Action Item: Submit a Comment to TRC

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Take action: Submit a Comment to TRC to Address Contamination at the Compressor Site

Comments are due May 4 | Details, Instructions, and Sample Comments are available here and below

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TRC, a consultant for Enbridge, has been reviewing the clean up process for contamination at the site of the compressor station and neighboring beach area. Years ago, community members raised concerns with MassDEP about known oil and arsenic contamination on this site. This complaint led to the opening of a PIP (public involvement plan) to begin addressing the issue. TRC has been overseeing the process since then. MassDEP has designated the north parcel as a toxic waste site.

The PIP program falls under MassDEP’s Bureau of Waste Site Cleanup (BWSC) department.

There have been a series of public meetings and written comment periods for community members to express the comments, questions, and concerns. Although it often feels like lip service, we do still think it’s important to submit comments, even if to just create a paper trail of documented concerns.

TRC will be accepting comments on the following documents. Comments are due May 4, 2021.

More info from TRC: https://www.trccompanies.com/insights/weymouth-pip/


How to Submit Comments:

Email Comments to: James Doherty, PE, LSP, at TRC WeymouthCompressorStation@trccompanies.com AND forward email to FRRACS for record-keeping (nocompressor@gmail.com)

OR

Mail Comments to: James Doherty, PE, LSP, at TRC Environmental Corporation, 650 Suffolk Street, Lowell, MA 01854


Sample Comments:

We suggest using this document from MassDEP as a resource as you write your comments: Top Ten Most Common MCP Risk Characterization Problems

Sample comments specifically in response to TRC Draft Immediate Response Action (IRA) Completion Report RTN – 4-28676:

  • In the introduction of Report 4-28676, it is noted that soil samples were collected from a depth of “ less than twelve inches below the ground surface”. It is also noted that the site is known as the Kings Cove Conservation Area. Additionally, the site is also the location of the MWRA 60” sewage pipeline ROW going to the Braintree/ Weymouth regional pump station. The site also is the location of all utilities serving the pump station. As with all such pipeline ROWs, the material at the top of the site is covered with up to a foot of topsoil utilized to hold freshly planted grass and shrubs. Thus, any soil samples taken at less than a depth of one foot, would only consist of soil trucked in for coverage. Prior samples taken on the compressor site, show contamination up to 20’ below ground level. The determination of the level of contamination exposure is based on its impact on background levels. 310 CMR 40.006 defines “background” as” those levels of oil and hazardous material that would exist in the absence of the disposal site of concern”.

  • In section 2.1 - Release Description, the evaluation of “imminent hazard” in this section, appears to selectively choose the criteria that will yield the chosen result (results oriented testing). 310 CMR 40.903 is entitled “scope of the risk characterization and supporting documentation”. This document does not define the risk scope of the area, nor supplies supporting documentation beyond laboratory analysis numbers.

  • In Section 2.2 - Site Conditions, the description of the noted site is limited. 310 CMR 40.0904 states “the scope and level of effort of the risk characterization shall depend on the complexity of the disposal site and response action being performed. The risk characterization shall be of sufficient scope and adequately documented to demonstrate that the Response Action Performance Standard (RAPS) has been met in accordance with 310 CMR 40.0191. This is obviously not the case with this document.

  • The level and quality of the Draft Report do not meet the standards established under 310 CMR 40.900. This is confirmed in a comparison with the Mass DEP document entitled “Top Ten Most MCP Risk Characterization Problems”. You could find all of them in the TRC report.

Sample comments in response to Draft Immediate Action Completion Report – RTN 4- 28615 

  • The Introduction notes that “sediment samples were obtained at a depth of 0-0.5 feet along 3 sample lines oriented parallel to the shoreline to assess human and ecological exposure”. The Kings Cove is impacted by sediment being carried in with Fore/ Town Rivers and Boston Harbor waters. A sample depth of 0-0.5 feet, may only consist of sediment from other Boston Harbor locations.

  • The second paragraph in section 2.0 - Release Description, states that the applicable 2-hour notification threshold for “arsenic is 40 mg/kg and for chromium it is 200 mg/kg” as specified in 310 CMR 40.321. The chart in 310 CMR 40.321(2)(b) states the “concentration” in ug/g not mg/kg.

Other Sample Comments:

Testing for toxins:

  • Has there been testing of sediments on the beach and in the bricks of the beach for asbestos? If there has not been testing for asbestos, why? Residents have been concerned about this. If TRC and MassDEP are not concerned about the presence of asbestos, why not rule it out by taking samples of the bricks and sediments on the beach and in the park?

  • Have clinkers that are present on Kings Cove been tested for heavy metals? Residents in the past before knowing what they were, including children, have collected clinkers and brought them home to rock collections thinking they were odd rocks or lava rocks.

  • Have you tested shellfish in the cove for different heavy metals and other toxins? If it has not been done, I request that you test shellfish in the cove and explore exposure receptor pathways through ingestion of shellfish.

Erosion Control:

  • Please provide temporary erosion control measures to stop further erosion of coal ash, clinkers and burner bricks onto King's Cove Beach. The erosion has gotten significantly worse and residents have been requesting erosion control measures for a long time. More trees and shrubs from the park have fallen onto the beach. We appreciate that caution tape has been put up in the park, however more must be done in the interim to prevent more coal ash and clinkers to erode.

Cleanup Responsibility:

  • If Algonquin/Enbridge/Calpine find that the cost of clean up is too costly, who will pay for the work?

  • Boston Edison, which is now Eversource, originally owned the property and dumped the coal ash, clinkers and burner bricks from the Edgar Power Plant. How much is Eversource responsible for the clean up, if at all?

Restoration:

  • In the permanent solution, I request that Algonquin/Calpine do a restoration of the beach by clearing the large clinkers and bricks or covering them up to make the beach easier to walk on and prevent further erosion of coal ash, clinkers and bricks from the bank.

  • Different measures should be explored as alternatives including, but not limited to, beach nourishment, removal of clinkers offsite, incorporating clinkers back into a restored bank behind erosion controls, nature-based solutions for erosion control and more armoring of the bank.

  • Access to the beach via a trail should be maintained in any permanent solution so people can walk on the beach to fish, fowl, navigate boats, and launch kayaks and canoes. I frequently walk on the beach myself.

Shellfish:

  • I request you test shellfish in King’s Cove for the presence of toxins

  • As the area is currently closed to recreational shellfishing because of the bacteria and could also have additional risks because of contaminated sediments

  • This is especially important as the area is conditionally restricted for commercial shellfish harvesting

  • Conditionally Restricted means: "Contains a limited degree of contamination at all times. Subject to intermittent pollution events and may close due poor water quality from rainfall events or season. When open, only commercial harvesting of soft shell clams for depuration is allowed."

  • I request that TRC/Algonquin/Calpine place signs on the beach stating "Closed to shellfishing" with pictures of shellfish crossed out in multiple languages including Chinese, English, Spanish and Vietnamese.

  • Knowledge that the area is closed to shellfishing because of bacteria may not be universally known.


Thank you for submitting a comment to TRC!