TAG WORK PLAN 2016 (October 22, 2015)

I am going to quote the last three (of four) objectives of the TAG Work Plan as listed on page 1 of Dr. Richard (Dick) Jackson's above titled report. They are to identify as follows:

2. "the problems with the monitoring and contamination of Canagagigue Creek in order to make recommendations to RAC"

3. "the problems associated with the monitoring and remediation of the Off-Site Municipal Aquifer in order to make recommendations to RAC"

4. "the problems associated with the monitoring and remediation of the On-Site Contamination at Chemtura in order to make recommendations to RAC"


Dr. Jackson has certainly identified these three major and possibly overwhelming problems in spades. These problems have been in existence since the very beginning. Some of them had been clearly identified both by the most recent CPAC as well as by past CPACs. All past comments, criticisms and concerns have been dismissed by Chemtura/CRA/M.O.E. as being irrelevant, uninformed or overstated. This has included provided technical literature, quotes and references from respected professionals in the field. All to no avail.

Dr. Jackson in a very short period of time has not only identified technical issues regarding huge problems with the partners in pollution monitoring methods and omissions but has clearly explained the rationale behind those technical issues. To this day the three partners in pollution (ie. PIPs) do not wish to acknowledge the following fact on page 4 stated by Dr. Jackson and many other experts: "...strongly hydrophobic chemicals- chlorinated dioxins and furans and DDT and its degradation products (DDD and DDE) - are most readily transported in surface water when sorbed to organic particles or in the subsurface when dissolved within an organic solvent, ie. a non-aqueous phas liquid or NAPL, perhaps composed of chlorobenzene or toluene or both".

Their most consistent denial is of course with the second part of Dr. Jackson's quote regarding the movement of Dioxins and DDT in groundwater. They flat out deny groundwater transport of these compounds by any means. Dr. Jackson has also stated that while the faster flowing DNAPLS have already been transported; the slower, thicker ones such as tars etc.may well be still slowly advancing on site.

Hence as these compounds are still moving both in surface and ground water and further contaminating both the Elmira aquifers as well as downstream creek sediments and floodplains, they must be removed at source. Whether that source is on-site near the former operating ponds, retention pits, creekbanks or even off-site on Chemtura's neighbour's properties; they must be either removed or destroyed in place.