MOE NOT SATISFIED WITH LANXESS/GHD RESPONSES

I'm really not clear as to what exactly is going on although I will say that despite a few decades of bad, incompetent and corrupt behaviour by them, this latest report from them is not the first time that I have seen significant signs of intelligent life. As I recall, the MOE's (MECP) comments on the 2017 Annual Monitoring Report last spring were described as the most comprehensive and critical comments in many years. There has been a turnover in personnel although as I've stated here I did not see any improvement with the presence of Terri Buhlman during and after the Dr. Richard Jackson time as TAG Chair. Jason Rice seems to be also a fish of a different sort as well as I am beginning to appreciate his written critiques.

The MOE are quite obviously upset with Lanxess's response to ministry comments written by GHD and dated November 19, 2018. This response was in relation to the MOE's comments and questions about the 2017 Canagagigue Creek Investigation. The MOE (Jason Rice) are clearly stating that their comments and requests have not been fully addressed to date and that Lanxess's/GHD's Draft Report must not be finalized until they are.

Clearly the MOE are not happy with sample results for creek sediments that include significant quantities of stones and gravel. Dioxins/furans and DDT adhere much more readily to fine grained sediments with large percentages of silts and clays. The MOE are also not impressed with GHD's apparent insistence that sediment concentrations of contaminants need only be compared to one set of criteria namely the Canadian Council of the Ministers of the Environment (CCME), Interim Sediment Quality Guidelines (ISQG). The MOE are insisting that other criteria including the CCME Probable Effect Level (PEL) and the provincial Severe Effect Level (SEL) criteria also be used and included.

The MOE (MECP) are also insisting that GHD include what they the MOE refer to as previous discharge locations to the creek from former gravel pits (GP-1, GP-2) as well as from the Stroh Drain still referred to by the MOE as drainage ditch from 6770 Line 86, Township of Woolwich. It seems very clear to me that the Stroh Drain continues to discharge to the Canagagigue Creek to the current time.

The MOE want to see earlier aerial photographs included in GHD's final Creek Report to show how the creek may have migrated over time. Major depositional areas along the creek could have large depositions of the Persistent Organic Pollutants (POPs) such as the dioxins/furans, DDT and more (eg. PCBs).The MOE again reiterate their unhappiness with the location of samople locations that have far too much coarse gravel for their liking which then underestimates the concentrations of POPs. The MOE also repeats their criticism of GHD collecting sediments using a shovel and make it plain that those samples are inaccurate and can impact the retention of fine sediments.

There are also complaints from the MOE in regards to TEQs and TEFs, that is Toxic Equivalency Quotients and Toxic Equivalency Factors. The MOE feels that GHD are relying on the wrong calculations to determine these numbers.

The MOE seem to be challenging the very essence of GHD's risk based framework for their assessment within the creek. The MOE believe as stated on page four that there needs to be an assessment of deeper sediments as well as a "non-risk based approach that considers source control and/or "hot spot" removal." I believe that this is a crucial blow to plans of lessening cleanup criteria by alleging that there is very little exposure risk to receptors in and around the Creek. All in all I am seeing some positive signs. Will they continue or is this the same old game being played upon the public?