain. When the creek was discoloured and stank it would tend to keep both people and wildlife away. Not so much nowadays as even the cattle at New Jerusalem Rd. and probably Northfield Dr. are back in the creek and drinking the water not to mention grazing on the floodplain.

The Ontario Ministry of the Environment are not honest brokers. Obviously neither are Chemtura and their well paid consultants. The science can be complicated. This of course allows dishonest brokers a field day. Combined with this is our current Woolwich Council who politically are working hand in glove with Chemtura and the M.O.E. to deny public input and real public consultation. The cowards are afraid of an informed citizenry with opportunities to publicly state their case as well they should be.

Thursday, November 10, 2016

HOW MANY OF WATERLOO REGION'S "BIG SHOTS" ARE POLLUTERS ? SHANLEY ST. KITCHENER



The headline above came to me as I read the glowing report of the family who owned the Electrohome building on Shanley St. in Kitchener. Apparently the Pollock family of Electrohome fame also were involved with CKCO-TV and in founding the University of Waterloo. Carl Pollock was the first member of the Waterloo Region Entrepreneur Hall of Fame. You know including a former polluting Woolwich mayor (gas & diesel), perhaps there should be a Waterloo Region Hall of Shame for all our world class polluters. Rubber companies, chemicals, furniture, automotive parts, municipal gasworks, service stations; the list is quite extensive. Could you get right on this please Ken?

Yesterday's Waterloo Region Record carried the following story titled "Former Electrohome site hitting market". Just for the record this former Electrohome site is not the only one that has polluted both soil and our groundwater. To this day there are low level solvents (TCE) in the Kitchener Parkway Wellfield located near a former Deilcraft plant.

Electrohome's Shanley St. site is contaminated with petroleum hydrocarbons as well as with Trichloroethylene (TCE). TCE is a common parts degreaser and solvent used for industrial cleaning of machinery, metals and apparently in some paint and finish shops. It was the culprit which caused mass poisonings in the Bishop St. community in Cambridge a decade ago. The Ministry of Environment are apparently involved in indoor air sampling in nearby homes around the Shanley St. area. I wonder how many residents there know how far away from the source that TCE via vapour intrusion through basements can enter homes and cause toxic effects?

In Cambridge residents suffered long term negative health effects and some even lost their lives due to TCE vapours in their homes. The cleanup is still ongoing. Shanley St. residents with questions should contact Debbie Vitez of Cambridge. She also runs the Cambridge Advocate website (See the link, above right).

Wednesday, November 9, 2016

COUNCILLOR SCOTT HAHN BACK TO COURT THIS COMING MONDAY



9 am. courtroom #101 in Provincial Offences Court Kitchener either Mr. Hahn or his legal representative will be present to allegedly hear a decision by the Crown Prosecutor as to whether or not they are going to go ahead with Municipal Election Act charges (MEA). I say allegedly due to the example we received with the behaviour of the Crown regarding the Election Act charges against Sandy Shantz. Month after month the Crown asked for and received Adjournements while they studied the file. Finally the Crown advised that in order not to give the impression of bias that an out of town prosecutor would be brought in. A Mr. Fraser Kelly was brought in from London and he took no time at all in giving me the impression of bias by his behaviour both in and out of court.

Here we go again. At the last court appearance (Sept. 26/16) the very same local Prosecutor, Mr. Andres advised that a "regional" prosecutor would be appointed to take over the case. Well it now turns out that that does not mean regional as in Region of Waterloo. I was advised that it was actually regional as in simply a different Prosecutor however in the same office as Mr. Andres. Well even that was a bit of a misnomer. It turns out that in fact it is simply yet another out of town Prosecutor. Perhaps plain speaking is discouraged in the legal profession for fear that we simple citizens might actually begin to understand what is going on.

The new Prosecutor's name in the Scott Hahn case is Michael Carnegie. He is from London, Ontario which might have been simply stated as an out of town Prosecutor in the first place. I had sent Mr. Andres an e-mail on October 5/16 requesting the new prosecutor's name and contact information. Mr. Andres replied with that information on November 2, one week ago today. That response by comparison for Mr. Andres was very good. I contacted Mr. Carnegie by e-mail the next day, November 3/16. I have had no contact from him whatsoever. There have been no questions, requests for information or clarification. Absolutely nothing.

I have advised Mr. Carnegie in writing of the same thing that I advised Mr. Andres weeks ago. My first choice is for an experienced, professional Prosecutor to proceed with MEA charges and to prosecute the case. Failing the Crown doing so I am prepared to prosecute the case myself rather than have it drop into oblivion similar to Sandy Shantz's case. A $12,000 Forensic Audit indicates that Mr. Hahn has violated the MEA multiple times. It should be a Judge's determination as to whether a simple "my bad" from Mr. Hahn is adequate under all the circumstances.

Tuesday, November 8, 2016

MORE SAMPLING BIASES IN THE "GIG"



There are a total of 209 variations of PCBs (polychlorinated biphenyls). None of them are good for aquatic life or consumers of aquatic life. Approximately a dozen are referred to as dioxin like in regards to their negative health effects upon life forms. Others which are not dioxin like actually have neurotoxic and immunotoxic effects much greater than Dioxins do. To date I have seen but four different PCBs sampled for in the creek.

Back in 2014 we were advised that fish in the Canagagigue Creek had through bio-accumulation; residues in their flesh that were high enough to warrant restrictions upon number of meals per month eaten by human beings. Of course it turned out that these human restrictions were based upon very careful exclusion of the most highly contaminated parts of the fish such as skin, fatty areas and the organs. All of these most highly contaminated parts of fish are consumed by larger fish and local wildlife. The parameters tested for were Dioxins/Furans, DDT, PCBs and mercury. Many other bio-accumulative chemicals present in the creek were not tested for. These include polycyclic aromatic hydrocarbons (PAH) plus numerous pesticides manufactured at Uniroyal and unsafely disposed of. These pesticides include the original "dirty dozen" as well as many others added to the list later on. The majority of the "dirty dozen" plus additions are present in the creek sediments and soils (bank & floodplain).

The focus has been on Dioxins and DDT for a long time. All of these other persistent, bio-accumulative and toxic substances must also be included in any ecological assessment. Just because a particular chemical on its' own is below a Lowest Effect level (LEL) in sediments does not mean that it should be excluded from fish tissue testing or even higher up the food chain testing. If it is bio-accumulative and it's present in the creek it will be found in higher food chain life forms. How arrogant are we as a species that we (M.O.E.) apparently are willing to sacrifice other species while pretending that human beings are not negatively affected and therefore everything is O.K.. It is not O.K..

Monday, November 7, 2016

OVERALL IMPRESSION OF THE CREEK INCLUDING M.O.E. GAMESMANSHIP



There is and has been from the beginning bias in these studies of the Canagagigue Creek. Chemtura do not want to pay big money to clean up their mess either on-site or off-site. For me the on-site failure will eventually doom the off-site efforts. After all as has been shown consistently everything Uniroyal/Chemtura introduced into their natural environment has moved off-site either by air, groundwater or surface water. Chemical vapours can even travel through the soil. It just hasn't all degraded or travelled as the processes are generally slow.

These biases include sample locations and times of year. They include picking various criteria such as LEL, PEL and SEL or Lowest Effect Level, Probable Effect Level and Severe Effect Level. Finally they include dragging these studies out for many years. Time and money are all against the citizens and in favour of the polluter and their captured "regulator". They include hundreds of pages, eventually thousands of pages of data not only requiring study the first time but multiple times as the meetings and next studies incorporating the earlier ones are released. The entire dishonest process is designed to weed out the dedicated and honest citizens who are truly interested and willing to get involved and engaged.

The entire creek is contaminated with a litany of toxic, bio-accumulative chemicals. These chemicals are all poisonous to life as indeed the pesticides were designed to kill either weeds, insects, fungi or other "pests" etc.. The creek is suffering from at a minimum LEL toxicity it's entire five mile length. Many areas are at Probable Effect Levels and some are at Severe Effect Levels. The sampling has been grossly biased concentrating on sampling known highly contaminated areas closest to the Chemtura site. Floodplain samples further down the creek have been sporadic and inconsistent in their locations. Many pesticides detected allegedly do not have criteria or perhaps they are simply being witheld. While there have been likely fifty different toxic chemicals detected to date there are probably hundreds of others that we have not been told about. This most recent scam has been going on since 2012 and is scheduled to go well into 2017. All this time, taxpayers' money and effort is not to produce an honest picture of the creek; it is to confuse, complicate, demoralize and finally minimize Chemtura's cleanup expenditures.

Hence the M.O.E. continue to do their job protecting powerful interests.

Saturday, November 5, 2016

HIDING THE PCB, DIOXIN & DDT FOREST WITH THE TREES



What exactly are the M.O.E. doing? Back around 2012 George Karlos (former M.O.E.) advised CPAC that the Ministry would be doing sediment sampling in the Canagagigue Creek in order to "reassure" the local citizens. Boy did he screw up big time on that one. The results especially DDT were horrific. Now we have the M.O.E.'s latest report and it's more of the same only longer, more detailed, more parameters and more sample locations. We have PCBs, Dioxins/Furans, DDT and its' metabolytes, PAHs (polycyclic aromatic hydrocarbons) and other pesticides that I've never seen or heard of before; all in the Canagagigue Creek.

Also what I did not know is that allegedly we are going to get a full biomonitoring assessment of the creek perhaps in February 2017. At first blush looking at the text I received yesterday, no thanks to the ***** at the M.O.E. and Chemtura, I thought that there might be some additional fish tissue analyses and or bioaccumulation data. So far this morning I haven't seen any such new data. There is a rehash of the 2012-2014 data plus some new 2014 and 2015 data. The new data I found interesting. While it is still inadequate to remotely, accurately determine risks to biota in and around the creek; nevertheless it certainly paints a very ugly picture. The extent of Uniroyal Chemical contamination in creek sediments and the floodplain both in concentrations and in sheer numbers of toxic contaminants takes my breathe away.

This report does factor in Total Organic Carbon (TOC). Dr. Jackson had explained to us months ago that TOC is the glue that binds hydrophobic (water fearing) compounds to soil particles. The percentage of TOC determines to a certain extent the availability of Dioxins/Furans/DDT and other hydrophobic compounds to both the benthic community living in and on the creek sediments as well as to fish and other life forms in the creek. This report calculates the site specific Severe Effect Level (SEL) of specific contaminates based upon the % of TOC in the sediments and soils. I had feared that the game was rigged and the M.O.E. would simply via calculations determine that all these toxins present in the creek sediments were magically, effectively neutralized by the Total Organic Carbon. Not so at all.

My skepticism is based upon nearly three decades of dealing with these professional liars. Therefore I have to assume that their magic bullet will come in this proposed February 2017 biomonitoring report. If not then they are leaving their final nonsense to their proposed HHRA (human health risk assessment) although that seems awfully risky if their biomonitoring report can't spin minimal risk to aquatic organisms and local wildlife near the creek.

The title also suggests that I expect that all the guilty parties (Mark, Sandy, M.O.E., Chemtura, GHD) will do their best to continue to exclude CPAC and myself from being a major part of the process. With each and every report, stretched over months and years, it makes citizen understanding and technical ability to criticize more complicated and difficult. Possibly they are hoping that TAG without Dr. Dick Jackson will be way over their heads along with the vast majority of Woolwich/Elmira residents and simply have to trust in the M.O.E. and Chemtura "experts". What a huge blunder that would be.

Friday, November 4, 2016

INTENTIONAL MINISTRY DELAYS



CPAC found out a year and a half ago that the Ministry of Environment were witholding reports and technical information to suit their own timing rather than due to lab delays. CPAC hired MBN Environmental to take samples near the local creek and had no difficulty in getting them analysed promptly by a professional lab. Lo and behold the 2015 creek sampling done by the Ministry has just been released within the last week. It should certainly be interesting to see if the delay was to allow the M.O.E. to remove samples that would even further comprimise their untenable position based upon the 2012, 2013 and 2014 sampling results. Their untenable position is that all that is required is a human health risk assessment thus ignoring many exceedances of criteria for sediments, fish tissue residues and floodplain soils. These criteria are for both aquatic life in the creek as well as for human beings.

Meanwhile we hope that on Thursday November 17 6:30 pm. at the TAG meeting there will be some kind of update as to whether the increased off-site pumping has started or not. It would also be nice to know whether or not Chemtura are going to use In Situ Chemical Oxidation (ISCO) on various off-site hot spots or not. I'm not counting on finding out as we have no idea whether Chemtura or the M.O.E. will grace us with their presence. Funny thing Sandy and Mark but as TAG have turned the accountability screws on them they have up and disappeared just like they did with CPAC two years ago. Exactly what kind of technical advisory group (TAG) are able to do their best work when Chemtura and the M.O.E. usually aren't present to answer questions? This will be Dr. Jackson's last TAG meeting and that is a huge loss.

The last RAC (remediation advisory committee) meeting of the year is scheduled for December 8 at 4 pm. in Council Chambers. Dr. Jackson presumably will be there as Chair of TAG. To date we do not know who will replace him although I know approaches have been made to other professionals. Will Sandy and Mark make the same mistake twice by hiring a professional with backbone (as per Dr. Jackson) or will they bring in one of the plethora of ...kissers and toadies who don't want to offend Conestoga Rovers (GHD) or the M.O.E.? Finally who from TAG will replace Susan and Pat as TAG representatives at RAC? Dr. Jackson clearly indicated that he wished to rotate TAG members in and out on an annual basis.

Thursday, November 3, 2016

FLOODING, DAMS, GRAVEL PITS, POLLUTING INDUSTRIES AND FLOODPLAINS



This past Tuesday's Waterloo Region Record carried the following story titled "Don't blame nature for flooding's devastating impact". One excellent quote by Dr. Gilbert White is "Floods are acts of nature; but flood losses are largely acts of man." In light of climate change resulting in some areas experiencing more frequent storms and accompanying rainfall, changes are required. There have been and are negative effects from "historic and current human land use practices in our watersheds.".

It is our floodplains that need to be restored and not further marginalized to reduce human suffering and capitol losses. Humans including developers and politicians have been far too eager to maximize short term profits by building on floodplains. Quoting Barry Wilson the author of this article : "we submerge floodplains under deep reservoirs created by dams, we build settlements and industrial manufacturing facilities on them [Chemtura Canada- my addition] , we mine floodplains for gravel, and we drain and cultivate them for modern agriculture.". Regarding mining floodplains for gravel all you have to do is take an aerial trip along the Grand River through Waterloo Region. Worse yet we are still doing it with the current Jigs Hollow Pit beside Winterbourne. Regarding submerging floodplains via a dam simply look at the Woolwich dam. That dam was built (1972) in order to have water in the low flow summer months to flush Uniroyal's wastes down the Canagagigue Creek. Any "flood control" was primarily also for Uniroyal's benefit as their manufacturing site is on the creek's floodplain in Elmira.

Floodplains also supply a myriad of beneficial impacts to water quality, biological productivity, reducing erosion and to aquifers. They are also a form of cold water storage for release into waterways in late summer when the water temperatures otherwise would be harmful to fish. As usual human beings have simply outsmarted themselves albeit always for the benefit of the few at the time.

Wednesday, November 2, 2016

HIGH RISK WATER TAKING PERMITS



Firstly it's even debatable as to whether the province of Ontario knows which water takings actually are high risk to groundwater supplies and which aren't. This access to large volumes of groundwater is occurring in a knowledge vacuum according to Ontario's Environmental Commissioner, Diane Saxe. She states in the Waterloo Region Record article of October 28/16 titled "Province's glass is half empty" that "We're making decisions with our eyes closed. We don't have enough information yet we're allowing millions of litres to be taken out of the ground.".

Ms. Saxe is concerned that climate change will increase the stresses on Ontario's groundwater supplies as there are likely to be more frequent and longer droughts. With municipalities, mines, construction companies and golf courses also using large quantities of groundwater daily we may be reaching a point of depleting the groundwater in some areas. They extract 1.4 trillion litres of Ontario's surface and ground water supplies every day. There is a one time permit fee of $750 for low and medium risk water takings and a $3,000 fee for so called high risk extractions. As if $3,000 would do anything at all to mitigate or restore a depleted aquifer. That fee just like the $3.71 per million litres groundwater extraction fee for water bottlers is ridiculous and outrageous. It is yet again Canadian (Ontario) citizens subsidizing corporate interests via giving away public resources. We subsidize polluters by paying their costs for water treatment after they've polluted it and we essentially give away water resources to other corporations so they can profit by selling our own water back to us.

Tuesday, November 1, 2016

MIDNIGHT DUMPER IN CONESTOGA FINED $40,000



Last Saturday's Waterloo Region Record carried this pollution story titled "$40,00 in fines to company, director for toxic waste dumping". This of course refers to the dumping of 20 barrels of oily water, acids, waste oils and PCBs on a private property near Conestogo in May 2015.

The guilty party included a now deceased Donald Hector who did the deed (illegal disposal) after charging Ronald Soha to remove the drums for $2,500. This price was substantially lower than the $8,000 quoted by Safety-Kleen for removal and disposal. Justice of the Peace Michael Cuthbertson fined Mr. Soha $15,000 and the corporation he was a director of $25,000. At first blush I thought this was really on the low end of fines considering the toxic barrels were intentionally dumped on private property with no consideration of either the environment or the private property owner. Now it does turn out that the corporation involved, formerly Madison Steel is out of business and the principal director is 97 years old. I assume that those were mitigating circumstances in regards to the fine imposed.

The PCB angle intrigued me. Yes PCBs certainly have been found in oily waters and waste oils before and indeed Safety-Kleen at one time had a problem with incoming shipments of waste oils contaminated with PCBs. I wonder if the Ontario M.O.E. followed up on the source of these PCBs or not. There could be more to this if somewhere along the line PCBs were intentionally added to the mix of hazardous wastes being disposed.