CHEMTURA CANADA JANUARY 2013 PROGRESS REPORT

As I've been indicating for several months now Chemtura have greatly improved their off-site pumping rates. Once again for January all five of these wells have achieved their computer modelled pumping rates. One of the on-site wells (PW5) missed its' mark only slightly namely 1.9 litres per second versus the modelled 2.0 l/sec. Even with that the overall on-site pumping exceeded its' modelled rates of 5.2 l/sec. Overall again I would have to say that on and off site groundwater pumping are under control. Now if Chemtura/CRA can just maintain that for the duration unlike in the past.

This monthly Progress Report does not give us any new groundwater elevation data with which we can judge on-site hydraulic containment. I believe that these reductions in past mandatory reporting were with the blessing/consent of the past Chemtura Public Advisory Committee (CPAC). I warned them at the time that giving concessions or agreeing to them from the M.O.E. was not CPAC's business. From the volume of on-site pumping at PW4 & PW5 it is likely that the Municipal Upper Aquifer (MU)is reasonably well contained. The Upper Aquifer (UA)which naturally discharges to the Canagagigue Creek gave me some concerns last month and I would like to have seen how it is faring this month.

Table C.2 continues with small detections in the surface water of Canagagigue Creek of the usual three suspects namely NDMA, NMOR (nitrosomorpholine) and Toluene. Conestoga Rovers suggest that these are not statistically significant. Unlike them I won't play with words. These ongoing detections whereby the arithmetic mean of the samples is higher downstream on the site than upstream, indicates continuous discharges of these chemicals via groundwater into the creek.

I believe that the current CPAC have added these monthly Progress Reports to the Agenda for tomorrow evening. I will most likely ask Chemtura for a clarification in regards to statistically significant versus arithmetic means being consistently higher for three chemicals downstream.