The Tidewater Communities Project
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The Gas Holder Project
Spring, summer and fall 2010
During the spring, summer and fall of 2010, two gasholders located on the northwestern edge of the Tidewater Site were dismantled. According to the project's Completion Report (see document dated 7/8/11 on the RI DEM website) the holders had stood 30 feet high. The smaller of the two, Holder #7, was 130 feet in diameter, 400 feet around, and had a capacity of 1 million cubit feet. The larger holder, Holder #8, was 175 feet in diameter, 550 feet around, and had a capacity of 3 miliion cubic feet. They appear to have been built in the 1920s and 1930s. They were used to store gas in preparation for distribution until 1989, when they were abandoned. Rainwater had accumulated in the holders since that time.
In 2009, National Grid's environmental contractor for the Tidewater site, GZA Geoenvironmental, discovered that "an unknown quantity" of the contents of Holder #7 had leaked from the structure (see p.1 of Completion Report). In response, GZA contracted with another firm to investigate the state of the holders. The investigators found that a wooden frame that had served as a support for the roof had partially collapsed. They concluded that this "rendered long-term stability questionable" (p.2), and so proposed a project to decommission and demolish (D&D) the holders.
The work would require removing and processing the contents of the tanks before dismantling the structures. They contained 3-4 feet of sludge (from old stored gas) and accumulated rainwater.
Source: GZA GeoEnvironmental, Completion Report.
Holder with accumulated rainwater/ sludge
Source: GZA GeoEnvironmental, Completion Report.
Gasholders 8 and 7.
The first step in removing the contents focused on the rainwater. The rainwater had been contaminated by the sludge below, and so contained many volatile organic compounds (VOCs) - substances that transform from liquid or solid state to gas, a state in which they contaminate the air. The liquid also contained cyanide and various metals, such as arsenic, lead, mercury, barium, cadmium and zinc.
After removal from the tanks, the liquid was run through filters to reduce the contamination. The treated water was then dumped into the Seekonk river. This phase of the project was conducted between April 7 and July 20 of 2010. In all, 7.8 million gallons of rainwater were treated and dumped into the Seekonk (see p.3 of Completion Report).
Next, the sludge that had accumulated in the bottom of the tanks was removed and processed. The sludge consisted of a mixture of hazardous gas byproducts: samples that were sent for testing indicated high levels of VOCs such as trimethylbenzene, isopropyltoluene, benzene, napthalene, PCBs and total petroleum hydrocarbons (or TPHs) (see Appendix J of Completion Report, "Dense Sludge Analytical Results"). After removal from the tanks, water was removed from the sludge and the remaining dense sludge was mixed with cement in order to stabilize it. This was then placed into transportable containers for shipping off-site.
Source: GZA GeoEnvironmental,
Completion Report.
Removal of water from sludge.
Source: GZA Geoenvironmental, Completion Report.
Mixing sludge with cement.
Source: GZA GeoEnvironmental, Completion Report.
Preparing sludge for transport.
Most of this work was completed between August and October of 2010. It produced more than 308 tons of materials (stabilized sludge and other products of the treatment system) that were shipped off-site for disposal.
The structures themselves required special treatment prior to demolition: the flaking paint on the exterior had high levels of lead, and some of the materials themselves were contaminated with asbestos.
Source: GZA GeoEnvironmental, Completion Report
Lead abatement.
Source: GZA GeoEnvironmental, Completion Report.
Asbestos abatement.
Source: GZA GeoEnvironmental, Completion Report.
Holder demolition.
After the removal of these materials, the structures were demolished and the remaining materials were transported off-site.
Problems: "odors" and "exposures"
The work of removing and processing the sludge generated strong chemical smells. I first became aware of the Tidewater Site when I encountered these smells. At the time, my daughter had just begun kindergarten at one of the nearby schools. I raised the concern with staff members, and many of them also expressed concerns. One said that even some of the youngest children had mentioned the smells while playing on the playground, which was located not much more than 100 feet from where the work was being conducted. I was especially concerned about the possibility that young children were being exposed to these substances, as children have greater vulnerability to toxins. I was also concerned about the staff. One of my daughter's teachers was pregnant at the time, and I wondered how exposure to the toxins that I smelled might impact the fetus.
The school director gave me a pamphlet with basic information about the site, which she had received from the property owner. This had contact information for the Rhode Island Department of Environmental Management (RIDEM). After a few calls, I was able to speak with Mr. Joseph Martella II, the engineer who is responsible for overseeing the site.
Mr. Martella patiently and attentively listened to my concerns. He informed me that the department had just a few staff members: he alone was in charge of overseeing over 100 contaminated sites. As a result, members of the community often serve as the agency's 'eyes and ears.' In this case, however, National Grid had
implemented a sophisticated system for monitoring the air during the work. The system monitored the air for VOCs (volitile organic compounds) and dust continuously, 24 hours a day. The property owner had also arranged for continuous monitoring of levels of one particular VOC, napthalene. The air monitors were set up to send an "alert" to the workers on site if the levels of contaminants in the air reached a certain concentration. In this case, the workers could respond by shifting their work patterns, or implementing additional measures to reduce the contamination. One of these protective measures was spraying the work area with water to mitigate dust, as shown below.
Source: GZA GeoEnvironmental, Completion Report.
Dust mitigation.
Source: GZA GeoEnvironmental, Completion Report.
Location of continuous air monitors.
The monitors were also programmed to send a "stop work" notice if levels of VOCs or dust reached a greater (pre-determined) concentration. This continuous monitoring, which focused on a class of substances (VOCs) with varied potential for harm, was supplemented by the occasional collection of additional air samples that were sent for more detailed analysis.
Source: GZA GeoEnvironmental, Completion Report.
Air monitoring.
Since Mr. Martella had not heard anything about air quality issues from the property owner, he seemed to assume - reasonably enough - that the air was safe. He also mentioned that, based on his experience, if a major problem existed at the site, he expected to receive many complaints from the community. He said that this simply had not happened.
He encouraged me to contact the property owner with my concerns, and also emphasized that I should call him with any additional concerns, should they arise. I followed up by contacting the National Grid representative. She said that the work entailed removing "rainwater" and "mud" from the tanks. Like Mr. Martella, she cited the sophisticated air monitoring system, and said that these were monitoring levels of VOCs in the air to ensure that there were no residential exposures. She also mentioned that they were employing additional measures to avoid exposures, including wetting down the work area to keep the substances from travelling through the air.
In the coming days, however, I continued to smell the strong chemicals, and they did not smell like any rainwater or mud that I had ever encountered. The problem was that I could not identify the compounds, and so had no way of determining their toxicity. I went to the DEM to review the public files on the Tidewater Site, but I couldn't make sense of the files and files of documents. Finally,I contacted a representative of the contractor, GZA GeoEnvironmental. When I mentioned the smells, she said that some of us have sensitive senses of smell. She also suggested that the smell was coming from another location: perhaps a fire that had recently been burning not too far away in Pawtucket, or the coffee roaster nearby. When she mentioned the air monitoring system as evidence that the air was fine, I asked her to check in with the manager on site to see if the system had sent any alerts. She agreed to do so, and when I spoke with her a few moments later, she informed me that there had been no alerts. It was then that I described the smell - "like moth balls" - and she confirmed that this was napthalene, a substance indeed associated with the site. She said that napthalene has a low odor threshhold, so the fact that I could smell it did not mean that it was concentrated in the air.
That information was crucial - for the first time in weeks of searching, I had the name of one of the contaminants that I was smelling. I learned that napthalene could indeed be quite toxic. I contacted a number of colleagues working on issues of toxicity, and Dr. Rebeka Merson, a colleague at Rhode Island College who studies how toxic exposures impact marine life, offered to visit the site. After doing so, she informed me that she noted multiple VOCs in the air around the property. I also reached out to other parents at the school and the Environmental Justice League of Rhode Island, and - with this support - made a request to the DEM to ask the property owner to stop the work. DEM officials visited the site and conducted their own air monitoring. It turned out that by this time, however, the sludge processing was complete. DEM officials also requested the data from the air monitors that had been used throughout the project.
The data: Air contamination
It took a couple of weeks for the property owner to submit the data from the monitors to the DEM. Apparently, the monitors collected raw data, and this needed to be organized for analysis. When the data were finally made available, they demonstrated major shortcomings in the management of the hazards on the property.
The monitors had registered high-levels of VOCs on dozens of occasions, and the system had duly alerted workers on-site. The chart below lists the dates of all of the alerts that were sent, arranged according to the corresponding monitor.
I noted that several alerts were sent on September 15, 16 and 17, the days that I initially noted the smells and made my first calls. Apparently, this information was not conveyed to DEM officials. Perhaps it was not conveyed to the representatives of the property that I spoke with, who assured me that the air was safe even as notices of high concentrations of VOCs were being sent. These assurances kept members of the community from intervening in the work to protect the health of the community. Paradoxically, the function of the air monitoring system here was to deflect attention from the exceedances in concentrations of toxins in the air that it was registering.
The chart below provides data on levels of total VOCs and dust from one of the monitors during a 24-hour period. The red line indicates the action level that was set for VOCs, a concentration of 0.500 ppmv (parts per million). Between 10 am and noon on this particular day, at times, concentrations of VOCs nearly doubled that benchmark.
In retrospect, there were multiple technical flaws in the system of air monitoring. One of these flaws is that the community was not considered as a key stakeholder in planning how to respond to high concentrations of VOCs or dust. So, the response entailed an intervention on the part of the workers, but no provision was made to communicate these exceedances to the surrounding community. Suprisingly, it seems that there wasn't even a protocol for communicating these exceedances to the DEM. As a result, while the contractors contacted the DEM on multiple occasions to report evidence of high levels of zinc in the water that was being dumped in the river, no similar action was taken in response to the ongoing evidence of issues with air quality.
A second flaw is that the property owner and the DEM had not agreed on the significance of the levels that had been set. As a result, the property owner maintains that the exceedances were not dangerous. Representatives of National Grid and GZA GeoEnvironmental insist that the action levels were set conservatively, to facilitate intervention to ensure that concentrations of the substances did not reach dangerous levels. DEM's scientist, however, has challenged that claim, noting that the levels of benzene, in particular, exceeded safety limits for that contaminant threefold.
A third flaw is that the continuous sampling of VOCs focused on a class of substances with widely varying degrees of toxicity. We cannot say which substances people were exposed to. This has been a source of great frustration for community members, who look to air monitoring data for concrete information on potential harms.
What went wrong? Lessons from the gasholder project and the creation of the Tidewater Communities Project
Reforms in the management of brownfields since the 1980s have been grounded in the recognition that community members are key stakeholders in considerations of how these properties should be managed. This is, most importantly, because brownfields have the potential to cause harm to members of the community. Considerations of this harm have led to the creation of strategies to ensure that the interests and concerns of members of the community inform the management of these sites. If this is the yardstick for measuring the success of bownfield management, the gasholder project was a signficant failure. What went wrong?
The technical flaws in the system of air monitoring do not explain the gasholder project's failures. The much more significant issue is the notion that community members are peripheral to the management of the property. This notion contributed to some of the shortcomings in the air monitoring system -particularly the lack of a protocol for communicating information about harms to the community, and the failure to collect the kind of information that is needed to address community members' most basic concerns about toxicity and health.
The community's peripheral role is evident in the Completion Report, where concrete steps were taken in accordance with OSHA regulations to protect workers from the site's hazards, while community members located just a few steps away were left completely unprotected. As a result, workers conducting lead and asbestos abatement activities on the site were dressed in protective gear, while unprotected children and staff members stood just over 100 feet away on the playground. When I mentioned this to an official, he commented that the use of protective gear did not mean that the substances were dangerous - the workers might be required to wear this gear to fulfill regulations. Of course, the regulations are based on evidence that substances like asbestos and lead are indeed hazardous. I noted a similar divergence between the seemingly cautious approach that was taken to evidence of high levels of zinc in the treated water, and the more muted response to high levels of contamination in the air.
As discussed here, Rhode Island's Rules and Regulations for the Investigation and Remediation of Hazardous Material Releases requires public involvement in the process of determining an appropriate remediation plan. Before the Department of Environmental Management will approve a remediation proposal, it must be presented for public comment. The gasholder project, however, and multiple projects that have occured since then, have been authorized before the public presentation of the remediation plan and before the convocation of a community conversation about that plan. I suspect that this willingness to approve projects without public involvement reflects a widespread sense that most people lack the specialized information that is needed to contribute to the management of brownfields. A news reporter conveyed this notion to me most bluntly after I related some of my concerns about Tidewater to her. She said, "But, who are you to second guess DEM?"
Indeed, certain kinds of specialized information are necessary for members of the public to understand and contribute to these conversations. Yet, the history of the gasholder project affirms the unique role that members of the community bring to these projects: they are the only ones who can adequately watch out for their own interests.
During the gasholder project, community members attempted to intervene when the air monitoring system failed to prompt action to address problems with the work. In fact, in working with members of the community since the conclusion of the gasholder project, I have been surprised to learn that others also called to complain about the work. A school official reported having called with concerns, as did a nearby resident. The resident recounted that the contaminated air entered his home, where it remained for weeks. He suffered headaches. The Completion Report also makes reference to two complaints from members of the community (see p.17). The first came from a resident of an apartment building that borders the Tidewater Site. A DEM official visited the site on August 25 in response to this complaint. He investigated the protocols that were being used to address odors as well as the air monitoring system, and allowed the work to continue. A few days later, on September 1, another caller complained about the work, prompting a second visit by a DEM official.
In this case, it seems that the official was particularly concerned about the caller's claim that sludge was being pumped into the river (see note to right). He verified that this was not the case and left.
These instances show that community members were unable to frame their concerns in ways that influenced the work. As a result, they were unable to address the very real threats to health that they perceived.
In preparation for the project, during the Spring of 2010, the property owner distributed information to some of the neighbors. The director of the International Charter School gave me a copy of this packet of information when asked about the work. It contained crucial contact information for communicating concerns about the
site. It also contained useful information about toxics
Source: GZA GeoEnvironmental, Completion Report
Note from complaint call to DEM.
and brownfields. The Information about this particular project, however, was minimal. In fact, most of the description of the work was focused on an investigation of contamination on the property, not on the gasholder project. The description of the gasholder project was limited to the following:
"In addition, National Grid will begin activities related to the demolition of the two former
gas holder structures this spring. The initial activities will include removal and treatment of
water from the holders. Following the dewatering activities, National Grid anticipates
demolishing the holder structures in the summer and fall of 2010."
In this description, the liquid in the tanks is characterized as "water" rather than "sludge." Because of this, the pamphlet does not provide the information members of the community need to consider the kinds of exposures that could result from the project, and to evaluate potential exposures. On September 1, National Grid circulated an updated flyer, I suspect in response to the complaints. This included more information, and accurately characterized the contents of the holders. Nonetheless, representatives of the property owner used the language of "rainwater" and "mud" when I called about the smells. This greatly constrained my ability to advocate on my own behalf, and on that of the broader Tidewater community. Moreover, the National Grid representative positioned herself as a patron addressing a client, rather than a stakeholder, and asking if I was calling to thank her for their good work.
The notices on the holder project also contain assurances that the work is being supervised by Rhode Island's Department of Environmental Management: "These investigation activities will be conducted in accordance with RIDEM's Remediation Regulations..." This too positions members of the public as clients rather than stakeholders. It also conflicts with disagreements that emerged after the project, as RIDEM officials and National Grid representatives seemed to have significantly different opinions on whether this was the case. In fact, RIDEM officials began an investigation (see document dated 1/12/11 on DEM's Tidewater website) into whether National Grid had violated the Department's air pollution regulations, specifically Air Pollution Control #14, after collecting and reviewing the data from the air monitors. [National Grid claimed that the regulation did not apply to the gasholder work. DEM officials insisted that it did, indeed, apply. Nonetheless, they decided not to pursue the matter, citing considerations of how best to allocate the Department's limited resources.]
The Tidewater Communities Project was developed in response to the failures of the gasholder project. Since late Fall 2010 and Spring 2011, the project developed from a collaboration between me (Holly Dygert), Jen Rossi (another parent of a child at the International Charter School, ICS), and Amelia Rose (formerly director of the Environmental Justice League of Rhode Island). You can read more about the project and its evolution here.
Initially, Jen and I worked with Dr. Julie Nora, Director of ICS, to convene an ICS-based stakeholders group. This group reached out to local officials and representatives of the property owner in an effort to learn more about the site and its management, and to exert greater influence on its management. Not long after, we began mobilizing a broader stakeholder group that included members of multiple schools in the area and members of the community. As part of this initiative, we have conducted community outreach campaigns, held community meetings and initiated a public involvement plan. You can learn more about these and other efforts on the Community Action page.