INTENTIONAL CANAGAGIGUE CREEK SAMPLING BIASES REDUCE LANXESS CLEANUP COSTS

Liars can figure and Figures can lie is a very old truism. Then there is the one possibly from Winston Churchill that states: Lies, damned lies and statistics. You get the picture. Numbers and figures have been the go to method for unscrupulous, self-serving folks to get their way for time immemorial. Politicians especially love them because most are too lazy and too dumb to actually carefully analyse the numbers themselves. Hence they can cheerfully ask for a "summary" from their toadies and underlings to support whatever their position is. ................................................................................................................ The soil and sediment investigation of the Canagagigue Creek in 2017 was riddled with various errors, typos and subterfuges. The most recent one titled "2020 Canagagigue Creek Sediment and Soil Investigation" dated June 30, 2021 is just as bad. A major part of the scam is to judiciously use varying Method Detection Limits (MDL) to ensure fewer detections of toxic compounds in and around the Canagagigue Creek. Inappropriate MDLs can also focus attention in one direction and away from areas that you'd rather readers not notice. Particularly areas that could cost you more time, more money and more public scrutiny and or condemnation. ................................................................................................................................... The simplest and most obvious criticism is that the MDLs are repeatedly and constantly higher than the provincial or federal criteria for most of the contaminants of concern (COC). This means that if for example the criteria (provincial-Table 8) for Total DDD in soils is .05 parts per million (ppm) and as is typical in this report you have a MDL of either .11 or .23 ppm then with the first MDL (.11) your sample of DDD needs to be actually more than double the criteria in order for the lab to detect it. If the MDL is .23 as it often is in this report then your sample concentration would have to be almost five times higher than the provincial health criteria to be detected by the lab. In other words by having laboratory detection limits (MDLs) in excess of the government mandated health criteria you are artificially reducing the number of both low level detections of the contaminant as well as detections sometimes well in exceedance of the criteria. Also realize that these MDLs can be to a certain extent an intentional request of the person submitting the samples (polluter or his consultants). For example it may be that the lab charge less for analyses with higher MDLs than with much lower MDLs. This is due to the greater effort and care required by the lab for lower MDLs. Also realize that all of these legally mandated criteria, no matter how low, are achievable by the proper accredited labs. This ability to achieve lab analyses is of course required before any pollution standards/concentrations are set in the first place. ...................................................................................................................................... There is yet another possible reason for a high Method Detection Limit (MDL). It is sometimes referred to as matrix interference and refers to the situation where a lab is analysing a sample for a particular contaminant but that sample is also contaminated with a very high concentraion of other different contaminants. This sometimes can force the lab to be unable to achieve the MDL that they would like. Likely in the case of Uniroyal/Crompton/Chemtura /Lanxess this has occurred to their advantage. In these cases it is grossly misrepresentative to the point of fraudulent, in my opinion, for the report writers not to CLEARLY & REPEATEDLY advise the readers throughout the text if the high MDLs (greater than criteria) are caused by matrix interference and high concentrations of other contaminants. Also it is highly misrepresentative, as this report does, to repeatedly suggest that sampling has shown that numerous contaminants such as Total DDD, DDE and DDT are non-detect within a sample when in fact that non-detection is simply an artifice of the ridiculously high MDLs. ................................................................................................................... Generally speaking the MDLs are lower both for soils and sediments further from the Lanxess property (i.e. further downstream in the creek). This induces greater detections further downstream and reduces detections closer to their plant. Also the high MDLs are more biased against sediment detections than soils because the sediment criteria are so much lower than the soil criteria. Therefore greater numbers of detections and possible exceedances in the sediments are not determined as they are referred to as Non-Detect. I have also noticed in the Background samples for four different creeks that there appears to be a bias against both Shirt Factory Creek detections and Landfill Creek detections. In other words MDLs are actually lower for the same chemicals in Bolender Park Creek and in the unnamed creek (Larch's Creek?). Finally there is a huge bias with the MDLs towards getting detections of dioxin/furans versus getting detections (and exceedances) for DDD, DDE, DDT and Lindane. Apparently there is very little problem in achieving very much lower MDLs for dioxins (it has a much lower criteria) than there is for the much higher criteria and MDL DDT compounds. If there is some honest rationale for this it badly needs to be explained versus the appearance that DDT compounds are few and far between while dioxins are evrywhere. ............................................................................................................................ I am still examining this report carefully. As a general comment I will however state the following. What a deal it is for polluters if they can both save money upfront with lower per unit lab analysis costs (due to higher MDLs) and then also save money at the back end with lower cleanup costs due to fewer detections of toxic compounds. God bless our democratic, free enterprise system.