I HAVE TO ASSUME THAT THE ONTARIO MINISTRY OF ENVIRONMENT OPERATE CORRUPTLY ACROSS THE ENTIRE PROVINCE

I don't think that Elmira just got "lucky" with the sweetheart deals, private negotiations and neverending coverups whose purpose is to minimize both the culpability of private companies and the MOE as well as to minimize the extent of contamination hence the money spent to "remediate" it. Multi-national, multi-billion dollar companies actually find hiring lawyers far cheaper than spending the money they saved with improper or illegal waste disposal on belated cleanups. ...................................................................................................... Here in Elmira the number of lies, deceptions and environmental coverups are shocking. We had multiple sources to the destruction of our drinking water aquifers yet both Uniroyal Chemical and the Ontario MOE found it better for themselves to blame everything on Uniroyal. No wonder Uniroyal initially fought like hell to share the blame but eventually the MOE knew that they would wear the responsibility for ignoring and condoning not only Nutrite and Varnicolor Chemical (Union St. & Lot 91) but also potentially Sanyo, McKee (slim?), Borg, Roxton, multiple gas stations, Thur, multiple municipal landfills in town, the old Shirt Factory on Park St. and more. Therefore the Ontario MOE made Uniroyal an offer they couldn't refuse and they didn't. ........................................................................................................................ The hydrogeological evidence is slowly becoming clearer as the multiple sources (hot spots) off the Uniroyal site are being exposed as the contaminant plumes shrink back to their source areas around town. That said all the guilty parties intentionally ignored shallow soil sampling at these many sites decades ago that could have clarified the truth as to who were responsible. .................................................................................................... The provincial Environment Ministry are just like so many other government ministries that boast "world class" competencies and qualifications. All provincial ministries were created to solve or at least mitigate various problems. Unfortunately these "problems" are often public problems with private causes. Think of the Ministry of Labour as well as the MOE. The Labour portfolio was intended to keep labour peace and harmony mostly for the benefit of the owners/employers while telling workers that their employment standards would improve. Just look at the mess they have made on issues such as mass poisonings of rubber workers both in Waterloo Region and across the province. Ditto with the Environment Ministry and mass poisonings of air and water across the province. The fact of the matter is that many of our provincial ministries are simply for appearances. Amazing for example as to how expensive our education system is with results that absolutely are not world class. Yet the beneficiaries within the system claim that all is well. Look at our Long Term Care (LTC) homes across the province. Covid-19 has exposed the provincial government's underfunding and pathetic enforcement of rules and regulations. Meanwhile the private owners of these LTC homes are laughing all the way to the bank while their donated to favourite politicians and parties run interference for them. The system is both broken and rotten. Just like the MOE/MECP. The rot is at the top and buying and installing complicit managers is partly how they manage it. Legislation and rules preventing both accountability and transparency are also necessary. Lastly Freedom of Information (FOI) is wishful thinking as is true Whistleblower legislation. Those in charge never stop lying or manipulating. It's in their best interests but not ours.

THE PUBLIC FACE IS MOE CONTROL ORDERS VERSUS THE REALITY OF PRIVATE BILATERAL DEAL MAKING BETWEEN POLLUTERS AND GOVERNMENT

No morals, no ethics, no shame: that could be the mantra of both the Ontario Ministry of Environment (MOE) and of Uniroyal/Crompton/Chemtura/Lanxess. For good measure let's throw in Varnicolor Chemical and Nutrite although I admit that of the three polluters, I know the least about Nutrite. Ammonia for sure they contributed but they also were no slouches with NDMA, 2,4-d and more on and under their property. ................................................................................................................... It is usually better for the public interest when the guilty parties are publicly throwing mud and accusations at each other than when they are privately and comfortably scheming and negotiating with each other. That's when the sweetheart deals get brokered that absolve each other of blame and lessen the cleanup or mitigation of their illegal and unethical past activities. This is where our governments shine. Yes Dorothy all our governments shine in the fine art of manipulating public opinion in the direction they want whether for good or for evil. ............................................................................................................. The first Control Order laid on Uniroyal Chemical was dated April 13, 1984. This was a mere fourty two years after the company had begun dumping toxic liquid wastes, sludges, tars and solids onto their property, under the surface of their property and both directly and indirectly into the Canagagigue Creek. An honest and moral government would have shut have down the operation by then, arrested, charged and imprisoned senior company executives convicted of either environmental crimes or health crimes against humanity. Of course none of that occurred. ................................................................................................................. Along with better record keeping and more sampling of existing groundwater, monitoring wells; the MOE ordered new monitoring wells on the east side of the property close to RPE-1. This was the most northerly of the five retention pits (east side i.e. RPE). Specifically they wanted all the stratigraphic layers monitored in and around well OW 7. Now oddly while that was a simple and inexpensive request, Uniroyal embarked on a much more ambitious program on the east side. This encompassed fifteen individually numbered wells from OW 25 to OW 39 placed between RPE-4/RPE-5 and the extremely close Stroh property line. As mentioned previously, most of these were strangely screened in the Upper Aquitard (UAT) versus in the Upper Aquifer (UA or UAF) which is the water bearing and transferring layer of soils rather than the silty/clay less permeable UAT. ......................................................................................................... One possible reason for this is as follows. Every single well closest to RPE-4 and RPE-5 including OW 25, OW 27, OW 29, OW 31, OW 33, and OW 35 were screened solely in the Upper Aquitard (UAT). Meanwhile the wells closest to the Stroh property line included both screens in the UAF and the UAT. What the hell? Even more bizarre is the fact that after the 1987 excavations of waste pits BAE-1 and RB-1 and RB-2 located as well between RPE-4/RPE-5 and the Stroh property line; only three UAF wells were left standing along the property line namely OW 28, OW 32, and OW 39 although they were drilled in 1985, 1988 and 1986 respectively. Meanwhile every single UAT well drilled nearest RPE-4/RPE-5 in the Upper Aquitard (UAT) was destroyed, removed and grouted during the 1987 excavations. ......................................................................................................... To further confuse the narrative there were also in 1984 three wells drilled in the actual waste pit itself, RPE-4 and two wells in RPE-5. Finally four wells were drilled to the west of these two waste pits (RPE-4 and 5) namely OW 40, OW 41, OW 42 and OW 43 all of which are still there today. Oh and lastly Woolwich Township contracted with Conestoga Rovers in 1984 to drill monitoring wells and examine the municipally owned Bolender and First St. Landfills. All this from a minor and modest 1984 Control Order that ordered none of it...at least publicly? ................................................................................................................ Here is my take. The MOE grew some gonads and yelled and hollered at Uniroyal because they knew the town's drinking wells were toast and the public would have to be informed some time. Uniroyal yelled back and threatened legal action as usual. Private negotiations then took place. The actual reasoning for the weird timing of new wells and weird screening in the UAT was in order to "prove" privately that Uniroyal's liquid wastes had not crossed the Stroh property line via groundwater. This is an old, tried and true hydrogeological trick whereby water levels from different stratigraphic units are compared to each other rather than water levels in the same startigraphic unit (usually aquifers UA, MU etc.). Therefore comparing UAT water levels nearest RPE-4 and 5 with UAF water levels nearest the Stroh property line would "prove" that groundwater was flowing westwards away from the Stroh property. Was the Ontario MOE fooled or was this just more of the old boys nudge and wink private negotiations? Regardless the purpose was to dissemble, minimize the problem and lie to the public. As always.

HONEST EXPLANATIONS REQUIRED - THEY KNEW FOURTY YEARS AGO THAT THEY HAD CONTAMINATED THE STROH FARM & THE MUNICIPAL WELLS

I've just spent a couple of hours looking over the history of monitoring wells on the east side of RPE-4 and RPE-5. These wells therefore are located between the two largest "consolidation pits" RPE-4 and RPE-5 and the Stroh property line. In fact many of these wells are located within either inches or mere feet from the Stroh property. Of interest is the sheer number of wells located next to these two pits versus the very few further north beside RPE-1, 2, 3 (about 3) not to mention further south (perhaps 4). There have of course been a few more added in the last couple of years as Lanxess go through a pretend investigation of the Stroh farm. Back in the early 1980s there were about fourteen wells drilled beside RPE-4 and 5. Clearly they not only knew that their liquid wastes had flowed onto the Stroh farm but they knew that the two southern pits were by far the worst. ........................................................................................................ These fourteen wells were numbered from OW 25 to OW 39. Keep in mind that some of these wells had multiple screen depths such as OW 32 which was screened at three, six and eight metres depth. Four of them were drilled and screened into the Upper Aquifer namely OW 28-2, OW 32-3, OW 34-5 and OW 38-5. Oddly? all the rest were drilled into the Upper Aquitard. That in itself requires an explanation. ...................................................................................................... What also requires explaining is the number of wells which were shut down or abandoned early on. How odd that most of these wells were installed between 1981 and 1984 and yet clearly many were torn up and destroyed around 1987 as extensive cleanup and remediation was ongoing including excavation of nearby BAE-1 and RB-1 and RB-2 all prior to the supposed discovery of NDMA in the south wellfield in the fall of 1989. There are barely four of these wells still in operating order and only a couple of them are actually screened in the Upper Aquifer today. ....................................................................................................... The more I study and read the more obvious it becomes that all important environmental decisions have been decided behind closed doors while public consultation has all been a play managed by corrupt, incompetent and biased politicians looking to keep the public from understanding how badly they have been deceived and abused for many decades.

HAS MR. "BEEN CONSOLIDATED" i.e. BRIAN BEATTY BEEN CAUGHT AGAIN?

This posting is not an attempt to tease or poke fun at the Woolwich Observer, especially after yesterday's flattering posting here about our local newspaper. That said, the Merlihan brothers (hmm...one or both?) have advised me in the past that they got burned badly by publishing my testimony to them regarding Mr. Beatty being "consolidated" by Dr. David Ash of Uniroyal Chemical way back in the early 1990s. That particular incident involved Mr. Beatty quoting another hydrogeologist, Mr. Stan Feenstra, out of context regarding the 1% Solubility Rule and DNAPLS (dense non aqueous phase liquids). ................................................................................................................. Well danged but I'm going to do it again. I have of late been doing what I enjoy most and that is re-reading technical reports dealing with the contaminated former Uniroyal Chemical property here in Elmira, Ontario. Fortunately for me there is a lifetime of reading available. This of course is difficult for any new members of TAG or old members of RAC as they literally do not know what they do not know. There is of course no excuse for the old members of RAC not to have read many of these reports. The thing is RAC agencies and bureaucrats are there simply to give the public the impression that they care and are on top of things. What a joke. Next Thursday RAC are going to have their first meeting in a year! While municipal councils, TAG (Technical Advisory Group) and other committees of council have been holding virtual (Zoom meetings) for many months, RAC has not. Afterall they are primarily a knowingly and willingly uninformed group including the GRCA, Region of Waterloo, Woolwich Township, two TAG members, Lanxess and the Ontario Ministry of Environment (MECP). Even the MECP have turned over all their staff with decades of knowledge regarding this site. Now to be honest there are a couple of knowledgeable people present such as Eric Hodgins of the Region and perhaps one long bought and paid for Lanxess employee. ................................................................................................................ So what did I catch Mr. Beatty doing this time? In my experienced (and to gasps of horror and outrage from the entitled) and professional judgement I've caught Mr. Beatty again gilding the lily in regards to his presentation of hydrogeological data. The data is in multiple maps presented in the Annual Monitoring Report # 10, January 1992. These maps are contaminant plume maps of various toxic substances including benzene, toluene, phenols, chlorobenzene, NDMA etc. Keep in mind my use of the term "professional judgement" is based upon more than thirty years of reading, debating and discussing hydrogeological matters with folks with a four year university degree (BSc.) perhaps later combined with a MSc. and perhaps not. Also keep in mind that my "discussions" with experts, both honest and bought and paid for, has been seriously curtailed of late due to incompetent (at best) Woolwich Township politicos intentionally excluding opportunities for discussion with both the general public as well as with stakeholders such as myself who can hold their own with any and all hydrogeological experts. ..................................................................................................................... Mr. Beatty has portrayed the Upper Aquifer (UA) contaminants as being solely on the Uniroyal property (they are not) and as flowing solely west or south on the Uniroyal property versus east onto the Stroh property. Of course the fallacy of that has already been proven via the January 2019 excavations and partial cleanup of the northern end of the Stroh property along the Lanxess property line. That is public knowledge and undeniable. Mr. Beatty has also committed sins of omission by not including a major ground and surface water feature affecting off-site flow of liquid contaminants. These features include the Stroh Drain, Ditch & Berm (SDDB) which is located a mere ten metres from and parallel to the property line between Lanxess and the Stroh farm. It is also possible regarding sins of omission that Mr. Beatty has incorporated inappropriate monitoring wells along the property line to bolster his inaccurate position that everything stayed on the Uniroyal property. These inappropriate wells include one that is out of commission (grouted) and three others that are NOT screened in the Upper Aquifer as indicated but rather are screened in the Upper Aquitard (UAT versus UA). It would seem clear that using contaminant concentrations from wells screened in the wrong stratigraphic unit to describe contamination in a different unit is wrong if not potentially intentionally deceitful. This by the way is not the first time that this trick has been used by Uniroyal Chemical (and successors) mouthpieces. Crompton's "Optimization" program was caught by me doing this back in 2004 (possibly well CH 44) and again during the Ammonia Treatment System discussions in 2007 (CH 97). ............................................................................................................ One could almost begin to think that "professional" client driven consultants like to have a few problematic monitoring wells available on site in order to back up some unlikely self-serving conclusions for those clients.

KUDOS TO WOOLWICH OBSERVER FOR THEIR HAWK RIDGE HOMES COVERAGE

Well last week the Observer reported on both my and Ron Koniuch's Sulco/CCC) Delegation to Council in regards to the never ending proposed residential subdivision to be located within breathing, smelling and dying distance of Lanxess Canada. Sulco as well as the former Nutrite (fertilizer) and the former Varnicolor Chemical are also nearby. This week the Observer's Editorial is titled "Council right to have concerns about Elmira subdivision". Of these four companies three of them have a documented history of soil and groundwater contamination caused by their own lack of responsibility. Sulco may have deep soil and groundwater contamination but that is primarily from Uniroyal/Lanxess. ........................................................................................................... Besides the Editorial the Observer also have a wonderful cartoon showing Sandy Shantz and another councillor delivering a Welcome Wagon basket to a future new homeowner in the subdivision. The basket contains noise-cancelling headphones, a nose plug, a Hazmat suit and a First-aid kit. What an appropriate cartoon under the ridiculous circumstances surrounding this subdivision. ..................................................................................................... The Editorial gives a brief environmental history of the area and industrial neighbours and it is not a pretty picture. The Duke St. "rowdies" and their sucessful lawsuit against Uniroyal Chemical is mentioned as well as some details of the toxins handled and mishandled at the Varnicolor Chemical site. Interestingly I believe it possible/likely that the following statement in the Editorial might just have come from something I wrote about Varnicolor decades ago namely "The chemicals there had the potential to cause leukemia, birth defects and internal bleeding, as well as liver, kidney and eye damage." ................................................................................................................... This folks is why local history should never be forgotten. It is relevant to issues today and to the health and safety of residents.

IS DIVERTING CONTAMINATED WATER ONTO YOUR NEIGHBOUR"S PROPERTY (Stroh in particular) CONSIDERED REMEDIATION?

Apparently in Elmira it is. The last couple of days I've been posting here indicating that shallow aquifer flow directions have been misrepresented by Uniroyal/Crompton/Chemtura and lanxess consultants for more than thirty years now. So too have been surface water flows on and off their site. I have also indicated that groundwater concentrations of contaminants have been low directly beside GP-1 (gravel pit 1) where we have been told in numerous company and consultant reports that the bulk of overflowing waste waters ended up. It's all a charade. .................................................................................................... I have also been reexamining groundwater results from the 1980s and early 90s on the east side of the now Lanxess Canada site. Firstly I will explain what Uniroyal and Conestoga Rovers seemed reluctant to explain to both the public and to UPAC members nearly thirty years ago. East side groundwater results, especially in wells further away from the east side toxic waste pits (RPE 1-5), have ben significantly affected by manmade changes and diversions on the east side. Some of these diversions have been confirmed by Uniroyal/Lanxess whereas others have not. One of the pressing motives for diverting contaminated surface and groundwaters away from flowing westwards into the Canagagigue Creek on site was to reduce the demand for hydraulic containment of the shallow (i.e. upper) aquifer on the east side of the creek. This was in fact sucessful although the company and consultants did not then mention their sucessful diversions. .................................................................................................................... The company has admitted to ploughing furrows on the east side for the express purpose of diverting overflowing wastewaters southwards rather than let them flow westwards into the creek. The company utterly failed to mention either the Stroh Drain, Ditch & Berm (SDDB) or the groundwater collection system directly beside their eastern boundary with the Stroh farm. This groundwater collection system could be a somewhat conventional agricultural tile drain system although I am doubtful. Lastly and even more controversial is the possibilty of an Interceptor Trench or other subsurface collection system which is possibly diverting and gravity flowing contaminated groundwater eastwards onto the Stroh property where it eventually winds its' way back into the Canagagigue Creek further downstream. .......................................................................................................... The apparent purpose of these manmade constructions would appear to be in order to minimize the extent of Uniroyal Chemical contamination and hence minimize the number of dollars required to properly remediate their pollution. Of course the company, by whatever name, has always failed to honestly and in good faith talk with all the community stakeholders. They have handpicked the ones that are more amenable to their ideas and initiatives. Woolwich Township have cheerfully gone along with that corruption.

UNDERWHELMING GROUNDWATER RESULTS FROM TWO WELLS ON THE EDGE OF GP-1

These two wells are OW 69 and OW 24. More specifically they are OW 69-3 and OW 69-8 screened in the Upper Aquifer (i.e. shallow ) as well as OW 69-13 screened in the Municipal Upper Aquifer. These wells are located immediately on the left (west) side of GP-1 near the north end of that allegedly former gravel pit (i.e. GP-1). OW 24 oddly has three Upper Aquifer wells namely OW 24 S1, S2 and S3 screened at three, five and six metre depths. This well also has OW 24i for intermediate screened in the Municipal Upper Aquifer at approximately the twelve metre depth as well as OW24d (deep) screened in the Municipal Lower Aquifer at the thirty metre depth. Monitoring well OW 24 is also on the immediate left (west) side of GP-1 although further south than OW 69. ............................................................................................................... So how underwhelming are these various groundwater concentrations? Oh and I'm talking about groundwater results in the early 1990s shortly after the guilty parties began seriously building more monitoring wells and regularly sampling them. Therefore these results are prior to the two "consolidation" pits on the east side being excavated (Dec. 1993) as well as before GP-1 was partially excavated in 2013-2014. The groundwater concentrations for NDMA, chlorobenzene, toluene, chlorophenols and a host of other contaminants were often below the laboratory detection limit and when detectable they were very low. Quite frankly this is nonsensical after the claims by Uniroyal, CRA, MOE etc. that the bulk of the overflowing waste waters from east side pits RPE 1-5 ended up in GP-1 and GP-2. If that was true then the chemical contaminants would have been very high in the early 1990s. Yes dioxin/furans and DDT results were "high" however that is subjective in that the health criteria are thousands of times lower for these contaminants, most especially for dioxins/furans. Therefore the concentrations of dioxins/furans were only "high" relative to thier extreme toxicity and hence low criteria. ..................................................................................................... On the other hand the concentrations of numerous of the same contaminants in wells both west and east of pits RPE-4 and RPE-5 in the same time frame were huge. We are talking wells such as OW41, OW42, OW43, OW70, OW5 on the west side of the "consolidation" pits and OW28, OW37-5A and OW8 onthe east side. These concentrations often exceeded 10,000 parts per billion (ppb) and sometimes even exceeded 100,000 ppb. It is becoming clearer all the time that whatever chemical skills Uniroyal/Crompton/Chemtura/Lanxess have; they are equaled or exceeded by their story telling skills.