Tuesday, April 9, 2019


To say that this report is challenging is an understatement. I have been working diligently on it as in hours per day most days since I received the hard copy from Woolwich Township (Thank you Lisa). This work has been onerous including setting aside other ongoing retirement projects, hobbies, and even some family time. I respectfully suggest that even professionals in the field who are working on employer ordered projects all day would be very hard pressed to either be willing or able to spend the time on this report that I have.

It is my opinion that these conditions are intentional both from the standpoint of Lanxess and the Ontario MOE (MECP). I would remind you that I have spent over the last thirty years time studying the 1966, 1995-97, 2012, 2013, 2014 and now this 2017 sampling report regarding the Canagagigue Creek. The number of criteria both for soils and for sediments are staggering when you look at both provincial and federal guidelines, standards and criteria. Table 2 and Table 8, ISQG, LEL, PEL, SEL, Bgnd, for even an incredibly scoped and reduced parameter list of only DDD, DDE, DDT, and dioxins/furans (TEQ), requires constant care and attention.

Then if you begin to include typos and other errors or omissions in this report especially in the tables between pages 19 and 24 in the text it makes understanding even more complex. Further omissions include listing some but not all of the numerical values for various criteria. For example please advise me why SEL (severe effect level) criteria seems so difficult to find in this report. I have found it on-line but I will say that both in the Tables at the back of the report (i.e. Tables 3-11) as well as the tables between pages 19 and 24 it appears to be missing in action.

I have previously mentioned ridiculously high detection limits and their reducing effects on both detections and criteria exceedances for sediments in the creek in all reaches. Those high detection limits are also used in creek bank soils and they reduce detections and exceedances in soil samples as well albeit not to the same extent as they do so with the much lower sediment criteria.

I have also determined that those high detection limits of .020, .030, .040, .060, .110 and .114 ppm were not used in earlier soil and sediment reports from 2012, 2013, 2015, 2016 reports whether creek studies or even the soil reports on the Lanxess/Stroh property line. There is a huge smell around these high detection limits and frankly even if they are a possibly necessary result of interference from multiple other compounds in the creek such as mercury, PCBs, PAHs etc. that does not either validate or excuse the fact that they are destroying the credibility and validity of this report allegedly telling us the severity of DDT compounds and dioxin/furan contamination in the creek. You absolutely can not have detection limits from 2 1/2 times to 23 times greater than the Table 8 criteria and 20 to 114 times greater than the ISQG (interim sediment quality guidelines) and tell me that this report is either clear, helpful or credible. Frankly this entire report in my opinion is essentially a crock and useless as is. It should NOT be the basis for anything other than an indictment of the Ontario MOE (MECP) if they do not loudly and publicly condemn it for its shortcomings.

Sincerely Alan Marshall Elmira EH-Team, current and past CPAC member, past UPAC member

P.S. Over the last two weeks I have consulted with various professionals in in the fields of Biology and Chemistry with credentials varying from MSc. to Phds. Terms they have used to describe this GHD March 2019 report include "kindergarten" science and "Cargo Cult" science.

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