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10/17/24 Update – Please email Alan Rousseau (rousseaua@verizon.net) for the attachments mentioned here.

1. MEPA Activity – Massachusetts Environmental Policy Act Office

a. Public Involvement Plan (PIP) has been updated as of September. Significant changes have been made to this 18-page draft PIP. Attached is an 9/11/24 email from Kate Harson, MEPA EJ Liaison, with further comments on the PIP.

b. Sludge Landfill Public Informational Meeting (PIM) has been postponed to a future date (TBD). This was because the State Environmental Justice office determined that the City did not provide enough advance notice and did not provide the presentation documentation in advance of the 9/5/24 meeting. Attached is an 9/19/24 email from DPW Director Dane Arnold indicating the City has decided to delay the PIM until they can review a Biosolids Master Plan from the State. As of 9/26/24, Dane says the State has not released the Biosolids Master Plan.

c. DEIR - Woodard & Curran (W&C) and the City are continuing to meet on a weekly basis on the Draft Environmental Impact Report (DEIR).

d. WP-33 expansion permit and our wetlands Order of Conditions appeal are on hold pending completion of the MEPA process.

2. 1,4-dioxane Contamination –We are awaiting further action by the Gardner Board of Health (BoH). Since our last update, we attended the 9/23/24 BoH Meeting and Alan attended a 10/15/24 BOH tour of the Landfill property. The tour covered the Solid Waste Landfill Erosion areas, two non-functional monitoring wells, and the southern fence line of the Sludge Landfill, including outfall pipes #1 & #2. The tour was very good and informed the Board of the locations of both landfills on this site. Board members will be creating a list of questions for the next BoH Meeting on October 28th at 4:30 PM at Gardner City Hall in the Mayors conference room. Please mark your calendars and attend!

3. Wetland Complaint – In September, MassDEP investigated a wetland complaint at the Sludge Landfill. Attached is an 9/30/24 email Tom Rebula, MassDEP Environmental Analyst, with a copy of the Judith Schmitz, MassDEP Wetlands Section Chief, 9/27/24 letter: Wetland Complaint – Inspection Report.

4. GCA Drop Box – The Gardner Clean Air Drop Box file share has the information that you need to understand the SLF expansion and participate in the upcoming public meeting. Please reply to this email to obtain access.

5. Lawn Signs - Reply to this email or call/text 978-618-5755 in order to arrange for either a sign drop-off or pick-up. We now have over 60 lawn signs posted in Gardner and Templeton!!

6. GCA Facebook Page - The Gardner Clean Air Face Book page is now growing in followers and page likes. Please take a moment to check out the page and give it a like and share. Also, use the Lawn Sign image (attached) when posting comments on the Sludge Landfill expansion. This will amplify the lawn sign communication.

Proposed Gardner Sludge Landfill Expansion (9/9/24) Overview: The City of Gardner is planning to construct a 4.3-acre expansion to the Sludge Landfill (SLF) in Wildwood Cemetery Forest, off West Street (route 68) in Gardner. This is 72% increase in the size of the existing 6.0-acre SLF. This expansion is only a temporary (17-year) solution to managing the City’s wastewater sludge, but the sludge will remain at this site forever. So will the threat to nearby public and private drinking water wells (see map) from liner leakage, which is common to most landfills. Less than 20% of Massachusetts sludge is deposited in landfills. There are only a few remaining sludge landfills in Massachusetts and no other community is creating or expanding a sludge landfill. Sludge disposal alternatives exist, so the City has choices.

The most recent June 2024 Gardner Solid Waste Sanitary Landfill Monitoring Report, revealed exceedances for 1,4- dioxane. The exceedances (levels above the Office of Research and Standards Guidelines (OSRGs)) were found in 4 on- site monitoring wells and a private off-site pond (located approximately 1,200 feet south of the landfill. “MassDEP considers 1,4-dioxane an emerging contaminant because it is toxic, widely used so that pathways for human exposure exist, and health protection standards are needed. 1,4-dioxane is a synthetic chemical with many uses as a solvent. Based on toxicity studies, EPA has categorized 1,4-dioxane as likely to be carcinogenic to humans.” The Gardner Board of Health is currently following-up on the cause (erosion or liner leakage) and the source (SW Landfill or SLF) for this contamination.

The SLF expansion construction is currently targeted for FY2026. This project is currently in the state Massachusetts Environmental Policy Act (MEPA) process. The City will be scheduling a public meeting and is currently working on a Draft Environmental Impact Report required by the MEPA office.

Templeton Impact: Future risk of drinking water wells due to groundwater / surface water contamination. The geology of the site has glacial outwash and fractured bedrock which does not provide any natural containment for leachate leakage. The SLF expansion Hydrogeological Evaluation Report indicates that south-southeast groundwater flow direction. Wetlands and streams, south of the SLF site, flow to the Otter River. Templeton’s Otter River and Sawyer Street public wells are located within a mile. Templeton private residential wells are also located within a mile. The City has no plan or procedure to restore water resources in the event of a system failure and contamination in 1, 5, 10, 25, or 100 years.

Continuation of persistent odors, emanating from the existing SLF, negatively impact the health and quality of life for Templeton residents within a mile. Sewer gas is a combination of carbon dioxide, methane, hydrogen, and hydrogen sulfide. It accumulates as a result of fermentation and a decomposition of organic matter. Hydrogen sulfide, the characteristic "rotten egg" gas, is generated by anaerobic decomposition of organic matter and will collect toward the bottom of enclosed tanks or manholes. After exposures to hydrogen sulfide, the human nose becomes desensitized. The gas might still be present, and it can cause death or dizziness that might resulting in a fall that causes injury.

For more information contact: Millers River Watershed Council (Ivan Ussach, Director)

Gardner Clean Air (Alan Rousseau, rousseaua@verizon.net, 978-618-5755)

Hi Everyone, September 1, 2024

  In order to provide you with some important reference documentation on Gardner’s proposed Sludge Landfill Expansion, I have created a Drop Box file share.  If you would like access to the Drop Box, please reply to rousseaua@verizon.net Currently, the Drop Box is uploaded with the following list documentation.  Because there is a lot of info here, I recommend starting with #1, #2, and #3.

  1. Gardner Sludge Landfill Flyer (10/13/23) – 2 page summary prepared by the Millers River Watershed Council (MRWC).

  2. Gardner Sludge Disposal Points 2Feb2024.dox (2/2/24) – 2 page summary of Sludge Landfill Expansion and 3 alternatives.

  3. 16643 enf Gardner Sludge Landfill Expansion – Gardner.pdf (2/10/23) – Mass EEA Secretary’s Certificate requiring a Draft Environmental Impact Report (DEIR).  The first 15 pages describe the project & the scope for the DEIR.  The remainder of the Certificate has the comments from the 29 entities, including MassDEP.

  4. Gardner Sludge Landfill Expansion Community Meeting  Prep Session 14Feb2024.pdf (2/14/14) – Power Point document with key topics and questions for the public meeting.

  5. Landfill Failures (Sept 2016) – Center for Health, Environment & Justice doc that addresses landfill failures and liners.

  6. 332-068 Gardner 2024 Annual Env Monitoring Report (June 2024).pdf – Most recent Solid Waste Landfill Monitoring Report for the now-closed landfill.  Exceedances for 1,4-dioxane are found in 5 monitoring locations, including 1 off-site pond.

  7. RY2023 SLF Operations Report_FNL SBMTL_2-15-24.pdf (2/14/24) – Most recent Sludge Landfill Annual Operations Report.

  8. NEBRA-MassCEC-MassSludgeSurveyThe Mass Sludge Survey2018-v.1-FINAL-30DEC2019.pdf (Dec 2019) – Survey and report by NEBRA and Mass Clean Energy Center on how sludge is handled in Massachusetts.

  9. Wildwood Forest Management Plan (2012) – Forest Management Plan done for the City of Gardner that includes a property overview, regional significance, management summary, landowner goals, and a mapping of all of the tree stands.

  • ENF Info Submitted to MEPA 12Dec2022 (12/12/22) – Folder with the City’s submission of Environmental Notification Form (ENF) to MEPA Office.   Includes the ENF Cover Letter, ENF Report, and Appendices that include the 900 page Engineering Report (Jan 2022)

  • SLF Maps 31Aug2024 – Folder with expansion area maps and vicinity maps.

 Wishing you all a nice Labor Day!

 Best Regards, Alan

Alan N. Rousseau, 211 Betty Spring Road Gardner, MA 01440 (H) 978-632-0618 (C) 978-618-5755

 Gardner Clean Air (GCA) is a grass roots community organization that was formed 2014.  Gardner Clean Air supports clean and sustainable solutions for wastewater sludge management, such as Anaerobic Digestion, and not expansion of the Gardner Sludge Landfill.  The GCA Facebook page can be found at this link: https://www.facebook.com/GardnerCleanAir/