Millions Spent Year after Year On WR Grace Victims? Well at Least on Paperwork.

Flat Out Lies, Fraud and Cover Ups. The State of Montana is in bed with WR Grace, has been for Decades and as Politics Gets Millions on Top of Millions, the WR Grace Victims and Families Get Suffering, Prolonged Painful Death... and No End in Site to the Justice of the WR Grace Victims.

Letter from ARI TECHNOLOGIES INC. - Dale M. Timmons on thermochemical conversion technology - utter complete inaccuracy -

"November 16, 2010

Ms. Carol Campbell

Assistant Regional Administrator

USEPA REGION 8

1595 Wynkoop St.

Mail Code: 8EPR

Denver, CO 80202-1129

Subject: LIBBY ASBESTOS SUPERFUND SITE ROD, OU’S 1&2

Dear Ms. Campbell:

I read with interest and then shock the above-mentioned Records of Decision. Because

the technology developed by my company is prominently mentioned in the RODs and

because the information provided is wholly incorrect, it is appropriate to reiterate the

inaccurate statements, make appropriate inquiries and for EPA to provide a detailed

response to this letter.

The information provided in the RODs that address thermochemical conversion would

imply that EPA actually conducted an evaluation of the technology as part of an effort to

identify a cleanup alternative that is protective of human health and the environment and

to protect citizens of Libby, Montana. However, this is not the case.

In reference to thermochemical conversion, the RODs state as a basis for rejecting further

consideration of the technology:

1. The technology has “higher relative cost”,

2. The technology is “relatively new”,

3. There is a “lack of irreversibility data”,

4. “Because the wastes must be shipped to an off-site treatment facility in another state,

treated, and then shipped back to the site for disposal, transportation costs are also

disproportionately high”,

5. The process uses “hydrofluoric acid” as a reagent for the process.

Corporate Office

1221 – 2nd Ave. N.

Kent, WA 98032

425-391-0437

www.aritechnologies.com

November 15, 2010

These statements are utterly and completely false. And EPA has absolutely no basis

upon which to make them. Here is why:

A. EPA cannot know the cost of thermochemical conversion technology because

ARI Technologies was never contacted by EPA or the Montana DEQ to find out

anything about the technology.

In fact, my personal attempts to provide the EPA

with technical briefings and cost information were rejected by EPA Region 8 and

EPA Region 3.

B. This technology was awarded a National Operating Permit by EPA Headquarters

in 1997. This was thirteen years ago. The technology has been repeatedly

demonstrated many times since. Exactly what is the definition of “relatively new”

and how is it used to protect the citizens of Libby, Montana?

C. The treated products produced by thermochemical conversion technology are

chemically and physically identical to igneous rocks. Any competent geologist

knows that materials of this composition do not spontaneously turn into asbestos.

Formation of asbestos requires hydrated high temperature, high pressure

conditions and a few million years of deep (several kilometers) burial. It is

impossible for materials possessing volcanic rock compositions to spontaneously

turn into asbestos under atmospheric conditions. The statement regarding

irreversibility in the ROD demonstrates a supreme lack of understanding of

geochemical processes.

D. ARI’s web site prominently displays the on-site treatment capabilities of this

technology. ARI conducted its 90-day permitting treatment requirements using a

transportable system on site under the supervision of EPA. I personally made a

formal, well-publicized presentation in March 2009 to a group of approximately

250 stakeholders of which 14 individuals just happened to represent EPA

including EPA’s legal counsel. The subject of this presentation was on-site

thermochemical conversion of asbestos waste.

The section in the ROD stating that there is a requirement for transport of the waste clearly demonstrates that EPA’s level of evaluation of this technology did not include even a causal glance at ARI’s web site or any internal communication whatsoever.

E. ARI’s thermochemical conversion process does not use, never has used and never

will use hydrofluoric acid in any way. Exactly where did EPA come up with this

belief?

After reviewing the above-mentioned RODs, I have no alternative but to draw the

conclusion that the information provided on our technology was simply made up by the

EPA.

I have read many RI/FS and ROD documents in my career.

I have to say that, with respect to the information contained on thermochemical conversion technology, I have never read a document that is more completely false and inaccurate than the abovereferenced RODs.

I would be very interested in receiving an explanation regarding how millions of tax dollars can be spent on a Record of Decision, the contents of which appear

to be the product of creative writing instead of diligent, well thought out technical

evaluations.

The utter complete inaccuracy of the information discussed herein calls into

serious question all other information contained in the documents and the associated

conclusions.

EPA has been tasked by the President to protect human health and the environment and

SARA established a preference for treating waste rather than covering it up.

The contents of these RODs clearly show that an objective evaluation was not conducted.

Rather, what was believed to be the cheapest option was obviously chosen early in the

process and the justification for eliminating other options was then invented.

I look forward to your response.

Sincerely,

ARI TECHNOLOGIES INC.

Dale M. Timmons, R.G.

Principal

c.c., Richard Opper, Montana DEQ

Brian D. Schweitzer, Governor, Montana

Max Baucus, U.S. Senator "

Posted here by
Crystal L. Cox

Investive Blogger

Got a Tip Exposing Montana Politicians, WR Grace, the EPA or ??? on the Cover Ups to Protect the Horrific Crimes and Deadly Corruption of the WR Grace Company?

Crystal@CrystalCox.com