September 2018 LANXESS PROGRESS REPORT

Off-Site pumping has NEVER achieved remotely close to the promised, in November 2012, rate of Triple 54 litres per second for ALL the off-site pumping wells. It has never achieved the later downgraded goal of Double the 54 litres per second mark in late 2012. September 2018 had an off Lanxess site (ie. Elmira Aquifers) pumping rate of approximately 64 litres per second. That is good historically but again no where near the rate that Chemtura and Conestoga Rovers advised was necessary in order to remediate the off-site aquifers by 2028.

Page 8: Remediation of former operating ponds. There are no new activities to report for this item in September 2018. This refers to DNAPLS in the RPW west side ponds namely RPW1 & 2 as well as RPW 5,6,7, & 8. Shameful and disgraceful. Thank you very much Sylvia and Susan for your APT assistance of Uniroyal with this failure.

Table C.2 Surface Water contaminant concentrations. This Table has gone completely bizarre. Ten toxic chemicals have higher concentrations upstream near Bolender Park than downstream at the bottom of the Lanxess (Uniroyal) property. This is nuts! Has GHD on behalf of Lanxess told the truth or have they butchered this Table with perhaps the up and downstream testing locations reversed?Lindane is also higher upstream near Bolender Park versus downstream. Then chlorobenzene, toluene and xylenes are higher downstream which makes more sense although nothing should be higher downstream if there containment was working. It isn't.

Figure D.3 confirms issues with on-site shallow aquifer containment. Only six monitoring well groundwater elevation results are shown and three have elevation differentials with the creek's surface water from half a metre to nearly .9 of a metre whereas the other three have a tiny elevation differential of only .02 metre to .11 metre. The idea to prove hydraulic containmnet is to have all the groundwater readings significantly lower than the creek surface water readings to indicate that relatively clean water is flowing inwards to the pumps versus contaminated groundwater flowing outwards into the creek.

Figure D.11 tacitly claims that there is no chlorobenzene in the Bedrock Aquifer. I find this unlikely as there is a plume of chlorobenzene in the Municipal Lower (ML) Aquifer (see Fig. D.10) between W5A and W4. There is also a window in the Lower Aquitard (LAT) in this location allowing direct access from the ML to the Bedrock Aquifer (BR).

Table F.1 shows the thickness of LNAPL (toluene) floating on the water table at various monitoring wells. It remains horrific as it has since we learned about the presence of this free phase Light Non Aqueous Phase Liquids (LNAPLs) in 1995. Thicknesses vary from half a metre to traces only including "Black tar-like blobs present on probe/tape/bailer." These companies from Uniroyal to Lanxess won't even remove shallow LNAPL much less somewhat deeper and more difficult DNAPL. Thank you Sandy Shantz and most former Woolwich mayors for your support of these polluters.