March 10, 2010


Report to public CPAC meeting of March 29/10


Bunker C fuel oil, gasoline, motor oil are all examples of LNAPLs. Light , non aqueous phase liquids have a density of less than 1 and hence will float on the surface of water. The Exxon Valdiz spill gives us a clear visual as to how these chemicals behave in the natural environment. They slowly dissolve in water even with the mixing action of waves and current. They will float for miles before fouling beaches and wildlife.
DNAPLs on the other hand have a density greater than 1. Thus these dense, non aqueous phase liquids sink in water. In surface water they will sink to the bottom where they will tend to flow to depressions on the bottom. An example would be the Dow Chemical toxic “ BLOB” found in the St. Clair River back in the seventies. Similarily in groundwater, DNAPLs will sink through saturated Aquifers until they find a less permeable surface or depression to stop them. The old theory was that they always sunk completely through permeable Aquifers until they hit a less permeable Aquitard. This is not necessarily accurate and world class research institutions such as the Waterloo Groundwater Institute have updated their knowledge of both the behaviour of DNAPLs and the proper remediation of them.

At the present time and indeed for the last twenty years the most urgent cleanup issue facing Elmira has been the universally recognized and admitted existence of DNAPLs in the subsurface of Chemtura (Uniroyal). By universally recognized and admitted I’m referring to the Ontario Ministry of the Environment, APT Environment, the Elmira Environmental Hazards Team, Conestoga Rovers, Dames and Moore, Morrison and Beatty, Golder, CH2MHILL etc. What has been at issue by CRA and Chemtura (Uniroyal) has been the quantity and type of DNAPL. By type I’m referring to Free Phase versus Residual DNAPL. This argument has long been nothing but an excuse for doing little or nothing . Since the meeting in January 2007, involving Dr. John Cherry, Dr. Beth Parker , Pat McLean, Susan Bryant, Wilf Ruland and myself , that excuse has been destroyed. Dr.s Cherry and Parker in one of their very current DNAPL publications have clearly indicated that the Uniroyal time frames would indicate the dissolution of Residual DNAPL (immobile and held by capillary forces within the pore spaces between grains of sand/silt) while the Free Phase DNAPL (saturated and free flowing within the pore spaces) remains. The most recent CRA DNAPL report was presented to the public and some CPAC members at their November 28/08 public meeting. It was not distributed prior to the meeting to myself or the public despite my twenty year ongoing history of authoring DNAPL reports for APTE , the EH-Team and the Soil & Water sub-committee of CPAC. Nearly fifteen months ago , at the January 19/09 public CPAC meeting I presented a report to the members and the public listing the authors and co-authors of numerous DNAPL reports strongly criticizing CRA’s litany of inadequate and misleading DNAPL reports. These authors etc. included professional hydrogeologists , they included myself, Dr. Henry Regier, Wilf Ruland, APTE, Susan Bryant and even Pat McLean signed on for one of them. They also included a July 2003 document requesting source removal of DNAPL from the west side, written by the Soil & Water sub-committee and unanimously voted on and passed by CPAC.

There has been exactly zero new scientific data or theories presented publicly at CPAC to remotely refute the conclusion of the presence of Free Phase DNAPL , relatively easily accessible, below the surface at Chemtura. On Febuary 6, 2009, Susan and Pat were quoted in the Elmira Independent as saying that the committee is “still in the early phases in DNAPL” remediation and that “…nobody has signed off on the DNAPL work to date”. . I have been very concerned for the last two years that this sub-committee’s wish to keep the best informed member of the public regarding DNAPL , off the committee, to be exceedingly strange. Is it possible that this is so that it will be easier to sell a pretend cleanup to both the rest of CPAC and to the public?

Alan Marshall Elmira Environmental Hazards Team