WHAT ARE THE SLIMY, SCHEMING TWITS DOING?

 Well let's see now. Firstly they are not committing to pump, pump and more pump. Oh no just because they bragged, lied, boasted, lied,  shouted, lied about the wonders of hydraulic containment for twenty -five years (1991-2016) they aren't attacking our contaminated aquifers with even a tiny fraction of the pumping they themselves deemed necessary. They started cutting back on their costs back in 2016. They had never really hung in for long periods and achieved the pumping they said they could much less the TRIPLE and later DOUBLE the off-site pumping they (Chemtura/CRA) determined was necessary in November 2012. How can any honest person involved in this fiasco have the slightest respect for the dirty polluter, their impotent regulator and or the consultants working for them? The answer is simple. Honest people do NOT have the slightest respect for PROFESSIONAL LIARS and their fellow travellors such as the RMOW, Woolwich Twn,. GRCA. I expect that after watching their behaviour since 1989 I would gag having to sit with those filth.

O.K. so what are they committed to doing?  How about rewriting history, making excuses both old and new and generally patting each other on the backs and saying "What swell fellows are we!". I mean look at what they've accomplished.  They've reduced cleanup costs to the absolute minimum and less even as their failures have become more apparent. They have made a bunch of incompetent twits at TRAC believe in themselves. I am of course referring to Allan Deal and Luis Almeida of GHD amongst them. Oh I nearly forgot. The dishonourable and corrupt Ontario Ministry of Environment are rewriting the Control Order or whatever name they are giving their optional, only if you feel up to it, suggestions certainly not orders or commands. This new document will mostly be discussed in private between Lanxess and the MECP (Ministry of Enhanced Corporate Pollution) although there will be some token once over by TRAC at the very least for appearances sake.. 

Finally the guilty parties will do some more studies. Just imagine almost twenty-seven years ago (August 1998) they started pumping the off-site municipal aquifers.  CPAC has known since early in 2012 that they didn't have a hope in succeeding and actually briefly had Woolwich Twn. support on that matter. A mere nearly thirteen years later Lanxess Canada feel the need to examine other proven cleanup technologies. 

WHY THE HELL ARE WE LEAVING THE LYING, CORRUPT PARTIES (FOXES) IN CHARGE OF THE HENHOUSE ?   

ARE WE ALL REALLY THIS STUPID OR DO WE NEED TO DO SOMETHING MORE CONCRETE?

K-W RECORD HAMMERS CHEMTURA/UNIROYAL IN OCTOBER 2016

 

The front page story on October 21, 2016 was titled "Chemtura starts offsite chemical probe". It was followed by a Record Editorial on October 28, 2016 titled "Get serious about Elmira cleanup".News flash K-W Record: Uniroyal and successors have never been serious about cleaning up Elmira. It's all been for show and for appearances.  It's now eight years later and what has been done? Not a single shovel full of contaminated downstream soils and sediments have been removed from the Canagagigue Creek.  Our aquifers are not only admitted to being still well above drinking water standards for NDMA and chlorobenzene (& likely other chemicals) but all guilty parties are dancing a jig of joy for their public relations acumen and how their false and pathetic excuses are being lapped up. Perhaps that's why they call them lapdogs rather than watchdogs?

The so called chemical probe on the east side Stroh property was just one more sham among many. Fifteen centimetres or 5.9 inches is how deep those swine sampled the soils. Despite this they got tons of hits above health criteria.  They sampled perhaps 15 metres eastwards from the Uniroyal property line with Stroh. 

As far as the Record's Editorial let me ask them this. If Chemtura's and the M.O. E.'s  cleanup wasn't serious eight years ago what the hell is it now? A JOKE, a FARCE, a SCAM ? All they are doing right now is smoothing and fine tuning their excuses as to why they are still decades away from restoring the Elmira Aquifers to drinking water standards. I and a few other CPAC members have been telling the media and the corrupt Ministry of Environment for decades as to what needed doing and they have only been listening to the company's bought and paid for experts (QPs) as well as a few co-opted semi citizens on the Woolwich hand picked committee who have benefited personally from giving concessions to the polluter. 

Come on K-W Record WE STILL NEED YOU TO DO YOUR JOB!   

WOW AND WE THINK THAT WE HAVE A CRISIS HERE IN CANADA

 

"Trudeau must go, " "Trudeau and the Liberals have lost the confidence of the House" etc. etc. etc.  True or not I would suggest that Canada's problems fade into obscurity next to say Israel's, Syria's Russia's and the Ukraine. If the resignation and following critical letter by a senior Cabinet Minister signal the end of Justin Trudeau then what on earth does the detonation of a bomb in the heart of Moscow targeting a senior Russian General do? General Kirillov was the head of the Nuclear, Biological and Chemical authority and the Ukraine are publicly taking "credit" for his assassination. He had been accused by the Ukraine of using chemical weapons in the war there between Russia and the Ukraine. 

Then we learn that Israel, all of course in the name of Israeli security, are now occupying lands inside Syria. First they destroyed the Syrian Air Force via bombing and now they have troops stationed on and past the Golan Heights contrary to a treaty they signed along with Syria and the U.N. around 1974. Apparently ridding themselves of Hamas isn't enough nor is seriously damaging Hezbolah. This has been followed by incursions into Lebanon, Syria and possibly even Iran.    

Does any of this even in the slightest explain why Canadian politicians and authorities appear so slow and sloth like in their response to environmental problems from destroyed groundwater to climate change? Does this explain why the Canadian government are hell bent on scapegoating legal Canadian firearms owners for the governments own failures to stop gun smuggling across the U.S. border or to remove illegal firearms from the hands of street gangs in Toronto? 

Maybe Canadian politicians lack the imagination to be really bad buggars or maybe they are just better at hiding their foulest of deeds.

RECENT EXCELLENT SUPPORTING DOCUMENTS

 

Sebastian at least for the moment seems to be sticking to his membership with the Totally Rotten And Corrupt Committee (TRAC). Despite that error he is however producing some excellent critiques of Lanxess and GHD's (consultants) nonsense and ever wishful thinking masquerading as science.

In his December 5/24 critique to TRAC Sebastian takes issue with GHD's undying optimism that despite gross pumping failures and shutdowns , all is well hydraulic containment wise.  Sebastian states "In the monthly progress reports, GHD has a note at the bottom of the average daily pumping rates table stating: "...the Target Average pumping rates is set at 90% of the set point rate. GHD recommends that Lanxess maintain the target pumping rates greater than or equal to these rates."  The combined on-site pumping rates are now below the 50% mark and have been for months." 

So GHD writes one thing for public consumption (progress reports) but tells TRAC the absolute opposite. God how I despise professional liars.

Secondly Sebastian responded to GHD's nonsense about the  low lying "Gap" area draining Uniroyal Chemical toxins onto the Stroh property. Oh my Lord to have to deal with those GHD second string (literally) twits yet again. Sebastian stated "Let me just add that this response by GHD is typical.  The answers appear superficially plausible but do not have the details to support their always optimistic conclusions (to the company at least). There is a continued absence of professional detachment and of a critical disposition on the part of GHD which has gone on far too long as far as groundwater remediation in Elmira is concerned. We deserve better."

Meanwhile mayor Shantz and Woolwich Council continue to cover their eyes and ears and hold their nose while supporting this sham of a cleanup in Elmira. Our media have also grossly failed us. Where is the Elmira Independent when we so desperately need it?

OUR GOVERNMENTS ROUTINELY INDEMNIFY LOCAL CORPORATIONS AGAINST ADVERSE SITUATIONS

 

Two examples are obvious and neither was in the public interest. Safety-Kleen were indemnified against additional contamination found behind Breslube in Breslau in order to get Safety-Kleen to buy the company. The problem was there was a lot of contamination between Breslube and the Grand River in both the soils and groundwater. It included LNAPLs (oils) floating on the surface of the groundwater as well as lots of solvents, some chlorinated. There were also PCBs mixed in with the floating LNAPLS.  This contamination was serious enough to eventually shut down the two municipal wells close to the river known as K70 and K71 (K  for Kitchener). Of course the Region has failed to come clean with the public about this.

The second example has to do with the sale of Varnicolor Chemical to Phillips Environmental who wanted to keep the company going as a solvent recycler. The Ministry of Environment had a Control Order insisting on a full aerial and VERTCIAL examination of sub-surface contamination.  Gosh though Phillips were a little worried about the vertical examination and balked. Next thing you know  that cleanup condition is gone. This was about 1993 or 94. Guess what? To this day there are still Varnicolor Chemical solvents deep in the Municipal aquifer underneath the site. The MOE gave Phillips an Indemnity that they didn't have to go looking for the deep contamination that eventually we found was indeed there. 

Three bodies made separate deals with Uniroyal Chemical back in the 1990s allegedly for costs that they had incurred from Uniroyal's contamination. The Region of Waterloo may have gotten $40 million for their pipeline costs, lab costs etc. but it likely came with strings attached. Or maybe the $40 million was both costs and a bribe. Maybe it depends upon how you look at it. Regardless the Region backed off on DNAPL s just like the Township and the MOE. These last two also had their own agreements. We know that the MOE agreement was a sweetheart agreement that saved Uniroyal hundreds of millions of dollars in cleanup costs for both DNAPLs as well as "new" contamination found. In exchange for settling over the summer of 1991 the Ontario MOE were not publicly humiliated at the renewed Environmental Appeal Board hearings in the fall of 1991. In fact those hearings were shut down. The Township also settled for costs with Uniroyal but you can bet the farm that Uniroyal squeezed them but good probably in regards to "friendly" public consultation only.

This folks is how our governments deal behind our backs with corporate big shots flexing their financial muscles.

WEIRD ELMIRA/UNIROYAL HISTORY BY GERRY THOMPSON ON ROB DEUTSCHMANN'S PODCAST

  This particular Podcast (Old Grey Mare) is an hour long and was transmitted on May 14, 2022.  Full disclosure I had a small bias in favour of Rob Deutschmann based upon his persistent kicking sand in the WRPS and their stupid "civilian" Board's face. Gerry Thompson, former CAO of Waterloo Region, I doubt I've ever met although I have a tiny bias regarding his perceived closeness to Ken Seiling (in my eyes). 

The very early question from Rob to Gerry was why the Ministry of Environment (MOE) had not found NDMA much sooner than 1989. Oddly Gerry hummed and hawed but never said what the public had been told namely that the MOE had never tested for NDMA before. Personally I've always believed that the MOE lied about that (and so much more) and maybe Gerry forgot or he simply didn't want to repeat the lie.

Gerry also responded to a question about the MOE 's behaviour and actions thusly: "The MOE talk but do nothing."  Furthermore he said that "...the MOE has neither the ability nor the will to do anything...". Gerry also suggested that Uniroyal burying drums was "probably illegal".  Now by this time I'm wondering if this interview done in May 2022 was past Gerry's prime however he certainly sounded confident and sharp with his words.

Oddly Gerry hinted that the other parties to the legal action for costs seemed to be primed and ready to go. He suggested that Uniroyal already had Conestoga Rovers (hydrogeological consultants) on board as well as a number of Bay St. lawyers. My comment is that it's almost as if they'd been waiting for the MOE's announcement for months.

Gerry also suggested that initially it was thought that NDMA could be absorbed through the skin hence showers and baths were dangerous. Later on Gerry felt that this characteristic of NDMA was found to be false. Now that is not my recollection however that one I'd prefer to check out properly before calling Gerry nuts or wrong. By the way by this time in the podcast I'm really enjoying Gerry's comments but I've repeatedly  screamed in frustration at my monitor because of Rob's constant interruptions. His comments are not remotely as interesting as his guest's are but O.K. by the end of the podcast his interruptions had become less egregious.

Regarding dealing with Uniroyal and David Ash Gerry stated  that "they argued over everything..." and that David was a company man.". Now at one point Rob said something about "early detection" of NDMA which made absolutely no sense in the context of this whole interview.

Now this next one by Gerry is a whopper and one reason over the decades that I've lost respect for the Region of Waterloo. Gerry said that the contamination into the "Gig" was greatly reduced before "it could begin to migrate into the watershed (Grand R.)". Sorry Gerry but Uniroyal's toxic crap had been flowing down the Canagagigue Creek and into the Grand River since the mid and late 1940s a whole four decades before it was allegedly "discovered" in the Elmira south wellfield (E7/E9). Also the hydraulic containment of the aquifer discharging into the Canagagigue didn't begin until 1997.  Therefore more than fifty years for the dissolved contaminants as well as the undissolved but attached to sediments DDT and dioxins to also migrate a measly five miles downstream. 

Another huge problem for me is Gerry's claim that NDMA was a by-product of  herbicide Agent Orange production.  My knowledge is that NDMA was a by-product of  a couple of different Uniroyal product groups such as ADAM and another which escapes me at the moment. Probably what Gerry was thinking of was dioxin (2,3,7,8 TCDD) was a toxic by-product of Agent Orange .

Gerry did O.K. even for someone so closely involved in the crisis thirty plus years ago. If he did zero preparation for his podcast then the errors are somewhat explainable. Otherwise not so much. Fortunately there are still a few citizens around who can hold the history true.

 

WOOLWICH TWN./COUNCIL KNOWINGLY ALLOW & PROMOTE FALSE TESTIMONY AT THE TRAC COMMITTEE

 They do this by having the likes of Joe Ricker, Luis Almeida and Allan Deal speaking as mouthpieces for Lanxess Canada.  On another note, Sebastian I saw you working hard to get the truth out at last Monday's TRAC meeting.  You are opposed by professional, albeit sloppy liars as well as Woolwich officials (mayor, councillor(s?), Tiffany ($$$) ). I see absolutely no one on TRAC assisting you. Are they all that stupid, uninformed, corrupt, apathetic or are they under some kind of career duress? TRAC have two names namely Technical Remediation Advisory Committee or my preferred one of Totally Rotten And Corrupt. It is time Sebastian and you know it.

Further lies, drivel and bullsh**  from Monday's TRAC meeting include Tiffany's suggestion that the ridge is only 1/2 a metre high.  Nice try there. Go read the topographical contours and you will find it is higher. Also the contour lines have been conveniently altered off-site on the Stroh property.  Susan Bryant, decades ago, in  a fit of moral outrage stated that Uniroyal/Chemtura "adjust the science according to their needs". This is what they've always done and continue to do. Both Luis and Jason Rice of the MECP stated that there are no issues with the lack of data on the east side (Stroh property) and with the exceedances of DDD and 2,3,7,8 TCDD found in the Stroh Drain . Those dioxins were approximately 30 times greater than the federal sediment criteria for 2,3,7,8 TCDD. Allan Deal also categorically claimed (at least until he reverses himself) that dissolved concentrations of chlorobenzene will always keep increasing if there is DNAPL nearby. Horse manure. Sometimes maybe but the solubility of chlorobenzene is low especially in multi-mixtures of  dozens or hundreds of solvents etc. Mr. Deal then turned around and said that if the dissolved chlorobenzene concentrations are decreasing then there is no DNAPL nearby. Again horse manure! It all depends on other factors including well placed pumping wells beside the sub-surface free phase DNAPL pumping 24/7 over a period of years. That will lower dissolved concentrations of chlorobenzene while it still exists sub-surface as a DNAPL (dense non aqueous phase liquid). Mr. Deal's last comment may open a window into his incredibly bad understanding of DNAPLS. He claimed that his definition of Effective Solubilty is the presence of other solvents that may increase or decrease solubility. Wow what I've read and been told is that there are a few co-solvents out there, but not many, that can increase a chemical compound's solubility. Overall the more chemical compounds dissolved in groundwater drastically reduces the solubility of either chlorobenzene or whatever particular one you are looking at. Mr. Deal is a plain and simple DNAPL DENIER along with Luis and other self-serving semi-credentialed individuals.

All the parties who signed on to this conspiracy to pretend to clean the Elmira Aquifers and Creek should burn in hell. That includes citizen co-optees both the well known ones and the lesser so. Their presence engaging with the enemy is reminiscent of collaborators during the war. They did it for self-serving reasons and profited from it to their shame, then and now regardless of the magnitude of the issue (i.e. war vs. environmental degradation). Many human beings have at best a tiny moral compass and many of them rise to positions of authority (Donald Trump). 

Meanwhile Allan Deal and others venture their opinions on hydrogeological matters beyond their knowledge or scope. They have been indoctrinated to believe that their opinions have merit. They DO NOT. In fact their opinions are always HIGHLY SUSPECT. Produce relevant, not cherry picked evidence at all times. Your word and opinions are biased, bought and paid for and far too often inaccurate and misleading.

LANXESS TAG TEAM IDIOTS - LUIS & ALLAN D. ARE SETTING NEW LOWS IN INCOMPETENTCY

 I forgot to mention here yesterday that that turd Luis actually suggested that Sebastian was confused and was claiming that water ran uphill. Hmm "turd" could be a little strong as it implies that Luis intentionally attempted to undermine Sebastian's credibility so let's assume that Luis merely was confused and or is stupid and actually thinks that Sebastian said that which he did not. There were other misstatements (lies?) noted in the notes I made of the TRAC video by Luis. He stated that none of the aerial photos showed any kind of pathway or stressed vegetation from Uniroyal over to the Stroh property. In fact there are and while 1964 isn't very clear it is one of them. There is a much better one published by Conestoga Rovers in one of their GP-1, GP-2 reports around 2013. It was a non CPAC citizen who pointed it out that caused me to go on my self-guided tour (with R. Stroh permission).

First of all question #4 had asked GHD if they had done any calculations to determine chlorobenzene's Effective Solubility whether on or off site. The answer was an unsurprising no. This despite Jaimie Connolly (MOE) having done so years ago during DNAPL investigations on the former Uniroyal site.  Both Allan D. and Luis A. buttressed each other's frankly pathetic understanding of DNAPLS during their presentations.  Allan D. suggested yet again that he hadn't used the 1% Rule to deny DNAPL presence. Such a liar. Luis or Allan (tag team) also suggested that concentrations of dissolved chlorobenzene from pumping well W4 were around 4,000 ppb. He did this with exactly zero data backup presented. He also suggested that fifteen years later concentrations had dropped to below 80 ppb. the drinking water standard, again with zero data backup. Luis you are incompetent with either a poor memory or poor credibility or both. Your word is meaningless to the well informed. Produce the data for us. You also claimed that on-site pumping well PW4 had concentrations around 4,000 ppb. and that they have not decreased over decades of pumping. Listen you twit. That is nonsense. Concentrations at PW4, OW62 and OW88 all huddled together have exceeded 4,000 ppb. by orders of magnitude decades ago precisely because there was/is FREE Phase DNAPL present in the sub-surface and Bob Hillier (MOE) brought a sample form OW88 to UPAC in the early 90s.

Secondly DNAPL dissolves slowly hence it is difficult to get high concentrations of chlorobenzene at any time much less when an aquifer is being pumped 24/7. Of course concentrations will drop especially at off-site pumping well W4 that was pumped 24/7 for approx. fifteen years. Let's see the concentrations today and if they remain low then clearly the off-site chlorobenzene DNAPL at OW57-32 and near the Howard St. Water Tower had a  much smaller initial volume/weight etc. than on-site PW4 area.

One of the overhead Handouts (pg. 62) presented suggested that significant cosolvents in the per cent range or higher by total solvent composition could affect chlorobenzene concentrations. For the love of all that is holy you don't want to try to explain what you mean there. You will screw that up as well. The final point on this Handout (pg. 62) states that concentrations of unnamed VOCs and SVOCs in the off-site aquifers are in the parts per billion range and are not expected to have an impact on effective solubilities. Really? Without doing any calculations at all you can figure out Effective Solubilities in your head. Also again I might add not a single concentration result (with well # & date) is presented as backup. Finally you don't list the names of the VOCs and SVOCs you are referring to. Did you check a half dozen of them or 100 different Uniroyal solvents off site? I call BULLSHIT on that one. 

EXACTLY HOW THICK IS WOOLWICH TWN. HIDING BEHIND THE LIKES OF LUIS ALMEIDA & ALLAN DEAL OF GHD?

 

Monday night's TRAC meeting was at least as pathetic as the earlier ones that I have seen mostly on-line. O.M.G. but the brass, ignorance, horse manure and just plain lies are beyond any limits. Clearly when you can hide your lies behind donkeys selling donkey excrement then you no longer fear anybody on that committee calling you to account.  Sebastian tried and he tried hard. He did his homework and he had his facts in order. What he did not have was an honest venue or an honest Chair person. He politely dismantled Luis bullsh** about higher elevations and about the "Gap" not presenting as a possible contaminated area. After 35 years of arguing with bought and paid for credentialed  QPs I have learned that as long as the Chair (Nathan Cadeau) is either uninformed or corrupt, combined with the bulk of members being the same then absolutely any garbage masquerading as fact or truth will fly.  What I found most shameful was how Nathan allowed Luis to interrupt and shut Sebastian down (along with that crapper Hadley-Lanxess) and NONE of the other TRAC members said "Hey wait a minute. I want to hear  the  rest of what Sebastian is telling us." Clearly  TRAC have been given their marching instructions and that is to never pay any attention to Sebastian or for that matter myself. Worse yet they appear willing to let Sebastian blow in the breeze at the whim of corrupt officials and professional bullshit artists. 

Luis's magical swale on the west side of toxic ponds RPE 1-5 discharged from an open ditch into an open swamp and yet through the physical, chemical and psychological properties of wishful thinking and money all the contents then took flight over the swamp (which discharges east into the Stroh property) and from there the contents discharged into former gravel pit GP-1.  Anybody stupid enough to believe this Lanxess/GHD bullcrap will believe anything for a price. 

So Sandy, David, Nathan, Jason, Tiffany, Luis, Allan D., Hadley and others just name your price . Clearly you have and will continue to contort reality to make Lanxess and the Ontario MECP happy. Surely you will personally benefit from that?  

MONTROSE CHEMICAL LOS ANGELES - CALIFORNIA - *** DDT *** CHLOROBENZENE *** BENZENE *** REMIND YOU OF UNIROYAL CHEMICAL HERE IN ELMIRA, ONT.?

 

A 13 acre site, smaller than Uniroyal Chemical's in Elmira. A small amount of total DDT buried at sea but still millions of pounds. Toxic wildlife effects fourty plus years later. We are advised that chlorobenzene is one of the main components of DDT production. This site (Montrose Chemical) has been a SUPERFUND site for decades. Lawsuits were filed against it by both state and federal governments. Approximately $140 million spent to date on environmental issues. The site is riddled with DNAPLS (chlorobenzene). One of the remediation methods specific to DNAPL removal is known as ERH or Electrical Resistance Heating. Aecom Engineering & Consulting had provided a cleanup plan with parts of the site being cleaned within 32 to 50 years and other parts between 3,700 and 5,800 years! The EPA and other authorities rejected those cleanup plans as not timely. 

Note Woolwich Township: Various California authorities strongly condemned cleanup plans as "grossly inadequate", " absurd",  "fatally flawed", "unrealistic", "short sighted", "inaccurate" etc.  They were not subtle nor were they particularly polite when being given either misinformation or the runaround. I propose that symposiums and seminars be held to assist municipalities in dealing with recalcitrant polluters. They could be titled " 10 Step Process To Remove the Inherent Deferential, Uninformed and Unequal Balance of Power between multi national, multi billion dollar corporations and their  local municipal councils."

We at CPAC back in the 1990s and early 2000s were told that DDT and dioxins (2,3,7,8 TCDD) were both insoluble and immobile in water. We responded that Uniroyal's groundwater however was filled with   solvents which could mobilize many allegedly insoluble compounds including DDT and dioxins. Well guess what? These on-line technical reports concerning the Montrose Chemical cleanup specifically state that DDT is soluble in chlorobenzene. In fact it's solubility is high with about 74 g of DDT dissolving in only a 100 ml. of chlorobenzene. Further statements indicate that chlorobenzene contaminated groundwater along with DDT in it, will eventually cause the DDT to precipitate out. ".  "If this occurs, DDT may be a mobile toxic contaminant in the aquifer." . Funny how none of this has ever been explained to past UPAC/CPAC members or to the public. I guess consultants to polluters do not feel duty bound to share information that is distressing to their polluting clients.

Despite Allan Deal's (GHD) ridiculous statements and comments to TRAC this fall, CHLOROBENZENE IS DNAPL. It is the presence of both free phase and residual chlorobenzene DNAPL that has estimates of 3,700-5,800 years for cleanup by Aecom. Personally I've been aware that DNAPL in the subsurface can take decades to centuries to fully dissolve but these estimates even shock me.  What has also shocked me is the wanton disrespect for the truth about chlorobenzene/DNAPLS that so many here in Elmira have embraced including our hopeless Ministry of the Environment (MECP).   

DID UNIROYAL CHEMICAL DUMP 60 MILLION KILOGRAMS OF CHLOROBENZENE ON THEIR SITE BETWEEN 1945 AND 1970?

 

Wow but that's a huge number. Now keep in mind that we have a few other numbers at our disposal such as 160,000 to 175,000 gallons per day of toxic liquid wastes being discharged to possibly the east side ponds alone ( i.e. RPE 1-5). Now of course this daily dumping was not straight chlorobenzene. It was mixed in with benzene, toluene, xylenes, phenols, DDT, dioxins, 2,4-D and so much more. 

A few days ago I posted here that MORE THAN 3,300 kilograms of chlorobenzene was dumped on the Uniroyal site. Now this figure came from Lanxess/GHD who were bragging about how much chlorobenzene had been removed from Elmira's groundwater since pumping started in 1998. Well this weekend I started thinking about that figure (3,300 KG.) and something leapt out at me.  Chlorobenzene is a classic DNAPL chemical with a high density (greater than 1) and a low solubility. For example NDMA has a Solubility of 1,000,000 mg per litre (ppm.) whereas Chlorobenzene has a Solubility of only 466.3 mg/l (ppm.).  Therefore to put it simply for every gram or kilogram of chlorobenzene that has been discharged on the Uniroyal site only a tiny amount actually dissolves in the groundwater albeit it does exceed the 80 ppb. Ontario Drinking Water Standard. 

Can this knowledge of Solubility concentrations be worked backwards to calculate a minimum total weight of chlorobenzene dumped into unlined pits and ponds between 1945 and 1970 when the Elmira Sewage Treatment plant was finally successfully up and running and Uniroyal wastes went through there for treatment? Keep in mind these retention pits and ponds were how all the chlorobenzene ended up firstly in the groundwater under Uniroyal's site and then later in Elmira's groundwater . I believe calculations can be done although I will admit that I am checking with authorities having better math skills than I.  

A couple of additional points. Any calculations determining possible total weight of chlorobenzene discharged might assume that the concentrations of chlorobenzene found in groundwater are all very high perhaps even approaching the maximum Solubility. In fact this does not seem to occur other than extremely rarely. In fact groundwater concentrations are often only at 1% (or lower) of the maximum Solubility. Hence in fact when this is incorporated into one's mathematics I believe that it suggests that it would take a whole lot more than 60 million kilograms of chlorobenzene dumped onto Uniroyal's site to produce 3,300 kilograms of dissolved chlorobenzene being removed from the groundwater. 

Clearly just like surface water contaminant concentrations; groundwater concentrations of some chemicals (chlorobenzene) grossly underestimates the total volume or weight discharged to the natural environment in the first place. In one sense this is a disincentive to polluters to minimize their discharges if the totals appear to be minimized by the process of dissolution. 

I expect that GHD will shortly sharpen their pencils and if they are smart refuse to release their calculations. Fortunately for us they usually aren't all that smart.   

EGOS, BRAVADO, ALLEGED PROFESSIONALISM & OTHER IMPEDIMENTS TO PROPER CLEANUP

 

Around 2008  I gave a Delegation to CPAC in which I described ISCO or In Situ Chemical Oxidation. ISCO is a well known, well established in place (i.e. "in situ") subsurface remediation that breaks down chlorinated solvents among other things. What should have been  particularly interesting to CPAC members who in their infinite stupidity had already lost their most knowledgeable and combat hardened member (moi) was that ISCO had just been used successfully in Cambridge to break down TCE  (Trichloroethylene) at the Northstar Aerospace site.  This environmental calamity affected the Bishop St. community causing disease and death. CPAC continued their stupidity under the leadership of Pat M. and Susan B. by not asking questions or embracing the knowledge provided by yours truly.

Then around 2010 or so Chemtura (Uniroyal) proudly announced that they were doing a pilot study  near pumping well W3R of ISCO.  Allegedly the pilot test failed although at the time it seemed kind of a rushed job throughout. Sure enough by 2015/2016 the new TAG Chair Dr. Richard Jackson was all over Chemtura for their pathetic and Mickey Mouse pilot test of ISCO. Dr. Jackson spared no contempt for their amateurish attempts at testing ISCO.

Lo and behold Lanxess are now talking about trying ISCO yet again! They are also looking at a couple of biological forms of remediation along with ISCR which stands for In Situ Chemical Reduction. Now we old hands are never impressed when a new initiative of any kind is announced. Afterall we have learned from Uniroyal and successors that talk is always much cheaper than actual cleanup. The other thing that we have learned is that they will never give even the tiniest credit to anyone who they have not prechosen for their ideological flexibility, willingness to bend like a contortionist  and ability to ignore the obvious when necessary. 

By the way these are all established cleanup remediations and could have and should have been implemented ten, twenty or thirty years ago. Woolwich Township, TRAC, Lanxess, GHD and the MECP will ignore any discussion of that of course.    

SINCE 6:15 am THIS MORNING THE TRAC PACKAGE HAS EXPANDED TO 132 pages. MORE THAN 3,300 KILOGRAMS OF CHLOROBENZENE DUMPED ON THE UNIROYAL SITE

 

Guess how many TRAC members will actually read those additional pages this weekend as well as all the rest of the package? Yup about that many (less than the fingers on one hand).  The additional 24 pages appear to be at least partially overheads in which GHD will be misrepresenting the four questions from TRAC they have to date answered so incompletely and poorly. The two I focused on were the failure to properly test the soils and sediments throughout the Stroh property albeit closest to the Stroh Drain, Ditch & Berm (SDDB) as well as the so called DNAPL issues both on and off the former Uniroyal Chemical site. The good news here for Lanxess/GHD/MECP is that TRAC members are fully satisfied and willing to move on no matter how tenuous, unlikely, incomplete, unreasonable or just plain stupid the answers that they are given. Afterall isn't TRAC's mantra  "WE CARE & WE QUESTION; NOT OUR ISSUE IF THEY LIE TO US" ?

The lying goes back decades and continues to this day. Susan B., Sylvia B., Pat M. all were long ago co-opted and making private deals not in the public interest with Uniroyal Chemical and successors. These deals included agreeing with the polluter that DNAPLS were a non issue which is outrageous. Yes I can believe that a couple of thimbles of chlorobenzene would have quickly, fully dissolved in the shallow aquifers as well as any tiny amount that moved into deeper aquifers. However by Lanxess/GHD's own admissions 3,300 KILOGRAMS have already been removed from the Elmira Aquifers since 1998 and it's still going.  Furthermore nearly 2,000 KILOGRAMS of that chlorobenzene are unaccounted for via normal production use and waste percentages.  Clearly there were large spills of this classic DNAPL chemical with a low solubility and a density greater than 1 (i.e. a "sinker"). These numbers are also in their November 18/2024 "Screening of Enhanced Technologies for Offsite Groundwater Remediation of the Elmira Drinking Water Aquifer" (page 3).

Evidence of free phase and residual DNAPL presence both on and off site is very strong. One of the excuses for continuing high NDMA concentrations in our groundwater is because of the very low drinking water standard of 9 parts per trillion (.009 ppb.). Meanwhile chlorobenzene with a drinking water standard of 80 parts per billion (80 ppb.) is still in our Municipal Lower Aquifer at 173 ppb. and the Municipal Upper at 123 ppb.  For that you can thank the sloppy handling and disposal of chlorobenzene resulting in DNAPLs throughout their site as even stated by Frank Rovers (CRA) at a meeting attended by Susan B. back in the 90s. 

LAST TRAC MEETING WAS 2 1/2 WEEKS AGO AND NOW NEXT ONE (Mon. DEC. 9/24) HAS 108 ADDITIONAL PAGES OF READING

 

Please I was a formal UPAC & CPAC member for ten years plus I still read these packages cover to cover and guess what: I am one of the few to do so. Other members whether lay persons (citizens) or so called professionals simply do not have either the time or the will to do that much reading prior to the two and three hour meetings. The credentialed ones in particular feel that their civic duty is being fulfilled when they volunteer for a municipal committee and then show up most of the time. Believe me lots of them struggle to do even that. This is a big reason that it is so easy for Lanxess, and the MECP to snow even the professionally trained TRAC members. Think of (professional) hockey teams playing each other but only one is getting paid for their game time, their preparation time, their travel time plus expenses. Volunteers let their volunteer work slip before they let their income producing work slip.

I'm still reading the 108 pages I received three days ago. Some is easy and some is tough sledding but it all takes time. The AGENDA alone is 1 1/2 typed pages worth. The Minutes of the last meeting (Nov. 14/24) are only 9 pages and all the rest is new items i.e. "Updates". "Other Business" and "Correspondence Received" . Much of that is propaganda such as the new MECP 2028 Order to replace the old failed one. So now we get a new failed one. There will be an Update on the HHERA  which ignores the fatal sampling flaws in it from the very beginning. Screening of Enhanced Technologies for the off-site groundwater aquifers is another waste of time as if any of these worked then why weren't they embraced and used twenty or thirty years ago? Oh right because they cost more money to implement than talking about this cleanup will ever cost.. 

At the moment with little to no real discussion we are advised that the technologies being retained for further study include ISCO, ISCR, Bio-Augmentation and Bio-Stimulation.  All of these plus all of the rejected ones have some merit but once again the polluter is deciding everything including which will move forward and which won't. Look why doesn't Woolwich Township and the Region simply shut TRAC down for the good it does and declare everything clean? The wildlife in and around the downstream Creek won't complain  nor will the Old Order Mennonites who's health is affected. Certainly the MECP could divert more money say to ignoring Grassy Narrows and other environmental crises but do so in a more smooth and professional manner.

IT SURE LOOKS TO ME AS IF TRAC HAVE ABANDONED EVEN THE APPEARANCE OF TRANSPARENCY

 O.K. so over a week ago TRAC's Support person (Stacey) refused to send my latest two critiques of GHD 's  (Luis A.) responses to TRAC's questions on to TRAC. Now that while problematic and not supportive of either accountability or transparency rested on Stacey's and Woolwich's shoulders. Meanwhile  I had already sent  these two strong critiques of Luis A.'s nonsense (his responses to Questions ! & 4) along to TRAC members and administration. Now frankly I don't give a fig for Woolwich's process and procedures because they routinely are designed to insulate and protect the guilty and dishonest versus doing anything positive or in the public interest. In fact this whole 34 year admitted failure to achieve drinking water standards or clean up the downstream toxins in the Canagagigue Creek has been an exercise in manipulation, dishonesty and deceit.  Woolwich Township have been front and centre in assisting this scam of the public. 

Magically it appears as if my two latest critiques will not be added to TRAC's correspondence list or included in the Minutes of their last meeting.  Compared to the brazen and deceitful actions Woolwich have taken over the years to support the conspiracy that everything possible is being done to clean up Uniroyal Chemical's messes, this is par for the course. All meaningful opposition must be silenced by whatever means possible. This included defamation of Woolwich volunteers (CPAC members) in Woolwich Township's  April 9, 2015 letter describing an alleged but phony "stakeholders' meeting" held at the Woolwich Administration building. Uniroyal and corporate successors along with fellow travellors are committed to walking away from their responsibilities while selling their self-serving version of reality to the public.    

DISHONEST, PROFESSIONAL AND AMATEUR LIARS HAVE CONFIDENCE IN LANXESS, GHD & THE MECP

 

I mean apparently they are so far down the road of dishonesty they likely feel that there is only one direction to go. I would suggest that that sole, remaining dishonest direction has them hot on the footsteps of  "Thelma and Louise" and we all know how that ended (mighty crash etc.). Maybe their goal is simply to pass on before their behaviour is fully exposed to the world. Maybe their goal is even more modest such as simply getting out of politics or various bureaucracies prior to the public recognition of their self-serving, anti public interest . Icons such as Peter Nygard (still pending?), Bill Cosby, Harvey Weinstein and a trove of others likely will exceed the size of their disgrace and public exposure but it will be seen and enjoyed nevertheless by the very few who have honestly opposed them.

The Agenda is out for next Monday's TRAC meeting and hoo boy are TRAC ever getting their hands even dirtier by participating in the entire sham of a process. Sebastian and a couple of others can honestly claim that they spoke up on a few significant issues but they are being used as window dressing by the really bad ones. In hindsight does anyone remember the name of a moderate or two within Adolph Hitler's Cabinet? O.K. if you feel that that comparison is too strong or stark how about moderates within any group who refuse to resign for self-serving reasons  despite knowing that the group have either lost their way or never had found it. 

The Agenda for next Monday is full of attempts to bolster the impression that Lanxess and the MECP are seriously on the hunt for better remediation methods. They are merely ten, fifteen to thirty years behind the timeline necessary to actually have the Elmira Aquifers remediated. Even now they are admitting on page 7 of their Minutes of the last meeting (Nov. 14/24) that even with a new initiative towards cleanup that NDMA for certain will require decades more time to occur.

Now keep in mind that it is the exact same organizations (Lanxess, CRA/GHD, MOE/MECP) who swore to Elmira citizens from 1990 through to almost 2017 that YES they would clean up the aquifers by 2028. That's over twenty-five years that they kept INSISTING  that everything was under control when numerous citizens, professionals and amateurs knew it couldn't be done. Then around 2016 sometime we heard the first peeps of  "...oh gosh this is harder than we thought. Maybe we won't get it done by 2028." That is now a crescendo of voices with predictions of the Elmira Aquifers achieving drinking water standards by 2050 or 2060.

I no longer believe a word they say. Why would I? They have lied, lied and then lied some more. DNAPL coverups continue to this day. They still admit on page 16 that there is approximately 2,000 kg. of "excess" chlorobenzene been discharged to the natural environment. That is most likely via free phase DNAPL discharge of raw chlorobenzene and that is why despite NDMA being difficult to achieve it's very low drinking water standard (9 ppt.); we still have lots of chlorobenzene in our Elmira Aquifers well above drinking water standards. If I know exactly where this free phase DNAPL migrated to off-site then why allegedly doesn't Lanxess, GHD and the MECP?  

Hence Elmira citizens feel free to believe whatever rubbish these parties tell you. It's always self-serving and intended to save them cleanup expenditures.

THE HYPOCRISY BEHIND OUR ENVIRONMENTAL LAWS

 

"Polluter Pays" is a good one. Here in Elmira the taxpayers are on the hook for 50% of the cleanup costs of the aquifers not underneath the former Uniroyal Chemical (i.e. "off-site"). Why are the taxpayers on the hook for these sums? Uniroyal dumped toxic wastes willy nilly both on and off their site essentially at will. The Ontario Ministry of Environment were mandated to control these discharges and failed to do so properly. The result is the mess that we still have today and for which taxpayers continue to pay.

Our environmental laws with assistance from corporate lobbyists have focused solely on off-site impacts. Therefore . theoretically at least if a polluter could dig a big enough and deep enough hole, lined with say steel they could simply dump everything into that.  The problem is that our earth and waters are interconnected.  Dr. Gail Krantzberg (McMaster), years ago at CPAC, stated that every toxic waste that Uniroyal, spilled, dumped or  placed on or into their property will eventually leave their property. This can be via volatolization as liquids evaporate or it can be via groundwater movement, surface water erosion and or even soil gas migration. So what do progressive polluters do? Why they hire talent, QPs, consultants and anybody else who will sell their bull while pretending to be independent of the polluter themselves. They cut down forests to write reports stating that nothing has left their site. Dead fish downstream just blame somebody else. Odours and colours in Canagagigue Creek then lets do another study and waste another couple of years "discussing" it. Anything rather than clean up their own messes.

Then of course well off polluters who are big fish in a small community can easily overwhelm local councils. Between the equally guilty Ontario Ministry of Environment on side with natural attenuation and hydraulic containment of  industrially contaminated aquifers, local councils have few resources. In fact it is the MOE/MECP they turn to for assistance. The system has been corrupted beyond repair and that's exactly how polluters like it. Relatively small fry like Varnicolor Chemical or smaller can be put through their paces by the MECP.  Uniroyal/Lanxess just laugh at them because multi national, multi billion dollar corporations have much deeper pockets and budgets to play in the courts with. Again even our courts have lost their independence of the unholy dollar.  

IT'S BEST ALL DONE QUIETLY & PRIVATELY

 

Lanxess are talking, discussing and maybe negotiating with the downstream Old Order Mennonites living and working the land along the Canagagigue Creek.  What exactly are they talking about? My suspicion is that want something from this community and are willing to pay an enormous sum for it although they won't weaken their negotiating position prematurely. Potentially cleaning the Creek sediments and creekbank soils along with some floodplain soils could cost a hundred million dollars and take years to accomplish.  Think about it. There is more than five miles of Creek winding it's way downhill towards the Grand River just south of West Montrose. Think about dredging a couple of feet or more of the bottom sediments for that distance. Think about removing large areas of soils above the Creek waterline for that distance. Think about the floodplains themselves and how much contaminated fields there might be.

Or the alternative and totally irrelevant to the biased and phony HHERA (Risk Assessment), perhaps the 22 downstream families might accept say a million dollars per family to sign off on the whole mess. Just call it all an act of God while ignoring all the executives, bureaucrats and politicians who clearly had neither respect nor caring for the men, women and children affected by their self-serving decisions since 1942. Heck if necessary I'm sure some of the guilty parties would cheerfully throw some taxpayers money at these Old Order Mennonite families if they will sign a release indicating that they will never sue for damages.

If many of these families have either young or old members requiring serious health care whether directly, indirectly or not at all from Uniroyal Chemical toxins; they would certainly have an incentive to mitigate their health expenses especially as they generally are not covered by OHIP.  I expect some families would be relieved, others maybe not. There might even be a holdout or two. Regardless Lanxess would not be talking to them out of the goodness of their hearts. Lanxess are a corporation not a charity and it's all about the bottom line and what is best for Lanxess Canada.  

  

NEXT TRAC MEETING PLUS UPDATE ON WOOLWICH TWN. BEHAVIOUR

 

O.K. so the next TRAC meeting has been moved up to Monday December 9/24 at 6 pm. No I do not recommend anyone attend without an extensive background in Elmira politics as well as environmental matters. The reason is because of the volume and extent of bulls**t that will be thrown around at the meeting as if it came straight from above. Which it doesn't . In fact it comes from straight below and gives the devil much amusement. Keep in mind one can attend virtually as even some of the TRAC members who don't live in Elmira or Woolwich like to do to avoid winter car travel.  Don't ever get confused and think that all TRAC members are either locals or for that matter even Canadian citizens. They are not with Susan B. being the most egregious. Finally the in person meeting video seems to appear on the Woolwich Township website about five days after it's completion.

Yesterday's Woolwich Observer carries the ad for this upcoming TRAC meeting. It also states "Delegations must be submitted a minimum of eight (8) days prior to the Technical Remediation Advisory Committee meeting date to be included on the agenda."  That raises a number of issues such as why do the contents of  Delegations have to be submitted in advance at all?  Asking to be on the Agenda with a title of one's submission relevant to TRAC's mandate and the Elmira water issues should be sufficient. Secondly submitting one's Delegation eight days prior when at most the Minutes from the previous meeting as well as the proposed new Agenda do not get released until six or seven days prior is weird. Afterall you may well decide to present as a Delegation only after you see what is already planned to be discussed at TRAC. Lastly of course is the usual failure of TRAC (TAG) members to ask any intelligent or otherwise questions of Delegates of whom they have been advised not to ask questions of at all. 

All of this is typical Woolwich hunker down behaviour. They give lip service to openness and transparency while weeding out disparate voices and opinions, especially those of citizens far more knowledgeable on the subject matter than they or their bought and paid for Qualified Pe****s are. Both Luis and Allan D. are second stringers for GHD which indicates how  little concern Lanxess have for the reduced local opposition and critics ability to be heard in Woolwich and by Woolwich. 

ALWAYS ARROGANT, KNOW IT ALL AND PRETENDING TO BE MORALLY ABOVE THE CITIZENS THEY WORK FOR

 

I think that was what really set me off back in 2015 with Woolwich Township. They (Sandy & Mark) had just lied and manipulated as well as defamed volunteer CPAC members all to gain support from Uniroyal/Chemtura and the Ministry of Environment (MOE/MECP).  They clearly were part of the multi agency (RMOW, GRCA, Woolwich Twn., Ontario-MOE) conspiracy to let Uniroyal/Chemtura off the hook with their relatively inexpensive and ineffective alleged cleanup of our ground and surface waters. Yes the decades of air pollution which likely made many sick and eventually killed others has been improved although it took decades of talk, lies and bulls**t  before real action was taken.

Hence I have seen fit to make my contempt and disrespect for Woolwich Twn. very clear. They do not deserve my respect or for that matter anybody else's. Now of course here is where it gets tricky. Every four years we tend to get a new crop of councillors. Should they be automatically condemned for their audacity to run for political office? Should they be condemned for going into office possibly believing that public service is a noble and honourable profession? Obviously not especially if they are young and naive which they would have to be to believe that hooey. 

So township councils get second and third and fourth chances and eventually you've lived long enough to understand how the system works. New members are quickly indoctrinated into an us versus them attitude. It's a lot like policemen who are trained to view the citizens they are sworn to protect as often dangerous thugs. Yes a very few likely are but the vast majority of citizens just want to mind their own business and get home at the end of the day without incident.   

Woolwich Twn. continues to coddle dangerous polluters and skirt around the law. Just because every second rate politician at all levels (municipal, regional, provincial) and every second rate bureaucrat serving these second rate politicians, long ago decided that the easiest route for them was to go along to get along, doesn't make it right. No one has ever laid out the options, including the do nothing option, clearly for local citizens. No one in authority has ever explained what the environmental effects, much less the human health effects are for constantly permitting Uniroyal and successor corporations to make all the pollution decisions for the rest of us. No one has had the nerve or the honesty to spell out why so many citizens all around us are contracting cancers and suffering and passing on prematurely as a result. 

Our authorities/politicians have long ago sold us out and if they had any brains they would realize that they've also sold out their own friends and families just to get themselves re-elected and remain on the gravy train. Is it status and ego or is it money? Hard to believe that Township councillors (other than the mayor)  would sell out for the small money involved. Maybe some of them are true believers that those with the money and power should make all the decisions. Maybe on the other hand most of them have connections to the big money locally and are confident that they and theirs will be eventually rewarded if they stay the course.      

 

TRAC QUESTION 2 IS THE NEXT ITEM TO LOOK AT

 Luis Almeida and all the rest of the Lanxess/GHD crew as well as TRAC have been avoiding this issue for the last few years despite a number of written comments I've sent in comparing the pumping rates both on and off site since 1998 (Off-site) and since 1992 (On -site). Mr. Almeida's response in this forum is pretty much as weak as anybody else's with a whole lot of gobbledygook mostly ending with an exasperated sort of "Trust us". Well sorry Luis but that ship sailed decades ago.

Luis also claims that "It's also important to note that Lanxess has set target rates are above pumping rates that achieve containment." Yeah that's important if it's true. For literally decades though it's the opposite of what we were told at UPAC and CPAC. It is also the opposite of what GHD WRITE below their pumping results in each and every monthly Progress Report . There they make it plain that they GHD recommend that Lanxess maintain the Target Pumping Rates for both on and off-site pumping wells. 

I mentioned gobbledygook back in the first paragraph. CRA/GHD have been known and been caught! assigning off-site Sentry Wells in the past such as CH44 and CH100 that they knew were screened in both the shallow aquifer as well as in the municipal upper aquifer. This gave artificially high groundwater elevations just off-site allowing Chemtura/Lanxess to claim hydraulic containment when it did not exist. Hydrogeologist Wilf Ruland argued this exactly in a private meeting with Chemtura but ran for cover when CRA objected loudly. Dr. Regier was present as was a number of less honest persons than Dr. Regier and myself. Months later the Environmental Review Tribunal agreed with my assessment on this well being improperly assigned by CRA   as an off-site Sentry Well.

LOTS MORE DECEPTIONS, LIES, TYPOS (Ha!), IN GHD'S RECENT REPORT TO TIFFANY SVENSSON

 

First off this might surprise readers. Tiffany is not dumb. To my knowledge she is a professional hydrogeologist who knows perfectly well when deception attempts are being made. I guess however she does know where her bread is buttered. Did I not recently see that she received $30,000 for her efforts last year as Chair of TAG?  That's pretty damned good for a part time job in my opinion. Think of all the volunteer Woolwich citizens (not Susan B. who is neither a citizen of Woolwich nor Canada) and the literally years that they have spent giving of their time and effort to try to help cleanup the Elmira Aquifers and the Canagagigue Creek.  Other than a couple of individuals (only one of whom is a citizen from here) who have been well rewarded for their service to the Woolwich mayor and Chemtura/Lanxess , all the rest have been given the cold shoulder or much worse.

This latest argument is just Woolwich constantly pushing. They are frustrated because they know that to date they have been unsuccessful in shutting me up or down. Yes only Sebastian of the former 2010-2015 CPAC is on TRAC however that membership has slowly over 9 1/2 years gone from problematic to embarrassing to counter productive. TAG, RAC and TRAC have done zero good for the public and significant bad by simply providing the professional liars... oops make that simply providing the world class instigators of TYPOS,  cover and protection from appropriate public criticism and condemnation. That said I do acknowledge that Sebastian has stepped up and publicly contradicted his TAG and TRAC colleagues on a number of occasions. They knowing that he won't go any further appear willing to let him do so, right up until they don't and then he'll be shown the door. 

The November  14/24  letter to Tiffany from Luis  Almeida has a total of five questions from TRAC to Lanxess/GHD. To date I have given reasonably detailed responses to GHD's responses to Questions 1 (Stroh property and Stroh Drain, Ditch & Berm (SDDB) as well as to GHD's response to Question 4 regarding Effective Solubilities say of chlorobenzene versus Aqueous Solubilities. GHD responses were shoddy and defective similar to other past reports. Meanwhile TRAC's Question 2 is about below Target pumping rates and actually makes me realize that TRAC and Tiffany make actually be paying some attention to my technical critiques as this is one that I've been pounding on for the last couple of years or more. TRAC's Question 3 is about the revised HHERA (Human Health & Ecological Risk Assessment) and TRAC wanting a response from Lanxess/GHD more than a year later. Also TRAC would like an update on the clean up of "hot spots" in the vicinity of residents along the Creek. This wording I find a little odd as historically the "hot spots" referred to three areas conveniently along roads crossing the Creek downstream namely at the New Jerusalem Rd.,  Northfield Dr, and Jigs Hollow Rd. (outside West Montrose)  . Finally Question 5 is TRAC asking for a Well Installation Log which GHD are somewhat claiming is already done.

So do the additional three questions all need my comments? Perhaps one or two do but not all of them. We shall see. 

PROXY WARS

  Proxy wars is an old term which suggests that various wars over the decades (centuries?) were fought between world powers who did not want to actually get involved in a head to head war with each other. Hence proxy wars. Suggested examples are North Korea, Vietnam, Afghanistan, Ukraine etc. Rather than the U.S. getting into it with China or Russia they support one side in some kind of regional conflict while China or Russia support the other side with weapons and other war material.

Hence to Woolwich Township. CAO Brenneman likely wants to keep his hands clean as does the mayor. In the past I've engaged with Mr. Brenneman and found him to be slippery, sly and deceptive. Not at all interested in straight forward discussion or attempts to actually resolve a disagreement. I have had significant disagreements with Nathan Cadeau and at one time Lisa Schaefer when she was the CPAC and then TAG Support person. I am very pleased to state that at least the last few years of her tenure in that job that we got along very well. I appreciated her above and beyond efforts to answer questions or clarify some issues and I told her that. Now recently out of the blue (it seems to me), the new Support person is on the warpath regarding my usual, normal, strong criticism especially of Lanxess, GHD and the Ministry of Expanded Corporate Pollution (MECP). Yes my writing often has editorial content as well as factual content such as my changing acronyms like MECP or even TRAC.

I attempted a compromise and a softer tone in my first response after the Support person made the frankly idiotic and totally unacceptable demand that I no longer engage in accusations of either incompetence or dishonesty, essentially with everybody. That got me nowhere so back to the blunt approach. How exactly does she think that I am supposed to write that Luis or Alan Deal seem to be at 100% odds with proven facts that everybody has? Mr. Deal misrepresented  the 1% Rule by suggesting out loud and publicly at TRAC that 1% of the Aqueous Solubility (approx. 5,000 parts per billion) was at least a yellow flag that DNAPL could be present. That is bulls**t . It is 1% of the EFFECTIVE SOLUBILITY not of the AQUEOUS SOLUBILITY and the difference could be as dramatic as only 50 or 500 parts per billion of chlorobenzene may very well indicate the presence of free phase DNAPL nearby.

Let me see maybe I could refer to public, blatant, misrepresentation or lies as boo boos. Now of course this would all be moot if Mr. Deal, GHD or Lanxess were willing to admit to their gross errors and publicly rectify them. Hell those twits won't even admit to failing to clean up the Elmura Aquifers for which they have been in total control since day one. Hmm maybe I could refer to their written and spoken disinformation as TYPOS. That's it, typos could be my new code word to replace professional bullsh** artists etc.  Let's see how this goes.

ACCUSATIONS OF INCOMPETENCE OR DISHONESTY TOWARDS LANXESS/GHD/MIN. of ENVIRONMENT NO LONGER PERMITTED BY WOOLWICH TOWNSHIP

 

Well it's come full circle. I've been ordered by the new Woolwich Support person for TRAC not to criticize or disparage those responsible for the failed ground and surface water cleanup in Elmira.  Hence both TRAC and Woolwich Township aren't even hiding the fact any longer that their purpose is to provide cover and protection for Lanxess Canada in order to avoid their legal responsibilities to clean up their toxic mess.

The following was sent to TRAC, Woolwich Council, the media and other stakeholders this morning.

  

November 23, 2024

Stacey: Calling someone a five minute wonder is not an insult but simply a fact. For example Hadley Stamm (Lanxess) is a five minute wonder, as you are. Nathan Cadeau was a five minute wonder. Now he may relatively only be a ten minute wonder. This expression simply makes the obvious point that appointing persons with zero direct experience to an ongoing thirty-five year long problem is more than a little weird and problematic. How do those in charge believe that the appointee will ever have that 35 years of knowledge and history available to them and at their fingertips? Clearly they don't and clearly that is exactly what they want.

Hence please view these words in the light of yourself with zero direct experience dealing with Uniroyal/Crompton/Chemtura/Lanxess(O.K. 5 min.) as well as CRA/GHD and the MOE/MECP. Are you out of your cotton picking mind telling me that I cannot make “accusations of incompetence or dishonesty toward ...any affiliates or stakeholders of TRAC...” You said this in your Thursday, Nov. 21/24 4:31 pm. E-mail to me. The next day (11 am.) you again stated that “Accusations, disrespectful language ... will not be accepted or circulated.“

News flash Stacey. You (or Woolwich Twn.) are not my censor. Is that the major purpose of the past TAG and current TRAC? Are those municipally appointed bodies simply a protective shield for polluters from the truth and from appropriate criticism? Back in 1998 Uniroyal stormed out of a CPAC meeting because they were strongly criticized over their toxic air emissions harming multiple Duke St. residents. They and the MOE did something similar albeit less dramatic in late 2014 because CPAC were pushing them for answers on the Stroh farm contamination. Sandy got elected in October 2014 and immediately gave Chemtura and the MOE/MECP everything they wanted which included getting rid of me and other excellent citizen volunteers who refused to kiss Chemtura's or the MOE's butts.

Neither you nor Sandy nor Woolwich tell me what to write or how to write my technical criticisms of Lanxess and GHD junk science or lies. If you don't like my strong criticism then instead of shooting the messenger try to honestly address the issue/problem. Woolwich Township has become a cheerleader for junk science, incompetence and polluter dishonesty. Nothing has been accomplished in cleaning the downstream Canagagigue Creek fifty plus years AFTER the worst on-site Uniroyal discharges ended.

Our groundwater is still polluted well above drinking standards in all aquifers with Uniroyal chemicals. Despite this the Woolwich folks in charge pretend that more respectful dialogue will magically solve everything. Eventually there will be a resolution which Lanxess and the MECP will like but it will come as it always has at the expense of the public interest and of the environment.

By now you may have correctly interpreted my lack of respect for Woolwich documents being used as a stick in order for Woolwich to get their way, no matter how perverted. Also I might add that your statements that “...it is critical that all correspondence adheres to the Township's Procedural By-Law and Customer Service Standards. This ensures productive dialogue and a respectful environment for all parties...” Really Stacey that is pure rubbish and at least one of us knows it. There has never been a respectful environment at UPAC, CPAC, TAG or TRAC. That is guaranteed by the ongoing lies told to both committee members and the public by Lanxess, GHD and the MECP. Try reading Sebastian Seibel-Achenbach's critique of TAG that I referenced in a recent communication.

I will not be aligning my e-mails to meet either your or Woolwich Township bogus standards that reward liars and punish truth tellers. Take your threats of my critical documents not being “accepted or circulated “ and shove them where the expression suggests.

Alan Marshall

WOOLWICH ARE LOSING THEIR MINDS

 

Well I suppose I have to admit that my writings on the failures and lies by those in charge of the Elmira cleanup are for a purpose. I want a written record of all the technical incompetence if not technical negligence that has occurred .  That said, as you can well imagine, how does one do that without using words such as incompetent, shoddy, negligent, gild the lily, falsehoods etc. Well Woolwich have sent me a letter flatly stating that my Tuesday and Thursday e-mails to TRAC and Woolwich Council will not be accepted as official correspondence for TRAC.  Further they stated "Future correspondence that includes language such as accusations of incompetence or dishonesty directed toward Council members, Township staff, TRAC committee members...will not be tolerated."

Well darn, other than calling TRAC members "deferential" I'm doubtful that I've said a whole lot more about them. Even the word "deferential" is a quote from one of their own members (Sebastian) describing their behaviour.  

Well it seems that if I write critiques of the cleanup plans with the words "excellent, insightful, brilliant, world class" then all is good. Otherwise not so much. Oh and they also suggested that in reference to the Township's Procedural By-Laws and Customer Service Standards that "These policies clearly state that workplace violence, harassment, and any form of verbal or physical abuse will not be tolerated." 

Hmm I'm wondering if they are hinting that Uniroyal/Lanxess, GHD and the MECP  all work for Woolwich Township? Otherwise as those groups are 99% of my target then what the heck does a made in Woolwich Township document (Procedural By-Law) have to do with anything? Elected Council members do need thick skins as they are up front at Council meetings and sometimes take the brunt of public outrage on the occasional issue. That's just a fact of political life. I agree that the bread and butter Township staff really shouldn't be expected to take any crap from the public. TRAC members are appointed volunteers and should be prepared to defend their positions and decisions from time to time. That said I don't believe that the public can ask them questions at public meetings as they did for decades prior to Ms. Shantz becoming Mayor.

LANXESS/GHD LYING TO TRAC & THE PUBLIC MUST STOP!

the following will be sent immediately to TRAC, Woolwich Council, Regional Council, maybe the media and certainly to the honest, remaining environmental activists in Elmira 

On pages 5 and 6 in Luis Almeida's letter of November 14/24 to Tiffany Svensson (TRAC), Luis gilds the lily yet again via distraction and deflection. Tiffany starts the TRAC Question 4 as follows:  "Has Lanxess determined the effective solubilities of NDMA and chlorobenzene in the upper and lower municipal aquifer?" Luis made no attempt to answer that question.  Tiffany in Question 4 followed with "Addressing the concern of using the "aqueous" solubility value of chlorobenzene in the September 12, 2024 presentation to support the assessment that there is no NAPLs present off site...".  Here Tiffany quite frankly states that GHD (Alan Deal) incorrectly used the Aqueous Solubility value instead of the much lower Effective Solubility value. Luis's inaccurate, dishonest and misleading answer was "GHD did not use the 1% rule or effective aqueous solubilities to infer or repute the presence of DNAPL."

Well in fact GHD (Alan Deal) did exactly that. He did it and as I was at that meeting I not only wrote down what he said but later confirmed his words from the You Tube video of the TRAC meeting.  I also checked Mr. Deal's overhead slides (pg. 16) which is where the misrepresentation started.  Then I posted on my Blog (Elmira Advocate) on September 13, 14 and 16, 2024 condemning Alan Deal's words and falsehoods . My posts are still on line and as well Woolwich Council and TRAC were made aware of Alan Deal's comments in which he used the 1% rule (of thumb) relative to AQUEOUS SOLUBILTY instead of  relative to Effective Solubilities which can literally be ten, a hundred or a thousand times lower than Aqueous Solubilities which refer to dissolving for example chlorobenzene in a container of clean, pure water versus  the trashy groundwater under Uniroyal/Lanxess that can easily have a hundred different contaminants mixed in it. Effective Solubility is real world solubilities not laboratory solubilities.

Before I quote Alan Deal's dumb remarks at the September TRAC meeting let me give you a touch of DNAPL history.  Yours truly can take credit for introducing the 1% Solubility rule to UPAC (Uniroyal Public Advisory Committee) way, way back in the day i.e. early 90s. Brian Beatty was the groundwater consultant (Morrison & Beatty) for Uniroyal at the time. Mr. Beatty introduced the 10% Solubility rule to UPAC and had the nerve and brass ba**s to quote a well known hydrogeologist by the name of Stan Feenstra.  As this was before the Internet was well established (with me at least and maybe everybody) I went up to my alma mater and dug into the Arts Library where I found Mr. Feenstra's original document. Mr. Beatty had quoted him out of context in which he was referring to the past  10% Solubility Rule being replaced by the now current 1% Solubility Rule. I talked to Mr. Feenstra on the phone and he agreed to send me a letter criticizing the misrepresentation by Mr. Beatty.  I gave this letter to all parties and David Ash of Uniroyal ended up "consolidating" Mr. Beatty whom we thankfully never saw again.  Many more from CRA/GHD need to follow Mr. Beatty's walk.

Here are Alan Deal's exact words from the September 12/24 TRAC meeting :

"IF YOU DETECT CHLOROBENZENE AT A CONCENTRATION THAT'S AT OR GREATER THAN 1% OF ITS' AQUEOUS SOLUBILITY, SO SOMETHING AROUND 5,000 MICROGRAMS PER LITRE, THEN THAT COULD  INDICATE THAT THERE IS DNAPL UPGRADIENT OF THAT MONITORING WELL."

"SO IT'S  MAYBE NOT A RED FLAG BUT A YELLOW FLAG THAT... THIS IS SOMETHING THAT YOU ARE DOING YOUR EVALUATION YOU DO HAVE TO KEEP IN MIND."

I have been aware of the difference between Aqueous and Effective Solubilities for decades. At one point years ago Jaimie Connolly, MOE/MECP hydrogeologist, actually did a calculation for CPAC comparing the vast numerical differences between Effective Solubility in Uniroyal's groundwater versus the various chemical contaminants Aqueous (Lab) Solubilities.  Obviously GHD, Lanxess and the MECP in their decades old quest to coverup DNAPL presence both on and off site have ignored Effective Solubilities at every opportunity and continue to do so. That local politicians allow, permit and support this misconduct/corruption speaks to their integrity.

Alan Marshall  (still too blunt, accurate and honest to sit at the table with the rest of the deferential sheep )  

STILL POKING & PRODDING THE BEAR WHILE LEAVING A PAPER TRAIL FOR FUTURE CORRUPTION PROSECUTION

 

Are there any guarantees of future prosecution? I would say no there aren't.  The thing is politics which runs everything including our justice system one way or the other (just look at the U.S. Supreme Court with Donald Trump's idiot appointments) .  Don't fret we too in Canada are stupid enough to let politicians make judicial appointments and we wonder why we get occasional idiots behind the bench (think Robert Reilly).  Just to be specific yes I am talking about corruption prosecution in regards to the gross failure of the public interest being first and foremost in the decision making of our municipal, regional and provincial politicians surrounding the non-cleanup of our Elmira/Woolwich ground and surface water in addition to of the downstream Canagagigue Creek. Is it possible that at some point in the future there will be the political will to bring these corruption charges?

The last two days I've been discussing a letter sent to Tiffany Svensson (TRAC) from Luis Almeida (GHD) ostensibly answering five questions that TRAC have. Now as much as I have criticized TRAC for being too deferential and refusing to step up and verbally lay down some rules of engagement such as less lying from Lanxess and friends; I will say this. They are not totally oblivious to some of the issues being swept under the rug. Often times they will express concerns (as Sebastian has) and some times they will follow up. Unfortunately they have never drawn a line in the sand hence Lanxess, MECP and GHD have no respect for them.

Monday's Blog Post here went to TRAC plus some Woolwich Council members. Yesterday's Post went to TRAC, Woolwich Council and Waterloo Region Council. I didn't bother sending anything this time to the K-W Record or to the Woolwich Observer. I expect that today I will be looking at Luis Almeida's response to TRAC's  Question #4 which is about DNAPLS . Whether I continue with the other questions is unlikely as I still have to comment on last week's allegedly public TRAC meeting. 

FURTHER COMMENTS & OBSERVATIONS REGARDING LUIS ALMEIDA'S (GHD) SOMEWHAT HOPELSS NOV. 14/24 LETTER TO TIFFANY SVENSSON

 

So called professional consultants (GHD) only write such drivel and nonsense when they are assured that serious and knowledgeable critics are not allowed the opportunity to straightforwardly address their inaccuracies.

Nov. 19/24

FURTHER COMMENTS & OBSERVATIONS REGARDING LUIS ALMEIDA'S SOMEWHAT HOPELESS NOV. 14/24 LETTER TO TIFFANY SVENSSON

In TRAC Question 1, TRAC requested topography information and flow path info for historic waste management units. The first effort by GHD was pathetic whereas the second was mostly non-existent. Let me advise Luis thusly: Good ground surface contour lines, i.e. topographical information is required to confirm/prove flow paths of rainfall, liquid toxic wastes etc. These topographical lines show the flow direction via gravity flow. Your provided map is crap! It fails to show all the east boundary/border topographical lines i.e. from north to south along the property line/border. You have focused on contour lines only at the south end of the site despite leakage and migration from the most northern pit (RPE-1) plus all the rest (RPE-2-5) based on Region of Waterloo and GRCA topographical maps which you have used in your past reports. Secondly some of your contour lines are not identified by elevation and others have soil sampling locations inconveniently placed on top of contour elevation numbers making them illegible. Finally of the contour lines I can read not all match the ones that I used several years ago from your published maps labelled as Region of Waterloo or GRCA sourced.

Luis suggested that there was a ditch or swale on the west side of the pits parallel to the Creek. While I don't dispute that some of the overflow, spillage etc. from the east side pits may well have found it's way into that ditch/swale unfortunately you have not indicated where that miraculous and helpful ditch/ swale starts or stops. Also just because liquid wastes are overflowing from all five east side pits doesn't mean that it all flowed out of the west side of the pits and found your ditch/swale. These five pits were partially in ground and partially above ground by your own maps and figures. Liquid contents overflowed in all directions including onto the Stroh farm. Contour lines indicate that the pits were higher than the Stroh property the length of the property line and liquids would flow eastwards not just westwards. Finally your wonderful ditch/swale did NOT run directly into either GP-1 or GP-2. It ended north of the two gravel pits at the swampy area that already had standing water/liquids in it. From there any flow in the west side ditch/swale spread out and again gravity flowed via ground surface contours south-east through the so called ”Gap” area and onto the Stroh farm where it met other migrating liquids that had flowed almost due south on the Stroh property. The 1983 Stroh Drain, Ditch & Berm (SDDB) was built for two purposes namely to drain the swampy area on both properties and secondly the Berm was to weaken the force of the flooding Canagagigue Creek which had been eroding contaminated soils from a very low lying area slightly further east on the Stroh property where much of the migrating toxic liquid wastes settled.

Luis keeps referring to the Gap area as topographically high. Ridiculous! The name “Gap area” refers to Chemtura/Lanxess intentionally failing to take soil samples in 2015 at the LOW LYING former swampy area immediately north of where the north-west to south-east diagonal ridge of high ground sits. Then when soil samples were actually heaven forbid taken on the Stroh farm at an amazing depth of 15 cm. or 5.9 inches in 2018, the 2015 stupidity (?) of taking soil samples on the entire perimeter of the Uniroyal/Lanxess east side property EXCEPT for the one low lying area that many of us toured, saw and walked on in 2019 was rectified via the addition of SS20 and SS21. Now of course even then Lanxess had to play games by including parts of the high ground at the southern end of SS20 leading to the high ridge of ground. Hence “the GAP” is merely a 2015 sampling gap and failure of Uniroyal/Lanxess that Luis and others have appropriated in an attempt to undermine finding higher concentrations of dioxins and DDT compounds by intentionally sampling the high ground exactly where everybody knows flowing liquids would not have travelled over.

By the way aerial photography actually did expose part of the flow path from the Uniroyal property to the Stroh property . It was both the 1955 and 1968 maps in a March 2012 CRA Report regarding the Gravel Pits that showed an arc if you will of bare ground running through the LOW LYING GAP from Uniroyal over to the Stroh property exactly where the SDDB was later built to join up with Martin Creek and then the Canagagigue Creek. I notice that Luis failed to mention the 1968 aerial map which a generous person would not call an intentional lie. My generosity however failed me after about the 137^th lie from Uniroyal/CRA or wait a minute was it the 371^st lie? This is another advantage of delay. Memories tend to weaken. Good news however Luis did mention a 1955 map which however like the rest he mentioned was not shown.

Luis really is confused. He claims that soil sampling locations S-17 (02) and SS09-15 are within the Gap area. They are not! Also he claims that previously mentioned SS20 is within the Gap area when only the most northern part of that specific area is. Furthermore his Table 1 shows a TEQ (i.e. Total dioxins) criteria of 99 pg/g or parts per trillion (ppt.). Now it turns out that this TEQ criteria is based upon MECP Table 2 criteria whereas most of the time we use MECP Table 8 criteria. I checked the 2017 and 2020 Canagagigue Creek Soil and Sediment reports and indeed Table 8 was used likely due to the samples being taken within 30 m. of surface water. Perhaps Luis would like to amend his criteria for soil samples taken within 30 m. of the Stroh Drain, Ditch & Berm (SDDB). When it comes to the soil samples along the Uniroyal eastern property line they all appear to be based upon Table 2 criteria which is likely O.K. for the further north soil samples but not appropriate for soil samples taken just across the property line from the constantly flowing SDDB.

One other small problem for Luis is that he's gotten his soil units wrong. DDT compounds (i.e. DDD & DDE as well) have always been in units of micrograms per gram or parts per million. He's got them in his personal Table 2 as picograms per gram which is parts per trillion. This basically is saying that all the DDT compounds are one million times smaller than they actually are by CRA/GHD earlier reports.

Again Luis somewhat oddly is claiming that the former gravel pit investigation included the Gap area. Well if he persists in believing that the high ground at the south end of SS20 is part of the GAP area (it isn't) then maybe he might also want to claim that Uniroyal Chemical contamination did not leak off-site because Uniroyal secretly bought the Stroh farm fifty years ago. See where I'm going with this? Professional have an answer for everything. Oh and just to upset Luis a tad more the “...surface water drainage area located at 6670 Line #86” is both a surface water drain as well as a groundwater drain. The groundwater is upgradient on the Uniroyal/Lanxess site and is somewhat diverted by the below ground surface SDDB (P.S. It's deeper than it looks and intersects shallow groundwater!)

Luis also talks about an independent Elmira community member who collected soil/sediment samples. That also is in error. There were two Elmira community members of which you know both and of which I am but one. Is Luis taking a shot here at SSA by inferring that he isn't independent or did he not know? Secondly we did not collect soil /sediment samples we collected soil samples properly, logged them, and sent them for analysis. I have seen other GHD reports claiming that our samples were soil/sediment which certainly is no more bizarre than so much of what they claim. I wonder why however they would not simply have asked the question? Ah yes I forget. I'm on mayor Sandy's, Lanxess, MECP naughty list. It really is unconscionable for any commoners without certified brown nosing credentials (i.e. cleared by Sandy, MECP, Lanxess) to offer opinions contrary to those bought and paid for by our world class polluters.

Moving along in increasingly better humour I must also add that of the lowly, miserable and cheap, minimal sediment sampling in the SDDB two hits stand out. DDD was significantly above the Table 8 health criteria and dioxin TEQ was found at a concentration of 24.4 parts per trillion (ppt) with a Table 8 (within 30 m. of surface water) criteria of .85 ppt. That is about 36 times higher than the criteria yet all the Queen's's men and all the Queen's horses couldn't get their crap together and decide that an honest, full investigation was required. Afterall you could still upgrade three roads on the west side of Elmira for a truck bypass while cleaning up the Stroh and Martin contamination on the east side.

You know there are still four more questions ahead of us but as a senior, senior citizen I'm getting ready for my nap. Congratulations to all the dishonest and corrupt parties over the decades who have stalled and delayed so successfully for so long. Some of the original citizen critics such as Esther Thur and Pat Potter are dead and others are suffering the ravages of time. Continue to keep me from speaking on an equal basis with others so far less knowledgable and competent and soon I too will be no longer capable.

Alan Marshall Elmira Environmental Hazards Team plus numerous others still vertical

SAME OLD LIES & COVERUP BY GHD TO HIDE STROH CONTAMINATION

 

The following is an e-mail I recently sent to Stacey Bruce of Woolwich Township. Stacey is the Support person for TRAC. 

Stacey: Thank you for passing along the October 2024 Monthly Progress Report.  Also I appreciate the seven page letter to Tiffany Svensson (TRAC) dated November 14, 2024 and sent by Luis Almeida of GHD. While I have only briefly examined to date TRAC Question 1 and 4,  I can advise you for your own information that Mr. Almeida's answers are woefully inaccurate. 

 His map is very poor as are his comments that the Gap area is topographically high which is nonsensical , inaccurate and likely intentionally disingenuous. It is unfortunate that Sebastian (& Tiffany) continue to reference "the Gap area" as either symbolic or significant to the major issue of massive liquid wastes flowing onto the Stroh property from Uniroyal Chemical's east side ponds (RPE 1-5). The gravity flowing toxic liquid wastes crossed the property line from Uniroyal to the Stroh farm (west to east) for almost the entire length  of the Uniroyal site with the notable exception being the southern end of "the Gap area" whose surface elevation begins to rise as it meets the very large, diagonal, north-west to south-east ridge of high land that is mostly on Uniroyal's property with a very little on the Stroh property. Luis is just having fun by pretending to think that "the Gap area" only consists of the high ground at the southern end of the Gap area. Obviously liquid wastes flow downhill via gravity and it is typical for example of Uniroyal/Chemtura to sample soils on the higher ground and then pompously declare that gosh we didn't find any evidence of migrating liquid wastes here.   

The sampling on the Stroh farm has been minimal, shallow and totally bogus and unacceptable and Lanxess gratefully thanks the MECP for their service to the cause of sham cleanup.

Stacey feel free to send this my early response on to TRAC . 

Thank You Alan Marshall 

There are more issues and inaccuracies  in Mr. Almeida's letter than mentioned above. Ms. Bruce has already indicated that she sent my e-mail on to TAG for what good that will do.  

WELL, WELL, WELL IT ALMOST SEEMS AS IF THE MECP DON"T TRUST LANXESS

Tell me it isn't so. I've just gotten through in a letter to TRAC  describing Lanxess's  appreciation of the MECP's service to the cause of sham cleanups. Now in the MECP's November 8/24 letter to Lanxess I see a tad of coincidence in that the MECP are asking TWO questions in a row about DNAPLS.  I described the first question in last Thursday's post about residual DNAPL admitted to by Lanxess in former, on-site landfill M2.  Today's post is about the second question by the MECP asking Lanxess why contaminant concentrations in CH-75B reacted conversely to each other starting in 2019. Apparently NDMA concentrations started dropping significantly then whereas chlorobenzene concentrations began rising significantly. 

So is the MECP legitimately wondering or are they just advising Lanxess to do a better job in clarifying the non-existence of free phase DNAPLS preferably both on and off-site? To a non bought and paid for fellow travellor  of  Lanxess the answer is relatively obvious. W4 had been both containing and slowly dissolving the free phase DNAPL found 100 feet below ground at OW57-32 almost beside W4. Afterall why do you think the twits put the pumping well (W4) there in the first place but to deal with the non-admitted free phase DNAPL CRA inadvertently found in the first place. 

Concentrations of chlorobenzene dropped significantly after years of pumping so in 2017 Lanxess quit pumping W4. Lo and behold the chlorobenzene then happily migrated under the pumping of well W3R. Along the way it also went past CH-75B where sampled concentrations began rising. No surprise at all. 

COMBATING WOOLWICH CORRUPTION ONE STEP AT A TIME

 

I guess it all helps when everybody is on the same team doesn't it? That was certainly the take away I was left with when Mark Bauman, Scot Hahn and Sandy Shantz all skated on proven allegations, complaints and even formal Municipal Elections Act (MEA) charges. They skated because there was no will or backbone to actually apply the law as clearly written. All three grossly violated the MEA and other than the court of public opinion giving them a slap on the wrist, they got off unscathed. One point I especially appreciated was the idiot out of town prosecutor Frasier Kelly actually blaming me for alleged technical errors in the filing of the charges. Duh and why do you think all those charges had to go by the perusal and supervision of a Justice of the Peace you twit? It was the JP who decided whether the charges were properly written up and laid, not me the complainant. Yes with friends like that in high places corrupt politicians may just as well keep on ignoring inconvenient (to them) election laws and maybe any others they don't care for such as provincial laws detailing municipal behaviour around closed meetings, allowing Delegations and so much more such as Procedural By-Laws and Codes of Conduct. My experience is that by far the worst behaviour and violators are councillors and mayors not citizens.   

Today's K-W Record has an article by Michael Tutton titled "Watchdog says Tim's card brouhaha shows electoral officer needs power to levy fines".  Duff Conacher of Democracy Watch has stepped into the debate about a Conservative idiot campaign manager in Nova Scotia handing out free Tim Horton cards  (for one coffee) during a campaign visit by his candidate. Clearly the alleged bribe was very small but it nevertheless is clearly contravenes elections laws. Mr. Conacher advises that cases like this can "...drift on for months and end up being abandoned." He recommends a sort of parking ticket style of fine for the lesser corrupt practices under the Elections Act. 

The point is clear. Laws that are not enforced are ignored (especially by politicians?).  So it is the duty of citizens to step in when our authorities are too busy or too friendly with the law breakers to do their jobs. Woolwich politicians are warned: fly straight or pay at least the consequences of public shaming.

INTERESTING UNANSWERED MECP QUESTIONS TO LANXESS

The Min. of Environment sent a letter dated November 8, 2024 to Lanxess regarding their 2023 Annual Monitoring Report. Now overall the MECP are Lanxess's biggest boosters and biggest defenders. This of course is prima facia evidence of corruption as this is NOT the MECP's core duty. Their core duty is to prevent pollution and when they have grossly failed at that such as with the Elmira Uniroyal Chemical case they are then supposed to be in charge of CLEANUP. They are not supposed to be in charge of the appearance of cleanup nor the chief cheerleaders of wishful thinking cleanup.

Nevertheless the MECP apparently have a problem with alleged residual DNAPL still in existence in the former on-site M-2 Landfill. Apparently decades after DNAPL was not surprisingly found in the M-2 area,  it's type and location has not been clarified to the Ministry's satisfaction. They have asked on page 5 of their Comments where it is located, why these alleged residual sources are not contributing to off-site groundwater contamination and what are the existing sources of dissolved NDMA and chlorobenzene in groundwater off and on the site.

Firstly more than likely free phase DNAPL is still in the M-2 area. Secondly what has taken the MECP so long to demand answers to questions that should have been honestly and properly answered decades ago? Is this the MECP simply going through the motions and pretending to be an honest to God regulator of polluters?

The MECP comments while addressed to Lanxess were also sent to mayor Shantz plus Tiffany Svensson. Presumably also to TRAC (totally rotten and corrupt). This should all ensure little to no pressure  for any kind of timely response and good Lord certainly no kind of timely action. Thirty-five years after the start of the November 1989 Elmira Water Crisis the biggest winners have been delay, obfuscation and deception. Obviously no urgency has ever been shown or demonstrated and to do so now would be terribly inconvenient and disrespectful to the polluters, the politicians and all their fellow travellors.