COMING BACK TO THE M.O.E. REVIEW LETTER OF JUNE 13,2018

I posted here about this letter this past Wednesday. There are some additional comments required. The main thrust of the 2017 Canagagigue Creek Investigation was to provide data and support for an upcoming bastardization of the Risk Assessment process which was also done in 2004. That human health and ecological SSRA (Site Specific Risk Assessment) however was solely in regards to the Uniroyal/Chemtura property. As a highly informed albeit non professional I can advise that speaking in the vernacular, the SSRA was a glorified piece of horse crap. Now we did have a professional PhD in Biology who examined, researched, and questioned the process from start to finish. Dr. Henry Regier even went so far as to travel to Hamilton to talk to the "expert" bureaucrats involved. He wrote a number of reviews and comments about the SSRA as practiced here in Elmira and no he did not say that it was a glorified piece of horse crap. I still have his reviews and comments and I can assure you that his professionalism and focus on facts and proper process and procedures are second to none. He much more smoothly and nicely, albeit very strongly, came to similar conclusions as I did regarding the first SSRA done here by Uniroyal/Chemtura and their fellow travellors. Now we're getting a second one by the same folks who brought us their original odourous psuedo science. Aren't we lucky?

The M.O.E. would like Lanxess to do additional biological investigations this summer in the Canagagigue Creek. Presumably this will mean fish although it could certainly mean a whole lot more than fish as well.

The M.O.E. in their letter have pointed out that the report issued a few months back was simply raw data with no evaluations of it included. Many specific questions need to be answered in the evaluations included in the final report.

Page 3 of the M.O.E. review has an example Table provided by the M.O.E. The data however is quite eye opening. It shows Dioxin/Furan Soil & Sediment results at various locations in the creek by depth. Five out of the six locations have their highest concentrations of Dioxin/Furans at the deepest depth tested and the sixth one has its highest concentration found at the second deepest sampling point.

There are a number of errors in the report by GHD on behalf of Lanxess. I used to complain about the reports done by CRA being riddled with errors of one type or another. The good news is that GHD are carrying on in the same fine tradition and it is encouraging to see that they also appear unable to consistently match text to figures and to make other typographical and amateur (unedited?) errors.