| David
Murphy Office of the Commissioner Dept. of Environmental Protection One Winter St. (3rd flr) Boston, MA 02108 February 25, 2002 RE: Notice of Availability of Offsite Restoration Plan, Quarry Hills, Quincy/Milton Dear Mr. Murphy: Friends of the Blue Hills takes this opportunity to review the abovementioned Plan offered for comment by the DEP in the Environmental Monitor February 9th. INTRODUCTION |
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story entitled "Trouble Arrives in Torrents"
published in the Quincy Patriot-Ledger on February 2nd detailed
massive and recurring flooding and sedimentation of residential neighborhoods
on Sheldon, Ballou, and Unity Sts. in Quincy. In the story Quincy DPW director David Colton said that the sediments originated at the 450-acre Quarry Hills site a half mile upstream, where 13 million tons of Big Dig excavate have been dumped since 1997. Colton also said that he had asked the Dept. of Environmental Protection to require "off-site mitigation studies" from the Quarry Hills developers. In response, Steve Lipman of your office said that the Dept. was reviewing a study submitted by Quarry Hills in late December. Is this that study? If the affected homeowners were hoping it would give them any indication of how and when the damages would stop, they were mistaken. Curiously, the same Administrative Consent Order mandating the "Off-site Restoration Plan" also required Quarry Hills to draft a revised "Pollution Prevention Plan" by November 25th of last year. This plan was to address stormwater discharges from the vast, high-perched, and steeply-sloped site. Does this plan exist? Certainly it would be of much more interest than the one in hand. When will the public be invited to review it? Although the Quarry Hills project is in its fifth year, this is the first time the Dept. has asked for public comment on any document or plan. In the meantime its "Special Projects Office," of which you are the head, has issued numerous orders, notices, approvals, and determinations, all negotiated privately with the proponents. None of these items have had any discernable impact on the project, except to facilitate whatever expansions or modifications the proponents have desired. Given the stunning failure of the "Special Projects Office" to prevent major ongoing damages generated by Quarry Hills, why should anyone bother to comment on this very limited and perfunctory Plan, which recommends virtually no action of any kind? The proponents are $20 million over budget, the site is ringed with dying wetlands, and the Dept, judging from its sponsorship of this document, is unwilling or unable to break away from five years of doubletalk and dereliction. At any rate, here are my notes. THE OFF-SITE RESTORATION PLAN The Consent Order required that the Plan: --survey all off-site wetlands and waterbodies associated with the three brooks draining the site --identify and map any areas where silt or clay has been deposited --evaluate physical, biological, and ecological impairments --develop a plan to restore impaired areas METHODOLOGY Unidentified parties visited various sites on foot on unnamed days under unknown conditions. Sediments were probed with an auger. Some visual observations were made of vegetation. Considering that the scope required an assessment of impairments, it is remarkable how many standard parameters were not recorded, for example: --water depth, color, and odor --bank condition --turbidity --suspended sediments --conductivity (particularly meaningful for clay pollutants) --benthic invertebrates The absence of such observations greatly reduces the value of the survey for the purposes named. The authors also fail to identify any documents, plans, or data they reviewed in order to supplement the field visits. Did the proponents produce any? Apparently they were neither looked for nor provided. |
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| "LOST"
WETLANDS Several large and badly-damaged wetlands escaped the surveyors' notice entirely. For instance, no data is supplied regarding the two-acre wooded swamp at the head of the Cunningham Brook drainage (marked "A" on accompanying aerial), even though it receives runoff from a large portion of the project site. Neither did they evaluate the elongate, low-lying section of the brook downslope of the east end of Lyman Road (marked "B") even though, like the first area, it is plainly indicated on the Dept's 1:5000 wetland orthophoto maps. Even when sites were visited, sampling locations are hard to determine from the narrative and maps. An arrow marked "3" on the first of these maps (at right) points to a steep ledge, not a wetland. The text descriptions in this area are not sufficiently specific to identify the sites. The routes by which sediments reached them are not described either. SEDIMENT MAPPING |
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The
Plan's scope required the authors to "identify and map any areas where
silt and/or clay materials have been deposited and the depth of these
materials." |
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--that most sediments are mixed, and most deposits are not well-sorted --that nearly all sediment transport takes place during infrequent high-flow events --that most erosion and sedimentation occur at or near the period of peak flow --that peaks are long past by the time fine particles precipitate in a quasi-uniform surface layer |
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It should be noted that the authors nowhere mention many obvious signs of recent and major erosion along the stream channels surveyed. This erosion provided much of the material later mixed with site-derived sediments and deposited elsewhere. By limiting their observations to the depth of unmixed "silt and/or clay materials" laid down at the tail end of storm events atop deeper and more diverse substrates, the authors appear completely unaware of processes responsible for the majority of sedimentation that occurred along the stream corridors visited. Along Cunningham Brook, for instance, where it broadens into a five-acre wetland downstream of the lower bridge in Cunningham Park, the authors write Sedimentation impacts to the Bordering Vegetated Wetland between Cedar St and the gas easement are observable on the ground surface to a depth of approximately 1/16" to 1/4", with an average of 1/8" observed. Here they record only a small fraction of these impacts, neglecting to note that beneath the fine surficial sediments a much deeper horizon of clay mixed with varying amounts of sand, silt, leaf litter, and organics typically occurs. This mixed horizon often extends down 4-6" or more. Its base is easily recognized where it rests on a predominantly fibrous natural organic soil. The transition marks the limit of disturbance by recent high-flow events. By ignoring this horizon, the authors completely overlook most of the "fine silt and/or clay" deposited in the area, which forms a large delta-like apron at the head of the wetland. This omission becomes particularly egregious at Black's Creek, the estuary downstream from Cunningham that flows to Quincy Bay. Here the Plan states: No evidence of sedimentation, colloidal or otherwise, was observed within any portions of the wetland or water bodies |
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This broad, marshy area might have been expected to become a primary focus of sedimentation, since so few low-gradient wetlands occur between it and the site (Russell Pond occupies a similar situation in Milton). Indeed, photos taken by naturalist Sue Dixon show the Creek's main channel opposite Putnam St. completely blocked by hundreds of cubic yards of recent materials, forcing it into a new alignment along the north bank. Other Dixon photos show the entire area flooded with water resembling fresh-mixed cement--the typical appearance of runoff from Quarry Hills (these photos were provided to the Dept. months ago, but were apparently never shown to the authors). |
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| In
the absence of further information, one cannot say what led the Plan's
authors to reach their conclusion of "no evidence of sedimentation."
Perhaps they climbed down the bank, saw none of the oyster-gray films
so prominent at Quarry Hills, and climbed right back up. It may have
never occurred to them that the Creek's tidal flows could blend such
deposits with dark-colored estuarine muds and silts almost immediately.
IMPAIRMENTS The October 1st, 2001 Consent Order states that: The Off-Site Wetland Restoration Plan shall include an evaluation of biological, ecological, and physical impairments There is no discussion of this requirement in the Plan. Apparently the authors believe that the only impairment they are required to consider is the deposition of unmixed surficial layers of "fine silt and/or clay" late in storm events. Moreover, the issue of toxic contaminants of various sorts in these sediments is never broached; they are assumed to be clean materials. This is not the case. Most of the soils brought to the site are urban excavate from downtown Boston, also called "historic fill." In addition, various wastewater treatment sludges from paper mills and municipal sewage plants have been used as capping materials. Last year the proponents received a "Dirty Dozen" award from MA Toxics Action for their substitution of these sludges for the required clean materials, and also for their inability to keep them on the site. The following is from FBH's nomination form submitted to MA Toxics: As the vast, steeply-sloped site is intended for public recreational use, the spreading of industrial wastes and sewage sludges across its surface is questionable at best, particularly in view of the developer's long-standing inability to control stormwater discharges. FBH has observed repeated losses of the contaminated sludges via erosion, and their transport downstream into parks, yards, and basements, where many people have been involuntarily exposed to them. |
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The best that can be said for the Plan is that it provides some useful
data regarding unmixed surficial fine sediment deposits in the wetlands
surveyed, although these deposits represent, as stated earlier, only
a small portion of the total off-site migration of materials from
the Quarry Hills project. |
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