MORE REGARDING THE REVISED OFF-SITE INVESTIGATION WORK PLAN

On page 2 of this November 23/16 report we have an admission that contaminated groundwater could be captured by the Stroh Drain. The report also suggests that surface water flowing across Chemtura's eastern border could also be captured by the Stroh Drain. There are a couple of issues however. Firstly they use a lot of ifs as in if there is contaminated groundwater and if surface water flowed across the eastern site border. This is typical consultant and Chemtura stalling and delay. In other words reinvent the wheel each and every time. Never build upon already proven facts as these are. Also I note GHD's failure to use the same terminology as everybody else. The manmade ditch is called the Stroh Drain. It is not a drain, a tilebed , a swale or anything else.

The top of Page 3 refers to one outlier in regards to groundwater sampling. Further down they reference three different monitoring wells with concentrations exceeding their respective Ontario Drinking Water Standards. Well OW36-5 is not an outlier. Also allegedly the source of contaminants to well OW 36-5 is impacted fill. So what exactly? The entire area is one former uncontained series of waste pits and holes in the ground. Where are you not going to find impacted soil, impacted fill and or highly contaminated soil and groundwater? Yes there have been excavations and re-excavations on the east side.

GHD also claim that the Supplementary test pits produced a pattern of decreasing concentrations to the east towards the property line with the Stroh farm. Just more nonsense. There is no such pattern.

The parameters to be tested for in this tiny investigation of the Stroh farm include Dioxins/Furans and DDT. Sometimes. As limited as those parameters are it's only some of the test pits that will be investigated for both. Are you kidding me? The rationale is based upon past testing results on the Chemtura side of the border. If Dioxins exceeded the criteria then the alleged corresponding test pit off-site will only be tested for Dioxins as well. This is beyond asinine.

Page 8 has the same nonsense as was described in the preceding paragraph. Basically off-site wells will only be tested for the parameters that were found on the supposedly corresponding on-site wells. This is ridiculous and an obvious attempt at restricting detected parameters by minimizing the number of parameters beforehand.

This "investigation" follows all the tried and true deceptions and gamesmanship that has successfully been pulled for the last thirty years on this site. When will citizens ever get honest brokers in charge of these investigations and cleanups?