CONCEPTUAL SITE MODEL- ELMIRA & CHEMTURA

Dr. Neil Thomson's CSM (Conceptual Site Model) prepared for Chemtura/Lanxess has been completed. My first concern is that it's under the banner of that idjit Alan Deal formerly CRA and now GHD. While Dr. Thomson has credibility both at the University level as well as here in Elmira, Mr. Deal does not. That is truly unfortunate and immediately makes the final product suspect. Unfortunate and avoidable.

On page 3 we are advised that the level of Upper Aquifer (UA) wells was monitored while pumping took place in the Municipal Aquifer. Allegedly as there was no response in the UA we are told that there is no direct connection between the aquifers. Which wells in each aquifer and what time of year did this take place? Stating that there is no direct connection throughout Elmira seems to me to be a huge generalization from pumping at maybe three Municipal Aquifer wells.

Page 7 advises us that east side well OW43-11 has had very high Chlorobenzene concentrations for decades. Indeed as suggested this probably indicates a nearby source of Dense Non-Aqueous Phase Liquids (DNAPLS) in the Municipal Aquifer.

Similaly well OW88-19 in the south-west part of Chemtura also has had extraordinarily high levels of dissolved chlorobenzene for decades. This also indicates the nearby presence of DNAPL, most likely free phase. Again this well is screened nearly 20 metres below surface and in the Municipal Aquifer.

Free phase DNAPL was found in the past at TPW-2 (Tar Pit 2) also on the west side. Found and left I might add. I did not see it mentioned in this CSM which is disappointing.

I have long had a problem with the alleged lack of chlorobenzene in the Bedrock Aquifer. Page 10 gives a fairly convincing explanation as to why it's not there. I'm not yet 100% convinced byt credit needs to be given for this explanation and rationale regardless.

Page 14 is a repeat of a stunning revelation given to us by Dr. Thomson regarding the overall mass of chlorobenzene in the Elmira Aquifers. At a RAC meeting Dr. Thomson advised us that approximately an additional 2000 kilograms of chlorobenzene is in the ground from an unaccounted for source. This is no surprise to me. The two most likely sources are Borg Textiles formerly across Howard Ave. from Varnicolor Chemical. Varnicolor itself is suspect although for that to be true then there had to be a major fraud/coverup in regards to shallow aquifer groundwater readings of zero for chlorobenzene. All very suspicious.

Overall this CSM is helpful. One other anomaly is the title of the document namely "Municipal Aquifer Conceptual Site Model". Come on guys it's far more than the Municipal Aquifer as it includes the bedrock aquifer as well as two different shallow aquifers and more. Not sure why they titled it as such.