Category Archives: WR Grace Superfund Site

2016 Green Acton comments on WR Grace cleanup plan

Below is the text of Green Acton’s 2016 letter to the EPA about the Grace cleanup site. A PDF is available here Continue reading

Additional Sources of Information

For more information on the WR Grace Superfund Site in Acton, Massachusetts: Continue reading

Public Repository of WR Grace Documents – Additional Information

The Acton Memorial Library maintains a public repository of documents about the WR Grace Site. These documents, dating back to the 1970’s, can be found in a loft area (accessed by a small spiral staircase), above the Civil War exhibit on the second floor of the library. (Please ask at the reference desk, if you need assistance.) WR Grace documents are also available for public review at the Acton Health Department in Acton Town Hall.

Many of the documents before 1997 concern the identification and cleanup of contaminated sludge and soil from onsite lagoons and other disposal areas. More recent documents focus on the groundwater contamination that extends beyond the borders of the WR Grace property, reaching both the Assabet River to the south and three public water supply wells to the northeast. (The Acton Water District treats the public water supply to meet all applicable water quality standards.)

Overview Documents:
For an overview of past and current issues at the WR Grace Site, see the following documents:

1. Draft Phase II, Remedial Investigation Report, for the WR Grace Site, Acton, MA, Aug. 30, 2002, by GeoTrans
(In Volume I: See the text, especially Sections 1 through 3; In Volume II: See Appendix B)

If you are interested in further information about the WR Grace site, the August 30, 2002 Remedial Investigation Report (RI) is a good place to start. The text in Volume I provides an overview of the site. (Section 3 of the text provides details on the contaminants, including a more extensive list than the usually cited benzene, VDC, vinyl chloride, arsenic and manganese.) The figures include cross sections of the benzene, VDC, and vinyl chloride plumes, and the distribution of inorganic compounds (arsenic, manganese, iron, and aluminum) in groundwater onsite. Large site maps (24” X 36”) are also included in this and many other WR Grace reports. Appendix B (in Volume II of the RI), provides two lists of the contaminants that exceed water quality standards—one list organized by chemical name, and the second by sampling location.

2. Annual Groundwater Monitoring Reports (2003 through Current Year)
These reports, usually available in the spring of each year, include plume maps showing the location and concentrations of VDC, vinyl chloride, and benzene in groundwater at the WR Grace Site from the prior year’s annual sampling. They also discuss any changes in contamination levels compared to previous years, and any issues of current concern. Contaminants currently sampled in groundwater include volatile organic compounds, inorganic compounds, 1,4-dioxane, and geochemical parameters.

3. Five Year Review Reports Issued by EPA, (September 1999, September 2004 and September 2009)
Five Year Review Reports include a summary of the history of the site and actions taken to address contamination, as well as site photos, maps, tables, and an assessment of the protectiveness of the cleanup of soils at the site. (Five Year Reviews by EPA are required as part of the Federal “Superfund” process because “hazardous substances, pollutants, or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure.”)

Public Repository of WR Grace Documents

The Acton Memorial Library maintains a public repository of documents about the WR Grace Site. These documents, dating back to the 1970’s, can be found on the second floor, in the oldest portion of the library. (Please ask at the reference desk, if you need assistance.) WR Grace documents are also available for public review at the Acton Health Department in Acton Town Hall.

Many of the documents before 1997 concern the identification and cleanup of contaminated sludge and soil from onsite lagoons and other disposal areas. More recent documents focus on the groundwater contamination that extends beyond the borders of the WR Grace property, reaching both the Assabet River to the south and three public water supply wells to the northeast. (The Acton Water District treats the public water supply to meet all applicable water quality standards.)

If you are interested in further information about the WR Grace site, the August 30, 2002 Remedial Investigation Report (RI) is a good place to start. The text in Volume I provides an overview of the site. (Section 3 of the text provides details on the contaminants, including a more extensive list than the usually cited benzene, VDC, and vinyl chloride.) The figures include cross sections of the benzene, VDC, and vinyl chloride plumes, and the distribution of inorganic compounds in groundwater onsite. Large site maps (24” X 36”) are also included in this and many other WR Grace reports. Appendix B (in Volume II of the RI), lists the contaminants that exceed standards in two ways—by chemical name, and by sampling location.

**** Draft Phase II, Remedial Investigation Report, for the WR Grace Site, Acton, MA, Aug. 30, 2002, by GeoTrans, (In Volume I: See the text, especially Sections 1 through 3; In Volume II: See Appendix B)****

According to the current site schedule, WR Grace will submit the following critical documents during Spring 2004. These documents will be available for public review in the public repository at the library.

1. Public Health Risk Assessment
2. Ecological Risk Assessment
The two risk assessments will determine which areas of the site will require remediation (cleanup).

3. RI/FS: Remedial Investigation/Feasibility Study: The Feasibility Study will assess different technologies and approaches to remediate the site and will propose a cleanup strategy. Public comment is welcome.

Background Information for Maps and Tables (Read First)

Many of the maps and tables on this website are from the Draft Remedial Investigation Report, OU-3, WR Grace Superfund Site, Acton, MA, by GeoTrans, Inc. August 30, 2002. The Remedial Investigation Report (“RI”) was produced by WR Grace’s consultant, GeoTrans, in order to comply with federal requirements as part of the EPA “Superfund” process. This “RI” Report is available in the Public Repository at the Acton Memorial Library.

A. MAPS

The WR Grace property, comprises approximately 260 acres, and is located in the southeastern corner of Acton, and part of Concord. It is accessed from Independence Road, off of Parker Street in Acton. (See Map 1- Area map.)

The WR Grace Superfund Site includes all locations on and off the WR Grace property that have been affected by the migration of contaminants from the Grace property. The site therefore extends to the Assabet River in the south, (near Route 62) and beyond Fort Pond Brook to the northeast (near Route 2, and School Street Extension). See plume maps.

Areas on the WR Grace Site that could have been sources of contamination are shown on Map 2 – Source Areas (Figure 1-3, from the RI.) The MBTA rail line, Sinking Pond, and Independence Road can be used as landmarks to help viewers orient themselves. The potential source areas include: the former Primary Lagoon, the former Emergency Lagoon, the capped Industrial Landfill, the former Secondary Lagoon, the former Boiler Lagoon, the former North Lagoon, the former Tank Car area, the former Battery Separator area, the former Blowdown Pit, and the former Neutralization Pit.

The locations of the five public drinking water wells affected by the site are marked on the contaminant plume maps: Assabet 1 and Assabet 2/2A are in the southwestern portion of the site. The three School Street Public Wells/Wellfields: Lawsbrook, Scribner, and Christofferson, are in the northeastern portion of the site. Additional contamination is being drawn to the School Street public drinking water wells due to their pumping.

Plume Maps
The dated plume maps, on this website, show the extent of contamination of groundwater as known at that particular time. VDC (vinylidene chloride, also known as 1,1-dichloroethene or DCE) is the most wide spread contaminant at the site. Additional maps showing cross sections of the VDC, benzene, and vinyl chloride plumes (so that one can see the relative depth of contaminants), can be found in the RI Report by GeoTrans, available in the public repository at the Acton Memorial Library. Figures showing the distribution of high levels of arsenic and other inorganic compounds are also included in the RI (See Figures 3-21 through 3-30).

1984 Map vs. Later Maps: The VDC contamination is depicted on the maps in color contours representing different contaminant concentrations, regardless of depth. Areas that are not colored may be “white” either because the area was never sampled (and there may or may not have been contamination there), or because the area was sampled and no contamination was found at concentrations above drinking water standards. A comparison of the 1984 map to the later maps illustrates this point. The lack of a delineated plume to the northeast in the 1984 map was due to a lack of data, not due to an absence of contamination. Contamination to the northeast was not delineated by WR Grace until after 2000.

Changes in the contaminant plume can be seen when comparing three VDC maps from 2001 and 2002 to each other. (Maps 4, 5, and 6). The apparent movement of the VDC groundwater plume across Fort Pond Brook in the northeast area, most likely reflects more extensive sampling information, rather than an actual migration of contaminants.

According to the 2002 RI Report, contaminant levels have decreased considerably on the southern part of the site since 1984 due to:

  • cessation of contaminant disposal in impoundments,/lagoons
  • the operation of the Aquifer Restoration System, and
  • source removal (soils)

To date there has not been any cleanup on the northeastern portion of the site.

Map Data:

VDC Contamination in Groundwater
Map 3, the 1984 map, depicts data collected by WR Grace before 1984 on the southern part of the site, as well as data collected between 1984 and 1987, by other investigators, on what is now known as the northeastern part of the Site.

Map 4 represents data collected between September 2000 and February 2001. This same plume is shown in the August 2001 EPA Community Update. (Street names and a dashed line depicting the limit of the Private Well Survey Area have been added to the figure.)

Map 5 represents data collected between July 2001 and June 2002. This is the same plume that is depicted in the Aug. 2002 RI Report (See Figure 3-3), and in the December 2002 EPA Community Update (See Figure 1). (Local street locations have been added to the figure.)

Map 6 shows a cross-section of the VDC contamination along a transect extending from the former Blowdown Pit to just past the Scribner Public Wellfield, from the same data set used to create Map 5. This same vertical distribution of the VDC groundwater plume is depicted in the Aug. 2002 RI Report (See Figure 3-5), and in the December 2002 EPA Community Update (See Figure 2). Map 6 allows one to see the relative and varying depths of groundwater contamination in the northeastern part of the site. Note that the contamination is at shallow depths at the blowdown pit which was a source area, and then is mostly deep and within the bedrock under residential areas, but then rises to shallower depths close to Fort Pond Brook, and Scribner, one of the School Street Public Water Supply Wells/Wellfields..

Map 7 represents data collected as part of the annual water quality sampling round between October 14, 2002 and November 12, 2002. A new round of sampling was completed in the Fall of 2003. The 2003 annual water quality data, along with corresponding plume maps should be made publicly available in early 2004.

Other Groundwater Contaminants
Map 8 represents the plume of vinyl chloride contaminated groundwater on the site, mapped using data collected between July 2001 and June 2002. This same plume is depicted in the Aug. 2002 RI Report (See Figure 3-9).

Map 9 represents the plume of benzene contaminated groundwater on the site, mapped using data collected between July 2001 and June 2002. This same plume is depicted in the Aug. 2002 RI Report (See Figure 3-15).

B. TABLES

Table 1. is the Summary of compounds detected in groundwater, August 2000-June 2002 that is found in the Aug. 2002 RI Report (See Table 3-3). This Table lists the VOCs, (volatile organic compounds), SVOCs (semi-volatile organic compounds), and Inorganic Compounds that groundwater was sampled for and the number of detections above a given “Screening Value” (water quality standard that was used as a benchmark).

Thirty VOCs were detected onsite, and 12 of these were detected above their screening value (See asterisks). Twelve SVOCs were detected onsite. Four of these were detected above their screening values. Twenty-three inorganic compounds were detected onsite, and 14 were detected above their screening values. Section 3 of the August 2002 RI Report provides further details and context to explain the significance of these results.

ACES Questions to ATSDR About Public Health

COMMENTS/QUESTIONS for the upcoming 2003/2004 ATSDR Public Health Assessment

Introduction: ACES has two main lines of concern about past and present contamination from the WR Grace Superfund Site, one related to following up on previously identified health risk concerns, and the other to addressing newly identified potential health risks. Our concerns are detailed in Sections A. and B. below.

A. Previously Identified Health Risk Concerns, Followup Needed
The 1992 ATSDR Public Health Study was never finalized, but it began a valuable assessment by looking at cancer rates at the CENSUS TRACT level in Acton and Concord, as well as looking at the concentrations of contaminants in Acton drinking water, and in soils, sludge, and groundwater at the WR Grace Superfund Site. Both the ATSDR and John Snow Institute studies noted that cancer has long latency periods, and as the ATSDR report stated in 1992 “Sufficient time may not have elapsed to allow cancer to develop.” Since 1992, eleven additional years of data should now be available. Also in the intervening years there may have been technological and analytical advances to allow a fuller assessment of the impact of the contaminants on public health. Therefore:

1. As part of the planned 2003/2004 ATSDR Public Health Assessment of the WR Grace Site, please assess disease rates at both the census tract level in Acton and West Concord, as well as town-wide in Acton.

2. Please include in the assessment all cancers tracked by the MA Cancer Registry, paying special attention to the cancers addressed by the John Snow Institute (leukemias, bladder cancer, colorectal cancers, liver cancers, non Hodgkins lymphoma, Hodgkins disease, and all cancers combined.)

a. Please assess both cancer incidence and cancer death rates.

b. Please include all data from the earliest possible date through the present. (JSI looked at cancer mortality data in five groupings: 1969-1973, 1974-1978, 1979-1983, 1984-1986, and 1987-1988; and at cancer incidence rates from 1982-1988.)

c. Please present data in a form so that rates from different time periods can be directly compared. (The 1995-1999 data cautions about comparing different data sets from different years.)

d. Please indicate any data limitations when assessing cancer data or trends. For example the MA Department of Public Health annual report on “Cancer Incidence and Mortality in MA 1996-2000” warns that some cancers may be under-reported due to how and where they are diagnosed –ie in a hospital or not, (leukemia, multiple myeloma, etc.). Also the actual incidence rates for some cancers with shorter survival times, (including liver and pancreatic cancer), may be 10% higher than initially reported due to delay and error. Please recheck all data, (including historical data), so that any corrections for under-reporting, error, or delayed reporting are made.

3. Please extend the assessments of infant mortality and low birth weights, up to the present, and provide and analyze all of the data from 1969 to the present.

4. One limitation that has been anecdotally related about previous assessments was that Acton’s population was too small and too mobile to fully analyze the effects of the WR Grace contaminants on public health. Are there any new statistical or other analytical tools available that can now be used to overcome previous limitations? Could space-time cluster analysis or other techniques be applied? Could the remaining population of long-time residents be identified, surveyed, and assessed for health effects? If so, please help with the planning for these assessments.

5. People exposed to contaminated drinking water were exposed to several chemical contaminants together. Please assess the possible synergistic and cumulative effects of human exposures to multiple chemicals in the body.

6. The 1992 ATSDR report concentrates on the potential relationship between chemical exposure and cancer rates. Please also assess other health-related outcomes that may be related to chemical exposure. These could include: chromosomal disorders, other birth defects, multiple sclerosis, Lou Gehrig’s disease, asthma, infertility, learning disabilities, autism, rates of ADD and ADHD, other Special Education needs, etc. Can Acton’s rates of these or similar health issues be compared over time to state rates? Are there any clusters of these conditions within Acton? Could any of these health issues be related to the chemical contaminants at the WR Grace Site?

7. A 1984 ATSDR memo stated that an epidemiological study was being conducted in Battle Creek, Michigan, that could be relevant to conditions in Acton since three of the contaminants being assessed were the same as ones from the Acton site. What were the results of that study? Please provide the Acton Board of Health, ACES and the Acton Memorial Library with hard copies of that and any other relevant studies from Battle Creek or elsewhere, including any ATSDR studies of the Superfund Site in Woburn, MA.

8. Please avoid generalizations and be as precise as possible, especially when describing potential health risks. Please use statistical means to explain risk rather than undefined terms such as “significant health risk”, “significantly increased risk of cancer”, “appreciable health effect”, or “excess cancer risk”, etc.

9. Please address the question of odors and possible health effects associated with airborne contaminants from the site.

B. Newly identified Potential Health Risks
Since 1992, a plume of contaminated groundwater to the northeast of the previously defined area has been newly delineated. This northeast plume of contamination is deep under residential areas, and is migrating towards and discharging to Fort Pond Brook and to three separate Acton public drinking water wells/wellfields known collectively as the School Street Wells. Up to 190ppb of 1,1 dichloroethene (also known as VDC or DCE) was measured in this plume, as of Fall 2002. (The drinking water standard for VDC is 7ppb.) WR Grace’s August 2002 Remedial Investigation Report states that the concentrations of contaminants reaching the public wells are expected to rise in coming years as the most concentrated part of the plume is pulled towards them. The Acton Water District treats the water from these wells with a stripping tower before the water is piped to consumers.

10. Since no treatment technology is 100 percent effective 100 percent of the time, please assess the health impacts of the contaminants from this northeast plume to drinking water customers, assuming no treatment of the water. What are the worst-case potential health impacts due to exposure via ingestion, dermal exposure, and inhalation?

11. Private irrigation wells in the plume to the northeast may have brought contamination to the surface in the past. Please assess any possible health effects this past exposure may lead to. Please also assess any potential synergistic effects that may have occurred if residents were exposed to WR Grace contaminants in conjunction with lawn chemicals.

12. Please do an analogous health assessment to that done for the previous question, assuming that in the future an irrigation well were to bring the most concentrated level of contaminants to the surface, both with and without accompanying human exposure to lawn chemicals.

Background Information on Public Health Questions

Public Wells Contaminated
In 1978 two Acton town wells were found to be contaminated with organic compounds. (Contamination was later found to have come from a nearby industrial site, now designated as the WR Grace Superfund Site.) These public wells, Assabet I and Assabet II, had been in operation since the early 1970’s, and in 1978 supplied 40% of the town’s drinking water. Contaminants included : Ethylbenzene, 1,1-Dichloroethylene (also known as DCE or VDC), Benzene, 1,1,1-Trichloroethane (TCA), Trichloroethylene (TCE), Methylene Chloride, Toluene, and Chlorobenzene.

Board of Health Forms “Health Risk Subcommittee”
In response to residents concerns about past exposure to contaminants in drinking water, the Acton Board of Health formed a “Health Risk Subcommittee”. This subcommittee enlisted the aid of experts in the field, including epidemiologists: Dr. David Ozonoff, Dr. Daniel Wartenberg, and Dr. Stephen Lagakos, and the then head of the MA Cancer Registry, Richard Clapp. Bailus Walker, Jr., Commissioner of The MA Department of Public Health wrote to Acton Health Director, Steve Calichman, in December 1985: “We agree that some of the contaminants are quite toxic and are potential carcinogens. The Department [MA Department of Public Health] will be pleased to work with you and your office in designing a surveillance system….We look forward to collaborating with you.”

1988: Health Study Proposed, to MA DEQE
In 1988, on behalf of the Acton Board of Health three epidemiologists, Drs. Wartenberg, Ozonoff, and Lagakos submitted a proposal to the Massachusetts Department of Environmental Quality Engineering. The proposed study, entitled “A Surveillance and Investigation Program to Assess the Health Status of Residents of Acton, MA”, included development of a computer model to “reconstruct flows from the contaminated wells over time to evaluate which residences got the contaminated water and how much they got. ….This information would be input to the epidemiological evaluations.”

DEQE Director Carol Rowan West responded to the proposal: “…funding is not available. Our present research budget has been reduced given the fiscal problems of the Commonwealth.”

Town Meeting Funds Study
The Board of Health subcommittee subsequently obtained funding from the Town of Acton via a warrant article, and The John Snow Institute, Center for Environmental Health Studies (JSI), carried out a “Town of Acton Health Surveillance”. (See description of JSI study by ATSDR below.)

1992 ATSDR Documents
The Agency for Toxic Substances and Disease Registry (ATSDR) prepared preliminary “Public Health Assessment—Initial Release (PHA-IR)” and “— Public Comment Release (PHA-PCR)” documents in 1992.

These reports summarized contaminant levels found in the Acton public drinking water wells, Assabet I and Assabet II, as well as in soils, sludge, and groundwater at the WR Grace Superfund Site. The ATSDR documents also included cancer incidence rates for bladder cancer, brain cancer, kidney cancer, leukemia, liver cancer, lung cancer, pancreatic cancer, and stomach cancer for the years 1982-1988 in census tracts 3631.01 in Acton, and 3612 in Concord, MA. When compared to statewide rates significantly elevated rates were only found for brain cancer in women in Concord. Colorectal cancer incidence rates were not included in the census tract data presented in the ATSDR reports.

The ATSDR reports also discussed an early 1990’s health study conducted by the John Snow Institute, (JSI), Center for Environmental Health Studies for the town of Acton, to assess the public health impact from potential exposure to contaminated drinking water.

According to the ATSDR 1992 report (PHA–PCR):

(Begin quotation from ATSDR report)

“JSI conducted a descriptive epidemiological study in Acton which involved comparison of cancer cases (incidence) and deaths from cancer (mortality), incidents of low birth weights and fetal deaths in Acton to expected numbers for Massachusetts as a whole.”

“JSI assessed cancer mortality rates for bladder, liver, [and] colorectal cancers and leukemia between 1969 and 1988. The overall cancer mortality rate in Acton was lower than the Commonwealth’s rate except for the 1984-1986 time period. In addition, JSI determined that the rates in Acton do not suggest a definite increase in any specific cancer. Cancer incidence data indicate a statistically significant excess of colorectal cancer among males and bladder cancer among females for the 1982-1986 time period. Since that review, JSI received 1987 to 1988 cancer incidence data which suggest that the rates for colorectal and bladder cancer for both sexes were below the Commonwealth’s rates.”

“Preliminary work conducted by JSI determined that the occurrence of low birth weights (less[than] 2500 grams) was slightly elevated in the time period between 1975-1979 (during the expected time of exposure) when compared to a later time period, 1980-1984. More recent findings suggest that the rate of low birth weights in Acton is not high.” [Definition of high??] “Additional work is in process to verify the most recent findings and to account for a number of confounding factors.” [confounding factors?]

“JSI reviewed state fetal death records (deaths which occurred after 20 weeks gestation). In comparing contamination period and post contamination fetal deaths to the Commonwealth’s rates, JSI found no association between different time periods which would indicate an effect of exposure to contaminated water. Distance from residence to Assabet Wells One and Two were plotted and no association was found between residence and proximity to these wells.”

“It was difficult for the author [author of ATSDR Report?] to assess the findings of this study because of the number of assumptions that needed to be made due to the inherent limitations in the data.”

“(1) In looking at the rates in Acton it is assumed all residents were exposed. Approximately 40% of the community received water from these wells, however, specific consumers of water from Assabet Wells One and Two cannot be identified.

(2) Rates were not compared to individual doses. This cannot be done because, in addition to not knowing who the actual consumers were, the duration of exposure and the concentration an individual ingested from tap water are unknown. The maximum time period of exposure is the time period the wells were opened from 1970 to 1978, an assumption can be made that the concentration detected at the time of closure is representative of the concentration in the wells between 1970 and 1978.

(3) Sufficient time may not have elapsed to allow cancer to develop. Some types of cancer take longer than 10 years to develop.”

(End quotation from ATSDR report)

Correspondence from the John Snow Institute, (July 18, 1991), echoes point number three made in the ATSDR report. Terry Greene from JSI wrote: “…it is important to keep an eye on the data as it arises over time in light of the long latency period between exposure to carcinogens and the actual development of cancer.”

JSI also wrote that they requested data from the MA Cancer registry on “…non Hodgkins lymphoma, and Hodgkins disease, as these cancers are sometimes associated with exposure to carcinogens.”

ATSDR Public Health Assessment – Status Update

On August 26, 2008 the federal Agency for Toxic Substances and Disease Registry, (ATSDR), held a public meeting in Acton on their Public Comment Release, ATSDR Public Health Assessment of the WR Grace Superfund Site in Acton, MA. Appendix G of this report is an Assessment of Cancer Incidence in Acton and Concord Census Tract 3612: 1982-2000 by the Massachusetts Department of Public Health.

At the August 2008 meeting they provided copies of the report, asked for verbal public comment and stated that there would be a public comment period until September 30, 2008 for written comments on the report. At the written request of the Town of Acton, Acton Water District and ACES, as well as state Senator Pamela Resor, ATSDR extended this public comment period to October 30, 2008. As of December 2010, ATSDR has not responded to the 2008 public comments it received, nor issued a final version of their Public Health Assessment.

*Click here to view the entire 2008 ATSDR Report.

Pages of interest include: (Note: Pages below are the actual page numbers of the report, not the “pdf” page numbers.)

Main Report Pgs. iv-v; Summary

Pgs. 1-2; Background; Site Description and History

Pgs. 23-24; Health Outcome Data: Summarizes Cancer incidence data for Acton; 1982-2000 for 6 selected cancer types; includes higher than expected occurrence of Central Nervous System (CNS) and brain cancer from 1982 to 2000, that was statistically significant during 1982-1987.

Pgs. 24-28; Community Health Concerns: Includes ATSDR’s responses to questions from a public meeting held in Acton, Oct. 28, 2003.

Pgs. 28-29; Conclusions

Pgs 29-30; Recommendations & Public Action Plan

Pgs 31-64; Responses to Comments Received: Provides ATSDR responses to public comment received to earlier drafts of the report, including questions submitted by ACES.

Pg. 122; Appendix G; Health Consultation, Assessment of Cancer Incidence in Acton and Concord Census Tract 3612: 1982-2000

Appendix G. Pgs. 1-2; Background & Objectives

Appendix G. Pgs. 8-14; Results of Cancer Incidence Analysis

Appendix G. Pgs. 10-11 Brain and Central Nervous System (CNS) Cancer; Higher incidences than expected in Acton from 1982 to 2000, Higher rate was statistically significant during 1982-1987. See discussion on pgs. 17-20.

Appendix G. Pgs. 12-13: Leukemia; Statistically significant elevation in leukemia during 1988-1993 in the Concord Census Tract that includes the WR Grace Superfund Site. See discussion on pgs. 22-24.

Appendix G. Pgs. 28-30: Analysis of Geographic Distribution of Cancer Incidence

Appendix G. Pgs. 30-32: Discussion

Appendix G. Pgs. 32-33: Limitations

Appendix G. Pg. 33: Conclusions

Appendix G. Pgs. 65-81 Risk Factor Information for Selected Cancer Types

Also see: ACES comments on ATSDR Health Study; Oct. 2008 to view ACES Oct. 30, 2008 comments on the August 2008 ATSDR Public Release Public Health Assessment
The full August 2008 ATSDR report can be viewed on the Town of Acton website, under Health Department, at: http://www.acton-ma.gov/DocumentView.aspx?DID=153
A summary of the report is at: http://www.acton-ma.gov/DocumentView.aspx?DID=152
*Note that the summary does not mention the statistically significant incidences of CNS and brain cancer, and leukemia found in certain time periods or census tracts in the area, nor the MA Department of Public Health’s comments on those incidences. (See Appendix G of the report.)*
Chronology of Current ATSDR Report:

October 2003—ATSDR Public Meeting in Acton Town Hall to gather concerns from the community. ATSDR planned to release a completed study in 2004.

August 2005—ATSDR provided copies of a draft study to the Town of Acton, Acton Water District and ACES. The Town of Acton and ACES submitted comments on the draft.

August 26, 2008—ATSDR held a public meeting at the ABRHS cafeteria to present results from the ATSDR Public Health Assessment. MA Department of Public Health officials also presented their “public health consultation” results: Assessment of Cancer Incidence in Acton and Concord Census Tract 3612: 1982-2000. The ATSDR report was made available to the public at the end of the public meeting. MA DPH results are included in the ATSDR document as Appendix G. Public comments were due by September 30, 2008.

September 10, 2008— The Town of Acton, Acton Water District and ACES sent a joint letter to ATSDR requesting a minimum of a 30-day extension of the public comment period. Senator Pam Resor sent a separate letter also making this request.

By October 28, 2010—Public comments from ACES and others are received by ATSDR, per comment period extension by ATSDR.

December 2010—status: ATSDR has not responded to the 2008 public comments it received, nor issued a final version of their Public Health Assessment.

Two Health-Related Studies

Two separate public health evaluations related to the WR Grace Superfund Site in Acton, MA have recently been conducted.

1. Public Health Risk Assessment (PHRA) by WR Grace, under the USEPA (US Environmental Protection Agency) guidance: This quantitative risk assessment was undertaken to help determine the future level of cleanup required at the site. It assumes exposure to contaminated groundwater on the site, at concentrations present when the PHRA was conducted. It does not assess public health risks related to previous contamination levels in the drinking water or elsewhere.

A July 1, 2005 Public Review Draft of the Public Health Risk Assessment was prepared for WR Grace by Menzie-Cura & Associates, Inc. and can be found in the public repository at the Acton Memorial Library. The risk assessment divided the site into six groundwater regions and found increased health risks in all six areas due to potential future exposures to groundwater contaminants. The assessed cancer risk in the six groundwater areas ranged from 2 in 1000 to 6 in 100 (PHRA Table ES-1).

See: Public Health Risk Assessment, EPA Superfund cleanup, for excerpts from the 2005 WR Grace Public Health Risk Assessment, conducted under EPA guidance.

EPA website: http://www.epa.gov/region01/superfund/sites/graceacton/

2. Public Health Study by ATSDR (Agency for Toxic Substances and Disease Registry): ATSDR (a federal agency under the Centers for Disease Control in Atlanta, Georgia) reported in 2003 that this separate study would consider past and/or present exposures to site contaminants and look at available public health data, including cancer rates. It would not evaluate the effect of exposure to multiple chemicals at once, but instead evaluate risk associated with each chemical in isolation. It also will not assess areas where it is assumes that there is no “completed exposure pathway”. The ATSDR study includes both qualitative and quantitative factors and “professional judgement”.

In August 2008, ATSDR released a public comment version of their Public Health Assessment. It generally found no apparent health hazard in most exposure scenarios, however it did note that the limited public well water data that was available from the late 1970’s had TCE levels that may have exceeded health guidelines. Also there was an increased lifetime risk from adult trespasser contact with contaminated sediments, and there was a higher than expected occurrence of central nervous system and brain cancer from 1982 to 2000, that was statistically significant during 1982-1987. (See Appendix G of the report for a discussion by the MA Department of Public Health on the central nervous system and brain cancer incidence.) See further information about the 2008 ATSDR study, including an index of topics at: ATSDR Public Health Assessment – Status Update . Also see: ACES Comments on ATSDR Health Study; Oct. 2008.

ATSDR website: http://www.atsdr.cdc.gov

Public Health Risk Assessment, EPA Superfund Cleanup

(See PHRA excerpts below)

As part of the USEPA (US Environmental Protection Agency) agency Superfund Site process, WR Grace was required to conduct a Public Health Risk Assessment (PHRA) for the site. This quantitative risk assessment, conducted under EPA guidance, was undertaken to help determine the future level of cleanup required at the site. It assumes exposure to contaminated groundwater on the site, at concentrations present when the PHRA was conducted. It does not assess public health risks related to previous contamination levels in the drinking water or elsewhere. A July 1, 2005 Public Review Draft of the Public Health Risk Assessment was prepared for WR Grace by Menzie-Cura & Associates, Inc. and can be found in the public repository at the Acton Memorial Library. The risk assessment divided the site into six groundwater regions and found increased health risks in all six areas due to potential future exposures to groundwater contaminants. The assessed cancer risk in the six groundwater areas ranged from 2 in 1000 to 6 in 100 (PHRA Table ES-1).

Following are some excerpts from the Executive summary of the 2005 Public Health Risk Assessment submitted to EPA by WR Grace & Co.

Excerpts from Executive Summary:
Public Review Draft
Public Health Risk Assessment
W.R. Grace & Co. Operable Unit Three
Acton, Massachusetts
Prepared by: Menzie-Cura & Associates, Inc.
July 1, 2005

Summary of Findings:
“The USEPA cancer risk range identified in the National Contingency Plan (NCP) is 1 in 1,000,000 (expressed as 10 exp -6) to 1 in 10,000 (expressed as 10 exp -4) over the course of a 70-year lifetime. In this assessment, cancer risks are categorized as below the USEPA cancer risk range (equal to or less than 10 exp -6), within the USEPA cancer risk range (greater than 10 exp -6 but equal to or less than 10 exp -4), or exceeding the USEPA cancer risk range (greater than 10 exp -4). For non-cancer health effects, a total target organ-specific hazard index that exceeds 1 is considered a potential cause for concern. In this assessment, target organ-specific hazard indices are categorized as either below or above the USEPA non-cancer hazard index benchmark of 1.”

Conclusions:
“The PHRA indicates that future residential exposures to untreated groundwater from the two public water supply wellfields and the Powder Mill Plaza irrigation well do not result in exceedances of USEPA’s cancer risk range or target non-cancer risk. Future residential exposure to tap water from the School Street Wellfield results in a target organ-specific hazard index of 2 from both arsenic and manganese. However, arsenic is below the MCL, and although the maximum manganese concentration exceeds the Federal Health Advisory, it is below the maximum background groundwater concentration. In addition, current exposures to all Site surface water bodies and wetlands, and future exposures to all but Sinking Pond and the North Lagoon Wetland do not result in exceedances of these risk management criteria.

Exceedances of USEPA’s cancer risk range and target non-cancer hazard index for a future wader/swimmer in Sinking Pond and a future wader in the North Lagoon Wetland are from incidental ingestion of arsenic in accessible sediment.

For Site groundwater, exceedances of USEPA’s cancer risk range, target non-cancer hazard index, or both are from potential future residential exposure to VOCs (mostly vinyl chloride), arsenic, and manganese in tap water (all areas) and irrigation water (all areas but the Southwest Area) from potential future private wells.”