MOE/MECP ARE "SATISFIED" WITH MILL CREEK CLEANUP

Today's Waterloo Region Record carry the following story titled "Province is "satisfied" with Mill Creek cleanup". Their satisfaction is based upon the "restoration efforts" made by the consultant on behalf of either the MOE or the trucking company responsible for the spill of jet fuel last January. These efforts included importing fill, site grading and removing all equipment. Further planting and minor grading are scheduled for the fall as are monitoring of ground and surface water in the future as well as monitoring of sediment quality and "marine life" in the creek two creeks impacted (Mill & Aberfoyle Creeks).

Somewhat of concern for me is the reliance as well by the MOE on "natural attenuation" in the creek. Sometimes this means actual biological or chemical breakdown of toxic components and other times, depending on the chemicals involved and the soil conditions, is mostly wishful thinking. In those cases it may be as much about dilution is the solution to pollution as it is about actual breakdown of toxins into their non-toxic components. I also wish that this article had advised as to the actual quantities of contaminated soil that was removed and replaced with imported clean fill. That is a crucial piece of evidence regarding the seriousness of the cleanup. Afterall 50,000 litres of spilled jet fuel can go a long way both horizontally and vertically.

MY DELEGATION TO RAC NEXT THURSDAY

First off it will be similar to the one I recently presented to Woolwich Council on August 13 and posted about here on August 14/19. There are electronic versions now of both my original 2 1/2 foot wide by 3 1/2 foot tall map of the east side of the Lanxess property as well as the updated version which has yellow arrows on it indicating the flow path of overland waste waters from the former waste pits and ponds (RPE 1-5) southwards and eastwards to the Stroh property. The few red arrows indicate where the dioxins/furans, DDT, and more likely settled out into a large depression on the land surface of the Stroh property. A Woolwich staff person, Lisa probably, will handle putting the electronic maps up onto the two overhead screens so that the RAC members can better view them.

I may focus more in this delegation on the sources of my data namely the GRCA, MOE, CRA/GHD etc. This will also likely include the sources of the ground surface contour lines on my map. In other words the facts are undisputed. What is in ridiculous dispute is Lanxess's, GHD's and the MOE's attempts to say that the waste waters somehow did not gravity flow over onto the Stroh property. The stakes are high of course. Both the environmental stakes for the public as well as the financial stakes for the company are large. The Canagagigue Creek has shown itself to be incredibly resistant to quickly flushing all these chemicals from the past, downstream to be enjoyed both by the Grand River as well as down into Kitchener-Waterloo. It appears obvious that there is an ongoing source either still on the Lanxess property or just off their property that has acted as a "sink" over the decades and is slowly giving up its toxic contents to the Creek. Lanxess like their predecessor corporations will diligently search out the least expensive "fix" that they can find.

RAC MEETING NEXT THURSDAY SEPTEMBER 5, 2019

The Agenda for next Thursday as well as the Minutes for the last RAC (Remediation Advisory Committee) meeting of April 11, 2019 have been sent out. General complaints first. The last RAC meeting was nearly five months ago. Why aren't these Minutes sent out months ago when they are fresh in the minds of the attendees? That said I do believe that I was advised that copies are somewhere within the Minutes of Woolwich Council meetings, possibly months ago. While something it's not good enough. Send the damn Minutes out promptly to the attendees of those meetings!

RAC has met or is scheduled to meet in 2019 namely April 11, September 5 and December 12. That is pathetic and please do not hide behind self-serving rules instituted by the guilty parties stating that three meetings per year are adequate. They are adequate if your goal is appearances only. If you seriously want to be involved with the cleanup of both the Elmira aquifers and the Canagagigue Creek then it is at best tokenism.

Three lousy meetings a year and both Eric Hodgins of the Region of Waterloo and Nancy Davy of the Grand River Conservation Authority can not attend the last RAC meeting. For God's sake send replacements or stand up and wave a white flag and admit this committee is an intentional waste of time.


TAG reps had some very good comments at the last RAC meeting such as not being satisfied with the lack of a number of other contaminants such as lindane not being included in the list of Contaminants of Potential Concern (COPC). Also TAG were still planning on having a representative of a local lab attend TAG to talk about method detection limits and the issue of them being so much higher than both provincial and federal criteria.

TAG also advised that they were unhappy with the vast majority of sediment samples being taken from the bottom of the creek via shovels versus the proper core samples.

RAC were advised by Mr. Almeida (GHD) that there had been a large scale spill of 2,4,5-T ester at some point in the past in or around Building 15 Tank Farm. No specifics were given particularly as no questions were asked about it.

Discussion from Mr. Este (Dwight) of Lanxess about the proposed Community Advisory Panel (CAP) took place. It was to be up and running very shortly. One more phony public consultation body to buttress the polluter and regulator and their inadequate work.

Ramin Ansari (Lanxess) made a presentation regarding the Creek Investigation Report, the Contaminants of Potential Concern and the Conceptual Site Model (CSM). We were reminded that dioxins/furans were constantly found at higher concentrations at greater depths in creek bank soils, creek sediments (bottom of channel), and in floodplain soils. DDT was found at higher concentrations at greater depths only in creekbank soils and is consistent at greater depths otherwise. This information puts the lie to both the MOE/MECP and Uniroyal/Lanxess claims that these toxic substances remain at shallow depths only such as 15 cm. or 5.9 inches.

It is my opinion that just like past Risk Assessments on the Uniroyal site that this one for the Creek will be a Crock! The process is dominated by politicos, qualified persons (QPs) allegedly, consultants, and those either beholden to Lanxess or accepting money from them with little or no honest and informed citizens with any say in the process. Even the honest experts mostly have zero to little first hand experience or history with this site and will be given the mushroom treatment i.e. covered in sh.. and kept in the dark. This is where honest, informed, non-co-opted citizens presence is desperately required.

CONTAMINATED SITES/BROWNFIELD DEVELOPMENT

Yesterday's Waterloo Region Record carried a story titled "A brownfield boom could be coming to city of Waterloo". In one sense it is a positive story in that our municipal and regional governments are incentivizing the cleanup of old contaminated industrial sites around Waterloo Region. The question of course is this: Some of these former industrial sites have been contaminated (soil & groundwater) for anywhere from thirty to seventy-five years or longer. Therefore why haven't these contaminated areas been addressed long ago as the article indicates there is a community benefit from cleaning them up. After all both soil and groundwater contamination can migrate. The contamination in soil can volatilize and move as soil gas from contaminated to uncontaminated areas. Groundwater contamination can and does migrate both to surface water discharge areas as well as to lower groundwater elevation areas around municipal pumping wells used for drinking water.

The number of former contaminated industrial sites are surprising. Since 2009 eleven sites have been remediated to one extent or another in Kitchener, six in Cambridge, two in Waterloo and one in Woolwich Township. That is very interesting although it would be in the public interest to advise which former industrial sites these were. Why should either I or the general public be kept in the dark? For example which among many possible sites in Woolwich Township received these tax incentives?

While Waterloo historically had less heavy industry than say Kitchener or Cambridge nevertheless currently there are active but uncompleted redevelopments at ten properties in the city. That gives us a better idea of the extent of ground pollution in our Waterloo cities and townships. If I had to guess I might suspect that some of the residential development in Breslau might have received tax incentives due to past major contamination from Breslube/Safety-Kleen. All of us should know the true societal and environmental cost associated with textiles, general manufacturing, leather goods, chemical production, plastics, rubber, automobile tires, and so much more.

WHY DOES THE SCIENCE GET DONE AFTER THE FACT?

The likely answer is money. Money and politics that is. Industry that produces pesticides and herbicides do their own research and guess what: it's not always the best science. Today's Waterloo Region Record carries the following story titled "Scientists find bees that nest in soil exposed to deadly pesticides". Honey bees have been well studied due to the negative effects upon them by viruses as well as by neonicotonoid pesticides. The University of Guelph are now studying the effects of pesticides on bees that nest in the ground which encompasses more than 400 bee species in Ontario. The news is not good to date in those studies.

The past focus has been on honey bees probably due to the bee losses over many years and the accompanying honey losses. Now the University of Guelph are finding that bees which feed on the nectar and pollen as well as help pollinate squash, pumpkin, gourds and melons are being exposed in the soil to lethal concentrations of pesticides sprayed on these crops.

Self-monitoring and self-regulation in industry has been a failure environmentally across North America. The whole purpose of pollution is to externalize business waste disposal costs upon the public via the cheapest discharges possible to the natural environment. This includes air, surface water, groundwater and direct soil discharges of toxic wastes as well. Hell human beings even dump directly into the oceans when they can get away with it. Our governments are there to protect us from these bad apple and or rogue industries yet far too often governments turn a blind eye to industry transgressions for a multitude of reasons. The recent SNC-Lavallin case is but one example of a corporate body both breaking the laws (bribery of foreign governments) with impunity as well as lobbying their own government to change the rules/laws for their direct benefit (deferred prosecution/remediation agreements).

MORE INFO ON THE JULY LANXESS PROGRESS REPORT

Several days back I reported on the on again, off again W9 pumping well located near Park and Union St. in Elmira, Ontario. There are other issues and problems including Table A.1 which is the usual monthly Bypass/Upset Conditions Report. Let me simply say this: It is a listing of each pumping well shut down during July 2019 along with the reason/excuse and for how many hours or even for a day or three. As usual there is a full page of shutdowns. Not good.

Table A.2 is a listing of the concentrations of contaminants at various stages of the on and off site treatment systems. Some of the numbers both on and off site are ridiculously high. This includes 5,600 parts per billion (ppb) of chlorobenzene at off-site pumping well W8 located beside Union St. and the former Nutrite/Yara property in the north end of Elmira. This concentration of chlorobenzene is smoking gun evidence of the presence of free phase DNAPL (Dense Non Aqueous Phase Liquids) that have travelled from Uniroyal westwards and under the former Nutrite property.

There is also 13.11 ppb of NDMA present at W8 and that is a horrific concentration when you realize that the drinking water standard for NDMA is .009 ppb. Pumping well W9 also has high concentrations of NDMA namely at 30.57 ppb/ These concentrations are outrageous especially thirty years after the beginning of the 1989 Elmira Water Crisis. Of course with the containment versus cleanup on site permission by the province of Ontario (and MOE) there are many chemicals on the Uniroyal/Lanxess property with groundwater concentrations in the thousands of parts per billion. Also shameful thirty years after the start of the so called "cleanup".

THREE YEARS AGO TAG WERE RELUCTANT TO GO PUBLIC IN A BIG WAY

Basically Dr. Jackson, Chair of TAG at the time, told them that it might very well be necessary. He knew and said that the problems in Elmira were not technical problems they were public policy issues. In other words our politicians, local, regional and provincial were hopeless. They lacked the will for the fight necessary to get the Elmira cleanup on track. It was obvious to Dr. Jackson that the Ontario MOE were part of the problem versus part of the solution. The real solution was to go over the politicians heads and go directly to the public.

I did not blame the new TAG members for their reluctance. With the exception of two veterans on TAG with a history of making private deals and concessions to Uniroyal/Chemtura, the rest, even those with technical backgrounds, were totally new to the dynamics, the politics, the issues and the inherent dishonesty of the whole process. They were honest people still new to what they had gotten themselves into. They were not the least comfortable with news conferences and or speaking publicly about issues with which they had just barely gotten their feet wet. Dr. Jackson asked them to essentially jump off a cliff and to trust him. They respected him but they did not know him well. They hoped that there was a less dramatic method to achieve their goals. They were wrong and Dr. Jackson was correct.

I posted yesterday about the August 20/19 TAG Review Comments sent to Lanxess and to be presented to RAC (Remediation Advisory Committee) presumably on September 5/19 in Woolwich Council Chambers. I view those comments very, very positively. Lanxess and GHD will not. This is where the rubber meets the road. Lanxess will push back. They will respond just like Chemtura, Crompton and Uniroyal Chemical before them in the time honoured way. That is they will bullshit and bafflegab. This is exactly what they did with TAG and Dr. Jackson from September 2015 until the end of December 2016 when he departed. That is exactly what they have done since the start of the Uniroyal Public Advisory Committee (UPAC) in January 1992 with able assistance from Woolwich Council and friends.

Pat McLean and Susan Bryant essentially "captured" UPAC in the very late 1990s by filling it with their appointees only to throw it away by making UPAC a committee of Woolwich Council in 2000. They lost sight of the public interest by trying to please everybody. They knew that to keep their status and positions of Chairwoman (Pat) and secret executive committee member (Susan & 1 more) they had to please council, UPAC members, Uniroyal and the MOE. The two of them were excellent politicians whose primary goal was their own self-importance and enhancement. They told both sides what they wanted to hear and they sold out the public interest in favour of their own for which they were rewarded and honoured by both Uniroyal and friends and as well by local authorities such as the GRCA and the Region of Waterloo.

Yet again our authorities determined that their best interests aligned with those of big money and power, not with the publics' interests. They were experts in saying one thing publicly while making deals privately with the powerful. Pat and Susan understood this long before I did and cut their own deals with our local authorities and Uniroyal and successors. It has served them well, not the public.

TAG PRODUCE SERIOUS CRITICISMS REGARDING LANXESS'S HANDLING OF THE CANGAGIGUE CREEK CLEANUP

The Technical Advisory Group (TAG) have sent their review comments to Lanxess in a seven page document dated August 20, 2019. While smooth and professionally done they are forceful and blunt at the same time. TAG advise that they do not agree with the methods used to screen for Contaminants of Potential Concern (COPC). This includes 22 of 23 substances with soil exceedances that were not retained as COPCs (pg.2). On page three TAG point out that high Method Detection Limits (MDL) greater than the Table 8 criteria and/or the ISQG guidelines may have affected the final list of COPC.

Also on page three TAG point out that Lanxess's consultants GHD made an inaccurate statement in regards to a number of former waste pits being remediated and/or contained by the Upper Aquifer Containment System. Finally on this page (3) TAG remind Lanxess that the Upper aquifer is not consistently contained (Cynthia Doughty-MOE) and that toluene on site can mobilize "hydrophobic" dioxins/furans and DDT. Further north on the west side as well as the east side groundwater is totally uncontained.

Page four is excellent as well with the following: "...TAG wants to ensure that the potential pathway for impacted soil and sediment to reach the Stroh Drain and be transported via the drain to the Canagagigue Creek be exhaustively examined including confirmatory soil and sediment sampling in the Stroh Drain...".

Page five references tissue sampling done in cattle and sheep in 1999. "The tissue analysis indicated that dioxins in lamb and beef were not detected or detected at the detection limits." Well this statement begs the question as to what the criteria/guidelines are and were the detection limits above or below these criteria? That information will tell the tale!

TAG also would like to know if the indicated sediment and soil depositional areas in the downstream Canagagigue Creek will be tested for the contaminants of potential concern to ensure that they are not also hot spots (pg. 6). On the same page TAG ask whether there is a more precise method to sample sediments than using a shovel. Yes proper core samplers were used 24 times while less precise and likely to miss sediments via the shovel method was used 338 times. To me this is similar gamesmanship to sampling three quarters of the sediments with detection limits higher than all the criteria and guidelines. It is effectively useless.

The last page (pg. 7) debunks GHD's claim that "...there are currently no additional ongoing contaminant sources and impacts from the Facility to the Creek." This claim was based upon a lack of currently active seeps into the creek. TAG also ties greater concentrations at depth for DDT, DDE, and DDD to their concerns with the Stroh Drain on page seven.

I have long praised Dr. Richard Jackson's blunt and forceful criticisms if not outright contempt for the longterm gamesmanship that has gone on here in Elmira, Ontario regarding attempts at remediation and cleanup. I am growing nonetheless to appreciate Tiffany Svensson's different style and reports like this can only magnify my admiration.

HOW BADLY CONTAMINATED ARE THE ELMIRA AQUIFERS TODAY?

The short answer is horribly. Thirty years after the south wellfield was shut down after NDMA was found there our drinking water aquifers are still way above the Ontario Drinking Water Standards (ODWS). The good news I suppose is that every year chlorobenzene and NDMA and a host of other contaminants are being pumped slowly out of the ground. By the way by "aquifers" I mean the municipal upper aquifer (MU), the municipal lower aquifer (ML), and the Bedrock aquifer (BR). Each of these are very deep from perhaps sixty feet below the surface (MU) to well over one hundred and twenty feet deep(BR). Keep in mind there are areas where the MU is much closer to the surface and unfortunately that is below the former Uniroyal Chemical site among others.

Today I will focus on NDMA with a drinking water standard of 9 parts per trillion (ppt) and chlorobenzene with a drinking water standard of 80 parts per billion (ppb). Parts per billion are one thousand times larger than parts per trillion. There are many more contaminants such as ammonia, benzene, toluene, aniline, MBT, chlorophenols although we are advised that they too are being reduced along with NDMA and chlorobenzene by the pump and treat systems.

Large parts of Elmira in the MU still have NDMA at 100 ppt namely from First St. south to Southfield Dr. Other smaller areas of Elmira have NDMA at 1,000 ppt such as on the east side of town between Howard Avenue and Oriole Parkway as well as a small area at the south end of Industrial Dr. There is also a very high but localized area near Park and Queen St. with concentrations of 10,000 ppt.

NDMA in the ML, the next deeper aquifer is actually worse. Oriole Parkway at Arthur St. spreads south and west in a plume which is at 1000 ppt. It goes all the way south to South Parkwood Blvd. The area at Union St. and Erb south to First St. and west halfway to Duke St. has a plume at 10,000 ppt.

NDMA in the deepest aquifer (BR) has a plume centred around Arthur St. and going south to Oriole Parkway at 1,000 ppt. Again at the south end of Industrial Dr. as well as part of Arthur St. there is a plume at 1,000 ppt.

Chlorobenzene in the MU is above drinking water standards from and including the Lanxess (Uniroyal) site south-west to First St., west along First St. more than halfway to Duke St. then south to Howard Avenue, back east to Union St. and then heading north-west back to the Lanxess property. Concentrations within this large loop 100 ppb up to 637 ppb all well above the 80 ppb ODWS.

Chlorobenzene in the ML has a very similar large loop to the south-west although it is not connected to the Lanxess site as it is in the MU. Concentrations are between 135 ppb and 372 ppb. There are also very high concentrations between 100 ppb and 2,900 ppb on the former Nutrite (Yara) property near Union St. and Bauman St. if Bauman extended all the way to Union St.

We have a very long way to go to restore our drinking water aquifers. My and others predictions are 2050 at the earliest. Even then without sub-surface source removal mainly at Lanxess and possibly elsewhere in Elmira would you be confident to drink that groundwater?

MULTIPLE SOURCES OF NDMA AROUND ELMIRA

First point. Looking at Figures 4.6 and 4.7 (plume maps for NDMA) and Figures 4.8 and 4.9 (plume maps for chlorobenzene) in the 2018 Lanxess Annual Monitoring Report, things are not so good. Sure there have been large reductions in the concentrations of both chemicals in the upper and lower municipal aquifers, but oh my God, there is so much more left to do just to achieve drinking water standards for both. Keep in mind drinking water standards are not zero. Even after they've lowered the concentrations to 9 parts per trillion for NDMA and 80 parts per billion for chlorobenzene, the groundwater is far from clean much less pristine.

Second point. Uniroyal and corporate successors are not going to make their 2028 deadline for achieving drinking water standards.

Third point. That deadline is damn near FOURTY YEARS after discovering toxic levels of NDMA in our drinking water.

Fourth point these Figures are plume maps showing us the concentrations in 1998 prior to off-site pumping and then in 2018 after twenty years of pumping and treating the off-site groundwater under the town of Elmira. Both the 1998 and the 2018 plume maps have something in common. Careful examination leads to the obvious conclusion that there are multiple sources of contamination to the Elmira aquifers. This likely goes for chlorobenzene as well as NDMA. Ammonia we'll leave for the moment because all the guilty parties have admitted that there were at least two sources namely Uniroyal Chemical and Nutrite Fertilizers. I also suspect a third source further south.

Possible additional NDMA sources would be either Sanyo Canada or a very nearby industry with a small chance that it could be the former McKee Harvestors. In addition there is an unexplained high concentration area very close to the former south wellfields namely E7 and E9. Lastly there are additional sources of NDMA both near Park St. and Queen St. as well as apparent sources in and around the former Varnicolor chemical site on Union St.

Possible additional chlorobenzene sources would be sub-surface DNAPL near the water tower and fire station on Howard Avenue. That free phase DNAPL possibly comes all the way from Uniroyal Chemical but more likely comes from the much closer Borg Textiles or Varnicolor Chemical. Issues complicating reading these plume maps are a lack of monitoring wells between Howard Avenue and Oriole Parkway. Also the Conceptual Site Model produced by Dr. Neil Thompson suggests that there is an additional 1900 kg. of chlorobenzene in the Elmira aquifers than what solely came from Uniroyal Chemical. Very strange without a second source and certainly both Borg and Varnicolor should not have been strangers to chlorobenzene despite MOE shallow sampling on the Varnicolor site.

Lastly all these likely additional sources could easily have been determined between 1990 and 1992. They were not intentionally for political reasons. They likely still could be determined with honest, unbiased, shallow soil and groundwater sampling. Honest and unbiased sampling means out of the control of Lanxess, GHD, MOE (MECP) and Woolwich Township at the very least.

RAC MEETING SCHEDULED FOR SEPTEMBER 5, 2019 - A PREDICTION

Actually I have two predictions for the 3 pm. September 5/19 Remediation Advisory Committee (RAC) meeting to be held in Woolwich Council Chambers. I sincerely hope that I am wrong with both of them. They are that there will be no questions whatsoever from RAC members after my Delegation to them and secondly that there will be no mention of Cynthia Doughty's (MOE) letter of June 20/19 to Jason Rice (MOE) indicating the failure of the Upper Aquifer Containment System (UACS), essentially since its inception.

I posted here on July 31/19, the day before the last TAG meeting, about Ms. Doughty's very interesting letter. She has flat out stated what I have long suspected and in years past have raised at CPAC meetings. Unfortunately as always in subjective matters, the polluter's well paid consultants have interpreted the data favourably at all times to their client, whether Uniroyal Chemical, Crompton Co., Chemtura or Lanxess as they will always do.

Regarding my prediction that there will be no questions from RAC members, that is almost a given. I believe that the parameters and results for the upcoming threatened Risk Assessment for the Canagagigue Creek have long been settled privately among all the parties. This would include Lanxess, the Ontario Ministry of Environment (MOE), GHD, Grand River Conservation Authority (GRCA), Woolwich Township, Region of Waterloo etc. The Risk Assessment and lead up work to it are merely window dressing, or as Dr. Henry Regier said about the last one on the Chemtura site years ago... "green washing". Hence the window dressing is for the media, local citizens and the general public. Therefore my Delegation is unlikely to be well received or appreciated as I discuss the Stroh property contribution to the dioxins/furans and DDT in the creek.

If there were any well informed members on the RAC committee, they might decide to ask me difficult questions in an attempt to lessen my impact or credibility. Perhaps the MOE or even Lanxess reps might do so but likely they too are scared of opening a can of worms that they can't close.

MOE REFUSED TO TEST THE SEDIMENTS IN THE MARTIN POND IN 2013

Gail Martin wrote an article in the Elmira Independent on May 9, 2013 titled "Creek sample shows increased DDT levels". The sampling in various locations in Canagagigue Creek took place last November 2012. There were some surprises to say the least. Neither the MOE nor CPAC members were expecting any results in the 12,000 to 13,000 ppb. concentrations. This is all rather ironic as George Karlos of the MOE had suggested a year ago or so that this sampling would put the community's fears and concerns to rest. Hardly as both soil and sediment criteria are thousands of times lower than these numbers.

Also of concern was the MOE neatly sidestepping sampling within the Martin man-made in-ground swimming pool that has been used for generations of children. The MOE claimed that there was a geotextile membrane inside the pond that sealed it. In this case I can advise from first hand observation that indeed there is some sort of geotextile membrane on the inside of the pool. The problem is this. While the membrane may reduce sediments and soils from the interior of the pond from entering it, the membrane does absolutely nothing for suspended sediments entering the pond directly from the pipe which runs via gravity flow between the Stroh Drain, Ditch & Berm and the interior of the pond. Dr. Sebastian Seibel-Achenbach and myself saw this pipe and saw it running when we had permission from the Martin family to sample the Stroh Drain etc. on their property along with MBN Engineering & Consulting, who were working with CPAC. Hence it is more than likely that both dioxins and DDT would or could be found in this swimming pond despite the MOE's refusal to test it. Also of interest is the fact that now in August 2019 more than six years later, while there has been more biased and unscientific testing, to date not a shovel full of contaminated sediments or creek or floodplain soils have been removed. Par for the course in Elmira, Woolwich Township, Ontario.

SIMPLE QUESTIONS UNASKED REGARDING PUMPING WELL W9?

TAG, RAC, and the public have been told that off-site pumping well W9 was shut down because Lanxess and GHD couldn't effectively treat toluene and benzothizole exceedances in the groundwater pumped from the well. O.K. so what's the next obvious question? How about WHY NOT? Uniroyal/Lanxess on-site groundwater is filled with toluene and benzothiazole (plus a hundred other chemicals) and that groundwater is pumped, treated and discharged back into the Canagagigue Creek. Why is the groundwater a few hundred metres due west of Uniroyal/Lanxess, near the corner of Park St. and Union St. such a problem that well W9 is two years late or more coming on-line?

One fairly obvious answer is that Lanxess just like every corporate body before them are constantly cheaping out every possible aspect of the remediation of both the Canagagigue Creek and of the Elmira Aquifers. Therefore just take a look at the different treatment systems in use for different wells both on and off their property. There is activated carbon treatment, ultraviolet treatment, LNAPL separation and removal, ammonia treatment etc. Ahh but here's the rub. Not for every well, all of which are pumping contaminated groundwater. So which wells get the Cadillac treatment and which wells get the Volkswagon beetle treatment? The general answer is that as few as possible for the former and as many as possible for the latter.

W9 gets ultraviolet treatment only. That's it folks, nothing more. By delaying implementing this well from 1989 until 2019, the company had the benefit of an additional thirty years of groundwater flow and dilution. Or in the alternative since off-site pumping didn't start until 1998, they had the benefit of an additional twenty-one years of groundwater flow and dilution. Maybe they expected lower concentrations of contaminants in behind the large building where W9 is located alongside Shirt Factory Creek.

Hmm. And exactly what is or was that building? Let's see now. At one time it was Park Avenue Textiles and before that it was the Elmira Shirt and Coverall Company. Also of interest is that Elmira's first municipal landfill was located on this property as well. Now this landfill was before Uniroyal Chemical's time but was it before say Roxton Furniture (across the road) or a number of other local polluting industries? Highly unlikely. As is common historical revisionism, Woolwich Township and the MOE would have us believe that nothing but wood ashes and a little municipal garbage went into this landfill. Horsefeathers!

Of course as is the usual answer to these allegations, industrial and political admirers of relatively inexpensive waste disposal will claim that no evidence exists to corroborate that likelihood. Well actually there are two responses to that. If any soil testing both shallow and deep has already been done in and around this property, building, and landfill, rest assured the results are a carefully guarded secret. Secondly if no testing has ever been done then shame on Woolwich Township, the Ontario Ministry of Environment (MOE), Uniroyal Chemical, CRA etc. The Elmira Aquifers are grossly contaminated and ALL sources of contamination should have been looked for and investigated thirty years ago.

YOU WILL NEVER FIND WHAT YOU REFUSE TO LOOK FOR !

PUMPING WELL W9 SURE SMELLS

Pumping well W9 was supposed to be a significant addition to the off-site pumping (i.e. off the Uniroyal/Lanxess site) in the Elmira Aquifers. First of all it was a couple of years late in coming on line allegedly due to benzothiazole (BT)and toluene concentrations not being adequately reduced by the treatment methods being used. We then waited and waited for new equipment which we were told would take care of things. Well it did at least for a very short while. Three whole months of improved pumping and treating at W9 namely April, May, and June 2019. Now pumping and treating for July 2019 are back in the crapper. The Target Average pumping rate is supposed to be 13.6 litres per second. April was 12.6, May was 13.1 and June actually met and surpassed the Target Average with 15.2 l/sec. Last month, July 2019 has plummeted back to 4.3 l/sec.

We are advised in the July "Progress Report" that the failure of W9 yet again is due to the effluent after treatment being acutely toxic to the insect test subjects. 50% of them died in the first test and a followup killed 100% of them. Realizing that all the treated groundwater from both Uniroyal/Lanxess and the rest of Elmira is discharged into the Canagagigue Creek and you can see the problem. Cleaning Elmira's groundwater at the expense of the Canagagigue Creek is not supposed to happen although citizens certainly advised our authorities back in the early 1990s that that sure looked to be what the plan was. Well here we are three decades since the 1989 Elmira Water Crisis and it appears to me that the Canagagigue Creek continues to be the waste disposal sewer for mankind's "progress". This is more than the ongoing pumping and treating and includes the pretend creek investigation by GHD, the pretend conceptual site model for the creek and soon to be pretend Risk Assessment.

FINE TUNING ATTEMPT?

After my Delegation to Woolwich Council Tuesday night regarding the contaminated east side Stroh property, there was perhaps at best a half-hearted attempt by the mayor to soften or minimize my concerns. She advised Council that the Technical Advisory Group (TAG) has been discussing soil samples in the "Gap" area. While this is true it only barely touches upon the issues of Persistent Organic Pollutants (POPs) deposited on the Stroh property to the east. The "Gap" area is part of the likely flow path of contaminated waste waters from Uniroyal Chemicals east side pits southwards into the former wetlands area.

Perhaps the mayor was simply buttressing her position that everything is under control and up front in regards to the cleanup of either the Elmira Aquifers or the Canagagigue Creek. Unfortunately that would be incorrect unless under the control of the polluter and corrupt regulator is OK with you. Mayor Shantz is the chair of RAC and has been recently sitting in on TAG meetings. She is a believer in the status quo and in supporting all our local authorities and agencies. I am not so inclined based upon their history right up until the present.

Overall councillors did not seem overly impressed with the mayor's comments. After all my Delegation was calm, cool, and backed with facts and maps. While in principle I don't appreciate revisionism being practiced upon a citizen's Delegation, this was not a big deal in the scheme of things.

LAST NIGHT'S DELEGATION TO WOOLWICH COUNCIL

Well first off I received a cordial welcome from Council and did not have any interruptions during the course of my Delegation. I believe that I may actually have run over the ten minute time limit by a minute or so but again was allowed to finish without interruption for which I thanked the Chair when I was done. I also believe that council members (less Fred Redekop who was unfortunately absent) were receptive and listening carefully. Indeed Councillor Larry Shantz had a very good question at the end of my presentation in regards to the depth and the reason for the shallow depth of the superficial excavations along the Lanxess/Stroh property line.

One piece of advice that I received later from the gallery was that councillors have a multitude of issues constantly running simultaneously and hence it is best to realize that they out of necessity are generalists not specialists who are extremely well versed in all issues. Therefore especially when dealing with Uniroyal/Lanxess and technical contamination issues it is best to keep things simple and straightforward.

I spoke about the ground surface contour lines on the east side of the Uniroyal/Lanxess property and how a number of government agencies over the years have produced these elevation (i.e. ground surface) contours and how consistent they are with each other. These agencies include MOE/MECP, GRCA, Conestoga Rovers etc. The orange arrows on my large map show the flow direction of overflowing waste waters leaving the east side pits in the late 1940s, and throughout the 1950s and 1960s. Simply following the contour lines it is clear that the massive quantities of waste waters ended up settling out in the large depression on the Stroh property to the immediate east of the Stroh Drain, Ditch, and Berm (SDDB). The failure of Lanxess to sample the soils in and around the Stroh Drain (SDDB) and of the MOE to not insist upon it is reprehensible and entirely self-serving for both groups.

ENVIRONMENTAL LIP SERVICE ONLY PLEASE - THIS IS CANADA AFTERALL

The last couple of days we've seen three different articles in the Waterloo Region Record regarding either direct or indirect environmental problems. They have been the one about algal blooms on Lake Erie that I posted about yesterday as well as lead in the drinking water of residents of Newark, New Jersey. Finally yesterday's paper advised readers about concerns for a new gravel pit proposed along Witmer Road,south of Petersburg in Wilmot Township.

Our media understand the life and death consequences both to individuals and to humanity as a whole. Overall the media have been bringing the life altering, or worse, issue of climate change to the public regularly. And that pretty much is where it ends. Air travel expands, pipelines continue to be built and money is being made in the oilsands and will continue to do so for a long time.

Closer to home the article about the proposed gravel pit has all the local players telling us supposedly stupid citizens that gravel pits that follow the rules are not harmful. Two points to that. The first point is bull manure. The rules do not protect the public or the environment. They are far too lax. The second point is that what rules there are, simply are not enforced. Like the Ministry of Environment (MOE/MECP), the Ministry of Natural Resources (MNR) hasn't enough manpower to regularly and comprehensively monitor and supervise the plethora of gravel pits just in Waterloo Region much less throughout the province. Even if they do stumble across violations, just like the MOE they write up a ticket and personnel higher up in the MNR decide that it's not in the public interest to pursue either fines or charges.

There is a third point. The article about the Wilmot Township gravel pit near Petersburg suggests that the gravel pit will be restored to agricultural lands. More extreme bull manure. First of all the drainage beneath it has been drastically altered as the sand and gravel have been removed from beneath the soils. Secondly the fertile topsoil has been scraped away and piled up to be eventually (years or more likely decades later) spread back over the surface of the ground. Experts at the Hunder Pit Ontario Municipal Board hearing a few years back held in Woolwich Council Chambers put the lie to that scenario. Agricultural soils are filled with bacteriological and other life. Both bacteria and fungi in the soil actually assist the roots of crops in taking nutrients from the soil and making them available for crop growth and health. Disturbing this topsoil via scraping and piling drastically reduces the productivity of the soil and it can take decades for it to be restored AFTER it's been spread back out onto the ground surface.

As I said, here in Ontario and Canada it's all about lip service. Tell the people what they want to hear but do not ever even slightly impair the ability of the wealthy and powerful from exploiting our natural resources for their benefit to the detriment of the environment and the rest of our citizens.

HARMFUL ALGAL BLOOMS (HABs)

Today's K-W Record carries the following story titled "Scientists on high alert as massive algal bloom threatens Lake Erie". The bad news is that this is nothing new. Similarly the cause is very well known yet conveniently ignored. Agriculture is a large and strong target to go after. The simple cause is too much phosphorus running off our farm fields and getting into Lake Erie where it promotes the rampant growth of algae. Sure we can blame climate change as well. Warmer temperatures in the lake increase algal growth combined with heavier rainstorms sends more phosphorus laden soils via creeks and rivers into Lake Erie.

These algal blooms can be toxic . The blue-green algae is known as cyanobacteria which produces a toxin called microcystin. Microcystin can be both harmful to humans, pets and livestock or even fatal. It has been found in various municipal water systems including Toledo in 2014. Although this story doesn't say it, I am. Gutless politicians don't want to pass laws that the agriculture industry will claim discriminate against them. Tough. Besides corn, soybean and other crops being over fertilized or fertilized too soon before heavy rains there are also problems with livestock grazing either in floodplains or walking into rivers and creeks directly. Their manure only exacerbates the problems of nutrient loading to our Great Lakes although Lake Erie is most vulnerable. Voluntary measures by farmers to date have not been adequate. Much more is needed.

POLITICOS SPEND THEIR CAREERS COVERING UP THEIR MISTAKES & FAILURES

Most of us everyday citizens, that is non-politicians or government bureaucrats, figure that once the cat is out of the bag, then forget lying and covering up. Not politicians and their ilk. They are hard wired to always gild the lily or put the best face on unfortunate or negative events that reflect badly on them. One obvious example is Uniroyal Chemical and the 1989 Elmira Water Crisis. Uniroyal's waste disposal methods were beyond primitive and third world like until around 1968-1970. They destroyed the local creek, polluted the Grand River, and destroyed the Elmira drinking water aquifers. I say destroyed because thirty years later we are still waiting for their "restoration" with the latest estimates being another thirty years. I'll believe that "restoration" when I see it and I'm within a whisker of being seventy years old.

Part of the public exposure through the 1990s of the self-serving and dishonest behaviour of Uniroyal Chemical also reflects upon our Ministry of Errors and Excuses when it was known as the MOEE. The behaviour that I am referring to is ongoing public statements (i.e. lies) by the Ministry of Environment (currently known as MECP) in the 1970s and 80s that everything was fine, under control, and that the Elmira drinking wells were protected. Uniroyal when asked then and now like to use the MOE/MECP as a shield. Oh they say we do as we are told by the MOE. They are fair but firm. Uniroyal and successors have always known that this crap they have been espousing is exactly that, namely crap. They have consistently pressured, threatened, and intimidated the Ontario MOE constantly looking for concessions, exceptions, and relief from onerous environmental interpretations of the law.

Then we have the Walkerton crisis in 2000. Same thing all over again except this time it was Walkerton's council and staff who messed up along with the typical incompetence demonstrated by the Ontario Ministry of Environment. They couldn't find their own butts in a snowstorm much less find serious environmental infractions and if they do find them rest assured they will go nowhere until there is a crisis. This folks is what happens when the politicians at the top (provincial and municipal) are always in coverup mode and their attitude of ignoring and covering up serious problems permeates downwards through the ranks. I sometimes wonder if those that get promoted in the MOE are essentially yes men and women and those who are forthright and honest get career sidetracked into positions where their honesty cannot harm those in charge.

Again the Varnicolor Chemical scandal which is ongoing to this day. Full coverup mode even thirty years later and after the owner actually got sent to jail with an eight month sentence. The company were an illegal toxic liquid dumping organization who were protected by the MOE both before and after I and others publicly exposed the company. Even today the MOE will not release to the public documents pertaining to this site and its ongoing remediation over the last twenty-five years. Why would they when both they and provincial politicians would rather this embarrassment go the route of all the others.

In Cambridge we had the Northstar Aerospace disaster. Hundreds of homes and occupants in the Bishop St. community inhaled trichloroethylene (TCE) and Trichloroethane (TCA) fumes for decades due to vapour intrusion courtesy of Northstar and another commercial neighbour. Allegedly the MOE inspected this site and missed everything going on throughout this period. Or the inspectors simply didn't want to rock the boat. Were their job reviews based upon finding environmental infractions or perhaps just the opposite? Clearly the system is rotten.

Politicians, government ministries, and accompanying bureaucrats rely on the short attention span of citizens. Most of us are focusing on our every day lives including jobs and families and health. We pay through the nose for government services and far too often get poorly served by them. These politicians and governments have our money and busy lives to hide behind. They become experts at puffery and bull.... . Each and every failure is chalked up to a one time exception or "slipping through the cracks". They will claim that their agencies are "world class". That is their puffery and bull.... in action. Systemic failures will not be admitted to. When pressed they use their financial might (paid for by you) to use the courts to support them and harass citizens. That is the unfortunate behaviour of some school boards among other agencies.

The last brief coverup of past failures I will mention is the last Woolwich Council's behaviour to hide their failure to properly oversee and supervise the potentially explosive methane issues in and around Bolender Park in Elmira, Ontario. The methane originates from the Bolender Landfill, possibly due north of the Park although far from proven not to include parts of the park itself. The last council continue to hide behind their consultants Conestoga Rovers and their successors GHD. This includes denying everything while actually beginning to take some appropriate steps to make up for their benign neglect for decades. Council either denied the lack of regular and ongoing monitoring as well as denying the failure to monitor the entire perimeter of the former landfill. Even their failure to determine the exact location of the entire landfill is mind boggling. They appear to prefer to be ignorant in order to maintain their plausible deniability if it turns out that citizens and children are playing above methane infused garbage. It is also their refusal to provide honest communications with citizens asking hard questions that is so disgraceful. Rest assured if the worse happens that they will suddenly discover the hard way that coverups are not in the public interest.

All in all the behaviour of unaccountable and morally suspect politicians.

"VOLUNTARY" CLEANUP OF GRAVEL PIT-1 - INDEED IT WAS, IN HINDSIGHT

The March 7, 2013 edition of the Elmira Independent carries the following story titled "Committee opposes partial excavation of waste pits." CPAC (Chemtura Public Advisory Committee) wanted both gravel pits, GP-1 and GP-2 excavated and contaminated soils (dioxin/furans, DDT, & more) removed. In order to save a buck, Chemtura only wanted to excavate parts of GP-1 and cap then GP-2 in order to reduce water infiltration into the pit. All in all it was an excellent scam by both the company and the Ontario Ministry of Environment.

To date Chemtura or their successor Lanxess have not so much as acknowledged or commented on the probable relocation of GP-1 despite as always the evidence is from sources intimately associated with the company and its site in Elmira, Ontario. Both text from reports in the 1980s and early 90s as well as a 1983 and 1992 maps indicate the earlier accepted location of GP-1. Conestoga Rovers has even admitted that they have over time made adjustments to the size and shape of Gp-1 in particular. They have not admitted to outright relocation however.

If as I believe that GP-1 was arbitrarily and bilaterally moved by Uniroyal Chemical and CRA then indeed the cleanup of the likely much less contaminated pretend GP-1 should have been voluntary. What is indescribable and heinous however is the potential Ontario Ministry of Environment's (MOE/MECP) collusion with Uniroyal on the matter. I'm sure that they would prefer the word "negotiated" but that would be a misnomer. I very much doubt that they have the right to "negotiate" away the legal responsibilities of a coporate polluter who has contaminated their neighbour's property. If the MOE did collude with Uniroyal and CRA on this matter, then it is trilateral not bilateral relocation of a contaminated area. The original (via the 1983 map) GP-1 was on Uniroyal's property but was located in the lower lying area on the north-east side of the diagonal ridge of high ground in their south-east corner. This diagonal ridge (north-west to south-east orientation) of higher ground is what deflected the overland flow of waste waters from the east side pits south-east onto the neighbouring Stroh property. Therefore overland flow into the real GP-1 would have more obviously continued south-eastwards through the "Gap" area and onto the Stroh property and farm.

THREE DECADES OF PROFESSIONAL DECEPTION

Sometimes I wonder why I have such disrespect for various alleged professional consultants, spokespersons, and experts who all amazingly to me, not so much to others, find ways to interpret facts favourably to their clients or even misstate facts also favourably to their clients. There is an immense advantage to being the proponent for either development proposals or remediation proposals for your own property. Firstly, generally speaking, you control the facts and hence the narrative. Also, generally speaking, there is no real government regulator in serious, open confrontation with you, unless of course you are a small fry and then things can change in a hurry. Just ask Varnicolor Chemical owner Severin Argenton about that. Some former government employed drinking buddies quickly jumped ship when the tide turned against Severin and the MOE back in the early 1990s.

Over the last two days I have posted here about the pumping of waste waters from the west side of the creek (Canagagigue) over to the east side pits on the top of the hill. I also posted here about synonyms, typos, and other misstatements and errors amazingly all being helpful to the narrative that the polluter and sometimes their guilty regulator preferred.

There are a few but very significant errors in Table 3.1 in the August 1991 Environmental Audit written by Conestoga Rovers (CRA) on behalf of Uniroyal Chemical. These include inaccurate dates of disposal as well as not clearly indicating the exact dates that various west side ponds were constructed which would then give a clearer indication of how many years they were actually in operation say compared to the east side pits. Similarly it would help if this "Waste Disposal Summary Table" more clearly indicated which pits and ponds were primarily for liquids versus solids or sludges. Also DDT is mentioned as being in the Building 8 sump but there is no indication in this Table as to the final destination for this product (it was into RPE-4).

Even the nomenclature for RPE and RPW is deceptive. RPW refers to the west side "ponds" as in Retention Pond West and RPE refers to the east side "pits" as in Retention Pit East. This certainly gave me for a very long time the false belief that the process liquids primarily were disposed into the west side "ponds" versus into the east side "pits". Uniroyal and successors had a multitude of opportunities to correct those misunderstandings at public UPAC and CPAC meetings for decades but did not.

Both the August 1991 and the January 1992 Environmental Audits are seriously convoluted and complicated in regards to explaining to citizens and lay persons exactly where solid and liquid wastes ended up. Yes they are clear that in the first few years just about everything liquid went directly or indirectly into the Canagagigue Creek. After that the company used more convoluted routes to essentially get the same result. After 1946 the Uniroyal Chemical sewer and sump systems sent the vast majority of waste waters to the east side pits which already by 1948 were causing vegetative distress to further east crops (Stroh property) as well as along the creek on the Uniroyal property. Clearly the information we received in the early 90s about Mr. Stroh senior having received compensation for crop damage makes sense.

If the guilty parties had been up front at the start of public consultation (i.e. UPAC) then citizens would have focused much more on the east side long before the discovery of the Stroh Drain, Ditch & Berm in May 2014.

CORRECTION REGARDING STROH DRAIN, DITCH & BERM

Following is copy of an e-mail sent earlier this morning to Tiffany Svensson, (TAG Chair), Joe Kelly (member), Sebastian Seibel-Achenbach (CPAC & TAG member) and Lisa Schaefer (Support Co-ordinator for RAC/TAG - Woolwich Township employee)




Tiffany & Joe: I have been rereading old but very relevant reports describing the overland flow of liquid wastes from the east side pits. Two of the sources are the 1985 "A History of Uniroyal Waste Management at Elmira" by W. Jackman, J. Ralston,and A. Smith. The first two gentlemen are from the Ontario MOE and the last is from the GRCA. The second report is the August 1991 "Environmental Audit" produced by Conestoga Rovers (CRA) under order from the MOE and on behalf of Uniroyal Chemical.

The 1985 report states on page 4 : "By 1948, seepage from the ponds was being collected in open ditches and drained to a gravel pit (GP on Fig. 1)."
"The 2,4-D wastewater continued to be pumped to the ponds until 1965 when the municipal waste treatment plant..."

And on page 6 : "Any wash water from the 2,4,5-T process entered the same waste streams as the 2,45-D process."

The August 1991 Environmental Audit on Page 37 states that liquid wastes leaked out the bottom of RPE-1 because it was built on a sand lens and caused "vegetative stress" on both crops on the east side and vegetation on the west side. as far away as the Canagagigue Creek.

However as per page 38, pits RPE-2, 3.4 were built on top of clay and hence there was much less and much slower leakage through the bottom. The obvious fact was that ongoing and daily pumping of liquid wastes into these pits resulted in significant overflows of wastewater versus CRA's claim of "intermittent" flow.

Page 39 states: "Intermittent overflow from the pits was collected in open ditches and drained to a gravel pit on the south-east portion of the property." Furthermore "This seepage toward the gravel pit continued until approximately 1965, when the Elmira STP began to receive wastes from Uniroyal." And on the same page "...the east pits continued to be used to equalize the loadings to the Elmira STP."

Page 43 states: "Seepage and overflow from the pits RPE-1 to RPE-5 was directed by drainage ditches into gravel pits located in the south-east portion of the site. This practice began in the early 1940s until approximately 1970 when the east side ponds were closed and /or lined. Liquids would pond in the gravel pits and eventually seep down into the subsurface soils. Liquid waste water was continuously standing in the gravel pits until the east side pits were closed. When seepage from these pits subsided in the early 1970s, the gravel pits dried up."

Prior to my commenting/criticizing CRA's obvious conflict of interest (i.e. client driven and paid for reports) and choice of language (
"seepage", "intermittent") to minimize the extent of pollution and cost of cleanup to their client (Uniroyal Chemical) I wish to ask Lisa Schaefer to please send this e-mail report to all of TAG at a minimum. Thank you Lisa. Secondly I wish to advise that Woolwich Township should have both these reports, and much more, in their archives. If not then either the MOE/MECP or Lanxess should be able to provide them to Lisa, Tiffany and all TAG members. As a last resort I am the proud owner of a complete set of Uniroyal to Lanxess reports (approx. 1980 - 2019) and I would either e-mail you entire pages as Attachments or possibly bring in the reports for you to examine with myself present.

Point One: Note in the above quotes how many times seepage and overflows were directed into a gravel pit (SINGULAR!) versus gravel pits plural. That is because they were directed towards a gravel pit (GP-1) only, however GP-1 was not in the current location where CRA conveniently moved it to on their maps over the last three decades. I have the maps showing its relocation from its original location on the north-east side of the diagonal ridge of high ground that a number of us walked on top of on April 11, 2019 during our site tour.

Point Two: We are supposed to believe that "seepage" or "intermittent overflow" of the east side pits resulted in surface drainage in open ditches (versus say in an enclosed pipe) over a distance of 300 metres from RPE-5 and closer to 750 metres from RPE-2 which is much further north. That is ridiculous nonsense. Only very large volumes of liquids waste waters would flow that distance without being entirely absorbed into the soil along the way. Furthermore CRA have stated that these waste water flows resulted in "continuously standing" liquids in the gravel pits.

Point Three: From 1946 until very close to 1970, the east side pits were the recipients of the vast bulk of process waste waters and liquid wastes generated by Uniroyal and successors production processes on the west side of the creek. From 1942 until 1946 liquid wastes were simply put directly into Shirt Factory Creek (SFC) and from there the Canagagigue or directly allowed to run off the river flats into the Canagagigue Creek. From 1946 until 1970 they were pumped via two pipelines across the creek and over to the east side pits. The waste waters averaged around 165,000 Imperial Gallons Per Day (IGPD) with lows of 140,000 gallons and highs of 240,000 IGPD. These daily volumes could not possibly be absorbed by the soil and indeed they were not. They flowed southwards and eastwards following the ground surface elevation contours until they ended in a large depression on the Stroh property to the immediate east of the Stroh Drain, Ditch & Berm. Yes these liquid wastes were not in a pipe and certainly spread out with some going west towards the creek on Uniroyal's property and some going into the currently known GP-1 location. Most however went over to the Stroh property. Ground surface elevation contours do not lie. My large map has these contours now for the entire east side and these contours are sourced from the MOE/MECP, GRCA, CRA, MTE and others and are consistent with each other.

Joe, in regards to the small pond just south of RPE-5 your observation was worthy however that depression is the result of contaminated soil being excavated and put into RPE-5 in 1969 essentially after the east side pits were out of service. This information is also in the Environmental Audit.

Sincerely Alan Marshall CPAC & EH-Team member P.S. TAG & CPAC member Sebastian Seibel- Achenbach has more current and extensive knowledge of these matters than TAG hence his position being closer to mine than to some TAG members.

SYNONYMS, TYPOGRAPHICAL, & OTHER INTENTIONAL (?) ERRORS TO CONFUSE AND DECEIVE THE PUBLIC

There are several reports from the 1980s and very early 1990s written by consultants for Uniroyal Chemical and the Ontario Ministry of Environment (MOE/MECP) that have become the "bibles" for environmental activists and citizens who have seriously pursued the truth for the last three decades regarding the 1989 Elmira Water Crisis. There were a couple of others from consultants hired by the Region of Waterloo namely CH2M HILL and one done by consulting firm Terraqua. These last two, especially the Terreaqua report (1986) I have very little difficulty with.

There are serious problems with the 1985 "History of Uniroyal Chemical Waste Management" produced by the MOE and GRCA as well as with the two Environmental Audits produced by Conestoga Rovers in August 1991 and January 1992. There are too many times that either products, building names, sumps, waste pits and ponds are referred to using synonyms without explanation or clarification. There are what look like typographical errors whereby a building number is one digit off what it was previously, again without explanation or clarification. As far as the wastewater distribution and disposal system there are a plethora of names and numbers for the very same sumps for example. Also there are incorrect dates and waste pit locations in the Environmental Audit.

All of this almost seems to be a bit of showing off. You know when you try to talk to a person about their work and they try to impress you with a ton of acronyms and or a ton of meaningless numbers thrown in to make their jobs and knowledge seem both greater than yours and vaster than it really is. Some consultants aren't happy unless they are basically speaking a different language than their audience which may also have the intent of discouraging questions if you have been totally lost during the presentation. Using synonyms to confuse your audience can be no more than trying to impress or it can be simple rudeness or finally it can be to intentionally confuse your audience.

Recently I've been rereading these reports, yet again. Keeping them all on the table at the same time and going back and forth between them is helpful. One can slowly pick out the confusing if not contradictory statements and see how it is done. The why is a little more subjective although from the experience and viewpoint of dealing with these two groups for three decades one can readily come to one's own conclusion. Sometimes there are blatant errors and other times it is careful word choice to make you think one thing until you reread it and compare to the other reports. Between multiple reports and authors one can slowly pick one's way through the smoke and haze. All of this further hinders true public consultation.

MORE DETAIL ON METHOD DETECTION LIMITS (MDL)

Yesterday's post included comments from Jason Rice MOE/MECP) (in a letter to Tiffany Svensson) regarding why MDLs vary between ALS labs and the MECP labs. Various reasons include:

For dioxin/furan analysis ALS uses EPA Method 8290 instead of EPA Method 1613. The latter is the superior of the two and the one used by the MOE/MECP.

Regarding DDT analysis ALS labs uses Method E3487 versus ALS labs using Methods WT-TM 1102 and 1302. While those numbers are Greek to me apparently using the ALS Method results in higher Method Detection Limits (MDLs). Also the MECP use more sensitive instrument equipment than ALS which lowers MDLs. Finally The MECP lab method has a larger final volume of sample extract also lowering MDLs.

For both dioxin/furans and DDT there are also superior versus inferior clean-up steps involving the lab equipment used. Mr. Rice (MECP) believes that the ALS steps are inferior to the MOE's.

My take on all this is that you get what you pay for and hence Lanxess had no incentive to get the best lab work done as it would cost more money upfront to the lab and then later with the greater cleanup of the Creek occasioned by the greater number of criteria exceedances that the lab would find if they used the superior methods.

KIND OF AN ODD TAG MEETING LAST EVENING

First off everybody behaved nicely including Sandy Shantz politely and respectfully giving me her condolences on the passing of my father-in-law, Aden Brubacher. A couple of others did as well. I thanked them sincerely including our pretend mayor, Sandy. No I did not call her that but treated her as respectfully and courteously as she treated me.

The meeting was odd for many reasons. First of all there were no MOE staff present. Neither was Ramin Ansari, Dwighte Este, Helder Botellho from Lanxess present. Therefore as usual exactly zero questions could be asked by either TAG members or the public of the MOE (MECP) or Lanxess which is exactly as those two bodies seem to prefer. As if the public could ask questions even if the MOE and Lanxess were present courtesy of the horse.... Terms of Reference for TAG and RAC. Also odd was Sandy Shantz (RAC co-chair) sitting at the front with TAG chair Tiffany Svensson. Sandy has spent the last two meetings in the gallery with the rest of us plebes and that's exactly where she should be sitting, not at the front. What the hell is she doing...supervising or micromanaging her own appointee as chair of TAG???

Two new TAG members were introduced last evening namely Katharina Richter and Dustin Martin. They both live in Elmira, Woolwich Township whereas another TAG member Susan Bryant lives in neither. Both new members certainly seem well qualified although I believe that both have zero experience regarding Uniroyal and Elmira issues. That they will eventually (years) get up to speed is likely if they become keen and continue on. It will take years partly due to the history and complexity of the issues and also due to the reduced number of meetings per year. Unfortunately last night's meeting was incredibly dull and somewhat technical with lots of acronyms being thrown around. The dullness is partly due to the lack of input from MOE and Lanxess. While UPAC and CPAC have suffered in the past from too much time taken up by Conestoga Rovers on behalf of Uniroyal/Crompton/Chemtura the opposite is currently happening.

Tiffany and TAG have messed up again. The earlier messup was accepting the 5.9 inch (15 cm.) only sampling and later excavations on the north-west side of the Stroh property. This one is accepting Lanxess's (Ramin's) self-serving refusal to do soil testing further south on the Stroh property in and around the Stroh Drain, Ditch and Berm (SDDB). This was done despite TAG member Sebastian Seibel-Achenbach's disagreement.

David Hofbauer advised that in his opinion the MOE in their comments to Lanxess were attempting to get more data into the Risk Assessment process unless Lanxess/GHD can better explain why it isn't needed.

Jason Rice replied to Tiffany Svensson's request for information regarding Method Detection Limits (MDL). Clearly ALS labs testing is inferior to both the MOE labs and probably Maxxam who have been used for years by Uni/Crompton/Chemtura. When I say inferior I strongly suspect intentionally inferior as they (ALS) were likely contracted to do the less expensive and less accurate testing and inherent higher MDLs by Lanxess all in the name of saving money AND in the name of generating many more NON-DETECTS (ND) in the soil and sediment samples in the downstream Canagagigue Creek. This is what occurs when the MDLs are higher than the criteria and health guidelines. Instead of more exceedances of criteria in the samples, simply more ND are generated. Talk about a win-win for Lanxess and a lose-lose for the public and the environment. The extent of gross and toxic contamination in the Canagagigue Creek is once again minimized thus lowering cleanup costs dramatically.The scam and sham of the Elmira cleanup continues. Bless you all politicians, fellow travellors and self-serving bureaucrats for keeping your heads down and letting them get away with it.

MORE ABOUT YESTERDAY'S POST AND TODAY"S TAG MEETING

First of all today's TAG meeting at 6:30 pm. in Woolwich Council Chambers will have a detailed discussion regarding the Ministry of Environment's (MOE/MECP) written comments on both Contaminants of Potential Concern (COPC) and on the Canagagigue Creek Conceptual Site Model (CSM). Lanxess and their consultants GHD have been working on these two matters for some time now.

Rather than go through the MOE's comments in detail I am going to boil it down to the basics. Lanxess, the proud owners of a still disgustingly contaminated site (i.e. Uniroyal in Elmira) do not wish, like every owner before them, to spend one nickel more than absolutely necessary on the cleanup of either their own site or of the Elmira Aquifers and the downstream Canagagigue Creek. The Elmira cleanup has for decades made a mockery of the politicians mantra that "Polluter Pays". All the successive owners of the Uniroyal Chemical site including Uniroyal themselves played the system shamelessly.

The MOE/MECP have touched on only a couple of the games that have been played over the decades. This includes the failures of the Upper Aquifer Containment and Treatment System (UACTS) to fully hydraulically contain the south-west corner of the site much less to contain the shallow aquifers discharge to the creek throughout the site. They have also advised that on page 2 of their July 30/19 document that Lanxess did not evaluate COPC's in groundwater "because the groundwater COPC evaluation was reportedly documented in the Annual Monitoring Report No. 28". "However, AMR No. 28 does not specifically identify the groundwater COPCs."

Elmira citizens and the environment have been on the receiving end of these "errors", falsehoods and deceptions for thirty years now. It is long past time for the games to stop and the truth to be told by both polluters and regulators.