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.