FURTHER TO YESTERDAY'S POSTING ABOUT ACETONE ACTING AS A COSOLVENT

Jaimie Connolly's (Ontario M.O.E.) October 31, 2012 report is riddled with errors and unproven assumptions. Jaimie states in his fourth paragraph that "I had concluded that off-site detections of the compound 2-MBT likely occurred because acetone (which was used on site) acted as a cosolvent, facilitating it's off-site movement at high concentrations.". Firstly I dispute any such conclusion and would need to see when and where Jaimie allegedly made this conclusion. One of the reasons I am skeptical is because CRA went to the trouble of actually doing a study to determine if there was a relationship between extremely high groundwater concentrations of 2-MBT and either acetone or chlorobenzene as cosolvents. This whole issue of cosolvents had been originally raised by Dr. Henry Regier and certainly the groundwater concentrations on the Yara site of 2-MBT were extraordinary. There were concentrations of 1,364% and 4,250% of 2-MBT's stated lab solubilities.

CRA concluded after comparing the 2-MBT concentrations with current acetone and or chlorobenzene that there was not a relationship or causal effect with either of those two solvents. Jaimie then by an incredible leap states that there was, but worse yet twists the study into somehow stating that acetone was a cosolvent for chlorobenzene. Jaimie may be stating that that is his opinion but I'm stating that if you're going to leap blindly off a scientific cliff you should have at least some research or study to back you up. Jaimie does not.

The other issue is this. Acetone was considered as a cosolvent in the case of extraordinary groundwater concentrations of an almost insoluble compound namely 2-MBT. Jaimie now wishes to further compare apples to oranges by suggesting that acetone is a cosolvent to chlorobenzene. Please! Chlorobenzene is already readily soluble in water without any help from acetone or anything else. It's lab solubility is approximately 440,000 parts per billion. The groundwater concentrations while high behind (west) Varnicolor were absolutely nowhere near the ridiculous solubility concentrations of MBT. In fact chlorobenzene was barely at 1% of it's solubility in groundwater. This percentage is in the range of possible nearby presence of DNAPL and combined with evidence found by CRA, strongly indicated the presence of DNAPL and was indeed initially so suggested by CRA. For Jaimie then to categorically state "...the overall evidence is not indicative of DNAPL ocurrence..." is ridiculous. 1% groundwater concentrations combined with a sheen on the groundwater 100 feet below the surface, stained soil samples from 100 feet down, odours and finally CRA's and Chemtura's hiding from this issue literally for years tells the tale.

Add to all that both Conestoga Rovers (CRA) excuse riddled (oopsy we spilled something) August 29/12 memo added to Jaimie and the M.O.E.'s excuse riddled memo of October 31/12 and on the balance of probabilities there is DNAPL present and acetone is a pathetic red herring.