MOE/MECP COMMENTS ON 2018 ANNUAL MONITORING REPORT (AMR)

The following report dated October 31/19 was sent to me yesterday courtesy of the TAG/RAC Support Specialist. Cynthia Doughty is the MOE/MECP hydrogeologist and I have been very impressed with several of her comments and critiques of GHD and Lanxess efoorts and reports. This one is also very interesting.

On page 3 of her report Ms. Doughty criticizes the lack of consistency by GHD (Lanxess consultants) in reporting the number of containment wells in the Upper Aquifer Containment System. She quotes different sections of the AMR as having different numbers of containment wells.

On page 4 we learn that one of the only two deep monitoring wells on the former Varnicolor site (MW 41) was included in a chlorobenzene plume map. She is curious as to why a non-routine well was suddenly used for a plume map drawing. As to myself I find the fact that Lanxess/GHD are using a well result from the former Varnicolor Chemical site (Union St.) in an Elmira contaminant plume map to be long overdue and a tacit admission that data from that property is part of the Elmira Aquifers and should long ago have been both relevant to the overall cleanup and that the data is public information and should not have been intentionally kept hidden from both the general public and from long time stakeholders such as myself and CPAC.

On this same page Ms. Doughty discusses seasonal losses of hydraulic containment in the Upper Aquifer Containment System (UACS). She also suggests that there are areas of the creek which are not sampled regularly enough to conclude that Upper Aquifer groundwater is contained in those areas. On page 5 Ms. Doughty elaborates noting local losses of hydraulic containment in September, December (potential), April and May 2018. She believes that these need to be better discussed in the AMRs. She also rather bluntly takes GHD to task for gilding the lily (my words) by stating in the AMR that "the UACS continues to prevent the discharge of contaminated UA1 groundwater to the Creek beneath the southwest portion of the Site". She states that this statement "is not accurate."

On page 6 Ms. Doughty questions why wells W6A and W6B are experiencing decreased well efficiency after just being commissioned in 2017. Both these wells failed to achieve their Target pumping rates in 2018 and she feels that the AMR should be providing a detailed explanation as to the problem.

My only concern or disagreement with Ms. Doughty is in regards to her point number 21. She is inquiring as to the purpose of pumping well W8 and it's low pumping rate. While I too would like to see a higher pumping rate nevertheless the purpose appears very clear as this location is a hot spot for both NDMA and chlorobenzene.

Overall I believe that this is an excellent critique and only regret Ms. Doughty's willingness to give GHD/Lanxess so much time to respond including in next spring's 2019 Annual Monitoring Report (AMR).