LANXESS FEBRUARY 2020 "PROGRESS" REPORT

The following pumping wells failed to make their Target pumping rates during February 2020. On-site well PW5 was shut down for seven days allegedly for maintenance. Off-Site pumping wells W5A and W5B were shut down for the same length of time also allegedly for maintenance. Of course wells W6A and W6B had their Target rates reduced months ago hence they are now allegedly "achieving" their Target pumping rates. Pumping well W9 continues not to pump at all while a new treatment system is built for it. This well has not been regularly on-line pumping for the last few years due to one failure after another. Lanxess have turned the temporary shutdowns at pumping well E7 into a virtue with their claims that "pulse" pumping actually improves NDMA removal from the groundwater. The long and short of it is that the pumping rates for all the off-site wells eight years ago were far higher than they are today (approx 53 l/sec versus approx. 38 l/sec today). Keep in mind that Chemtura and Conestoga Rovers promised verbally and in writing that they would TRIPLE those pumping rates in order to achieve the mandated 2028 Elmira Aquifers cleanup deadline. As usual the MOE/MECP are simply along for the ride giving approval to this sham of a cleanup.

Tables A.2 and A.4 indicate specific concentrations of chemical contaminants both on and off-site. These concentrations continue to be horrific on site and after twenty-two years of off-site pumping still have some ridiculously high concentrations of chlorobenzene, toluene, NDMA, Carboxin, Mercaptobenzothiazole and more.

Contaminated water is still being discharged from the MISA (Municipal industrial strategy for abatement) system directly into the creek containing Lindane, NDPA and Aniline. The conductivity of this discharged water is also very high.

Surface water issues in the Canagagigue Creek remain as indicated in Table C.2. Over time the higher chemical concentrations downstream due to discharges from the Uniroyal/Lanxess site allegedly have reversed with many higher concentrations upstream than down. Yes NDMA and Toluene averages remain higher downstream but so many other chemicals have higher averages upstream indicating to me that there is still discharges from the Bolender Park Landfill and other upstream sources.

It is very difficult for me to see either any hope whatsoever of achieving cleanup of the Elmira drinking waters by 2028 or of even continuing improvement towards that goal. I think that all parties (Moe/MECP, Lanxess, GHD, Woolwich Twn.) have thrown in the towel but simply aren't telling TAG, the public or the local stakeholders such as CPAC that it's over. At some point expect the MOE/MECP to legalize and legitimize this failure by all the guilty parties.