SOME PERSPECTIVE REGARDING CHEMTURA & CONESTOGA ROVERS DNAPL EFFORTS

For about the last week I've been blasting away at the pretty obviously overwhelming evidence of free phase DNAPL (dense non-aqueous phase liquid) below surface on the Chemtura site in Elmira. I may also once or twice have referred to data gaps in the groundwater monitoring which I have attributed to intentional avoidance of producing damaging evidence contrary to the company line. All that being said I am going to throw Chemtura/CRA a bone here. After extensive digging through DNAPL Investigation Reports, DNAPL Status Reports, Monthly Progress Reports and the Annual Monitoring Reports; I will admit that I have found more groundwater testing for DNAPL chemicals than I expected. I had at the last CPAC meeting demanded of Jeff Merriman of Chemtura why he/they weren't doing more of this testing. He pointed out off the top of his head that the data was in the Monthly Progress Reports. He was correct in that the previous 1 3/4 years of monthly reports did have significant DNAPL information. More surprisingly to me was the Annual Monitoring Reports which I am still going through. They do indeed have about a half dozen wells in the former RPW ponds which are regularily tested for Chlorobenzene, Toluene (LNAPL), Aniline, Benzothiazole, MBT and Carboxin.

Again as I collect more data all on one Table for individual DNAPL chemicals I am seeing the very nature of DNAPL contamination. There are some wells which over time amd over years of groundwater pumping have reducing concentrations. Unfortunately other wells and or compounds over time and over years of groundwater pumping have little or no reductions in their groundwater concentrations. These conditions absolutely do not reflect the characteristics of constantly diminishing residual DNAPL presence. They do reflect however the reduction or elimination of residual DNAPL (ie. in the pore spaces between grains of sand/gravel only) while at the same time free phase pools of DNAPL are in existence; constantly slowly dissolving over decades and centuries into the groundwater.

Therefore while I commend CRA/Chemtura for more DNAPL testing than I had originally thought I still condemn their refusal to admit to free phase DNAPL on their site. As my friend and colleague Rich Clausi likes to say "You will never solve a problem until you admit that it exists.".