CHEMTURA AUGUST 2014 PROGRESS REPORT

There is more work being done this month to remove some DDT and Dioxin in GP!. GP2 was determined by the Chemtura/CRA/M.O.E. brain trusts to be unworthy of excavation despite having samples above health and required action standards. Apparently in Ontario larger corporations routinely tell the Ministry of the Environment which standards they will respond to and which ones they won't.

Page 5 carrys a typical Conestoga Rovers typo in their reports. I believe over the last five years I am seeing more and more obvious errors that should be caught by normal editing prior to publication. Please note I am not referring to intentionally misleading or client driven factual fictions that are in a class by themselves.

Table A.2 purports to give the flow rates for both on and off site pumping wells going to the treatment system. Quite frankly I don't find the numbers in Table A.2 matching up with the flow rates as expressed in the text on pages two and three. This may require a clarification at this Thursday's (Sept.25/14) public CPAC meeting.

Table A.3 advises us of various on-site contaminant concentrations in the influent to the treatment system. It is a good reminder of the centuries of pumping ahead if Chemtura and the M.O.E. continue to refuse on-site source removal/reduction.

Appendix B deals with the MISA or Municipal Industrial Strategy for Abatement outlets on site. Aniline and carboxin are very high in the SWS (surface water system) outlet but are not tested for in MISA 0200, 0400 or 0800 outlets. Obviously they and other industrial contaminants should be.

Finally Table C.2 deals with surface water. The overall non-detect averages are making the creek look reasonably good. BEHP still appears to be an upstream issue but don't hold your breathe waiting for the Ontario M.O.E. to investigate. One suggestion: SS +925 is the furthest downstream sampling point. Based upon further knowledge including Wilf Ruland's suggestions of free phase DNAPL having exited RPE4 & 5 it would be appropriate to move the downstream sampling point another 100 to 200 metres further downstream. Then we could have an ongoing sampling that probably would capture more of Chemtura's neverending off-site leakage. Similarily the upstream location could be moved further upstream to ensure we are not including Uniroyal/Chemtura's Bolender Park (dump) contaminants that Uniroyal added to many decades ago.

All in all I give CRA a C+ for their efforts to minimize and hide the severity of the Chemtura mess.