MORE ON 2010 ANNUAL MONITORING REPORT (ie. # 29)

First off these Reports used to be titled, for example, Annual Monitoring Report #25. This was the title for the A.M.R. for 2006 produced in February 2007. Hence our current one, belatedly just received, is the TWENTY-NINTH such annual report. As you can see our vigilant Ontario M.O.E. were busily ordering paperwork years before the Elmira drinking wells were shut down. This is one of the reasons for their embarassment in having multiple sources of contamination to the drinking water. They were paying attention and still missed it! Speaking of embarassment is the dropping of the number of A.M.R.'s also slightly embarassing to either CRA or Chemtura? If not, it should be.

Appendix C when compared to previous years is awfully thin on data. My first thought is that old CPAC concessions strike again. Both the number of wells is strikingly reduced as well as the number of parameters (chemicals). Tables C.1, C.2 and C.4 are bare bones compared to previous years. Again by mostly only listing NDMA and Chlorobenzene perhaps Chemtura/CRA think that readers will perceive reductions in contamination that are in reality just absences of data.

I did notice in at least a couple of locations references to grids and or quadrants. At long last there is an attempt to make these well locations clearer to the majority of readers who unlike myself have not yet memorized dozens or hundreds of well locations. More of this needs to be done for all tables and charts listing wells. Not knowing where they are located completely destroys the relevancy of the information provided.

Appendix D deals with Trend Analyses ie. Concentration versus Time Graphs. CRA have long used the Mann-Kendall Test, which I have long criticized. Strangely enogh it is counter intuitive both ways. In some instances it claims a decreasing trend when the graphs provided clearly aren't and on other occasions I've seen what I view as no trend yet the Mann-Kendall test calls it increasing. Nevertheless looking at Table D.1 and D.2 covering multiple aquifers, both on and off site, provides clarification. According to CRA's own interpretation there are a total of eight DECREASING TRENDS. This however is out of a total of ONE HUNDRED AND THIRTEEN trends examined. Yes there are many trends (ie. wells/aquifers/ NDMA or Chlorobenzene) in which there is no trend identified or where there are greater than fifty percent non-detects of a parameter. The point however I am raising is this: dissolved toxin concentration reductions do not remotely prove source removal or "cleanup". Even if they did, all the ballyhoo around pump and treat and we still only have eight decreasing trends. Pump and treat or hydraulic containment is still the poor (or cheap) man's sorry excuse for a real clean up.