with the DEP
Risk Assessment: Is It Really Safe?
Amherst old landfill has a deteriorated cap that does not prevent precipitation from entering into the landfill and leaching out contaminants which pollute surrounding wetlands. Levels of lead, arsenic, cadmium and mercury in the surrounding wetlands reached a degree that triggered a mandatory risk assessment. The risk assessment done by DEP concluded that “there is no significant risk to human health”. However, DEP ignored most of the risks associated with increasing levels of contamination.A Tighe & Bond Final Comprehensive Site Assessment report on Amherst’s old landfill and surrounding areas, states that there is a known risk of harm to the environment due the "Severe Effect Levels" that was never evaluated because evaluation "was not requested in the MADEP letter".
It also states that a known risk to public welfare listed in the report was never evaluated because the landfill is functioning according to specifications (which are, in reality, grossly violated as stated in the Current State of the Cap summary).
Furthermore, it states that a known risk to human health from the maximum detected concentrations of contaminants in the wetlands off the Hop Brook Drive was not evaluated due to the area not being readily accessible. In reality, there is a trail going through this wetland that connects the Hop Brook Dr. with the bike path. This trail is used for hiking by area residents without any knowledge of the risks.
Detailed Description with Document References
The 2007 DEP report states (page 3) that GW-3 standard (a standard for all groundwater in the state) was exceeded for lead and chromium for wetlands of the Hop Brook Drive (Brickyard area), with the most impact at the monitoring well 3-68.
However, the 2009 DEP Comprehensive Site
Assessment states (vol.2,
page 3, PDF page 70) that:
a risk to human health from the groundwater percolating
in the basements of residential houses located approximately 200
from the monitoring well.
The 2009 Comprehensive Risk Analysis mentions (vol.1, page 6-3, PDF page 37) that:
"Gull Pond ... is occasionally used for fishing by area residents"
"human exposure to areas impacted by the site from abutters and nearby residents is considered likely".
Page 7-4 (vol. 1, PDF page 7) of the same report states that:
Arsenic was detected at Gull Pond Inlet at concentrations exceeding MassDEP Screening criteria, and iron levels exceeded "Severe Effect Levels"
Arsenic and cadmium were detected at KC Trail wetland at concentrations exceeding MassDEP Screening criteria and iron levels exceeded "Severe Effect Levels"
Mercury was detected at Hop Brook wetland at concentrations exceeding MassDEP Screening criteria.
There is environmental risk at KC Trail wetland for arsenic and cadmium, at Gull Pond for arsenic and at the Hop Brook wetlands (SW-15 area) for mercury.
Most of these risks were not analyzed by the Comprehensive Risk Analysis provided in the report:
According to the page 12 (vol.2, PDF page 79) of the report by Tighe and Bond, the risk of harm to environment was not evaluated because it "was not requested in the MADEP letter".
The same page states that the risk of harm to public welfare "was not specified in the MADEP letter ... since these considerations have been addressed under Solid Waste Regulations".
Since the Solid Waste Regulations that regulate the thickness and permeability of the landfill clay cap are grossly violated, the Qualitative Risk Assessment included in the report is grossly inadequate. Gull Pond is regularly used for fishing derbies, with people (including children) consuming the caught fish without any knowledge of health hazards.
The page 7-3 (vol. 1, PDF page 5) of the report states that:
"risk assessment was not conducted for the SW-15 area”. [SW-15 is the area of wetlands of the Hop Brook Dr. (Brickyard area) with the biggest contamination impact mentioned in the report]
“However, this wetland area is a forested wetland that is not readily accessible to the general public and therefore was not considered a significant human health or public exposure risk".
In reality, there is a trail going through this wetland that connects the Hop Brook Dr. with the bike path. Many people use that trail for hiking not knowing that the area is contaminated and no risk assessment was ever done.
only risk assessment that was done was for "fall victims" and
children trespassing or playing around
the area "2
days/week during warm months" in the
vicinity of the KC Trail and Gull Pond.