Water Quality- Drinking Well Impacts

As we presented on the Public Hearing (Zoom) call for the Variances request by the Massachusetts Department of Transportation, held on October  27, 2020, water quality is one of our major concerns for the project:

 

It is our understanding that the project proposes more than 11 acres of new impervious area (pavement). This is 11  acres that will increase runoff as well as the discharge of salt, petroleum, brake fluid, engine oil etc.,

potentially including pollutants heavy metals (like lead, cadmium, cyanide and zinc), into the groundwater

and nearby surface waters that feed our wells. Although the project is proposing several infiltration basins,

Mass DEP acknowledged in the Public hearing that these basins do not treat for salt. It is  our understanding that these infiltration basins are supposed to naturally filter the various pollutants  coming off the interchange pavement and no mechanical type of treatment is being provided. Our concern  is that after a few years of being bombarded with the polluted runoff, these systems will become saturated  and the soils, plugged with sediment, will no longer function properly.

 

We are also concerned about the contaminants that will be present during the 6-year project construction

term, and the ongoing effects of pollutants generated by an increase of auto and freight traffic.  Freight will be running 24/7  and some will be self-automated. Concerns include run offs due to spills, oil, auto and freight traffic

accidents. 

 

MassDOT indicated at the public hearing that water quality would be better than it is now, but  the original highway was constructed prior to the new water quality regulations. New construction should now  required to meet the revised regulations, which better protect groundwater. 

 

We would also appreciate Massachusetts Department of Environmental Protection's (MassDEP) confirmation that your office's comments to both  the DEIR and FEIR were addressed, specifically the project design team’s decision to use a lower runoff  (inches) for the 100 yr-24 hr. storm when calculating storm water detention and flood storage. Our concern  would be that if the infiltration basins and flood storage are undersized, runoff could spill over the top of outlet  structures prior to filtration.

 

Over the years the interchange has come closer and closer to our neighborhoods, first  with the lengthening of the Mass Pike exit ramp to I 495, then with the removal of the toll plaza. Large  trees were taken down on both occasions. Then last year, several feet width of large trees were removed  along the Mass pike adjacent to Roosevelt Farms, in what we think is in anticipation for this project. T he proposed ramp from the Mass Pike to 495, will be pushed  16-20 ft. closer to the area of Roosevelt Farms along Bullmoose and 60- 80 ft closer to the area adjacent to the former toll plaza location. These encroachments have two impacts:

 

1) increasing road noise for area homeowners and 

2) reducing the water filtering capability of the critical

terrain between the highway and the aquifers that feed our wells.

 

The MassDOT Project Manager mentioned the MassDOT Salt Remediation Program at the  public hearing. He indicated that he was not aware of any issues as of right now. Unfortunately, there are  already two homes in the Huckleberry development whose wells are being treated for salt due to highway  runoff. Others installed remediation equipment of their own before the program was introduced. We also  know of one pending applicant likely not reflected in the state’s system as of the last public meeting.

 

Still, we would prefer that after-the-fact remediation efforts not become the norm. MassDOT needs to take

a proactive approach to avoid further well contamination in this strategic corridor that will only see higher

traffic volumes over time. We do not want to wait for our wells to get contaminated, and then try to fix

them. 

 

The Variance application  package only identifies potential concerns to public water supply wells. Our 100+ private drinking water  wells were not even identified as a concern, even after our numerous public comments through the MEPA  process and the MassDOT public hearings. Therefore, we are respectfully requesting MassDEP consider  the project be required to implement a detailed groundwater monitoring program to monitor the quality of

runoff and groundwater during and after the interchange project. 

 

We suggest the program include the

sampling of wells at designated homes in our developments, as well as at new monitoring wells to be

installed at key locations between the interchange and our housing developments. This plan should be

started prior to construction in order to establish baseline readings. (Approximately one-third of our Coalition members have tested our wells within the last three years and would be more than  happy to share results to assist with establishing the program.) Periodic sampling should then be  conducted during construction as well as for several years after construction to identify impacts and if

necessary, take corrective action. This plan should also include clear instructions (contact person etc.) on

the process should our drinking water be impacted. 

 

We would also like MassDEP to consider using non-sodium ice melting agents on the surfaces in and around the interchange.

 

As also mentioned during the public hearing, we are concerned about the wildlife, wetlands and vernal

pools in the area of the project. Outstanding resource waters such as the Cedar Swamp ACEC, Sudbury

River and Whitehall Brook should be protected from contaminated runoff as well. Vernal Pool (VP-14)

located directly adjacent to I-90 WB ramp, adjacent to Roosevelt Farms is listed as only having a  temporary impact. This vernal pool will receive direct runoff from the highway and will have long-term  impacts that should be addressed. While property owners have the ability to treat our water  systems, if required (not desirable), this is not an option for the environment and wildlife.

 

Though not directly related to wetlands and resource areas, we are hoping we can bring to MassDEP’s

attention to some of our other concerns regarding the project, such as noise, both during construction and

after construction. As recommended in the MEPA certificate, we are hoping for a commitment that all

construction be conducted during normal working hours so that we are not disturbed at night with loud

construction noise as well as lights. This was an issue a few summers ago when MassDOT removed the

toll plaza adjacent to our developments and worked throughout the night, jackhammering and utilizing

bright construction lighting.

 

Below is the list of concerns in addition to Water Quality, we presented in both of our comment letters in

response to the DEIR and FEIR. Any assistance MassDEP can provide us in these areas would be greatly

appreciated:

 

-Highway noise during and after construction

-Air quality during and after construction

-Light pollution during construction

-Fruit Street bridge replacement - emergency access

-Concern for lower Property values

 

The HNWC appreciates MassDEP's time and consideration. We hope we can count on your  support to protect not just our homes but also the lovely environment in our neighborhoods and in the  area of this significant project.