JUNK SCIENCE: ISN'T IT WONDERFUL FOR POLLUTERS?

The first obvious question is why isn't the Ontario Ministry of Environment, Conservation and Parks (MECP) taking Lanxess and GHD to task for their junk science? Maybe I'm mistaken and MECP actually stands for Ministry of Enhanced Corporate Pollution. You the readers feel free to interpret the following data in Lanxess's just released "2017 Canagagigue Creek Sediment and Floodplain Soil Investigation".


MOE Table 8 criteria.(ppm.)../...ISQG (interim sed quality guide)(ppm.)


DDD ....... .008 .............../...... .00354

DDE ...... .005 .............../...... .00142

DDT ...... .007 .............../...... .00119



Five different locations in the creek have the following numbers of samples with non detect values rather than a specific numerical value for DDD, DDE, and DDT. These non detects are all at detection limits many times greater than both the criteria listed immediately above.

Figure 6.2 102 non detects at a detection limit of .020 ppm. This detection limit is 2 1/2 to 6 times greater than the two relevant criteria for DDD. The detection limit is 4 to 16 times greater than the two relevant criteria for DDE. The detection limit is nearly 3 to 18 times greater than the two relevant criteria for DDT. Therefore large numbers of exceedances are most probably being missed with these method detection limits being so much higher than the criteria set for these toxic chemicals found in the Canagagigue Creek.

Figure 6.2 102 as mentioned immediately above.

Figure 6.4 231 non detects at a detection limit of .020 ppm.

Figure 6.6 155 non detects at a detection limit of .020 ppm.

Figure 6.8 194 non detects at a detection limit of .020 ppm.

Figure 6.10 95 non detects at a detection limit of .020 ppm.


There are other non detects at even higher method detection limits for these three chemicals (DDD, DDE, DDT). These higher detection limits vary from .030 ppm to .22 ppm and include many at .030, .040, and .060 ppm. There is 1 at each of the following detection limits: .072, .10, .12, and .22 ppm. The total number of non detects at these ridiculously higher detection limits is 46.

It is my submission that there are vastly greater numbers of non detections in the creek than there are detections (approx. 800 non detects versus 200 detections. This gives the incorrect and inaccurate impression that the Canagagigue Creek is in far better condition than it actually is.

2017 CANAGAGIGUE CREEK SEDIMENT & FLOODPLAIN INVESTIGATION

The final draft of this report came out last week. I received part of the hard copy of it yesterday as reported here yesterday. The title is poorly named because of the very few floodplain soil samples taken. There were numerous soil samples taken but they were creekbank soils (i.e. above the normal water level of the creek). Following are a list of the dates here in the Advocate that I posted about the draft copy of this report one year ago. The dates are March 24 & 28, 2018 as well as April 5, 6, 9, 10, 11, 14, 15, 16, 2018. Most of these posts are very critical of the draft report due to its user unfriendliness and fatal errors such as locational biases as well as method detection limits (MDL) that far exceeded the environmental criteria for DDD, DDE and DDT. I believe that the stated exceedances of criteria were minimized for the DDT compounds and break down products by these far too high MDLs.

To be more specific the standard MDLs seem to be 20 parts per billion (ppb) which is the same as .020 parts per million (ppm). This means that any concentrations below this 20 ppb value will be designated as ND (.020) which means Non-Detect at a detection limit of 20 ppb. The criteria for DDD, DDE and DDT in sediments is 8, 5, and 7 ppb. Therefore exceedances are only noted for DDD when the concentrations are actually 2 1/2 times higher or more than the criteria of 8. Exceedances for DDE are only acknowledged when they are four times or more higher than the criteria of 5 ppb. Exceedances for total DDT are only acknowledged when they are almost triple the criteria (7) or higher. Therefore these unreasonably high MDLs serve to downplay and minimize the extent of DDT & metabolytes contamination in the sediments of the Canagagigue Creek.

It gets worse of course. I stated that the normal or standard MDL for DDT compounds was 20 ppb. In fact there are numerous instances when the MDL is at 30, 40 or 60 parts per billion.Incredibly there are even a few instances of MDLs for these contaminants at 100, 110 and 140 ppb. Of course the figures and maps have the highest DDD, DDE and DDT exceedances coloured for quick and easy reference. Oddly they don't have any of the high or extremely high MDLs coloured for easy reference. Based upon the number of Non Detects at detection limits (MDL) far in excess of the criteria it is my opinion that this report is intentionally deceptive and misleading and greatly understates the extent of toxic contamination in the Creek.

THANK YOU WOOLWICH TOWNSHIP - GOOD NEWS/BAD NEWS

First of all I received hard copies, as promised, this morning of the Final Creek Investigation Report and of the Conceptual Site Model (CSM) at the Township offices. That is the good news. This included two reports plus a USB stick in the back of one of them. The bad news is that there are supposed to be approximately 3,000 pages in grand total and I'm sure the two hard copy reports might cover, including maps and tables, maybe three to five hundred pages at best. Wow! Therefore between the USB stick and the Zip files I received earlier by e-mail I guess there's still a couple of thousand pages plus that I'm supposed to read on my computer. My nearly seventy year old eyes might be able to handle thousands of pages of hard copy but one I like to put maps and figures side by side to compare information and two, staring at a computer screen, unpaid for hours or days at a time isn't happening.

Oh there's more bad news. The discussion about these two reports is this Monday April 1/19 at the 5 pm. TAG meeting in council chambers. Perhaps there's some significance to that date (April Fool's). The other bad news is that how many exactly of the people present do you think will read these entire 3,000 pages whether hard copy or on their computer? The last bad news of course is that if one is not a friend of the alleged mayor and hence appointed to TAG then you don't get to either make comments or ask questions even if you've read the whole damn thing. There are other issues as well but these are adequate to mention at the moment.

GREATER SPECIFICITY ABOUT "LOCATIONAL BIAS"

I have likely indicated that the majority of soil and sediment sampling took place at or very near the New Jerusalem Rd. bridge over the Canagagigue Creek as well as just upriver towards Lanxess Canada and lastly much further downstream at the Northfield Dr. bridge over the Creek. The obvious common feature is very easy road access to these locations whether public roads or even some private farm lanes between Lanxess and the New Jerusalem Rd. This private access would likely be the Martin farm and it's private bridge across the Creek as well as easy access along the river.

GHD have broken the entire length of the Canagagigue (Gig) into four reaches. Starting at the mouth of the Gig as it enters the Grand River just south of West Montrose up to Northfield Dr. is referred to as Reach One. From there to a few hundred metres east of New Jerusalem Rd. is Reach Two and Reach Three is from there to a couple of hundred metres south and east of the Lanxess site in Elmira. Lastly Reach Four goes from there through the Lanxess site and ends at Church St. (Hwy # 86) in Elmira. The majority of soil and sediment sampling is therefore in Reach Three and Four. Also the majority of actual creek length is in Reach One and TWO.

All of this locational bias might be acceptable if the assumption being used is that Reach One and Two are equally as contaminated in soils and sediments as is Reach Three and Four. However my expectation is that instead the assumption will be is that right at Northfield Dr. (Reach One to the east and Reach Two to the west) requires some remediation as does Reach Three at the New Jerusalem Rd. as well as just to the west of New Jerusalem Rd. Therefore cleanup is most likely to occur at the criteria exceedances while avoiding the areas that were not sampled. This would be a typical CRA/GHD "cleanup" based upon the last thirty years of "cleanups" around the site in my opinion.

IMPRESSIVE TAG MINUTES

O.K. let's get a couple of things clear first. RAC and TAG were manufactured by a couple of incompetent and spineless Woolwich councillors under pressure from both Chemtura Canada and the Ontario MOE. One of their own colleagues referred to RAC and TAG as "cringeworthy". This was due to the lack of public input made available into both the RAC and TAG process as well as due to the preponderance of professionals and others on RAC and TAG including the chair of TAG. In a nutshell there were far too many bureaucrats and politicians deeply involved and far too few of the general but very interested public permitted to even ask questions or make comments. It was and is "cringeworthy."

Despite that and despite TAG having two members with serious conflicts of interest both pecuniary and otherwise, TAG members are learning, stepping up and showing backbone. Being one of the knowledgeable citizens intentionally shat upon by the mayor and her sidekick at the time I do not lightly heap praise upon a "cringeworthy" organization. The trouble is that they deserve praise and that was easy for me when Dr. Jackson was chair as he took no prisoners in his attempt to drag Chemtura and the MOE into the 21st century in regards to proper hazardous waste site investigation and remediation. I admit it took me longer to appreciate the second chair's style and methodology but Tiffany Svensson continues to impress. The Minutes are out from the last TAG meeting on February 28/19 and both the TAG chair and members are showing increasing confidence in criticizing Lanxess and GHD efforts and non-efforts. In hindsight I can see how much stronger my criticism became the longer I was involved with UPAC & CPAC and hence the more I learned both technically and unfortunately politically. With increasing knowledge and understanding of the issues there should be a much lower tolerance of junk science, puffery,and other forms of corporate and bureaucratic horse manure.

The Minutes indicate that TAG categorically rejected GHD's attempt to pass off old, generally irrelevant sampling data as evidence that there overland flow of waste waters had not crossed their property line and discharged into the Stroh Drain and area further east prior to the Stroh Drain. TAG also blasted GHD and Lanxess over their composite sampling which was supposed to be no more than an initial screening step. Instead Lanxess and GHD want to end soil sampling on their own property after taking inadequate soil samples (composite as well as in the wrong location) and they do not want to test soils and sediments in and around the Stroh Drain. As usual Uniroyal/Lanxess continue to hide behind their partners in pollution, the Ontario MOE.

Lindane should be one of a number of Contaminants of Concern (COC) however GHD have screened them and many others out of the creek investigation and upcoming Risk Assessments. Afterall that's what your well paid, client driven consultants are supposed to do for their favourite polluter.

Pat McLean continues to shill for the polluter as they require a citizens advisory panel (CAP) to look at their current environmental operations and effects. Hence Ms. McLean is asking TAG to expand their mandate to include current operations and not just historical waste disposal and remediation. Generally the polluter get what they want so I expect the mayor will bow once again to corporate, polluter pressure.

TIDBITS OF DATA FROM THE CANAGAGIGUE CREEK REPORT

ppm=parts per million ppt=parts per trillion

New Jerusalem Rd. area had the following results for DDT and metabolites in soil. The Table 8 standard for 2,4 + 4,4 DDD is .05 ppm and the maximum concentration found was 72.7 ppm. The Table 8 standard for 2,4 + 4,4 DDE is also .05 ppm and the maximum concentration found was 3.974 ppm. The Table 8 standard for 2,4 + 4,4 DDT is .078 and the maximum concentration found was 399.3 ppm.

For dioxins and furans found in soil samples in the New Jerusalem Rd. area of the creek the Table 8 standard is 7 ppt and the maximum concentration found was 242 ppt. These maximum exceedances are anywhere from eighty to a few thousand times higher than the MOE Table 8 standards for these toxins found in soils in and around the Canagagigue Creek.

The same geographical area has higher exceedances for dioxins and furans found in the creek sediments (i.e. the bottom of the creek).The Interim Sediment Quality Guideline (ISQG) is .85 ppt and the Probable Effect Level (PEL) is 21 ppt. The maximum concentration found was 1,090 ppt.

Further downstream in the creek at what Lanxess call Reach Three soil samples had 2,4 + 4,4 DDT at a Table 8 standard of .078 ppm had a maximum concentration of 38.52 ppm or approximately 500 times higher than the standard.

At this same location dioxins and furans in sediment samples at a Table 8 standard of .85 ppm had a maximum concentration of 134 ppm which is approximately 150 times higher than the standard.

These figures are just a small sampling of the big picture. The creek is an environmental disaster based upon all the criteria and standards in existence yet through mathematical manipulations and contortions combined with locational sampling biases and just plain weasel wording, self-serving assumptions and so much more we will all eventually be advised that oh we've found two or three hot spots that will take some remediation but then all will be well in the creek. If only it were so.

MORE ON THE FEBRUARY 2019 LANXESS PROGRESS REPORT

We covered the off-site aquifer pumping last Monday.

Table A.2 advises us that the two highest inputs into the combined on and offsite treatment system for the municipal aquifers is toluene at 6,500 parts per billion and carboxin at 850 parts per billion (ppb). Toluene is an LNAPL (light non-aqueous phase liquid) and carboxin is a DNAPL (dense non-aqueous phase liquid) chemical.

Table A.4 gives us concentrations of various chemicals going into the on-site Upper Aquifer Containment & Treatment System (UACTS). There are some more than idiotic method detection limits of both 50,000 and 100,000 ppb. for Methyl Ethyl Ketone and for Acetone respectively. Otherwise the highest concentration chemicals are toluene, chlorobenzene, mercaptobenzothiazole, carboxin and aniline. These various LNAPLs and DNAPLs assure us that the Lanxess site will continue to be a toxic waste site for decades to centuries unless physically removed, chemically broken down or some other serious and legitimate form of source removal.

The MISA outlets to the creek continue with their relatively light discharges of lindane, carboxin and NDPA.

Table C.2 continues with its bizarre data results particularly the arithmetic means for various chemical contaminants. Ten different acid extractables (phenols & chlorophenols) allegedly have higher concentrations upstream of Lanxess than downstream. Is this discharges from the former Bolender Landfill just north (upstream) of Lanxess making their way into the creek? We then have three base/nuetral extractables with the more likely scenario of having higher concentrations at the downstream end of Lanxess than the upstream. These include MBT, BT, NDMA. Oddly we still have four of this group of chemicals with higher concentrations (arithmetic means) at the upstream end namely aniline, carboxin, NMOR and BEHP. Frankly this makes no sense to me at all. Has the uncontained Bolender Landfill for some strange reason decided to leak more now than years ago?

Frankly based upon ongoing incompetence my suspicion is that either CRA or GHD or both simply have mucked up their data, yet again. This needs serious examination but don't hold your breathe.

This folks is but an example of the professionalism, care and honesty with which this entire cleanup has been conducted over the last thirty years.

FINAL CANAGAGIGUE CREEK SEDIMENT AND FLOODPLAIN SOIL INVESTIGATION REPORT (March 18, 2019)

This report and various drafts have been underway for at least the the last three years. Strong criticisms have come from the MECP (MOE), TAG, CPAC and myself as a CPAC member. This latest iteration consists of more than 2,500 pages. Unless one is paid to stay on top of an issue, dragging it out over a period of years and literally many thousands of pages of technical reports pretty much guarantees that citizens' ability to stay with it in detail is greatly compromised. That is probably done intentionally.

I just received an e-mail this morning with the data although thankfully I have been promised a hard copy of the package. That is worthy of a kudo to Lanxess and others. Obviously I have not read this report yet although a quick glance certainly indicates that the data is from the 2017 sampling done in and around the creek. Going only from memory at this point in time here are some of the issues with this report.

Allegedly the routine dumping on land and water of Uniroyal's dioxins/furans/DDT, lindane, parathion, endosulphan, solvents and oh so much more ended in approximately 1970. Yes groundwater leakage continued for decades more. Flooding of the creek also scoured and redeposited these contaminants downstream. We are less than a year away from half a century since they stopped more or less direct discharges to the creek. Does anybody not think that the bulk of their filth has already gone downstream to the Grand River and to Lake Erie? Seriously? Fifty years to seriously address cleaning up the Canagagigue Creek??? My suggestion is to throw all the surviving Responsible Parties (RPs) and Qualified Persons (QPs) advising them, into jail. That might do far more to avoid future damage than attempting cleanups half a century later. Shame on the province of Ontario, MOE, Uniroyal, Crompton, and Chemtura at a minimum.

The list of Contaminants of Concern (COC) is ridiculously short. The criteria were made by Chemtura/Lanxess and they stink.

There is a locational bias in all the sampling along the creek. The objectives and mandate was to learn where these contaminants are located. Exactly how is that possible when the sampling has only taken place at the easy access locations by the New Jerusalem Rd., Northfield Dr. and Jigs Hollow Rd. beside West Montrose?

Much further study is required to sift through this report. This report will then be the basis for a Site Specific Risk Assessment (SSRA) done for both Human Health and Ecological (wildlife) purposes. Dr. Henry Regier was intimately involved with the last SSRA done in the early 2000s for the Uniroyal site. He referred to is as greenwashing for scoundrels. Why would this next SSRA be any better?

MAYBE IT'S JUST AN OVERSIGHT - 152 SHANLEY St. KITCHENER

Today's Waterloo Region Record carries the following article titled, "Owner's plans for Electrohome site "very close"." And no the law is not an oversight. It is riddled with favours towards developers, the real estate industry, and manufacturers, all to the detriment of neighbouring residents who only want a healthy, attractive neighbourhood to raise their families and to live in.

Electrohome originally owned the property and building and when their furniture business departed they either sold or gave away their contaminated site. Contaminated by them in order to reduce their costs of production which should have included proper waste disposal but apparently did not. Even in the 1960s there were environmental laws against improper disposal of toxic chemicals, paints and solvents. That those laws were not enforced by our provincial government seems obvious. That they were not enforced in a residential neighbourhood is just plain ridiculous as was the zoning and land use policies of the City of Kitchener back then which would permit housing immediately beside a manufacturing facility.

It gets worse. Municipal by-law standards are a joke. The City have been shoveling the sidewalks and cutting the grass for decades. The property taxes have been unpaid for decades until the owner, Andrew Spylo, paid 37 cents on the dollar recently to retain ownership. Apparently corporate taxes are also in arrears and the province had had a lien on the property since 2002. But Andrew Spylo still owns the property and presumably will pocket any profits from the alleged imminent sale of it. This folks is what comes of having money talk. This is the direct result of developers, manufacturers, and business people making donations to individual politicians and or their parties. That money adversely affects legislation whether municipal by-laws or provincial or federal laws.

Lastly are the likely unknown health effects on the neighbourhood. Are local adults or children getting sick at greater rates than the rest of the city? Are there any cancer clusters in the area? Are there neurological problems from simple insomnia to much worse in the neighbourhood? Is any government body at any level either asking these questions or better yet trying to get answers for them? If not then we are living in a third world country. Hopefully there aren't any municipal wells within a mile or two of that site. Hopefully the trichloroethylene (TCE) is at very low concentrations in the soil and groundwater because it is an absolutely horrible chemical in the natural environment. Just ask the Bishop St. community in Cambridge, Ontario. Generations there have suffered and died from the effects of the TCE released into the ground by Northstar Aerospace and Rozell (G.E.). Our governments are very good at looking out for the interests of the monied classes in our society. The rest of us, not so much.

OTHER SOURCES - SEE 2018 ANNUAL MONITORING REPORT (AMR)

Plume maps can indicate where the source areas are. Of course with aquifers being stacked on top of each other sometimes with low permeability aquitards in between, these indications of source areas can get a little tricky. In other words sometimes contaminants from surface discharges can go straight downward into both the Municipal Upper Aquifer (MU) and the Municipal Lower Aquifer (ML). Other times the contaminants go down to the MU, travel horizontally and then find a "window" where the aquitard is thin or non-existent between the aquifers. Through the window the contaminants go into the deeper aquifer albeit not directly below the contaminants in the higher elevation aquifer (MU). They are off-set.

Check out Figures 4.4 to 4.9 in the recently released 2018 AMR. Those are plume maps for NDMA and chlorobenzene in both the MU and the ML at the start of off-site pumping in 1998 and then again twenty years later. After decades of pumping the source areas tend to stand out better than when the aquifers have had decades of movement and contaminant migration. I think you will see other potential source areas than just Uniroyal Chemical and Nutrite (ammonia). I'm seeing potential source areas near Varnicolor Chemical, Borg Textiles, Sanyo Canada and maybe even McKee Harvestor. All this could have been investigated easily decades ago but hasn't been. It's almost as if our authorities (MOE, RMOW, Woolwich Twp.) and polluters don't want it investigated.

"CHEMTURA FINED $150,000"

The above title is quoted from the May 15, 2012 Woolwich Observer. The $150,000 fine is but one of many that Uniroyal, Crompton and Chemtura have ben forced to pay over the decades. In my opinion they have viewed those fines not as shameful but as simply the cost of doing business. This particular fine was for the release of BLE-25 from a pressure vessel that sent its contents up a stack and into the air after the rupture disk in the pressure vessel let go. This rupture disk is an intentional fail safe somewhat akin to a shear pin on an outboard boat motor. Its breakage is far better than the alternative which is a far larger, more costly breakage or explosion in the case of a pressure vessel. Allegedly there were no health issues but certainly inhaling a mixture of acetone and diphenylamine isn't good for anyone. On the positive side Chemtura did spend a lot of time and money and to the best of my knowledge did do a good job cleaning cars, houses and outdoor equipment all around Elmira afterwards.

OFF-SITE PUMPING STILL INADEQUATE - EVEN WORSE IN FEBRUARY

Five reasonably good months in a row. From September 2018 until January 2019 the total off-site pumping in the Municipal Aquifers was between 62 and 65 litres per second. Historically those values are excellent. Unfortunately they aren't even close to what we were told by CRA and Chemtura in November 2012 was necessary to achieve drinking water standards throughout the aquifers by 2028. We were first advised that a tripling of the then approximately 53 litres per second was required and then they later suggested a mere doubling would do the job. We've never even come close.

Last August 2018 was a stinker for a myriad of reasons. Last month (February 2019) was as well. Lanxess have succeeded in disappointing so often that I can't even be bothered reading their never ending list of excuses. This is plugged, that is broken, this requires maintainence, yada, yada, yada. The total off-site pumping rates in the municipal aquifers last month totalled 47.5 litres per second. Just like last August those pumping rates aren't even as good as they were seven years ago when they said that they needed to TRIPLE their pumping rates. Hot air, bull manure and local political protection is what the Elmira cleanup has always been about.

MILL CREEK (CAMBRIDGE) FUTURE UNCERTAIN

One spill. That may be all it takes to finish off one of the last cold water creeks in southern Ontario. Today's Record carries the following article titled "Fuel spill pushes Mill Creek "to the edge," residents worry." Mill Creek winds through Puslinch Township and Cambridge before joining the Grand River. Ministry of Environment (MOE) officials are confident that things are under control and that there are no exceedances of toxic chemicals in the creek. However those same idjits were confident for twenty-five years that they could restore Elmira's drinking water aquifers to Ontario Drinking Water Standards (ODWS) criteria by 2028. Over the last few years both they and the corporate polluter have admitted that things don't look good for that 2028 cleanup date. By the way calling the MOE "idjits" is rude however it's less rude than calling them liars.

One local resident of the area has stated that "The cleanup work is window dressing." The MOE suggest that residents drinking water is safe and that there have been no reports of ill or dead wildlife locally. Personally I suggest the MOE install a hot line telephone out in the woods and conduct training courses on how to use it for local wildlife. That would probably be nearly as effective as much of the "work" that they do. Especially the "work" focused on licenses, safety permits, Environmental Compliance Agreements, Control Orders, Certificates of Approval and the like.

As recently as a week ago residents reported that they could still see an oily sheen on the water as well as smell the fuel in the creek. That is from the initial spill back on January 13 of this year.

A GOOD DECISION MADE

This past Monday I posted here and it was titled "Discrimination Must End, Favoritism Not So Much". It was about an invitation to TAG members to attend a site visit of a specific area of the Lanxess site referred to as the "Gap". The "Gap" is aptly named as it is an area that GHD and Lanxess appear to have been avoiding doing soil sampling of for the last four years. This is probably because of the likelihood that this low lying area is the pathway for overland flow of hundreds of thousands if not millions of gallons of toxic wastewater from the company's overflowing east side toxic waste pits.

Vivienne Delaney and Michael Heitmann also asked to attend that site visit as they have attended some (Vivienne all but one) of the RAC and TAG meetings since they started in September 2015. They were denied. I had already been invited for a site visit albeit the invitation was for the following day. As politically incorrect and totally racist kids likely learned from society around us (the second world war barely over), we had a common comeback when we felt we were being treated badly. It was "Am I black?" Well that thought came to me when I was informed that I was invited for the following day rather than along with the TAG members. Then when I learned that Michael and Vivienne had been totally denied permission to attend a site visit of the "Gap" area that may shed light on the topography and ground contours that are somewhat in dispute, that was it. I politely advised that my first choice was to attend the site visit along with Michael, Vivienne and the TAG members and my second choice was to attend the site tour the following day with Michael and Vivienne. Otherwise no thanks.

Lanxess personnel advised that they needed to consult with others presumably TAG and possibly Woolwich (Sandy?)and maybe even the MOE(?). Well I'm not remotely suggesting that my opinions of Woolwich politicians (most not all) or the MOE have softened. They have not. Ditto with my attitudes based upon thirty years of experience with Uniroyal/Crompton and Chemtura personnel. Lanxess have only been in charge for a couple of years. There's lots that they have not improved upon or changed in the public interest. They have however made a very good decision regarding backing off on the discrimination against honest, experienced and informed citizens that our mayor with support from Chemtura and the MOE instigated four years ago. Kudos to Lanxess and Ramin for their decision to invite Michael, Vivienne and I to join the site tour this coming April 1/19.

LOOKING FOR THE ELECTION FINANCIAL STATEMENTS

Well four years ago half of Woolwich Council publicly demonstrated their incompetence and their willingness to draw outside the lines. In Mark Bauman's case it turned out to be more laziness than anything sneaky or dishonest. I can't say the same for the other two miscreants however. What was also demonstrated was an attitude within some Woolwich Township staff of loyalty towards their council colleagues versus loyalty towards either the public or the laws of the land. That was very disappointing.

Then of course we also saw the absolute travesty of MECAC, the Municipal Election Compliance Audit Committee. What a pitiful bunch of old, has been politicians trying to relive their glory days. What that means is looking out for themselves and their buddies while blatantly ignoring their mandate and the Municipal Election Act (MEA). They were too biased and incompetent to even give either Mark Bauman or Sandy Shantz the boot from office after I blew the whistle on their illegal behaviour in regards to their missing Financial Statements and Audit (Sandy). It took Richard Clausi and I telling the media before the Woolwich Clerk in conjunction with Sandy and Mark, decided that they had to step down. Even then they didn't want to admit that they were obligated by provincial law to step down.

I believe that somewhere around March 21/19 may be the deadline for councillors and losing candidates to post their Financial Statements from last fall's municipal election. Undoubtedly the two new councillors have been warned about the bogeyman ready to pounce on them for the slightest slip. That of course is just typical Woolwich misinformation. All three candidates screwed up big time and between Sandy and Scott Hahn actually had many thousands of dollars of expenses tucked away out of sight until they were caught by Dr. Holt (Scott) and me (Sandy).

So rest assured if your mistake is a simple mathematical mistake of $100 or so I won't be calling upon the biased, conflict of interest club called MECAC to make excuses for you.

THE DISGRACE OF THE THIRD WORLD WATER SYSTEM IN WEST MONTROSE IS OVER AT LAST

You know before the Walkerton E.Coli bacteria crisis that caused seven deaths and the poisonings of a couple of thousand people, the raw water source in West Montrose was bad but not so ridiculously awful as it was after the Ontario Clean Water Act and the O'Connor Commission Report was released. Likely there were other water sources filled with bacteria that at times were problematic but thank god were not run by alcoholic morons and supervised by typical incompetent politicians and bureaucrats.

That said the West Montrose water system plodded on full of bacteria right at the four floodplain wells. How could those wells not be filled with bacteria? Each spring when the Grand River flooded they were submerged. The rest of the time they were recipients of the flow from the upgradient septic systems in West Montrose. The Region knew this full well. All the tankers of water poured into the West Montrose reservoir weren't due to a lack of water in the Grand River. After all that's why there's a dam (Shand Dam/Belwood) upriver in order to maintain the flow in the Grand in the drier summer months.

Yes there was a functioning water treatment system on Tallwood Drive in West Montrose. However,the Walkerton Inquiry and the O'Connor Report was very clear. Drinking water needs to be protected from the source to the taps at the end of the distribution system. The reason for this is the probability of either human or mechanical error anywhere within the water treatment system. West Montrose residents were one error away for decades from disaster. That is now removed due to the pipeline carrying water from the Region's Integrated Urban System (IUS) over to Conestoga and then along to West Montrose.

At least likely bacteriological disaster is removed. Unknown or untested industrial chemicals are something altogether different. Also what health conditions have either been caused or exacerbated by decades of source bacteria possibly/probably on occasion getting through the treatment system?

WSIB - WORKERS SHAFTED INTENTIONALLY BY BOARD?

The front page article in today's Waterloo Region record is titled, "Mixed messages on WSIB review." Recently a Kitchener widow of a deceased rubber worker was advised by a WSIB employee that not all cases of more than 300 already denied will be reviewed. This of course is in contradiction to what the WSIB said just last week that WSIAT (Workplace Safety and Insurance Appeals Tribunal) cases that had been turned down would be included in the overall review by the WSIB. The widow, Gayle Wannan, is skeptical that the WSIB is genuinely interested in applying the latest evidence when taking another look at rubber workers' claims. Personally I'm skeptical that "new" evidence is needed or whether it even exists. There has been overwhelming evidence of cancer clusters in the rubber industry for decades and longer. This has always been all about protecting employers from lawsuits and reducing the liability of governments to pay disability pensions and death benefits caused by occupational diseases.

The WSIAT rarely grants reconsiderations for the simple reason they don't have to. Again I believe their mandate is more financial than either humanitarian or honestly insurance based. Citizens are allowed to ask Ontario's Superior Court of Justice for a judicial review of a WSIAT decision. That is incredibly slow and incredibly expensive. After all judges and lawyers need to maintain their lifestyle while pretending to have empathy for factory workers in the local rubber plants. Yes Dorothy, class differences are alive and well in Canada.

I expect that perhaps half of the affected workers and their families will eventually receive some compensation for the premature deaths and illnesses of their loved ones. This will have exactly nothing to do with the so called "evidence" and everything to do with past Liberal and Conservative governments saving face. The provincial government controls the WSIB and WSIAT and party affiliations between Ontario's two governing parties make little difference in the ongoing exploitation of citizens by those with power and money.

DISCRIMINATION MUST END, FAVOURTISM NOT SO MUCH?

Vivienne Delaney is and has been a member of CPAC since 2011. Then it was called the Chemtura Public Advisory Committee and since late 2015 has been called the Citizens Public Advisory Committee. Michael Heitmann is a Videographer and Documentary Filmaker. He has spent at least five years working on a Documentary about Elmira and Uniroyal Chemical. His Documentary included extensive interviews and quotes with the company's Remediation Manager. If Lanxess wished to host a social get together or party they would of course invite their friends and colleagues. It's called favourtism and we all do it. We invite our friends and like minded people to social get togethers.

Woolwich Township invite applications for various committees of council. Generally unpaid work i.e. volunteer committees are not swamped with volunteers and particularly with volunteers with particular and specific skill sets relevant to the positions. Sometimes municipal councils are lucky and have very experienced individuals with skill sets directly related to the particular volunteer committee. Smart councils then thank their lucky stars and appoint those volunteers before they change their minds. Stupid councils do not appoint such individuals. Stupid councils look for reasons not to appoint them, particularly if the committee is supposed to be a committee of volunteer citizens overseeing a cleanup of the community after a local company has destroyed the air, the groundwater and the nearby surface water. The past Woolwich Council was one of those stupid councils. That council felt that the company deserved sympathy and support from being held accountable by local citizens whom had been appointed by the previous Woolwich Council specifically to clean up the mess. Our 2014 to 2018 council allowed the polluter to decide who would and would not be allowed on the committee. That is called discrimination.

A site tour on the Lanxess property for the TAG committee is not a social gathering. It is all business as it should be. TAG have been invited to examine the area of the Lanxess property known as the GAP. Apparently Lanxess are having a problem actually determining its exact location. Viv Delaney and Mike Heitmann who attend public TAG meetings asked if they could attend the tour as well. They have been denied. They are as invested in getting a proper cleanup as anyone and have been at it longer than most of the TAG members. Vivienne in fact has first hand experience in regards to having seen the GAP area from the Stroh side of the property line and could be helpful just as I could as well, having also seen the GAP from the Stroh side of the property line. Dr. Dan Holt as well although he is currently out of the country. Intentionally avoiding competent people to either solve or assist in solving a problem is called discrimination. Woolwich Township are very experienced at discriminating. In the past so has Uniroyal/Chemtura.

MORE ON THE OBSERVER ARTICLE & ON THE LANXESS EAST SIDE TOUR INVITE

Lanxess reps have misspoken when they claim in a statement to the Observer that "The historical data indicated that this area of the Lanxess property is not impacted." Sorry folks but that is utter B.S. The data they have provided indicates dioxins at 6.97 TEQ (ppt.) in SS-21 and 3.34 TEQ in SS-20. The criteria for soils within 30 metres of a surface water body (Stroh Drain) are 7 TEQ (ppt.) Furthermore SS-20 had two thirds of its composite sampling area on the high ground and was not part of the Gap area. Another soil sample from TP-7 had a TEQ of 15 (ppt.) which while likely more than thirty metres away from the Stroh Drain still exceeds the 13 ppt TEQ criteria for agricultural soils which are what are on the Stoh property.

There is also the entire issue of composite sampling versus discrete individual soil samples. The composite sampling simply spreads out the high readings and averages them with low to zero readings in order to remain below the criteria.

Lanxess claim that they will look at any new information that justifies sampling in the GAP area. New information is not required. Common sense, logic and honesty however are required to seriously investigate the Stroh Drain and immediate area. That has been sadly lacking simply to save the company money and as usual the Ontario MOE (MECP) are doing little or nothing to help the public and the environment.

Regarding the east side tour invite I have responded nicely to Ramin (Lanxess) advising that I'm not comfortable accepting an invitation for a tour while other honest and informed citizens expressing interest in the tour are excluded. The ball is in Ramin Ansari's court and I have thanked him for the invite. I hope that he is O.K. to extend the invitation to Michael Heitmann, documentary filmaker, and to Viv Delaney, CPAC member for the last eight years.

CREDIT TO TAG MEMBERS & CHAIR

The general idea of a municipal council throwing out an entire committee of council, one would think, has but two reasons. Either the new council have zero confidence in either the ability or the credibility of the committee of council or the council know that the committee are both able and credible and that scares the heck out of them. Quick get rid of them and start over with new folks who know little or nothing.

The first action (zero confidence) occurred after the Todd Cowan council was elected in October 2010. The second action (able & credible) occurred with the Sandy Shantz council elected in October 2014.

The TAG committee now have 3 1/2 years under their belt and they smell deception in regards to the Gap area and the Stroh Drain. David, Joe, Linda, Tiffany (chair), Sebastian (8 1/2 years experience) are appropriately asking tough questions and are insisting on intelligent responses from GHD and Lanxess. I am enjoying watching TAG put those two parties through their paces. Nevertheless GHD and Lanxess continue playing games and being less than straightforward.

Currently Lanxess have invited TAG to another site visit this time again to find the mysterious Gap area that Lanxess are having such a hard time finding allegedly. Oddly they are reluctant to invite the few CPAC members who have walked that area to attend at the same time as the TAG members. Perhaps we (CPAC) have already "contaminated" the jury pool??? TAG certainly have not expressed any concerns with CPAC members attending public TAG meetings nor should they. I have found most of the TAG members to be polite, straightforward and accommodating. Lanxess and GHD however appear to be chips off the block of CRA and Chemtura. Smoother yes.

WELL DONE WOOLWICH OBSERVER

Observer reporter, Faisal Ali, has attended the last two TAG meetings namely on January 24 and February 28, 2019. I hope that this will become regular coverage and that we will see him at regular TAG (Technical Advisory Group) and RAC (Remediation Advisory Committee) meetings. His story in today's Observer edition is titled, "Minding the gap is the latest push for group monitoring cleanup of Elmira chemical site. The "Gap" is aptly named as it is a low lying area between the Stroh and Lanxess properties that more than likely was the flow path for the hundreds of thousands of gallons per day of Uniroyal Chemical toxic waste waters that were pumped across the Canagagigue Creek into waste pits located on the extreme east side of Uniroyal right next to the Stroh farm.

Mr. Ali has quoted Joe Kelly, Chair Tiffany Svensson and Pat McLean, all of TAG, regarding their concerns that the Gap area be properly investigated and sampled. To date Chemtura and Lanxess have done their very best to avoid that and the litany of reasons and rationales have varied from reasonable to ridiculous. Most of the data Lanxess submitted is either irrelevant (wrong location) or incomplete and sketchy (OW14 groundwater sampling) and requires serious clarification and explanation.

One further comment is that more than one group are monitoring the cleanup. CPAC now known as the Citizens Public Advisory Committee (formerly Chemtura Public Advisory Committee) are also on the job and several CPAC members attended both the Januray 24 and February 28 TAG meetings.

WSIB & MIN. OF LABOUR HYPOCRISY

Today's Waterloo Region Record carries the following article titled, "Appealed rubber claims will be reviewed." Apparently a number of twice rejected claims by rubber workers for workman's compensation will now be included in the sweeping review being undertaken by the Workplace Safety and Insurance Board (WSIB). Also our inimitable Ministry of Labour are also conducting a major review of occupational cancer led by Dr. Paul Demers and expected to be released by the end of the year.

All of this folks is simply a smokescreen. The facts, the data and the scientific knowledge have all been with us for many decades. Various solvents cause various cancers. Rubber chemicals and their additives are carcinogenic. In Europe in the late 1800s doctors were diagnosing cancer at elevated rates in chemical and dye workers in the textile industry (Travis-Agaard Report). These are the same and or similar chemicals still used today in various rubber and chemical industries.

The smokescreen is that before the WSIB can reverse their decisions they need to pretend that their new decisions are based on new medical information. Bullshit three times over! What this has always been about is money. Since 2014 appeals of WSIB decisions have grown significantly while compensation payouts have been slashed in half. This will allow employers' contributions to be reduced ensuring more donations to the favoured political parties (Liberal & Conservative).

Meanwhile the WSIB Chair (Liz Witmer) who has overseen this disgrace is crying crocodile tears publicly regarding the financial crisis that she and the WSIB have caused for families suffering from rubber industry exposures. This is not to mention the health crisis that their colleagues over at the Ministry of Labour have allowed to continue and fester for many decades, all in the name of corporate profits. Flock off and stop sacrificing citizens to enhance both government and industry bank accounts.

"CONSULTANT REJECTS PUMP-AND-TREAT CLEANUP PROGRAM"

On May 3, 2012 the Elmira Independent published several articles and an Editorial regarding the likelihood that the 2028 deadline to restore Elmira's groundwater to drinking water standards would not be achieved. Other articles included "CPAC seeks review of Chemtura cleanup" and the Editorial was titled,"More funding needed for MOE". The Woolwich Observer also published an article on May 5, 2012 titled "Township backs CPAC call for more action on cleanup." Lastly the Observer also had an excellent cartoon with the following caption "Concerned about the pace of cleanup efforts at the Chemtura site, CPAC wants the province to speed up the process-slow and steady won't win the race."

Of course both Chemtura and the MOE took great umbrage that a committee of volunteer citizens, no matter how experienced and professional, would dare question their infallibility. CPAC had several professionals in the field on their committee including David Marks, hydrogeologist, Dr. Henry Regier, biologist, Ron Campbell owner of Acute Environmental, Graham Chevreau certified chemist and health & safety consultant plus CPAC had hired Dr. Gail Krantzberg from McMaster University to look at the pump & treat program and her report advised that much more than pump & treat technology was needed in order to achieve sucessful 2028 cleanup of the Elmira Aquifers.

Six months later Chemtura and their consultants Conestoga Rovers (CRA) brought out their own new plan which promised a tripling of the pump and treat rates as well as In Situ Chemical Oxidation (ISCO) technology application to off-site hot spots. Of course to date none of these promises have occurred. That can be laid directly at the feet of the new 2014 Woolwich Council as they politically intervened and manipulated the application process as well as publicly attacked the previous council's CPAC appointees. In September 2015 two new committees were appointed both of which (especially TAG) are trying but the momentum and honest experience was intentionally set aside by Sandy Shantz and Mark Bauman.

IS THE REAL LESSON FROM THE ELECTROHOME TAX SALE THAT THE OWNER GOT A BREAK?

"Kitchener's effort to force a a tax sale of a notorious contaminated site has led to the owner getting a $800,000 tax break." That may be true but for me and for the health of local residents the real concern should be that the site "... is contaminated with metals, petroleum hydrocarbons and volatile organic compounds, including trichloroethylene, classified as a carcinogen by the U.S. Environmental Protection Agency." These quotes are from the last Friday's Waterloo Region Record article titled, "Tax sale gives property owner $800K break."

From the colour photograph included with the front page story it appears as if this contaminated property isn't even fenced off thus allowing children, teenagers or even local pets to visit the toxic site. Furthermore these above mentioned chemicals can migrate in the subsurface both as a vapour and with the groundwater. In the U.S. there have been a number of major health issues including cancer clusters and deaths attributed to trichloroethylene (TCE) migrating as a vapour into the basements of homes. The exact same thing happened to the Bishop St. community in Cambridge and wasn't discovered until about 2005. The culprits were Northstar Aerospace and Rozell (G.E.). Cancers, ill health and deaths have been attributed to the migrating TCE. The process of entering into homes is known as vapour intrusion.

The question for me is whether our authorities be they municipal, regional or provincial (MOE/MECP) have done any testing or investigation whatsoever to determine if this can or has occurred in the Shanley and Duke St. area of Kitchener.

FOLLOWUP OF THE FEBRUARY 28/19 TAG MEETING

Despite some critical comments made yesterday regarding Lou Almeida (GHD) nevertheless he did make some interesting and helpful comments such as pits GP-1 and GP-2 "communicated" with the creek. He stated that the primary route of contaminant transport to the Canagagigue Creek was both overland flow from the pits as well as seepage through soils and into groundwater that discharged into the Creek. Well now that kind of puts a different slant on Chemtura and the MOE's claims to CPAC in 2013 and 2014 that the remediation of these former gravel pits was voluntary. In fact I suggest that Mr. Almeida's honest comment indicates the dishonesty of both Chemtura Canada and the Ontario Ministry of Environment (MOE/MECP).

Again just like the GP-1 excavation done in 2013 followed up in 2014 with the "supplementary" excavations in 2014, there will be a return bout on the Stroh farm. It turns out that the December and early January excavations done on the Stroh farm didn't catch everything above the criteria for dioxins/furans and DDT. Oh what a surprise (not). Lou informed us that confirmatory sampling of both the sidewalls and the base of the shallow excavation has found more. What the hell do you expect when you only test 15 cm. or 5.9 inches deep in the first place? The current plan is for more digging in March. Hmm we'll see.

Tiffany Svensson, TAG Chair, suggested that the reasons for dropping some chemicals from the list of Contaminants Of Potential Concern (COPC) was "thin". Lindane, in particular, she finds to be problematic. It is one of the dirty dozen persistent organic pollutants (POPs) and should not be dropped. Susan Bryant added that while Lindane was not manufactured on site it was still a raw material that was added to the manufacturing process of other pesticides such as Vitavax and that it continues to flow off-site via MISA outlets on the Lanxess site and into the Canagagigue. She also asked a very good question namely "Has Lindane been tested recently in sediments in the creek?" I would suggest that the answer to that question is no.

Lou Almeida tried to justify dropping Lindane by stating that it was initially looked at for the 2002-2003 Health & Environmental Risk Assessment on the Uniroyal/Crompton site. He stated that it was dropped because it was below the site specific criteria. What he didn't say was that the site specific criteria are much higher than either the generic criteria as well as much higher than any criteria in and around the Creek. Naughty Lou!

Susan B. also added that there were 23 contaminant exceedances in various soil samples examined that were not listed in the COPC. Lou responded with the very interesting comment that the top 1.5 metres of soil is considered available for migration into the creek. What the hell! Then why do they continue to do surficial soil sampling only 15 cm. or 5.9 inches deep???

Pat McLean suggested that TAG's mandate should be expanded to include things like fires, current air emissions etc. Linda Dickson spoke in agreement as she feels that there are two different areas of jurisdiction between RAC and TAG with RAC having the larger role. My question is this simply more of Pat helping out her buddies over at the chemical plant (Lanxess) who have been courting Sulco (Canada Colours), asking to join their Citizens Advisory Panel (CAP). Is that not going so well hence TAG is their backup plan?

SURPRISE (PLEASANT) AT TAG MEETING

Well, well, well. I was worried that Lou Almeida's (GHD) bullshit might carry the day.He had provided a report titled "Draft Gap area Review and Discussion". It was riddled with deceptions, transpositions, fibs and even subtle self-serving inaccuracies. I spent considerable time yesterday examining his report in detail and finding the facts to disprove his worst claims. There really was no need. TAG members en masse simply rejected the document outright. They accurately saw it as just one more excuse in a long litany of excuses as to why Lanxess/GHD would not properly sample and test the Gap area to find evidence of high concentrations of dioxins and DDT that may have flowed overland from their further north, east side pits onto the Stroh property and into the Stroh Drain.

Both TAG Chair Tiffany Svensson and Sebastian Seibel-Achenbach very bluntly told Lou that proper sampling of the Gap area still hasn't taken place. Lou replied that he had provided all the relevant data that Lanxess and GHD had in regards to that area. Lou continued to make excuses including the following humdinger: "the data don't support significant overland flow to the heavily forested area." Really? This forested area is to the west as well as the north of the Gap area. Essentially as Lou has confirmed, GP-1 and 2 were contaminated via overland flow from the pits due northwards. The bulk of the overland wastewaters gravity flowed southwards in a swale that can still be seen on site today via aerial and satellite photos. It entered the CRA confirmed wetlands and then spread out slowly moving via gravity to lower lying areas. These areas included GP-1 and GP-2 due south as well as some flow westwards and a major flow east and south over to the Stroh property. The topographic maps from both Conestoga Rovers (CRA) and other parties confirms this. This flow entered an even lower lying area on the Stroh property which helped hold the water creating the wetlands on both the Stroh and Lanxess property until the Stroh Drain was built in order to specifically drain the swamp so to speak.

Tiffany was particularly on her game last evening. She stated that GHD's "composite sampling was not very representative" and was "inadequate." Pat McLean stated that "the committee (TAG) was not very happy with composite sampling" and that Lou Almeida's argument that "composite sampling had been accepted simply doesn't hold water". Wow!

Sebastian assailed Lou advising that his purported dioxin TEQ criteria of 99 pg/g was inappropriate and furthermore that his supplied historical documents were both inadequate and not conclusive in regards to the likely soil contaminants in the Gap area.

Upon Lou's suggestion that there might be a problem with the definition of the Gap area, Pat McLean came back with it might be "difficult for Lanxess and GHD to find the Gap area". Holy crap but has Pat been eating her cheerios of late? She followed this by stating that no additional soil sampling in the Gap area has been done and that has been "a consistent message for many years."Tiffany again reinforced her opinion that real sampling not composite sampling is required.

Joe Kelly, I believe in support of his colleagues, however went one appropriate step further. He stated that the historic data available has key elements missing (i.e. Gap and Stroh Drain sampling) and that "we have an area that flows to the creek. It would benefit everyone to get it tested. It's a win-win." This focusing by Joe Kelly is important. I am concerned that the sole focus on the Gap could prove disastrous for the Stroh Drain investigation if Lanxess/GHD somehow manage to find samples with low concentrations of dioxins/furans and DDT then that will be their excuse not to examine the Stroh Drain. It is unconscionable that the parties with a huge financial stake at risk are the same parties in charge of sampling and everything else. It's called a conflict of interest folks.

Further comments and discussion from last night's meeting will be presented here tomorrow. This includes comments from Susan and Linda Dickson.