CHEMTURA'S SO-CALLED "TREND ANALYSIS"

This past spring as usual we received the 2012 Annual Monitoring Report. Appendix D is referred to as "Trend Analysis". In reality it is no such thing. Ostensibly it shows contaminant trend directions (up/down/no trend) for NDMA and Chlorobenzene both on and off the Chemtura site and in different aquifers primarily the Municipal Upper (MU) and the Municipal Lower (ML).

There are numerous difficulties with their analysis. First off they use the Mann Kendall test which on occasions gives bizarre interpretations. Most of us can look at a simple graph and determine if the line is rising versus falling. As the vertical axis is concentrations and the horizantal is time it's pretty straightforward. Secondly only looking at two parameters is ridiculous. There are most likely all kinds of nasty surprises in the Elmira Aquifers from a plethora of sources including Yara, Chemtura, Varnicolor and a myriad of past leaking gas stations. For example I doubt that Chromium vi has ever been tested for despite the long standing textile industry in Elmira.

Thirdly are the wells that Conestoga Rovers have chosen to examine for their "trend analysis". Many of these off-site wells are essentially outside the NDMA and Chlorobenzene plumes. Hence they have a multitude of non-detects. Basically there are enough MU and ML wells in Elmira to get a good understanding of the trends. Except of course they are not tested regularily by CRA. Therefore there isn't enough data to really see any longterm trends.

Finally with all these drawbacks what does CRA's testing show us? Essentially nothing. There are a few Decreases, a couple of Increases, a lot of No Trends and a lot of > 50% non-detects. There is absolutely based on Chemtura's/CRA's analyses no realistic optimism that they are indeed cleaning up the Elmira Aquifers on a timeline that would remotely achieve drinking water in all Elmira Aquifers by 2028 as ordered.