On October 22, 2019, Kim Kastens, a Green Acton Director and Chair of the Water Committee, traveled to the Headquarters of the Environmental Protection Agency in Washington, DC to make a request about remediation of 1,4-dioxane at the WR Grace Superfund site. The trip was in association with the Center for Health, Environment and Justice, a nonprofit that helps communities impacted by Superfund sites. The text of Kastens’s statement, which was approved by consensus of the Green Acton Directors, was as follows:
To: Environmental Protection Agency
From: Kim Kastens, PhD, on behalf of Green Acton, Inc.
October 22, 2019
My name is Dr. Kim Kastens, and I am here representing Green Acton, an environmental advocacy organization based in Acton, Massachusetts.
Our request to you today concerns the WR Grace Superfund site in Acton. We request that the Record of Decision for the WR Grace Superfund site be reopened, that 1,4-dioxane be added to the groundwater remediation plan, and that 1,4-dioxane-contaminated groundwater be extracted and treated.
Acton, Massachusetts, is a town of approximately 22,000 people, located 23 miles northwest of Boston. All of Acton’s tap water comes from groundwater wells within the town limits. Contaminants from two Superfund sites — WR Grace and Nuclear Metals, Inc. (NMI) — have leaked into Acton’s groundwater and threatened the town’s water quality.
The Nuclear Metals, Inc. Superfund site (in neighboring Concord, Massachusetts) is the source of a plume of VOCs (volatile organic compounds) and 1,4-dioxane that traveled across the town line and reached one of Acton’s town water supply wells. The NMI Superfund project has successfully intercepted this plume with an extraction well. Just this past summer, the 1,4-dioxane treatment system installed by EPA’s contractor succeeded in treating the extracted water to the level at which 1,4-dioxane was non-detectable. We thank you for your efforts and congratulate you on your success at the Nuclear Metals, Inc. Superfund site.
Our other local site, the WR Grace Superfund site, is also leaking VOCs and 1,4-dioxane into Acton’s groundwater. The VOCs have been successfully treated over many decades of effort. However, the groundwater remediation plan for the WR Grace site does not include 1,4-dioxane, because the Record of Decision was signed before 1,4-dioxane was recognized as a Contaminant of Concern.
As you know, 1,4-dioxane was widely used as a solvent and stabilizer in industrial applications. It is a clear liquid that migrates easily in groundwater and tends not to biodegrade. The EPA Technical Fact Sheet on 1,4-dioxane describes it as “likely to be carcinogenic to humans by all routes of exposure.”
The Massachusetts Department of Environmental Protection has established a guideline of 0.3 µg/L for 1,4-dioxane in drinking water. At the Nuclear Metals Inc. Superfund site, EPA’s remediation plan has a slightly higher target, of 0.46 µg/L. During the 2017–2018 round of sampling at the WR Grace site, the 1,4-dioxane measured in groundwater samples reached as high as 25 µg/L. This is more than 50 times EPA’s target for remediation at the NMI site.
Treatment to remove 1,4-dioxane from water is difficult. There is no one-size-fits-all, off-the-shelf technology, and the available processes are susceptible to problems arising from other chemical attributes of the influent water. EPA has already invested time, money, and technical expertise in figuring out how to treat 1,4-dioxane in Acton’s iron- and manganese-rich groundwater through its work on the NMI plume. This investment can be leveraged, and a relatively easy triumph can be had, by applying the hard-won technical prowess from the Nuclear Metals site to the nearby WR Grace site.
The Record of Decision for the groundwater of the WR Grace site was signed in 2005; 1,4-dioxane was discovered in the groundwater of the site in 2006. If the timing had been just slightly different, surely 1,4-dioxane would have been included in the remediation plan, just as it was when the Nuclear Metals, Inc. ROD was signed in 2015.
It’s not too late to rectify this accident of timing and remove this poison from Acton’s groundwater. We request that EPA:
- reopen the Record of Decision for the groundwater cleanup of the WR Grace Superfund site
- add 1,4-dioxane to the remediation plan
- thoroughly characterize the distribution of 1,4-dioxane in the groundwater in and around the WR Grace Superfund site
- develop a plan to extract the worst of the 1,4-dioxane-contaminated groundwater
- treat the WR Grace 1,4-dioxane to the same level (0.46 µg/L) as is being done for the Nuclear Metals plume
This request is endorsed by the Commissioners and staff of the Acton Water District, who have provided a letter of support.
Thank you for your attention to this request. We look forward to working with EPA staff and contractors, the Town of Acton, and the Acton Water District to ensure that Acton’s groundwater and drinking water are safe and clean.