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us who had been involved were somewhat surprised by your comment that the effort proposed for the summer, subsequently withdrawn, was only to have been a “temporary” solution, and that the Phase II plan would subsequently propose a permanent solution.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
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
508-359-4474
cc:
