OP-ED ON THE EXTREMELY SLOW CLEANUP PROCESS AT OLIN SUPERFUND SITE: It’s Not Over Till It’s Over – 15 Years & Counting

Below is an op-ed submitted by Wilmington resident Stephanie Baima:

This spring we have seen all manner of sustainability causes thawing and bouncing back to life, from the approval of Vineyard Wind to President Biden’s pledge to cut greenhouse gas emissions in half by 2030. As a Millennial who hopes and works for a future not ravaged by climate change, ecosystem collapse and the like, this is immensely relieving. There has even been some long-awaited progress on an environmental cause in town, on our very own Superfund site.

I have known about the Olin Chemical site since age nine, when my parents were solicited to enroll me in an epidemiological study. In 1999, DPH had been pressed to investigate a suspected cancer cluster in children living in south and west Wilmington, in the general vicinity of the 50-acre site, located at 51 Eames St. We provided extensive, detailed data on our household water usage and my health, however my awareness of the situation was mostly because one of the girls in my Girl Scout troop had leukemia. As I grew up, I learned about the polluted industrial site in neighboring Woburn, made famous by the film A Civil Action, and, via my love for Julia Roberts, Pacific Gas & Electric’s misdeeds in Hinkley, California, in the movie Erin Brockovich. I heard my parents and civically engaged neighbors mention Olin from time to time in the context of Town Meetings, and then I went off to college.

More than ten years later the COVID-19 pandemic brought me, like so many, back to my hometown. Having studied chemistry, and then governance and public affairs, I inevitably ended up getting involved with Olin. I’m by far the latest joiner to the Wilmington Environmental Restoration Committee (WERC) Technical Team, which sports a lean roster of five incredibly dedicated town residents who have doggedly pursued the clean-up of the site since the early 1990’s. These unpaid volunteers have found themselves not only up against a recalcitrant Olin, but at times the Town itself, eager to remediate the site just enough for it to be sold for redevelopment. Especially with the cancer cluster families held in limbo for two decades waiting for an answer on whether their maladies were connected to the contaminated groundwater, WERC’s have often been the loudest voices putting pressure on Mass DEP and US EPA, to do something.

So, how much progress has been made on the cleanup of the Olin site in the decade since I was last in town? Not as much as you would like to believe, and definitely less than it would appear to the casual observer.

According to EPA operating procedures, the site was divided up into three operable units (OUs), OU1 for contaminated soils on the property, OU2 for contaminated surface water including wetland sediments, and OU3 for contaminated groundwater. Since it was specifically our contaminated groundwater that led to inclusion of the site on the Superfund National Priorities List 15 years ago in 2006, resulted in the decommissioning of five of the Town’s wells (perhaps permanently) in 2003, and, not least of all since the contaminated water is now linked to the cancer cluster, it would logically follow that OU3 is the most important site unit. It is certainly that by which WERC measures progress and will ultimately measure success.

This March 30th, EPA released a Record of Decision (ROD), a 444-page anti-beach read containing the most comprehensive summary of site history, remediation activities, and data to date, as well as the agency’s choice of remediation strategies and activities going forward. This is some kind of progress, since a ROD is the foundational document from which remediation plans can be built, but at the same time it is just another piece of paper in a trail spanning four decades. Since 2007, with Olin and other prior owners and operators of the site under an EPA order, a Remedial Investigation and Feasibility Study were conducted. These produced data on health and ecological risks of the site, but are a far cry from “shovels in the ground.”

From: https://cumulis.epa.gov/supercpad/SiteProfiles/index.cfm?fuseaction=second.schedule&id=0100438

If you’re not yet underwhelmed, you should also know that the Olin site was added to EPA’s Emphasis List of Superfund Sites Targeted for Immediate, Intense Action in early 2019 – but taken off this January after – you guessed it – another piece of paperwork, a Proposed Plan for the cleanup, was issued.

Since these bureaucratic milestones are what there is to show for progress, it would be good if they were satisfying to the local community. To WERC at least, they leave much to be desired, beginning with EPA misleadingly referring to the ROD as the “final cleanup plan” in their press releases. OU3, the groundwater containing the contaminant of primary concern, n-nitrosodimethylamine (NDMA), is lying belowground, in soil and in bedrock fractures far from the Olin property, with the extent of contamination still not known. Because of this, there are data gaps which must still be filled before a plan can be made for remediation. Therefore, the “final cleanup plan” ROD has been issued only for OU1 and OU2, leaving the most important piece for later.

There’s also the matter of EPA’s responses to the public’s commentary. It’s usual for the agency to leave wiggle room in a proposal to accommodate some changes, but in this case, despite 100 comments from residents, WERC, the Town Board of Selectmen, Wilmington’s technical consultant GeoInsight, WWI LLC and an MIT Superfund advisory group, none were made.

Finally, while WERC’s membership has stayed consistent, the site’s cleanup was handed over from MA DEP to EPA in 2005 and there have been many personnel changes along the way. The result is that WERC knows the site, its data, and its history far better than the agency and therefore must frequently point out oversights, if not outright errors. This scenario is understandable but at times makes it very difficult to feel adequately served. A case in point: members of WERC were the ones to bring it to EPA’s attention that the temporary cap, a plastic membrane intended to keep precipitation from penetrating the contaminated soil, thus further spreading the contamination, was shredded earlier this year. The expectation that Olin would act like a responsible party and monitor the site adequately themselves is laughable, if you know the history.

This additional paperwork issuance and pathetic state of affairs didn’t stop Representative Moulton from praising the progress on the site. In his April press release, he said “Government exists to serve us, collectively, and a good test of whether it is working for the people as designed is whether it leaves our land and our environment safer and cleaner for generations and generations to come.” Well, sure, but which generation, exactly, will get to enjoy the safer and cleaner?

The gulf between what it will take for EPA, the Town, and politicians to claim success – a site that is able to be redeveloped – and what our community can consider success – the ability to use our groundwater aquifer and get our peace of mind back – is evident, both in the paperwork progress and in the surrounding self-congratulations. The families most impacted got a degree of closure on March 24th when DPH’s long-awaited epidemiological study was released, confirming “an association between childhood cancer and prenatal exposure to NDMA, or NDMA and TCE in Wilmington from 1990 to 2000.” Our community will continue our decades-long wait for real progress, now knowing for certain how toxic our groundwater is, and painfully aware that it will be the last thing cleaned up.

The next public meeting for the site will be held virtually via Microsoft Teams on Wednesday, June 23, 2021 from 6:30-8:30 PM. I strongly encourage you to attend, get your neighbors to attend, and add your voices to those demanding action, not paper.

In the meantime, it is fair to say that some progress has been made, but let’s save the congratulations for when there is actually something to show for it.

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