Hopefuly everyone is aware of the meeting this Thursday at 6:30pm at the High School, where the EPA plans on presenting their new plan to address remaining underground contamination located in Operational Unit 2 where the Nyanza Chemical Plant was previously located. Details on the plan and an overview of the site (including Operational Units) can be found in the published plan located at: https://semspub.epa.gov/work/01/100012890.pdf
I have been proud to advocate with others for the EPA to develop an alternative remedy with a goal to actually clean up the contamination in OU2 and not just contain it. So I was pleased when the EPA notified me that this recommendation was on its way. However, even though I have read and analyzed the report extensively, I still had some questions. So last week I had the opportunity to sit down with the EPA and MassDEP to ask some questions about the plan and how they came to the conclusions that they did.
This issue is a very serious issue, and so I want to provide a little background information to ensure that any discussion about this is focused correctly. First, it important to note that the cleanup plan being proposed does not mean that no progress has been made cleaning up the site; this plan is a revision to the one that is currently being implemented right now. The current method however, which has been in place since 2006, has not resulted in a reduction of the contamination levels underground that we all expected and hoped for. In fact, the current method estimates that it would take over 600 years to achieve contaminant levels that could be considered safe for humans and the environment.
We also need to ensure that everyone understands what the danger actually is. While some may conjure up images of the “cap” exploding and a series of contaminants shooting up into the air like volcanic ash, that’s not really the danger at all. Sites south and west of the cap have very little to worry about with regards to contamination. The danger lies in chemicals that are underground, flowing east and north, the vapors of which can be transferred upward through the soil and into the air into enclosed spaces. The area where this can happen is referrred to as the “plume” here in town. This groundwater plume eminates from the area where the lagoons and chemical dumps were for the Nyaza plant, which is around the Worcester Air Conditioning area. While dermal contact and ingestion do not carry the same kind of cancer risks as inhalation of the vapors, they do carry other significant risks if continually exposed.
When examining a new remedy for OU2, the EPA initially developed 10 different proposals and did further analysis on the six best alternates. These were graded according to:
Overall Protection of Human Health and the Environment
Compliance with ARAR’s
Long-Term Effectiveness and Permanence
Reduction of Toxicity, Mobility, or Volume Through Treatment
After their evaluation, the EPA is proposing remedy #4 (GW-4). This proposed plan appears to practice a middle-of-the-road philosophy on all of these evaluation criteria. My initial reaction was probably similar to those of you that have already read the report...Why is the EPA proposing a cheaper, less effective plan than some of the alternatives, and why shouldn’t we advocate for the more effective ones? The very short answer from my meeting is it comes down to both cost and ability to practically implement. The Nyanza project will be competing with similar projects around the nation, so there is a concern it might not get funded. Also, implementation of the plan requires cooperation of different entities that are outside of their control.
The recommended plan also leans heavily on what the EPA terms “Institutional Controls”, without being specific about what those are. It is my firm belief that Ashland’s revitalization should not be stunted because the EPA shifts the burden of protection on us; they should bear the responsibility for ensuring that the site and people are safe at their own expense. However after conversation with the EPA, I do feel that they share this philosophy and are willing to work with us. Since 2016, we have put in place informal administrative policies that protect health and safety in the plume area. I am asking that these informal policies become institutional controls. It requires testing to happen before a full application for a project can even be filed, sending those test results to the EPA, and incorporating EPA’s recommendations into the final local decision. It also requires specialized detection equipment and health and safety plan for any construction projects, and the elimination of any irrigation wells within the area.
While grateful to the EPA for their time and the resources put into this recommendation, I still have many questions. Unfortunately there is no clear “right” answer. And while the complexity of the calculus for this problem is similar to other public policy decisions, the stakes are higher. It may come down to a question of do we want to be more aggressive in pursuing a more expensive and harder to implement remedy in the hopes that the site will become cleaner quicker, but at the risk of not having any progress made at all?
I look forward to hopefully having more clarity after the meeting. I hope to see you there as well. For those who cannot attend it will be broadcast via WACA.