CHEMTURA CANADA SEPTEMBER 2015 "PROGRESS REPORT"

Firstly Chemtura's off-site pumping is achieving their current pumping targets. That is of course their constantly changing target pumping rates. Three years ago they promised to triple their off-site pumping. Since then they've fudged and claimed that they will double it. Well talk is cheap. Three years later they are holding steady albeit they are allegedly upgrading their treatment capacity as well as installing a few new wells. This is why I know they aren't remotely capable of achieving success by 2028. The turnaround time for upgrades is just too ridiculously long.

Figure D.1 is typical of CRA/GHD (new name) horse manure. It purports to be groundwater contour lines for the surficial aquifer in the northeast corner of the site. In fact it is but part of their continuing misinformation campaign pretending that groundweater has not flowed off the east side of their site onto the Stroh property. A careful look at the data points reveals the ridiculousness of their contour lines allegedly showing flow only to the west.

Table C.2 shows surface water sampling in the Canagagigue Creek. BEHP (a pthalate) shows higher concentrations at the upstream end of the Chemtura site than the downstream end. This has occurred before indicating possibly issues from the former Bolender Landfill. Toluene however has higher in stream concentrations of Toluene at the downstream end than at the upstream end. This is hardly a surprise looking at the massive quantities of Toluene still on Chemtura's site.

I have great skepticism in regards to Chemtura's Upper Aquifer 1 and 3 groundwater contour maps in Appendix D. UA3 shows a very large area of allegedly "static" (i.e. non moving) groundwater and UA1 allegedly is not discharging to the creek even in the north-western quadrant which is not hydraulically contained. It all seems conveniently self-serving.

Table F.1 shows the thickness of NAPL (non aqueous phase liquid) around Building 15. It varys from .18 of a metre to nearly half a metre thick. Funny how by not aggressively removing it over the last twenty years it hasn't been reduced very much. Excuses flow a whole lot faster than this NAPL apparently.

Table G.1 also shows the direct results of not removing hot spots on the Chemtura site. It also shows their spokespersons dishonesty. Petroleum hydrocarbon groundwater results are ridiculously high in the south-west area (OW 10-6) as are other chemicals including NDMA and so much more. Jeff Merriman has publicly advised at past CPAC meetings that Chemtura do not have petroleum hydrocarbons on their site. Such rubbish!

Table H.1 shows still high groundwater results for NDMA at several off-site wells that have been so for decades. These include CH38 near pumping well W3 (now W3R) and beside the old Borg and Varnicolor sites on Union & Howard Avenue.

The pumping tests and corresponding groundwater testing are still showing surprisingly high NDMA results off-site to the north-west around well OW60. This is discouraging as Chemtura have claimed that it is a localized source. Literally weeks of pumping and the NDMA is still over 20 parts per billion (ppb) in the groundwater with a drinking standard of .009 ppb.

I have long advised that these "Progress Reports" would be better named "Failure Reports". They are all about puffery and satisfying the Ontario Ministry of Environment's face saving requirements rather than about remediating this grossly contaminated site.