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.