LNAPL Update

After seven years and eight months of battling Enbridge and their cohorts, it finally happened. FRRACS made a slight mistake. We at FRRACS are big on the truthiness, so we want to let you know about this and explain--to the best of our ability--what is actually going on.

Many of you are familiar with the PIP (Public Involvement Plan) process in which we have all been involved since approximately November of 2017. This process is in regards to the contamination on the compressor site and all adjoining parcels of land, including King's Cove Park. The PIP forces Enbridge to inform the community of the contamination and what they are going to do about it. It also allows us our say over how they are going to safely work in an area that is simply a toxic waste site--one that should have been deemed a Super Fund Site decades ago. But we digress. Enbridge employs TRC as the Licensed Site Professionals (LSPs), and we have had many public meetings regarding how toxins were to be handled while constructing this unnecessary compressor station.

The toxins in question, briefly, are coal ash, coal clinkers, asbestos bricks, and LNAPL (Light Non Aqueous Phase Liquids--#2 and #6 diesel oil and diesel oil additives). It is the LNAPL that garnered us our first error in this case!

Before we go on to explain the LNAPL and where we got caught in a misstep, we would like to take a moment to give a big shout out and thank you to Margaret, the Queen of the PIP-sters! Without a law or an engineering degree, Margaret has kept us on the straight and narrow with this particular project for these past five years. Her eagle eyes and attention to every detail forced Enbridge to at least make a pretense of caring about the toxins and to develop a plan to deal with all of them during construction and beyond. And Margaret will make sure that we do not stray from our mission of protecting our Basin home from the disbursement of the toxins on the North Parcel. We would be derelict in our duty if we did not also give a big shout out and thank you to Mike for pouring over these enormous documents time after time looking for the real story behind what Enbridge is/was doing.

Now to the LNAPL. On August 8, we received notice from TRC that the Final Partial Permanent Solution with Conditions Statement (PSCS) had been filed with the Mass Department of Environmental Protection (MassDEP). You can read this 640 page document here if you have the time. On page 604, we found information regarding a plan to remediate the LNAPL with "in situ solidification." This would involve solidifying this toxic waste with concrete to create a "slurry" that would--supposedly--stabilize the LNAPL and the ground. Augers would have to be used to inject the concrete into the LNAPL and a massive environmental can of worms would be opened. It would also cost millions to do this. When we read it, we thought this is what they were GOING to do. Instead, this was just one of four options being explored.

Margaret emailed James Doherty, the LSP for TRC, and asked for clarification on this situation because we KNEW from the April 2018 meeting with the former LSP, Kelly Race, and others from TRC that the LNAPL was never to be disturbed. Never. Mr. Doherty did not reply until three days later, after we had already alerted the Conservation Commission and Councilor Burga about this situation. Mr. Doherty stated that Enbridge was not going to use the solidification, but was instead going to use a method known as Natural Source Zone Depletion (NSZD).

What is NSZD, you ask? Basically, in this case, it means they are going to leave it in the ground to rot. The problem is that it doesn't. According to this site, "It doesn’t degrade over 20 to 30 years and heating oil contamination tends to stay at the tank source. Excavation is the most economical and effective way to clean up contaminated soil." The tank source in this case was on the North Parcel. FRRACS wanted the LNAPL removed but Enbridge stated at the time that removal would cost in excess of $13M, and they would not consider it. In retrospect, that is a drop in the bucket for this $60M+ over-budget compressor that has cost somewhere in the neighborhood of $180M. (By the way, the ratepayers are paying every penny of this. Thanks DPU!)

While we apologize to you, dear Member, for our error, we can also defend it by saying that there is zero trust between all of us and Enbridge. Remember, this is the same company that once told the Weymouth Conservation Commission that they would never put a compressor station on the North Parcel because the hydraulics were all wrong and once told Mayor Kay that they wanted to put up a little "garden shed" (the compressor station) on the site.

And while we are on the subject of trust, we do not trust them in this situation, either. On page 136 of the PSCS, it states that the idea of the solidification is "retained." I.e., this is a legal "out" whereby they could, at another time, decide to use this option. We have requested--twice--clarification from Mr. Doherty. We will let you know if and when we get an answer.

If you have gotten this far in this long, long email, we want you to know why, all of a sudden, the LNAPL is in play. Or at least, what we believe is the issue. The ground beneath the compressor station is unstable and, therefore, the station and pipes themselves are at risk. The ground cannot be stabilized because of the LNAPL and because of sea-level rise (caused by climate change caused by things like this compressor station) and the tidal inundation of the underlying soil that is occurring as we speak. The foundation of the compressor building already has cracks in it. (Yup, we have pictures.) In the TRC/Enbridge episode of "Fantasy Island" you can somehow stabilize a sinking hunk of landfill!

Thank you for reading, and please pardon us for our "mistake." We would never want to lead you astray!