A FEW SPECIFICS FROM MY AUGUST 26/07 CRITIQUE OF CRA'S AUGUST 2007 DNAPL INVESTIGATION REPORT

Language, terminology and criteria. It's like pre-trial Motions. You attempt to limit and focus debate to your advantage. Conestoga Rovers (CRA) essentially redefine words for their own uses. Direct and indirect evidence are their invention and definition. They have been criticized for these abuses of the English language repeatedly.

Fake criteria are their specialty notwithstanding the attempt to switch the 1% Solubility Rule with 10% by an earlier consultant. CRA seem to love their self declared 10,000 ug/g (ie. parts per million) criteria. Quoting the Region of Waterloo in 1993 " The fact that DNAPL is present in this area and that the soil samples are at concentrations of less than 10,000 ug/g disproves the theory that soil quality greater than 10,000 ug/g is an indication of DNAPL. This argument was used by Dames and Moore without success.".

Regarding CRA's inability to properly calculate Effective Solubility, while significant isn't the whole story. Effective Solubility refers to multiple contaminants simultaneously dissolved in groundwater versus lab or aqueous Solubilty which refers to but one contaminant dissolved in a litre of pure water. Quoting my Report "At the same time it should not be ignored that we have a breakthrough here. Regardless of the method of calculation, we have after approximately 16 years, an admission that the whole prior basis for calculating either the 10% solubility rule (Brian Beatty) or the 1% aqueous solubility rule is effectively bogus. Either former criteria dramatically reduces and minimizes the likelihood of evidence pointing to the presence of either residual or free phase DNAPL."

Unbiased experts, untainted by personal financial and professional gain, have clearly stated in direct contravention to CRA/Chemtura's self serving positions, that decades of groundwater flushing will dissolve residual DNAPL long before free phase DNAPL fully dissolves. Professor's J.Cherry and B.Parker have indicated this in their professional writings which they provided to me as well as in a personal interview. That Ruland, Mclean and Bryant have virtually refused to publicly speak about that meeting in January 2007 speaks volumes. Their public silence or perhaps even private comments regarding it are likely due to Susan Bryant's humiliation of having agreed to allowing Uniroyal Chemical's Indemnity for on site known contamination, including DNAPLS, to stand. She should have screamed that Indemnity to APTE co-ordinators, members and the public. She chose not to. Instead she has actively aided and abetted Uniroyal/Chemtura in their decades long DNAPL coverup.

My August 2007 critique also speaks similarily to recent comments made at a CPAC meeting by member Ron Campbell. He disagreed with CRA's longstanding claims that either stable or decreasing concentraions of dissolved DNAPL chemicals in a hydraulically contained aquifer somehow proved a lack of Dense Non-Aqueous Phase Liquids (DNAPL) nearby. To date CRA as usual have refused to provide any literature searches or honest scientifc support for their self serving alleged statements of fact.

I also commented seven years ago in regards to exceedingly high groundwater concentrations of DNAPL chemicals on the Yara site. Recall that Jaimie Connolly and Wilf suggested in 2006 that free phase DNAPL was present off the Chemtura site on their neighbour's property (Yara/Nutrite). CRA in their 2007 DNAPL Investigation Report suggested that no it was just high dissolved concentrations that had leaked from their south-west corner (M2 area). Then in an incredible bit of tortured and twisted logic CRA stated that "continued" hydraulic containment on their site would reduce these high off-site concentrations. CRA's vaunted municipal aquifer hydraulic containment has been ongoing since January 1992.

There is lots more but this gives you the readers the idea.