OTHER SIGNIFICANT FACTS FOUND IN THE JULY 2003 CPAC REQUEST FOR ACTION

There are some reminders of facts which Uniroyal and successors have traditionally attempted to either deny or underplay. For example Action 3. is to excavate RPW-1 and RPW-2. These letters stand for Retention Pit 1 & 2. At the top of page 2 we are advised that there is evidence of DDT in groundwater samples. Polluters like to claim that certain chemicals are hydrophobic and do not readily dissolve in water. Well they are in the groundwater on the Uniroyal site. Also DDT as well as dioxins are in Ontario's list of legislated maximum concentrations allowed in drinking water. This list is the Ontario Drinking Water Standards or ODWS. If these compounds had zero solubility in water then they would not need to be on this drinking water list in the first place. ........................................................................................................................ Also on page 2 under 5. which is to excavate entire dry channel and island we are advised that Light Non Aqueous Phase Liquid (LNAPL) mobilizes dioxins. In fact a 1996 LNAPL sample showed 209,070 parts per trillion (ppt) dioxin. Just recently Lanxess (GHD) have advised TAG that toluene, a LNAPL chemical and the major component of the on-site LNAPL plume, can not dissolve or mobilize dioxins unless it is at a ridiculously high concentration in groundwater. Well guess what? That is exactly what LNAPL is. There is too much of the chemical (toluene) present to fully dissolve in groundwater hence the chemical floats on the surface of the groundwater and is called LNAPL. ............................................................................................................... CPAC made very clear that hydraulic containment alone of the Uniroyal (Lanxess) site was not adequate. They also strongly believed that "Eliminating hot spots on a reasonable schedule, starting with the worst spots will speed the clean-up of the off-site aquifer as well as the downstream sediments." Today and for the last few years all parties, the guilty ones and others, now admit that hydraulic containment alone will fail to meet the mandated 2028 deadline. Citizens and CPAC were correct but the process in Ontario allows the polluter to run the show up to and including riding roughshod over an anemic, impotent Ministry of Environment. Why do we allow this perverted process in Ontario? The answer is power and $$$$$$$$$$$$$ defeats truth, facts, environmental and human health.