MINISTRY OF ENVIRONMENT CREEK STUDIES (the "Gig") ARE SKETCHY

Partly they are poorly written. This I pointed out to M.O.E. Biologist Mike Spencer back in 2012 and 2013. He came to CPAC to explain what he had done in these studies examining Dioxins/Furans and DDT in the Canagagigue creekbed sediments and floodplain soils. Terminology and definitions were inconsistent from report to report. For example I've lost count of the times in these numerous reports (1996, 2012, 2013, 2014 & 2015) when "sediments" and "soils" have been used interchangeably and confusingly. Also I have seen conclusions stated by the M.O.E. in these reports that I feel are not well supported by the data. For example they state that the deeper sediments in the creek have higher concentrations of contaminants. This is at best a generalization as in fact there are a number of contrary examples. Scientific consistency is a problem throughout as well. Many sediment samples go from 0-10 cm and then 10 to 20 cm only to have the next sampling round be 0-12 and 12-24 cm. for example. That is not scientifically rigorous whatsoever.

Sample locations also vary over these studies. Any study allegedly comparing data over time should have as much as possible other variables consistent. Hence DDT sampled at Station #21 in the creek sediments should use the exact same location for each and every different sampling round over the years. This has not occurred. Station #21 started off downstream of the New Jerusalem Rd. bridge in 1996 then moved upstream. Then it changed from one location to three different ones being sampled albeit close together. A skeptic could easily conclude that the samplers realized that a nearby location consistently had much greater deposition of sediments on an ongoing basis hence they moved to where they knew they would get higher concentrations of DDT and Dioxins all in the hopes of minimizing the eventual dollars Chemtura needs to spend to "clean up" the creek. This is done via a sampling bias that magnifys the number of concentrations of toxins requiring cleanup closer to the Chemtura site and minimizes the concentrations found downstream which exceed the applicable criteria. Of course when citizens are dealing with an inherently dishonest and corrupt M.O.E. these doubts are exacerbated.

The number of sediment sampling locations has always been problematic. Station #21 is located at New Jerusalem Rd., Station #22 at Northfield Dr. and Station #23 at Jigs Hollow Rd.. In other words we have but three sediment sampling stations spread over a creek distance from Chemtura to the Grand River of over 7 kilometres (5 miles). Making the huge and unrealistic assumption that these three sites are representative of the whole seven kilometres of creek is sketchy at best. Then when we look carefully at the amount of sampling for the two furthest downstream we find that they have been sampled far less than Station #21. Station #21 was sampled in each of the five sampling years. Stations #22 and #23 only in 1996 and 2014. You of course will never find what you do not look for. Finally think about this. If we assume that these three sites are representative of seven kilometres of creekbed then we must understand that the entire creek is contaminated not just the miniscule area around each sampling location. Hence the entire creek needs to be cleaned up.

Suggestions that both Dioxins and DDT are at higher concentrations closer to Chemtura are borne out at some locations, sometimes. Unfortunately they are also contradicted by the data sometimes. DDT for example back in 1996 was found at the highest concentrations in the sediments just downstream of Regional Rd. #22 (Station #22). It was also found at the highest concentration in the floodplain soils upstream of Station #22 albeit closer to Stn. #22 than #21. Similarily Dioxins were found at the highest concentration in floodplain soils upstream of Station #22 and the second highest of these ten sample sites was upstream of Station #23 midway between Stn. #22 and #23. Dioxins were also found at higher concentrations in 1996 in the creek sediments at Station #22 and #23 than at Stn. #21. All this begs the question as to why the sampling focus on Station #21 since then unless it is to simply be able to sell a small cleanup to Chemtura and to bamboozle the public.

Sampling bias also includes what parameters are tested for. Dioxins and DDT have been relatively consistent in their sampling. The "dirty dozen" pesticides from the Stockholm Convention have not. Endrin, aldrin, BHC, heptachlor, endosulphan, chlordane etc. tested for in 1996 have not been tested for since. *** [Oops! 7:08 pm. They weren't tested for in 2012 and 2013 but were sampled for in 2014 and 2015] My bad. Similarily PAHs (polychlorinated aromatic hydrocarbons) were tested for in 1996 and again but once recently. PCBs have only had a few types tested for and found twice in the creek. What about all the others? What about testing for them as often as Dioxins and DDT? All of these sampling biases and failures serve to minimize the human and environmental health hazards in the creek thus allowing the M.O.E. to order (ha! negotiate) a much smaller cleanup.

In the first paragraph I had referred to the M.O.E.'s claim that the concentrations of contaminants are higher in deeper sediments. They also now are publicly advising downstream landowners that these deeper sediments are not biologically available to wildlife and humans. Both these statements are not borne out by the facts. There are many results in both the sediments and the floodplain soils where shallower samples are either higher than deeper ones or at worst extremely close in concentration. Perhaps another significant factor (variable) might be the time of year that sediment samples are taken. Again however the M.O.E. have not been rigorous in keeping their sampling dates consistent. That said what used to be the biggest flooding time of the year namely the spring freshet may have been supplanted by climate change induced more vigorous storms throughout the year. Regardless one would expect that heavier rain events would result in greater flushing of sediments and greater mobilization of deeper sediments along with their being transported downstream and into the Grand River.

I have found one striking (to me) fact while studying this data. To my surprise flooddplain soils generally appear to have much higher concentrations of both Dioxins and DDT than do creek sediments. At least in the original M.O.E. Jaagumagi and Bedard study (95-96) they did. From that point on things get confusing courtesy of the M.O.E. apparently using the same alphanumeric descriptions for Floodplain (FP-1,2,3 etc,) SOIL locations AND for Floodplain SEDIMENT locations. What the bloody hell! This refers back to my first paragraph where I referred to Soils and Sediments terminology apparently being used interchangeably. Well maybe they aren't. I believe I've just had a small epiphany. This may well be the M.O.E. intentionally or possibly stupidly muddying the waters so to speak. Keep in mind I believe I raised this issue with Mike Spencer (M.O.E.) regarding the 2012 study. Only three Floodplain sites were sampled for soils namely FP-1, FP-5 and FP-6. FP-1 appeared to be tested for Sediments rather than soils which was why I asked Mr. Spencer what was going on. His answer was inadequate and unclear, whatever the reason. Then there were no Floodplain sites tested in 2013. Lo and behold the 2014 study also seemed to be conflating ( mixing up) Soils and Sediments in reference to what had been Floodplain Soil locations namely FP-1,2,3,4 etc.. Also keep in mind that by the time we received the 2014 results (Sept. 2015) Mayor Shantz and Councillor Bauman had removed CPAC and myself intentionally from being able to either speak or ask questions at public meetings involving Chemtura or the Ontario M.O.E.. Anyhow as of now I believe that they are indeed sampling sediments in the creek while using Floodplain names ie. FP-1,2,3 etc.. Talk about a bait and switch.

Hence there are three issues. Firstly if indeed Floodplain Soils downstream have not been tested for since 2012 but rather those locations have been changed into sediment testing locations then this is a huge sampling bias against floodplain Soils. Those downstream results were much higher for both Dioxins/Furans and DDT than the sediment results in the 95-96 sampling. Therefore by eliminating them and focusing only on sediment results downstream, the M.O.E. have artificially once again focused attention only upon lower concentration sediment sites probably in an attempt to pretend that the downstream is not a problem. Secondly if indeed as was clearly demonstrated in the 95-96 sampling; the downstream Floodplains are much more contaminated with Dioxins/Furans and DDT then they are also likely much more contaminated with PCBs, PAHs and Persistent Organic Pollutants (dirty dozen etc.). Finally (thirdly) this raises the question. How can floodplain Soils all the way down the creek have higher concentrations of contaminants than the creek which is the initial source to the Floodplain soils? The answer may be extremely troubling. The bulk of the contaminants via suspended sediments are constantly travelling down the creek and discharging into the Grand River. The Floodplain soils are only "enriched" after flooding in the creek has carried contaminated suspended sediments over the creekbanks and deposited them on the floodplains. In other words the creek sediments are constantly being resuspended into the water column during high flows and moving all the way down the creek. The Floodplain soils on the other hand are not being either eroded or resuspended nearly as readily or often. They are more stable plus they are not nearly as often submerged or in contact with heavy flows of water as the sediments in the bottom of the creek are.

This may be why Dr. Richard Jackson has been so insistent upon suspended sediment testing in the creek and why the M.O.E. have been so reluctant to do so. If indeed the bulk of the contaminated sediments are constantly being transported downstream then that magnifies the obvious size of the problem of their ongoing discharge from the Chemtura site as they are constantly being refreshed and redeposited in the creek . Secondly it puts in perspective the fact that our heritage river, the Grand, may well be displaying "adverse effects" from the mouth of the Canagagigue Creek for who knows how far downstream. This may be a can of worms that the M.O.E. do not want to open.

These reports spread over five years, as the final complete report is due in February 2017, I believe are intentionally obtuse, difficult, poorly written and misleading. Dr. Jackson likely could have cut through the final report due next spring but he is retiring at the end of December 2016 and we will have a new Chair of TAG. Meanwhile yours truly and CPAC are intentionally excluded from full participation in both TAG and RAC meetings. No pointed and embarrassing questions for Chemtura, GHD or the Ministry (M.O.E.). No verbal Delegations to TAG and but four times a year can we address RAC. This has been the purpose of getting rid of CPAC as full partners and stakeholders in this very public environmental disaster. After Dr. Jackson is gone there will be exactly zero stakeholders with even a tiny fraction of the knowledge, expertise and history as CPAC and myself have.