MOE REVIEWS 2017 EAST SIDE OFF-SITE INVESTIGATION

There is both good and bad in this review by the recently renamed Ministry of Expanded Corporate Pollution (MOECP) otherwise known as Ministry of Environment, Conservation and Parks. One of the goals with split samples was to ensure the accuracy of GHD's sample results. GHD failed, at least with their Dioxin results. Two sample areas in particular were a problem namely SS17C and SS18B. The measured Dioxin TEQ (Toxic Equivalency) by the MOE was higher than the applicable criteria whereas GHD on behalf of Lanxess measured concentrations of the same samples as below the criteria. This is very bad because once I or the public no longer even trust the supposedly accredited labs doing the analyses, then it's game over for the company and their consultants. Or in the alternative the labs have done a good job and the taking or mixing of samples was fudged.

Page 2 makes reference to former gravel pit GP1, allegedly south and west of the high diagonal strip of land in Lanxess's south-east corner. Interestingly, contrary to Jeff Merriman's comments to CPAC that the further north RPE pits were intentionally breached to allow contaminated liquids to flow southwards into GP1 1 & 2; this report states that it was "seepage and overflow" which caused waste water to flow southwards into these former gravel pits. This is not the first time that I have seen attempts by Lanxess to distance themselves from Chemtura/Crompton/Uniroyal personnel. Of interest is that Dwight Este also seems to be gone/transferred? No loss to the citizens of Elmira with that pair out of Elmira.

The reality is far more likely that the original map in the 1985 "History of Uniroyal Waste Disposal" written by A. Ralston, Wayne Jackman (MOE)and Tony Smith (GRCA) is the accurate one. It has GP1 located on the north-east side of the high diagonal strip of ground. This strip of ground runs from the north-west direction towards the south-east. If this is the case then the higher concentrations of DDT and Dioxin/Furans are far more likely to have run in a south and east direction through GP1 and over the border with the Stroh farm and then into the Stroh Drain. Lanxess and Chemtura dearly want to cover up this embarrassing and illegal fact.

The MOE point out that Table 2 criteria may not be appropriate for the soil samples taken at SS20 and SS21 on the Lanxess property because they are within 30 metres of the Stroh Drain. Table 8 criteria are 7 ppb. versus Table 2 criteria of 13 ppb. GHD measured SS21 as having 6.97 ppb which is one hell of an outstanding coincidence to my mind. Regardless the MOE measured the same sample as being at 10 ppb. which exceeds Table 8 criteria although not Table 2.

Another interesting point is that SS20 is sampled entirely on the high ground.This why its' neighbouring location (SS21) has higher concentrations of Dioxin/Furans as it is in the lower elevation area where overland water flow is more likely.

While there is good news in this belatedly delivered report to me; nevertheless the bad news is that the MOE have accepted the basic bullshit premise that surficial soil samples only 5.9 inches deep are acceptable for Dioxin and DDT sampling. As always you will never find what you refuse to test for which is Dioxins/Furans, DDT and more at depth, carried there by massive solvent concentrations in Uniroyal waste waters.