PIP Q/A #1
Prepared by the Public Involvement Plan (PIP)1 Group for the Buckley and Mann site
What is this all about?
A group of residents has learned that one of the properties being considered for the municipal Golf Course has been and still is contaminated, so we are trying to obtain information about the likely future liability for the town. We have prepared this Q&A based on information in a report2 prepared by Camp Dresser & McKee, environmental consultants to the current owner.
What does contamination mean?
That there are toxic pollutants in the soil at the site, and that they are present at concentrations harmful to human health and the environment.
Why does that matter to us?
Because if the town buys the land, then by law it will be our responsibility to pay for the study (site assessment) and cleanup of the contamination. The study and cleanup costs have not been included in projected costs, and they could be hundreds of thousands or even millions of additional dollars. Depending on the extent of the contamination, it could also affect the time table for the proposed golf course, which would mean a delay in revenues from the project.
But wouldn't this be taken care of, once we get environmental permitting for the Golf Course?
No. There are two separate sets of regulations, the Massachusetts Environmental Protection Act (MEPA), which is the permitting commonly referred to when talking about the Golf Course, and the Massachusetts Contingency Plan (MCP), which regulates cleanup of contaminated sites. In order to build the Golf Course, the Town needs to get a MEPA permit, but that process primarily considers the potential impact of the Golf Course on the environment. Whether or not the MEPA permit is issued, once the Town buys contaminated land, it is responsible for studying and cleaning it up in accordance with the MCP.
What is known about the contamination at the site?
That there are toxic compounds exceeding health standards in the soil at a former landfill, and that there are toxic compounds present in nearby lagoons and wetlands. These are the only areas that have been studied so far, so we do not know the extent of any contamination that may be present in other parts of the site, such as the former mill buildings.
What are the contaminants that are present?
They are called PAHs3, PCBs, and metals such as lead and chromium. According to the EPA, the types of PAHs in the soil at the site are probable human carcinogens (i.e. cancer-causing chemicals). The use of PCBs has been banned in the US because of their severe health impact; they are a particular concern near ponds and rivers because they accumulate in fish and small animals, and ultimately in people who fish or hunt in such areas. Chromium is a known human carcinogen, and lead can cause neurological damage, particularly in children. We do not know what contaminants may be present in other parts of the site because they have not been studied. However, based on the age and use of the property as an industrial site, there may also be asbestos, lead paint, waste/debris, or chemicals that were used in operations in those areas.
Has any of the contamination been cleaned up?
Some, but not all. A small amount [315 cubic yards] of soil was removed off site for disposal. The rest of the soil with contaminants - about 4,500 yards - was excavated and then buried in the landfill area without any lining beneath it. According to the reports, the contaminant levels in the soil still exceed human health standards.
What does this mean for the town, if we buy the property?
If the town buys the property, we will assume the liability for all cleanup that is required by State regulations and the cost of all subsequent investigation and remediation in the future. This includes the known problems of finding out the extent of the contamination in the landfill and the lagoons, cleaning up the material in the landfill area so that it doesn't pose a risk to human health or to the wetlands, and possibly conducting a cleanup in the lagoons area. Also, because the contaminants are so close to the Mill River and Tail Race brook, we would have to pay for a study of those areas, and for a cleanup if necessary. And all of this doesn't include other areas of the property, such as the area of the mill buildings, which haven't yet been studied.
What kinds of contamination could be present in the areas that have not been studied?
Potentially asbestos, lead paint, chemicals, PCBs. According to the consultant's report, scraps of building material found at the property were believed to be asbestos from the original siding. If there is asbestos present in the mill buildings, there would be costs associated with abatement or disposal. Also, because of the age of the buildings, there may be lead paint present. Other potential sources that would need to be investigated include spills of chemicals associated with former industrial operations, floor drains, sumps, equipment pits, fuel tanks, and on-site transformers that may have used PCBs. Based on its long history as an industrial site, the property warrants a thorough investigation.
What would the total costs be?
It's hard to say, because only partial work has been done so far. Depending on the total amount of contamination, costs for cleanup in wetlands areas, cleaning up groundwater so that it's safe to drink, and cleaning up asbestos can run into millions of dollars, so it's important for the town to know the extent of the problem.
How can I learn more about this?
Come to the public hearing to be held at the Freeman Centennial Auditorium at 7 pm on Tuesday, October 23, 2001. There will be a presentation by the owner's consultant, followed by a question-and-answer session. Written information about the site can be found in the library's reference section and at the Conservation Commission offices in Town Hall, and updates of the PIP group's activities will be occasionally posted on-line at www.norfolknet.com.
(1) The MA Department of Environmental Protection's "Public Involvement Plan (PIP)" process is a process by which concerned residents can get information about and provide input to cleanup activities at contaminated sites in their community.
(2) Information in this Q&A was obtained from the following report prepared by Camp Dresser and McKee, Inc., consultants to the current property owners: August 2001 Class A-3 Response Action Outcome and Release Abatement Measure Completion Report, Buckley and Mann, Inc., Norfolk, MA.
(3) PAHs: Polycyclic Aromatic Hydrocarbons; PCBs: Polynuclear Aromatic Hydrocarbons. Additional information about the compounds present at the site can be found at: http://www.atsdr.cdc.gov/toxfaq.html