PARTNERS IN POLLUTION'S CREDIBILITY TAKES A HIT (CRA, Chemtura, M.O.E.)

Since last Thursday evening's public CPAC meeting two documents have miraculously been produced from Woolwich Township's archives. The first is the CPAC Minutes of April 24, 2006 and had been properly distributed eight years ago. The second is a May 2, 2008 letter from Jaimie Connolly (Ministry hydrogeologist). It was not properly distributed to all the longterm stakeholders including myself. Funny thing is Woolwich Council had just given me the boot from CPAC a couple of months earlier and CPAC Chair Pat McLean was in charge of distribution. What she lacked in technical knowledge and ability she made up for with political shrewdness.

Jaimie Connolly's letter will haunt Chemtura/CRA for many years. Their refusal to produce it upon request from me at public CPAC meetings is also relative to their ongoing verification plans with the Chemical Industry Association of Canada. Refusing to produce documents that you are relying on to make a hydrogeological point because it hurts your position on other points is not the *Responsible Care way. Ethics and transparency are not to be doled out just to your supporters but to all stakeholders.

Jaimie's letter speaks to the varying thickness (viscosity) of DNAPL chemicals. These Dense Non-Aqueous Phase Liquids gravity flow downhill with no regard for either groundwater flow direction nor for nearby pumping wells (hydraulic containment). Some of Uniroyal/Chemtura's DNAPL has been thin and very mobile and most of it has long ago flowed to low points on top of aquitards or low permeability zones. The thicker DNAPL sometimes described as motor oil consistency or even as tars will move much more slowly. Keep in mind the thusly described DNAPL at TPW2 in 1993 wasn't all removed and yet was no where to be found during the drum removal excavations from there a couple of years ago. It clearly moved! Therefore the M.O.E.'s longtime excuses that they can't order on-site cleanup due to containment is clearly specious. Not only is groundwater moving off site by design in the north-west Municipal Upper Aquifer under the Optimization plan but it is also leaking from the shallow aquifer into the Canagagigue Creek in areas where there are no pumping wells. The Municipal Lower and Bedrock aquifers are also not contained on site. Finally as stated earlier DNAPLS have and will continue to gravity flow off the Chemtura site whether Jaimie agrees in 2006, disagrees in 2008 or comes around again at a later date.

Of course for me Jaimie's biggest revelation is on the second last page of his May 2, 2008 letter. This is why the partners in pollution wouldn't release Jaimies's letter. All's fair in love and war and for years they had a friend as Chair of CPAC. The benefits to both parties were significant. They knew that if I had had that letter I would have trumpeted Jaimie's revelations years ago. Jaimie unequivocally makes it clear exactly as the young CPAC did in 2012 that hydraulic containment on its' own is inadequate to clean up the off-site aquifers. Source removal or reductions in source concentrations are vital!

The April 24, 2006 CPAC Minutes have a detailed discussion of DNAPL issues and proposed source removal. I also discussed In-Situ Chemical Oxidation (ISCO) in those Minutes relative to trichloroethylene removal from the Bishop St. community in Cambridge. Chemtura/CRA/M.O.E. were asked by me eight years ago whether ISCO could be used in Elmira. This is not by far the first time citizens have proposed solutions that were disparaged by the experts (CRA/Chemtura/M.O.E.) only to be embraced years later. Again on page two the Ministry of the Environment and Jaimie proclaim their support for source removal/remediation versus relying solely on hydraulic containment (ie. pump & treat). Therefore source removal has been requested/demanded in July 2003 by CPAC, 2006 by Jaimie C. & the M.O.E., 2008 again by Jaimie C. and finally in 2012 by the CPAC Resolution. Twenty-four years to date of screwing around folks. Less talk and more action! Chemtura shit or get off the pot! Either clean up properly or get the hell gone so somebody else can clean up your mess!