HomeMy WebLinkAbout2009-12-01-BLUPC-rptWilliamson
Environmental LLC
280 Ayer Road, Harvard, MA 01451 e Office: (978) 862 -0110 • Fax: (978) 862 -0111
December 1, 2009
Mr. Dennis Busa
6 Westminster Avenue
Lexington, Massachusetts 02420
Subject: Opinion on Risk of Harm to Human Health
Busa Farm Pesticide Area P -2
52 Lowell Street
Lexington, Massachusetts
This letter has been requested to provide an opinion as to the potential risk that exists for future
use of the soil remaining in the immediate vicinity of pesticide area P -2 after the completion of
Limited Removal Action (LRA) activities. This letter should be reviewed in tandem with the Phase
1 and 11 Environmental Site Assessment Report — 52 Lowell Street, Lexington, Massachusetts
(Phase I & 11 Report) prepared by Woodard & Curran of Andover, Massachusetts, dated August
2009 and Williamson Environmental's Limited Removal Action Documentation Report (Pesticide
Area) — Revision No. 1 dated December 1, 2009.
Pesticide Area P -2 is an area within the northeastern most greenhouse where one (1) surface soil
sample (designated SS -6) was collected by Woodard & Curran for analysis of organochlorine
pesticide, chlorinated herbicide, organophosphorous pesticide, extractable petroleum
hydrocarbon, total arsenic, and total lead analyses. Analytical results of soil sample SS -6 indicated
that Endosulfan I and Endosulfan 11 were detected in said soil sample at concentrations of 0.51
and 0.53 milligrams per kilogram (mg/Kg), respectively. The Massachusetts Department of
Environmental Protection (MA DEP) reportable concentration (RC) for S -1 soil for both Endosulfan
I and Endosulfan II is 0.5 mg/Kg.
Woodard and Curran's Phase I & 11 Report recommended the following; "in the samples greenhouse
(sample SS -6), ... Endosulfan was detected at a concentration in excess of the Reportable
Concentration, but the MCP exempts notification where the detection of pesticides is attributable to
application of pesticides in a manner consistent with their labeling." To that end, an affidavit was
obtained from you (Mr. Dennis Busa) attesting to the fact that pesticides used within said greenhouse
were applied in accordance with the manufacturer's directions.
Despite being exempt from reporting criteria, Williamson Environmental conducted a LRA in the area
of P -2. The purpose of conducting LRA activities in pesticide area P -2 was to remove the pesticide
impacted surface soil located in an area of repetitive pesticide application. The P -2 excavation was
approximately 8 -feet by 5 -feet by 2 -feet deep in size. Soil observed in the excavation consisted of
medium- to coarse - grained sand with localized top soil and peat moss. Following soil excavation
activities, one (1) composite soil endpoint sample was collected from the base of the P -2 excavation
area (designated P -2) and submitted to a laboratory for organochlorine pesticide analysis via Method
SW846 8081A.
Review of the analytical results for the one (1) soil endpoint sample (designated P -2) collected on
September 24, 2009 from the pesticide area P -2 excavation area indicate that three (3) compounds
analyzed for were detected above MA DEP RCS -1. Chlordane, Endosulfan I and Endosulfan II were
detected in said soil sample at concentrations of 0.80, 0.61 and 0.57 mg/Kg, respectively. The MA
DEP RCS -1 for Chlordane, Endosulfan I and Endosulfan 11 are 0.7, 0.5 and 0.5 mg/Kg, respectively.
The presence of Chlordane, Endosulfan I and Endosulfan 11 in pesticide area P -2 is attributed to the
application of pesticides consistent with their labeling.
Opinion Letter
December 1, 2009
The maximum concentration of Endosulfan detected in soil sample P -2 was 0.61 mg /Kg, which is
below the MCP Method 1 Standards for S -1 soil for both GW 2 and GW -3 ground water. A
comparison of the analytical results of the soil samples to the MCP Method 1 Soil Standards for S -1
soil is presented below in Table A.
Table A - Endosulfan
Com arlson of Concentrations Detected and MCP Standards
Summary of MA DEP ShortForm Results
Concentration
MCP RCS -1
MCP Method 1
MCP Method 1
MA DEP HI Limit
detected in soil
(mg/Kg)
Standard for S -1
Standard for S -1
sample
6.00E -04
soil and GW -2
soil and GW -3
collected
ground water
ground water
9124109 m /K
1.00E -07
4.00E -03
Table PS -1
Endosulfan
0.61
0.5
200
1
Since the concentration detected (0.61 mg/kg) is less than applicable Method 1 Standards there
is no significant risk of harm to human health associated with residual concentrations of
Endosulfan in area P -2.
Chlordane was detected in soil sample P -2 at a concentration of 0.80 mg/Kg. That concentration
is above MCP Method 1 Standards for S -1 soil for both GW -2 and GW -3 ground water as
summarized below in Table B.
Table B - Chlordane
Comp arison of Concentrations Detected and MCP Standards
Summary of MA DEP ShortForm Results
Concentration
MCP RCS -1
MCP Method 1
MCP Method 1
MA DEP HI Limit
detected in soil
(mgft)
Standard for S -1
Standard for S -1
sample
6.00E -04
soil and GW -2
soil and GW -3
collected
ground water
ground water
9124109 m /K
1.00E -07
4.00E -03
Table PS -1
Chlordane
0.8
0.7
0.7
0.7
A Method 3 Human Health Risk Assessment was conducted using the MA DEP ShortForm
Version 4 -06, Vlookup Version v0808 for chlordane, downloaded from the MA DEP website
(http: / /www.mass.gov /dep/ service /complianceiriskasmt.htm). The ShortForm calculates a
numerical risk value for the concentrations of a compound in the form of Excess Lifetime Cancer
Risk (ELCR) and Hazard Index (HI) utilizing assumptions and calculations accepted by the MA
DEP. As outlined at 310 CMR 40.0993(6), a condition of no significant risk to human health
exists if an ELCR does not exceed one -in -one hundred thousand and a HI does not exceed one
(1). Presented below in Table C is a summary of the ELCR and HI calculated for chlordane for
residential, park visitor, trespasser and construction worker scenarios as defined in the
ShortForm.
Table C - Chlordane
Summary of MA DEP ShortForm Results
ShortForm Table
ELCR
HI
MA DEP ELCR
MA DEP HI Limit
Reference
Limit
Resident — Soil:
6.00E -04
1.00E +01
Table RS -1
Park Visitor — Soil:
1.00E -07
4.00E -03
Table PS -1
1.00E -05
1.00E +00
Trespasser — Soil:
6.00E -09
4.00E -04
Table TS -1
Construction
4.00E -09
3.00E -03
Worker — Soil:
Table CW -1
Page 2 of 3 Williamson
Environmental LLC
Opinion Letter
December 1, 2009
As indicated on Table C, the concentration of chlordane exceeds the ELCR and HI for a residential use
scenario. It is our understanding that the proposed use of the Busa Farm property will be for passive
recreational use /sport fields and uses consistent with the risk assessment scenarios for park visitor,
trespasser and construction worker.
It is the opinion of Williamson Environmental that if the residual concentration of chlordane detected in
soil sample P -2 represented a reportable release condition and was subject to MA DEP jurisdiction, that
the concentration detected in soil sample P -2 would not represent a condition of significant risk of harm to
human health for uses consistent with the risk assessment scenarios for park visitor, trespasser and
construction worker.
Please call the undersigned if you have any questions.
Sincerely,
Williamson Environmental LLC
r: Joseph Resca
2009.12.01
16:22:36 - 05'00'
Joseph A. Resca
Senior Project Manager
Page 3 of 3 Williamson
Environmental LLC