Environmental Journeys 12: Metals — Paintshop Pond and Beyond
Neal Stephenson’s book Zodiac — An Eco Thriller came out in 1988 and my friend and Menzie-Cura colleague Katherine Fogarty gave me a copy as a gift. The “hero” of the bizarre story is an environmental science activist, Sangamon Taylor. He is on a quest to battle industrial polluters in Boston Harbor. I think Katherine gave me the book because we were doing a lot of work in the harbor. As I read, a scene caught my attention.
Sangamon Taylor is sitting in his office when a guy dressed in a track suit comes in with a Doritos bag of colorful dirt. Sangamon learns that the dirt has come from a trail at a college. He then prods the dirt and announces that the colors — green, red, and blue — are associated with pigments and heavy metals. The runner tells Sangamon that the trail is next to a pond within a forested area of the college. The runner describes the colors of the soils as psychedelic. Sangamon gets on his bicycle and rides to the campus to confirm the information. Having seen the colorful soils himself, he researches the history of the place and discovers that a paint factory once stood there and that the parcel was donated to the college.
I put the book down. The pages were describing one of my active projects, Paintshop Pond at Wellesley College! Wellesley College has one of the most beautiful campuses in the United States. As the college website states, Henry Fowle Durant, who founded the College in 1870 (it opened in 1875), believed that young women should be educated in the midst of beauty. Landscape architect Frederick Law Olmsted, Jr. described Wellesley’s landscape in 1902 as “not merely beautiful, but with a marked individual character not represented so far as I know on the ground of any other college in the country.” Glacial topography, he believed, gave the campus “its peculiar kind of intricate beauty.” The College attracted many strong and independent women who greatly influenced our world and our understanding of the world. Those most familiar to me are Madeline Albright, Hillary Clinton, Norah Ephron, Ali MacGraw, Cokie Roberts, Dianne Sawyer, and Gail Charnley.
I learned early in the process that a major part of solving the puzzle of contamination at Wellesley involved dealing with the fact that this beautiful college included a hazardous waste site contaminated with heavy metals. Another part of the puzzle involved reaching a shared understanding by the College and the Massachusetts Department of Environmental Protection (MassDEP) regarding how this contamination situation arose. While there are many histories of the contamination, one of the most complete and interesting is given by a Wellesley student Jessica L. Ostfeld ’20 who created a wonderful story map with collaborators Rebecca Goldman, Sara Ludovissy, Marci Hahn-Fabris, Jenifer Bartle, and Sarah Hoskins.
Geography and history are good places to start this story. The photo below shows the close proximity of the Henry Woods paint pigment manufacturing operation to the Wellesley College campus. The operation began in 1848 before the College was built and continued operating until 1921 when the company went bankrupt. The Wellesley administration considered the industrialized area as an encroachment upon the campus. The College acquired the property in 1932 to maintain it as a buffer and prevent further industrialization. As laws developed over time, that meant the College also acquired the contamination associated with the former manufacturing operation.
Wellesley students and members of the community enjoyed the woods and trails surrounding Paintshop Pond. As noted in Wellesley College’s history of Paintshop Pond, A friendly serpent with a paintbrush tail cavorting near a Wellesley athlete reveals early student awareness of the potential hazards of industrial encroachment on the College in this excerpt from a whimsical 1924 map made by four alumnae.
The 11-acre property was quite diverse and included Paintshop Pond with a sluiceway leading to Lake Waban, upland areas where the manufacturing buildings once stood, and surrounding wetlands. As indicated in Wellesley’s history, the College’s intent was to keep this former industrial area bordering the western portion of the campus as open space and prevent it from being developed for further industrialization. In 1975, the Commonwealth began investigating the site, revealing the potential health and environmental issues associated with pigment-related heavy metal contamination.
The colorful soils around the former manufacturing area were evident to anyone walking along the trail and I saw these during my first visit to the site. The bright colors were hard to miss given the nature of the source materials and pigment products.
Prior to Menzie-Cura’s engagement, a 1982/1983 initial assessment of site conditions by the firm GHR Engineering had revealed high concentrations of lead and chromium in the soils. The study indicated a more detailed assessment was needed along with technical advice on how to address the situation. An integrated approach of scientific and engineering measures were applied to assess and develop remedial solutions to the complex nature of the property.
Menzie-Cura was hired by the College because of our combined expertise on health risk assessments for people as well as ability to conduct assessments for the fish and wildlife that inhabited the water bodies and surrounding wetlands and forests. We had established a reputation for successfully guiding remedial and restoration efforts based on the assessment of risks. We were also known to Wellesley’s outside counsel Paul Galvani of the Boston law firm Ropes &Gray; he was involved in the New Bedford Harbor Superfund Site which was a major effort on our part at the time. As I mentioned earlier, the Paintshop Pond situation presented a puzzle and legal representation was a key aspect of navigating the legal and regulatory landscape to come.
Solving the puzzle was not straightforward or easy. It involved:
- Complex perceptions and understandings that developed and evolved within the Wellesley College administration, MassDEP, College alumni and trustees, lawyers, scientists and engineers.
- Frustration on the part of the College over being responsible for contamination it had not caused.
- The fact that the contaminated sediment areas of Lake Waban were owned by the Commonwealth of Massachusetts; the sediments had been contaminated primarily before the College acquired the upland property associated with Henry Woods operation. Attribution of contamination in the lake was unclear.
- The anticipated risk assessment and eventual remedial approach were particularly complex at a time when MassDEP experience for oversight of such complex sites was relatively limited. Key risk assessment criteria still needed to be defined along with the methodologies to conduct such assessments.
- Hexavalent chromium a particularly toxic metal was present in groundwater and in the wetlands and required special studies to protect human health and ensure remediation was successful.
- The costs of disposal of contaminated soils and sediments was substantially affected by whether disposal could occur on site or off site.
- There was a strong desire to have a positive outcome beyond simply eliminating potential for exposure.
- Surface water, wetland, and upland forest habitats would be destroyed where soils and sediments were removed. A plan was needed to restore such losses.
- The College had already moved some contaminated soils from the area for fill in other locations on campus and these areas needed to be addressed.
- There were many regulatory and legal agreements that would need to be worked out.
Before we got to the heart of the matter and before a shared understanding about a solution was reached, the College implemented initial interim remedial measures involving the removal of some pigment waste piles, covering of lagoon areas, and fencing the perimeter of the site with warning signs to exclude people from the area. However, this interim solution was temporary at best and quickly proved untenable as a long-term solution.
Movement toward a shared understanding was influenced by agreeing to a facilitation process between MassDEP, and Wellesley College and its’ consultants. This involved Barry Monahan who was Wellesley’s Assistant Vice President of Administration and Community Affairs, Steve Johnson and other key MassDEP personnel, me as the lead consulting risk assessor for the College along with team members from Menzie-Cura, and Christine LeBlanc, the project Licensed Site Professional (LSP) and lead environmental engineer. Lawyers were excluded from this process. Over many months, this process was facilitated by Susan Santos, an expert on conflict resolution, environmental assessment, and risk communication. The process worked. We came to see each other more completely, developed a level of trust sufficient to move forward, and came to a shared understanding of what was needed to complete a comprehensive human health and ecological risk assessment in support of the remedial goals at the site.
While the process involved all of us, I’d like to acknowledge Barry Monahan. He had the requisite characteristics of careful listening, asking probing questions, and representing the interests of the College as we moved toward a viable outcome. I searched for him while writing this story and sadly found that he passed in 2018. He really was the steady hand on the tiller of our boat.
Katherine Fogarty became the Project Manager for Menzie-Cura. Wendy Heiger-Bernays led the human health risk assessment while I led the ecological risk assessment. We were supported by a strong group of scientists who sampled various media, conducted exposure tests, and analyzed data. An issue that was key to the evaluation of ecological risks was achieving a sufficient weight-of-evidence to reach reliable conclusions. But there was no clear definition of the term weight-of-evidence other than a qualitative sense of what it meant. No guidance existed at the national or state levels. This needed to be established to support clear decisions. Therefore, I spoke with Nancy Bettinger and others at MassDEP and reached agreement that we would develop a workable definition and a methodology that could serve the Commonwealth not only for Paintshop Pond but for all ecological risk assessments. A team of experts was assembled that included USEPA regional personnel, state scientists, academic scientists, and consultants. We benefitted from the participation of Jack Gentile who had played a key role at USEPA in the development of the Agency’s Framework for Ecological Risk Assessment.
I chaired the effort and our team met over several months and established the needed definitions and methodology for incorporating weight-of-evidence considerations into ecological risk assessments. The methodology was subsequently used widely by practitioners in the United States; it was incorporated into guidance in some Canadian provinces. Our work and publication influenced the eventual development of national guidance by the USEPA and other organizations. We published the methodology in 1996. Team members are listed as authors. We owe much of the success to the support of Nancy Bettinger and others from MassDEP, the lead environmental regulatory agency.
The weight-of-evidence methodology underpinned the ecological risk assessment work for Paintshop Pond. The application to Paintshop Pond was supported by considerable sampling and analytical work by us and by East Coast Engineering. I especially appreciated the work of Christine LeBlanc, the LSP for the site, who adeptly melded all aspects of the project work to achieve solutions for the site. LSP’s shoulder major responsibility for the assessment and eventual conclusions regarding the site; this is a responsibility placed on them by the Commonwealth of Massachusetts.
An interesting example of ecological risks surfaced for me that points to the nature of the contamination and the species-specific sensitivity of some ecological receptors. I was unable to find any frogs in the wetlands or even the forests around the former manufacturing site. Being someone adept at finding frogs (i.e., a Frog Whisperer), I found this strange and so I hired other frog experts to search for them visually and by sound. There were no frogs to be found and I thought contamination might be playing a role. I learned from Christine LeBlanc and others that some investigators experienced rashes when their skin inadvertently came into contact with the pigments contained in the wetland muds. I checked through our sampling data for wetland sediments and found that hexavalent chromium was elevated in concentrations. This particular form of chromium is highly toxic and can cause irritation to the skin upon contact. It made sense to me that animals with sensitive skin such as frogs and their young tadpoles might not be able to inhabit contaminated wetlands areas because of the irritation. Based on these assessments, the wetlands were slated for remediation.
After our assessments were completed, we met with members of the College community and with the wider Wellesley community to share the results and explain the planned remediation. The community meetings included interactive sessions involving posters that facilitated conversations on specific topics between the scientific experts, the College representatives, and members of the community. I found these sessions very beneficial based on my personal interactions and the feedback from community members.
We also arranged one-on-one meetings with individuals with particular health or environmental concerns. These were arranged through the College. Wendy Heiger-Bernays handled this part of outreach and traveled to people’s homes to discuss the site and their concerns with them.
The College set up a website containing easily accessible information on the status of the project for the community. Posts described what we found and what it meant along with what would happen next. An example of one of these information pieces can be seen here for the June 1999 report.
Working with the College, Christine LeBlanc developed a remedial and restoration design that included the final piece of the puzzle. This piece addressed many of the concerns I listed earlier and led to a win-win for the College and for MassDEP and the Commonwealth. For decades the College had been searching for a way to expand its recreational sports areas. The only viable option had been property across Rt 135 which meant students crossing a major thoroughfare. The Paintshop Pond area had been off limits for development by the College because of various regulatory constraints. But now there was the appetite to integrate a major remediation program with extensive soil disturbance.
The solution agreed to by the College, its trustees, and MassDEP involved using the area on the College adjacent to Paintshop Pond as containment cells for interning the contaminated soils and sediments. The containment cells would be lined with thick HDPE membrane and the surface of the contaminated soils and sediments would be covered with the same. This on-site remedial measure would provide a way to manage costs. More importantly, a positive outcome would be achieved beyond reduction of exposure and risk as these containment areas would support the conversion to playing fields. Further, the natural areas bordering the lake and pond would be restored through wetland reconstruction and made accessible with walking trails.
Once the risk assessment was completed and the remedial design outlined, the College assembled a remediation and restoration team led by Haley & Aldrich to implement the project. Our role became guiding the effort with respect to risk reduction and associated benefits. This portion of the effort was led by my friend Russel Schuck who was a key figure in Haley & Aldrich’s sediment remediation practice. We were all surprised and saddened when Russel passed away in 2017.
The transformation of Paintshop Pond from a contaminated site to playing fields and natural systems is shown in the next three images.
My last official visit to the College was at the invitation of College President Diana Chapman Walsh. I was asked to meet with her and Arlene O’Donnell who was then the Commissioner of the Massachusetts Department of Environmental Protection. These two entities — the College and MassDEP — had come together to solve what once seemed to be an unsolvable puzzle. They had reached a shared understanding through hard work by many people. The three of us walked the paths winding through the reconstructed wetlands. I shared my knowledge of the conditions before and after the remedy and reconstruction. It was a sunny day; the wetland habitat looked wonderful as we passed over it on an elevated walkway. And, I think I heard a frog.
Our work on evaluating metals at Paintshop Pond led to many similar projects throughout the northeast, mid-Atlantic, and elsewhere. For these, we applied the weight-of-evidence methodologies developed in Massachusetts for Paintshop Pond to conduct the ecological risk assessments. As we proceeded, we sometimes broke new ground on thorny issues from a technical and regulatory assessment standpoint. One of the challenging locations was Mill River in Connecticut. It was contaminated with lead from a battery manufacturing operation. This project was led by Sue Kane-Driscoll who today is one of the leading experts on sediment assessments. Our involvement at Mill River was the first time the Connecticut Department of Environmental Protection was open to an approach that went beyond comparing measurements of metals in soils and sediments to the commonly used screening levels. On a prior project, we had found methodological flaws with many screening levels and published a paper on that finding. It was rewarding that agencies were seeking site-specific risk-related information to inform decisions.
The project closest to Paintshop Pond was a site along the coast of Maryland where Herring Run flowed toward the Chesapeake Bay. The 68th Street Dump Site bordered the tidal creek. It offered 283 acres of wetland and upland habitats in the middle of an urban environment. Remediation could lead to loss of habitats and therefore the tradeoffs and considerations were complex. Heavy metals emanated from soils and from groundwater. The ecological sampling and risk assessments for this site were managed by Meg McArdle of Menzie-Cura.
The assessment of risks from metals involves many considerations. A concentration in a soil, or sediment gives an initial insight but not much else about the likelihood of harm without understanding the nature of the metal and other contextual information. The issues around assessing risks of metals became increasingly recognized by the USEPA and a decision was made by the Agency to develop a Framework for Metals Risk Assessment. It was led by Anne Fairbrother and Randy Wentsel who were at USEPA at the time; I was pleased when they later joined me at Exponent.
For the development of the Framework, I was asked by USEPA to participate in discussion and workgroups leading up to the effort. This included chairing a meeting of stakeholders from government agencies, academia, industry, metals-related organizations, and lawyers. I was then tasked to lead a workgroup that would develop a draft set of Metals Principles for use in risk assessment. This exercise involved synthesizing all the discussions and input from stakeholders and USEPA into a set of concise statements that were subsequently reviewed and edited by the Agency. I was especially proud to be asked to do this work and to lead the workgroup on behalf of the Agency. Here are the Metals Principles.
All of the Menzie-Cura technical staff were involved in the risk assessment of metals at one time or another. I’d like to acknowledge a few that were especially instrumental during our first few projects when we were breaking new ground and communicating our findings to a broad range of stakeholders. The integration of technical expertise and communication by these folks was especially important for the assessment process.
I thank Sue Kane-Driscoll, Meg McArdle, and Christine LeBlanc for their helpful edits and comments.
