The health effects and potential liability associated with “rail trail contamination” is often cited as a reason to not convert the abandoned MBTA rail bed that traverses Dover into a mixed-use recreational trail referred to as “The Dover Greenway”. As three registered Massachusetts Licensed Site Professionals (“LSPs”) with more than 75 years of combined experience addressing environmental contamination issues, and as Dover residents, we felt an obligation to share our environmental experience on this topic. Regardless of your view on the merits of The Dover Greenway, potential rail trail contamination should not be a reason to vote against the rail trail. In fact, this project as proposed would only serve to reduce risk from potential oil and/or hazardous material so if this is your concern or a factor in your decision, you should be voting “Yes” on Article 19 on May 1, 2017.
The simple fact is that none of the contamination concerns raised over the years are new or specific to Dover. Rail road corridors have been around for a long time and conversion of these corridors to recreational use as rail trails is commonplace. Nearly as old are the processes, policies and techniques that we as scientists use to evaluate and address contamination during rail-trail conversions. We are not attorneys and the liability questions and concerns have been vetted and answered by the Town’s attorney which can be found here: (http://www.doverma.org/wp-content/uploads/2012/05/Bay-Colony-Rail-Trail-First-Supplement-to-KDB-Memorandum-.pdf). We are scientists that are specifically licensed to assess and mitigate oil and/or hazardous material in Massachusetts and based on our experience, addressing potential contamination will be an easy step for The Dover Greenway project.
When rail trail conversions started becoming common after 2000, the Massachusetts Department of Environmental Protection (“MassDEP”) developed a Best Management Practices document (the “BMP”) to provide guidance for rail-trail conversions. The BMP provides a practical approach that is also protective of health and the environment and reduces risk. The relevant elements of the BMP have been incorporated into the feasibility study and project design in the Beals & Thomas report commissioned by the town, which is available on the town website (http://www.doverma.org/PDFs/FINAL_DOVER%20FEASIBILITY_STUDY.pdf). The proposed contamination mitigation elements include removal of the rotting creosote-laden railroad ties that are a continuing source of contamination on the railway bed followed by capping the rail bed with a suitable barrier consistent with the BMP guidance promulgated by MassDEP. These measures will effectively eliminate both a continuing source of contamination and prevent contact with contaminants in existing soils, if present.
Since 2004 the BMP guidance has been successfully implemented on rail trail projects across the state and Paul Locke, Assistant Commissioner of MassDEP’s Bureau of Waste Site Cleanup, who developed the guidance, reported to us that he is not aware of any projects where problematic environmental contamination was discovered during or following the rail-to-trail conversion process in a rural right-of way environment such as Dover. Based on our experience, the proposed conversion will provide a net environmental benefit through mitigation efforts such as the removal of the treated railroad ties and by capping the rail bed.
As Dover residents, whose day job is to specifically evaluate and clean up oil and/or hazardous material in the environment, we believe the rail to trail conversion as proposed, would only serve to help address contamination, if present. Furthermore, we work in this industry and none of us are concerned about the contamination or the potential liability to ourselves or our families who live in Dover. So, if you are concerned about contamination and this is a consideration in your vote on May 1, 2017, the Dover Greenway project is the only mitigation plan currently proposed so please vote “YES” along with us.
Respectfully,
Paul McKinlay, PG, LSP
Ronald E. Myrick, Jr., PE, LSP, CHMM
Nancy C. Roberts, MS, LSP
