EPA & USGS DEFINITIONS OF EFFECTIVE SOLUBILITY

    EPA - U.S. Environmental Protection Agency

USGS - United States Geological Survey

         SOURCES:

  "Effective Solubility Assessment for Organic Analytes in Liquid Samples, BKK Class 1  Landfill, West Covina California 2014-2016  USGS Open-File Report 2019- -1080"

    "EPA  Ground Water Issue  Dense Nonaqueous Phase Liquids  March 1991" 

Page 8  EPA      

                         "Organic compounds are only rarely found in ground water at concentrations approaching their solubility limits, even when organic liquid phases are known or suspected to be present. The observed concentrations are usually more than a factor of 10 lower than the solubility presumably due to diffusional limitations of dissolution and the dilution of the dissolved organic contaminants by dispersion. This has also been attributed to:  reduced solubility due to the presence of other soluble compounds, the heterogeneous distribution of DNAPL in the subsurface, and dilution from monitoring wells with long intake lengths."

Page 2  USGS

                           "...the presence of DNAPL or mixed DNAPLs was considered unlikely based upon measured concentrations below the aqueous solubility threshold of 1 percent that is commonly used as a "rule of thumb" to screen for the presence of DNAPL, as described in the Draft Leachate Investigation Report ..."

"However, the 1- percent threshold for considering groundwater concentrations indicative of NAPL presence refers to effective solubilities rather than aqueous solubilities, when the NAPL may contain more than one compound ."

    Personally I have been aware of the difference between Aqueous or Lab Solubilities and Effective Solubilities for at least the last twenty-five years. So have Conestoga Rovers and GHD and any other "experts" in the field. Oddly none of them spoke up at last Thursday's TRAC meeting as Allan Deal (GHD) verbally misrepresented the 1 % rule of thumb by suggesting that concentrations at or above 4,900 ppb (ug/l) were required to indicate DNAPL presence. 

I think Sandy that either your "experts" are no such thing OR they find it beneficial not to criticize or dispute Lanxess and their client driven consultants. Keep on appointing polite, deferential people who will never say BULLSHI*  even when they're up to their necks in it.

Alan Marshall  EH-TEAM & more

REGARDING LIQUID CONTAMINANTS, EFFECTIVE SOLUBILITIES ARE LOWER THAN LAB SOLUBILITIES

 The title above refers to yesterday's second last paragraph here where I discussed Mr. Deal's misleading of TRAC and the public by stating that the 1% rule indicated that chlorobenzene concentrations had to equal or exceed 4,900 ug/l (ppb.) to indicate possible DNAPL upgradient. That is nonsense based upon the multitude of dissolved chemical contaminants in Uniroyal/Lanxess's groundwater. Much lower concentrations based upon the EFFECTIVE Solubility would indicate DNAPL nearby. 

Five minute wonder Hadley (Lanxess) advised TRAC that Lanxess are now thinking of recirculating treated groundwater into the Elmira Aquifers. This sounds the same as suggestions decades ago to "reinject" allegedly clean groundwater back into the aquifers. I'm skeptical and for good reason.

TRAC were advised that the MECP are not ready to finalize the Risk Assessment after all these years (of deception, delay and obfuscation-my comments).  My guess is that they too are wondering if the public will be able to swallow the "no unacceptable risks" bulls**t  Lanxess (Stantec) are selling. 

Sebastian actually advised at Thursday evening's TRAC meeting that the pumping at on-site well PW4 was "woeful". He is correct yet for him to criticize Lanxess so harshly is music to my ears. That well is the MAIN well preventing the grossly contaminated on-site Municipal Upper (MU) from flowing off-site and recontaminating the Elmira Aquifers all over again. These excuses by Lanxess do not bode well for the promised pumping forever (in perpetuity) on the Uniroyal/Lanxess site. 

One more of these excuses was presented by Allan Deal advising that an "engineering buffer" is built into the Target pumping rates. This is to suggest that the Target Rate is flexible and can be readily under achieved without consequences. One that is not what we were told decades ago and to this day the following sentence is written in the footnotes (1) below each month's (Progress Report )Table of Average Daily Pumping Rates : " GHD recommends that Lanxess maintain the target pumping rates greater than or equal to these rates."  So quit making excuses and get your G.D. pumping rates back where they belong which is the long ago approved TARGET PUMPING RATES!!!

Apparently the Ontario MECP are writing some kind of tech report about the Risk Assessment. Whoopdy Do !!! Now it sounds as if Lanxess may share that report with the downstream farming families (Old Order Mennonites) first and then later with TRAC. Well the good news for Lanxess is that they will not get much if any opposition from either group. 

Again Lanxess are terrified about both on and off site DNAPLS hence repeated attempts to either manufacture or enhance "evidence" that might suggest they don't exist and never did.  Comparing chlorobenzene concentrations in wells PW4 (on-site) and W4 off-site is one example. Allegedly the chlorobenzene concentrations have been dropping in W4 and not so much in PW4. If this proves anything it is that the free phase DNAPL beside PW4 on-site at well OW88 is greater in mass and volume than the DNAPL found beside the Howard St. water tower in well OW57-32  which instigated W4 being located right there. 

Thank you Mr. Deal for using Varrnicolor Chemical as a distraction to TRAC members. At the same time you have emphasized how Varnicolor were/are a source of contamination to the Municipal Aquifers in Elmira albeit allegedly only of six solvents including very toxic Vinyl Chloride, DCE and others. Also we are advised that after 35 years Varnicolor still is not fully remediated either, as the owner who tried to get a clean bill of health in 2016 from the MECP has given up on it.  

I would characterize Thursday's TRAC meeting as an exercise in Dishonest Sincerity by GHD. Woolwich Township should be ashamed of their enabling this manipulation and deception of their citizens.

UNIROYAL/LANXESS CONSULTANTS CONTINUE TO LEAD WOOLWICH TOWNSHIP BY THEIR NOSES

 This is certainly accurate for the newer, younger Township councillors. They haven't got a clue albeit how could they? The CAO, mayor and former TAG Chair Tiffany Svensson are totally different. Unless all three are far stupider than I give them credit for, then they know full well what's going on and are a part of it. Last night's TRAC meeting was yet another case of the same two twits, Luis Almeida and Allan Deal strolling down the garden path with untrained amateurs  in tow.  Now the likes of Eric Hodgins (RMOW) and maybe one or two other professionally trained  persons not so much. I suspect that this is the reason honest persons such as Katherina Richter and Dustin Martin walked away from TAG. The stench of complacency and bulls**t was too overpowering. Only one TRAC member last evening showed the slightest amount of common sense and outrage and that was Sebastian Seibel-Achenbach. He pushed hard against both Luis and Allan Deal's plethora of excuses and lies regarding Lanxess's major pumping reductions and failures especially on-site albeit off-site as well.

Agenda Item 5.1.2.3 discussed pumping rates. and as indicated above it was yet again excuse after excuse as to why over the last three to four years both on and off-site pumping has been decreasing. Decreasing by ridiculous amounts especially when we are told that they aren't going to achieve drinking water standards by 2028. Does an Olympic athlete after being told that he is shy of the Olympic standard, slow down? Does he coast when his coach tells him it's time to get to work ? That is exactly what Lanxess have been doing while making up excuse after excuse rather than getting to it and pumping MORE as they have promised to do in the past.

Then we get to what passes for an "investigation" by these clowns. CRA have been caught over the years fudging and pretending that they are doing scientific inquiry and studies. Dr. Richard Jackson (former TAG Chair) literally laughed at their so called "pilot testing" of ISCO (In Situ Chemical Oxidation).  Both Morrison-Beatty's and CRA's DNAPL "investigations" were a farce intended to disprove the obvious which had even been admitted privately by Frank Rovers (CRA) that the site was filled with DNAPLS whether free phase or residual. Honest interpretations of the data showed the same thing.

Last night's "Chlorobenzene Source Evaluation " at TRAC was more of the same. Essentially Allan Deal (GHD) set out to "prove" that Dr. Neil Thompson of the University of Waterloo was wrong when he reported several years ago that there was an excess 1300-1900 kg. of chlorobenzene in the Elmira Aquifers. That "excess" was based upon Uniroyal Chemical records showing exactly how much chlorobenzene was used in production over the decades and how much chlorobenzene was discharged into the wastewaters dumped on site. Lanxess later reported that isotopic analysis proved that it was different chlorobenzene in parts of the Elmira Aquifers than what was discharged on the Uniroyal site. 

Mr. Deal's "investigation" had four components to it of which he failed to share the results of the alleged "review of historic chlorobenzene users"; he installed one whole new monitoring well somewhere with a blurry map  of where; he collected samples and analyzed them for VOCs and finally he collected samples for isotope analysis. Not a mention by Mr. Deal of Borg Textiles as a historic chlorobenzene user. What relevance was there for the new monitoring well? What did it prove or disprove? His analysis of samples for VOCs was irrelevant in that the samples were from Varnicolor Chemical and "are not COCs at the Lanxess site" which is a whole lot different than saying they are not on the Uniroyal/Lanxess site. COCs are Contaminants of Concern and chosen by Lanxess. Finally the isotopic analysis. What a pile of pus . Where were the samples whether shallow soils or groundwater from the other "historic chlorobenzene users" such as Borg.? No evidence was shared with the public five years ago from Dr. Neil Thompson (likely shared with Lanxess) and the repudiation of it by Allan Deal was presented with equally vague and weak evidence as far as laypersons and the public are concerned. Basically Mr. Deal proved nothing. 

On page 16 of Mr. Deal's "Chlorobenzene Source Evaluation" he discussed solubility and the 1% rule.  His written quote from the Environment Agency seemed accurate but then he verbally fudged it's interpretation by suggesting that 4,900 ug/l (ppb) was the concentration criteria suggesting DNAPL upgradient was possible. That is false as the lab solubility of chlorobenzene in water is 490,000 ug/l in pure water NOT NOT NOT in the grossly contaminated groundwater on the Uniroyal site.  The real on site solubility is referred to as the EFFECTIVE solubility exactly as the quote indicates. Mr. Deal verbally misled TRAC and the public. Feel free to alter the recording to protect the entire, long term DNAPL coverup. 

This is the third TRAC meeting and all three have been propaganda sessions. I left last night's meeting at the end of the alleged DNAPL/Chlorobenzene investigation. It's been decades of professional liars spewing junk science to generally spineless but sociable wimps. I'll catch up on the new Control Order and likely pretend, new remediation when the meeting is up on the Township's website. TRAC is also carrying on their anti-public behaviour in either denying them the right to ask questions or delaying it unnecessarily.

THE TAIL WAGGING THE DOG IN ELMIRA HAS ALWAYS BEEN THE CORPORATE POLLUTER

 The tail is Lanxess and the dog is the cleanup. This perversion tells the tale of who is really in charge in Canada. It is corporations who are above the law. Why wouldn't they be? They lobby governments for laws, rules and regulations that are corporate friendly. They make all the major decisions behind the scenes. If political parties want major corporate donations whether above or below the table then they do what they are told. Or quoting Sebastian Seibel-Achenbach and others "He who pays the piper calls the tune."

The MIckey Mouse cleanup in Elmira since 1989 has been 100% under the control of Uniroyal Chemical, Crompton & Knowles, Chemtura and now Lanxess. Lanxess have given us significant groundwater pumping reductions both on their site and off-site throughout Elmira. They have given us a pathetic, biased  Risk Assessment  (R.A.) stating that there are no unacceptable risks in the downstream Canagagigue Creek from Uniroyal/Lanxess. Well of course they aren't unacceptable to Lanxess and their fellow travellors . Stantec who did the R.A. did so accepting the data from Lanxess/GHD at face value. It was biased data throughout the length of the Creek based upon improper sampling methods (shovels v. core samplers) and inflated laboratory Method Detection Limits (MDL) above government health criteria thus eliminating valuable data and health exceedances. 

Who are Uniroyal/Lanxess's fellow travellors? First and foremost are the Ontario Ministry of Environment (MECP).  Call them a captured regulator or whatever you will the government of the day has never given them the financial backing to successfully take on corporate giants in our courtrooms.  Speaking of our courtrooms they are the playground of the rich and that too is no accident. The wealthy feel that they have a divine right to rule this country and have made certain that they and their friends are given status and respect within the judicial system which again political parties have molded to suit them and their friends needs, not yours or mine.

Further fellow travellors include municipal councils, regional councils, GRCA, and many more. All well off groups financially who have vested interests in maintaining the status quo.  All of these groups will grudgingly follow mass citizen movements but they will never lead them or help them initially. Whether modest change or revolution none of these groups want change.  Hence the inertia and lethargy by our authorities to step up and honestly address public problems, especially those that have been contributed to by our complacent governments and various authorities.  

1989 - 2024 LOTS OF TALK & STUDIES BUT SO VERY LITTLE ACTUAL CLEANUP IN ELMIRA

 

Some pits and ponds were emptied and backfilled in the 1980s BEFORE the announcement of NDMA in Elmira's drinking wells. I believe that our authorities were not at all taken by surprise but were fully cognizant that they had contaminated Elmira's drinking wells long before November 1989. In fact I fully expect that the lying sh**s knew that they had contaminated both the north wellfield (E2, E5, E8 etc.) as well as the south wellfield (E7, E9) probably no later than 1979.

On-site cleanup since the start of the Elmira Water Crisis in November 1989 has not been zero. In  late1993 a few DNAPLS were removed from TPW-2 and RPW-5 and put  into the Mausoleum or Envirodome along with the contents of RPE4 & 5. Then in 1999 the Mausoleum was emptied and the contents trucked to Corunna near Sarnia for burial in an alleged, secure hazardous waste site. Later on a few more DNAPLS were inadvertently found near RPE-3 and removed. There was also some excavations of creekbanks and part of an island in Canagagigue Creek in the early 2000s. I believe that there may have been some relatively minor further creekbank excavations on the north-west side of the Creek as well . 

The problem with both the excavations in the 1980s as well as the 1993 excavations is that only visible surface wastes were removed. Jeff Merriman, a Uniroyal Chemical engineer, bragged to UPAC & CPAC that excavations stopped when they could no longer see or smell the contamination. Not exactly a serious scientific analysis especially considering the known leakage through the bottom of the pits  (3,400 litres per day on the west side alone) according to CH2M HILL , consultants to the Region of Waterloo.

Now today in September 2024 Lanxess want us to believe that they are serious about doing remediation that could have and should have been done 25 or 35 years ago.  They will also likely claim that the remediation today is so much better than it used to be. Really?  Dr. Richard Jackson (TAG Chair) advised TAG and the public in late 2016 that there were no "magic bullets" i.e. new cleanup methods.  Perhaps some of the numerous remediation methods have been fine tuned, chemical amendments added etc. . That in itself would be great but are we going to trust the professional liars (Lanxess & the MECP) to be in charge of that cleanup after the mess they have made together for the past 35 years? Secondly will they only cleanup the off-site Elmira Aquifers or will they actually clean up as well the former Uniroyal site itself to ensure that down the road negligence doesn't re-contaminate the Elmira Aquifers?

Or perhaps Lanxess and the Ministry (MECP) just want to talk about new remediation methods for the next 35 years. Talk alone is cheaper especially if you ignore the value of the environment and the lives of human beings and wildlife.  

WOOLWICH FINALLY RESPOND (SORT OF) TO MY MULTIPLE E-MAILS TO THEM, THE REGION & THE MEDIA ABOUT CLEANUP FAILURES

 

A little over a month ago I sent about seven detailed critiques to all three groups above.  My critiques over the last couple of years have also listed two items namely decreasing groundwater pumping rates both shallow and deep and both on and off the Uniroyal/Lanxess property as well as references to chlorobenzene as free phase DNAPL found 100 feet below ground surface in monitoring well OW57-32 (R) beside the Howard St. water tower in approximately 2007. Perhaps according to this week's  (Thurs. 6 pm.) TRAC Agenda Lanxess are finally going to address those two items. The rest are still being ignored as the professional liars in town are wont to do. 

The seven detailed critiques focused on the Stroh and Martin farms to the east and slightly south of Uniroyal/Lanxess. They included items such as elevated east side pits (RPE 1-5), Interceptor Trenches, phony location of GP-1,  putting Uniroyal contaminants through the Martin swimming pond, lack of buffer zones with the two farms, the "sink" of dioxins and DDT on the Stroh farm and where it is located etc. All of these are huge issues which only first class scum and their fellow travellors would or could ignore. The fact that the downstream Creek ("Gig") is still so highly contaminated is a clear indication that toxic chemicals have never stopped leaching, flowing and migrating off the Uniroyal site and likely won't until much, much more than on-site hydraulic containment (pump & treat)  is the solution. 

One of the recipients of the three groups above is councillor Nathan Cadeau. Yes he is woefully unqualified, ignorant and full of false piss and vinegar. Nevertheless he is the Chair of TRAC and should have been passing along my critiques and more to TRAC members AND to Lanxess/MECP. Has he? I would say 50/50 whether he has or not. I don't believe that he is honest and straightforward but I KNOW that he is grossly ignorant of the Elmira Water Crisis which puts him in with most of  Woolwich citizens.

HOW DESPERATE & STUPID ARE THEY AND IS THE SUDDEN RELEASE (this Thursday) OF THE NAME OF THE SECOND SOURCE OF CHLOROBENZENE RELATED?

 I've been trying to figure why Lanxess have suddenly decided to rat out one of their former corporate colleagues here in Elmira. While Varnicolor is long gone I believe that Glenoit is the newer name for Borg Textiles. Has a deal been done or are Lanxess simply too big to worry about legal issues by naming the second source? Another reason may be that if Lanxess/MECP are going to try and bullsh*t  the public into believing that they've suddenly decided to properly remediate the Elmira Aquifers then they have to show some good faith. Good faith as in admitting who the second (or third?) source is. Doing this not only improves their credibility but it paints them in a more sympathetic light as in they've taken all the chlorobenzene blame for the last thirty-five years. Strangely (?) at the last RAC meeting Jason Rice (MECP) disagreed that there was a second source of chlorobenzene. Maybe he hasn't received the memo that it's O.K. 35 years later to tell the public that there were multiple bad pollution actors in Elmira for decades and that many of them contributed to poisoning the wellfields. Yes Uniroyal Chemical was likely the biggest and baddest (?) but Nutrite, Varnicolor and the about to be named one this Thursday at TRAC also contributed. Plus others still unnamed.

How about a second source of NDMA? I would say that that is more than just a possibility. From Varnicolor using the precurser to NDMA namely dimethylamine as a raw material in their commercial can coating process to the fact that higher than expected concentrations of NDMA were found from observation well CH38 beside Sanyo on Industrial Dr. for decades as well as further south closer to the south wellfield. Even the location of pumping well W3 and W3R give us a clue as the pumping wells were often very close to various off-site source areas. W3 /W3R is actually between Sanyo and the former McKee Harvester. Coincidence maybe . Pumping well W6A/B was a much later addition and is located at the extreme south end of the former Borg Textiles.

One thing all the guilty parties have shown themselves to be incapable of doing is being honest with Elmira/Woolwich citizens. As well they will never admit to the conspiracy between Uniroyal and the Ontario Ministry of Environment to minimize both parties negligence and incompetence in protecting our drinking water. 

CAN THE INGRAINED HABITS OF PROFESSIONAL LIARS BE OVERCOME?

 

Why not? Alcoholics can be weaned off of alcohol. Drug addicts have broken the cycle of addiction. Smokers have totally turned around their health and future by stopping in time. Human beings have an infinite capacity to change when they themselves so choose. We cannot do it for them. I have no illusions that my naming Uniroyal Chemical and corporate successors as "professional liars" has changed any of them. 

Speaking of "illusions" does anyone remember the excellent Documentary by Michael Heitman and Bonita Wagler titled "Grand Illusions".  If you don't it's because Lanxess Canada pulled the plug on it AFTER it was completed. My understanding is that the documentary was "balanced" in that the two originators had interviewed both community members as well as Chemtura employees. That said again my understanding is that Lanxess didn't like something their own employee had said on camera. My expectation would be that the employee was Jeff Merriman who led the Uniroyal etc. environmental charge for decades before retiring.

Has my condemnation of our corrupt Ministry of Environment changed their behaviour? I don't think so. They are as useless as teats on a bull with occasional exceptions from specific employees. Two days ago I posted here about whether or not Lanxess, the MECP and Woolwich Twn. seriously were interested in real remediation of the Elmira Aquifers.  Three days ago I posted a long but only partial list of lies that we the public have been told by our various "authorities" and their professional liars. 

Is professional lying an addiction? Should there be a psychiatric designation for it? Some people literally can't speak more than a few sentences without throwing in intentional lies and disinformation.  The very best politicians however have their lying under control. They can turn it on and off like a tap. Former mayor Todd Cowan had no such control and he's hardly alone. Self-aggrandizement is a part of the psychopathy of compulsive liars.  

It certainly is habit forming.  Normal citizens recognize that most politicians lie on occasion. Normal citizens would be shocked at how most politicians rely on it however as when in doubt lie your way out of it. Rarely do citizens applaud lying politicians who later apologize for their economy of truth. Hence there isn't much incentive to confess when it's just easier to repeat the original lie or make up a new one. They are generally difficult to prove one way or the other. 

Where does this all get us? Remember possibly President Reagan long ago when discussing arms agreements with Russia suggesting that the "U.S. will trust but verify.".  Well it's the same with polluters, their corrupt regulators and politicians from all levels suddenly at the last minute deciding that gosh more needs to be done to either clean up Elmira prior to the 2028 deadline or at least give the impression that that is what they want to do.  Their words and promises are wind, verification will be necessary and not verification from tame, lapdog committees appointed by the professional liars themselves.

 

DO WE CONDEMN LANXESS FOR SITTING ON THIS INFO FOR SEVEN YEARS OR DO WE PRAISE THEM FOR FINALLY COMING CLEAN ABOUT IT?

According to their Agenda for the upcoming TRAC meeting (Thurs. Sept 12/24) namely Item 5.1.4 they are going to blab about both DNAPLS (chlorobenzene) and about their Off Site Isotopic Analysis Study. Now some of this was shared with TAG and the public via Dr. Thompson (U. of Waterloo) several years ago around 2018. He claimed that there was an excess quantity of chlorobenzene, above and beyond Uniroyal Chemical's donations/dumping, in the off-site Elmira Aquifers. He also claimed that this excess chlorobenzene from a second source could be identified allegedly by isotopic analysis. It was obvious to me that there were but two very likely sources across the road from each other (Howard Ave.) who could be responsible, both of whom I have identified for years here in this Blog (Borg Textiles & Varnicolor Chemical).   

Now if it is Varnicolor there is going to be hell to pay as their groundwater allegedly showed NO chlorobenzene present via Ministry lab testing.  That would indicate gross corruption by the Ministry and while they avoided an Inquiry thirty some years ago this would be too much. It would be clear evidence of intentional government corruption. Now with both companies long gone from Elmira maybe some backroom deals have been done. One thing is for sure namely that both companies  either had a dye shop (for textiles) or paint and solvents as the major source of their business (Varnicolor).  Could both companies be responsible for the excess chlorobenzene?

Agenda Item 5.1.2.3 is titled "Investigating Well Extraction Pumping Rates". Now this again is interesting in that I've been sending e-mails to both Woolwich Council and TAG/TRAC for at least the last couple of years about this. Now do keep in mind that we the public are dealing with professional liars here  in Elmira. Maybe they are going to come clean and maybe they aren't. It could go either way just as their fatally flawed HHERA  (Human Health & Ecological Risk Assessment) claims that there are "no unacceptable risks" in the downstream Canagagigue Creek from Uniroyal's still present DDT, dioxins, lindane, PAHs, parathion etc.

I'll wait and see how clean the company comes AND if they want to share with the public why the public consultation body never felt the need to speak out publicly on these matters. Was TAG/TRAC kept in the dark or were they asked nicely as friends of Lanxess/MECP to keep their traps shut on these and other public matters. Either way is damning of all parties.

ARE LANXESS CANADA SINCERELY CONSIDERING ACTUALLY PRPOERLY REMEDIATING THE ELMIRA AQUIFERS?

 

Now come on! Quit laughing and quivering with mirth. Just because they and their corporate predecessors along with their regulator (MECP) have spent the last 35 years lying to the public about the Elmira Water Crisis is no reason to be skeptical. Maybe they're experiencing a Come To Jesus moment. Maybe they're on drugs. Hell maybe they've actually grown a conscience or something else bizarre has happened. Who knows?

Now of course there is still the problem of AFTER the Elmira Aquifers are clean to drinking water standards they are still directly connected to the upstream mess called Uniroyal/Lanxess Canada. Sure, sure there has been on-site hydraulic pump & treat since 1992 of the Municipal Aquifers and  since 1997 of the shallow Upper Aquifer. One of the serious problems is that while still lying  about it they have reduced their on-site pumping dramatically thus allowing off-site leakage despite their denials.  Imagine the day after Lanxess either goes belly up or retreats to the U.S. or Germany. Who's going to pay for the electricity to keep the pumps going? Who's going to maintain the motors, pumps and treatment facilities? The Elmira Aquifers will unfortunately end up right back where they were in the 70s, 80s and 90s.

Promises from the company are nothing but wind. Do the cleanup of both the aquifers and the Creek properly and then come talk to me.  After 35 years of irresponsible lying and deceit we the public do not owe you one inch of leeway or confidence.  

STORIES (LIES) MY FAVOURITE POLLUTER HAS TOLD ME

 

Impermeable clay aquitards

10% Solubility Rule

Tripling the amount of Off-Site pumping

30 years to remediate the Elmira Aquifers

Polluter Pays

independent public consultation

Uniroyal was the only source of contamination

"NDMA is not in our vocabulary"

nothing flowed eastwards from Uniroyal onto the Stroh property

nothing flowed southwards onto the Martin property

hydraulic containment in ALL aquifers

using shovels instead of core samplers is O.K.

there are no free phase DNAPLS on the Uniroyal site

there are no free phase DNAPLS off the Uniroyal site

all surface drainage on the east side went into GP1 & 2

there are no unacceptable risks downstream in the Canagagigue

risk assessments will be done properly and honestly

chemical odours are not necessarily health issues

professional consultants have a code of ethics or responsibility towards the public interest

The above took me about ten minutes to think of and write down. Over 35 years there have been lots of other truth efficiencies and economical truths. 

RAC & TAG + LIPSTICK = TRAC (TOTALLY ROTTEN & CORRUPT)

 

Hmm ! Is it hypocritical after a title like the one above to suggest that there are some decent human beings on TRAC? First of all I truly expect that there are some decent human beings on TRAC (a matter of percentages) albeit I would suggest that they aren't very smart. Educated yes, smart no. Most of the smart ones have abandoned that particular ship and TAG a along time ago. Even the Region of Waterloo had walked away for a while from UPAC, CPAC etc. when they had had enough. They did it low key but they gave warning that it was coming as it did.

Perhaps "Totally Rotten and Corrupt" could be replaced with a gentler moniker. How about "Too Reasonable About Corruption"?  Maybe better would be "Too Relaxed About Corruption". Ahh a rose by any other name would smell as sweet or in my jargon  ...corruption by any other name is just as putrid.

TRAC just like RAC & TAG was introduced by Sandy Shantz  both to mollify Chemtura/MECP as well as to deceive the public.  None of them were ever intended to actually promote proper remediation of the Elmira Aquifers, the Canagagigue Creek or heaven forbid the cesspool beneath the former Uniroyal Chemical.  They were intended to give the appearance of honest publlc consultation which they aren't and to give some credibility to the Ministry (MECP) and Lanxess's worse than Mickey Mouse pump & treat alleged remediation.

Remediation which can not help to fail (as they agree) although their excuses and blame runs the gamut from legitimate and accurate public criticism to "asymptotic behaviour" as well as "back diffusion".  The company (Uniroyal, Crompton, Chemtura & Lanxess) have been in full control of the cleanup since 1989 with only token criticism from the Ministry of Environment (MOE/MECP). Despite full control including mostly refusing Source Removal they have not cleaned up (or even close) the Elmira Aquifers nor have they removed even a shovel full of the downstream DDT and dioxins they are responsible for. Polluter Pays is nothing but a Ministry slogan. not a reality.