MORE ON CHEMTURA'S MAY 2013 PROGRESS REPORT

Last Thursday I indicated that Chemtura's on and off-site pumping was finally achieving all of its' target pumping rates. This would refer to the Municiapl Upper (MU) and Municipal Lower (ML) Aquifers. Today I will be discussing primarily their shallow aquifer or upper aquifer (UA).

Attachment A, Table A.3 has some interesting chemical concentrations in the shallow or upper aquifer. Now do keep in mind readers that at no time has Chemtura/Conestoga Rovers ever suggested that their pump & treat system will EVER clean up their on-site mess. Following are a few chemicals and their concentrations found on their site nearly a quarter century since they shut down the Elmira wellfields (1989) and closer to a half century (OK 43 years) since they stopped disposing raw chemical wastes on site in shallow pits and ponds.

chlorobenzene 3,000 parts per billion (ppb)
toluene 30,000 , 43,000 , 78,000 ppb
mercaptobenzothiazole 2,800 , 4,600 , 10,000 ppb
carboxin 3,400 , 4,100 , 9,400 ppb

plus aniline, benzothiazole, chlorophenols . methyl ethyl ketone and others have method detection limits (MDL) in the 25,000 - 50,000 ppb mark which makes detections of them essentially impossible.


Figure D.3 is titled "Head Differential at Key Monitoring Pairs". These monitoring pairs refer to six shallow wells and the very nearby surface water elevations of the Canagagigue Creek. In theory at least, if you can artificially reduce the groundwater elevation below the surface water elevation, then you are preventing natural groundwater discharge into the creek. This of course refers to heavily contaminated groundwater discharge into the creek. For the month of May 2013 half of the monitoring pairs have a diffenece in elevation of .1 of a metre or LESS! This is not good! At one time a few years back the hydrogeologist for the Region of Waterloo suggested that it was very difficult to ascertain exactly how much lower the groundwater elevations needed to be in order to be confident that contaminated groundwater was not leaking into the creek. It is my opinion that CRA have lowered the groundwater only enough to prevent large amounts from entering but I do not believe for a second that it's all contained even in the one quadrant (SW) of the site that allegedly is hydraulically contained via pumping wells.

There is further evidence relevant to the alleged hydraulic containment of the south-west quadrant of the Chemtura site. That would be Figures D.4 , D.5 and D.6 . Figure D.7 refers to UA3 which is deeper than UA1 and which only incidentally is lowered by pumping in UA1. This Figure (D.7) shows one small area as being contained while this aquifer (UA3) over the rest of the site is referred to as "static". In other words CRA would have us believe that this groundwater magically exists but doesn't flow anywhere. That is way more than wishful thinking.

Table E.1 advises us of the depth of LNAPL (light non aqueous phase liquid) on the site in various areas. A lot of this LNAPL is toluene floating on the shallow water table (UA1). The M.O.E., CRA and Chemtura have known about it at least since the mid 90's. If you look above you will see the concentrations of dissolved toluene in the groundwater. The ongoing and neverending source is the free phase LNAPL still floating on the water table. Chemtura advises us that they can't remove this LNAPL/toluene. My belief is that for a price they can but until the Ontario Ministry of the Environment (M.O.E.) grow a backbone, they won't. Such is the state of environmental "cleanup" in Ontario.