I'M TRYING TO FIGURE OUT THE RAMIFICATIONS OF RECENT (?) DNAPL RESEARCH

 

The answer to the question to Dr. John Cherry and Dr. Beth Parker (U. of Waterloo at the time) as to whether DNAPL should be left in place or removed from the Uniroyal Chemical (Chemtura) site was very clear. This question was posed to them by Susan Bryant, Pat McLean, Wilf Ruland (hydro G) and myself in January 2007.  To the apparent horror and shock of the other three, the answer from both Profs was absolutely free phase DNAPL that is accessible should be removed in order to shorten by decades the cleanup time of the aquifers it is impacting. The return trip to Elmira by the four of us was very quiet and solemn. Only in hindsight did I realize that the intended purpose of the trip was to get the single holdout (myself) to reverse my position that the DNAPL should be removed sooner than later.

Now seventeen years later I am in the middle of reading a Master's degree thesis regarding DNAPLs and Natural Attenuation. This thesis has as usual been reviewed by many of the author's peers including Drs. Parker and Cherry! I personally have had a very dim view of Natural Attenuation over the decades from information provided to myself and other citizens that claimed that among other issues chlorinated solvents (DNAPLS) were highly resistant to bacteria/microbial breakdown in the subsurface. If you think about it chlorine in and of itself is an antibiotic used specifically to kill bacteria in drinking water hence it made sense that it would not succumb readily to bacterial breakdown itself. 

This thesis is looking at TCE specific breakdown by both biotic and abiotic breakdown meaning by biological breakdown including bacteria and abiotic or chemical breakdown in the subsurface. This research and studies have been underway for years by a combined group from the University of Waterloo and the University of Guelph.

SURPRISE SURPRISE GUELPH INDUSTRIALISTS WERE NO MORE INTERESTED IN PUBLIC SAFETY & HEALTH THAN THOSE IN KICHENER-WATERLOO, CAMBRIDGE & ELMIRA

 

What do I base that statement upon? It is based upon a 2018 Master's Thesis submitted to the University of Guelph . The specific quote is on page 2 of the Introduction.  That quote is "In the City of Guelph, TCE and in some instances other chemicals have been detected at six urban water supply wells including Smallfield, Sacco, Carter, Emma, Membro and Edinburgh wells (Aquaresource Inc. and Stantec 2010). Two of the wells, Sacco and Smallfield, were taken offline in the early 1990s as a result of detection of low level Volatile Organic Compound (VOC) contamination (Kennel 2008)." My title above is further based upon  the fact that two of the advisers to the Masters student are Dr. Beth Parker and Dr. John Cherry, two preeminent groundwater researchers and two of my favourite hydrogeologists having met both personally in January 2007 and discussed DNAPLS at Uniroyal Chemical in Elmira with them.

Now I might add that the "other chemicals" above likely included breakdown products of Trichloroethene (TCE) such as cisDCE, trans DCE, vinyl chloride and maybe even a dash of tetrachloroethene (PCE). Of the six wells with TCE detections four of them are quite close to the former IMICO site. Talk about slamming the gate decades after the horses (TCE) has bolted! These four wellfields are the Edinburgh, Membro, Carter and Emma wellfields.

Here is a further peculiarity /coincidence between Elmira (Uniroyal) and Guelph (IMICO & others). Both are located extremely close to world class institutions studying groundwater contamination particularly including chlorinated solvents known as DNAPL chemicals such as chlorobenzene, TCE, chlorophenols etc. Despite this both cities seem wholly uninterested in getting world class UNBIASED information from these two world class institutions (U. of Waterloo, U. of Guelph). Are we to believe that both our provincial authorities (MECP) and municipal mayors and councillors are not looking out for the public interest but simply for their own?

 

SCOPING/MINIMIZING HAS CONTINUED IN THE NEIGHBOURHOOD SOUTH OF IMICO IN GUELPH

 Last Saturday I had asked a number of questions regarding whether or not indoor air testing had been done yet on homes in the area of Hayes, Kingsmill, Menzies, Audrey and Lawrence Ave.  I am disappointed to advise that as per information of, at the very least a dubious nature,  the Guelph Mercury reported four years ago that a grand total of TEN homes would have indoor air testing offered to them . These ten homes were in locations allegedly closest to the outdoor soil gas vapour probes with readings of 250 micrograms per litre (and presumably higher??). Very, very strange considering that the criteria or Soil Vapour Screening Level (SVSL) for TCE is only 13.6 micrograms per cubic metre (ug/m3) 

This is indeed even more serious scoping/minimizing of a very serious problem with the clear intent to limit the potential disaster that may have occurred and be occurring in this neighbourhood. I mentioned Saturday about the focus for sampling on Menzies, Audrey and Lawrence Ave. as well as a laneway between Lawrence Ave. and Victoria Rd. Between zero sampling of so many streets and homes in the TCE (trichloroethylene) affected areas combined with all of one gas probe sample once on Hayes Ave., our authorities have likely reduced the affected areas by more than 50%.  

This is not in the public interest. It is however in both the City of Guelph's interest as well as the Ministry of Environment's. Basically through deception and lying they are telling the public that this isn't a health disaster for many citizens it is merely a minor inconvenience for a few who may have  slipped between the cracks .

This article in the April 6, 2020 Guelph Mercury falsely states that 900 ug/m3 was the highest level found of TCE. In fact it was 2,520 ug/m3. The article also states that "...any health effects from TCE in the area were unlikely, and the risk of any vapour intrusion into any homes was low." The reporter advised that these two opinions came from the Ministry of Environment (MECP) and the Wellington-Dufferin-Guelph Public Health. Those are outrageous, wishful thinking, likely bulls*&^ statements given before any indoor testing has been done and before there is any determination of the integrity, lack of cracks or unsealed openings in the foundations of homes throughout the neighbourhood.  This is an older neighbourhood and utilities entering homes through the basements are possible vapour entry points as well as minor cracks in foundation walls and floors.   

"SCOPING", THE ART OF MINIMIZING YOUR ENVIRONMENTAL RESPOSIBILITIES RIGHT FROM THE START

 

Locally the focus here in Elmira has been selling the bulls*** idea that the only two contaminants in Elmira's groundwater requiring remediation are NDMA and chlorobenzene. The other 80-100 are given short shrift or no shrift at all. DDT, dioxins, chlorophenols, benzene, toluene and other petroleum hydrocarbons have been ignored allegedly because they will be "picked up" along with NDMA and chlorobenzene.  In fact DDT and dioxins won't be nor will undissolved LNAPL chemicals (gas, oil etc.) as undissolved (i.e. free phase) DNAPL chemicals (chlorophenols, chlorobenzenes, TCE, TCA, DCE etc.) also will not be. 

So what kind of scoping seems to be going on concerning the IMICO site in Guelph? Without commenting too much on the on-site scoping I can tell you that the 2017 and 2019 sampling of soil gas vapours in the subdivision between IMICO and the Eramosa River has very conveniently ignored way too many residential homes.  These include on Hayes and Kingsmill St. south of York Rd. and as well any homes or workplaces where human beings could be spending eight hours per day or more between York Rd. and Beverley St.  

Of the initial three gas probes in 2017, two had detected TCE (trichloroethylene) with one being well above the outdoor gas vapour screening level. Sampling occurred in June 2017 initially and has been followed with soil gas vapour sampling in 2019 with another fifteen gas probes spread through the community namely Menzies, Audry and Lawrence Ave. 

Those vapour readings are extremely concerning and I hope that our authorities have since taken action above and beyond sampling and report writing. Has the proposed indoor air sampling been done and have all neighbourhood residents been given all the results or is it the old bulls***  whereby each individual home owner are given their own indoor readings only thus preventing them from seeing the magnitude of the problem ? Finally as was done in the Bishop St. community in Cambridge have heavily vapour impacted homeowners been offered emergency shelter until their homes are safe to live in again?

BOTH TCE & DCE HAVE MIGRATED FROM IMICO (Beverley St.) TO SOME OF GUELPH'S DRINKING WATER WELLS

 

I was shocked not by the fact that volatile organic chemicals have flowed in the groundwater into some drinking wells in Guelph but that they would admit it in a technical document. The document is the June 12, 2020 Phase Two Environmental Site Assessment written by Jacobs (formerly CH2M HILL). Now that being said I have reread the relevant paragraphs and there appears to be some stickhandling going on (isn't there always!). Apparently Guelph's Membro, Park and Emma Wells have low levels of both TCE (trichloroethylene) and 1,2 DCE in them.  Now yes both these chemicals are beneath and throughout the IMICO property albeit in higher elevation Bedrock Aquifers than the Gasport Formation which is the primary source of municipal drinking water. However then we are advised that this Gasport Formation is hydraulically connected to a higher elevation Bedrock Aquifer called the Goat Island Formation which does have TCE and 1,2 DCE in it from the IMICO site.

SO... any chance our illustrious politicians, bureaucrats, "experts" and  hangers on would like to comment on vapour intrusion in the Kingsmill, Menzie, Audrey and Lawrence neighbourhood located between IMICO and the Eramosa River? I have seen a map showing soil vapours of chlorinated solvents including TCE, VC and PCE sometimes in excess of health criteria. The question of course is how many homes have these toxic vapours entering through basements and at what concentrations. Has this health threat been honestly investigated and the facts honestly disseminated to all the local residents?

"THEY ALL LIE "

 The source of the quote above in the title is at the end of yesterday's post here in the Advocate.  Pat Potter was decades ahead of her time and she knew liars when she heard them. Among many claims to fame was her discovery of the P.C.B.s found at Smithville, Ont.. She also discovered a dump possibly inside an abandoned quarry with petroleum hydrocarbon wastes in it. I vaguely recall her mentioning the original source as possibly Imperial Oil. The problem for me was that I failed to take her quote "They all lie" literally. 

She literally meant that ALL the people responsible and authorized as either spoke persons or "experts" were going to lie to the public. They had already settled the broad outlines of what they were and were not willing to do, spend, blame etc. plus what they might be willing to concede was true. Essentially the narrative they had all agreed to in private was that public hysteria, outrage and anger had to be softened as much as possible. These emotions could lead to dire social upheavals including an overall loss of respect for politicians and our democratic form of government.

There's an old adage that Democracy while not perfect is still by far the best form of government. I would suggest that no manmade institution has ever been or ever will be perfect. Democratic governments have certainly exceeded many other forms of governance including despots, communism, monarchies etc. They have however also failed abysmally around the world. Any and all forms of government can and have been perverted by persons of ill will. These persons are generally inferior as human beings but superior as liars. I would suggest that this is what separates us from animals. We communicate and lie constantly especially those of us in positions of power and authority.

Think of the arrogance required to assume that only elected citizens be given all the facts. Only politicians and their allies allegedly are smart enough to make the tough decisions. These tough decisions include growth and development for growth's sake. The included lies are that growth pays for itself. Growth helps the economy. Growth helps municipalities have larger tax bases and on and on. 

Apparently both in Guelph and Elmira (actually everywhere) development is wonderful even on contaminated sites. Who knew? By intentionally stickhandling around a serious environmental investigation of the Stroh (& Martin) farm, Elmira (Woolwich Twn.) has green lighted commercial development including a highway By-Pass up and around the east side of Elmira. In Guelph plans are underway for affordable housing on the former industrial IMICO site on Beverley St.  Minor issues such as no first floor housing (2nd story and up) and no gardens being allowed on site unless they are raised gardens with the soil all brought in from off-site haven't stopped plans in their tracks as they should. That site is a mess just as the former Uniroyal site in Elmira is.

Not to fear however as the authorized to lie, cheat and steal persons including politicians are all on board. They will sell their anti-social plans to most of us. This will require lots of credentialism and "Qualified Persons" as well as a few co-opted citizens, various municipal committees, mayors and councillors to all be on board. Provincial agencies/ministries are also helpful to sell the highly odourous and slimy "truth" to us. Who do we believe? A few honest citizens or dozens and dozens of bought and paid for bureaucrats, government employees, elected officials etc.? At what point do we as citizens understand that we have been lied to by all levels of government routinely and continuously and that everybody else involved are simply along for the self-serving financial ride?  

  

MECP CORRUPTION APPEARS CONSISTENT

 Why would I even think that the MECP were less corrupt in their dealings with other contaminated sites and polluters? Wishful thinking I guess. I have read many technical documents relating to other contaminated sites both in Waterloo Region and in Guelph. There are many similarities including wilful blindness and a stupidly naive reliance upon voluntary compliance. Examples include Ciba-Geigy,  Cnd. General Tower and Northstar Aerospace in Cambridge, Sunar and Canbar in Waterloo and IMICO in Guelph. 

I believe that the MECP's criteria in and of themselves are less than satisfactory. I believe that their political masters (provincial governments) have mandated them to avoid opening cans of worms as much as possible. In other words if you don't sample soils, groundwater, air on a maligned site than how can you possibly ever declare it contaminated? Getting back to their criteria they are premised on the wholly unrealistic and frankly naive assumption that pollution is an "accident" and that if a company reports a spill, it is the very first one ever no matter how many decades they've been operating there. Therefore the Min. of Environment (MECP) can confidently sample and if for example they only test for the "spilled" chemical they may get lucky and have a low concentration below the Ontario Drinking Water Standards.

Hence no big problem to report upstairs or to the neighbours. In Guelph the IMICO site has been empty since the 1980s. On the surface at least. Below ground however things are moving. Groundwater generally flows south-east in some aquifers and possibly south-west in others. There are multiple aquifers including several in the Bedrock of varying permeability and transmissivity. 

Apparently to this day there are still LNAPLS in the sub-surface. A prudent person (i.e. not the MECP etc.) might assume that with all the chlorinated solvents on site that there are also DNAPLS most likely firmly entrenched and embedded in the fractures in the close to surface Bedrock. All of this is horrible news yet the City of Guelph are more than ready to turn the site into affordable housing and parkland. Shame on everybody until the site is substantially cleaner than it is right now.

Quoting the late, great Pat Potter  "THEY ALL LIE".

UNRELENTING INDUSTRIAL/COMMERCIAL/RESIDENTIAL PRESSURE FOR DEVELOPMENT LANDS STYMIES PROPER CLEANUP

 It's happening here in Elmira , it's happening in Guelph and it's likely happening in every city in southern Ontario as well. In Guelph it's all about getting Ministry of Environment approvals  to allow the sale of the former IMICO lands both for residential development and for alleged parkland. The MECP first have to permit a Record of Site Condition (RSC) before development can take place. This requires a certain amount of flexibility possibly up to the Olympic gymnastic level in order to be able to say that the property is clean enough for development. Here in Elmira the same nonsense only less has occurred as Woolwich Council and the Region of Waterloo have falsely claimed that the lands on the east side of Lanxess are not contaminated. This is to allow both the Elmira By-Pass to go up the east side as well as to permit commercial and industrial development on the former Stroh and Martin farms.

Once again the corruption is throughout the system. It requires municipal councils, regional councils and provincial ministries (MECP) all focused on growth at all costs to be able to push against local citizens' rights to clean air, water and food. While my focus will be on Lanxess Canada at my next talk I may also touch upon IMICO briefly as it is a horrendously polluted site that has been allowed to migrate, dilute and delay proper cleanup for decades.

PRESENTING WITH APPROPRIATE FANFARE: THE (UN)OFFICIAL PLAN

This is an only slightly tongue in cheek rendition of Lanxess's  upcoming plans to emerge relatively unscathed from their potential public relations nightmare. Keep in mind that the corporate world have long embraced the strategy of "managing" the crisis versus actually solving the problem.  Crisis resolution companies have sprung up specifically to fill this market niche required by naughty companies who have been caught red handed in less than stellar behaviour.

So Lanxess purchased a dirty polluting company who have made a mess of the local, natural environment be it the ground water, surface water, air, soils and sediments.  Obviously Lanxess bought it expecting to make a profit which meant that they needed guarantees up front from the alleged regulator the MECP whose job has transitioned from ordering appropriate cleanups to maintaining smooth operating conditions for new owners who will invest only a tiny amount of their profits back into "cleanup". Hence the MECP do not shut down even the dirtiest of polluters as long as they get at least a nominal public respect from them and a minimal financial input giving the appearance that they give a sh*&. They do not and neither does the MECP. 

The MECP will write yet another Control Order or whatever fancy, new name they have for it. It will have strong language insisting upon the sanctity of the natural environment and all living things within it including yappy, complaining human beings.  They will privately tell Lanxess which paragraphs are for public show and which ones are at least half serious. Keep in mind this whole charade of regulator versus polluter is for public consumption only. Lanxess will flex their financial muscles and tell the Ontario MECP where to go privately if the MECP get out of line by Lanxess's determination.  The where to go will be to court where Lanxess will spend the MECP rapidly into submission.

The whole process is a serious effort at good public relations. Neither governments nor their masters want the public to understand who is really in charge. Sure as hell it isn't the monkees that we send to council tables, legislatures or parliament. Again they are there for show and to support the whole scam. It was decided long ago that industrial pollution was simply the price to pay for entrepreneurs to risk their money producing marketable goods. They should not also have to encompass serious environmental costs just to make citizens and residents happy. Afterall why are specific provincial and federal politicians supported and paid for both over and under the table if not for them to produce results acceptable to industrial corporations. Those results include weak environmental laws with lots of loopholes and tricky wording. They also include strong government endorsements alleging environmental compliance and honesty where none exists.  

 

EVEN CHILDREN ARE SACRIFICED ON THE ALTER OF POLITICAL EXPEDIENCY

 Who might I be talking about here? How about the Waterloo Region District School Board and the Ron Archer affair? To the best of my knowledge teacher Mr. Archer was subjected to the "Pass The Trash" policies of the school board at the time. This meant that as student and parent complaints dogged him from one school to the next he was simply transferred to a new school where school authorities most likely lied to outraged parents by suggesting that oh no there were absolutely zero complaints in his record suggesting inappropriate behaviour, words and touching. Of course that story stopped after his conviction and jail time. Yes since then other teachers and at least one principal have been charged with sexual offenses and removed from WRDSB schools.

Then we have Woolwich Township whose mayor is a former Chair of the School Board (WRDSB) i.e. Chair of the Trustees . Sandy of course is not the first psuedo politician to start at the Trustee level and rise through municipal politics and further (think Liz Witmer). During MECAC alleged deliberations  several years back Sandy actually had the nerve to raise the confrontation between myself and a teacher that occurred almost simultaneously with the Ron Archer affair (early. mid & late 90s). Sandy of course misrepresented those facts as she is wont to do from time to time. 

Back to Woolwich Township who to my knowledge have done absolutely nothing past or present to protect children swimming in the Martin home made, in ground swimming pool. A man made diversion known as the Stroh Drain, Ditch & Berm (SDDB) was built in the early fall of 1983 which connected both ground and surface water from Uniroyal Chemical into Martin's Creek which had a small diversion on it to replenish the water in the Martin swimming pond. 

Finally we have the former Bolender Landfill children's attraction of a Water Park. The location at the north end of the Park seemed odd when the boundaries of the Landfill have always been open to speculation. In fact soil samples taken prior to the construction showed "organics" which is the term usually used for decayed and decaying food stuffs. There are also word of mouth descriptions from nearby long term residents as to where they saw garbage buried. Oh and of course this municipal dump also accepted Uniroyal and other local industrial wastes.

All in all our local authorities have to my mind made their priorities clear and they certainly are not the children. 

IS THERE A DIFFERENT ENVIRONMENTAL REGISTRY SOMEWHERE?

 The current Environmental Registry is not adequate. Supposedly if you check on it regularly you will find ahead of time upcoming environmental changes, issues, hearings etc. Lovely but still inadequate.

What I would like to see is an Environmental Registry listing past complaints, charges, convictions, investigations, cleanups and or other environmental work performed . This Registry would/should be a geographically based such that for example a citizen of Cambridge can look up all environmental spills, cleanups and investigations etc. within the jurisdiction of Cambridge. 

Here in Elmira alone we would find a number of surprises for many people. The extra, ongoing work at Varnicolor Chemical (now Elmira Pump) is but one such example. Their pump & treat system was expanded in order to pump groundwater from Motiveair behind their property for remediation. Also ground contaminated by Varnicolor ,behind Motiveair, was excavated. All this was done on the quiet. Shame to Woolwich Twn. and most especially to the Ontario Ministry of Environment (MECP). There have also been a number of gas stations remediated locally and more.

Knowledge is power which is exactly why municipal governments and the MECP deny public facts and knowledge to the public. They do not want us to know how severely contaminated our town is and has been. Even our local health units should have  and sould share this information if they have it. There is an inadequate registry known as ERIS. Nothing there about Varnicolor or many other local polluters.

WHINY WOOLWICH DON"T LIKE "THEIR" TOES STEPPED ON.

 Woolwich have an Integrity Commissioner either by that name or another. So did/does Putin, Hitler, Ghaddafi, Amin, Saudi Arabia ...well you get the picture. Appearances matter especially among the uneducated, untalented and woefully uninformed.  Or in other words among the electorate.

Woolwich roared when they were " investigated" even oh so gently by our authorities, repeatedly. Sometimes quality or lack thereof in investigations demands multiple attempts by various bodies to try to paper over the obvious cracks and gaps in the so called investigations. In fact I would humbly nominate Canada as a potential world leader in Mickey Mouse investigations . If talk equaled real investigations then Canada certainly is a world leader. Just look at the junk science that's been done up here in Dogpatch (excuse me Woolwich) since 1989. Actually even prior to 1989 as the Ministry of Environment, Woolwich Twn. and the Region of Waterloo all reassured Elmira citizens that their water supply was fully protected from Uniroyal Chemical's greed, laziness and negligence. 

Woolwich have since moved heaven and earth, not to regain our local, clean drinking water but to shut down opposition . They have even aided and abetted Uniroyal co-opted citizens helping guarantee them perpetual seats at the table, one way or the other. People like that are known as "controlled opposition" and the advantage for polluters and liars is that they are indeed controlled. They have received benefits tangible and intangible but benefits nevertheless to be "good" boys and girls. With full knowledge of these  benefits Woolwich have appointed them repeatedly to UPAC, TAG and TRAC. Eventually likely after it's too late Woolwich and their toadies will be exposed.

SLEAZY OR JUST EVERYDAY CONTEMPT OF CITIZENS BY WOOLWICH MAYOR & COUNCILLORS?

 

O.K. in hindsight I am willing to admit that Julie Ann Herteis probably by far was not the worst councillor Woolwich has ever suffered through.  There are reams of smarter, more worldly councillors who had both a mean streak and a dishonest streak that I don't believe that Julie Ann has.  Nevertheless appointing her to a temporary councillor position might seem peculiar under many circumstances. If Woolwich Council in replacing Scott Hahn's sudden resignation had simply said "We have the right and the authority to unilaterally make this appointment (Julie Ann) and that's that." then quite frankly myself and most might have complained of favourtism etc. for a full five minutes. Instead Woolwich Council lied like dogs and went through a huge process of taking applications, demanding written biographies and insisting upon a public spectacle whereby ten very talented and credentialed individuals stood up and made a speech about why they were qualified and wanted the interim councillor's  job.

Ooops let me amend that. There were nine applicants who went the full distance plus Julie Ann who did her own thing. In one sense I have to respect her refusal to play the game exactly as Mayor Shantz and Counillors wanted it. She did not dress up at all. Blue jeans, running shoes, plain shirt etc.. She did not make a five or ten minute speech. She did not brag about her past accomplishments. She stated that she had "experience" as a councillor (one term) which she did and then lost at reelection time.

Meanwhile her competitors included business owners, professionals, PHds, all dressed formally, who made lengthy speeches as requested. They gave their curriculum vitaes and spoke of their love of Woolwich Township and public service. Most were clearly exceptional individuals who could have handled being a municipal councillor with ease. Julie on the other hand, whom I have since learned is smarter and more accomplished than I knew, struggled as a councillor. Hey we all have our strengths and weaknesses.

Councillors began voting. Good Lord but at that they weren't even terribly subtle. Julie was by far favoured for the position from the start. Well let me clarify. She wasn't favoured at the start of voting. No that minor inconvenience had already been eliminated. Julie was handpicked for the position before the process began. The process was all for show and Council however hadn't gotten all their ducks together or they would have made the voting last longer than it did. Wham, bam thank you Mam but Julie is the new short term councillor. I expect that most of the other applicants also figured out pretty quickly that they'd been used. They'd been lied to in that none of them were ever going to get the position. They all went through a public process that was simply designed to deceive the public. 

Woolwich Township still continue to behave in that fashion. It's called TRAC and it's equally disgusting.  

LEGITIMIZING FAILURE OR PUTTING LIPSTICK ON A PIG

This is what  authorities do. Unlike the rest of us who make errors  and both acknowledge them and pay the consequences, our authorities do neither. Firstly they lie either bluntly about their failures or they gild the lily by suggesting that in fact it really was a success for the following ridiculous reasons. Then, post failure they rewrite plans, documents, procedures or whatever is necessary to make the failure prettier and more palatable. They will always find the mythical rainbow at the end of their screwups.

The province of Ontario mandated 2028 cleanup to drinking water standards of our Elmira groundwater is simply the most obvious and glaring failure. It has been admitted to by Chemtura, Lanxess and MECP since 2016 and 2017. Of course over the last five years there have been lots of excuses suggesting acts of God, misfortune and other impossible to forsee factors. These have included "back diffusion",  the extremely low drinking water standard for NDMA (.009 ppb.), "asymptotic behaviour", lunar eclipses and ingrown toenails . Oh alright but if Lanxess, their consultants GHD or the Ministry (MECP)  had suggested those last two would you have jumped on them as quickly as you did me?

Here is what Lanxess and fellow liars have not admitted to:

Lack of on and off-site pumping

Lack of on-site DNAPL cleanup

Lack of off-site source removal

Lack of overall on-site source removal

Lack of strong, unbiased, non-deferential citizens on RAC, TAG & TRAC 

The new paperwork will be aided and abetted by Lanxess's partners in pollution namely the MECP and Woolwich Township. It will include position statements, new remediation plans, new Control Orders or equivalents and new public consultation always fully controlled by the mayor and CAO and butt kissing councillors. Of course nothing about the cleanups of water, sediments or soils will be improved, merely the further delays "justified".