Amherst Residents for Environmental Accountability (AREA)

Problems with the DEP Risk Assessment: Is It Really Safe?

Short Summary

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.

The report states that the groundwater in the most affected area that includes wetlands off the Hop Brook Dr. is classified as GW-3 standard, but "evaluation of groundwater exposures was not within the scope of this focused risk characterization." These exposures include health hazards from groundwater percolating into the basements of residential homes just 200 feet away.

According to the last Ground-Water Management Study on file in the DEP archives, wetlands affected by the contaminated plume are located in the primary aquifer recharge area and will affect the Lawrence Swamp area used for the Town's drinking water if the contamination is allowed to continue. As citizens of the Town, we should request to address the problem before it affects the Town's drinking water supply. The landfill cap integrity should be restored to stop leachate generation before any installation on the landfill is considered. It would be impossible to fix this on-going problem after 20,000 solar panels are installed on top of the landfill.

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:

"Although groundwater in the subject areas would be classified as GW-3 according to the above criteria, evaluation of the groundwater exposures is not within the scope of this focused risk characterization".

This neglects a risk to human health from the groundwater percolating in the basements of residential houses located approximately 200 feet from the monitoring well.

The 2009 Comprehensive Risk Analysis mentions (vol.1, page 6-3, PDF page 37) that:

Page 7-4 (vol. 1, PDF page 7) of the same report states that:

Most of these risks were not analyzed by the Comprehensive Risk Analysis provided in the report:

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:

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.

The 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.