JAIMIE CONNOLLY'S SECOND DNAPL REPORT (TWO YEARS LATER)

May 2, 2008 - Ministry of Environment ten page report sent to Jeff Merriman, Senior Chemical Engineer at Chemtura Canada Co. Jaimie Connolly (M.O.E.) advises in the first two pages that there may indeed be DNAPL mass in RPW-4 and RPW-7 (Retention pits 4 & 7). Jaimie concedes that the likely DNAPL present in RPW-7 is no longer mobile. He also advises again in contradiction to Conestoga Rover's (CRA) report that the known free phase DNAPL in area M-2 on the south-west side of the site does likely still need remediation after further systematic assessment. Further he advises that the Upper Aquitard (UAT) is very thin beneath the M-2 location and hence the drinking water aquifer (MU) is still threatened from this area. He also expresses concerns regarding contamination in the P-1 area and the Main Tank Farm (MTF) both on the west side. He references the inadequate presence of monitoring wells nearby. Similarly he sounds the alarm regarding siggestions/conclusions from CRA that contamination in the East Central area does not impact the creek. His evidence includes fluctuating levels of DNAPL chemicals (chlorobenzene) in the shallow groundwater such as observation wells OW-72 and OW-70. Jaimie feels that the high levels of contamination in the East Central area originating partially from retention ponds east namely RPE-4 and RPE-5 need much more investigation and likely remediation. ..................................................................................................... Back to the west side Jaimie is wavering on whether or not DNAPL exists off-site to the west from Uniroyal on the Nutrite/Yara property. Regardless he states that the very high 2-MBT (mercaptobenzothiazole) concentrations requires serious attention including boreholes (soil testing) and additional groundwater monitoring. Jaimie also feels that the concentrations of 2-MBT have yet to be fully understood or explained whether caused by co-solvents or unlikely amounts of DNAPL movement. Acetone is one of the possible co-solvents and it's rapid degradation in the aquifer system is consistent with other sites (Hamilton). Furthermore Jaimie believes that indeed formerly high concentrations of acetone acted as a co-solvent, greatly increasing the solubility of 2-MBT and aiding in its off-site movement within the aquifer system and eventually the 2-MBT partitioned into the aquifer solids acting as an ongoing source of 2-MBT concentrations within the aquifer. Jaimie then quotes the lack of monitoring of acetone in various aquifers from the Annual Monitoring Reports (AMR 14, 15 & 16) despite remaining high concentrations in RPW-7. ................................................................................................................................ In paragraph 17. (page 7-8 Jaimie discusses Effective Solubilities versus Laboratory Solubilities of various solvents in water. He reproduces Table E.1 from CRA's DNAPL report and it is shocking. Effective solubilities generally refer to the incredibly reduced solubility of various chemical solvents in groundwater that has multiple contaminants in it versus the calculated Lab Solubility of one solvent at a time in pure water. To say that the Effective Solubilities are grossly reduced from the laboratory solubilities is a huge understatement. They are literally orders of magnitude lower including ten, one hundred and even thousands of times lower for some chemicals in Uniroyal/Lanxess's groundwater. This greatly changes DNAPL indicaters such as the 1% Solubility Rule which states that compounds found in groundwater at 1% of their Lab Solubility indicate the likely presence of Dense Non Aqueous Phase Liquids (DNAPL). Clearly the huge lowering of solubilty concentrations also hugely lowers the concentrations indicative of DNAPL presence. Uniroyal/successors and CRA/GHD (consultants) failed to clarify that for UPAC (Uniroyal Public Advisory Committee), CPAC members and the general public. Finally Jaimie suggests that mobile DNAPL and LNAPL (light non aqueous phase liquids) seems to be decreasing with time. He believes that there is a gradual transition of these NAPLs towards tars and solid residue. Personally I also would suspect that after seventy plus years that mobile DNAPLS have gravity flowed to low points on aquitards and lower permeability areas within aquifers where they remain slowly dissolving into the groundwater. ......................................................................................................................... Page 9 is the kicker! Jaimie states "But, I am concerned that the evaluation of the threat posed by individual areas is not taken as far as it should be where the contamination is currently hydraulically contained. In my opinion, long term reliance mainly on hydraulic containment carries with it substantial risk. Reduction in source concentrations is a desireable objective and is consistent with the multi-barrier approach to dealing with contaminant threats." ................................................................................................................................................ Jaimie Connolly, hydrogeologist has made it very clear that the current (2008) status of DNAPL delineation and remediation is inadequate. Since then, once again DNAPLS have been put on the back burner for many years with nothing more than occasional untruthful verbal references to concensus on the matter. To the Ontario Ministry of Environment's (M.O.E.) ongoing shame they have not stepped up to insist upon proper DNAPL remediation both on this site or on impacted nearby off-site locations.