2017 ANNUAL MONITORING REPORT

Quite a while back I posted here in regards to the MOE's (MECP) comments & criticisms of this annual report done by CRA/GHD on behalf of Chemtura/Lanxess. The MOE's comments were described as the most critical, comprehensive and blunt in many years which I both agree with and enjoyed immensely. I think that I even had some good words to say on behalf of the MOE hydrogeologist, Abdul Qyuum (sp.?) who wrote the MOE comments.

Last Thursday November 29/18, GHD responded to the MOE's comments. I was actually sent their responses in a very timely manner for a pleasant change. At some point I expect that the artificial exclusion and stifling of stakeholders both by private meetings and late or never correspondence, other than friends of Chemtura/Lanxess and mayor Sandy Shantz (ie. TAG), may actually bite the guilty parties including the MOE right in the as you will.

The MOE state that the Environmental Compliance Approval (ECA) which replaced the former Certificates of Approval (C of A) absolutely insists upon continuous water level monitoring of both selected shallow aquifer monitoring wells as well as of the surface water of the Canagagigue Creek. The purpose is to always be able to prove or disprove whether or not the contaminated groundwater is hydraulically contained (via lower water elevations) and not discharging into the Creek. GHD agree with that however admit that four of the six surface water elevation stations do not have continuous monitoring data. Wow, that is bad and a blatant contravention.

The MOE specifically point out an area of the Upper Aquifer Containment & Treatment System (UACTS) that at the minimum sufferred a temporary loss of containment, hence discharged contaminated groundwater into the Creek. GHD to their credit seem not to be denying the obvious nor minimizing the seriousness of the situation to the extreme ends that their predecessors CRA did.

The MOE suggested that hydraulic containment of the Municipal Upper Aquifer (MU) on Lanxess's west side was in doubt due to consistent concentrations of NDMA just off Lanxess's western border with Nutrite (Yara). GHD responded that they disagreed and that the source of the dissolved chlorobenzene was not migrating groundwater from Lanxess but is "continuous back diffusion of chlorobenzene and NDMA from fine-grained aquitard soils adjacent to the MU." Hunh that reason actually seems plausible to me.

On page 8 GHD to their credit actually admit that the Municipal Lower Aquifer (ML) is not contained on the Lanxess site. Previous CRA and Uniroyal/Chemtura spokespersons would tie themselves up in knots before they would ever admit that obvious fact. GHD do however suggest that this lack of containment is not critical because allegedly the concentrations of contaminants on site do not exceed the Ontario Drinking Water Standards (ODWS). Of that I am skeptical.

The MOE appropriately are not pleased with GHD using groundwater concentration data from different sampling dates and then using them all together to plot concentration graphs for on-site NDMA. These dtaes include 2017, 2006, 1999 and 1993. I agree that that is bizarre and GHD's responses are weak.

The MOE suggest that the very high concentrations of of NDMA in on-site, east side well OW42-4 need to be investigated. GHD disgarees suggesting again weakly that these high results are isolated in the immediate area. To my mind all the more reason to get the source out of the ground if it is both shallow and isolated.

On page 12 the MOE are again suggesting that there is a lack of hydraulic containment this time on the west and perhaps south border of Lanxess at monitoring wells OW105d and OW16i. GHD denied this and I must admit that their arguments have some merit.

The MOE are again suggesting that there are other sources of chlorobenzene to the off-site drinking water aquifers in Elmira. This is huge and is not being disputed by GHD. They also point out that they have done an isotopic analysis in August 2018 trying to determine if the chlorobenzene is from different sources. To date we the public have not been advised of the results of this analysis.

There is a discussion as to where the highest concentrations of NDMA are located in the MU aquifer. They are 1) beneath the former south-west operating ponds (RPWs) 2) off-site in the north-west (OW60-26) and 3) south of Lanxess at pumping well W3R located between Sanyo and the former McKee Harvestor plant.

The MOE still appropriately have free phase DNAPL concerns on the Lanxess site. Now if only they'd do something about those concerns.
GHD's responses are disappointing as they, just like CRA, go through the old chestnut about free phase DNAPL being indicated if the groundwater concentrations of DNAPL chemicals exceed 1% of the compound's aqueous solubility. That is fine if the DNAPL compound is the sole contaminant in the groundwater unlike the dozens to hundreds of different contaminants in Elmira's groundwater. 1% of the EFFECTIVE Solubility of the DNAPL compound should be the benchmark not 1% of the solubility in pure, uncontaminated water.

Overall GHD and the MOE get good marks for paying closer attention to last years (2017) AMR than usual. Nevertheless there are still major issues being talked about rather than actually being physically resolved.