WVN Newsletter #213: New appeal, turf work begins
- Dear Wayland Voter,
Work has begun work to install artificial turf at the High School
football field. A town press release predicts that, despite two
environmental appeals and a lawsuit, the field will be ready as
planned when school opens in the fall.
The Wayland Boosters have run into continuing controversy
since announcing plans last year to spend $300,000 in town
land preservation funds and about $700,000 in private donations
on the project. A suit opposed the use of taxpayer funds.
Environmental questions prompted a citizens' appeal to the state
Department of Environmental Protection that resulted in a
revised plan. Citizens appealed the revised plan on June 1.
The citizens who sued said they didn't oppose the project but
questioned the use of taxpayer funds for a purpose not specified
in the Community Preservation Act. The citizens who filed
environmental appeals didn't oppose the project in theory, but
asked for assurance that the town's water supply and adjacent
federally protected land and river would be safe from toxic runoff
Town Administrator Fred Turkington's June 11 announcement of
the start of construction referred indirectly to the citizens' action,
noting that work on one part of the project won't begin until the
latest appeal is resolved.
"We are constructing the field in accordance with DEP orders
and regulations which protect resource areas including nearby
town wells and the Sudbury River," Turkington said.
This and other recent developments raise questions about
quality controls and concern for natural resources. Molly Upton
The June 1 citizens' appeal asserts that the new drainage plans
for the impervious field are inadequate for the expected volume
of water and contaminants draining from the field may
endanger nearby town wells and the Great Meadows National
On May 21 Town Administrator Fred Turkington told the
selectmen that construction was expected to start on May 29,. At
that meeting Selectman Bill Whitney's questions revealed that
there were no plans for a "clerk of the works" or qualified third
party overseer to ensure that various specifications such as
compaction are achieved. Turkington responded that Gale
Associates, designer and Booster consultant, was the "contract
administrator." Whitney responded that this would not provide
independent quality control. Field construction will be overseen
by Turkington and Joy Buhler, business manager of the school
In addition, Gale has not demonstrated that its plans to divert the
field runoff away from the Happy Hollow wells and toward the
north have been evaluated by any other engineers, and it's
unknown if the Gale plans may result in discharge into the
abutting Sudbury River refuge.
Water Commission Chairman Joel Goodmonson said he would
ask Turkington to implement a peer review of the plans.
Attendees at a Water Department meeting indicated they had
heard Conservation Commissioner and professional engineer
Andy Irwin decry some of the tests that Gale had presented.
The Water Department's consultant, Tata & Howard, discussed
with the Department plans to comply with DEP requirements to
protect the wells from runoff from the High School parking lots.
Carrying out these plans, which are independent of those for the
field, but triggered by the field proposal, will cost about $100,000
if the town does some of the construction.
The Tata & Howard representatives said they had cursorily
looked at the Gale plans and found it odd that both the "before"
and "after" field construction plans dealt with the same volume of
water. This is odd because the new field, unlike grass, would
be impervious. The implication is that the volume of water will
overwhelm a constructed swale (trough-like depressed area)
planned to the north of the field and thus won't be filtered, and/or
this amounts to more water near the ball field.
In addition, the swale is designed to handle a one-half inch
rainstorm, though Wayland recently has had at least one rain
dumping four inches or more and in April there were six rainfalls
exceeding a half-inch.
The June 1 citizens' action appeals the DEP's earlier
Superseding Order of Conditions. The new appeal came after
the citizens reviewed the revised plans, including the swale.
CONSTRUCTION CHANGE ORDER
Turkington said the addition of a new drainage scheme for the
field would be handled as a change order for the contractor
already selected for the field construction. This raises the
question whether a change of this size is proper under bidding
rules. The Boosters have been telling residents and donors that
the field should be in place in time for the fall athletic season. A
change order would presumably avoid delay.
Since taxpayers' Community Preservation Funds are involved,
voters may logically want assurance that the town will ensure
proper drainage via a peer review of the drainage plans as well
as a clerk of the works to monitor construction and spending.
After a December 2006 citizens' appeal to DEP of the
Conservation Commission's approval of the field with
conditions, the DEP requested changes in the field and parking
lot drainage. The DEP received a plan for field drainage with the
outfall pipe repositioned outside of the 400-foot radius of Zone I
of the Happy Hollow well field. On May 17, the DEP issued the
Superseding Order reinstating the Concom's conditions and
adding six additional conditions.
The Gale plans call for a swale north of the field to filter the
outflow of water, which is very likely to contain bits of the
pulverized truck tires from the field and resultant products from
the rubber breakdown. (The list of 96 contaminants is too long to
print here.) For those interested, the Swedish Chemicals Agency
recommends not using rubber granules from waste tires in
Turf.pdf. Another site is:
http://www.synturf.org/images/NBI_20Engelsk.pdf. The site
http://www.synturf.org/rubbercrumbtoxic.html has lots of excerpts
from scientific articles under the section "rubber crumb."
Many of these contaminants are known to be harmful to aquatic
life, and the federally protected Sudbury River and its wetlands
are adjacent to the site of the field. The DEP Superseding Order
notes that the Gale plans calling for the pipe and swale,
although outside Zone I, are "within the 100 foot Buffer Zone
associated with BVW (Bordering Vegetated Wetlands)."
One of the looming questions is the proximity of the new swale
to the wetlands as well its capacity. It is not clear that such a
discharge as proposed by Gale is feasible given the letter
submitted to the DEP by Elizabeth Herland of the Fish and
Wildlife Service, who manages the Sudbury River refuge.
In her letter of May 15, which may have crossed in the mail with
the DEP permit, she states: "It will not be acceptable to have any
runoff from this project affect refuge lands. The Service will not
grant a drainage easement for this project I respectfully
request that the applicant provide documentation depicting the
extent of flow from the drainage outfall location, including during
peak rainfall events. This should include the calculations of how
the drainage will be affected when the Sudbury River is at flood
stage, which generally occurs once or twice a year. This
calculation of flow should be provided on a map which indicates
the location of the refuge boundary. It would be preferable for the
applicant to design a retention system on the high school
property so that concerns about drainage and flooding can be
eliminated.In particular, a complete pollution elimination system
should be required if questions in the appeal cannot be
The citizens' appeal states: "We are seeking appropriate
modifications to the Project which will ensure that the quality of
the water leaving the Project (either surface or subsurface flow)
does not degrade the source waters of the Happy Hollow wells
and the wetlands bordering the Sudbury River.
"We respectfully request that the Department revisit our concerns
regarding potential for toxic tire leachates to degrade vital
drinking water aquifer sources and cause environmental
degradation to fish and aquatic species in the receiving
wetlands and that possible remedies presented by us in our
original Appeal be incorporated in a Final Order."
The challenge of where to put field runoff and its leachates -- not
too close to the wells, and not too close to the Great Meadows --
serves to highlight site issues that the High School Building
Committee should be examining.
Though artificial turf is widely used, the specific technology
planned for Wayland is less than a decade old, and there is
disagreement in some other Massachusetts communities over
possible environmental hazards and also the legality of using
Community Preservation funds. Some are pondering a
regulation that would prohibit construction of artificial turf fields in
Zone II. The High School project, barely outside of Zone I, is in
Zone II. Zones I and II are designations of areas that require
protection because they contribute water to the well fields.
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Michael Short, Editor