DANG THAT CHRISTMAS SPIRIT

I'm going to say one nice thing about Sandy Shantz in today's posting. Wait a minute I can think of two nice things. Hmm. I'd better do it quickly while I can think of them.

1. TAG meetings are held at 6:30 pm. when working folk are able to attend versus literally decades of Susan and Pat scheduling to their convenience namely 9 am. on a Monday morning. P.S. This past schedule eliminated Richard Clausi (EH-Team ) from attending as he was a teacher and it cost me wages once per month to attend. Thank you Sandy.

2. A professional Chair was hired by Sandy Shantz for TAG (Technical Advisory Group) meetings. O.K. maybe a professional Chair was unnecessary as a number of "amateurs" handled the Chair's job acceptably or better however both Dr. Richard (Dick) Jackson and Tiffany Svensson were/are good Chairpersons and just as importantly Pat McLean and Susan Bryant are no longer in control of what used to be known as the Chemtura Public Advisory Committee (CPAC). That particular past Chairperson (Pat) sometimes did not discharge her Chair duties within any known rules of decency, honesty or transparency.

The next TAG meeting is scheduled for Thursday January 24, 2019 most likely in Woolwich Council Chambers and if not there then in the room behind (north of) council chambers. That room is known as the Dodie Hummel Room. Of interest is that Ramin Ansari, hydrogeologist for Lanxess Canada has indicated that he would like a further discussion in regards to both the alleged Interceptor Trenches on the Lanxess property as well as TAG and CPAC (now the Citizens Public Advisory Committee) concerns around the East side (Stroh farm). These concerns include the "Gap" area still, as well as the likelihood that there is a "sink" of Dioxins/Furans, DDT, PAH (poly aromatic hydrocarbons) and possibly mercury and PCBs.

I was included in the last off the books discussion in September about this matter and expect to be this time as well. A TAG member has asked me to bring my personally made 2 1/2 foot by 3 1/2 foot map as it is by far the easiest to see and read due to both its' size and clarity.

THE QUESTION THAT NEEDS TO BE ASKED

We've all seen movies such as "The Firm" with Tom Cruise. Another movie that comes to my mind is "Regarding Henry" starring Harrison Ford. To say that movies like this give an incredibly negative perception of the behaviour of corporate America (or corporate Europe etc.) is a huge understatement. Also I'm sure there are lots of fiction books as well that describe corporate behaviour that doesn't just border on psychopathic behaviour but leaps right into it. Surely corporate decisions around issues such as Thalidomide, Agent Orange, DDT, exploding gas tanks on Pinto cars, banning chemicals or drugs in North America while cheerfully selling them in third world countries would lead many of us to be highly suspicious of the phrase corporate ethics or corporate conscience.

Hence I'm going to ask the question regarding corporate behaviour here in Elmira, Ontario. Has our less than esteemed (in my opinion) Uniroyal Chemical, Crompton, Chemtura Canada or even the latest corporate name of Lanxess Canada ever behaved way outside the lines of "normal" corporate behavior? Specifically have they ever indulged in say psychological warfare? Have they gone beyond the bounds of client driven consultants writing self-serving reports that minimize the extent of environmental problems? Have our local polluters, as in the myriad corporate ownership changes, meddled in, oh for example, local environmental citizens' groups? Clearly any such meddling would be for the self-serving interests of the polluter. Could it be as simple as fairly privately bad mouthing one or two specific activists with local, naive politicians? Could it be as serious as attempting to entice local activists to the dark side so to speak? Could it go even further such as recruiting co-opted citizens to actively engage in undermining and disparaging other activists?

The very first indication I had of what I perceived to be peculiar or bizarre corporate behaviour along these lines occurred back in the spring of 1994. Granted a very senior APT person had previously suggested to me that they thought that Uniroyal might be bringing out a psychological expert to public meetings to gauge specific citizens regarding their commitment, flexibility, amenability to persuasion etc. Rich Clausi, Esther Thur and I had all departed APT Environment. This split was soon common knowledge including in the local media.

I was approached by Robert McBain who was working for Uniroyal Chemical as a a media relations person. He started complaining to me about Susan and Darrol Bryant. At the same time he flattered me unmercifully about how fact based my arguments were versus Susan and especially Darrol going on about "Mother Earth" and "Sister water". I found Mr. McBain's comments inappropriate and self-serving but also felt that he was testing to see how angry and upset I might be towards either APT Environment or the Bryants. Both of those individuals had been in India at the time of our (Rich, Esther & I) split from APT and I had absolutely zero animosity to either one and as far as APT went I was extremely disappointed with their poor decision to focus on Sylvia versus on the DNAPL issue. I was disappointed but understood their reasons.

Therefore Richard and I together met and talked to both Susan and to Sylvia Berg about this approach from Mr. McBain. I felt that this was an intentional attempt to drive a wedge between two local environmental groups and I wanted Susan, and even Sylvia who I had lost considerable respect for, to be forwarned. While I don't regret doing the right thing by telling them, I have to think in hindsight that neither of them would have done the same for Richard, Esther and I. I also wonder in hindsight if either Susan or Sylvia ever shared that private meeting with any other APT coordinators.

NO GOOD DEED GOES UNPUNISHED OR A PREEMPTIVE STATING OF THE FACTS UPFRONT

Yesterday I received a letter in the mail which may well have been sitting there for a few days it being Christmas time and all. It was from Elections Ontario and in fact was addressed to the local candidate for last June's provincial election who I had agreed to be the Chief Financial Officer (CFO) for. This candidate, a personal friend and environmental colleague, ran for a much lesser known party and knew he had a snowball's chance in hell of even coming close to winning but he supported their platform and thus ran for them. Unlike municipal elections, provincial elections insist upon a Chief Financial Officer to be named for each candidate. I was asked and immediately said that I was not an accountant or a lawyer nor was I familiar with provincial election law. My friend said something like: Alan you weren't familiar with municipal election rules and laws but you immediately made monkeys out of the Woolwich Clerk, incoming mayor and a multi term councillor. Well first off that wasn't the purpose of my looking into their election finance statements. I saw what I believed were some pretty basic and obvious significant errors and decided that I would do a little research to confirm that indeed Sandy, Scott and Mark had messed up badly. Now credit must go to Dr. Dan Holt as he was the one who started the ball rolling with Scott Hahn's absolute mess of a Financial Statement. If that was an attempt on Scott's part to deceive then he must have been told not to worry that they are a formality and that nobody will check them. Oops.

Anyway last summer while I was in the process of filling out my friend's provincial Financial Statement, I advised him that I wouldn't be doing these forms in a rush because it was important to do them as carefully and accurately as possible because I knew that somebody would be checking them, plus if anything went wrong there would be a bevy of irate local politicians just looking for the opportunity to jump all over me, especially. Hence I took my time, read all the instructions, checked and double checked each and every addition, subtraction and calculation to ensure accuracy. Despite my care and attempt to do an excellent job nevertheless I had them signed by me and returned to the candidate literally months before the deadline in December 2018. He advised me that he wouldn't be directly sending them to Elections Ontario but instead to the Party Auditor who apparently was to check all the candidates forms over before sending them to Elections Ontario. That surprised me but as I had returned the forms, to the best of my knowledge properly and accurately completed, to the candidate literally months before the deadline I understood that my duties had been completed.

The Elections Ontario letter has arrived and communications are already underway between the candidate and the Party. Supposedly reassurances have been given by the Party to the candidate but I just have a funny feeling on the back of my neck. Somebody, somewhere has messed up. The question is how strict are the provincial laws? Believe me the Municipal Election Act is a complete joke and farce. With probable bad intent, incompetence and every error being a self-serving one, all three municipal candidates walked from the consequences. Yes they suffered some embarrassment but even that they somewhat mitigated by having their friends involved in the so called investigative process. With good intent, serious and honest effort and absolutely zero self-serving errors made, the candidate and his CFO (me) should have no difficulties. Let's see how this shakes out.

MOE NOT SATISFIED WITH LANXESS/GHD RESPONSES

I'm really not clear as to what exactly is going on although I will say that despite a few decades of bad, incompetent and corrupt behaviour by them, this latest report from them is not the first time that I have seen significant signs of intelligent life. As I recall, the MOE's (MECP) comments on the 2017 Annual Monitoring Report last spring were described as the most comprehensive and critical comments in many years. There has been a turnover in personnel although as I've stated here I did not see any improvement with the presence of Terri Buhlman during and after the Dr. Richard Jackson time as TAG Chair. Jason Rice seems to be also a fish of a different sort as well as I am beginning to appreciate his written critiques.

The MOE are quite obviously upset with Lanxess's response to ministry comments written by GHD and dated November 19, 2018. This response was in relation to the MOE's comments and questions about the 2017 Canagagigue Creek Investigation. The MOE (Jason Rice) are clearly stating that their comments and requests have not been fully addressed to date and that Lanxess's/GHD's Draft Report must not be finalized until they are.

Clearly the MOE are not happy with sample results for creek sediments that include significant quantities of stones and gravel. Dioxins/furans and DDT adhere much more readily to fine grained sediments with large percentages of silts and clays. The MOE are also not impressed with GHD's apparent insistence that sediment concentrations of contaminants need only be compared to one set of criteria namely the Canadian Council of the Ministers of the Environment (CCME), Interim Sediment Quality Guidelines (ISQG). The MOE are insisting that other criteria including the CCME Probable Effect Level (PEL) and the provincial Severe Effect Level (SEL) criteria also be used and included.

The MOE (MECP) are also insisting that GHD include what they the MOE refer to as previous discharge locations to the creek from former gravel pits (GP-1, GP-2) as well as from the Stroh Drain still referred to by the MOE as drainage ditch from 6770 Line 86, Township of Woolwich. It seems very clear to me that the Stroh Drain continues to discharge to the Canagagigue Creek to the current time.

The MOE want to see earlier aerial photographs included in GHD's final Creek Report to show how the creek may have migrated over time. Major depositional areas along the creek could have large depositions of the Persistent Organic Pollutants (POPs) such as the dioxins/furans, DDT and more (eg. PCBs).The MOE again reiterate their unhappiness with the location of samople locations that have far too much coarse gravel for their liking which then underestimates the concentrations of POPs. The MOE also repeats their criticism of GHD collecting sediments using a shovel and make it plain that those samples are inaccurate and can impact the retention of fine sediments.

There are also complaints from the MOE in regards to TEQs and TEFs, that is Toxic Equivalency Quotients and Toxic Equivalency Factors. The MOE feels that GHD are relying on the wrong calculations to determine these numbers.

The MOE seem to be challenging the very essence of GHD's risk based framework for their assessment within the creek. The MOE believe as stated on page four that there needs to be an assessment of deeper sediments as well as a "non-risk based approach that considers source control and/or "hot spot" removal." I believe that this is a crucial blow to plans of lessening cleanup criteria by alleging that there is very little exposure risk to receptors in and around the Creek. All in all I am seeing some positive signs. Will they continue or is this the same old game being played upon the public?

TWO ENVIRONMENTAL FIELD TRIPS YESTERDAY

The first one was to the north end of Bolender Park where Aardvark drilling were installing a well, a methane monitoring well that is. I had a good chat with some of the staff there and had confirmed that not only were high groundwater levels an issue over the years because they flooded the gas probes but even with this new monitoring well the high groundwater levels were a problem. Of major interest to me is that Woolwich staff and council while denying any of my suggestions were needed now seem to be doing them. Until now there were never any methane probes on the south side of the Bolender Park Landfill which was simply ridiculous.

The second field trip was to the east side of the Lanxess (Uniroyal ) property. From the cemetery on the south side of Church Street on the way out of town (towards Guelph) one can see the beginning of the shallow and superficial cleanup of the next door farm, the Stroh farm. Of course when I and CPAC advised Chemtura Canada and the MOE that the Stroh farm was contaminated by Uniroyal Chemical toxic wastes we could get absolutely zero support from those two parties. Four years later while the cleanup so far is superficial it is a start. Dioxins/furans, DDT and NDMA have been found in the shallow subsurface well above all criteria. Of course if they had tested deeper they would likely have found more contamination. Similarly if they'd tested for more contaminants they'd likely have found more. The investigation of both the Stroh and Martin farms have as yet not been remotely satisfactory but we continue to hope and push as we've been doing for decades.

TIS THE SEASON FOR HOPE

We are less than a year from the thirty year anniversary of the shutdown of the south wellfield in Elmira. Unfortunately Elmira residents were drinking a combination of water and low level solvents plus NDMA long before that. Pretty soon our authorities will no longer have anything to fear from a health study. After all most of the adults exposed for the longest duration will have passed on. Perhaps children living in Elmira from 1970 until 1991 may have health effects they've never understood.

We've had just about thirty years of fiction, fantasy and untruthfulness from just about everybody remotely involved with the 1989 Elmira Water Crisis, whether polluters, governments, consultants or politicians of varying stripes. Hence why would I have even a tiny bit of hope that the scheduled second discussion about the "Gap", the Stroh Drain and the Interceptor Trench might possibly be honest and forthright? Nothing else has been so why now?

The real issue is about a diversion of both surface and groundwater from Uniroyal/Lanxess over to the Stroh farm and then southwards into the Canagagigue Creek (Gig). It is possible that the Stroh Drain was dug in order to legitimately drain low lying, swampy areas on both properties. It would be somewhat difficult to believe that the folks at Uniroyal didn't understand ahead of time that there likely would be some pretty nasty stuff being moved downstream into the "Gig" by this Drain. Regardless depending upon the timing of the construction of the Drain, maybe the GRCA wasn't even informed about it.

The Interceptor Trench however is far more problematic. As is allowing the successor company to the likely guilty one doing the investigation. That would be a classic fox guarding the hen house scenario. Lets see, how about the Ontario MOE? Please, I may be hopeful but I'm no longer naive.

More than one or two more shallow soil samples or one monitoring well are required. If the goal is to eliminate Persistent Organic Pollutants (POPs) such as DDT, dioxins/furans, PCBs and much more from being washed into the "Gig" then extensive soil samples both shallow and deep are required in the lowest lying areas where they would have settled decades ago. Also the sediments in the bottom of the Stroh Drain need to be tested as well as the creek soils along the Drain. Then there are a couple of downstream locations along the Stroh Drain that have been partially blocked thus allowing dissolved sediments to accumulate. In other words Lanxess, the MOE and RAC need to swallow their pride and honestly ask CPAC for its assistance. TAG members and their chair have been listening and learning. Now the other parties need to as well. It will require back and forth communication and dialogue not Sandy Shantz's stilted pretend public consultation.

NOVEMBER 2018 PROGRESS REPORT

It's still very disturbing. There are currently four pumping wells under performing namely one on-site (PW5) and three off-site namely W6A, W6B and W9. The last of course is promised to be up and running by mid January. Way too little way too late. I doubt that it will actually increase the total off-site pumping because to date wells W3R and E7 have been pumping above their targeted rates in order to cover for W9.

I've been wondering about the ammonia treatment system for some time now. It treats pumping well W8 on the east side of Union Street due west of Lanxess but does not treat W9 on the west side of Union Street also due west of Lanxess. Those wells are awfully close together and yet W9 is down allegedly due to benzothiazole and toluene exceedances with no mention of ammonia issues. Hmmm odd. Also while ammonia treatment for pumping wells W5A and W5B on First St. east right next to Lanxess and Yara (Nutrite) is no surprise I do find that treating new well W6A & B further south on Oriole Parkway to be peculiar. Similarily former pumping well W4, due west of Varnicolor Chemical, was also treated for ammonia. Based on that as well as on the plume maps for ammonia it seems clear to me that Yara and Uniroyal were not the only sources of ammonia to the Elmira Aquifers. When will they ever come clean to Elmira residents?

Surface water in the Canagagigue continues to amaze. Have they recalculated their arithmetic means for the chemicals detected up and downstream in the creek? There has been a major turnaround in the last few months and it is bizarre. Acid extractables namely all the chlorophenols now have higher concentrations upstream than downstream. That is the major turnaround and something or somebody is doing something differently. It's either the math or the data has been audited because these averages shouldn't be changing that quickly.

The base/nuetral extractables as well as the volatile organics are the usual with numerous higher concentrations downstream in the creek than upstream. This is what I would expect as the creek is "enriched" with toxics as it passes through the Lanxess property. A major explanation needs to be given on this matter but of course neither I, CPAC nor the general public can raise this issue verbally at upcoming TAG meetings and RAC don't meet again until April 11, 2019. It's called insulating the polluter (Lanxess) and regulator MOE/MECP) from difficult or embarrassing questioning. Those parties sincerely thank you once again Sandy and Mark and Woolwich Council.

"WILL THERE BE ANOTHER WALKERTON"

The above title is quoted from Geoffrey Stevens Opinion piece in yesterday's Waterloo Region Record. Mr. Stevens, like others before him, lays the blame squarely at the feet of the then Premier, Conservative leader Mike Harris. He reminds us that "Some of the survivors (Walkerton) are still suffering health issues 18 years after the crisis."

Mr. Stevens states that "...Harris put his agenda of tax cutting and spending reduction ahead of the protection of the public." Interestingly while one might think that bond rating agencies would enthusiastically embrace cutting government spending, apparently not so much because of the accompanying tax reductions. Standard & Poor as well as Moody's are lowering Ontario's credit rating believing that the focus on reducing taxes, especially business taxes, that is the purpose behind lower spending will actually make Ontario's debt picture even worse. Well!

Mr. Stevens also bluntly attacks Premier Doug Ford for reneging on the Greenbelt protections. This huge swath of land circling the Greater Toronto area will be opened up for commercial and industrial development. Mr. Stevens uses the word reneging because that is exactly what Doug Ford has done.

Then there are the proposed exemptions to the Clean Water Act that municipalities can decide to follow in the cause of less scrutinized development. Mr. Stevens suggests that this "...does not mean Ontario will experience another tainted-water crisis. It simply increases the possibility."

Mike Harris made a public apology to the people of Walkerton for the Ontario government's responsibility, via the Ministry of Environment (MOE), for the poisoning of thousands of citizens and residents of Walkerton. The MOE and Ontario were not solely responsible but they played a major part in the disaster. So far we've had Walkerton and Elmira as the two best known drinking water disasters in Ontario. Which community will become the third best known?

SUPPLEMENTAL EAST SIDE OFF-SITE GROUNDWATER INVESTIGATION WORK PLAN

The MOE (MECP) had requested a supplemental groundwater investigation of the neighbouring Stroh farm as the initial one only tested groundwater a few metres onto the Stroh property. In fact those results did have NDMA at concentrations dozens of times to a couple of hundred times greater than the Ontario Drinking Water Standards (ODWS). Other chemicals were found on the Stroh property very close to the ODWS namely 2, 4, 6 trichlorophenol and 2, 4-dichlorophenol. The original plan was to have four wells both shallow & deep drilled along the roadway into the Stroh property. The MOE requested that one of those wells instead be drilled in the "Gap" area which is the lowest lying elevation along the property line between Lanxess and Stroh and across from the Stroh Drain.

One comment (pg. 3) in this December 13/18 letter from GHD to the MOE that is incorrect is that the only receptor to the contaminated groundwater is potable groundwater as in a shallow well. This is inaccurate as both the Municipal Aquifer may be a receptor as well as the surface water in the Stroh Drain. There is life in that year round surface water flow and it can be negatively affected by contaminated groundwater discharging into it whether from the sides or from the steel pipe coming in from the north. Despite longstanding and only partially correct claims that DDT and dioxins/furans are not capable of being dissolved in groundwater, I think that they and more should also be tested for in the groundwater on the Stroh property.

There is a reference to limited time access to the Stroh property. That is hardly surprising as Mr. Stroh certainly does not lose his property rights completely due to his neighbour's migrating contamination. Also we are advised that after a few monitoring rounds the newest wells on his property will be plugged, removed and decommissioned.

WE THE SHEEP MUST BE MOLLIFIED

So refreshing to know that Liz Witmer, chair of the (corrupt?) WSIB, has ordered a review of the files of 300 hundred former rubber workers. Of course there may very well have been 3,000 whose health and lives were affected by the working conditions in various rubber related factories around Kitchener-Waterloo but that's beside the point for the WSIB, the Ministry of Labour and our provincial government. It's all about scoping at the very start so just in case an adverse decision results, you've already limited the financial damages to your budget and the damages to your credibility and reputation.

Today's Waterloo Region Record carries the following story titled "Rubber Town: Workers, families hope for answers from WSIB review". The skeptics aka knowledgeable people are blunt in their assessment of the alleged promised review. "It's a public relations exercise." It's also a bureaucratic, minimum one year exercise by the WSIB. Allegedly it's all about the science and the records and what individual workers can prove they were exposed to according to Scott Wilson a WSIB board member. I believe that that is primarily nonsense. Why should the workers who are now sick and dying have to "prove" anything other than where they worked and from when until when? They were never given the records of which chemicals were in which departments. They were never given written lists of the chemicals in the products by the factories. The science of solvent poisoning has been available since the late 1800s and in the ensuing 100 years and more the science has only become more definitive and more obviously hazardous.

WSIB spokesperson Christine Arnott suggested that they want to undertake a review in a "thoughtful and deliberate way using the best approach." She also advised that they are working deliberately to put a plan in place as soon as possible." Isn't that just sweet? In my opinion they will indeed be deliberate and thoughtful in putting together a plan. They will deliberately take as long as humanly possible in order for as many as possible sick rubber workers to pass on thus lowering the financial liability of the WSIB. Is it even possible that managerial bonuses are at stake based upon the numbers of rejected claims that are overturned in the review as in the fewer overturned past decisions the higher the bonuses?

My father worked for Uniroyal in Elmira for twelve years and then for thirteen years at the Breithaupt Street plant. The Breithaupt Street plant has been mentioned twice in this series as having very polluted air. I wonder as in Elmira if the neighbours were also adversely affected by the fumes from the plant? By the way my father became sick a year after retiring and died at age seventy-three.

LAST NIGHT'S RAC MEETING

First off kudos to both Tiffany Svensson and Sebastian. They both were firm yet polite in putting forth their positions that the "Gap" needed more attention and investigation. To say that there has been resistance to testing either soil or shallow groundwater in this area is an understatement. As Tiffany pointed out last evening, the term "Gap" is in reference to a gap in our data in this area. This
"Gap" was most pronounced in the 2015 soil testing just barely on the Chemtura/Lanxess property whereby samples were taken from the north end of the Chemtura east side down to just below RPE-5. Then sampling jumped over the lowest lying area along the Chemtura/Stroh border only to be resumed again at the extreme southern most part of the property line.

The initial proposal of four wells (possibly shallow & deep) along the entrance roadway into the Stroh home and farm has been changed to three along the road and one supposedly in the "Gap" area. I had thought from across the room that the proposed well was located OK but Sebastian who was much closer to the map did not. At the end of the meeting I asked Lisa to put the map back up on the screen and then Sebastian and I looked at it again. Sebastian may be right after a closer look but we both agreed that my map (pilfered from a CRA report and then expanded northwards) which has the topographical (surface elevation) lines on it needs to be at the next January 24, 2019 TAG meeting to be certain where to locate either shallow wells or to do soil testing.

Both Sebastian and Tiffany expressed concerns with possible migration of Surficial Aquifer water either northwards or eastwards from the Lanxess site. Now Ramin of Lanxess quickly dismissed their concerns which was wrong to do unless Ramin as he later stated is totally focused on the deeper municipal aquifers and missed the shallow or surficial description.

Ramin to his credit appeared willing to have another meeting immediately after the RAC meeting yesterday to discuss the "Gap" with GHD, TAG, and the MOE (MECP). Tiffany deferred and suggested that it would be better at the January 24/19 TAG meeting with all TAG members present. Ramin, GHD (Lou), and Jason Rice of the MOE will attend that meeting for the discussion. Speaking of the MOE it was they who suggested that Lanxess/GHD move the one well over towards the "Gap". Ramin also at this time made an interesting comment about "...looking for the pipe" apparently in reference to the alleged Interceptor Trench. This is when my exclusion from the discussion is most not in the public interest Sandy. That comment needed clarification and expansion.

Tiffany also spelled out clearly why she and TAG are so concerned with this whole area which includes the "Gap", the Stroh Drain, the Interceptor Trench etc. They are looking for potential sources to the never ending Dioxins/Furans and DDT always found the length of the Canagagigue Creek wherever they are tested for. Tiffany also asked for a commitment from Lanxess that the "Gap" and more will be seriously examined if not immediately then in a later plan but before the finalization of the Risk Assessment for the Creek. She advised it be examined in either the Conceptual Site Model (CSM) of the Creek or else in the Risk Assessment process itself. Ramin agreed.

Off-site pumping well W9 is finally to be starting pumping on January 18, 2019. Long overdue. 2,4-D is being added to the Contaminants of Concern (COC) list. There should be many more.

Joe Kelly made a very good comment regarding high concentrations found at the upstream location of Station #30. He suggested that the contaminants may be coming from the Bolender dump site (ie. landfill).

Ramin very gently and subtly suggested that Mr. Stroh was not being terribly cooperative with Lanxess or the MOE in regards to testing on his property. Hardly a surprise in all the circumstances. Jasin Rice (MOE) advised that the final Creek Report was being delayed as the MOE felt that all their concerns had not been fully answered by Lanxess. Hence it might not be able to get it to TAG in time for them to read it prior to the January 24/19 TAG meeting. Issues include the "Gap" and Contaminants of Potential Concern (COPC). That is good because the COCs have been far too focused and narrowed on Dioxins and DDT to date.

The next RAC meeting is scheduled for April 11, 2019 at 4 pm.

P.S. I was politely advised last evening at RAC by Lanxess that Lanxess is no longer part of or a subsidiary of Bayer.

STILL DEFINITELY IS NOT PUBLIC CONSULTATION

Today at 3 pm. the Remediation Advisory Committee (RAC) quarterly meeting will be held in Woolwich Council Chambers. I assume that our mayoralty pretender, Sandy Shantz, will be the sole chair as Mark Bauman is no longer a council member. A week ago I listed the Agenda items for today's meeting. Ramin Ansari's (Lanxess) suggestion that a further meeting will be held in the first quarter of 2019 to discuss the Interceptor Trench information presented at the last RAC meeting in September is inadequate and inappropriate. He and Lanxess have had three months to look into the matter. The first quarter of 2019 could take us to the end of March. That is six months after new and devastating information was presented in Council Chambers to Lanxess and it was done at the request of Woolwich Councillor Mark Bauman. Is it any wonder it has taken us thirty years to get to the point that ten years of serious and focused efforts could have and should have done?

No one else on TAG or RAC have been able to take the lead on the Interceptor Trench issue. Fortunately TAG member Dr. Sebastian Siebel-Achenbach with his background on the last (and best) CPAC and his ongoing membership as a CPAC member stepped up on this issue. He was present both in 2014 when I raised the matter at a public CPAC meeting and he was the recipient along with the other CPAC members of the new data (Affidavits & diagram) that I found last summer. Hence he too pushed for this matter to be discussed and gave his immediate acceptance to speak to Lanxess after the meeting along with my assistance.

The discussion with Lanxess while in a public place (council chambers) was off the books. Neither my name, Sebastian's, nor the words "Interceptor Trench" were mentioned in the Minutes although Lisa Schaefer did indicate in the Minutes that this meeting took place after the regularly scheduled RAC meeting. The three to six month wait for feedback is unconscionable. This is not public consultation. It isn't even close. Having a veto over the membership of the appointed public representatives and exercising it is abominable. Not having to respond either within a reasonable length of time or at all to any stakeholder member of the public, much less a stakeholder with a nearly thirty year history of participation and research, is also abominable. This will eventually bite all the guilty parties in the as. and that includes Sandy Shantz.

OUR OWN GOVERNMENTS ARE DOING US IN

Did I miss the referendum? You know the public referendum which asked if Canadians were agreeable to letting all the corporate wrong doers off the hook in exchange for free (mostly) health care to fix us up after we have suffered the consequences of corporate negligence and malfeasance. This is somewhat of the similar mindset as the debate currently underway regarding citizens/employees giving up their right to sue employers for injuries received on the job in exchange for no fault workman's compensation.

There are obvious problems with both scenarios of course. For example if a press takes off your hand and arm on the job, all the compensation and retraining in the world will never get you your arm back. Similarly nobody can guarantee that your hopefully new job will either pay as much or be as secure as your old one. Finally that loss of a limb is permanent. Prosthetics are getting much better but I haven't seen any lineup of people wishing to exchange their original limbs for any prosthetic on the market.

Our health care system can sometimes be described as miraculous. Other times not. So, courtesy of government and corporate negligence, you've contracted cancer. This could be from bad air in industrial Ontario or even coming up from the Ohio valley. Thousands of Canadians die from air pollution every year. Will all the cancer surgery, chemotherapy or radiation ever fully restore your health? It sure as hell won't make you as good as new even though it hopefully will save your life. Then there are hidden issues such as spraying of Agent Orange in Gagetown, New Brunswick. How about spraying of railroad lines, power corridors, highway ditches and commercial forests to reduce undergrowth and weed out specific tree species to allow for greater growth of others? How many companies here in Ontario were using Agent Orange decades after industry knew it was extremely poisonous? Why in the name of God was it being used in Ontario AFTER the Vietnam War? Hell why was it ever allowed to be used in Vietnam in the first place? Dow Chemical and others were having cloracne and other health issues in the 1930s.

My family and everybody else's family have all been affected by soaring cancer rates. Yes smoking can cause cancer. But fewer and fewer people are smoking while cancer rates continue to rise. Solvents, diesel fumes, pesticides, thinning ozone layers and so much more cause cancer and our governments and scientists and doctors have known the causes for many decades. But there is money being made by individuals and businesses all the while. We certainly don't want to stop the money train do we? For decades Dow, Monsanto, Hercules, Uniroyal, Hoescht and so many other companies have been raking in the money with their toxic products. Yes they've been trying to mitigate their lethality and the side effects to both humans and the environment but for some reason actually stopping production is always their very last choice. $$$$$$$ And our governments run interference for them against us.

OH THANK GOD, ELIZABETH WITMER IS CONCERNED

Well her concern plus twenty-five cents that sick or dead rubber workers did not receive from Workman's Compensation won't buy them a cup of coffee. That is exactly what her "concern" is worth, that is nothing. Gee where was her concern when many of them fought the Workplace Safety & Insurance Board (WSIB) for years and lost to get their rightfully owed financial compensation to pay for lost work, lost wages and lost family members? While she was collecting her six figure plus salary, sitting in a plush air conditioned office accepting huge work related risks such as a papercut from her paycheque, rubber workers in Kitchener-Waterloo were being poisoned and dosed with carcinogenic chemicals all day long. Carcinogenic chemicals that their employers, scientists, chemists and the government have known about for many, many decades. Some of those same chemicals caused the first diagnosed bladder cancers in Germany in the late 1800s for God's sake!

Today's Waterloo Region Record carries this story titled "Rubber workers' claims to be reviewed." Allegedly a "dedicated review team" from the WSIB will re-examine more than 300 claims filed by rubber workers. Odd but I wonder what that "dedicated review team" are doing right now? The WSIB are understaffed we are told so which other claims will now be set aside to free up staff for this review? I also wonder if the WSIB will re-examine claims from dead rubber workers. Or how about dead rubber workers who either do not have immediate family or they too have passed on? Will the WSIB compensate the estates of rubber workers who lost everything; their health and all their assets paying for health care and prescriptions?

This is simply one more sham by government on the people as the squeaky wheel gets the grease. Kudos to the Record for their series of articles and shame on both the Liberals and Conservatives for continuing to serve the wishes of their corporate clients at the expense of the health, safety and financial needs of the public.

ENVIRONMENT UNDER THREAT FROM BILL 66

Bill 66, cutely named "Restoring Ontario's Competitiveness Act", is being described as "...the biggest and most significant environmental rollback to occur in a generation in Ontario" by the Canadian Environmental Law Association (CELA).It will rollback protections in the Clean Water Act passed after the 2000 Walkerton tragedy as well as the Great Lakes Protection Act and the Greenbelt Act. It is essentially a way of selling relief from appropriate and necessary environmental safeguards in exchange for jobs being allegedly produced. Of course as with most legislation passed by our corrupt and partisan lawmakers it will have little to no followup or accountability afterwards to determine if the jobs promised actually were permanent or produced at all. Welcome to Doug Ford's version of Conservatism.

There have been a number of articles published in the last couple of days in the Waterloo Region Record. They include "Proposed bill allows cities to bypass environmental laws", "Victims, advocates fear for Bill 66" and an Opinion piece by Geoffrey Stevens titled "Ford's hypocrisy on the Greenbelt". This legislation has been introduced with zero public consultation and witj exactly zero public request for it. It is all about Doug Ford playing politics and solidifying his base support and doing the really dirty work early in his mandate. We will all suffer in the long run but politics is rarely about the long run. And unfortunately citizens memories are terribly short. Walkerton you say. What about Walkerton? What happened there?

THE HEALTH & SAFETY TRAGEDY OF CORPORATE & GOVERNMENT INDIFFERENCE

I believe it is the third in the series about rubber workers that is in today's Waterloo Region Record. To say that the series by Record reporter Greg Mercer is an expose of our corrupt Workers Safety & Insurance Board (WSIB) is an understatement. To say that it is an indictment of former Conservative Cabinet Minister Liz Witmer is an understatement. When Liz Witmer was allegedly representing Waterloo Region and area in the legislature she did less than nothing to help us here in Elmira during and after the Elmira Water Crisis which is still going on. The only reason it's no longer considered a "crisis" is due to slick crisis management and public relations efforts by Uniroyal and successors as well as by local, regional and provincial governments over the last three decades.

The other elephant in the room among many regarding the coverup and minimizing of health and environmental damage here in Elmira is the health of Uniroyal workers over the decades. Many of the chemical exposures here at the Uniroyal plant are common solvents such as benzene and toluene which rubber workers were exposed to in the Kitchener rubber plants. In fact there would have likely been far more and different airborne chemical exposures here in Elmira than in Kitchener tire plants.

I recall Esther Thur compiling a list of Uniroyal employees who had died prematurely over the decades. That list may be with her records at the Wilfred Laurier University Archives unless it has been expunged. I also recall her telling me incidents of employees, including her husband, at the neighbouring Elmira Furniture Co. later Roxton, becoming sick from fumes leaving Uniroyal and entering their building on Union St. through open windows in the summer months. I also recall during the height of the air fumigations in Elmira between 1998 and 2001, CPAC being advised by Murray Haight that Uniroyal/Crompton employees were leaving windows open at the plant in order for them to get fresh air while they were working. This of course while helping the most immediately exposed inside the factory did little to alleviate the odours and exposures for the rest of Elmira.

All in all the health of employees of this company has never been made public. Based upon the litany of highly toxic compounds that this company has handled and mishandled over the decades including NDMA, Diacetyl, Benzene, Parathion, dioxins, Endrin, Silvex, DDT and so many more it is difficult to believe that Uniroyal now Lanxess employees and their families haven't paid a very high price.

MEDIA SCHIZOPHRENIA

The Woolwich Observer's Steve Kannon wrote an Opinion piece back on May 14, 2011 in which he stated the facts as he knows them regarding past CPACs as well as my dismissal from the most recent one by Todd Cowan, an a..hat extraordinaire who I must say was publicly humilated four years later possibly even slightly more than he deserved, all things considered.

Steve Kannon couldn't quite make up his mind about me and my dismissal as he praised me to the skies while at the very same time throwing in a few unappreciated (by me) cheap shots. Steve stated "...his enthusiasm for the cause leaves him no time for the niceties." Further "He speaks his mind leaving many people uncomfortable. It's a useful role calling a spade a spade as he notes elsewhere in the paper this week." "Furthermore that's not to say that there's no place for some s..t-disturbing, CPAC like Woolwich Council itself, can be too civil, too eager to be agreeable, to quick to defer to experts." "The truth he says should trump other considerations."

Well I certainly appreciate the kudos but somehow the criticisms that I'm too driven or too focused or too hardnosed just don't line up with the other nice and complimentary things that Steve said. Citizens have an absolute right to express their views on public interest matters and as the K-W Record was quoted here not too long ago municipal councils must expect and accept criticism from the public whether it is gentle, diplomatic or blunt and hardnosed. Steve you are trying to suck and blow simultaneously. My behaviour has always been a red herring simply because verbally I do not stand down for professional, credentialed liars, technical experts or QPs (Qualified Persons) who think they have the absolute right to lie to the public on health, safety and environmental matters. They do not.

RAC MEETING NEXT THURSDAY

The December RAC meeting is being held at 3 pm. in Council Chambers next Thursday, December 13, 2018. On the Agenda are 4.1 presentation of work plan for the Supplemental East Side Offsite Groundwater Investigation 4.2 Status Update on the Containment and Treatment System (Presumably both the on and off site CTS) 4.3 Status Update on the Creek Risk Assessment process 4.4 Tag Recommendations to RAC.

The Minutes were received from the September 27/18 RAC meeting and I am very pleased with a couple of inclusions namely the TAG Motion and Reccommendation that was presented to RAC by TAG Chair Tiffany Svensson. The Motion categorically made it clear that the "Gap" and Stroh Drain have as yet not been properly sampled, tested and investigated. The MOE claim that they want the Stroh Drain evaluated as part of the risk assessment process within the Creek investigation. If the MOE had a history of living up to their words I'd be less concerned. Unfortunately they do not have such a history.

The second inclusion on page 3 is the meeting after the formal meeting that Dr. Sebastian Seibel-Achenbach and I had with Ramin, Lou, Dwighte of Lanxess and GHD. TAG Chair Tiffany and others were also present. While the words "Interceptor Trench" did not get included in the Minutes nevertheless the fact that the ad hoc meeting was acknowledged is good and that there will be a followup meeting during the first quarter of 2019.

TAG also had a Motion and Recommendation for RAC regarding the failure to date to get off-site pumping well W9 up and running. Concerns were also expressed in regards to DDT results in discharges to Shirt Factory Creek that are Non-Detect but at a Method Detection Limit higher than the Provincial Water Quality Objectives (PWQO).

TAG requested clarification on two new monitoring wells at College St. in Elmira and whether they had implications for either the Conceptual Site Model of the Elmira Aquifers as well as for peculiar chlorobenzene concentrations off-site. Ramin Ansari of Lanxess advised that they had had discussions with the property owner(s) of the former Varnicolor Chemical site. Co-sampling was done although they still need to evaluate the data. This is strange as this sampling is now many months old. Also Ramin indicated that an isotope analysis of the water took place in order to determine if there is a second source other than Uniroyal Chemical as well as the age of the source. Very interesting!

TAG and the few public present were advised that Lanxess had hired Stantec, ERM and Geosyntec to assist GHD with the Risk Assessment planned for the Canagagigue Creek.

Lastly The Tag Chair (Tiffany) appreciates that TAG will be allowed to have technical experts attend TAG meetings in order to move forward more effectively. I presume that she is referring to technical experts that the company (Lanxess) have hired as earlier stated unless she is suggesting that TAG may hire their own.

2017 ANNUAL MONITORING REPORT

Quite a while back I posted here in regards to the MOE's (MECP) comments & criticisms of this annual report done by CRA/GHD on behalf of Chemtura/Lanxess. The MOE's comments were described as the most critical, comprehensive and blunt in many years which I both agree with and enjoyed immensely. I think that I even had some good words to say on behalf of the MOE hydrogeologist, Abdul Qyuum (sp.?) who wrote the MOE comments.

Last Thursday November 29/18, GHD responded to the MOE's comments. I was actually sent their responses in a very timely manner for a pleasant change. At some point I expect that the artificial exclusion and stifling of stakeholders both by private meetings and late or never correspondence, other than friends of Chemtura/Lanxess and mayor Sandy Shantz (ie. TAG), may actually bite the guilty parties including the MOE right in the as you will.

The MOE state that the Environmental Compliance Approval (ECA) which replaced the former Certificates of Approval (C of A) absolutely insists upon continuous water level monitoring of both selected shallow aquifer monitoring wells as well as of the surface water of the Canagagigue Creek. The purpose is to always be able to prove or disprove whether or not the contaminated groundwater is hydraulically contained (via lower water elevations) and not discharging into the Creek. GHD agree with that however admit that four of the six surface water elevation stations do not have continuous monitoring data. Wow, that is bad and a blatant contravention.

The MOE specifically point out an area of the Upper Aquifer Containment & Treatment System (UACTS) that at the minimum sufferred a temporary loss of containment, hence discharged contaminated groundwater into the Creek. GHD to their credit seem not to be denying the obvious nor minimizing the seriousness of the situation to the extreme ends that their predecessors CRA did.

The MOE suggested that hydraulic containment of the Municipal Upper Aquifer (MU) on Lanxess's west side was in doubt due to consistent concentrations of NDMA just off Lanxess's western border with Nutrite (Yara). GHD responded that they disagreed and that the source of the dissolved chlorobenzene was not migrating groundwater from Lanxess but is "continuous back diffusion of chlorobenzene and NDMA from fine-grained aquitard soils adjacent to the MU." Hunh that reason actually seems plausible to me.

On page 8 GHD to their credit actually admit that the Municipal Lower Aquifer (ML) is not contained on the Lanxess site. Previous CRA and Uniroyal/Chemtura spokespersons would tie themselves up in knots before they would ever admit that obvious fact. GHD do however suggest that this lack of containment is not critical because allegedly the concentrations of contaminants on site do not exceed the Ontario Drinking Water Standards (ODWS). Of that I am skeptical.

The MOE appropriately are not pleased with GHD using groundwater concentration data from different sampling dates and then using them all together to plot concentration graphs for on-site NDMA. These dtaes include 2017, 2006, 1999 and 1993. I agree that that is bizarre and GHD's responses are weak.

The MOE suggest that the very high concentrations of of NDMA in on-site, east side well OW42-4 need to be investigated. GHD disgarees suggesting again weakly that these high results are isolated in the immediate area. To my mind all the more reason to get the source out of the ground if it is both shallow and isolated.

On page 12 the MOE are again suggesting that there is a lack of hydraulic containment this time on the west and perhaps south border of Lanxess at monitoring wells OW105d and OW16i. GHD denied this and I must admit that their arguments have some merit.

The MOE are again suggesting that there are other sources of chlorobenzene to the off-site drinking water aquifers in Elmira. This is huge and is not being disputed by GHD. They also point out that they have done an isotopic analysis in August 2018 trying to determine if the chlorobenzene is from different sources. To date we the public have not been advised of the results of this analysis.

There is a discussion as to where the highest concentrations of NDMA are located in the MU aquifer. They are 1) beneath the former south-west operating ponds (RPWs) 2) off-site in the north-west (OW60-26) and 3) south of Lanxess at pumping well W3R located between Sanyo and the former McKee Harvestor plant.

The MOE still appropriately have free phase DNAPL concerns on the Lanxess site. Now if only they'd do something about those concerns.
GHD's responses are disappointing as they, just like CRA, go through the old chestnut about free phase DNAPL being indicated if the groundwater concentrations of DNAPL chemicals exceed 1% of the compound's aqueous solubility. That is fine if the DNAPL compound is the sole contaminant in the groundwater unlike the dozens to hundreds of different contaminants in Elmira's groundwater. 1% of the EFFECTIVE Solubility of the DNAPL compound should be the benchmark not 1% of the solubility in pure, uncontaminated water.

Overall GHD and the MOE get good marks for paying closer attention to last years (2017) AMR than usual. Nevertheless there are still major issues being talked about rather than actually being physically resolved.

LACK OF MEDIA REPORTING OF THE GLWQA

The 2012 Great Lakes Water Quality Agreement (GLWQA) was signed by Canada and the United States in order to both restore and protect the five shared Great Lakes in North America, namely Superior, Huron, Michigan, Erie and Ontario. This protection and restoration includes shorelines, wetlands and groundwater entering the Great Lakes. Friend and colleague Dr. Henry Regier sent me an e-mail package today which includes the 2019 Progress Report of the Parties. The Great Lakes Executive Committee (GLEC) are meeting today and tomorrow in Toronto for discussions on these matters.

Both Canada and the United States have designated Areas of Concern (AOC). In Canada we have been able to delist (ie. fully remediate) three of them namely Collingwood Harbour (1994), Severn Sound (2003) and Wheatley Harbour (2010). There are fourteen more AOCs in Canada with Ontario obviously hosting them. One includes the St. Lawrence River at Cornwall which is extremely close to the province of Quebec.

So clearly the GLWQA should be of concern to all Canadians but especially to Ontarians. Where are the updates in our media whether newspapers, television or radio? Why are we not kept abreast of all developments whether good or bad regarding the cleanup and remediation of these sites around the Great Lakes? Why so far is this Toronto meeting of the GLEC not front and centre in the news cycle?

SOME GOOD NEWS O.K. WITH A DASH OF REALITY AS WELL

I am starting to get the impression that the MOE are doing some pushing of Lanxess and their good buddies GHD. The other good news is that citizens, with an enormous amount of time and effort, can affect the direction of investigations, and eventual cleanup. This is despite our local council being in bed with the polluter even to the extreme of picking and choosing public consultation members based upon the polluter (Chemtura/Lanxess) having the hammer (veto).

I received last Friday a copy of a November 6, 2018 response to the MOE (MECP) from GHD, Lanxess's consultants. GHD are proposing to install from four to eight wells depending upon finding the Municipal Upper Aquifer along the laneway that enters the Stroh farm up on Highway #86 (Elmira to Guelph highway). If they can't find the MU Aquifer then it will be only four shallow wells. They are doing this because of the MOE's insistence on a better groundwater investigation of the Stroh property just to the east of the Uniroyal/Lanxess property. Keep in mind that all of the investigations since 2015 on the east side of Chemtura/Lanxess are a direct result of the 2011-2015 CPAC and SWAT which includes yours truly. We opened the can of worms that the MOE, Uniroyal and CRA had kept carefully hidden for three decades or more.

Now for the dash of reality known as the elephant in the room. The "Gap" has NOT been delineated, examined or investigated even remotely properly and by intention. Similarly neither has the Stroh Drain. This secret, man made Drain has effectively drained both surface and groundwater from both the Stroh and Uniroyal properties for decades. Much of that drainage would have been contaminated with persistent organic pollutants (POPs) either attached to soil particles and or dissolved in solvent contaminated groundwater. The fact that solvents and NDMA have been found still at high concentrations on the east side property is both sobering and scary. How much of the Persistent Organic Pollutants such as dioxins, DDT and PCBs are still in and around the Stroh Drain we do not know until a serious search is undertaken.

CORPORATE HUMANITY - AN OXYMORON

YOU ARE JUDGED BY THE COMPANY YOU KEEP SANDY. THIS MEANS UNIROYAL/CROMPTON/CHEMTURA & NOW LANXESS (BAYER/MONSANTO)


What a litany of corporate monsters. Recently we have had the Waterloo Region Record article written by Greg Mercer and titled "Rubber Town". Today the Record published "A long fight for compensation" also by Mr. Mercer. Much of the heat is focused upon our corrupt provincial governments removing the right to sue from employees and installing an equally corrupt Workman's Compensation Board, now optimistically named the Workplace Safety and Insurance Board (WSIB). Today's article makes it clear that the WSIB takes its direction from both the provincial government and employers and has reduced employers' WSIB premiums drastically by reducing payouts to injured workers.

Bayer and Monsanto are currently in the news due to class action lawsuits and decisions that a Monsanto herbicide, Glyphosate, has caused cancer in human beings. Of course we all know about Uniroyal Chemical and the 1989 Elmira Water Crisis. Oh and of course Uniroyal, Dow, Hercules, and others are all implicated in the production of Agent Orange and its accompanying by-product dioxin. This dioxin (2,3,7,8 TCDD) has damaged and killed human beings in Vietnam and even here in Ontario due to its work as a brush remover along highways and power lines.

Getting back to local rubber producers the two most mentioned are B.F. Goodrich and again Uniroyal Chemical. There are still living persons whether union men or management or even company consultants who know first hand how bad the fumes were inside the local tire plants. The Waterloo Public Interest Research Group (WPIRG) produced a booklet regarding solvent fumes and poisonings and distributed it to rubber workers including Uniroyal employees. After I blew the whistle on Varnicolor Chemical here in Elmira, I was given a copy of the WPIRG booklet detailing the various solvents and their health effects.

Once again having health and safety laws that are either not enforced or easily stick handled around has elevated shareholders' profits on the backs of employees health and lives.

GO AHEAD SANDY, KEEP ON SUPPORTING UNIROYAL/Chemtura/Lanxess. That speaks volumes to the informed and intelligent people in Woolwich Township and further afield.