ELMIRA INDEPENDENT COVERAGE OF CPAC MEETING

Last Friday's Elmira Independent carried this story "In-situ remediation project moves forward". Currently after two allegedly unsucessful locations to pilot test chemical oxidation, Chemtura believe they have found one. It is on Industrial Drive south of Oriole Parkway. There is a well named CH38 on the Sanyo Canada property that has had extremely high NDMA readings for more than two decades and it is this area and southwards near pumping well W3 that may be treated with ISCO. ISCO or In-situ chemical oxidation does exactly what its' title implies. It oxidizes other chemicals. In the case of carbon based (organic) chemicals such as chlorobenzene (C6H5Cl) it reduces the contaminant (chlorobenzene) by joining oxygen (O2) with the carbon to produce carbon dioxide (CO2) and as well adds oxygen to hydrogen (H) to make water (H2O). Allegedly it can break down NDMA (CH3)2 NNO or C2H6N2O similarily. While I am a little skeptical about this I will investigate further before expressing too strong of an opinion.

There was a second article in the Independent titled "MOE plans DDT study". It is fair to say that the initial studies in 1996 should have been followed up in a timely and scientifically valid method and were not. This is part of the reason that I am suspicious of what is belatedly happening now. It is interesting that as the Chemtura Public Advisory Committee (CPAC) gain traction on the cleanup of the Elmira Aquifers; the M.O.E. appear to be changing channels and direction. Over the decades the M.O.E. have done this before when Chemtura (Uniroyal) were under pressure.

RECYCLING IN GRAVEL PITS & HIGH PRAISE FOR CPAC

The Woolwich Observer carry this story in yesterday's paper "Toxic recycling to become more common at gravel pits, watchdog group warns". Meanwhile Thursday's Elmira Independent carried an Editorial by Gail Martin that really caught my eye titled "Making good things happen". While these two topics aren't remotely related I'm including both of them today because it's just not that often that two different important local environmental stories are in the media.

Ontario's Provincial Policy Statement (PPS) for 2014 has thrown a last minute curve at gravel pit activists. Without public consultation it has included the promotion of recycling facilities in pits and quarries. This was one of the issues at the Jigs Hollow Pit and was opposed unsucessfully to the end by at least one Woolwich Councillor, namely Bonnie Bryant. The issue of recycling concrete and asphalt is this. Asphalt above ground on dry land is essentially innocuous. When submerged as occurred in Teviotdale on the Berendsen farm it will leach various petroleum hydrocarbons into the groundwater and nearby wells. The Ontario government, Ministry of Transportation and Ministry of Environment threw the Berendsen family to the wolves. The government buried the asphalt in a swamp and then lied unmercifully for years while the Berendsens' cattle died. There are also huge issues with asphalt and concrete being ground up and or crushed. Air emissions especially of silicates from concrete are extremely hazardous. Again shame on our provincial Liberal government for sneaking this into the PPS surrepticiously.

Gail Martin of the Independent has written an Editorial praising the efforts of the volunteers on the Chemtura Public Advisory Committee. Associated with CPAC is the SWAT subcommittee (Soil, Water, Air & Technical) of which I am a member and which I hope she is including. The issue at the moment is the decision by the Ontario Ministry of the Environment to do another study of creek sediments and floodplain soils downstream of the Chemtura site, in the Canagagigue Creek. Gail is very optimistic that good information will come from this M.O.E. study and indeed it is worthy because more or fresh Dioxins and DDT found downstream will pressure the M.O.E. to order more cleanup of the Chemtura site. The M.O.E. have oft used the excuse that they can't order on-site cleanup unless contaminants can be proven to still be leaving the site. This argument is pathetic on all levels but is bolstered by the fact that 99.5% of all studies and reports are done by Chemtura's highly paid for decades, client driven consultants. Who wouldn't want the Chemtura gig and the guaranteed lifetime income stream associated with it? Lifetime that is if you behave.

Therefore I hope that Gail's optimism is correct and my pessimism based on the M.O.E.'s history is wrong. There are a thousand ways to jigger scientific studies and the partners in pollution on this site know them all. Allegedly CPAC will have input into the Work Plan produced prior to the study. That Work Plan may require as much study or more than the final results.

WATER TREATMENT IS DANGEROUS IN MORE WAYS THAN ONE

Well if nothing else Waterloo Region residents are getting a basic lesson in both Chemistry and peripherally in water treatment. The slogan "Better living with Chemistry" is a public relations ploy that of course is only half truthful. At the Greenbrook TREATMENT PLANT and Pumping Station, a Chemistry 101 experiment blew up literally. Housewives my wife assurred me, possibly a tad condescendingly, all know never to mix bleach (chlorine) with Ammonia. Why you ask by the way did I capitolize the above words "treatment plant"? I did so because between yesterday's and today's articles in the Waterloo Region Record I can't find the words "treatment plant" in reference to Greenbrook. Very strange. Am I reading too much into that? Does the Region think that citizens are so incredibly dumb that they can't figure out what chlorine and ammonia are used for? That maybe just maybe they aren't being used to wash the floors or toilets?

Both chemicals are used at Greenbrook as part of the disinfection of water. In other words they are used to kill bacteria. There are other chemicals used including hydrogen peroxide. As well Ultraviolet (UV) irradiation is part of an Advanced Oxidation Process used to remove 1,4 Dioxane a toxic chemical whose source I believe is the former Ottawa St. Landfill. Prior to its' disposal in the former landfill it came from private companies including Varnicolor Chemical in Elmira.

Therefore the point is this. Mere storage of toxic and reactive chemicals is dangerous in the first place. More dangerous however is the use of toxic chemicals in water treatment. Chlorine and ammonia combined form chloramines. Either chlorine or chloramines KILL bacteria. Think about pesticides and herbicides for a moment. DDT, 2,4-D, 2,4,5-T are all poisons by design. They kill either insects or vegetation. Unfortunately they also have killed birds, wildlife and humans via impurities within themselves (dioxins in Agent Orange). Chlorine and chloramines chemically react in drinking water and produce Trihalomethanes, Haloacetic Acids, Cyanogen Chloride, NDMA and the list goes on. These unintended by-products of disinfection won't kill as fast as E.Coli (0157) bacteria for example. But they will kill given enough time and even the slightest lack of extreme vigilance in water treatment. Whether human error as occurred on Wednesday or mechanical failures; water treatment is dangerous to our health. Today's Record article is titled "Pump station explosion inquiry in "early stages".

HAS NDMA BEEN PRODUCED FOR YEARS AT THE WEST MONTROSE WATER TREATMENT PLANT ?

There are numerous scholarly research papers published linking NDMA production with public water treatment using chloramines. Indeed this is the reason there is a formal drinking water standard of 3 mg/litre (parts per million) of chloramine in treated drinking water. The chloramine helps kill bacteria from the treatment plant to the taps in our homes but above 3 mg/l it is dangerous. Chlorine actually kills most of the bacteria from the wells (raw water) and into the treatment plant. Ammonia via ammonium sulphate is added to the chlorine present to produce chloramine which lasts longer in the distribution system than chlorine. Chloramine also produces fewer Trihalomethanes (THMs) than chlorine which is a good thing. Unfortunately chloramine produces other toxic by-products of disinfection including NDMA. Agencies with on-line research articles on this subject include the U.S. Environmental Protection Agency (EPA), the National Health Service (U.K.), Wikipedia, and the World Health Organization.

I distributed the article from the World Health Organization via e-mail yesterday to Woolwich Township, two Councillors (B.Bryant & M. Bauman), CPAC, SWAT, three local newspapers and one West Montrose resident. I also left a phone message with two other West Montrose residents. This article indicates that NDMA concentrations have been found in drinking water distribution systems using chloramine; far in excess of any levels measured at the treatment plant itself. To date the Region of Waterloo have not shared any of their NDMA test results for West Montrose with the residents or the public via their Annual Drinking Water Reports. The WHO article also indicates that NDMA is both carcinogenic and genotoxic.

The information I received Wednesday afternoon claims that currently the West Montrose treatment plant is shut down while being converted from chlorine/chloramine treatment to Ultraviolet irradiation. My understanding is that UV does not produce THMs or NDMA therefore this certainly appears as a step in the right direction. The obvious question however is why scrap the current system for a temporary fix of a couple of years? The Region are in the process of deciding on a totally new source of water for West Montrose. Based upon long standing bacterial contamination of the raw water, this decision is overdue by at least ten or fifteen years. Temporarily replacing the current system with a totally different disinfection system speaks to the Region's belated acknowledgment that THMs and possibly NDMA among other toxic by-products, are a serious health issue.

THE REGION OF WATERLOO'S DECEPTION IS COSTING LIVES

Can that above title be proven beyond a reasonable doubt in our court system? I would say yes given two conditions and those are unlimited funding and a scrupulously honest judge. The second condition is more likely than the first. The first I would indeed suggest is impossible.

Yesterday afternoon I had my information sharing sitdown with Woolwich Township. I will admit that I had doubts that the meeting would be valuable especially since the Engineering & Planning Director had reported back to Council at the public Council meeting the evening before. His information was based upon alleged facts given to him by the Region of Waterloo. In attendance were Councillors Mark Bauman and Bonnie Bryant as well as Mr. Kennalley the E & P Director. Both Councillors (especially Mark B.) have been on the receiving end of criticism from me here in the Advocate over the last few years, therefore they knew going in that short of personal exchanges/confidences; everything else was up for public distribution. Both Councillors were informed, serious, concerned and apparently eager for more technical information about the West Montrose water system and associated problems. Neither they nor I were disappointed.

While we focused on West Montrose, other Woolwich Township water problems were at least briefly mentioned. These included the Trichloroethylene contaminated water from the William St. Wellfield in Waterloo coming up to Elmira, chloramines in Maryhill's water, and the longtime presence of petroleum hydrocarbon contamination in the natural environment in Heidelberg. Regarding West Montrose I was able to show the Councillors and Director some of the inconsistencies in regional reporting of Adverse Incidents. For example one incident of a high Turbidity (cloudy, discoloured water etc.) reading caused a Boil Water Advisory in West Montrose yet subsequent worse readings over the years weren't even reported as Adverse Incidents. Similarily the language in the Annual Reports is deceptive and not remotely clear or transparent. Even the reporting of Adverse Incidents which specifically refers to contraventions of the Safe Drinking Water Act are not so stipulated. The lack of any drinking water standards means these Reports are not stand alone reports as so much vital information is missing. I pointed out that the E.Coli and total Coliform detections in the raw water are in a class all their own and this is a very bad thing. Also exceedances of the Safe Drinking Water Act by chloramines are minimized by the Region not saying exceedances, not giving the exact numerical value and not telling us what the standard is. I believe all three Township officials left this meeting with a much improved understanding of how we all have been kept in the dark by the Region of Waterloo.

Information from Tuesday's council meeting was shared with me as I was attending a meeting of the Woolwich Bio-En Citizens Liason Committee at the same time as Council was in session. It is stunning. I was well aware that water tankers replenish the water reservoir on Tallwood Dr. in West Montrose. The public were advised Tuesday evening by Mr. Kennalley that the entire West Montrose well system has been shut down entirely for the last month and that water tankers are currently the sole source of water for the community. Nowhere in the Region's Annual Reports for the last ten years does it ever mention the necessity for diluting, supplementing or entirely replacing West Montorse's water supply. These tankers have augmented/diluted the water supply at the rate of four tankers per day during the warmer summer months and two tankers per day during the rest of the year. Further we were advised that while a brand new source of water is two to three years away (from K-W) via a pipeline; the current water treatment system using chlorine and chloramine is being scrapped. In fact a whole new system using Ultraviolet radiation is currently under construction thus necessitating the shutdown. Finally after more than a decade of being in charge of a water system with badly contaminated source water, the Region have gotten serious. Of course the new disinfection system still will be dealing with badly contaminted raw water and of course the Region of Waterloo would rather cut off their own arms than admit to serious and potentially deadly health issues over the years in West Montrose.

In my opinion the lying and deception are of a criminal magnitude. Year in and year out the Region of Waterloo have publicly and repeatedly advised the residents of West Montrose that their water was safe, secure and healthy. All three are blatant lies. Whether via the risk of bacterial contamination or the ongoing exceedances of health standards by the by-products of disinfection; West Montrose residents have been put in harms way by regional officials untruthfulness. West Montrose is not the only community in the Region of Waterloo who have sufferred due to contaminated water but it is decades overdue for all our authorities to tell us the uncomfortable and personally inconvenient truth.

LAST EVENINGS WOOLWICH BIO-EN CITIZENS LIASON COMMITTEE MEETING

Last evenings meeting at the Rec Centre in Elmira had a few more bodies in the visitors chairs than usual. By the way the next meeting is scheduled for 7 pm. Tuesday May 6, 2014 at the public library. The previous meeting in early March had raised some concerns which caused CLC member Michael Purves Smith to bring a page of questions to this meeting. They dealt with Water, Biological feedstock materials, methane gas for vehicle use, possible expansion of the facility and potential increases to truck traffic.

The first question received a simple no there would be no increase in municipal water use occasioned by the requested amendments to the Renewable Energy Act (REA).

In regards to biological feedstock sources both Earl Brubacher and Chuck Martin emphatically stated there would be no human or medical wastes involved at the facility. The requests for mushroom wastes etc. is needed because the M.O.E. require upfront specific feedstocks in writing. Generalized food wastes isn't adequate for them. ICI or industrial, commercial and institutional wastes are simply cafeteria food wastes etc..

The proposed use of methane gas as a fuel for trucks will not require any changes to their infrastructure. Impurities will need to be removed from the methane such as CO2, hydrogen sulfide, ammonia and particulates. This is a demonstration project that was brought to Woolwich Bio-En by the Bio-Gas Association. It is a pilot project and is also a form of public relations for the Association. There is an existing pipeline in town which can be accessed near the Woolwich Bio-En plant and the gas can be removed at the south end of town at the proposed retail outlet.

Chuck Martin suggested that if and when Bio-En required more gas production they would probably build a second plant. Meanwhile that is highly unlikely because currently the Ontario government are not offerring any power from gas contracts whatsoever . There was a long discussion on truck traffic which included Bob Jonkman, Michael Purves Smith, Vivienne Delaney and numerous CLC members. Gerry Heiduburt contributed to this and other discussions around technical process matters. Michael's understanding was that 80 total truck movements per day was the agreement. Chuck explained that under ordinary production they would be having substantially less than that but would be pushing up against the 80 maximum if and when they had a problem and were forced to empty their system out. In fact Chuck feels that Michael's estimate of normal use of fifteen trucks in and fifteen out per day is high. Chuck believes that when all is working properly and there are no breakdowns or serious production issues they can get away with perhaps only seven trucks in and out per day for a total of fourteen or fifteen truck moveents. Incoming trucks and associated odours were also discussed. It appears that plant odour suppression systems are "robust". All parties agreed that incoming trucks must be closed or covered and if the covering is only a tarp; regular odours will not be tolerated including by Woolwich Bio-En.

In regards to paper sludge from paper mills I raised a question about chlorine being mixed in. I was assurred that all incoming feedstocks require testing prior to delivery. In fact salt (NaCl) or chlorine would be harmful to the bacteria in the Digester and won't be accepted. Apparently sources are tested annually or every 1000 tonnes whichever comes first.

The engines have been tested on natural gas and they will be tested using the methane gas produced, in about six weeks. We were advised that while there is no minimum power production demanded by the Ontario power Authority nevertheless all electric power produced must be sold to them. Overall the entire bureaucratic process has been onerous and in hindsight Chuck was skeptical if he would have gone ahead eight years ago if he knew the extent of red tape necessary.

PARTNERS IN POLLUTION'S CREDIBILITY TAKES A HIT (CRA, Chemtura, M.O.E.)

Since last Thursday evening's public CPAC meeting two documents have miraculously been produced from Woolwich Township's archives. The first is the CPAC Minutes of April 24, 2006 and had been properly distributed eight years ago. The second is a May 2, 2008 letter from Jaimie Connolly (Ministry hydrogeologist). It was not properly distributed to all the longterm stakeholders including myself. Funny thing is Woolwich Council had just given me the boot from CPAC a couple of months earlier and CPAC Chair Pat McLean was in charge of distribution. What she lacked in technical knowledge and ability she made up for with political shrewdness.

Jaimie Connolly's letter will haunt Chemtura/CRA for many years. Their refusal to produce it upon request from me at public CPAC meetings is also relative to their ongoing verification plans with the Chemical Industry Association of Canada. Refusing to produce documents that you are relying on to make a hydrogeological point because it hurts your position on other points is not the *Responsible Care way. Ethics and transparency are not to be doled out just to your supporters but to all stakeholders.

Jaimie's letter speaks to the varying thickness (viscosity) of DNAPL chemicals. These Dense Non-Aqueous Phase Liquids gravity flow downhill with no regard for either groundwater flow direction nor for nearby pumping wells (hydraulic containment). Some of Uniroyal/Chemtura's DNAPL has been thin and very mobile and most of it has long ago flowed to low points on top of aquitards or low permeability zones. The thicker DNAPL sometimes described as motor oil consistency or even as tars will move much more slowly. Keep in mind the thusly described DNAPL at TPW2 in 1993 wasn't all removed and yet was no where to be found during the drum removal excavations from there a couple of years ago. It clearly moved! Therefore the M.O.E.'s longtime excuses that they can't order on-site cleanup due to containment is clearly specious. Not only is groundwater moving off site by design in the north-west Municipal Upper Aquifer under the Optimization plan but it is also leaking from the shallow aquifer into the Canagagigue Creek in areas where there are no pumping wells. The Municipal Lower and Bedrock aquifers are also not contained on site. Finally as stated earlier DNAPLS have and will continue to gravity flow off the Chemtura site whether Jaimie agrees in 2006, disagrees in 2008 or comes around again at a later date.

Of course for me Jaimie's biggest revelation is on the second last page of his May 2, 2008 letter. This is why the partners in pollution wouldn't release Jaimies's letter. All's fair in love and war and for years they had a friend as Chair of CPAC. The benefits to both parties were significant. They knew that if I had had that letter I would have trumpeted Jaimie's revelations years ago. Jaimie unequivocally makes it clear exactly as the young CPAC did in 2012 that hydraulic containment on its' own is inadequate to clean up the off-site aquifers. Source removal or reductions in source concentrations are vital!

The April 24, 2006 CPAC Minutes have a detailed discussion of DNAPL issues and proposed source removal. I also discussed In-Situ Chemical Oxidation (ISCO) in those Minutes relative to trichloroethylene removal from the Bishop St. community in Cambridge. Chemtura/CRA/M.O.E. were asked by me eight years ago whether ISCO could be used in Elmira. This is not by far the first time citizens have proposed solutions that were disparaged by the experts (CRA/Chemtura/M.O.E.) only to be embraced years later. Again on page two the Ministry of the Environment and Jaimie proclaim their support for source removal/remediation versus relying solely on hydraulic containment (ie. pump & treat). Therefore source removal has been requested/demanded in July 2003 by CPAC, 2006 by Jaimie C. & the M.O.E., 2008 again by Jaimie C. and finally in 2012 by the CPAC Resolution. Twenty-four years to date of screwing around folks. Less talk and more action! Chemtura shit or get off the pot! Either clean up properly or get the hell gone so somebody else can clean up your mess!