OVERVIEW OF THE REGION OF WATERLOO'S ANNUAL REPORTS

Firstly the highlights or improvements: The second page describes the drinking water system. For example it lists the names and the numbers of wells in the particular system. Then it describes the actual manner of disinfection (bacteria removal) for the wells whether an Ultarviolet system or sodium hypochlorite or ammonium sulphate combined with sodium hypochlorite . Any unusual expenses during the year are listed and itemized. These reports advise us as to how much of the year individual wells may have been shut down. Lead testing is done and concentrations listed. Under Organic parameters my suggestion of several years ago has finally been implemented which was to show Haloacetic Acids (HAA).

The problems or inadequacies with these reports. Firstly still not enough organic parameters. There are way too many ubiquitous solvents in our groundwater which for some reason the Region don't want to test for. This includes, Toluene, Xylenes and NDMA. There are lots more. Organic testing for parameters is not always done every year. That is ridiculous. Every two to three years simply means that a problem such as a major spill nearby will go unnoticed longer. A description of the location of the wells would be nice. Why shouldn't citizens know which wells are nearest them and for example be able to keep an eye out in their neighbourhood for spills or leaks that could affect their drinking water? The depth and the aquifer the well is screened in would be helpful. If a bedrock well it could explain a slightly sulpher smell in the water for example.

This one is huge. So well W47 was offline for 34 weeks in 2021. WHY? Tell us why our drinking wells are shutdown while we are on water restrictions please. Was it a mechanical breakdown or is there a plume of benzene approaching the well. If the well is toast forever then tell us. Don't just keep repeating for five or six years that it is offline and then finally tell us it has been decommissioned without telling us the reason why.

Give the public the standards or criteria please. This includes standards for the products of disinfection such as chlorine residuals, chloramine concentrations, Halaoacetic Acids and Trihalomethanes. Simple exceedances yes or no are imprecise. Are we constantly drinking water that is on the razor's edge of exceeding the health standards or is there a significant margin of safety? The same thing should go for the organic parameters whether benzene, trichloroethylene or Glyphosate (Round Up) in our drinking water.

Some of the Region's Annual Reports have the concentration numbers for HAA and THMs. Far too many don't and refer you elsewhere. That is a cop out and most of us won't find them. If you want, put them in both spots but quit effectively hiding them.

These changes would be a very good start. As they currently are it is far too easy for marginal quality wells to be kept in the system for far too long and these reports effectively hide their shortcomings for most readers.

LOOKING BACK & LEARNING FROM IT

Ah for the good old days when the Elmira Independent, Gail Martin and Julie Sawyer were covering CPAC meetings. There were two excellent articles in the December 3, 2008 edition of the Independent. These two articles covered a CPAC meeting held on November 28, 2008. The first article was titled "Ministry has harsh words for Chemtura" and the second titled "Contaminants should be removed, says Marshall".

The first article describes the report produced by the Ontario Ministry of Environment presented at the CPAC meeting which criticized Chemtura s "best efforts" to maintain hydraulic containment of it s site during construction of the new Ammonia Treatment System. Steve Martindale of the M.O.E. stated "Chemtura s monthly reporting has identified when containment had been lost". "It is the Ministry s opinion that the loss was understated". Further Steve Martindale stated "in regards to omitting monitoring wells from it s monthly reporting that Chemtura should not unilaterally revise the monitoring program for the containment wells". I attended the meeting as usual and also strongly criticized the lack of hydraulic containment of the site during the Ammonia Treatment System upgrades.

The second article was in regards to DNAPLS or dense non-aqueous phase liquids. A CPAC sub-committee had studied DNAPLS for nearly two years and determined that very little work was further required. Unsurprisingly these conclusions were the ones favoured by Chemtura, the M.O.E. and Pat & Susan of CPAC. Pat & Susan ensured that neither the highly critical letters of Jaimie Connolly (M.O.E. hydrogeologist) nor of Wilf Ruland were included in the report or handed out to CPAC members. They also refused to advise CPAC members of the incredible meeting held in January 2007 between Drs. Beth Parker and John Cherry with myself, Susan, Pat and Wilf Ruland. The critical letters of Connolly & Ruland eventually surfaced during the next reincarnation of CPAC around 2012 and I spoke publicly to CPAC about their significance. Susan suggested that she and Pat may have failed to send them to me because I was not on e-mail at the time. What a pathetic excuse for hiding crucial information.

The incredible meeting held at the University of Waterloo recommended source removal of DNAPLS whenever and wherever possible. This shocked and dismayed the other three and especially so for Pat & Susan whom I believe had long ago made a private, verbal deal with Uniroyal to let them slide in exchange possibly for more creek work.

I have since learned that this was neither the first nor the last examples of hiding key information from the public by various authorities and individuals.

ANNUAL REPORTS (DRINKING WATER) STILL UNCLEAR OR DECEPTIVE?

I've had a quick look this morning at the On-line Region of Waterloo Drinking Water Reports for the City of Kitchener. Kitchener has six different well systems spread around the city. Many wells are shut down due to industrial contamination although you'll never see that written in any of the reports. Other wells have long term low level readings of Trichloroethylene (TCE) the contaminant/degreaser of choice for industry for many decades.

The Parkway Wells are one example of low level TCE being present. This is courtesy of a former Deilcraft furniture plant's presence in the area. There was a cleanup however TCE is a notorious DNAPL (dense non-aqueous phase liquid) and extremely difficult to find and remove all the free phase chemical in the sub-surface.

The Woolner's Well System has been shut down for some time now. It is located along the Grand River albeit further downstream than the long shutdown K70 and K71 wells immediately downgradient from Breslube/Safety-Kleen. There have long been problems with the odour from these river infiltration wells. If memory serves the presence of Phenols in the river water over the years may have contributed to the odour problems.

The Strange St. Well Supply is sort of a misnomer as those wells have long been degraded by local industrial contamination. If I had to guess I would guess that the long gone Uniroyal Tire Co. on Strange St. was the major source of industrial contamination. Currently three of the five wells from this system are out of service and the two remaining wells are relatively new and located out Glasgow St. well away from the original ones.

The Greenbrook Well Supply System was shut down a few years back in order to install an updated treatment system to remove 1,4 Dioxane from the raw water courtesy of Varnicolor Chemical or Uniroyal from Elmira, Ontario being put into the nearby Ottaw St. Landfill. Currently it is working well although it also suffered from an explosion due to human error a while back due to the inadvertent mixing of chlorine and ammonia. Oops!

The K34 Well System consistes of three wells which are working well.

The last, biggest and most expensive system is the Mannheim Water Treatment Plant. The repairs and upgrades in 2017 were in the millions of dollars. This is the shame of industry externalizing their waste disposal costs by putting them onto the taxpayers. Groundwater prior to pollution is abundant and inexpensive compared to treating surface water such as the Grand River.

LOVE CANAL NORTH - UNIROYAL, CROMPTON, CHEMTURA & NOW LANXESS

The K-W Record did a story in 1980, a year after the Love Canal story broke. It was a comparison between our very own Uniroyal Chemical in Elmira and the infamous Love Canal in the United States. The Ontario Ministry of Environment stated in the story that Uniroyal could never cause a similar disaster with their buried on-site wastes for two reasons. Firstly the chemicals were buried in plastic lined pits and secondly because the company and the site were under government supervision. Well how did that exactly turn out again?

To say that the M.O.E. claim was disingenuous is putting it mildly. It was their "supervision" in the first place that allowed the company to bury the most highly toxic of wastes both beside a surface water body (Canagagigue Creek) and immediately above the underground aquifer which supplied Elmira with its' drinking water. Nice job that.

As far as plastic lined pits that's a new one on me. Yes they allegedly had plastic on top of their two "consolidation" pits, RPE 4 & 5. That however was to prevent rainfall from entering the pit and like a bathtub then overflow the liquids over the top. By the way whether the plastic kept rain out I don't know but I do know that it sure didn't stop pesticide odours from exiting the pits and I've got the Trespass citation from way back in 1991 to prove it.

All the pits and ponds installed in the 1940s and 1950s were unlined and leaked like a sieve. They were then lined with CLAY in 1970 and continued leaking albeit at a slower pace. CH2MHILL, consultants to the Region of Waterloo, estimated in 1992 that after clay lining the west side operating ponds leaked about 3,400 litres per day. The likely reason that clay was used was because the toxic stew of wastes Uniroyal had would likely have quickly dissolved and gone right through any plastic sheeting on the market at the time.

The last point is this. Love Canal was horrific because people including children were living right on top of it. The actual volume of wastes was a small fraction of the volume here in Elmira. In other words Love Canal was actually small potatoes compared to our local mess. Their suffering however was not.

CITY OF WATERLOO WATER SUPPLY PROBLEMATIC

Part of the problem is the lack of information provided. When one has found discrepancies in the past with information provided by the Region who are in charge of water supply and treatment, one tends to be very skeptical of data gaps or just plain lack of clarity. That is the case with the three water systems supplying Waterloo residents with their water. First off Well W10 is located on the west side of the city in a non-industrial, almost rural area. It appears to have been shut down for years with the usual zero explanation as to why. We are simply advised this year, the same as last, that the system has been offline for the entire year. What pretty much seals the deal is the sample dates for the various organic (carbon based) and inorganic chemicals tested. All these dates are from 2005, thirteen years ago. Zero more recent sampling data.

The Erb St. Well System consists of four wells W6A, W6B, W7 and W8 all pumping into the Erb St. reservoir. W8 was offline for 5 weeks, W6B was offline for 4 weeks and well W6A was offline for the entire year. The previous year Well W6B was offline for 13 weeks and well W6A offline for the whole year again. While there was also zero explanation in 2016 as well, there are clues. The disinfection system had numerous adverse results with both too short of a Contact Time of the chlorine with the water as well as too low of a concentration of chlorine in the treated water. Hence disinfection had to be restored on numerous occasions. Clearly there are either bacteria problems in the source water or there is an ongoing problem with the treatment system. i would expect engineering problems could be more readily remedied than contaminated source water in the wells.

Now we come to the William St. Well System. There are four wells namely W1B, W1C, W2 and W3. Well W3 was offline for the entire 2017 year. No explanation given. It wasn't offline however the preceding year. Strange. Also odd are the chloramine readings listed as exceeding half the Ontario Drinking Water Standards (ODWS). The ODWS for chloramine is 3 mg/litre. These readings are between 1.51 and 1.82 mg/litre. These 1/2 exceedances fill an entire page, there are so many. Chloramines are the chlorine residual that stays in the treated water to kill any coliform or E.Coli bacteria. Why they are so routinely high (albeit below the maximum criteria) likely is due to bacteria levels coming from somewhere.

The other long term problem with the William St. wells are trichloroethylene (TCE) concentrations. Again they are below the ODWS of 5 parts per billion (ppb) but they should not be present in drinking water at any measurable concentrations. They are routinely in Waterloo residents tap water at up to 1.5 ppb. Last year there were higher results and likely they have been significantly higher over the previous years.This has been ongoing for many decades and shame on both the Region and City for tolerating it. I seriously doubt that there are any human studies which can definitively determine that decades long, low dose TCE exposure isn't harmful to human beings.

ANNUAL REPORTS (DRINKING WATER) FOR WOOLWICH

I covered the West Montrose System last Saturday. Today will be the Conestogo and Maryhill Systems. Heidelburg is shared between Woolwich and Wellesley (Region of Waterloo). Heidelburg has surprised me for years that despite the major groundwater contamination and ongoing remediation at their downtown corner (former Mayor Strauss gas station); their drinking wells seem to be unaffected. I expect Mr. Strauss that that is much more good luck than good management on your part.

Both systems in Conestogo, the Golf Course System and the Conestogo Plains System seem clear of any problems according to the reports.
That is odd given the small Grand River influence on one of the Golf Course wells. I would have expected to see more bacteria in the raw water. Also I'm pleasantly surprised by the lack of bacteria in the Conestoga Plains wells based upon the conglomeration of septic systems all around the wells. Again perhaps better good luck than good management. Kudos to the Wellesley Township Reports as they actually have the quarterly readings of both Haloacetic Acids (HAA) and Trihalomethanes (THM) included. This is unlike Cambridge and Woolwich townships who make you go looking for them when they should be included directly in the region's Annual Reports.

What also seems odd is that the Conestoga Systems (presumably both?) are going to be replaced by the incoming pipeline from St. Jacobs and Waterloo bringing water up from the Integrated Urban System (IUS) used throughout Kitchener, Waterloo and Cambridge. While the raw water problems in West Montrose certainly demand a replacement source and it is the same pipeline then being extended over to West Montrose; it is peculiar that Conestogo allegedly has such good water yet it's also being replaced. I have to wonder if this is the Region being the Region. Once found to be liars and deceivers it's a long road back. They out and out lied publicly about the Kitchener river wells K70 & K71 along the Grand River, downgradient from the Breslube (now Safety-Kleen) site in Breslau. Those wells were closed and it wasn't due to the strongest bacteria in history it was due to leakage from subsurface oils and petroleum sludges between the factory and the Grand River.

The Maryhill two water systems are generally quite acceptable in quality. There have been past problems with bacteria but they seem better in this report. Unfortunately chloramines, a disinfectant by-product are a little on the high side in the one system. They aren't above the maximum criteria of 3 mg/litre but they do rate attention and are singled out because they exceed 1/2 the criteria for inorganic compounds. It is understandable based upon past bacteria issues in the raw water that they are shading the treatment a little on the heavy side with this chlorine compound.

The following comment is not specific to the Woolwich water systems. All these reports from the Region of Waterloo lack the exact Ontario Drinking Water Standards (ODWS) with each chemical tested in the treated water. They have a simple YES/NO to indicate if that standard has been exceeded. This is unacceptable as residents do not know how close the chemical comes to exceeding the criteria plus they also do not know if the Method detection Limit (MDL) provided is reasonable or not in regards to the drinking water standard. My comments and criticisms over the years to both the Region and Woolwich have provided for some improvements in these Reports. Well done but more still needs to be done for these Reports to serve residents better.

MORE CAMBRIDGE DRINKING WATER CONCERNS & ISSUES

First some big picture items. Far too many of the Cambridge wells are identified by number only. That is totally ridiculous to enable residents to know if their closest wells likely supplying their households are up to snuff in comparison with other raw water sources around Cambridge. While well systems such as the Shades Mill System and the Pinebush System may be helpful in letting residents know where their water is coming from, listing wells by number only such as G4, G5, G6, G9, P6, P9 is totally unhelpful and in fact downright deceptive. Give an address or something so residents know which wells are better and which are worse. For example which wells are located near the former Ciba-Geigy (Novartis?), which are near the Cambridge Landfill, which are near Northstar Aerospace etc..

Way too many Cambridge wells are MIA -missing in action. No explanation, no idea as to whether they were polluted, what they were polluted with (bacteria, solvents etc.), whether they have a mechanical breakdown that will be repaired etc.. It would also help if the Region's on-line Annual Reports (drinking water) went back a few years as they used to rather than only posting two years worth and then advising to contact them directly for older reports. On-line reports are supposed to save everybody time and energy not give them the runaround. Speaking of runaround where did these Cambridge wells go and why? P2, P5, P6, P7, G10, G11, G12 and G13? O.K. I know what happened to the two wells closest to Northstar Aerospace (P6 & P7) although that's no thanks to the Region of Waterloo.

Getting back to all the Annual Reports for the different wells and well systems in Cambridge I have a bone to pick with the Region and the City. The Annual Reports have recently added a column for HAA results. That's right HAA. Any idea what the hell that is? Well it stands for Haloacetic Acids which are toxic by-products of disinfection. Similarly THMs are Trihalomethanes which are also toxic by-products of adding chlorine to the water ie. the disinfection system. However the Annual Reports may have a column for HAAs and THMs but they don't have a concentration present. There is a reference to the individual municipal reports claiming that that is where they can be found. What the hell, put them in the Regional Annual Reports where they belong. Anyways after some serious digging I found them. Sort of. In the City of Cambridge Annual Report they have a single concentration for ALL the wells for the YEAR. Yup it's an annual average of all the Cambridge wells for the entire year. That folks is lying by numbers as it's totally useless.

Oh and I found another well to add to yesterday's list of wells shut down either entirely or for numerous months in 2017. That would be well G9 which again no thanks to the Region of Waterloo, I know where it is located. It is in the south end of Cambridge not far from the Allen-Bradley plant. This well has historically had low levels of Trichloroethylene (TCE) in it for decades. Maybe the levels have risen, maybe something else has been found, who knows. It was shut down for the entire year.

Numerous Cambridge wells have allegedly been twinned. G4 now has G4A combined with it. Similarly H4 has H4A, H5 has H5A, G5 has G5A. My strong suspicion is that the original wells are contaminated with either industrial or agricultural chemicals and the second twinned well is screened at a different, less contaminated depth in the aquifer. This may be bolstered by the fact that there have been low levels of contaminants in the Hespeler wells for decades (H3, H4 & H5). Also as mentioned yesterday three Hespeler wells are either decommissioned (H3) or shut down for the whole year (H4 & H5). Finally well G4 was shut down for 40 weeks last year and well G5A for the entire year. This twinning of the wells ie. adding a second well at the same location has only been going on for the last five years or so.

Finally I need to also point out that Glyphosate, the active ingredient in the herbicide Roundup continues to have an outrageously high Method Detection Limit of 25 parts per billion (ppb). Advising us that Glyphosate is <25 ppb (less than 25 ppb) is shameful and outrageous and I don't care how high the current drinking water standard for Glyphosate is. We have a right to know what is in our water and if it's there at 5, 10 or 15 ppb. then tell us directly!

Just for the record there are also two low level detections of a herbicide (metalochlor) and a solvent (dichloroethylene) at wells G6 and G5 respectively. It is no coincidence that these two wells are both near the old contaminated Ciba-Geigy plant.

Overall we are all drinking highly treated groundwater due to a history of negligent toxic waste disposal (& spills) by industry with Mickey Mouse enforcement and remediation if and when it is found.