Anonymous public comment

Document ID: EPA-HQ-OPP-2008-0850-0056
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: October 02 2011, at 12:00 AM Eastern Daylight Time
Date Posted: October 3 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: August 24 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: October 6 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80f4a202
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What value is commenting on Chlorpyrifos Oxon nearly thirty years after the EPA was notified of its existence but still has taken no action? The State of Illinois notified the EPA in the early 1980’s of their discovery of the conversion of Chlorpyrifos to Chlorpyrifos Oxon in chlorinated water. The EPA took no action. Several other States have since notified the EPA after finding this issue. The USDA also published a scientific paper after they thought they had discovered the issue. The EPA has done nothing. Why is this issue important? Dow has been using a super chlorination procedure to “decontaminate” water sources contaminated with Chlorpyrifos. Dow also has known since at least the early 1980s of this conversion issue but continued to use this procedure. Why is this so important? Chlorpyrifos Oxon can exist for an extended time in the cool, dark conditions in wells. Dow’s decontamination procedure actually made the water more toxic to all those who drank from the contaminated wells. Chlorpyrifos is considered to be 3000 times more toxic than Chlorpyrifos. Tens of thousands of people have been affected by Dow’s criminally fraudulent actions and by the EPA’s incompetence. Why did Dow use this procedure? Dow used this procedure because it allowed them to hide well contaminations. Each well contamination is a possible media event which they avoided. Contaminating water gets the media’s attention. How did it do this? The procedure converted Chlorpyrifos, which is easily detected in water due to its foul taste and sulfur odor, into Chlorpyrifos Oxon which is odorless and has no taste. Their use of the decontamination procedure gave those using the contaminated water the false sense of having clean water again after supposedly having their water decontaminated. Dow reported to them after analysis of their water that they had no Chlorpyrifos but Dow knew they contained Chlorpyrifos Oxon and did not warn them of this highly toxic material.

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