Tuesday, April 17, 2018
DEEPER ANALYSIS OF CANAGAGIGUE CREEK TOXIC RESULTS
To date I've been talking about the number of total detections of DDT, DDE, DDD and Dioxins/Furans above the criteria in creekbank Soils and the much lower criteria which have been exceeded in Sediments in the bottom of the creek. Today we are going to examine the actual exceedances of the Ontario Ministry of Environment's Table 8 criteria by specific chemical. That is however only the chemicals that Lanxess/M.O.E. have designated as Contaminants of Concern (COC). There are many more unmeasured in this report, toxic chemicals in the creek.
The 22 exceedances of criteria in creekbank Soils in the Northfield Dr. area consist of six for 2,4 + 4,4 DDT, five for 2,4 + 4,4 DDE, and four for 2,4 + 4,4 DDD. There were seven exceedances for Dioxins/Furans measured as the TEQ (toxic equivalency) exceeding 7 parts per trillion (ppt). These 2,4 + 4,4 designations are the total of the different breakdown products of DDT (ie. DDD, DDE) as well as the total of DDT itself. In the upcoming paragraphs I will simply state the exceedances for DDT, DDE and DDD thusly rather than continue the 2,4 & 4,4 designations. There were a grand total of 96 soil samples analysed. Therefore 23% of samples analysed exceeded the criteria.
There were 17 exceedances in creek Sediments of which one was for DDT and the other 16 for Dioxins/F. Therefore 18% of the 96 samples analysed exceeded the specific criteria for each contaminant.
Next upstream was the New Jerusalem Rd. location (ie. east side of the road). There were 88 Soil exceedances of which 22 were for DDT, 30 for DDE and 18 for DDD. Dioxin/F concentrations exceeded the criteria 18 times. Thus of the total of 192 samples, 46% exceeded the criteria.
There were 85 Sediment exceedances at the New Jerusalem Rd. location. Nine were for DDT, 16 for DDE and 12 for DDD. There were 48 exceedances for Dioxins/F. Thus 6% of the total number of 1,372 Sediment samples had exceedances.
At Station 21 just barely upstream of the New Jerusalem Rd. samples there were 75 Soil sample exceedances namely 20 for DDT, 24 for DDE and 10 for DDD. There were 21 exceedances for Dioxins/F. Therefore out of a total of 144 Soil samples, 52% exceeded the criteria for these toxic chemicals.
There were a total of 93 exceedances for Sediments at Station 21. These were 19 for DDT, 22 for DDE and 15 for DDD as well as 27 exceedances for Dioxins/F. Thus 33% of the 280 total samples at this location exceeded the criteria.
Downstream of Station 20 we had 115 Soil exceedances of the criteria. 28 were for DDT, 36 for DDE and 24 for DDD. Dioxins/F had 27 exceedances. Thus 60% of the 192 Soil samples exceeded the criteria for DDT, DDE, DDD and Dioxins/F.
Sediments downstream of Station 20 had an even higher number of exceedances. There were 138 exceedances consisting of 24 for DDT, 25 for DDE and 35 for DDD. Dioxins/Furans had 54 exceedances. This is a total of 38% of the 365 samples analysed exceeded the various criterias.
Lastly we have the Lanxess property itself. There were a total of 69 Soil exceedances in the creekbank Soils consisting of 13 for DDT, 15 for DDE and 14 for DDD. There were 27 Dioxin/F exceedances in these creekbank Soils. This is a total of 24% of the 288 Soil samples exceeded the various criteria for these chemicals.
Creekbed Sediments had 60 exceedances consisting of 13 for DDT, 9 for DDE and 14 for DDD. There were 24 Dioxin/F exceedances. This is 35% of the 172 Lanxess property Sediment samples exceeding the criteria for these chemicals.
As stated earlier by a Commenter here in my Blog, these sample totals are quite astounding. It is unfortunate in my opinion that the sample locations were not chosen more appropriately to cover the entire 7.5 kilometres of the creek from Uniroyal/Lanxess all the way down to the Grand River. Any claims by GHD/Lanxess that they had M.O.E. approval for their Workplan are likely honest. Any claims that they consulted with all the stakeholders and the general public are just plain disingenuous and dishonest.
Monday, April 16, 2018
STATION 20 & THE LANXESS SITE RESULTS ALONG THE CREEK
Last Saturday I posted about the Soil and Sediment results at Northfield Drive and then upstream to the east side of New Jerusalem Rd. and then Station 21 immediately on the west side of New Jerusalem Rd. We continue westwards to Station 20 which is just a couple of hundred metres downstream of the Lanxess site. Lastly we examine the Soil and Sediment results on both sides and in the bottom of the creek as it travels north to south through the Lanxess property.
Station 20 covers an area at least 800 metres in length. Although the first four sample locations are all bunched together at the extreme north-west corner of this stretch, the last four sample locations are all well spaced and well apart as they head downstream towards Station 21. There were a total of 115 exceedances of criteria (both DDT & Dioxins) in the Soil samples and 77 results which were below the Table 8 criteria for Lanxess's defined COCs (Contaminants of Concern ie. DDT & metabolytes plus Dioxins/Furans). A total of 192 Soil samples were taken at this location.
For Sediments at Station 20 we had 137 exceedances for both COCs and 227 results which were either below criteria for Dioxins or non-detect in large part due to the Detection Limit exceeding the criteria for DDT, DDD and DDE. This was a total of 364 samples taken from this location. Strangely even with very high TEQ (Dioxin) results at the upstream end of Station 20 sampling there were even higher results downstream past the discharge from the Stroh Drain which Lanxess, GHD and the Ontario M.O.E. are desperately trying to ignore. This is especially so for DDT and its' metabolytes.
Interestingly the Lanxess site had "only" 69 Soil sample exceedances and 219 results below either the criteria or the Detection Limit. Regarding Sediments there were 60 exceedances of criteria and 112 results either below the criteria or below the Detection Limits. This is interesting as allegedly this site is the source of everything downstream all the way to the Grand River. Intellectually that is correct of course as all the production of DDT (insecticide) and 2,4-D and 2,4,5-T (herbicides) took place on the west side of the Canagagigue Creek. Also there has been past efforts to clean up the creekbanks along the Uniroyal/Chemtura site which should have lowered DDT and Dioxin detections.
There were however two pipelines in full throttle taking these liquid wastes across the creek and pumping them up to the east side ponds namely RPE1-5. Drums full of liquid toxic wastes were also buried on the east side in RPE-5, BAE-1, RB1 & 2 along Uniroyal Chemical's east side border with the Stroh farm. It has long been apparent from the lower concentrations of these contaminants in the soils near the creek on the east side that some sort of diversion took place. Uniroyal/Chemtura have long claimed that all liquids flowed west & south from these pits and ponds, none east. That has now been disproven courtesy of myself and CPAC. Furthermore Uniroyal's refusal with Ministry of Environment acceptance to put any hydraulic containment in the shallow aquifers on the east side of the creek also indicated that they had "solved" the east side liquid waste problem privately and dare I say surrepticiously.
The extent of this environmental disaster here in southern Ontario is grotesque. Now watch the Mickey Mouse remediation plans which come forward. In this province it is not polluter pays. It is polluter pretends to pay while hiding behind the Ontario Ministry of Environment.
Saturday, April 14, 2018
2017 CANAGAGIGUE CREEK REPORT IS EVEN MORE PRECIOUS
IS IT INTENTIONALLY USER UNFRIENDLY ?
Over the last couple of weeks plus I've complained and criticized this report for being difficult to follow and difficult to read. Some of it has been inherent to the number of samples involved (approx. 1,000) in really just two locations namely Northfield Dr. and the New Jerusalem Rd. area. Now keep in mind while GHD & Lanxess may call this three locations two of them are mere feet apart with Station 21 samples on the left side (west) and new Jerusalem on the right (east) side when you are facing north. This number of approx. 1,000 consists of multiple different samples in the same location merely deeper usually with three depths in soils (0-5, 5-10, 10-15 cm.) and four depths in sediments (05, 5-10, 10-20, 20-30 cm.) It also includes four different parameters (DDD, DDE, DDT, Dioxin TEQ). It also includes two discrete samples at each Soil location and three discrete Sediment samples at each location.
There are also a ton of samples further upstream including the Lanxess site itself and Station 20 just below the Lanxess site. Much further downstream the Northfield Dr. location has a mere 220 samples including both Soils and Sediments. There is literally miles of untested creek above and below Northfield Drive. These numbers and locations speak to both the locational bias I spoke of yesterday as well as partially to the sub-title above. Are all these samples necessary? The answer is no. Three soil samples merely separated by two inches (5 cm.) of soil is ridiculous. If you really felt the need for three separate soil samples then take them either a foot or two apart in depth. That would give you a legitimate understanding as to how these Persistent Organic Pollutants (POPs) have really penetrated into the earth. Similarly testing creek Sediments at two inch (5 cm.) intervals is silly. The deeper samples are 10 cm (4 inches) apart which is only slightly better.
Here are some of the results from testing. Northfield Dr. has 22 exceedances in total out of 96 creekbank Soil samples. These are exceedances of the Ministry of Environment Table 8 soil criteria for DDD, DDE, DDT and for Dioxin/Furans. Regarding Sediments Northfield Dr. has only 17 exceedances out of 124 samples. This much lower number is partly attributed to the Detection Limit as mentioned in an earlier post actually being higher than the criteria for total DDD, DDE and DDT.
New Jerusalem Rd. has 88 exceedances in total out of 192 Soil samples. There are 85 total exceedances out of 1,372 Sediment samples. Again the Sediment samples are minimized by the laboratory Detection Limit being higher than the Sediment criteria for total DDD, DDE and DDT thus eliminating a number of exceedances and labelling them as Non-Detect.
Station 21 just west of and immediately upstream of New Jerusalem Rd. has 75 Soil exceedances out of 144 Soil samples. It also has 93 creek Sediment samples out of 280 samples. Just like the other locations the Sediment exceedances while high are muted due to the high laboratory Detection Limits.
Lastly I want to refer again to the sub-title of "Is it intentionally user unfriendly?". Along with the ridiculous errors in the text portion I pointed out yesterday, I was stunned to see how the Tables were organized or should I say disorganized. The Figures (6.1-6.10) list the sampling locations for creekbank soils and sediments in order from downstream right up to and including the Lanxess site. Then in the Index we see that the Tables Section is also listed in the same order. Or is it? Table 5 is listed as "New Jerusalem Rd. and Station 21 - Soil Sample Analyses". Table 6 is listed as "New Jerusalem Rd. and Station 21 - Sediment Sample Analyses". What the heck are they admitting that these TWO locations are really but one? Then when you carefully and equisitely decipher the location code at the top of each sample you find that the Tables are no longer in fact in the same order as the Figures. Furthermore all it would take is a clear darker ink heading/title indicating that the first half of Table 5 is Station 21 Soil Analyses and the last half is New Jerusalem Rd. Soil Analyses. Similarly the first half of Table 6 is Station 21 Sediment Analyses and the last half is the New Jerusalem Sediment Analyses. It too is as clear as mud.
This switcheroo is poorly marked AND it makes comparing the Tables with the Figures very difficult. After Tables 5 & 6, Tables 7,8,9 and 10 are back to being straightforward again. Surely this entire Report is sufficiently detailed and messed up (the text) not to require even more mental and visual gymnastics on the part of citizen volunteers and even outside professionals in order to follow it. If the purpose is to make this report extremely User Unfriendly then I suggest Mission Accomplished. It of course begs the question as to why Lanxess and their consultants are doing this. Intentional or simply Uncaring?
Friday, April 13, 2018
TRYING TO MAKE SENSE OF THE MESS
So yesterday after almost throwing out the baby with the bath water I went back to the 2017 Canagagigue Creek report. I slowly went through Figures 6.1 - 6.11. The FIVE locations (only) where creekbank soils and creekbottom sediments were sampled are in reverse order geographically. In other words 6.1 & 6.2 start downstream at Northfield Dr. encompassing Four sampling locations and then 6.3 & 6.4 move upstream to New Jerusalem Rd. where there are eight sampling locations. Soils are sampled and results displayed in the odd numbered Figures ie. 6.1, 6.3, 6.5, 6.7, 6.9 and Sediments are sampled and displayed in the even numbered Figures namely 6.2, 6.4, 6.6, 6.8 and 6.10.
After the New Jerusalem Rd. site we move upstream (sort of) to the next site which happens to be Station 21. Upstream is technically correct however it's "upstream" by just a tad more than the width of New Jerusalem Rd.. New Jerusalem Rd. is not an eight lane 401 type of road. It's gravel and all of twenty feet wide maybe (ie. one narrow lane each direction). So in other words this third site is merely the continuance of the New Jerusalem Rd. site. Station 21 is covered by Figures 6.5 (Soils) and 6.6 (Sediments) and consists of six individual locations.
Figures 6.7 and 6.8 are for Soils and Sediments (respectively) for Downstream of Station 20. Station 20 is an old designation for a location on the creek where it bends after leaving the Lanxess property and briefly runs sort of parallel to the most southern border of the Chemtura/Lanxess site. From there eight sample locations run downstream almost as far as the start of the Station 21
sample locations on the west side of New Jerusalem Rd..
Figures 6.9 and 6.10 are twelve locations along both sides of the creek where it runs through the Lanxess property. Unsurprisingly despite the amount of work done in the creek (west banks) between 2000 and 2005, the greatest number of exceedances for both DDT and Dioxins are still on the west side of the creek. This speaks to as usual not doing a complete job the first time around as well as the likelihood of a diversion or by-pass on the east side of the creek sending contaminated groundwater southwards and eastwards over to the Stroh farm.
Finally Figure 11 is of the four Floodplain samples (ie. away from the creek but in the floodplain designated area) as well as the one floodplain pond that was sampled in the Station 21 general area. The number of floodplain Soil locations (4) make it pretty clear that for this investigation floodplain Soils were given only token attention. Back in the mid 1990s ten floodplain Soils locations were sampled and they were contaminated from the Uniroyal property all the way down to the Grand River with DDT and Dioxins plus of course all the other Uniroyal herbicides, pesticides, solvents PAHs and more that they wish we would forget about.
By simply looking at the number of samples and their specific locations along the Canagagigue Creek it is clear that the sampling locational bias continues unabated.
Northfield - 4 locations
New Jerusalem - 8 locations
Station 21 - 6 locations
Station 20 - 8 locations
Lanxess - 12 locations
My expectation is that it is cheaper to remediate a shorter, smaller distance from the company as well as to focus on the first mile (approximate) downstream from the Uniroyal plant to just past New Jerusalem Rd. combined with again four token locations at Northfield Dr.. Also it's easier to mobilize vehicles and equipment where there is easy road access to the creek which again is New Jerusalem Rd. and Northfield Dr.. All of this is easier and cheaper than honestly admitting that the entire five miles (7+ kilometres) of Canagagigue Creek all the way to the Grand River is grossly contaminated. Most of these five miles do not have easy road access to them thus it is the usual self-serving psuedo/junk science pretending that the less accessible areas of the creek are clean. Such typical Woolwich horse manure promulgated by Chemtura/Lanxess and their fellow travellors and partners in pollution. The Ontario Ministry of Environment will go along as usual because they are so horribly compromised by their historical negligence, incompetence and let's face it, underfunding and lack of scrutiny by the province of Ontario.
Thursday, April 12, 2018
ARE YOU KIDDING ME? THIS IS DISGRACEFUL EVEN BY THEIR STANDARDS
I've been posting here for the last week and a half about the 2017 Canagagigue Creek Sediment and Floodplain Soil Investigation report. I have expressed my difficulty about aligning the text with numerous Figures showing soil and sediment results on maps as well as with multiple Tables also showing DDT, DDD and DDE results along with Dioxin results in creek sediments and creekbank soils. Well yesterday I came to a conclusion. GHD are completely inept. Or should I say that it is the same former Conestoga Rovers folks screwing up only at a new level of incompetence? Whomever this is both an insult to citizen volunteers reading this report as well as a damning indictment of what passes for public consultation here in Woolwich Township. This report was issued on March 19/18. Volunteers and professionals alike have had it for weeks. Have not the likes of Dwight Este and Ramin Ansari of Lanxess read this ridiculous nonsense? What have the Ontario Ministry of Environment been doing? Are they really going to bull their way through and pretend that this report is remotely an acceptable example of a consultant's scientific work? The first public meeting (TAG) is one week away and the second (RAC) follows one week later. Get this mess passing as text in your report fixed and new copies distributed BEFORE the public meetings.
Monday and Tuesday of this week I posted here about both the number of exceedances of health criteria in the creek soils and sediments as well as the number of discrepancies in the text. These discrepancies in the text are with both Figures 6.1-6.11 as well as with Tables 3-11. I earlier on mentioned other errors and inconsistencies in the text such as labelling New Jerusalem Road and Station 21 as "Reach 2". Reach 2 is shown on Figure 4.1 and is further downstream starting east of New Jerusalem Rd. and going right to Northfield Drive (#22).The text around pages 16-21 also repeatedly state that the criteria for total DDT in sediments is .078 parts per million (ppm). It is not. It is .007 ppm.. Furthermore Station 21 appears not to be specifically defined or shown in this report. From previous reports I know that it is located just on the west side of New Jerusalem Rd..
There are constant references in the text to 2,4-DDT + 4,4-DDT (ND*.05) whereas the Figures and Tables refer to this total DDT as having a non-detect of .5 versus .05 . It would be appropriate for this to be explained.
The constant failure to ignore 2,4-DDD + 4,4-DDD exceedances in the text as previously mentioned requires explaining. There is none.
Page 18 claims that the criteria for DDE in sediments is .05 ppm. That is inaccurate. It is .005 ppm.. These references are in regards to samples from New Jerusalem Rd. and Station 21. This is where I was trying to reconcile the text results with Table 6.2 on page 17. It was hopeless. Table 6.2 is titled "Summary of Sediment Sample results" and many, not all, of the numbers in that Table do not match up with anything I can find.
I was able to confirm many of the numbers listed in Table 6.1 titled "Summary of Soil Sample Results" contrary to the mess that is Table 6.2 .
I believe there may be a transposition between 6.3 "Reach 3 and Downstream of Station 20" starting on page 19 with 6.4 "Lanxess Facility" starting on page 20. 6.3.4 "Dioxins/Furans in Sediment (page 20) at downstream of Station 20 has the identical text and results as 6.4.4 Dioxins/Furans in Sediment (page 21) for the Lanxess facility which is an entirely different location further upstream from Station 20 which by the way is also poorly defined or located in this report, thank you very much. Again I can't match up the numbers for Dioxins/Furans in Sediment for the Lanxess facility with Table 6.2 . I believe this is because the entire paragraph of text has been inexplicably duplicated from the previous page. Maybe these are somehow printing errors but regardless why haven't they been caught and CORRECTED and then distributed to all stakeholders?
This is a mess. It is impossible to figure out what the hell they are doing or talking about as they've garbled it beyond recognition. Fix it you twits. Don't deny or sit on it knowing most citizens will throw up their hands and wrongly assume that they simply can't follow an already complicated and difficult report.
Wednesday, April 11, 2018
PARTIAL YET VERY SIGNIFICANT CONCLUSIONS FROM THE 2017 CANAGAGIGUE CREEK REPORT
The Conclusions ie. "Summary and Recommendations" are primarily on pages 22 and 23 of the 2017 Creek Report I've been discussing here for the last little while. Generally I agree with the Conclusions whereas the Recommendations have a severe odour to them. This odour is a very familiar one to those few persons who have been following the Uniroyal Chemical saga and alleged "cleanup" for decades. I would describe it as an earthy bouquet intermingled with strong tinges of rot, death and corruption.
The Sediment results state that "It is typical that:
DDT is generally consistent at the various sample depths and locations
Dioxins/Furans generally increase with sample depth at the majority of the sample locations"
COCs or Contaminants of Concern (ie. DDT & Dioxins etc.) generally are consistent or increasing with depth within areas of deposition.
Particle size analysis of samples does not indicate any partitioning of COC concentrations relative to their particle sizes
The second and third conclusions are extremely important. Neither DDT nor Dioxins/Furans have their highest concentrations at the shallowest depths tested. In fact just the opposite. The ranges for the samples taken are 0-5 cm, 5-10 cm 10-20 cm. and 20-30 cm. although some Tables bizarrely show the last range as 20- .
I would after a detailed look at Figures 6.2, 6.4, 6.6, 6.8, & 6.10 describe the first point (DDT) more as there is no obvious pattern of concentrations with depth. Indeed some samples have higher DDT concentrations at depth whereas many do not.
The Creek Bank Soil results state that "It is typical that:
DDT is generally consistent or increases with depth at the various sample locations
Dioxins/Furans generally increase with sample depth at the majority of the sample locations.
The variability in the concentrations at the creek locations and in erosional and depositional areas do not provide any consistent trends."
The first two conclusions are absolutely stunning. They are the complete opposite of what both Conestoga Rovers and GHD have stated in the past. They have long stated that DDT and Dioxins strongly adhere to soil particles and do not move downwards in the soil. They have reinforced that nonsense by taking composite soil samples from 0-15 cm in depth and studiously avoiding comparisons at depth by sampling no deeper as well as mixing their 0-15 cm sample depth together (hence composite). That is precisely what they did in their report immediately before this one namely "The Off-Site Investigation Report February 14, 2018".
In this Creek Report they have sampled much narrower ranges of depths namely 0-5, 5-10 and 10-15 cm and each sample has been separate from the deeper depths. Unfortunately they still are refusing to look for their Contaminants of Concern at deeper depths because that would only increase the cost of remediation exponentially by having to dig deeper.
The Flood Plain Soil results indicate:
"The COC concentrations within the floodplain sample areas are less than the sample locations within the creek bank and sediments.
DDT is generally consistent at the various sample locations and depths
Dioxins/Furans generally increase with sample depth at the majority of the sample locations."
I mostly tend to agree with the second and third conclusions. The first one regarding COCs I would suggest adding the phrase "generally but not all" after the word "are" and before the word "less". This also may be partially due to the greatly reduced number of samples taken and analysed from the Floodplain soils versus creek bank soils and creek sediments.
Once again finding any COCs (ie. Dioxins/Furans) at higher concentrations at depth is stunning. What is also interesting is the much greater depths tested in the very few Floodplain Soil Investigation samples versus the greater number of shallower soil samples in the creekbank soil samples. The Floodplain soils are tested down to 30 cm below ground surface. This is double the creekbank soil depths of only 15 cm. One last problem I have is actually with the third conclusion afterall. I have just revisited Figure 6.11 . It seems as if Dioxins/Furans are at higher concentrations in three of the five deeper samples. Three out of five is not exactly a large majority.
I have in a previous post indicated my disgust with the Recommendation for a Human Health and Ecological Risk Assessment. Far too much subjectivity, assumptions and mathematical voodoo. Perfect grist for professional liars.
Tuesday, April 10, 2018
MORE TOXIC CHEMICAL EXCEEDANCES IN CANAGAGIGUE CREEK
First off look at the title. It almost implies that you can have acceptable toxic chemicals in the natural environment. This is the big lie perpetrated by both the Ontario Ministry of Environment as well as by polluting industries. None of these chemicals should be in the natural environment anywhere at any concentration. The fact that they are now ubiquitous in the air, soil and water is a damning indictment of human for profit greed and our worldwide political leadership's willingness to tolerate the poisoning of our planet. The fact that they are present at "background" concentrations everywhere is reprehensible.
Back we go to the Lanxess site that was supposedly cleaned up ten to fifteen years ago of Dioxins and DDT. That cleanup was so typical of the cheapest most minimal cleanups that have been done over the decades. 2,4-DDD + 4,4-DDD which again were not mentioned in the text have a total of fourteen exceedances in the Sediments of the creek on the Chemtura/Lanxess site. 2,4-DDT + 4,4-DDT also had fourteen exceedances both in the text and in Table 10 regarding creek Sediments. Finally 2,4-DDE + 4,4-DDE had ten exceedances in both the text and Table 10.
Lastly Dioxins and Furans in the creek sediments on the Lanxess site had 26 exceedances of the criteria. Interestingly one sample in the creek had a reading of 285 pg/g or 285 parts per trillion (ppt) while the standard is .85 ppt.. This matches with the data in Table 10. The .85 ppt refers to the Interim Sediment Quality Guideline (ISQG) while there is also a criteria referred to as the Probable Effect Level (PEL) which is at 21.5 ppt.
Only four historic Floodplain Sites were tested for in this report namely FP5, FP8, FP9 and FP10 although a Floodplain Pond near New Jerusalem Rd. was also tested. DDD again is unmentioned in the text however this time it sort of makes sense as there were zero exceedances of the criteria. Total DDT had five exceedances mentioned in the text whereas I only found two in Table 11. Total DDE is stated in the text as having fifteen exceedances and again I only found one exceedance in Table 11. This discrepancy borders on the bizarre.
Then we hit Dioxins and Furans in Floodplain sites (Soils). The text clearly states that the results in Table 12 had five exceedances of the criteria. That matches with what I found in the Tables section. The problem is that there is no Table 12. What the hell! These results are clearly in Table 11 not in the non-existent table 12. These errors in the text absolutely do not instill confidence in me that everything is either competent or on the up and up in this report.
These are the results offered in the text section of this report and how they compare with the Tables section. I will be looking at the Conclusions and Recommendations and seeing how realistic they are with regards to the data found.
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