LAST EVENING'S TAG MEETING

We had a grand total of twelve people present at the Technical Advisory Group meeting. That would include six TAG members and Chair, the Township's Support Specialist Lisa, and then five people in the audience. One was a spouse of a TAG member, two were Documentary filmmakers who both appeared in a Waterloo Region Record story yesterday describing Lanxess's attempts to sabotage their Documentary on Elmira's Water Crisis and finally two current members of CPAC.

Both chair Tiffany Svensson and CPAC and TAG member Dr. Sebastian Seibel-Achenbach mentioned that to date Lanxess and GHD, have not responded appropriately to concerns regarding the "Gap" area along the Lanxess/Stroh border. Sebastian also pointed out that GHD's responses and comments regarding off-site groundwater contamination issues are all focused on groundwater in the northern half of the eastern border. The guilty parties are studiously avoiding both the "Gap" and the Stroh Drain and how this man made Drain diverts both surface and groundwater eastwards and southwards eventually discharging into the Canagagigue Creek further downstream.

That said the Ontario MOE (MECP) have advised Lanxess in writing that they are not satisfied with their east side groundwater investigation to date. The MOE are recommending a Supplemental groundwater investigation because the swales and drainage ditch influence have not been properly investigated. We are advised that a final report on the Creek is due on the Fourteenth of December which really gives GHD no time to improve it through more investigation.

Susan Bryant asked Ms. Svensson about money being made available to TAG to get professional assistance regarding the threatened upcoming Risk Assessment. Ms. Svensson suggests that the Township are fine with TAG getting technical support. The problem I see is throwing good money at a proven bad idea, namely Site Specific Risk Assessment (SSRA).

TAG discussed some hypothetical upcoming Application Process for new TAG members. With Sandy as mayor and Lanxess happy with barely meeting the public (two or three citizens only), three to four times a year, don't count on any significant changes. Also the so called changes in the Terms of Reference will be given lip service only as all the other Terms of Reference for UPAC and CPAC have been over a period of decades. They are a joke and simply a make work project for Township staff to give the appearance of updating/improving public consultation.

TAG members provided updates on the September and October Lanxess Progress Reports as well as GHD responses to the MOE in regards to the groundwater report and last year's Annual Monitoring Report.

Sebastian teed me up for some interesting clarifications and comments. These included the complete lack of work being done as promised this fall on excavating small quantities of contaminated soil on the Stroh farm, along the Lanxess property line. Sebastian also asked me about the decades old and never ending comments in the Monthly Progress Reports to the effect that there are no new developments in remediating the former lagoons/ponds in Lanxess's south-west corner namely the RPW (retention ponds west) ponds. I advised that DNAPLS had gone through the bottom of the ponds decades ago and were still there happily, slowly dissolving for decades more into the on-site groundwater. I also clarified that ten chemicals during September and October of this year have higher concentrations at the upstream end of Lanxess than the downstream end. Likely the Bolender Park Landfill combined possibly with bank erosion, as suggested by Vivienne Delaney, is responsible.

Chair Ms. Svensson was uncomfortable with my input which in most honest public consultation venues would be bizarre. RAC/TAG and Lanxess however are not honest public consultation venues. This is not the fault of Chair Svensson as she was hired by mayor Shantz and is taking her direction from that woefully uninformed and biased individual who seems to be taking her direction from Lanxess Canada with a side order of MOE sour grapes thrown into the mix.

LANXESS SAYS JEFF MERRIMAN'S INTERVIEW IS NOT RELEVANT

Bullshit Alert!!!!!!! Lanxess Canada (part of Bayer) who bought out Chemtura Canada in 2017 will not give approval for release of film footage involving former long time employee (ie. decades) Jeff Merriman. Mr. Merriman up until his retirement was the manager of environmental remediation for Chemtura Corp. and Crompton Co. before it. His decades of work on the Uniroyal site, where I believe he also worked, was as a professional, credentialed card carrying apologist for his employers. Lanxess is denying approval for the release of film footage of Mr. Merriman speaking to two filmmakers on the Chemtura property in regards to long overdue cleanup of the site, the Canagagigue Creek and the Elmira aquifers. Lanxess claim, according to a story in today's Waterloo Region Record, that Mr. Merriman's
interview is not relevant "because he is no longer an employee of the company." Bullshit! He was the face and the voice of the company, including at the time of filming, for close to twenty-five years.

The article in today's Record is titled "Elmira water Documentaries in limbo." I personally have seen both Documentaries, Bonita's as well as Michael's. They are both very good possibly bordering on excellent. My preference was for the longer one at the time although with recent edits I do not know. Local illuminaries such as recently, thank God, retired Ken Seiling and pretend mayor Sandy Shantz are included with speaking parts. More importantly are numerous local citizens who generally know what they are talking about unlike the two politicians. CPAC (Citizens Public Advisory Committee) members are in the film including Dr. Dan Holt, Vivienne Delaney, Dr. Sebastian Seibel Achenbach, Rich Clausi I believe and myself. Maybe Graham Chevreau and Ron Campbell as well although I'm not sure. Dr. Richard Jackson, former TAG (Technical Advisory Group) Chair was also interviewed.

It is disgusting and shameful that Lanxess Canada are unwilling to give the O.K. for the use of interviews of Jeff Merriman who vigorously and sometimes less than scrupulously honestly defended the often indefensible position of his employers. Say what you will about Jeff he was a good and loyal employee and that comes through clearly in these documentaries.

REMINDER

REMINDER: Tomorrow evening at 6:30 pm. the Technical Advisory Group meets in the Dodie Hummel room immediately beside Woolwich Council Chambers. Discussions will include the Groundwater study done on the Stroh property to the immediate east of Chemtura/Lanxess. As of the July 13, 2018 critique by the MOE (MECP) there are a number of concerns including a lack of monitoring wells , a lack of coordinated monitoring (ie. on & off site simultaneously) and a lack of determination of effects of the contaminated groundwater (NDMA, multiple chlorophenols) upon receptors whether human or otherwise. For me this also includes the effects of contaminated groundwater upon life in the Stroh Drain which is the surface water receptor of much of this groundwater.

Discussions will also include the Off-Site East Side Investigation by GHD on behalf of Lanxess. To date it has at best been superficial. All attempts possible have been made to properly avoid soil sampling in the "Gap" area despite both myself, CPAC and TAG members all requesting it be done. It is very likely that this area as well as the downgradient Stroh Drain are DDT and Dioxin/Furan "sinks" (ie. those Persistent Organic Pollutants (POPs) have collected there and slowly migrate during flood or heavy rain events).

The East Side Interceptor Trench was brought to both TAG and RAC's attention back in September of this year. At the moment I do not see it on the Agenda. This potential criminal negligence issue needs to be properly addressed now and a long time ago.

CHICKENS COMING HOME TO ROOST - WITH PERHAPS A DROP OF BLACKMAIL FOR FLAVOUR?

Technical Experts Meeting - definition- "a clever way to exclude the general public, the informed public, and to cheaply reimburse Lanxess's friends and allies for favours rendered and behaviour acceptable to the multi convicted, truth challenged polluter"

There was a "Technical Experts Meeting" on September 5, 2018.The meeting was to further discuss the results of the raw data obtained from GHD's 2017 Creek Investigation and to follow up on the March Technical Experts Meeting, discussing the same issues. Several issues were discussed including serious problems with the so called "background" site in the creek which ridiculously is located at the north end of the property by the bridge on Church St. which crosses the Canagagigue Creek. It is also suggested that more "...sampling of the Creek sediments up stream of the site and in Shirt Factory Creek and Landfill Creek may need to be completed."

Also of great interest to me is the significant differences in the clam tissue concentrations from stations located on the west side versus those on the east side of the creek. This could represent the differences between pumping and treating on the south-west corner (i.e. the Upper Aquifer Containment & Treatment System) versus the alleged Interceptor Trench running most of the length of the east side of their property.

The chickens coming home to roost for Woolwich Township could be the incredibly short sighted decisions to build municipal landfills both in the floodplain and along the Canagagigue Creek. No less than three of them exist in Elmira namely the Bolender Landfill, the First St. Landfill and the former M2 now located on Lanxess's south-west side. Of course there is also the former toxic waste dump known as Lot 91 across Landfill Creek from the First St. Landfill. This unremediated site was sold by the Township to Severin Argenton of Varnicolor Chemical infamy. Uniroyal/Crompton/Chemtura certainly in the past have not indicated being burdened with scrupulous adherence to principles, ethics, morals and sometimes even environmental laws of the land. Would they be capable over the decades of insisting upon municipal cooperation in exchange for their silence on the municipal, environmental liability posed by these unremediated toxic landfills that don't even have basic leachate controls?

Would Uniroyal and successors even insist upon things like which volunteer citizens they want appointed to CPAC, RAC and TAG in exchange for their not pushing to have these leaking, toxic waste sites remediated at Township expense? Certainly it is much easier for Chemtura/Lanxess to have "friends" of an amenable and flexible nature on these oversight committees than proven, informed citizens unwilling to be co-opted. Might Chemtura/Lanxess's influence even explain Woolwich's bizarre heads in the sand response to methane issues in and around the Bolender Park Landfill?

LANXESS OCTOBER PROGRESS REPORT

It's just so blatant that pumping and treating just aren't a priority with Lanxess any more than they were with Chemtura. "The PW4, PW5, W5A, W5B, W6A, W6B, and W9 average daily pumping rates were less than their Target Average pumping rates in October 2018...." What then follows is a list of the most recent mechanical, electrical and or computer problems plaguing Lanxess's hydraulic containment systems. Keeping it in perspective however, the two wells with the historically highest pumping rates, namely E7 and W3R, are holding their own. It's all the others, both on-site now as well as off-site, that are not operating in an acceptable manner.

That's right, it's not just the off-site cleanup wells that are crapping out, it's the two on-site Municipal Aquifer (MU) wells, PW4 and PW5 that are slipping. This is not good. Years ago Jeff Merriman of Chemtura advised CPAC that with the removal of on-site pumping wells PW1 in their north-west corner and PW3 in their south-east corner that the on-site pumping would actually increase to 6.0 litres per second (l/sec) with the addition of PW5 to PW4 pumping. That of course has rarely happened. The current on-site Target pumping rate is a skinny 4.7 l/sec although actual pumping rates of 5 l/sec are common. In October 2018 they only managed 4.0 l/sec.

Appendix C in this monthly Progress Report is again a major concern. Surface water (ie. the Canagagigue Creek) has a number of toxic chemicals with higher in stream concentrations downstream as the creek flows through the Lanxess property. While this is not good it is however unfortunately "normal". What isn't normal are the number of toxins, just like last month, being found at the upstream end of Lanxess with higher concentrations than downstream. This indicates that as everybody has known for the last thirty years that sampling beside the Bolender Park Landfill and pretending that that location is upstream or background concentrations is ridiculous. Uniroyal Chemical and Varnicolor and others all used the Bolender Park Landfill and every other municipal landfill they could up into the 1980s (Woolwich Landfill on Seiling Dr.), north of Elmira.

The chemicals with higher downstream concentrations according to Table C.2 are MBT, BT, NDMA, NMOR, Chlorobenzene, Toluene and Xylenes. The chemicals with higher upstream values are six different trichlorophenols, two different dichlorophenols and cholorophenol along with three different cresols and phenol.These are all typical Uniroyal and even Varnicolor Chemical solvents although the Mercaptobenzothiazoles (MBT) and Benzothiazoles (BT) are Uniroyal signature chemicals.

I have to wonder and speculate here. How likely is it that suddenly after decades of monthly reporting that these negative changes in surface water are actually occurring? With a new company (Lanxess) and new consultants sort of (GHD) is it possible that the method of calculating average mean concentrations for example has changed? In other words is it possible that GHD are just a little more honest than CRA???

CANAGAGIGUE CREEK CLEANUP - ONGOING DISCOURSE

Quite frankly I suspect that if literally the public had a dollar for every word that Uniroyal, Crompton, Chemtura, Lanxess, the Ministry of Environment (MOE or MECP), Conestoga Rovers (CRA) or GHD had ever written about the Canagagigue Creek that it would be cleaned up by now. Hence the title above. Talk is cheap and so are "investigations" and reports. Real Cleanup not token cleanup is expensive.

On November 19,2018 Lou Almeida of GHD, on behalf of Lanxess Canada sent responses to Jason Rice of the MOE regarding the MOE's purported June 13, 2017 "..." Canagagigue Creek Draft Report Review Comments." I say purported because as slow as GHD are I don't think that they waited a year and a half to respond to the MOE and I also don't believe that the MOE sent in their comments to the 2017 investigation and field work while the work was actually underway. Likely just another typo among millions (LOL).

My following comments are not meant as a formal or extensive critique. They are simply hitting a few highlights and concerns I have noticed in GHD's Nov.18/18 report to the MOE.

Data gaps now suddenly appear to be a huge issue for the Ontario MOE. For the love of Mike I've been telling the MOE since 2012 and every followup testing (2013, 2014, 2015,..you get the picture) that there is a huge locational bias involved in their and Chemtura/Lanxess's testing locations. When you keep testing in and around location 20 and 21 as well as the New Jerusalem Rd. bridge, of course once you've gotten the first few hits you are likely to continue to find DDT and dioxin/furans over time in the same location. Similarly when you don't test for these chemicals in 90% plus of the downstream creek, you will never find them.

A number of references in this letter and others suggests that all parties are somehow including all stakeholders in the process around the Canagagigue Creek cleanup. This is a blatant misrepresentation. Myself and the knowledgeable and informed CPAC members as well as the general public have been intentionally and maliciously excluded from the process.

The MOE have serious concerns regarding sampling of sediments where DDT and dioxin/furans are less likely to accumulate such as sediments with high percentages of coarse gravels versus finer silts and clays.

Page 3 actually states that the MOE have a concern regarding off-site source locations such as the Stroh Drain which they prefer to call "agricultural drainage ditch from 6770 Line 86". That is good news although it would be nice if they would publicly speak to that.

GHD confirm that "...natural erosion and deposition processes occur along the entire study area" in the creek and that "These natural processes are affected seasonally and temporally by significant storm events."

Dioxin concentrations in both soils along the creek banks and in creek sediments in the bottom of the creek generally are higher with depth (Table on page 4). This is huge and relevant to the Mickey Mouse investigation and promised excavations to be done before 2018 concludes. To date Lanxess have not started them.

The MOE still have concerns regarding GHD's sample collection method using a "shovel" versus the normal method of sediment collecting. The implication as I understand it is that the shovel picks up more coarse gravel than the alternate method hence lowering the concentrations of DDT and dioxin/furans as those compounds are associated with fines (ie. silts & clays) not with coarse gravels.

The MOE indicate errors later in the report (pg. 12) dealing with comparing contaminant concentration results with the wrong criteria. They also advise that there is confusion in the text (pg. 13) describing the location of sampling areas and the "reaches" #1 to #4 as defined in the initial GHD report.

There is also confusion and errors in regards to reporting MOE sediment samples as soil samples (pg. 14) and as well the MOE suggests that GHD have incorrectly stated sample depths of a number of samples (ie. 10-20 cm versus 20-30 cm.).

Page 15 makes reference to a Control Order in regards to a fish collection program. This Control Order is news to me however I am currently making inquiries about it.

I have a general comment to make regarding GHD's responses to the MOE's concerns and criticisms. I believe that GHD's responses are generally better than their predecessors, CRA. I see some frank admissions to blatant errors that I have learned that CRA in the past would avoid. Good for GHD.

MUNICIPAL, REGIONAL & PROVINCIAL ENVIRONMENTAL FAILURES

It doesn't get much more blatant than this. Today's Waterloo Region Record has published a story titled "Kitchener will try to force sale of Electrohome site in January." This site located at Shanley and Duke St. in Kitchener has been vacant and contaminated for decades. Apparently, contrary to the vaunted method of natural attenuation, this site remains contaminated with among other items chlorinated solvents. Who knew that chlorinated solvents, also known as DNAPLs were so difficult to remediate naturally. Oh right, everybody in the industry knows that and they've known it probably for half a century at the least.

One of the contaminants is TCE better known as trichloroethylene. This is the same contaminant as dramatized in the movie "A Civil Action" starring John Travolta. It's the same contaminant which caused wide spread disease and death in the Bishiop St. community in Cambridge. It was discovered around 2005 but had been getting into homes via the basements as a gas for decades prior to that. The proper term is vapour intrusion. Has any of our authorities even tested nearby homes around Shanley and Duke St. for vapour intrusion? Nothing surprises me anymore and if the answer is no and the negligence is through the roof, nobody will be held accountable. It's the Canadian way.

Another reason that buyers even promised huge concessions are staying away from this Kitchener site could be the example set in Elmira by the Ministry of Environment (MOE). The former Varnicolor Chemical site was purchased from Phillips Environmental by a company now on site known as Elmira Pump around 2000. The owners of Elmira Pump were advised that another five years or so of operating a shallow aquifer pump and treat system would allow the MOE to give the new owners a Record of Site Condition (RSC) allowing them to sell part of the site for commercial development.They are still waiting for the RSC. Turns out that the original hydraulic containment system or pump and treat installed in 1995-96 was expected to clean up the mess within a decade. More than twelve years after that deadline they are still remediating.

It seems that the MOE may have misinformed Elmira Pump exactly as they misinformed the public back in the 1990s. The MOE at that time had Uniroyal Chemical on the hook to clean up the Elmira Aquifers. They surely didn't want Varnicolor Chemical to muddy the waters and did their best to cover up the extent of deep contamination on their property. If you were a developer today looking to pick up a bargain property with a history, would you trust any promises from the Ontario MOE?