Saturday, April 14, 2012


I have now completed reading Conestoga Rovers March 2012 report titled "Former Gravel Pit Area Investigation". I am now slogging through the much thinner "Remedial Options Evaluation". It is much less technical and objective and much more subjective. Hence I'm finding it difficult going without the use of rubber boots and a shovel.

There are a number of items with which I take issue. First of all the consultants remind us that much of where they are now is based upon their 2003 HHRA or Human Health Risk Assessment report. They appear to be speaking of this report as if it had some universal credibility and recognition. It did not. It was riddled with errors and inconsistencies and unrealistic assumptions. It was presented to CPAC and heavily criticized most strenuously by Dr. Henry Regier and myself. There were other CPAC members who also criticized it. Henry went so far as to make a trip to Hamilton to discuss his technical concerns and questions with Ministry (M.O.E.) bureaucrats. Henry has written repeatedly about the response he received and that it was not satisfactory. I wrote numerous criticisms as well which were essentially ignored or deflected.

This Remedial Options report also appears to make a big deal out of groundwater concentrations which are below the Ontario drinking Water Standards (ODWS). This is a deflection as very few to zero humans are directly drinking water from the Canagagigue creek. It is also much more significant that DDT and Dioxins are bioaccumulative. Thus even very small concentrations in water for example that are ingested move up the food chain and magnify over time.

CRA conclude that the only receptors to their Dioxins in the south-east corner are shrews and human trespassers. This is nonsense. Both Dioxins and DDT are found either in creek sediments or floodplain soils all the way down the creek as far as the Grand River, five miles away. These floodplain soils are grazed upon by cattle who uptake the DDT and Dioxins and transfer them into their milk. From there we get to enjoy Chemtura's pollution first hand.

Conestoga Rovers (CRA) repeatedly claim that their Dioxins and DDT do not leach into groundwater. To date I see zero evidence backing this claim other than their bald assertion. The evidence points to low level Dioxins in the groundwater and the flow is uncontested directly to the creek. Then there are Dioxins downstream in the creek. Maybe there will be a surprise twist however after decades of reading CRA's literature, usually the plot and narrative fizzles out before the end.

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