TAG CONTINUES TO STICKHANDLE CAREFULLY WITH LANXESS/GHD/STANTEC

So do I celebrate TAG's appropriate concerns and criticisms as ever so carefully expressed last evening at the virtual Technical Advisory Group meeting or do I condemn their bullsh.t flattery and stroking of Lanxess, GHD and Stantec egos? Both I guess. The Draft Risk Assessment (HHERA) for the Canagagigue Creek was presented by Loren Knopper of Stantec and it was an unmitigated piece of garbage. In fact I was wearing as usual my UBC (Univ. of British Columbia) sweatshirt and hoping that somebody/anybody would ask me what the letters stood for. My response was going to be either "Utter Bull Crap" or "Unusually Bad Crap". Alas other than the short on-line social time prior to the meeting, yours truly and other non approved persons by Lanxess/MECP/Woolwich Twn., are not allowed to speak. Disgusting and contemptible and it will be the most blatant and obvious failure of public consultation and this entire process eventually. .............................................................................................................. First of all as indicated in the HHERA (Risk Assessment) the Stroh property is indeed part of the "Study Area" according to Mr. Knopper. He also pointed out that there are/were 150 different Uniroyal chemicals initially considered. The fact that they narrowed them down to only four COPCs (Contaminants of Potential Concern) for the study is in my opinion a triumph of scoping, bizarre logic, self-serving psuedo science and world class puffery. Mr. Knopper confirmed that as long as PPE (Personal Protective Equipment) is used on the Uniroyal/Lanxess site (Reach 4) then all human health risks are ACCEPTABLE the length of Canagagigue Creek all the way down to the Grand River. Regarding the Ecological Risk Assessment things are merely slightly more tenuous as Reaches 1-4 are fine (i.e. Acceptable) for everything except birds and mammals. Hence reptiles, fish, amphibians, invertebrates allegedly will not be harmed by major exceedances of DDT, dioxins/furans/PCBs, mercury, beta-BHC, lindane etc. anywhere in the creek. Well sort of: the Risk assessment is ignoring excessive levels of PCBs, mercury and PAHs in the creek because allegedly they are not from Uniroyal Chemical. Yes they are in the creek but don't worry critters or humans, if you get sick or die from them it doesn't count against Uniroyal/Lanxess Canada. Isn't that just wonderful? Birds and mammals it is admitted may have some Unacceptable risks in Reaches 3 and 4 which are respectively closest to the site and the site itself (Reach 4). ........................................................................................................................... Sebastian (TAG & CPAC member) expressed concern with the lack of analytical data from the Stroh property. Two locations for sediment samples in the Stroh Drain accompanied by two soil sample results provided by myself with zero explanation/confirmation as to when, where and how they were collected. Mr. Knopper stickhandled around this very serious and appropriate concern. Sebastian also expressed interest and surprise regarding the alleged 48 pg/g (ppt) human health criteria stated in the report. After more than thirty years studying and attending public meetings on this site, that number/criteria was also news to me. Mr. Knopper defended it. Wilson Lau advised that the fish tissue results from several years ago were taken from lean tissues and thus not representative of where the bulk of dioxins in particular end up which is in fatty tissues as well as in the liver. Dr. Knopper suggested that humans only eat the lean tissues so all was well. ReallY? Are animals and predators of fish (including hawks, ospreys etc.) equally as discriminating? Wilson also had diffidulty following the rationale regarding garden produce, limited crossing time of cattle in the creek and lack of exposure to the creek of free range chickens. .......................................................................................................................................... Susan Bryant asked if there was any consideration in the Risk Assessment of pre-existing body burden of dioxins of residents along the creek. The answer was no as well as the fact that the Risk Assessment did not assess infants exposure to these chemicals through mothers' milk. David Hofbauer suggested that there actually was significant fishing in the Canagagigue Creek particularly from foot bridges in Reach 1 and 2. Ms. Bryant also asked about the very high concentrations of DDT and dioxins found in Reach 3. Mr. Knopper confirmed that in fact "statistical outliers" equaled "hot spots" in the creek. Susan suggested that these high concentrations (and toxicity) got washed into the other lower concentration data thus reducing its' obvious significance. This was similar to Wilson's comments right at the end of the meeting that "...dose averaging was a problem." Also a short duration exposure could be spread out over a long time in the various calculations. This also was not good or necessarily accurate. ................................................................................................................................. Susan B. also pointed out that Ramin Ansari of Lanxess had at one point advised that the end goal of the Risk Assessment was that it had to be acceptable to the local community. Susan suggested that leaving deposits of high concentration contaminants behind would NOT be ACCEPTABLE to the community and thus more removal needed to be done downstream. She also advised that the assumptions in the report that the land use (agricultural) would not change was "highly questionable". Sebastian Seibel-Achenbach pointed out clearly that there have never been ANY Health Studies done along the creek. The inference was clear that a Risk Assessment that has zero data regarding long exposed multi-generational local residents health is not good science or good anything. ....................................................................................................... TAG wil be sending written comments to Lanxess/MECP/Stantec etc. Unfortunately they will be far too diplomatic and far too deferential to likely persuade Lanxess to change anything.