MORE RISK ASSESSMENT B/S COURTESY OF LANXESS & GHD

LANXESS have responded to a Ministry of Environment letter dated April 9, 2020 regarding COPC's, CSM and 2020 sampling program. That stands for Contaminants of Potential Concern and Conceptual Site Model. Page 2 in the report by Lanxess references upstream Uniroyal Chemical industrial wastes in the Bolender Park Landfill. Lanxess are quoting an old report which states that some of Uniroyal's wastes were put in this landfill including filter cloths. It does not say ONLY filter cloths it says including filter cloths. And what else could Uniroyal have possibly put in the Bolender Park Landfill? Let's see now how about dioxins, resins and absolutely everything else that they put in M2 in barrels and more. .................................................................................................. The Stroh Drain sediments are going to be sampled in the fall. Wow that only took that pack of slobs what, six years, to do the obvious? For them and the MECP that's pretty good. The MECP still say that the shovel method of collecting sediment samples is inappropriate but rest assurred they'll roll over in time not to slow down Lanxess's mickey mouse Risk Assessment. ................................................................................................... Turns out that there was a Lindane release in 2000. Refresh my memory please with the details about that particular release among hundreds. ............................................................................................................... On page 6 it looks to me as if GHD were caught by the MECP gilding the lily somewhat. This was in regards to a screening limit regarding frequency of detection (5%) of compounds. Never fear, polluter lovers, there are no penalties for creative fibbing in hydrogeology. ............................................................................................................... On page 10 Lanxess claim that they only have info on Uniroyal industrial deposits into the Bolender Landfill from two old reports. Are they conveniently forgetting the CRA reports done in the 1980s describing Elmira's (i.e. Uniroyal's) industrial desposits into the landfills? ................................................................................................................. On page 13 there is discussion of ongoing subsurface toluene as an LNAPL assisting the transport of DDT and dioxins into the creek. Tsk Tsk! This could have and should have been cleaned up twenty-five yuears ago. Back to haunt you and no surprise. .................................................................................................. Page 14 mentions ten different Uniroyal chemicals that are greater than their groundwater criteria on site. They include benzene, toluene, chlorobenzene, TCE, 1,2 dichlorobenzene, chlorophenol, 1,4 dichlorobenzene, 2,4,5-T, ethylbenzene and DDT. Oddly very few of these made Lanxess's COPC list. How odd. ...................................................................................................................... On page 15 Lanxess is refusing to consider additional parameters be analysed in the sediment. Oh Oh Lanxess. The MECP might publicly call you out and beg you to do more. Lastly the MECP believe that historic (past) creek bed locations should be sampled. Of course they should but come on now, you've already raised your voice once. You don't want to hurt the company and their consultant's feelings do you?