THE HEALTH & SAFETY TRAGEDY OF CORPORATE & GOVERNMENT INDIFFERENCE

I believe it is the third in the series about rubber workers that is in today's Waterloo Region Record. To say that the series by Record reporter Greg Mercer is an expose of our corrupt Workers Safety & Insurance Board (WSIB) is an understatement. To say that it is an indictment of former Conservative Cabinet Minister Liz Witmer is an understatement. When Liz Witmer was allegedly representing Waterloo Region and area in the legislature she did less than nothing to help us here in Elmira during and after the Elmira Water Crisis which is still going on. The only reason it's no longer considered a "crisis" is due to slick crisis management and public relations efforts by Uniroyal and successors as well as by local, regional and provincial governments over the last three decades.

The other elephant in the room among many regarding the coverup and minimizing of health and environmental damage here in Elmira is the health of Uniroyal workers over the decades. Many of the chemical exposures here at the Uniroyal plant are common solvents such as benzene and toluene which rubber workers were exposed to in the Kitchener rubber plants. In fact there would have likely been far more and different airborne chemical exposures here in Elmira than in Kitchener tire plants.

I recall Esther Thur compiling a list of Uniroyal employees who had died prematurely over the decades. That list may be with her records at the Wilfred Laurier University Archives unless it has been expunged. I also recall her telling me incidents of employees, including her husband, at the neighbouring Elmira Furniture Co. later Roxton, becoming sick from fumes leaving Uniroyal and entering their building on Union St. through open windows in the summer months. I also recall during the height of the air fumigations in Elmira between 1998 and 2001, CPAC being advised by Murray Haight that Uniroyal/Crompton employees were leaving windows open at the plant in order for them to get fresh air while they were working. This of course while helping the most immediately exposed inside the factory did little to alleviate the odours and exposures for the rest of Elmira.

All in all the health of employees of this company has never been made public. Based upon the litany of highly toxic compounds that this company has handled and mishandled over the decades including NDMA, Diacetyl, Benzene, Parathion, dioxins, Endrin, Silvex, DDT and so many more it is difficult to believe that Uniroyal now Lanxess employees and their families haven't paid a very high price.

MEDIA SCHIZOPHRENIA

The Woolwich Observer's Steve Kannon wrote an Opinion piece back on May 14, 2011 in which he stated the facts as he knows them regarding past CPACs as well as my dismissal from the most recent one by Todd Cowan, an a..hat extraordinaire who I must say was publicly humilated four years later possibly even slightly more than he deserved, all things considered.

Steve Kannon couldn't quite make up his mind about me and my dismissal as he praised me to the skies while at the very same time throwing in a few unappreciated (by me) cheap shots. Steve stated "...his enthusiasm for the cause leaves him no time for the niceties." Further "He speaks his mind leaving many people uncomfortable. It's a useful role calling a spade a spade as he notes elsewhere in the paper this week." "Furthermore that's not to say that there's no place for some s..t-disturbing, CPAC like Woolwich Council itself, can be too civil, too eager to be agreeable, to quick to defer to experts." "The truth he says should trump other considerations."

Well I certainly appreciate the kudos but somehow the criticisms that I'm too driven or too focused or too hardnosed just don't line up with the other nice and complimentary things that Steve said. Citizens have an absolute right to express their views on public interest matters and as the K-W Record was quoted here not too long ago municipal councils must expect and accept criticism from the public whether it is gentle, diplomatic or blunt and hardnosed. Steve you are trying to suck and blow simultaneously. My behaviour has always been a red herring simply because verbally I do not stand down for professional, credentialed liars, technical experts or QPs (Qualified Persons) who think they have the absolute right to lie to the public on health, safety and environmental matters. They do not.

RAC MEETING NEXT THURSDAY

The December RAC meeting is being held at 3 pm. in Council Chambers next Thursday, December 13, 2018. On the Agenda are 4.1 presentation of work plan for the Supplemental East Side Offsite Groundwater Investigation 4.2 Status Update on the Containment and Treatment System (Presumably both the on and off site CTS) 4.3 Status Update on the Creek Risk Assessment process 4.4 Tag Recommendations to RAC.

The Minutes were received from the September 27/18 RAC meeting and I am very pleased with a couple of inclusions namely the TAG Motion and Reccommendation that was presented to RAC by TAG Chair Tiffany Svensson. The Motion categorically made it clear that the "Gap" and Stroh Drain have as yet not been properly sampled, tested and investigated. The MOE claim that they want the Stroh Drain evaluated as part of the risk assessment process within the Creek investigation. If the MOE had a history of living up to their words I'd be less concerned. Unfortunately they do not have such a history.

The second inclusion on page 3 is the meeting after the formal meeting that Dr. Sebastian Seibel-Achenbach and I had with Ramin, Lou, Dwighte of Lanxess and GHD. TAG Chair Tiffany and others were also present. While the words "Interceptor Trench" did not get included in the Minutes nevertheless the fact that the ad hoc meeting was acknowledged is good and that there will be a followup meeting during the first quarter of 2019.

TAG also had a Motion and Recommendation for RAC regarding the failure to date to get off-site pumping well W9 up and running. Concerns were also expressed in regards to DDT results in discharges to Shirt Factory Creek that are Non-Detect but at a Method Detection Limit higher than the Provincial Water Quality Objectives (PWQO).

TAG requested clarification on two new monitoring wells at College St. in Elmira and whether they had implications for either the Conceptual Site Model of the Elmira Aquifers as well as for peculiar chlorobenzene concentrations off-site. Ramin Ansari of Lanxess advised that they had had discussions with the property owner(s) of the former Varnicolor Chemical site. Co-sampling was done although they still need to evaluate the data. This is strange as this sampling is now many months old. Also Ramin indicated that an isotope analysis of the water took place in order to determine if there is a second source other than Uniroyal Chemical as well as the age of the source. Very interesting!

TAG and the few public present were advised that Lanxess had hired Stantec, ERM and Geosyntec to assist GHD with the Risk Assessment planned for the Canagagigue Creek.

Lastly The Tag Chair (Tiffany) appreciates that TAG will be allowed to have technical experts attend TAG meetings in order to move forward more effectively. I presume that she is referring to technical experts that the company (Lanxess) have hired as earlier stated unless she is suggesting that TAG may hire their own.

2017 ANNUAL MONITORING REPORT

Quite a while back I posted here in regards to the MOE's (MECP) comments & criticisms of this annual report done by CRA/GHD on behalf of Chemtura/Lanxess. The MOE's comments were described as the most critical, comprehensive and blunt in many years which I both agree with and enjoyed immensely. I think that I even had some good words to say on behalf of the MOE hydrogeologist, Abdul Qyuum (sp.?) who wrote the MOE comments.

Last Thursday November 29/18, GHD responded to the MOE's comments. I was actually sent their responses in a very timely manner for a pleasant change. At some point I expect that the artificial exclusion and stifling of stakeholders both by private meetings and late or never correspondence, other than friends of Chemtura/Lanxess and mayor Sandy Shantz (ie. TAG), may actually bite the guilty parties including the MOE right in the as you will.

The MOE state that the Environmental Compliance Approval (ECA) which replaced the former Certificates of Approval (C of A) absolutely insists upon continuous water level monitoring of both selected shallow aquifer monitoring wells as well as of the surface water of the Canagagigue Creek. The purpose is to always be able to prove or disprove whether or not the contaminated groundwater is hydraulically contained (via lower water elevations) and not discharging into the Creek. GHD agree with that however admit that four of the six surface water elevation stations do not have continuous monitoring data. Wow, that is bad and a blatant contravention.

The MOE specifically point out an area of the Upper Aquifer Containment & Treatment System (UACTS) that at the minimum sufferred a temporary loss of containment, hence discharged contaminated groundwater into the Creek. GHD to their credit seem not to be denying the obvious nor minimizing the seriousness of the situation to the extreme ends that their predecessors CRA did.

The MOE suggested that hydraulic containment of the Municipal Upper Aquifer (MU) on Lanxess's west side was in doubt due to consistent concentrations of NDMA just off Lanxess's western border with Nutrite (Yara). GHD responded that they disagreed and that the source of the dissolved chlorobenzene was not migrating groundwater from Lanxess but is "continuous back diffusion of chlorobenzene and NDMA from fine-grained aquitard soils adjacent to the MU." Hunh that reason actually seems plausible to me.

On page 8 GHD to their credit actually admit that the Municipal Lower Aquifer (ML) is not contained on the Lanxess site. Previous CRA and Uniroyal/Chemtura spokespersons would tie themselves up in knots before they would ever admit that obvious fact. GHD do however suggest that this lack of containment is not critical because allegedly the concentrations of contaminants on site do not exceed the Ontario Drinking Water Standards (ODWS). Of that I am skeptical.

The MOE appropriately are not pleased with GHD using groundwater concentration data from different sampling dates and then using them all together to plot concentration graphs for on-site NDMA. These dtaes include 2017, 2006, 1999 and 1993. I agree that that is bizarre and GHD's responses are weak.

The MOE suggest that the very high concentrations of of NDMA in on-site, east side well OW42-4 need to be investigated. GHD disgarees suggesting again weakly that these high results are isolated in the immediate area. To my mind all the more reason to get the source out of the ground if it is both shallow and isolated.

On page 12 the MOE are again suggesting that there is a lack of hydraulic containment this time on the west and perhaps south border of Lanxess at monitoring wells OW105d and OW16i. GHD denied this and I must admit that their arguments have some merit.

The MOE are again suggesting that there are other sources of chlorobenzene to the off-site drinking water aquifers in Elmira. This is huge and is not being disputed by GHD. They also point out that they have done an isotopic analysis in August 2018 trying to determine if the chlorobenzene is from different sources. To date we the public have not been advised of the results of this analysis.

There is a discussion as to where the highest concentrations of NDMA are located in the MU aquifer. They are 1) beneath the former south-west operating ponds (RPWs) 2) off-site in the north-west (OW60-26) and 3) south of Lanxess at pumping well W3R located between Sanyo and the former McKee Harvestor plant.

The MOE still appropriately have free phase DNAPL concerns on the Lanxess site. Now if only they'd do something about those concerns.
GHD's responses are disappointing as they, just like CRA, go through the old chestnut about free phase DNAPL being indicated if the groundwater concentrations of DNAPL chemicals exceed 1% of the compound's aqueous solubility. That is fine if the DNAPL compound is the sole contaminant in the groundwater unlike the dozens to hundreds of different contaminants in Elmira's groundwater. 1% of the EFFECTIVE Solubility of the DNAPL compound should be the benchmark not 1% of the solubility in pure, uncontaminated water.

Overall GHD and the MOE get good marks for paying closer attention to last years (2017) AMR than usual. Nevertheless there are still major issues being talked about rather than actually being physically resolved.

LACK OF MEDIA REPORTING OF THE GLWQA

The 2012 Great Lakes Water Quality Agreement (GLWQA) was signed by Canada and the United States in order to both restore and protect the five shared Great Lakes in North America, namely Superior, Huron, Michigan, Erie and Ontario. This protection and restoration includes shorelines, wetlands and groundwater entering the Great Lakes. Friend and colleague Dr. Henry Regier sent me an e-mail package today which includes the 2019 Progress Report of the Parties. The Great Lakes Executive Committee (GLEC) are meeting today and tomorrow in Toronto for discussions on these matters.

Both Canada and the United States have designated Areas of Concern (AOC). In Canada we have been able to delist (ie. fully remediate) three of them namely Collingwood Harbour (1994), Severn Sound (2003) and Wheatley Harbour (2010). There are fourteen more AOCs in Canada with Ontario obviously hosting them. One includes the St. Lawrence River at Cornwall which is extremely close to the province of Quebec.

So clearly the GLWQA should be of concern to all Canadians but especially to Ontarians. Where are the updates in our media whether newspapers, television or radio? Why are we not kept abreast of all developments whether good or bad regarding the cleanup and remediation of these sites around the Great Lakes? Why so far is this Toronto meeting of the GLEC not front and centre in the news cycle?

SOME GOOD NEWS O.K. WITH A DASH OF REALITY AS WELL

I am starting to get the impression that the MOE are doing some pushing of Lanxess and their good buddies GHD. The other good news is that citizens, with an enormous amount of time and effort, can affect the direction of investigations, and eventual cleanup. This is despite our local council being in bed with the polluter even to the extreme of picking and choosing public consultation members based upon the polluter (Chemtura/Lanxess) having the hammer (veto).

I received last Friday a copy of a November 6, 2018 response to the MOE (MECP) from GHD, Lanxess's consultants. GHD are proposing to install from four to eight wells depending upon finding the Municipal Upper Aquifer along the laneway that enters the Stroh farm up on Highway #86 (Elmira to Guelph highway). If they can't find the MU Aquifer then it will be only four shallow wells. They are doing this because of the MOE's insistence on a better groundwater investigation of the Stroh property just to the east of the Uniroyal/Lanxess property. Keep in mind that all of the investigations since 2015 on the east side of Chemtura/Lanxess are a direct result of the 2011-2015 CPAC and SWAT which includes yours truly. We opened the can of worms that the MOE, Uniroyal and CRA had kept carefully hidden for three decades or more.

Now for the dash of reality known as the elephant in the room. The "Gap" has NOT been delineated, examined or investigated even remotely properly and by intention. Similarly neither has the Stroh Drain. This secret, man made Drain has effectively drained both surface and groundwater from both the Stroh and Uniroyal properties for decades. Much of that drainage would have been contaminated with persistent organic pollutants (POPs) either attached to soil particles and or dissolved in solvent contaminated groundwater. The fact that solvents and NDMA have been found still at high concentrations on the east side property is both sobering and scary. How much of the Persistent Organic Pollutants such as dioxins, DDT and PCBs are still in and around the Stroh Drain we do not know until a serious search is undertaken.

CORPORATE HUMANITY - AN OXYMORON

YOU ARE JUDGED BY THE COMPANY YOU KEEP SANDY. THIS MEANS UNIROYAL/CROMPTON/CHEMTURA & NOW LANXESS (BAYER/MONSANTO)


What a litany of corporate monsters. Recently we have had the Waterloo Region Record article written by Greg Mercer and titled "Rubber Town". Today the Record published "A long fight for compensation" also by Mr. Mercer. Much of the heat is focused upon our corrupt provincial governments removing the right to sue from employees and installing an equally corrupt Workman's Compensation Board, now optimistically named the Workplace Safety and Insurance Board (WSIB). Today's article makes it clear that the WSIB takes its direction from both the provincial government and employers and has reduced employers' WSIB premiums drastically by reducing payouts to injured workers.

Bayer and Monsanto are currently in the news due to class action lawsuits and decisions that a Monsanto herbicide, Glyphosate, has caused cancer in human beings. Of course we all know about Uniroyal Chemical and the 1989 Elmira Water Crisis. Oh and of course Uniroyal, Dow, Hercules, and others are all implicated in the production of Agent Orange and its accompanying by-product dioxin. This dioxin (2,3,7,8 TCDD) has damaged and killed human beings in Vietnam and even here in Ontario due to its work as a brush remover along highways and power lines.

Getting back to local rubber producers the two most mentioned are B.F. Goodrich and again Uniroyal Chemical. There are still living persons whether union men or management or even company consultants who know first hand how bad the fumes were inside the local tire plants. The Waterloo Public Interest Research Group (WPIRG) produced a booklet regarding solvent fumes and poisonings and distributed it to rubber workers including Uniroyal employees. After I blew the whistle on Varnicolor Chemical here in Elmira, I was given a copy of the WPIRG booklet detailing the various solvents and their health effects.

Once again having health and safety laws that are either not enforced or easily stick handled around has elevated shareholders' profits on the backs of employees health and lives.

GO AHEAD SANDY, KEEP ON SUPPORTING UNIROYAL/Chemtura/Lanxess. That speaks volumes to the informed and intelligent people in Woolwich Township and further afield.