WVN Newsletter #171: Raytheon cleanup comment sought
- Dear Wayland Voter,
After Raytheon moved out of the Route 20 property now
earmarked for the town center housing/office/shopping project, it
agreed to take responsibility for any harmful and persistent
chemicals left in the ground. The state-regulated effort is now at
Phase IV and is expected to go on for many more years.
The site is environmentally fragile because it is near a protected
river and a recharging area for town wells. Where developers
can build, and how soon, may depend on the cleanup. There
have been changes at Raytheon, which is negotiating with the
developers. There are many unknowns.
A recent public meeting gave citizens the chance to ask
questions. You can watch a broadcast for the hearing and
submit your comments. Molly Upton explains below.
RAYTHEON TO EMBARK ON NORTHERN CLEANUP
The public was certainly involved at Raytheon's Public
Involvement Plan (PIP) meeting held May 17, with many
questions trying to discern what types of changes on the property
could disturb the flow of groundwater (and contaminants) at the
site. Raytheon presented a draft of its plans (Phase IV) for
remediating the northern area of the site, and said it planned to
submit remedy operation status reports on the southern and
western portions of the site during this year.
The meeting will be shown on Wayland's cable channel 9 on on
Thursday June 15 at 8 p.m. Written comments by interested
citizens and town officials on the proposed Phase IV plan are
due on June 22, 2006 to:
Louis Burkhardt, Raytheon Co., Mail Stop 1880
528 Boston Post Rd.
Sudbury, MA 01776.
Raytheon is required by Department of Environmental Protection
regulations to respond to public comments.
The complete May 17 PIP meeting presentation and the Draft
Phase IV report are available at www.ermne.com. The user
name is raytheon and the password is wayland (all lower case).
Click on documents and the May 17 PIP meeting
is currently the last entry. Hard copies of such documents are
also at the Wayland library (ask reference desk librarian) and the
Board of Health.
Raytheon representatives said they had not seen any definitive
plans from Twenty Wayland LLC for its proposed mixed use
development (town center project) on the site.
Raytheon still owns the liability for the contamination, but
Twenty Wayland LLC is in "negotiations" with Raytheon
regarding the timelines of the cleanup and costs associated with
an expedited effort, WVN learned in a subsequent discussion
with Louis "Chip" Burkhardt, who is replacing Ed Madera as
Raytheon's project manager. In addition, the issue of a septic
system is "part of the negotiations with the developer," Madera
told the meeting.
The Licensed Site Professional of record, John Drobinski of
Environmental Resources Management, told WVN that the
restrictions on the deed are still intact. A letter of June 27, 2005,
from the town's licensed site professional, Ben Gould of CMG
Environmental, to the Wayland Board of Selectmen emphasized:
"The deed restrictions summarized herein are legally binding on
the large majority of developable land at the Site (77 of the total
"Among the restrictions are prohibitions against residential use,
children's daycare, public access, and recreational use; and
"The restrictions imposed by the Site owner on October 21,
1997 are unusual in that only the LSP-of-Record is authorized to
amend or terminate them. This person is currently Mr. John
Drobinski, P.G. of Environmental Resources Management, Inc.,
which is Raytheon's primary environmental subcontractor
for the Site.
"Therefore, it follows that any future development of this property
must accommodate Raytheon's easement rights to limit Site
activities or uses that might interfere with ongoing assessment
and remediation of contamination identified at the property." (The
June 2005 letter as well as a presentation to selectmen are also
on the Raytheon cleanup web site, under "BOS meeting.")
CHANGING OF (SOME OF) THE GUARD
Raytheon's outgoing project manager, Ed Madera, introduced
his replacement, Chip Burkhardt, who conducted most of the
meeting. WVN found some of Burkhardt's responses to be less
definitive than those of Madera. Whether this is because
Burkhardt is new to the position or reflects increasing pressure
being brought to bear by Twenty Wayland LLC is hard to know.
WVN learned in discussions after the meeting that Raytheon's
legal bills recently have grown significantly. Burkhardt said at
one point, "Whatever goes on is subject to negotiation." Madera
added: "The liability depends on the situation; It depends on the
agreement with the owner how to deal with." He added: "The
remediation plan will be based on agreement with the
developer, and discussion of sharing costs." But, he added, the
regulations require notification, and Raytheon is bound by the
Massachusetts Contingency Plan (MCP) timelines.
John Drobinski will continue as LSP of record. Drobinski is also
a selectman in Sudbury.
The groundwater depth is as little as 6 feet (in non-flood times)
in the northern area of the property and more than 15 feet in the
contaminated portion of the southern area. The depth of
groundwater could be a major factor in whether basements are
allowed, as digging might affect the flow of groundwater. It is
also possible that a change in the ratio or placement of pervious
surface could affect the groundwater flow, according to the
Raytheon representatives. For instance, if a septic system
changes the plume hydraulics, that would not be good, the
meeting was told.
Madera agreed that construction of buildings could change the
hydrology, and that Raytheon also would need ongoing access
to the numerous monitoring wells on the property.
According to DEP regulations for Mass. Contingency Plan (MCP)
310 CMR 40.0000 (sections 40.0970-40.09.80 and 40.0932)
there are standards of proximity for buildings to contaminants.
For the groundwater category gw2, buildings must be a vertical
distance of 15 feet from groundwater and a horizontal distance of
Raytheon's long-term goal is to achieve drinking water
standards in the ground water, because the site is within the
drinking water supply area. The standard for drinking water is 5
parts per billion of PCE (tetrachloroethylene) and TCE
(trichloroethene). (Among "daughter compounds," the risk of
inhalation is greater than the risk in the drinking water.)
The interim goal is to reduce concentration so there is no
One frequent question was what's the process if another area of
contamination is discovered. The answer was that if a new area
is found with the same types of contaminants, its treatment will
be rolled into the existing release tracking numbers (RTN),
rather than starting a new filing.
Another question was what does Raytheon expect to find
beneath the current building. Raytheon has done some
sampling in the slab and thinks there is not a problem with soil
contamination, but will remediate if it finds contamination. It has
found chlorinated volatile organic compounds, such as TCE, a
minor amount of PCE, and daughter compounds such as
dichloroethene and vinyl chloride.
On the site, Raytheon is in the monitoring phase (remedy
operation status) on the southern area groundwater remediation
and wetland monitoring to the west. It has diminished the
wetlands contaminants, which included a number of metals
chromium, copper, lead and silver - also PCBs, PAHs (polycyclic
aromatic hydrocarbons) and arsenic. Raytheon is using a
permanganate injection process in the southern area to
neutralize the contamination. There is also methyl tertiary butyl
ether (MTBE) on the southern portion. The MBTE probably
originated from a gas station to the east of the property, as
Raytheon records indicate no such chemical was used at the
Raytheon performs semi-annual groundwater gauging at all
accessible site monitoring wells, and analyzes groundwater
samples from select monitoring wells at the site. There are 170
Because Twenty Wayland LLC did not agree to inform the town
of its discussions with Raytheon, the question arose: how will
the Planning Board know if redevelopment plans presented by
the developer will actually meet with Raytheon's permission? If
Twenty Wayland wants to move forward responsibly and
expeditiously, it will agree to present to the Planning Board only
those plans that have received the stamp of approval from
While this sounds too logical to be an issue, one audience
member noted the existing unused daycare center had been
constructed at the Route 20 property entrance a few years ago
despite the restriction on its use. This left some wondering if the
deed restrictions would preclude construction work on the
site; they definitely would limit occupancy.
After repeated questioning, Madera said "there will be word if we
agree on a plan." "We need to have an agreement on a plan and
a process before we lift the deed restrictions."
NORTHERN AREA CLEANUP
The meeting was held because under DEP regulations
Raytheon is required to inform the public and town officials of its
plans to clean up the northern area of the site that is
contaminated with chlorinated volatile organic compounds. The
current DEP submittal, recently presented in draft form for
comment, is Phase IV Remedy Implementation Plan.
Raytheon has located "the head of the beast" or the apparent
source of TCE (trichloroethene) in groundwater, where the
concentrations are about 100,000 parts/billion. The allowed
drinking water quality standard, by contrast, is 5 parts/billion.
Raytheon has a long term goal of achieving drinking water
standard, but this will take a couple of decades.
In this area, the water flow is an upward gradient, with the flow
generally toward the river. Further to the east, the groundwater
tends to flow downward. However, the contamination plume is
moving downward even though the water gradient is moving
upward. While contaminants have not reached the bedrock,
(about 60 feet below grade) TCE and daughter compounds
have been found at various depths, which Raytheon may decide
The northern area site is immediately north of the existing
parking lot and northwest of the Town's Wastewater Treatment
Plant and its sphere of influence involves some land owned by
the Wayland Commons developers.
Raytheon plans to excavate to a depth of 25 feet using two coffer
dams with diameters of 80 feet and 60 feet. It will haul away
about 5500 cubic yards of soil, clean the water via a carbon filter
and discharge it via the storm drain back into the river. The water
table at this part of the site is 6 feet below the surface, and the
top 5 feet of soil are clean.
The excavation project should begin in August and last for 2-3
months, and then monitoring will occur for a year. Once the
residual is known, Raytheon can design an injection system of
carbon substrate to help degrade the remaining TCE by
encouraging bacteria that will break it down. The timeline
in the draft text indicates 2008 should see substrate injections
and a final inspection report. The Raytheon team said it would
be difficult to determine how long the TCE will take to degrade,
but the likely timeframe is decades to reach a purified state.
The Northern Area also falls within the jurisdiction of the
Conservation Commission under the state's Wetlands
Protection Act Regulations [310 CMR 10.05 (4)] and Wayland's
Wetlands and Water Resources Bylaw, Chapter 194.
The excavation project is within the Bordering Vegetated
Wetlands and Buffer Zone. Raytheon therefore filed a Notice of
Intent for this site work with the ConCom, and that public hearing
has been continued until June 22.
Remember to please submit by June 22 whatever written
comments and questions you may have to Raytheon after either
viewing the meeting and/or reading the Sraft Phase IV report on
the project Web site (www.ermne.com).
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