OTHER REASONS FOR THE LANXESS ADMITTED FAILURE TO ACHIEVE DRINKING WATER STANDARDS

First and foremost is the failure to do Source Removal. This Source Removal includes DNAPL removal both on and off-site particularly on the Yara property as well as behind (west) Varnicolor Chemical near the Elmira Water Tower. All parties, guilty or otherwise had/have full knowledge of this DNAPL. Also the failures in the placement of shallow hydraulic containment have also contributed to the failure of off-site cleanup in the Municipal Aquifer (MU). The shallow hydraulic containment was strictly placed in the south-west corner of Uniroyal Chemical leaving the north-west, north-east and south-east all hydraulically uncontained. Yes all three of these areas are contaminated and have and still do contribute to the toxic load in the creek which by the way recharges the Municipal Aquifer underneath it. Furthermore the Canagagigue Creek flows east and any recharging to the east MU is upgradient of the flow of the MU both southwards and westwards. There are historical reasons as well. Jeff Merriman (Chemtura) use to tell us that they would excavate a pit for example and stop digging when they no longer could see or smell chemicals. News flash: Longterm Uniroyal Chemical employees lost their sense of smell long ago. Otherwise they would still be working with running eyes, nose plugs and occasional nausea just like normal citizens sufferred on Duke St. from 1998 to 2000 inclusive. Hence all "cleanup" work done on site is suspect regarding what they left behind. This includes west side pits being cleaned out in the mid/late 1980s only to the bottom of the pits. There was no attempt to go deeper even though the various chemicals had all penetrated deeper to the MU even after the 1970 clay lining of the west side pits. .................................................................................................... The DNAPLS on the Yara site included MBT, BT, Aniline, Carboxin etc. These are generally considered to be Uniroyal signature chemicals and their presence in high concentrations in groundwater on the Yara site indicates to me that DNAPL gravity flowed from Uniroyal westwards onto their neighbour's property. Also chlorobenzene was found in high concentrations near the Elmira Water Tower and the choices of a source are slim. They include Borg Textiles (Howard Ave.), Varnicolor Chemical (Union St.) or DNAPL, again from Uniroyal, gravity flowing westwards towards OW 57-32 (water tower). .......................................................................................................... ISCO (In Situ Chemical Oxidation) was used successfully in Cambridge, Ontario (Northstar Aerospace)to breakdown and remove trichloroethylene, also a DNAPL chemical . I suggested its use back around 2006 and was ignored by all. Then around 2013 Conestoga Rovers attempted an amaturish (according to Dr. R. Jackson, 1st TAG Chair) pilot test beside Industrial Dr. which of course was unsucessful and to this date never reattempted. .................................................................................................... Interestingly Source Removal is a proven technology which works. My belief after three decades plus of factual fictions from all the guilty parties (including politicians) is that it is just fine with them not having succeeded with the cleanup. They've run out the clock with angry citizens from 1989 and they've saved themselves a ton of money.