The Town’s Licensed Site Professional (LSP), Ben Gould of CMG Environmental explained the history of how LSPs became MassDEP’s solution on how to regulate and ensure cleanup of hazardous waste releases to a “safe” standard under the 1992 Massachusetts Contingency Plan. Organzied under the LSP, the public may participate in the cleanup by means of the Public Involvement Plan (PIP)
Gould detailed his role in the Initial Site Investigation (ISI) and the PIP for the disposal site. MassDEP defines a disposal site as the area where uncontrolled oil and/or hazardous material (OHM) has come to be located, regardless of property boundaries.
His role involves presenting his findings in regard to the site scope and proposed response actions to the public at specified intervals, and both take and then respond to public comments and concerns within specified periods until a Permanent Solution is warranted. The current Public Comment period is now running from April 11 through May 10, 2025.
Gould explained the various contaminants levels, the applicable standards, and reportable concentrations for soils, groundwater and drinking water because the site is in an aquifer two protected zone. He noted of the substances found that deserved the most concern were Per- and polyfluorinated alkyl substances (PFAS). PFAS was found in every ground water monitoring well above the reportable concentration of 20 ppt with the highest level at 172 ppt.
The groundwater is flowing downgradient in a south-west direction. Along with 195 Main Street, the disposal site for PFAS contamination may well extend easterly into 201 (Middle School), northerly into 207 (North of MS access road), southerly to 183 and properties along Leary Street, westerly to properties along Main Street, including wetlands that drain to Dudley Pond, and will be included in the next steps in his investigation.
For those concerned about Dudley Pond as a source of drinking water for Happy Hollow wellfield, Gould pointed out that while the Water Department has identified PFAS as high as 33.2 ppt in a 10/6/21 sample of raw water, the Water Department has treated the water supply and removed PFAS since February of 2022. In 2029 the drinking water maximum contaminant level (MCL) will be 4 ppt for PFAS and will involve fines for exceedances.
Regarding questions about exposure safety from irrigation well water, swimming/wading pools, and gardening, Gould described PFAS as not being easily absorbable through the skin so that was less of a risk. The Health Department has informed CMG that there are no private water wells or irrigation wells withing 500 feet of 195 Main Street property.
Gould did note that garden vegetables can absorb PFAS from irrigation water. The EPA lifetime health advisory (cancer risk assessment) for drinking water is 70 ppt for PFOA and PFOS, the two top chemicals found as PFAS. Also, the tissue of fish swimming around in water with a 70 ppt level would also be at 70 ppt level. PFAS at least, does not bioaccumulate in the body in comparison to mercury moving up the food chain and concentrating at the top in tuna or swordfish.
Gould’s work involves reviewing the property history which he found recorded as far back as 1875 in a birds-eye view map. The 195 Main property has been used as quarry, likely trash disposal, the Old Wayland Dump (1935-1958), and Old DPW garage. The property has three release tracking number (RTN) associated with it: 1985 RTN 3-0001594 (contaminated soil from #6 fuel oil release at Claypit Hill School used to pave the DPW parking area). 1998 RTN 3-0016798 (overflow of catch basins into Dudley pond wetlands) and 2022 RTN 3-0037750 (feasibility study finds OHM and PFAS placing the site in DEP Tier 1 class)
The accompanying documentation can be found on the Mass.gov website for Executive Office of Energy and Environmental Affairs (EEA) Data portal, waste site and reportable releases or the Health Department at 41 Cochituate Road (first floor Town Building) PIP repository.
