Analysis of Medfield State Hospital clean up by Bill Massaro


Bill Massaro has become the town’s de facto expert on the environmental clean up at the Medfield State Hospital, and below are his 10/1/09 thoughtful comments in response to DCAM’s 9/15/09 PIP meeting.  That PIP meeting was focused exclusively on the C & D site along the Charles River.  However, at that meeting DCAM promised that they would initiate soon a meeting that will address all the environmental issues at the Medfield State Hospital site in a comprehensive manner.  That planned future meeting is the one to attend if you are interested in the Medfield State Hospital project’s environmental clean up issues. ===========================================

Mr. John M. O’Donnell, Deputy Director                                                                 October 1, 2009

Massachusetts Division of Capital Asset Management                                              Page 1 of 3

One Ashburton Place, 15th Floor

Boston, MA 02108

RE:  Draft Public Involvement Plan MSH C&D Fill Area

Release Tracking Number 2-3025561

Dear Mr. O’Donnell,

This letter is written in response to your request for comments/questions/concerns regarding the subject Draft PIP Plan presented by you and Mr. Okun to Medfield Town Administration, representatives of the Town Board of Health and Conservation Commission, and concerned residents on September 15.

I would first like to thank you for your patience and for your explanation of the PIP procedure to those of us who were new to either the process and/or were not a part of the discussions and tour this past July and August at the C&D disposal site.

I would like, however, to say that those of us who had been involved were somewhat surprised by your comment that the effort proposed for the summer, subsequently withdrawn, was only to have been a “temporary” solution, and that the Phase II plan would subsequently propose a permanent solution.  In my review of documentation and notes, as well as in discussions with other attendees from the MSH on-site meeting, we believe that the limited pull-back of contaminated material from the Charles and proposed covering with 12” of loam had never been presented to us as “temporary”.

Also, at that meeting, you had asked for any information that might be available from a prior PIP on Leaking Underground Storage Tanks and advised that you had asked the Medfield Library to locate any documentation sent to them as that PIP’s designated Information Repository.  In the event that you have not yet received any response to your inquiry, I have verified that the Library has set out the documentation and correspondence for RTN 2-3020799(including RTN’s 2-3020984 & 2-3021162) and it is available in the main reading room.

Regarding those documents it was interesting to find in my review of them that the Public’s concerns submitted under that prior PIP were very similar to those I have raised in my previous letters to you,  both on those closed RTN’s as well as on the Phase I reports for this current RTN; and I believe they are appropriate and applicable to this draft PIP Plan for 2-3025651 as well:

1.) Contamination Extent and Nature

The extent of contamination for this C&D site was estimated at 27,700 cubic yards

after limited subsurface investigation of the entire MSH property by TRC Environ-

mental in November 2003; and Maguire Associates’ 2005 and 2007 site investigations

were conducted only at the central and eastern portions of the Site.  Actual extent of

the site has yet to be fully defined.

The nature of the contamination has not been fully determined.  The Draft PIP’s

Summary of Completed Studies description of the materials found makes no

mention of the potential asbestos in Test Pit 5, the unknown fibrous-textured tiles

found in TP-10, and no mention of Medical waste possibly evidenced by the

test tube found in TP-1.

October 1, 2009

p. 2 of 3

This same Summary also does not mention the prior study’s Chain of Custody

issue regarding cadmium soil contamination; and it does not address Maguire

Associates’ conditional statement of having tested only for certain chemical

constituents.

Additional test pitting should be planned to more accurately determine the nature

and extent of the contamination with emphasis on identification/clarification of

the potential asbestos, unknown tiles, and test tube findings, with particular attention

given to the Western portion of the Site which adjoins wetlands.  Also, in addition to

re-sampling at the Phase I locations, additional locations should be selected for new

Charles River sediment samples.

2.) Exposure /Toxicity Pathways and Evaluation Criteria

The evaluations used in the Numerical Ranking System (NRS) Scoresheets, both

for the prior LUST PIP and the Phase I reports for this C&D Site, were based on

the usage/occupancy of the entire property at the time the investigations were

performed.  For the earliest of the LSUT PIP incidents this meant: one occupied

building, infrequent visitors, no children, few workmen, less than 99 people within

½ mile and no planned recreation activities.

These same criteria were used in the 2-3025651 Maguire Associates report’s rankings

in 2007.  This report also went on to state that current water usage in the area of the

Hospital was used in determining sensitive receptor impact on the Medium Yield Aquifer

and Town Well #6.  In spite of your assurances at the 9/15 meeting that this is a required

practice, I still find this difficult to accept given that negotiations over the number of

housing units to be placed on the property were well under way with the Town at that

time.

The Draft PIP Plan should include a statement, possibly under “Ongoing Environmental

Studies” (Para. 2.3), confirming that the legislated 440 units, 1000+ residents, 125+children,

their water usage demands, and their planned, hiking, riding, canoeing activities

on the property will be used in generating the subsequent Phase reports and action plans,

rather than its current abandoned condition.

3.) Comprehensive Whole-Site Plan

The following response was given to residents’ comments on the prior 2-3020799 PIP Draft

Plan:   “other concerns expressed by the public are beyond the scope of the MCP and

hence the PIP process…and cannot be addressed as part of the response actions at this site.

However, they will be addressed as part of the development of the site.”

I am concerned that a similar response will be given to comments/concerns on this Draft Plan,

and fear a series of similar canned policy/procedure–type responses for previous RTN’s

evaluated under then-current usage and “closed” expediently, economically, or temporarily.

For example, will new paved lot run-off be a factor in evaluating any proposed solution for the

C&D site, or are  the residents parking lots  outside of the current PIP process?

October 1, 2009

p. 3 of 3

This seeming fragmentation of the extensive contamination issues at MSH Property could

not possibly be in the best interests of the State,  the Town, Hospital abutters, and planned

post-development residents.  As stated in previous correspondence, I am encouraged by

your confirmation that you have been tasked to develop the comprehensive plan for the

whole MSH Property, and look forward to its release.

4.) Public Involvement Activities/Comment Opportunities

In my review of the previous PIP I noticed that a section addressed “Documents

To Be Made Available for Public Comment”.  In addition to the Draft PIP Plan, the

list included:  S.O.W. for the Site Assessment Plan (PhaseII); Reports summarizing

the findings of the Phase II Report; Phase III Identification, Evaluation, and Selection

of Comprehensive Remedial response Action Alternatives; The Remedial Response

Implementation Plan (RRIP)-Phase IV; Major plans concerning the Operation and

Maintenance of Response Actions-Phase V; and RAM Workplans and Status Reports.

Will these documents be supplied under this PIP?  Are there additional documents that

will(or will not) be provided?

5.) Miscellaneous

A list of attendees and the minutes of the 9/15 meeting were to be sent to attendees.  Are

they available?

The Maguire Associates Phase I report states that “one CERC-NFRAP site (the MSH

Property) is listed…in November 1980 it was determined that the Property is not on the

NPL”    It is my understanding that the CERCLIS list is  essentially the “superfund”

candidate list, and that the National Priority List is those sites that have been chosen to

receive cleanup funds.  Why was the MSH property originally put on the list; why

was it subsequently removed and put on the No Further Remedial Action Planned list; and

were the evaluation criteria used in that decision adequate and appropriate given the now

planned use of the property?

As stated above, I appreciate your commitment to developing  a comprehensive contamination identification and cleanup plan for the MSH Property. I look forward to the release of the Phase II plan for 2-3025651 as well as your review of any previously “closed “ RTN whose solution might be inappropriate or inadequate given the planned development of the Property.

Sincerely,

William Massaro

36 Evergreen Way

Medfield, MA 02052

wmassaro@comcastr.net

508-359-4474

cc:

Mr. John M. O’Donnell, Deputy Director                                                                 October 1, 2009

Massachusetts Division of Capital Asset Management                                              Page 1 of 3

One Ashburton Place, 15th Floor

Boston, MA 02108

RE:  Draft Public Involvement Plan MSH C&D Fill Area

Release Tracking Number 2-3025561

Dear Mr. O’Donnell,

This letter is written in response to your request for comments/questions/concerns regarding the subject Draft PIP Plan presented by you and Mr. Okun to Medfield Town Administration, representatives of the Town Board of Health and Conservation Commission, and concerned residents on September 15.

I would first like to thank you for your patience and for your explanation of the PIP procedure to those of us who were new to either the process and/or were not a part of the discussions and tour this past July and August at the C&D disposal site.

I would like, however, to say that those of us who had been involved were somewhat surprised by your comment that the effort proposed for the summer, subsequently withdrawn, was only to have been a “temporary” solution, and that the Phase II plan would subsequently propose a permanent solution.  In my review of documentation and notes, as well as in discussions with other attendees from the MSH on-site meeting, we believe that the limited pull-back of contaminated material from the Charles and proposed covering with 12” of loam had never been presented to us as “temporary”.

Also, at that meeting, you had asked for any information that might be available from a prior PIP on Leaking Underground Storage Tanks and advised that you had asked the Medfield Library to locate any documentation sent to them as that PIP’s designated Information Repository.  In the event that you have not yet received any response to your inquiry, I have verified that the Library has set out the documentation and correspondence for RTN 2-3020799(including RTN’s 2-3020984 & 2-3021162) and it is available in the main reading room.

Regarding those documents it was interesting to find in my review of them that the Public’s concerns submitted under that prior PIP were very similar to those I have raised in my previous letters to you,  both on those closed RTN’s as well as on the Phase I reports for this current RTN; and I believe they are appropriate and applicable to this draft PIP Plan for 2-3025651 as well:

1.) Contamination Extent and Nature

The extent of contamination for this C&D site was estimated at 27,700 cubic yards

after limited subsurface investigation of the entire MSH property by TRC Environ-

mental in November 2003; and Maguire Associates’ 2005 and 2007 site investigations

were conducted only at the central and eastern portions of the Site.  Actual extent of

the site has yet to be fully defined.

The nature of the contamination has not been fully determined.  The Draft PIP’s

Summary of Completed Studies description of the materials found makes no

mention of the potential asbestos in Test Pit 5, the unknown fibrous-textured tiles

found in TP-10, and no mention of Medical waste possibly evidenced by the

test tube found in TP-1.

October 1, 2009

p. 2 of 3

This same Summary also does not mention the prior study’s Chain of Custody

issue regarding cadmium soil contamination; and it does not address Maguire

Associates’ conditional statement of having tested only for certain chemical

constituents.

Additional test pitting should be planned to more accurately determine the nature

and extent of the contamination with emphasis on identification/clarification of

the potential asbestos, unknown tiles, and test tube findings, with particular attention

given to the Western portion of the Site which adjoins wetlands.  Also, in addition to

re-sampling at the Phase I locations, additional locations should be selected for new

Charles River sediment samples.

2.) Exposure /Toxicity Pathways and Evaluation Criteria

The evaluations used in the Numerical Ranking System (NRS) Scoresheets, both

for the prior LUST PIP and the Phase I reports for this C&D Site, were based on

the usage/occupancy of the entire property at the time the investigations were

performed.  For the earliest of the LSUT PIP incidents this meant: one occupied

building, infrequent visitors, no children, few workmen, less than 99 people within

½ mile and no planned recreation activities.

These same criteria were used in the 2-3025651 Maguire Associates report’s rankings

in 2007.  This report also went on to state that current water usage in the area of the

Hospital was used in determining sensitive receptor impact on the Medium Yield Aquifer

and Town Well #6.  In spite of your assurances at the 9/15 meeting that this is a required

practice, I still find this difficult to accept given that negotiations over the number of

housing units to be placed on the property were well under way with the Town at that

time.

The Draft PIP Plan should include a statement, possibly under “Ongoing Environmental

Studies” (Para. 2.3), confirming that the legislated 440 units, 1000+ residents, 125+children,

their water usage demands, and their planned, hiking, riding, canoeing activities

on the property will be used in generating the subsequent Phase reports and action plans,

rather than its current abandoned condition.

3.) Comprehensive Whole-Site Plan

The following response was given to residents’ comments on the prior 2-3020799 PIP Draft

Plan:   “other concerns expressed by the public are beyond the scope of the MCP and

hence the PIP process…and cannot be addressed as part of the response actions at this site.

However, they will be addressed as part of the development of the site.”

I am concerned that a similar response will be given to comments/concerns on this Draft Plan,

and fear a series of similar canned policy/procedure–type responses for previous RTN’s

evaluated under then-current usage and “closed” expediently, economically, or temporarily.

For example, will new paved lot run-off be a factor in evaluating any proposed solution for the

C&D site, or are  the residents parking lots  outside of the current PIP process?

October 1, 2009

p. 3 of 3

This seeming fragmentation of the extensive contamination issues at MSH Property could

not possibly be in the best interests of the State,  the Town, Hospital abutters, and planned

post-development residents.  As stated in previous correspondence, I am encouraged by

your confirmation that you have been tasked to develop the comprehensive plan for the

whole MSH Property, and look forward to its release.

4.) Public Involvement Activities/Comment Opportunities

In my review of the previous PIP I noticed that a section addressed “Documents

To Be Made Available for Public Comment”.  In addition to the Draft PIP Plan, the

list included:  S.O.W. for the Site Assessment Plan (PhaseII); Reports summarizing

the findings of the Phase II Report; Phase III Identification, Evaluation, and Selection

of Comprehensive Remedial response Action Alternatives; The Remedial Response

Implementation Plan (RRIP)-Phase IV; Major plans concerning the Operation and

Maintenance of Response Actions-Phase V; and RAM Workplans and Status Reports.

Will these documents be supplied under this PIP?  Are there additional documents that

will(or will not) be provided?

5.) Miscellaneous

A list of attendees and the minutes of the 9/15 meeting were to be sent to attendees.  Are

they available?

The Maguire Associates Phase I report states that “one CERC-NFRAP site (the MSH

Property) is listed…in November 1980 it was determined that the Property is not on the

NPL”    It is my understanding that the CERCLIS list is  essentially the “superfund”

candidate list, and that the National Priority List is those sites that have been chosen to

receive cleanup funds.  Why was the MSH property originally put on the list; why

was it subsequently removed and put on the No Further Remedial Action Planned list; and

were the evaluation criteria used in that decision adequate and appropriate given the now

planned use of the property?

As stated above, I appreciate your commitment to developing  a comprehensive contamination identification and cleanup plan for the MSH Property. I look forward to the release of the Phase II plan for 2-3025651 as well as your review of any previously “closed “ RTN whose solution might be inappropriate or inadequate given the planned development of the Property.

Sincerely,

William Massaro

36 Evergreen Way

Medfield, MA 02052

wmassaro@comcastr.net

508-359-4474

cc:

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