UACTS,CTS, & OSCTS

All three of these containment systems have come up short.The first is the Upper Aquifer Containment & Treatment System and recently Cynthia Doughty of the MOE has advised all parties that the UACTS has been inadequately containing the shallow aquifer on the Uniroyal/Lanxess site for decades. Secondly the CTS or on-site Containment & Treatment System has had problems pumping well PW5 to its Target Rate for months thus jeopardizing hydraulic containment. Thirdly the OSCTS or Off-Site Containment & Treatment System has been generally under performing for decades. Despite increased pumping rates for the last few years the totals are still nowhere near high enough according to CRA and Chemtura/Lanxess to achieve the 2028 deadline. The determination of these pumping rates was made by CRA in November 2012.

Other failures included the lack of removal of both DNAPLS and LNAPLS. Uniroyal/Crompton/Chemtura and presumably Lanxess all think that just because they used their junk science to convince the least knowledgeable or most co-opted CPAC members to acquiesce to little or no DNAPL removal, that they are home free. News flash: There is no statute of limitations for bad decisions made via deceit or gamesmanship. Regarding LNAPLS Jeff Merriman of Chemtura kept telling us that it was not possible for Chemtura to remove them from the subsurface. I believe that that is horse manure. For a price they can be removed. Chemtura/Lanxess simply aren't willing to pay the price to clean up their own mess which has impacted the off-site environment for many decades.