Open Letter to Princeton Mayor & Council RE: AvalonBay

Dear Mayor and Council-

Thank you for arranging the introduction of AvalonBay's demolition contractor to the public. After last night Council meeting I have the following questions and suggestions:

Please also see the attached summary of research I have been doing over the last several months in regard to the prudent environmental investigation of the former hospital site.

1. Has anyone surmised that AvalonBay will not purchase the hospital property if the soil is contaminated? Why hasn't AvalonBay closed on the sale of the property?  Why hasn't AvalonBay agreed to soil testing? Why wasn't the existence of a medical waste incinerator identified within any of the environmental reports which were then provide to the Princeton Planning Board ?

2. Should the town hire an expert in large-scale demolition and construction to review demolition and construction documents? Has Jack West ever reviewed demolition and asbestos abatement plans for buildings up to seven-stories on a 5+ acres site?

3. What is the protocol for demolition of a site that includes an incinerator and underground drainage piping that processed chemicals and solvents from a hospital?

By what method should the interior drain-line systems within each level of the old hospital building be tested and removed?

From Health Facilities Management. "Guarding against environmental hazards when rebuilding an existing site": "Before large-scale demolition begins, it is necessary to identify what lies in the building infrastructure. For instance, one of the most pervasive chemicals on old hospital sites is mercury. Mercury's harmful properties are well-documented and most facilities strive to be "mercury-free." However, old cast-iron or glass piping in buildings generally contain enough mercury to raise serious concerns about contamination unless every line between the laboratories and the final discharge has been replaced in recent years."

From Pollution Prevention Guide for Hospitals (excluding medical wastes): "Sewer Lines, Traps, and Sumps. Mercury is often present in sewer lines drains, traps, and sumps as it may have been discarded in this manner over the years. Caution should be taken to avoid spilling the contents in case mercury is present. Non-water contents must be handled as hazardous waste unless proven otherwise."

4. The University Medical Center at Princeton is listed as a large quantity generator (LQG) of hazardous wastes on the federal EPA's The National Biennial RCRA Hazardous Waste Report (Based on 2011 Data), p. 171.

What are the statutes requiring soil testing when a site used by a large quantity generator (LQG) of hazardous wastes is reused for residential purposes?

5. Should you be concerned about environmental litigation exposure? Did the Consent Order functionally curtail further inquiries from the Planning Board, Princeton municipal staff, Council and the PEC?

From the Consent order: "The Planning Board shall not require AvalonBay to submit additional testimony or documentary submissions regarding issues not affected by the revised design, that is, environmental contamination, existing traffic counts and availability of utilities."

6. Should the municipality conduct a soil test in the street close to the junction where the sewer lines connects to the sewer main?

7. Is Avalon's contractor planning to put only one dust monitor and one asbestos monitor on the entire five+ acre site during demolition?

8. Is Avalon's contractor going to test the crushed masonry for hazardous substances, especially asbestos, before they use it to backfill the former hospitals' basements? Avalon Princeton will be built on a slab.

9. Do the Princeton municipal employees who will be on site during demolition have a right to know about hazardous substances?  What is the written opinion professed by the Joint Insurance Fund?

Thank you for your time and consideration.