4.5.2021 Memo Re: Status of PFAS in Wayland Public Water Supply

PFAS in drinking water has become an emerging issue nationwide. PFAS is not an issue specific to Wayland or even Massachusetts. PFAS are widely used chemicals in a variety of industrial processes since the 1940’s including the production of carpets, clothing, fabrics for furniture, paper packaging for food and many other common household materials. While consumer products and food are the largest source of exposure to these chemicals for most people, drinking water can be an additional source of exposure. In 2009, the United States Environmental Agency (EPA) issued a provisional health advisory for PFAS of 70 parts per trillion (ppt), which EPA confirmed and established in 2016. According to EPA, health advisories are informational, non-enforceable, and non-regulatory. Health advisories are designed to provide technical information to state agencies and other public health officials. EPA states that its PFAS health advisory is “to provide Americans, including the most sensitive populations, with a margin of protection from a lifetime of exposure.” On October 2, 2020, MassDEP issued a new public drinking water standard in Massachusetts of 20 ppt for six specific PFAS compounds, which Mass DEP abbreviates as PFAS6. PFAS6 had not been previously regulated or required to be reported in the Commonwealth. The new regulation is effective April 1, 2021 for the Town of Wayland.

 

The Town has been proactive in testing for PFAS since January 2020 and has actively monitored the PFAS levels in each of the Town’s four (4) water well fields. Wayland continued its testing program in advance of MassDEP’s effective date for required testing. On February 4, 2021 the Town received the January 2021 testing report, which reflected a PFAS reading in excess of the MassDEP maximum contaminant level (MCL) of 20 ppt at the Happy Hollow well field. Upon receipt of the elevated readings, the Town notified MassDEP to obtain further instructions. Following MassDEP protocol, the Town performed confirmatory testing in late February, results of which were received in March 2021, and which also exceeded the MCL of 20 ppt at the Happy Hollow well field. Results for tests taken in mid-March were received late in the day on Thursday April 1, and once again exceeded the MCL. Once confirmed, the latest test results will cause the Town to be in violation of the MassDEP MCL for PFAS6.

 

A Town working group was formed comprised of DPW Director Thomas Holder, Water Superintendent Don Millette, Assistant Town Administrator John Bugbee, and an engineer with the Town’s retained firm of Tata & Howard to communicate and work with MassDEP. Under MassDEP guidance, the working group created a public education document for distribution to all Wayland residents. A larger PFAS working group was formed comprised of DPW Director Thomas Holder, Water Superintendent Don Millette, Assistant Town Administrator John Bugbee, Health Director Julia Junghanns, Information Technology Director Michael McCann, and Town Administrator Louise Miller. Various members of the working group worked with the Chair of the Board of Public Works and consulted with the Chair of the Board of Selectmen and Chair of the Board of Health to create a press release in advance of mailing the PFAS6 public education document approved by MassDEP. Others worked on a letter to residents with permitted private wells. Both the public education document and the letter to private well owners were mailed late last week. Anticipating that the Town will continue exceeding the PFAS6 MCL, the working group coordinated the purchase and distribution of water to residents, with distribution beginning the week of April 5. The Town’s CERT (Community Emergency Response Team) and MRC (Medical Reserve Corps) teams were contacted to provide volunteers for the distribution effort. Meetings were held with the School Superintendent resulting in bottled water distribution to the Town’s schools beginning April 1. Private schools, daycare facilities, and other childcare facilities, as well as nursing homes and assisted living facilities were contacted and provided with the public education document. The Town also created a PFAS dedicated web page with PFAS-related information for residents and businesses. Town staff in the Department of Public Works, Health Department, and Town Administrator’s Office were provided with information to respond to residents’ and businesses’ questions.

 

It is important to note that MassDEP states that “consuming water with PFAS6 above the drinking water standard does not mean that adverse effects will occur. The degree of risk depends on the level of the chemicals and the duration of exposure. The drinking water standard assumes that individuals drink only contaminated water, which typically overestimates exposure, and that they are also exposed to PFAS6 from sources beyond drinking water, such as food. To enhance safety, several uncertainty factors are additionally applied to account for differences between test animals and humans, and to account for differences between people. Scientists are still working to study and better understand the health risks posed by exposures to PFAS.” MassDEP advises that if PFAS6 levels are over the MCL, sensitive consumers (pregnant women, nursing mothers, infants, and people with a compromised immune system) should consider using bottled water that has been tested for PFAS for drinking, for making infant formula, and for cooking foods that absorb water (such as rice). Alternatively, consumers could use a home water treatment system that is certified to remove PFAS by an independent testing group such as National Sanitation Foundation (NSF), Underwriters Laboratories (UL), Water Quality Association or the CSA Group.

 

The MassDEP working group met with MassDEP on Friday to discuss the Town’s next steps and both shortterm and long-term options for removal of PFAS6 from the Town’s drinking water.

 

Over the next 30 days, the Town will receive a Notice of Non-Compliance from the MassDEP. Wayland will then be required to provide an alternative drinking water source for residents in the sensitive populations by the end of April. The Town has already set up a plan for distribution of bottled water. The Town will also be required to send a second public education document to all residents. Short-term Next Steps: Over the Next 90 Days MassDEP will issue an Administrative Consent Order with a plan for removal of PFAS6 from the Town’s drinking water. This may be source removal, filtration, or alternative water source, including emergency connection to MWRA. The Town should also simultaneously evaluate its options with respect to its public water supply, including permanently connecting to MWRA. The Town is working with the engineering firm of Kleinfelder on evaluating a permanent MWRA connection.

 

The Town will implement a long-term solution for its public drinking water supply once engineering studies have been completed and reported to the Board of Public Works for decision.

 

Town Counsel has advised that there is a mechanism to address the potential need for funding from the Water Enterprise Fund Retained Earnings on an emergency basis, without a vote of Town Meeting. The Town faces both an unknown order of magnitude of funding need and the potential crossover between 2 fiscal years. Finance Director Brian Keveny will contact the Massachusetts Department of Revenue (DOR) to begin any required notification. In addition, Public Works Director Thomas Holder is investigating 0% State Revolving Fund loans for public water systems and grants that may be available to offset costs.

 

Multiple working groups have already been created to respond to the issues presented by elevated PFAS6 levels in the Town’s drinking water supply. We are also working on identifying potential local sources of PFAS6. We are reviewing data from the monitoring wells at the High School and hydrogeology that was completed by Weston & Sampson during the design of the High School athletic fields complex. The Town’s short and long-term responses will involve potential requests for actions and decisions from 3 boards: the Board of Public Works, the Board of Selectmen, and the Board of Health. I am, therefore, requesting that the Board of Public Works provide the name of 2 members and the Board of Selectmen and Board of Health each provide the name of 1 member to be included in the larger working group. Each of the boards are subject to Open Meeting Law, which means that discussions cannot occur outside of board meetings and meetings must be posted at least 2 business days prior to taking place. The members of the boards who become part of the working group will participate in discussions with staff and must be mindful that further discussions with other members of their boards outside of public meetings may result in a violation of Open Meeting Law.

 

EPA’s health advisory of 70 ppt for PFAS in drinking water:

 

EPA’s research page on PFAS:

 

MassDEP PFAS information for consumers:

 

MassDEP information about bottled water and home filtration systems: