the following will be sent immediately to TRAC, Woolwich Council, Regional Council, maybe the media and certainly to the honest, remaining environmental activists in Elmira
On pages 5 and 6 in Luis Almeida's letter of November 14/24 to Tiffany Svensson (TRAC), Luis gilds the lily yet again via distraction and deflection. Tiffany starts the TRAC Question 4 as follows: "Has Lanxess determined the effective solubilities of NDMA and chlorobenzene in the upper and lower municipal aquifer?" Luis made no attempt to answer that question. Tiffany in Question 4 followed with "Addressing the concern of using the "aqueous" solubility value of chlorobenzene in the September 12, 2024 presentation to support the assessment that there is no NAPLs present off site...". Here Tiffany quite frankly states that GHD (Alan Deal) incorrectly used the Aqueous Solubility value instead of the much lower Effective Solubility value. Luis's inaccurate, dishonest and misleading answer was "GHD did not use the 1% rule or effective aqueous solubilities to infer or repute the presence of DNAPL."
Well in fact GHD (Alan Deal) did exactly that. He did it and as I was at that meeting I not only wrote down what he said but later confirmed his words from the You Tube video of the TRAC meeting. I also checked Mr. Deal's overhead slides (pg. 16) which is where the misrepresentation started. Then I posted on my Blog (Elmira Advocate) on September 13, 14 and 16, 2024 condemning Alan Deal's words and falsehoods . My posts are still on line and as well Woolwich Council and TRAC were made aware of Alan Deal's comments in which he used the 1% rule (of thumb) relative to AQUEOUS SOLUBILTY instead of relative to Effective Solubilities which can literally be ten, a hundred or a thousand times lower than Aqueous Solubilities which refer to dissolving for example chlorobenzene in a container of clean, pure water versus the trashy groundwater under Uniroyal/Lanxess that can easily have a hundred different contaminants mixed in it. Effective Solubility is real world solubilities not laboratory solubilities.
Before I quote Alan Deal's dumb remarks at the September TRAC meeting let me give you a touch of DNAPL history. Yours truly can take credit for introducing the 1% Solubility rule to UPAC (Uniroyal Public Advisory Committee) way, way back in the day i.e. early 90s. Brian Beatty was the groundwater consultant (Morrison & Beatty) for Uniroyal at the time. Mr. Beatty introduced the 10% Solubility rule to UPAC and had the nerve and brass ba**s to quote a well known hydrogeologist by the name of Stan Feenstra. As this was before the Internet was well established (with me at least and maybe everybody) I went up to my alma mater and dug into the Arts Library where I found Mr. Feenstra's original document. Mr. Beatty had quoted him out of context in which he was referring to the past 10% Solubility Rule being replaced by the now current 1% Solubility Rule. I talked to Mr. Feenstra on the phone and he agreed to send me a letter criticizing the misrepresentation by Mr. Beatty. I gave this letter to all parties and David Ash of Uniroyal ended up "consolidating" Mr. Beatty whom we thankfully never saw again. Many more from CRA/GHD need to follow Mr. Beatty's walk.
Here are Alan Deal's exact words from the September 12/24 TRAC meeting :
"IF YOU DETECT CHLOROBENZENE AT A CONCENTRATION THAT'S AT OR GREATER THAN 1% OF ITS' AQUEOUS SOLUBILITY, SO SOMETHING AROUND 5,000 MICROGRAMS PER LITRE, THEN THAT COULD INDICATE THAT THERE IS DNAPL UPGRADIENT OF THAT MONITORING WELL."
"SO IT'S MAYBE NOT A RED FLAG BUT A YELLOW FLAG THAT... THIS IS SOMETHING THAT YOU ARE DOING YOUR EVALUATION YOU DO HAVE TO KEEP IN MIND."
I have been aware of the difference between Aqueous and Effective Solubilities for decades. At one point years ago Jaimie Connolly, MOE/MECP hydrogeologist, actually did a calculation for CPAC comparing the vast numerical differences between Effective Solubility in Uniroyal's groundwater versus the various chemical contaminants Aqueous (Lab) Solubilities. Obviously GHD, Lanxess and the MECP in their decades old quest to coverup DNAPL presence both on and off site have ignored Effective Solubilities at every opportunity and continue to do so. That local politicians allow, permit and support this misconduct/corruption speaks to their integrity.
Alan Marshall (still too blunt, accurate and honest to sit at the table with the rest of the deferential sheep )
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