CHEMTURA CANADA PROGRESS REPORT - MARCH 2016

There are concerns that Chemtura's hydraulic containment of the Upper Aquifer is not adequate in that the head differential between corresponding groundwater levels and surface water just isn't large enough at some points. For example at the 610/615 metre mark south of Church St. the head differential is a healthy .8 metre. In other words the surface water of the creek is .8 metre higher than the corresponding groundwater levels thus the creek discharges into the aquifer versus the other way around. Unfortunately the differential at 460/450 and 540/540 is a pathetic .04 metre. I do not believe this is remotely a large enough differential to assure hydraulic containment of the aquifer at these points. Similarily as admitted on page 5 there is an absolute loss of containment at 510/500 as the groundwater levels are actually slightly higher than the surface water in the creek.

Pages 8 & 9 in the report indicate that there will be a further delineation of groundwater contamination along the eastern site boundary. Unfortunately it appears as if GHD (CRA) will be focusing solely on well OW36-5 (R). While this particular well had horrific contamination as per the December 2015 East Side Surficial Soil and Groundwater Report nevertheless a wider investigation is necessary. This includes the area southwards along their eastern property line that was intentionally ignored in the December 2015 Report as well as in the area of the Stroh Drain.

Both page 5 and Figure D.1 in my opinion indicate the inherent dishonesty of Chemtura and their consultants. Despite the MTE Consultants Report of October 2014 which clearly showed that both ground and surface water flow eastwards onto the Stroh property, the text and GHD's Figure show otherwise. This north-east corner is the high ground with everything else falling downhill from there. GHD are still pretending that nothing flows off-site to the east.

Figure D.4 is also deceptive by my read of the data. It claims that there is a huge area of Chemtura's eastern half of their site which does not have the Upper Aquifer present. The problem is that they have extended this area further south past at least four monitoring wells (OW28-5, OW32-3, OW8s, OW8-4) that their own included table shows has Upper Aquifer groundwater present in them. Sometimes Chemtura's consultants are just too tricky for their own good.

Lastly Table F.1 gives us LNAPL thickness readings. LNAPLS or Light Non Aqueous Phase Liquids float on the surface of the water table. Think of oil and gas floating on the surface of the ocean and you'll sort of get the idea. The worst areas in Chemtura's south-west have this LNAPL (mostly Toluene) between .2 metre and .49 metre thick floating on their water table (ie. UA1). This is reprehensible that the Ontario Ministry of the Environment have not insisted that it be removed decades ago. As long as it remains, along with DNAPL, the longer the Chemtura site threatens both the Elmira Aquifers and the Canagagigue Creek. LNAPL being shallow is much easier to find and remove than the much deeper DNAPL (Dense Non Aqueous Phase Liquids).

This is Chemtura's "Progress" Report. With their friends on Woolwich Council protecting them I expect these "Progress" Reports will continue indefinitely.