Thursday, April 5, 2012


Man these guys haven't lost a thing. Tewnty years plus in reading reports from Conestoga Rovers (CRA) and they are still the masters. Their latest report is titled "Former Gravel Pit Area Investigation", March 2012. It refers to the Dioxins and DDT primarily that is in the south-east corner of their site, in and above the water table and extremely close to Canagagigue Creek. Their Figure 5.1 is a good example of why I chose the above title. A good debater can shift or channel a debate away from his weak areas and toward his strengths. Similarily a good consultant, in a report showing absolutely horrendous contamination of the worst toxin known to mankind (dioxin), can do the same. CRA are working very hard to minimize the extent of cleanup and hence the money expenditure by their client Chemtura. Therefore it is crucial to misdirect the readers. Figure 5.1 is in black and white except for yellow highlighted areas which show "Exceedance of Both Ecological And Human Health Based Cleanup Criteria". This information might be of the significance that the highlighting purports IF the Ecological Criteria were lower than the Human Health Criteria, but they are not. First of all there is only an Ecological Cleanup Criteria for Dioxins alone and it is thirty times higher than the Human Health Cleanup Criteria. Therefore it is nothing more than a red herring. Are we seriously cleaning up this site for the benefit of the shrews that CRA care for or are we concerned about human health? I'm sure it's all just a coincidence but the focus on areas that exceed BOTH the very high Ecological Criteria and the Human Health Criteria are all in GP1 and GP1 only. This red herring focuses attention (and they hope cleanup) on one much smaller area than the whole south-east.

So let's back away from the Ecological and focus on the much lower Human Health Criteria. But this time NOT just Human Health Criteria for Dioxins. CRA managed this by including the Ecological Criteria which just so happens to only apply for Dioxins not for DDT. There is no DDT Ecological Criteria on this Figure. Now if we look at the Human Health Criteria for BOTH chemicals, lo and behold every single test pit and data point in both GP1 and GP2 as well as the rest of the south-east area EXCEEDS the Human Health criteria. It exceeds the Human Health Criteria for BOTH Dioxins and DDT. Now that is the data that should be highlighted on this Figure (5.1). Go figure!

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