Friday, August 23, 2019
TAG PRODUCE SERIOUS CRITICISMS REGARDING LANXESS'S HANDLING OF THE CANGAGIGUE CREEK CLEANUP
The Technical Advisory Group (TAG) have sent their review comments to Lanxess in a seven page document dated August 20, 2019. While smooth and professionally done they are forceful and blunt at the same time. TAG advise that they do not agree with the methods used to screen for Contaminants of Potential Concern (COPC). This includes 22 of 23 substances with soil exceedances that were not retained as COPCs (pg.2). On page three TAG point out that high Method Detection Limits (MDL) greater than the Table 8 criteria and/or the ISQG guidelines may have affected the final list of COPC.
Also on page three TAG point out that Lanxess's consultants GHD made an inaccurate statement in regards to a number of former waste pits being remediated and/or contained by the Upper Aquifer Containment System. Finally on this page (3) TAG remind Lanxess that the Upper aquifer is not consistently contained (Cynthia Doughty-MOE) and that toluene on site can mobilize "hydrophobic" dioxins/furans and DDT. Further north on the west side as well as the east side groundwater is totally uncontained.
Page four is excellent as well with the following: "...TAG wants to ensure that the potential pathway for impacted soil and sediment to reach the Stroh Drain and be transported via the drain to the Canagagigue Creek be exhaustively examined including confirmatory soil and sediment sampling in the Stroh Drain...".
Page five references tissue sampling done in cattle and sheep in 1999. "The tissue analysis indicated that dioxins in lamb and beef were not detected or detected at the detection limits." Well this statement begs the question as to what the criteria/guidelines are and were the detection limits above or below these criteria? That information will tell the tale!
TAG also would like to know if the indicated sediment and soil depositional areas in the downstream Canagagigue Creek will be tested for the contaminants of potential concern to ensure that they are not also hot spots (pg. 6). On the same page TAG ask whether there is a more precise method to sample sediments than using a shovel. Yes proper core samplers were used 24 times while less precise and likely to miss sediments via the shovel method was used 338 times. To me this is similar gamesmanship to sampling three quarters of the sediments with detection limits higher than all the criteria and guidelines. It is effectively useless.
The last page (pg. 7) debunks GHD's claim that "...there are currently no additional ongoing contaminant sources and impacts from the Facility to the Creek." This claim was based upon a lack of currently active seeps into the creek. TAG also ties greater concentrations at depth for DDT, DDE, and DDD to their concerns with the Stroh Drain on page seven.
I have long praised Dr. Richard Jackson's blunt and forceful criticisms if not outright contempt for the longterm gamesmanship that has gone on here in Elmira, Ontario regarding attempts at remediation and cleanup. I am growing nonetheless to appreciate Tiffany Svensson's different style and reports like this can only magnify my admiration.
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Don't hold your breath for all this to be done. As far as sampling sediments, a shovel or trowel is fine on the floodplain but a core sampler is best for within the creek in order to retain the fines. This was the methodology I used based on the USGS American standards for sampling sediments both in and out of the fluvial environment.
ReplyDeleteAlan AND Tiffany and TAG know the truth ! and the negligent parties (by NON-DISCLOSURE - AVOIDANCE and NON_ACTION) also know the truth, so it is obvious to all that Sampling and Testing and Public Disclosure of the exact spots identified as most highly suspect must follow...the only side-note is the curse that should befall the politicians who have sidestepped their responsibility so far
ReplyDeleteFor the benefit of readers: Dioxins/furans and DDT more readily are attached to fines than to coarse stone or gravel. Hence by using a shovel in the bottom of the creek, the fines flow away as the shovel is lifted thus reducing the concentrations of dioxins/furans and DDT that are found. I detect a strong and unpleasant odour around this kind of sampling for sediments on the bottom of the creek.
ReplyDeleteThe odours come out of the creek once the floor is disturbed? I haven't wanted to venture near it
DeleteMy bad. The odour I was speaking of is the "odour" of junk science or the "odour" of deception.
ReplyDelete