CHEMTURA PROGRESS REPORT - MARCH 2013

The pumping sucesses that Chemtura have enjoyed for the last nine or ten months have hit a snag. Surprise, surprise the issue is attributed to Ammonia Treatment System (ATS) problems again. On-site well PW4 hit it's lowest monthly average pumping rate since February 2012. That being said this well has been the workhorse for on-site pumping for the last three years. Off-site well W4 which does not have as good a record as PW4 nevertheless has been pumping at its' target rate for the last eight months and March's 4.7 litres per second versus the targeted rate of 11.4 is a disappointment.

There also was an issue with the UACTS or upper aquifer containment and treatment system. At one of the monitoring locations the groundwater levels were higher than the nearby surface water in the Canagagigue Creek. This would indicate at a minimum a local loss of hydraulic containment. In other words contaminated groundwater was not being prevented from discharging to the creek until the pumping wells lowered the groundwater levels below that of the water in the creek.

I have some questions regarding the Yara pump and treat system. Those wells are going directly into the ATS on the Chemtura site. The ATS is the last operation for groundwater treatment. Is there pre-treatment to remove chemicals from the Yara groundwater before it hits the end of the treatment train at Chemtura? If not that could explain some of the problems with the biological mechanisms that are failing in the ATS.

There were two chemicals which exceeded their effluent objectives namely NMOR and Toluene. NMOR while below the effluent limit nevertheless was triple its' effluent objective. Toluene was described as just barely exceeding its effluent objective of .4 ug/l with an effluent of .42 ug/l on March 6/13. However when I checked on Table A.1 it appears as if Toluene was discharged to the creek at .86 ug/l which is more than double its' effluent objective.

Clearly Chemtura are struggling again with their self proclaimed solution of hydraulic containment. How they think they can sell tripling of the volumes of groundwater to be pumped and sucessfully treated is beyond me. Maybe that's the whole point. They don't require community approval merely community presence.