MORE CRITICISM OF THE 2017 CANAGAGIGUE CREEK SEDIMENT & FLOODPLAIN SOIL INVESTIGATION

I've previously indicated that in my opinion the Method detection limits (MDL) of DDD, DDE and DDT in this report are far too high because they exceed the MOE Table 8 criteria or standards. I've also mentioned that they exceed the federal Interim Sediment Quality Guidelines (ISQG) by an even larger amount. So the question is are either the Ontario MOE or the federal government stupid enough to set environmental health and safety standards at concentrations below what it is possible to accurately test for? Oops maybe that's not a fair question. How about this. Have these bodies delivered lab results closer to their own criteria in other reports hence suggesting that this particular report has detection limits that are much too high?

The answer is yes and lo and behold they are in the MOE's 2012 and 2013 reports on soils and sediments in and around the Canagagigue Creek. Keep in mind in this their latest amateur hour effort they've used detection limits of .020 ppm (and higher!) for DDD, DDE, and DDT in both soils and sediments while the respective MOE Table 8 sediment standards are .008, .005, and .007 ppm respectively.

The soil and sediment results in these reports are on page seven and eight for the 2012 report and on page eight for the 2013 report and include .001, .003, .004, .005, .006, .007, .008, .009, .010, .011, .014, .016 ppm values for various DDD, DDE, and DDT isomers. Seems odd to me that they could confidently achieve these lower results but in this the final investigation report they allegedly can't.

The next goof in the 2017 report occurs on pages nineteen through twenty-three and is in nine small tables throughout these five pages stating the the lowest values they found were at ND (.20) ppm. Come on guys this may be a simple typo that should read ND (.020) but to repeat it nine times over five pages is amateur hour. Are you guys really professionals???

Lastly these same nine tables include the lowest and highest results found as well as the MOE Table 8 standards. I suggest that the lower federal criteria (ISQG) should also have been included in these tables in order to demonstrate that the MOE Table 8 standards are not the most stringent and hence the detection limit they are using (.020) is even more inappropriate when compared to the ISQG criteria. Following are the two different standards:


............Table 8 .....ISQG ppm

DDD *** .008 **** .00354

DDE *** .005 **** .00142

DDT *** .007 **** .00119