PROBLEM FORMULATION DOCUMENT FOR THE RISK ASSESSMENT FOR THE CANAGAGIGUE CREEK (HHERA)

This document is 551 pages long and was sent by e-mail. Ten to thirty years ago I and others would have been screaming at the assho.es in charge if they had dared to pull that kind of shi. Today it's the norm because the numbers of honest, pissed off citizens holding Uniroyal Chemical's feet to the fire are gone. It gets worse of course. The link with the report on it disappears/expires? after a few weeks so if you haven't downloaded it, it is gone. Or I suppose you could fill up your personal computer with it and every other report. .................................................................................................................... Basically this report is an excuse for delay. Chemical after chemical discovered in creek sediments in 1995-96 are now allegedly at lower concentrations and as such the 95-96 concentrations are dismissed as "historical" and no longer relevant. I wonder if they were relevant to the lifeforms downstream, including humans, whose health sufferred from them? Neither Lanxess today nor the Ministry of Environment care. They know that these toxins in either suspended sediments or sediments in the bottom of the creek are constantly moving downstream via normal flow as well as during heavier storms and floods. As production of DDT and Agent Orange (2,4-D & 2,4,5-T) has stopped, these particular compounds eventually have to have all migrated off site, into the creek and then downstream. ............................................................................................... Benzo.a.perylene, Endrin, Aldrin, chlordane, lindane, heptachlor expoxide and more were all present in high concentrations at one time but apparently are harder to find now. I say apparently because no informed and honest people believe a word coming out of the mouths of the company, their consultants or the Ministry (MOE/MECP). So called "background" levels are also part of the scam.I've known and stated for thirty years that using the Canagagigue Creek waters immediately above the Uniroyal site is absolute bullsh.t. There is way too much pollution already in the creek from both Bolender Park Landfill (with Uniroyal wastes in it) as well as from other upstream industries. ............................................................................................................ Other chemicals removed from the status of COPC (contaminants of potential concern) include toluene, aniline, NDEA, BHEP, copper and yes PCBs. Lots of PCBs allegedly at one time in the creek. Where are they from? Allegedly they are not from Uniroyal/Lanxess which is all that it takes apparently to remove them from the COPC list. There were 64 detections of them in creek sediments in 1995-96. Ten of those detections exceeded the sediment criteria with the largest concentration exceeding the criteria by thirteen times. Wow! However the good news for downstream residents and creek users is that PCBs and their extreme toxicity whether still present or not have been removed from the COPC list which means that they will not be considered as part of either the Ecological Risk Assessment or the Human Health Risk Assessment. I mean would it be fair to include these obvious health dangers to nearby residents in a Lanxess Risk Assessment? Then regardless of who is the source (my bet is still Uniroyal) Lanxess would have to be part of the cleanup/remediation solution. Oh gosh how unfair to our local but WORLD CLASS POLLUTER. Whatever we do we must not alienate or upset them and lose a bit of taxbase and or employment. Once again let the citizens suffer from the sins of industry. This is always best achieved by the polluter and fellow travellors being in full control of all the reports, documents and citizens permitted to speak and sit at so called public meetings.