AGAIN CYNTHIA DOUGHTY (MOE HYDROGEOLOGIST) RAPS KNUCKLES & SPANKS LANXESS's CONSULTANTS (GHD)

It of course does not happen often enough that any credentialed experts get up on their hind legs and tell off the polluter and their hired guns (i.e. consultants). It was done occasionally in the past by Bob Hillier and Jaimie Connolly, both hydrogeologists with the Ontario Ministry of Environment (MOE/MECP). Unfortunately while their comments were mostly (but not always) shared with the stakeholders and citizens, nevertheless these experts were only occasionally in attendance at regular UPAC and CPAC meetings thus their comments and criticisms were soon buried beneath the ongoing verbal and written onslaught produced for the benefit of Uniroyal/Crompton/Chemtura and now Lanxess Canada. Nowadays we see even less of them as not even their employer (MOE/MECP) regularly attends TAG meetings. It's a disgrace. ..................................................................................................... Ms. Doughty's report is dated September 23/20 and is a serious critique of GHD's May 21/20 "Supplemental East Side Offsite Groundwater Investigation...". In other words it was supposed to be a groundwater investigation of Lanxess's east side neighbour, the Stroh farm. Of course it was no such thing in reality as GHD to this date still have not constructed monitoring wells throughout the southern half of the property nor have they sampled the soils to even determine the most rudimentary understanding of what aquifers or aquitards exist in the area of the Stroh Drain, Ditch & Berm (SDDB). On top of this criticism of mine Ms. Doughty included several of her own. ..................................................................................................... My first concern is that no one has provided Ms. Doughty with Table 3.1 from the 1991 Environmental Audit which is a fairly serious list of the various chemicals and toxins buried in the east side pits and ponds. This is clear from her comment on page 2 (of 7) namely "Detailed information about the historical waste management activities is not available." Holy crap Batman but is there exactly zero corporate memory now within the MOE/MECP as to what has gone on in the past? Boy is that ever convenient for both them and Lanxess Canada. ................................................................................................................ Ms. Doughty mentions the fact that GHD can not even properly use the long known abbreviations for 2,4-D and 2,4,6-T appropriately. That said I find it odd that they are focused on 2,4,6-T when the issue has always been 2,4,5-T not 2,4,6-T. I wopuld like to see some explanation for that. Is it simply an intentional bait and switch of some sort? Ms. Doughty also seriously questions repeatedly, GHD's claims that site-related contaminants are attenuated with depth (i.e. lower concentrations with increasing below ground surface depth). She also clearly denies GHD's position that aquifers on the east side are of limited extent and discontinuous (pg. 4). ................................................................................................ Ms. Doughty makes her skepticism very clear regarding GHD's groundwater flow directions as they are using groundwater elevations from wells installed across multiple hydrostratigraphic units. In other words they are using water elevations for example to show flow direction in the Upper Aquifer (UA) from wells that are screened across both the UA and the Upper aquitard (UAT). This is a no-no. Also the presence of NDMA further to the east and cross-gradient versus down gradient is appropriately questioned by Ms. Doughty. Finally she has a number of concerns that are not answered by GHD in regards to wells OW7d, OW7-12 and OW7-29 and their NDMA concentrations. ........................................................................................................ By page 6 Ms. Doughty is asking why a number of apparently other deep wells were not sampled by GHD. She also clearly condemns GHD's claim that NDMA is being "attenuated" (decreased) as sampling crosses the property line between Lanxess and the Stroh farm. She also makes clear that the purpose of this investigation was not only to determine current contamination on the Stroh farm but also future contamination originating from the Lanxess site. Lastly she would like a better identification of all wells that are completed within multiple hydrostratigraphic units. Her Summary on page 7 categorically states that "The 2020 report has not pulled together the lines of evidence to adequately demonstrate delineation of site-related contamination on the adjacent property...". In other words GHD you get a F (failure) for your efforts to date. Well said Ms. Doughty. Now lets see what the MOE/MECP brass whom she reports to unfortunately will do with this.