"RE-EVALUATION OF CANAGAGIGUE CREEK CONTAMINANTS OF POTENTIAL CONCERN-VERSION 2"

This document is dated October 25, 2019 and is a total of 600 plus pages. I've downloaded so far the 24 pages of text plus the first three figures (maps). In a nutshell it is my opinion that this program and related studies, testing, analysis etc. are just one more of many shams, scams, and psuedo science that is far more subjective than objective and far more financially motivated than anything else. Sorry for being so wishy-washy about it.

The big picture: It's all about whether or not a myriad (> 30) of contaminants found in the Creek both recently and as well decades ago are actually site-related Contaminants of Potential Concern (COPC). These contaminants include heavy metals (+ mercury), polyaromatic hydrocarbons (PAH), pesticides, insecticides (including DDT & metabolytes), PCBs, and dioxins/furans.

The Creek is still a mess despite coarse fish now living in it and bio-accumulating these chemicals and metals. Clean the G.D. creek! Just because Lanxess hope or want mercury, PCBs etc. not to be "site-related" is irrelevant. The DDT, dioxins/furans, lindane, PAHs, and more are theirs. Clean the Creek properly once and be done with it. If the MOE/MECP want to go after hypothetical (or real) upstream polluters after the fact is fine. Get the cleanup underway!

The timing of this Creek cleanup is excruciatingly self-serving for both the MOE/MECP and Lanxess. The collusion and incompetence surrounding Uniroyal Chemicals's destruction of the air, ground and surface water has been exposed for thirty years now. Three Decades!

Most of the blatant bulk waste water discharges of toxic chemicals ended between 1968- 1970. We have had fifty years (Half A Century!) of permitting groundwater flow, surface water flooding and accompanying erosion to dilute and disperse these toxins downstream into the Grand River and further. Our authorities have knowingly allowed neighbouring properties to be conduits to further disperse these toxins. How incredibly convenient to wait FIFTY Years before seriously considering any downstream cleanup whatsoever.

One contaminant after another is being excluded from the list of so called COPCs. Lanxess and friends (MOE/MECP) appear to be willing to settle on DDT and dioxins/furans being the only site-related COPCs. This exclusion process is not objective nor is it remotely scientific. It is entirely self-serving which is exactly what you would expect when the fox is in charge of security for the henhouse. Lanxess, their consultants (GHD) are running the show with token resistance/oversight from the MOE/MECP.

One of the many excuses (not reasons) for excluding various chemicals is that they do not have very much higher concentrations on the Lanxess property than are found immediately upstream. This is primarily due to the wise and self-serving decision to keep Woolwich Township senior staff and councillors on board over the decades. We the general public have long been denied technical reports showing Uniroyal Chemical toxins being dumped into all our local landfills including the Bolender Park Landfill immediately upstream of the site. What a great deal having artificially elevated contaminant levels upstream (i.e. so called "Background") to which you can compare the concentrations you still have on -site that to date have not eroded, flowed via solvent contaminated groundwater into the Creek, or otherwise been reduced over time.

Lastly the actual recent testing in the Canagagigue Creek has all been bogus. Between ridiculously high Method Detection Limits (MDLs) and using the "shovel" method of sampling versus the "core" method, the detections and exceedances of these toxins have all been artificially reduced. For the benefit of Lanxess supporters who cry "Show me a better way to sample the parts of the creek bed with "armouring" (i.e. hard stone, hard packed gravel etc.), let me say this. DON'T ATTEMPT TO SAMPLE THE ARMOURED CREEKBED. Dioxins/furans, DDT and other hydrophobic compounds adhere to sediments and fines, not to rocks and stones. By sampling in the least likely areas to find these toxins you are automatically reducing the percentage of sampling points that have exceedances. By using the "shovel" method you also lose fines as you pull the shovel up from below the water's surface. Also the high MDLs greatly exceed the provincial and federal criteria thus again falsely providing more non-detects which artificially reduce the percentage of exceedances of these toxic chemicals.

O.K. now lastly: Each and every toxin that is excluded allows our authorities to pretend that the Creek is less polluted than it really is. Our authorities DO NOT AND NEVER HAVE HAD ANY ABILITY WHATSOEVER TO MEASURE THE CUMULATIVE ENVIRONMENTAL OR HEALTH EFFECTS OF MULTIPLE CONTAMINANTS SIMULTANEOUSLY CO-EXISTING IN THE CANAGAGIGUE CREEK. ALL THEIR INDIVIDUAL CRITERIA PRETEND/ASSUME THAT THIS PARTICULAR CONTAMINANT ALONE IS PRESENT. IT IS A SHAM FOLKS! THEY ARE SCAMMING EVERYONE.