MAY 2011 CHEMTURA PROGRESS REPORT

As usual I received this monthly report late last week via courier. Both the on and off site hydraulic containment pumping are going strong. I believe this is three months in a row of the pumping rates meeting the expected target rates.

Figure D.3 is a bar graph showing the difference in water levels between the surface water (Canagagigue Creek) and the nearby groundwater levels. As long as the groundwater levels via pumping are kept below the surface water levels, then in theory the Chemtura site is "contained" and not discharging into the creek. What I have trouble understanding is why some of these monitoring pairs (Ground vs. surface water) have a difference of between .3 and .7 metre and others as little as .05 metre. I'm skeptical that .05 metre guarantees hydraulic containment.

Table C.2 deals with surface water quality. Chemtura's consultants (CRA) have a statistical method which supposedly determines if there is a significant difference between chemical concentrations upstream and downstream of the Chemtura site. Usually there is little "statistical" difference however if one simply compares upstream to downstream numbers and ignore the statistical comparisons what one finds is that the following chemicals, all have slightly higher downstream than upstream concentrations. They are NDMA, NMOR, Ethylbenzene and Toluene. Certainly this could be coincidental despite the fact that these four chemicals and many more are all in Chemtura's groundwater.

Table E.1 lists the thickness of LNAPL (light non aqueous phase liquid) at various monitoring wells on the Chemtura site. The thickness of undissolved solvents floating on the water table vary from a trace up to .41 metres thick. That's right .41 metre or about 16 inches thick. A lot of this LNAPL will consist of the same Toluene as mentioned in the previous paragraph. This free phase LNAPL floating on the water table, decades after it's discovery, is but one more reason I am convinced that the "cleanup" underway is a joke and a sham. The technology exists to remove this LNAPL and is not being implemented due to cost considerations. This is not progress.