2010 ANNUAL MONITORING REPORT

Please note that two days ago I posted in regards to the Annual Environmental Report, a totally separate document. Today's comments will focus on Figures 4.5, 4.6, 4.7, 4.8, 4.9 and 4.10 which are in Volume II (Figures & Tables). First off Conestoga Rovers (CRA) have mislabelled part of Fig. 4.8. The Figure is dealing with Chlorobenzene in the Municipal Upper aquifer yet they have labelled the data in the included tables as NDMA. Unfortunately CRA relatively regularily screw up routine things like this.

Figures 4.5, 4.6 and 4.8 each have three tables included at the top, marked as Historic NDMA or Chlorobenzene, 2010 NDMA or Chloro.. and finally Abandoned .... Historic NDMA or Chloro.. . The significance is the greatly reduced monitoring done in 2010 in order to produce these Figures which allegedly show the current state of the NDMA and Chlorobenzene plumes. Not surprisingly some of these Figures show what appears to be smaller contaminant plumes. In fact by reducing the number of wells which they monitored in 2010 they have managed to avoid wells with higher concentrations . Thus the reduced plumes in some instances are merely an artifact of concessions which the old CPAC have given Chemtura/CRA over the last several years. I publicly spoke against these concessions at the time, knowing full well they would be used to produce false information that would make the "cleanup" look better.

You will also notice in the third table at the top titled Abandoned Wells, a listing of wells and their Historic concentrations, which have been removed from service. By looking at their historic concentrations you will see a number of abandoned wells which had very high NDMA or Chlorobenzene concentrations. In my opinion this was the major rationale for their removal. Again I argued with the old CPAC at public meetings that these wells represented consistent long term data that should not be abandoned simply because they were either embarassing or inconvenient to Chemtura/CRA. Again I say to the new CPAC: Do not even in your dreams consider for a moment polluting your integrity/credibility by incorporating some of these old CPAC members. You the new CPAC will learn the technical stuff. What you can't learn is integrity, responsibility and honesty to the public. Either you believe in that from the beginning and practice it or you will sellout eventually.