Guess how many TRAC members will actually read those additional pages this weekend as well as all the rest of the package? Yup about that many (less than the fingers on one hand). The additional 24 pages appear to be at least partially overheads in which GHD will be misrepresenting the four questions from TRAC they have to date answered so incompletely and poorly. The two I focused on were the failure to properly test the soils and sediments throughout the Stroh property albeit closest to the Stroh Drain, Ditch & Berm (SDDB) as well as the so called DNAPL issues both on and off the former Uniroyal Chemical site. The good news here for Lanxess/GHD/MECP is that TRAC members are fully satisfied and willing to move on no matter how tenuous, unlikely, incomplete, unreasonable or just plain stupid the answers that they are given. Afterall isn't TRAC's mantra "WE CARE & WE QUESTION; NOT OUR ISSUE IF THEY LIE TO US" ?
The lying goes back decades and continues to this day. Susan B., Sylvia B., Pat M. all were long ago co-opted and making private deals not in the public interest with Uniroyal Chemical and successors. These deals included agreeing with the polluter that DNAPLS were a non issue which is outrageous. Yes I can believe that a couple of thimbles of chlorobenzene would have quickly, fully dissolved in the shallow aquifers as well as any tiny amount that moved into deeper aquifers. However by Lanxess/GHD's own admissions 3,300 KILOGRAMS have already been removed from the Elmira Aquifers since 1998 and it's still going. Furthermore nearly 2,000 KILOGRAMS of that chlorobenzene are unaccounted for via normal production use and waste percentages. Clearly there were large spills of this classic DNAPL chemical with a low solubility and a density greater than 1 (i.e. a "sinker"). These numbers are also in their November 18/2024 "Screening of Enhanced Technologies for Offsite Groundwater Remediation of the Elmira Drinking Water Aquifer" (page 3).
Evidence of free phase and residual DNAPL presence both on and off site is very strong. One of the excuses for continuing high NDMA concentrations in our groundwater is because of the very low drinking water standard of 9 parts per trillion (.009 ppb.). Meanwhile chlorobenzene with a drinking water standard of 80 parts per billion (80 ppb.) is still in our Municipal Lower Aquifer at 173 ppb. and the Municipal Upper at 123 ppb. For that you can thank the sloppy handling and disposal of chlorobenzene resulting in DNAPLs throughout their site as even stated by Frank Rovers (CRA) at a meeting attended by Susan B. back in the 90s.
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