PARATHION, DIACETYL, AGENT ORANGE, 6PPD, CYANIDES, NDMA - IS THERE ANYTHING UNIROYAL/LANXESS WON"T PRODUCE FOR MONEY???

"Better Living Through Chemistry" What a pile of pus that is, thank you very much Uniroyal Chemical. Parathiaon is a herbicide that has caused immense human sufferring. Diacetyl also produced here in Elmira, Ontario is the cause of "popcorn lung". It is a manmade butter flavouring. Agent Orange was produced here as a defoliant for use in Vietnam as well as in North America as a herbicide. It also killed crops and caused human starvation before causing mutagenic injury to generations of both Vietnamese civilians and to the U.S. troops who dumped it on them. Cyanides are well known poisons including the one that killed thousands in Bhopal, India. It's more toxic albeit less volatile first cousin has been used here in Elmira. 6PPD is a tire additive to reduce rubber deterioration from ozone. It is implicated around the world for causing fish mortality especially in trout and salmon. NDMA we all know as a waste by-product of Uniroyal's TUEX brand name. NDMA is highly carcinogenic but rest assured our political authorities at all levels have avoided ANY health studies in and around Elmira and the Old Order Mennonite population along the Canagagigue Creek, downstream of Uniroyal/Lanxess. Wouldn't want to embarass our world class polluters or cause them any undue costs. ............................................................................................................ Think about these facts all fellow travellors of Uniroyal/Crompton/Chemtura and now Lanxess. You are complicit. Oh and rest assurred: the list in the title above is all I either know or can remember at the moment. How many more are there that will be slowly exposed in the upcoming years?

2021 ANNUAL REPORT FOR THE PINEBUSH WELL SYSTEM (CAMBRIDGE)

This well system is located in the north-east part of Cambridge not too far from the former Ciba-Geigy pesticide plant. Those of you with long memories will recall the alleged "single" leak of dinoseb to the natural environment back in the early 1990s. Such typical, political drivel. When the smoke cleared there were at least a couple of dozen different chemicals in the soil and groundwater around the plant and if memnory serves me correctly that includes the infamous NDMA found throughout Elmira's well water. This well system consists of three wells namely P10, P11 and P17. We are advised in the report that normally only two wells are in operation at any one time with P10 operating in conjunction with either P11 or P17. Here's where things get sticky. Yes there were over a million and a half dollars in equipment repairs and replacements to the Pinebush Water Treatment Plant in 2021. Hence wells P10 and P11 were offline for 15 weeks in 2021 as was the entire Pinebush Well System. Fair enough but...why was well P17 down for the entire year? This is highly suspicious and one likely reason is that that well is being pumped to waste. In other words the alleged "single" spill of Dinoseb thirty years ago is still having an effect on the groundwater quality. ........................................................................................................ Bacteria results and nitrate and Nitrite results are very good. The last Sodium result published (2018) is high however. All the other chemical results are from 2020 and while there are no surprises far too many of the Method Detection Limits (MDL) exceed 1 part per billion (ppb) which is too high for drinking water. There are 9 chemicals with MDLs at or above 1 ppb with Glyphosate (Roundup) at 25 ppb. which is outrageous and the purpose is likely simply hiding Glyphosate detections in our drinking water. ............................................................................................................ Overall this well system seems typical which means that it does have groundwater quality issues from industrial discharges however the Region of Waterloo are "managing" them. While I hope that the bad old days are gone more likely it's just that governments and bureaucracies have learned to keep things quieter than the 1990's with Northstar Aerospace in the Bishop St. community, Ciba-Geigy, Canadian General Tower, Uniroyal Chemical in Elmira etc.

BEYOND GARBAGE, BEYOND STUPID, BEYOND GIBBERISH: WHY AREN"T TAG MEMBERS SCREAMING AT LANXESS, GHD & STANTEC?

Oh right I keep forgetting. The TAG members were handpicked to be polite, respectful and "nice" at all times to the professional liars in front of them. Did TAG members take an oath of non-hostility, non-confrontation and even non-anger despite whatever prevarications, factual untruths, deception and outright gibberish are presented to them? It sure looks that way. Where is Will Smith when you really need him? O.K. bad example but it sure makes the comparison when you realize how offensive the constant lying and deception is without TAG members, at the very least, confronting Lanxess, MECP, GHD or Stantec. Call them out! Let the public hear what you know about the raw data being used in the ridiculous Risk Assessment. ........................................................................................................ I've just done a quick review (this time) of both the 2017 and 2020 Canagagigue Creek "Investigations". Way beyond pitiful. Way beyond contemptible. Way beyond truthful. The Emperor (Ramin?) has no clothes and NOBODY at TAG will tell him so to his face. I am beyond disgusted. Yes Sediment results are technically and factually worse than Soil results. Partially this is due to sediment criteria being at least ten times more stringent (i.e. lower) than soil results. Hence if you have a Method Detection Limit (MDL) of .020 ppm (ug/g) for both soil and sediment but the MECP Table 8 criteria for some DDT compounds in soil is .05 ppm then an exceedance of that criteria at least registers as a detection (i.e. the criteria exceeds the MDL). However the same MDL (.020) for sediments having a lower criteria due to greater exposure to lifeforms in the sediments will often not register as either a detection or an exceedance. This is because the Table 8 criteria for some DDT compounds in sediment is .005 ppm hence the MDL is four time greater than the criteria. Other criteria for sediments such as the ISQG (Interim Sediment Quality Guidelines) have even lower criteria than the Table 8 criteria thus putting the MDLs even that many more times greater than the criteria. What a scam! ................................................................................................................. Make no mistake, soil results are also jigged. Make no mistake that these high MDLs are thousands of miles beyond self-serving for Lanxess Canada. They have effectively taken a grossly contaminated creek from the former Uniroyal Chemical site all the way to the Grand River (5 miles) and superficially made it appear to just have a few exceedances here and there combined with a few "hotspots" here and there. The Risk Assessment draft Conclusions go beyond asinine, in my opinion, all the way to manslaughter. Both wildlife and human beings have sufferred for decades without proper acknowledgement or proper remediation of the creek and clearly our authorities at all levels support this coverup.

LANXESS SHAREHOLDERS REJOICE: EXCAVATING A FEW CREEKBANKS IS MUCH CHEAPER THAN REMOVING TOXIC SEDIMENTS THE LENGTH OF THE CANAGAGIGUE CREEK

Hunh? Why is this? Well sediments are the soil if you will on the bottom of the creek. Sediments started as suspended sediments in the flowing water and can be deposited either on the bottom of the creek where they do build up to a certain amount and or they can be deposited in ...wait for it... depositiional zones along the creek as creekbank soils. These are likely on inside, curved slower moving areas of the creek (i.e. inside bends). Of course heavy rains and floods can certainly remobilize these sediments as well as creekbank soils and put them back into the water column where they move yet further downstream. Simple mechanics of excavating drier soils above the water line make them much easier to remove then dredging the bottom of a small creek and avoiding ripping up the creekbanks in the process. Also environmental controls to attempt to minimize gross amounts of suspended sediments killing fish etc. would be much greater while excavating sediments than creekbank soils. ................................................................................................................................ A week ago I posted here about the ridiculously high Method Detection Limits (MDL) in the "2020 Canagagigue Creek Sediment and Soil Investigation" and how they grossly minimized both detections as well as exceedances of criteria by toxic compounds. Sediment results are by far much more subject to these high MDLs than Creekbank soils. Why? I think my first paragraph answers that question. Secondly it is the DDT compounds (DDD, DDE, DDT) that are subject to these high MDLs, not dioxins/furans. Why is this? I'm not sure but it is strange that the dioxin TEQs (Toxic Equivalents) are measured in picograms per gram (pg/g) which are the same as parts per trillion (ppt) wheras DDT concentrations are generally measured in either parts per billion (ppb) or parts per million (ppm). The ppt are 1,000 times smaller than ppb which are 1,000 times smaller than ppm and yet the labs seem to have no difficulties in accurately measuring the dioxins which are at least a thousand times lower concentrations than the DDT compounds. Seems just a tad self-serving to me. ............................................................................................................................................ Since last Monday when I mentioned that Stantec had not included the data from the "2020 Canagagigue Creek...Investigation", I have explored further. It is clear that Stantec did include some data from the 2020 Investigation such as the Stroh Drain very high sediment results provided by GHD as well as the Pacific Rim lab reports provided by myself. Including the Pacific Rim results in the Risk Assessment (RA) was very odd as zero provenance or background information was provided along with the lab report. In other words how many witnesses were present during the sampling, where exactly in the area of the Stroh Drain were the samples taken, at what depth, via what protocols etc. Also the Pacific Rim lab results were NOT as Stantec stated, a combination of soils and sediments together. That is incorrect. One of the soil samples was a composite of two different soil samples and the other soil sample was just that: a soil sample taken quite close to the Stroh Drain. ........................................................................................................................ My further explorations mentioned in the previous paragraph are in regards to 2020 data NOT being included in the RA. I have looked carefully for creekbank soils, flodplain soils and sediment results from the 2020 Investigation and I can not find them in Stantec's Risk Assessment. I still also have inquiries out on this matter but I am concluding that possibly Stantec have decided that the ridiculously high MDLs rule out the validity or accuracy of the aforementioned soil and sediment sample results. Too bad that Stantec didn't also feel that way about the data from the "2017 Canagagigue Creek Sediment and Floodplain Soil Investigation" as well. GIGO - Garbage In Garbage Out.

NO WONDER WOOLWICH'S ATTITUDE TOWARDS CONFLICTS OF INTEREST IS SO BAD

Duff Conacher of Democracy Watch was quoted a few days ago in the Waterloo Region Record as suggesting that both the provincial Ethics laws for M.P.P.s as well as Conflict of Interest laws need to be renamed. Mr. Conacher stated that they should be titled " The Law for Making Conflicts of Interest Impossible to Enforce" or something very close to that. He further advised that not only was enforcement of the current law almost non-existent but when an attempt was made it was via a "kangaroo" court of other M.P.P.s judging their own. ........................................................................................................... Mr. Conacher and Democracy Watch have a long and honourable history of making governments more transparent and accountable. Here in Woolwich we have a joke at the start of each RAC and TAG meeting in which members piously deny being in Pecuniary conflict of interests. What a farce. Both Pat McLean as a CPAC member paid travel expenses, accomodations and meals to sit on the National Advisory Panel for the Canadian Chemical producers Assoc. as well as Susan Bryant who received at the very least copies of the E-DAT computer program showing wells and aquifers beneath Elmira, literally many years before other stakeholders, citizen volunteers etc. were in gross violation of Conflict of Interest matters. Pat would have been nominated by Crompton/Chemtura when she was the Chair of the Chemtura Public Advisory Committee (CPAC) kept her appointment and freebies quiet throughout her tenure as Chair. Similarly Susan Bryant kept quiet from CPAC while she was a member that she was doing editing work for Conestoga Rovers, consultants to Crompton/Chemtura and being compensated, I repeat at the minimum, by years early access to data and information that would have been very helpful to all CPAC members and the general public. ............................................................................................................................... So again clearly if our provincial governments show no real concern for Conflicts of Interest then Woolwich see nothing but advantages in appointing and keeping conflicted citizens on Boards and Committees. This includes when a formal complaint has been made as it was in 2017 by the 2011-2015 CPAC membership to Sandy Shantz and Woolwich Council. Woolwich absolutely refused to investigate, discuss or acknowledge any of it.

TAG - AS ALWAYS, GOOD NEWS AND BAD NEWS

Man it is difficult to determine my own feelings towards TAG members. Yes in general I believe the TAG committee doesn't have a chance. That is by intent of Lanxess, MECP and Woolwich Township. That said, there are good members on TAG including Sebastian, Wilson and David for sure with hopefully Linda and Dustin as well. Heck even Susan last evening spoke well on behalf of the residents (Old Order Mennonites) along the Canagagigue Creek. Usually I include Katharina but she is still trying to complete reading the Risk Assessment with, as a Biologist, her focus on the Ecological Risk Assessment (ERA). Tiffany is a bust, Sandy's presence is a farce and Dustin has missed the last couple of meetings. Linda was a little quiet last night but other TAG members did step up. ................................................................................................ Wilson appropriately raised the alarm concerning Polycyclic Aromatic Hydrocarbons (PAH- pyrene, fluoranthene, antracene etc.) with concentrations greater than the screening (criteria) values. He suggested that there was a data gap as the CCME (Canadian Council of Ministers of the Environment) as well as Ontario Ministry of Environment (MECP) criteria are more for ecological (wildlife) purposes than for human health issues. Wilson also criticized Dose Averaging over a lifetime as being inappropriate for farmers/Residents who have heavy exposure to creek sediments and soils for about 60 days per year. Carcinogenic effects and others could misrepresent exposure and risk as these shorter risk timelines are underestimated via Dose Averaging. .............................................................................................. Sebastian raised the issue of a Health Assessment for the Mennonite families along the creek. Wilson suggested that Health Assessments have been done before in other Risk Assessments (RA) that he's seen. Basically a health history of residents might give TAG and others a better understanding of the risks involved. Tiffany, unsurprisingly to me, seemed unenthusiastic to the idea. Sebastian further advised that Elmira has seen nothing from the Ministry of Health (provincial or federal) over the decades. Susan suggested that APTE decades ago tried to raise health issues and or studies and got nowhere with any authorities. She also suggested that something like a blood test for dioxins could be helpful. Regarding concerns for pregnant women and their heightened exposure/risk to toxins, Wilson stated that "no level of dose averaging is appropriate if a human receptor is pregnant." Susan added that WHO (World Health Organization) have stated that there is "No safe level of exposure" for dioxins . Finally Wilson stated that he does not agree with all of Stantec's assumptions such as chickens aren't near the creek and that cattle crossing time in the creek is limited. He feels that these assumptions are unsupported. ....................................................................................................................................... David recalled that there were assumptions made about sediments and sand being diluted before they ended up as amendments to the soil in gardens. He finds those assumptions to be odd. Susan pointed out that currently there is little to no exposure to Uniroyal Chemical contaminants in our drinking water with the Elmira aquifers no longer suppling that water. She therefore suggested that there was both greater human exposure through the creek and that the substances involved (DDT & dioxins) were more dangerous than dissolved chemicals in groundwater. Therefore why was more money not being used to clean up the creek. Linda agreed somewhat with Susan although she also is strongly in favour of restoring Elmira's groundwater to a potable condition. ................................................................................................ Years ago I too was told that there was no safe level of dioxin exposure. Now the MECP, Lanxess consultants and others are trumpeting mathematical formulas determining Risks from Exposures, Hazards and Receptors present. It seems obvious to me that "suits" far away from the acute toxins released by Uniroyal Chemical have no business telling people living amongst those toxins for the last fifty to seventy yaers, anything. It also seems to me that those very same "suits" are being paid by the polluter not by the residents. Will TAG ever stand up and tell Lanxess/GHD/MECP to FU.K OFF? .................................................................................................... Lastly no one is mentioning the Martin swimming pond. CHILDREN swam in it for generations. It is filled by contaminated groundwater as well as by the contaminated Stroh Drain with dioxins and DDD at the absolute minimum based upon the wholly inadequate "2020 Canagagigue Creek Soil and Sediment Investigation". Both myself and a TAG member have seen the pipe flowing from the Stroh Drain and discharging into the Martin pond. A former Woolwich councilor has also seen that pipe although I'm skeptical of that councillor as an honest witness. Exactly where in this entire bullsh.t process has Stantec or anybody else determined the Risks that those generations of children have been exposed to?

LANXESS/GHD SELF SERVING MISREPRESENTATION OF THEIR OWN CRAPPY DATA

The "2017 Canagagigue Creek Sediment and Floodplain Soil Investigation" is riddled with poor data, poor sampling protocols, and ridiculous labratory Method Detection Limits. Despite that, honest brokers could make some accurate understandings and conclusions from parts of the data if they so wished. They do not. Lanxess and GHD via their Risk Assessment (HHERA) have come up with conclusions and assumptions that fly in the face of their own data and its'very limited quality. Via their Risk Assessment they have made gross conclusions such as the only unacceptable risks for human beings exist in Reach 4, the Lanxess site. These they claim can be mitigated by the use of Personal Protective Equipment (PPE). They have also concluded that for ecological receptors Reach 4 has the only unacceptable risks. Specific to the 2017 report are various data presented in their Figures section. This data should have been discussed/debated page by page three and a half years ago but was not. ................................................................................................................... These Figures compare numbers and percentages of various contaminants (DDT & dioxins) with their locations in the creek i.e. Reach 1 (next to the Grand R.) with Reaches 2, 3 and 4 (Lanxess site). While there appears to be some decrease in concentrations in Reach 1, it is minor. Similarly Figures showing "normalized" concentrations of contaminants in regards to the number of metres from the Grand River is an eye opener. The concentrations again are very similar. Reach 2 (around Northfield Dr.) is greatly under represented in these Figures for some reason despite a number of samples taken from that area. Graphs showing the distribution of higher concentrations found in each of the four Reaches also contradict the broad and self serving conclusion that Reaches 1, 2, and 3 are much less toxic and risky than Reach 4 (Lanxess site). Depth sample comparisons are also interesting as it appears to me that there are just as many higher concentrations of contaminants in deeper soil/sediment samples as in shallower ones. Lastly there are graphs comparing different concentration results taken by the Ontario Ministry of Environment versus GHD. The results generally show significantly higher concentrations analyzed by the MECP for the same samples than by GHD and their labs. What the hell! Are GHD even fudging their collection of samples or somehow diluting them prior to analysis??? .................................................................................................................. In the real world crappy, dishonest and generally low quality reports get thrown into the garbage bin. In Elmira/Woolwich, with the blessing of the Ministry of Environment they are misinterpreted, fudged and if necessary stakeholders can be intimidated into compliance. What Woolwich citizens need more than alleged "experts" looking out for their interests are trained and experienced citizens whose careers can not be jeopardized by Lanxess, GHD and or the Ministry of Environment (MECP). In other words more independence and fewer "suits" would go a long way. Oh right Woolwich had that up until September 2015 and they and Chemtura/Lanxess/MECP didn't care for it and got rid of it.

MORE

......................................................................................................................................... LEFT CLICK ON PICTURE/CARTOON TO MAKE IT LARGER! Sometimes a picture is worth a thousand words and this is one of those times. This discussion of inaccurate and deceptive data encapsulates the junk science/psuedo science used by CRA, Uniroyal, MOE/MECP since 1989. Many of our local politicians are aware of the state of "investigations" done in Elmira, Ontario and they don't care. Or in the words of Saul Bellow (K-W Record Sept.11,2021) "A great deal of intelligence can be invested in ignorance when the need for illusion is deep." It's all about maintaining the status quo and keeping most people believing in our authorities basic honesty. ........................................................................................................................................ Prior to 2008 I used to ask Susan Bryant why she and I could not challenge Uniroyal/Crompton/Chemtura plus any buddies they wanted (CRA, MOE/MECP etc.) to a public debate regarding the cleanup of the Elmira Aquifers and of the Canagagigue Creek. Susan always demurred for reasons unknown to me. Since 2008-09 when I finally figured out the game I understood that such a debate could have turned things around completely. I knew then and now that between Susan and myself and the truth, we could have thumped all the professional liars publicly. Which is exactly what nobody else wanted.

GIGO - GARBAGE IN AND GARBAGE OUT - THE SHAME OF PROFESSIONAL LIARS IN CHARGE

The Draft Risk Assessment released recently to TAG members and other stakeholders is based upon truly awful raw data. Awful in that it grossly minimizes the extent of serious contamination of the Canagagigue Creek from the former Uniroyal Chemical (now Lanxess Canada) downstream five miles to the Grand River. Of course it also goes further than that but to my knowledge specific Uniroyal compounds have not been tested for in the Grand River. I have over the last several days been giving updtaes on specific problems/failures with this "Draft Risk Assessment Canagagigue Creek, Elmira, Ontario". I have also gone back to the original reports including as of this morning the "2017 Canagagigue Creek Sediment and Floodplain Soil Investigation" as well as yesterday's "2020 Canagagigue Creek Sediment and Soil Investigation". .......................................................................................................................... Besides refreshing my memory with the Figures section (6.1 - 6.11) of the 2017 report, I also went to the Archives in my Elmira Advocate Blog. Well that was certainly an eye opener as well. The Figures section showed the analytical results up and down the creek including non-detects, detections and exceedances of both the Ministry's (MECP) Table 8 criteria as well as of the ISQG (Interim Sediment Quality Guidelines). I had written several comments on the various Figures mostly very critical of the obvious attempts through colouring exceedances to minimize the readily visual extent (volume) of contamination as well as the severity of it. Similar to the 2020 Investigation, the numbers of Method Detection Limits (MDL) in excess of the criteria for both Soils and Sediments is incredible. While a MDL of .020 parts per million (ppm) decreases the number of both detections and exceedances for DDD, DDE, and DDT, the deception is greater for Sediments than Soils because the two criteria (MECP Table 8, ISQG) are very much lower for Sediments than they are for Soils. Hence a MDL 7 or 8 times higher than the criiteria for these pesticides in Soils is more like 50 times higher than the criteria for Sediments and hence even more likely to be documented as a Non-Detect (N.D.). The dates for some of my Elmira Advocate posts on the 2017 Canagagigue Creek ...Investigation can be found by going through my Archives Section on the right side of my Blog. The dates you would be looking for include April 4, 5, 12 2018 as well as June 30, 2018. I'm sure there are lots more. .................................................................................................................................... Generally speaking the Method Detection Limit bias is against finding detections and exceedances in Sediments for Lindane, DDD, DDE and DDT. Dioxins/furans do seem to get a much more accurate treatment. There is also a MDL bias against Soils but as mentioned in the previous paragraph is less pronounced and deceptive than it is for Sediments. Finally both reports (2017 & 2020) have an incredible bias against either detections or exceedances of PCBs, pesticides other than DDT compounds such as lindane, endosulfan, aldrin methoxyclor etc., and Polycyclic Hydrocarbons (PAH). On top of all this is the locational bias that years ago I both wrote about and spoke at public CPAC meetings regarding the 2012-2015 sampling done in the Canagagigue Creek. All in all by using grossly inadequate and biased data the company (Lanxess) and the Ministry of Environment (MECP) have assurred that the Risk Assessment for the Canagagigue Creek (HHERA) grossly minimizes and understates the risk to both human beings and wildlife. This should save Lanxess Canada many, many millions of dollars in cleanup costs. Payoffs to the MECP, local politicians and a couple of local citizens are in order. Try not to cheap out there as well if you want future concessions and special treatment at the expense of the public and environment. .....................................................................................................................

................................................................................................... Left Click To Make The Image Larger - Just a humourous reminder about GIGO

IS IT POSSIBLE THAT STANTEC SIMPLY COULDN'T STOMACH LANXESS/GHD'S RIDICULOUS JUNK SCIENCE DATA? (i.e GARBAGE IN GARBAGE OUT)

................................................................................................................................................ LEFT CLICK ON ABOVE CARTOON TO EXPAND IT FOR EASIER READING! ......................................................................................................................................... O.K. besides going through the recent "Draft Risk Assessment Canagagigue Creek, Elmira, Ontario" I have also reread and carefully examined the data in the "2020 Canagagigue Creek Sediment and Soil Investigation". The data is horrific in that over and over again we have labratory Method Detection Limits (MDL) 50, 60, 70, 100, 200 and 285 times greater than the criteria for a specific toxic chemical compound. In other words the toxic compound whether lindane or one of the DDT compounds (DDD, DDE, DDT) will not register as a detection much less an exceedance of the health and safety criteria unless the the concentration is 50, 60, 70, 100, 200, or 285 times greater than the criteria depending on which ridiculously magnified MDL is used. All these compounds based upon their toxicity have appropriately low concentration criteria which criteria are measurable by professional labs. UNLESS...the lab may have higer costs for analyzing at extremely low concentrations based upon greater effort and work required OR if there are a multitude of other compounds present in the sample above and beyond the specific one being analyzed for. In that case perhaps the polluter involved needs to identify some of the other compounds present. In the case of Uniroayl Chemical it could be any one of 150 various chemical compounds of varying toxicities. If the sample (soil or sediment) is so bad that reasonably accurate concentrations cannot even be determined by a professional lab then perhaps the obvious decision should be to start excavating and removing the grossly contaminated soils or sediments from the natural environment. Unfortunately Uniroyal/Lanxess almost seem to embrace these situations that make their pollution data essentially useless. In other words they treat these Non-Detects at ridiculously high Method Detection Limits (MDL) as being true Non-Detects which they are not. A Non-Detect at a MDL that is at least close to the health criteria can give the reader a reasonable understanding of the extent of the contamination and possible risks involved. A Non-Detect at a MDL however that is 50 times higher or more than the health criteria is essentially useless. There could be severe contamination with serious risks involved for persons or wildlife exposed to the contaminant or not. There is no way of knowing under those circumstances. On and off the Uniroyal site there are enough detections of so many contaminants that one should assume that a high MDL Non-Detect is bogus rather than the other way around. ................................................................................................................ Examples are as follows: Background Sediments (i.e. four creeks) for Lindane have Method Detection Limits between 10.5 and 106.3 times greater than the criteria of .00094 ppm. DDD has Method Detection Limits (MDL) between 6.4 and 64.9 times greater than the criteria of .00354 ppm. DDE has MDLs between 23.9 and 119.0 times greater than the criteria of .00142 ppm. DDT has MDLs between 19.3 and 193.2 times greater than the criteria of .00119 ppm. .................................................................................................................................. The Stroh Drain which I refer to as the Stroh Drain, Ditch & Berm (SDDB) has the following ridiculously high Sediment MDLs of between 106.4 and 159.6 times greater than the criteria for the pesticide Lindane. DDD (pesticide) has sediment MDLs between 64.9 and 96.0 times greater than their criteria. DDE has MDLs between 119.7 and 176.1 times greater than their criteria. DDT sediment has MDLs between 193.3 and 285.7 times greater than their criteria. ..................................................................................................................................... Sediments in Reach 3 (immediately downstream from Lanxess property) have MDLs between 10.6 and 106.4 times greater than the criteria for Lindane in creek Sediments. DDD has MDLs in Reach 3 between 3.1 and 65.0 times greater than their sediment criteria. DDE has MDLs between 12.0 and 119.7 times greater than their sediment criteria. Finally DDT has MDLs between 19.3 and 193.2 times greater than their sediment criteria. ....................................................................................................................... The very same nonsense occurs for Reach 4 (Lanxess property) in the Canagagigue Creek. Dioxins appear unaffected by this high MDL plague. Similarly Soil samples are much less affected than Sediments. Overall these high MDLs greatly lower the number of both detections and exceedances of contaminants tested for in the creek. They also clearly give most readers, on a limited time budget, the quick impression (via Non-Detects) that the Creek is in better shape than it really is. It is contaminated the entire length from Lanxess all the way (5 miles) to the Grand River, both above and below criteria, with multiple compounds including dioxins, DDT, DDD, DDE, lindane (Likely), PCBs, PAHs, mercury and more, in both soils and sediments. I've based the title above on Stantec allegedly NOT including any of the "2020 Canagagigue Creek Soil and Sediment Investigation" into their recently released "Risk Assessment Canagagigue Creek, Elmira, Ontario". I have inquiries out on this matter. If in the 650 or more pages I've simply missed a page or two or more with the 2020 data in it then I can assume that Stantec are actually able to stomach Lanxess's ridiculous junk science data. My bad.

MORE CANAGAGIGUE CREEK RISK ASSESSMENT FAILURES BEING UNCOVERED

First of all where the hell is the most recent Soil & Sediment sampling? That would be the 2020 Canagagigue Creek Soil and Sediment Investigation. I've gone through the entire 450 page Appendix "C" in the recently released Draft Canagagigue Creek Risk Assessment and it's not there. All the other investigations since 1995 are there namely 95-97, 2001-2003, 2011-15, 2017. I've also gone through the Text, Figures and all the other Appendixes. Nada. O.K. the entire report might be 600 pages or more but I don't think the 2020 data is present. The only thing dumber and even more damning of the credibility of this report, out of at least a half dozen serious stupidiies, would be the inclusion of the Pacific Rim data (provided by me to Ramin) without ANY specifics including when, where, who, and how. Yes I do have inquiries underway with others asking if they know where the 2020 data could possibly be hidden. ................................................................................................. Why should the 2020 data be more embarassing to the phony narrative of a few "hot spots" only in the creek? All the data over the last thirty years have shown exceedances in Soil and Sediments all the way down the Canagagigue Creek as far as the Grand River. At that point they stop sampling but trust me there is no such thing as a DDT or dioxin "net" across the mouth of the Canagagigue Creek preventing hundreds of Uniroyal Chemical compounds from flowing southwards towards Kitchener, Waterloo and Cambridge.

CREEK RISK ASSESSMENT - JUST MORE OF THE SAME DISHONESTY AND DECEIT

I have received the Minutes from the last TAG meeting (February 24/22). Here we have captured TAG's comments to the HHERA (Risk Assessment) presented by Stantec on behalf of Lanxess Canada and GHD their consultants. What an absolute croc of crap. The Risk Assessment that is. TAG have raised a number of legitimate concerns most of which were brushed aside, minimized or dismissed outright by Dr. Knopper of Stantec. I mean hell the poor guy wants to get paid by Lanxess for all his work afterall. .................................................................................................................... TAG are concerned about "dose averaging" of farmer/residents. Stantec determined that they have about 60 days per year of exposure and that is considered "short term exposure". Wow! I just love it when unexposed "experts" tell residents that their exposure is just fine (i.e. "acceptable"). TAG pushed fairly hard regarding the lack of data for the Stroh Drain area and hence a mjor part of the Stroh and Martin properties. Again Stantec/Lanxess have totally unrealistically compared Stroh Drain exposure levels to those of Reaches 1 and 2. Dr. Knopper concluded by strongly advising TAG that Stantec "...are confident in their findings." Findings I might add totally determined by the inadequate sampling of GHD. Inadequate via numbers, location and protocol (shovel vs. core samplers). TAG's concerns regarding fish consumption by the Mennonite community and other key assumptions by Stantec regarding chickens and cattle consumption were also politely brushed aside by Dr. Knopper. Afterall he is the expert explaining high level technical B/S to both lay persons and yes professionals in other fields (biology/hydrogeology/soils etc.). Dr. Knopper assured TAG that restrictions or public advisories were unecessary. ............................................................................................................................ Already high existing body burdens of DDT and dioxins/furans were raised by TAG members. Fortunately for Lanxess, MECP, GHD and Stantec those are all private between the Mennonite residents and their doctors. No health study has ever been done and if our local politicians have anything to say about it, none ever will be. Dr. Knopper emphasized that it's all about what the regulators say are acceptable levels of risk present. Nobody denies the presence of DDT, dioxins and two more; it's all about their alleged exposure to humans and wildlife and hence level of risk. Of course the other 150 chemicals - 4 Contaminants of Potential Concern = 146 allegedly don't provide any risk whatsoever and hence are excluded from consideration. That is a huge parcel of inadulterated horse manure. .................................................................................................................. Susan Bryant (TAG) and Ramin Ansari (Lanxess) had a brief discussion regarding the known "hotspots" in the creek. Ramin did not commit himself to removing them only in re-examining the data. He's concerned about excavating one or two areas and then not knowing how far to go and when to stop. I call BULLSH.T on that. The whole exercise is simply a mathematical attempt to MINIMIZE cleanup and MINIMIZE costs to Lanxess Canada at the expense of both wildlife and human health. As it has been for the last seventy years approximately. ............................................................................................................................................... Susan in writing is suggesting that Lanxess excavating a couple of hotspots along the creek would be acceptable to the community. Of course it would be as long as the intentionally misinformed community believe that those are the only "hotspots" Hardly. Locational sampling bias has been obvious for many years and I've written about it here and at CPAC in 2012-2015. Excavation of two or three "hotspots" is better than nothing but it likely only scratches the surface. The real plan is just to let these toxins continue flowing down the Canagagigue to the Grand River, with or without minor excavation/cleanup.

UPCOMING TAG MEETING

As has been for the last couple of years the TAG (Technical Advisory Group) meeting will be virtual versus in person. Personally I think it's time to go back to live, in person meetings. The meeting is next Thursday at 6:30 pm. and there is an announcement in today's Woolwich Observer with details such as how to register with the support specialist ahead of time. Basically an e-mail to lschaefer@woolwich.ca prior to this Tuesday at noon hour will get you in. ......................................................................................................................... Therefore we are talking about March 24/22 at 6:30 pm. although those watching are all requested to show up at 6:15 pm. to ensure that all can be seen and not heard. That's right attendance in Woolwich does not mean participation. The public however are allowed to express joy and or admiration at the highly customized attempt at public consultation here in Elmira/Woolwich Township. Local polluters and politicians are in love with this format and constantly like to brag about how local citizens come together to better their environment. In fact TAG has evolved yes into a number of very good citizens who unfortunately have enough ties with the local environmental industry to ensure that unlike the past CPAC, they always remain "nice" in their dealings with the Ministry of Environment, Lanxess and their consultants GHD. There is no severe criticism as that might upset the dirty polluters in town and their political stooges on Woolwich Council. There is no calling out of either apparent lies or even of the blatant ones. First and foremost TAG always remain "nice" even when being led down the garden path. ................................................................................................................ The Agenda of next Thursday's meeting and Minutes of last month's meeting will likely be e-mailed out tomorrow.

I"M HALF WAY THROUGH OR MORE THE 450 PAGES IN APPENDIX C OF THE RISK ASSESSMENT

Today's post is relevant to both last Monday's and last Saturday's posts here in the Advocate. The difference is I am well over 100 pages further along in my analysis of the raw data. It is frankly a disgusting exercise. There are in places tens of pages in a row with either DDT or dioxin results but the same sediment samples have not been analyzed for PAHs, PCBs or a multitude of pesticides such as lindane, eldrin, endrin, endosulfan and many more. The contaminant bias is becoming clearer and clearer. It is becoming even worse than the locational bias I have written about before. Clearly Uniroyal/Lanxess are trying to sell the public a bill of goods. Yes the 450 pages of raw data are available to TAG members but trust me none of them, all with full time jobs, have examined 250-300 pages carefully as I have. The results are stunningly bad as far as this being even remotely a legitimate Risk Assessment either for human beings or the ecology. ................................................................................................................................... PCBs were regularly found in 1995-97 when they were analyzed for. When they were Non-Detect it was generally at a Method Detection Limit of 20 parts per billion (ppb) which of course hides the lower concentration PCBs. Polycyclic Aromatic Hydrocarbons (PAH) were also regularly found in the mid 1990s. Like PCBs they were also regularly NOT found or analyzed for after that. These compounds include anthracene, pyrene, benzo a pyrene, fluorene, pyrelene, napthalene and many others. They are highly toxic. One potential slipup was a sediment sample analyzed in August 2015. Unbelievably, fifty years supposedly after the overflowing east side ponds quit overflowing and discharging, twenty different PAHs were found with concentrations from Trace levels up to 240 ppb. Pesticides are similar. There are about 25 of them listed and usually ignored during analysis of samples. Highly toxic Lindane was commonly found in sediments etc. during the mid 1990s. A few samples wwere analyzed in 2014 and found low levels (1-3 ppb.) of chlordane, and cis & trans nonachlor. Other pesticides during a very rare sampling found seven different Uniroyal Chemical pesticides present at concentrations of 1-2 ppb.. ............................................................................................................................................... I just came upon a PCB sample in creek sediments at a concentration of 320 parts per billion (ppb). Another one is at 220 ppb. In the last paragraph I mentioned an August 2015 analysis for PAHs. Well the same sampling event however at a different location also came up with PAHs, some at concentrations of 230, 240 and 250 ppb. The two prizewinners, pyrene and fluoranthene were at 440 ppb and 500 ppb. Interestingly one of the highest recent levels of pesticides in sediments were sampled and sent for professional analysis by CPAC in 2015. These results are in this Risk Assessment and have concentrations as high as 530 ppb of Fluoranthene. ............................................................................................................................................ There are a number of conclusions. PCBs, PAHs (20 of them) and 25 different pesticdes other than DDT are not being regularly analyzed for. At the same time when they are analyzed for, they are found to be present. All of these compounds are toxic and do not belong in animals, birds, fish, reptiles or human beings. The alleged criteria for them are based upon each chemical, absolutely by itself, having a certain numerical safe concentration. Nobody knows what the toxicity of exposure to multiple chemical compounds simultaneously is. What we do know is that a Risk Assessment based upon DDT and dioxins/furans primarily is a joke when there are so many other toxic compounds in the creek being studiously ignored AND when humans present have already been exposed for decades. The last conclusion is this: Uniroyal/Crompton/Chemtura/Lanxess have cheerfully and patiently delayed and delayed beginning cleanup of the Canagagigue Creek. No wonder when every day their toxins continue to leave their property and migrate downstream towards the Grand River. Should they be financially rewarded for their complicity in using downstream citizens as guinea pigs since 1943?

THE LAW IS STILL AN ASS - USE AND ABUSE OF THE LAW CONTINUES (KELLY DONOVAN)

It is my recollection that a couple of years ago, lawyer James Bennet, on behalf of the Waterloo Region Police Service (WRPS), actually admitted that many female police officers had been treated improperly and inappropriately by the force over the decades. He then went on however to suggest that despite that they were using the wrong venue to redress their grievances. Well here we are a few years later and that game continues. It continues because the courts and the judiciary want it to continue. Today's Waterloo Region Record carries a story titled "Former local police officer's allegation of bias by a judge against her called "spurious". That headline by the way also needs discussion because I believe that it is biased. ........................................................................................................ Is there anyone who has kept in touch with current events in Canada who does not know of the institutional bias against women in our military, local police forces and RCMP? Essentially any and all male dominated professions/jobs rely on the majority of males not wanting to have to compete against women for promotions, plum assignments etc. Then of course as was proven in the early 90s here in Waterloo Region, the City of Waterloo's Public Works Department was also a bastian of male supremacy and bias against females doing physical work on the landscape crews and others. I know because I worked there and I assisted a lady who was being harassed. Of course neither the male dominated union nor the management staff were any help whatsoever as their focus was on protecting the vast majority of male members of which only a few were actually the problem. ...................................................................................................................................... To date a class action suit against both the Police Services Board and the WRPS has been unsucessful. Similarly Kelly Donovan, a former police officer who went her own route seeking redress has had years of delay and denial thrown at her. This appears to be the main plan of the guilty parties. Multiply the stress, the hassle and the financial costs of redress through the legal system until the litigants go away. Meanwhile the courts in a blaze of institutional, intentional stupidity advise the litigants to go back to their hopeless and biased unions and or go to the Human Rights Tribunal of Ontario. ........................................................................................................................... Exactly how stupid are all these institutions? Well as I said in the second paragraph is there anyone who has kept in touch with current events who hasn't been reading for many years the horrible, illegal and unethical treatment of women within the RCMP, army and navy and in numerous police forces? Our institutions have lost immeasurable respect from the public who pay the bills. How many intelligent parents would advise their daughters to seek a career in those professions? How many current female members of those professions, despite their individual experiences on the job, good or bad, could honestly recommend it to new female recruits? My personal belief has always been that it is the male as.holes at the top who never embraced or agreed with opening the doors to women who have tacitly looked the other way and given mere lip service to gender integration of these jobs. The result is that they have denigrated and disrespected the very institutions that they allegedly were trying to protect/insulate.

YOU WILL NOT FIND WHAT YOU REFUSE TO SAMPLE FOR

The corollary of the title above is that polluters can and do affect the conclusions of their sampling simply by insisting on sampling the very same one or two compounds while ignoring other significant toxic compounds that they know are present. The overall idea is to minimize the dollars necessary to properly and fully clean up contamination that they've been the biggest contributers to. While many of all these toxic compounds are present together, often one area will have greater PAH or PCB contamination while another has DDT compounds in great concentrations. Similarly Lindane and other non DDT pesticides can be particularly high in one location while dioxin/furans have their higher concentrations just upstream or downstream. ................................................................................................................ To date I have carefully examined about 100 pages of the 450 pages of data in Appemdix C of the Risk Assessment. These results include sediments in the bottom of the creek, surface soils on the Uniroyal/Lanxess site and creekbank soils above the waterline but along the creek itself. Here are the results: ................................................................................................................................... Surface soils on site: ........28 different samples and positive detections for DDT compounds (i.e. including DDD & DDE).............. ...............................90 different samples and positive detections for dioxin/furan compounds...................... ................................9 different samples and positive detections for polycyclic aromatic hydrocarbons (PAH)......... ...............................24 instances where PAHs were listed as NOT being sampled for......................... ................................2 different samples and positive detections for PCBs.......................... ...............................30 different samples with Non-Detect (N.D.) PCB results and high Method detection Limits........ ...............................58 instances where PCBs were listed as NOT being sampled for......................... ................................0 different samples and detections for Pesticides other than DDT................... ............................................................................................................. ....................................................................... Sediments......................34 different samples and positive detections for DDT compounds (i.e. including DDD & DDE)........ ..............................118 different samples and positive detections for dixin/furan compounds..................... ................................1 positive detections for PAHs.................................................. ..............................106 instances where PAHs were listed as NOT being sampled for..................... ...............................55 instances where PCBs were listed as NOT being sampled for..................... ................................2 different samples with Non-Detect (N.D.) PCB results and high Method Detection Limits......... ................................8 different samples and positive detections for pesticides other than DDT.......... ...............................36 instances where pesticides were listed as NOT being sampled for................ ................................................................................................................ ................................................................................................................. Creekbank Soils...............137 different samples and positive detections for DDT compounds (includ DDD & DDE)......... ..............................154 different samples and detections for dioxin/furan compounds................................ ................................0 different samples and detections for PAHs............................... ..............................154 instances where PCBs were listed as NOT being sampled for............. ..............................154 instances where pesticides other than DDT were NOT listed as being tested for.......... .................................................................................................................................. .................................................................. Obviously this is a lot of work. Obviously prior to the last TAG meeting last month likely exactly nobody including me had time to thoroughly analyze this data prior to the public but virtual meeting. That was intentionally done as usual.

A DIFFERENT TYPE OF SELF-SERVING SAMPLING BIAS

Regarding the Lanxess Canada site in Elmira, Ontario I have previously elaborated on locational sampling biases. These have included much greater sampling at locations along the creek that have public road access as well as once Chemtura/Lanxess found "hot spots" they focused all their future sampling on these locations. What that did was to artificially reduce the likelihood of finding other "hot spots" downstream from the former Uniroyal Chemical site. ...................................................................................................................... Today's sampling bias is even more insidious. There is an old saying that "You will never find what you don't look for." In other words if you don't want to find a lot of mercury in the Canagagigue Creek than don't test for it. If you are particularly worried about finding PCBs in either soils or sediments then for gosh sakes don't analyse in the lab for PCBs. The very same for Polycyclic Aromatic Hydrocarbons (PAH). The same strategy goes for pesticides other than DDT. If you want to avoid finding Endrin, endosulfan, dieldrin, lindane and so many others then avoid testing for them in the lab. Problem solved. You see if there is little transparency combined with minimal accountability then you the polluter (and friends) are off to the races. ................................................................................................................ I'm currently going through Appendix C in the recently released Draft Risk Assessment (HHERA) for the Canagagigue Creek. While there are a huge number of sediment, soil and creekbank samples there is a dearth of compounds being tested for. It's all about dioxin/furans and DDT with a few solvents, metals, PCBs and PAHs occasionally thrown in for filler. If you test for PCBs ten times over ten years then the best you will ever get on average is one detection per year at a 100% detection rate. Imagine however if you test for DDT one hundred times a year for ten years! If you only had a detection rate of 25% you would still average 25 detections per year. This is the joy and the shame of dishonest statisticians. This is how polluters and fellow travellors deceive citizens and remove other present toxic compounds from consideration.

WAR, ENVIRONMENT, HUMAN SUFFERING

Obviously bombing, shelling and destroying cities does neither the residents nor the environment any good whatsoever. There is no "upside" environmentally to dead bodies in the streets, starving and freezing human beings. Also obviously the gasoline and diesel fuel required to run war machines increases fossil fuel use. Open fires to keep people warm also adds to global warming as wood fires en masse are likely far worse environmentally than modern day effecient gas furnces. There are major concerns with food production as the Ukraine normally export vast amounts of grains to the world. I don't even want to think about the damage to the world environment in the case of even a limited nuclear war. Radiation poisoning, air pollution and even greater loss of life and resources required to keep the survivors alive is a small part of that scenario. ............................................................................................................ The media seem to feel that Russia (Putin) badly miscalculated the amount of resistance to invasion that the Ukraine would and could mount. At the same time pundits are now suggesting that Putin has only two very bad options. The first is to withdraw, lose face and support at home for his miscalculation and adventurism and possibly be removed internally as the leader of Russia. That option is obviously very unappealing to Putin. The second option is to take off the gloves and do to Kviv what they've done to two other Ukranian cities namely totally destroy them. Hence the "two very bad options" for Putin and the world. ........................................................................................................ Is there a third option put forth by Nato and the U.S. a possibility? Obviously a "face saving" retreat by Putin is both unlikely or an impossibility. Is there a a way to give Putin a "victory" that immediately ends the war, keeps the Ukraine independent and restores peace in Europe? The face saving victory is probably what Putin at this moment needs. It is difficult to believe that the world wide condemnation plus economic and financial sanctions are not a huge concern to Russia in the long run. Even world wide sports sanctions and isolation must affect the Russian people and eventually their government. Politicians and dictators alike want credibility and respect. So too do their citizens. Russia on the world stage are seen in a positive light at the Olympics and as economic partners. All of that is currently at risk. Yes a quick trip to the Ukraine along with installing a puppet pro Russian government was likely what Putin wanted and gambled on. That quick trip hasn't come about. ..................................................................................................... Most wars end when one side or the other are devastated beyond any hope of a military turnaround. The worst wars occur when two very powerful sides go at each other. As stupid as that is we (humanity) have proven our stupidity over and over again throughout history. Are the rest of the world capable of negotiating with Russia a mutually satisfactory end to this conflict BEFORE it escalates to more countries and also preferably before the Ukraine is a smoking mess of death and destruction? I do not believe that either of those two options are Russia's (Putin's) desired result. Russia wants nuetral or pro-Russian satellite countries between them and Europe. A broken, smoking, starving Ukraine isn't much of a buffer or protection from NATO or Europe in general.

WILSON LAU (TAG) AND "DOSE AVERAGING" OR A FANCY TERM FOR DILUTION IS THE SOLUTION TO POLLUTION

In the Canagagigue Creek there are Sediment exceedances of the ISQG (Interim Sediment Quality Guidelines) hundreds and even a couple of thousand times greater than the criteria. There are also exceedances of the Table 8 MECP Guidelines for Soil that are hundreds of times greater than the criteria. There are surface soils on the Lanxess property, there are creekbank soils above the waterline along the creek and there are Floodplain Soils further downstream which also have high concentrations of DDT and dioxins/furans. Clearly the source of these exceedances and toxic contaminants is the former Uniroyal Chemical now known as Lanxess Canada. Possibly/allegedly there are different sources for mercury, PAHs and PCBs in the Canagagigue Creek. I say possibly/allegedly because after thirty plus years of lying and deception who in the world knows when those @#$%^&* are telling the truth or not? ....................................................................................................... Yes there are very high and toxic concentrations of DDT, dioxins/furans and so many other chemicals here and there in the creek soils and sediments both on and off the former Uniroyal property. At the same time there are hundreds of low level concentrations of these very same chemicals intermingled from the Uniroyal/Lanxess site all the way down to the Grand River (& likely past). Why is this? Well first of all certain hydrophobic chemical compounds far more readily attach themselves to soils and particles rather than dissolve freely in water. These moving suspended sediments in surface water bodies (Creeks, rivers etc.) usually end up downstream being deposited either on the bottom of the waterway (i.e. sediments) or along curves in the creek. Hence there are both depositional as well as erosional areas along creeks. These of course can change over decades and centuries. ................................................................................................................... I have long maintained that there has been a huge sampling bias over the years in the Canagagigue Creek. Firstly it's so much easier for technicians and samplers to access the creek at the various three roads and bridges crosssing the Canagagigue namely New Jerusalm Rd., Northfield Dr. and Jigs Hollow Dr (By West Montrose). Secondly as soon as you've hit some high concentrations you keep coming back to the same easy access area. hence there are huge portions of the downstream Canagagigue that have never been sampled. ......................................................................................................................... Now for the purposes of both a Human Health and Ecological Risk Assessment (HHERA) Lanxess and friends are looking at the presence of toxic compounds in the natural environment (i.e. Risk). Then they are looking at whether there are any Receptors (human & wildlife). Finally they are looking at and calculating the amount of Exposure of each and every receptor to the toxic compounds that are present. Right off the bat they are looking at probabilities not possibilities. In other words if the human presence is limited by recreational opportunities such as the "Gig" not being a trout river then that lowers the risk. If the Canagagigue ("Gig") doesn't have rapids then there is no exposure from white water rafting. There are a hundred opportunities to limit exposure times and amounts and the various algorithms and calculations incorporate them. There are also opportunities to limit the number of toxic compounds and hence Risk. Lanxess refuse to acknowledge that exposure to Polycyclic Aromatic Hydrocarbons (PAH), PCBs and mercury are their repsonsibility so despite their presence in the creek they are totally removed in the mathematical considerations. Lanxess and friends then pretend that they have properly calculated the Risk and Exposure to local residents, wildlife and recreational users when they have not. .......................................................................................................... Going back to "Dose Averaging" I might agree in theory that a creek that has only 50% of it's length grossly contaminated MIGHT (or Not) be less toxic or risky that one that is grossly contaminated from Lanxess all the way (5 miles plus) downstream to the Grand River. This is because end points could include acute poisoning and quick death or longer term toxic doses that also eventually end up in death. In other words dead is dead whether today or tomorrow. Similarly cancer can be provoked by short term acute exposures or by longer term lesser exposures. Much of these Risk Assessment calculations are based on assumptions and guesswork. The sloppier the sampling (sampling biases), the sloppier the analyses (Detection Limits> criteria), the sloppier the public consultation (ELMIRA!) and the more dishonest the people in charge, the greater the assumptions and guesswork. .................................................................................................................................. In a nutshell what are Lanxess, GHD and Stantec doing with their Risk Assessment? By examing the toxins that have flowed five miles downstream over the last 3/4 century they are appropriately admitting the obvious. Pollution migrates. What they are conveniently pretending to ignore is that DILUTION IS THE SOLUTION TO POLLUTION. They are intentionally averaging in all the low level detections of DDT and dioxins/furans found both on their site and found even more two to five miles downstream. The reality is that all their various chemical compounds have gone far past the mouth of the "Gig" into the Grand River but again they have been even more diluted in the higher water volumes in the Grand River. The Canagagigue should have been cleaned up fifty years ago but what the hell it has moved tremendous amounts of Uniroyal's poisons downstream and this free waste disposal service was not going to be stopped a single minute sooner than necessary. And our governments and Ministry of Environment have enabled this shameful disgrace without conscience. And now Lanxess want a pat on the back and an "Atta boy" for a grossly delayed and grossly inadequate "cleanup" of the creek. They all deserve time in prison for their antisocial and criminal behaviours.

BAIT & SWITCH GUIDELINES (RISK ASSESSMENT)

First of all these are another method for dishonest brokers such as polluters and governments to use on citizens. They are best served along with prevarication, deceit, psuedo science, puffery and heavy duty bullsh.t. I discovered these different guidelines on page 91 of the text during a fish consumption discussion. Many years ago we in Elmira were advised in writing of Tissue Residue Guidelines (TRG) for fish. Then sampling was done and surprise, surprise all kinds of fish in the Canagagigue Creek surpassed the TRGs for DDT, dioxins, mercury and PCBs. It was obvious and it was a no brainer that both Uniroyal Chemical pollution and allegedly some other source or two had contaminated the fish well beyond consumption limits. The TRG for DDT in fish is 14 parts per billion (ppb) and the TRG for dioxins in fish is a much smaller .7 parts per trillion (ppt). Both of these were unsurprisingly exceeded in the Canagagigue Creek. .............................................................................................................. Now more than three decades after local citizens involvement with the Ministry of Environment and a multitude of other lying officials we learn that well no TRGs really aren't what counts. Apparently in 2012 Health Cnada came up with a Human Consumption Guideline for DDT which is 5,000 ppb. To add insult to injury in 2020 the Government of Canada decided that 20 ppt dioxins was an appropriate guideline. Talk about moving the goalposts and or a huge Bait & Switch. This is not the first time that our authorities have moved criteria and guidelines albeit they usually claim it's due to new data. My belief is it's due to new requirements for an industry that can't make the cut. In other words for political reasons. Decades ago there was game playing going on with Trichloroethylene (TCE). Industry cried that the 5 ppb. guideline was too rigorous so they got a temporay reprieve as the Ontario Drinking Water Standards (ODWS) were raised to 50 ppb. for TCE. Later they were lowered again. This is your government looking after the financial health of industry rather than the health of their citizens.

KEN REGER PASSED LAST SATURDAY

The Obituary in today's K-w record advises that Ken was in his 90th year. Ken was very well known in and around Elmira for his advocacy regarding re-establishing bluebirds into the surrounding area. He built and monitored hundreds of nest boxes in Woolwich and Wellington Townships. Ken also worked for a number of years at Uniroyal Chemical where he was a steamfitter. For me Ken's claim to fame was his advocacy and testimony at the Environmental Appeal Board hearings held in Elmira in the very early 1990s. I also was priveleged over the years to occasionally talk to Ken on the phone for environmental advice regarding Uniroyal's successor corporations (Crompton, Chemtura etc.). ............................................................................................................ I have quoted Ken in my book (Amazon/Kindle) titled "Elmira Water Woes: The Triumph of Corruption, Deceit and Citizen Betrayal". I quoted Ken from articles in the Elmira Independent and K-W Record in which he was quoted speaking at the Environmental Appeal Board (EAB) hearings in Elmira. Ken's testimony was factual, to the point and first hand. He spoke to the results of chemical contamination in the pelts and bodies of muskrats and other animals that he trapped in and around the Canagagigue Creek. He also spoke to the barrels placed on top of each other (9 barrels deep) that were buried at the south end of the former municipal landfill (M-2) on the Uniroyal property. These barrels of chemicals were unearthed during the 1965 excavations to build the Elmirs Sewage Treatment Plant. To this day I believe that his testimony carried more weight and credibility than anything any of the "suits" and other professionals had to say at the hearing. To this day Ken's first hand testimony can still be used to refute both MOE/MECP and Lanxess Canada historic horse manure that they still try to peddle.

LANXESS - TRULY STUNNING COWARDICE

Lanxess use and misuse data with supreme confidence because they know that just like in Russia they can silence dissent and opposing opinions. In Russia they throw opponebnts of their political regieme as well as of their military aggression in jail for years. Here they also misuse the courts albeit not quite to the same extreme. Lanxess have bizarrely used the Pacific Rim lab report as some sort of vindication of their utter and complete gutless wonder failure to properly investigate the Stroh property to their immediate east. Each and every small incursion to sample soils on the Stroh western border with Lanxess (Uniroyal) has led to stunning results when you realize that the overflowing Uniroyal Chemical wastes on the company's eastern border ended over half a century ago. The same thing happened with three out of four sediment samples analyzed from the Stroh Drain as they well exceeded the federal ISQG (Interim Sediment Quality Guidelines) for dioxins/furans. ................................................................................................. The Pacific Rim Lab report provided by myself to Ramin of Lanxess had a composite soil sample with a concentration of 4.06 parts per trillion dioxins/furans. While below the 7 parts per trillion (ppt) soil standard for soils within 30 metres of a surface water body, it wasn't that far below. The other concentration was 1.4 ppt. These are the only two soil samples taken in or around the Stroh Drain to the utter shame of both Lanxess and the Ontario Ministry of Environment. Ramin and Lanxess in their recent Draft Risk Assessment for the Canagagigue Creek brazenly boast that these concentrations vindicate their failures to sample these soils. TWO soil samples beside a 450 metre long drain that indeed have dioxins/furans (2,3,7,8 TCDD) present fifty years after the cessation of gravity flowing waste waters into this private property next door. These two soil samples prove that an honest, serious, unbiased investigation is required. Those two soil samples in conjunction with four sediment samples analyzed by GHD consultants on behalf of Lanxess, in the Stroh Drain, are a smoking gun proving that exactly as the topographical contours of the GRCA, Region of Waterloo, CRA indicate; overflowing waste waters from Uniroyal's east side pits gravity flowed onto the Stroh property to the immediate east of the north end of the Stroh Drain where they settled into a low lying, bowl shaped area. Now of course this low lying area also overflowed from time to time and further discharged these dioxin laced waters further south both on the Stroh property (& Martin property) and then into the Canagagigue Creek. ...................................................................................................... How can Lanxess make their ridiculous claims? Simple. They have eliminated local citizens with backbones who will oppose them. We (CPAC) have been eliminated from speaking, asking questions or making comments at public meetings. The truth is in the data but when the citizen reps are carefully chosen by Woolwich Township (& Lanxess) NOT to be aggressive or confrontational then they are easily ignored and silenced. Brazen lying and incredible bullsh.t are enough to make most good people back down. The data even in the two Reaches of the creek (Reach 3 & 4) closest to Uniroyal/Lanxess have dioxin/furan concentrations all over the map. Dioxins and most chemical compounds do not readly mix in soils the way they do in solvents, oils and waters. Hence you can literally have concentrations a hundred times higher than all criteria literally beside another soil sample (or sediment sample) that has a concentration of dioxins/furans of .3 parts per trillion. This is normal and in fact by going through either the original 2017 and 2020 Canagagigue Creek Investigation data or the same data in Appendix C of this report released earlier this year one readily sees how many soil sample concentrations are exceeded by my (Pacific Rim) lab report and especially also the vast majority ((approx. 94%) of sediment sample concentrations in Reaches 3 and 4 that are exceeded by the sediment results in the Stroh Drain. That Lanxess can in writing explain this away is a lie/bullsh.t on the order of the U.S. claiming "weapons of mass destruction" being in Iraq. The company have no shame and no pride. They are beyond pathetic and are emboldened by the support of fellow travellors including local politicians with their own agenda. ..................................................................................................... As long as Lanxess receive the support of their local fellow travellors they feel no need to be even careful with their lies. Nobody else matters to them including their victims over the decades.

LANXESS STUPIDITY APPEARS INVULNERABLE TO EITHER REASON OR STRENGTH

A week ago yesterday I posted here about the public, virtual TAG meeting and how a number of TAG members while being too deferential to the professional liars present, nevertheless spoke truth to power. Overall I guess that I was pleased that TAG members, despite their deference, did look carefully at the Draft Risk Assessment (RA), and expressed their concerns and criticisms. Maybe someday Lanxess might develop some empathy, concern, human kindness, honesty and decency. Meanwhile it's all bullsh.t baffles brains and nobody at these virtual, public meetings appear willing to call the company out and confront them. Kind of embarasses the crap out of me that this is what citizen "public consultation" has degenerated into. Esther Thiur, Pat Potter and the early Susan Bryant, before being co-opted, would never have believed it would happen. Can you just imagine a TAG member saying to Lanxess/GHD something like: "Wow I really enjoyed your rendition of the limited facts that we have. Could you possibly top that off with your opinion that your pollution has actually toughened up human beings and wildlife and that therefore your saving tens of millions of dollars on proper toxic waste management has helped everybody?" ......................................................................................................................... Way back in 1994 when I, Rich Clausi and Esther Thur left APTE, I advised the media that I would call a spade a spade. I didn't mention calling a liar a liar and in fact have been extremely judicious at in person meetings to avoid quite that strength of language. I've been much less so here. Regardless when CRA or Chemtura/Crompton/Uniroyal just blatantly lied and got caught I have been known to suggest that their comment was "horse manure". Oh for the good old days when you could at least slightly embarass the Ministry of Environment and or some of their bought and paid for consultants. Today it's all puffery and bullsh.t from them all. And we citizens (especially the younger ones) are putting up with it. ...................................................................................................... I hate to say it but it sure looks as if the old guard's patience is going to have to be rewarded via Lanxess (Uniroyal) doing what they have traditionally done which is screw up royally. The last really good one was the BLE-25 fugitive emissions that blanketed Elmira in the fall of 2010. That resulted in a whole sale changing of the guard at the municipal level (i.e. Woolwich Twn.) followed by the best CPAC (Chemtura Puvblic Advisory Committee) there ever was. That mess did property damage with hopefully limited health damage. We may get lucky again or maybe not but rest assurred as long as we have a very weak Ministry of Environment, very weak municipal council and the short term profit motive driving corporations, another one is coming. Maybe there will be a real awakening and maybe citizens will just go back to sleep again.

2021 REGION OF WATERLOO ANNUAL REPORT (Water)

WILLIAM ST. WELLFIELD in Waterloo ............................................................................................................ This wellfield has been problematic for many decades. Personally I blame Seagram's, Canbar and Sunar although what weight or responsibility each should be assigned I do not know. The most obvious horrid contaminant is Trichlororethylene (TCE), the same toxin in both the Middleton Wellfield (Cambridge) as well as in the Bishop St. community (Cambridge) courtesy primarly of Northstar Aerospace with some additional assistance from another nearby industry. ................................................................................................................... The William St. Wellfield consists of four wells namely W1B, W1C, W2 and W3 according to page two of the report. The very next page however we are advised that Well W1C was off-line for one week which could easily have been for annual maintenance. Well W3 however was off-line for 52 weeks last year. That is not maintenance that is a well either shut down for serious contamination or in the alternative "pumping to waste" for the very same reason. "Pumping to waste" is an unfortunately common occurence when you have contaminated groundwater. One well nearest the source may be designated as an Interceptor Well whose purpose is to intercept the bulk of the contamination and pump it to waste i.e. into the nearest sewer, drain or surface water body. This is one of the "management" methods the Region of Waterloo use to stickhandle around proper contamiant remediation. ............................................................................................................................................ The next issue is Sodium. My God but people on low Sodium diets had better not be drinking this tap water. Levels greater than 20 mg/l are reported to the Public Health Department and Ministry of Environment. The William St. Wellfield has Sodium at a concentration of 228 mg/l. Surprisingly to me Nitrates are also high albeit below the criteria of 10 mg/l. Normally Nitrates and Nitrites might be high when cattle, pigs etc. are nearby as in rural areas. William St. is in downtown Waterloo. Regardless the concentrations are higher than most at just over 3 mg/l. ...................................................................................................... Method Detection Limits (MDLs) concern me throughout these Annual (Water) reports. There are eight chemical compounds with MDLs at or greater than 1 ug/l (part per billion) including Glyphosate at a ridiculous 25 ug/l. These high MDLs can hide far too many detections of chemicals that individually may not be toxic but in conjunction with each other are. The science of health effects from multiple simultaneous toxic compounds in drinking water is essentially non-existent. ........................................................................................................................... Then we have TCE. Monthly and more testing shows that it is always present despite minimal treatment. While the results are below the Ontario Drinking Water Standards (ODWS) nevertheless both on its own for a period of decades as well as in conjunction with other low level contaminants, I do not believe that our authorities have a handle on the long term health effects. Lastly chloramines (product of bacteria disinfection) are consistently higher than half the standard prescribed by the ODWS and are thus red flagged. Overall Waterloo residents deserve better than this.

THIRTY-TWO YEARS LATER ONTARIO MANDATES NDMA REPORTING FOR WATERLOO REGION

Well I've been calling for many years for increases in the number of contaminants tested for in our drinking water such as toluene, ethylbenzene, xylenes and NDMA or N-Nitrosodimethylamine. My suspicion of course has been that these toxic contaminants have been tested for for years (decades), detected and simply not reported in these Annual Reports (drinking water). According to page 9 of the recently released water report for 2021: "Municipal Drinking Water License 012-102 issue April 20, 2021 requires quarterly sampling Nitrosodimethylamine (NDMA) at the farthest pouint in the distribution system." This is on page 9 of the full on-line report (Region of Waterloo Annual Water reports) and on page 4 of the first report titled "Integrated Urban Water Distribution System (IUS)". ...................................................................................................... Yes NDMA is the contaminant which shut down the Elmira two wellfields in 1989-1990 courtesy of Uniroyal Chemical with likely assistance from Varnicolor Chemical. Just a small part of the political coverup was the plethora of other polluters in Elmira operating under the huge pollution umbrella of Uniroyal Chemical. This included Varnicolor, Nutrite (Yara), gas stations, landfills, and other industrial facilities. Now at first glance I noticed that despite the Order demanding quarterly sampling for NDMA there were only three samples taken last year. Then looking at the April issue date that became clearer versus my thirty years of experience initially indicating to me that the vast majority of environmental laws are routinely ignored and rarely enforced. ..................................................................................................... The criteria for NDMA in drinking water is 9 parts per trillion (9 ng/l or .009 ug/l). The three samples reported were .0014, .0033 and .0027 ug/l which is the same as 1.4, 3.3 and 2.7 parts per trillion. Gosh I wonder what the levels of NDMA throughout the Kitchener, Waterloo and Cambridge system were thirty years ago? We'll likely never know.

REGION OF WATERLOO 2021 ANNUAL (WATER) REPORT

The above date is correct. These water reports are produced at the end of the previous year and generally in my opinion are both produced in order to comply with the Ontario Safe Drinking Water Act and for public relations purposes. I believe that the Region of Waterloo work hard within political constraints to provide good qual;ity drinking water. The problem of course is those "political constraints" and the number of regional councillors who are more concerned with steady political employment than they are with the health and safety of our citizens. ............................................................................................................... Today I'm going to discuss the 2021 Annual Report for the Middleton Well System in Cambridge. What an expensive and unhealthy water source the Middleton has been for many decades solely due to politicians' penchant to go easy on industrial polluters. Industrial polluters who of course provide employment and a tax base for our local governments. It's a classic case of shutting the farm gate after the horses have bolted. In this case the "horses" are DNAPL (dense non aqueous phase liquids) and to be specific the DNAPL chemical is Trichloroethylene (TCE) the very same chemical that Northstar Aerospace so egregiously dumped and spilled into the Bishop St. community causing immense human health suffering. In the Middleton Wellfield case the obvious source would be Canadian General Tower although I have had an informed professional advise me otherwise. Other suggestions include a nearby drycleaners from the days of TCE being a common dry cleaning fluid. .......................................................................................................................... There was over a third of a million dollars spent on electrical and software upgrades for Well Houses during 2021. This is a drop in the bucket overall for this wellfield and it's highly extensive and expensive treatment facilities necessary to remove toxic contaminants from the grossly polluted groundwater. Only treatment of Grand River water is more expensive. The raw water is both ground and surface water (Grand River) and it is the surface water that contributes bacteria, both E.Coli and Total Coliform, to the raw water input. This is removed via chlorine in one form or the other. Sodium is way too high (140 mg/l) and greatly exceeds the recommended level of 20 mg/l. The vast majority of industrial solvents and pesticides are Non_Detect however some are at far too a Method Detection Limit. In fact a total of nine chemicals are at Non-Detect with Method detcetion Limts (MDL) at or above 1 ug/l. Glyphosate is at a ridiculous MDL of 25 ug/l and this most likely is an administrative method of hiding exactly how much Glyphosate (Roundup) is now in our groundwater from excessive agricultural and residential use. ...................................................................................................................... Trichlorothylene (TCE) concentrations are scary stuff. Yes courtesy of expensive treatment combined with dilution from other wells in the Cambridge Wellfield System, the concentrations are below the Ontario Drinking Water Standards (ODWS). One is at 1.7 ug/l (parts per billion) and several in and around 1.5 ug/l or ppb. It is the ongoing longterm presence in Cambridge drinking water that concerns me. Combine that with zero knowledge of interactions with other chemicals (glyphosate for example) and I am very doubtful of the longterm health and safety of drinking water from this source. This wellfield as well as one in Waterloo (William St.) are a screaming indictment of past industrial practices allowing TCE seepage, leakage or dumping into the ground. It literally stays for decades to centuries in the groundwater.

CPAC AND WOOLWICH COUNCIL ANIMOSITY PUBLICLY BOILS OVER

Another history lesson for the smart people who know the importance of history and those that don't can just move along. Your rude, uninformed and stupid comments are just that. In September 2015 Woolwich Council via lying, disinformation and manufacturing a non-existent crisis, once again went to bat for our local, world class polluter. Mark Bauman and Sandy Shantz (councillor & mayor) attacked the integrity and competence of a group of Woolwich volunteers who had been appointed to CPAC (Chemtura Public Advisory Committee) by the previous council. The attack included a by invitation only, private meeting at the Township offices to throw mud and insults upon CPAC members (including myself) who had been refused admittance to the meeting concerning themselves. The date was April 9, 2015 and the worst offenders included Susan Bryant and Pat McLean, former members of CPAC who had not been reappointed by the Todd Cowan administration. They were however not both publicly and privately defamed as the 2011-Aug. 2015 CPAC members were. Also Pat and Susan were quietly removed due to their too close (chummy & self-serving?) connections with Conestoga Rovers and Uniroyal/Chemtura. .................................................................................................................... Between the March 29, 30 (K-W Record) and March 31/2016 Woolwich Observer, the animosity became more public. Then the Record also published stories and opinion pieces on April 5 and 6, 2016 as well. Basically Woolwich Council (Sandy & Mark) decided that payback to these Woolwich citizens and volunteers who had criticized their almost God like understanding and abilities to manage the cleanup of the Uniroyal Chemical polluted aquifers, soils and creeks was due. Therefore with Sandy and mark leading the charge the idiots publicly advised both Dr. Dan Holt and myself to go pound salt when we, following normal Delegation rules and policies, appeared at a Woolwich Council meeting to speak about Uniroyal/Chemtura Canada issues. Sandy and Mark as they have been known to do from time to time, simply made up shit. Oh they said, don't you know that Council have just recently (last summer) made up these two committees of new volunteers regarding the ongoing environmental cleanups? We at Council are far too busy/important to duplicate the job of these two appointed by council committees so take your comments to them. Of course Sandy and Mark didn't add that TAG (Technical Advisory Group) did NOT accept verbal Delegations to themselves. RAC (Remediation Advisory Committee) on the other hand would albeit they would only meet three or four times a year. Some years that is. Other years only twice. ......................................................................................................................................... Well when the smoke cleared Woolwich Council had been publicly roasted yet again by local media including television, radio and newspapers. Oh by the way the one Woolwich Councillor who spoke against the rest of council refusing to listen to Dr. Holt and I was Councillor Patrick Merlihan, co-owner of the Woolwich Observer. He at least knows the meaning of both free speech and the right of citizens to address their councils directly on serious, local issues.