MORE ON THE REMEDIAL ACTION PLAN DESIGN REVIEW - Sept. 25/15

It's not all bad news. Further plume delineation of the off-site northwest Municipal Upper NDMA plume indicate that it is smaller than originally thought. Monitoring well results from pages 13 & 14 show Non Detect results for NDMA at new wells located very close to OW60 the hot spot for NDMA. This well is located in the residential area just north and west from the old Shirt Factory on Park Street. Similarily the extent of the MU NDMA plumes around new pumping well W6B on Oriole Parkway and around W9, the former apple orchard on Union St. have also been reduced due to new groundwater monitoring results.

The Municpal Lower aquifer has two separate NDMA lobes. One is on the Yara (Nutrite) property on Chemtura's western border and the other is further south starting from just behind the old Varnicolor Chemical site on Union St. beteen First and Howard Ave. It then runs southwards down towards Oriole Parkway. The NDMA results on the Yara property are astonishingly high as in 300-340 parts per billion. These results are frankly horrific when the drinking water standard is .009 ppb. The NDMA results in the ML in the second plume are much lower in the 2-6 ppb. range yet still hundreds of times greater than the drinking standard. These plumes do not appear to be much different than originally determined.

page 16: Chlorobenzene in the Municipal Upper Aquifer now appears to contain more mass than originally expected based on the latest monitoring results. Again the chlorobenzene results around OW60 (north-west of Park St.) are consistent with the known low chlorobenzene results in that area. Both pumping well W3 and monitoring well CH38 on Orilo Parkway had few surprises in this latest review. Chlorobenzene concentrations are below drinking standards at CH38 and still above them at W3. New pumping well W6B located west of CH38 on Oriole Parkway also is below the drinking standard. The new well (OW 171) between W5A/B and W4 behind Varnicolor is the well whose concentrations indicate greater mass than expected.

page 17: Here we also see indications of greater chlorobenzene mass in the Municipal Lower (ML) than originally thought even as late as the 2012 report. This is not good news and further indicates the difficulty in achieving cleanup by 2028. All the other chlorobenzene results indicate very high concentrations as expected, including hundreds and thousands of parts per billion in the ML.

page 17 & 18: Chemtura and consultants are still claiming a lack of chlorobenzene in the Bedrock Aquifer. Frankly based upon the direct connections with it due to lack of competent aquitards I find that result unlikely. Whether dissolved or free phase, I expect at some point we will suddenly "discover" chlorobenzene in the Bedrock.

All in all so far in this report I am smelling lots of excuses. It makes me wonder yet again how Chemtura/CRA/M.O.E. could have been so confident of success over the last fifteen years based upon allegedly incomplete hydrogeological information. The other problem of course is even after they "learn" more there is such a long turnaround time to make significant improvements in their remediation efforts. It's now over three years since they identified the need to triple the off-site pumping and do some off-site source removal via In Situ Chemical Oxidation (ISCO) and neither is up and running yet.