Home page > Environmental Justice > David vs. Goliath: PFAS vs. TLA

Sometimes David Beats Goliath

We delayed the TLA Trash Transfer Station. Here's how we did it, and what comes next:
• Holbrook Conservation Commission meeting notes from July 17
• Holbrook Conservation Commission meeting video from July 17 (starts at 14:45)
• PFAS data: state-tested sites through 2023
• Proposed Joint Order: plan for PFAS testing by Randolph, Holbrook, and Braintree
  Additional documents online...
• Joint PFAS Resolution
• TLA-Holbrook Solid Waste Transfer Station (Mass.gov website)
• Baird-McGuire Superfund site (EPA website)
• Joint PFAS Resolution by Holbrook and Randolph 2022
• Video showing TLA site outflow to Randolph-Holbrook Commuter rail (with Randolph Town Councilor Natacha Clerger)
• Video explaining water flow to Randolph-Holbrook WTP (with Holbrook Select Board Associate William Watkins)
• SUPERFUND SITES IDENTIFIED BY EPA TO HAVE PFAS CONTAMINATION (The Baird-McGuire Superfund site is #50 on the map)
• EPA BAIRD AND MCGUIRE SUPERFUND SITE (federal EPA report)
• 2022 Drinking Water Report: noting that our new WTP will remove PFAS as of January 2025
• Community Update Regarding PFAS in Drinking Water in Holbrook December 2021 report including "State Funding for PFAS Remediation"
• State funds clean drinking water efforts: Randolph/Holbrook grant for $43,560 to make filtered water available for residents

Holbrook Conservation Commission meeting notes from July 17

Randolph has been David throwing stones at the TLA Goliath for many years now. This week, one of those stones hit the mark, and the Holbrook Conservation Commission denied an extension to the construction permit for the TLA-Holbrook Solid Waste Transfer Station. That means, at least until this issue is resolved, that the trash transfer station right on the Randolph-Holbrook border will not move forward.

The stone that hit Goliath was PFAS. In particular, the public discussion focused on how TLA had not adequately addressed PFAS testing upstream and downstream from the construction site. That site is adjacent to the Randolph-Holbrook train station, where Sylvan Lake drains into Glover Brook which then leads to our Tri-Town Reservoir. That site is also downstream from the Baird-McGuire Superfund site ("Superfund site" means "federally declared as a toxic waste cleanup site"). In the discussion at the Holbrook Conservation Commission on July 17, both the Superfund site and the trash transfer station itself were acknowledged as potential sources of PFAS in our reservoir.

The PFAS stone grew from a small pebble in February 2022, when the Randolph Town Council passed a "Joint PFAS Resolution" with the Holbrook Select Board calling for PFAS testing. We explicitly called for testing of the TLA site and the Superfund site--but they're in Holbrook--in Randolph we did test since then Glovers Brook, which is in Randolph downstream from the TLA site. At the Holbrook Conservation Commission, the TLA people were asked if they had done any PFAS testing, and they replied "No." The Con Comm then considered a 1-year extension to allow PFAS testing, but decided in a 3-4 vote to deny even a 1-year extension, so that the PFAS testing would be required during 2023.

In other words, our stone that hit Goliath was because TLA ignored our Joint Resolution to conduct PFAS testing. I didn't expect that to be a useful "stone" when I wrote the Joint Resolution (with Randolph Town Councilor Natacha Clerger and Holbrook Select Board Associate William Watkins -- click for two explanatory videos) but that's the "stone" they cared about. This opens a new front in the battle against TLA--we can pursue further the "PFAS restrictions" where previously we had focused on traffic issues, road issues, and other environmental issues.

We can pursue further PFAS restrictions by ordering PFAS testing. Our 2022 Joint Resolution only recommended PFAS testing--and the Holbrook Con Comm's rejection only recommended that TLA gather PFAS data before reapplying. We could push further to make PFAS testing an ongoing requirement, instead of a one-time recommendation. MassDEP, the state environmental agency, agreed last year to test 7 sites in Randolph--and they do so, once a year, with a 6-month lag time to send us the results. I went out and bought a commercial PFAS test, which I dipped in a Braintree vernal pond on West Street near the reservoir--that costs $75 and gets results in a couple of weeks. I think it's time to "do it ourselves" since the MassDEP is unwilling to do it in a timely manner. Those PFAS testing results could actually inform what we do next--including heavy restrictions on TLA.

Let me outline the other topics that came up at the Holbrook Com Comm meeting. All of these played a role in persuading the Con Comm members to vote 3-4 against extending the construction permit.

1. PFAS Seepage: I testified about "leached PFAS" which means that PFAS leaches into our reservoir even if the water source isn't "hydrologically connected." Some naysayers point out that Glovers Brook is no longer "hydrologically connected" to our reservoir--which means that the brook's water flow doesn't go directly into our reservoir. That's true, but irrelevant. It's true that Glovers Brook (and hence Sylvan Lake and the Superfund site) is blocked from its former direct feed into the Richardi Reservoir--instead, it feeds the "water hazards" on the Braintree golf course adjacent to the Richardi Reservoir (which is our "backup reservoir" on the Braintree/Randolph border). But that's irrelevant, because PFAS seeps underground even when the water flow isn't directly connected. PFAS are called "forever chemicals" because they sit in the sediment indefinitely, and slowly seep through if nearby. That sort of seepage occurs into the Richardi Reservoir from the golf course, as well as seepage from Braintree's trash-filled vernal pools on West Street into our main Great Pond reservoir. We need to test all of those!

2. External Burdens: I also raised a concept called "externalities", which means that Holbrook might pay for the damage done to Randolph and Braintree (the two towns through which the trash transfer trucks will run). Basically, under the TLA plan, Holbrook gets all the benefit (free trash pickup forever, plus property taxes), but Randolph and Braintree bear a lot of the burden. There are three aspects Holbrook might pay for: (a) PFAS testing and remediation; (b) extra road repairs for damages from 1,000 tons of trash per day passing on our roads; (c) extra cleanup for trash dropped from the trucks en route to TLA-Holbrook; and (d) pollution insurance for spillage/damage downstream from TLA (which is all in Randolph!). This isn't the first time anyone has raised the possibility of Holbrook paying for the external costs of TLA, but we should keep this concept alive for the future.

3. 20 ppt standard: Several people brough up "PFAS rule changes"--the state and federal standards have changed since the TLA project began, but there have not been any changes in the TLA plan. I checked afterwards about what has been tested for PFAS--here are the relevant reports:

   • Yes, there's PFAS: "SUPERFUND SITES IDENTIFIED BY EPA TO HAVE PFAS CONTAMINATION" -- the Baird-McGuire Superfund site is #50 on the map -- does have PFAS contamination in the view of the U.S. Senate Committee on Environment and Public Works (March 2019 report).

   • No, there's not significant PFAS: EPA BAIRD AND MCGUIRE SUPERFUND SITE -- a 2018 report saying PFAS is below 41 ppt and hence not a significant risk -- backup downloaded without missing appendix C-2 (our actual PFAS data is mysteriously omitted!)

   • Changing standards for PFAS: The standard for PFAS as of 2022-2023 is 20 ppt (parts per trillion). The reports above pre-dated that standard. The new 2024 proposed standard is 4 ppt. Our Tri-Town reservoir is usually below 20 ppt, but has never been recorded below 4 ppt.

4. More rain overflows: Several people raised the issue of "100-year floods" washing PFAS into our reservoir. In other words, even if Glovers Brook normally is shunted into holding ponds at the golf course that might only slowly seep into the reservoir, in a large-scale rain event, those ponds would flow into the reservoir in large quantities. This summer's frequent 100-year floods indicate that climate conditions are changing enough that we can expect regular large-scale rain events and hence a lot more PFAS flow. In other words, "100-year floods" will occur every 100 months from now on, and we should expect large-scale overflows as part of our planning.

5. Pollution Insurance: What if there's a catastrophic pollution event across the Holbrook-Randolph border? Like, a toxic waste leak from the Baird-McGuire Superfund site that leaks due to TLA construction? Is that covered by TLA insurance? Ms. Sandi Cohen of Randolph asked this question, and the answer was "No, TLA insurance only covers within Holbrook." That means If there's a catastrophic pollution leak, it would be a classic case of "environmental injustice" -- where the damage would flow downstream to Randolph, and as soon as it crossed our border, 1/8 mile from the leak point in Holbrook, there would be no insurance coverage for clean up. One might even think that's a REASON why sites like this are always built near borders -- so the problems all flow across the border (take a look at every dump or waste site you can think of - they're very often right on the border! Like our old Randolph town dump -- it's right on the border of Stoughton, on the west side of Rt 24. Or the Braintree-Weymouth gas compressor station, which is under construction under protest too, right on the Quincy border). Let's say during TLA construction that an old dioxin barrel stored underground is ruptured (dioxin is very toxic and was used to manufacture pesticides of the type made at Baird-McGuire) -- yes, TLA insurance would cover clean-up in Holbrook. But the dioxin would flow from Sylvan Lake right into Randolph for several miles downstream -- adjacent to hundreds of homes -- and Randolph would have to pay for that cleanup because it's not covered by TLA insurance -- that's environmental injustice!

PFAS data: state-tested sites through 2023

(Click to enlarge map; right-click to download)

Our Joint PFAS Resolution in 2022 asked for the MassDEP to test for PFAS -- which they did. But MassDEP is only willing to test a few sites, maybe once a year. They DID find some elevated PFAS levels at the TLA site and downstream -- which is useful, and is listed below. But our real purpose for PFAS testing isn't just to do a test -- the real purpose is to zero in on "PFAS hotspots" so we can remove the contaminated soil and actually address the problem. To do that, we need PFAS testing near any site that is found with elevated PFAS -- in other words, MORE spots upstream and downstream -- to find exactly where the PFAS source is.

This isn't a process that I'm making up -- it's the standard way that toxic hotpots have been found in water supplies for decades. There's even a movie about it -- A Civil Action, a true story about a contaminated water supply in Woburn Massachusetts (starring John Travolta). In Woburn, they plotted toxin test sites on a map, and by looking at the pattern geographically, they found the "hotpots", which were barrels of toxins dumped in the woods. We should try to replicate that process -- by plotting elevated PFAS on a map, then testing again at nearby spots, then plotting those on a map until we see a pattern and identify a hotspot.

Here's the map we have so far -- it's pretty thin! but it gives us a hint of where to test next. The "red spots" are where high PFAS was found (over 20 ppt). The green spots are where PFAS was tested, but not found. The data points are labeled from the table below.

Here is the data that went into that map, from MassDEP ("ng/l" means "nanograms per liter" which is the same as "ppt" which means "parts per trillion"). The letter labels here are shown on the map. The red X-rings indicate a spot with "over 20 ppt". The letter-number labels on the map are proposed "next testing sites" upstream and downstream from each red X-ring. The goal is to find a "smoking gun" -- a PFAS hotspot -- where water testing and/or soil testing show PFAS levels above 100 ppt. If we can identify a "hotspot", we can dredge the soil and phsyically remove the PFAS source. Or maybe we'll find some half-buried barrels, like John Travolta's character did in Woburn. It's not very expensive to conduct PFAS testing -- I propose that below -- and if we find a hotspot and clean it up, we will SOLVE our PFAS problem. Currently, we're just REMEDIATING by cleaning out PFAS that makes it into our reservoir. The next step is to REMOVE the source of PFAS before it gets into our reservoir!

Sources:
• Braintree PFAS testing report dated Feb. 4, 2022 - PFAS results begin on pg. 5/21
• Baird-McGuire Superfund report dated April 7, 2021 - PFAS described on pg.10/207; PFAS data table on pg. 187/207.
• MassDEP PFAS analytical report dated 1/18/22 - PFAS glossary on pg. 60/119
• PFAS test map with PFAS > 20 in red - extracted from page 68/119 of MassDEP report

Proposed Joint Order for Randolph, Holbrook, and Braintree

PFAS tests conducted 2018-2022

(with labels indicated on map; red > 20 ppt and green < 20 ppt):
• A-J) Ten PFAS testing sites around the Baird-McGuire Superfund site were tested from 2018 to 2019, and seven sites scored PFAS over 20 ppt. That means there's likely a hotspot somewhere in that area -- I propose several testing sites (A1/A2/A3) downstream from the Superfund site, and others (J1/J2) at the TLA site to try to find a hotspot. All of these proposed testing sites are in Holbrook, not Randolph.

• K/L) I proposed some PFAS testing in Braintree but not at the spots that MassDEP tested. They did find elevated PFAS at point L -- 26 ppt -- the Farm River at Granite Street -- and the right follow-up is to test closer to the reservoir (points L1/L2/L3/L4 below). Those points are listed above in two sections -- "Vernal ponds" and "King Hill Road". Point K -- Cranberry Brook at Washington Street -- is upstream from Glovers Brook and hence unaffected by TLA -- it's at 17 ppt so no further testing is warranted for now.

• M/N/O) I proposed points M/N/O in the first round of testing -- those are along the Blue Hills River as it crosses I-93. I thought perhaps a car fire in the 1980s or 1990s on the Interstate would have left a PFAS hotspot. MassDEP's data indicates that just didn't happen -- PFAS around 4 ppt -- so we don't need to test there anymore.

• P) High Street adjacent to the Blue Hills Reservation was tested at PFAS = 10 ppt. This could have been a seepage hotspot from the Blur Hills River, but it's not high PFAS, so we don't need to test there anymore.

• Q/S/T) Norroway Brook was tested at three points -- first at West Street (point T, at the Dog Park trail) with PFAS = 25 ppt. It was also tested at point S (Norroway Pond north of Grove Street with PFAS = 11 ppt, which means the long wetland area might be filtering out some PFAS. At point Q (Norroway Brook at Oak Street) testing found PFAS = 21 ppt. This indicates a PFAS source independent of TLA -- upstream from point T (which is near Stoughton, not Holbrook). We should investigate upstream with further PFAS testing -- I suggest several testing points south of point T on Warren Street and Bear Swamp (T1/T2/T3). And downstream too (T4) to investigate point Q.

• R/V) Stetson Brook runs from the Lyons School directly into the reservoir at Oak Street -- it was tested and found PFAS = 8 ppt. Same for point V at Oak Street and North Street -- PFAS = 7 ptt. These are independent of TLA and independent of Norroway Brook -- no further testing needed at those sites. U) Glovers Brook at the Ice Arena on North Street got tested at PFAS = 32 ppt, the worst score of all our tests. Glovers Brook is directly downstream from TLA and this warrants substantial further testing along Glovers Brook to try to identify the hotspot(s). Those are labeled U1/U2/U3/U4 for some proposed testing spots -- these are further downstream from the TLA site, and all in Randolph.

PFAS tests proposed for next round

(with pink labels indicated on map)
• L1/L2/L3) Along abandoned King Hill Road in Braintree
• L4) There are vernal ponds along Pond Street up to the Braintree border which continue to West Street across the Braintree border -- these are downstream from the Blue Hills River tested as ponits M/N/O.
• T1/T2) Bear Swamp now is town property in the Jablonski tract off Warren Street. There's an open water pond near a culvert just off Warren Street -- let's test there and another point fuirther upstream.
• T3) There's also open water between Warren Street and West Street where the culvert crosses over onto the northern Jablonski property -- let's test there too, to see where the PFAS at point T originates.
• T4) There could be another PFAS source between Powers Farm and point Q downstream (which tested at PFAS = 21 ppt) to the north -- so let's test in between those.
• U1/U2) Points further downstream on Glovers Brook, to track PFAS downstream from TLA.
• U3/U4) On the Randolph side of the Richardi Reservoir, as near the Braintree Golf Course as possible

Proposed Council Order for Randolph

• WHEREAS the Town of Randolph has conducted PFAS testing through MassDEP at 10 locations throughout Randolph during 2021-2022; and

• WHEREAS MassDEP found PFAS levels in excess of 20 ppt at 3 of those locations, as well as 7 locations in Holbrook and 1 location in Braintree, all upstream from Tri-Town Reservoir; and

• WHEREAS the people of Randolph desire to identify the sources of PFAS that have often resulted in our reservoir PFAS levels exceeding the state limit of 20 ppt; and

• WHEREAS our waterways often cross municipal boundaries resulting in PFAS entering from outside of Randolph;

• NOW THEREFORE BE IT RESOLVED that the Randolph Town Council authorizes additional PFAS testing to be conducted; and

• BE IT FURTHER RESOLVED that the PFAS testing locations shall be upstream and downstream from the three previous PFAS testing sites which exceeded 20 ppt; and

• BE IT FURTHER RESOLVED that the PFAS testing shall be conducted by the Town of Randolph DPW, or its designee, and paid for by the Town of Randolph; and

• BE IT FURTHER RESOLVED that additional PFAS testing shall be included in future Conservation Commission permits, including across municipal borders such as TLA funding additional PFAS testing downstream in Randolph; and

• BE IT FURTHER RESOLVED that the Town of Randolph shall encourage the Towns of Holbrook and Braintree to conduct similar PFAS testing including cross-border funding.