“Natural” Gas Compressor Station in Weymouth, Massachusetts

A Comprehensive Assessment of the Potential Human Health Impacts of a Proposed “Natural” Gas Compressor Station in Weymouth, Massachusetts

Released September 24, 2019

A report by:

Regina LaRocque, M.D., M.P.H. Board Member, Greater Boston Physicians for Social Responsibility Associate Professor of Medicine, Massachusetts General Hospital/Harvard Medical School

Brita Lundberg, M.D. Board Member, Greater Boston Physicians for Social Responsibility Member, Massachusetts Medical Society Environmental and Occupational Health Committee

Zoe Petropoulos, PhD candidate Boston University School of Public Health

on behalf of Greater Boston Physicians for Social Responsibility

Contact:

Anna Baker, M.P.H. Executive Director, Greater Boston Physicians for Social Responsibility [email protected] (617) 868-3003

Regina LaRocque, M.D., M.P.H. Board, Greater Boston Physicians for Social Responsibility (617) 519-6705

1" " EXECUTIVE SUMMARY

Greater Boston Physicians for Social Responsibility (GB PSR) is a non-profit organization of physicians, health professionals and public health experts. In this report, we provide a quantitative and qualitative assessment of the human health impacts of a proposed 7,700-horsepower natural gas compressor station that Spectra Energy proposes to build in Weymouth, Massachusetts. This report focuses on three areas of concern that were inadequately assessed by the Commonwealth’s Health Impact Assessment (HIA) and by the Massachusetts Department of Environmental Protection (MassDEP) permitting process:

I.! Health Concerns Related to Existing Soil and Groundwater Contamination at the Proposed Site

Spectra Energy’s soil and groundwater testing at the proposed site demonstrates high levels of heavy metal contamination, particularly arsenic. Exposure to these heavy metals is associated with cancer, cardiovascular disease, diabetes, and impaired neurologic development. Spectra Energy inappropriately claimed that the soil at the site represented “historic fill,” thus exempting these contaminants from their risk assessment. Although this designation is now being challenged by the state, the HIA and the Spectra Energy risk assessment"consequently failed to consider the human health risk of the dispersion of these contaminants during construction and operation at this site.

We evaluate the documented soil and groundwater contamination at the proposed site and conclude that excavation of arsenic and other heavy metals poses an unacceptable risk to nearby residents, workers, and users of the adjacent King’s Cove Park, as well as to adjacent fishing stocks.

II.! Health Risks of Cumulative Exposures to Air Pollution Associated with the Proposed Compressor Station

The environmental exposures that will be introduced into the Fore River Basin by the proposed compressor station will not be singular insults to health that occur in a vacuum. Multiple air pollutants are already elevated above state-approved levels in the Fore River Basin and pose a threat to human health, according to air samples collected by MassDEP and by local residents. Furthermore, rates of certain cancers, heart disease, asthma, and chronic obstructive pulmonary disease (COPD) – all of which are associated with air pollution -- are already elevated in the Fore River Basin.

We provide a quantitative estimate of cancer and non-cancer risks associated with existing air pollutants in the Fore River Basin. We evaluate the additional burden of air pollutants that will be produced by the proposed compressor station and conclude that it poses a threat to human health.

2" "

III.! Contributions of the Proposed Facility to Ambient Sound Levels

Elevated ambient sound levels are associated with heart and lung disease, mental illness including depression, decreased ability to concentrate, and decreased academic performance in children. Monitoring campaigns have demonstrated nighttime sound levels at residences near the proposed site that are already at the World Health Organization’s (WHO) recommended limit. Routine operation of the proposed compressor station will elevate the sound level at these residences above the WHO recommended levels and intermittent events (e.g. testing the emergency generator scheduled and emergency blowdowns) will further increase sound levels.

We conclude that insufficient attention has been paid to the potential health effects of the noise that would be created by the proposed compressor station, particularly in the context of existing noise levels in the community. Consideration of these health impacts needs to be incorporated into all decision-making pertaining to the compressor station.

IV.! Recommendations:

A.! The state legislature should commence public hearings to examine: o! The flawed regulatory process that resulted in the approval of this project. These flaws include the failure to consider existing air pollution levels and population vulnerabilities, as well as the lack of a quantitative, cumulative risk assessment for potential residential exposures to soil and groundwater contaminants.

o! Why the Massachusetts DEP overturned the state’s own regulatory precedent in providing an air quality permit for the proposed project.

o! The impact that the proposed compressor station will have on the Commonwealth’s ability to meet its greenhouse gas reduction mandates under the Global Warming Solutions Act.

B.! The Massachusetts Department of Environmental Protection should: o! Overhaul its air quality permitting process to require independent external experts to perform air dispersion modeling and to ensure that models accurately reflect the meteorological conditions and geographic characteristics of a proposed site.

o! Solicit independent external reviews of the soil remediation plan put forward by Spectra Energy for the Weymouth site. 3" "

C.! The Massachusetts Department of Public Health should: o! Conduct comprehensive health impact assessments with improved transparency and scientific rigor. Such assessments should quantitatively assess the potential cumulative and interactive effects of multiple environmental exposures and should incorporate existing population vulnerabilities.

o! Request assistance from the U.S. Centers for Disease Control and Prevention to conduct an epidemiologic investigation of the disproportionately elevated disease rates (leukemia, asthma, heart disease, COPD and nasopharyngeal and bronchogenic tumors) in the Fore River Basin and their potential relationship to existing environmental exposures.

V.! Conclusion

We call on Governor Baker, the Massachusetts Department of Public Health and the Massachusetts Department of Environmental Protection to halt the construction of the compressor station in Weymouth. No regulatory framework can make this facility safe for the surrounding community or for residents of the Commonwealth.

4" " TABLE OF CONTENTS

I.! Background

II.! Existing Soil and Groundwater Contamination at the Proposed Site

III.! Health Effects of Cumulative Exposure to Existing Air Pollution in the Fore River Basin

IV.! Projected Emissions from Proposed Facility and their Potential Health Impact

V.! Contribution of the Proposed Facility to Ambient Sound Levels

VI.! Conclusions and Recommendations

VII.! Maps and Supporting Materials a.! Appendix A: Disease Rates in Census Tracts in the Fore River Basin b.! Appendix B: Population Size, Income, and Demographics in the Fore River Basin c.! Appendix C: Location of Nearby Schools d.! Appendix D: Underground Storage Tanks, Hazardous Material Sites, and Facilities with MassDEP Air Operating Permits e.! Appendix E: FEMA Flood Risk Zones, Hurricane Surge Inundation Areas

5" " I.! BACKGROUND "

About Greater Boston Physicians for Social Responsibility and Our Reports

Greater Boston Physicians for Social Responsibility (GB PSR) is a non-profit, volunteer organization of physicians, scientists and public health professionals. We are professionally qualified to comment on the expected health impacts of the construction and operation of a proposed 7,700 horsepower compressor station in Weymouth, Massachusetts.

GB PSR has published two previous reports1 in response to the proposed compressor station. In the first report, released in February 2019, we pointed out shortcomings, omissions and faulty assumptions in the methodology and conclusions of the state- commissioned health impact assessment (HIA). These flaws included, among others, the HIA’s disregard of the excess rates of lung disease, heart disease and cancer in the neighboring municipalities and the failure to account for existing elevated levels of air toxics. In our second report, released in May 2019, we outlined the unaddressed safety and emergency response hazards associated with the proposed compressor station due to the dense population of the surrounding neighborhoods and the extreme difficulty of evacuation given the very limited ingress and egress to the area.

In this report, we build on those prior evaluations and provide a comprehensive quantitative and qualitative assessment of the potential health risks posed by the proposed compressor station. We focus on three areas of concern that the state-commissioned Health Impact Assessment (HIA) and the Massachusetts Department of Environmental Protection (DEP) permitting process failed to address or inadequately addressed:

1.! The soil and groundwater contamination at the proposed site; 2.! The human health risk to surrounding communities of cumulative exposures to air toxics; and 3.! The noise impact of the proposed project. Our approach is consistent with that recommended by the DEP state hearing officer, Jane Rothchild, in her June 2019 decision in an appeal to the state’s air quality permit. Ms. Rothchild suggested that MassDEP review its longstanding practice of granting air quality permits based solely on an applicant’s emissions, without regard background levels of pollution. “Such a practice” she wrote in her opinion, “would likely reduce the levels of pollution in the ambient air and better protect the public health and the environment.”

""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 1"https://gbpsr.org/wp4content/uploads/sites/11/2019/05/compressor4public4safety4report.pdf;"https://gbpsr.org/wp4 content/uploads/sites/11/2019/02/gbpsr4report4weymouth4compressor4station.pdf" " 6" "

A Proposed Compressor Station in Weymouth Massachusetts

Algonquin Gas Transmission, LLC (a subsidiary of Spectra/Enbridge Energy) has proposed the construction and operation of a new interstate gas transmission compressor station at 50 Bridge Street in Weymouth, Massachusetts in the Fore River Basin. Weymouth is a coastal town, on the shores of Hingham Bay, and the town’s territory includes Grape Island, Slate Island and Sheep Island, all of which are part of the Boston Harbor Islands National Recreation Area. Four communities (Quincy, Weymouth, Braintree and Hingham) surround the site, and immediately adjacent to the site are three densely populated, low- income, heavily minority residential neighborhoods (Quincy Point, Germantown and North Weymouth). Two neighborhood parks (King’s Cove and Lovell’s Grove), which are among the only parcels of undeveloped land in the area, share a property line with the proposed site.

The residential community in the Fore River basin is surrounded by existing heavy industrial development, including gas and oil storage tanks, a hazardous waste processing facility, a biofuel processing facility, a fertilizer processing and pelletizing plant, a municipal power plant, one of the largest gas and oil fired power generating plants in the state, a metering and regulating station, and a sewage pumping station. The Fore River is also a Designated Port Area that sees heavy traffic by ocean vessels, tugs, and ferries, and provides water-dependent industrial uses. A bridge over the Fore River between Quincy and Weymouth is adjacent to the proposed site and is a major commuting route used by more than 30,000 vehicles each day.

The proposed compressor station will be used to expand the Algonquin Gas Transmission pipeline system to increase transportation and allow exportation of natural gas, extracted by hydraulic fracturing, onto the Maritimes and Northeast Pipeline, LLC system that connects the northeastern United States and Canada. The proposed compressor station is also a central component of the Atlantic Bridge Project, the goal of which is to sell U.S. natural gas to international markets. The proposed compressor station would be equipped with a 7,700-horsepower natural gas-fired turbine-driven compressor unit, with an additional turbine unit planned under a subsequent pipeline expansion. Emissions from the proposed compressor station will result from the gas-fired systems, from planned and emergency gas releases (“blowdowns”), from leaks from above ground components, and from separator vessels and storage tanks. The yearlong construction process will also require diesel-powered equipment that will produce emissions. Per company testimony, the construction process will also aerosolize approximately 1,000 cubic yards of soil that is known to be contaminated with toxic chemicals and heavy metals.

7" " In January 2017, the Federal Energy Regulatory Commission granted permission for construction of the compressor station, on the condition that the company receive the appropriate permits and approvals from the state. The Massachusetts Department of Environmental Protection (MassDEP) provided three permits, for air quality, wetlands, and waterways. The wetlands permit was issued in 2016, the waterways permit was issued in May 2017, and the air quality permit was issued earlier this year. These decisions were appealed by the town of Weymouth and are still under appeal. The Massachusetts Office of Coastal Zone Management is currently reviewing whether the project complies with relevant coastal land management laws.

In July 2017, Governor Baker directed the Massachusetts Department of Public Health (DPH) and MassDEP to perform a health impact assessment (HIA) focused on the air quality impacts of the proposed compressor station. The HIA was performed by the Metropolitan Area Planning Council. The final 156-page report was published in early January 20192 and was accompanied by 79 pages of appendices.3 As stated in the preface of the HIA document, the purpose of the HIA was to “identify unanticipated health effects in advance of decision-making and allow stakeholders and policymakers to integrate health protection and promotion into their decisions.” The HIA concluded that any health effects resulting from direct exposure to the air and noise emissions from the proposed facility during operation were “unlikely”. Per the HIA, health effects from direct exposure to noise emissions during construction were possible, but it concluded that the relative magnitude of these effects would be low.

MassDEP issued an air quality permit for the proposed compressor station approximately one week after the HIA was released, on January 11, 2019. The permit was appealed by the towns of Weymouth, Quincy, Braintree, and Hingham, as well as by a group of residents. The permit appeal hearings began in May 2019, but were delayed until mid-June, because it was revealed during the hearing that MassDEP had failed to submit relevant air monitoring data. On June 27, 2019, the state adjudicator presiding over the hearing, Jane Rothchild, recommended that MassDEP reject the appeal and uphold the air quality permit, which the department did on July 12, 2019.

The adjudicator added a requirement that blowdowns be limited to two per year and that future HIAs consider the cumulative effect of pollutants as well as existing pollution from current infrastructure on human health.

""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 2"http://foreriverhia.com/wp4content/uploads/2019/01/Final4Report_20190104.pdf" 3"http://foreriverhia.com/wp4content/uploads/2019/01/Appendices_20190104.pdf" 8" " II.! EXISTING SOIL AND GROUNDWATER CONTAMINATION AT THE PROPOSED SITE

The Lovell’s Grove/Ferry Point area of Weymouth, where the compressor station is proposed to be sited, is a longstanding industrial site, and the land itself is comprised of accumulated industrial waste. From the 1860s until 1909, the Lovell’s Grove area was home to a 10-acre park. The area was then filled with coal ash in the early 1900s before the 1925 construction of the Charles Edgar-Edison Electric Power Station—the first coal-fired, high pressure steam power plant in the world. Coal ash refers to by-products of coal burning; it naturally contains heavy metals, like arsenic, mercury, and cadmium.

Spectra Energy produced a “Permanent Solution with Conditions Statement Report,”4 which includes the results of soil and groundwater sampling conducted at the site and a risk assessment for potential exposures to identified soil and groundwater contaminants. This report confirms existing contamination at the site, including soil and groundwater measurements that indicate high levels of arsenic, well above the screening levels established by Massachusetts DEP.5

There are three important limitations with the “Permanent Solution with Conditions Statement Report” produced by Spectra Energy:

1) The report attributes the measured heavy metals to ‘historic fill’ and therefore excludes these contaminants from the list of ‘compounds of potential concern’ in the risk assessment;

2) The report fails to consider key populations (‘receptors’) who are vulnerable to the effects of heavy metals, such as children, those with underlying health conditions, and the elderly; and

3) The report fails to consider that workers will be exposed to ambient air pollutants, along with toxic soil contaminants; these could have additive effects.

""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 4"TRC"Environmental"Corporation."2018."PERMANENT"SOLUTION"WITH"CONDITIONS"STATEMENT" REPORT."Volume"I"of"IV." 5"Screening"levels"are"levels"of"a"given"contaminant"below"which"no"remedial"action"is"necessary."These"are"calculated"by" MassDEP"and"used"by"property"owners"when"conducting"site"assessments"in"compliance"with"the"Massachusetts" Contingency"Plan."These"values"are"intended"to"protect"human"health"and"the"environment"and"different"categories"of" the"screening"levels"denote"different"scenarios"on"which"the"screening"levels"were"based"(e.g."GW41,"GW42,"and"GW43"for" different"groundwater"scenarios)." 9" "

a) Spectra Energy identified heavy metal soil contamination at the proposed site in Weymouth in its Permanent Solution with Conditions Statement Report

The Massachusetts Contingency Plan (310 CMR 40.00) requires owners to assess their property for hazardous material contamination and to calculate health risks associated with the use of contaminated land. For soil, the Massachusetts Contingency Plan sets the “S-2” level based on a risk of harm to human health and the environment; this represents the concentration below which no remediation is required. The Massachusetts Contingency Plan’s Upper Concentration Limit (UCL) corresponds to 10 times the “S-2” level for all contaminants except arsenic. Levels above the UCL are considered to pose significant risk to public welfare and require appropriate actions to remediate. The MCP “background” level is the level of soil contamination that would be expected to exist if the prior polluting activities had not occurred. Remedial actions taken by an applicant are supposed to reduce contaminant levels to near or below the background levels.

Table 1 shows the soil measurements performed by Spectra Energy at the site in Weymouth. There are detectable levels of all measured heavy metals, and the levels of arsenic are particularly elevated. The maximum concentration of arsenic identified at the site is more than ten times higher than the “S-2” concentration, indicating that remedial action to reduce arsenic in the soil should be taken to protect public welfare and the environment.

10" " Table 1. Maximum soil concentrations of four heavy metals measured in Weymouth, MA and the relevant Massachusetts Contingency Plan screening level, upper concentration limit, and background concentration

Maximum Soil Concentration Massachusetts Massachusetts Measured in Contingency Plan Background Contingency Heavy Metal Weymouth by Upper Concentration Plan S-26 Spectra Energy Concentration Limit7 (mg/kg) (mg/kg) (mg/kg) (mg/kg)

Arsenic 228 20 500 20 Cadmium 2.9 100 1,000 2 Lead 43.2 600 6,000 100 Mercury 0.4 30 300 0.3

While the maximum concentrations of the heavy metal contaminants other than arsenic are below the “S-2” levels, we contend that there is no threshold for safe exposure to these heavy metals (see discussion below of the human health risks of exposures to heavy metals) and that exposure of nearby residents should be prevented.

b) Spectra Energy identified heavy metal groundwater contamination at the proposed site in Weymouth in its Permanent Solution with Conditions Statement Report

For groundwater, the Massachusetts Contingency Plan “GW-3” level represents the concentration below which no remediation is required. A lower, “GW-1” threshold is applied when there is potential for the use of the groundwater as a drinking water source.

Table 2 shows the maximum concentrations of heavy metals measured in the groundwater in Weymouth. Arsenic was detected at a level of 7 μg/L. This concentration of arsenic is very close to the groundwater screening level applied when the groundwater is used as a drinking water source (GW-1). Construction of the proposed construction site will disrupt the arsenic-contaminated soil and may lead to further contamination of groundwater at the site.

""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 6"Under"the"Massachusetts"Contingency"Plan,"the"S42"values"represent"the"concentrations"under"which"no"remediation"is" required."These"are"health4protective"values,"based"upon"a"risk"of"harm"to"human"health"and"the"environment."S42"values" are"“based"on"property"uses"associated"with"moderate"exposure"and"accessible"soil,"either"currently"or"in"the"foreseeable" future."Additional"criteria"are"established"for"the"protection"of"groundwater,"based"on"the"leaching"potential"of"the" contaminated"soil.”" 7"The"Upper"Concentration"Limit"(UCL)"is"also"a"health4protective"value"used"for"risk"assessment"at"sites"with" contaminated"soil"and/or"groundwater."The"UCL"corresponds"to"10x"the"highest"exposure4related"standard,"which"is"S42" here"for"all"but"arsenic." 11" "

Table 2. Maximum groundwater concentrations measured in Weymouth, MA for four heavy metals and the relevant Massachusetts Contingency Plan screening levels.

Maximum Groundwater Massachusetts Massachusetts Concentration Heavy Metal Contingency Plan Contingency Plan Measured in GW-1 (μg/L) GW-38 (μg/L) Weymouth (μg/L) Arsenic 7 10 900 Cadmium 4.0 (non-detect) 5 4 Lead 10 (non-detect) 15 10 Mercury 0.20 (non-detect) 2 20

c) Human health risks of exposure to heavy metals

Heavy metals are toxic to humans across a range of exposure levels, and there may in fact be no safe level of exposure to these contaminants.

Acute exposure to high levels of arsenic is associated with vomiting, diarrhea, muscle cramps, and, in very severe cases, death.9 Chronic exposure to arsenic is associated with cancer, cardiovascular disease, and diabetes, and it may have negative effects on children’s neurodevelopment. Recent research has identified an increased risk for cardiovascular disease, coronary heart disease, stroke, lung cancer, and prostate cancer after chronic exposure to low doses (i.e. <100μg/L) in drinking water.10,11

The other heavy metals measured in soil and groundwater, including cadmium, lead, and mercury, also pose threats to human health, even at low-dose exposures. Mercury is a very toxic element that humans are often exposed to through consumption of fish and shellfish. Coal burning is a major source of mercury in the environment. Mercury is a well- established neurotoxin, but has also been associated with kidney damage, miscarriage, and premature birth. Lead, a potent neurotoxin, is found in indoor dust from leaded paints, in soils from historic sources like leaded gasoline, and sometimes in water sources from

""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 8"Under"the"Massachusetts"Contingency"Plan,"the"GW43"values"represent"the"concentrations"under"which"no"remediation" is"required."These"are"health4protective"values,"based"upon"a"risk"of"harm"to"human"health"and"the"environment."The" GW43"values"are"based"on"“potential"environmental"effects"resulting"from"contaminated"groundwater"discharging"to" surface"water.”"GW41"corresponds"to"thresholds"for"when"there"is"potential"for"the"use"of"the"groundwater"as"a"drinking" water"source." 9"https://www.who.int/news4room/fact4sheets/detail/arsenic" 10"Garcia4Esquinas,"E.,"Pollan,"M.,"Umans,"J.G.,"Francesconi,"K.A.,"et"al."2013."Arsenic"Exposure"and"Cancer"Mortality"in"a" US4based"Prospective"Cohort:"the"Strong"Heart"Study."Cancer"Epidemiology,"Biomarkers"&"Prevention."doi:" 10.1158/105549965.EPI413402344T" 11"Moon,"K.A.,"Guallar,"E.,"Umans,"J.G.,"Devereux,"R.B.,"et"al."2013."Association"between"Low"to"Moderate"Arsenic" Exposure"and"Incident"Cardiovascular"Disease."A"Prospective"Cohort"Study."Annals"of"Internal"Medicine."doi:" 10.7326/00034481941594104201311190400719" 12" " leaded pipes. The presumed threshold of lead’s neurotoxicity has been progressively lowered, as researchers continue to find increased risk of certain health outcomes at doses lower than what was previously believed to be safe, leading many researchers and public health officials to conclude that there is no safe level of exposure.12 Cadmium is a well- established kidney toxin that can accumulate in the body for years. High levels of exposure can also disturb calcium metabolism and cause bone softening. Common sources of cadmium exposure in humans include firsthand and secondhand tobacco smoke and consumption of contaminated foods, such as shellfish.13

In addition to the effects of exposure to individual heavy metals, there is growing evidence that exposure to multiple heavy metals can have a synergistic effect on certain neurobehavioral outcomes.14,15

d) Spectra Energy excluded the documented heavy metal ground and soil contamination from the risk assessment presented in its Permanent Solution with Conditions Statement Report

Historic fill is defined by MassDEP as “fill material which was brought into the disposal site from another location and is not primarily composed of debris”.""MassDEP provides seven criteria16 for defining historic fill17 and explicitly states that “where these other materials are the source of [oil and hazardous materials] and they comprise the majority of the filled area, that condition would not be considered historic fill.” MassDEP further states that to qualify as “historic fill” the site must have arsenic concentrations < 100

""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 12"Bellinger,"D.C."2008."Very"low"lead"exposures"and"children's"neurodevelopment."Current"opinions"in"pediatrics.""doi:" 10.1097/MOP.0b013e3282f4f97b." 13"https://www.who.int/ipcs/features/cadmium.pdf?ua=1" 14"Horton,"M.K.,"Hsu,"L.,"Claus"Henn,"B.,"Margolis,"A.,"et"al."2018."Dentine"biomarkers"of"prenatal"and"early"childhood" exposure"to"manganese,"zinc"and"lead"and"childhood"behavior."Environment"International." doi.org/10.1016/j.envint.2018.08.045"" 15"Valeri,"L.,"Mazumdar,"M.M.,"Bobb,"J.F.,"Claus"Henn,"B.,"et"al."2017."The"Joint"Effect"of"Prenatal"Exposure"to"Metal" Mixtures"on"Neurodevelopmental"Outcomes"at"20440"Months"of"Age:"Evidence"from"Rural"Bangladesh."Environmental" Health"Perspectives."doi:"10.1289/EHP614." 16"“a)""was"emplaced"before"January"1,"1983"(the"effective"date"of"MGL"c21E;""(b)""may"contain,"but"is"not"primarily" composed"of,"construction"and"demolition"debris,"reworked"soils,"dredge"spoils,"coal,"coal"ash,"wood"ash"or"other"solid" waste"material;"(c)""was"contaminated"with"metals,"hydrocarbons,"and/or"polycyclic"aromatic"hydrocarbons"prior"to" emplacement,"at"concentrations"consistent"with"the"pervasive"use"and"release"of"such"materials"prior"to"1983;""(d)""does" not"contain"oil"or"hazardous"materials"originating"from"operations"or"activities"at"the"location"of"emplacement;"""(e)""is"not" and"does"not"contain"a"generated"hazardous"waste,"other"than"Oil"or"Waste"Oil;""(f)""does"not"contain"chemical" production"waste,"manufacturing"waste,"or"waste"from"processing"of"metal"or"mineral"ores,"residues,"slag"or"tailings;"and"" (g)""does"not"contain"waste"material"disposed"in"a"municipal"solid"waste"dump,"burning"dump,"landfill,"waste"lagoon"or" other"waste"disposal"location.”" 17"https://www.mass.gov/files/documents/2016/08/qj/draft4historic4fill4technical4update42016405420.pdf" 13" " mg/kg; this is less than the maximum concentration measured at the proposed site in Weymouth (Table 1; 228 mg/kg).

Spectra Energy therefore inaccurately claimed that the industrial waste at the site represented ‘historic fill’, thus exempting their “Permanent Solution with Conditions Statement Report” from the requirement to assess the human health risk of potential exposure to these heavy metals.

e) Spectra Energy excluded vulnerable populations from the risk assessment in its Permanent Solution with Conditions Statement Report

The risk assessment in Spectra Energy’s “Permanent Solution with Conditions Statement Report” only considers the health risks of exposure to contaminated soil and groundwater among future commercial workers and future construction workers; it fails to consider residents or users of the local park spaces (e.g. nearby King’s Cove Park), particularly those who may be especially vulnerable to the effects of heavy metal exposure (i.e. children, those with underlying health conditions, and the elderly). The Spectra Energy report states that residents and park users will not be exposed to toxic soil contaminants because of the current presence of pavement, vegetation, and a fence; however, they offer no evidence in support of this assertion or demonstration that a fence can meaningfully separate the nearby park users from soil contaminants potentially dispersed during excavation.

The Spectra Energy report acknowledges that there will be future soil disturbances during construction of the proposed compressor station that will be performed under a Health and Safety Plan and a Groundwater and Soil Management Plan, which has yet to be developed. However, their report is not convincing in its assurances that residents and park users will be unexposed. The state-commissioned HIA confirmed that the creation of dust during the construction phase is one potential avenue for health effects. We note that state regulations requiring tenting and other interventions to prevent the dispersion of metals and petroleum-based soil contaminants.

f) Spectra Energy failed to conduct a comprehensive risk assessment for workers

Spectra Energy’s “Permanent Solution with Conditions Statement Report” did not account for cumulative risk to workers, including the combined effect of exposure to soil contaminants and exposure to pre-existing elevated concentrations of air toxics and criteria air pollutants in this region (as described in detail in the following section of this report).

14" "

g) Additional concerns regarding soil and groundwater contamination at the site

Residents of the surrounding towns have repeatedly raised concerns about the coal ash and heavy metal contamination at the proposed site and the erosion of this area into King’s Cove (Figure 1). The proposed site is also at risk of flooding—part of the plot is in a FEMA flood risk zone, and the entire plot would be inundated in the event of a hurricane (Appendix E). There are similar scenarios across the U.S., in which coal ash contamination is seeping into waterways through erosion, flooding, or industrial accidents.18,19 A report published this year by the Environmental Integrity Project, based on EPA’s groundwater monitoring data, concluded that the groundwater near 9 out of 10 coal-fired power plants was contaminated with high levels of heavy metals, like arsenic and chromium.20

Figure 1. Photograph showing exposed cinder and coal ash along King’s Cove Bay, next to the proposed construction site (photo credit: Dr. Matt Bivens)

This report focuses on the human health impacts of the proposed compressor station and activities related to its construction, but we underscore that the Fore River Basin serves an important ecological role as the location of one of the largest smelt spawning runs in Massachusetts.21 The area has seen a resurgence of the river herring populations in recent

""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 18"https://www.epa.gov/tn/epa4response4kingston4tva4coal4ash4spill" 19"https://www.sciencedaily.com/releases/2019/06/190603124715.htm" 20"https://www.environmentalintegrity.org/coal4ash4groundwater4contamination/" 21"http://www.sustainablebraintree.org/Fore_River_Spawning_Habitat.pdf" 15" " decades, in part due to substantial state and federal investments in projects to improve their habitat.22,23 These fish populations are important to the larger fish and animal populations that benefit from their resurgence. These include cod, haddock, striped bass, and lobster that are fished locally and throughout New England. Any contamination of the Fore River Basin waterways with coal ash containing heavy metals poses a threat to these already fragile herring populations and to the fisheries that rely on their success. If high amounts of heavy metals, like mercury, accumulate in the herring, we could also see higher levels in the larger fish that consume them, which ultimately means that humans who consume these fish will also be exposed.

We also know from anecdotal accounts that some individuals in Weymouth, Braintree, and Quincy fish and harvest clams as a food source, which could put them at risk of being exposed to any heavy metals and other contaminants that will contaminate these waterways during construction and operation of this compressor station.

During the writing of this report, MassDEP entered into an Administrative Consent Order (ACO) with Algonquin LLC (the subsidiary of Spectra Energy) to institute an enforceable schedule for the company to “address deficiencies in its assessment and cleanup of the site of the proposed compressor station.” During an audit of Spectra Energy’s “Permanent Solution with Conditions Statement Report,” MassDEP identified multiple insufficiencies and errors. These included some of the concerns we have raised here—such as the designation of coal ash contamination as ‘historic fill’—in addition to concerns about other contaminants at the site. The original deadline to address these issues and conduct additional samples and analyses was July 19, 2019, which Algonquin did not meet. The additional sampling and analyses are now due January 17, 2020, as established by the ACO.

h) Conclusion

We evaluated the documented soil and groundwater contamination and conclude that excavation of arsenic and other heavy metals at the proposed site poses a risk to nearby residents, workers, and users of the adjacent King’s Cove Park, as well as to adjacent fishing stocks. We consider it unacceptable that Spectra Energy did not assess potential residential exposure to soil and groundwater heavy metal contamination in its risk assessment in the “Permanent Solution with Conditions Statement Report”.

""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 22"https://holbrook.wickedlocal.com/news/20160721/fore4river4watershed4herring4run4project4has4legs" 23"https://www.mass.gov/service4details/fore4river4watershed4restoration4braintree4ma" 16" " III.! HEALTH EFFECTS OF COMBINED EXPOSURE TO EXISTING AIR POLLUTION IN THE FORE RIVER BASIN

a)! There are multiple existing sources of air pollution in the Fore River Basin; these were disregarded by the state-commissioned HIA

The state-commissioned HIA failed to assess the cumulative human health risk that would result from adding new emissions from the proposed compressor station to current levels of air pollution in the Fore River Basin. In other words, the state-commissioned HIA treated each pollutant of concern from the proposed compressor station as an isolated exposure that occurs without concurrent exposure to other air pollutants.

Importantly, the state-commissioned HIA made a false assumption that the proposed compressor station would be the only source of emissions in the Weymouth area. In fact, the 2-kilometer ‘focus area’ around the proposed facility currently contains four facilities with MassDEP Air Operating Permits, as shown in Figure 2.

Figure 2. Facilities with MassDEP air operating permits in the Fore River Basin

17" " The focus area also includes eight facilities included in the U.S. EPA National Emissions Inventory (NEI), as shown in Figure 3. The National Emissions Inventory24 is a comprehensive and detailed estimate of air emissions that is released every three years by the U.S. EPA.

Figure 3. Facilities in the Fore River Basin included in the 2014 U.S. EPA National Emissions Inventory

b)! Measurement of existing air pollution levels in the Fore River Basin

Two groups have measured the existing level of air pollution in the Fore River Basin in recent years. First, a group of concerned citizens conducted independent air monitoring close to the proposed compressor station site and in nearby residential areas in 2017. Second, MassDEP performed two air monitoring campaigns in the Fore River Basin during the summer and fall of 2018, as part of the state-commissioned HIA. The first phase of MassDEP air monitoring was comprised of 7 days of volatile organic compound (VOC) monitoring conducted at five locations for 24 hours on every sixth day for 7 weeks in July and August. The second phase, conducted from August 1 to November 30, involved semi- continuous air monitoring for benzene, toluene, ethylbenzene, and xylenes, as well as 24-

""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 24"https://www.epa.gov/air4emissions4inventories/national4emissions4inventory4nei" 18" " hour samples of formaldehyde and acetaldehyde every 6 days, at the Weymouth Metropolitan Water Resource Authority pump station, which is near the proposed site for the compressor station.

Table 3 shows the measurements of air toxics from the Fore River Basin, along with the EPA and the MassDEP threshold concentration that regulators use to identify findings of concern.

Table 3. Measured levels and threshold levels for evaluating cancer risks of air toxics in Weymouth, Quincy, and Braintree25

Maximum Concentrations U.S. EPA Massachusetts U.S. EPA Unit Risk from MassDEP Reference Pollutant Allowable Ambient Estimate (URE) First Phase Concentration Limit (AAL) (µg/m3) (1/µg/m3) Monitoring, Fore (RfC) (µg/m3) River Basin (µg/m3) Measurements Thresholds Risk Estimate Formaldehyde Not Measured 9.8 0.08 0.000013 Benzene 0.482 30 0.1 0.0000078 Carbon 0.549 100 0.07 0.000006 Tetrachloride Acetaldehyde 2.5 9 0.4 0.0000022 1,3-Butadiene 0.0508822 2 0.003 0.00003 Naphthalene 1.55 3 14.25 0.000034 Acrolein Not Measured 0.35 0.07 N/A Diesel Particulate Not Measured 5 N/A N/A Matter

c)! Assessment of Cancer Risk from Exposure to Existing Levels Air Toxics in Weymouth, Braintree and Quincy, based on data collected by Local Citizens and MassDEP

""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 25"The"URE"is"the"EPA’s"upper4bound"estimate"of"the"excess"cancer"risk"resulting"from"daily"exposure"to"1"µg/m3"of"an"air" pollutant"across"the"entire"lifetime."The"RfC"is"the"EPA’s"best"estimate"of"the"concentration"of"an"air"pollutant"that" humans"can"be"exposed"to"continuously"for"a"lifetime"without"a"substantial"increase"in"their"risk"for"adverse,"non4cancer" health"outcomes."This"estimate"accounts"for"potential"susceptibility"of"certain"“sensitive"subgroups.”"It"should"be"noted" that"there"is"a"substantial"amount"of"uncertainty"surrounding"RfC"estimates,"so"they"should"not"be"treated"as"definitive" thresholds,"but"rather"a"reference"to"put"exposure"levels"into"context." The"AAL"is"often"based"on"the"MassDEP’s"Non4Threshold"Effects"Exposure"Limit"(NTEL)"for"known"or"suspected" carcinogens."The"NTEL"is"the"concentration"of"a"given"air"toxic"that"is"associated"with"an"excess"cancer"risk"of"1"in"1" million,"assuming"continuous"exposure"to"that"concentration"over"a"lifetime."MassDEP"factors"into"these"estimates"the" potential"for"exposure"to"these"air"toxics"through"exposure"media"other"than"ambient"air"(i.e."they"typically"assume"20%" of"an"individual’s"exposure"comes"through"ambient"air,"while"the"other"80%"comes"from"other"media)."By"accounting"for" exposures"through"other"sources,"MassDEP"is"acknowledging"the"importance"of"cumulative"risk"assessment,"a"concept" they"failed"to"incorporate"in"the"HIA." 19" " We sought to understand the cancer risk associated with the existing air pollution levels in the Fore River Basin, since such an assessment was not performed by the state- commissioned HIA. To do this, we applied the risk assessment methodology used in the U.S. EPA National Air Toxics Assessment (NATA), a recurring assessment of air toxics in the U.S. that is widely used as a screening tool by public health officials across the country.26

Table 4 summarizes the total cancer risk that we calculated for the Fore River Basin based on the average measured concentrations, as well as the maximum measured concentrations, of air toxics.27

""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 26"https://www.epa.gov/national4air4toxics4assessment" 27"To"convert"ambient"concentrations"to"exposure"concentrations,"we"applied"the"average"adjustment"factor"used"in"the" NATA"for"each"of"the"pollutants."Average"concentrations"for"pollutants"during"the"first"round"of"the"air"monitoring" conducted"by"MassDEP"were"not"reported"in"the"HIA,"so"we"used"the"maximum"value"reported."These"maximum" concentrations"may"overestimate"risks,"however,"there"was"limited"temporal"variability"in"the"monitoring"data"conducted" by"MassDEP"so"annual"averages"could"not"have"been"estimated"even"with"the"average"concentrations"from"this"round"of" air"monitoring."It"should"be"noted"that"not"all"eight"air"pollutants"listed"in"the"tables"above"were"monitored"for"the"HIA"or" by"citizens"in"these"three"municipalities."For"these"pollutants,"we"used"the"maximum"annual"average"value"from"the"NATA" for"Quincy."For"risk"calculations"using"the"air"monitoring"data"from"the"Fore"River"Basin,"we"did"not"separate"the" monitored"values"or"risk"calculations"by"municipality."

" 20" " Table 4. Cancer risk calculated using air monitoring data from the Fore River Basin

Cancer Risk Regulatory Thresholds 28 Benzene National Total Cancer Total Cancer MA Emission Standard MassDEP Risk per million, Risk per million, Location and Data Contingency for Hazardous Air AAL and (based on (based on Source Plan, Pollutants NTEL, average maximum per million (NESHAP), goal per million concentration) concentration) per million Fore River Basin, 1 for average MassDEP First (Averages not exposures; 74.3 10 1 Phase monitoring reported in HIA) 100 for highest exposure scenario Fore River Basin, 1 for average Citizen 24-hour exposures; 35.3 100 10 1 monitoring29,30 100 for highest exposure scenario Fore River Basin, 1 for average MassDEP Second exposures; 44.2 110 10 1 Phase 100 for highest monitoring31 exposure scenario

Our findings demonstrate that existing air pollutants in the Fore River Basin represent an unacceptable cancer risk per established regulatory thresholds, even prior to the construction of the proposed compressor station. Furthermore, our estimates are consistent across different air monitoring efforts, enhancing our confidence that existing air pollution levels in this region are above thresholds deemed protective of human health. These findings indicate that action is currently needed to reduce the concentrations of hazardous air pollutants in the Fore River Basin.

""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 28"Different"governmental"bodies"use"different"thresholds"to"determine"what"levels"of"cancer"risk"are"acceptable."The" Massachusetts"Contingency"Plan"(310"CMR"40.00)"states"that"a"site"poses"an"imminent"hazard"if"the"resulting"excess" lifetime"cancer"risk"is"greater"than"10"per"million28."The"National"Oil"and"Hazardous"Substances"Pollution"Contingency"Plan" (40"CFR"300)"states"that"excess"cancer"risk"exceeding"100"per"million"is"unacceptable28."The"U.S."EPA"does"not"define" unacceptable"cancer"risk"thresholds"for"air"pollutants."However,"the"Benzene"National"Emission"Standard"for"Hazardous" Air"Pollutants"(NESHAP)"rule"states"that"a"cancer"risk"of"100"per"million"for"the"most"exposed"person"is"the"upper4limit"of" acceptable"risk."The"same"rule"says"that"the"goal"is"to"keep"cancer"risk"for"most"people"to"a"lifetime"risk"of"no"more"than"1" per"million."The"MassDEP"AAL’s"are"based"on"the"NTELs,"which"correspond"to"a"lifetime"cancer"risk"of"1"per"million," however,"it"should"be"noted"that"the"AALs"are"not"regulatory"levels,"but"health4protective"guidelines. 29"For"cancer"risk"estimates,"we"included"concentrations"of"dichloromethane,"ethylbenzene,"24hexanone,"and"carbon" disulfide"as"these"pollutants"were"measured"at"relatively"high"levels."Only"respiratory"hazards"were"included"in"the" respiratory"hazard"index,"which"does"not"include"the"hazard"quotients"for"dichloromethane"and"24hexanone,"which"are" listed"separately." 30"Average"concentrations"were"calculated"assuming"ND"were"equal"to"RL/2." 31"Maximum"concentration"for"benzene"and"acetaldehyde"were"the"best"guesses"based"on"the"figures"in"Appendix"E"of" the"HIA." 21" "

d)! Assessment of Non-Cancer Risk from Exposure to Existing Air Toxics in Weymouth, Braintree and Quincy, based on data collected by Local Citizens and MassDEP

We also calculated the non-cancer risks associated with exposure to the measured levels of air toxics in the Fore River Basin. Non-cancer risks are often expressed as “hazard quotients.” A hazard quotient below 1 can be interpreted to mean that no adverse effects are expected to result from exposure. A hazard quotient above 1 does not automatically mean that adverse health effects are expected, but it does mean that the risk for these outcomes is elevated and warrants concern. To address the potential health effects due to exposure to multiple air toxics at once, we estimated the “hazard index.” The hazard index represents the sum of the hazard quotients for pollutants with the same endpoint (e.g. multiple pollutants all affecting the respiratory system). Like the hazard quotient, a hazard index below 1 indicates that exposure to the pollutant or pollutants is considered unlikely to cause any adverse non-cancer health outcomes, given a person is exposed to the stated exposure levels continuously for their lifetime. Both MassDEP and the U.S. EPA use a hazard index above 1 as the threshold for non-cancer outcomes.

Table 5 shows the hazard index for respiratory outcomes that we calculated based on the measured levels of air pollutants in the Fore River Basin. The use of hazard indices represents a cumulative risk approach, as we are incorporating multiple chemical exposures into our final risk estimates.

22" "

Table 5. Non-Cancer Risks Associated with Current Pollution Levels in the Fore River Basin

Non-Cancer

Hazard Index (respiratory), Hazard Index (respiratory), Location and Data Source Average Concentrations Maximum Concentrations

Fore River Basin, (Averages not reported in 1.01 MassDEP First Phase monitoring HIA) 0.32 for respiratory; 0.32 for respiratory; Fore River Basin, 8.8 for dichloromethane; 103 for dichloromethane; Citizen 24-hour monitoring32,33 0.43 for 2-hexanone 4.81 for 2-hexanone Fore River Basin, 0.51 1.12 MassDEP Second Phase monitoring34

Our findings show that the maximum measured concentrations of air toxics, as evaluated by MassDEP, pose a respiratory hazard to the health of the residents of the Fore River Basin. The monitoring conducted by the group of local citizens also demonstrates that two air pollutants (dichloromethane and 2-hexanone) are well above the threshold hazard index of 1.

e)! Other Air Pollutants in the Fore River Basin

We included only selected air toxics in our estimate of cancer risk and non-cancer hazards in the Fore River Basin. However, there many important air pollutants (also known as ‘criteria air pollutants’35) that we did not consider in our analysis: ozone, carbon monoxide, particulate matter, nitrogen dioxide, sulfur dioxide, and lead. Most of these pollutants are associated with respiratory outcomes (like asthma), stroke and cardiovascular disease, which means their impacts can and should be combined with the non-cancer hazard estimates for air toxics. Compressor stations are documented sources of these criteria air pollutants, and the state-sponsored HIA acknowledges that the proposed facility will contribute emissions of particulate matter, nitrogen dioxide (NO2), sulfur dioxide, and carbon monoxide. Furthermore, the data presented by Spectra Energy in the “Updated """"""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 32"For"cancer"risk"estimates,"we"included"concentrations"of"dichloromethane,"ethylbenzene,"24hexanone,"and"carbon" disulfide"as"these"pollutants"were"measured"at"relatively"high"levels."Only"respiratory"hazards"were"included"in"the" respiratory"hazard"index,"which"does"not"include"the"hazard"quotients"for"dichloromethane"and"24hexanone,"which"are" listed"separately." 33"Average"concentrations"were"calculated"assuming"ND"were"equal"to"RL/2." 34"Maximum"concentration"for"benzene"and"acetaldehyde"were"the"best"guesses"based"on"the"figures"in"Appendix"E"of" the"HIA." 35"https://19january2017snapshot.epa.gov/criteria4air4pollutants_.html" 23" " Air Dispersion Modeling Report” from May 2018 demonstrates that levels of fine particulate matter (less than 2.5 µm in diameter or PM2.5) in the Fore River Basin combined with expected emissions would result in concentrations (7.97 µg/m3) that have been associated with increased risk for all-cause mortality in a recent epidemiological study.36 There is also evidence that PM2.5 concentrations below the NAAQS standard may be linked with increased risk for emergency room visits for pediatric asthma,37 an outcome for which Weymouth already ranks in the top quartile in the state (Appendix A).

f)! Limitations of Our Approach to Risk Assessment

There are several reasons why our risk and hazard estimates may underestimate the potential health risks in the Fore River Basin. First, the air monitoring data that was performed in the Fore River Basin may not be representative of year-round concentrations.38 Concentrations of air toxics are generally higher in the winter, and the available measurements were taken in the summer. Second, we did not consider additional non-inhalation exposure routes or indoor sources of air toxics. Third, our approach assumes that these exposures affect cancer risk and non-cancer hazard in an additive manner and does not address the possibility that exposures to multiple chemicals could result in synergistic effects (i.e. the cumulative effects are greater than the sum of the individual effects). Fourth, our approach does not account for exposures to pollutants not designated as air toxics (e.g. criteria air pollutants) nor does it account for non-chemical stressors (e.g. noise, housing/neighborhood characteristics) or population-specific vulnerabilities. For these reasons, it is entirely plausible that our risk and hazard estimates may underestimate the potential health risks.

g)! Environmental justice considerations

The state-commissioned HIA identified that residents of the three municipalities surrounding the proposed facility (Weymouth, Quincy, and Braintree) have higher rates of heart attack and chronic obstructive pulmonary disease hospitalizations compared to the state average, as well as elevated rates of certain cancers (including lung and oral cavity/pharynx). Most census tracts in the 2-kilometer ‘focus area’ around the proposed compressor station site are in the top two quartiles in the state for both lung and bronchus

""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 36"Di,"Q.,"Wang,"Y.,"Zanobetti,"A.,"Wang,"Y.,"et"al."2017."Air"Pollution"and"Mortality"in"the"Medicare"Population."New" England"Journal"of"Medicine."doi:"10.1056/NEJMoa1702747" 37"Bouazza,"N.,"Foissac,"F.,"Urien,"S.,"Guedj,"R.,"et"al."2017."Fine"particulate"pollution"and"asthma"exacerbations."Archives" of"Disease"in"Childhood."doi:"10.1136/archdischild420174312826" 38"We"note"that,"qualitatively,"the"continuous"air"monitoring"data"from"Boston,"as"presented"in"Figure"52"of"the"state4 commissioned"HIA,"indicates"that"formaldehyde"concentrations"in"this"region"may"increase"in"the"warmer"months,"like" June"and"July,"so"the"formaldehyde"monitoring"in"Weymouth"may"not"have"captured"those"peaks"in"concentration." 24" " cancer and oral and pharyngeal cancer (see Appendix A). The census tract across the water in Braintree from the proposed site is in the top quartile for rates of leukemia, non- Hodgkin’s lymphoma, and laryngeal cancer (Appendix A). The HIA also identified that children in Weymouth have higher rates of pediatric asthma when compared to the state average. In fact, Weymouth is in the top quartile in the state for overall asthma hospitalization rates (Appendix A). Weymouth is also in the top quartile for COPD hospitalizations and COPD emergency department visits (Appendix A). These findings indicate that the population living in proximity to the proposed compressor station is at greater risk for adverse health outcomes due to air pollution.

The state-commissioned HIA also identified that there are two environmental justice (EJ) communities in the focus area surrounding the proposed facility—the Quincy Point and Germantown neighborhoods. These communities meet the EJ criteria39 for: 1) median annual household income at or below 65% of statewide median income, and 2) 25% of the residents are minority or foreign born. The two census tracts that contain these neighborhoods, both of which are largely within the focus area, are in the bottom quartile for income in the state and the top quartile for percent non-white population in the state (Appendix B).

Per a 2009 report from the National Research Council of the National Academies,40 a robust human health risk assessment should consider cumulative effects of exposure to pollutants, evaluate non-chemical stressors, and assess existing population vulnerabilities. The state-commissioned HIA did not consider cumulative effects, nor did it incorporate population vulnerabilities into their assessment of potential health impacts. As we have shown in this report, it is possible to incorporate this type of vulnerability into a cumulative risk assessment, even if their incorporation is just qualitative (see discussion in VI. Conclusions and Recommendations).

h)! Conclusion

We estimated cancer risks and non-cancer risks associated with existing air pollution levels in the Fore River Basin, and conclude that existing air pollution levels in the Fore River Basin are associated with risks to the public’s health. Current elevated rates of certain cancers, heart disease, asthma, and COPD also indicate that the community surrounding the proposed compressor station is particularly vulnerable to additional environmental exposures.

""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 39"https://www.mass.gov/files/documents/2017/11/29/20174environmental4justice4policy_0.pdf" 40"National"Research"Council."2009."Science"and"Decisions:"Advancing"Risk"Assessment."Washington,"DC:"The"National" Academies"Press."https://doi.org/10.17226/12209." 25" "

IV.! PROJECTED EMISSIONS FROM PROPOSED FACILITY AND THEIR POTENTIAL HEALTH IMPACT

a)! Air pollution dispersion modeling for the proposed facility performed by Spectra Energy

As required by MassDEP, Spectra Energy conducted an evaluation of ambient concentrations of air pollutants expected to result from the proposed compressor station. Such an evaluation involves making informed guesses about what pollutants will be emitted from the facility, the concentrations of these pollutants as they are emitted, and the dispersion of these pollutants as they move away from the source. This process involves air dispersion modeling, which often utilizes models produced and made publicly available by the U.S. EPA. Once an applicant has estimates of air concentrations of these pollutants at locations near the source, they can determine whether these emissions pose a threat to human health.

Dr. Douglas Dockery,41 an expert witness at the air quality permit appeal hearing, outlined multiple erroneous assumptions that were made in the Spectra Energy’s air dispersion models. The first was the use of the AERMOD model instead of the Shoreline Dispersion Model. The Shoreline Dispersion Model is more appropriate for facilities located on the shoreline, such as the proposed site in Weymouth, because it accounts for the potential for shoreline fumigation (a turbulent process that forces contaminant plumes to disperse downwards). The AERMOD model used by Spectra Energy also assumed that the proposed facility was surrounded by “rural” land cover to estimate surface roughness, albedo, and the Bowen ratio (all of which are characteristics of the land that affect air dispersion), rather than the more appropriate “open water” designation. Finally, the AERMOD model that Spectra Energy used relied on data from Gray, Maine (a non-coastal area) for estimating the vertical structure of the atmosphere; this assumption does not accurately account for the sea breeze conditions that occur on the Fore River Basin shoreline.

""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 41"Dr."Dockery"is"a"professor"of"environmental"epidemiology"at"the"Harvard"T.H."Chan"School"of"Public"Health."He"holds"a" master’s"degree"in"meteorology"from"MIT"and"a"master’s"and"doctoral"degree"in"environmental"health"sciences"from" Harvard"School"of"Public"Health."Prior"to"his"academic"appointments,"he"did"air"quality"modeling"as"a"physical"scientist"at" the"U.S."EPA"and"later"as"a"staff"meteorologist"at"an"environmental"consulting"firm"in"Massachusetts."His"academic" research"has"focused"on"the"health"effects"of"exposure"to"air"pollution."His"expertise"on"this"topic"has"led"to"his"role"on" numerous"advisory"committees"for"the"U.S."EPA,"including"the"Clean"Air"Science"Advisory"Committee"review"panels"on" nitrogen"oxides"and"particulate"matter."He"has"also"served"as"a"reviewer"of"the"U.S."EPA"Air"Quality"Criteria"for"particulate" matter,"sulfur"oxides,"nitrogen"dioxide,"and"ozone." 26" " b)! Average Air Toxics Emissions from U.S. Compressor Stations

To better understand the potential emissions from the proposed compressor station in Weymouth, we calculated the average air toxics emissions from all U.S. compressor stations involved in the transportation and distribution of natural gas, as reported in the U.S. EPA’s 2014 National Emissions Inventory (NEI).42

We compared the average emissions of seven air toxics produced by compressor stations in the U.S. to the emissions levels reported by the 14 existing NEI facilities in Weymouth, Braintree, and Quincy—eight of which are within 2 kilometers of the proposed facility (Figure 3 above). Table 6 summarizes the average emissions from U.S. compressor stations, the ranking that a compressor station with the average emissions would have if it were in the Fore River Basin, and the emissions of the next largest source in this area.

Table 6. Average emissions from U.S. natural gas compressor stations compared to emissions from 14 NEI facilities in Braintree, Weymouth, and Quincy.

Average Emissions from Ranking Among All Emissions from the Pollutant U.S. Compressor Sources in Braintree, Next Largest Stations (in tons) Weymouth, and Quincy43 Source (in tons) 1,3-Butadiene 0.07 1/4 0.0002 Acetaldehyde 0.67 1/5 0.011 Acrolein 0.59 1/6 0.002 Benzene 0.18 2/9 0.003 Ethylbenzene 0.03 3/6 0.009 Formaldehyde 3.8 1/8 0.2 Naphthalene 0.01 2/9 0.0004

For four of these seven air toxics (1,3-butadiene, acetaldehyde, acrolein and formaldehyde), a compressor station with the average U.S. compressor station emissions located in the Braintree-Weymouth-Quincy area would rank first among all facilities in the area – emitting up to 350 times more of certain air toxics than the next largest source in the Fore River Basin. For the other three air toxics, it would rank second or third. Therefore, if the proposed compressor station emissions are comparable to the average emissions of U.S. compressor stations, the proposed facility will be among the most significant emitters of these seven air toxics in the Fore River Basin.

c)! Relevant Regulatory Precedent

""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 42"https://www.epa.gov/national4air4toxics4assessment/nata4overview" 43"Note:"Not"all"14"NEI"facilities"in"these"communities"emit"each"of"the"7"air"toxics"listed"in"this"table,"therefore"the" number"of"facilities"included"in"the"ranking"is"dependent"on"the"number"of"facilities"that"report"emitting"that"pollutant." 27" " The state’s air quality permit issued for the Weymouth compressor station contradicts its own regulatory precedent. In 1990, MassDEP rejected a proposal by Clean Harbors of Braintree, Inc. to build a rotary kiln incinerator in East Braintree, approximately one mile from the proposed compressor station. The Massachusetts Secretary of Human Services Secretary at the time concluded that the site was not suitable for the incinerator because of concerns like the ones that we raise in this report:

1)! the existence of elevated rates of respiratory disease in nearby communities, 2)! the proximity of sensitive subpopulations such as the elderly, and 3)! the difficulties with safely evacuating the elderly and disabled in the event of an emergency.

28" " V.! CONTRIBUTIONS OF THE PROPOSED FACILITY TO AMBIENT SOUND LEVELS

The state-commissioned HIA described the expected impact of the proposed compressor station on ambient noise levels during the construction and operation phases, summarized the findings of multiple sound monitoring campaigns in the area, and defined the health effects associated with chronic exposure to high levels of sound and populations that may be more susceptible to these effects. The HIA concluded that the proposed compressor station would have “possible”, “negative” health effects during the construction phase and an “unlikely”, “neutral” effect on health of “very low” magnitude during the operation phase. The HIA also concluded that there are vulnerable populations who could be more susceptible to the impacts of noise.

As we have previously stated, the state-commissioned HIA treated environmental exposures as singular insults to health that occur in a vacuum. This is not the reality of most environmental exposures, and robust health impact assessments should consider cumulative environmental exposures. With regard to noise, the state-commissioned HIA did not address the potential for residents of the Fore River area to have high levels of sound exposure at work, potentially increasing their risk for cumulative noise-related health effects. This oversimplified view is also present in the current Massachusetts DEP noise policy,44 which allows proposed facilities to increase sound levels up to 10 dBA over ambient levels; this does not consider existing levels or potential cumulative impacts of multiple co- exposures. It should also be noted that increases in sound are exponential, not linear, as decibels are reported on a logarithmic scale. The sound intensity of a noise of 50 dB is 10x more powerful than that of a noise of 40 dB.

The health effects associated with chronic exposure to sound above health-protective thresholds include increased risk for developing cardiovascular disease,45 through long-term inflammation, increased stress hormones, oxidative stress, and high blood pressure. Sleep disturbance caused by nighttime noise exposure is associated with an increased risk of injury and impaired blood pressure regulation. There is also evidence that individuals with pre-existing hypertension are at greater risk for noise-related heart failure (i.e. hypertension is an effect modifier).46 Many of the criteria air pollutants are also associated with increased

""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 44"https://www.mass.gov/files/documents/2018/01/31/noise4interpretation.pdf" 45"Münzel,"T.,"Gori,"T.,"Babisch,"W.,"Basner,"M."2014."Cardiovascular"effects"of"environmental"noise"exposure."European" Heart"Journal."doi:"10.1093/eurheartj/ehu030" 46"Sørensen,"M.,"Olav,"W.N.,"Sajadieh,"A.,"Ketzel,"M."2017."Long4Term"Exposure"to"Road"Traffic"Noise"and"Nitrogen"Dioxide" and"Risk"of"Heart"Failure:"A"Cohort"Study."Environmental"Health"Perspectives." 29" " risk of cardiovascular disease, which suggests that the effects of noise and ambient air pollution may have an additive effect.

In the description of current ambient levels and projected ambient levels, the state- commissioned HIA identified that the ambient nighttime L90 at one residential location near both the Calpine site and the proposed compressor station was 45 dBA, which corresponds to the World Health Organization’s recommended limits for nighttime levels. The noise level at this same location is expected to exceed the WHO recommended nighttime level during the operation phase of the proposed compressor station. The nighttime noise levels are expected to increase by 8 decibels at another residential site near the proposed facility, an increase that is considered acceptable because it is below the Massachusetts DEP policy of a 10-decibel threshold.

The state-commissioned HIA also described intermittent events (e.g. testing of the emergency generator, scheduled and emergency blowdowns) that would increase sound levels at nearby residential sites by 2-4 dBA, which is concerning given that many sites are already close to the EPA and WHO health-protective day and nighttime thresholds. The HIA refers to the emergency blowdowns as likely events, but does not discuss the potential for these events to occur at night, when they could potentially impact residents’ sleep. Penalties are commonly added to noise estimates (e.g. estimates of Ldn, which is the average noise level over 24 hours) occurring at night to account for this.

This ‘oversimplification’ is demonstrated by the MassDEP noise policy allowing proposed facilities to increase sound levels up to 10 dBA over ambient levels; such a policy does not consider existing levels nor potential cumulative impacts of multiple co-exposures. Future noise policies should have to account for existing noise levels in a community.

30" " VI.! CONCLUSIONS AND RECOMMENDATIONS

The National Environmental Justice Advisory Council47 and the National Research Council of the National Academies recommend including non-chemical stressors, interactive effects between stressors, and existing population vulnerabilities into the risk assessment process48. Such an approach was not undertaken by the state-commissioned HIA or MassDEP.

In this report, we performed a comprehensive assessment of the human health risks of air and noise pollution from the proposed facility. We offer evidence that the construction and day-to-day operations of this facility will have detrimental health effects for nearby residents, and pose a risk to citizens of the Commonwealth who share the water and airshed surrounding the Fore River Basin. Sound, air, and water pollution from a compressor station in Weymouth poses risks to human health that will be felt for generations to come.

We recommend that the state legislature:

o! Commence public hearings to examine the flawed regulatory process that resulted in the approval of this project. These flaws include the failure to consider existing air pollution levels and population vulnerabilities, as well as the lack of a quantitative, cumulative risk assessment for potential residential exposures to soil and groundwater contaminants.

o! Commence public hearings to examine why the Massachusetts DEP overturned the state’s own regulatory precedent in providing an air quality permit for the proposed project.

o! Commence public hearings to assess the impact that the proposed compressor station will have on the Commonwealth’s ability to meet its greenhouse gas reduction mandates under the Global Warming Solutions Act.

""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" 47"National"Environmental"Justice"Advisory"Council."2004."Ensuring"Risk"Reduction"in"Communities"with"Multiple"Stressors:" Environmental"Justice"and"Cumulative"Risks/Impacts."Washington,"DC."https://www.epa.gov/sites/production/files/20154 02/documents/nejac4cum4risk4rpt4122104.pdf" 48"National"Research"Council."2009."Science"and"Decisions:"Advancing"Risk"Assessment."Washington,"DC:"The"National" Academies"Press."https://doi.org/10.17226/12209." 31" " We recommend that the Massachusetts Department of Environmental Protection:

o! Overhaul its air quality permitting process to require independent external experts to perform air dispersion modeling and to ensure that the model(s) accurately reflects the meteorological conditions and geographic characteristics of a proposed site.

o! Solicit independent external reviews of the soil remediation plan put forward by Spectra Energy for the Weymouth site.

We recommend that the Massachusetts Department of Public Health:

o! Conduct comprehensive health impact assessments with improved transparency and scientific rigor. Such assessments should quantitatively assess the potential cumulative and interactive effects of multiple environmental exposures and should incorporate existing population vulnerabilities

32" " VII.! APPENDICES: MAPS

Appendix A: Disease Rates Appendix B: Population Size, Income, and Demographics Appendix C: Location of Nearby Schools Appendix D: Underground Storage Tanks, Hazardous Material Sites, and Facilities with MassDEP Air Operating Permits Appendix E: FEMA Flood Risk Zones, Hurricane Surge Inundation Areas

The maps demonstrate that the proposed site is in a densely populated census tract. That tract and the surrounding census tracts (2-km radius around the proposed station) are notably in the top quartile in the state for:

1.! Non-white population 2.! Residents who are children (under the age of 5) or elderly (over the age of 65) 3.! Oral and pharyngeal cancer, lung and bronchus cancer, Hodgkin’s Lymphoma; laryngeal cancer; leukemia; multiple myeloma; non-Hodgkin’s lymphoma; asthma hospitalization; age-adjusted COPD emergency room visits and hospitalization.

4.! Lowest quartile for median household income by census tract

The site is also categorized by FEMA as a high-risk flood zone coastal area.

33" " Appendix A: Disease Rates

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53# # Appendix C: Location of Nearby Schools

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Appendix E: FEMA Flood Risk Zones, Hurricane Surge Inundation Areas

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