QUOTING SUSAN BRYANT: "WHAT THEY (MOE) DO IS SOMETIMES PITIFUL, EVEN TO THEM."

I must agree with Susan's quote from February 5, 1999 in the Elmira Independent. What they permit in regards to investigations and reports from Uniroyal Chemical, their consultants, and all Uniroyal's corporate successors is indeed pitiful. Then of course is the MOECC's own investigations and reports. The most recent one dated June 13, 2018 is a fine example. It is titled ""Audit of the Lanxess Canagagigue Creek Floodplain Soil Investigation,Elmira 2017".

First some perspective on this "Audit". The overall efforts expended by GHD,consultants to Lanxess,were substantial. They sampled and tested creek sediments, creek bank soils, and floodplain soils in the Canagagigue Creek between the Lanxess property and the mouth of the Canagagigue Creek at the Grand River,just south of West Montrose, Ontario. They sampled extensively on the Lanxess property but unfortunately, generally focused on either identical or nearby locations downstream from there. There has been an obvious locational sampling bias by both the company and the Ontario MOECC since at least 2012 and thereafter. Hence there has emerged from repeated sampling of the same locations so called "hot spots" in the Creek that most likely are ridiculous. When you don't sample in other locations then you don't find the other "hot spots"and never will.

The total number of samples taken and tested by GHD in the "2017 Canagagigue Creek Sediment and Floodplain Soil Investigation", unlike their recent Off-Site Investigation (Feb. 14, 2018-the narrow Stroh strip of land along their border), was as stated, impressive. The weakest and least impressive investigating of the Creek however was in regards to the mere five floodplain soil locations which they (GHD) tested. The MOECC reviewed the rest of GHD's above mentioned report in an eight page report also dated June 13, 2018. I would categorize it as much better done and much more professionally done than their longer (nineteen Pages) Audit Report. That shorter review by the MOECC points out a number of errors and discrepancies in GHD's report which I have also undiplomatically likely referred to as "amateur hour" mistakes. It also on page two makes it clear that Lanxess and GHD must examine other potential contaminant sources to the Creek, specifically including the Stroh Drain which they prefer to awkwardly call "agricultural drainage ditch from 6770 Line 86, Township of Woolwich".This is a huge item and my bets are on the MOE eventually winning a formal competition as they do their world famous MOE gymnastics dismount from their current position on seriously and honestly investigating the Stroh Drain.

So what is wrong with the MOECC's "Audit Report"? Table 1 (page 5) is a disgrace. The first row representing o,p + p,p DDT values has six out of eight numbers representing data from the 1997 Jaagumagi & Bedard (MOE) report transcribed incorrectly. The only reason the other two are O.K. is because they are N/A or not available. I also believe that the last row (ie. 4th row) has also inaccurately transcribed the Dioxin TEQ values from the Jaagumagi & Bedard report inaccurately.

Table 1 also rather bizarrely appears to be comparing the MOECC test results with Jaagumagi & Bedard as well as with GHD's test results. The problem is that while the listed parameters are identical between the MOECC and Jaagumagi & Bedard, they are different from the listed GHD parameters.Based upon errors in the text and data in GHD's initial investigation as well as in errors in the MOECC's longer "Audit Review"; quite frankly I'm getting tired of going back to the original reports either Jaagumagi & Bedard's or GHD's 2017 Canagagigue Creek Sediment and Floodplain Soil Investigation confirming all their errors. Therefore these different parameters (eg. o,p + p,p DDD versus only p,p DDD) may be typographical in Table 1 or they could be that GHD specifically didn't test for the same parameters as Jaagumagi & Bedard did twenty years ago. A third option is that they did test the same parameters and the MOECC simply couldn't manage to find them and include them in Table 1. Regardless the inclusion of GHD's different parameters in this table is both confusing and a skeptic might even think intentionally deceptive. As I said "amateur hour".

As mentioned earlier (paragraph 3) there were only five Floodplain Soil sample locations in GHD's 2017 Investigation. Of these Jaagumagi & Bedard only sampled four of them namely FP5, FP8, FP9 and FP10 with each location at varying depths. Well actually Jaagumagi & Bedard sampled a total of ten locations altogether namely FP1, 2, 3, 4, 5, 6, 7, 8, 9, and 10. Therefore right off the bat there is little or no accurate, scientific comparison between Lanxess/GHD's efforts and Jaagumagi & Bedard's. Same thing with the MOECC's test results and Jaagumagi & Bedard's.

Here is where it gets even worse. The samples were taken at different depths at a number of the "common" locations or in fact simply weren't taken at all by Jaagumagi & Bedard. One example may be the FP Pond location that GHD sampled. Did you notice how I put the word "common" in quotation marks two sentences ago? This is because there actually weren't any "common" locations. The best GHD could do apparently is while using the exact same location names; they could only get within about 100 metres of the original floodplain sampling locations. Therefore GHD's 2017 Canagagigue ...Investigation results should not be compared with anything other than the current provincial or federal criteria for each and every chemical found. It should not be compared with concentrations of DDT and Dioxin/Furans in different locations, different depths, different soil types, different parameters and lastly twenty years apart with different sampling techniques, equipment and personnel. That is sheer junk science and the masters of it have honed their craft here in Elmira over the last thirty years.

Lastly I mentioned in the preceding paragraph that investigation results should not be compared with anything other than the current provincial or federal criteria for "...each and every chemical found." Well they certainly didn't test for each and every Uniroyal signature chemical or otherwise. Nevertheless as per the MOECC's Appendix II they have found the following additional chemicals in floodplain soils namely chlordane, PCB 114, PCB 171, dieldrin, endosulphan II, lindane, PCB 60, PCB 74, and trans-nonaclor. Therefore above and beyond the fact that DDT and Dioxins/Furans are mostly above the legal criteria, how do you feel about all the other toxic chemicals in the Canagagigue Creek? Maybe the threatened SSRA (Site Specific Risk Assessment) along with a pinch of fairy dust will determine that all these other toxins will magically nuetralize DDT and Dioxin/Furans. Maybe we will learn that animal patties in and around the creek are also magic antidotes for man made toxic chemicals. Have faith in both junk science and the just mentioned horse manure. They will prevail as they always have in Woolwich Township.

COULD THE MOE BE MORE INCOMPETENT THAN CORRUPT?

Personally I'm doubtful however with their latest effort dated June 13, 2018 you'd never know it. This is the second of two reviews dated that day and this is the longer one focusing solely on Floodplain Soils.It is ironic that the other 8 page one pointed out a number of errors in GHD's efforts in their report about the 2017 investigation of the Canagagigue Creek sediments and soils. This review by the MOE(CC) is a classic case of comparing apples to oranges, pineapples, or even to watermelons.

Firstly you cannot honestly or scientifically pretend that measuring the same chemicals twenty years apart at different locations is relevant to anything. GHD picked the new sampling locations. They got them supposedly within 100 metres of the MOE ones from twenty years ago. Good Lord groundwater may be somewhat homogenous but soils are not. Literally two soil samples fifteen feet apart can have drastically different concentrations of either DDT or Dioxins in them. Therefore 100 metres apart simply is not comparing apples to apples. It is not relevant to anything at all. Secondly the MOE's Table 1. is simply inaccurate. They have not correctly listed the data from twenty years ago regarding MOE concentrations of DDT. Thirdly the calculations on page 7 allegedly determining the percentage decrease of DDT over the last twenty years do not match the numbers stated in their Table 1. This is more typical CRA stuff. It is inaccurate, embarrassing and shameful. We the taxpayers are paying for sloppy work. Enough long ago.

May 2018 LANXESS PROGRESS REPORT otherwise known as DILUTION IS THE SOLUTION TO POLLUTION

The title above says it all. In a nutshell the Ontario MOE's "strategy" for remediating contaminated sites is "natural attenuation" aided and abetted by the appearance of professional oversight developing the best environmental solutions. In reality the "best environmental solutions" are far more likely to be "the cheapest and least effective solution". That is a direct quote by Dave Belanger, consultant for CH2MHILL back in the early 1990s on behalf of the Region of Waterloo in describing Conestoga Rover's Upper Aquifer Containment & Treatment System.

For the benefit of the naive and or others with a bias in favour of our alleged professional regulators let me say this. You can make excuses until the cows come home. You can cry about reduced budgets, layoffs and more. That may be so but those excuses do not remediate contaminated sites nor do they mitigate either ecological or human health issues. Provincial politicians may very well be to blame but until the Ontario Ministry of Environment develop some backbone at the top and stand up and call it like it is and call out the province for ignoring the health of our environment then it will not stop. Yes there will be firings and maybe, just maybe, there need to be resignations at the top to highlight the scam that passes for environmental regulation in this province. In other words senior MOE personnel, don't support provincial puffery and bullshit. Speak out and tell the people of this province the truth. That truth is that large corporate polluters have free rein. The system that has been developed here in Ontario allows large polluters to hire their own client driven consultants and run their own clean ups. It does not work. It is nothing but a scam giving the appearance of the best available technology being applied to environmental problems that could have and should have been stopped decades earlier. When the lower rung staff begin to understand that the whole thing is for show it robs them of the incentive to do a good job. When they learn that a problem avoided leads to promotion and raises then why on earth would they be proactive with polluters whom they are supposed to be supervising? The problems are at the senior level and trickle down and permeate throughout the organization. There should have been a Public Inquiry in the early 1990s here in Elmira. It might have caused heads to roll both politically and in the MOE but we citizens would have been the winners. It did not happen.

The May Progress Report is very discouraging. Page 5 under the title of "Remediatiation of Former Operating Pond Area" has the same old comment for the last decade or two. It states "There are no new activities to report for this item in May 2018." That is shameful and is designed to simply allow the MOE not to make a decision. There was an absolutely minimal "cleanup" of part of RPW-5 and TPW-2 back in the fall of 1993. Allegedly this "clean-up occurred in December 1993 after the on-site Envirodome was already full to its effective capacity. The rest of the operating ponds (RPW-6, 7, 8) were not excavated as they should have been. We have been asking them since then as to whether or not they were satisfied with Uniroyal's answer. Their response has been in the monthly Progress Reports ever since in one form of wording or another.

Table C.2 is awful again this month. The following Uniroyal chemicals have higher concentrations downstream than upstream as the Canagagigue Creek flows through their property. These chemicals are MBT, BT, NDMA, NMOR, chlorobenzene, toluene and m&p xylenes. This is disgraceful and likely won't even be raised at the potential TAG meeting set for one week from today at 6:30 pm. in Council Chambers.

WOOLWICH TOWNSHIP STAFF & COUNCILLORS (?) ARE GOING TO COURT

You would think that they have better things to do with our time and our tax dollars. Apparently they don't think so. Many years ago Woolwich Township presumably with the blessing of Council built a water pipeline through private property. Now we all probably have water pipelines on our residential properties. How else do you think you get your municipal water from the underground pipes beneath the streets into your house? The difference of course is that the underground pipe is bringing water to your property for your use. The water pipeline that goes through the #86 Auto Recycling property doesn't go anywhere near the buildings facing Arthur St. in Elmira. It services the former Martin's Pet Food plant on Martin Lane just north of the former Paleshi Motors (now #86 Auto Recycling).That's right, the Township without benefit of an easement or any other legal right simply ran the pipeline straight through the back of the property now known as #86 Auto recycling.

When the owner Mr. Rattasid bought the property he of course did his due diligence.He had his lawyer look for any liens, chattels or easements. None were found at the back of his property which consists of several acres. The front can be readily accessed from Arthur St. The back has an access to High St. available he thought. Turns out that while High St. dead ends at his property there is a small problem. It's called a buried pipeline on his property running perpendicular to the end of the road. The pipeline is sitting in a area of sunken ground something like a ditch. Mr. Rattasid has been advised that he can not fill in or cover over the deepest part of the ditch which would give him egress and exit from his property onto High St.

So in a nutshell he has asked the Township for relief from a problem that they caused. Either move the water pipeline and put it on municipal property as is the normal, usual and legal practice or make some other accommodation to assist him. The Township as sometimes is their habit have chosen not to assist him in any way. This is clearly a property rights issue which the courts are now going to have to resolve. No one expects to leave the Elmira Pet Products plant in the lurch for water. It can hardly be their fault. However the Township have to do better than simply saying no we won't fix the problem we created through an illegal pipeline across private property.

THREE DECEPTIONS PRODUCED BY WOOLWICH COUNCILLORS & THE MOE

The three lies oops "factual fictions" are in regards to ammonia in our drinking water, industrial dumping in our in town landfills and third and fourth sources of industrial contamination in the south wellfield prior to its shutdown in November 1989.

What I am offering today is simply additional evidence to all the other different evidence offered here over the last eight years.

South of Uniroyal and in and around the former Varnicolor site on Union St. we had commercial pig farms. Yup, pigs. And besides putting on weight, guess what pigs do,en masse. You got it. Hence this site and the whole area has had high urea amd ammonia levels for decades. To this day the new wells required to remediate the Elmira aquifers are being routed through the fairly new Ammonia Treatment System located at Lanxess (Uniroyal Chemical). Deep pumping wells near Uniroyal and Nutrite require ammonia treatment such as W5A/B as well as the on-site deep pumping wells PW4 & 5. One new nearby well (W8)just barely off the former Nutrite site is also routed through the Ammonia Treatment System. Surprisingly so are new wells W6A/B and they are way south on Oriole Parkway. It would seem to me that this is from the anmmonia mentioned from the Union St. area and the former pig farms. Keep in mind neither the Region of Waterloo nor Woolwich councillors want to offend our agricultural brethren.

Woolwich councillors have frankly behaved like spoiled, arrogant pieces of crap in regards to my discovery of methane gas en masse in the former Bolender Park Landfill. As there are a whole whack of technical reports by Conestoga Rovers (CRA) confirming this and expressing concerns on occasion; Council's head in the sand bullshit really seemed excessive even for them. Maybe there's a reason. Firstly CRA not only have produced numerous reports and investigations of the Bolender Park Landfill but they have done the same thing for the First St. Landfill beside the former Transfer Station on Howard Avenue. You can bet your bottom dollar that our municipal usurpers of power and authority have no intention of those reports ever getting into my hands or any other honest citizen's.Yes of course these reports were paid for by you and I but the truth is the last thing our local councillors (in general only) intend to ever share with us even when we've paid for it. Oh and I've just come across a formal Thesis submitted to the University of Waterloo back in the early 1990s which advises that Varnicolor were prohibited from dumping in the (Elmira) town dump because believe it or not their highly flammable solvent wastes caught fire in 1970. Gotta love it! In 1970 could be either the Bolender Landfill or the First St. Landfill. So please Woolwich council stop lying by telling citizens that heavy duty industrial wastes from numerous local industries didn't go into our in town landfills. They went in and they currently are slowly going out.

Wilf Rulansd, hydrogeologist, is not my favourite person. He's got a big mouth when backing a party or two within a public consultation body on matters that are none of his business. His business as a consultant is to ALL the members of the group he is representing, not only to his buddies more closely tied to Council. Furthermore he is not as firm as he should be when being bafflegabbed and deceived by the likes of the MOE and Chemtura's (Uniroyal) consultants. A little more backbone then and a lot less inappropriate nerve and input regarding his clients' internal disagreements.

Regardless of all that, Wilf did write an interesting report to APT back in the day. In the December 18, 1989 "Apt Remarks" he advised that "It is unlikely that Uniroyal is the only source of groundwater contamination, but there is almost nothing known about the extent of contamination off the Uniroyal property." He further added regarding the presence of NDMA and cyclohexylamine in the south wells that "It seems unlikely that Uniroyal is the source because the Uniroyal monitoring wells seem clear of these chemicals. Furthermore, it is unlikely that these chemicals would appear alone in the well water if the source were Uniroyal."

Shortly afterwards NDMA was (conveniently) found in monitoring wells near Uniroyal. Nevertheless Wilf's observations and conclusions speak volumes.It never made sense that serious soil and groundwater testing did not occur at multiple sites throughout Elmira including industrial sites and former landfills. This was because MOE/Uniroyal deals were in the making to save Uniroyal money and the MOE "face". They were already being roundly condemned. Imagine if it was shown in 1989 or 1990 that due to MOE negligence and incompetence that there wasn't one source of drinking well contamination but half a dozen or so. The opposition from the MOE concerning investigating Varnicolor only adds to this scenario. The MOE had to be publicly humiliated through 1990 to get a shallow groundwater study. They promised including in a Control Order to do a deep study. It has never happened. Plus they have studiously avoided sampling for NDMA on the Varnicolr site for the last thirty years while still pumping & treating and remediating the site to this day.

SECOND (& THIRD & FOURTH) SOURCES OF ELMIRA'S CONTAMINATION

This is likely the most significant reason that local politicians, M.O.E., Region and others prefer some local environmentalists over others. The ones they prefer are into the "Let's make a deal mode" whereas I never have been. Deals that exclude the public interest and or intentionally deceive the public I will not tolerate. Hence while not all our local councillors will have been let in on the big scam involving the shutdown of all our municipal wells nearly thirty years ago, a few of the more "reliable" ones will be. They will know that the Region and the Township went along with the October 7, 1991 sweetheart deal between Uniroyal Chemical and the Ontario Ministry of the Environment. Above and beyond the Indemnity given to Uniroyal, both parties agreed to the fiction that Uniroyal solely was responsible for the contamination to the municipal aquifers here in Elmira. Solely responsible as in solely responsible not just for NDMA but for chlorobenzene and all the rest which easily would be another twenty chemicals and or solvents at measurable concentrations. The first crack in Uniroyal and the M.O.E.'s armor occurred in 2000 when Uniroyal started yelling for financial assistance from Nutrite (Yara) due to ammonia contamination in the municipal aquifers.

The Elmira Independent published the following story on October 21, 2009 titled "Second source of contamination: Marshall". Gail Martin of the Independent reported on my Delegation to UPAC on October 5, 2009 at which meeting I indicated groundwater evidence in the south end of Elmira that was inconsistent with the version of Uniroyal as the sole source. I named both NDMA and chlorobenzene as having concentrations at various wells far in excess of upgradient concentrations ie. closer to Uniroyal. These wells included CH38 near Sanyo Canada on the corner of Industrial Drive and Oriole Parkway. While the Independent did not quote my naming of Borg Textiles and Varnicolor I believe that I did. Borg I gave likely credit for the chlorobenzene and Varnicolor for the NDMA. Interestingly two years ago, Neil Thompson of the University of Waterloo, on contract to Chemtura (Uniroyal) publicly advised that there was an excess of 1,300 kilograms of chlorobenzene in the Elmira Aquifers that could not be explained. In this case I was only seven years ahead of the experts. This will eventually all come out although most of the guilty parties will either be dead or certainly retired. They should have all been charged and convicted for their coverups and collusion especially between the M.O.E. and Uniroyal Chemical.

COMING BACK TO THE M.O.E. REVIEW LETTER OF JUNE 13,2018

I posted here about this letter this past Wednesday. There are some additional comments required. The main thrust of the 2017 Canagagigue Creek Investigation was to provide data and support for an upcoming bastardization of the Risk Assessment process which was also done in 2004. That human health and ecological SSRA (Site Specific Risk Assessment) however was solely in regards to the Uniroyal/Chemtura property. As a highly informed albeit non professional I can advise that speaking in the vernacular, the SSRA was a glorified piece of horse crap. Now we did have a professional PhD in Biology who examined, researched, and questioned the process from start to finish. Dr. Henry Regier even went so far as to travel to Hamilton to talk to the "expert" bureaucrats involved. He wrote a number of reviews and comments about the SSRA as practiced here in Elmira and no he did not say that it was a glorified piece of horse crap. I still have his reviews and comments and I can assure you that his professionalism and focus on facts and proper process and procedures are second to none. He much more smoothly and nicely, albeit very strongly, came to similar conclusions as I did regarding the first SSRA done here by Uniroyal/Chemtura and their fellow travellors. Now we're getting a second one by the same folks who brought us their original odourous psuedo science. Aren't we lucky?

The M.O.E. would like Lanxess to do additional biological investigations this summer in the Canagagigue Creek. Presumably this will mean fish although it could certainly mean a whole lot more than fish as well.

The M.O.E. in their letter have pointed out that the report issued a few months back was simply raw data with no evaluations of it included. Many specific questions need to be answered in the evaluations included in the final report.

Page 3 of the M.O.E. review has an example Table provided by the M.O.E. The data however is quite eye opening. It shows Dioxin/Furan Soil & Sediment results at various locations in the creek by depth. Five out of the six locations have their highest concentrations of Dioxin/Furans at the deepest depth tested and the sixth one has its highest concentration found at the second deepest sampling point.

There are a number of errors in the report by GHD on behalf of Lanxess. I used to complain about the reports done by CRA being riddled with errors of one type or another. The good news is that GHD are carrying on in the same fine tradition and it is encouraging to see that they also appear unable to consistently match text to figures and to make other typographical and amateur (unedited?) errors.