2010 ANNUAL ENVIRONMENTAL REPORT

This Chemtura report, written by CRA, is dated May 2011 and was received a few days ago at the same time as the 2010 Annual Monitoring Report dated February 2011. The Environmental Report which has been submitted annually since 1991 lists changes that have occurred over the last year at Chemtura and how they have impacted the environment.

What has long been difficult for me to understand is the claimed ongoing decreases in air emissions from all on site sources including waste water and production processes. Twenty years ago Uniroyal (Chemtura) were emitting 350,000 kg of emissions up their stacks per year. By 2001 it was 117,000 kg and last year 86,000 kg. At first glance one would certainly expect huge decreases in the stink from Chemtura . Despite massive decreases between 1991 and 1998/99 we had the RAM group and the "Duke St. rowdies" fighting literally for their breath and their lives. Then things finally cleared up dramatically only to again have Elmira citizens attending CPAC last fall with major complaints primarily about evening and weekend stinks from Chemtura. I must therefore conclude that while decreases are good, that which is still going up the stacks is not. Table 3.4 shows that Toluene concentrations are at 88% of the M.O.E.'s maximum allowable. Xylenes are at 79% and Nitrogen Oxides at 57%. The next highest release concentration wise is Toluene Diisocyanate whose concentrations are at 47% of the M.O.E.'s criterion. It would seem to me that the problem once more is the treating of chemical releases as somehow being released individually. All of these standards are based on the patently false assumption that chemicals don't interact, react and cause combined noxious odours. Rather than individual standards perhaps the sheer numbers of chemicals in the air must force the standards to a much lower level. Or heaven forbid maybe we will get to the point some day where no air emissions are tolerated in order for companies to operate. Wouldn't that be amazing even if currently technically unlikely?