WILSON LAU (TAG) AND "DOSE AVERAGING" OR A FANCY TERM FOR DILUTION IS THE SOLUTION TO POLLUTION

In the Canagagigue Creek there are Sediment exceedances of the ISQG (Interim Sediment Quality Guidelines) hundreds and even a couple of thousand times greater than the criteria. There are also exceedances of the Table 8 MECP Guidelines for Soil that are hundreds of times greater than the criteria. There are surface soils on the Lanxess property, there are creekbank soils above the waterline along the creek and there are Floodplain Soils further downstream which also have high concentrations of DDT and dioxins/furans. Clearly the source of these exceedances and toxic contaminants is the former Uniroyal Chemical now known as Lanxess Canada. Possibly/allegedly there are different sources for mercury, PAHs and PCBs in the Canagagigue Creek. I say possibly/allegedly because after thirty plus years of lying and deception who in the world knows when those @#$%^&* are telling the truth or not? ....................................................................................................... Yes there are very high and toxic concentrations of DDT, dioxins/furans and so many other chemicals here and there in the creek soils and sediments both on and off the former Uniroyal property. At the same time there are hundreds of low level concentrations of these very same chemicals intermingled from the Uniroyal/Lanxess site all the way down to the Grand River (& likely past). Why is this? Well first of all certain hydrophobic chemical compounds far more readily attach themselves to soils and particles rather than dissolve freely in water. These moving suspended sediments in surface water bodies (Creeks, rivers etc.) usually end up downstream being deposited either on the bottom of the waterway (i.e. sediments) or along curves in the creek. Hence there are both depositional as well as erosional areas along creeks. These of course can change over decades and centuries. ................................................................................................................... I have long maintained that there has been a huge sampling bias over the years in the Canagagigue Creek. Firstly it's so much easier for technicians and samplers to access the creek at the various three roads and bridges crosssing the Canagagigue namely New Jerusalm Rd., Northfield Dr. and Jigs Hollow Dr (By West Montrose). Secondly as soon as you've hit some high concentrations you keep coming back to the same easy access area. hence there are huge portions of the downstream Canagagigue that have never been sampled. ......................................................................................................................... Now for the purposes of both a Human Health and Ecological Risk Assessment (HHERA) Lanxess and friends are looking at the presence of toxic compounds in the natural environment (i.e. Risk). Then they are looking at whether there are any Receptors (human & wildlife). Finally they are looking at and calculating the amount of Exposure of each and every receptor to the toxic compounds that are present. Right off the bat they are looking at probabilities not possibilities. In other words if the human presence is limited by recreational opportunities such as the "Gig" not being a trout river then that lowers the risk. If the Canagagigue ("Gig") doesn't have rapids then there is no exposure from white water rafting. There are a hundred opportunities to limit exposure times and amounts and the various algorithms and calculations incorporate them. There are also opportunities to limit the number of toxic compounds and hence Risk. Lanxess refuse to acknowledge that exposure to Polycyclic Aromatic Hydrocarbons (PAH), PCBs and mercury are their repsonsibility so despite their presence in the creek they are totally removed in the mathematical considerations. Lanxess and friends then pretend that they have properly calculated the Risk and Exposure to local residents, wildlife and recreational users when they have not. .......................................................................................................... Going back to "Dose Averaging" I might agree in theory that a creek that has only 50% of it's length grossly contaminated MIGHT (or Not) be less toxic or risky that one that is grossly contaminated from Lanxess all the way (5 miles plus) downstream to the Grand River. This is because end points could include acute poisoning and quick death or longer term toxic doses that also eventually end up in death. In other words dead is dead whether today or tomorrow. Similarly cancer can be provoked by short term acute exposures or by longer term lesser exposures. Much of these Risk Assessment calculations are based on assumptions and guesswork. The sloppier the sampling (sampling biases), the sloppier the analyses (Detection Limits> criteria), the sloppier the public consultation (ELMIRA!) and the more dishonest the people in charge, the greater the assumptions and guesswork. .................................................................................................................................. In a nutshell what are Lanxess, GHD and Stantec doing with their Risk Assessment? By examing the toxins that have flowed five miles downstream over the last 3/4 century they are appropriately admitting the obvious. Pollution migrates. What they are conveniently pretending to ignore is that DILUTION IS THE SOLUTION TO POLLUTION. They are intentionally averaging in all the low level detections of DDT and dioxins/furans found both on their site and found even more two to five miles downstream. The reality is that all their various chemical compounds have gone far past the mouth of the "Gig" into the Grand River but again they have been even more diluted in the higher water volumes in the Grand River. The Canagagigue should have been cleaned up fifty years ago but what the hell it has moved tremendous amounts of Uniroyal's poisons downstream and this free waste disposal service was not going to be stopped a single minute sooner than necessary. And our governments and Ministry of Environment have enabled this shameful disgrace without conscience. And now Lanxess want a pat on the back and an "Atta boy" for a grossly delayed and grossly inadequate "cleanup" of the creek. They all deserve time in prison for their antisocial and criminal behaviours.