CHEMTURA CANADA PROGRESS REPORT FOR DECEMBER 2015

On-site pumping at PW4 & PW5 were both above their target Average for the month of December. Off-site pumping however was problematic with three pumping wells being slightly below their target pumping rates. Wells W3, W4 and W5A were all on the low side due to pump failures in W4 and W5A whereas W3 was low due to activated carbon replacement in the W3 carbon adsorber. Table A.4 lists the Bypass/Upset Conditions which result in downtime for pumping wells. As usual it is a full page litany of problems and issues fortunately most of them short term for December. That said one wonders how they will sucessfully pump even twice as much water reliably and consistently, much less the triple volume they claimed they would back in November 2012.

Table A.3 is a listing of groundwater concentration of contaminants found in two of the Upper Aquifer pumping wells located in the south-east corner. This aquifer remains heavily contaminated on-site with high concentrations of Chlorobenzene, Toluene, Mercaptobenzothiazole, Carboxin and Aniline. Of course unlisted here is NDMA and many other compounds.

Table C.2 is a comparison of contaminants found upstream of Chemtura versus downstream. Recently BEHP has been found at slightly higher upstream concentrations than downstream which is peculiar. Tolune on the other hand has a slightly higher downstream average concentration than above which is to be expected as it is plentiful on Chemtura's property.

Table D.3 is a comparison of the water elevation at key groundwater and surface water pairs. The idea is to compare the two elevations to confirm that groundwater pumping has lowered the groundwater elevations in order to stop them from discharging into the creek. Unfortunately three or one half of the groundwater pairs have very small differences in elevation between the groundwater and surface water. These differences are in the vicinity of .1 metre or 4 inches or less. This is an inadequate differential to guarantee hydraulic containment.

Figure D.4 I would characterize as typical CRA/GHD? deception. It is a groundwater elevation contour map for the Upper Aquifer (UA1) on their site. It includes a Table with well over one hunderd wells and their groundwater elevations. It also shows in grey a large area on their north-east side which purports to be missing the UA1. Sadly within this grey area they have four wells shown directly on their eastern border. Lo and behold if one looks them up within the Table of over one hundred wells, they are there along with their UA1 groundwater elevations. The purpose of this deception is to continue to pretend that their grossly contaminated eastern property line is not discharging via UA1 groundwater into the Canagagigue Creek. It is.

Figures E.1-E.5 are concentrations of NDMA and Chlorobenzene on the west and south side of their site either on their property line or just over. While Chemtura like to brag about their concentration Trends decreasing I find it bizarre that so many of them are still well above their respective drinking water standards. CH47 exceeds both, CH56B well exceeds the NDMA standard and both CH89 and OW165 occasionally exceed the NDMA standards. I don't find this reassuring at all.

Finally Table F.1 advises us that nearly twenty years after discovering LNAPL (light Non Aqueous Phase Liquids) in their subsurface on the west side they are still there in varying thicknesses floating on top of the water table. These thicknesses vary from Traces to 1/3 and nearly 1/2 a metre in thickness. This is not acceptable after twenty years of allegedly trying to remove them. LNAPLS include floating petroleum hydrocarbons, gasolines, oils, Benzene, toluene, and more.

All in all another depressing Progress Report wrapped in giftpaper and presented with a ribbon on top. That site is a mess and will continue thusly for decades to centuries without considerably more source removal being done on site.