THE PUBLIC FACE IS MOE CONTROL ORDERS VERSUS THE REALITY OF PRIVATE BILATERAL DEAL MAKING BETWEEN POLLUTERS AND GOVERNMENT

No morals, no ethics, no shame: that could be the mantra of both the Ontario Ministry of Environment (MOE) and of Uniroyal/Crompton/Chemtura/Lanxess. For good measure let's throw in Varnicolor Chemical and Nutrite although I admit that of the three polluters, I know the least about Nutrite. Ammonia for sure they contributed but they also were no slouches with NDMA, 2,4-d and more on and under their property. ................................................................................................................... It is usually better for the public interest when the guilty parties are publicly throwing mud and accusations at each other than when they are privately and comfortably scheming and negotiating with each other. That's when the sweetheart deals get brokered that absolve each other of blame and lessen the cleanup or mitigation of their illegal and unethical past activities. This is where our governments shine. Yes Dorothy all our governments shine in the fine art of manipulating public opinion in the direction they want whether for good or for evil. ............................................................................................................. The first Control Order laid on Uniroyal Chemical was dated April 13, 1984. This was a mere fourty two years after the company had begun dumping toxic liquid wastes, sludges, tars and solids onto their property, under the surface of their property and both directly and indirectly into the Canagagigue Creek. An honest and moral government would have shut have down the operation by then, arrested, charged and imprisoned senior company executives convicted of either environmental crimes or health crimes against humanity. Of course none of that occurred. ................................................................................................................. Along with better record keeping and more sampling of existing groundwater, monitoring wells; the MOE ordered new monitoring wells on the east side of the property close to RPE-1. This was the most northerly of the five retention pits (east side i.e. RPE). Specifically they wanted all the stratigraphic layers monitored in and around well OW 7. Now oddly while that was a simple and inexpensive request, Uniroyal embarked on a much more ambitious program on the east side. This encompassed fifteen individually numbered wells from OW 25 to OW 39 placed between RPE-4/RPE-5 and the extremely close Stroh property line. As mentioned previously, most of these were strangely screened in the Upper Aquitard (UAT) versus in the Upper Aquifer (UA or UAF) which is the water bearing and transferring layer of soils rather than the silty/clay less permeable UAT. ......................................................................................................... One possible reason for this is as follows. Every single well closest to RPE-4 and RPE-5 including OW 25, OW 27, OW 29, OW 31, OW 33, and OW 35 were screened solely in the Upper Aquitard (UAT). Meanwhile the wells closest to the Stroh property line included both screens in the UAF and the UAT. What the hell? Even more bizarre is the fact that after the 1987 excavations of waste pits BAE-1 and RB-1 and RB-2 located as well between RPE-4/RPE-5 and the Stroh property line; only three UAF wells were left standing along the property line namely OW 28, OW 32, and OW 39 although they were drilled in 1985, 1988 and 1986 respectively. Meanwhile every single UAT well drilled nearest RPE-4/RPE-5 in the Upper Aquitard (UAT) was destroyed, removed and grouted during the 1987 excavations. ......................................................................................................... To further confuse the narrative there were also in 1984 three wells drilled in the actual waste pit itself, RPE-4 and two wells in RPE-5. Finally four wells were drilled to the west of these two waste pits (RPE-4 and 5) namely OW 40, OW 41, OW 42 and OW 43 all of which are still there today. Oh and lastly Woolwich Township contracted with Conestoga Rovers in 1984 to drill monitoring wells and examine the municipally owned Bolender and First St. Landfills. All this from a minor and modest 1984 Control Order that ordered none of it...at least publicly? ................................................................................................................ Here is my take. The MOE grew some gonads and yelled and hollered at Uniroyal because they knew the town's drinking wells were toast and the public would have to be informed some time. Uniroyal yelled back and threatened legal action as usual. Private negotiations then took place. The actual reasoning for the weird timing of new wells and weird screening in the UAT was in order to "prove" privately that Uniroyal's liquid wastes had not crossed the Stroh property line via groundwater. This is an old, tried and true hydrogeological trick whereby water levels from different stratigraphic units are compared to each other rather than water levels in the same startigraphic unit (usually aquifers UA, MU etc.). Therefore comparing UAT water levels nearest RPE-4 and 5 with UAF water levels nearest the Stroh property line would "prove" that groundwater was flowing westwards away from the Stroh property. Was the Ontario MOE fooled or was this just more of the old boys nudge and wink private negotiations? Regardless the purpose was to dissemble, minimize the problem and lie to the public. As always.