|EPA Project Manger, Joe LeMay will be holding a public meeting regarding the recent testing in the area of
Olympia Avenue and Dewey Avenue in East Woburn. EPA has stated that they are being cautious on the fact
that more PCE contaminants have been found in the ground water in that area. EPA has asked for permission
to drill in the basements of the residents in the neighborhood for further testing.
The Public Meeting will be held in City Council Chambers of Woburn City Hall on
Wednesday, January 26, 2011 at 7:00 p.m.
ASC and Cambridge Environmental, Inc. January 26, 2011 Comments on Vapor Intrusion Issues Wells G & H Superfund Site
The Aberjona Study Coalition, Inc. in conjunction with Cambridge Environmental, Inc. write to provide comments
on the vapor intrusion investigations that have been taking place at the Wells G & H Superfund Site in Woburn over the past year. While we are pleased that these issues are being investigated, we are very disappointed
that the Aberjona Study Coalition (ASC) was not invited to or involved in any way in the December 2010
meeting with EPA at City Hall todiscuss groundwater results and vapor intrusion in the Dewey and Olympia Avenues neighborhood. In preparing these comments, we have reviewed the fact sheet for the January 26, 2011 public meeting, the June 1, 2010 Indoor Air Quality and Vapor Intrusion Assessment, and the October 15, 2010 Northeast Quadrant Vapor Intrusion Assesment work update. We have a number of concerns about the
methods used to evaluate vapor intrusion as outlined in the sections that follow.
Unit Risk Value for Tetrachloroethylene
The June 2010 report entitled Indoor Air Quality an Vapor Intrusion Assessment; Report of Results prepared for UniFirst Corporation by The Johnson Company includes results from sub slab and indoor air measurements conducted on the UniFirst property immediately north of the Dewey and Olympia Avenues residential neighborhood. The report includes a preliminary human health risk assessment for the vapor intrusion pathway. The risks assessment estimates increased risks of cancer based on a unit risk value of 5.9 x 10-6 m3/ug for tetracholroethylene (PCE), the unit risk value used to calculate EPA's Regional Screening Levels (RSLs) for
chemical contaminants. The Massachusetts Department of Environmental Protection (DEP) currently recommends a unit risk of 1 x 10-5m3/ug when characterizing the carcinogenic potency of PCE. 1 In 2008, EPA performed a toxicological review of tetrachloroethylene2 (currently an External Review Draft) that recommends a unit risk
of 2 x 10-5 m3/ug as the most public health protective value (amidst a range of 2 x 10-6 m3/ug to 2 x 10-5
1 DEP's documentation of the unit risk for tetrachloroethylene is available at http://www.mass.gov/dep/toxics/stypes/pcerisk.pdf.
2 EPA's toxicological review of tetrachlorolethylene is available at http://oasup.epa.gov/eims/eimscomm.getfile?p_download_id=475838.
While the value used in the UniFirst vapor intrusion risk assessment has previously been recommended by EPA
for use at Superfund sites, it is inconsistent with DEP guidance and is at the low end of the range recommended by EPA's draft toxicological review for PCE. At a minimum, we believe that health risk assessments for the Wells
G & H Site should adopt the DEP unit risk for PCE, and consideration should be given to using the most public health protective value recommended in EPA's draft review. Use of these values would increase human health
risk estimates for PCE by a factor of 1.7 to 3.4 Because PCE contributes a substantial fraction of the total
cancer risk estimates due to vapor intrusion at the UniFirst property, use of these unit risk factors could affect
the conclusions of the risk assessment.
Cancer Risk Limits
The preliminary risk assessment report for the UniFirst property states that volatile organic compounds in air
are not considered to pose a significant risk to human health if the excess lifetime cancer risk is within or below the EPA Superfund target excess lifetime cancer risk range of 1 x 10-6 to 1 x 10-4. For the imminent hazard evaluation, a target excess lifetime cancer risk of 1 x 10-5 was applied. By stating that cancer risks within
the EPA Superfund range are acceptable, the risk assessment is effectively using the upper end of the
Superfund range (1 x 10-4) as the acceptable risk limit.
We strongly recommend the use of a more stringent cancer risk limit when evaluating vapor intrusion issues
in the Dewey and Olympia Avenues neighborhood. DEP recommends a risk limit of 1 x 10-5 for sites evaluated under the Massachusetts Contingency Plan (MCP). Epa has frequently selected more stringent risk limits than
the upper end of the Superfund range at some sites. We suggest using the DEP cancer risk limit of 1 x 10-5 for future evaluations of this pathway.
Massachusetts DEP's Draft Vapor Intrusion Guidance
The Massachusetts DEP has recently published draft vapor intrusion guidance focusing on the evaluation of this pathway at disposal sites in the Commonwealth. This guidance mirrors the Massachusetts Contingency Plan in identifying contaminant migration to the indoor air of a residence as a Critical Exposure Pathway. 3 Critical Exposure Pathways must be eliminated to background conditions to the extent feasible. The vapor intrusion guidance identifies residential indoor air threshold values that indicate when the vapor intrusion pathway is of concern in residential settings. The threshold indoor air concentration for PCE, for example, is 1.4 ug/m3.
These threshold values should be applied to data collected in the Dewey and Olympia Avenues neighborhood.
If indoor air concentrations are identified at levels greater than threshold values, measures should be taken to eliminate the migration of vapors to indoor air. Measures should include elimination of the source in
groundwater to the extent feasible. If elimination of the source is not possible, mitigation should include the installation of passive or active ventilation systems such as sub-slab ventilation systems.
3. The MCP defines a Critical Exposure Pathways as "these routes by which oil and hazardous materials(s) released at a disposal site are transported, or are likely to be transported, to human receptors via (a) vapor-phase emissions of measurable concentrations of oil and hazardous materials (OHMs) into the living or working space of a pre-school, daycare, school or occupied residential dwelling...."
2008 Summary and Comments from ASC on the Surface Monitoring Plan
We write to provide a brief summary of and comments on the Surface Water Monitoring Plan (SWMP) for the Industri-Plex Superfund Site dated May 23, 2008. Understand that ASC primary concerns are ensuring that any remedial activities that take place at the site are both safe and effective. We therefore frame our comments
such that they address two simple questions - (1) Is the proposed approach safe? and (2) Will it work?
The Surface Water Monitoring Plan for the Industri-Plex Superfund Site Operable Unit 2 summarizes the surface water monitoring to be conducted during the design and implementation of the Industri-Plex OU2 remedy. Its stated objectives are to develop data to monitor surface water trends and to demonstrate compliance with standards and guidelines. The monitoring plan will remain in place until long-term monitoring replaces it under
the Final Environmental Monitoring Plan for Industri-Plex OU2, after the completion of remedial activities. The SWMP focuses on total and dissolved arsenic, benzene, and ammonia and generally requires surface water sampling at most of the same locations sampled during the remedial investigation (RI) and feasibility study (FS). Monitoring is proposed for seven locations along Halls Brook and the Aberjona River downstream of Industri-Plex OU2. Rainfall amounts, stream depth and velocity, and six water chemistry parameters will be measured continuously. Monthly samples will be collected manually during non-storm conditions to establish baseline conditions. Samples will be automatically collected during storm events involving one inch or more of rainfall
with a goal of collecting four storm samples during a year.
Six of the seven proposed surface water monitoring stations are the same as those monitored during the RI/FS. One Station (Station 6) was moved to the bridge where Washington Circle crosses the Aberjona River (approximately one-half mile upstream from its RI/FS location) to better represent surface water quality leaving the site. Three monitoring stations located downstream on the Aberjona River that were previously sampled by the U.S. EPA are proposed to be eilminated.
Is it Safe?
Comments in this section reflect ASC's primary concern about whether the proposed monitoring will result in surface water data that will be sufficient to ensure that the site will be safe for the community after the
completion of remedial activities.
Monitoring locations. ASC would like to ensure that stormwater inputs from the BOston Edison Easement
and the Atlantic Avenue Drainway do not result in contaminant concentrations in surface water that would be unsafe for the community. The proposed locations do not address stormwater inputs from these sources. Furthermore, it is possible that remedial activities could increase metals releases downstream on the Aberjona between Stations 7 and 8. It is not clear from the RI/FS data that Horn Pond Brook is responsible for the
increased flux in arsenic that was observed from Station 7 to Station 8. It is plausible that sediment scouring during storm events is responsible for this increased flux, with the arsenic in the re-suspended sediments originating from sources upstream on the Aberjona, including the Industri-Plex site. We recommend continued monitoring at Stations 7 and 8 along with the collection of additional data to understand the increased arsenic flux, possibly including an additional pre-design investigation (in the Remedial Design Work Plan) focused on
this topic. Simultaneous monitoring of the arsenic fluxes from the Horn Pond tributary and the Aberjona main channel, both upstream and downstream of the confluence with the Horn Pond tributary, is necessary to understand the mass balance of fluxes responsible for the apparent increase of arsenic transport observed at Station 8.
Performance criteria for arsenic. ASC remains unconvinced that the remedy and performance criteria protect against recontamination of sediment downstream of the Industri-Plex site due to continued releases of arsenic. The concentrations of arsenic on suspended sediment particles, as calculated from data collected during storm sampling, greatly exceed the various performance criteria derived for sediment. The following figure
demonstrates this point. Plotted are the imputed concentrations of arsenic on suspended particles, calculated
for each monitoring station as the differences of averaged total and average dissolved arsenic concentrations divided by the average concentrations of total suspended solids. 1 Also depicted (as green lines) are the performance criteria for arsenic in sediment, which range from 230 to 300 mg/kg. Arsenic concentrations on suspended particles greatly exceed the performance criteria from monitoring stations 2 to 6, which suggests
that deposition of these particles has the potential to re-contaminate sediments to levels above the
performance criteria, i.e, that the flux of arsenic - even 1 A paper by Davis et al, (1996) entitled
"Bioaccumulation of arsenic, chromium and lead in fish: constraints imposed by sediment geochemistry" finds arsenic concentrations of up to 2,990 mg/kg in Halls Brook Holding Area sediment, consistent with the imputed concentrations on particles presented in the figure.
Benzene. Benzene is a contaminant of concern for which surface water cleanup standards were established in the Record of Decision (ROD). These cleanup standards were developed to ensure the safety of public health
and the environment. Due to the location of plume discharge, benzene is most likely to be detected at Station
2, yet the SWMP does not propose testing surface water from Station 2 for benzene, statin that it would be too dangerous for the sample collector. Streamflow in the vicinity of Station 2 likely does not ge dangerously high except during extreme storm events. While caution should be used while collecting samples, ASC recommends sampling and testing water from Station 2 for benzene.
Dropping contaminants. One of the goals of the SWMP is to determine whether contaminants are present in surface water at levels that could potentially harm members of the community and/or the environment. The
SWMP proposes eliminating contaminants of concern from the monitoring program after one year if those contaminants have not been detected at specific locations or in specific types of samples (such as storm
samples). While ASC understands the desire to eliminate chemicals of concern from the monitoring program to control the cost of the program, ASC also believes that it is important that chemicals not be eliminated unless
it is clear that both the source of the contaminant has been eliminated and it has not been detected for at least one year.
Seasonality of monitoring. Seasonal variations have the potential to affect contaminant concentrations in
surface water. Contaminant uptake will be affected by plant growth with contaminants being trapped by
wetland vegetation. In the autumn, there may be a large release of contaminants from wetlands because
plants will no longer be trapping pollutants. For this reason, ASC recommends that there be a seasonal basis
for storm event sampling. At least one storm event should be sampled in each of spring, summer, autumn,
and winter, and consideration should be given to collecting a sample during a spring thaw when snowmelt
may contribute considerably to surface water as well as after the end of the growing season to capture largest fluxes of wetland pollutants.
Will it work?
Comments in this section reflect ASC's interest that the proposed activities result in the successful collection of surface water data that will allow proper design of remedial activities that will reduce risks to the community
to an acceptable level.
Monitoring equipment. It is essential that the equipment used to automatically collect samples during storm events be operate during storm events. For this reason, if wireless telemetry is being proposed, it should
also be used to rapidly report data to those performing the monitoring. The system should automatically alert a monitoring crew to large storm events so that the crew can ensure that sampling is being done correctly during key storm events.
Compositing of samples. The SWMP proposes composting individual aliquots of water (collected every one to two hours) over entire storm events. Compositing storm samples may cause the loss of important information regarding the evolution of storm-generated pollutant fluxes. To remedy this, ASC recommends that at least one storm event be sampled such that each individual aliquot collected at Station 2 is analyzed. In this way, it will
be possible to determine when the chemocline in the Halls Brook Holding Area breaks down, and hence when during storms the largest pollutant mass fluxes occur. These data could be used to determine whether composting over entire storm events is justified.
Filtration. The Field Sampling Plan (FSP) currently provides no information on when the filtration of samples will occur. The FSP states that composite samples collected at each station will be processed upon completion of
the sampling program (generally 72 hours after initiation) and analyzed for total and dissolved arsenic. To distinguish arsenic attached to particles from dissolved arsenic, filtration should be done immediately, not after waiting 72 hours.
Sampling method. The apparatus for collecting surface water samples during storm events is discussed on
page 11 of the SWMP. While the sampling apparatus may be appropriate, it is difficult to understand the arrangement of equipment without a figure. ASC suggests that a figure showing the sampling apparatus be added to the SWMP.
Stage discharge relationships. The SWMP states that stage discharge relationships will be developed during
the preliminary stage-response evaluation period, which may be one month or more in duration. Each spring a supplemental stage-response evaluation may be conducted. However, stream response to storm and runoff events may not be constant even over this one year period. These relationships should be adjusted more frequently, perhaps twice each year. The USGS gauging station may be useful for calibration and validation.
Battery life in Isco sensors. Isco sensors such as those proposed for streamflow measurements and automatic collection of data have a tendency to rapidly consume batteries If the batteries in this equipment fail, the equipment may not collect data during key storm events. What is the anticipated battery life of this equipment given the intended sampling frequency? Is the weekly operational maintenance sufficient to ensure that
battery power will be sufficient to operate the equipment at key times?
Additional General Comments:
Reporting. ASC would like to receive copies of the surface water monitoring reports as they become available
and would like to be given an opportunity to submit comments on them.
Database. ASC believes the database proposed in the Site Management Plan will be very useful. ASC believes that it would be useful to provide graphic capabilities along with the database, allowing users to view selected data on an easily interpreted graph. Furthermore, ASC suggests that data other than EPA data (such as data collected by researchers at Tufts University and the Massachusetts Institute of Technology) be either included in the database or made available to users of the database through links to the data. The conceptual site model
for the site could benefit from an awareness of these outside data sources.
Aberjona Study Coalition Preliminary comments on the Remedial Design Work Plan
Though a formal review of the Remedial Design Work Plan is not complete, a few general comments have been developed based on our preliminary review.
Preliminary Design Investigations (PDI) results. ASC would like to receive the results of PDIs as they
Sulfides. Researchers have anecdotally noted that samples of bottom waters from the north basin of Halls
Brook Holding Area pond have odors indicating the presence of reduced sulfur compounds. It is not clear from
the Administrative record if samples from HBHA pond have been collected and analyzed for sulfides. If not, it would be valuable and appropriate to sample for sulfides as part of the upcoming pre-design investigations,
as there is a relatively stringent Ambient Water Quality Criterion for sulfides (2 ug/l for undissociated H2S). Moreover, significant excavations into anoxic soils or sediments might result in the release of odors to air.
If so, there could be potential for nuisance and (if odors are severe) irritation health effects. ASC recommends
the development of odor control plans that include (if appropriate) ambient air monitoring for odorous chemicals such as ammonia and hydrogen sulfide.
Participation. EPA was receptive to the suggestion that a technical representative of the ASC be allowed to attend key technical meetings between EPA and the PRPs. As part of the Community Relations Support Plan, ASC would appreciate receiving details on how the process will work.
Aberjona Study Coalition Comments - Consent Decree March 24, 2008
First, the role of the Aberjona Study Coalition (or other potential stakeholders such as the City of Woburn) is nowhere discussed in the Consent Order. At various places in the Consent Order mention is made of the
review roles of the U.S. environmental Protection Agency (EPA) and the Massachusetts Department of Environmental Protection (DEP). We would appreciate recognition of our opportunity to comment and
participate throughout the remedial process. We appreciate that EPA will be developing a Community Relations Plan (CRP) that presumably will define our role, and we would welcome the opportunity to provide input and feedback prior to the CRP's issuance.
Second, since the Potentially Responsible Parties (PRPs) will be conducting the remediation, we are potentially interested in greater access to information at the design stage. Would it be possible for a representative of the Aberjona Study Coalition to attend (as a non-participating observer) key technical meetings held between EPA
and the PRPs? We are aware that a smiliar opportunity is afforded to the Citizens Research and Environmental Watch (CREW) in its role as an oversight stakeholder in the cleanup of the Starmet/Nuclear Metals site in
Concord, and have the impression that CREW has provided valuable contributions to the process. Also, a
greater continuing awareness on our part will likely reduce the need to comment on various topics that emerge.
Third, as a general comment at this time, the Aberjona Study Coalition expects to see a high level of monitoring (both spatial and temporal) to be required both during and after the remediation. The remedy is based upon
the minimum level of protection afforded by the Superfund program, as the target cancer risk level of 100 in a
million is at the upper end of the acceptable range of 1 to 100 in a million. Hence, it is paramount that a good
deal of monitoring data be collected to confirm that, with statistical confidence, the performance standards are
met. Additionally, we remain concerned that the remedial action, even if conducted exactly according to plans,
will be insufficient to protect human health and the environment. Performance Criteria for arsenic at concentrations of 50 mg/kg in soil, 230 mg/kg in sediment, and 150 ug/l are well above background levels and reflect the fact that significant contamination will be left in place. While institutional controls can be effective a preventing excessive exposure to the contamination, they do not necessarily contain it. In particular, the
surface water performance standards for arsenic and ammonia, which are designed to protect in situ aquatic
life, do not consider transport implications. Since the 150 ug/l standard for arsenic potentially reflects dissolved conditions, meeting this criterion could be accompanied by a high level of arsenic transport if most of the arsenic is attached to suspended sediment. If so, a large flux of arsenic could deposit in the watershed downstream and lead to unacceptable levels of arsenic in sediment. Consequently, consideration should be given to arsenic speciation and total flux. Similarly, the performance standard for ammonia is based on direct toxicity, and does not consider the importance of nitrogen flux/loading to the Aberjona watershed, which has been designated as impaired...
Fourth, we note that Section 11(c) provides an opportunity for the PRPs to offer alternatives to EPA's preferred remedy (the elements of which are described in the COnsent Order's SOW). If alternatives are presented, we trust that EPA and DEP will review them at a high level of scrutiny, and provide the ASC and other stakeholders with ample opportunity and notice for review and comment of such de novo information such that we can be assured that the goals of protecting health and the environment are met. Fifth, we are curious to know that
steps and measures will be used to implement the provisions of Section 26 of the Consent Order that requires potential imposition of institutional controls on properties not controlled by the PRP's. Is there a provision for forcing these agreements in cases in which property owners are not cooperative? It not, does a failure to
achieve appropriate activity and use limitations potentially jeopardize the protectiveness of the remedy? Comments provided in partnership with Cambridge Envrionmental Inc. Environmental consultants to the
Aberjona Study Coalition Inc. Sincerely, Linda A> Raymond, Secretary Aberjona Study Coalition, Inc. Cc:
Senator James Marzilli Representative, Jay Kaufman Representative, Patrick Natale, Joseph LeMay EPA Remedial Project Manager, Mayor Thomas McLaughlin City of Woburn, Charles Doherty Woburn City Council President.
ASC Cover Letter Comments to the EPA MSGRP Study - August 31, 2005
The following Cover letter was sent to the EPA along with 26 pages of comments on the EPA MSGRP study, feasibility study and proposed plan. A full text of the Co. Email your request to Fitwalker1@aol.com. A complete set of comments was sent to Senator Edward M. Kennedy, Senator John F. Kerry, Congressman Edward J.
Markey, State Representative, Patrick Natale, EPA Regional Administrator, Robert W. Varney, Anna Mayor, DEP Superfund Project Manger, Mayor JOhn C. CUrran, Paul Medeiros, President Woburn City Council, Woburn Daily Times Chronicle and the Woburn Advocate, Mr. Joseph F. LeMay P.E. Remedial Project Manager Suite 1100 (HBO) 1 Congress Street Boston, MA 02114-2023.
Dear Mr. LeMay: Since April of 2002 we have been associated with the Aberjona River Study. In July of 2002
we invited you and members of your group to speak at the Woburn Neighborhood Association, Inc. meeting regarding this study. It was after that meeting that the idea to form the Aberjona Study Coalition, Inc. (ASC)
was conceived. OVer the past forty-one months we have established a coalition consisting of six community groups: Woburn Neighborhood Association, Inc., Woburn Residents Environmental Network, Mystic River Watershed Association, Concerned Citizens Network, Friends of Upper Mystic Lake, and Medford Boat Club that represent over 225,000 residents who border the Aberjona River. OUr first task was to hire a technical advisor who is an expert in the relevant environmental sciences and would act as our interpreter to translate the many complex reports that will be issued over the next few years as a result of the Aberjona River Study. The first of the complex Environmental Protection Agency (EPA) reports, "Baseline Human Health and Ecological Risk Assessment Report", was released in two parts during the spring and summer of 2003. This report is the foundation of all of the reports that were to be issued from the EPA over the next few years. IF the assumptions are not correct in the baseline report it could have a lasting effect on all of the decisions that will be made. With this in mind when searching for a technical advisor we chose Cambridge Environmental, Inc.
As a joint effort of the Aberjona Study Coalition, Inc. and our technical advisor, Cambridge Environmental, Inc.
we submitted thirty-one pages of comments on the Baseline Human Health and Ecological Risk Assessment for Operable Unit 3 of the Wells G & H Superfund Site. We stated in the text, by necessity, that our comments
were in part incomplete. We expected to receive and then comment on additional information from the EPA by way of a response to some of the preliminary comments submitted in October of 2003. At that time we also reserved the right to provide further comment to the EPA on issues regarding information that was incomplete.
On June 28, 2004 we received the EPA response to our thirty-one pages of comments to the Baseline Human Health and Ecological Risk Assessment Report. After reviewing the EPA responses we found that many of EPA responses were vague and incomplete. Rather than comment on this release, we decided to wait until the full baseline report for the entire Aberjona Watershed was issued before making any further comments. In our
initial review of the Multiple Source Groundwater Response Plan (MSGRP) Remedial Investigation, Feasibility
Study and Proposed Plan we discovered that some of the comments we submitted in October of 2003 were not satisfactorily addressed by the EPA.
Comments that were not adequately addressed included comments on the ecological risk assessments (i.e. a paucity of data collected from each reach and unrealistic exposure estimates for the green heroin and mallard). Due to incomplete information, it is difficult to judge the validity of the conclusions of the ecological assessments. On April 6, 2005 we received the March 2005 report, a 12-volume report titled Draft Final MSGRP Remedial Investigation Report. This report was issued without an EPA comment period. We were told by the EPA that
the Feasibility Study would be forth coming and we would have an opportunity to comment on both reports at
the same time.
On June 30, 2005 at an EPA public meeting the Proposed Plan Report was distributed to those in attendance.
The Remedial Investigation/Feasibility Study, which was supposed to be released prior to the Proposed Plan,
was received days later. At this meeting, the public was informed of a thirty-day comment period with a
deadline of August 1, 2005.
The Aberjona Study Coalition, Inc. publicly requested an extension to the comment period at this meeting of
June 30, 2005. On July 1, 2005 the Aberjona Study Coalition, Inc. submitted a written request to the EPA
asking for an extension to the comment period to OCtober 1, 2005. And on July 27, 2005 at an EPA public hearing, the Aberjona Study Coalition, Inc. again requested that the EPA reconsider its decision and extend
their comment period.
Through our efforts, and the efforts of United States Senators Edward Kennedy and JOhn Kerry, Congressman Edward Markey, State Representative Patrick Natale, concerned municipal groups and citizens the EPA did
extend the comment period to August 31, 2005. During August of 2005 we again expressed our need to
extend the EPA comment period to United State Senators Kennedy and Kerry and Congressman Markey.
Senator Kerry and Congressman Markey further forwarded our request to EPA Regional Administrator, Robert
W. Varney. Mr. Varney has yet to respond.
The Aberjona Study Coalition, Inc. believes that the EPA has put a tremendous and unacceptable burden to
review and assess such a complex report within 60 days on the average citizen to whom we represent. We
plan to continue to review the reports and provide comments during the next comment period.
Over the past sixty days, as a joint effort the Aberjona Study Coalition, Inc. and our technical advisor Cambridge Environmental, Inc. have spent hundreds of hours reviewing the Multiple Source Groundwater Response Plan (MSGRP) Remedial Investigation, Feasibility Study and Proposed Plan. As stated above, on a number of occassions, we have made a formal request to have the comment period extended. Attached is a twenty
six-page comment and question document in response to the Multiple Source Groundwater Response Plan (MSGRP) Remedial Investigation, Feasibility Study and Proposed Plan.
We state by necessity, that our comments are in part incomplete, due to the inadequate comment period. At
this time we reserve the right to provide further comments to the EPA on issues that arise after further review
of the Multiple Source Groundwater Response Plan (MSGRP) Remedial Investigation, Feasibility Study and Proposed Plan Reports. We believe since the EPA has chosen to meet the least stringent levels of its range of acceptable risks, there is little room for error in the implementation of its plans if the target risk ranges are to be truly met. Every step should be subject to comprehensive evaluations. The proposed plan should be able to stand up to metriculous scrutiny if it is truly valid and all efforts should be made by the EPA to have its work justified and evaluated in a proper and more appropriate timeframe. If the plan goes forward as proposed (or even with minor modifications), the continued process of public participation is crucial to its success. In fact, opportunities for public participation should be intensified.
We recognize the need to present the results of our assessments in simple terms to communicate to the widest fraction of the public as is possible. Yet we bristle when we hear others pronounce absolute judgments of
safety such as "there is risk" or "there is no risk". Thee is always risk. The ASC and other members of the
public understand this concept, and oversimplification of it for risk communication purposes obscures the basic meaning of risk. Thank you for giving us the vehicle in which to voice our comments and concerns. We look forward to your response.
Aberjona Watershed Risk Assessment Update - November 2003
In July of 2002 we invited the EPA to speak at the Woburn Neighborhood Association meeting regarding the Aberjona River Watershed Study. It was after that meeting the idea to form the Aberjona Study Coalition was born.
Over the past sixteen months we have established a coalition consisting of six community groups: Woburn Neighborhood Association, Woburn Residents Environmental Network, Mystic River Watershed Association, Medford Boat Club, Concerned Citizens Network and Friends of the Upper Mystic Lake. The Aberjona Study Coalition (ASC) represents over 225,000 residents who border the Aberjona Watershed. Our first task was to
hire a technical advisor who is an expert in the many environmental sciences and would act as our interpreter to translate the many complex reports that will be issued over the next few years as result of the EPA Aberjona Watershed study.
The first of the complex reports "Baseline Human Health and Ecological Risk Assessment Report" was released in two parts during the spring and summer of 2003. This report is the foundation of all of the reports that will be issued from the EPA over the next few years. If the assumptions are not correct in the baseline report it could have a lasting effect on all of the decisions that will be made. With this in mind when searching for a technical advisor we chose Cambridge Environmental, Inc.
The Cambridge Environmental team was selected by the Aberjona Study Coalition (ASC), a stakeholder in the
U.S. Environmental Protection Agency's (EPA) investigation of chemical contamination of the Aberjona River, to provide technical assistance in evaluating the results of EPA's work. The ASC represents a broad group of citizens - more than 225,000 residents in Woburn, Winchester, Wilmington, Medford, and Arlington MA - who
have diverse and long-standing interests in the Aberjona River and surrounding areas.
The ASC has three goals with respect to EPA's efforts: to ensure that the investigation is technically sound; to ensure that the investigation is complete; and, most importantly to ensure that the investigation is adequately protective of human health and the environment. Cambridge Environmental's review of the EPA's Baseline Human Health and Ecological Risk Assessment (hereinafter "the Risk Assessment") for Operable Unit 3 of the Wells G & H Superfund Site (the "Site") indicates that EPA has satisfied some, but not all, of the ASC's goals. In general, the Risk Assessment is technically sound, i.e., the methods are consistent with U.S. EPA guidance and procedures, and the calculations set forth are mathematically correct. However, significant data gaps exist. It is not clear that enough data have been generated and analyzed to support the Record of Decision that must be developed for the Site. Moreover, the Risk Assessment does not adequately characterize potential risks to human health, and therefore may not represent a health-protective analysis.
Many of our concerns about the Risk Assessment are addressed through presentation of additional information and the collection and/or analysis of additional data. In the comments we provided, we offer specific suggestions for changes and additions to supplement the Risk Assessment. Our comments are presented in four categories: General comments on the Risk Assessment and Site Investigation; Major comments on the human health risk assessment, Major comments on the ecological risk assessment; and Minor comments. By necessity, our comments are in part incomplete, in that we expect to receive, and then comment on, additional inforamtion from EPA by way of response to some of the preliminary comments presented here.
We reserve the right to provide further comment to EPA on issues for which information is currently incomplete. We also will comment in the future on issues tied to information to be provided by EPA in subsequent reports (e.g., the fate and transport analysis that EPA intends to provide in the Remedial Investigation report for this site). For more information or to request a copy of the Aberjona Study Coalition comments, you can contact the EPA community Relations person Angela Bonarrigo at 617-918-1034 or by email Bonarrigo.email@example.com.