FOURTH (LAST) INCREDIBLE DNAPL REPORT CONTRADICTING UNIROYAL/LANXESS/CRA/GHD POSITION'S

This report (May 15, 2008) is done by Wilf Ruland who finally did good work on behalf of the public with his two DNAPL reports/letters to CPAC in support of Jaimie Connolly's (M.O.E.) two reports of April 3, 2006 and May 2, 2008. All four of these reports spread over two years (2006-2008) undermine and effectively nuetralize Chemtura and Lanxess's self-serving position that there was a concensus on the DNAPL issue either then or since. Perhaps multi-national, multi-billion dollar corporations define "concensus" as no parties or stakeholders either suing their ass.s or charging them criminally for their negligence and misbehaviour. Of course it also helps our world class polluter (Uniroyal/Lanxess) when essential reports either go MIA (missing in action) or are quietly not distributed to all stakeholders as CPAC (2011-2015) discovered with these four reports. Susan Bryant publicly suggested at one of those CPAC (2011-2015) public meetings that I did not receive those crucially important letters because I did not have e-mail between 2006 and 2008. Apparently fax, phone or public mail simply weren't high enough tech for Susan and her buddy, then CPAC Chair, Pat McLean. ..................................................................................................................... Wilf suggests that a series of maps showing aquitard (i.e. impermeable or low permeabilty soils such as clays, silts etc.) surface contours and thickness with locations of known "windows) needs to be completed. "Windows" refers to high permeabilty openings through the aquitard allowing contaminants ready access to deeper zones. He also flat out states that Chemtura needs to make a commitment to improve on-site groundwater quality via remediation of likely pure phase DNAPLS and LNAPLS with measures to remove or nuetralize these contaminant sources. THIS IS HUGE & A LONG OVERDUE STATEMENT DEMANDING MORE ON-SITE SOURCE REMOVAL OF DNAPLS & LNAPLS !!!! ................................................................................................................................. Wilf appears to me to have missed the boat regarding further investigation at RPW-5. Is this some form of quid pro quo with Chemtura? Allegedly he did not find any MOE recommendations. Is he not including Jaimie's advice into the MOE's recommendations? Wilf does want excavation of berms between RPW-6, 7 & 8 where these berms are shown to contain hot spots of soil contamination. This is VERY IMPORTANT AS WELL! Wilf suggests that "directional drilling techniques to install horizontal purge wells" in and around TPW-2 be completed in contradiction to CRA's recommendation of only continued routine groundwater monitoring. In the M-2 area (south-west) Wilf suggests more investigation looking for additional drums in the M-2 area as well as paving or sealing the surface of M-2 to stop ongoing water infiltration into the area. Regarding RPE-2 and RPE-3 (east side) Wilf mentions more groundwater sampling including for PHC (petroleum hydrocarbons) which Jeff Merriman (Chemtura) specifically misled me and CPAC about their presence. ............................................................................................................................................... Wilf on page 4 (10) recommends "...a major excavation" to eliminate DNAPL hot spots downgradient of RPE-5 in the vicinity of OW42-4 "...with every effort being given to trace and eliminate the contamination all the way back to the source." WOW !!! Wilf further states that after that is completed that the following year an excavation be undertaken "...to eliminate the DNAPL hot spot downgradient of RPE-4 in the vicinity of OW40-6". WOW AGAIN !!! ................................................................................................................. On page 5 (11) Wilf suggests "...installing a shallow groundwater cut-off trench ..." to intercept LNAPL and other contaminants on the downgradient side of the Main Tank Farm. He also repeats his concerns with "...eliminating the downward flow from the MU (municipal upper) to the ML (municipal lower) aquifer and possibly from there into the bedrock aquifer in the west part of the site near well MOE1." On page 6 he would also like to see "Modern and innovative remediation techniques..." considered for the Uniroyal Chemical site with suggestions included. Finally Wilf advises that there are ongoing flows of contaminated groundwater from the west part of the Chemtura property causing significant off-site groundwater contamination of the ML and bedrock aquifers near well MOE1. ............................................................................................................ THIS IS A BALLSY, STRONG REPORT LONG OVERDUE!!!! WHETHER THE CAUSE IS JAIMIE CONNOLLY'S APRIL 3, 2006 and MAY 2, 2008 DNAPL REPORTS OR NOT; THESE KINDS OF BLUNT ASSESSMENTS OF UNIROYAL/CRA etc. FAILURES AND MISDIRECTION HAVE BEEN FAR TOO INFREQUENT AND TOO FAR APART !!!!!!!!!!!!!!!