CHEMTURA DECEMBER 2012 PROGRESS REPORT

Is it coincidence that we've finally had several months of excellent on and off-site pumping at the same time as Chemtura are desperately trying to steal back their *Responsible care verification? Based on CRA's computer modelling they again have met all their pumping requirements.

As indicated in each of these monthly Progress Reports, Conestoga Rovers have a statistical analysis which allegedly shows no statistical increase in chemicals downstream from their plant versus upstream. As I've indicated before a simple, direct comparison of the means (averages) however consistently shows slightly higher downstream concentrations than upstream for, this month, NDMA, NMOR and Toluene. I grant you these are tiny increases but increases they are. Also do not overlook the huge dilution effect of surface water on the relatively small but ongoing discharges of toxins to the creek courtesy of Chemtura.

Appendix D Figure D.3 shows us the difference in elevation between groundwater and surface water in the canagagigue creek. All the monitoring pairs show that the groundwater elevations are lower than the creek which would indicate hydraulic containment. The problem is the extremely minute amount of lowered elevation. At the north end of the Upper Aquifer Containment System (UACS) it is only .1 metre or a few inches. Further south the difference in elevation is a significant .5 metre to .9 metre. Why so much in the south and so little in the north? This does not give me confidence that even the limited 1/4 containment of the Upper Aquifer (ie. SW corner only) is doing it's job adequately.

Table F.1 is disappointing as it again shows us the volumes of free phase LNAPL (light non aqueous phase liquid) floating on the watertable, being monitored and then ignored. A couple of wells in particular seem to routinely have .3 to .5 metre thick of this oily liquid floating on the watertable. The technology has long existed to remove it but the will simply hasn't. Shame on both the M.O.E. and Chemtura.

The game goes on unabated. Perhaps as public opinion and outrage rises we will eventually have a meaningfull cleanup of both the on-site source areas as well as some of the off-site source areas.