This draft letter was prepared by the town’s consultant, Andrea Stiller, to summarize the results of the site visit conducted last Thursday by DEP at the MSH as a required step in the two pending appeals. The Board of Selectmen will send the letter, as it may get revised, next Tuesday.
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October 17, 2011
The Commonwealth of Massachusetts
Department of Environmental Protection
Central Regional Office
627 Main Street
Worcester, MA 01608
Attention: Mr. Gary Dulmaine, Bureau of Resource Protection, Division of Wetlands and Waterways
Mr. Mark Baldi, BWSC Section Chief, MassDEP Central Regional Office
The Commonwealth of Massachusetts
Division of Capital Asset Management
One Ashburton Place, 15th Floor
Boston, MA 02108
Attention: Mr. Allen Wiggin
RE: Letter of Understanding
Site Inspection Meeting (MGL c 131, Section 40)
For Request for Superseding Order of Conditions
Former Medfield State Hospital Medfield, MA
DEP RTN 2-3020799
Gentlemen:
On October 13, 2011 the Department of Environmental Protection Bureau of Resource Protection, Division of Wetlands and Waterways, held a site inspection and site meeting at the Medfield State Hospital in preparation of the issuance of a Superseding Order of Conditions. In attendance were representatives of DCAM, Weston and Sampson, DEP, Medfield Conservation Commission, State Hospital Review Committee, Medfield Selectmen, Congressman Lynch’s Office, Charles River Watershed Association, Trustees of Reservation, the Medfield State Hospital PIP Group, concerned residents, and others.
Concerns with the Notice of Intent and Immediate Response Action (IRA) Plans for the Charles River, were discussed. Some outcomes of the discussions that we find particularly relevant are summarized below. Thank you for the opportunity to meet and discuss our concerns.
Sincerely,
Mark Fisher
Ann B. Thompson
Osler L. Peterson
Items from the DEP BRP site visit of 10/13/11
1. Given that all necessary approvals have not been granted (Superseding Order of Condition, Army Corp. 404 Permit, others), the plan to remediate the Charles River and C&D Area will not commence this year, but rather in the next construction season. Work within the river and its banks will not occur until the low water season in 2012.
2. The use of a temporary Aquablok cap over the described 800 square feet of the Charles River sediment will not occur at all; in lieu of this, DCAM will apply for a permit from the Corps of Engineers to permanently remove the oily and toxic sediments by vacuum dredging.
3. The existing IRA Plan will be re-filed as an Assessment Only IRA. The DEP deadline for the IRA Plan Modification is October 31, 2011.
4. Recent conversations by various parties with Spectra Energy regarding the feasibility of removing all contaminated soil within the easement for their natural gas transmission line in the C&D area suggest that Spectra is willing to discuss it and provide estimates for work by Spectra’s subcontractor. DCAM will re-explore this option with representatives of Spectra Energy and obtain estimated costs and schedules of removing all of the debris fill in the C&D area easement, including relocation of the line if necessary.
5. Detailed remedial evaluations of alternatives to the previously issued Phase III remediation alternatives evaluation for the SPD Area and the C&D/River Area will be reviewed in detail by DCAM/Weston and Sampson including:
a) Full removal of the C&D debris, including in the gas line easement, and off-site disposal.
b) Full removal of all the C&D Debris to a new designated location on the MSH property (described by DCAM as a very unlikely and requiring an involved permitting process, but this option should be explored regardless; avoiding off-site disposal could significantly reduce the project cost).
c) Removal of all of the contaminated fill in the C&D area throughout the Riverfront Area (not mentioned at the meeting, but something we would like to see reviewed).
d) Other options as appropriate, including those already reviewed by DCAM/W&S, although with more complete descriptions of proposed debris fill removal and costs, and soft bioengineering alternatives to rip rap. In addition to exploring new alternatives, additional explanation of the previously outlined alternatives in the focused Phase III would be helpful; the “Maximum” fill removal option described in the prior focused Phase III Report for the River/C&D areas did not explain from what areas fill would be removed, to what extent, etc.
6. Feasibility of soft bioengineering alternatives for the bank instead of the use of rip rap will be reviewed in detail. This is required by DEP by December 31, 2011.
7. At the October 13, 2011 meeting, Mark Baldi stated that he planned to require a Phase IV Report by the end of June. The Town requests ample time to review any and all phase reports under the PIP process with proper responses to our concerns before remediation can commence.
8. Inquiring as to Brownfields funding and other possible funding sources to perform a more complete cleanup will be sought by DCAM and Congressman Lynch’s Office.
Some comments were made at the site meeting that the current NOI should be retracted and a new one be submitted that more accurately reflects the proposed work. We would like to know whether this going to occur.
Again, thank you for the opportunity to comment on the proposed work
cc: Mr. John O’Donnell, PE, LSP, Deputy Director, DCAM
Mr. Mark Baldi, Section Chief, MassDEP Central Regional Office
Mr. Frank Ricciardi, P.E., LSP, Weston & Sampson
Mr. John Thompson, LSP, SHERC Chairman
Ms. Deborah Bero, Esq., Medfield Conservation Commission, SHERC
Mr. William Domey, PE, Board of Health, SHERC
Mr. Ralph Tella, LSP, SHERC
Mr. Cole Worthy, LSP, SHERC
Ms. Andrea Stiller, LSP, ADS
Town of Medfield Repository, Public Library
