TRAC THIS IS ALSO YOUR RESPONSIBILITY TO BE MONITORING & INSISTING UPON COMPLIANCE FROM LANXESS CANADA

 

Look it's one thing to be a cheerleader versus a watchdog but at some point you have to insist that Lanxess comply with their Control Orders, Environmental Compliance Agreements, MISA requirements and other mandated conditions affecting Elmira's groundwater cleanup as well as the cleanup of the Canagagigue Creek. Yesterday we discussed their failure to maintain the balance between on and off-site pumping necessary to ensure hydraulic containment in both areas. 

Again I have the data going back to 1997 at my fingertips showing the volume of pumping from the UACS (Upper Aquifer Containment & Treatment System). Each month I transfer the pumping results from the ongoing Progress Reports onto one individual page for the year thus reducing 12 monthly reports pumping information for all containment systems to a single page. Now if Lanxess Canada had made some sort of breakthrough several years ago that magically reduced the required amount of pumping and treating of groundwater, they certainly haven't publicly made a big deal of it. In fact for many years the Target pumping rates for each well along with the actual pumping that particular month were discussed in detail. Uniroyal, Crompton and Chemtura were occasionally balancing and adjusting based upon water level conditions ("Gig") and other factors which they openly and properly discussed with the UPAC and CPAC committees. We were often advised that short term reductions were not necessarily a problem however the Target pumping rates were carefully set in order to maintain the necessary hydraulic containment and avoid loss of contaminants from on-site either to off-site groundwater or for the leakage of contaminants from the on-site Upper Aquifer to the discharge point into the Canagagigue Creek.     

Above and beyond the committee members themselves is the fact that all actions and particularly changes from past practices are to be discussed at the public RAC/TAG and now TRAC meetings. When pump & treat is the primary remediation method it is of particular public interest to discuss rationales for any changes in pumping regimens, especially reductions. This has not been done either for on-site Municipal Upper Aquifer (MU) pumping or for on-site shallow groundwater (i.e. Upper Aquifer-UA) pumping. The pumping rates have simply been getting lower and lower over the last several years with no public discussion involved. Whether or not I have been able to stomach in person attendance at these alleged public meetings the fact is that I have watched and listened to them in their entirety via their on-line presence. I have also written critiques of each and every one afterwards. Perhaps there are implications to these Lanxess Canada, MECP and TRAC UA pumping failures somewhat similar to the implications I wrote about yesterday concerning the Municipal Upper Aquifer (MU) pumping failures.