The Environmental Protection Agency (EPA) has scheduled a community/stakeholder information session, about the status and future of the WR Grace (WRG) Superfund site, for February 3 at 7pm. This post provides some background and links to further information to help area residents formulate their questions and comments about the status of the clean-up, what zoning allows on the site, the WRG proposed Solar Array, the Conservation Restriction* (CR), sewering, public water supply, access and traffic, and more.
**UPDATE 21 Jan 2021: Directions for joining the virtual meeting (via Microsoft Teams or by phone) are posted on the EPA website.

History and Background

The WR Grace Superfund site is located in southeast Acton and southwest Concord. From 1945 to 1991, the American Cyanamid Company, the Dewey & Almy Chemical Company, and then WR Grace, Inc. produced sealants for rubber containers, latex products, plasticizers, concrete, and other products on the WR Grace property at 50 Independence Road. Effluent wastes were disposed of in several unlined lagoons; solid and hazardous wastes were placed into an on-site industrial landfill. Discharges to the unlined pits continued until 1980. 

In 1978 it was discovered that toxins from the WRG facility had contaminated two of Acton’s (Acton Water District) drinking water wells, which were then shut down, resulting in immediate loss of 40% of the Town’s drinking water supply capacity. In 1980, WRG and EPA entered into a Consent Decree to clean up the waste disposal areas and restore groundwater to a fully usable condition. In 1983 the area was declared a federal Superfund site. The Superfund designation spans the WR Grace property, part of the adjacent Linde, Inc. property at 37 Lawsbrook Road, a residential cul de sac (Lexington Drive), and an area north of Lawsbrook Road that encompasses the School Street water supply wells (see Map 1, below). 

Map 1 (from the 2013 Site Update). Features of the full WRG Superfund site, which spans an area larger than the WRG property alone.

Remediation has been going on more or less continuously since 1980. Acton Citizens for Environmental Safety (ACES) was formed by Acton residents in response to the drinking water contamination at WRG. For many years, it was, along with the Town, a primary watchdog and monitor of the cleanup/remediation process and progress. Green Acton and ACES legally merged in 2016, and Green Acton has continued that monitoring role. In 2016, the Town of Concord took ownership of the 70 acres of WRG property on its side of the town line, and subsequently installed a solar array and a school bus depot on the parcel. The February 3 meeting will focus on the 185 acres of WRG property in Acton.

To dig deeper, follow the bulleted links below:

Map 2: the WRG property. The black line outlines the original WRG property. The diagonal dashed line is the Concord/Acton town line, and the swooping brown line is the train tracks. Red dots are Acton Water District public water supply wells, and the green area is the AWD water protection Zone 2. Note the areas set aside for Conservation Restriction and for the proposed Solar Array.
(map credit: Ron Parenti, 2020)

Status of the Superfund Cleanup

Remediation at the WR Grace Superfund site has spanned nearly four decades and continues today. The earlier phase of the cleanup focused on soil contamination (OU-1), and was carried out between 1994 and 1997.

As discussed in the 2019 Five-Year Review Report, the remaining remediation at the site focuses on groundwater contamination (OU-3). The stated goals of the current cleanup are to restore the drinking water aquifer and to eliminate the threats posed by direct contact with or ingestion of contaminants in sediment in two areas: the North Lagoon Wetland (NLW) and Sinking Pond. For many years, various groundwater extraction and treatment systems operated at the property. The surface sediments at NLW and Sinking Pond were replaced with clean soil in 2011. Some progress toward re-vegetation of the NLW and the banks of Sinking Pond has been documented by WRG consultants, with sparse and patchy vegetation being observed. However, efforts to re-establish trees and shrubs do not yet appear to be successful: there are few surviving planted trees and shrubs on the pond’s banks.

Currently at the property, natural processes are being allowed to decrease contaminant concentrations and break down contaminants through Monitored Natural Attenuation (MNA). Grace contractors continue to collect and analyze groundwater at the site for volatile organic compounds (VOCs), inorganic compounds such as arsenic, and geochemical parameters such as pH. According to the Five-Year Review Report, contaminants on the majority of the property appear to be attenuating well, with the exception of a cluster of wells near the former Primary Lagoon, which have recently shown rising levels of VOCs (vinyl chloride and vinylidene chloride). Contaminants present on the property, but not included in the site’s Record of Decision and remediation plan, include 1,4-dioxane and per- and polyfluoroalkyl substances (PFAS). 

The Industrial Landfill area of the property has been capped and does not require any additional remedial activities, but will require an Activity and Use Limitation (AUL) to be applied to the property’s deed. The AUL would require that the cap be maintained and prevent the disturbance of the landfill and cap by future owners or users of the land. The presence of the landfill area and subsequent AUL will restrict, but not necessarily prevent, future development in this area of the property. 

The Acton Board of Health has an administrative hold on the installation of private irrigation wells within 500 feet of the mapped groundwater contaminant. According to the Five-Year Review Report, additional institutional controls may also be needed, and the form of these controls is not yet agreed between EPA, MassDEP, and the Town. In any case, any new development on the WR Grace property would not be able to rely on on-site wells as water sources.

Zoning

The WR Grace properties, the adjoining Linde, Inc. properties, and properties along Knox Road are zoned as “Technology District (TD).” Under Acton’s Zoning Bylaw, the allowable uses in the Technology District include: Agriculture, Conservation, Municipal, Educational, Religious, Public or Private Utility Facilities, Child Care Facility, Commercial Educational or Instruction, Community Services Organization, Office, Health Care Facility, Repair Shop, Technical Shop, Studio, Building Trade Shop, Parking Facility, Transportation Services, Warehouse, Manufacturing, and Solar Photovoltaic Installation. Other uses may be possible by special permit from the Board of Selectmen.

Solar Array

At an October 2020 Board of Selectmen meeting, WR Grace representatives presented a proposal for a solar panel installation on a portion of the Grace property. The proposed installation would be in the northeast corner of the area south of the tracks (see Map 2). The entire installation of 5 Megawatts of DC capacity, plus batteries for storage, would be approximately 30 acres. It includes some cleared areas where parking lots and buildings would be, and many acres that were meadows when WR Grace ceased operations, but which have since reverted to forest. In Acton, clearing more than an acre of trees to install a solar array requires a variance; a permitting hearing is scheduled for February 16. There’s a trade-off to be considered between the environmental benefit of forests and the environmental benefits of solar panels. A small part of the electricity output would be used to power cleanup operations at the Superfund site, but most of it would be sent back to the grid to add more renewable energy to it. The plan would also be subject to review by Eversource and the Acton Board of Health.

2009 Sewering Settlement and Conservation Restriction

The WR Grace site is within Acton’s Fort Pond Sewer district. Although no connections to the system have been built, WR Grace was charged the “sewer betterment” fees for the ability of its various parcels to connect to the sewers. WR Grace sued the Town in 2009 arguing that many of the parcels would never connect to sewers.

Arbitration resulted in a settlement, approved by Acton Town Meeting in 2009 (Article 49), with these features:
• a 15-acre area north of the MBTA commuter rail tracks (see Map 2) was permanently restricted from development, via a Conservation Restriction
• a corridor from Lawsbrook Road (between Lexington Drive and Linde, Inc.) is reserved for two purposes: the Town of Acton can use it to monitor the Conservation Restriction, and WRG retains the right to build a road there to access the non-protected parcels to the west of the restricted land
• the number of sewer betterment units (SBUs) was reduced on a number of the parcels; this reduced the amount WRG had to pay, and reduces the size of any future sewering

* A Conservation Restriction (CR) is an agreement to prevent or restrict the development of a piece of land. In Massachusetts, the state verifies that there are environmental elements worth preserving on land parcels proposed for CR status. Conservation Restrictions are agreements between a parcel’s owner, the holder of the restriction (in this case the Town of Acton), and the Commonwealth. 

Access and Traffic

There are four potential access points to the WRG property, via: 

  1. Independence Road (south of commuter rail tracks)
  2. Parker Street (north of commuter rail tracks) 
  3. Lawsbrook Road (north of the MBTA commuter rail tracks) 
  4. Route 62 (Powdermill Road) via Knox Trail (south of commuter rail tracks)

Independence Road was the historical access road to the WR Grace plant. It passes through a quiet, low-density, residential neighborhood, with the WRG entrance at the far end. 

Parker Street is a residential country road. A narrow strip (approximately 300 feet) of Parker Street frontage lies adjacent to the railroad tracks, across from the eastern end of River Street.

The WRG property includes a long, narrow north/south-trending access road from Lawsbrook Road to the northern part of the property, ending at the area now under Conservation Restriction. The terms of the CR agreement (see above) preserve the possibility that access could traverse that narrow strip, then travel around the east and south edges of the Conservation Restriction area, and into undeveloped areas north of the train tracks.

Of the roads surrounding the WRG property, Route 62 has the greatest capacity for additional traffic, and the industrialized Knox Trail comes close to the south edge of the WRG property. It is not clear whether WRG has suitable access across intervening properties. The 2005 Preliminary Reuse Assessment by EPA includes a November 11, 2004 memo from the Town of Acton noting easements on old deeds that might provide access from the north end of Knox Trail along a narrow way called “Plant Road.”

Public Water Supply Wellfield Protection

The WRG parcels south of the MBTA commuter rail tracks lie in close proximity to the AWD Assabet wellfields, which house drinking water supply wells for the town of Acton (see Map 2). Collectively, these wells provide more than 50% of the water used in Acton on a typical day. Thus, care must be taken to ensure that this resource is not compromised by any future development of the WRG property. Though water from these wells is treated by the South Acton treatment plant, this facility was designed to remove the VOCs that polluted the aquifer when WR Grace was in operation. This treatment technology might not be effective in eliminating other types of contaminants, such as nitrogen, certain petroleum byproducts, or emerging contaminants.

In view of the importance of the Assabet wells to the town of Acton, any proposed reuse of the WR Grace properties must be carefully reviewed by elected Town officials, Town boards, and the Acton Water District to guard against the introduction of a new pollution source, or a change to the dynamics of existing contamination. A segment of the WRG property south of Independence Road lies within a groundwater protection Zone 2 district (see Map 2), and just beyond the 400-foot Zone 1 protective radius of the Assabet 3 well. 

Recent correspondence with AWD staff indicate that reuse proposals likely to be viewed favorably by AWD include passive uses and structures, such as the proposed Solar Array (see above). On the other hand, strong objections would almost certainly be raised by the district to any project that would require the storage of hazardous materials, or large volumes of wastewater discharge to the underlying aquifer. Structures such as a residential development, office park, or school might be acceptable if the likelihood of aquifer contamination is found to be negligible. As part of the permitting process, the AWD would require a detailed evaluation of factors such as water use, rainwater management, and sewage disposal.

Other Possible Development Ideas 

In 2005, EPA conducted a reuse assessment at the site, working with WR Grace and local stakeholders. The report from that assessment is out of date, but may contain some good ideas. 

At the October 2020 Board of Selectmen meeting, Acton residents spoke in favor of some other ideas, including a commuter parking lot with a shuttle to the South Acton commuter rail station, and an east-west, shared-use bicycle and pedestrian path connecting River Road in Acton to West Concord.

**UPDATE 27 January 2021: The NMI/Starmet Reuse Planning Committee of the Town of Concord recently released a draft report outlining reuse options for the NMI Superfund site. Although the NMI and WRG sites differ in important aspects, this report addresses some issues that will also need to be considered at WRG, and may trigger some ideas or questions.

Bring Your Ideas and Questions on
February 3!

Do you have other ideas or questions? Bring them to the February 3 meeting. How might development of the WRG property impact you as a neighbor, a water user, a taxpayer, and/or a commuter? 

This web post was co-created by Green Acton WRG Working Group members Kim Kastens, Richard Keleher, Ariel Newman Wright, Ron Parenti, and Jim Snyder-Grant.

A Heads-Up: Prep Your Questions and Comments for WR Grace Status and Reuse Meeting

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