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Randolph Water Analysis: PFAS 2022

Feb. 22, 2022: The Tri-Town Water Board allowed for a tour of our two water treatment plants (permission granted to Councilor Gordon and Select Board Member Watkins, but not to members of the public, and with the agreement of "no pictures"). Here are our notes from that "tour", so the public sees the full story, and can make informed decisions.

Resolution on PFAS filters

Based on the water plant tour, Councilors Gordon and Clerger will introduce a Resolution on PFAS filters at the March 14 Town Council meeting. Please come and comment -- we recommend investigating how the water plant can implement a partial PFAS filter right now, and propose a solution for the next couple of years (replace the top half of the filter material to minimize risk of old pipes and drains). Click to download Resolution in MS-Word

Resolution on PFAS testing

Since the Water Forum last summer, we've been pushing to get some PFAS testing -- and the Town Manager did get 7 test sites set up with the state DEP. At the water plant tour, we heard that Braintree is conducting its own PFAS testing. Councilors Gordon and Clerger will introduce a Resolution on PFAS testing to supplement the state testing with sites that were missed -- we propose three new sites (see image at upper right) and propose that additional sites be determined later. Click to download Resolution in MS-Word

1) How can we add PFAS filters?

Coming out of the Randolph & Holbrook water forums, the conclusion seemed to be that adding PFAS filters would (a) require a new building and (b) cost over a million dollars for (c) only a two-year interim period. Based on the water plant tour, we think all three of those conclusions are incomplete.

The complete story is that while the Randolph/Holbrook water plant can't do exactly what was done in Braintree, we CAN add PFAS filters that will reduce our PFAS content substantially -- ensuring that we stay below the 20 ppt state-designated health level.

The Braintree water plant replaced their existing filter material, which didn't filter out PFAS, with Granulated Activated Carbon ("GAC"), which does filter out PFAS. They replaced all filter material in all five of their filter tanks, which reduced their PFAS level from 21 ppt to near 0 ppt. The GAC filters are several feet deep; the water comes in at the top, filters through the GAC material, and drains out at the bottom, with some PFAS adsorbed onto the GAC in between. Over time, as the GAC adsorbed more PFAS, Braintree's output PFAS level has crept back up, and is now around 10 ppt. So Braintree is "recharging" the material in two of their five tanks (replacing the GAC with cleaned and recycled GAC) -- this project is currently out to public bid.

The issue in the Randolph/Holbrook water plant is that our tanks are older and more fragile, so replacing the filter material runs the risk of damaging the tanks and piping. In particular, the drains at the bottom of the tank are at most risk, so we should avoid exposing the bottom -- it's less risky to only replace the top half of the filter material.

In the water forums, the assumption was "all-or-nothing" replacement -- and it's true that we can't do it all, like Braintree did, without a new building to house new tanks. But we CAN replace the top half of the filter material with GAC, and expect half the result that Braintree got. That would mean our PFAS level is reduced from around 20 ppt to around 10 ppt, and that reduction might last a year or two below the 20 ppt health cutoff level.

Braintree appropriated about $680,000 for replacing all five filters with GAC, which included removing the old filter material and purchasing the new GAC material. That total did not include the "recharge" taking place now -- that's expected to cost somewhere around $50,000 per tank. Randolph/Holbrook has 8 somewhat smaller tanks with about the same total filter material; it should be roughly half the cost to remove and replace half the existing filter material. That means roughly $340,000 to get started, split between the two towns. If the new water plant construction takes longer than the expected two years, we might want to invest another $100,000 for GAC recharge in 2024. All of the costs are eligible for ARPA funding -- in other words, there is no property tax increase nor water rate increase for this expense.

2) Who decides on adding PFAS filters?

Our real decision here is whether it's worth $340,000 to cut our PFAS levels in half until the new water treatment plant comes on line. That figure is just an estimate, and an accurate engineering cost might be calculated -- but it's not over a million dollars, as we previously understood.

Our decision also includes the risk that the existing tanks could suffer damage during the GAC filter process. The worst-case scenario is that one of the eight tanks is shut down entirely for several weeks. The tanks are somewhat independent, so if each tank is half-filled with GAC separately, the risk would only be one tank failing. And the risk is reduced by only replacing the top half of the filter material.

The people of Randolph and Holbrook should make this decision, based on the complete story of the costs, benefits, and risks. There are four government entities -- representing the people and therefore listening to the people -- to implement installing partial PFAS filters in the Randolph/Holbrook water plant:

  • i) The Tri-Town Water Board is evidently not involved in this decision -- they are responsible only to the water's edge for the existing water treatment plants. While they WILL be responsible for decisions on PFAS filters in the new water treatment plant, it's up to the other three government entities for the old Randolph/Holbrook water treatment plant.
  • ii) The Joint Water Board: This board includes only Randolph and Holbrook, not Braintree. This board is responsible for decisions at the old Randolph/Holbrook water treatment plant, including whether to add PFAS filters or not. They are answerable to the two Town Councils...
  • iii) Holbrook Select Board: Selectman Watkins will introduce a Resolution to obtain engineering cost estimates for replacing half the filter material with GAC, and then implement the replacement one filter at a time, if the cost is reasonable. The people will have an opportunity to be heard at the hearing on this order, and its content can be amended at that time.
  • iv) Randolph Town Council: Councilors Gordon and Clerger will co-introduce the same Resolution in Randolph, with another opportunity for public input and amendment. The Randolph Town Manager and the Randolph Department of Public Works are directly responsible for implementation -- all of the staff at the Randolph/Holbrook water treatment plant work for the Randolph DPW.

3) How can we get additional PFAS testing?

Everything above is about reducing our PFAS levels after PFAS has already gotten into our reservoir. We can also look to reduce the amount of PFAS entering our reservoir in the first place. It's possible to test each input source -- the small streams that feed into the reservoir -- and identify which stream has high PFAS levels. We could then try to identify how that stream gets contaminated, or implement some sort of system to reduce the PFAS input from that stream.

At the urging of the Town of Randolph, the Massachusetts DEP (Department of Environmental Protection) recently began PFAS testing at 7 source points in Randolph around our reservoir. Those test results take several weeks to get back from the state lab, and the state may repeat the process periodically. That might find some high PFAS levels in source streams.

The Town of Braintree is performing additional testing on their own, in points around Braintree. That includes the Farm River, which feeds the reservoir from the northeast. We think all three towns should share PFAS testing results -- Selectman Watkins and Councilor Gordon will follow up to ensure that the test results are shared by all three towns. In addition, we would like to propose that the Randolph and Holbrook perform additional testing on our own at the following testing sites:

  • a) Holbrook TLA Transfer Station: There's a small stream that flows north from the Holbrook/Randolph Commuter Rail Station that feeds our reservoir. The TLA Transfer Station itself is a possible source of PFAS since it is a "brownfield" contaminated site.
  • b) Holbrook Tumbling Brook: This stream runs from Holbrook into the South Street Conservation Area and then joins Randolph's Glovers Brook. The DEP test sites do include Glovers Brook, but testing further upstream would better identify PFAS sources.
  • c) Randolph Blue Hill River south of I-93: The DEP test sites include the Blue Hill River in the State Park near the Deer Park neighborhood in North Randolph. But the river then crosses I-93 north and back south before entering the reservoir. I-93 itself is a possible source of PFAS contamination from automotive and road runoff. That would not show up in DEP testing in Deer Park, but would show up if we set up another test site further downstream. That could be on the Randolph/Braintree border behind Pacella Park Drive.
  • d) Randolph on west side of Dike: A walkable dike separates the north half from the south half of our reservoir. The neighborhood to the west of that dike includes Pond Street and Webster Street, which have no DEP testing sites, but drain directly into the reservoir through a small stream near the dike. DEP testing includes Norroway Pond south of this neighborhood, and the Blue Hill River north, but not this neighborhood itself.
  • e) Randolph side of Richardi Reservoir: We have a second reservoir, also spanning the Randolph-Braintree border, that is fed by the Cochato River through the South Street Conservation Area. It's not tested by DEP (but the Richardi Reservoir itself is on the Braintree testing list). This area is accessible from the dead end of Meadow Lane and other streets that run east from North Street in North Randolph.

We came up with this preliminary list of testing sites by looking at maps for stream flows. We would welcome input from the public on additional testing sites in Holbrook and Randolph. After gathering input from residents, Selectman Watkins and Councilors Gordon and Clerger will introduce parallel Resolutions to the Holbrook Select Board and Randolph Town Council to initiate PFAS testing on the sites in their respective towns.

Randolph Water Analysis: PFAS

(notes from 2021)

  • The Randolph-Holbrook-Braintree Tri-Town reservoir exceeded the state PFAS limit of 20 ppt in summer 2021. This webpage is a response to the required letters about PFAS sent out to all residents of Randolph and Holbrook.

  • See Wikipedia background on PFAS -- in summary, high PFAS levels come from synthetic chemicals and cause cancers and other health problems. They are called "forever chemicals" because they accumulate in the body over time.

  • Randolph held a Water Forum over the summer, focusing on PFAS, and Jesse asked about how we can reduce PFAS entering our water supply in the first place -- let's call that pre-remediation. This webpage is also a follow-up to that discussion; but first some details of post-remediation (removing PFAS on the way out of the reservoir)
Post-remediation (PFAS removal after leaving the reserovoir)

  • PFAS can be filtered out of drinking water by "reverse osmosis." A PFAS filter could be installed at the water plant and all our water would be PFAS-filtered. Braintree did exactly that, at a cost of about $300,000. Braintree uses the same water supply as Randolph and Holbrook, but via a separate pipe system. For Randolph and Holbrook to install the same PFAS filter would cost well over $1 million.

  • The new water treatment plant will include a PFAS filter for all three towns. Construction is slated to begin next summer. That means the million dollars would be a temporary fix just for a couple of years until the new plant goes on line.

  • Holbrook will hold their own Water Forum on Dec. 7 to discuss whether to invest in a PFAS filter with Randolph (among other issues).

  • Both Holbrook and Randolph have PFAS-filtered water available for residents for free -- Holbrook's is at Stanney's on Union Street, and Randolph's is at the DPW behind the Ice Rink and the RICC (it opened a few weeks ago, with no ID or anything else required, after Jesse requested that).
Pre-remediation (PFAS avoidance before entering the reserovoir)

  • The Water Forums explained well the general sources of PFAS -- all sorts of chemical coatings and additives -- answering the question "How does PFAS get into water supplies?" But rather than answering the general case, we need answers to the specific question: "How does PFAS get into OUR water supply?"

  • There are specific sources of PFAS -- perhaps some industrial source, or some runoff from roads, or some contaminated site -- and those sources can be identified. Once identified, we can reduce the amount that gets into our reservoir, and if successful, we wouldn't have to worry about PFAS filtering at all.

  • The state DEP (Department of Environmental Protection) is planning to make source studies available. Jesse asked about getting a "ground survey", looking at topological maps for likely source areas, then touring those areas to test for PFAS. Jesse asked repeatedly over the past few months and got no clear response on the state investigation. So instead, Jesse asked an environmental group (Clean Water Action) -- they said it'd be better to await DEP. That will likely take many months, because the DEP needs to plan for the entire state.

  • In the meantime, we can perform some PFAS tests on our own -- at different locations around the Tri-Town reservoir, and at the Richardi Reservoir and other sources too. That would give the DEP a headstart (if we find some evidence), to use once they get their program started.

  • That's where we stand in December 2021. Your input welcome; we'll discuss at Town Council meeting of 12/6/21, and at the Holbrook Forum on 12/7/21.
Committee to Elect Jesse Gordon, 52 West St, Randolph MA 02368

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