Tuesday, August 16, 2022

Economy Wreaks Havoc on Amherst Construction Projects–Is Shutesbury Next?



Jones Library, Amherst MA
August 13, 2010
Photo Credit: John Phelan

A perfect storm of rising construction costs, soaring interest rates, and high inflation has forced neighboring Amherst to rethink its ambitious construction agenda as cost estimates on four projects head skyward.


As media outlets Amherst Indy and the Amherst Bulletin have reported, a whopping $40 million has been added to the bottom-line number for four construction projects: the Fort River Elementary School, a new Department of Public Works, a new Fire Station, and the renovation of the Jones Library. 


$40 million represents a 44% increase over the original four-project total of $90.8 million.


Shutesbury has its own roster of construction projects: installing a new 30,000+ square foot asphalt roof on the Shutesbury Elementary School (SES); replacing the Locks Pond Road culvert; building a new library; and the as-yet-unknown costs of remediating contamination on Lot O-32, the site of the proposed library. 


Estimates vs. Actual Costs


There is little doubt that Shutesbury will have to deal with the same problems as Amherst since construction costs are still trending upwards. 


Applying an increase of 44% to the culvert, school roof, and library project estimates (there are no estimates yet on Lot O-32 remediation costs), may supply a more realistic approximation of costs once the design is complete on the roof and library projects as well as suggest cost increases on the culvert project.


New Library: 5,490 Square Feet


Using information provided by the Small Library Pilot Project page on Shutesbury’s MN Spear Memorial Library website, the last estimate procured by the Trustees came to $6.3 million. Shutesbury’s portion of that amount is $2,063,571 or 38%.  We have saved  $890,700 in cash and voted to borrow $1.17 million. 


$6,300,000 1.44 = $9,072,000 

$9,072,000 0.38 (our portion of library costs) = $3,447,360


Subtracting town investments and the amount we will borrow for this project, the increase is quite hefty:


$3,447,360 - ($890,700 + $1,172,871) = $1,383,789


In this scenario, the town will have to come up with another $1.4 million to keep the library project on course. As with Amherst, S. Deerfield, and other communities, cutting the construction budget will be difficult since the grant from the Massachusetts Board of Library Commissioners does not allow the flexibility of adjusting the scope of work–such as reducing the square footage or trimming library programs–to meet municipalities’ budget requirements. 


For Shutesbury, transferring more money from savings is unlikely since cash reserves were reduced by 58% by 2022 Annual Town Meeting votes and a promised set-aside of funds to replace the SES roof.


Amherst has not yet voted on its own debt exclusion for its slate of projects and so may still adjust its borrowing needs. Because Shutesbury voted for a debt-excluded amount of nearly $1.2 million at the end of June, a big jump in costs will be a problem. 


According to the MA Department of Revenue’s Division of Local Services, the ability of municipalities to add to a voter-authorized debt exclusion in order to cover cost increases is limited. Unless it is a “modest amount attributable to inflation, new regulatory requirements or minor project changes”, municipalities must apply to the Division of Local Services Director of Accounts to obtain permission to increase the original borrowing amount. Otherwise, another debt exclusion override vote will be required.


Locks Pond Road Culvert Project


Shutesbury’s 2021 Annual Town Meeting voted to approve a total of $1.3 million in funding to replace the culvert on Locks Pond Road, near Lake Wyola:


Article 5. A motion was made and seconded for the Town to vote to fund the construction of a replacement culvert at Locks Pond Rd and Lake Dr, near the dam by borrowing up to $201,007, transferring $250,000 from capital stabilization and using the remaining funds of the Municipal Small Bridge grant for a total of up to $801,007. 


Applying a 44% increase to this job, which is likely not going to begin until the fall of 2023, yields an increase of $550,886 the town may need to raise or borrow to complete this project next year.


$1,252,014    1.44 = $1,802,900


But wait, there’s more! In addition, taxpayers may have to pay moving and/or storage fees to overwinter the yet-to-be-installed culverts unless appropriate town-owned space is found for this purpose.

SES Roof Replacement: 30,304 Square Feet


Voters approved $60,000 to pay for a design for the SES roof replacement at Annual Town Meeting this year, though there is no evidence this study is underway. The plan, as described by the Town Administrator on the floor of town meeting, was to obtain a more precise cost for the roof replacement project before calling a Special Town Meeting in the fall to transfer funds to do the job.


In the absence of a design, I will use the amount the Finance Committee estimated in their pre-Town Meeting Budget Report to perform the calculations.


$750,000 (Finance Committee estimate) 1.44 = $1,080,000


This would require Shutesbury to raise or borrow an additional $330,000.


This estimate may be low since there was no official cost estimate performed on the school roof. The gymnasium roof, at 4582 square feet, represents only 15% of the much larger asphalt area and cost $254,100 to replace. 


The asphalt roof project has been postponed since at least 2014, and the roof has continued to leak despite yearly patches administered by the former Town Buildings Committee. No doubt the passage of time and continual water damage will present added challenges to the replacement job, driving costs higher still.


The town has applied, for the sixth time, to the Massachusetts School Building Authority (MSBA), for a grant to replace the SES roof. At Town Meeting this year, the Town Administrator inferred that Shutesbury’s chances of procuring a grant were better than ever this year, presumably due to the involvement of state Representative Natalie Blais.


In perusing the town’s 2022 Statement of Interest to the MSBA (available from the Town Clerk), I noticed that despite a line in the asphalt shingle section of the form stating, “We are no longer seeking repair of the gym section of the elementary school roof”, the town goes on to apply for a grant for the gym section in addition to the asphalt section of the roof anyway. This is no doubt a mistake made by town officials–hopefully, not a fatal one.


If the grant process fails again, the town will have to come up with funds to fix the roof. This might mean another round of borrowing. The alternative is to delay the roof project for another year. Unless the town moves quickly to obtain the design, that may happen anyway.


Although this is just an exercise based on the experiences of Amherst, it is worth thinking about since we might find ourselves in a similar situation. 


What do you think Shutesbury will do if large increases in its construction project estimates occur? 


  1. The town will again postpone the SES roof project in the event we once again fail to secure a grant from the MSBA; 


  1. The town will postpone the culvert job another year;


  1. Voters will decide cost overruns outweigh the desire and need for a new library;


  1. Taxpayers will vote to borrow approximately $2,264,675, to complete all these projects.


Weigh in here: https://nextdoor.com/p/PsDGf6_YfDTt?utm_source=share&extras=NzAyNTE2Ng%3D%3D




Tuesday, June 21, 2022

Can Lot O-32 Escape its Past?

Former Residence at 66 Leverett Rd., aka Lot O-32 (Courtesy of Shutesbury Assessors)

In my previous post, Lot O-32’s past life as an automotive repair shop and unofficial dumping ground came back to haunt the town–albeit, temporarily–when reportable levels of polychlorinated biphenyls (PCBs) were discovered in groundwater samples behind the former three-bay garage. 


Ten years later, the parcel’s role as a former Department of Defense (DoD) site has become an issue, triggering another Release Notification to the Massachusetts Department of Environmental Protection (MA DEP).

Library Grant Application Spurs New Site Assessment


Town officials discussed the need to choose between Lot O-32 and a parcel behind Town Hall as a site for a proposed new library at a July 20, 2021 Select Board meeting. The Library Director noted that “targeted soil sampling” would be necessary to allay any fears regarding the safety of Lot O-32. It was decided that the garage building would be demolished and debris cleaned up on the parcel before soil and water testing was performed.


Environmental firm O’Reilly, Talbot & Okun (OTO) was hired to perform a Limited Subsurface Assessment of Lot O-32. In their report dated October 5, 2021, they describe the 10 soil boring locations detailed below.


B-1

former garage area

no reportable levels of contaminants

B-2

outside storage area behind former garage

no reportable levels of contaminants

B-3

down-gradient of former garage and former garage UST

no reportable levels of contaminants

B-4

proposed footprint of new library building

no reportable levels of contaminants

B-5

proposed footprint of new library building

no reportable levels of contaminants

B-6

proposed area for a new septic system leach field

no reportable levels of contaminants

B-7

area of removed debris

no reportable levels of contaminants

B-8

area of removed debris

no reportable levels of contaminants

B-9

concrete pad for an unknown abandoned utility/feature

100 mg/kg of C5-C8 aliphatic hydrocarbons

B-10

area of removed debris and removed abandoned car

no reportable levels of contaminants


All samples were analyzed for volatile organic compounds (VOCs), polychlorinated biphenyls (PCBs), and volatile and extractable petroleum hydrocarbons (VPH/EPH).


Sample B-9 was found to have the legally reportable limit of 100 mg/kg of C5-C8 aliphatic hydrocarbons, requiring a Release Notification Form filing with MA DEP. The firm recommended notification to MA DEP by January 28, 2022. 


With a debt excluded override vote to fund a new library scheduled for June 28, many questions come to mind:


  1. Will this issue fade away like the PCB discovery 10 years ago? 

  2. How long might remediation take and has the town done any work on this problem since being notified by OTO in October 2021? 

  3. What might it cost to remediate the site–and who must pay?

  4. What does this mean for a possible construction project?

  5. What are the alternatives to constructing a building on Lot O-32? 


I set to work finding answers to these questions. Here’s what I found.

1. Will this issue fade away like the PCB discovery 10 years ago?

Other than being reportable releases of contaminants at the same parcel, the 2012 and 2022 filings with MA DEP have little in common. 


For instance, the 2012 PCB release constituted a 72 Hour Reporting Condition because of a “release to groundwater near water supply”. The release of VOCs discovered in late 2021 and reported in early 2022 was characterized as a “release of oil to soil exceeding reportable concentration(s) and affecting more than 2 cubic yards”, placing it within the 120-day reporting threshold.


MA DEP-imposed Immediate Response Action (IRA) plans differed greatly for these two filings. In 2012, state officials advised additional sampling of the monitoring wells on Lot O-32, sampling of private drinking water wells within 500 feet of where PCBs were found, as well as repeat testing of the soil at that location. As noted in my previous post, all PCB test samples returned values below reportable levels and the Release Notification was retracted.


The VOC release prompted a more complicated IRA. 


The town filed the Release Notification Form on January 28, 2022. In a Notice of Responsibility letter dated February 1, 2022, MA DEP officials identified the forms, one of which the town must submit to the Department on or before January 28, 2023, as a “party with potential liability for response action costs and damages under M.G.L. c. 21E, §5”:


  1. A Tier Classification Submittal;

  2. A Permanent Solution or Temporary Solution Statement; or

  3. A  Downgradient Property Status Submittal.


The letter suggests that liable parties “take prompt action” to reduce cleanup costs and avoid annual compliance fees. The town must employ a state-certified Licensed Site Professional to oversee or perform all IRA work.

2. How long might remediation take and has the town done any work on this problem since being notified by OTO in October 2021? 


The Massachusetts Contingency Plan, the regulations created to administer Chapter 21E, has a maximum timeline of six years from notification of MA DEP to complete site remediation. Full compliance can occur at any point before the six-year deadline.


There is no evidence that Shutesbury has taken any assessment or remedial action since being notified of the VOC release by OTO. A Library Trustees meeting on November 4, 2021 discussed OTO’s findings and two company representatives were present to answer questions. At this meeting, OTO’s representatives stated that gasoline migrates within a 400-foot area. 


An unidentified Trustee stated:  “We are required to report within 120 days, and within those 120 days we would conduct further testing, conduct remediation, or take other steps before reporting to DEP.” 


While the 120-day reporting portion of the statement is correct, the rest is not, since MA DEP did not issue an IRA until after it received the Release Notification submitted by Shutesbury on January 28, 2022. If Shutesbury wanted to get started as early as possible on the IRA, the Notification form should have been filed immediately. 


The town could have used those four months between October 5 and January 28 to determine the status of Lot O-32 and put residents’ minds at ease. Apparently, nothing has been done in the nearly five months since filing, either, as that information surely would have been posted on the library’s website in the interest of transparency.


The Trustees met again on November 8, 2021, and unanimously decided to recommend Lot O-32 as the site for a proposed new library. The Select Board minutes of November 9, 2021, contain this recommendation by the Trustees and the statement, “the lot received a clean bill of health”.

3. What might it cost to remediate the site–and who must pay?

Since there was no further assessment of Lot O-32 following the OTO report last fall, there is no available information regarding remediation or its costs. 


As to who is expected to pay for the cleanup, it is clear that MA DEP considers the town of Shutesbury, as the owner, the “potential” responsible party. The Notice of Responsibility states:


You should be aware that you may have claims against third parties for damages, including claims for contribution or reimbursement for the costs of cleanup. Such claims do not exist indefinitely but are governed by laws which establish the time allowed for bringing litigation. The Department encourages you to take any action necessary to protect any such claims you may have against third parties. 


In this matter, the Shutesbury Town Administrator (TA) stated at a public meeting on May 11, 2022 (1hr. 30 min.) that the Army Corps of Engineers/DoD “will be held responsible” for necessary remediation. 


In an undated letter (available from the Shutesbury Town Clerk) from the TA to MA DEP, reference was made to a January 11, 2022, meeting between unnamed town officials, OTO representatives, and representatives of the Army Corps. The letter states that the Corps did not consider this release “a reportable event”. 


I could find no minutes or notes from the above-referenced meeting, though a representative of the Army Corps was copied on the Notice of Responsibility letter from MA DEP. 


At a Select Board meeting on January 19, 2022, the “TA update” describes a meeting between a DEP representative, an OTO representative, and, assumedly, the TA. The update states that both DEP and OTO consider the Army Corps/DoD the responsible party. There was no mention of an Army Corps representative being present.


It remains to be seen whether the DoD will take responsibility for remediation at Lot O-32. Their seeming dismissal of this release event is understandable since a positive finding infers that their cleanup in the mid-1990s was incomplete.


The town could have saved itself this worry over liability if it had commissioned a "21E Site Assessment" before purchasing the property in 2004–which could have absolved the town of responsibility in regards to legacy contamination cleanup costs. Real estate due diligence often includes a Transaction Screen or Phase 1 Environmental Site Assessment. The Commonwealth of Massachusetts considers such actions relevant because:


  1. Disclosure obligations for any known contaminants under Chapter 93A  can influence a buyer’s decision to purchase, the price offered, and conditions for the sale;

  2. The presence of hazardous waste is considered material information to a buyer and its presence is considered a material defect;

  3. The presence of hazardous waste is a public health issue.

Considering the town’s historical knowledge of Lot O-32, it was negligent toward Shutesbury taxpayers and residents that town officials did not undertake such an assessment.

If Fuss & O’Neill had performed the Transaction Screen in 2004 prior to purchase instead of 2010, been given access to the inside of the garage, and been informed of the former military installation, their report would likely have listed many more environmental conditions and risks. If such a report had been made available to Shutesbury taxpayers before the vote to purchase the land, the outcome may have been different. 

4. What does this mean for a possible construction project?

The town asserts that, because the contaminated B-9 soil bore site is 900 feet from the proposed library location, construction will not be impacted. This may or may not be true; the OTO report states, “Further assessment is warranted to evaluate the source, nature, and extent of the release detected at boring B-9.”


There is also the question of potable water, required for a building permit. According to the OTO report, water from the test well drilled in 2014 will need additional assessment from experts in the field of water potability. Though Trustees said at the November 9 meeting that the water was not potable “because it is a test well”, OTO states that “the town is assessing whether groundwater from this well might be a suitable future source of drinking water.”

5. What are the alternatives to constructing a building on Lot O-32? 

The Massachusetts Contingency Plan, 310 CMR 40.00, allows owners of contaminated properties to apply an Activity and Use Limitation (AUL) to said property. This is often done as part of a Temporary or Permanent Solution to site contamination, one of the three possible submittals required by MA DEP as noted earlier in this post. 


AULs must be recorded with a parcel’s deed to be valid. The purpose of these instruments is fourfold: 


  1. To notify interested parties of possible oil and hazardous material remaining on the site;

  2. To identify allowable activities and uses on the site;

  3. To identify non-allowable activities and uses on the site;

  4. To delineate the owner’s obligations regarding maintenance of the AUL.


In the event of high cleanup costs for Lot O-32, an AUL could limit taxpayer liability by restricting activities that would be allowed on the parcel. The site would need further assessment and be characterized as “No Substantial Hazard” or “No Significant Risk” before applying the AUL.


Whether or not voters decide to borrow funds in excess of the proposition 2-½ limit to build a new library, the contamination issue on Lot O-32 needs to be addressed. The question is not whether the site can someday be developed; waste disposal sites are often rehabilitated and re-used. The concern for Shutesbury taxpayers is that of cost. Transparency dictates that Shutesbury Town Officials should have taken steps to determine the cost of cleaning up Lot O-32 prior to the vote on whether to borrow funds to build a library there. Can we afford a new municipal building as well as cleanup costs for Lot O-32? It is something to consider carefully before casting our ballots on June 28.





Tuesday, June 14, 2022

Digging Deeper into Shutesbury’s Lot O-32

Debris Behind the Former Automotive Repair Garage, Lot O-32

New developments have occurred since I last recounted the storied past of town-owned Lot O-32, located at 66 Leverett Road. The parcel, purchased in 2004 by the Town of Shutesbury from Amherst developer Barry Roberts, has experienced multiple insults over the decades, scarring its landscape.

Before its purchase by Mr. Roberts, Lot O-32 was used as a vehicle repair shop, landscaping and gravel business, and unofficial dumping site. Between 1957 and 1967, it was “used by the Air Force for a terminal very high-frequency omni-directional range (TVOR) facility, a type of short-range radio navigation system for aircraft”, according to a report dated October 25, 2021, by O’Reilly, Talbot & Okun. This company performed a limited subsurface assessment of the site as the town prepared for possible development of the parcel.


Findings by this firm prompted a “Release Notification Form” filing with the Massachusetts Department of Environmental Protection (MA DEP) regarding volatile organic compounds (VOCs) found at one of the soil boring sites. Although soil sample borings B-1 through B-8 and B-10 were not concerning, sample B-9 showed compounds compatible with a release of gasoline.


MA DEP has defined Lot O-32, or portions thereof, as a waste disposal site under MA General Law Chapter 21E, also known as the MA Superfund law, and the MA Contingency Plan, 310 CMR 40. Further assessment by the town is required and a report must be submitted to MA DEP by January 23, 2023.


This is the second time Shutesbury has filed with the MA DEP due to contamination found at this site. Approximately 10 years ago the town was required to notify the Department of a finding of polychlorinated biphenyls (PCBs) from a groundwater sample in a well adjacent to a drum located behind the former garage building on Lot O-32. That notice was retracted five weeks later.


Between 2010 and 2012, Lot O-32 was poked and prodded several times by a handful of environmental assessment companies as the town sought to determine whether the site was contaminated. Here is a timeline of contamination-related activities involving the site and the investigations leading up to the discovery of PCBs behind the dilapidated garage, the reporting of such to MA DEP, and the subsequent retraction.


Note: The late Larry Kelley of Amherst reported at length on these issues 10 years ago on his blog, Only in the Republic of Amherst. The photos presented in this post are from his blog, which I encourage readers to peruse.

1995: The U.S. Military Cleans Up a Messy Legacy

In 1995, contamination from the underground storage tank (UST) installed by the military prompted a Formerly Used Defense Sites Program (FUDS) cleanup of Lot O-32 by the U.S. Army Corps of Engineers on behalf of the Department of Defense. During cleanup, the Corps removed the UST (page 6) and 100 tons of gasoline-contaminated soil from the former TVOR location.

2010: First Looks by Fuss & O’Neill and O’Reilly, Talbot & Okun 

In the summer of 2010, civil and environmental engineering firm Fuss & O’Neill performed an Environmental Transaction Screen for the Town Of Shutesbury. A report dated December 29, 2010 (obtainable through the Shutesbury Town Clerk’s office), updated a July 24, 2010 Transaction Screen with “additional information provided…by the Town of Shutesbury.”


The purpose of the screen was to identify potential environmental conditions (PECs) affecting Lot O-32. A representative from Fuss & O’Neill walked the lot with the Town Administrator (TA), noting a debris pile and two empty drums behind the garage. The representative was denied access to the interior of the garage and was unable to make any judgments by merely peering through a window. Evidence of historical dumping was observed and the TA reported that 13 dumpsters filled with waste were removed from the site before the town purchased the property.


Unseen by Fuss & O'Neill, Inside the Garage: Open Floor Drain

 Cracked Cement Flooring

The TA noted that two underground storage tanks were removed from the site in 2004: one held home heating oil for the former residence and the other stored gasoline and was located near the garage. Shutesbury’s Fire Chief provided information for the fuel oil UST removal, which showed no evidence of leakage. The firm noted that it did not review any documentation for the gasoline UST removal.


The report characterized the presence of dumping, i.e., the empty drums, as the only PEC and “recommended further evaluation”. The ongoing UST gasoline release cleanup activities (enter Release Tracking Number = 1-16996 in the search boxes ) at the nearby Fire Station were identified as an “environmental concern” for Lot O-32, based on the proximity of the two parcels. 


The Fuss & O’Neill report made no reference to the TVOR military facility. 


During the summer of 2010, the town also commissioned a study (page 123) by geotechnical engineering and environmental consultancy firm O’Reilly, Talbot & Okun (OTO). The purpose of the study was to identify geographical conditions that may impact the construction of a new library. 


OTO reported encountering groundwater in three of four soil borings at depths of three, seven, and fifteen feet below the ground surface. Though this was not considered a major issue for the finished building, the firm recommended using water-control methods during construction.


One issue concerned the site's high silt and fine sand levels, which could contribute to building footing instability. They suggested excavating another six inches in depth and providing crushed stone on which to place the footings. Dewatering sumps during construction were also recommended. 

2012: Cold Springs Environmental Consultants Weigh in

In 2012, Shutesbury hired Cold Springs Environmental Consultants (CSEC) for further assessment of the environmental conditions noted in the Fuss & O’Neill report on Lot O-32. The town had previously worked with CSEC during the Fire Station contamination issue. 


During due diligence inspections carried out in December 2011 and January 2012 and described in a report dated April 26, 2012, CSEC noted several Recognized Environmental Conditions (RECs) on the site: 


  • The locations of the removed heating oil and gasoline tanks; 

  • An open floor drain with an unknown terminus exiting a wall in the garage building; 

  • A debris pile behind the garage that included a 55-gallon drum containing debris and petroleum; 

  • A pile of debris southwest of the garage; 

  • Scattered debris such as abandoned vehicles along a dirt road extending south;

  • The site’s proximity to the Shutesbury Department of Public Works and Fire Department.


 Again, there was no mention of the former military installation. 


During the month of December, CSEC supervised the installation of four monitoring wells and obtained groundwater samples from each: 


  • GP-1, placed near the former gas UST;

  • GP-2, near the debris pile behind the garage;

  • GP-3, near the floor drain line terminus; and

  • GP-4, at the site of the former fuel oil UST.


All four samples were tested for Volatile Organic Compounds (VOCs). Sample GP-1 was also tested for Volatile Petroleum Hydrocarbons (VPHs). Samples GP-2, GP-3, and GP-4 were also tested for Extractable Petroleum Hydrocarbons (EPHs). All results were below legally reportable concentrations.


Two soil samples, at depths of 12 to 14 inches, were obtained from a test pit at the garage floor drain terminus (FD-S-1 and FD-S-2). A surface soil sample from beneath the drum in the debris pile behind the garage was also collected (DR-1). No reportable levels for VOCs or EPHs were detected in any of the samples. However, based on the finding of PCBs in the petroleum remaining in the drum, Sample DR-1 was also tested for PCBs. Analysis showed 39.9 ppb PCBs; MA DEP reportable levels are 2,000 ppb.


The lab test finding of PCBs in Sample DR-1 prompted additional soil and groundwater testing on April 10, 2012.


Drum Located Behind Garage Building

Three triangulated soil samples were taken from the area beneath the petroleum-containing drum: 

  • DR-1

  • DR-2

  • DR-3

Another soil sample, FDT-1-20”, was taken near the garage floor drain terminus at a depth of 20 inches.


Levels of PCBs in all four soil samples were below the laboratory detection threshold of <22.6 to <27.9 ppb.


Monitoring wells GP-2 (near the drum)  and GP-3 (near the floor drain terminus) were also retested. Because the test wells were located in an area of residential drinking water wells, a strict standard of no more than .50 ppb was applied. PCB levels in GP-2 were recorded as .544 ppb, above the Reportable Concentration. GP-3 levels were found to be .425 ppb, just under the reportable limit. 


In accordance with 310 CMR 40, CSEC notified MA DEP within 72 hours of notifying the town of the results. A DEP official approved an Immediate Response Action which required sampling of private drinking water wells within 500 feet of the affected well site–including Lot O-32’s monitoring wells. The soil beneath the contaminated drum was to be tested at a depth of two to three feet. 


Additional sampling was carried out under the Immediate Response Action Plan. According to a CSEC report dated May 30, 2012, new samples taken from all four test wells were tested for PCBs and found to be below “the laboratory detection limits of 0.206 to 0.233 parts per billion” and thus well below the reportable limit of .50 ppb. Laboratory filtered and unfiltered samples from each well were tested.


The company’s president attributed this outcome to the prior samples taken from GP-2 and GP-3 containing soil sediment, to which PCBs tend to adhere. In his opinion, this was the cause of the previous high readings, not because of the presence of PCBs in the groundwater. Apparently, town officials questioned this result, to which the contractor replied that “it happens with sediment sometimes.”


The soil from the area beneath the removed drum was retested as well. The new results were less than 30.90 ppb, the laboratory reporting limit, compared with the prior results of 39.90 ppb. The report stipulated that the soil bore sample was retrieved from a depth of 20 inches, rather than the two to three feet stated in the report of April 26. The reason given for this discrepancy was that “PCB levels in soil do not increase with depth based on the laboratory analytical data”.


The May 30 report advises the town that, based on the new data, the prior Release Notification to MA DEP may be retracted by filing the appropriate documents by June 24, 2012. The TA submitted the Release Notification & Notification Retraction Form on May 30, 2012.


In early June, test results from surrounding wells were delivered to the town. The most significant finding involved elevated salt levels in many drinking water wells–particularly the Shutesbury Department of Public Works (DPW).


Next, I’ll take a look at the most recent environmental issue found on Lot O-32 and how it may affect the taxpayers of Shutesbury.
















Information Mining on Shutesbury.org

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