FURTHER COMMENTS ON CHEMTURA JUNE 2011 PROGRESS REPORT

We are consistently receiving less and less relevant information from CRA/Chemtura. Whether or not "sanctioned" by the old CPAC nevertheless it is plain wrong and intentionally deceptive by Chemtura. Table A.1 gives us only raw Chlorobenzene and Toluene concentrations going into the Groundwater Containment and Treatment System, nothing else.

Appendix B dealing with MISA (Municipal Industrial Strategy for Abatement) discharges to Canagagigue Creek shows us decreasing concentrations of Ammonia at MISA 0200 going from primarily surface water drainage into the creek.The other parameters are unchanged over time. MISA 0400 is similar although it claims reductions in Lindane as well. First off Lindane is no longer used on site so this must be Lindane in groundwater infiltrating into the surface discharge pipe and secondly looking at the chart (fig. B2), the claim for decreasing Lindane is highly suspect. MISA SWS claims no trend for Lindane but again clearly there are increases over the last year.

Appendix C deals with surface water (the "Gig"). Using CRA's statistical program they claim no statistically significant changes but again looking at the raw data in Table C.2 one can see increases downstream (SS+925) from upstream (SS-110) namely with NDMA, NMOR and Toluene. While clearly an improvement from the 60's, 70's, and 80's it isn't an improvement in the health of the creek prior to Uniroyal's using it as their private sewer.

Appendix D deals with the so called MU Sentry Well Program. This is just one more public relations tool for CRA/Chemtura to attempt to fool the public. They have cherry picked wells near their west side property line after a period of low on-site pumping. These wells respond fairly quickly and hence when pumping on-site is low these wells chemical concentrations rise quickly. Similarily when we go through a relatively sustained period of good on-site pumping, the concentrations follow suit and decrease. Simply keeping track of their on-site pumping compared to their targeted pumping rates gives us the same picture. If nothing else the informed reader should gain an understanding of the short termed nature of hydraulic containment aka pump and dump. Even without stopping the pumping completely, merely slowing it, the toxic concentrations rise off-site nearby very quickly. This is why SOURCE REMOVAL is so necessary. These MU SEntry Wells are actually measuring the extent of sub surface contamination in the south-west corner of the Chemtura site. This corner is where in years past CRA (Conestoga Rovers) have claimed resides 97.5 % of the contaminants flowing into the creek from Uniroyal/Chemtura.