REVIEWING THE VARNICOLOR LOT 91 COVERUP IN ELMIRA

I have examined contaminated sites and their various technical reports for nearly thirty years. These have included of course Uniroyal Chemical, Varnicolor, Nutrite here in town as well as numerous sites in Kitchener, Waterloo and Cambridge. I've also read a few reports on contaminated sites in Guelph. These technical reports have been primarily hydrogeological reports and while Uniroyal certainly by a wide margin has the most it wouldn't be inaccurate to suggest that I have read probably several hundred reports in total. A few have been in regards to surface water investigations including sediments and soils and some have focused on air emissions.

Absolutely none, including Uniroyal Chemical have ever had the concentrations in soil of toxic contaminants that exist on the former Varnicolor Chemical Lot 91 site at the extreme east end of Oriole Parkway. Absolutely none have been examined less with more talk from the Ontario Ministry of Environment. Drums have been excavated with and without solvents and PCBs in them. Tanks and tankers have been removed from the site with and without solvents in them. We have been told by various consultants as well as the MOE that everything is contained on the site and is slowly by natural attenuation being cleaned up. The technical reports Conclusions may say that as well. Their hard data, facts, logic and common sense say otherwise.

Dumping of liquid toxic wastes took place on this site. Likely far in excess of two thousand drums of used solvents and still bottoms were intentionally drained on this site. Still bottoms are the liquid sludge which is the waste product remaining after dirty solvents have been run through a still to remove contaminants. Yes some source removal, as in drums and tanks were removed. Large scale soil removal or soil cleaning has not occurred. Natural attenuation is simply code for dilution. The MOE are permitting the contaminated groundwater to flow both into Landfill Creek and then into the Canagagigue Creek as well as allowing it to flow into the Elmira drinking water aquifers where maybe it is eventually pumped and treated. Maybe. Eventually. If we're lucky.

TAKE 100% OF THE BLAME & WE (MOE & TAXPAYERS) WILL BAIL YOU OUT FINANCIALLY

It could be called let's make a deal or it could be called collusion. Back in 1989 there was very little development in the south end of Elmira. Not so today. There was no 24 hour truck gas & diesel station at Union St. and Earl Martin Drive. There was no car wash and gas station right beside the south wellfield buildings as there is now on the north side. There was no Voisin Motors on the south side of the wellfield (E7 & E9). All the manufacturing industries due east of the former wellfield were not there in 1989. They sure are now. Is it any wonder that the Region threw in the towel and told us several years back that they had no interest in reviving the south wellfield? Why would they after our local councils surrounded it with heavy industry as well as underground storgae tanks of gasoline and diesel?

Sanyo Canadian and and the former McKee Harvestor have pumping well W3 surrounded on the north and south sides. As mentioned Saturday pumping well 3 like all the pumping wells is located in areas of high concentrations of contaminants. This is very odd if the source is totally Uniroyal at the north end of town and W3 is at the south end. The high concentrations of NDMA and chlorobenzene are also odd as normally plumes are high at the source and quickly diminish as they move further away. Similarly it's always been odd to me to have the highest pumping by far of all the off-site wells at the former wellfield itself E7 and E9 at the extreme south end of Elmira. As mentioned on the weekend, all parties originally believed that the source of the contamination had to be very close to the wells. Hindsight seems to be proving them correct.

Yes Sandy all parties and powers have lied like dogs for the last thirty years plus. They got caught red handed stroking Uniroyal Chemical and treating them with kid gloves only to find out that numerous other local industries were aware of that and decided that they too should belly up to the free bar. The free bar was of course,free, illegal toxic waste disposal. What an attraction for local industry. Even if you get caught you can count on the local politicians in conjunction with the MOE to cover your tracks and put the taxpayers on the hook to pay for a big chunk of the cleanup. How many were there? If you count all the service stations, manufacturing concerns etc. there are easily ten.

Varnicolor are guilty of contaminating the Municipal Aquifer from both their former locations namely 62 Union St. and Lot 91 at the eastern end of Oriole Parkway. Both site investigations were intentionally inadequate and with MOE permission or likely insistence neither explored contamination at depth on the two sites. The Municipal Aquifer is much closer to the surface at Lot 91 and hence much more vulnerable to surface contamination which was both gross and intentional. It is an unholy alliance of professional deceivers who believe that the general population are uninformed rubes who need to be unmercifully exploited and lied to at all times. If we the citizens en masse ever knew the level of misinformation, deception and manipulation being practiced by our local politicians, they'd all be run out of town on a rail. Couls happen yet.

ECO-LOGIC FLATLY STATED THAT THE NDMA SOURCE WAS VERY CLOSE TO THE SOUTH WELLFIELD

Eco-Logic were a small company in Rockwood, Ontario. They were hired by the Region of Waterloo in December 1989 to both look at the health risks from NDMA as well as to determine who or what was the source of the NDMA in the south wellfield. The first thing they determined via water sampling was that the NDMA in the distribution system was solely coming from the two wells, E7 and E9, in the south wellfield. Early on there was no NDMA coming from the five wells in the North Wellfield. This soon changed after the south wellfield was completely shut down. There was a groundwater divide based upon the normal and natural groundwater flow from Uniroyal Chemical being in a south-west direction. Once the south wellfield was shut down, the natural south-west groundwater flow continued however there was also a component of Uniroyal's groundwater pulled northwards by the pumping in the five north wells. This relatively increased draw of groundwater northwards resulted in the north wellfield also becoming contaminated with NDMA.

Eco-Logic was correct in their analysis that the NDMA source that ended up in the southern wells was from the south of Elmira. What they likely didn't realize was that isolating the Elmira Distribution System from the southern wells was a very short term fix and the fact that the other NDMA source in the north from Uniroyal would certainly announce itself very quickly after those were the only wells left pumping.To this day there has been little overt attempt to determine who was responsible for the NDMA near the south wellfield.

It is even conceivable that there were three sources in Elmira responsible for NDMA in the north and south wellfields. Certainly Uniroyal Chemical was one of them. Another I have long favoured was Varnicolor Chemical. My best educated guess for the third even further south would be either Sanyo Canadian or even the old McKee Harvester formerly located at Industrial Drive and Southfield Drive. Sanyo and McKee have the distinction of geographically surrounding the long running, pumping well W3 which is on Industrial Drive beside currently Leroy Auto and formerly Midas Muffler. Sanyo is north of the pumping well and McKee immediately south of it. There is a large open field to the immediate east with the Resurfice Corporation on the east side of the field.

Both pumping well W3 and its replacement W3R have had inappropriately high concentrations of both NDMA and chlorobenzene for decades. Just north of W3R at Industrial Drive and the south side of Oriole Parkway is monitoring wells CH38. They too have had inappropriately high concentrations of NDMA and chlorobenzene for decades. While Borg to date can not be ruled out in contributing chlorobenzene it is by no means certain.

What is certain is the Mickey Mouse investigation by Jim Bradley's five man team in late 1989 as well as the investigation in 1991 and 1992 by Ch2MHILL, were both inadequate. While CH2MHILL had a broad mandate and did excellent work in examining the current and future water supply for Elmira and St. Jacobs, they did not do a good job in investigating likely industrial suspects as NDMA sources in Elmira.

OFF-SITE LNAPLS & DNAPLS - THE ELEPHANT IN THE ROOM

While it's long been understood by the non-mentally deficient or ill that both LNAPLS and DNAPLS exist in the subsurface at the former Uniroyal Chemical (now Lanxess). What has been conveniently overlooked and ignored for the past thirty years are the off-site LNAPLS and DNAPLS sitting in and above the Elmira drinking water Aquifers. Even the APT coordinating committee members way back in the late fall/early winter of 1993 forgot about on-site DNAPLS and caused a major rift within APT that cost them the efforts of three excellent citizen volunteers.

This post however will focus on off-site DNAPLS both below the Nutrite property as well as below the Varnicolor property. The difference between the two is that the DNAPLS on the Nutrite property migrated westwards from the Uniroyal site. They gravity flowed along the surface of a relatively impermeable aquitard which slopes downwards from the Uniroyal site onto the Nutrite site. The DNAPLS on the Varnicolor site were introduced by both negligent, liquid waste handling as well as by intent. These chlorinated solvents are almost by definition perfect examples of DNAPLS (dense non-aqueous phase liquids) as they have a density greater than water (1.0) and they dissolve very slowly into groundwater with a specific maximum solubility.

The most common DNAPLS found in the groundwater at Varnicolor Chemical were Trichloroethylene (TCE), 1,1,1, Trichloroethane (TCA), Vinyl Chloride, Dichloroethylene (DCE), and Dichloroethane (DCA). These five chemicals were also finally publicly exposed as having entered the Municipal drinking water Aquifer beneath Varnicolor over two years ago.

Mention should also be made of the DNAPLS found just west of Varnicolor near the Elmira water tower. They were found approximately 100 feet below the ground surface in and around well OW 57-32 in 1998. Of course, as was usual, Uniroyal and the MOE never advised UPAC/CPAC about this major discovery. Yours truly found it in an old report in 2011 and brought it to CPAC's attention. These DNAPLS had Chlorobenzene in them. While they are much closer to the Varnicolor site than Uniroyal, the Varnicolor site allegedly has not had any detections of chlorobenzene on it. That is very strange as Chlorobenzene is both used as a paint solvent as well as for other industrial purposes including in the textile industry. It has also been found both behind (west) of Varnicolor as well as in the Howard Street storm drain to their immediate south. Lastly the chlorobenzene at OW57-32 could be free phase DNAPLS which possibly flowed from Uniroyal Chemical similarly as they flowed westwards onto the Nutrite (Yara) property.

LNAPLS were of course also found at the Varnicolor site floating on the water table. One of their components, toluene, has been found at great depth, all the way down to the Municipal Upper Aquifer (drinking water) courtesy of Varnicolor Chemical. The effect of these NAPLS, both DNAPL and LNAPL, is to have extended by decades the cleanup of the Elmira Aquifers. Thank you Uniroyal (Lanxess), CRA and the Ontario Ministry of Environment for your single minded dedication to the interests of polluters versus to the public interest and the environment in general.

VARNICOLR CHEMICAL CONTRIBUTED NDMA TO THE ELMIRA DRINKING WATER AQUIFERS

MOE In Full Coverup Mode For The Last Twenty-Nine Years

NDMA is one of a very few chemicals that is so incredibly soluble that it immediately dissolves into groundwater and then moves with the groundwater at it's normal rate of speed. Most other chemicals, organic and inorganic, are somewhat "retarded" by temporarily bonding with soil particles as they flow in the slowly moving groundwater. As a result geoscientists will usually spot inorganics (non carbon compounds) moving off a contaminated site prior to organics such as hydrocarbon solvents. NDMA however leads the way for both. The bad news with NDMA is that it can be drawn into drinking water wells long before more conventionally tested for compounds such as benzene, toluene, chlorobenzene, trichloroethylene etc. are ever discovered. I believe this is exactly what happened in Elmira thus exposing the population to NDMA in their drinking water years before the MOE tested for and found it in the south wellfield in November 1989. Why the MOE never tested many years earlier when they and Uniroyal knew it was being produced on site is another matter.

NDMA can be formed in acidic environments in the presence of dimethlamine (DMA). DMA was used as a raw material at Uniroyal Chemical, Nutrite, and Varnicolor Chemical. The MOE knew all of that decades ago as well. At the source NDMA can be relatively quickly flushed from the sub-surface as it tends not to be "retarded" by soils once the precursers (DMA) and other conditions have been removed or changed. NDMA while readily broken down in surface water from sunlight is amazingly persistent in groundwater. It also has an extraordinarily low Ontario Drinking Water Standard (ODWS) of 9 parts per trillion (ppt) or .009 parts per billion (ppb). Therefore even when the source of the compound has been eliminated it can continue moving in the groundwater away from the source for many decades as it has here in Elmira.

Back in 1990 NDMA was found in the Varnicolor Surficial Aquifer at a maximum of fifty times higher than the ODWS. In both 1990 and 1991 it was found off-site in nearby shallow wells to the north, south and east, close to but below the ODWS. Many other Varnicolor chemicals and solvents were also found in nearby shallow, off-site wells. The testing in either the Surficial or Upper Aquifer for NDMA was not remotely extensive either by number of monitoring wells nor by number of dates testing occurred. The deeper testing on the Varnicolor site itself was essentially non-existent for the first fifteen or sixteen years after the south wellfield was shut down for NDMA contamination.This included the one well (M2-1) on-site drilled down to the fourty foot depth and just into the Upper Aquifer. As soon as the south wells were shut down this well miraculously was taken out of service and never tested again for anything. CH2MHILL Consultants who examined possible sources in Elmira for NDMA contamination were in a conflict of interest position with Varnicolor Chemical as Varnicolor were clients of theirs right up until the Region of Waterloo asked them to work on the Elmira-St.Jacobs Water Supply Project in 1991.

The MOE have been extorting or perhaps persuading is a better term, Elmira Pump, the owners of the former Varnicolor site to clean up the site since 1999/2000. They have been extremely careful to keep all the data out of the public realm where it could embarass the MOE almost into extinction. Can you imagine if Doug Ford and his band of merry mischief makers and expense slashing folks ever knew how badly the MOE really messed up in Elmira? Can you imagine if they understood that all against the public interest, the MOE had been hiding evidence of their incompetence for the last 29 years? It just might be the formal end of the MOE as we know it.

Even after all these decades the MOE have been very careful not to test for NDMA as much as possible in and around the Varnicolor site. Deep wells were finally ordered in 2005, fifteen years after they were first ordered in a MOE Control Order and then unilaterally dropped. To my knowledge NDMA may have been tested for once in one deep well on site since then. That's it. You will never find what you carefully avoid testing for.

Lastly, contrary to the Golder Report and others, the Surficial Aquitard (SAT) on the Varnicolor site does not consist of clay and does not cover the entire site. It consists of silts intermixed with gravel, sand and even cobbles in places. Also the SAT thins to nothing in the south-west and easterly directions. This allows direct access to the Upper Aquifer (UA) and the Upper Aquitard (UAT) below it which also has "windows" or openings in it allowing direct access of contaminants into the drinking water aquifers further below. Just like at Uniroyal, once contaminants have hit the bare ground it's only a matter of time before Elmira residents are drinking them.

TOMORROW 2 PM IS THE CLOSING DATE FOR GETTING ON THE MUNICIPAL BALLOT

The Woolwich Township website carries details regarding the upcoming October municipal election. Somewhere in there they dishonestly state that the Township are nuetral and have no horse in the electoral race. That is typical bureaucratic bull manure. They, being senior staff for sure, and possibly even lower tiered staff, are stakeholders. They support the status quo big time. They support councillors who pinch pennies anywhere but in staff positions, wages and benefits.

They support councillors who aren't too bright. They support councillors who don't rock the boat. They support councillors whose attitude is get along to go along. They do not want rebels, activists or strongly, fiscally conscious councillors who understand that a huge component of Township expenses are wages and benefits and empire building. Therefore they support Sandy, Murray Martin, Julie-Anne and likely Larry Shantz. Patrick is too likely to support staff cutbacks if he gets any council support. Mark Bauman, Mr. Flip Flop, is gone thank goodness.

If for example I was ever on Council I would support the firing of both Dave Brenneman and Val Hummel. Both have made huge mistakes and been deceptive to the public, Mr. Brenneman far worse than Ms. Hummel. WE unfortunately have been stuck with very bad governanace for a long time. The one breathe of fresh air from 2010-2014 was destroyed by one individual on council with sticky fingers who got caught. Unfortunately it reflected on all of them despite the fact that it was his own Council who turned him in.

I'm very glad to see two names on the ballot for Ward Two (St. Jacobs). I wish someone was running against Sandy, Murray and Larry. After long and serious thought I decided that I would rather enjoy my retirement than attempt to change the biased minds of most of the self-serving idiots currently and after October 2018 on Council. Spending my money for the "opportunity" to soar with the entrenched "turkeys", just didn't excite me.

DEFINITION OF A PROFESSIONAL

Well if you are describing a groundwater professional the definition is a certified and licensed individual who will not rat out a fellow professional who is intentionally deceiving or lying to a) the public b) a non -professional c) anybody other than a fellow certified hydrogeological professional. This of course is based upon only thirty years experience dealing with hydrogeologists. Occasionally if a member of the public is very lucky, the stars will align in order for the public to be told the plain, unvarnished truth. Even in professional hydrogeological reports prepared on behalf of a client, rarely will the hydroG professional speak the plain truth, especially if it is bad news. After all he/she wants too get rehired for followup investigations, remediation alternatives and further expensive reports etc. A hydrogeologist who ever expressed shock, surprise, disgust or even just plain anger at a client who clearly had been surreptitiously dumping toxic wastes into a drinking water aquifer, river or lake providing drinking water would be reprimanded and likely fired on the spot.

I do not feel qualified to comment on other professionals such as doctors, nurses, teachers etc. Oh heck who are we kidding? Doctors can be very religious especially if they have a God complex. That said there isn't nearly as large a conflict of interest between the doctor's interests and the patients hence generally I expect they try to be as honest as humanely possible. Similarly nurses just like doctors can get overwhelmed and make mistakes but generally I would be surprised if they weren't very honest and straightforward with their patients. Teachers are in somewhat of a different boat. It's one thing telling a sixteen year old that they really need to be focusing on a simpler goal than rocket scientist if they are failing math, physics and sciences in general. I can't really imagine any good way for a teacher to tell an eight year old that their prospects are very slim and probably they never should. Telling stories to parents about their kids is another tough one. What parent ever wants to hear that their little boy or girl are really much slower than almost all the other boys and girls? In these circumstances discretion and subtlety are absolutely mandatory.

Professional engineers, geoscientists and hydrogeologists allegedly have some duty to the public in matters affecting health and safety. Certainly a civil engineer who signs off on a bridge or underpass which later collapses is held accountable. In my experience I have never seen a hydrogeologist held accountable for either failures, bad advice, minimizing contaminant threats or just general bullshitting and bafflegabbing serving either the clients interests (likely financial) or their own in order to get recommended or rehired. We all know that lawyers are experts at word smithing, lily gilding and other black arts in order to serve their clients. Fortunately other lawyers are there to provide context, and to keep them within some limits of truthfulness. As awful as our judicial system is, at least sometimes there is a balance of power between the prosecution and the defence. No such thing occurs between client driven consultants and the public who are stakeholders in the process. Our government "regulators" have long ago been defanged by budget cutbacks as well as by being "captured" by better financed industries offering jobs, directorships and consulting business for retired regulators. The system is rotten and everyone in the know, knows it.

VARNICOLOR DID THE DEED

I guess in hindsight the only surprising thing is that the Ontario MOE let Varnicolor walk back in the mid to late 1980s in regards to the contamination in the Howard Street Storm Sewers (HSSS). The investigation was primarily done by Varnicolor and their hired consultants. Exactly how unbiased do you think that was? As I mentioned here Saturday I attempted to get all the documentation and reports from Woolwich Township unsuccessfully many years ago. What I have however I reviewed over the last couple of days and it is quite damning.

The most investigative activity occurred closer to 1986-87 and not in 1982-84 as I had formerly understood. Also there was both an entire Appendix as well as references earlier on in Canviro's 1987 hydrogeological report regarding the Varnicolor Chemical groundwater situation. Canviro were a subsidiary of CH2MHILL who dropped Varnicolor as a client when the Region of Waterloo hired them to do extensive hydrogeological work for them after the start of the Elmira Water Crisis in 1989.

The Township were involved through former Public Works Department employees providing information regarding drainage in the area as well as pipe connections from the Varnicolor property into the HSSS. Bill Kowalchuk, CAO for Woolwich Township, also was involved in defending Varnicolor and in an amazing coincidence was hired by Varnicolor approximately a year later after being fired by Woolwich Township. The firing as CAO by Woolwich is strictly a verbal comment provided to me by someone in the know, although I've never heard it disputed to date.

The excuses as to why Varnicolor didn't do it came fast and furious from all parties with a vested interest in keeping Varnicolor's pristine reputation intact. This included from the MOE. Then after I blew the whistle the MOE continued their stalwart defense of Varnicolor. You know it's almost as if the MOE knew that their day of reckoning was just around the corner and they needed no distractions from Uniroyal Chemical being squarely and solely on the perpetrator's pedestal.

Evidence included volumes of liquids in the storm sewers far beyond what should have been in them long after rainstorms. They felt that groundwater en masse had to be being directed into the Howard Street storm sewer. Perhaps what they didn't consider was the possibility not just of contaminated groundwater from Varnicolor but outright intentional dumping. In other words waste solvents and waters that Severin Argenton couldn't recycle, hence unless he dumped them illegally, were nothing but an expense to him. These solvents found in the HSSS at high concentrations were all solvents found in Varnicolor's groundwater except for chlorobenzene. The solvents included 1,1 dichloroethane and 1,2 dichloroethane which the reports incorrectly stated weren't in Varnicolor's groundwater. They were, although they may have been found at a slightly later date.

Regarding chlorobenzene, an innocuous solvent commonly found in paint thinners and other uses, I've never understood why along with the dozens to hundreds of others found at Varnicolor, it allegedly was not. Either there is yet another source or as stated last Saturday here, the MOE did some serious fudging of lab data.

THE LONG TIME INTENTIONAL FOG OF COLLUSION IN ELMIRA IS CLEARING

I believe that David Brenneman, current CAO of Woolwich Township, is a part of it. Many years ago I approached him both verbally and in writing for information that was in the hands of Woolwich Township regarding the incidents of solvents in the Howard St. storm drains. There was a formal investigation by the Township and they allegedly could prove nothing although Varnicolor Chemical were the focus of the investigation. These incidents, in the early 1980s, occurred on a number of occasions in the storm sewers running between Varnicolor Chemical and Borg Textiles on Howard Street and their discharge point, Landfill Creek which empties into the Canagagigue Creek. Mr. Brenneman intentionally stalled and delayed for many months with no followup or response and then pulled his usual whining and crying that I was rude to him when I demanded an answer. What an arse. Sorry David, I keep forgetting that I seem to be the one in public service and that I report to you.

In hindsight why would Borg Textiles send any of their liquid wastes through the storm sewers when they had a perfectly good creek (Landfill Creek) running through the back (south end) of their property which discharged directly into the Canagagigue Creek anyway? The surface topography of their site means that all waters flow south into Landfill Creek. Also the storm sewer on Howard Avenue is on the north side of the street. To this day in fact there are catch basins (grates) on both the Elmira Theatre Company property next door to the former Varnicolor as well as on the Elmira Pump co. property which is the former Varnicolor site. Clearly it would have been almost impossible for Borg to discharge high strength liquid wastes into the Howard Street storm drains without running a hose across the road and into the catch basins whereas it would have been simplicity itself for Varnicolor to do so on their own property.

This leads back to the alleged lack of chlorobenzene found in the shallow groundwater on the Varnicolor site. Did the Ontario MOE fudge those lab results? Did they fudge the samples they sent to the lab? Did they fudge the written reports afterwards and replace detections with non-detects (ND) knowing that any detections of chlorobenzene would both likely prove Varnicolor's guilt in the early 1980s regarding the storm drains as well as implicate them with the Elmira Water Crisis as chlorobenzene was a major compound found in the Elmira aquifers? The MOE were desperate to cover up the extent of Varnicolor's pollution on both their sites.

Then we have the ongoing coverup of the extent of remediation on the old Varnicolor site since about 1993. Extensive shallow excavations were done across the site. It looked impressive. Deep testing, despite the initial control order demanding it, never occurred or if it did occur was never reported to the Varnicolor Liaison Committee, myself or presumably APT. If the data was given to either Susan or Sylvia then they buried it as Richard Clausi, Ted Oldfield and myself never saw it. Please tell me that pair weren't actively undermining public consultation that early on.

Finally deep monitoring wells were ordered by the MOE at the expense of Elmira Pump in March 2010. Again the MOE are hiding and refusing to give that information to the public. They are so far past being liars it is incredible. Even now they are refusing to give Elmira Pump their Record of Site Condition (RSC) so that they can sub-divide their property and build commercial storage units on the surface of the site. Over two years ago this RSC was allegedly imminent after the presentation of the results of a Risk Assessment. Still nothing allegedly!

There is but one reason for all this subterfuge and that is that Varnicolor contributed NDMA and possibly chlorobenzene as well as at least half a dozen other toxic chemicals to the Elmira Aquifers, all on the MOE's watch. Bad enough the MOE couldn't control Uniroyal, a multi national, but they couldn't even stop little, dinky Varnicolor. That is pathetic and that folks is your Ontario MOE tax dollars at work, protecting industry, both large and small.

THE TRUTH IS OUT THERE

Wally Ruck of Uniroyal infamy said in 1989 that "NDMA is not in our vocabulary". He and Uniroyal both got lambasted for that ridiculous comment as it was later proven that Uniroyal had found NDMA at extremely high levels in their wastewater in 1979, ten years previously. They also had found it in the air surrounding their facilities many years beforehand and they knew it was a health concern.

Similarly the Ontario Ministry of Environment (MOE) claimed ignorance of NDMA in 1989. They claimed that September 1989 was the very first time that they had ever tested for it in Elmira. They claimed that they had no standard for it. They claimed that it was some recently discovered industrial chemical and that they had no experience or knowledge with it whatsoever. Some of their comments were lies. That makes me wonder if all of them were lies.

NDMA is known as N-Nitrosodimethylamine as well as Dimethylnitrosamine. Both are one and the same. Both are known to be highly carcinogenic. Some scientists have referred to NDMA as being just about the most carcinogenic compound there is. That's quite a claim with stiff competition from dioxins, PCBs and the like.

In November 1978 the MOE published a booklet titled "Water Management Goals, Policies, Objectives and Implementation Procedures of the Ministry of the Environment". Harry Parrot was the Minister of the Environment.

On page 45 we are advised that there are some chemicals with zero tolerance limits. They would include DDT, PCBs, PBBs, Mercury and Mirex. To this day we absolutely have DDT, PCBs, and Mercury the length of the Canagagigue Creek below the Lanxess (Uniroyal) site. Possibly Mirex in low quantities is there too. Oh we also currently have dioxins/furans. Lots of them. Not to worry however as the MOE have since raised the allowable limits. What was a zero tolerance level when they thought they had none now appears to onerous for some manufacturers to be able to comply with.

On page 50 of this MOE booklet is a list of "Herbicides Actively Used in Ontario". 2,4,5-T is on that list. 2,4,5-T is known as 2,4,5 Trichlorophenoxyacetic Acid. It contains as a by-product of manufacture the most toxic dioxin there is which is 2,3,7,8 TCDD or Tetrachlorodibenzodioxin. This dioxin is the toxic ingredient in the infamous herbicide Agent Orange. Uniroyal Chemical in Elmira produced both 2,4-D and 2,4,5-T and then combined them to make and sell Agent Orange to the U.S. military. Here in Ontario we sprayed it along power corridors and highways.

Finally on page 48 there is a listing of substances with undefined tolerance limits. It includes Dimethylnitrosamine and describes it thusly: used in herbicides and cutting oils - identified as mutagenic and carcinogenic

The Ontario MOE knew that Uniroyal had been manufacturing herbicides since the late 1940s or early 1950s. By 1978 or likely earlier the MOE knew that NDMA would be found in their products and or waste waters. Allegedly the MOE didn't think to test Elmira's water for another eleven years? Uniroyal had been testing their waste waters for NDMA at least since 1979. Did the MOE knowingly look the other way while Uniroyal poisoned the water supply in Elmira? Did their lack of a standard allow Uniroyal to profit for an additional decade or longer while handing out death sentences to some Elmira residents? Why do we the public allow corporate murder for profit?

THE PAST NEEDS TO INFORM THE PRESENT

Dr. Richard Jackson enlightened citizens during his brief tenure as TAG Chair. Unfortunately his departure also enlightened us as to the futility of "public consultation" as practiced here in Woolwich Township. He understood that a bunch of newbies, no matter how well intentioned, need honest and straightforward leadership from experienced hands. They do not need game players with gross conflict of interests showing them the way.

Dr. Jackson pointed out that a huge impediment to cleaning up the off-site aquifers by 2028 was the penetration into low permeability aquitards (clay & silt) with various solvents and other toxic chemicals. He was correct and the proof is in the pudding. Despite Uniroyal and their successors and CRA and theirs (GHD) having their way for the last thirty years; it is now acknowledged by all parties that the Elmira Aquifers will not be at drinking water standards until at least 2050. Maybe longer.

Of interest however is that briefly this matter was mentioned in the March 28, 2003 Elmira Independent by Editor Gail Martin. She mentioned both the fact that chemicals can enter the aquitards as well as Dr. Jackson's use of the word Diffusion. Diffusion occurs when the highly permeable aquifer (sand & gravel) adjacent to the aquitard begins to lose its' contaminants via for example pumping and treating of the groundwater. Then very slowly the contaminants are drawn out of the aquitard (ie. diffusion) and back into the aquifer.

Joanne Peach of the Woolwich Observer at around the same time advised readers that Wilf Ruland (hydrogeologist) had advised CPAC that "Optimization" was unlikely to make a significant difference to the groundwater cleanup. In fact at one time Wilf suggested that the only thing being optimized was the money being spent on pumping and treating by Crompton. After all 50% of off-site pumping was paid for by the taxpayers hence Crompton had an incentive to "optimize" their pumping by doing less on-site and more off-site.

The result of the above paragraph is the understanding that once again the CPAC of the day got played and the MOE assisted Uniroyal/Crompton in so doing by preemptively passing the June 21, 2000 Amended Control Order allowing a relaxation of the mandated on-site hydraulic containment of contaminants. The MOE legally allows leakage off-site in 2000 even before the Optimization discussions got started at UPAC. Then UPAC and CPAC crap all over the plan and then suddenly Susan, Pat and Wilf "save the day" by agreeing to it on strict terms and conditions demanded by CPAC. What bullshit! This was one more instance of citizens being led both by the nose and by other co-opted citizens with conflicts of interest. Newsflash. Yes you can throw out the baby with the bathwater when the "baby" is neither human nor in the public interest.

IF YOU CAN'T LICK THEM, JOIN THEM?

Or so the saying goes. I sent off today, two days ahead of the deadline, my Application to join MECAC (Municipal Elections Compliance Audit Committee) as a member. MECAC of course are the pack of individuals who demonstrated, for those members of the public who wished to more fully understand how politics are done in both Woolwich Township and the Region of Waterloo, what exactly cronyism and favouritism is all about. They gave Sandy Shantz a pass on even requiring a full and independent audit of her Financial Statements. They allowed her, after getting caught, to hire her own Mickey Mouse audit of her Statements. Now just to be clear, any privately ordered audit of a candidate's Financial statements are Mickey Mouse. Most of these audits have Limitations clauses in them, advising whoever wants to know, as to how superficial these private audits are. This is in stark contrast to a full and independent audit ordered by MECAC. Scott Hahn found this out the hard way and in fact that audit quite appropriately hammered him. Thank You Froese and Partners.

In my Application I included my education (1974 BA in Economics) along with a one year Accounting course. I also ran my own business for nearly a decade and gained bookeeping experience from that. I just wound up my term as the Chief Financial Officer for a local candidate in the provincial election from last month. I of course filled out the Financial statements for my candidate and submitted them. Then of course there was my two to three years experience here in Woolwich Township examining the Financial Statements (or lack thereof) of three successful candidates namely Mark Bauman, Scott Hahn and Sandy Shantz. Interestingly two of those three have now dropped out of our local political scene which I view as a very strong positive. MECAC had major credibility issues due to both conflicts of interest as well as due to either incompetence or bias or both. Way too many former local politicians and worse on that committee. MECAC's failure to point out that Sandy Shantz had forfeited her office due to her failure to provide an audit of her greater than $10,000 expenses and contributions was shameful. That took myself and Rich Clausi to bring that to the forefront.

Therefore clearly MECAC needs a redo. I'm putting my name forward to assist them. Clearly my Application will be accepted if they wish to have a more knowledgeable member and dare I say a member with fewer conflicts of interest. They will also have a member who believes in full disclosure and accountability.

CONCESSIONS, DNAPLS, DEEP WELLS AT VARNICOLOR & BIOGAS

The November 25, 2009 edition of the Elmira Independent raises concerns about a number of monitoring wells that Chemtura wish to drop from regular monitoring. It is strictly a cost saving mechanism as there is little to no rationale behind their removal. CPAC has kept delaying commenting because Pat and Susan's buddy Wilf Ruland is out of the country and they aren't remotely capable of commenting themselves on the matter. Yours truly was quite capable of so doing based upon my ongoing reading of both monthly Progress Reports as well as of the Annual Monitoring Report. Unfortunately as I had been removed by corrupt Woolwich councillors from CPAC, as intended Chemtura, the MOE and CPAC refused to give me the list of wells in a timely manner. That is called public consultation in Woolwich Township.

At the March 29, 2010 CPAC meeting we were advised that DNAPL remediation would be yet again put on hold.I was quoted as telling CPAC members that as long as you are willing to sit and talk with Chemtura that is exactly what they will do. They do not talk, bargain or negotiate in good faith. They are masters of the delay and do nothing strategy because it saves them money.

The Elmira Independent published a story in their March 17, 2010 edition titled "Deep monitoring wells required on former Varnicolor property". Approximately nineteen years after the MOE laid a control order on Varnicolor demanding deep monitoring and a deep investigation; they are now ordering the current owners known as Three Eights Inc. to do so. This company is currently known as Elmira Pump Co. This follows my public statements in 2009 that there were other sources of contamination to the Elmira Aquifers. Time since then has only reinforced those claims although the MOE and other authorities refuse to advise the public regarding these other local polluters.

On April 24, 2010 Mike Hicknell of Elmira sent a Letter To The Editor (Woolwich Observer) asking why the town of Elmira historically gets all the problem sites. He referenced Uniroyal, Varnicolor, Nutrite, slot machines and finally the proposed new Bio-gas installation at the north end of town. He asked why Elmira residents don't tell these developers to get lost. He also asked whether "...smart business people know they can always get their way and do what they want in Elmira?"

STOP THE PRESSES!!! CPAC NOTCHES ANOTHER VICTORY! CRA/GHD ADMIT ERROR

Obviously titles are used to attract attention to an article. That said the above title is actually an understatement of the facts. For approximately thirty years that I am aware of Uniroyal Chemical and their corporate successors plus Conestoga Rovers and their corporate successor (GHD) have been gilding the lily, promoting factual fictions, fibbing, truth challenged or whatever nicer words can be used for l.ing like dogs. Yours truly has almost made an art form out of exposing their forked tongue inabilities to utter frank and non-fictitious comments and words of at least near truth ideas.

The most recent one only took them four years after being exposed by CPAC and after decades of their own falsehoods. It also took at least a grade six level of technical deceit. Figures can lie and liars can figure. This combined with a dash of junk science combined with a pinch of misdirection and CRA (GHD) have long refused to admit that any groundwater from their east side has ever flowed eastwards onto the Stroh farm. CPAC are you ready. Public are you ready. Lanxess are you and your fellow travellors and councillors ready. In the June 2018 Progress Report, GHD have publicly (gasp & choke) admitted on page 5 that ``...there is a local groundwater flow divide and some SA (surficial aquifer) groundwater adjacent the site boundary flows east.``

I told them this many years ago while on the old CPAC. The latest and greatest CPAC told them this in 2014 and then backed it up with an independent report from MTE Consultants. Only now four years later are they willing to admit the obvious. This folks is why public consultation without serious support from local councils and politicians is doomed. Those even in weak positions of authority such as municipal councillors can not continue to support the status quo, corporate polluters and vested interests (eg. developers & planners) at the expense of the public interest. Those in charge of enforcement of provincial environment laws must enforce them. This means the pathetic and pitiful Ministry of Environment.

Citizens can point the way. The media, especially our sole remaining one in Elmira, need to pick up their socks. They do a good job on many issues but clearly have been silenced regarding Chemtura and Lanxess. That is to all our detriment.

SIX YEARS OF HORSE MANURE OR CLOSER TO THIRTY YEARS?

The six years refers to November 2012 when Chemtura Canada, Jeff Meriman and Dwight Este all fibbed to CPAC and the public. They were quoted by the Elmira Independent stating that they were planning on tripling the volume of their groundwater pumping and treating in order to speed up the remediation and restoration of the Elmira Aquifers.Within a couple of years they started to refer to it as a doubling of the groundwater pumping rates.They didn't blink, they didn't explain, they didn't apologize, they weren't red in the face and they didn't even come close to doubling much less tripling their groundwater pumping. They are professional BS artists whose words are wind!

The latest monthly Progress Report is for June 2018. Their pumping rates did not achieve their Targets for three different wells namely on-site PW4, offsite W9 and E7. W9 is still zero since last September and the other two have new excuses. The total off-site pumping rate of all off-site wells (ie. Elmira Aquifers) is 57.2 litres per second. Back in 2012 it was usually around 52 or 53 litres per second. In other words off-site pumping has increased approximately ten per cent. This is a very long way short of doubling (ie. a 100% increase) or tripling of rates.

Elmira and Woolwich citizens have been misled, deceived and blatantly lied to by the provincial MOE, Woolwich Township, occasionally the Region of Waterloo, Uniroyal and their consultants. There should have been a huge outcry around 2001 when we first learned that Nutrite had contributed ammonia to the municipal drinking water aquifers. All those parties plus one other citizens group as well as Nutrite were parties at the Environmental Appeal Board (EAB) hearings in 1990-1992. All those parties had to know why Nutrite were present as a party. The EAB was aborted in mid hearing by the MOE and Uniroyal hence the public never got to hear either Nutrite's testimony nor their cross-examination. All the parties conveniently (for Nutrite) kept Nutrite's invovement to themselves for the next decade including when Uniroyal began fibbing to UPAC/CPAC about having underestimated THEIR ammonia contribution to the groundwater and hence needing to borrow the Region's (Elmira) Sewage treatment Plant for a couple of years to remove it. It was all bullshit. The excess ammonia was all Nutrite's which was proven at yet another EAB hearing.

Once again no apologies, no remorse, no explanations, no shame. This is the face of unaccountable, government backed professional liars and deceivers.

BACK TO LAST WEEK'S TAG MEETING

O.K. I have to admit that it is very dry (boring!).The first 2/3 of the meeting was punctuated in my notes with words like "snoozefest" and "What a joke". This was likely because TAG were once again graced with the likes of Alan Deal a long time CRA employee. Now he works for GHD and he's as bad as ever. At least he seems to have recovered from the effects years ago of technical questioning from myself. In those days I wasn`t gagged by our pretend mayor, Sandy Shantz. Poor old Mr. Deal would get bright red as he stumbled through lengthy, circuitous explanations of Uniroyal, Crompton, Chemtura poor decision making.

We learned that there had been a spill of approximately 200 kilograms of diphenylamine (DPA) from a rail car on the Lanxess property. Allegedly the rail car had been overfilled by the supplier. There was also a recent spill of approximately three to four pounds of ammonia. We were told that a chiller shut off but the compresser did not thus raising the pressure causing a pressure relief valve to open. We were also told that Lanxess will be discontinuing ammonia storage on site. If so I expect that that will change Lanxess`s `Worst Case Scenario`in case of accident, fire or other emergency.

My written comments to TAG about one of the MOE`s recent reviews of the Canagagigue Creek investigation was briefly discussed. It was admitted that the MOE had screwed up with their inaccurate reproduction of some of the results from the 1996 Jaagumagi & Bedard biological study of the creek. Comments from Henry Regier were put off until the next TAG meeting in Septemeber.

It was interesting to know that Lanxess`s lab seems to get Dioxin results approximately 30% lower than the MOE`s lab. This does not surprise me in the least.

TAG are in many aspects on the right track. Others they simply don`t understand and nobody is helping them. Member Bill Barr has resigned citing work responsibilities. He too was over his head but I believe meant well.

SPENDING TAXPAYERS MONEY UNNECESSARILY, OTHERWISE KNOWN AS BOYS AND THEIR PEEING CONTESTS

Indelicately put, it's all about who can pee the furthest from a standing position. Boys invented this game because due to inherent advantages, half the population really can't compete. Now the real tough country boys actually would do this with an electric fence as the target. I always was glad that I was a city boy. Now when it comes to politicians and other assorted bent characters, they have altered peeing contests thusly. They use the courts for their peeing contests. The courts, similar to private enterprises, are always willing to take the business. After all, judges are former lawyers and they know that lawyers really are mostly human and they have to eat to.

Here's however where politicians, school boards, municipalities; you get the picture, have totally changed the rules of the game. No electric fences, no splash, no embarrassment as their shortcomings are exposed. Is this why so many of our male politicians are short? Think of Wideman, Zehr, Deutchman, Cowan, Hahn, Martin, Bauman. Also there is the huge bonus of going to court and not risking one red cent of your own money. After all this is a huge reason for little politicians with big egos and pride, but not much else, to go to court. They are spending OUR money to defend their alleged inherent superiority, intelligence and integrity. They sure as hell couldn't afford to do it on their own dime.

Which brings us to the rescheduled August 2, 2018 court date involving Woolwich Township. Yes that's you and I. But you say we have no dog in any fight with the owners of #86 Auto Recyling and you are correct. This is certain Woolwich councillors and staff who have decided to spend OUR money to teach these out of town, non-Mennonites a lesson. The lesson is to behave like the former owners of this former landfill; which means to be quiet and do as you are told by the Township and their elected representatives, no matter what. Yes the Township have illegally appropriated some of the Rattasid's property for a municipal waterline. No they don't want to talk about it nicely. #86 Auto Recycling have been told and that should be good enough. If they continue to insist that the Township have no right to accessing their land without an easement or other legal means and that the Township has no right in putting conditions on #86 Auto Recycling regarding their use of their own land near the waterline, then in retaliation the Township will spend YOUR last tax dollar in running #86 Auto Recycling through the legal mill. Keep in mind that we have the best legal system in the world, that money can buy. Especially YOUR money.

INDEPENDENT ARTICLE REGARDING SECOND SOURCE OF CONTAMINATION

The Elmira Independent article was dated October 21, 2009 and the title was "Second source of contamination: Marshall". I presented a Delegation to the October 5, 2009 CPAC meeting on the matter. In it I state that I believe that other companies closer to the south wellfield than Uniroyal contaminated the drinking wells with NDMA. I specifically mention well CH38 near Industrial Dr. as having NDMA readings much higher than other wells much closer to Uniroyal Chemical. Gail Martin quoted me as naming several likely candidates. These likely included Sanyo (slim evidence), Borg Textiles ( more evidence) and Varnicolor Chemical (highest evidence). The article also mentions that I have brought this information to Woolwich Council and staff as well as to CELA (Cnd. Environmental Law Association).

In the November 18, 2009 Independent we are advised that three new members were appointed to CPAC by Woolwich Council. Two of the three were buddies of Susan Bryant's and they turned out to be unremarkable to worse. Only Ken Driedger, pastor of Zion Mennonite Church, was a loss when he was not reappointed by the next Woolwich Council in 2010-11. I had recommended that mayor Todd Cowan reappoint him, albeit unsuccessfully.

In that same edition of the Independent Gail Martin wrote an excellent Editorial titled "Remembering Elmira's water crisis". The following people were given credit for their efforts to assist the restoration of the local environment here in Elmira as well as downstream in the "Gig" namely Alan Marshall, Richard Clausi, Dr. Henry Regier and Esther Thur all members of the Elmira Environmental Hazards Team. One other non-member was mentioned.

MOE REVIEW OF GROUNDWATER INVESTIGATION ON STROH FARM

First off this is not public consultation. I have been actively involved with UPAC, CPAC and RAC and TAG meetings since 1992. I am by far the most knowledgable local citizen bar none, or even groups of citizens, bar none, regarding geology, hydrogeology, chemistry, solvents, other contaminants, history of the site, Canagagigue Creek, contaminant fate and transport etc. All players including MOE, Lanxess, CRA, GHD, Woolwich Township, RAC, TAG, RMOW etc. know this. That said I received yesterday an APRIL 12, 2018 MOE DOCUMENT. Yes there have been worse examples of important documents being denied to and hidden and delayed from citizens but when is this going to stop? There will be Uniroyal trials as Pat Potter predicted and those guilty will be punished. Sending out documents asap to all other parties first and then waiting for them to show up on a correspondence list, literally months later, for me to begin inquiries is contemptible. Yes I have formally complained and yes I have been advised that attempts will be made to correct it. We will see.

The April 12, 2018 MOE Review is titled "RE: Lanxess Elmira - 2017 East Side Off-Site Investigation Report Groundwater Review Comments". It is written by a MOE hydrogeologist and sent to Jason Rice of the MOE who sent it along to Ramin Ansari of Lanxess Canada Co. "It is the view of the ministry that the implications of the observed NDMA exceedances in the shallow overburden on the East Side off-site Property need to be assessed." This east side property is of course the Stroh farm.To date the MOE have advised that the off-site groundwater assessment is deemed "incomplete". The MOE also clearly state that past conclusions regarding the Surficial Aquifer (SA) in Lanxess's north-east corner are totally unacceptable. This is huge especially since 2014 when the last and current CPAC proved that both ground and surface water had flowed eastwards, off-site onto the Stroh farm from the north to the south along the property line. As per page 3 the implications are that contaminated groundwater will continue to move off-site further to the east from an active or residual NDMA on-site source. "The current monitoring network in SA is deemed not adequate to conclusively confirm the existence of a flow divide and its location."

All of this has been known by the Ontario MOE, Uniroyal, CRA and other guilty parties for decades. They have all agreed to cover up this inconvenient truth for their own benefit. Myself, SWAT and CPAC brought this issue to light and paid the price of expulsion from public consultation courtesy of an incompetent and or corrupt Woolwich Council . This longterm and ongoing east side environmental cover up folks is corruption, plain and simple.

MOE REVIEWS 2017 EAST SIDE OFF-SITE INVESTIGATION

There is both good and bad in this review by the recently renamed Ministry of Expanded Corporate Pollution (MOECP) otherwise known as Ministry of Environment, Conservation and Parks. One of the goals with split samples was to ensure the accuracy of GHD's sample results. GHD failed, at least with their Dioxin results. Two sample areas in particular were a problem namely SS17C and SS18B. The measured Dioxin TEQ (Toxic Equivalency) by the MOE was higher than the applicable criteria whereas GHD on behalf of Lanxess measured concentrations of the same samples as below the criteria. This is very bad because once I or the public no longer even trust the supposedly accredited labs doing the analyses, then it's game over for the company and their consultants. Or in the alternative the labs have done a good job and the taking or mixing of samples was fudged.

Page 2 makes reference to former gravel pit GP1, allegedly south and west of the high diagonal strip of land in Lanxess's south-east corner. Interestingly, contrary to Jeff Merriman's comments to CPAC that the further north RPE pits were intentionally breached to allow contaminated liquids to flow southwards into GP1 1 & 2; this report states that it was "seepage and overflow" which caused waste water to flow southwards into these former gravel pits. This is not the first time that I have seen attempts by Lanxess to distance themselves from Chemtura/Crompton/Uniroyal personnel. Of interest is that Dwight Este also seems to be gone/transferred? No loss to the citizens of Elmira with that pair out of Elmira.

The reality is far more likely that the original map in the 1985 "History of Uniroyal Waste Disposal" written by A. Ralston, Wayne Jackman (MOE)and Tony Smith (GRCA) is the accurate one. It has GP1 located on the north-east side of the high diagonal strip of ground. This strip of ground runs from the north-west direction towards the south-east. If this is the case then the higher concentrations of DDT and Dioxin/Furans are far more likely to have run in a south and east direction through GP1 and over the border with the Stroh farm and then into the Stroh Drain. Lanxess and Chemtura dearly want to cover up this embarrassing and illegal fact.

The MOE point out that Table 2 criteria may not be appropriate for the soil samples taken at SS20 and SS21 on the Lanxess property because they are within 30 metres of the Stroh Drain. Table 8 criteria are 7 ppb. versus Table 2 criteria of 13 ppb. GHD measured SS21 as having 6.97 ppb which is one hell of an outstanding coincidence to my mind. Regardless the MOE measured the same sample as being at 10 ppb. which exceeds Table 8 criteria although not Table 2.

Another interesting point is that SS20 is sampled entirely on the high ground.This why its' neighbouring location (SS21) has higher concentrations of Dioxin/Furans as it is in the lower elevation area where overland water flow is more likely.

While there is good news in this belatedly delivered report to me; nevertheless the bad news is that the MOE have accepted the basic bullshit premise that surficial soil samples only 5.9 inches deep are acceptable for Dioxin and DDT sampling. As always you will never find what you refuse to test for which is Dioxins/Furans, DDT and more at depth, carried there by massive solvent concentrations in Uniroyal waste waters.

MECAC'S INCOMPETENCE OR IS IT CORRUPTION?

Last Thursday's Woolwich Observer had an article in their July 4, 2015 edition highlighted in "This Week in History". It indicated that the Municipal Election Compliance Audit Committee (MECAC) had looked at Sandy Shantz's revised Financial Statements and pronounced themselves satisfied. They hence improperly dismissed my Application for a review and an Audit of her Financial Statements. What "This Week in History" doesn't mention is what came next. It turned out that an Audit of Sandy's Financial Statements was absolutely mandatory by law as she had exceeded $10,000 in campaign expenses. MECAC of course totally missed this and Sandy of course had noooooo idea that by erroneously and falsely reducing her listed expenses to less than $10,000 she had avoided the cost and hassle of a mandatory audit. So either MECAC are grossly incompetent including their Chartered Accountant Chair Carl Zehr OR they knew and acted in a corrupt fashion to thwart Ontario law. Did I mention that Sandy likes to brag that she was a book keeper? Seems like this "book keeper" knows how to keep the books far better than Carl, Sandy or any of the other MECAC members and former politicians.

SEBASTIAN REFUSES TO BACK DOWN AT TAG

Sebastian Seibel-Achenbach was outnumbered and out opinioned but that did not deter him. A number of TAG members tried to persuade him, sweet talk him and deflect him with half measures but none of it worked. He was unhappy that TAG wanted to endorse the MOE's recent review of the Lanxess/GHD soil sampling and testing just barely on the Stroh farm from the east side of the Uniroyal/Lanxess property. To say the sampling and investigation was superficial is a gross understatement. Worse than how small an area of the Stroh farm they tested along with the proven Micky Mouse depth of only 5.9 inches (15 cm); was the once again shoddy investigation of the "Gap" area. This area was named the "Gap" because of how it was studiously avoided in the first set of investigations on the Chemtura/Lanxess side of the property line back in 2015.

First of all this area is within 30 metres of a surface water body, namely the Stroh Drain hence the criteria should be the more stringent Table 8 not Table 2. David Hofbauer, a TAG member seemed to be in support of TAG recommending that the MOE accept Table 8 as the appropriate criteria. Sebastian will be writing a Motion for TAG to vote on in regards to the low lying area nearest the south end of the Stroh Drain where it is closest to the Lanxess property.

Two additional points need to be incorporated . They are 1) TAG must not fall into the trap of accepting the MOE's review first with the cap in hand request that additional and deeper sampling needs to be done in the Gap area. Either the MOE insists upon more sampling be done in that area as described by Sebastian or TAG should not accept/endorse the MOE's review. 2) Fill may or may not be relevant in the Gap area. The Dioxins and DDT could be very shallow in depth, one foot down or two metres down. Many examples exist on site of deep hydrophobic compounds including PCBs, DDT and Dioxin/Furans. Contrary to Chemtura/CRA fibs as well as Lanxess/GHD fibs these persistent organic pollutants in the presence of a myriad of solvents can and do penetrate into the earth. Sometimes they penetrate on their own and sometimes they are buried by fill. No more excuses and bullshit please MOE, GHD and Lanxess.

Pat and Susan seemed to be waffling and trying end runs around Sebastian. Tiffany also seemed to be trying to deflect Sebastian with talk of "confirmatory" sampling. "Confirmatory" sampling is bullshit when you are only digging down 5.9 inches. Dig down two metres and then talk to me about confirmatory sampling.

VARNICOLOR CHEMICAL & BORG TEXTILES DID IT

The evidence is strong in both cases. On a balance of probabilities Varnicolor contributed NDMA (N-Nitrosodimethylamine)to the municipal drinking water aquifers and Borg contributed chlorobenzene. Now do keep in mind that this is based upon evidence produced by client driven consultants for Uniroyal/Lanxess Canada Co. I am quite certain that if the current owners of the former Borg Textiles were to hire their own consultants they would pin the blame squarely on Lanxess or perhaps even on Varnicolor.

The big problem with blaming Varnicolor for what has been described as an excess of 1300 kilograms of chlorobenzene in the Elmira Aquifers by Neil Thompson of the University of Waterloo; is that chlorobenzene testing in Varnicolor's shallow aquifers back in the 1990s came up empty. Now there has been lots of additional testing since then but the Ontario MOE in their infinite capacity to be deceptive have done their very best not to share that data with the public. I believe, without any confirmation from Elmira Pump, that the MOE have even threatened Elmira Pump not to share this data with me. Elmira Pump are the current owners of the old Varnicolor site. I also believe that most likely Borg Textiles handled chlorobenzene. What has always bothered me is that Varnicolor as a paint and solvent recycler should have handled chlorobezene as well. If the MOE fudged the lab reports, one way or the other, then we are likely talking corruption on the jail time scale.

Then we have the NDMA issue. Varnicolor did come up with generally low levels of NDMA in their shallow groundwater in the 1990s. There were however a couple of very interesting, deep soil samples that were much higher in concentration. Again I am aware that the MOE have done everything possible to avoid looking for NDMA on the Varnicolor site. What you don't test for you will never find. That has been their out. I believe that their might have been all of one deep sample taken in the last fifteen to twenty years which is just ridiculous. Unless of course you don't want to muddy the waters of having Uniroyal/Lanxess take responsibility for the complete Elmira Aquifers cleanup. This certainly would explain the October 7, 1991 sweetheart deal that the MOE gave Uniroyal Chemical, including the Indemnity for all known contamination.

The last huge evidence also includes the Uniroyal/Lanxess Annual Monitoring Reports over the years. They have plume maps as well as contaminant trends graphs showing high concentrations of NDMA and chlorobenzene where they simply should not be if Uniroyal were the sole source to the Elmira Aquifers.

TAG MINUTES

The Technical Advisory Group (TAG) Minutes from their last meeting on April 19, 2018 were sent out late last week. Usually TAG members and others receive them approximately a week ahead of the next scheduled meeting which happens to be tomorrow at 6:30 pm. in Woolwich Council Chambers. As the next TAG meeting is scheduled for September 20, 2018 then the Minutes of tomorrow's meeting won't be available until approximately September 13, 2018 or two and a half months away. This process of waiting 2 1/2 months to see the Minutes after a meeting is inappropriate. It pretty much guarantees that some important items from the meeting don't make it into the Minutes and that members aren't likely to notice omissions.

I believe that the following items in the recently received Minutes are important. The GHD rep stated that the creek is a dynamic environment with sediments moving constantly.That is huge as it points out how bizarre it is to still be having toxic chemical exceedances decades after production and waste burial took place.

The same rep, Mr.Farquharson, also stated that the first step is a sediment transport study. This is huge and only decades overdue. Dr. Richard Jackson pushed for this and got absolutely nowhere so is this for real or just more of the same poo poo del toro?

TAG believes that there is an ongoing source of DDT and Dioxins (plus a lot more) leaching downstream from the site.This relates back to both point one (dynamic environment) as well as to the ongoing flood events over the decades.

The floodplain Reach 2 is literally miles downstream in the Canagagigue Creek and yet 50% of total Dioxin TEQ (Toxic Equivalency) results exceeds the criteria.

Sediment results in Reach 3, downstream of the Stroh Drain discharge, have 64% and 56% of their sediment samples exceeding the criteria. These could be from either the Lanxess facility directly or indirectly via the man made diversion off-site to the Stroh farm.

We are advised in the Minutes that Dioxin & Furan sediment results increase with sample depth at the majority of the sample locations. This is huge and helps put the lie to Lanxess and GHD claims that these contaminants tend to remain in very shallow soils.

Regarding the test results for creek bank soils there is a similar finding. DDT concentrations are consistent or increase with sample depth and Dioxins & Furans increase with sample depth. This is also huge for the same reason as the previous point.

The floodplain soil results summary also states that concentrations of Dioxins & Furans generally increase with sample depth. Wow again.

There are a number of tables purporting to compare one years sediments or soils with previous years results. Firstly they are cherry picking particular years and not showing all the years since 2012 that testing occurred and the Tables are not self explanatory. In other words you really have to go back to both reports being compared to figure out what they are trying to do.

MINISTRY OF EMPTY CORPORATE PROMISES (MOECP)

The devil made me do it! I just love when the MOE keep on changing their name. Funny how Lanxess (Uniroyal) have been doing the same thing. Trying to hide from their own behaviour and history seems likely to me. I was advised on the weekend that they have changed from Ministry of Environment and Climate Change (MOECC) to Ministry of Environment, Conservation and Parks (MOECP). What a joke. A pig by any other name is still a pig. Or better yet putting lipstick on a pig doesn't changer what he is. Go Dougie Ford.

Further name possibilities for those of a creative bent. How about Ministry of Excuses, Corruption and Pollution? Or perhaps Ministry of Expanded Corporate Pollution. I really like that one.

I didn't go along with the last couple of meaningless and essentially stupid name changes. When it was the Ministry of Environment & Energy (MOEE) I called them the Ministry of Errors and Excuses. Since then I've stuck with either M.O.E. or MOE. MOE is appropriate as well when you think of the three stooges, Larry, Curly and MOE. MOE is obvious whereas Larry is the Ministry of Labour and Curly the Ministry of Transport. Just think of the state of driving as well as the safety these days. For the Minister of Labour try being a non-union employee in this province over the last fourty years. Discrimination is rife even when it's not about gender, race or religion. I think you get my point.

Last thought: Ministry of the Evolving Communist Party. OK that one is silly but sometimes silly is necessary.