Medfield’s State Hospital Environmental Review Committee (SHERC) put together the following list of questions for DCAM for the 7 PM continued technical issues meeting this Thursday at the Town House.
As requested by DCAM during the January 12, 2012 technical meeting at Medfield Town Hall, we are providing in advance of the January 19, 2012 meeting a list of requests and topics for discussion for this second meeting. Please note that there may be additional items not specified below.
We would like to discuss further issues related to the following items in the Comment Letter handed out last Thursday’s meeting containing the Town Questions and DCAM Responses to the Draft Phase II and III documents:
2, 7, 9, 10, 14,15,16,17,18,19,27,28,29,32,35,36,37,39,41,44,45,46,48,89
In addition, or in some cases more specifically, we would like to discuss the following:
1. Scheduling/Communication: The Town needs a list of PIP meeting dates for February, the dates that the reports will be made available to review, dates due and anticipated dates of any other relevant project milestones including planned field work, report generation and similar. When will we receive the next Draft Phase III for example? We would expect that DCAM would first obtain and digest new data from the proposed sampling locations before the Phase III would be presented so that the SPD Site can be addressed holistically.
We need a Communication Plan that includes more than simply distributing copies of handouts, agendas and report. Lead time should be provided to the Community as to what is planned for a meeting and the material to be presented given to the Community a reasonable amount of time in advance to allow them to at least see what is coming up at a meeting.
2. Communication: We request that future reports and handouts, including meeting agendas be produced a week in advance of the PIP public meeting so that the Town has a chance to review and present reasonable questions on the documents; this would be a better use of meeting time for DCAM and its consultants, as well as the Town’s.
3. Complete Plan: For our meeting on January 19, 2012, please provide ONE complete accurate site map showing ALL exploration locations and sampling points for all media (sediment, soil, groundwater, surface water, pore water etc.) collected in the past to the current time, the explorations proposed in the future, and showing the drains and other utilities. This will likely need to be 24” by 36” in size.
4. Plan: Please include on the plan the proposed 0.5 to 3 foot sample locations proposed for the C&D Area and Power Plan Area. Why is the 0 to 0.5 interval not being sampled for analysis? This is the most accessible of the soils. Also, ash fill below 3 feet also needs to be tested and characterized and incorporated into the Risk Assessment. We believe that accessible soils throughout the power plant should be assessed.
Also please show proposed locations for the piezometers along the shoreline that will have passive diffusive samplers to evaluate PCE in groundwater below the river. The proposed Monitoring Well Locations Plan did not show these sample locations. We believe there should be sampling at the edge of the C&D nearest Town Well 6.
5. C&D Groundwater Testing: Given periodic exceedances of GW-1 metals concentrations in groundwater from four wells in the C&D area, why were these wells not analyzed during the quarterly sampling program for metals in September and December 2011 sampling rounds? We expect all COCs to be included in the monitoring program.
6. Dioxins/furans: We would like to further discuss dioxin/furan testing. Unless DCAM can provide documentation demonstrating that all trash was transported of site for disposal/incineration, it should only be “presumed” that, as stated by the Hospital Assistant Superintendent, disposal and incineration did occur on-site.
7. Radiological: Have any radiological surveys been conducted of the C&D? The hospital, particularly the Clark Building, had x-ray equipment.
Does DCAM have records of removal, transport, disposition of this equipment?
8. Medical Waste: A Boston Globe Article dated November18, 1980 reported that DEQE had included 12 impoundments of medical/surgical waste at Medfield State Hospital on a list of Massachusetts sites deserving further investigation and classification. Subsequent statements from the former assistant Superintendent of the Hospital further supported the historic use of the C&D area as a medical waste disposal site. The Draft Phase II CSA/SPD Annual Report contains no information regarding either the presence or absence of medical waste.
Was there any screening for pathogens?
9. Remediation: Remedial approaches should not be decided until all the data identifying nature and extent, receptors, exposure pathways, etc. are collected.
The Town has advised DCAM that it prefers removal of all of the waste from the Zone II and maximization of removal from the potentially productive aquifer and gas line easement. Please confirm that the requested options are being evaluated and that they will be included in the Phase III Remedial Evaluation.
Preliminary Risk Assessment Questions (and Others)
10. Exposure Parameters for HHRA: Site-specific exposure parameters should be incorporated into the risk assessment – not added as a supplemental addendum. MA DEP default parameters do not reflect frequency of the use of this area. Not all future uses are accounted for (e.g. boat launch, residential units, appropriate age groups for useage i.e. child ≠ youth for exposure).
11. CVOC Plume: Stormwater/Groundwater discharging into the river need to be evaluated, as does sediment in the river for CVOCs.
12. Nature and Extent of Petroleum Contaminated Sediment: We Request that ALL field logs and photos for all sediment sampling locations be compiled and distributed.
13. Pipes, Outfalls, Seeps: These need to be integrated and mapped. Transport through the pipe, along the preferred pathway around the pipe and via seeps address three different transport pathways.
14. Sediment Data:
Why were data not collected for CD-SD-123 and -124? What is their purpose?
15. Work Plan information: Technical, concepts, methods etc. noted in work plans should be present in the reports (e.g. analytical methods, exclusion of ecological receptors). If field staff and labs need to know the information then it is important enough to be included in the final reports.
16. Eco exposure parameters: Not all habitat within the C&D area is equally attractive to receptors, and for receptors with small home ranges, impacts could be greater.
17. Collocated Soil and Terrestrial Invertebrates: Provide a figure that shows collocated soil and invertebrates locations. This request is independent of what the science may say about the probability of meaningful concentration correlations; the spatial correlation is useful for the reader.
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