Wednesday, April 11, 2018


The Conclusions ie. "Summary and Recommendations" are primarily on pages 22 and 23 of the 2017 Creek Report I've been discussing here for the last little while. Generally I agree with the Conclusions whereas the Recommendations have a severe odour to them. This odour is a very familiar one to those few persons who have been following the Uniroyal Chemical saga and alleged "cleanup" for decades. I would describe it as an earthy bouquet intermingled with strong tinges of rot, death and corruption.

The Sediment results state that "It is typical that:

DDT is generally consistent at the various sample depths and locations

Dioxins/Furans generally increase with sample depth at the majority of the sample locations"

COCs or Contaminants of Concern (ie. DDT & Dioxins etc.) generally are consistent or increasing with depth within areas of deposition.

Particle size analysis of samples does not indicate any partitioning of COC concentrations relative to their particle sizes

The second and third conclusions are extremely important. Neither DDT nor Dioxins/Furans have their highest concentrations at the shallowest depths tested. In fact just the opposite. The ranges for the samples taken are 0-5 cm, 5-10 cm 10-20 cm. and 20-30 cm. although some Tables bizarrely show the last range as 20- .

I would after a detailed look at Figures 6.2, 6.4, 6.6, 6.8, & 6.10 describe the first point (DDT) more as there is no obvious pattern of concentrations with depth. Indeed some samples have higher DDT concentrations at depth whereas many do not.

The Creek Bank Soil results state that "It is typical that:

DDT is generally consistent or increases with depth at the various sample locations

Dioxins/Furans generally increase with sample depth at the majority of the sample locations.

The variability in the concentrations at the creek locations and in erosional and depositional areas do not provide any consistent trends."

The first two conclusions are absolutely stunning. They are the complete opposite of what both Conestoga Rovers and GHD have stated in the past. They have long stated that DDT and Dioxins strongly adhere to soil particles and do not move downwards in the soil. They have reinforced that nonsense by taking composite soil samples from 0-15 cm in depth and studiously avoiding comparisons at depth by sampling no deeper as well as mixing their 0-15 cm sample depth together (hence composite). That is precisely what they did in their report immediately before this one namely "The Off-Site Investigation Report February 14, 2018".

In this Creek Report they have sampled much narrower ranges of depths namely 0-5, 5-10 and 10-15 cm and each sample has been separate from the deeper depths. Unfortunately they still are refusing to look for their Contaminants of Concern at deeper depths because that would only increase the cost of remediation exponentially by having to dig deeper.

The Flood Plain Soil results indicate:

"The COC concentrations within the floodplain sample areas are less than the sample locations within the creek bank and sediments.

DDT is generally consistent at the various sample locations and depths

Dioxins/Furans generally increase with sample depth at the majority of the sample locations."

I mostly tend to agree with the second and third conclusions. The first one regarding COCs I would suggest adding the phrase "generally but not all" after the word "are" and before the word "less". This also may be partially due to the greatly reduced number of samples taken and analysed from the Floodplain soils versus creek bank soils and creek sediments.

Once again finding any COCs (ie. Dioxins/Furans) at higher concentrations at depth is stunning. What is also interesting is the much greater depths tested in the very few Floodplain Soil Investigation samples versus the greater number of shallower soil samples in the creekbank soil samples. The Floodplain soils are tested down to 30 cm below ground surface. This is double the creekbank soil depths of only 15 cm. One last problem I have is actually with the third conclusion afterall. I have just revisited Figure 6.11 . It seems as if Dioxins/Furans are at higher concentrations in three of the five deeper samples. Three out of five is not exactly a large majority.

I have in a previous post indicated my disgust with the Recommendation for a Human Health and Ecological Risk Assessment. Far too much subjectivity, assumptions and mathematical voodoo. Perfect grist for professional liars.


  1. Why your last comment? What I gather from all this is a very not thought out sampling program. I have yet to see a purpose, a plan of sampling which includes how deep to sample, how many samples to obtain and where they are to be samples and most of all for water parameters. I do agree with the floodplain results as this or deposition of sediments only happen during high water events as opposed to the regular creek and bank sampling. My conclusions to this series of posts rests on one question. WHAT NEXT AND WHO PAYS?

  2. We here in Elmira went through a Mickey Mouse HHRA & ERA in 2005. It was time consuming, immensely detailed and mostly asinine. Dr. Henry Regier then and now of CPAC commented at length and in detail as to the grotesque weaknesses of Risk Assessments (ie. HHRA & ERA). These are the next step after two public meetings on April 19/18 (6:30 pm.) and April 26/18 (4 pm.) in Woolwich Council Chambers.

  3. So basically nothing further will be done after these next two meetings.