LIES, FIBS, MISREPRESENTATIONS & JUNK SCIENCE RELATIVE TO *RESPONSIBLE CARE

*Responsible Care is more than just rules, regulations and procedures. It also encompasses ethics. For most of the world ethics would include honest communications between parties and stakeholders. Hence for a company to routinely misrepresent facts and distort reality to their self-serving version should preclude them from receiving verification/reverification under *Responsible Care.

Following are but a few examples of what I am referring to. More sensitive readers may choose from the discriptive list in the title if they feel more comfortable in characterizing Chemtura and fellow travellors behaviour, for example, as junk science versus lies.

The NDMA plume centred around OW60, north-west of Chemtura is a "relic" or "remnant" plume. This is a self-serving factual fiction for Chemtura and fellow travellors to prop up their original fiction that only one company contributed to the destruction of the drinking water aquifers. Their definition of "relic/remnant" plume reminds me of Brian Beatty's testimony at the early Environmental Appeal Board hearings that stated that dissolved contaminants left in a westward direction from Uniroyal and then were held essentially immobile by countervailing hydraulic forces due to the north and south wellfield simultaneously pumping. This theory was disproven by among other things the fact that the south wellfield was contaminated with Uniroyal chemicals as shortly afterwards was the north wellfield. Immobile plumes of high concentrations of chemicals do not remain stationary in groundwater. They move and they eventually through dilution etc. decrease. High readings in the same area over years/decades, without extraction wells beside them, indicate a source area of contamination.

Acetone is a co-solvent which has magnified the concentrations of chlorobenzene in the groundwater around OW57-32R, beside pumping well W4. Many solvents will act as a co-solvent for chemicals that do not readily dissolve in groundwater. Examples would include essentially insoluble compounds such as DDT, Dioxins, Mercaptobenzothiazole and numerous other compounds found on the Chemtura site. This phenomenon explains the detection of normally hydrophobic (water avoiding) compounds in groundwater. These hydrophobic compounds readily dissolve in solvents but not in clean groundwater. The M.O.E. without presenting a lick of scientific literature to back them up, claim that no longer present acetone increased the solubility of chlorobenzene, allowing for higher concentrations than in upgradient locations, closer to Chemtura/Uniroyal. That is rubbish and worse. A study that was done by Conestoga Rovers a few years back actually was unsucessful in pinning high dissolved concentrations of Mercaptobenzothiazole upon significant concentrations of acetone also present. Jaimie Connolly of the Ontario M.O.E. appears to have grabbed upon this study with the hopes that no one present at CPAC will remember the conclusions (wrong!) and distort them into "proving" or at least supporting his unsubstantiated theory. I've publicly called him on it and to date no response from him, CRA or Chemtura.

Last but not least is Chemtura/CRA/M.O.E. refusal to acknowledge source areas off the Chemtura site. This includes the already mentioned OW60 (NDMA) as well as OW57-32R (chlorobenzene), CH-38 (NDMA)and CH44 area (NDMA/Chlorobenzene) on the Yara/Nutrite site. To date Chemtura only wish to "credit" Yara for Ammonia contributions. There are soil readings with multiple other chemicals above and beyond NDMA and Chlorobenzene.

An honest company wishing to achieve *Responsible Care would not let these strongly disputed facts fester. If they were being honest and forthright they would not sweep them under the carpet primarily using the credentials of their consultants and the M.O.E. . They would take the time and trouble to either find and produce third party unbiased studies backing their positions or they would agree to funding independent peer reviews of these important problems. To date that has not occurred.