Aberjona Study Coalition, Inc.                          


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      To the Aberjona Study Coalition,  Inc

August 2017
Comments to the Proposed Plan for the SWP of the G&H wells Superfund site:

We write to provide thoughts and comments on the Proposed Plan (Plan) for the cleanup of soil, groundwater, non-aqueous phase liquid (NAPL), and wetland sediment/soil contamination within the Southwest Properties (SWP) at the Wells G&H Superfund Site.  The comments are based on a review of the July 2017 Plan, the November 2016 Remedial Investigation (RI), the December 2016 Feasibility Study (FS), and on information presented by EPA and members of the public at the August 3, 2017 Formal Public Hearing held at City Hall in Woburn. The ASC comments were prepared with the assistance of our technical advisors CDM Smith and Mr. Richard Lester a sub-contractor to CDM Smith.

General Comments

Of primary importance with respect to the cleanup of the SWP are two questions.  First, will the proposed Plan work?  And secondly, will the result be a site that will be safe for both current and anticipated future uses of the properties?  After reviewing the RI, FS, and Plan, we believe that overall, the Plan is implementable and with the proposed institutional controls, will result in properties that are safe for current and future uses of the properties.  We do, however, have several comments regarding specific aspects of the Plan as outlined below.

Impacts on Business Operations

A remedy such as that proposed for the SWP necessarily will involve some disruption of business operations currently taking place on the properties.  What level of disruption is anticipated for businesses operating at these properties?  Owners of the properties are involved in negotiations with EPA regarding the Plan and will be familiar with the schedule for implementation of the Plan, but tenants of the properties may not be as well informed.  Measures should be taken to accommodate such tenants during the cleanup.  Tenants of these properties should be given as much notice as possible regarding activities that could disrupt business operations, especially if such activities will have a major impact on business operations.

Vapor Intrusion

The potential for vapor intrusion is addressed in the Plan through the use of institutional controls.  These controls will require evaluation of the vapor intrusion pathway if any change in usage of the existing commercial buildings is contemplated, or if any new buildings or additions to existing buildings are constructed on the SWP.  The proposed Plan estimates that groundwater will achieve cleanup levels in approximately 20 years.  Many changes can occur over the course of 20 years.  While the institutional controls will remain in place, a review of potential vapor intrusion issues should be specifically required as part of the Five-Year Reviews to assess protectiveness of the Plan.

Institutional Controls

Given that institutional controls are a key part of the Plan, specific deed restrictions and institutional controls should be detailed and the public should be informed of these controls to ensure that public health will be protected.

Additionally, the proposed plan includes institutional controls on groundwater.  The Massachusetts Contingency Plan specifies that groundwater aquifers are considered state resources and that institutional controls cannot be placed on groundwater unless the State designates these groundwater areas as inappropriate for the uses that pose risk in the human health risk characterization.

Preliminary Remediation Goals

Health-based preliminary remediation goals (PRGs) discussed in both the Feasibility Study and the Plan are generally based on an incremental lifetime cancer risk (ILCR) of 10-6 and a hazard index of 1.  An ILCR of 10-6 on a chemical-by-chemical basis is protective and will likely result in a total lifetime cancer risk that is both within the Superfund risk range (10-6 to 10-4) and less than the Massachusetts Contingency Plan guideline of 10-5.  An exception is made for arsenic for which the ILCR is set at 10-5.  Given background levels of arsenic in the environment and other chemical-specific considerations, the proposed PRGs for arsenic are within reason.  For non-carcinogens, why is a hazard index of 1 used to develop PRGs?  Using a target hazard index of 1 for each chemical leaves open the possibility that the cumulative hazard index across all chemicals could be greater than 1.  It is true that not all chemicals affect the body in the same way, but without consideration of target organs affected by each chemical, would it not be possible for risks to exceed state and Superfund guidelines?

Traffic Impacts

The Plan indicates that approximately 1,600 to 2,500 truckloads will be transported off-site in addition to other vehicles for construction activities.  The Plan includes provisions to control noise impacts through noise dampening equipment or limiting operating hours.  The Plan also states that EPA will work with town officials to determine the best routes to and from the SWP.  Best Management Practices should also be implemented to ensure trucks do not track soils and sediments from the property onto nearby roads and properties, especially for vehicles operating off of paved areas at the site.

Wetland Impacts

The preferred alternative for the cleanup of wetland sediment and soil involves the excavation of approximately 7,000 cubic yards of wetland sediment and soil from approximately 63,000 square feet of wetland area (slightly less than 1.5 acres).  EPA notes that the Clean Water Act and Executive Order regarding Protection of Wetlands require a determination that there is no practicable alternative to conducting the work that will impact wetlands.

Because maximum concentrations of petroleum hydrocarbons, PCBs, and lead in wetland sediments and soil exceed preliminary human health remediation goals by a significant margin (more than an order of magnitude for PCBs and lead) and concentrations metals exceed ecological criteria, we concur with the determination that conducting remedial work in the wetland is necessary.

The selected alternative includes pre-design investigation to refine the vertical and horizontal extend of wetland sediment and soil exceeding cleanup levels.  ASC would appreciate the opportunity to review and comment on the findings of these investigations as well as any changes to the proposed plan that significantly affect the areal extent of the work to be conducted in the wetlands.

Long term monitoring

The proposed approaches to address contaminated soil, non-aqueous phase liquid (NAPL), and groundwater on the SWP all include long-term monitoring of environmental media to evaluate the effectiveness of the remedy.  It is not clear what long-term monitoring is proposed to evaluate the effectiveness of the soil remedy.

For groundwater, the FS indicates that 59 monitoring wells and 14 extraction wells will be sampled, with 50% of the wells being sampled each year.  Monitoring will include target chemicals of concern, degradation byproducts, metals, and general physical and chemical parameters.

All aspects of the proposed long-term monitoring should be clearly detailed in the remedial design, including what actions will be taken if monitoring reveals that remediation goals are not being met.

Floodplain Impacts

EPA has requested comment on floodplain impacts.  Flooding has been an issue along the Aberjona River.  Strong efforts should be made to minimize temporary impacts of construction on the floodplain.  In the long term, as long as there is no net loss of flood storage capacity (as proposed) and efforts are taken to minimize temporary impacts, the proposed plan is acceptable.

Proposed Draft Determination:  PCB Cleanup Level

The Plan proposes a soil cleanup standard for polychlorinated PCBs of 5.3 mg/kg for recreational exposure to soil.  Soil contaminated with PCBs at concentrations greater than 1 mg/kg but less than 5.3 mg/kg would be addressed with the use of institutional controls preventing residential redevelopment.  EPA asked specifically for comment on this cleanup level.

The Massachusetts Contingency Plan provides a Method 1 standard (cleanup level) of 1 mg/kg for PCBs in soil that is easily accessible (category S-1 soil).  The MCP specifies a Method 1 standard of 4 mg/kg for potentially accessible soil.  As has been done for the Wells G&H site, site specific calculations can result in calculation of other cleanup levels based on site-specific conditions.  Site-specific calculations of health risks based on recreational exposure to soil indicate that risks will be within generally recognized guidelines at a cleanup level of 5.3 mg/kg.  As proposed in the Plan, institutional controls should be implemented for properties containing PCBs in soil above a concentration of 1 mg/kg to ensure that no future residences are constructed in areas containing residual levels of PCB contamination above 1 mg/kg.

We look forward to working with you in the future on this important environmental project.

July 2017
The EPA issued a request for comments during a public info meeting held on July 13, 2017 on the proposed clean-up plan for the G & H Wells Superfund site. Comments are due on or before August 14, 2017. A copy of the plan and comment instructions can be found on the G & H Wells Superfund Website; https://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0100749 scroll down to the report.

July 2017
On July 13, 2017 a ribbon cutting ceremony was held at the new Aberjona Nature Trail site adjacent to the Woburn Rifle Club on Salem Street.

January 2017
On January 12, 2017 the EPA awarded an extension to ASC. The new agreement will run through May 2020.

December 2016
On December 31, 2016 ASC will apply for an extension to the grants issued by the U.S. Environmental Protection Agency has granted the Aberjona Study Coalition, Inc. (ASC) an extension through May 31, 2020. To date the grants total $150,000.
At this point in time the EPA is completing the surface water cleanup on the Industri-Plex site. Over next few years the EPA will establish a similar plan for the Wells G&H site. ASC will expected to comment on the plans

August 2016

Recently the Aberjona Study Coalition (ASC) along with their environmental technical advisers from CDM Smith were invited to visit and to observe remedy implementation at the Industri-plex Superfund Site.We very much appreciated the opportunity to see the current status of the remedy and to interact with EPA Project Manager, Joe LeMay at the site.During the site visit we observed contractors implementing the various components of the clean-up and restoration, and judging from what we observed, progressing well in the effort.  The coffer dam structures have been installed in the Halls Brook Holding Area, which is being prepared to treat contaminated groundwater discharge.  Dredging/removal of contaminated sediments are underway in the lower portion (the secondary treatment cell).  These materials are by nature wet, and we did not observe any dust in the staging area where the sediments are loaded into trucks for off-site disposal.  Two encouraging signs were (1) the number of birds already utilizing the reconfigured Halls Brook Holding Area and (2) the amount of debris removal that EPA has removed from the wetland area adjacent to the Mass Rifle Association.  Once finished, we expect the remedy will provide a functional resource that will greatly diminish the level of contaminants flowing through the Aberjona River watershed while simultaneously providing an improved naturalized area for passive recreation activities including walking and bird watching.Joe LeMay provided information that addressed our concern over wetlands compensation.  Because the Halls Brook Holding Area is being used as part of the remedial solution, new wetlands were required to replace it.  Technically, the replacement area needed to be as large as the area taken, but this requirement was modified to allow for improvement and restoration of some existing wetland areas.  This approach was not adequately explained in the draft 100% Design Report, but per Mr. LeMay’s explanation, should be improved in the final report.  If some portion of the treatment cell continues to be used by birds, the overall improvement will be even greater.The upcoming dredging in the Cranberry Bog area will be more noticeable to the public (specifically nearby residents), but that efforts have and will be undertaken to provide notification and information.  Once the remedy is completely in place, environmental monitoring will be a key component, both in the short-term (to ensure that the system is working) and long-term (to check that it continues to work).Overall, we think the remediation is a great success story, and will be a big step forward for Woburn and communities downstream on the Aberjona River.

April, 2016
ASC Received and will comment on the Remedial Design Report part 2. This report is one of the last reports prior to the start of construction which is expected to be completed by the end of 2016.

ASC Members: Former Ward 6 Alderman Mike Raymond, Linda Raymond, Former Alderman Ward 6 John Ciriello, EPA Project Manager Joe LeMay, Steve Zemba of CDM Smith

Walking the Aberjona Nature Trail. 

Proposed G&H Well Superfund clean up area

Halls Brook sediment removal behind the Cofferdam

Steve Zemba CDM Smith,  Donna Robbins ASC,Rich Lester CDM Smith, Linda Raymond ASC and Kathy Barry ASC tour the Idustri-Plex and G&H well site
Mike Raymond ASC and Joe LeMay EPA Project Manager discuss the project schedule during the June site Visit
September, 2014
The EPA has awarded an additional $50,000 Technical Assistance Grant to ASC on the Aberjona River combined study of the Industri-Plex and Woburn G & H Wells Sites.

July, 2013
ASC along with our Technical Assistant Cambridge Environmental, Inc. have responded to the U.S. Environmental Protection Agency with recent comments.  The EPA is in the process of viewing ASC comments.  The EPA will be submitting their response to ASC comments sometime in August 2013.  These comments will be published on this website.

February 12, 2011
EPA Grants Extension to ASC TAG Grant
The U.S. Environmental Protection Agency has granted the Aberjona Study Coalition, Inc. (ASC) a 3 year extension of their original three year $100,000 Double Technical Assistant Grant (TAG) for the Aberjona River Study, which is part of both the Industri-Plex and Wells G & H Superfund Sites in Woburn, Ma.

The Technical Assistant Grant has enabled ASC to hire a Technical Assistant, Cambridge Environmental, Inc. to (1) assist ASC to assimilate the technical information so that they can better afford over 225,000 residents who border the Aberjona River Watershed a comprehensive understanding of the present day risks to human health and the environment the Aberjona River poses from the two Woburn Superfund Sites, and (2) to assure the community that the Aberjona Watershed is and will be safe.

The Board of Directors of the Aberjona Study Coalition, Inc. include the Woburn Neighborhood Association, Inc., Concerned Citizens Network, Friends of the Upper Mystic Lake, Mystic River Watershed Association, Woburn Residents Environmental Network, and Medford Boat Club. 

At this point in time, the EPA is continuing their extensive testing process and is negotiating the final work plan for this project with the Primary Responsible Parties (PRP's).

As milestones are completed, the Aberjona Study Coalition, Inc. (ASC) will announce a public meeting schedule to provide updates and share concerns of the communities involved.

March 2008 
EPA Grants Extension to ASC TAG Grant
The U.S. Environmental
 Protection Agency has granted the Aberjona Study Coaliton, Inc. (ASC) an extension through March 2011 of their original $100,00 Double Technical Assistant Grant (TAG) for the Aberjona River Study, which is part of both the Industri-Plex and Wells G & H Superfund Sites in Woburn, MA.

At this point in time the EPA has issued their Record of Decision (ROD).  The ROD presents the selected remedial action for both the Industri-Plex and Wells G & H Superfund Sites.  The next stip in the process will be to develoop a detailed remediation plan.  In the near future the Aberjona Study Coalition, Inc. will announce a public meeting schedule to provide updates and share concerns of the communities involved.

June 16, 2003 
EPA Awards Grant to Woburn Community Group
Boston- The U.S. environmental Protection Agency announced that it has awarded a $100,000 Technical Assistanct Grant (TAG) for the Aberjona Study which is part of both the IndustriPlex and Wells G & H Superfund sites in Woburn, MA.  When Congress wrote the Superfund law, they wisely included a provision that provides financial resources for citizens to participate in the many deciions affecting their communities, " said Robert W. Varney. "I look forward to the opprtunity tow ork with the Aberjona Study Coalition in these final years of cleanup of these two sites."

The Aberjona Study Coaliton, Inc. is pleased to have been awarded the EPA Technical Assistance Grant, said Linda Raymond, treasurer of the Aberjona River Coaliton, Inc. "A technical Assistant will assist us in assimilating the technical information so that we can better affort the 225,000 residents who border the Aberjona River Watershed a comprehensive understanding of the present day risks to human health and the environment the Aberjona River poses from the two Woburn superfund sites."

The Aberjona watershed incldes the communities of Arlington, Medford, Reading, Stoneham, Wilmington, Winchester, and Woburn.  Represented on the Board of Directors of Aberjona River Study Coalition, Inc. are the Woburn Neighborhood Association, Inc.l, Mystic River Watershed Association, Woburn Residents Environmental Network, Medford Boat Club,
Friends of the Upper Mystic Lake, and Concerned Citizens Network.

Recognizing the importance of community involvement and the need for citizens living near Superfund sites to be well informed, Technical Assistance Grants provide funds for qualified citizen's groups to hire independent technical advisors.

The Aberjona Study Coalition, Inc. plans to use a consultant to interpret data and reports on the upcoming remedial investigation, feasibility study, cleanup decisions, and any other reports and documents that are generated about these two sites.  The group also plans to keep residents of these communities informed by newslettyers, meetings and Internet website of activities, decisions and outcomes at these two sites.

EPA has recently released a draft baseline human health risk assessment for the Aberjona River study area.  The study looks at potential risks to members of the public who come into contact with the sediment, soils, or surface water, or consume fish within the study area.

 Aberjona Study Coalition, Inc.
10 North Maple Street
Woburn, MA  01801

contact Linda Raymond - 781-935-2438

or by email fitwalker1@aol.com

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