Pwg community info forum final hr_ms_081919_for stoppepperelltoxicdirt town website

TOXIC DIRT = TOXIC TOWNS
Community Information Forum
Monday - 19 August 2019
Nissitissit Middle School | 33 Chace Avenue | Pepperell, MA 01463
Pepperell Watchers Group
www.stoppepperelltoxicdirt.com

Agenda
 Welcome
 Interim Policy
 Overview of 161 Nashua Road Proposed Project
 Status of Reclamation Projects in Other Towns
 Case Testimony
 Protecting the Nashua River (Nashua River Watershed Association)
 History and Current Actions
 Call to Action
 Questions
Welcome to the PWG
Community Forum

Interim Policy
Proposed MCGI/“TERRA Environmental”
Soil Reclamation Project

Reclamation Projects:
Interim Policy History*
 In 2015 - To help regulate the booming “soil
removal” industry in MA, a Soil Reclamation Policy
was instituted
 Managed through Administrative Consent Orders
(ACOs) issued by MA Department of Environmental
Protection
* https://malegislature.gov/Laws/SessionLaws/Acts/2014/Chapter165
https://www.mass.gov/files/documents/2017/09/05/massdep-policy-comm-15-01-2015-08-
28.pdf

Policy # COMM-15-01*
 MassDEP’s intent to issue site-specific approvals via ACO
 Reuse large volumes of soil for reclamation of sand pits,
gravel pits and quarries
 “Poses no significant risk of harm to health, safety, public
welfare or the environment”
 “and would not create new releases or threats of
releases of oil or hazardous materials”
* https://www.mass.gov/service-details/reclamation-soils-policy-and-facilities
Interim Policy

Interim Policy
 Administrative Consent Order (ACO)
 Permit granted by MA DEP
 Incorporates methods and procedures to be
followed during management and execution
of the reclamation project*
* https://town.pepperell.ma.us/DocumentCenter/View/3943/MCGI-Cover-Letter-with-SMP_June-28-
2018_Final_07062018 (page 2)

Purpose and Intent*
 Filling and re-use of spent (or abandoned)
quarries, sand pits and gravel pits.
 Provides increased in-state options. Such
soil often must be shipped out-of-state at
substantial cost.
* https://www.mass.gov/service-details/reclamation-soils-policy-and-facilities

 “Poses no significant risk of harm to health,
safety, public welfare or the environment”
 Soil must be field screened at a frequency of
one (1) field-screening test per approximately
50 cubic yards of soil.
* https://town.pepperell.ma.us/DocumentCenter/View/4458/MCGI_TERRA-Soil-Management-Plan-
Pepperell_FInal-REV-2
What’s Allowed*

1 Cubic Yard ~ About the size of a Washing Machine
What’s Allowed

Reclamation Projects: What’s allowed?
 Poses no significant risk of harm to health, safety, public
welfare or the environment
 Soil must be field screened at a frequency of one (1) field-
screening test per approximately 50 cubic yards of soil.*
 Half-round end dump trailer 38 feet long with 4 foot high
sides has a 33.7 cubic yard capacity.
* https://town.pepperell.ma.us/DocumentCenter/View/4458/MCGI_TERRA-Soil-Management-Plan-
Pepperell_FInal-REV-2

Overview

Overview: Proposed 161 Nashua Road
SCOPE: Estimated 3.2 million cubic yards of soil
From excavation projects in MA /other NE states
* As of March 2019

What does 3.25 million cubic yards look like?
The Hoover Dam is 1244’ long, 660’ thick and 726’ high,
and comprised of 3.2 million cubic yards of concrete.

How is the Dirt Getting Here?
Trucks: 160,000 possible trailer truckloads of construction fill

What is in the Dirt?
“Regulated Contaminants”
In accordance with MA DEP’s Policy COMM-15-01
 Chromium 6 (hexavalent chromium)
 Lead
 Mercury
 Benzo(a)pyrene
 Dozens of Others…

MCGI Proposed Testing for Contaminants
 Naturally deposited soils = 1 test per 1,000 cubic yards
 Soils from known/suspected areas of elevated metals = 1
test every 1,000 cubic yards test per 1,000 cubic yards
 Historic fill solid = 1 test per 500 cubic yards
 Commercial/industrial soils = 1 test per 500 cubic yards
 Other = 1 test per 500 cubic yards

Height of Finished Project?
The proposed height of the finished project
will be 299.5 feet
30 Feet Higher
than the elevation of the original site

Site Location
 Adjacent to Pepperell Skydiving at the airport
 200 feet from Nashua River – our newest Wild
& Scenic River!
 100 feet from Pepperell’s Zone II aquifer

Map of Shared Water Resources
Between Hollis & Pepperell

Project Time Frame and Routes
 Dumping will take place over 7 ‐ 9 years
 Trucks will enter the site from 6:30 a.m. – 5:00 p.m. M-F.
Weekends/after hours will be proposed to the town on a
case-by-case basis
 Potential roads that are affected are 111, 113, and 119

Traffic/Safety Impact
8 ‐ 10, Large 18-wheeler dump trucks PER HOUR

How Will It Affect You?

Status of
Reclamation Projects
in Other Towns

What’s the scorecard on how
these projects are managed?

BRIEF BACKGROUND OF
SOIL RECLAMATION PROJECTS
There are currently seven (7) projects with an ACO in place.
All seven are in violation of their respective ACOs.
Uxbridge
Rutland
Dudley
Carver
Bridgewater
Saugus
Groveland

Uxbridge, MA
 Cease and Desist orders filed to stop
project
 Board of Health: 40% failure rate of soil
samples
BRIEF BACKGROUND OF

Rutland, MA
Fined for:
 Failure to submit monthly inspection reports
for one full year
 Failure to submit quarterly construction
reports for one full year
 Failure to monitor wells and move a “failed”
truck off the site within 30 days
BRIEF BACKGROUND OF

Dudley, MA
Fined for:
 Knowingly accepting a load that exceeded acceptance
criteria
Failure to submit:
 Results of the pre-construction groundwater
monitoring within the deadline
 The Initial Construction Status Report within the
deadline
BRIEF BACKGROUND OF

Carver, MA
 Failure to submit quarterly reports (only
22% have been filed)
 Failure to submit monthly reports (only
22% have been filed)
BRIEF BACKGROUND OF

Bridgewater, MA
 Began operations in 2018
 Over 64 “regulated” chemicals (out of 90)
reported as over established limits
 Failed to perform timely monthly inspections
over 50% of the time
BRIEF BACKGROUND OF

Saugus, MA
 Fined for failure to perform monthly
inspections that adhered to the agreed upon
ACO
 Monthly reports show dozens of “regulated”
chemicals over reporting limits, including lead
BRIEF BACKGROUND OF

Groveland, MA
 Fined for failing to conduct soil sampling …
the very first two months of operation!
Groveland’s Licensed Site Professional (LSP)
will be the LSP for Pepperell
New
BRIEF BACKGROUND OF

What’s the scorecard on how
these projects are managed?
What do YOU think?

Proposed Soil Reclamation Project
Pepperell Community Information Forum
August 19, 2019
Martha Morgan, NRWA Water Programs Director

Nashua River Watershed Association’s Comments on the
Pepperell Reclamation Project at 161 Nashua Road
_________________________________________
The Site
• The Project Site is adjacent to the Nashua River, which just
this year has been designated by Congress a Partnership
Wild & Scenic River.
• Pepperell residents at Pepperell’s 2018 Annual Meeting
unanimously voted to accept the Wild & Scenic Stewardship
Plan, together with its recommendation to seek Wild &
Scenic River Designation.

Hydrology
• The Project Site is an inappropriate use of property
directly adjacent to a river, in this case, the Nashua River,
and Pepperell’s Nashua Road Well #1.
• There is likely a direct hydrologic connection to the
Nashua River from the project site. The site is a former
sand and gravel pit. Soils associated with gravel pits
support high groundwater flow velocities, and have much
higher permeability rates.

• The Project Site’s northwest corner falls within
Pepperell’s Nashua Road Well’s “Zone II” area of
contribution. The siting of the Nashua Road Well at
that location is very likely due to high permeability/
high yield hydrologic aquifer.
• High permeability means soil contaminants
potentially in the soils can reach the river, and
potentially the well, much more quickly.

• Fill material placed at the Project Site tends to
create “groundwater mounding,” which would
exacerbate the threat of contaminated flows
reaching the Nashua River or Pepperell’s Nashua
Road Well #1.

Soil Sampling Frequency
• The frequency of soil sampling of fill material
delivered at other sites in the Commonwealth
has proven to be inadequate, resulting in
contaminated soils being delivered without
detection.

• The proponents say soil samples will be tested
every 1,000 cubic yards for soils considered to
be naturally deposited soils or soils that are
suspected or known to have elevated metals.
• An average tractor trailer truck can hold
approximately 20 cubic yards, or about 30 tons.
• That results in testing approximately every 50
truckloads.

• If any criteria (such as heavy metals, volatile
organic compounds, etc.) are exceeded, testing
may then be increased to every 25 truckloads
(1/500 cu.yds.) or every 5 truckloads (1/100 cu
yds).
• NRWA does not believe the proposed analytical
testing protocols proposed are sufficient to
adequately characterize the incoming fill material.

Nashua River Watershed Association believes the
proposed Soil Reclamation Project is inconsistent
with the values the NRWA and others place on our
natural resources and river ecosystem.
The NRWA has grave concerns that the proposed
project threatens these resources and supports
the Town of Pepperell in rejecting this project.

Soil Dumping
Uxbridge, MA
2014 - 2019
Uxbridge Case Testimony

History and
Current Actions

Call to Action

What Can You Do?
 Call or write your US/State Officials
 Purchase a sign as you exit tonight ($8)
 Donate to support legal fees
 Talk to your neighbors; ask them to act

Quarry Photos

Questions

Pwg community info forum final hr_ms_081919_for stoppepperelltoxicdirt town website

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