IN SITU TREATMENT PILOT STUDY WORK PLAN

The above named report (work plan) was handed out to CPAC in late December by Conestoga Rovers, the authors, on behalf of Chemtura Canada. To date I have found a number of instances where the text discription of various Figures and Tables included is inaccurate. The first of these on page 3 I did verbally advise Jeff Merriman, Environmental Engineer for Chemtura about at last week's public CPAC meeting. He advised that he would look into it and contact CRA if corrections were needed. Unfortunately this is not remotely the first time that pretty glaring typos, transpositions and other technical errors have shown up in CRA's work. Even things like groundwater concentration lines have had glaring errors in the past whereby data points are located on the wrong side of the concentration lines. If yours truly the first time reading through a report can pick up on this stuff then it kind of begs the question as to who if anybody edits these reports prior to their public release. It also begs the question as to why the Ontario M.O.E. who receive copies aren't objecting to what are basically bush league errors. While I would suggest that the majority of these technical reports from CRA have more substantive problems including false premises and assumptions; nevertheless they should be picking up on these obvious and glaring errors. One logical reason as to why they aren't, could be that they simply aren't reading them, or they are reading them many months later and if nobody else has picked up on it, they feel better off leaving it unsaid. I do know that after two decades plus of reading nonsense of varying hues and colours from CRA, that honest, timely responses are in short supply. Normally Chemtura will simply ask to defer the questions to the next meeting while they confer further with CRA.

Regarding false premises and assumptions I would for this report include a couple of elephants in the room. CRA and Chemtura claim that the high concentrations centred around OW60, west of their site, are due to a relic plume which advanced towards the north wellfield back in the 70's and 80's only to retreat back southwards when the north wells were shut down. That is most probably absolute hooey which could readily easily be proven or disproven if CRA would include appropriate data in this report. They have not so far although they make incorrect references to where it is located. I am still looking for it.

The second elephant would be the long time high concentrations of NDMA centred around CH38 and further south at pumping well W3. So far no word as to why chemical oxidation is being used at OW60 and beside Chemtura on the Yara/Nutrite property but not further south. Even CRA's typical vagueness would be better than pretending there isn't an issue here.

Thirdly of course are the high chlorobenzene concentrations at OW57-32R beside pumping well W4, behind Varnicolor Chemical. Yes Chemtura/CRA finally addressed them last summer claiming DNAPL wasn't a factor. Their tortured and twisted logic combined with tepid support from the M.O.E. which included a Limitation clause on their report, did none of their credibility much good. Regardless they have a problem that reappears every time the pumping stops; from a few feet away. This area could also benefit from a dose of In Situ Chemical Oxidation.

All in all a typical CRA report.