MULTIPLE SOURCES OF NDMA AROUND ELMIRA

First point. Looking at Figures 4.6 and 4.7 (plume maps for NDMA) and Figures 4.8 and 4.9 (plume maps for chlorobenzene) in the 2018 Lanxess Annual Monitoring Report, things are not so good. Sure there have been large reductions in the concentrations of both chemicals in the upper and lower municipal aquifers, but oh my God, there is so much more left to do just to achieve drinking water standards for both. Keep in mind drinking water standards are not zero. Even after they've lowered the concentrations to 9 parts per trillion for NDMA and 80 parts per billion for chlorobenzene, the groundwater is far from clean much less pristine.

Second point. Uniroyal and corporate successors are not going to make their 2028 deadline for achieving drinking water standards.

Third point. That deadline is damn near FOURTY YEARS after discovering toxic levels of NDMA in our drinking water.

Fourth point these Figures are plume maps showing us the concentrations in 1998 prior to off-site pumping and then in 2018 after twenty years of pumping and treating the off-site groundwater under the town of Elmira. Both the 1998 and the 2018 plume maps have something in common. Careful examination leads to the obvious conclusion that there are multiple sources of contamination to the Elmira aquifers. This likely goes for chlorobenzene as well as NDMA. Ammonia we'll leave for the moment because all the guilty parties have admitted that there were at least two sources namely Uniroyal Chemical and Nutrite Fertilizers. I also suspect a third source further south.

Possible additional NDMA sources would be either Sanyo Canada or a very nearby industry with a small chance that it could be the former McKee Harvestors. In addition there is an unexplained high concentration area very close to the former south wellfields namely E7 and E9. Lastly there are additional sources of NDMA both near Park St. and Queen St. as well as apparent sources in and around the former Varnicolor chemical site on Union St.

Possible additional chlorobenzene sources would be sub-surface DNAPL near the water tower and fire station on Howard Avenue. That free phase DNAPL possibly comes all the way from Uniroyal Chemical but more likely comes from the much closer Borg Textiles or Varnicolor Chemical. Issues complicating reading these plume maps are a lack of monitoring wells between Howard Avenue and Oriole Parkway. Also the Conceptual Site Model produced by Dr. Neil Thompson suggests that there is an additional 1900 kg. of chlorobenzene in the Elmira aquifers than what solely came from Uniroyal Chemical. Very strange without a second source and certainly both Borg and Varnicolor should not have been strangers to chlorobenzene despite MOE shallow sampling on the Varnicolor site.

Lastly all these likely additional sources could easily have been determined between 1990 and 1992. They were not intentionally for political reasons. They likely still could be determined with honest, unbiased, shallow soil and groundwater sampling. Honest and unbiased sampling means out of the control of Lanxess, GHD, MOE (MECP) and Woolwich Township at the very least.