CPAC CANCELLED

Well in my humble opinion Chemtura dodged a bullet last night. That said they dodged it by sheer luck; it's not as if they did anything nefarious or even sneaky to do so. The weather especially around Elmira and area was to say the least unpredictable yesterday. One minute the sun was shining and the next visibility due to high wind and blowing snow was almost nil. Therefore the CPAC Chair Dr. Dan Holt cancelled the meeting. This was especially kind to the out of town attendees but even in town there were problems during the day.

The Woolwich Observer on their Community Information Page carry an ad for this year's Annual Drinking Water Reports . They can be obtained either in hard copy or on-line via the Region of Waterloo website. I've been following them for many years and while they provide interesting information nevertheless there are holes in their so called drinking water protection that you can drive a truck through. More will follow as I spend time reading them over.

CPAC DIVERSITY, VERSATILITY & EXPERIENCE SHINE THROUGH

Well tonite (6 pm.) is the public CPAC meeting and of course DNAPLS will be mentioned by yours truly. The headline refers to one of the CPAC members using their knowledge and experience to produce some incredibly, visually stunning data. I've been of late producing tables of data but this goes so much further. Yesterday's post mentioned five different wells in RPW6 & 7 which have high concentrations as well as lacking any decisive persistent decreasing trend. Today I'm examining the most recent data and what I am seeing is this:

The most outstanding results would be Carboxin, Chlorobenzene and Toluene all in RPW6 as well as Carboxin and Chlorobenzene again this time in RPW7. The specific wells are U+500, OW74-6, U+540, OW10-9 and RPW7-1-8. There are many more results which cast grave doubt on Chemtura/CRA's self serving theories regarding residual DNAPL presence and free phase DNAPL absence.

All of this boils down to money and a lack of accountability built into our so called environmental protection systems. Our politicians are very long on talk and appearance and very short on action and delivery. Polluter pays is nothing but a catchy vote getting phrase for them.

"DNAPL" WELLS AT CHEMTURA IN ELMIRA, ONTARIO

Recently I've been expounding upon the blatant ridiculousness of the position that Chemtura have taken for two decades plus regarding free phase DNAPLS on their site in Elmira. That being said I am trying not to personally attribute that behaviour to the Elmira officials who represent the company at public CPAC meetings. While it is Jeff, Josef and Dwight who are the public spokespersons; all three are employees who must follow the orders coming out of corporate headquarters in Waterbury, Connecticut. My confidence in regards to this flows from the fact that every day from Monday through Friday; Chemtura U.S. (ie. Waterbury) are on this blog/website checking out every word I post. This I know courtesy of a program known as Statcounter.

After carefully checking concentrations of a half dozen DNAPL (dense non aqueous phase liquids) chemicals in the groundwater in Chemtura's south-west corner and former location of their operating ponds (RPW5-8), I can with confidence indicate that the evidence of free phase DNAPL presence is overwhelming.

For example wells OW74-6, U+500 and RPW7-1-8 show that five of six DNAPL chemicals, despite fourteen years of shallow aquifer hydraulic containment, continue to have high concentrations in the groundwater. These concentrations with the exception of Benzothiazole and Aniline generally remain above the 1% solubility benchmark indicating nearby DNAPL. The solubility of Aniline and Benzothiazole are extremely high (ie. millions of parts per billion) hence making even 1% of their labratory solubility an extremely high concentration in groundwater. Indeed Aniline concentrations in groundwater while below 1% solubility nevertheless are routinely between 2,000 and 200,000 parts per billion. Keep in mind all these DNAPL compounds plus many more are all dissolved in essentially the same shallow groundwater.

Extraction wells U+540 and U+560 show that four out of six DNAPL chemicals, despite fourteen years of shallow aquifer hydraulic containment, continue to have high concentrations in the groundwater. Three of those four chemicals also generally remain above the 1% solubility mark. Other wells in the former operating ponds have two and three DNAPL chemicals whose concentrations while rising and falling over time are not consistently decreasing.

This kind of detailed analysis of Chemtura's DNAPLS has never been done by independent, unbiased credentialed experts. That being said there have been a couple of occasions when the Ministry of the Environment have carefully and respectfully put in writing their opposing opinions to Chemtura's DNAPL propaganda. One such important letter was researched and written by Jaimie Connolly of the M.O.E. on April 3,2006. Steve Martindale of the M.O.E. is supposed to bring to CPAC tomorrow night some kind of update on Jaimie's April 2006 opinion. If history is any judge Steve will attempt to downplay Jaimie's very clear and strong written 2006 opinions.

Recently Woolwich Council have suggested that they will provide CPAC with $10,000 towards a professional peer review. Chemtura have recently again been approached unsucessfully for funding of peer reviews of Chemtura's consultants work. This is hardly surprising as the company while ostensibly in favour of public consultation are actually horrified at the thought of either the general public or CPAC being able to confront them on a level playing field. Client driven, well reimbursed consultants are their weapon of first choice against the public interest, in favour of their own.

CHERRY PICKING VERSUS THE WHOLE PICTURE

Often a dishonest informant can pick individual unrepresentative examples to try and prove a falsehood. For example hypothetically a dictatorship murders 50 political opponents and critics per year. The dictatorship is overthrown and after the new democratic government is installed politically motivated murders plummet to four over the course of the next year. A dishonest critic could scream to the heavens that the new government are routinely involved in murdering critics/opponents and yet an honest appraisal would clearly show a cause and effect whereby murders are dramatically reduced. Four murders need to be investigated absolutely but to routinely assign responsibility to the new government as with the old is inaccurate.

In matters scientific or hydrogeologic the expression is cherry picking whereby either a proponent or a critic carefully choose individual samples from a large group and then assign conclusions incorrectly to the whole group based upon a very small sample. Last week I picked three wells with concentrations of MBT over a twenty year period in Chemtura's south-west corner. All three wells showed increases and decreases but very little if any overall downward trend. This was not cherrypicking for two reasons. Firstly I expressly stated that there were numerous wells that did have decreasing trends. Secondly my point is not to assign the results of these three wells to all the others either in the south-west corner or on the whole site. My point was to clearly indicate the different behaviour of these wells to those with decreasing concentration trends.
It is my understanding and belief that downgradient groundwater contaminant concentrations are not homogeneous. Downgradient wells are screened both in different aquifers as well as at different heights within the same aquifers. Furthermore DNAPL chemicals do not automatically sink in their entirety through aquifers and then congregate in one single pool sitting on the surface of the low permeability surface or aquitard. As a result multiple separate groundwater plumes can theoretically result from one DNAPL chemical being released at the surface. Finally in the case of a couple of pools of free phase DNAPL connected by a trail(tail) of residual DNAPL; the residual DNAPL which is simply a tiny quantity of DNAPL within the pore spaces between the grains of sand or gravel will dissolve much faster than the pools of DNAPL. Hence for example a plume from a higher elevation of residual DNAPL will have decreasing concentrations much sooner than a plume emanating from a pool of free phase DNAPL. This is the point which I wished to send in my posting last week. Within the same geographic area such as Retention Pond West 6 (RPW6) one can have wells with decreasing concentration trends over time as well as wells which do not. One can not assign the behaviour of the wells with decreasing trends to all the others by saying "aha there isn't free phase DNAPL present". On the other hand it is legitimate to say that probably there isn't free phase DNAPL up gradient of those wells whereas there probably is free phase DNAPL upgradient of these other wells without decreasing concentration trends.

LINE 9 PIPELINE SPILLS

O.K. I can see this story by W5 being a little controversial. When I read the headline in the Waterloo Region Record "Pipeline spills uncovered, some close to Waterloo Region", I was shocked. Then I read 35 spills in total versus 7 reported to the National Energy Board and 13 reported to W5 by Enbridge. As I got further into the story it seemed almost a huge relief to understand that the difference wasn't exactly spills to the natural environment so much as spills within Enbridge's "facilities". Presumably this would be pumping stations, storage facilities etc..

So exactly how problematic are these numerous spills, some small, some large, within "facilities"? That is a very good question. I personally have worked in a facility that handled large volumes of hazardous liquids. These included fuels, solvents and oils etc.. According to the Enbridge spokesperson all spills are completely captured and cleaned up. Hmm. Where I worked at Varnicolor Chemical in Elmira, Ontario we were subject to a whole raft of provincial rules and regulations surrounding tank farms, containment areas, spill management and on and on. They were all routinely ignored and totally unenforced by the Ontario Ministry of the Environment.

Let's give Enbridge the benefit of the doubt for a moment. Let's assume that their tank farms don't leak. Let's assume that their entire facilty is covered in concrete and is routinely inspected for and cracks repaired. Let's assume that their equipment such as pumps, hoses and tanks are in good repair. Let's assume that they have an adequate supply of absorbent materials and berms. Hopefully they have a portable vacuum truck as well. Hopefully their staff are well trained including regular spill training. Given all of these good things I still am perplexed. Why so many spills at facilities? Where I worked spills were caused by faulty, out of repair equipment, constant new employees without training and low tech or no tech spill alarms on tanks and pumps. Furthermore tank farms leaked and the ground surrounding them wasn't impermeable. Enridge you've got some explaining to do.

MITIGATING FRACKING

Today's Waterloo Region Record has an Editorial that first appeared on Bloomberg News' Bloomberg View. The Record have titled it "Another view: Save water". It talks about ways of saving and recycling the massive quantities of water used in the fracking process whereby water under pressure is injected to break up shale formations and release both oil and gas. The suggestion is that fracking water can and should be used over and over again when possible thus saving on overall water use. The state of Pennsylvania also demands that drillers disclose "...how much water a well will use, from where and what effect that will have on local sources.".

O.K. it's hard to argue against those ideas. Or is it? Even with those improvements are the true full costs of fracking worth the additional value of oil and gas released? Is this just one more case whereby private interests pocket the profits and society and the environment get stuck with the bill for the damages done by fracking?

ALL OTHER THINGS BEING EQUAL : ECONOMICS & HYDROGEOLGY

As in economics, hydrogeology cause and effect is difficult to determine sometimes due to confounding factors. Recently I have been examining concentrations of DNAPL chemicals over time in Chemtura's former operating pond area (south-west). The trends are literally all over the place as the following examples will show.

Shallow Aquifer Pumping Well U+500 Mercaptobenzothiazole (MBT) was 11,000 ppb in 2000 and 12,000 ppb in 2001. Last month (Jan. 2014) the concentration was 14,000 ppb.

Pumping well U+560 MBT was 10,000 ppb in 2001, 4,700 ppb in 2002, 4,350 in 2012 and finally 7,700 ppb in Jan. 2014.

Monitoring well OW74-6 had MBT at 3000 ppb in 1991, 5,900 ppb in 1994, 44,000 ppb in 2000, 8,700 ppb in 2004 and finally 9,700 ppb in 2006.

These wells have all been under the influence of hydraulic containment of the shallow aquifer since 1997. There are indeed many wells in the south-west operating ponds whose concentrations have significantly decreased while others go up and down over many years. Both carboxin and chlorobenzene also are in wells in the operating ponds which have not shown expected decreases due to either dissolution over time or the pump and treat "remediation". I expect that an honest examination by unbiased professionals could most probably determine precisely which wells have nearby sources of free phase DNAPL versus those whose concentrations show a decreasing trend due to the complete dissolution of nearby residual DNAPL. To date we the public have had no such unbiased and honest examination.