Just to be clear that is indeed review comments by our blessed and beloved MECP not for this year completed (2022) but from the previous year (2021 . The Annual Monitoring Report (AMR) comes out each spring from Lanxess's consultants. It is an annual report and summary of important and ongoing alleged remediation items such as on and off site pumping & treatment plus groundwater elevation contours as well as contaminant concentrations of various plumes on and off site. It used to contain much more but has been trimmed over the decades either due to superior cleanup performance (HA!) or more likely just because.
Hmm the MECP are getting a little pushy here. They actually claim that Lanxess have failed to elucidate the sources of NDMA to the Elmira Aquifers after 1970. They further advise that future reporting (AMR) should include whether or not the decomissioned on-site ponds are still contributing as a residual source of NDMA in groundwater at the site.
On page 4 the MECP bluntly state that the "...timeframe to achieve the existing clean-up objective to restore to drinking water standards for NDMA and chlorobenzene in the off-site MA is uncertain".
A supposed isolated detection of toluene in September 2021 in the Creek and how this detection of toluene was corrected is not provided in the AMR. Similarly the rationale for believing that a temporary loss of containment in the Upper Aquifer allegedly did not cause any adverse affects in the Creek has not been provided. In other words yet again the Conclusions of GHD (always helpful to Lanxess) are not squared with the data and information presented.
Rebound refers to contaminated soils discharging contaminants into the surrounding groundwater and hence raising the concentrations of themselves in the groundwater. Apparently this phenomenon is being proven at the South Wellfield as pumping well E7 is being shut down intermittently and indeed NDMA concentrations begin to rise again in the groundwater. There is also much discussion of residual sources of NDMA and chlorobenzene in groundwater.
Further discussion of the pros and cons of the Ricker Method plume stability analysis concludes that Ricker can not predict a time frame to achieve a remediation goal at sites where there is a residual source in the aquifer/aquitard. Apparently in the Municipal Aquifers under Elmira residual phase LNAPL & DNAPL? are considered a continuous source of dissolved plume NDMA and chlorobenzene.No surprise there folks. Yet where was the fuc.ing MECP during all the DNAPL investigations and first class coverup?
Other MECP concerns are how much cleanup of the Elmira Municipal Aquifers are due to natural attenuation processes versus from the On and Off-Site Containment & Treatment System. Apparently the effect of the pump & treat systems on residual sources is unknown. Unsurprisingly the MECP would like future AMRs to provide information about the status and distribution of residual sources of NDMA and Chlorobenzene in both the saturated and unsaturated soil zones at the Site and off-site.
There are a few new interesting admissions here by the MECP. Good for them. Doubtless Lanxess will ignore them and there will be no consequences.
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