LANXESS OCTOBER PROGRESS REPORT

It's just so blatant that pumping and treating just aren't a priority with Lanxess any more than they were with Chemtura. "The PW4, PW5, W5A, W5B, W6A, W6B, and W9 average daily pumping rates were less than their Target Average pumping rates in October 2018...." What then follows is a list of the most recent mechanical, electrical and or computer problems plaguing Lanxess's hydraulic containment systems. Keeping it in perspective however, the two wells with the historically highest pumping rates, namely E7 and W3R, are holding their own. It's all the others, both on-site now as well as off-site, that are not operating in an acceptable manner.

That's right, it's not just the off-site cleanup wells that are crapping out, it's the two on-site Municipal Aquifer (MU) wells, PW4 and PW5 that are slipping. This is not good. Years ago Jeff Merriman of Chemtura advised CPAC that with the removal of on-site pumping wells PW1 in their north-west corner and PW3 in their south-east corner that the on-site pumping would actually increase to 6.0 litres per second (l/sec) with the addition of PW5 to PW4 pumping. That of course has rarely happened. The current on-site Target pumping rate is a skinny 4.7 l/sec although actual pumping rates of 5 l/sec are common. In October 2018 they only managed 4.0 l/sec.

Appendix C in this monthly Progress Report is again a major concern. Surface water (ie. the Canagagigue Creek) has a number of toxic chemicals with higher in stream concentrations downstream as the creek flows through the Lanxess property. While this is not good it is however unfortunately "normal". What isn't normal are the number of toxins, just like last month, being found at the upstream end of Lanxess with higher concentrations than downstream. This indicates that as everybody has known for the last thirty years that sampling beside the Bolender Park Landfill and pretending that that location is upstream or background concentrations is ridiculous. Uniroyal Chemical and Varnicolor and others all used the Bolender Park Landfill and every other municipal landfill they could up into the 1980s (Woolwich Landfill on Seiling Dr.), north of Elmira.

The chemicals with higher downstream concentrations according to Table C.2 are MBT, BT, NDMA, NMOR, Chlorobenzene, Toluene and Xylenes. The chemicals with higher upstream values are six different trichlorophenols, two different dichlorophenols and cholorophenol along with three different cresols and phenol.These are all typical Uniroyal and even Varnicolor Chemical solvents although the Mercaptobenzothiazoles (MBT) and Benzothiazoles (BT) are Uniroyal signature chemicals.

I have to wonder and speculate here. How likely is it that suddenly after decades of monthly reporting that these negative changes in surface water are actually occurring? With a new company (Lanxess) and new consultants sort of (GHD) is it possible that the method of calculating average mean concentrations for example has changed? In other words is it possible that GHD are just a little more honest than CRA???