CANAGAGIGUE CREEK CLEANUP - ONGOING DISCOURSE

Quite frankly I suspect that if literally the public had a dollar for every word that Uniroyal, Crompton, Chemtura, Lanxess, the Ministry of Environment (MOE or MECP), Conestoga Rovers (CRA) or GHD had ever written about the Canagagigue Creek that it would be cleaned up by now. Hence the title above. Talk is cheap and so are "investigations" and reports. Real Cleanup not token cleanup is expensive.

On November 19,2018 Lou Almeida of GHD, on behalf of Lanxess Canada sent responses to Jason Rice of the MOE regarding the MOE's purported June 13, 2017 "..." Canagagigue Creek Draft Report Review Comments." I say purported because as slow as GHD are I don't think that they waited a year and a half to respond to the MOE and I also don't believe that the MOE sent in their comments to the 2017 investigation and field work while the work was actually underway. Likely just another typo among millions (LOL).

My following comments are not meant as a formal or extensive critique. They are simply hitting a few highlights and concerns I have noticed in GHD's Nov.18/18 report to the MOE.

Data gaps now suddenly appear to be a huge issue for the Ontario MOE. For the love of Mike I've been telling the MOE since 2012 and every followup testing (2013, 2014, 2015,..you get the picture) that there is a huge locational bias involved in their and Chemtura/Lanxess's testing locations. When you keep testing in and around location 20 and 21 as well as the New Jerusalem Rd. bridge, of course once you've gotten the first few hits you are likely to continue to find DDT and dioxin/furans over time in the same location. Similarly when you don't test for these chemicals in 90% plus of the downstream creek, you will never find them.

A number of references in this letter and others suggests that all parties are somehow including all stakeholders in the process around the Canagagigue Creek cleanup. This is a blatant misrepresentation. Myself and the knowledgeable and informed CPAC members as well as the general public have been intentionally and maliciously excluded from the process.

The MOE have serious concerns regarding sampling of sediments where DDT and dioxin/furans are less likely to accumulate such as sediments with high percentages of coarse gravels versus finer silts and clays.

Page 3 actually states that the MOE have a concern regarding off-site source locations such as the Stroh Drain which they prefer to call "agricultural drainage ditch from 6770 Line 86". That is good news although it would be nice if they would publicly speak to that.

GHD confirm that "...natural erosion and deposition processes occur along the entire study area" in the creek and that "These natural processes are affected seasonally and temporally by significant storm events."

Dioxin concentrations in both soils along the creek banks and in creek sediments in the bottom of the creek generally are higher with depth (Table on page 4). This is huge and relevant to the Mickey Mouse investigation and promised excavations to be done before 2018 concludes. To date Lanxess have not started them.

The MOE still have concerns regarding GHD's sample collection method using a "shovel" versus the normal method of sediment collecting. The implication as I understand it is that the shovel picks up more coarse gravel than the alternate method hence lowering the concentrations of DDT and dioxin/furans as those compounds are associated with fines (ie. silts & clays) not with coarse gravels.

The MOE indicate errors later in the report (pg. 12) dealing with comparing contaminant concentration results with the wrong criteria. They also advise that there is confusion in the text (pg. 13) describing the location of sampling areas and the "reaches" #1 to #4 as defined in the initial GHD report.

There is also confusion and errors in regards to reporting MOE sediment samples as soil samples (pg. 14) and as well the MOE suggests that GHD have incorrectly stated sample depths of a number of samples (ie. 10-20 cm versus 20-30 cm.).

Page 15 makes reference to a Control Order in regards to a fish collection program. This Control Order is news to me however I am currently making inquiries about it.

I have a general comment to make regarding GHD's responses to the MOE's concerns and criticisms. I believe that GHD's responses are generally better than their predecessors, CRA. I see some frank admissions to blatant errors that I have learned that CRA in the past would avoid. Good for GHD.