FIRST NATIONS APPEAL GOES TO THE SUPREME COURT OF CANADA

Line 9 may be up and running with its' flow reversed and capacity increased but the fight isn't over yet. The Chippewas of the Thames First Nation are pitted against Enbridge, the National Energy Board and the attorney general of Canada. The issue is one of genuine consultation or rather token consultation as is the form favoured by most politicians on all issues but especially environmental ones. The Chippewa's believe that there are potential effects of the pipeline on their aboriginal and treaty rights and that the Crown failed to properly consult and accomodate their legitimate concerns.

The Waterloo Region Record carried this story on March 11/16 titled "Court agrees to hear appeal over Line 9". The appeal follows a loss at the Federal Court of Appeal last October. Enbridge unsurprisingly claim that they have consulted respectfully and will continue to do so regardless of the Supreme Court outcome.

SEWAGE SLUDGE DISPOSAL ON FOOD PRODUCTION LAND

On March 1 of this year a group of scientists published an open letter in the Waterloo Region Record. The title of the article /letter was "Scientists' open letter on the dangers of biosolids". This practice is commonplace in Waterloo Region and elsewhere.

There basic premise is that the supposed benefits (free fertilizer) are more than offset by the risks to human and environmental health. Only a tiny number of possible contaminants are tested for and when you realize that all current and legacy industrial chemicals enter our sewage treatment plants and end up in sewage sludge, it is not a pretty picture. Rebranding sewage sludge as biosoilds may make their land application more palatable to the public but does nothing to enhance safety.

The authors describe various classes (hundreds) of flame retardants, P.C.B.s and Dioxins (hundreds of each) that are not fully tested for nor could they practically be so tested. It is the same thing with prescription pharmaceuticals. While someone is so prescribed, everyone gets to enjoy them eventually via food production. Biological contaminants include bacteria, viruses and prions.

These scientists' short term solution is stockpiling or landfilling of sewage sludge in secure locations with leachate collection systems until a better means through science is discovered. They believe that science can discover better treatment options and better learn the risks involved in handling sewage wastes.

Their final summation is "Governments are playing Russian roulette with sewage sludge. Over time, there is a high probability this game will be lost at the public's expense.".

ABUSE OF THE RISK ASSESSMENT PROCESS

Abuse of each and every process, safeguard and system evolved ostensibly to aid human beings in their battle with pollution is the hallmark of the truly dedicated sociopathic polluter. Risk Assessment seems to be a local favourite here in Woolwich Township and Elmira. Right now we have a different M.O.E. idiot attending what for years was known as UPAC or CPAC (ie. Uniroyal/Chemtura Public Advisory Committee). She was publicly musing last week whether or not a Risk Assessment of the downstream Canagagigue Creek was a good idea. I would suggest that the environment would be better served via decision making determined by tea leaves or a Ouija Board. At least there would be less inherent bias in that process.

Over a decade ago Chemtura did a Human Health Risk Assessment (HHRA) and an Ecological Risk Assessment (ERA) on their Elmira site. The final result was that their site is risky for omnivorous shrews tunneling in their soil as well as to trespassers walking on their site. Really? No biomagnification results for predators of shrews such as hawks, foxes or raccoons. No adverse affects for workers on the site 40 hours per week or more. Just for us naughty environmental trespassers. Pardon me if I think their SSRA was a crock of crap.

Dr. Henry Regier (Biology) was one of the best informed, professional skeptics after he did additional research into the SSRA. This included extra discussions and communications with M.O.E. staff who were supposedly overseeing/monitoring Chemtura's SSRA. It turns out that the M.O.E. staff involved were out of their depth and missed important aspects of the SSRA process. It is afterall a complicated process in order to dissuade us laypersons from becoming too critical.

The net result is that the downstream Canagagigue Creek is contaminated with DDT and Dioxins/Furans in excess of provincial and federal standards. This will cost Chemtura big bucks to clean up. It is much cheaper for them to razzledazzle the public with highly credentialed and willing to help (for big $$$$) professionals who love to speak publicly about themselves, their accomplishments, their credentials, their hairdo (?) and how poisons are all about the dose because gosh darn even cancer drugs themselves are carcinogenic didn't you know.

This is not serving either the public or the environment. It is serving the bottom line of the corporation (Chemtura) and the tattered and frayed credibility of the M.O.E. in that they can claim they really haven't failed us yet again by ignoring both the farm on Chemtura's east side and the downstream Canagagigue Creek.

BRASS & NERVE WITHOUT SHAME OR ETHICS

Sociopaths. I'm looking for words to describe the behaviour of the partners in pollution. Voulnteer citizens on CPAC (formerly CPAC & SWAT) have been leading the direction of the cleanup in Elmira for the last five years. From an acknowledgement that the 2028 cleanup was impossible in 2012 to increased pumping and off-site source removal and now to the admission by the Ontario Ministry of Environment that indeed Uniroyal/Chemtura's contamination has flowed eastwards onto the neighbour's property; CPAC (Citizens Public Advisory Committee) have led the way. Chemtura and the M.O.E. have been dragged kicking and screaming oh so slowly over the last thirty years in the direction of environmental responsibility. They have a very long ways to go.

TAG under the leadership of Dr. Dick Jackson are trying and working hard. RAC are the same bunch of bureaucratic hangers on and cheerleaders of the status quo that they've always been. Any honest members will not rock the boat by admonishing or upbraiding the Ontario M.O.E..

Chemtura are again seeking the *Responsible Care designation. Last time around Dr. Dan Holt appropriately voted against and Pat Mclean dishonestly voted in favour. Oh what a surprise when Chemtura are responsible for Pat's jetsetting around North America with all expenses paid by them. Mayor Shantz denies that this is a conflict of interest. She also claims that the sun rises in the west.

The second BLE spill occurred just before Christmas. Talk about cheap half measures ruling on that site. A containment pan was installed to catch leaks or ruptures. However as the BLE was hot and under pressure its' contents sprayed and got to the creek. This was because the unit is OUTDOORS. That was revealed Tursday afternoon at the RAC meeting. No wonder they had yet another albeit smaller spill.

One of TAG's recommendations regarding reinjecting treated groundwater into the aquifer versus discharge into the creek has been agreed to in principle by the M.O.E.. This means nothing however as they have no principles. Similarily I believe that I heard a promise from Ms. Buhlman that suspended sediment levels will be measured.

Since Thursday's RAC meeting I have heard the word "shill" used in regards to one of the presenters. I find that word harsh and insulting but otherwise can find no fault with it.

After Terri Buhlman's pandering to Chemtura by minimizing the ongoing damage in the Canagagigue Creek, Dr. Jackson made an amazing statement. He stated that the concentrations of Dioxins in our creek are substantially higher than those in Jackfish Bay one of the fourty-three Areas of Concern being remediated through the IJC (International Joint Commission). Jackfish Bay is in Canada on Lake Superior.

Regarding the East Side Investigation report the M.O.E. stated that greater delineation of soil and groundwater must occur hence more work is required. Dick Jackson stated that Chemtura will be invited back to the next TAG meeting in order to discuss these further steps on the east side property (Stroh). Dr. Jackson also stated that he wants investigation of the DRAINAGE EFFECT OF THE STROH DRAIN all the way up to RPE5. Keep in mind Dr. Jackson refers to it as an agricultural drain whereas as I was the first member of the public to discover it, I named it the Stroh drain. The issue of the 175 metres of unsampled Chemtura property line directly beside the Stroh Drain is also to be discussed at the next TAG meeting.

We have one last acceptance of a TAG Recommendation. Helder Botelho of Chemtura has agreed to consult with experts at the University of Waterloo regarding In Situ Chemical Oxidation (ISCO). While this certainly verifies TAG's knowledge and expertise on the matter it means exactly nothing if Chemtura choose to consult and then ignore good advice.

ONTARIO MOECC SHOW THEIR CONTEMPT FOR CITIZENS AGAIN

Last evening's RAC (Remediation Advisory Committee) was a pathetic joke. Chemtura and the Ministry of Environment contemptuously wasted everybodys time and essentially served notice that they have the money and the will to continue doing so either forever or until they are stopped. Councillors Mark Bauman and Sandy Shantz allowed and enabled last night's disgrace. The first indication of trouble was the Chair (Shantz) allowing Dr. Ronald Brecher to go on and on and on. Ostensibly he was delivering a lecture on risk assessment. In actuality it was a back patting, self-serving, ego enhancement load of drivel. In thirty years of CPAC meetings plus recent TAG and RAC meetings, last nite set a new low. Councillor Bauman showed up fifty minutes late and saved himself that much sitting. He did however miss a good presentation from Dwight Boyd of the GRCA regarding flood issues in the Canagagigue Creek.

Dr. Brecher was hired by Chemtura. If mayor Shantz had bothered to attend a single CPAC meeting between 2010 and 2014 prior to being elected mayor she would have known that Chemtura were shut down from monopolizing CPAC meetigs years ago. Their consultants (CRA) used to pull the crap that Dr. Brecher did last night. Essentially it's nothing more than a filibuster.

Following Dr. Brecher we were treated to more longwinded bullshit from Terri Buhlman of the M.O.E.. How dare she treat Elmira citizens the way she did last evening. It was arrogant, uninformed crap in conflict with both the facts and the comments of Dr. Richard (Dick) Jackson, the Chair of TAG. Ms. Buhlman advised the meeting that the Canagagigue Creek has high concentrations of contaminants in sediments in localized areas. She then went on to state that there is no acute toxicity in the creek as per the 2014 M.O.E. data. Dick Jackson on the other hand chacterized the contamination as very serious regarding Dioxins & DDT and stated that we don't know how spatially extensive it is.

Dr. Jackson had very little opportunity to say much last evening. He did advise RAC as to TAG's Recommendations regarding RAC's position and followup with both Chemtura and the M.O.E.. I suspect that last night's RAC meeting was an eyeopener for Dr. Jackson. As much as it pains me to say so I will add the following. TAG did a good job last evening. Pat McLean appropriately took both the M.O.E. and Chemtura to task for their last minute delivery of documents to TAG and RAC. This is the same stunt that mayor Shantz pulled last July at the MECAC meeting. Also Susan Bryant put GHD (Chemtura's consultants) on the hot seat over their failure to sample a 175 metre long stretch along the eastern property line directly beside the Stroh Drain.

Last night was Chemtura and the M.O.E. deflating expectations of further serious cleanup. The M.O.E. especially want a years long further process prior to actually doing anything in the creek downstream of Chemtura. They are simply stalling. There has been an acknowledgement that more needs to be done on the Stroh farm due to off-site flow from Chemtura. That too will be the ultimate minimum in cleanup with the maximum in "studies" and talk. Nothing has changed and full credit goes to Mark Bauman and Sandy Shantz. If they aren't already on Chemtura's payroll then they are fools. They are assisting the company to avoid hundreds of millions of dollars of cleanup costs.

WOOLWICH TOWNSHIP WELLS

I covered the disgrace of bacteria contaminated raw water in West Montrose already so today we'll look at the rest of the rural Woolwich Township Well Systems. The Conestoga Golf Course Supply consists of two wells C5 and C6 located near the Grand River. Apparently one of them has a minor hydraulic connection to the river yet bacteria and Turbidity seem very good. Chlorine levels and Sodium are very good as well. Other than my standard complaints with what these Annual Reports don't provide the lack of up to date test results is my only other complaint. Test results for chemicals are two years old which I find unacceptable.

The Conestoga Plains Water System consists of wells C3 and C4. Odd but I wonder where C1 and C2 went. Could this explain also the very good results for raw water bacteria, Turbidity and Chlorine levels? Many years back I read that they had bacteria problems which certainly made sense when you realize how close their residential septic systems were to their wells. I wonder if the Region drilled new deeper wells or moved them further away? Regardless except for their 2013 test results all looks good. In fact it looks so good I have to wonder why the Region's original plan of a pipeline from Conestoga to West Montrose using Conestoga's water supply was replaced with a further pipeline over to St. Jacobs and tapping into the Integrated Urban Supply (IUS).

The Maryhill Village Heights Water Supply consists of wells MH3 and MH4A. Bacteria results are fine in the raw water although Turbidity is high. Everything else is good with the exception of once again 2013 test results for chemicals in the treated water.

The Maryhill Water Supply System consists of wells MH1 and MH2. Turbidity of the raw water here is also high albeit bacteria levels and everything else appear fine with two exceptions. The test reults are all from 2013 and Chloramines are a problem. Chloramines are formed from ammonium sulphate being added during treatment which is supposed to make a more stable disinfectant in the distribution system as well as help keep Trihalomethanes (THMs) at lower levels. THMs are also a by-product of disinfection. Notably the Region have not been reporting THM levels in the Maryhill Systems as well as many others. Both THMs and Chloramines are health issues in their own right. Mixed together is anybody's guess.

The Heidelburg Water Supply System is a bit of a geographical/political conundrum. It also supplies water to St. Clements which is in Wellesley Township. The system consists of wells HD1 and HD2 with HD1 offline for 28 weeks during 2015. Everything looks good including THMs at 19.8 ppb. (100 is the standard) except for the 2013 test results. They are especially disconcerting when one realizes that there has been a former gas station under remediation for decades. I do not know how these two wells have not drawn gasoline hydrocarbons into themselves over that time period.

MORE KITCHENER WELLS & PROBLEMS

The Strange St. Well System is the oldest wellfield in Kitchener. It consists of wells K10A, K11A, K13, K18 and K19 sort of. At one time there were also wells K12 and K17 but they are long gone. I posted about them and the list of industrial solvents in them back on June 25, 2010. Wells K13, K18 and K19 were offline for all of 2015. We were advised of some minor construction and upgrades and are left to assume that that may be why these three wells were shut done all year. When one goes back to the 2014 Annual Report these same three wells were shut down again for the whole year although apparently with more serious construction. Other than high Sodium readings (71.5 mg/l) and a few high Chloramine readings albeit below the maximun allowed, these wells or at least K10A and K11A seem reasonably O.K..

The Woolner Wellfield consists of three river infiltration wells known as K80, K81 and K82. They are located downstream from the long closed Forwell and Pompeii Systems, also river infiltration wells beside the Grand River downgradient from Safety-Kleen in Breslau. The Woolner wellfield has had problems with odours and algae possibly influenced by phenols in the river from most likely the Safety-Kleen site. These three wells, K80-K82 were closed down all of 2015. What the 2015 Annual Report doesn't tell us is that they've been closed for the last five years. What it also doesn't tell us is that either river water directly or groundwater from river infiltration wells are inherently more expensive and difficult to treat for human consumption.

The Mannheim Water Treatment Plant receives raw water from the Grand River, treats it and mixes it with groundwater from at least seven wells namely K91, K92, K93, K94, K21, K25 and K29. The Mannheim Village wells and Shingletown Wells can also indirectly supply the Mannheim Pumping Station Reservoir. I had earlier suggested that the Middleton Wellfield in Cambridge was the most expensive water in the Region of Waterloo. Well in 2014 Mannheim cost taxpayers close to $4 million in maintenance, parts and upgrades. 2015 was less "reasonable" at just shy of $9 million. Holy God is this system producing magic water that is the fountain of youth or what?

The what I have to suspect is the bacteria levels in the river. In 2014 raw river water samples had maximum Total Coliform levels of 370,000 with E.Coli maximum counts at 5,800. In 2015 the raw water had a lower maximum Total Coliform count of 75,000 but E.Coli hit a count of 5,900. I don't know how the Grand River compares with other surface water bodies but I do know how it compares with groundwater and that can only be described as terribly bad. The treatment of this water is out of this world. Indeed the treated water results are good in regards to chemicals and bacteria but at what a cost. This cost is not only dollars but in by-products of the massive disinfection of the water. Both chloramines and Trihalomethanes are in the treated water in our taps. Perhaps groundwater is used to improve the taste of the treated river water. Keep in mind the THMs and chloramines are legal but I don't believe that that means they are healthy.