AMATEUR HOUR WITH JIGS HOLLOW PIT DOCUMENTATION

It's so blatant I really am appalled that they seem to get away with it. Some of the documentation being distributed via on-line reports is essentially illegible. These reports are on the Woolwich Township website and they are impossible to read on the monitor and equally as bad when you print them off. Literally I've been resorting to using a magnifying glass in order to read the numbers involved. Disgraceful and shameful.

The next issue involves the intentional omission of all the Winterbourne well records from the hydrogeological study. There are approximately seventy private drinking wells in Winterbourne most likely drilled into the deeper Aquifers. The proponents of the gravel pit have managed to eliminate them from any consideration by claiming that the Grand River magically protects the villagers of Winterbourne from any impacts on their wells. This is beyond ridiculous.

Many more formal Borehole Logs need to be presented. Well records are not the same thing as Borehole Logs. They are helpful but they do not visually show the different stratigraphic layers as clearly as Borehole Logs. Then after Borehole Logs are completed it is much easier and more accurate to produce sub-surface Cross-Sections showing where the aquitards and aquifers are. This is lacking with the Jigs Hollow Pit studies.

Tonites meeting is at 7 pm in Woolwich Council Chambers. I suspect that there will be a good turnout and lively discussion. Citizens need to see the public process for gravel pit approvals/disapprovals for themselves.

JIGS HOLLOW PIT - BAIT AND SWITCH

Looking back over the years of paperwork and reports on the Jigs Hollow Gravel Pit it is clear that the proponents have been a little disingenuous shall we say. They have presented an ever moving target to citizens who have been involved with this proposal for about a decade. Initially the plan presented was for a strictly above the water table gravel pit. That was opposed for numerous reasons including the location very close to both Winterbourne and Conestogo. The problem if you will is the inherent beauty of the area combined with the natural view along and through the Winterbourne Valley as the Grand River winds its' way. Noise was also a concern and to be blunt the well off folks along Golf Course Road really didn't pay big bucks to have a gravel pit view and noise in their backyards.

The pit was approved in late 2010 by the lame duck, outgoing Woolwich Council. A Holding Provision was added to make sure that the gravel pit could not simply apply to the Ministry of Natural Resources for an amendment allowing them to go below the water table. They would have to come back to Woolwich Council for a zone change ie. removal of the Holding Provision.

Lo and behold Preston Sand and Gravel did so after they had started work on the site. They allegedly belatedly realized that the water table was too high along the Grand River to allow them to keep the floor of their pit 1.5 metres above the water table. Their plans were changed to permit them to excavate three to four metres below the water table. This was discussed in meetings with Woolwich Township, Region of Waterloo and the Grand River Conservation Authority as recently as January 2015.

Their last change (and expansion) was to decide that it was perfectly O.K. to chase the below water table gravel deeper. In fact they now want to excavate gravel fourteen metres below the water table. That is over fourty feet deep right beside the Grand River. In fact it is six metres or nearly twenty feet beneath the bottom of the Grand River. What the hell? That indeed is a bait and switch and a constantly moving target. Along with the noise and altered viewscapes there is the environmental concerns which include effects upon wildlife and threatened nearby drinking wells. Furthermore in the middle of the expanding proposals, recycled concrete and asphalt processing was added. Quite frankly if one can ignore the potential damage to both human beings and wildlife; one has to almost admire the chutzpah, brass and arrogance of the proponents.

ABUSE OF PROCESS

Last Thursday I posted here that I was unhappy with the overall process regarding gravel pit Applications and specifically the Jigs Hollow Pit Application. Well since then I've been reading a plethora of consultant's reports and my disgust has only increased. On the bright side I've read both the GRCA's position on removing the Holding Provision preventing below water table excavation as well as the Region of Waterloo's. The Region hired Blumetric Inc. to do a peer review for them. Yes this is the same company from whence our new TAG Chair comes from. Both the Region and the GRCA are opposed to removing the Holding Provision at this time which is appropriate and good news.

The Hydrogeology Reports have certainly been interesting. The earlier ones certainly weren't by any means extensive enough or detailed enough to get a good picture of the hydrogeology of the area. The few wells involved (4) were all very shallow. In discussions I have been advised of issues as well as having found some myself. Full credit must go to Preston Sand & gravel as well as their consultants. They certainly have been inventive, imaginative and clever in their efforts to paint their project as environmentally sound. Afterall instead of rehabilitating the pit back to productive farmland they are simply going to leave a big hole, let it fill with groundwater and call it a lake. Pretty slick that. This Tuesday in Council Chambers should be interesting.

NEW INSIGHTS - CHEMTURA'S SOUTH-EAST CORNER

Amazing what time and a little more information can clarify for you. There are a couple of key maps which I have been studying over the last two years plus. They are small and detailed with vast amounts of information incorporated into them. Things like ground surface contour lines, the location and date of Elmira's original STP (sewage treatment plant-what a joke) on the Nutrite property, locations of other, old landfills right in town; things like that. One of the maps even has the original location of the Canagagigue Creek where it originally flowed through the 1965 built Elmira STP at Chemtura's southern border on the west side of the creek.

Back in those days the metric scale of measurement wasn't on anybody's radar. Hence the ground elevations are all in feet above sea level rather than metres above sea level (masl) as is common now. Fortunately in my day the school boards hadn't completely deteriorated into either stupidity or corruption hence my ready ability to compare feet asl with metres asl (above sea level). This 1983 map done by Ralston, Jackman and Smith corroborates later maps and their surface topography (ground levels).

It is interesting that Jeff Merriman of Chemtura at one public CPAC meeting tried to somewhat tailor the narrative around the intentional funneling of east-side toxic wastewaters southwards towards GP1 & 2. He suggested that maybe once a year either gates or an intentional breech of the earthen pits and ponds was undertaken to drain them southwards. This seems highly unlikely and of no purpose to me. Meanwhile other sources have referred to "furrows" being ploughed in a north-south direction on the east side to automatically direct wastewaters southwards. Indeed older aerial photographs show what may well be furrows.

What is clear is that Uniroyal Chemical knew exactly how dangerous and hazardous those waste waters were to life in the Canagagigue Creek. That they were trying to dilute and or polish the wastes by running them through and above the earth over a distance of many hundreds of metres does not in my mind do much to ameliorate their guilt. If either the Ontario water Resources Commission (OWRC) or later the Ontario Ministry of Environment (M.O.E.) either approved or ignored these practices again does not mitigate Uniroyal/Chemtura's guilt. It simply adds to the guilt of the OWRC and M.O.E..

Chemtura knowingly, I believe, cleaned up a make believe GP1 a few years back. This 1983 map along with a bastardized version of it produced several years later by CH2MHILL, consultants at that time to the Region of Waterloo, tells the tale. GP1 was later relocated on the other side (west side) of the high ridge of land that runs diagonally in Chemtura's south-east corner. My best guess would be that Conestoga Rovers (CRA) did it for Chemtura although proving intent and motive would be difficult. The 1983 map may have given CRA the idea as it actually has arrows showing that some wastes, after GP1 was filled, may have backflowed around the north-western tip of the high ridge and then flowed southwards through what is now designated as GP1.

What a charade! Of course the possible backflowing of the real GP1 doesn't make the toxic wastewaters coming in from the northern pits that flowed around and past GP1 via slightly lower ground surface and then discharged onto the Stroh property (eastwards) suddenly disappear. Likely the manufacture of the Stroh Drain (1985?) was to both indeed drain the swamp on both their properties and to help flush contaminated soils and sediments along into the creek which had been Uniroyal's sewer for decades.

JIGS HOLLOW GRAVEL PIT

Firstly I am offended by the process. This proposed pit was coming to Woolwich Council prior to the October 2010 municipal elections. That is three Councils ago! At the time it was known as the proposed Kuntz Pit. There was strong local opposition which presented repeatedly in Woolwich Council back then. Issues included the destruction of the beautiful Winterbourne/Grand River Valley vista. They included major skepticism in regards to the claims by the promoter that above water table extraction was financially feasible based upon the quantity of gravel and sand above the water table. In fact the local, amateur citizen activists were correct and the experts hired by Kuntz Sand & Gravel were full of it. Kuntz sold a share to Preston Sand & Gravel who are now the proponent. They are ably assisted by Sisco Inc., a planning/lobbying group out of Kitchener. The current proposal by Preston Sand & Gravel (PSG) is for below water table extraction of sand and gravel because...you guessed it, it isn't economically feasible to only remove the sand and gravel above the water table.

During the first time around process Councillor Murray Martin wouldn't commit to the citizens his opposition to this project. Their arguments, in their opinions, fell upon deaf ears. Lo and behold AFTER the October 2010 election the lame duck Woolwich Council sitting until the new Council took over, voted in favour of this then above water table pit going ahead. Murray Martin voted against it. A skeptic might believe that this was simply a death bed conversion with Murray hoping to be resurrected the next time around in 2014 which he was. Bonnie Bryant a novice beat him soundly in the 2010 election.

Fast forward to today and these concerned citizens are again going through the same process over and over again. This is similar to the nonsense that many of us have had with Uniroyal/Crompton/Chemtura for decades. They come up with one self-serving but inherently ridiculous and illogical idea after another and as soon as you beat one down with facts they simply rework it, twist it and take another go until the Ministry of environment says O.K.. It's still a self-serving plan that does little or nothing to help the environment and or is downright harmful to it.

This coming Tuesday at 7 pm. in Council Chambers, paid experts will speak on behalf of Council lifting their Holding Provision which prohibits below groundwater gravel extraction. This principle has been strongly endorsed by the Region of Waterloo for a long time in order to protect groundwater. Citizens will speak against this plan including Jan Huisson, Bonnie Bryant, Lynne Hare and Gordon Haywood. The public are desperately needed in attendance so that Woolwich Council understand that ongoing destruction of our environment for profit is unacceptable.

CORRUPTION OF THE MONOPOLY - ONT. MIN. OF ENVIRONMENT

The evidence of M.O.E. corruption is overwhelming. There is even circumstantial evidence that indicates that NDMA was not suddenly "discovered" in November 1989 via sampling (for the first time) of our south wellfield drinking wells. It's presence at Uniroyal Chemical had been known since the 1970s. Other solvents had been found in Elmira's drinking wells prior to the "discovery" of NDMA.

Currently the Ontario M.O.E. have been sitting on gross contamination in Canagagigue Creek for over two decades. They participated in limited cleanups of creekbanks on the Uniroyal/Crompton/Chemtura property in the mid 2000s but did not follow up a few years later to see if there had been significant improvement in the creek. There has not been. In fact many of the sampling results since 2012 are worse. Clearly the amount of Persistent Organic Pollutants in the natural environment, courtesy of Uniroyal Chemical, is greater than we the public have ever been advised. Yes Dorothy lying to the public is one form of corruption.

Some of the Dioxins/Furans and DDT are undoubtedly still coming from the creekbanks that run through the Chemtura property. This would include both the east and the west side creekbanks. PCBs and Mercury may or may not be directly attributed to Uniroyal Chemical. Decades of dealing directly with professional liars makes it impossible anymore to know when they are telling the truth and when they are up to their old tricks. Extremely limited evidence exists to suspect PCBs may indeed be from the Uniroyal/Chemtura site. Indirect evidence exists that Uniroyal PCBs may have been transferred off-site and then introduced into the natural environment via our other very well known local polluter, Varnicolor Chemical. Again even if Chemtura were willing to once again sit down with local citizens and the public and answer questions is of limited value. See my earlier comments referring to professional liars.

The east side of the Canagagigue Creek running through the Uniroyal/Chemtura property was never hydraulically contained. APT Environment, primarily but not likely totally, resigned from UPAC in June 1994 over the issue of the lack of complete Upper Aquifer hydraulic containment as had been initially promised. We were dumbfounded by the reversal and blatant broken promises in the Control Order of complete containment of all aquifers on the Uniroyal site.

Starting in 2014 I discovered the reason why the Ontario Ministry of Environment went along with this betrayal of the public. They knew that a significant amount of the gross east side contamination was not running due west down the steep slope into the Canagagigue Creek on-site, either via overland surface water travel or sub-surface groundwater. They knew as I discovered in 2014 that firstly there was a contaminant pathway both southwards and eastwards. It was the Stroh Drain probably built around 1985-86 when there was already massive cleanup and removal of buried pits and ponds underway, just prior to ostensibly "discovering" NDMA in the south wellfield. Secondly they knew the basic topography was not as Uniroyal Chemical had stated and implied. In other words everything did not flow from the high ground on the east side of their site either due west directly to the creek or due south into GP1 & 2 in their south-east corner. That high ground on the east side is indeed high ground in all directions including from further east. Uniroyal's toxic compounds had been flowing eastwards from the RPE (Retention Pit East) pits directly onto the Stroh fields and farmland almost from the first day of their operations.

Then there was likely a third reason the Ontario M.O.E. went along with the plan not to hydraulically contain the east side of the creek in 1994. There is visual evidence (Google Earth & Waterloo GIS) of manmade structures running from the north end of Chemtura (Church St.) southwards and eastwards across their property line with the Stroh farm just below (south) of RPE5. These structures or lines do not appear in any aerial photographs or satellite images (if even possible then) I have going back to the 50s, 60s or 70s. I believe that some form of Interceptor Trench was most likely built in the late 80s or very early 90s to intercept toxic groundwater discharging from the east pits and running westwards towards the creek. While there is a Surficial Aquifer in the north-east corner, the Upper Aquifer does exist further south in the area of RPE 4 & 5. This visual manmade structure could be something other than an Interceptor Trench such as the "Waterloo Barrier" invented by the University of Waterloo although I am doubtful.

To date the most we've received from direct questions to Chemtura on this matter are ridiculous comments such as a cattle fence, wildlife fence etc.. It is obvious that the Ontario M.O.E. could have investigated and put this matter to rest. Instead they and Chemtura with support from two idiot (or corrupt?) Woolwich Councillors instead chose to shut CPAC down after the October 2014 municipal election. That this matter has not remotely been addressed by the M.O.E., considering the impact and ramifications, is an abomination. This is one guilty party (M.O.E.) pretending to investigate another (Chemtura). This is what happens when a corrupt organization have a monopoly on access, data, facts, and the entire process of investigation, clean up and remediation.

REMEDIATION ADVISORY COMMITTEE (RAC) IN THREE WEEKS OR OUTSIDE LOOKING IN AGAIN

I wonder when the conflict of interest queens will get it. They have sold out Woolwich volunteers and friends and for what? To be preeminent? To be the top dog as far as representing Woolwich residents at Chemtura public meetings? Wow! Guess what? You're right back at zero. You are sitting on a committee with no power and little influence. You no longer have access to Chemtura and the Ontario Ministry of Environment. You did sit as TAG representatives to RAC for a grand total of what, six meetings? Oooh! I mean that is if you both attended all six which is unlikely given your attendance records over the last six years. The new TAG reps are Sebastian and Dave Hofbauer. They will do a good job and more importantly they'll do it honestly and transparently. No backroom secret meetings and no backroom scheming for their own aggrandizement. Will Susan and Pat beg Chemtura to again sit with them privately as they did during the CPAC of 2011 to 2015? They called their private meetings with Chemtura the ACC or APTE-Chemtura Committee.

The RAC group consisting of the Region of Waterloo, Grand River Conservation Authority, Woolwich Township, Ministry of Environment and Chemtura, meet on Tuesday March 14/17 at 5 pm. in Woolwich Council Chambers. Mark and Sandy are the co-chairs. When Dr. Richard Jackson was TAG Chair and one of the three TAG reps, things were always exciting. He took delight in telling the blunt and straightforward truth. Chemtura and the M.O.E. squirmed. Nobody on RAC contradicted him effectively albeit Chemtura and the M.O.E. tried. The problem was that Dr. Jackson had both truth, credentials and vast experience on his side.

Overall I have been thrilled with RAC and TAG compared to my expectations of both in the summer of 2015. Dr. Dick (Richard) Jackson was amazing. He took a bunch of newbies and showed them the truth. He showed them what deceivers and manipulators Chemtura and the Ontario M.O.E. were. It took him apparently all of five minutes to grasp the big picture and to hone in on the reality of the decades long pretend public consultation and alleged cleanup of the creek and aquifers.

I have to wonder as to whether TAG will continue their strong and aggressive stance. While all of Dr. Jackson's positions and recommendations to RAC were technically sound and sensible; he resigned due to public policy issues blocking progress, not due to technical issues. The public policy issues translates into M.O.E. intransigence, incompetence and my words not Dr. Jackson's :corruption.

I have also been pleasantly surprised that the conflict of interest queens have to date made zero public attempts to undermine Dr. Jackson or heaven help them disagree with him technically. Susan did criticize publicly on one occasion his harsh words for Terri Buhlman (M.O.E.). Despite my first paragraph I also have noticed some serious attempts at TAG and past RAC meetings by them to get improvements in Chemtura's and the M.O.E.'s downstream creek testing as well as their east side off-site (Stroh farm) sampling. Apparently when certain topics aren't on Chemtura's Do Not Talk list (eg. DNAPLS, Interceptor Trenches, phony GP1 excavation) then Pat and Susan can do good work.

RAC on their own without TAG are hopeless. The GRCA and Woolwich have little or no understanding of the contamination issues. The Region of Waterloo do although they have made their share of private deals as well; not always in the publics' best interests. TAG under Dick Jackson was making huge inroads into RAC. RAC could have some small influence on the M.O.E. and the province of Ontario if they step up and speak as one voice. The public desperately need TAG to resume their strong and aggressive stance. Anything less and they will be steamrolled by bureaucratic inertia, lethargy and corruption.

MORE ON GRASSY NARROWS

First off there is indeed Dioxin contamination at Grassy Narrows. Not surprising when one understands the pulp and paper processes used combined with the "disposal" of wastes generated by it. This was determined via fish and meat testing done in 2004 which indicated both Dioxins/Furans and Mercury in various species of wildlife including jackfish, whitefish, pickerel, lynx, fox, beaver, muskrat, mink ducks, geese and more.

As recently as last year further studies have indicated that there appears to be on-going low level Mercury contamination into the river. This may be from the upriver point source, the former Reed paper mill, or from upstream contaminated sediments still being flushed downstream. A Dr. Rudd has proposed two different forms of remediation namely Enhanced Natural Recovery (ENR) as well as
nitrate injection to prevent bacteria from producing methyl mercury.

To date our provincial Liberal government are, like all their predecessors, long on talk and study and short on remediation money. Does this ring any bells here in Elmira?

The suffering, pain and health damage in and throughout the English-Wabigoon river system is acute. It includes human and wildlife suffering and is the direct result of human and corporate greed and incompetence combined with little or no government oversight. We in Canada pay taxes through the nose and primarily instead of oversight and necessary control we receive puffery, false assurances and non-enforcement of laws allegedly designed to protect the public. Funny isn't it how the ones usually "protected" are the powerful, the wealthy, the guilty and the politically connected.

SIMILARITIES BETWEEN GRASSY NARROWS & UNIROYAL CHEMICAL IN ONTARIO

There is Mercury contamination in the local river/creek. The Ontario government through their Ministry of Environment are ultimately responsible. The closest inhabitants to the contamination are primarily viewed by the province and senior politicians as having very little influence or public support. Monitoring, testing, polite words are used by the government while prevaricating to the local citizens. Cleanup is often talked about but rarely occurs. Local politicians have run interference between the upset citizens and those responsible for the contamination.

There are differences. Here in Elmira we also have Dioxins/Furans, P.C.B.s and DDT above federal criteria in our creek sediments, benthic organisms and fish; all in the Canagagigue Creek. While pulp and paper mills have a reputation for discharging chlorinated dioxins as part of their bleaching process I am not aware as to this having occurred in the English-Wabigoon River system of which Grassy Narrows is a part. Here we have had pretend "public consultation" for the last couple of decades plus. I'm doubtful that the residents of Grassy Narrows would waste their time talking forever to the professional liars running the Ontario Ministry of Environment. Our local polluter Uniroyal/Chemtura have spent big sums of money on consultants and studies that were not necessary in order to clean up their discharges. Here the responsible (ie. guilty) party has played the game very well. They and their partners in pollution, the M.O.E., have worked together to accomplish what my friend Richard Clausi loves to quote: "When all is said and done, more was said than was done.".

The latest article in the Waterloo Region Record is titled "More mercury testing at Grassy Narrows" and was published last Tuesday.

LAST EVENING'S PUBLIC TAG MEETING

It was difficult to watch. It could even have been called a little bit painful. There was no one present sitting at the Council Table last evening to blame for the situation. Any blame assigned would fall on the shoulders of the four TAG members not present plus Sandy Shantz sitting in the last row of the gallery. She and Councillor Mark Bauman presented a "manufactured" crisis two years ago as the basis for removing dedicated, experienced, competent and professional Woolwich citizens from the Council appointed Chemtura Public Advisory Committee. The "crisis" was Chemtura and the M.O.E. failing to attend public CPAC meetings after the new Council was elected and the irony now is incredible. CPAC continues on as the Citizens Public Advisory Committee. It is not a committee of Woolwich Council. Chemtura and the M.O.E. still aren't attending CPAC's replacement, the Technical Advisory Group (TAG). They attend a total of four RAC (Remediation Advisory Committee) meetings a year namely September, December, March and June.

TAG did not have a quorum last night. Three formally appointed TAG members showed up namely Joe Kelly, Linda Dickson and Sebastian Seibel-Achenbach. Of the four who did not attend it is the second meeting in a row that both Pat Mclean and Susan Bryant were not present. Such blatant hypocrites. Is it that their wee noses are out of joint? They were replaced, as per Dr. Jackson's promise, by Sebastian and David Hofbauer as the two TAG representatives to RAC for the next year. Or is it just too delicious for them to have once again back doored Woolwich volunteers with the new Council in 2014 in order to get themselves reappointed to the Council appointed public consultation body dealing with Chemtura's contamination? They accomplished their goal but now attending TAG meetings is awfully time consuming and onerous don't you know. Disgusting and disgraceful behaviour.

Chemtura and the M.O.E. attended a few TAG meetings in late 2015 and in 2016. Dr. Jackson the TAG Chair (then), absolutely eviscerated Terri Buhlman (M.O.E.) for her deception, double talk and overall bullshit. Now Chemtura and the M.O.E. are again not attending Woolwich Council appointed citizens (TAG) dealing with the Uniroyal/Chemtura contamination.

Sandy Shantz should be down on her knees begging forgiveness of CPAC for removing and defaming them. Is she so thick that she still hasn't figured out how badly she got played by Susan and Pat? And by Chemtura and the Ministry of Environment? Or in the alternative does she know full well exactly what she's done and is pleased to have let Chemtura off the hook?

None of this is to blame the new TAG members. Or the newest Chair, Tiffany Svensson. They are in an impossible situation. While Pat and Susan have, mostly but not completely behind the scenes, vociferously attacked and vilified the CPAC members who replaced them in early 2011; CPAC have showed much more class. We have embraced the new TAG members as citizen volunteers educating themselves and doing their civic duty on these serious local matters.

Tiffany Svensson has extraordinarily big shoes to fill in replacing Dr. Richard Jackson as TAG Chair. He is a giant in his field with a working lifetime of first hand environmental experience dealing with many grossly contaminated sites. He also has a strong personality and cuts right through the heavy duty bullshit that magnifies and flourishes here in Woolwich Township. Do I believe after such a short introduction and time that Tiffany Svensson is up to the job? I do although the next few TAG and RAC meetings are crucial. She will attend the March 14th RAC meeting along with the two new TAG reps. Dr. Dan Holt should almost be proud of the fact that it has taken two highly, technically qualified persons to assume the Chairperson's position after himself. Dr. Dan did a great job and continues as Chair of the Citizens Public Advisory Committee (CPAC).

Last evening TAG consisted of a brand new Chair plus two of three members with but sixteen months experience on the Chemtura file. As much as I don't want to flatter Susan Bryant, the reality is that if present she could have gotten the meeting on to the really current and urgent business. Even Pat Mclean while technically incompetent could have pushed discussion onto contamination in the fish in the creek or onto the blatantly biased sampling locations proposed for the Stroh farm. If either Chemtura or the M.O.E. had been present, TAG members and Chair could have asked them pointed questions regarding those matters.

These folks were not present. Viv, Graham, myself and Sebastian from CPAC were all present last evening. CPAC members faithfully attended CPAC meetings from early 2011 until August 2015. I hope Mark and Sandy that you are well satisfied with your efforts.

FURTHER ANALYSIS OF CANGAGIGUE FISH DATA

DDT & Metabolites concentrations are much higher Downstream of Elmira in Carp in the Canagagigue than they are Upstream of Elmira. The same thing does not go for either P.C.B.s or Mercury in Carp found Downstream and Upstream of Elmira. The Dioxin data is inadequate Upstream to be certain although Downstream concentrations of total TEQ (PCB & Dioxin/Furan) exceed the CCME (Cnd. Council of Ministers of the Environment) criteria by a large stretch. Dioxins consistently contribute far more to the Total TEQ in fish than P.C.B.s although they (P.C.B.s) are a significant contributor just as consistently.

White Suckers also had their TEQ calculated much more often Downstream than Upstream. That said the Upstream TEQ was very close to the Downstream multiple TEQ values in Suckers. Both P.C.B.s and Mercury had amazingly similar concentrations in fish tissues Upstream and Downstream of Elmira in the Canagagigue Creek. Again DDT & Metabolites are the exception. Their Downstream values are much higher than their Upstream values. While these fish are certainly mobile there are constraints by the Woolwich Dam perhaps a mile or two upstream and the small dam (for firefighting purposes) on the Uniroyal/Chemtura property. Fish can go over these dams once only as they certainly can't travel back above them. Therefore is the M.O.E.'s definition of Downstream and Upstream perhaps a little deceiving here? How is this possible that some chemicals are found in fish at similar concentrations "Upstream" and "Downstream" and others are not? Are there other sources than Umiroyal/Chemtura for P.C.B.s and Mercury upstream ?

These previous fish are referred to as "Sport Fish" by the M.O.E.. "Forage Fish" are the shiners, creek chubb and bluntnose minnows. Their sampling was totally ridiculous to come to any overall conclusions regarding "forage fish" in general however we can see some patterns with shiners. From downstream of the Elmira Sewage Treatment Plant (right at the bottom or south end of Chemtura) the Toxic Equivalency Quotient (TEQ) is much higher all the way down the creek to the Grand River than it is both upstream of Elmira and upstream of the Woolwich Dam. P.C.B.s alone are higher from the New Jerusalem Rd. all the way as well down to the Grand River. Interestingly they are higher at the New Jerusalem Rd. not just below the Elmira STP. Is it possible that we have another source here as well? A source that enters the Canagagigue Creek just below Chemtura Canada's property? Two or three come to mind however all three were recipients of Uniroyal's (& others toxic wastes).

Mercury is simply at Traces levels in all three Forage fish unlike in Carp and Suckers.

ANALYSIS PLUS GENERALIZATIONS OF "GIG" RAW DATA

First off the broad picture. Common Carp and White suckers were only assigned two locations namely Upstream of Elmira and Downstream of Elmira. In comparison Shiners, Chubb, and Bluntnose Minnows were assigned six different locations, sort of. These were Upstream of the Woolwich Reservoir, Downstream of the Woolwich Reservoir, Downstream of the STP (Elmira Sewage Treatment Plant), New Jerusalem Rd., Northfield Dr. (#22), and Jigs Hollow Rd. (#46).

Sport Fish (allegedly) namely White Suckers and Carp were tested more or less equally regarding sampling for DDT & Metabolites, Dioxins/Furans, P.C.Bs and Mercury. The exception would be the lack of testing for Total TEQ or Toxic Equivalency Quotient for Dioxins/Furans and P.C.B.s combined, Upstream of Elmira. The one test done did have a significant TEQ for both fish. Significant in that it exceeded the fish tissue residue Guidelines.

Forage Fish namely Shiners, Chubb and bluntnose Minnows on the other hand were not tested more or less equally for the four previously mentioned parameters. Shiners were tested for all of them in five of the six possible locations. The exception was Upstream of the Woolwich Reservoir where they were not tested. Chubb were only tested in one location namely Downstream of the Woolwich Reservoir and not for total or combined TEQ of Dioxins/Furans and P.C.B.s. . Bluntnose Minnows were tested for all four parameters in only one location namely Upstream of the Woolwich Reservoir. Obviously detailed comparing of toxic contaminants by either species or location is impossible under these circumstances. It appears to me that the Ontario Ministry of the Environment have done it again ie. intentionally producing a psuedo scientific document that they can and will interpret any way that they want.

Some comparisons are possible. Carp are the prizewinners for both size of fish and size of toxic contaminant load. No surprise there. I am a little surprised with the distribution of Mercury. It is high both upstream and downstream of Elmira. Both these locations however are presumably defined as below the Woolwich Dam. While the highest TEQ was in Carp Downstream of Elmira, Shiners were a surprise. While having only one reading for five locations they were extremely high beating most of the Carp TEQs.

Carp had extremely high DDT & Metabolites concentrations in their residues Downstream of Elmira. That said again Shiners were a surprise, tieing and then exceeding the highest Carp concentrations of DDT & Metabolites at Northfield Dr. (tied) and at New Jerusalem Rd. (exceeded).

P.C.B.s are also a surprise. Shiners had their highest concentrations at New Jerusalem Rd. (96-110 ppb.). Carp were the prizewinners however UPSTREAM of Elmira with readings between 46 and 210 parts per billion (ppb.).

Also of a surprise are a TEQ in Bluntnose Minnows Upstream of Elmira of 1.2843. I find this strange and wonder where it's coming from. Keep in mind it's essentially impossible for fish living below the Woolwich Dam to get upstream past the Dam. Further analysis will continue.

TAG MEETING THIS THURSDAY

The Technical Advisory Group will meet publicly in Woolwich Council Chambers this Thursday at 6:30 pm.. The Agenda is out and looks to be very interesting. There will be a review of all documents received by TAG from December 12/16 until January 27/17. Also Item 4.1.1 is the flow rates for the Elmira Aquifers remediation. As of the last monthly Progress Report (December 2016) Chemtura's initial promised tripling or their final promised doubling of pumping rates has not yet begun. Item 4.1.1.1 will discuss In-Situ Chemical Oxidation which is yet another shameful and embarrassing issue for Chemtura. This is the remediation method which I proposed to CPAC back around 2009 based upon its' use in Cambridge, Ontario. Finally Item 4.1.2 will discuss monitoring on the east side. This of course refers to the Stroh farm and how it was the recipient of Uniroyal/Chemtura toxic wastes from the east side pits and ponds.

For me the more interesting documents to review include the December 13/16 Off-Site Investigation Work Plan and the December 30/16 Fish, toxicity and bioaccumulation data for the Canagagigue Creek provided by the M.O.E.. Obviously the December 22/16 2015 Model Check Point Analysis and the Remedial Action Plan Expansion Design Review of the same date will also be important and raise some red flags.

I have been posting here over the last several days in regards to the Fish, toxicity and bioaccumulation data that is the raw data going into the M.O.E.'s Ecological (Risk) Assessment due out by February 28, 2017. My comments and criticisms have been documented here both in the last several days as well as since the process started in 2012. Similarily the East Side (Off-Site) Investigation of the Stroh farm has to date exceeded the very low standards we've come to expect from Chemtura and their consultants over the decades. Just to be clear by exceeded I mean worse than usual. To date they still have not sampled the "Gap" although to be fair they are talking about it. Talk is by far the best part of all their cleanups. If stalling and delay were an Olympic event; Chemtura and the Ontario Ministry of Environment would be in perpetual contention for the Silver and Gold medals.

LOCATION, LOCATION & LOCATION

The above well known real estate truism describes the last nearly five years of Ministry of Environment "investigations" of the Canagagigue Creek. Firstly they repeatedly over tested upstream areas very close to the Uniroyal/Chemtura site while at the same time under testing locations further downstream. It's called a sampling bias and is a simple way to focus attention where you want it, not where it should be. If you sample three sites downstream miles from the Uniroyal/Chemtura site but once or twice while testing two or three sites upstream very close to the factory six to ten times then guess what? Not only do you have way more detections of toxic compounds where you've most tested but you are also likely going to hit higher concentrations the more you sample. In other words when the entire area is contaminated it is not difficult to fake "hot" spots exactly where you want them. This includes primarily testing right by road accesses such as the New Jerusalem Rd., Northfield Dr.(#22) and Jigs Hollow Rd. (#46). Afterall it's so much easier to mobilize remediation equipment and personnel where you have road access rather than marching and carrying equipment through fields, wetlands and bush.

The second location issue refers to where fish tissue residue samples were taken on the fish. Internal organs, especially the liver, accumulate persistent organic pollutants. Secondly fatty areas of the fish also accumulate POPs more than leaner areas. Notice that the fish samples were primarily skinless, boneless fillets on the leaner areas of the fish namely the upper back. This was no accident. Even then the concentrations significantly exceeded fish residue criteria. Imagine if they'd tested the more likely fatty areas and internal organs.

Finally persistent organic pollutants (POPs) bioaccumulate up the food chain. Hence higher predators end up having much higher concentrations than organisms lower down the chain. Therefore hawks, eagles, osprey have much higher tissue residues than benthic organisms (midges, mayflies) or fish. The same goes with coyotes, raccoons, mink etc.. Even directly in the aquatic environment higher fish predators such as pike and bass will accumulate greater concentrations of POPs than bottom feeders such as carp and suckers. Therefore once again by carefully choosing which fish (location) to test and which not to test our Ontario Ministry of the Environment have flavoured the outcome of their impending Ecological (Risk) Assessment.

They have minimized every variable possible in order to downplay the extent of the unremediated contamination in the natural environment (five miles of Canagagigue Creek and surrounding areas). They have also minimized the alleged "hot spots" to a very few locations very close to the Uniroyal/Chemtura site. It is decades past time to clean house both at the M.O.E.C.C. and also with the politicians whom they have served for decades.

FIGHTING POLLUTION WITH BOTH HANDS TIED BEHIND YOUR BACK

First off the authorities in agreement with their polluter friends must refuse to allow the most experienced, knowledgable and dedicated citizens to have the opportunity to question Chemtura Canada or the Ontario Ministry of Environment publicly and refuse to allow them the opportunity to comment at public meetings. This is what Woolwich Councillors Bauman (Mark) and Shantz (Sandy) did to CPAC in 2015. They would have been assisted in convincing their Council colleagues to go along by the dishonest words of Chemtura/M.O.E.C.C. representatives as well as by two other local, sour grapes citizens who would throw their own mothers under the bus for their own aggrandizement.

Access to technical documents needs to be limited by as many hoops and loops as possible. A lack of timeliness, awkward formats, financial costs to citizens are all part of the methodology of professional liars. Awkward formats includes handing out large documents via e-mail making both receipt and printing difficult. Financial costs include direct per page costs to citizens from Woolwich Township for printing Ministry of Environment e-mail reports that they (M.O.E.) should have sent out by hard copy in the first place. Don't forget that I've been paying my own costs privately for toner cartridges, paper and drums for my printers for the last nearly thirty years. Not a penny subsidized by anyone. Apparently my time, labour and expertise also don't count for anything. That I expect from Chemtura and the M.O.E. but for my elected Council reps it is disgusting.

To date I still do not have hard (paper) copies of the entire file sent to Woolwich Township and TAG last December 30/16. Of course I've only known about this file since the February 2/17 TAG meeting when it showed up on a correspondence list. Even then I had to break the rules by speaking from the gallery, requesting a copy, without putting my hand up for recognition by the Chair. The last Chair, Dr. Jackson, had been specifically told not to recognize any questions or comments from the gallery and I expect the new Chair has been as well. This of course is quite hypocritical when Sandy Shantz from the gallery routinely interrupts and speaks to TAG. That does however kind of make it difficult for her to get cranky about me occasionally doing it as well.

The paper copies of this report I now have came from Lisa Schaefer, a part time employee of Woolwich Township, after a little prodding on my part. That said she has done a lot of work including hopefully this Monday sending me the rest of the report which was missed when she printed out the initial batch last Thursday. I went down to the Township building (on my dime) and picked it up although truth be told that's not exactly a long trip. The reason for the missed many pages is fairly attributed more to the M.O.E. than to Lisa. Similarily issues with all the item numbers down the left hand side being missing may possibly also be due to the file format the M.O.E. used. I'm no file expert, computer expert etc. so I'm not positive on that. I can say that the hard copy I now have is ridiculously awkward as it is multiple pages wide and many pages long and trying to match up data such as chemical contaminants with location, with dates, with which fish (carp, suckers, shiners etc.) is brutal. Keep in mind some of these documents I received are 100 lines in length and the pages are eleven inches by seventeen inches. Seriously! One file has pages seventeen inches wide and it takes two pages side by side to have all the parameters in front of you. That is thirty-four inches wide. Another file I received has the paper the narrow way ie. eleven inches wide but it takes four pages side by side to have all the parameters available when you are looking at the concentrations and trying to match them with all the other variables. Yes that is fourty-four inches (11"x 4) in width on the table in front of you.

Try looking in the middle of a sixty-eight page report consisting of four packages of pages each group being seventeen pages (ie. 17x4=68) . Each page is 100 lines long and you're looking at a single parameter eg. mercury and then finding the corresponding information that is also in the middle of a 100 line page, spread over three more of these pages, each page of which is somewhere in the middle of your four packages. And everything is not numbered; the pages or the lines.

It's awkward as hell moving your computer screen back and forth sideways to match up multi-variable data. That's why printed copies normally are better, except of course when the printed copies lose the numbering system. Not for one second do I believe that this is unintentional on the part of the Ministry of Environment. They are currently in desperate straits and their credibility is in the toilet. They are pretending to be consulting with the public and providing transparency through releasing their data when in fact they are doing neither honestly nor clearly. Hence honest citizens, yet again, are forced to do battle with both hands tied behind their backs. And heaven forbid if a citizen loses their temper and out of frustration tells somebody where to go. Indeed that is the goal of professional liars and their fellow travellors. Intentionally frustrate honest citizens and provoke them into saying something politically incorrect or rude. Then dismiss them as being impossible to work with. Ring any bells Woolwich, Chemtura & M.O.E.C.C.?

FISH TISSUE RESULTS IN THE CANAGAGIGUE

Oh my God it's absolutely shocking! Not! There are levels of PCBs, Dioxins & Furans, Mercury and DDT & Metabolytes in excess of various health criteria in the tissues of fish in the "Gig". By the way that's in the tissues least likely to bioaccumulate these persistent organic pollutants (POPs). In other words in skinless, boneless fillets taken from the back of the fish. The areas most likely to accumulate POPs are internal organs such as the liver as well as fatty areas of the fish. No testing done there thank you!

The criteria mentioned include the Canadian Council of Ministers of the Environment ie. CCME criteria. There are many, many more POPs tested for and numerical values given and yet most if not all of them are allegedly below detection limits or essentially assigned no weight or value. I don't find that strange with extremely low concentrations but find it bizarre with common detection levels such as 5 to 50 parts per billion (ppb). Toxaphene is repeatedly reported at 50 parts per billion (ppb.) and then after it it states "no measurable response (zero) ". Mirex, aldrin, endrin, heptachlor, lindane, chlordane, photomirex, nonachlor and more all have numerical values assigned but are then claimed to be not there. Speaking of extremely low concentrations the MOE labs and others all measure Dioxins & Furans, in parts per quadrillion and parts per trillion which are respectively one million times smaller and one thousand times smaller than parts per billion. Therefore why are determined values in the parts per billion assigned to many pesticides (POPs) and yet claimed not to be there? Something stinks very badly.

The criteria and measurements for Dioxins are expressed as TEQ or Toxic Equivalency Quotient. As PCBs act in a similar way as Dioxins on life forms they too are expressed as TEQs. Hence all PCBs and Dioxins/Furans are expressed relevant to the most toxic Dioxin which is 2,3,7,8 Tetrachlordibenzodioxin or 2,3,7,8 TCDD. Therefore the various fish species tested have a TEQ measured in ng/kg or pg/g which is parts per trillion (ppt) which adds up all the various Dioxins, Furans and PCBs together. This gives the concentration of them in the fish's lean, back area. Hence they are understated to start with.

The CCME lowest criteria is .71 ppt for Dioxin/Furans and .79 ppt for PCBs.

The Total DDT CCME criteria for consumers of aquatic biota is 14 ug/kg or 14 parts per billion (ppb) of DDT in tissues (fish etc.). Total DDT includes adding in the DDT breakdown products namely DDD and DDE.

The CCME criteria for Mercury is 33 ug/kg or 33 parts per billion (ppb).

One last point is in regards to large numbers of fish whose gender (m/F) is not stated. The majority clearly are marked male or female but many common carp and white suckers are not designated as one or the other. Is this in error or are these symptoms of reproductive problems common in species affected by Dioxins and PCBs?

Here are a sampling of the results found in 2014 and 2015 in fish in the Canagagigue Creek:

Carp: Total TEQ ie. Dioxins/Furans & PCB equivalents item # 68.....3.74856 pg/g or ppt.
.....Also..item # 671....4.58208 pg/g or ppt.


White Sucker: Total TEQ Dioxins/Furans & PCB equivalents ........ .716911 pg/g or ppt.
.....Also..... .93998 pg/g or ppt.

Common Shiners: Total TEQ Dioxins/Furans & PCB equivalents ....... 2.77891 pg/g or ppt.
.....Also..... 3.26229 pg/g or ppt.

Bluntnose Minnows: Total TEQ Dioxins/Furans & PCB equivalents .......1.28431 pg/g or ppt.


DDT & Metabolytes: Criteria is 14 ppb. Common Shiners have multiple results of 120, 130, 150, 200 and 220 ng/g or ppb.


Mercury the criteria is 33 ppb. Common Shiner results are routinely between 20 and 30 parts per billion (ppb).


This is but a tiny sampling of the M.O.E.s data recently released. As fully expected the fish in the creek have uptaken toxic contaminants known to be in the sediments for decades; at levels well above guideline levels or criteria. Clearly without serious remediation fish and higher predators will continue to bioaccumulate these POPs causing reproductive problems, growth delay, increased mortality and other health effects. This includes the top predator namely human beings. This past four to five years has simply been the big stall once again. Stop talking, monitoring, testing, writing reports and start cleaning up Uniroyal/Chemtura's mess!

ADDENDUM- 11.20 am. I'm still reading hundreds of pages of raw data...Mercury upstream in the Canagagigue Creek for Carp 80 ppb-430 ppb. Mercury upstream for white suckers...40-70 ppb. all well above the criteria of 33 ppb.

SPECIFIC NUMBERS & DATA FOR FISH & BENTHICS IN THE "GIG"

Following are some big picture concentrations of contaminants in fish as well as survival rates of benthic organisms exposed to Canagagigue Creek sediments. That the sediments and their toxic contaminants are both lethal and biologically available to life further up the food chain is obvious. Equally obvious is that the Ontario Ministry of Environment are corrupt liars running interference between big polluters and local citizens adversely affected by the pollution.

There are five different sediment locations tested. Two are on the Chemtura site, two are downstream of Chemtura and one is a control site referred to as Peche Island. That site presumably is clear of sediment contamination as the test's validity is based upon 70% of the benthic organisms involved surviving 10 days in dechlorinated Toronto tap water sitting above the previously mentioned sediment samples. The dechlorinated and heavily treated Toronto tap water seems a tad bizarre to me but we will go with it for the moment. Also the most upriver Chemtura site is referred to as site 30 and it's right at the bridge (Hwy #86-Church St.). Frankly it's bad news in and of itself for Chemtura and the M.O.E..

The first benthic organism is Chironomous dilutus. Five samples produced survival rates after 10 days for the Peche Island sediments of 80-100 percent. Excellent. Unfortunately the four sediment samples from Chemtura and downstream weren't quite so healthy. Site 30 survival rates were between 60 and 80 percent. Site 750 at the south end of Chemtura had survival rates between 30 and 70 percent. Site 20 just past the Chemtura property line had survival rates between 60 and 100 percent. Interesting. Site 21-U1 near the New Jerusalem Rd. bridge had survival rates between 20 and 100 percent. Strange? Obviously these Canagagigue Creek sediments are toxic to this particular ubiquitous organism even after only a few days exposure.

Hexagenia spp did much better and clearly is a hardier (to pollution) organism. All the survival rates were between 80 and 100 percent with the exception of Site 21-U1. While three samples had 100 percent survival, one had only 70 percent and the other 10 percent. Oh my. This was a 21 day test which to me indicates that the testers knew in advance that Hexagenia were more pollution resistant.

This same organism was then tested for a 28 day period including Bioaccumulation tests. What the researchers were looking for was uptakes into their tissues of a DDT metabolyte as well as Dioxins and Furans. Unsurprisingly based upon sediment concentrations of these toxic contaminants, indeed they were bioaccumulated into the organisms. The only DDT metabolyte tested for was pp DDE and it had concentrations in tissues at Site 20 of nearly 24,000 parts per billion (ppb) and at Site 21-U1 of nearly 8,000 ppb. Dioxin and Furan uptake was much lower with 4,000 to 7,000 plus parts per trillion (ppt) uptake into the tissues of the organism. This of course is the start of the food chain bioaccumulation as fish and other life forms in the creek eat these benthic organisms.

Fathead minnows were tissue sampled after 28 days exposure to the sediments as well. More DDT metabolytes were tested and the results were much higher. The highest results were between 8,000 ppb and 35,000 ppb in the fish tissues at Sites 20 and 21-U1. Dioxin concentration of the most toxic type (2,3,7,8 TCDD) was just over 7,900 ppt at Site 21-U1.

Lastly a benthic organism referred to as Lumbriculus variegatus received a 28 day bioaccumulation test. It too bioaccumulated DDT & metabolytes up to 13,700 ppb at Site 20 and 6,600 at Site 21-U1. 2,3,7,7 TCDD was up to 7,600 ppt at Site 21-U1.

Tomorrow I will give you the readers some of the fish results. These include carp, suckers, chubb, shiners and minnows. They do not include the top predators in the creek namely pike and bass. This most likely is because those top predators will of course have the highest concentrations of toxic contaminants in their flesh. Also keep in mind that the M.O.E. have set up this study very carefully. By focusing their sampling all very near the Chemtura site; even if they can't avoid admitting there is a problem they have pre-limited the size and scope to just a small fraction of the entire five miles of contaminated creek all the way down to the Grand River. If Chemtura Canada are not paying off top M.O.E. officials then they surely should be based upon their services to them rather than to the public.

FISH, MIDGES, MAYFLYS & OTHER BENTHIC ORGANISMS IN THE "GIG"

Well I've been slowly going over the data sent to me finally via the intervention of the new TAG Chair Tiffany Svensson. Kudos to her for doing that. The data was of course released to Woolwich Township six weeks ago and I just received it yesterday. Some of the data is from samples taken in 2014 and 2015 by the Ontario Ministry of the Environment. Now you can understand why this cleanup and remediation are approaching the end of the third decade of going in circles.

The Ministry of Environment's Bio-Monitoring, Environmental (Risk) Assessment study or whatever name they choose to give it is horribly flawed. I have been publishing here my comments on the fatal weaknesses and flaws in it for the last few years as individual dribs and drabs of it slowly filter out. That indeed is part of the problem. I and the extraordinarily few who have bothered to read and understand the ongoing, literally for years, data are forced to reread and re-analyse the same reports over and over again in order to then see where the next piece of the puzzle fits into it. Overall these reports are simply meant to swamp and bury non QPs from following and understanding what's going on. QPs of course are the polluters and their friends terminology for Qualified Persons all of whom, unsurprisingly, are working for the polluters and their friends. The Ontario M.O.E. are simply hiding the forest for the trees. All of the data essentially say the same thing. Uniroyal /Chemtura are dirty polluters who have poisoned the natural environment with pesticides, persistent organic pollutants, Dioxins, Furans, P.C.B.s, DDT & metabolytes, mercury, solvents and so much more.

These items have been found above all criteria in the sediments and floodplain soils of the creek. They have been found in the benthic community which are sediment burrowing life forms such as midges, mayflys etc.. They are in fish from fathead minnows to carp, white suckers, pike etc.. They are hence bio-available which is no surprise. The sampling areas as I've previously indicated have been biased in order to pretend that the only areas of concern are very close to the Chemtura site versus the entire five miles down to the Grand River.

At best the Ontario M.O.E. will order a minor cleanup of the creek sediments near Chemtura. They will brag and send out Press Releases as to how they are helping the environment and they've done it all through public consultation with Woolwich Township and their residents. RAC, TAG and CPAC have all criticized their entire pathetic "investigations". TAG under Dr. Jackson was particularily incensed with the M.O.E.s nonsense , lying and disinformation.

This folks is how they've avoided cleaning up the mercury scandal in Grassy Narrows and we are seeing the very same coverup here.

PUBLIC CONSULTATION DOUBLE WHAMMY IN WOOLWICH TOWNSHIP

RAC & TAG as per the rules set down by Woolwich Council will not allow citizens to ask questions at their public meetings. Yes these are the public meetings dealing with our water supply, our creek, our air and the ongoing non-remediation of the Chemtura site which is responsible for all the previous problems. When it came time to appoint local, involved citizens to TAG the mayor was in a pickle of her own making. She had Applications from plenty of citizens namely two from the previous CPAC plus all the CPAC & SWAT members from 2010-2015. Her problem was that she and Mark Bauman wanted to get rid of the old CPAC folks because Chemtura and the Ontario Ministry of Environment were crying the blues about allegedly being treated disrespectfully. Quite frankly I was constantly amazed at how well CPAC members pretended to be respectful towards those professional liars and spin doctors.

The double whammy in the title above relates to the slow degeneration of other aspects of public consultation. This other aspect is in regards to reports and data being kept from both the general public as well as from informed, longterm environmentalists and activists. At one time hard copies of all reports were handed out to any citizens and stakeholders who requested them. For a while yours truly was automatically receiving copies of everything whether or not a formal member of CPAC. Nowadays hard copies are slowly disappearing as more and more lengthy reports from 50 to 400 pages are being sent by e-mail. This is beyond asinine and is simply one more way to discourage citizens from being active participants in the process. Also as per six Attachments I finally received today two of them are in a format which I am unable to print out. All in all this is being done to discourage the reading of reports by citizens and then informed questions or criticisms being heard publicly.

The latest games are courtesy of the M.O.E.C.C. being able to present their Ecological (Risk) Assessment Report by February 28/17 with minimal citizen input and comment. The raw data was sent out on December 30, 2016 and I received the e-mail Attachments this morning. Really classy and impressive and shameful to all guilty parties including the Ontario M.O.E., Chemtura and Woolwich Council.

SIGNIFICANCE OF CHEMTURA'S EAST SIDE DIVERSION

Based upon the suspected timing of the construction of the Stroh Drain it is likely that Uniroyal's liquid wastes had already flowed for decades onto the Stroh property before the Drain was built. Therefore it is unlikely that the idea of the Stroh Drain was first and foremost to be a conduit for toxic liquid wastes to bypass the Uniroyal/Chemtura property and any ongoing monitoring on that site or of the Canagagigue Creek through their property.

I do not know who specifically and exactly built this Drain. It does appear to connect far further south with some natural springs near the border between the Stroh and Martin farms. This natural spring then flows around the man made swimming pond on the Martin property and discharges into the Canagagigue Creek further downstream past most routine monitoring on and just below the Uniroyal/Chemtura site.

The Drain presumably was at least partly or perhaps even mainly initially considered to be a method to drain the very wet, low lying areas both between and on both properties. This large area collects both surface water runoff from both properties as well as has a very high water table which appears as surface water on both properties during the year. That said according to topographical contours the very lowest surface areas are about 20-35 metres east of the Chemtura/Stroh property line, on the Stroh property.

Environmentally I would believe that dissolved contaminants from the Uniroyal/Chemtura site in the Stroh Drain discharge downstream into the Canagagigue Creek. Hence these contaminants while bypassing the creek on the Chemtura site nevertheless end up back in the creek anyways. Not much environmental significance for life forms in the creek however possibly a huge human health significance as well as wildlife significance for those exposed to the surface waters of the Stroh Drain. Also there is the moral culpability factor. Did Uniroyal Chemical initially believe that the low lying areas on the Stroh property could act as a "sink" hence absorbing and holding their hydrophobic persistent organic pollutants (POPs)? Or was this completely above and beyond their thinking? Did Uniroyal Chemical aid or assist in the construction of this Drain in any fashion at all? What was their motivation if so? These are all questions that not only have gone unanswered to date but thanks to the intervention of morally (at least) corrupt politicians we haven't even been able to ask.

LANXESS (GERMANY) SHAREHOLDERS BEWARE

In my opinion, possibly the biggest red flag indicating a diversion of the grossly contaminated east-side groundwater was the 1994 Upper Aquifer Containment & Treatment System (UACTS) plan followed by the 1996 implementation of the same. Conestoga Rovers claimed that 97.5% of the groundwater contamination discharging into the on-site Canagagigue Creek could be hydraulically contained by eleven pumping wells all located in one quarter of the site, namely the south-west corner.

While undoubtedly the western retention ponds RPW 3-8 were horrific polluters of the natural environment; so were the east side pits and ponds namely RPE 1-5, BAE-1, RB-1 and RB-2. If we only knew to what extent and ability that Uniroyal and the Ontario Ministry of Environment were willing to lie and coverup for their own self-interest in the early 1990s. The only possible way that 1/4 of the site hydraulic containment could come even close to achieving 97.5% stoppage of discharge to the on-site Canagagigue Creek is if the rest of the site was being surepticiously contained, diverted or remediated.

To date we the public as well as CPAC have only had our questions regarding an Interceptor Trench on the east side, answered in the most superficial way by Chemtura. Their answers have included a cattle fence, a wildlife fence and or a fence to keep trucks and pedestrians away from RPE 4 & 5 when they were being excavated in late 1993 and put into the Envirodome (Mausoleum). I have made a couple of different suggestions as to what this is which appears on both Google Earth and on Waterloo GIS. An above ground fence it is not. That a wire fence is now currently present at least partially is not disputed. A wire fence would not however show up as clearly as scars in the earth indicating a buried trench, Permeable Reactive Barrier or something else much wider than a quarter inch strand of wire.

Perhaps this warning should be to senior M.O.E. personnel (not Lanxess shareholders) who approved or looked the other way regarding this apparent diversion of contaminated groundwater around the Uniroyal/Chemtura site both onto the Stroh and Martin farms and then back into the Canagagigue Creek. That part of the Stroh Drain was then also diverted directly into the Martin swimming pond is beyond horrific. Likely the Martins had no knowledge of what was going on upstream of them and believed that this was all simply natural groundwater originating on the Stroh farm discharging at the surface as a spring. Indeed perhaps the pipe into their pond was there before the Stroh Drain was excavated along the Chemtura/Stroh property line and led into the already existing natural spring further south.

That there has been no formal epidemiological study of the health of downstream Canagagigue residents is beyond shameful. That the Region of Waterloo health department, paid for by taxpayers, has not investigated succeeding generations of both the Martin family and other downstream residents is disgraceful. I do not know how it could be possible that generations of children swimming in the Martin pond as well as children playing in the creek downstream have not had permanent health problems. All of this could have been avoided if our appropriate authorities both regional, provincial and federal had done their duty. They have not. The costs both financial and reputation wise will be shared with Chemtura Canada eventually.

GROUNDHOG DAY AND ANTI B.... PILLS REQUIRED

Finally after nearly two decades of sitting and listening to the lies and crap coming from Chemtura (Uniroyal) and the Ontario Ministry of Environment; CPAC starting in 2011 and progressing with experience and time, laid down the law. We would not smile and nod when Chemtura or the M.O.E. refused to answer our questions. We would not sit there and listen to hours of unadulterated propaganda and bullshit from those two parties. They were put on notice that their nonsense, lying and gamesmanship would be called out and called out publicly. CPAC were replaced after the howls of outrage and anger from Chemtura and the M.O.E. fell upon the sympathetic and ignorant ears of the new Council in 2015. Lo and behold TAG under the Chairmanship of Dr. Richard Jackson publicly tore strips off the M.O.E. over and over again. It was absolutely a thing of beauty watching him take the senior M.O.E. liar to task and to school. Guess what? Dr. Jackson resigned or so we are told. Now we have another new Chair of TAG (Technical Advisory Group). Last evening was her first meeting and it went well. That said can you see the pattern? Tiffany Svensson is competent and professional. This is her area of expertise. That said she is essentially starting from zero on the Chemtura file as did many of her TAG colleagues sixteen months ago. We all recall the movie with Bill Murray titled "Groundhog Day". Has this become the fate of Elmira and Woolwich residents?

Two new TAG members were assigned to represent TAG along with the Chair at RAC (Remediation Advisory Committee) for the next year. They would be Dr. Sebastian Seibel-Achenbach and David Hofbauer. These are good choices. Ms. Svensson spent some time introducing a Dashboard which lays out the Short, Medium and Longterm Workplan if you will. It is an attempt to organize various areas and ongoing issues such as on-Site remediation, Off-site Aquifer remediation, downstream Canagagigue Creek restoration etc..

Upcoming reports include the Ecological Risk Assessment (ERA) from the M.O.E. due the end of this month. Also Dr. Neil Thompson will be presenting an updated Conceptual Site Model (CSM) to Chemtura, an "experts" meeting, RAC and eventually TAG. Apparently Conestoga Rovers couldn't get it right even after 25 years of effort.

The raw data for the ERA was sent out to TAG members at the end of December. I asked the Chair if copies were available to the public or perhaps on the Township's website. Lisa Schaefer, RAC & TAG Support Person, advised that it was not on the Township's website but was available upon request. I publicly requested a copy (including a please) in front of a dozen people. Her response was that requests need to be in writing. Classy Lisa as always.

ANOTHER PUBLIC MEETING FOR THE JIGS HOLLOW GRAVEL PIT

This public meeting is planned for Tuesday February 28, 2017 at 7 pm. in the Woolwich Council Chambers. The proponent IBI Group on behalf of their client Preston Sand & Gravel are attempting to remove the prohibition against below water table extraction which is currently in place for this gravel pit. This gravel pit is located directly across the Grand River from the village of Winterbourne and immediately downstream from the village of Conestogo.

This pit was initially approved by the lame duck Council late in 2010 which had been voted out of office by the electorate. Bonnie Bryant had campaigned vigorously against approving this pit and was elected while long time councillor Murray Martin got the boot. Then in 2014 Ms. Bryant ran for mayor and Murray Martin got elected back to Council. In possibly a bit of theatre and gamesmanship Murray had voted against this pit at the vote late in 2010. It wasn't enough then to get him re-elected. Now we will see with his upcoming vote where he actually stands on this pit especially if he agrees to below the water table extraction.

The Region of Waterloo along with most enlightened individuals and all environmentalists are against below the water table extraction. Gravel pits along the length of the Grand River are essentially death by a thousand cuts. The sand and gravel both above and below the water table act as filters removing both natural and manmade contaminants from the groundwater.

The best way in my opinion to stop this below the water table extraction is a combination of technical and environmental criticism to the plan combined with getting citizens out. Our Council like so many others are often moved more by their political self-interest than by the merits of the issue. If they feel they will suffer at the next election in 2018 by approving the removal of the Holding Provision against below water table extraction; then they will be hesitant to do the wrong thing. Otherwise without the public's presence and interest they will as usual worship at the alter of development and big business.

THE GAP, THE SINK, THE DRAIN & THE CORRUPTION

A picture is worth a thousand words. Perhaps a big picture is worth even more. I produced a three foot by two foot "picture" over two years ago. I presented it at one or two CPAC meetings prior to the takeover by Sandy Shantz and assorted people with little or no knowledge of either the history or the technical aspects of the 1989 Elmira Water Crisis. Just before this last Christmas someone gave me the bright idea of making copies of this large map. Copies however that were smaller, more colourful and easier to both carry around and read. This I did and I have handed them out to selected persons since. That would include CPAC members, Dr. Richard Jackson and Tiffany Svensson. I expect I'll have a few more available for tomorrow's TAG meeting in Council Chambers at 6:30 pm..

This map is a picture of the Uniroyal (Chemtura) site with the focus on the entire east side, north to south. It shows the location of most of the former east side pits and ponds. It also has topographical contour lines on it showing the high ground (red) as well as the lower areas (blue). Also marked on it is a huge swale running north to south along the west side of the east pits (RPE 1-5). This swale can be seen on both Google Earth as well as on Waterloo Region GIS, on-line. This swale is an indication of the volume of overflow from these pits in their operating heyday. The blue areas include the Canagagigue Creek, Stroh Drain and a low area within GP1 (gravel pit 1). The bottom half of this map is simply a copy of a Conestoga Rovers (CRA) 2012 map showing current conditions on the site at that time.

The top left corner shows two maps pinned to the big one (3'x 2'). The top map was produced (copied) in 1991 by consultants CH2MHILL from the bottom map (1983) produced by Jackman, Smith and Ralston representing the GRCA and the Ontario Ministry of Environment. Below that are two photographs taken in 2014 showing a northward view of the start of the Stroh Drain as well as a southward facing view of the pipe coming out of the ground which is the extreme north end of the Stroh Drain.

The title refers to "The Gap". This is the area intentionally not being sampled by CRA, GHD and Chemtura that runs along their eastern border parallel to the Stroh Drain which is perhaps 60 metres due east. The "Sink" refers to the low lying area on the Stroh property which is the area nearest the Chemtura property at the bottom (south) end of the first initial due south run of the Stroh Drain. This area is where it is most likely the greatest quantity of hydrophobic, toxic compounds are held in the soil. Hence it is a sink for DDT, Dioxins, P.C.B.s and much more. The "Drain" of course is the Stroh Drain. The "Corruption" is the behaviour of the M.O.E. and other authorities in desperately avoiding admitting to much less investigating these areas.