DIOXIN (TEQ) CONCENTRATIONS IN CREEK & FLOODPLAIN SOILS IN & AROUND THE LANXESS (Uniroyal) SITE & DOWNSTREAM (Canagagigue Ck.)

Again two reports namely the recently received 2020 Canagagigue report and the earlier 2017 report. Firstly the 2020 report: There were 50 soil samples taken of which a grand total of five exceeded my arbitrarily picked concentration of 50 parts per trillion (ppt). Larch's Creek, Bolender Park Creek, Shirt Factory Creek and landfill Creek had a total of five detections above the provincial criteria out of 26 samples for soils of 7 ppt. but none above my arbitrarily picked concentration of 50 ppt. ................................................................................................................... Downstream in the Canagagigue Creek Reach 2 (closer to the Grand River) had 6 of 16 soil samples exceed the provincial criteria (7 ppt) but only 1 above 50 ppt. Reach 3 (towards Lanxess) had 2 out of 2 soil samples both of which exceeded the provincial criteria (7) and my criteria (50 ppt). Reach 4 which includes the Lanxess site had 4 of 6 soil samples exceed the provincial criteria (7) but only 2 exceed my criteria (50). The purpose of my arbitrarily determined criteria of 50 ppt is as follows: At some point in time we will have soil results from in and around the Stroh Drain. I don't know what they will be but undoubtedly Lanxess/GHD/MECP will all howl and whine that the results are not significant despite the 7 ppt. TEQ provincial criteria for soils within 10 metres of a waterway and 13 ppt. if further away. Therefore 50 ppt. is 7 times greater than the lower criteria and pretty much 4 times greater than the higher one. It is a significant concentration by honest people's standards. Also this self-determined criteria (50 ppt) exceeds 90% of all the soil results in the 2020 report. ......................................................................................................... The 2017 Canagagigue report consists of 265 soil samples (creek & floodplain soils). A total of only 13 soil results exceeded my 50 ppt. criteria. Hence my criteria for significant dioxin presence in and around the Stroh Drain actually exceeds 95% of all the soil samples taken and tested by Lanxess/GHD in 2017. That is a very significant concentration if found in and around Stroh Drain soils. Not unexpectedly with the very high number of samples taken on the Lanxess (75) property, New Jerusalem Rd. (48) and at Station #21 (36) also near New Jerusalem Rd.; these three areas had the highest concentrations of dioxins in soil albeit only 6 exceeded 50 ppt at Lanxess, 3 exceedances at New Jerusalem Rd. and 4 exceedances at Station #21. All other sampling locations had zero exceedances of my 50 ppt. criteria. Hence again this data supports my, at the moment, hypothetical and arbitrary criteria of 50 ppt. being a very reasonable criteria for further soil testing and eventual remediation.