CHEMTURA CANADA PROGRESS REPORT- SEPTEMBER 2011

Last month's "Progress" was similar to the preceding eight months of 2011. The off-site pumping continues to be below the computer targeted requirements to restore the Elmira Aquifer to drinking water standards. My belief is that even if they were able to pump, long term, as they have promised and modelled, they still can not achieve drinking water standards without off-site and on-site source removal. This year (2011) their off-site pumping (W5A/B, W3 & W4) has been consistently pathetic. The only thing that has changed are their excuses over the months. September's excuse is that there was a communications fault and a back ordered part.

Once again the Combined Groundwater Collection and Treatment System has failed to meet their Objectives for Formaldehyde and NMOR (nitrosomorpholine). As this also is ongoing you would think by now that they would have figured a solution to this problem but apparently not. NMOR, NDMA, Toluene and Ethylbenzene are all found at higher concentrations at the downstream end of the Canagagigue versus the upstream end on the Chemtura property. Strangely I can't seem to find any readings for Formaldehyde in the creek this month.

The MISA discharges (surface water drains) and their trends continue to be unimpressive. The majority of chemical indicaters have No Trend Indicated when these trends should be decreasing.

Figure D.3 is also a bit of a worry. it shows the difference in water elevation between the creek and the nearby shallow groundwater. As long as the Upper Aquifer Containment System is operating properly , the groundwater levels should be significantly below the surface water levels, thus proving "containment". Unfortunately some of these groundwater readings show extremely small reductions in the groundwater elevation compared to the creek level. This is problematic.