ON & OFF SITE CHEMTURA CONTAMINATION

It is fair to say that both the Ontario Ministry of the Environment and Chemtura have been under sustained attack by CPAC over the last year plus. It is also fair to say that CPAC have worked very hard to focus on the facts and issues versus on the indivdual persons and personalities representing Chemtura and the M.O.E.. It is also my opinion that CPAC are beginning to understand my lack of patience and sometimes respect for individuals involved. They have dealt with intractable stubborness, illogic and puffery for approximately 1/20th of the time I have.

Jeff Merriman, environmental engineer for Chemtura, submitted a short report at the June 28/12 public CPAC meeting. Jeff was much more careful in his choice of words with this written report than he was verbally at the prior CPAC meeting. This written report has a number of significant qualifications to the bold/bald assertion that there are only three chemicals in the off-site aquifers. Chemtura and their consultants have for years been dropping monitoring of everything they possibly can as often as they possibly can, in favour of focusing on NDMA, Chlorobenzene and Ammonia.

Jeff's report with major qualifications such as "close in" off-site wells not counting and only chemical hits above the Ontario Drinking Water Standards (ODWS) counting does artificially reduce the numbers of off-site hits. One major comment that I applaud from Jeff is this: " We acknowledge that it is possible that there are other (non-Chemtura) sources of contaminants in the plume area." This is a major shift and concession to the truth from Chemtura and I believe it is the second such shift over the years from Jeff Merriman. Many years ago the former general manager Dr. David Ash refused to admit that there were any subsurface wastes on their site. He would only concede they had contaminated soil and groundwater. It is my recollection that after Dr. Ash departed Chemtura that Jeff did acknowledge they still had subsurface wastes without specifying whether DNAPLS, LNAPLS or former unexcavated waste pits as per the 1991 Environmental Audit. Jeff's acknowledgement mentions "other sources" plural and "contaminants" plural. This would include Nutrite (Yara) who while to date have only been "credited" with Ammonia have added 2,4-D and 2,4 Dichlorophenol to at least the shallow aquifer. I believe that Jeff is also tacitly finally including Varnicolor Chemical.

Jeff's report dated June 22/12 if read carefully, including qualifications, is much more accurate than his non qualified remarks at the May CPAC meeting. A further qualification Jeff uses is "results...since 1992". Yours truly has not and did not use any qualifications and I repeat that position namely that there are and have been tons/lots of other chemical contaminants in the off Chemtura site aquifers in Elmira. They are much easier to find twenty years ago because they were routinely being tested for. They have not disappeared any more than NDMA, Chlorobenzene and Ammonia have disappeared. They simply are not being currently, routinely tested for and hence will not be found. Similarily "daughter" breakdown products or worse unknown chemicals formed by reaction between chemicals also will not be found if not tested for. I will be submitting to CPAC soon a further report regarding results from a time when Uniroyal were testing for more than 100 different chemicals in Elmira's groundwater versus their current few.