CHEMTURA PROGRESS REPORT- MARCH 2011

Firstly after a major four month plummet in pumping rates at the off-site wells (W3 & W4) they have finally been restored. While still lower than they were for most of 2010 they are however above the minimum targets. The biggest disappointment for me is the problems at on-site well PW5. There have actually on occasion been months where both the on and off-site wells have been pumping to their computer modelled target rates but far too often not.

Typically Conestoga Rovers (CRA) are milking Decreasing Trends in a few wells on pg. 8 as indicative of good management and stewardship. In fact by comparing September 2008 when the on and off site pumping was at a reprehensible twenty year low to current results which include very stable pumping rates through most of 2010, they are able to show Decreasing Trends. Again even the cherry picking choices of wells they compare are helpful in making their case.

Pg. 9 claims that CRA are hydraulically containing the NDMA in the Bedrock at the south end of Elmira. Two points here. Firstly twenty years ago we didn't have NDMA in the Bedrock Aquifer. Thank you very much CRA and hydraulic containment. Deep pumping both on and off site has managed to spread the contamination vertically and this is no surprise. Secondly well E7 pumps in the Municipal Lower (ML) Aquifer not the Bedrock Aquifer plus there is an Aquitard between the two aquifers. CRA please feel free to explain this voodoo hydrogeology.

Table A.1 advises us of the levels of contamination going into the treatment system as well as those being discharged. Yes, the treatment system dramatically reduces contaminant concentrations but there are two contaminants being released into the Canagagigue Creek above the Objectives. Most objectionable to me are the numeric size of the Effluent Limits for numerous contaminants. They are much too high.

Upper Aquifer containment while perhaps difficult to get a handle on during high surface water levels (the "Gig") nevertheless by the measurement system being used by CRA is very problematic. It does not look good which means that contaminants are still leaking into the Canagagigue Creek (Gig) from the most highly contaminated areas on site.

There are other issues such as the thickness of LNAPL (toluene) still floating on the watertable as well as the non "Remediation of the Former Operating Pond Area" Pg. 9 which are a twenty year plus abomination. All in all a typical "Progress" Report.