-.--i ,'~ < ~ \ - .-l. I~ ~ - j j j j j j j j j j j j j j j j j j j j j j " • The Back River Committee Hingham/Weymouth 41 Massasoit Rd. N. Weymouth, MA C2!91 (1;17) 337-3896 Karen Stromberg. Public Involvement Coordinator DE? Northeast Regional Office Site .A.sses::>ment and Cleanup Section Scope for Work 10 Commerce Way for Weymouth ~leck Site Woburn. MA »1801 DEP Case # 3-1361 June 22.1992 Dear Karen Stromberg. Members of Ine Back River Committee of Weymouth and Hingham have careft:lly rcviewp.d the draft of the Public Involvement Plan for the Weymouth Neck Lardfill disposal site for lantosca. We find a number of flaws. Many of the misstatemerl!'; weie refuted by us before. but as they have been repeated we are objecting to [r,em aoa:n On page 1, ( par. 4) it is stated that Eastbay is a 27 acre site. On page 3. (par. 2) it is stated that currently the site is comprised of 27 acres at low tide. Eastbay Goes r.ot J'N;', that area to low tide. The deed on record at Dedham states 20.38 acres ato\ (0' rr:e<!f1 high tide. (A copy of the deed is enclosure #1) It was incorrectly stated !C' n,·") ~f,~r !:,.<, April 30th meeting. that iots 24 and 25 are in addition to the 20.38 acres Tha deec an,1 the or,ly on site survey map on record at Norfolk County Registry of OeoJds .:l.::r:", ,,-y Allen and Demurjian for lantosca dated June .985 (enclosue #2) cleariv ~.-;;'..vs tr;:;: the two lots are included.1n the 20.38 acres. Weymouth by-laws. or codes .:12- ':rey ::,rr; r;ailed. do not allow privale or public ways crossing the site to be counln:j ,,·s ·~lJl.':-.:;bi:.l area. therefore TWO more acres must be deducted from the usable site.(V~eY'T.C'~lh =y­ Law. enacted in 1979 is enclosure #3). That by-law wouid discount Broad F.eacll and :he road to Webb Park :eaving a maximum of 18.38 acres. w:thout discount:!:,; tl18 !'on-buildable let5 24 an.:! 25. On page 2. (par. 1) our hl:,;,r)IY Jl Bradley Fertilizer Plant said :hat it was fc,,"r .. ~,,(j :r 1862 "'o~ 1833.(one o~ :3evaral relrences we have to 1862;. On page 2. (par. 3). a desc,ir::tion of the wastes left by the Brad!ey Fertilizer ane:: Arr:erican Agriculture Chem'cai Company mentioned incidental spills of Sl,;/fLlric ac'c. The acid bUilding was bur'1t :0 the ground on Oct 30.1946 and when the leaden 'iaTS melted thousa.nds of ga/:ons 01 sulferic acid ignited. i have many newspaper articles about the fire wricr was of such magnitude that it was seen 1rom Bostor stlores. Copies of some (1f the many news items aie included here.(EnClosure 4) ,lames lhat destroyed !~e aei::! r:lan! were aiscribed as 2112 acres wi·-::e and 200 ft hlgh.-i-~e aCId spii!s seem fa, from incidental. Huge leaa Ii;,ed vats contair.ed ;he aClo. I f!7samcher! ;he his:ory of the lea::: I:ned :Uliding aT (he Hingham Li::rar'j, 'lJr.~re they hav;~ ::>n micr')fi!m three very old almanacs issued by the Bradley ;=~rti!izer Plant. The 31rnanacs were filled with i"lstOry of the piant includinG a descriptio~ G'I' the iead lined acid .cui/ding cue') as: i'lr<;G enormo .... s chambers each one: 5·j ,t :cnq. 20 It hit;I' 3.:",0 2!:: It. , --:J.. -2- wd. and each lined with 150 tons of lead. (copies of pages from the 1890 almanac are included with their transcriptionfor easier reading as enclosure #5). Is it any wonder that unusually large amount~ad were found in the soil some distance from the fire?(16,OOO mg/Kg wherr5is accePt~ In the remedial plan presented by lantosca, it was stated that if any Ctlemicals oT unexceptable levels were found they would be removed and properly disposed. However that area was simply covered with plastic, when complaints were made.When the plastic blew loose some top soil was added. A copy of the proper coverage for a much lesser contaminated public dump in Quncy is enclosed.(enclosure #6). Lead sludge was not used in the feltilizer as the scope stated. On page 2 (Par.3) it is stated that 'groundwater is not used as a drinking water source'. As this may be true now it has not always been so. North Weymouth had a very prolific well on a triangle of land near Neck Stand Rt. 3A which was used in the 1960ies. The state condemmed the well (Weston & Sampson Rpt. pg 18 enclosure #7) because of the high nitrate level in the well water which causes deformaties in unborn babies. The Weymouth Conservation thought that the contamination, in an area that had never been farmed, must have come from the Bradley Fertilizer Plant., working its way down the river into a stream that ran under 3A and into the well watershed. An earlier fire on the site of the Bradley Fertilizer Plant started when a ship from Chili, carrying 400 tons of nitrate exploded. The explosion blew apart seven cottages hundreds of feet from the ship. With that amount of nitrates in the water it is small wonder that some could find its way into the well. Maxium Goudy, husband of Weymouth Chairman of Board of Selectmen, said that when he was stationed at the Weymouth Neck Nikie Site in the 1950ies, that on one hot night some of the servicemen jumped in for a swim. Their skin stung and burned and they all had a red rash.They went in swimming from the same area as the ship explosion.(See enclosure #8 for well and #9 for boat- fire). An old insurance map is also enclosed to show the approximate distance from the wharf to the houses that were leveled to show the distance that the nitrate was spread. High amounts of arsenic were used in the manufacture of fertilizer. I read that Napoleon's remains were going to be examined because they believed that he may have died of arsenic poisoning and as arsenic never dissipates it would still be found as it could be on the Eastbay 18 acre site. 2,600 mg/Kg was found by Cert. Eng, on 11/88 when on Iy a level o~ 0.05 is pas~bIe. Copy of those tests are included. ___________ ~ '7 , '/ . On Page 11 (par. 1 ) the water system referred to is incorrect. I believe the Richardi Reservoir and Upper and Great Ponds refer to the drinking water system of Braintree, Hobrook and Randolph not Weymouth. We both have bodies of drinking water called Great Pond. but Weymouth has no Richardi or Upper Pond. I found grave problems when asked to join an on site review of Eastbay with the Army Corp of Engineers(Robert Mabb) at his request. Walking along below high tide line from Webb State Park I saw what easy access it was to a highly dangerous spot on Eastbay's site. Part of the old ChemicallFeltilizer Plant was on a wharf pertruding over the water. Tides run beneath it daily. The wharf is coverered with sod. Grass and weeds and some small trees have grown on top over the years. Huge hole from rotting timbers making it a clear and present danger to all not aware of the holes. The -3- scope of work map (pg.3) shows this hole ridden shakey 120 year wharf as a potential parking area.1 am including the two pages of photos of that area as it was stated in the amended version that there was no immediate danger on the site. lantosca is aware of the problem but the map is still included in the scope. The approach to this wharf is so easy. Children play in near by Webb Park daily. Boaters told our committee recently that they saw children fishing off the end of the wharf. Beams are falling into the water endangering boaters. It is against the law to erect a fence along the waterfront. ACE told lantosca to tear down fence posts. The wharf should be dismantled at once.(See enclosure #10) I am enclosing a portion of the 1980 FIRM Map from FEMA. The updated version put out in 1989 appeared slightly more restrictive than the 1980 map. As Mr lantosca purchased the site for Eastbay in 1985 he could have used the 1980 map, so that is the one we will use as comparison. The portion of land where town houses are located in the map included on page 3 of the scope is in the floodplain. We know when land is in a floodplain, especially a hazardous waste site how disruptive building can be to near-by clam beds, if a storm took place during construction. (Enclosure #11). Mr. McGuire of the Boston FEMA office said that the most up to date Flood plain map must be used at the time of application. The high amount of copper found on the site (Certified Engineering 11188 found 390 mg/kg when 1 mg/kg is acceptable) are at dangerous levels. Dr Carl Pfeiffler, PHD, M.D., former director of the Princeton Bio Center in Stillman N.J., wrote in his book 'Mental and Element Nutrients'," Copper is an essential element for supporting life, but in excess it can be toxic.