MINISTRY REPLIES TO CPAC REQUEST

At the last CPAC meeting in March, Sebastian asked George Karlos of the M.O.E. to do some sort of cost-benefit analysis regarding the Ministry's share of off-site pump and treat costs versus the estimated costs of on-site source removal of a limited area of NAPLS and contaminated soil etc.. To George's credit he has done so and in a timely manner. That being said it should also be pointed out that a very well respected SWAT team member namely Dr. Henry Regier did respond to CPAC and SWAT with a general overview of cost/benefit analyses. Henry advised that cost/benefit analyses are much too susceptible to mathematical jiggering. In other words the person doing or commissioning the study has a bias thus it is very easy if you know the end result you want, to ensure through your assumptions and data input to get that predetermined and desired result. Henry's analysis and work was also very helpful years ago at CPAC when he dissected so called risk assessments. These too could be easily managed through assumptions and data input to massage the result that was wanted by the people paying for the whole thing.

Regardless of these legitimate concerns I have found the M.O.E.'s two page analysis to be interesting. On a similar note the M.O.E. have recently released a report showing results of downstream sediment and floodplain soil testing done last fall in the Canagagigue Creek. This report too is flawed as it's locations tested make it impossible to compare with the testing done in 1996/97. George and the M.O.E. were advised in advance that their Work Plan should be shared with CPAC/SWAT ahead of time but they chose intentionally not to do so.

Getting back to the comparative analysis done by the M.O.E.; not surprisingly the costs of substantial source removal
at RPW5, 6, 7,8 are much higher than the Ministry's 50% share of off-site pump and treat. What surprised me is that they are as low as they are. The Ministry estimated them at between 34 and 51 million dollars. Quite frankly I view that as a bargain. Considering the environmental damage done by this south-west corner of Chemtura/Uniroyal and including human health costs past, present and future which the M.O.E. did not do; this is a bargain.