Saturday, April 14, 2018



Over the last couple of weeks plus I've complained and criticized this report for being difficult to follow and difficult to read. Some of it has been inherent to the number of samples involved (approx. 1,000) in really just two locations namely Northfield Dr. and the New Jerusalem Rd. area. Now keep in mind while GHD & Lanxess may call this three locations two of them are mere feet apart with Station 21 samples on the left side (west) and new Jerusalem on the right (east) side when you are facing north. This number of approx. 1,000 consists of multiple different samples in the same location merely deeper usually with three depths in soils (0-5, 5-10, 10-15 cm.) and four depths in sediments (05, 5-10, 10-20, 20-30 cm.) It also includes four different parameters (DDD, DDE, DDT, Dioxin TEQ). It also includes two discrete samples at each Soil location and three discrete Sediment samples at each location.

There are also a ton of samples further upstream including the Lanxess site itself and Station 20 just below the Lanxess site. Much further downstream the Northfield Dr. location has a mere 220 samples including both Soils and Sediments. There is literally miles of untested creek above and below Northfield Drive. These numbers and locations speak to both the locational bias I spoke of yesterday as well as partially to the sub-title above. Are all these samples necessary? The answer is no. Three soil samples merely separated by two inches (5 cm.) of soil is ridiculous. If you really felt the need for three separate soil samples then take them either a foot or two apart in depth. That would give you a legitimate understanding as to how these Persistent Organic Pollutants (POPs) have really penetrated into the earth. Similarly testing creek Sediments at two inch (5 cm.) intervals is silly. The deeper samples are 10 cm (4 inches) apart which is only slightly better.

Here are some of the results from testing. Northfield Dr. has 22 exceedances in total out of 96 creekbank Soil samples. These are exceedances of the Ministry of Environment Table 8 soil criteria for DDD, DDE, DDT and for Dioxin/Furans. Regarding Sediments Northfield Dr. has only 17 exceedances out of 124 samples. This much lower number is partly attributed to the Detection Limit as mentioned in an earlier post actually being higher than the criteria for total DDD, DDE and DDT.

New Jerusalem Rd. has 88 exceedances in total out of 192 Soil samples. There are 98 total exceedances out of 372 Sediment samples. Again while very high the Sediment samples are minimized by the laboratory Detection Limit being higher than the Sediment criteria for total DDD, DDE and DDT thus eliminating a number of exceedances and labelling them as Non-Detect.

Station 21 just west of and immediately upstream of New Jerusalem Rd. has 75 Soil exceedances out of 144 Soil samples. It also has 93 creek Sediment samples out of 280 samples. Just like the other locations the Sediment exceedances while high are muted due to the high laboratory Detection Limits.

Lastly I want to refer again to the sub-title of "Is it intentionally user unfriendly?". Along with the ridiculous errors in the text portion I pointed out yesterday, I was stunned to see how the Tables were organized or should I say disorganized. The Figures (6.1-6.10) list the sampling locations for creekbank soils and sediments in order from downstream right up to and including the Lanxess site. Then in the Index we see that the Tables Section is also listed in the same order. Or is it? Table 5 is listed as "New Jerusalem Rd. and Station 21 - Soil Sample Analyses". Table 6 is listed as "New Jerusalem Rd. and Station 21 - Sediment Sample Analyses". What the heck are they admitting that these TWO locations are really but one? Then when you carefully and equisitely decipher the location code at the top of each sample you find that the Tables are no longer in fact in the same order as the Figures. Furthermore all it would take is a clear darker ink heading/title indicating that the first half of Table 5 is Station 21 Soil Analyses and the last half is New Jerusalem Rd. Soil Analyses. Similarly the first half of Table 6 is Station 21 Sediment Analyses and the last half is the New Jerusalem Sediment Analyses. It too is as clear as mud.

This switcheroo is poorly marked AND it makes comparing the Tables with the Figures very difficult. After Tables 5 & 6, Tables 7,8,9 and 10 are back to being straightforward again. Surely this entire Report is sufficiently detailed and messed up (the text) not to require even more mental and visual gymnastics on the part of citizen volunteers and even outside professionals in order to follow it. If the purpose is to make this report extremely User Unfriendly then I suggest Mission Accomplished. It of course begs the question as to why Lanxess and their consultants are doing this. Intentional or simply Uncaring?

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