CHEMTURA'S CLEANUP DELAYS MORE THAN $$$ ? DEFLATING LIABILITIES $$ CRUCIAL?

Certainly delay is a potent weapon used by polluters and their friends in high places. It combined with decades of technical reports tends to weed out serious objectors and citizen activists. This then allows companies to more easily sell their version of reality. Since the Elmira water crisis began in 1989 Uniroyal Chemical has become Crompton, and then Chemtura. Now on the horizon is the possibility of yet another change in ownership to Lanxess of Germany.

I have long felt that $250-350 Million would go a long ways towards some serious source removal on the Chemtura site. This would entail contaminated soil removal as well as free phase and residual DNAPL removal beneath the west side retention ponds namely RPW-1 & 2 in the north and RPW-3, 4, 5, 6, 7, 8 further south. Of course the allegedly incapable of removal to date pool of LNAPL floating on top of the water table, originally from Building #15, could also finally be removed. Then on the east side we also have the retention pits RPE-1,2,3,4,& 5. Here we also have had work done over the decades albeit never deep enough or beneath the pits where DNAPLS have found a home. Some of the nasty results of these pits are just now being discovered via East Side Investigations which include test pits, soil samples and more groundwater sampling.

Only since the waning days (2014) of the best Council appointed CPAC (Chemtura Public Advisory Committee) ever have we learned of the extent of Uniroyal/Chemtura damage off-site to the east. We've all known of the damage to the Elmira aquifers west and south of the Chemtura site. Yes we did know that at one time the Canagagigue Creek was devoid of life. Not just fish, frogs, clams etc. but everything. Since the advent of both the Elmira Sewage Treatment Plant as well as the Upper Aquifer Containment & Treatment System (UACTS), discharge of dissolved chlorophenols and other solvents has been greatly reduced and life has returned to the creek. Since 2012 we have learned unfortunately that Persistent Organic Pollutants (POPs) are still in the creek sediments as well as Floodplain Soils.

Efforts were made both to stabilize the creekbanks on the west side only, as well as to remove certain highly contaminated, with Dioxins and DDT, creekbank soils. Again these excavations were solely on the west side of the creek. It's almost as if Uniroyal and their successors were aware of some sort of already in place containment or bypass on the east side. The previously mentioned UACTS is a series of pumping wells in Chemtura's south-west corner only. APT Environment left UPAC (Uniroyal Public Advisory Committee) in June of 1994 over their refusal to hydraulically contain the rest of the creek including the entire east side. Once again it's almost as if Chemtura and Conestoga Rovers had knowledge of some already, surreptitious, containment and or east side groundwater by-pass system in place.

The Ontario Ministry of the Environment have now conducted sampling primarily in the creek sediments in 2012, 2013, 2014 and 2015. We did get a hint two days ago (RAC meeting) of some new sampling that may have taken place this past summer. The results are often above the multitude of various criteria for creek sediments as well as Floodplain Soils when sampled. Dioxins and DDT lead the charge for criteria exceedances although the multitude of other contaminants includes mercury, PCBs, Lindane, Endosulphan, Endrin, Aldrin and so much more.

We also have solvents, PCBs, Dioxins/Furans and DDT found in test pits both along the eastern property line as well as in nine test pits mostly east of RPE-5. Soil samples as well as groundwater in this area beside the Stroh farm are highly contaminated. Chemtura and their consultants (GHD) appear extraordinarily reluctant to proceed with ordered soil and groundwater testing on the Stroh farm itself. Excuses include waiting for crops to be removed as well as problems receiving access permission. They have also to date studiously avoided soil and groundwater testing in the areas I refer to as the "Gap" and the "Sink". They are just off Chemtura's South-east property line on the Stroh property in and around where the Stroh Drain runs parallel to the property line for about 175 metres.

There is evidence, as only slightly subtly referred to earlier, of some sort of containment system for the east side. This has never been admitted to by Uniroyal or Chemtura. Satellite maps show what appears to be a manmade structure between the east side pits and the creek which runs southwards and then eastwards crossing over to the Stroh property just below (south) RPE-5. Coincidentally due south perhaps a hundred metres away is an outlet pipe running north to south which discharges into the top end of the Stroh Drain. This discharge pipe could be groundwater from field tile on the Stroh property, contaminated groundwater from the Chemtura property or a combination of both. I believe that the satellite images show some sort of Interceptor Trench designed to collect contaminated groundwater coming from the east side pits and preventing it from discharging naturally westwards into the Canagagigue Creek on the Chemtura property. This collected contaminated groundwater is possibly then being redirected via gravity flow southwards and eastwards onto their neighbour's property into the Stroh Drain where it eventually winds its' way eventually into the Canagagigue Creek much further downstream.

Where is the Ontario M.O.E., currently called the MOECC, in all of this? Basically up to their corrupt eyeballs. If they don't know exactly what's going on with the Stroh farm next door it's because they don't want to know. George Karlos of the M.O.E., both verbally and then in writing publicly stated in 2013 that he had personally walked the south-east corner of Chemtura over to the Martin swimming pond east and further south and that there was no reasonable pathway for contaminants from Chemtura's east side to get into the pond. A year later I walked the same area and discovered the Stroh Drain which had been kept secret form UPAC, CPAC and the public for three decades. Later on I and a current TAG member (Sebastian) confirmed that indeed there was a pipe diverting a small amount of the Stroh Drain water directly into the Martin swimming pond. How can we not believe that the M.O.E. have been enabling Chemtura's deception for a very long time?

Will these chickens come home to roost before or after Chemtura is sold to Lanxess? Will Lanxess shareholders be made privy to these further immense financial liabilities prior to any purchase decision? Granted I'm no accountant but I believe that $250 - 350 Million is needed to clean up on site and perhaps another $200 Million off-site for the Stroh, Martin and downstream Canagagigue Creek. Buyer beware folks.