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The Northeast Metro Tech Building Committee plans to build the new school in the 30-acre hilltop forest to the right as you face the guardhouse (south) of the existing school. From an environmental perspective, this is a terrible idea. The plan includes building more than a 2,000-foot-long access road between Farm Street and the existing school’s parking lot on Hemlock Road. This new access road would carry many school buses, cars, and trucks every day the new school is open. During snow and ice storms, trucks would apply 100s of pounds of salt containing chloride, which can be toxic to fish, frogs, salamanders, macroinvertebrates, and wetland plants.
The map below shows a 900-foot-long section of the proposed access road next to wetlands and a vernal pool. Runoff carrying chloride would flow directly from the parking lot and the access road through many catch basins into these water bodies and would kill fragile animals and plants. There is no treatment that will remove salt from the runoff.
I know what I’m talking about. For 30 years, I worked as a hydrogeologist for the US Geological Survey and the US Environmental Protection Agency (US EPA). During my career, I initiated and led many studies of road-salt impacts to wetlands, streams, and drinking-water sources in Massachusetts and New Hampshire. In fact, my work held up the expansion of I-93 in New Hampshire for several years until the state drastically changed its management and application of road salt. That project and my other studies all showed that when salty runoff flows from roads and parking lots, you can expect chloride levels to spike and far exceed federal and state standards for toxicity to aquatic life. (References to these studies are available upon request.)
In 1988, the US EPA defined chloride toxicity to aquatic life using chronic (long-term) and acute (short-term) criteria. The threshold of chronic toxicity occurs when “the 4-day average concentration of chloride, when associated with sodium, does not exceed 230 mg/l more than once every 3 years on average.” The acute toxicity threshold is defined using a briefer time span: “the 1-hour average chloride concentration that does not exceed 860 mg/l more than once every three years on average” (US EPA, February 1988, Ambient Water Quality Criteria for Chloride –1988: Office of Water Regulations and Standards, Criteria and Standards Division, Washington, DC, EPA 440/5- 88-001).
Massachusetts has adopted Surface Water Quality Standards using these same criteria. Specifically, 314 CMR 4.05(e) Toxic Pollutants states that: “All surface waters shall be free from pollutants in concentrations or combinations that are toxic to humans, aquatic life or wildlife.” Note that these are standards, not guidelines, and have the force of law.
Currently, the Wakefield Conservation Commission (Con Com) is reviewing the January 12, 2023, “Long Term Pollution Plan and Stormwater Operations and Maintenance Plan” for the new school. Regarding road salt, it contains only the following:
“2.7 Management of Deicing Chemicals and Snow The qualified contractor selected for snow plowing and deicing shall be made fully aware of the requirements of this section. Pre-treatment of roadways, when required, will be done in accordance with MassDOT standards for pre-treatment of roadways in sensitive areas. Straight rock salt shall not be used on site. At a minimum, Pre-Mix (rock salt and calcium chloride) shall be used for deicing. Other environmentally friendly deicers such as liquid magnesium chloride, calcium chloride, etc. may be used. All deicing chemicals shall be stored securely on-site. The snowplow contractor shall adhere to the deicing chemical use and storage requirements.”
These statements are wrong. Premix, sodium chloride, magnesium chloride and calcium chloride are ALL poisonous to freshwater organisms when chloride concentrations exceed the EPA and Massachusetts standards given above. All contain chloride and, in fact, calcium and magnesium chloride are more toxic than sodium chloride. These chemicals are not environmentally friendly. When trucks dump 100s of pounds of salt onto the Metro Tech’s access road during or after a storm, large amounts of toxic runoff will flow into sensitive wetlands and the vernal pool. As storms occur over time, more salt will flow into these waterbodies. These fragile ecosystems will not survive. They will be gone forever.
To my knowledge, no one involved in planning for the new school has taken samples to understand the pre-development water and ecological quality of the wetlands and vernal pool. It’s troubling to me as a water-quality expert that there is no baseline from which to assess post-development impacts.
The Con Com faces a choice between enforcing the Wetlands Protection Act, which means not approving the stormwater plan for the new school or losing its credibility by approving it. In my professional opinion, approving this stormwater plan means certain poisoning of the wetlands. It is not possible for the Con Com to approve this plan and obey the law.
The choice is clear. Reject the stormwater plan. Don’t build the road. Don’t destroy the forest and fragile wetlands. Build the new school on existing playing fields. For more information, go to NEMTforest.org or “Save the Forest and Build the Voke” on Facebook.
Douglas L. Heath, MS
Certified Hydrogeologist
