CHEMTURA'S 2015 ANNUAL MONITORING REPORT

Appendix D in the 2015 Annual Monitoring Report (AMR) is all about Trend Analyses. These include both Figures and Tables indicating increasing or decreasing trends in groundwater contaminant concentrations. Three indicater parameters are examined namely Ammonia, Chlorobenzene and NDMA. Wells are throughout Elmira (ie. off-site) and throughout the Chemtura property (ie. on-site). The off-site wells are in both Municipal Aquifers namely the Municipal Upper (MU) and the Municipal Lower (ML). Testing is also done on the off-site Bedrock wells. On-site wells are also in both Municipal Aquifers as well as the Upper Aquifers (ie. UA1, UA3). Please note that there are no on-site Bedrock wells in these analyses nor are there any off-site Upper Aquifer wells which could indicate other off-site sources contributing to our locally shut down drinking wells. These absences are not by accident.

I'm about to show you the results of Tables D.1 (Ammonia), D.2 (Chlorobenzene) and D.3 (NDMA) which give an overview of the success or failure of the pump and treat systems on and off the Chemtura property. Keep in mind that the statistical test used by CRA/GHD on behalf of Chemtura is called the Mann-Kendall test. I do not endorse it nor particularily think much of it. For example they include wells in the test which have shown very little or no contamination (ie. non-detects) but this is their analysis not mine.


***********************AMMONIA*********************

****25 off-site wells show 7 wells with decreasing trends in ammonia concentrations.

****26 on-site wells show 9 wells with decreasing trends in ammonia concentrations.





***********************CHLOROBENZENE******************

*****36 off-site wells show 9 wells with decreasing trends in chlorobenzene concentrations and 2 with increasing trends.

*****105 on-site wells show 20 wells with decreasing trends in chlorobenzene.





**********************NDMA*****************************

*****72 off-site wells show 14 wells with decreasing trends in NDMA and 1 with an increasing trend.

*****101 on-site wells show 17 wells with decreasing trends in NDMA and 2 with increasing trends.



These are the current trends for on and of site wells . On-site wells have been under a pump and treat regimen since 1992 and the off-site wells since 1998. Even with what I view as a flawed statistical method I do not remotely see how these statistics are remotely indicating cleanup (off-site) by 2028. While we have been promised for the last 3 1/2 years improvements in the off-site pumping as well as source removal by In Situ Chemical Oxidation; it has not started yet and the clock is ticking.