THE SHAME OF LONG-TERM ELDER CARE IN ONTARIO

Last week's Waterloo Region Record carried the following opinion piece titled "Long-term care was a crisis waiting to happen. We must fix it now". The article was written by Karen Galer a retired Registered Nurse. She categorically states that the current Covid crisis "...is highlighting these inequalities, exposing our society's dark side. The inequalities that she is referring to are the higher death rates in the U.S. due to Covid amongst Black people and Latinos. here in Canada it is the astronomical death rates occurring in some of our nursing homes.

She states that standards in long-term care homes have eroded over the decades with poorly paid staff, improperly trained staff, and a lack of personal protective equipment. Furthermore inspections are few or non-existent. That is outrageous that for profit nursing or retirement homes are not routinely inspected without advance notice being given.

More than twenty years ago I voiced my displeasure both to family members as well as to the institutions involved regarding my parents care. I even lodged a formal complaint to the Waterloo Regional Police in regards to a serious wounding incident at Sunnyside Home in Kitchener. Nothing, absolutely nothing was done. Apparently conditions have gotten worse not better in the interim. We can only hope that our decision makers themselves end up in one of the worst of these institutions. At that point their regrets will not help them.

CAPITOL PAVING & THE AGGREGATE INDUSTRY

I am aware of three victories of citizens over the aggregate industry and their lobbyists, influence, and connections in high places. I believe that the first was several years ago in Puslinch, followed by the unsuccessful Hunder Pit between Winterbourne and Conestogo and finally the proposed West Montrose Pit which Tony Dowling and Bridgekeepers rebuffed. So as not to demonize all aggregate companies and or proponents of these pits I will say that I did see and hear first hand the opinions and positions from Mr. Honsberger (proponent) of the proposed Hunder Pit at the OMB (Ontario Municipal Board) hearing held in Woolwich Council Chambers several years back. I found him to be an honest and straightforward gentleman.

Today's Waterloo Region Record carries the following article titled "Opponents of proposed gravel pit digging in". Former Woolwich Councillor Bonnie Bryant and others are quoted in this article both for and against the proposed gravel pit. I believe that their positions are both reasonable and sound. The pit in my opinion is to be located far too close to the village of Maryhill, its homes and businesses. I also need to comment regarding Ms. Bryant. She was in my opinion by far the most honest and smartest councillor during her term on the Todd Cowan council. That said I did personally like Al Poffenroth for a number of reasons although I suspect that his talents and abilities may have been past their "best before" date.

The only advice I might have for Ms Bryant and her neighbours is to contact Tony Dowling (Bridgekeepers & Gravel Watch Ontario) as well as Della Stroboscher (Conestogo), Jan Huisson and Gord Haywood for advice in their upcoming battle.

WATERLOO REGION RUBBER WORKERS HEALTH DAMAGES BELATEDLY ACKNOWLEDGED

Ten days ago the Waterloo Region Record published the following story titled "Former rubber worker's cancer linked to his employment". This past January the Ontario Workplace Safety and Insurance Board (WSIB) advised his family in writing that Mr. Stojsic's death in 2010 was "work related" following nearly three decades of his exposure to rubber, asbestos and lead. I will add that he was also likely exposed to lots of solvents in the air as well. Surprise, surprise, Mr. Joseph Stojsic's brother, Edward, also worked for decades in the rubber industry and he died three years ago courtesy of colon cancer.

The rest of this article written by James Jackson advises readers that to date only a very few (31) out of the three hundred denied claims ordered to be reviewed by the WSIB have been reversed. Statistics on the new claims filed since the expose in the Record are not available.

The WSIB under orders from successive provincial governments have kept claims low via psuedo science, demanding unreasonable "proof" of work related illness and by simply having persons in charge of the WSIB (like Liz Witmer, former MPP) who are long on smoothness and puffery while short on emotion and or reasonableness. The reasons for keeping successful claims low is simply costs. If you as a senior bureaucrat in the WSIB are ordered directly by your boss (and indirectly by the province of Ontario) to decrease costs by ten percent, while what easier method is there than to reduce your percentage of successful claims for financial compensation for work related illness and disease? Both sad and pathetic.

So here we are today and our federal (and provincial) governments are cheerfully throwing money at employees, wage earners, businesses, students, self-employed etc. in relation to Covid 19 economic impacts. Please notice that there are no high barriers, extensive interviews, demands for more and more documented proof to back your claim/application. You have lost money due to Covid so here you go right away.

Guess what folks? Where do you think this money is coming from? Is it actually "real" money backed by anything at all such as an asset of some sort? Partly where it is coming from is from the millions of Canadian citizens who have been robbed, lied to, and denied services and supports over the last fifty years by both our federal and provincial governments. Those governments have charged exorbitant taxes throughout while nickel and dimeing the sick, the elderly, the disabled, workers, minorities, women, indigenous groups etc. They then have distributed much of those monies to the powerful, wealthy, influential and especially to those viewed as friends of the current government.

This current crisis directly involves approximately 35 million Canadians. It's easy to screw hundreds to thousands of people out of a population of many millions. That said right now our thieving, lying governments are treading very softly and carefully. If they choose to screw all Canadians simultaneously there will be an awful price for them to pay and they aren't yet willing to take that risk.

CHEMTURA (WITH "PROFESSIONAL" HELP) STAYED UNDER THE RADAR IN GUELPH

Well why would we expect anything less from that company? From Dominion Rubber, Uniroyal, Crompton, Chemtura or now Lanxess; whatever their name and presumably wherever their location they are leaders: just not leaders in ethics, transparency, accountability, or understanding that the public who live and work near their facilities are stakeholders with rights. Yes I know that they and every other industrial concern have worked and paid for political influence via lobbying and donations and they have been successful in obtaining a favourable to themselves, legislative environment.

Last Friday I posted here an article titled "Is that rotten fish I smell or is it simply disgust at the "Lets make a deal" cleanup criteria of the Ontario M.O.E.?" In the last paragraph I suggested that there appeared to be some procedural problems as to date I had been unable to locate either the Phase Two Environmental Assessment (EA) nor a Remedial Action Plan for the Chemtura site in Guelph. Well that still stands however I have been able to locate (damn-in my own files ) an April 10, 2017 report from Peritus Environmental titled "Summary of SubSurface Investigations 120 Huron St. and 0 Oliver St., Guelph, Ontario. Those two addresses of course are the Chemtura Canada addresses in Guelph. This "Summary" does advise that GHD consultants on behalf of Chemtura did produce both a Phase One and a Phase Two EA, both dated 2008. This is a little odd as the Phase One EA that I have produced by GHD is dated December 2007. Oh well it's at least close, date-wise. Keep in mind that Peritus are the company that did the Risk Assessment (RA) in 2016 on behalf of the former Varnicolor Chemical site in Elmira, now known as Elmira Pump. I was promised the completed RA and as yet have not received it. Elmira Pump assure me that the Ontario MOE/MECP are to blame as they desperately want it in order to obtain a Record of Site Condition (RSC) from the MOE in order to sell part of the site for above ground commercial storage. I am disappointed with this document from Peritus. It's likely not any worse than anybody else's but I, through my wife, know the owner/founder. I've actually had him in my home four years ago giving myself, my daughter, Dr. Dan Holt and Rich Clausi a tutorial in regards to the Draft RA. I found the RA quite acceptable. Also keep in mind that GHD (formerly CRA) are the decades long consultants to Uniroyal and all their later iterations.

I don't care for gilding the lily. I don't like reports whose text does not scrupulously adhere to the data found and presented. One minor example are sentences such as the following: "The GHD investigations concluded that all soil and groundwater samples satisfied the applicable Ministry of the Environment and Climate Change (MOECC) generic Site Condition Standards (SCS) ...with the following exceptions:...". I swear to God they then on the next page list volatile organic compounds, BTEX compounds, metals, semi-volatiles, and pesticides both in soils and groundwater. What the hell! There is also simply too many references to things like "low level concentrations" of contaminants either in soils or groundwater. "Low level concentrations" my old and wrinkled butt! Soils are HIGHLY contaminated with multiple different metals, some above criteria such as lead, zinc, cadmium, mercury, and with lots more toxic metals below criteria such as arsenic, barium, chromium, cobalt, copper and vanadium. Other soil exceedances include acenapthylene, anthracene, benzo(a)pyrene, fluoranthene, phenanthrene and numerous others. Groundwater is the same with some contaminants above criteria such as toluene, vinyl chloride, trichloroethylene, DCA, DCE, some petroleum hydrocarbons, dissolved metals (chromium, cobalt, copper, lead, selenium, vanadium, zinc), and NITROSOAMINES such as NDMA above criteria with NDEA, NDBA, NMEA, NMOR present below criteria. Other Volatile Organic Compounds present but below criteria include benzene, carbon disulphide, dichloroethene (DCE), ethylbenzene, xylene, methylnapthalene. Finally there are other toxic compounds in groundwater present which do not as yet have criteria such as methylphenol.

It is my opinion based upon technical reports written by Chemtura's consultants that this site was a disgusting, contaminated mess for decades. It is difficult to believe that zero residential neighbours were not impacted. It is only fair to also add however that some of this contamination may have been present prior to Chemtura's (Uniroyal) alleged purchase in 1988. Apparently there is evidence of much earlier occupation of the site by Uniroyal (1971) and perhaps even Dominion Rubber earlier than that. Other industrial companies also occupied the site.

Lastly there were serious excavations ongoing a couple of years ago. How much they cleaned up I currently do not know.

RIGGING AN ALREADY RIGGED GAME - RISK ASSESSMENTS (RA) IN GUELPH & OTHERWISE

First of all the gobbledygook! QP are required for all the paperwork (busywork?) required by the Ministry of Environment. QPs are Qualified Persons allegedly. Then you have the previously mentioned RA, SSRA, MGRA, LSRA. New acronyms in the April 2014 Prelim Remedial Action Plan include RAP, PSS, RMM, ORC, RSC, ISCO, RMP, PSF, ESR and on and on. These are used simply to make the report essentially illegible to any lay persons , "citizen scientists", or simply concerned citizens wanting to read these documents. That is likely done intentionally in order to make the QPs feel like bigshots as well as to make it easier for QPs, MOE bureaucrats and woefully ignorant politicians to disparage and minimize citizen comments and concerns. Talking in gibberish/gobbledygook usually is all that's required to succeed.

The purpose of Risk Assessments (RA) is to reduce cleanup costs to the polluter or current owner of the site. In the IMICO case we are talking the City of Guelph who presumably will build in the cleanup costs to the developer of the proposed low income rental units which buildings will be precariously situated on less contaminated lands while the most contaminated lands can thus have their cleanup requirements reduced because the rental unit buildings will be twenty to fifty (?) metres away from them. Of course there won't be a concrete block wall erected around these more contaminated lands.

My overall impression is that the MOE/MECP and the province of Ontario are permitting reduced cleanup criteria and thus costs in exchange for more paperwork and monitoring, risk management measures (RMM) and profits to the consulting industry. In other words polluters and owners of contaminated sites can buy reduced cleanups from expensive consulting companies with the MOE providing cover by pretending to be a neutral, professional, and honest broker of the process. They fail on at least two out of three of those attributes. It's a scam folks and we are the ones being scammed. Grossly contaminated sites are not being properly remediated but because all the parties (players) are on side, we the public, including local homeowners and property owners, are left flapping in the wind. The public interest is intentionally emasculated. Public consultation yet again is accomplished (i.e. destroyed) via lip service and bureaucratic bullshit.

Human health and environmental health continue to be compromised for the financial benefit of others. The process is beyond deceitful.

IS THAT ROTTEN FISH I SMELL OR IS IT SIMPLY DISGUST AT THE "LETS MAKE A DEAL" CLEANUP CRITERIA OF THE ONTARIO M.O.E.?

I've got money, power, influence, and friends in high places so you'd G D better discuss these onerous cleanup criteria with me, my lawyers and my consultants or else I'll see you in court for the next twenty years. Hey "we've got the best judicial system in the world...that money can buy" and that's not by accident. There is never any hurry for judges and courts and especially for the wealthier parties attending court. Courts are and always have been both playgrounds for the rich as well as whips to punish their inferiors (i.e. less well off).

So you have governments who essentially set up their own ministries to fail. No government, federal or provincial, ever want their biggest supporters and donors going bankrupt (or even being seriously inconvenienced) by an environment ministry under their control. Therefore it's all about well off companies navigating, stick handling and basically skirting the more onerous and expensive legally mandated cleanup criteria. To enable this the federal and provincial governments have passed legislation allowing a plethora of options for those with the time, money and expert talent (consultants) at their fingertips. For the rest of us or even for small, family owned business, you are essentially SOL. If the M.O.E. goes after you, you'd better behave or just like Severin Argenton of Varnicolor Chemical, the M.O.E. will get up on their big boy hind legs and crush you. He went to jail for doing a fraction of the environmental damage that
Uniroyal Chemical just down the road did. None of those @#$%&*+ have ever seen the inside of a jail cell.

Generic soil and groundwater criteria. Risk Assessment (RA) determined criteria. Limited Scope Risk Assessment (LSRA) determined criteria. Site Specific Risk Assessment determined criteria (SSRA). Modified Generic Risk Assessment (MGRA) determined criteria. "existing evidence of elevated background concentrations in the Guelph area" thus permitting less cleanup. Numerous different Tables allegedly for different criteria based upon environmental sensitivity such as distances from surface water, land uses, political affiliations, political donations etc. O.K. I may have exercised a tad of literary exaggeration with those last two. In fact it is my opinion that our governments are much more subtle and careful not to demonize themselves to the public especially if elections are upcoming.

Then of course there appear to be numerous options for "do overs". Well at least for those with the time and money. Or even better with municipal governments (say Guelph for example) who are using someone else's money (i.e. tax money). It sure appears that they did Phase 1 and Phase 2 Environmental Assessments (EA) for IMICO in February and April 2014 but also a Phase 1 and Phase 2 EA in December 2007. What the hell is that all about? Then they also did a "Preliminary Remedial Action Plan" in March 2008 followed by...you guessed it...a "Preliminary Remedial Action Plan" in April 2014. Didn't they like the first one? Was it too onerous for their liking?

Meanwhile there appeared to be some logic and reasoning behind starting with a non-invasive study and investigation of a suspected contaminated site via a Phase 1 EA. Then if the Phase 1 study brought forth greater evidence and likelihood of environmental impacts or infractions, then a Phase 2, more invasive (i.e.digging and drilling) EA would kick in. If indeed exceedances of mandated criteria were determined than a Remedial Action Plan would be next. That at first blush sort of is the path that the IMICO site has followed. The Chemtura Canada path over at 120 Huron St. in Guelph seems weirdly different. There is a Phase 1 Environmental Assessment (EA) completed in December 2007. Major excavation and cleanup occurred a couple of years ago. Where the heck is the Phase 2 EA as well as the Remedial Action Plan? Did the M.O.E. or Chemtura negotiate some sort of confidentiality agreement between themselves?

These previous five paragraphs all lead to my title above.

MORE "MANAGEMENT" OF CONTAMINATED SITES IN GUELPH & WATERLOO REGION

In Sarnia they refer to it as the "chemical valley". Mr. John Jackson of Kitchener, decades ago, referred to Elmira's "mini chemical valley". This included Union St. and the many chemical companies on it such as Uniroyal Chemical, Nutrite, Sulco, and Varnicolor Chemical. The point in both instances was to group all the offenders together ostensibly as part of the planning process to keep residential homes far away. Of course that didn't work in Elmira and to this day developers continue to lobby Woolwich Township trying to build low income housing right across from both Sulco (CCC) and the former Uniroyal (Lanxess).

The real advantage to polluters of course is being able to hide under the umbrella of multiple local polluters. Especially in Elmira it was so easy for Varnicolor to blame the neighbours for odours and other unpleasant problems. Well the more I look the more I learn about the sordid pollution history of this area in and around York Rd. and Victoria Rd. in Guelph. The list of industrial companies who may have taken environmental shortcuts, possibly legal, possibly not, is extensive. Fibreglass Canada, Guelph Stove Works, Imperial Oil, Chemtura Canada, Biltmore Hats, Owens Corning, Hart, Huntsman, IMICO, plus three very handy and local landfills for these companies to dump their chemical wastes in alongside the Eramosa River. Once again residences are sprinkled throughout this heavily industrialized area. This is an excellent way for polluters to muddy the waters. Just point to every nearby other potential polluter and blame them.

Once of course you have been formally fingered as a culprit, the gamesmanship really begins. Scoping is a favourite. This is almost the opposite of polluters grouping together but of course is incorporated defensively without so much as a blush by polluters and their consultants. The consultant undertakes to study the soils and aquifers (groundwater) on their clients site. Of course they only have legal permission to dig, drill and test within the property boundaries of their client. Hence they are very careful not to only test on their own property but even the maps they produce would make you think that the world is flat and literally ends at their property borders. In Elmira Uniroyal produced maps showing groundwater contaminant plume maps that had extensive exceedances of multiple chemicals that magically ended at their borders. While the drinking wells to the south had been shut down and everyone knew they were at least a major contributor, you should have seen the gamesmanship on the east side of their site. No way were they going to admit that their liquid wastes had actually flowed from their waste pits located right beside their eastern property line, over that line onto the farmer's fields. There were rumours for decades about annual Christmas trips to that farmer with an envelope containing either cash or a cheque.

Meanwhile back in Guelph I have noticed something similar. The maps produced on behalf of IMICO (i.e. City of Guelph) are also a tad deceptive. Again it appears as if the world ends at their border with Beverley St. Then, bizarrely in hindsight, the maps with the Supplemental Soil Vapor Investigation (again on behalf of the City of Guelph) is for the properties south of York Rd. (i.e. Hayes, Kingsmill, Menzie, Audrey, Lawrence & Victoria Rd.) and they appear to start and stop at York Rd. In other words there is nothing to the north. Well guess what. If one can locate a much more comprehensive map one realizes two things. Firstly there are homes on Smith Ave., Hayes, Kingsmill and Audrey St. NORTH of York Rd. as those streets go right up to Beverley St. Secondly if there are exceedances of toxic soil vapours south of York Rd. then sure as hell there are exceedances at the above mentioned streets north of York Rd. and even closer to the former IMICO site. Possibly a pretty smooth move especially if there has not been any soil vapour testing done there. That's what I would call scoping.

Lastly do not forget that there are a few residential homes on both Beverley St. and on Stevenson St. Has any testing of soil, groundwater or soil vapours been done on their properties and if not, why not? As long as our governments and regulatory agencies are willing to play ball, there are a thousand ways to minimize and reduce the proper cleanup and remediate damage done to third parties by toxic pollution. It really is all about who has the money and the power and finally who is in charge of the cleanup and of the so called "enforcement" of our environmental laws. It has become a very cliquish, insular and self-serving cabal in my opinion.

SACRIFICING THE VULNERABLE IN ONTARIO TO THE ALL MIGHTY DOLLAR

Much has been written and said lately about the province of Ontario sacrificing our elderly nursing home residents to the ravages of Covid-19. The articles and opinion pieces in the Waterloo Region Record make it clear that this is not a recent phenomenon. Under funding, staff shortages, poor working conditions and lack of personal protective equipment have all been ongoing for decades. Shame on all of us but most especially to private nursing home owners, and the Ontario governments over the decades for their token supervision and inadequate funding.

I am going to suggest that there is yet another group of vulnerable Ontario residents who have also been sacrificed to the all mighty dollar. That would be residents living near polluting industries, landfills, sewage treatment plants etc. More specifically I would suggest that residents living near Uniroyal Chemical and Varnicolor Chemical in Elmira, Canadian General Tower, Ciby-Geigy, Northstar Aerospace in Cambridge and finally those living near the former IMICO in Guelph have been sacrificed one way or the other. One should also include those Walkerton residents who were sacrificed due to cost cutting and therefore enhanced pretend oversight and supervision by the Ontario Ministry of the Environment. These sacrifices include their health from poisoned air, drinking water, vapour intrusion and the natural environment around them. Of course this is only a small fraction of the citizens and their families in Ontario who have been sacrificed for the sake of the all mighty dollar.

I would also suggest that sometimes those citizens being sacrificed on the alter of reduced deficits/fiscal austerity were victimized unintentionally and without malice. Many others have been sacrificed on the alter of right wing ideology. Trickle down economics, fiscal austerity, "open for business", "slashing of red tape" and just plain bias in favour of the wealthy and powerful donors to the Liberal and Conservative parties comes to mind. What right wing party is going to campaign to their base on the benefits of the principle of "polluter pays". None. Yes they will, when pressed, give lip service to that principle. The reality is that polluters routinely walk away from their sins by abandonment of properties, sales to third parties, and /or mickey mouse cleanups with the collaboration of our very own MOE/MECP.

This collaboration includes municipal and regional governments who turn a blind eye to so called cleanups of contaminated properties that literally take decades to centuries to accomplish. Uniroyal Chemical (now Lanxess Canada) in Elmira did the bulk of their on-site toxic waste disposal from 1943 until 1970. For the last decade of that time, local citizens and some individuals in authority were telling governments and their agencies about the destruction of Canagagigue Creek, the air and potentially the groundwater. Half a century later (1970-2020) the site is still a toxic mess. Much has been done but in fact more has been said than was ever done. The Elmira Aquifers are still polluted and the best estimates now for their cleanup are 2050-2060.

DELAY and DILUTION are polluters and governments best friends! The longer you don't spend money on a contaminated site, the less pollution remains on it requiring cleanup. Dr. Gail Krantzberg, McMaster University, advised CPAC (Chemtura Public Advisory Committee) in 2012 that pollution on an industrial site tends to migrate. Some goes directly into the air, some contaminates and travels via groundwater and even contaminated soil produces toxic vapours which travel through the soil pore spaces contaminating other areas. Lastly of course is the most obvious and most abused namely dumping via "spills", leakage from lagoons, and overland travel directly into nearby surface water bodies.

These rivers and streams include the Canagagigue in Elmira, the Grand River in Waterloo, Kitchener, Cambridge and the Eramosa River in Guelph. That said most polluters prefer to at least pretend that they aren't dumping directly into these water bodies. They pretend that the soil between on-site lagoons, waste pits etc. and the nearest creek/river can magically detoxify liquid wastes. They pretend that gosh they didn't realize that contaminated groundwater likely flows directly towards and then discharges into the nearest surface water body.

In Cambridge, trichloroethylene (TCE) flowed underground via groundwater from Borg-Warner and Northstar Aerospace on Bishop St. and eventually discharged into the Grand River. Several hundred homes of course were situated between these polluting companies and the Grand River. The residents of those homes suffered and some continue to suffer health effects because of TCE vapour intrusion into their homes. In Elmira, grossly contaminated groundwater flowed from Uniroyal Chemical directly into the Canagagigue and from Varnicolor Chemical most likely into Landfill Creek first which then discharges into the Canagagigue Creek. Fortunately no homes were situated between the offending companies and the Creek.

Guelph however shares a similar stratigraphy and geographical land useage with Cambridge. There are several hundred homes located between IMICO (and possibly other polluters) and the Eramosa River. There are known toxic soil vapours in this community currently. The groundwater flows under these homes on its journey to discharge at the Eramosa River. This is not rocket science yet all our municipal, regional and provincial authorities have delayed necessary cleanups for three decades while gambling maybe not that local residents won't get sick but that they won't attribute their health issues with their local contaminated site(s). This to my mind may be intentional sacrifice of others for personal gain. Money is usually the motive for these kinds of behaviour. Somebody will be making money on the final redevelopment of the IMICO site (and others?). Meanwhile the general taxpayers in Guelph have been paying taxes for decades towards maintenance and studies of this site while the toxic effects have flowed downgradient towards unsuspecting residents.

Have they been lucky? Have some paid a terrible price already or will their future health and enjoyment of life be devastated? The public need to know these answers and most especially do the local residents near the York Rd. and Victoria Rd. neighbourhoods.

YET MORE REPORTS/BULLETINS COMING THROUGH REGARDING ALLEGED IMICO CLEANUP & REDEVELOPMENT

What a truly perverse and off the rails system. It's about three things first and foremost. The first is MONEY, the second is Money and the third is money. You can use different words if you like such as cost, return on investment, cost effectiveness, expenses, biggest bang for the buck, cost and complexity considerations etc. but what is first, foremost and of utmost concern to all parties is how little money can be spent to at least give the cloak or appearance of due diligence and substantial remediation of the on-site soils and groundwater. The reality is that a partial estimate of $13 million dollars was advised by the consultants simply to fully remove the contaminated soils on the former IMICO site. This estimate does not even start to address the contaminated on-site groundwater. Note I have twice mentioned "on-site" impacts. In fact the April 2014 "Preliminary Remedial Action Plan" by DCS (consultants) clearly states that there are recognized and acknowledged off-site impacts caused by contaminated groundwater leaving the IMICO site. Those impacts are known at York Rd. and based on the flow direction of the aquifer(s) most likely go through the Hayes, Kingsmill, Audrey and Lawrence Ave. properties towards the Eramosa River.

Strangely there have been subsequent (2018/2019) newspaper stories as well as bulletins on the City of Guelph's website that advise that the whole on-site "cleanup" of both soils and groundwater can be done for a mere $3-4.5 million. Wow that is truly a bargain basement cleanup price especially by the consultants partial estimate of $13 million ...oops actually $12,800,000. How did they do that? Well folks there are no magic tricks to actually clean up toxic soil and groundwater contamination. Fortunately however for polluters, regulators, consultants & more there are "management" tricks condoned/promoted by the Ministry of Environment/Ontario/City of Guelph such as redefining standards, redefining land uses, redefining acceptable cleanups and lastly redefining property boundaries. Minor issues such as minimizing exposures, exposure routes, length of exposures can all be massaged via risk assessments and other "management" methodologies.

In fact it has been suggested that the former IMICO property can be divided into two properties and the most contaminated areas on the south-east corner nearest to the Kingsmill, Audrey, Lawrence, Victoria Rd. properties can thus be designated for less stringent cleanup standards than the rest of the site. Now that's what I'm talking about in regards to "management" tricks. Anything to save a nickel at your expense and to hell with the downgradient neighbours.

Lastly can you also believe that the proposed redevelopment will be multi story rental accomodations? The plan is for the City of Guelph and the developers to access federal money to assist in the building of affordable housing for those households deemed to be low-to-moderate-income households. Hmm maybe that's a good idea so that those low to moderate income folks aren't financially able to sue the City or developers down the road for potential health implications. So let's not sugarcoat this just too much. The federal government has money to give and presumably the buildings will be on the better remediated soils while, I don't know, swings, walking paths, sandboxes can be put on the lesser remediated areas. Gotta love this system folks. Certainly friends of City Hall and the provincial and federal governments do.

THE BIG PICTURE IN THE GUELPH NEIGHBOURHOOD NEAR YORK & VICTORIA RDs.

The request/demand from "me again" i.e. Barry that I don't post about this neighbourhood and the plethora of environmental risks that they face is refused. Furthermore his whine about "wannabe scientists" and environmental activists is beyond pathetic. Governments and their agencies (MOE/MECP etc.) are far more adept at covering up crises and scandals than they are at either avoiding them or fixing them after the fact.

This neighbourhood has proven soil and groundwater contamination to the north, south and west of their location. To the east (i.e. Victoria Rd.) as per the recent comment from "me again" i.e. Barry there may be Hart/Huntsman/PDI. I personally recall from many years ago (decades?) news articles etc. about environmental issues at Hart Chemical. Huntsman not so much and PDI only recently in regards to plastic pellets discharged into the Eramosa River. I've also seen a followup article praising PDI's cleanup of those plastic particles. Therefore at this time lets hope that the known contamination is "only" to the north, west and south.

North- IMICO West- Site 4 (former landfills & major cleanup done at Chemtura on Huron St.) South- again the Site 4 former landfills on the north side of the Eramosa River.

Many years ago there was an article in the Globe and Mail about PCBs leaving a former General Electric site in Guelph. The plant was opened in 1954 and sold in 1987 although GE retained the responsibility for the contamination. Conestoga Rovers allegedly blew the whistle to the MOE and others when they discovered that the PCB treatment plant they were monitoring had an equipment failure that permitted a discharge of 78 parts per billion PCBs into the Guelph sewer system. Obviously PCBs have been found in the natural environment in and around Guelph before and just as obviously even well after their discovery they were escaping into the natural environment. This speaks to my comment the other day that most toxic contamination whether air, ground/surface water or soil continues to migrate if not removed or contained in a secure container with backup capabilities.

The Menzie, Audrey, Lawrence, Victoria Rd. neighbourhood has soil vapours containing trichloroethylene, vinyl chloride, tetrachloroethylene and dichloroethylene at above provincial health and safety guidelines in some samples. Presuming that the neighbours have not been poring these toxic chemicals into their backyards for decades, one can safely assume that it is nearby industries who unsafely disposed of these toxins on their property and that they have migrated into this neighbourhood over the decades. Hence "me again" demanding that I wait to read "all" the studies and also wait for either the province (MOE/MECP) or the City of Guelph to "complete" their studies and investigations is ludicrous. These local citizens are likely suffering ill effects now and the wait and delay of at least three decades is unconscionable. Vapour intrusion may be a more recently discovered phenomenon ( 30-40 years ago) than say groundwater contamination (late 1800s in Europe) but it is just as deadly or more so. Oh and by the way we don't know the status of soil vapours to the west of say Hayes Avenue because those soils have not as far as I know ever been tested. Also my map appears to show zero testing on Kingsmill Ave. and only one location sampled on Hayes Ave. Maybe the most recent sampling earlier this month has made up for these gaps. Rest assured however that NOT testing is a proven and reliable method of scoping or decreasing the size of environmental calamities.

I agree that most likely I have not been privy to "all" the studies and reports. The MOE/MECP are masters of keeping bad news to themselves. I have been chasing both MOE and consultants' reports about Varnicolor Chemical in Elmira for decades. The reports that I have read concerning this Guelph neighbourhood, just like the ones for decades in Elmira (1965-1988) prior to the Elmira November 1989 "water crisis", are all very clear. This Guelph neighbourhood is bombarded with toxic contamination of multiple kinds (PCBs, VOCs, PAH, PHC, metals etc.) likely from multiple sources and they should have had indoor vapour testing decades ago. Past delay was a heartless political game. Further delay is criminal.

SOIL CONCENTRATIONS INCLUDING PCBs IN GUELPH NEIGHBOURHOOD

PCBS are both notable and highly toxic. They have been implicated in a huge number of human health issues in North America as well as around the world. Great Lakes fish have them as does some wildlife in the Artic. I believe that similar to dioxins/furans they can be transported readily in the atmosphere. Perhaps behind the scenes some of our authorities may think that reporting on wildlife or human exposure to them is funny (see yesterday's comment section after my post). I sincerely hope that that comment by a disgruntled, former federal employee reflects only his bad attitude and not that of any of our authorities.

The prizewinner for concentrations of petroleum hydrocarbons (PHC) in soil certainly seems to be 137,000 parts per million as found in Test Pit 05 not too far from Hooper St. (nearer the west end of the stretch being studied along the Eramosa River). That was the F3 fraction of the PHCs. Unfortunately PCB detections may well be being diminished by ridiculously high Method Detection Limits (MDLs). Causing PCBs to be only discovered in soils if their concentrations exceed anywhere from one to three parts per million is ludicrous. This is especially so when three out of the four Guidelines presented are between .3 and .35 parts per million and the fourth is at 1.1 part per million. Obviously PCB exceedances will not be found when the MDLs exceed some or especially all of the Guidelines.

Despite this PCBs were detected at Test Pit 06, Borehole 16, Borehole 17, and Borehole 19. They are accompanied along this area by some incredibly high levels of Lead (34,800 parts per million (ppm)). The standard for lead in soil is 120 ppm. Zinc has been found at over 3000 ppm with a Guideline/standard of 340 ppm. Polycyclic aromatic hydrocarbons have been found in the soil in some areas between 100 and 200 times their standards. Cadmium in the soil has been found at up to 7 times its Guidelines.

Perhaps sometimes our authorities become overwhelmed with both the number of contaminants, the number of different standards based upon things like different soils, usages of soils from agricultural to parkland or residential, commercial; distances from surface water bodies etc.and even if the water is potable or not. Perhaps they forget one basic point. Human beings were never designed to come into contact with man made chemicals, especially the more toxic ones. Contact includes ingestion, inhalation and even just skin contact. Surrounding where we live, intentionally or otherwise, with dozens to hundreds of toxic chemicals is just idiotic in the extreme. All these contaminants move, one way or the other. Eventually exposure to them is a given if they are right where we live. Either move the people or get rid of the contamination.

SO HOW BAD IS THE CONTAMINATION JUST SOUTH OF THE ALREADY AFFECTED RESIDENTIAL NEIGHBOURHOOD IN GUELPH?

It is very bad. It's not just the occasional very high soil or groundwater concentration, it's the sheer volume of numbers of contaminants either above some or all of the soil Guidelines or it's the numbers of contaminants above some or all of the groundwater Guidelines. It's also the sheer number of contaminants present in the soil or groundwater sometimes not even counted because of admitted high Method Detection Limits (MDL). In other words the compounds are likely present but the particular sample has a very high MDL which in fact exceeds the Guideline number. Hence it shows up as non-detect at the very high Method Detection Limit. Credit does go to ALS Labs in Waterloo for highlighting these problematic readings in the 2015 report produced by MMM Group on behalf of the City of Guelph.

Some of the surprising (to me) contaminants include vinyl chloride, benzo(a)pyrene, cobalt, F3 petroleum hydrocarbons, dichloroethylene, F4 petroleum hydrocarbons, chrysene, fluoranthene, and lead. Less surprising is trichloroethylene. It seems to be the standard toxic chemical implicated in cases of vapour intrusion into homes. It's concentrations while sometimes in excess of some or all of the Guidelines, nevertheless are not as ridiculously high as they are or have been at IMICO, just north of the residential neighbourhood of Menzie, Audrey, Lawrence etc. that are bounded by York Rd. to the north and Victoria Rd. to the east with the Eramosa River to the south. These other contaminants in groundwater include metals, polyaromatic hydrocarbons (PAH) and volatile organic compounds (VOCs).

To date I have not spent as much time examining the soil concentrations as I have on the groundwater concentrations. Nevertheless a pattern does seem to be appearing. Lead, zinc and cadium seem to be regularly above all the soil standards presented in the report. Also PAHs are a huge problem in the soils along the north side of the Eramosa River (i.e. just south of the previously mentioned neighbourhood which is located towards the east end of what is referred to as Site 4 which starts near Wyndham St. and progresses across to Victoria Rd. Also keep in mind that to date I have only seen soil vapour results for the neighbourhood on the east end of this long stretch along the Eramossa River. Again F3 petroleum hydrocarbons (PHC) are the worst offenders of the four fractions known as F1, F2, F3 and F4. F3 concentrations are regularly in the thousands of parts per million (ppm) in the soil with the occasional astronomical concentration. Guidelines are between 240 and 1700 ppm.

As indicated in the text of the report, almost the entire length described along the Eramosa River contains industrial wastes along with normal municipal wastes (i.e organics). Many of these wastes such as slag can likely be easily traced back to their industrial sources. The ten test pits dug along this route, along with the borehole logs for the monitoring wells, describe the type of soils as well as the normal landfill wastes combined with industrial wastes that are present. The monitoring well borehole logs also describe the concentrations of combustible soil vapours that are in the subsurface and at their varying depths. It is not a pretty picture.

I guess that I'm mostly appalled at the overall state of contamination in, near, and around so many residential homes. All of these technical reports whether merely five years old or nearly thirty years old should have long ago triggered our authorities into action to protect citizens living in the area. I am also appalled by the numbers of different contaminants whether PCBs, PAHs, PHC, metals or VOCs. Far too many Guidelines are exceeded by far too many compounds in far too many media (air, water, soil) and in far too many locations. It is in my opinion a potential crisis that could have and should have been avoided a long time ago. Note I say avoided, not "managed". We as citizens pay full time politicians and government bureaucrats to look out for our interests not theirs.

OH MY LORD, IT JUST KEEPS ON GETTING WORSE AND WORSE IN GUELPH

It takes a lot to shock me after three decades plus of research and study into the greed, stupidity, and dishonesty of some politicians, bureaucrats and government employees. That said I am shocked. As very bad as the soil and groundwater contamination from the former IMICO site on Beverley St. was and is, it gets so much worse. IMICO is located north of the community encompassing Hayes, Kingsmill, Menzie, Audrey, and Lawrence Ave. in Guelph, Ontario. Would you believe that not only were the neighbours subjected to that but also the City of Guelph had three different landfill sites located between the Eramosa River and that same community? These three landfills possibly known as Sites 4A, 4B and 4C were located on the north side of the Eramosa River from approximately Wyndam St. eastwards to Victoria Rd. That is an incredibly long distance and the contents of the landfills included both organics (i.e. food waste) as well as industrial wastes. What is unusual is the admission of industrial wastes as most landfill operators/owners, after the fact, prefer to deny any industrial wastes in their landfills as they are often (usually?) toxic. Up here in Elmira, our brain trust local authorities prefer to constantly minimize their past stupid and polluting decisions to constantly accommodate self-appointed big shots including Uniroyal Chemical.

It seems that these landfills that were investigated as recently as 2012 have accepted both municipal wastes as well as plastics, metals, slag (iron ore or steel?), rubber, glass, fly ash, porcelain, wire, fiberglass and much more. Gee I wonder where fiberglass may have come from? Same thing with iron ore slag? Anybody know any foundrys near by (say IMICO)? Also of course are PCBs, polyaromatic hydrocarbons (PAHs), volatile organic compounds (VOCs), and of course petroleum hydrocarbons especially the F3 fraction which coincidentally is the same fraction that I wrote here about yesterday from IMICO.

Once again I am left to wonder. These landfills supposedly operated from 1935 until 1958. These homes have been located nearby for a very long time. Did anybody (municipal officials, realtors etc.) ever tell the prospective buyers exactly who/what their neighbours were? Have any health studies been done? Why hasn't indoor air testing been done decades ago?

IMICO - INTERNATIONAL MALLEABLE IRON CO. ARE THEY THE CULPRITS?

Just to be clear they may be the initial polluters having left behind heavy metals, petroleum hydrocarbons and volatile organic compounds (solvents) in the soil and groundwater. Of course I also expect they were significant air polluters in their day as well. That said it is my understanding that the City of Guelph have owned the site since 1997. So who do you think is responsible today for health effects that have originated on this site? Also keep in mind that there are other former, and maybe even possibly current, industries nearby. Two that I have an interest in would be Hart Chemical and Huntsman Corp.

Perhaps the City of Guelph thought they were doing the right thing back in 1997 when they purchased a highly contaminated site. Afterall two former owners, after IMICO, did not seem to get much positive press in regards to their cleanup efforts. That would be John Long followed by Mr. Tucker and Mr. Baldasaro of the Church of the Universe. If memory serves me correctly those latter two gentlemen were better known for their lifestyles possibly including marijuana and nudity.

So how bad has the pollution been from the former IMICO site? From my reading of a number of reports I would suggest that there is/was free phase LNAPL (light non aqueous phase liquid) as well as likely free phase DNAPL (dense non aqueous phase liquid) left behind on the site. The LNAPL would be the petroleum hydrocarbons (PHC) floating on top of the water table found at monitoring well OW23S in the south-east corner of the IMICO site. There is a reference to LNAPLS in the April 2014 Phase Two Environmental Site Assessment (page 6-7) as well as a concentration of the PHC F3 fraction of 508,000 parts per billion (ppb). There is another reference to a concentration of the F3 fraction of the petroleum hydrocarbons in April 2007 at 730,000 ppb. These are astronomically high concentrations and clearly represent floating petroleum hydrocarbons on the surface of the water table. As the water table (shallow groundwater) flows southwards towards the Eramosa River these LNAPLS flow along with it. The release of vapours into the soil from this floating liquid is almost unavoidable.

As serious and unhealthy as petroleum hydrocarbon vapours are, DNAPL chemicals which include chlorinated solvents generally are more toxic. These solvents include trichloroethylene (TCE), trichloroethane (TCA), tetrachloroethylene (PCE), and the breakdown products from them such as dichloroethylene (DCE), vinyl chloride (VC), and dichloroethane (DCA). TCE is especially known as highly toxic with a huge host of human health problems associated with exposure to its fumes. Its breakdown product, vinyl chloride (VC) is yet even more toxic to human beings.

I believe that LNAPLS may contain DNAPL chemicals in a mixture with the petroleum hydrocarbons. Similarly DNAPL mixtures may contain some lighter compounds mixed in with them. Hence it is possible to have TCE, VC, DCE etc. being released as a vapour into residential basements either from the LNAPLS floating on top of the water table or even possibly from the deeper DNAPL mixture. While LNAPLS move along with the flow of groundwater, the DNAPL mixture generally flows via gravity and possibly with some kind of pressure from an ongoing release behind it. That said a DNAPL mixture could have moved offsite decades ago and currently be immobile in the subsurface slowly releasing both dissolved contaminants into groundwater as well as vapours which move upwards towards the surface. While to date I have not found TCE concentrations in groundwater nearly as high as PHC concentrations, that is to be expected. The solubility of TCE in groundwater, especially in a mixture with so many other compounds (PHC, TCA, PCE, DCE, DCA etc) is much lower than the components of petroleum hydrocarbons. Most DNAPL chemicals inherently have relatively low solubilites in water although higher solubilities when mixed with some other solvents.

It is an outrage that the City of Guelph had not removed the obvious LNAPL mixture a long time ago. The deeper DNAPLS would have been more difficult to find yet was any attempt made to do so? All in all the nearby residents may have paid a terrible price for this apparent relaxed attitude towards toxic sub-surface contamination.

IT'S NOT ABOUT EITHER "CLEANUP" OR REMEDIATION

What it is about is letting the polluter off the hook as much as possible. In other words the "Polluter Pays" principle is nothing more than a political slogan or political jargon to get the voting public onside. Can you imagine a politician trying to get elected telling the voters that business or commercial investors are too important to be discouraged by being held liable for any collateral damage they inflict either upon the environment or on the health of citizens living in their neighbourhoods?

Politicians know that investment spurs development and economic activity. Hence for every rule, regulation or law insisting upon corporate responsibility and accountability, there are two other ways manufactured to circumvent those rules, regulations or laws. This is exactly why lawyers and environmental consultants are thriving. Far too many are merely intellectual prostitutes bought and paid for by corporate Canada and the corporate U.S.. What the hell, this is business, wealth and influence simply taking care of number one i.e. themselves at the public's expense.

We the general public are merely pawns. We are the vast numbers constantly having business costs externalized upon ourselves to make things rosier for the corporate titans among us. Those externalized business costs particularly include environmental costs. It is so much less directly expensive to industry to be able to legally dump hundreds of tonnes of contaminants into the air, the water and the soil than to have to clean them, detoxify them on-site or send them offsite for commercial detoxification. Our Ministry of Environments simply give then Certificates of Approval for their dumping. Those C. of A.s are now known as Environmental Compliance Agreements (ECA) and no wonder they are agreed to by industry. They are mathematically calculated volumes and weights that allegedly will be diluted by the property line of polluters to the point of not increasing background concentrations of toxic chemicals. What a farce. They aren't compared to the background concentrations that our parents and grandparents grew up in.

No they are constantly increasing concentrations and numbers of chemicals and we look around us in confusion and wonder why 45% of all citizens will now have cancer at least once in their lifetimes. We spend billions of dollars on health care to cure us after the fact instead of going to the sources of air, water and soil pollution and stopping them cold before they cause sickness and death. It is to the point that obvious gross and illegal dumping on a company's property is not stopped or illegal until or unless our authorities (MOE/MECP/Regional governments) can prove beyond a doubt that the dumping has already caused environmental or health impacts offsite to third parties.

We know that pollutants migrate in air, water and soil. We know that most acute effects take considerable lengths of time to occur. Some of our most local blatant dumping and irresponsible behaviour wasn't condemned or confronted until decades later. This includes Uniroyal Chemical, Varnicolor Chemical, Ciba-Geigy, Canadian General Tower, Safety-Kleen, Northstar Aerospace, Borg Warner etc.

There are so many more polluters that have never been confronted even when extensive remediation took place for development purposes many decades later. This would include Kaufaman Rubber, Breithaupt Leather (near St. Leger, Edwin St.), Canbar and Sunar in Waterloo, Voisin Motors (Elmira), the gas station at Arthur and Park St. in Elmira, the downtown Kitchener Gas Works and on and on. Its all about keeping the extent of contamination, environmental damage and human health damage quiet and under the radar. It's all about avoiding the blame game and pretending that this collateral damage is an unavoidable consequence of the standard of living that Canadians and Americans enjoy. Horse manure. It's an entirely avoidable consequence of politicians exempting business leaders, entrepreneurs, investors and the wealthy and influential from accountability for their negative, negligent, immoral and even sometimes criminal behaviour.

MR. RICE & MS. DOUGHTY DO EXCELLENT WORK

Last week, courtesy of Lisa Schaefer (Woolwich Township), I received a twelve page stapled together report. Upon closer examination, the first eight pages were from Mr. Jason Rice, Regional Engineer for the Ministry of Environment (MOE/MECP) and the next four pages from Ms. Cynthia Doughty, Hydrogeologist, also for the MOE/MECP. Jason's report was dated April 9, 2020 and Cynthia's was dated March 18, 2020. Both of their reports were critiques/comments of Lanxess and their consultant's (GHD) most recent reports dealing with Contaminants of Potential Concern (COPC) and with the Conceptual Site Model (CSM) for the Canagagigue Creek.

The two GHD reports are significant because they are part of the background documents for use with the proposed/threatened Site Specific Risk Assessment (SSRA) for the Canagagigue Creek (the "Gig"). This upcoming SSRA follows both a Human Health Risk Assessment (HHRA) and an Ecological Risk Assessment (ERA) completed in approximately 2004 on behalf of Uniroyal Chemical/Crompton. Dr. Henry Regier wrote a detailed critique of the SSRA process as inflicted upon Elmira based upon his experiences in researching the process as well as in interviewing MOE personnel on the matter back in approximately 2003-2004. Dr. Regier's entire critique can be found in Chapter Seven of my book (Elmira Water Woes: The Triumph Of Corruption, Deceit and Citizen Betrayal) either in the Waterloo Region Advocate blog or in the Cambridge Advocate Blog/Website.

Mr. Rice bluntly hits Lanxess and GHD right in the face with his page 3 statement that "shovel collection" sampling methods "were not described or approved in the workplan, nor discussed as an alternative sampling method with the Ministry during sample collection activities." Furthermore Jason states "The Ministry has already provided feedback on why the shovel samples that collected mostly gravel is not appropriate as it does not collect a representative sediment sample."

WOW! Or in my more direct and blunt language, Lanxess and GHD have rigged the game and continued the long hallowed and appreciated Elmira traditions of junk science and psuedo science (JSAPS). Or in the words of Susan Bryant they have "Adjusted the science according to their needs".

Mr. Rice on this same page alludes to the possibility of historical data showing exceedances of criteria may not have all been used to determine Contaminants of Potential Concern. He also suggests on page 4 that too much data may have been excluded without a proper rationale being presented in the text. He has concerns that for example the magnitude of exceedances was not given proper weight in the determination of COPC nor was it explained why it wasn't. Also an alleged professional source (U.S. E.P.A.) for the 5% frequency of detection rule could not be found. A number of other data sources appear not to have been used as a line of evidence in evaluating potential COPCs.

One of my favorite screw ups is GHD's ability (just like CRA's) to publish ridiculous typographical errors, over and over again. Mr. Rice refers on page 5 to
GHD misstating the data in Tables C.1. C.2 and C.3 .

On page 6 Mr. Rice takes issue with GHD using Shirt Factory Creek (SFC) as an "background" or upstream location. This location is not remotely background as it it partly on the Lanxess property and it flows through Elmira and picks up lots of contaminants on its way not to mention what was historically dumped into and around it by Uniroyal Chemical.

Regarding the Conceptual Site Model (CSM) on the bottom of page 6, Mr. Rice asks the question as to whether toluene in the on-site groundwater could be transporting DDT and /or dioxins to the creek. He also advises that other tributaries need to be sampled as he also did back on page 3. This includes the SDDB or Stroh Drain, Ditch & Berm which Lanxess/GHD/MOE like to refer to as 6770 Line 86. Anything to muddy the waters with those folks. Mr. Rice on this page advises that additional sediment sampling is required because Depositional Zones identified in the 2017 creek sampling and investigation were not sampled. Talk about fudging and massaging the results in my opinion.

Ms. Doughty also does not pull her punches. She is clearly upset/outraged by the failures of the Upper Aquifer Containment System (UACS). She advises that "...for at least the last three years, the UACS has temporarily lost hydraulic containment." These nine pumping wells (mostly in Upper Aquifer 1 with two also pumping from Upper aquifer 3) are located in the extremely heavily contaminated south-west corner of the Uniroyal/Crompton/Chemtura/Lanxess site. She states that the Draft CSM does not accurately portray the extent of the loss of hydraulic containment in the Upper Aquifer. She notes that that analysis inaccurately and inappropriately focuses on one area only and on one occasion when there were several time frames and several pumping wells involved in the failures to contain grossly contaminated shallow groundwater which discharges to the Canagagigue Creek.

Ms. Doughty further advise that surface water (the "Gig") elevation monitoring only occurs four times a year and thus monthly comparisons with groundwater levels are somewhat irrelevant. Also the CSM report by GHD should have clearly indicated which monthly comparisons of ground versus surface water elevations occurred after very recent surface water elevation monitoring. The whole idea of course with hydraulic containment of groundwater is to keep the groundwater elevations lower than the corresponding surface water elevations in order to stop groundwater discharge to the surface water (i.e. the crrek/"Gig").

Ms. Doughty similar to Mr. Rice pokes a hole in GHD's use of criteria or rationales that are not clear or transparent. GHD reference a loss of Upper aquifer containment for five days or more as being significant or relevant without any backup whatsoever. Where did this come from and is it relevant or not? I personally am also concerned with the apparent claim that a 1 cm. difference (i.e. lower) in groundwater compared to surface water is adequate hydraulic containment. I think that that tiny difference in elevation is superficial at best and deceptive as hell at worst.

These comments by two MOE/MECP professionals are quite incredible. I have seen other reports by Cynthia Doughty that I felt were excellent whereas Mr. Rice's were less so. I also know that often these critiques get buried if no other reason that these initiatives by Lanxess/GHD go on either forever or for so many years that they literally get forgotten. Excellent DNAPL reports by CH2MHILL, Jaimie Connelly (MOE), APT, myself and others are a perfect example. As the DNAPL coverup has never ended from 1989 until the present, CRA, GHD etc. just keep on churning out JSAPS (junk & psuedo science) while the other parties die, retire or simply fade away. It's a battle of attrition and as usual time, money and lack of integrity usually win.

To summarize, these two critiques alone are devastating evidence of the failures of process that allow the polluter to buy the cleanup/lack of cleanup that they want. Both GHD reports (COPC & CSM) should be thrown in the garbage and new, independent, paid for by the public (initially) reports written by appropriate professionals are required. Bought and paid for professionals working directly for the polluter need not apply.

THE SMELL OF DEAD RAT IS GROWING IN GUELPH

I have long suspected that former Woolwich councillor Mark Bauman's comments on the "blame game" being counter-productive were self-serving. Certainly when government agencies or ministry's start handing out Releases and Indemnity's to polluters then an odour begins to form. It is the odour of the "sweetheart" deal and it is common practice apparently for either regional or provincial (MOE/MECP) governments to participate in. In my opinion it is particularly common when the so called "regulatory" bodies have either been asleep at the switch or more likely have participated in the public relations campaign to verbally minimize both human health and environmental damages that have occurred. Local examples of which I am aware include Breslube/Safety-Kleen (Region of Waterloo) , Varnicolor Chemical and Phillips Environmental (MOE/MECP) as well as of course Uniroyal Chemical (MOE/MECP). The last two are in Elmira and the first is in Breslau. I am confident that there are others because so far three out of three sites that have I have spent considerable time studying here in Waterloo Region have all been recipients of the governmental golden kiss of non-liability. In other words, we the government declare that you are not legally or civilly liable for all the human and environmental damage that you have done in exchange for you agreeing not to sue our as... for negligence, incompetence, corruption, bad advice etc.

I have found yet another report on-line titled "Supplemental Soil Vapour Investigation...Residential Community Southwest of York Road and Victoria Road South, Guelph, Ontario" dated January 13, 2020. This report written by Geosyntec Consultants fleshes in much of what has and has not been happening to protect the lives and health of those nearby residents. This report, in my opinion, makes a mockery of the City of Guelph on-line bulletins suggesting the low probability of vapour intrusion into people's homes. My understanding is that these are generally older homes with fewer technological improvements in and around their basements to ensure sealing from water or vapour intrusion. In other words what has been standard industry practice for the last couple of decades or more such as tile drains hooked into the city storm sewers as well as waterproof sheeting attached to the exterior of the basement walls likely is not in place in and around these older homes. Also things like sumps which automatically engage to pump out rising groundwater are less likely in older homes unless they were retrofitted decades after the homes were built.

There appear to be two vastly different thresholds or screening levels in use by the Ministry of Environment (MOE/MECP) as far as further investigation of possible vapour intrusion into these homes. The one threshold is 250 ug/m3 (micrograms of trichloroethylene (TCE) per cubic metre of air) in outdoor soil vapor samples and the other is the much lower threshold of 13.6 ug/m3. These vastly different numbers need further clarification and explanation. That said guess what? The lower threshold for TCE (13.6) is not exceeded seven times out of twenty-six samples taken. Or in the alternative it is exceeded nineteen times out of twenty-six samples taken.

Regarding the much higher threshold (250 ug/m3) for outdoor soil vapour samples it is exceeded however much less often than the much lower threshold. This is of small consolation to those residents who live closest to the higher outdoor soil vapour concentrations. Also please note that to date that neither the City (Guelph) nor the province (MOE/MECP) have gotten around to doing any indoor air testing. That said they have to date offered indoor air testing to the grand total of TEN homes in the community. I view this as the old adage that you will never find that for which you do not look for. Verbally I have been advised that the extraordinarily limited indoor air testing will only take place AFTER the Covid 19 emergency has ended. I'm sorry but that doesn't cut it. THIS is an emergency until proven otherwise!

The indoor air safety threshold is a fraction of outdoor soil vapour thresholds. 5 ug/m3 of TCE in your home, potentially being inhaled 24/7 I believe is too high for this toxic chemical. The current goal (as yet unachieved) in the Bishop St. community in Cambridge is to get all indoor air down to .5 ug/m3 or less.

Getting back to the outdoor air soil vapour results we find to date that the 250 ug/m3 threshold is exceeded five times. Two exceedances are fairly small and three however exceed from almost four times to ten times the higher threshold. Now keep clearly in mind the drawbacks with these thresholds. They are set based upon the toxicity of the one and only chemical being examined at the moment namely trichloroethylene (TCE). Well guess what? There is more than just TCE in the soil vapours outdoors and there will be more than just TCE in any indoor vapours found. The following toxic compounds have been found in outdoor soil vapours namely cis 1,2 DCE, trans 1,2 DCE, PCE (tetrachlororthylene), and while vinyl chloride has not been found to date outdoors that may be a function of one very high method detection limit (MDL) of 13 ug/m3. Lastly this very same sample of outdoor soil vapours had a concentration of PCE about fifty times higher than its outdoor soil vapour threshold.

Lastly also keep in mind that only FIVE different toxic chemicals were examined via outdoor soil vapour testing. That may be a result of inadequate sampling of the soil itself. In other words the soil not the soil vapours were also tested. Unfortunately that testing is somewhat deceptive for a couple of reasons. Firstly one can have toxic soil vapours with minimal to no soil contamination at the same location and again the method detection limits for some of the compounds tested were far too high which produces far too many non-detect readings.

There is more but this is enough for now.

MORE INFORMATION ON THE POSSIBLE VAPOUR INTRUSION ISSUE IN GUELPH

I posted here both last Thursday and Friday about recent information and soil vapour data I had received from the neighbourhood near Victoria and York Rd just north of the Eramosa River. Yesterday while looking for information on-line about other nearby industries I stumbled across two announcements/bulletins on the City of Guelph's website. The first from March 13, 2020 was titled "Updated: Update on environmental testing on Menzie, Audrey, Lawrence Avenues". The second date April 3, 2020 was titled "Second round of soil vapour testing on Menzie, Audrey, Lawrence and laneway starts April 6". Firstly the City are to be commended for putting this information out there. That's the good news. The bad news is that the March 13 bulletin suggests that the Ministry of Environment (MECP) "...out of an abundance of caution..." used a threshold of 250 ug/m3 to evaluate the need for taking indoor air sampling. Well let me advise you that in my experience the only time the Ontario MOE/MECP uses an abundance of caution is when they have been caught redhanded gilding the lily and they've made the decision not to get caught again right away.

So soil vapour testing was done last November and ten homes have already been advised that the MOE/MECP are offering to do indoor air monitoring inside their homes looking for trichloeorethylene (TCE) vapours. Meanwhile this past Monday to Wednesday another round of outdoor soil vapour testing was done.

A quick look around the neighbourhood is not encouraging. I am now aware of exactly how close to this residential neighbourhood were/are other industries. On-line it appears that both Hart Chemical and Huntsman Corp. were/are both located at 256 Victoria Rd. Presumably the one company purchased the site from the other. I am aware that major environmental remediation has been either completed or underway for many years at that location. I suspect some sort of hydraulic containment was involved to stop the flow of chemicals into the Eramosa River. I'd be interested to know what if anything was done to stop soil vapours from migrating. Between the former IMICO, north and west of the neighbourhood and these two companies to the east it makes it clear that heavy industry located in the neighbourhood never has been compatible with residential homes.

CENTRE WELLINGTON DRINKING WATER & TRICHLOROETHYLENE (TCE)

Probably it's been nearly ten years since I looked at the drinking water in Centre Wellington Township which includes the towns of Fergus and Elora. I do know that back on June 17, 2010 I was shocked with the trichloroethylene (TCE) and other solvents in some of the Fergus wells and posted about them here. It was my understanding then and now that the source of the TCE (& likely other solvents) was the former General Steel Wares (GSW) factory in Fergus. My least favourite environmental consulting & engineering company, Conestoga Rovers & Assoc. (CRA), were their consultants at the time. Unknown to many, CRA actually won themselves a rap on the knuckles from the Ontario Ministry of Environment for discharges from GSW (Fergus) into the Grand River. TSk tsk.

Following are my comments about the Annual Water Report for Centre Wellington Township, dated February 2020:

Both raw and treated water is clear of both E.Coli and Total Coliform bacteria. That is both good and appropriate. Heterotrophic Plate Count however had a maximum value of 213 coliform units which is very high. A laboratory comment on that occasion stated "no data, overgrown with HPC". That certainly appears problematic although the HPC analytical result the following week was 0. Weird?

Chlorine and Turbidity (water murkiness) results are acceptable. Sodium results were a little high on two occasions out of eight but wait, stop the presses, the dates for these samples are January 19, 2016. What the hell, 2016 results are being used in a report dated 2020. Come on! Similarly early 2018 results were used in Table 16 titled Fergus Well 1 Schedule 24 Organic Results. These 2018 results showed all organic chemicals to be below the detection limits.

Table 24 with Lead results from 2019 showed all samples taken either on March 28/19 or September 11/19 to be well below the criteria for lead in drinking water.

Interestingly Table 26 had four results for TCE (raw water) from Fergus Well 1 taken in 2019. Two of the four exceeded the Ontario standard/criteria for TCE with the one being just over double the standard. WOW, that is bad! Either the treatment system is very good at removing TCE (unlikely) or more likely the results of the other groundwater wells are better and hence they are diluting the TCE concentrations to below the provincial criteria at least some of the time. Also keep in mind that while there are a total of nine groundwater wells as part of the system (6 from Fergus and 3 from Elora), we are advised that Fergus Well 2 is currently off line.

What I find curious is the names of the nine groundwater wells that make up this system. They are Fergus Well 1,2,4,5,6,7 and Elora Well 1,3,4. Hmm seems to me that there may be more than just Fergus Well 2 off line. Pray tell where Fergus Well 3 is as well as what happened to Elora Well 2?

It is long past time that these Annual Reports advised citizens of what specifically has happened to missing wells in their water systems. Maybe on occasion wells are shut down for reasons that are not alarming or concerning. On the other hand if water managers are playing musical wells with contaminated source water (groundwater), citizens have a right to know how precarious their water systems are.

CITY OF GUELPH 181 PAGE ANNUAL WATER REPORT

I have read carefully about 2/3 of the report and skimmed the rest. To say that it is long winded, detailed etc. is an understatement. I'm not totally convinced that it is superior to all the Region of Waterloo Annual Reports (i.e. Waterloo, Kitchener, Cambridge & four Townships). The reason is that it is very difficult to get the big picture or even to find the various specific data one is looking for. Yes much of the Region of Waterloo's data is far too thin without details as to why wells are shut down, why so many Method Detection Limit's are so high (particularly glyphosate), why other wells out of use for years continue to be considered part of the water system etc.. Anyhow here goes regarding Guelph's water supply and system.

It is broken down into the Guelph System and the Gazer Mooney Subdivision System. The second one consists of a total of about 200 people and uses the same water that is used throughout Guelph. There are 21 groundwater wells and a shallow groundwater collection system called the Arkell Springs Glen Collector System. This system consists of trenches that are occasionally inundated with water from the Eramosa River. Boy that's a new one to me. River water generally is much dirtier in every sense than groundwater but perhaps introducing it and then filtering it directly through sands and gravels is less expensive than Kitchener's ridiculously expensive Mannheim Treatment System which treats Grand River water.

The City has a Lead Reduction Plan that perhaps is superior to other municipalities. They offer a subsidy of up to 75% for homeowners to remove the lead pipes running from the municipal water lines into their homes. That is an excellent idea.

Besides the usual sodium hypochlorite to treat for bacteria the City also uses Ultraviolet Light (UV) for the previously mentioned groundwater Collection System as well as the Carter Wells (1 & 2) and the Arkell Wells (1,6,7,8,14 & 15). UV is usually used for raw water that may have excessive bacteria or other contaminants (NDMA or perhaps TCE). Hence surface water or groundwater under the direct influence (GUDI) of surface water is a candidate for this additional treatment. There were a few relatively minor Adverse Water Quality Incidents during 2019.

As to be expected there were a few issues with bacteria in the raw water including 4 E.Coli and 78 Total Coliform. Heterotrophic Plate Counts (HPC) had occasional maximum Coliform Unit counts that were very high namely in the Distribution System (280 cfu/ml) and the Point of Entry HPC (1300 cfu/ml).

As with other nearby cities (Kitchener, Waterloo, Cambridge), Trichloroethylene (TCE) is an issue in a few Guelph wells namely the Membro and Emma wells and possibly one other. While below the drinking water standard it still should not be in our drinking water at any measurable concentration.

Generally Volatile Organic Chemicals (VOC) on pages 53-56 look very good. The trouble is that on later Tables dichloroethylene, TCE, Xylenes, Ethyl Benzene show up although not in this Table (Table 23). Also they are below the drinking water standards. Of course the usual listing of Trihalomethane (THM) chemicals show up albeit well below the drinking water standard. This includes chloroform, bromodichloromethane, bromoform, and dibromochloromethane. The overall levels of THMs and Haloacetic Acids (HAA) are as good or better than many in the Region of Waterloo reports.

Sodium while technically above the Aesthetic Objective is nevertheless much better in Guelph than throughout the Region of Waterloo.

Overall despite the difficulty and time required to find the good stuff in this report, I would suggest that on a comparative basis Guelph water isn't any worse than Region of Waterloo water and in fact might be a little better. As with most other systems I have studied there are issues with bacteria in the raw water which requires too much chlorine and accompanying by-products of disinfection. There are also issues with low level solvents and just like the Region of Waterloo, there is virtually no mention of asbestos piping in the Guelph water system. That error of omission concerns me in that I wonder what other contaminants are in our drinking water that are either unintentionally or intentionally being ignored.

IT'S NOT EASY SURVIVING ALL THE TOXINS WE'VE INTRODUCED INTO OUR WORLD

I'm primarily referring to man made toxins as in chemical toxins versus bacterial or viral pathogens not to mention others. In both my March 23/20 and March 25/20 posts I added comments to those posts advising readers that contaminated drinking water was rarely contaminated with but one single parameter. We can get all hung up on E.Coli bacteria for example and completely miss the significance of Roundup herbicide (glyphosate) in our tap water. Or we can focus on glyphosate combined with trichloroethylene (TCE) found in various drinking water wells in Cambridge, Waterloo, and Kitchener and not even think about lead or, heaven help us, microscopic asbestos fibres in our tap water. Keep in mind that the slogan "Better Living Through Chemistry" is exactly that: a slogan. It is a slogan used on behalf of and for the benefit of the bottom line of chemical companies.

The fact is that we don't categorically and mathematically know exactly how toxic our drinking water is because we as yet have not figured out a way to measure and determine the health effects of multiple contaminants in our drinking water. Simply assigning a safe number, no matter how well calculated or determined, to a single contaminant in water and then pretending/assuming that each and every additional contaminant's effects do not increase the overall negative health effects on humans provided that each additional contaminant is not individually more toxic than the first contaminant is irresponsible at the least and potentially criminally negligent at the worst. Synergistic health effects based upon multiple contaminants are well known and understood. Simply because as yet we can not accurately measure those effects does not mean that they do not exist.

But it gets worse, folks. Much worse. What if we have a contaminant in our tap water and a contaminant in the air in our homes? The contaminant in our homes could be from our furniture or simply obnoxious odours from a neighbourhood business. Say a dry cleaner or from a local factory. Despite denials from the Region of Waterloo the evidence in the Bishop St. community in Cambridge points to both indoor air contamination from TCE as well as from the now closed water well known as P6. In that case the contaminant could be solely TCE but of course it isn't. Trichloroethane (TCA) not to mention Chromium VI were also mishandled and released to the natural environment courtesy of Northstar Aerospace and Rozell/ Borg-Warner. That natural environment is both the air and the ground and hence groundwater.

So would you believe that just as dozens out of thousands of potential water contaminants have criteria, for example the Ontario Drinking Water Standards (ODWS), so do dozens out of tens of thousands of air contaminants all have separate standards in air. The air standards are usually measured in either parts per million (ppm) or in micrograms per cubic metre of air (ug/m3). Yes these standards also measure many of the same solvents, herbicides, pesticides and other chemicals as are measured in water as well as others. So now besides multiple contaminants in our water supply we also have multiple contaminants in the air we breathe at the same time. Do you think that there is any number or criteria for example that can tell you if your health is at risk from low level TCE in your drinking water at the same time as you also have low level TCE in the air you breathe? There is not. How about 3 parts per billion (ppb) TCE in your water and 1.0 ug/m3 of TCA (trichloroethane) in your household air. Absolutely no way that our authorities can tell us what the effects of that will be upon us.

Think about the reality of the hundreds of chemicals that we are exposed to every day of our lives. Water, indoor and outdoor air and lest we forget: food. Do you think that we don't have chemicals throughout our food supply? Of course we do from dioxins in our milk to mercury and PCBs in our fish. Pesticides and herbicides are also on our fruits and vegetables. Talk about better living through chemistry. Doesn't it give you a warm feeling knowing that our exposure to these chemicals is making billions of dollars for chemical companies and others? We are the guinea pig generation with little protection offered to us, other than lip service, from our own governments.

GRASSY NARROWS EFFORTS CONTINUE

Truth be told I just don't get it. In this article in today's Waterloo Region Record, titled "Feds, Grassy Narrows sign mercury care home deal", we are advised that the contamination, with 9,000 kilograms of mercury, of the English-Wabigoon River system occurred in the 1960s. By the 1970's the effects were being felt by the local residents as well as throughout the local natural environment. Here we are a minimum of half a CENTURY later before the federal government are honouring a long promised treatment centre for residents in their home community. Meanwhile presently we are in the middle of the Covid-19 emergency and all levels of government are stepping up, taking charge, spending taxpayers money and apparently doing the right thing. Almost as if that's their job, their duty, and their responsibility. Which it is, for all of us.

Are we to conclude that it's ethnic discrimination, plain and simple? Or does the federal and provincial government's belated efforts have to do with the relatively small number of residents/citizens involved? In other words their votes just aren't enough to bother with them? Or is it all about their isolated location? Again, out of sight, out of mind? Covid-19 is affecting everyone. That's an awful lot of votes and governments surely don't want to alienate everybody. I suspect the reasons that governments failed to step up fourty and fifty years ago is a result of all the above factors. Shame on them for that. Also don't forget that the 60's "scoop" of native children was underway in full swing at the time. It was a different time with both government and public attitudes being harsher, dumber, meaner, or whatever name you wish to put on it.

This treatment centre will provide access to health services for those residents living with mercury poisoning. It will be a 24 bed facility and should have been built so very long ago. How many sick residents have passed on without proper care and treatment as a direct result of government inaction? Long-term funding is still required for the facility once it is built.

Citizens should never forget that governments often fail in their duty to protect citizens. Citizens should understand that when governments do step up it's usually too little and too late. Yes we can appreciate their current efforts but also never forget their broken promises.

HARD TO COMPARE CAMBRIDGE VAPOUR INTRUSION DISASTER WITH GUELPH CONCERNS

There are a number of similarities including potentially multiple sources of the most dangerous contaminants released into the natural environment. In Cambridge the three most prevalent issues were trichloroethylene (TCE), trichloroethane (TCA) and Chromium VI. That said in Guelph TCE and TCA are also front and centre with notable concentrations of tetrachloroethylene (PCE) as well at the alleged source area of IMICO. Furthermore both sites also have the common breakdown products of both TCE and TCA present. For TCE this includes compounds of dichloroethylene (DCE) and vinyl chloride (VC). For TCA this includes compounds of dichloroethane (DCA).

Another similarity is the stratigraphy or sub-surface formations. Both sites have a shallow overburden of soils, gravels and silts with the Bedrock close to the surface. Whether this actually induces greater vapour production from the sub-surface solvents in both the groundwater and the soils, I am not certain. I do know that any attempts to lower the water table via pump and treat technology of the groundwater definitely can induce greater volatolization (i.e. liquid phase to a gas phase) of these toxic solvents.

A major difference so far is that while there are reports showing both soil and groundwater concentrations of TCE, TCA, PCE, DCE, DCA, and VC for both Cambridge and Guelph likely source locations, I have after considerable search been unable to find soil Vapour concentrations in and around the Cambridge Bishop St. sources and area. Recall that yesterday I mentioned that the Guelph resident had sent out a map showing soil vapor concentrations in his neighbourhood. That map and test results was produced by Geosyntec Consultants. Their map however while showing very high soil vapours of TCE, PCE, DCE, and VC does not show soil vapours for either trichloroethane (TCA) or its breakdown products such as DCA. What I view as the likely source, namely the former IMICO foundry does have soil and groundwater readings for TCA and DCA. Those reports were produced by Decommissioning Consulting Services.

In Cambridge at least at the moment it appears as if the MOE/MECP immediately understood the potential/probable consequences of TCE in the groundwater being able to volatolize and enter residential basements via vapour intrusion. Hence it appears as if they immediately began indoor air testing in those nearby homes. For some reason in Guelph it appears as if outdoor soil vapour testing was some kind of intermediate step. According to the e-mail I received from the local resident, indoor air testing will commence after the pandemic crisis has abated. I expect that decision was only made after the authorities (MOE/MECP ?) saw the results of the outdoor testing. Keep in mind the outdoor testing decision took place well prior to the extent of knowledge we now have regarding the spread of the coronavirus pandemic in Ontario.

I have not been able to determine any specific TCE groundwater concentration necessary in order to produce vapor intrusion. Also I have not been able to determine any measurement of quantity of free phase TCE in its form as a DNAPL (dense non aqueous phase liquid) that would be necessary to produce vapour intrusion into homes.

THE FAINT OF HEART MAY NOT WISH TO READ THIS POST

I have long held the belief that humanity will end with a whimper and not a bang. In other words yes I have confidence that various egomaniacs, twits and others known as politicians will do some incredibly stupid things in the future just as they have always done in the past. That said, with or without war, I expect that it will be a disease whether bacterial, viral or whatever that finishes off humanity. No I don't believe the current one is at all likely to finish the job that humanity are hell bent on achieving, namely annihilation of the human race. My Phd. (Biology) daughter believes that insects will inherit the world. My only hope is that when humanity depart the earth they will not take every other species with them. Oh and of course I hope that this will not happen until my children (and potential grandchildren) have led long and happy lives.

What has led to this reflection? Tuesday I received two e-mails, one from a fellow I know in Cambridge and the other from a fellow I don't know in Guelph. Since then I have been reviewing information and reports that I already have as well as others on-line regarding some contaminated sites in Cambridge (Northstar Aerospace-Bishop St.) and Guelph namely the former? Chemtura Lab on Huron St. as well as IMICO on Beverley St. I believe that IMICO stands for International Malleable Iron Co. or something similar to that.

The fellow in Guelph included a map/figure in his e-mail which is dated January 2020 and which indicates soil vapour results for a number of toxic chemicals in a residential neighbourhood less than two hundred metres from the former IMICO foundry. The Chemtura Lab is farther away (south-west) from this neighbourhood than IMICO. What has further convinced me of the inherent stupidity, head in sand ostrich like behaviour and never ending focus on money versus human health and happiness is two facts. Firstly this property is owned by the City of Guelph. It is not owned by a numbered corporation or some long distance investors with no ties to the community or emotional attachment to the nearby residents. Secondly this property has been the subject of various and numerous professional environmental investigations by Proctor-Redfern, Lee Gartner and DCS consulting companies going back as far as 1994. Possibly (likely?) there are other consulting companies involved. Twenty-six years of soil and groundwater studies in and around the site and just in the last few months have they gotten around to examining the nearby residential neighbourhood for the obvious potential known negative health effects of some of these toxins.

I am not personally involved with this neighbourhood or the people living in it. It is possible that one or more of these consulting companies have years ago advised the City of Guelph, the Ministry of Environment, or the Guelph Medical Officer of Health that residents of this nearby neighbourhood were at severe risk. It is possible that individual Guelph councillors recommended action a decade or two ago to assist residents and he/she were voted down by the rest of council. I do not believe that it is a question of human failure but a question of who and how many have been involved in either a coverup or who were simply grossly negligent. Do not doubt the ability of human beings in positions of authority to know how to cover their tracks. Elmira, Walkerton and Cambridge (Bishop St.) have a long and dishonourable history of either fully successful or partially successful ccoverups although many of the bad actors were ultimately exposed in Walkerton.

Terrible past planning decisions have located heavy industry near residential neighbourhoods in Guelph, Cambridge, Elmira, Kitchener and Waterloo. In Guelph other past industries have been located near IMICO and the York and Victoria Rd. neighbourhoods. These may share responsibility or not with the most likely candidate to date. Contaminants in the soil and groundwater include tetrachloroethylene (PCE), trichloroethane (TCA), benzene, petroleum hydrocarbons, trichloroethylene (TCE) and vinyl chloride and more. It appears obvious that the long belated soil vapour sampling in Guelph is due to the long proven knowledge that TCE in particular easily volatolizes from groundwater and soils and can enter homes through their basements. This is known as vapour intrusion and is a long proven potentially lethal occurrence that has happened throughout the U.S. and just down the road in Cambridge in 2005. In Cambridge, remediation and mitigation are still going on fifteen years after the discovery of vapour intrusion by TCE from Northstar as well as G.E. Rozell, both located on Bishop St.

How severe the health effects may be in Guelph are unknown at the moment. If they are even a tenth as bad as Cambridge then once again those negligent or complicit in a coverup should end up in jail. This being Canada and the wealthy, influential and politically connected being well in control of all institutions (including the media), this will never happen. Those in charge appear to believe that those in pursuit of "filthy lucre" (i.e. money) are absolved from blame for collateral damage, especially damage to human life and health. Hence once again the truly irresponsible people in charge will walk as they have in Cambridge, Elmira, Kitchener and Waterloo.

This lack of accountability for human suffering and death that is a direct result of negligence and worse is why I believe that humanity are doomed to extinction. Just like the current coronavirus, those in charge around the world lied and minimized as long as they could. Only when the virus had spread world wide did they begin to more honestly advise their citizens about the pandemic among us. Too little too late is the watchword of our authorities and as long as they are never truly held accountable it will go on until the irrevocable end of all of us.

WILMOT TOWNSHIP ANNUAL WATER REPORT

The first of four reports under the banner of Wilmot, start with New Hamburg and Baden. The good news is that both HAAs and THMs are very good (i.e. low numbers). Regarding Adverse Water Quality Incidents (AWQI) they had three of which two were labelled as TC. Likely that means Total Coliform as the corrective action consisted of flushing and resampling the water main. The third had a BWA or Boil Water Advisory released. Hmm! Lead results in the Distribution System were zero although all of 8 samples were taken. A rather skinny report this one.

The New Dundee distribution system had no bacterial information on raw and treated water although the Distribution system was clear of both E.Coli and Coliforms. Lead sampling was sparse with zero plumbing samples taken and only four samples taken from the Distribution system. Lead results were zero. THM and HAA results were excellent (i.e. low). Of course no sampling/testing was done for asbestos which I would think might be more likely in an older community.

The St. Agatha system has no results for bacteria in raw or treated water however they did test in the Distribution system and bacteria were absent. The 43 HPC samples taken had a maximum reading of 46 Coliform Units which is a little high. Minimal lead testing took place (4 samples) but they were all zero. THMs and HAAs were the lowest I've seen to date in all the Region of Waterloo cities and townships.

The fourth system under the Wilmot banner is the Mannheim system which has been discussed previously.