RECOMMENDATIONS OF THE REMEDIAL ACTION PLAN DESIGN REVIEW (Sept. 25/15)

My post on Tuesday (Nov. 24) indicated that I found the numerous Scenarios for off-site pumping to be bizarre. Essentially I could not fine one Scenario that even came close to reducing the entire Elmira Aquifers to or below Ontario Drinking Water Standards (ODWS) for NDMA and Chlorobenzene. With eleven different Scenarios available for each chemical and in each of the Municipal Upper (MU) and Municipal Lower (ML) Aquifers, there certainly was significant differences in the size and location of the plumes. That said the Recommendation provided by GHD (CRA) is that pumping Scenario 11 is the one to go with.

Scenario 11 incorporates the existing off-site wells namely W4, W5A/B and E7. Well W3 has been replaced by W3R (R for replacement). It is immediately beside the old well. New off-site wells include W6A, W6B and W9A. The text on page 48 states: "Scenario 11 achieves the best overall reduction in initial mass and initial MU/ML off-site area above ODWS for NDMA and chlorobenzene.". In other words Scenario 11 removes the most contaminant mass and shrinks the area of the plume the most; and that's it folks. No more bragging about achieving drinking water standards for all contaminants in all aquifers apparently.

Also when one looks carefully at the numbers involved, something is amiss. The total off-site pumping is approximately 106 litres per second. Depending on which constantly changing numbers you use as the current pumping rates, that is a skinny doubling of the pumping rates. In fact the pumping rates for the last year have been very good, historically speaking, and have averaged around 60 l/sec. In other words this new plan isn't really even a doubling of the rate.

Then look a little more carefully. This new pumping Scenario includes Well E7 at 30.9 l/sec. We were told this past summer and fall that well E7 was going to be shut down and now here they have it back in business and pumping hard. Which is the truth? Also W3R is scheduled to pump an astounding 37.9 l/sec. I don't believe this new well has proven itself capable of those numbers as yet. Also no mention of In Situ Chemical Oxidation. This form of source removal should be used at hot spots to quickly reduce contaminant mass and make the groundwater pumping both more effective and more timely. To date we have no proof of either Chemtura's commitment to use it or that it will be effective for both NDMA and Chlorobenzene if they do decide to go with it.

Both my predictions from years ago and CPAC's since 2012 are now accepted as accurate. Even with this proposed major increase in off-site pumping rates; things are not looking good for 2028.