MAY 2010 CHEMTURA MONTHLY PROGRESS REPORT

This monthly report was received about a week ago and is mandated by one of the Ministry of the Environment's Control Orders. Unfortunately as we have learned from bitter experience, a Control Order means little or nothing as the M.O.E. will alter, revoke or amend them at will (ie. the polluter's will) without proper public notice, public input and or proper clarity. In the near future I will describe the contemptible manner in which the M.O.E. amended the 1991 Control Order, which was supposed to provide that ALL contaminated groundwater on the Uniroyal (Chemtura) site did not travel offsite and further contaminate the natural environment.

Figure D.8 is certainly an improvement over dozens of CRA's past efforts to visualize Municipal Upper Aquifer (MU) containment on the Chemtura site. Perfection would be more downgradient (SW) contour lines which would hopefully demonstrate more clearly that the entire south-west corner of their site is hydraulically contained.

I've pointed out at PUBLIC Cpac meetings a number of errors in CRA's positioning of contour lines relative to their own data points. Now I must suggest that at the top of pg. 7 in the text that they've misnamed a well. Monitoring well pair OW63 / CH47E probably should be OW62 / CH47E. The more significant fact however is that CRA now wish to drop all 3 monitoring pairs. These 3 well pairs were introduced by CRA during the Ammonia Treatment System plans in the fall of 2007. Yours truly was the ONLY Cpac member who publicly stated that these well pairs were a scam in that they absolutely were horrible choices to allegedly determine hydraulic containment because CH97 was located where the MU was directly connected to the Upper Aquifer (UA). Also OW62 was located right beside PW4 (pumping well 4) and could hardly fail to always have a lower elevation than offsite CH47E thus allegedly "proving" hydraulic containment. Wilf Ruland (dependent hydrogeologist) and Susan Bryant; after I took Wilf through the technical details agreed with me PRIVATELY that these wells were problematic. The pair of them then conveniently ignored this in their rush to get me kicked off Cpac probably primarily due to my opposition to the ongoing and neverending (since 1991) DNAPL scam and investigations. My Ammonia Treatment System appeal to the Environmental Review Tribunal was merely the excuse they used to remove me from Cpac and the DNAPL sub-committee. 2 3/4 years later, it appears that even CRA (Conestoga Rovers) are willing to admit that these monitoring pairs are useless for the purpose they were intended.

Pages 7 & 8 of the text do a lot of stickhandling to prove CRA's commitment to full hydraulic containment in the MU. It continues to gild the lily by alleging that the pumping rates "represent the highest ratio of off-Site to on-Site pumping". This is nonsense in that the on site pumping rates were only reduced the day before. Go for a month at reduced on site pumping and you'll see a much greater reduction in hydraulic containment.

Lastly on pg. 8 CRA claim to have the Bedrock Aquifer contained at well E7 in the south end of Elmira. Please explain to me CRA how this is possible when E7 is NOT screened in the Bedrock and there is an Aquitard (LAT) between the E7 wellscreen in the Municipal Lower (ML) and the Bedrock Aquifer.