MORE WORK ON THE FORMER VARNICOLOR SITE A GOOD IDEA

No I do not believe that more work is necessarily required to prove that the environmental risks involved to walk and work on the surface are any more than negligible. I have confidence that both Peritus Environmental and Elmira Pump have conscientiously and professionally done their due diligence plus. That said there is still good reason for more boreholes and monitoring wells being installed. Deeper boreholes and monitoring wells that is. Also the location needs to be changed. From my limited access to the Environmental Site Assessments (1 & 2) and the still in process Risk Assessment I believe that a major area of contamination has been missed. In the professional terminology that would be a PCA or Potentially Contaminated Area.

This missed area in my opinion does not alter the surface health and safety which is the focus of the Risk Assessment. That is because of two reasons. Firstly the Interceptor/Collector trenches near this area presumably have done their job and collected the contaminated Surficial Aquifer groundwater. Secondly the area I am referring to had its' contamination delivered at depth rather than at the surface as the rest of the site did. This area was behind the former orange Varnicolor building that used to face Union St. It consisted of a buried road tanker and a buried septic tank, both with pipe connections to a floor drain inside the orange building.

As indicated by testing of the contents back in 1991 as well as nearby soil, clearly these had been used to dump hazardous liquid wastes into the ground at depth. These toxic contaminants over time have migrated further downwards into the Upper Aquifer and Municipal Upper Aquifer both of which underlie the site. The purpose of deeper soil and groundwater testing in these areas now is to determine the extent of contamination still discharging into the Municipal Upper Aquifer which is under remediation throughout Elmira. If the former Varnicolor site is still a significant source of any contaminants, not just Chemtura's three favourites namely NDMA, Chlorobenzene and Ammonia, then on-site remediation needs to be considered. This could be unobtrusive in-situ chemical oxidation or even pumping and treating of the deeper groundwater.

Hence I believe that redevelopment is still immediately possible even with deeper testing and possible further remediation in order to assist cleaning up the Elmira Aquifers by 2028 as ordered. These additional costs however should not be borne by Elmira Pump who have done their due diligence plus much more. Chemtura and the Ontario Ministry of Environment need to step up. Afterall they are the architects of the sweetheart deal between themselves which assigned all blame and responsibility to Uniroyal Chemical for the destruction of the Elmira Aquifers.