CHEMTURA MONTHLY (SEPT.) PROGRESS REPORT

This Progress Report again was received late, namely on Wed. Oct. 20/10. Late in order to discuss September monitoring results and changes at the Oct. 18/10 CPAC meeting. Normally during non public CPAC meeting months it comes out on the 15th of the month. The Minutes and Agenda for the Oct. 18 meeting were received by the voting CPAC members Thurs. evening Oct. 14/10 by e-mail giving them one business day plus the weekend to read and absorb prior to the 9 am. Mon. meeting. I received mine Friday nite by e-mail only by special, last minute request by myself. Normally I'm phoned when they're ready, to come and pick them up.

The on site Municipal Upper Aquifer (MU) pumping was fine during September and with the exception of W4 (behind Varnicolor by the Watertower) so were the off site pumping wells. On page 5 , the claim is made by Conestoga Rovers (CRA) that UA3 (upper aquifer level 3) has a zone of "static" groundwater and does not flow off site. This is sketchy.The admission is made that the MU flows off site in the north-west but this is allegedly O.K. says CRA. Also the admission is made that on site groundwater flows offsite further south but it appears as if CRA think this is O.K. as it then flows back again on site where it is captured by well PW4. The M.O.E. have indicated indicated in the past that this is not acceptable but I'm confident that they will come around to Chemtura's point of view as they always do.

CRA claims that well E7 in the south end of Elmira is containing NDMA (and so much more) in the Bedrock Aquifer (BR). I view this as extreme wishful thinking on CRA's part as well E7 is only screened in the Municipal Lower (ML) not the BR and furthermore there is the LAT or Lower Aquitard between the well screen and the Bedrock Aquifer.

Further problems with this Monthly Progress Report include the complete lack of analytical data for both the on and off site wells in Table A.1 . How can one possibly judge the effectiveness of treatment systems without a clue as to what the influent is?
Figure D.3 is also worrisome as the head differential between surface water and groundwater is extremely tiny. CRA claim hydraulic containment in the Upper Aquifer based on the flimsiest and tiniest evidence.
The Sentry wells (Fig. D10- D13) clasim decreasing trends for Chlorobenzene but not for NDMA. Why this discrepancy?
Fig. D17 while not conclusive solely on its own merits nevertheless should raise huge questions as to why Varnicolor Chemical is at the centre of the largest area of Chlorobenzene concentrations in the Elmira Municipal Lower (ML) Aquifer. This is especially so as the M.O.E. labs 19 years ago claimed no Chlorobenzene was on the Varnicolor site. If not a smoking gun then surely it is a at least a noisy, recoiling one.
Table E.1 should be an embarassment to CRA. While repeatedly claiming that LNAPL (light non aqueous phase liquid) is not present, nevertheless in the fine print we find that in fact it certainly is.

This site is a disaster and these monthly reports are a greenwash. Source removal is and always has been necessary both on and off site. The off site source removal has only been known by myself and the public for a relatively short period of time but everyone has known of the necessity of on site source removal for more than two decades. Our town Council has been of little or no assistance from day one. This shameful behaviour continues.