Monday, April 23, 2012

CRA BAIT AND SWITCH TACTICS



One of the items on the Agenda for this Thursday's public CPAC meeting (6 pm.) is Chemtura's remediation plan for GP1 and GP2. These gravel pits were used back in the sixty's as the overflow destination of liquid toxic wastes which had been dumped into the east side pits at the then Uniroyal Chemical. These pits were the repository for tars, sludges, used solvents and wastes from all Uniroyal processes including DDT and Agent Orange production. Keep in mind that the two consolidation pits, RPE 4 & 5 were ordered excavated in the Settlement Agreement (sweetheart deal) of October 7, 1991. The M.O.E. and others flatly blamed these pits as contributing to the destruction of the Elmira Municipal Aquifer.

CRA on behalf of Chemtura wrote a work plan dated July 28, 2011. It is included as Appendix A in their report "Former Gravel Pit Investigation", March 2012. On page 13 in Appendix A CRA state " CRA will submit approximately 19 soil samples from intervals that are most likely to represent the most conservative conditions (ie. locations with the greatest contamination). I herein accuse them of failing to do this. Their test pit excavations are detailed in Appendix D. Eight of them are a whopping 1 metre (3 feet) in depth. The deepest pit is 2.13 metres .

Now lets go back to Appendix A, the Work Plan. Pages 8 & 9 have a Table titled "Summary of Key Soil Quality Observations in Stratigraphic logs". Borehole stratigraphic logs are simply a detailed observation of the soil removed when a borehole is drilled. The soil is laid out in order of its' removal from the subsurface so that scientists can correlate contamination to exact depths. These boreholes are from the following observation wells all in the south-east corner of the site, nearest to GP1 & 2. Starting from the top of the Table, I will quote parts thereof.

OW24-12 "Black stained sand and silt from 2.75 mbgs to 3.7 mbgs." (metres below ground surface)
OW15-7 "Strong chemical odours and elevated PID readings (50.2 ppm) from 3.3 mbgs to 5.5 mbgs."
OW69-13,8,3 "Strong odours from 4 mbgs to 5 mbgs."
OW146-3 "Chemical odours from 2.2 mbgs to 2.5 mbgs. Black stained gravel from 2.2 mbgs to 2.5 mbgs."
OW145-4 "Strong chemical odours from 1.2 mbgs to 2.5 mbgs." By the way the two nearest testpits (TP 18 & 19) were only excavated to 1 mbgs.
OW16-10 "Strong chemical odours and elevated PID reading (52.8 ppm) from 3.0 mbgs to 3.8 mbgs."
OW16-3 "Strong chemical odours from .7 mbgs to 3.5 mbgs." Again the nearest testpits were all of 1 metre in depth.
OW144-3 "Strong odours from 3.0 mbgs to 4.9 mbgs."

A skeptic could be forgiven for thinking that CRA have used their work plan as a blueprint for avoiding the worst contamination in GP1 & 2 as well as in the entire south-east corner. It appears that unsurprisingly the liquid contamination has moved vertically downwards into the ground and is much worse deeper than shallower. Removing the top .3 metre of soil is strictly a cosmetic fix and in my opinion is a typical CRA/Chemtura/M.O.E. pretend cleanup.

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