BELATED M.O.E. ANNUAL MONITORING REPORT COMMENTS

The report is dated December 12/16 and it covers the Ministry of the Environment's comments for both the 2014 and 2015 AMR (Annual Monitoring Report). This report actually encompasses the responses from Chemtura/GHD and they are the ones who've sent it out. I know, we are all of what, two weeks away from 2017. Getting anything on a timely basis seems impossible for these folks.

On page 2 we are advised that there is a loss of hydraulic containment in the Upper Aquifer "almost every spring, however, exceptional weather conditions in 2014 prolonged the effect.". For the record "exceptional weather conditions" are becoming the norm. It's called climate change.

We are also advised (pg. 3) that "bank storage" effects which are the cause for the above mentioned loss of hydraulic containment also contribute to "flushing" of contaminants from the creekbank areas, into the creek. Isn't that just grand? Hence GHD are stating that temporary losses of Upper Aquifer containment now are no big deal because contaminant concentrations in the area have been reduced due to past "flushing" into the creek.

On page 6 we learn that among other things GHD has a typo when they state (once) that the Drinking Water Standard for chlorobenzene is 180 ug/l. It is 80 ug/l. Also we learn that west of the Chemtura site, similar to most areas, the limiting factor to cleanup is NDMA because of its' extremely low drinking water standard.

Page 10 has a discussion of DNAPL presence in and around the Main Tank Farm (MTF) on the Chemtura site. Jaimie Connelly of the M.O.E. appropriately advises GHD that their simple criteria of groundwater concentrations of contaminants being less than 1% of the pure aqueous solubility of the contaminant proving a lack of DNAPL presence, is grossly inadequate. GHD took offense and denied DNAPL's presence without admitting that Jaimie's comments were dead on the money. GHD also used as part of their backup that the M.O.E. had concurred with them. Odd but Jaimie is the M.O.E.'s chief hydrogeologist and clearly he's not convinced.