"SUPPLEMENTAL EAST SIDE OFF-SITE GROUNDWATER INVESTIGATION"

Well they don't refer to some consultants as "client driven" without good reason. GHD, on behalf of Lanxess Canada, have written this 254 page report. I've seen worse and a few better. GHD in referencing the marked decrease in contaminant concentrations literally just a few meters across Uniroyal/Lanxess's east side property line refer to "natural attenuation". Puuulease spare me that crap. If natural attenuation was in force it would also have dramatically reduced contaminant concentrations still on the Lanxess property. It has not and some of the concentrations of 2,4-D, 2,4 dichlorophenol, 2,4,5-T, 2,4,6-T and more are still horrific on site. Speaking of the 2,4-D and 2,4 dichlorophenol it seems to me that GHD have mangled the customary acronyms with them and are using 2,4-D (i.e. 2,4 dichlorophenoxyacetic acid) interchangeably with 2,4 dichlorophenol which is the precurser to 2,4-D. Also I'm kind of questioning for this groundwater investigation why GHD/Lanxess are only testing for 2,4,6-T (i.e. 2,4,6 trichlorophenoxyacetic acid) and not for 2,4,5-T which is one of the precursers for the dioxins found in Agent Orange manufactured on this site.

NDMA has been found both on the Stroh farm along their property line with Lanxess as well as 240 metres to the east. In fact it was found 240 metres to the east in both shallow and deep aquifers. That to me is quite stunning. The concentrations as expected were higher along the property line than 240 metres farther away. Similarly 2,4-D allegedly: actually 2,4 dichorophenol was found both along the Stroh/Lanxess property line as well as 240 metres to the east although again as expected concentrations were lower further away. Interestingly again this contaminant was found in both shallow and deep aquifers at distance away from Uniroyal/Lanxess. Exactly how much liquid wastes overflowed in the first place from these east side pits? Clearly it had to be a very large volume probably for a very long time for remnants of it to still be measureable fifty years after the last spill/overflow. Lastly 2,4,6-T allegedly: actually 2,4,6 trichlorophenol was found in monitoring wells on the Stroh property along the property line with Lanxess at much lower concentrations than were found on the Uniroyal/Lanxess property. They were not however found in any of the shallow or deep wells 240 mtres to the east on the Stroh farm.

I view these results as very bad news for Lanxess Canada. Fortunately however their well paid spin doctors ...oops... I mean professional consultants will make a silk purse from the proverbial sow's ear. Good for them. Honest brokers will see right through that. Politicians or self-serving individuals, will be less likely to see through it.