CHEMTURA ON-SITE TESTING FOR DNAPL CHEMICALS

This posting if possible should be read along with my postings of last Friday and Saturday. Friday's posting focused on free phase DNAPL being present on the Chemtura site versus residual DNAPL. Saturday's posting mentioned free phase DNAPL flowing from Chemtura onto their neighbour's property, namely Yara (Nutrite). Keep in mind that as usual the vast bulk of negotiations between the M.O.E. and polluters are done in private and in secret and these were no exception. Hence in hindsight we can easily understand why Nutrite were so recalcitrant back in 2004 to accept their responsibility for putting Ammonia both onto Chemtura's property and into the Elmira Aquifers. They knew how badly Uniroyal (Chemtura) had polluted their property. These private discussions were to protect Nutrite, Uniroyal and our Ontario Ministry of the Environment from public and media scrutiny and especially CPAC scrutiny. Uniroyal (Chemtura) wanted to hide the free phase DNAPLS and the M.O.E. wanted to hide their refusal to order on-site cleanup despite smoking gun evidence of pollution leaving Chemtura's site that can't be controlled by hydraulic containment.

I have looked at the very limited data regarding DNAPL chemicals presented in Table A.3 of the Chemtura monthly Progress Reports since last September. It is limited by the number of DNAPL chemicals tested for, by the number of groundwater wells tested and by the location of those wells. Nevertheless despite the inherent limitations the concentrations presented are significant. Two of the four Base/Nuetral DNAPL chemicals are above the 1% solubility rule first brought to UPAC's attention by myself through a report written by hydrogeologist Stan Feenstra in 1992. Mercaptobenzothiazole and Carboxin are routinely above this screening tool (1%) and not just by a little. They are often five to six times higher than a screening tool which in itself understates the likelihood of the presence of nearby Dense Non Aqueous Phase Liquids. DNAPLS are so far past mere "evidence" on this site that the M.O.E. should hang their heads in shame. Not only do they surpass most of the highly inflated screening tools but they have been actually discovered in soil and groundwater in several locations on the site yet CRA/Chemtura/M.O.E. continue to deceive.