PFAS Memo to BoS 05.3.2021

Date: May 3, 2021

Re: PFAS Response Update

MassDEP Notice of Non-Compliance

The Public Works Director has prepared a second public notice document that the Town’s PFAS6 readings are in excess of the MassDEP maximum contaminant level (MCL) of 20 ppt. The draft was submitted to MassDEP for approval. The Public Notice Document, which follows the MassDEP template, is anticipated to be mailed to all residents on Tuesday May 4, 2021.

MassDep requires that the Town prepare both a short-term and a long-term plan for PFAS6 compliance. A four-board meeting of the Board of Selectmen, Board of Public Works, Board of Health and Finance Committee will take place on May 3, 2021 to review the short-term and long-term plans. A flowchart of decisions that need to be made to prepare the Town’s short- and long-term responses is attached. Each decision triggers a certain course of action, which then requires further decisions.

Threshold Decision Regarding Goals for PFAS6 Level

A threshold determination needs to be made regarding the Town’s goal for PFAS6 levels in the drinking water supply. The Town’s goals could either be to bring PFAS6 level to 0 ppt or to bring PFAS6 levels below 20 ppt, but still allow for PFAS6 to be present in the water supply. The goal for PFAS6 levels has very different consequences for both the short-term and the long-term plans. The Board of Health will provide an opinion on the Town’s goal for PFAS6 levels both in the short-term and the long-term. It should be noted that implementation of solutions that result in PFAS6 levels testing below 20 ppt would allow the Town to come into compliance with MassDEP regulations. MassDEP does not require that the Town achieve PFAS6 levels of 0 ppt.

Short-term Plan

Rebate Program

MassDEP requires that the Town provide an alternative source of drinking water for sensitive populations (pregnant women, nursing mothers, infants, and people with a compromised immune system) and advises that the sensitive populations 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). The Town has been distributing bottled water since early April to meet this requirement. On April 27, 2021, the Board of Public Works approved a rebate program. Next steps will be to put together the rebate program, draft an application form and disseminate information regarding the rebate. It is anticipated that the rebate program will be available beginning mid to late May. Certain customers (including day cares, public schools, nursing homes, assisted care facilities) will still be provided the option of having water delivered directly. The form of the rebate is also being evaluated internally to determine whether a credit on water bills or a rebate check is more resource efficient.

Near-term and Short-term Compliance Plan

The Town’s consultant for the short-term plan, Tata and Howard, has prepared a draft report outlining the near-term and short-term compliance plan to achieve PFAS levels below the regulated level. The draft report is attached and will be reviewed at the four-board meeting on May 3, 2021. The Board of Public Works will be further discussing and selecting options for the short-term at its meeting of May 10, 2021.

The report presents two short-term options: treatment, which would reduce PFAS6 levels to below 20 ppt, and an emergency MWRA connection, which would reduce PFAS6 levels to 0 ppt. While cost estimates are preliminary, there are significant cost differences between the options.

With respect to the short-term options, Tata and Howard presents two short-term treatment options, ion exchange and carbon, both of which are viable thanks to Wayland’s raw water quality. The treatment options, however, present different operations and real estate requirements. Tata and Howard recommends an ion exchange treatment system because it requires less maintenance and less land. The Town of Hudson had installed ion exchange and experience difficulties due to high levels of dissolved iron and manganese. Wayland does not have the same issues and so is not expected to face the same issues. The ion exchange filters will also not require changing for extended periods of time, which is another benefit. The main concern with a ion exchange treatment option is surface piping and potential freeze ups during winter. Tata and Howard provides a solution and cost estimate for winterization. The carbon option would require 4 times the land that the ion exchange treatment requires. Because the carbon system requires backwashing, it would necessitate a tie-in to the Water Department’s SCADA system and may require increased staffing. Whichever treatment option is selected by the Board of Public Works would need to be bid, procured, and a contract awarded. A treatment solution could be in place by the end of June with winterization completed in the fall.

Two potential downsides of treatment are the loss of one well at Happy Hollow to accommodate treatment requiring that output be increased from the Town’s other well location, and that the possibility that the Chamberlain well could exceed PFAS6 regulated levels, requiring that a similar treatment system be installed. These risks need to be evaluated in selecting a preferred short-term option.

The MWRA emergency connection requires that the connection be designed, including a pump station. The MWRA has offered its property and has offered to bid, procure, and award the contract. An MWRA emergency connection could be completed by November. Should the MWRA emergency connection be

selected as the short-term solution, the Town will require a near-term solution to providing an alternate source of drinking water to sensitive populations. The near-term solution could be a continuation of the rebate program or could be a near-term water treatment solution at the Happy Hollow wellfield, as determined by the Board of Public Works.

The Public Works Director will continue to work with Tata and Howard to edit the draft report and prepare, by May 10, 2021, the written short-term plan of how and when the Town will come into compliance with MassDEP PFAS6 regulations. No decision on a preferred option is required by May 10. The Board of Public Works has scheduled a meeting for May 10, where answers to questions raised on May 3 will be provided.

Long-term Response Requirements

There is no update this week. Please see previous memo for status. 

Potential Sources of PFAS6

Weston and Sampson continues to work with town staff on evaluating the location of additional monitoring wells. At this time, given the level of PFAS detected, it does not appear that there will be a single source identified.

In response to questions raised about whether the old turf field removed from the High School athletic complex approximately one year ago could be the source of the PFAS6, Weston and Sampson stated that it would expect the levels to be higher than what the Town has found at the Happy Hollow wellfield.

Nevertheless, that old turf field will be investigated with other potential sources in the coming weeks.

Financing

Tata and Howard provides preliminary cost estimates in its report. The cost of providing bottled water, water rebates, and short-term treatment can be absorbed within the FY2021 Water Enterprise Fund budget. The cost of winterization for the treatment option and the cost of an MWRA connection will require that the FY2022 Water Enterprise capital budget be modified. The cost of purchasing MWRA water will require that the FY2022 Water Enterprise fund operating budget be modified. The financing options are being further refined and will be discussed on May 3, 2021.

Town of Natick – Potential MWRA Partner

Among other communities, the Town of Natick is experiencing elevated PFAS6 levels in their drinking water supply wells. MassDEP has invited Natick to join in conversations with Wayland regarding the potential connection to MWRA both in the short and long-term. Natick does not have direct access to the MWRA. Should the Board of Public Works choose the MWRA emergency connection as a solution, then Natick would be expected to share the emergency connection cost with Wayland, increasing the cost because a larger pump station would be needed but decreasing the cost thanks to cost sharing. The Board of Selectmen would need to enter into an inter-municipal agreement with the Town of Natick to provide MWRA water to Natick through Wayland.