COPC AND OTHER BIZARRE/DISHONEST? DECISIONS WITHIN THE CREEK RISK ASSESSMENT

First of all is this as stated a "Canagagigue Creek Risk Assessment" or is it solely a Uniroyal Chemical caused Creek Risk Assessment? Those two are a world apart. Lanxess Canada claims/alleges that Uniroyal Chemical is NOT responsible for PCBs, mercury or PAHs (Polycyclic Aromatic Hydrocarbons) found in the Creek both above and below health criteria. Does Lanxess and every other corporate owner of this Elmira site lie? Dunh...let me count the ways over the last thirty plus years. The answer is yes. However on this particular issue I don't know although the real question is are we doing a Creek Risk Assessment to determine the health & environmental risks to humans and other life forms from all contaminants present or only those that we can prove came from Uniroyal Chemical? In other words would for example the local residents down the Creek be pleased to know that their cancers and other diseases are caused by different industrial polluters than Uniroyal Chemical? Would that ease their suffering somehow? I doubt it. This should be a complete Risk Assessment of the Canagagigue Creek not of allegedly just Uniroyal toxins that are present in great amounts. .................................................................................................................................. Even Uniroyal's long list of solvents, pesticides, dioxins etc. are not remotely included in this Risk Assessment (RA). They have scoped/removed literally hundreds of toxic contaminants from consideration based upon what I perceive as frivolous and self-serving criteria and rationales. A figure of 150 different chemicals present is in the report somewhere I believe. Oddly, the rationales for exclusion given on Table D.1 Appendix D are not consistent. For example both mercury and PCBs have at least one "Not site related" rationale given but different rationales dependent upon where the sample was taken. Bizarre. Regarding PAHs they appear to blame "Elevated detection limits>screening level" in many parts of this Table which seems to me to be nonsensical. No where in this Table have I seen the claim that PAHs are not a Uniroyal compound whereas it does say so in the text. What the hell? ................................................................................................................. Overall COPC (Contaminants of Potential Concern) are a real concern of mine. Willy nilly exclusion of toxic chemicals in the natural environment including Lanxess site soils, downstream creekbank soils and floodplain soils is ridiculous. Don't even get me started on the asinine sampling biases in most of the analytical data. Yes Susan Bryant suggested that Lanxess should remove grossly contaminated soils and sediments downstream however just look at the number of samples taken in only two or three places (coincidentally nearest roads & bridges providing easy sampling access) versus the very few samples taken in less readily accessible locations. Is it any wonder that far more high concentrations were found near the New Jerusalem and Northfield Dr. bridges when they were samled so much more often than other locations? I don't think so. This entire RA project is and always has been a crock and a sham and I've said so consistently here in my posts for years, report by report filled with errors, omissions and junk science.