February 15, 2017
By Mickey Friedman
Interested in PIP, the Public Involvement Process for the contaminated New England Log Homes site (NELH) in Great Barrington? Then it’s time for RIP, the Phase IV Remedy Implementation Plan – Revision 3. And the Alice in Wonderland world of environmental remediation. http://public.dep.state.ma.us/fileviewer/Default.aspx?formdataid=0&documentid=378546
I’ll start with clarifying the problem, then next time, address the proposed solution.
RIP is often indecipherable to lay men and women: with toxic chemicals measured as parts per million (ppm), parts per billion (ppb), and at NELH parts per trillion (ppt). Measured as solids, liquids, and gases. Mg/kg, picograms per gram (pg/g), and nanograms per liter (ng/l).
You’ll never learn that one ppb of dioxin is equivalent to a single drop in 500 barrels of clean water. One part per trillion, a single drop in 20 Olympic-sized swimming pools.
RIP reveals the 8.2-acre site “has been impacted primarily by dioxins and pentachlorophenol (PCP), with secondary impacts from metals, petroleum hydrocarbons, and polycyclic aromatic hydrocarbons (PAHs). The primary affected media at the Site is soil; groundwater has been impacted primarily by PCP.”
On “September 11, 2015: BTR collected 97 soil samples across the Site … Reported dioxin concentrations ranged from 1,324 to 1,898 picograms per gram (pg/g).” Or 1,324 to 1,898 parts per trillion. While the Upper Concentration Limit (UCL) for Massachusetts is 200 pg/g or ppt, Canada regards anything above their background level of 0.5 to 4 ppt in soil as a potential problem. In case you missed the memo, the Massachusetts Department of Environmental Protection (DEP) explains that “Upper Concentration Limits identify contamination which may pose a significant risk of harm to public welfare and the environment in the future, and to minimize the incremental contributions to anthropogenic background.”
“PCP concentrations were 800 and 65 mg/kg at depths of 6 and 14 feet bgs … Samples collected in this area in December 2013 indicated a surface concentration of PCP of 540 mg/kg …” The UCL for Massachusetts is 400 mg/kg. Or 400 ppm. Interestingly, the Canadians note “the lowest soil PCP concentration at which toxic effects have been observed in invertebrates is 10 mg/kg.” 10 ppm. And so their soil quality guideline for PCP is 7.6 ppm. That’s their background level – the level that already exists in Canadian soil. And bgs means “below ground surface.”
We discover that the last tests of groundwater were taken in 2004: “Dioxins were present in groundwater at concentrations of up to 1.562 nanograms per liter (ng/l); these
concentrations exceed the Method 1 GW-1 Standard of 0.03 ng/l.”
It’s always interesting to compare state and federal standards with the levels that are present at a contaminated site.
Why? Because, according to the World Health Organization, “dioxins are highly toxic and can cause reproductive and developmental problems, damage the immune system, interfere with hormones and also cause cancer.”
ATSDR, the United States Agency for Toxic Substances and Disease Registry, reveals: “Exposure to high levels of pentachlorophenol can cause increases in body temperature, liver effects, damage to the immune system, reproductive effects and developmental effects.”
Remember, there are no safe levels for exposure. Nevertheless, the regulatory agencies have set some practical standards. The United States Environmental Protection Agency (EPA) has determined that the limit for drinking water for pentachlorophenol is one part per billion, (1 ppb).
Speaking of drinking water, and the confounding language of remediation, I saw this in the 2005 Phase III Remedial Action Plan: consultants Fuss & O’Neill “concluded that although the Site is located within a Zone II for Town of Sheffield public water supply, conditions at the Site do not pose a potential for human exposure at the Sheffield public well supply and, therefore, a condition of No Significant Risk does exist with respect to ground water at the Site. F&O concluded that a condition of No Significant Risk does not exist with respect to soil at the Site. The current risk to human health is attributed to elevated concentrations of dioxins present in shallow soil at the Site.”
Which means we shouldn’t worry because we won’t ever drink this water but maybe in the future Sheffield might. But we should worry about the soil.
Luckily, Don Ward of the Sheffield Conservation Commission is actively monitoring what is happening at NELH. And perhaps it’s time to update those 2004 groundwater tests, for Sheffield’s sake, as well as checking the potential for renewed contamination of the Housatonic River.
Again, remember that the more we learn about these man-made chemicals, the more we discover that the lowest of doses have significant health impacts.
ATSDR concludes: “The level of 0.05 ppb is an ATSDR screening level for dioxin and dioxin-like compounds … based on non-cancer risks associated with the ingestion of soil in residential settings.” 0.05 ppb is equal to 50 ppt. Here, we’re talking about levels from 1,324 to 1,898 parts per trillion.
So much for the problem. What about the solution?
“RIP – The Problem” was first published in the January 26, 2017 issue of The Berkshire Record.
Mickey Friedman’s Berkshire-based I Ching mysteries, “Danger” and “Folly”, as well as his non-fiction “A Red Family” are available on Amazon.com.