COMMONWEALTH OF MASSACHUSETTS

EXECUTIVE OFFICE OF ENERGY & ENVIRONMENTAL AFFAIRS

DEPARTMENT OF ENVIRONMENTAL PROTECTION

THE OFFICE OF APPEALS AND DISPUTE RESOLUTION

IN THE MATTER OF: OADR Docket Nos. 2019-008, 2019-009,

2019-010, 2019-011, 2019-012, 2019-013
DEPFileNo: Application No. SE-15-027
Algonquin Gas Transmission LLC No. X266786 Air Quality Plan Approval
Weymouth, MA

PRE-FILED DIRECT TESTIMONY OF DOUGLAS W. DOCKERY

I, Douglas W. Dockery, do state as follows:

QUALIFICATIONS

1. I am John L. Loeb and Frances Lehman Loeb Research Professor of Environmental

Epidemiology at the Harvard T.H. Chan School of Public Health. From 2006 to 2016 I was Chair

of the Department of Environmental Health at the Harvard Chan School. For the past ten years,

until April U* of this year, I have been Director of the HSPH - NIEHS Center for Environmental

Health, the oldest Core Science Center (now in its 56* year) supported by the National Institute

of Environmental Health Sciences. (My Curriculum Vitae is attached hereto as Exhibit 1 t

2. I have a BS in Physics from the University of Maryland (1969), an MS in Meteorology

from the Massachusetts Institute of Technology (1972), and an MS (1974) and ScD (1979) in

Environmental Health Sciences from the Harvard School of Public Health.

3. I was a General Physical Scientist in the Systems Analysis Branch of the U.S.

Environmental Protection Agency Region 1 office in Boston, MA from 1972 to 1973, where I

did air quality modelling. 1 returned to school at the Harvard School of Public School in the fall

of 1973. During my first year of studies (1973-74) I worked part-time as a Staff Meteorologist at

Environmental Research and Technology, an environmental consulting firm in Concord, MA,

where 1 continued to work in air pollution modelling.

4. My professional society memberships have included the Air Pollution Control

Association, American Meteorological Society, American Public Health Association, American

Thoracic Society, the Society for Epidemiologic Research, and the International Society for

Environmental Epidemiology. I was President of the International Society for Environmental

Epidemiology for two years (1998 and 1999).

5. I was a Reviewer of the US EPA Air Quality Criteria for Particulate Matter and Sulfur

Oxides (1980), the Air Quality Criteria for Nitrogen Dioxide (1989, 1992), the Air Quality

Criteria for Ozone (1993), and the Air Quality Criteria for Particulate Matter (1995). I was a

Member of the US EPA Clean Air Science Advisory Committee (CASAC) Oxides of Nitrogen

Review Panel (2013-2017) and of the CASAC PM Review Panel (2015-2018).

6. To date, I have published 201 original research articles and 37 reviews and commentaries

in the peer-reviewed seientific journals. These publications have been frequently cited in the

scientific literature. A recent Web of Science search found 34 thousand citations to this body of

publications, including 6 articles with more than 1,000 citations, 23 publications with more than

300 citations, and 72 with more than 100 citations.

7. In 1992,1 received with my colleauges the Matilde M. de Santos Prize from the Mexican

Health Foundation (La Fundacion Mexicana para la Salud) for our paper entitled “Effects of

ambient ozone on respiratory function and symptoms in Mexico City schoolchildren.” In 2003,

my colleagues and I received the IMS Doctor Award from the Irish Journal of Medical Sciences

for the Best Clinical Research Paper (Respiratory and Overall) “Effect of air-pollution control on

death rates in Dublin, Ireland: an intervention study.” In 2009, my colleagues and I received the

first Best Environmental Epidemiology Paper Award from the International Society for

Environmental Epidemiology for our paper entitled “Fine-Particulate Air Pollution and Life

Expectancy in the United States.”

8. In 1999,1 received the first John Goldsmith Award from the International Society for

Environmental Epidemiology for sustained and outstanding contributions to the knowledge and

practice of environmental epidemiology.

9. Over the past 45 years, my research has focused on air pollution exposures and their

associated health effects. In 1988,1 became Principal Investigator of the Harvard Six Cities

Study. That study examined the health effects of air pollution exposures in populations who have

been followed for over thirty-five years. We examined the growth of lung function in children,

its decline in adults, and the environmental risk factors affecting these trajectories. In 1993 our

team showed that life expectancy was strongly associated with community particulate air

pollution levels; that study remains the single most frequently cited paper in the air pollution

literature. Our studies were pioneering in identifying particulate air pollution as a trigger for

acute cardiovascular events. Our work has been instrumental in the designation of health-based

air pollution standards for fine particulate air pollution by the U.S. Environmental Protection
Agency and the World Health Organization. My current work is assessing the health benefits of

air pollution controls.

TESTIMONY

I. AIR POLLUTION MODELLING

10. Although air modeling was reported to have been conducted according to EPA

Guidelines, the choice of models and model inputs given the shoreline location was not

consistent with these Guidelines.

II. The site of the proposed compressor and pipeline at Fore River presents specific

challenges with regard to modelling air pollution concentrations in the surrounding communities.

This is a particular issue for the population in Braintree, which is west and immediately inland of

the Fore River site. Specifically, dispersion from such shoreline sites are affected by sea breeze

circulation which changes the wind directions, wind speeds and turbulence intensities both

spatially and temporally in the areas inland of sources on the coast. Under sea breeze conditions,

the plume can be carried inland aloft largely intact before being brought down to the ground in a

process known as “sea breeze fumigation.” The classic reference Meteorology and Atomic

Energy’ succinctly comments on the importance of sea breeze circulations

"The sea breeze is important to diffusion studies at seaside locations because of the
associated changes in atmospheric stability, turbulence and transport patterns. Moreover
its almost daily occurrence at many seaside locations during the warmer seasons results
in significant differences in diffusion climatology over rather short distances. ”

^ Slade, D.H.. METEOROLOGY AND ATOMIC ENERGY, 1968. Section 2-3.5. doi:10.2172/4492043.
https://www.osti.fiov/biblio/4492043 . (Relevant sections are attached hereto as Exhibit 2.)
12. Selection ofAERMOD: The Trinity Consultants ‘‘‘'Updated Air Dispersion Modelling

Report”^ states that following the U.S. EPA’s Guideline on Air Quality Models^ AERMOD was

used to model the air quality impact of the proposed compressor and associated emissions. This

is consistent with the Traditional Stationary Source Models Recommendations in the EPA

Guideline (page 557):

4.0 TRADITIONAL STATIONARY SOURCE MODELS

4.2 Recommendations
4.2.2 Refined Analytical Techniques
b. For a wide range of regulatory applications in all types of terrain, the
recommended model is AERMOD.

13. However, as noted later (Section 6.0 Other Model Requirements and 7.0 General Model

Considerations) in the EPA Guidelines on Air Quality Models, other models are recommended

for sources on the shoreline. Specifically, the relevant sections are quoted below (emphasis

added).

6.0 Other Model Requirements

6.2 Recommendations
6.2.4 Modeling Guidance for Other Governmental Programs (Page 565)
b. ... Sources located on orjust inland of a shoreline where fumigation
is expected should be treated in accordance with subsection 7.2.8.
7.0 General Modeling Considerations
7.2 Recommendations
7.2.8 Complex Winds (PAGE 568)
a. Shoreline Fumigation. Fumigation can be an important phenomenon on
and near the shoreline of bodies of water. This can affect both individual
plumes and area-wide emissions. When fumigation conditions are
expected to occur from a source or sources with tall stacks located on or
just inland ofa shoreline, this should be addressed in the air quality
modeling analysis. The Shoreline Dispersion Model (SDM) listed on

Trinity Consultants, Updated Air Dispersion Modelling Report, Algonquin Gas Transmission, LLC > Weymouth
Compressor Station, Atlantic Bridge Project, Revised May 2018 (included in "Basic Documents")
^ U.S. era's Guideline on Air Quality Models, 40 CFR Part 51, Appendix W (7-1-11 edition) (attached hereto as
Exhibit 31
 EPA’s Internet SCRAM Web site (subsection 2.3) may be applied on a
case-by-case basis when air quality estimates under shoreline fumigation
conditions are needed.

14. In summary, the selection of AERMOD for evaluation of air pollution exposures from the

proposed Weymouth Compressor Station at this shoreline location is not consistent with these

U.S. EPA’s Guideline on Air Quality Models.

15. Application ofAERMOD: The implementation of AERMOD"^ requires the specification

of meteorological data using the AERMET^ meteorological processor. In applying AERMOD,

Trinity Consultants used preprocessed meteorological data provided hy the Massachusetts

Department of Environmental Protection (MassDEP).

16. When applying the AERMET meteorological processor to process meteorological data

for the AERMOD model, the user must determine appropriate values for three surface

characteristics; surface roughness length {zq}, albedo {r}, and Bowen ratio {Bo}. These

parameters are used to adjust diffusion characteristics, and are in turn estimated by the

AERSURFACE^ tool. AERSURFACE requires the input of land cover data from the U.S.

Geological Survey (USGS) National Land Cover Data 1992 archives (NLCD92), which it uses to

determine the land cover types for the user-specified location. AERSURFACE matches the

NLCD92 land cover categories to seasonal values of albedo, Bowen ratio, and surface roughness.

us Environmental Protection Agency AERMOD Implementation Workgroup. AERMOD IMPLEMENTATION GUIDE,

August 3, 2015 https://www3.eDa.eov/ttn/scram/7thconf/aermod/aermod imolrntn guide 3AuBUSt2015.pdf.
(Attached hereto as Exhibit 41.
^ US EPA, User's Guide for the AERMOD Meteorological Preprocessor (AERMET) EPA-454/B-18-002 April, 2018.
https://www3.epa.i;ov/ttn/scram/7thconf/aermod/aermet usereuide.pdf. (Attached hereto as Exhibit 5).
® US EPA. AERSURFACE User's Guide. EPA-454/B-08-001 January 2008 (Revised 01/16/2013)
httDs://www3.epa.eov/ttn/scram/7thconf/aermod/aersurface usereuide.pdf. (Attached hereto as Exhibit 6).
17. Trinity Consultants used the approach of characterizing the NLCD92 land cover

categories for the area within a 2 kilometer circle (Focus Area) of the proposed site (Updated Air

Dispersion Modeling Report, Table 3-2 Urban/Rural Determination Results). Based on the

observation that on 13.8% of the cells in this Focus Area were Urban, which they defined as

Code 22 (High Intensity Residential) or Code 23 (Commercial/Industrial/Transp), they

characterized the entire Focus Area as “Rural” for the AERSURFACE characterization of

albedo, Bowen ratio, and surface roughness.

18. However, 30% of the cells within the Focus Area (Table 3-2) are Open Water (Code 11).

There are major differences in AERSURFACE characterization for surface roughness, albedo,

and Bowen ratio between Urban, Rural, and Open Water land cover. To illustrate, the Table

below gives the surface roughness, albedo, and Bowen ratio for Mid-Summer conditions.

Table: Mid-Summer Surface Roughness, Albedo, and Bowen Ratio by NLCD 1992 3-2
Category

NLCD 1992 Category

Surface Albedo Bowen
Roughness Ratio
Code Description (cm)
23 Commereial/Industrial/Transp 80.0 0.18 1.5
22 High Intensity Residential 100.0 0.18 1.5
21 Low Intensity Residential 54.0 0.16 0.8
11 Open Water 0.1 0.10 0.1

19. This Table shows the very substantial difference in Bowen Ratio (8 to 15 fold) and

Smface Roughness (50 to 100 fold) between Open Water (Code 11) and the Urban (Codes 222

and 23) or Rural (Code 21) categories.

20. For reference, the recommendations for determining surface characteristics presented in

the AERMOD Implementation Guide are quoted below (page 6):

1. The determination of the surface roughness length should be based on an inverse

distance weighted geometric mean for a default upwind distance of 1 kilometer relative to
the measurement site. Surface roughness length may be varied by sector to accountfor
variations in land cover near the measurement site; however, the sector widths should be
no smaller than 30 degrees.
2. The determination of the Bowen ratio should be based on a simple unweighted
geometric mean (i.e., no direction or distance dependency) for a representative domain,
with a default domain defined by a 10km by 10km region centered on the measurement
site.
3. The determination of the albedo should be based on a simple unweighted arithmetic
mean (i.e., no direction or distance dependency) for the same representative domain as
definedfor Bowen ratio, with a default domain defined by a 10km by 10km region
centered on the measurement site.

21. By characterizing the entire area around the Weymouth Compressor site as Rural, Trinity

Consultants have not followed the AERMOD Implementation Guide which would have taken

into account the dominant Open Water surface characteristics at this site. This is of particular

importance for estimating the air pollution impacts of the Weymouth Compressor Station in

Braintree, as the upwind open-water fetch would reduce ground level dispersion characteristics.

22. Meteorological Data for AERMOD: AERMOD requires two types of meteorological

observations for its calculations - hourly records of surface meteorology (wind direction, wind

speed, air temperature, cloud cover, etc) and twice daily measures of the vertical temperature

structure of the atmosphere (Rawinsonde). Trinity Consultants used processed meteorological

data provided by MassDEP for the period 2012 to 2016 from National Weather Service site at

Logan International Airport (WBAN 14379) for the surface observations and vertical structure

^ https://www3.eDa.BOv/ttn/scram/7thconf/aermod/aermod impimtn guide 3AuBUSt2015.pdf. (See Exhibit 4)

8
data from the National Weather Service Rawinsonde Site (WBAN 74389, KGYX) at Gray,

Maine. The surface observations at Logan Airport are at a similar shoreline site less than 8 miles

from the Fore River, and therefore provide an excellent representation of surface meteorological

conditions at the Fore River site. The Gray, Maine Rawinsonde site approximately 11 miles from

the coast and approximately 120 miles from the Fore River site. While it represents generic

upper air conditions under most meteorological conditions in eastern New England, it does not

capture the vertical temperature structure of the atmosphere at shoreline locations during sea­

breeze conditions. For context, a study of sea breeze conditions at Logan Airport formd 309 days
o
with sea breeze over a ten year period (1998-2007).

23. Conclusions Regarding Air Modeling: As noted at the outset, the unique location of the

proposed Weymouth Compressor Station at a shoreline site presents unique challenges in

modelling due to the temporally and spatially varying wind direction, wind speed, and vertical

dispersion characteristics during sea breeze conditions. The air pollution modelling of the

Weymouth Compressor Station fails to follow good practice for such conditions in three key

aspects.

1. The AERMOD model is not equipped to deal with emissions from shoreline sources,
and based on EPA Guidelines should not be used in this situation.
2. The designation of the entire modelled area as having the surface characteristics or a
“rural” area, is not consistent with large fraction of this area being open water. For
sea breeze conditions in which the wind would blow emissions from the Weymouth
Compressor Station over Braintree, the upwind overwater fetch produces minimal
surface roughness and possibly decreased vertical dispersion. Again, the EPA
Guidelines were not followed for specifying these surface characteristics given the
shoreline location.
3. While the use of Logan Airport observations is appropriate for surface meteorology,
the use of the inland site at Gray, Maine for measures of the vertical structure of the

Jennifer Thorp. "Eastern Massachusetts Sea Breeze Study" MS Thesis, Piymouth State University, May 2009
httos://www.nrc.BOv/docs/ML1106/ML110600926.Ddf. (Attached hereto as Exhibit 7).
 atmosphere will not capture the unique spatially and temporally varying depth of the
mixing layer during sea breeze conditions.

24. These weaknesses in the model selection, choice of surface characteristics, and choice of

meteorological data call into question the ambient air exposure estimates for Braintree and the

other affected communities.

II. EVALUATING TOXIC AIR POLLUTANT EXPOSURES

25. The evaluation of the impact of emissions of compressor and associatedfacilities as a

single source without consideration of other sources or background ambient air concentrations

is not consistent with the stated MassDEP policies to protect the public health.

26. Total Versus Incremental Ambient Air TELs: Massachusetts DEP sets Threshold

Exposure Limits (TELs) to limit exposure from ambient air taking into account that people may

be exposed to a chemical from sources in addition to outdoor ambient air, including indoor air,

food, soil, and water.^ That is, chemical exposures from multiple sources are additive, and need

to be considered jointly. It follows that the chemical exposure in the ambient air from all sources

needs to be considered jointly, without separately considering the specific source of that airborne

exposure. Thus, the TELs for ambient air limit total chemical exposures, and not incremental

chemical exposure from any specific sources.

27. MassDEP Evaluation ofImpact on Toxic Air Pollutants: MassDEP has evaluated the

impact of the Weymouth Compressor project on the health of the population in the affected

Department of Environmental Protection, Air Quality Plan Approval, Transmittal no. X266786,11 January 2019,
Page 10.
population by comparing estimated air pollution exposures to AALs and TELs. In its “Response

to Public Comments”'® MassDEP described the review process as follows (emphasis added):

MassDEP required Algonquin to conduct toxics air dispersion modeling. In this modeling
Algonquin followed MassDEP’s long-standing protocol that requires an assessment of
the ambient concentrations of air toxics caused solely by that source’s emissions. These
modeled concentrations were then compared to the AALs and TELs to determine whether
there may be potentially unacceptable risks associated with that particular source. As
shown in the amended Table 5 of the Air Plan Approval, the maximum modeled 24-hour
and annual concentrations for each toxic air pollutant attributable to the facility are
below all applicable MassDEP’s AALs and TELs.

28. While the combined estimated ambient air exposures to formaldehyde and benzene from

the Wejnnouth Compressor project, other sources, and local background concentrations were

above TELs and AALs, in the Approval Letter of January 2019," MassDEP states “Based upon

a review of the modeling analysis contained in the application, maximum impacts from emissions

from the proposed Facility will be below the AALs / TELs.”

29. What is the basis for evaluating the impact of the Weymouth Compressor station alone

without consideration of background concentrations or other sources? I was not able to find

documentation or examples of MassDEP’s “long-standing protocol” referenced above. This

protocol is not consistent with the science discussed above that all airborne exposures to

chemieals are additive and contribute to net health risk. This protocol also is not consistent with

the MassDEP use of a relative souree contribution factor in defining TELs, which accounts for

cumulative risk of chemical exposures from multiple, independent pathways (outdoor air, indoor

air, water, soil and food).

° MassDEP Response to Public Comments on the "Proposed Plan Approval".January 2019, page 8 (included in
Basic Documents)
Department of Environmental Protection, Air Quality Plan Approval, Transmittal no. X266786,11 January 2019,
Page 11.
30. Finally this protocol is not consistent with the screening approach used by MassDEP for

criteria air pollutants.

31. Screening Evaluation of Criteria Air Pollutants: In their assessment of the impact of the

Weymouth Compressor station with respect to National Ambient Air Quality Standard,

MassDEP evaluates the modelled source-specific ambient air concentrations of the criteria air

pollutant against US EPA Significant Impact Levels (SILs).

32. These SILs have been recommended by US EPA as compliance demonstration tools for

evaluating impact of new sources. Guidance on the basis and implementation of SILs was

provided by the US EPA Office of Air Planning and Standards in a memorandum to all Regional

Air Division Directors in April 2018.*^ Quoting from that memorandum:

When a Prevention ofSignificant Deterioration (PSD) permit applicant has shown

through air quality modeling that the projected air quality impactfrom a proposed
source for a particular pollutant is not significant or meaningful, the EPA believes there
is a valid analytical and legal basis in most cases for the permitting authority to conclude
that the proposed source will not cause or contribute to a violation ofa National Ambient
Air Quality Standard (NAAQS) or PSD incrementfor that pollutant. To show that the
proposed source will not have a significant or meaningful impact on air quality, permit
applicants and permitting authorities may elect to use these Significant Impact Level
(SIL) values (air quality concentration values) as a compliance demonstration tool.

33. Note that the SILs are designed for Prevention of Significant Deterioration (PSD)

evaluation that is in cases in which existing ambient air concentrations are less than the National

Ambient Air Quality Standards.

Peter Tsirigotis. Guidance on Significant Impact Levels for Ozone and Fine Particles in the Prevention
of Significant Deterioration Permitting Program, Memorandum to Regional Air Division Directors, April
18, 2018. Office of Air Planning and Standards, US EPA https://www.eoa.gov/sites/production/files/2Q18-
04/documents/sils policy guidance document final signed 4-17-18.pdf. (Attached hereto as Exhibit 8).
34. SILs are set as a small fraction of the National Ambient Air Quality concentrations. For

example, the SIL for annual PM2.5 is 0.3 |Xg/m compared to the NAAQS of 12 |Lig/m , and for

24-hour PM2.5 the SIL is 1.2 pg/m^ compared to the NAAQS of 35 pg/m^. That is the PM2.5 SIL

is only 2.5% (1/40*) of the annual ambient air standard and 3.4% (~l/30*) of the 24-hour air

quality standard. SILs for the other criteria air pollutants are similarly only small fractions of the

NAAQS.

35. Thus, based on the US EPA Guidance and MassDEP practice in evaluating ambient air

quality impact of new sources:

• Screening values for criteria ambient air pollutants for compliance demonstration tools
for evaluating impact of new sources are defined by Significant Impact Levels.
• These screening values are applied only in the case of ambient air concentrations below
the air quality standards.
• Screening values are set at very small fractions of ambient air standards.

36. Screening Evaluation of Toxic Air Pollutants: In their assessment of the impact of the

Weymouth Compressor Station with respect to toxic air pollutants, MassDEP evaluates the

modelled source-specific ambient air concentrations of each chemical against MassDEP TELs

and AALs.

37. In contrast to the protocol used for evaluation of the source impact of the Weymouth

Compressor Station on criteria air pollutants this screening evaluation was applied in the case of

toxic air pollutants (benzene and formaldehyde) which have existing ambient concentrations

above the MassDEP ambient air standards (TELs and AALs). Secondly, the ambient air source

contributions of the Weymouth Compressor Station, were compared to the full ambient air

standards (100% of TELs and AAls), rather than an indicator of significant impact level, which
in the case of criteria air pollutants are only a small fraction (1/40**' to l/SO***) of the ambient air

standard.

38. Using a screening approach for toxic air pollutants consistent with the well documented

US EPA protocol for evaluating the impact of a new source for criteria air pollutants, benzene

and formaldehyde emissions from the proposed Weymouth Compressor Station would be denied

as an unacceptable risk to public health.

III. TOXIC AIR POLLUTANT EFFECTS

39. Expected ambient air concentrations of known human carcinogens (benzene and

formaldehyde) will exceed MassDEP standards for noncancer (TELs) and cancer (AALs).

40. Toxic Chemicals: Benzene and formaldehyde have been classified as Group 1

carcinogens by the International Agency for Research on Cancer (lARC), that is there is

sufficient evidence that these chemicals are known human carcinogens. There is not a defined

safe level (threshold) for these Group 1 human carcinogens. Rather, exposure limits are set to

limit lifetime risk of cancer to 1 in a million.

41. Cancer risks from airborne exposures to each of these chemicals are toxicologically

equivalent and additive. That is there is no differentiation of chemical exposures for specific

sources of the Group 1 human carcinogens. Moreover, the MassDEP has set ambient air Annual

Ambient Limits (AALs) for these Group 1 human carcinogens recognizing that total dose comes

from multiple exposures through multiple pathways including not only outdoor air, but also

indoor air, food, soil, and water.

42. Ambient Air Background Concentrations: MassDEP monitoring of VOCs in the Boston

Metropolitan area (Boston and Lynn) and at the Weymouth Compressor site found levels of

formaldehyde and benzene above the TELs and AALs. Monitoring at the Fore River site

confirmed that benzene and formaldehyde ambient air concentrations already are above the TEL.

Any incremental increase in the ambient air benzene or formaldehyde concentrations would be a

violation of the requirement to protect the public health.

43. Ambient air formaldehyde concentrations are consistently above the AAL (annual

average 0.08 |ig/m ). In 2017 the annual average formaldehyde was 2.3 jig/m in Boston, and 1.8

|ig/m^ in Lynn. Over the shortened sampling period of July to August 2018 in Weymouth, mean

average formaldehyde was 2.4 |Lig/m^. These average observed formaldehyde concentrations are

far above the AAL. They are also higher than or close to the 24-hour TEL of 2.0 |Xg/m^

indicating that most days are above the TEL. Indeed half of the sampled days in Weymouth (7 of
1
14 days) had 24-hour formaldehyde levels above the TEL.

44. Measured ambient air benzene concentrations also were above the MassDEP AAL
■3

(annual average 0.1 |Lig/m ) at the monitoring sits in Boston (2017 average 0.37 |a.g/m ) and

Lynn (2017 average 0.29 pg/m^), and slightly lower than the AAL in Weymouth (0.08 pg/m^).

During the short sampling period in Weymouth (August to November 2018) there were not any

24 hour average benzene concentrations observed above the TEL (24 hour average 0.6 pg/m^).

45. In summary, ambient air formaldehyde levels measured at the Weymouth Compressor

site had long term averages concentrations 3 times the AAL, and 24 hour values above the TEL

on half of the monitored days. In addition, average benzene concentrations in Weymouth were

See Figure 52, Health Impact Assessment of a Proposed Natural Gas Compressor Station in Weymouth, MA.
Metropolitan Area Planning Council, January 2019 (included in Basic Documents)

15
80% of the AAL. These ohservations show this community is already at unacceptable cancer risk

from each of these VOCs. Moreover, together these two VOCs jointly produce an unacceptable

cancer risk. Adding to these background exposures even by a small increment is not protecting

the public health of the affected population.

46. Effects Are Not Independent: AALs and TELs consider each chemical separately and

independently. However, as volatile organic compounds, these chemicals (benzene and

formaldehyde) have similar pathways of exposure, update, metaholism, detoxification, and

pathologies in the body. Therefore the pharmaco-toxicologic pathways of these VOCs are likely

not independent but rather likely additive (or super-additive). Protecting the public health of the

affected population would call for considering the combined effects of these VOCs rather than

the effect of each independently.