DNAPL REPORTS UNDERMINING LANXESS/CRA/GHD CREDIBILITY

I mentioned four reports in yesterday's posting namely Jaimie Connolly's (M.O.E.) April 3, 2006 and May 2, 2008 reports as well as Wilf Ruland's of April 21, 2006 and May 15, 2008. I will go over some of the highlights of each report starting with the first one (Jaimie's) of April 3, 2006. .............................................................................................................. Jaimie suggests that there is residual DNAPL in RPW-1 and TPW-1 both on the west side of the site. Furthermore free phase DNAPL while unfound nevertheless is possible/probable in TPW-1 as "tar-like material" was found there. TPW-2 is referred to as a known source area and the DNAPL as migrated from the shallow aquifers into the Municipal Upper Aquifer (drinking water aquifer) in that area. RPW-4 is uncertain regarding DNAPL presence however RPW-5 is a known source and repository of free phase and residual DNAPL. A small area of RPW-5 was excavated back in 1993. Jaimie suggsts that further sampling/monitoring, thirty years later, needs to be done in RPW-5. RPW-6 is a likely DNAPL source zone although limited groundwater wells are available or have been sampled. RPW-7/8 have significant residual LNAPL present as well as probable free phase and residual DNAPL. Jaimie states that both areas are potential long-term source areas. M2 in Uniroyal/Lanxess's south-west corner (former municipal landfill on site) is a known area of free phase DNAPL and the dissolved constituents are throughout the sub-surface aquifers there (including Municipal Upper). RPE-1 on the east side of the property is a known past and probably current free phase and residual DNAPL area. Jaimie refers to it as a long-term DNAPL source zone. CRA actually conceded that there is potential for DNAPL near RPE-5 (east side) and downgradient towards the creek. Off the Uniroyal/Lanxess property Jaimie C. suggests that "...it is possible that NAPL-phase does exist off-site toward the south-west." Apparently there are DNAPL chemicals even in the Bedrock Aquifer exceeding 1% solubility concentrations suggesting the presence of DNAPL, whether free phase or residual. Presence off-site of DNAPL is a huge complication and difficulty that if true should have been addressed decades ago in my opinion. That fact alone strongly condemns the goals and sincerity of those in charge again in my opinion. ................................................................................................................................. Jaimie Connolly suggests that more monitoring wells and greater monitoring are necessary along the western Uniroyal/Lanxess boundary, both in the north and the south. He also suggests that the tank farm in the west central part of the site (west of P-1) "...may be considered an area of concern requiring more investigation." Furthermore Jaimie is a proponent of greater testing of DNAPL found to determine things like varying chemical components and viscosity. This of course was disputed by Mark Bauman and Susanna Meteer years later at a CPAC meeting for in my opinion, weak reasons. He also focuses on the outstanding groundwater concentrations of 2-MBT (mercaptobenzothiazole) found on site. Jaimie STRONGLY advises the implementation of source removal technologies to remove DNAPL on the site. This is in direct opposition to Uniroyal and successors as well as their consultants CRA and GHD. He would like further remediation in TPW-2, M-2, off-site M-2, RPW 7/8 and RPW-5. Further he pooh poohs the claims that 10,000 mg/kg soil concentrations are an appropriate soil criteria. He lists a number of free phase DNAPL areas found with lower soil concentrations. For me I am surprised by Jaimie's insistence that there are extensive plumes of DNAPL chemicals in both the Municipal Lower (ML) and BEDROCK aquifers. That is a huge surprise to me and in fact chlorinated DNAPL chemicals in the Bedrock have not been made clear to either UPAC or CPAC much less to the public.