The following information is gleaned from Appendix E of the Minutes of the March 24/22 TAG meeting. TAG properly are concerned with the small list of Contaminants of Potential Concern (COPC) particularly PAHs or Polycyclic Aromatic Hydrocarbons. Apparently the criteria exceeded in sediments in the creek by PAHs refer to fish and sediment dwelling organisms and not human beings. TAG feel that that is inadequate as human beings can be exposed top sediments via swimming, wading and ingestion. Also groundwater contamination needs to be included in the Risk Assessment (RA) due to potential of vapour intrusion into buildings. .............................................................................. Of great concern is "dose averaging" whereby short term exposure of 60 days per year by farmers/residents is then averaged out over their lifetimes greatly reducing the so called average day's exposures. TAG's experts claim that short-duration exposures to carcinogens should be toxicologically equivalent to dose averaged daily exposures and they are not through the RA process. Wow! Also regarding contaminated groundwater is the issue of future sub-surface work being ignored. This includes utility conduit installations, foundation repair, excavating and trenching. .................................................................................. Interestingly although dioxin/furans and DDT compounds were accepted as COPCs, TAG points out that they were misidentified as NOT being volatile (i.e. easily transfer to the gaseous state) compounds when in fact by the MOE/MECP definition they are. ................................................................................. Tissue Residue Guidelines (TRG) in fish were well exceeded by dioxins, DDT, mercury and PCBs. This was despite the fact that these contaminants accumulate in fatty tissues, eggs and various organs (liver etc.). Instead the MOE/MECP only tested for the contaminants in lean, dorsal, skinless, boneless muscle tissue of the fish. Yet another way for polluters and their friends (MECP) to tilt the RA in the money saving direction they want. Also the RA has a ton of assumptions that are NOT either logically demonstrated or proven through real data. These include that free range chickens are not allowed to wander onto bank/floodplain soils, limited transit time of cattle crossings (creek) and grazing and the dilution of sediment mixed with native soils in field amendments (possibly dilution as well in childrens' sandboxes?). TAG indicates that there are no covenants or restrictions on farmland properties that would prohobit or control any of those activities. Lastly vegetation/garden produce potentially cultivated in contaminated sediment/soil sourced from the creek has not been properly considered in the RA. ....................................................................... These are all significant issues raised by TAG and not the complete list of their's and certainly not of mine. The fact that I and the public are oh so graciously "allowed" to submit something in writing to a biased, self-serving process fully captured by the polluter and friends is not reassuring.
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