REMEDIAL ACTION PLAN DESIGN REVIEW - Sept. 25, 2015

Par for the course. A major technical Chemtura document released by CRA (GHD) on behalf of Chemtura Canada dated September 25/15 and of course neither the most knowledgeable Woolwich citizen (moi) nor any CPAC members received a copy of it. This crap has been going on for a very long time although I do remember the M.O.E. taking a beating from a past CPAC and possibly even their chair Pat Mclean over putting Elmira items on the EBR (Environmental Registry) without verbally or in writing advising CPAC.

page 4: "NDMA and Chlorobenzene concentrations in the April 2014 groundwater samples collected from W8 were 295.5 ug/l (ppb) and 4,300 ug/l (ppb), respectively. These are the greatest concentrations of NDMA and Chlorobenzene in the off-site MA (Municipal Aquifer)." W8 is located on the Yara (Nutrite) property very close to Union St. in Elmira.

"...the full implementation of the off-site CTS pumping regieme recommended in the 2012 Model Update is not feasible. These include: Confirming the maximum pumping rate for existing extraction well W3 is 25L/s, approximately half the 51 L/s recommended in the 2012 Model Update".

page 5: "Damage revealed to extraction wells W5A and W5B required subsequent repairs that restrict their well yield to 5.0 and 6.3 L/s, respectively, which is less than the 12.6 L/s and 9.5 L/s respectively, recommended in the 2012 Model Update".

page 8: "The MAT is composed of silt till and it separates the MU and the ML into two distinct aquifers. The LGR zone is composed of fine sand. Where the LGR is present, the MU and ML combine to form a single aquifer." This is news to me as to date Chemtura/CRA have referred to the LGR (Low Gamma Resistivity zone) as a poor aquitard. Now , twenty-five years later, we are informed that it absolutely is no aquitard at all and in fact the MU (municipal upper) and ML (municipal lower) are actually one aquifer where the LGR is between them.

page 9: This also refers to "...aquifer like, or LGR like, material separating the MU from the ML.". In essence this simply advises that there are even more "windows" between the Elmira Aquifers than we previously were told and hence explains how great the early days BS we got from Uniroyal Chemical was, regarding "impermeable" clay aquitards protecting the drinking water aquifers from contamination.

page 10: "This is consistent with the MU composition observed at other locations, with a thick, silty gravel layer overlying a thin, coarse, well graded gravel layer.". I see this as possibly indicating a preferred route of groundwater flow at the bottom of the Municipal Aquifer with lesser flow through the higher elevations of the MU. Hence this could explain differences in contaminant concentrations in the same aquifer at the same or nearby locations.

page 11: "The MU is 3.9 m thick...". The 2012 Model Update predicted the MU would be approximately 6 m (metres) thick at the W6 extraction well location (Oriole Parkway)." "The MU and ML are thinner at the W6A/B location than was represented in the 2012 Model Update.". The significance of this is similar to the other pumping wells already mentioned. The proposed/predicted tripling of off-site groundwater pumping simply can not happen.

This is why Jeff Merriman of Chemtura now talks about doubling the pumping rate while at the same time referring to ceasing all pumping at E7. They've stated that ISCO (chemical oxidation) won't work on the Yara property and now we see that the increased pumping regimen is highly unlikely. Other than buying another three years of time exactly what have they accomplished? Most likely they are three years closer to closing up shop and leaving the entire mess to Canadian taxpayers. Thank You M.O.E. and many Woolwich Councils along with Regional Councils.