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Mass EPA letter
in response to my inquiry 12-2-2016

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- email string with the geologist who handled the clean up -

paved paradise

Here's the email mentioned in the first series of letters, on the introduction page. Mr Dumas, connected me with the geologist, who handled the clean up. After my response to Mr Heely, I never heard from either of them again. It wasn't until I wrote the mayor a month or so later, did the subject reemerge at any level, yet still no resolve and my questions remained unanswered.

-------- Original Message --------
Subject: RE: Lamb St Attleboro
From: <donna@equestdesigns.com>
Date: Wed, September 07, 2016 9:30 am
To: "Doug Heely" <dheely@esm-inc.com>
Cc: "Kevin Dumas" <mayor@cityofattleboro.us>

dpwMr Neely,
Your professional stamp means very little to me when satellite photography tells a very different story. And to conclude, because other government agencies were involved, indicates the job was done correctly, would be a big mistake on my part considering what I've seen and what I know about Massachusetts politics.

My father worked for Clean Harbors. He was responsible not only for clean ups but also transporting it to the appropriate site - some of these sites were are far as Niagara Falls, Ohio, and even Maine. His schooling in the area of environmental clean-ups was extensive and he also looked at the photography and saw what I saw, contaminated heaps on a new driveway.
That alone indicates these heaps have already contaminated the topside of the newly paved area - wouldn't it?  Doesn't this illustrate mishandled toxic waste?

And did you also notice a person climbing through the contaminated heaps? If it was performed as safely as you proclaim, why weren't there warning signs for anyone who might consider rummaging through the refuse heaps? PCB's aren't something you take lightly, neither are toxic metals or TCE.

Regarding TCE according to your report you stated, 
Since TCE has not been detected in any other samples (including soil), and has not been detected since 2008, we conclude that it is no longer a contaminant of concern."  Where did it go Mr Neely? I understand TCE can dissipate in the air rapidly, but soil and groundwater are a different story - it's a much slower process. You found TCE in 2008. When do you suppose the contaminant invaded the area? Likely within the 100 years Mossberg was in business - and then it just disappeared. I think you needed to test further.

Now, regarding the likelihood of salt acting as a carrier for the toxins. Facing the DPW,  the left side of the lot was previously dirt/ledge according to the satellite photography.  I'm not sure what you concluded regarding paving over old rock Mr Neely, but according to what I understand ledge/rock is porous, and Mossberb toxins, after 100 years, could very likely have penetrated this ledge well beneath the surface. 

I asked for proof that Lamb St was tested and proved clean on both sides of the DPW - the ledge and the soil.  I don't have anything that states this - instead these tests in fact confirmed contamination and the removal of some contamination and  transporting it to City of Attleboro waste water treatment plant sludge landfill on Pond Street - while other soil was reused.

" Some of the soil removed contained debris from the former Apco Mossberg building.  This soil was deemed not suitable for reuse within the footprint of the new building for structural reasons, and was reused in the southern corner of the property." 

I'd like the entire property retested including, air quality in the bays, salt, soil tests, and even rock beneath the driveway. Considering what is at stake, I don't feel I'm asking for much.

 I've sent a hardcopy of my email, including photography to the EPA in Washington and Massachusetts and hope to hear from them soon. The state referred the Maple Ave clean up in Seekonk to the Federal EPA - they are currently cleaning the Attleboro Dyeing and Finishing Company site and I'll take my matters of concern there personally.

I have to say Mr Neely you didn't address any of my concerns in a way which would satisfy me, instead you left me with many more questions while burying me in digital reports.

Thank you anyway,
Donna Lacourse

Here are the heaps on a newly paved driveway:
Lamb St Attleboro Google Maps   

-------- Original Message --------
Subject: RE: Lamb St Attleboro
From: Doug Heely <dheely@esm-inc.com>
Date: Tue, September 06, 2016 12:29 pm
To: "donna@equestdesigns.com" <donna@equestdesigns.com>
Cc: Kevin Dumas <mayor@cityofattleboro.us>

google satellite image enhancedDear Ms. Lacourse;
My name is Doug Heely, and Mayor Dumas asked me to respond to your email.  I have been working with the City overseeing a variety of environmental matters since 2006.  I am a Licensed Site Professional (LSP), which means I am licensed by the State to oversee the assessment and cleanup of properties impacted by oil and/or hazardous materials. 
I have overseen all of the assessment and cleanup work at the Lamb Street site since 2008.  There are many, detailed reports that have been submitted to MassDEP to document the assessment and cleanup of this property. 
All of these reports are available online: http://public.dep.state.ma.us/fileviewer/Rtn.aspx?rtn=4-0000439.   Note that this link also includes reports for other projects in the City, including environmental work related to the construction of Riverfront Drive.
You should also know that the Lamb Street property is covered under the City’s Brownfield Support Team initiative.  This Team includes people from EPA and MassDEP, among other agencies.  Therefore, there have been many layers of review and approval to ensure that all work is done in accordance with state and federal regulations.
The cleanup and redevelopment of Brownfield sites, like the former Apco Mossberg site, is vital to our economy and the environment.  Without these Brownfield programs, the numerous abandoned and contaminated sites that exist in New England would never be cleaned up.  The Brownfield programs are key to making sure that abandoned sites get cleaned up, and reused in an appropriate fashion.  The reuse of the Apco site as the new DPW is the perfect scenario, because after the cleanup was completed, the majority of the property was paved, and there are no activities that can or will disturb the subsurface.  Hence, it is simply not possible that salt stored in the new shed could ever be impacted by anything in the subsurface.
I can assure you that the cleanup of this site was done was in full accordance with the regulations, and that there are no health risks to anyone.  I would not put my professional stamp on the reports that have been submitted otherwise.
I would be happy to speak with you directly if you have any further questions or concerns.
Douglas Heely, PG, LSP
Environmental Strategies & Management, Inc.
273 West Main Street
Norton, MA  02766
508-226-1800 – office
508-226-1811 – fax
508-294-4298 – cell
From: Kevin Dumas [mailto:mayor@cityofattleboro.us
Sent: Friday, September 02, 2016 10:07 AM
To: donna@equestdesigns.com
Subject: RE: Lamb St Attleboro
Ms. Lacourse,
10 Mile River Lamb StreetThank you for your email and I understand your concern.  Attleboro certainly has its share of Brownfields sites (due to our industrial past) that we have been actively working on since I took office in 2004. 
The Lamb Street property has had extensive work done to it since that time and EPA, Massachusetts DEP, and licensed site professionals have been involved at this site.  I will inquire with the proper authorities to get a breakdown on what has been done on the Lamb Street property to satisfy your concerns.
Kind regards,
Kevin J. Dumas
Mayor | Office of the Mayor
City of Attleboro | City Hall - Government Center |
77 Park Street | Attleboro, MA  02703
p: 508.223.2222 x3221 | f: 508.222.2513 | mayor@cityofattleboro.us
From: donna@equestdesigns.com [mailto:donna@equestdesigns.com] 
Sent: Thursday, September 01, 2016 8:44 AM
To: mayor@cityofattleboro.us
Subject: Lamb St Attleboro
lamb street 2013 satelite imageLast September Attleboro broke ground to open a new DPW with salt barn and fueling station. None of this would be an issue if it hadn't built on a contaminated site.

The property is 101 Lamb St in Attleboro Massachusetts. Approximately 30 years ago there was a fire at Mossberg Co. and according to the EPA report last updated on June 27, 2011 on your website, the company manufactured tools, automobile starters, and spring kits. It was alleged years ago and commonly known in the town that this property was never supposed to be built upon. Well somebody found their way around that and labeled this toxic site a short clean up. Now, I've been watching clean-ups around town where lead is the contaminant, and what I've noticed is, these sites are on parking lots, buildings are torn down and refuse heaps remain for removal
What makes Lamb St much different is the fact that this lot was predominately land/soil and the clean-up, as I've shown in satellite photography on my facebook account, included removing mass quantities of contaminated soil. My problem is this, how do I know the city was able to remove all the soil that was contaminated considering it has been held in the ground by trees, brush, and other vegetation for about 30 years? Also, the business started in 1916, are you sure you have a complete record of that lot including any other environmental hazards?

The contaminates, according to the EPA report, included PCB's. From what I understand there is a certain procedure you are supposed to follow when dealing with such a toxic element, BUT there were no vacuum trucks, no drums, nobody monitoring the site. Instead a construction company handled cracking open the earth, which had remained intact all these years, and dug up massive piles of soil for removal. Where is the scientific proof for the residents of the city that the site had been cleaned? 

There are now new variables to consider with the buildings which have been constructed. First the fueling station, if any gasoline should leak underground and mix with these contaminants couldn't this pose an even greater threat/risk to the community? And taking into consideration the salt barn and the very nature of salt as a porous substance, indicates any toxic elements, beneath the surface of this barn, could be absorbed by this sand/salt mixture and ultimately poured all over town next winter. I'm sorry, but I need more than Wes's Construction trucks and state approval of a SHORT clean up to prove this site is safe. I see the potential for a much larger environmental event occurring when taking into consideration all the variables the site now presents.

Would you please provide documentation that the site was tested and proved clean, because according to the photography that wasn't a short-term clean up.
See the contaminated heaps at google maps:
Lamb St Attleboro Google Maps   
Lamb st images from 2013 and 2015 can be found here.
Thank you,
Donna Lacourse
398 South Main St 
Attleboro, MA 02703 



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