JAIMIE CONNELLY'S (M.O.E.) DNAPL LETTER OF MAY 2, 2008

A week ago here in the Advocate while discussing Jaimie's letter I advised readers about Jaimie's comments concerning source removal versus hydraulic containment as well as Dense Non-Aqueous Phase Liquids mobility in the subsurface based upon its' thickness (viscosity). Today I will discuss other issues he raised in his ten page letter. Keep in mind this letter was kept hidden from myself by the old CPAC Chair as well as by Chemtura/CRA and the M.O.E.. Afterall they knew damn well I would raise it at CPAC if I had it and they made certain never to mention it themselves until I attacked them over Jaimie's April 3, 2006 DNAPL letter. Meanwhile we are advised in the March 27, 2014 CPAC Minutes by Steve Quigley of CRA that hydrogeologist Wilf Ruland wrote a May 15, 2008 letter. This letter similar to Jaimie's May 2, 2008 letter allegedly reverses his position on the presence of off-site DNAPL on the Yara property. Again this letter was not distributed to the Elmira stakeholder who has attended more CPAC meetings over more years than virtually any other, namely me. Public consultation was always intended to be seen but preferably not heard from. It also helps imeasureably if the guilty parties are able to sucessfully co-opt some of the locals.

Jaimie's letter at paragraph 12 states "...that DNAPL is not likely present in the off-site M2 area." Then at paragraph 15 Jaimie states "...the locations of many of these elevated detections suggested a degree of DNAPL movement which seems unlikely." Hmmn! "unlikely" and "not likely"; it seems likely to me that Jaimie wouldn't bet the farm on either scenario just yet. Later in his letter he suggests an alternate theory involving acetone as a co-solvent but here again the proof isn't yet available so he recommends some bench scale testing of this theory. I wonder why I suspect that this has been done, written up and there's yet another letter out there I haven't seen? I do know that in CRA's August 2007 DNAPL Report (Appendix B), which Jaimie is commenting on, that co-solvent effects of acetone upon MBT (mercaptobenzothiazole) could not be substantiated.

At paragraph 17 of his letter Jaimie indicate that CRA's Effective Solubility calculations were done incorrectly. He then does the calculations which clearly show how dramatically the solubilities of solvents in groundwater are reduced by the presence of multiple compounds. Some organic solvents have their solubilities reduced by a factor of ten and others are reduced hundreds and even thousands of times from their lab solubilities. This is stunning information which multiplies the weight of the 1% solubility rule incredibly. Afterall if chlorobenzene concentrations in groundwater are 3% of their lab solubilities but 100% of their effective solubilities then you have DNAPL nearby and if these concentrations go on for years then it is most probably free phase DNAPL.

In paragraph 1 Jaimie takes a serious round out of CRA's oft repeated nonsense that declining concentrations of DNAPL chemicals here and here means there is no DNAPL present. Jaimie states "Where concentrations stabilize at elevated levels in spite of this flushing action, that is likely indicative of NAPL presence or else a large mass of adsorbed or solid contamination.".

Jaimie disagrees with CRA's conclusions in his paragraph 4 and 5 that DNAPL does not exist in RPW7 and M2.

Jaimie feels in his paragraph 9 that NAPL is present at or near the main tank farm and should be further investigated. he also has concerns with high chlorobenzene concentrations found intermittently on the east side at OW70 and OW72. These concentrations suggest to him the possibility of mobile DNAPL.

This document similar to the October 7, 1991 "sweetheart" deal aka Settlement Agreement with Uniroyal should have been distributed widely and was not. They both taint Chemtura, the M.O.E. and their fellow travellors. I guess when the facts are against you, deception and manipulation are your best friends.