PFAS Information

 
The next PFAS Information Session will be held on 4/16/2024 at 6:30pm. Information will be posted on the Town calendar.
 
April 16, 2024 PFAS Public Information Session (powerpoint, recording)
 
January 16, 2024 PFAS Public Information Session (powerpoint, recording, pfas sources, chart low concentrations, chart high concentrations)
 
The next PFAS Public Information Session will be held in April 2024.
 
 
OVERVIEW
The Town Hall campus well is a "Transient Non-Community Public Water System (PWS)" and was tested in September 2019.   The results showed levels of PFAS6 (definition below) above the Commonwealth’s Maximum Contaminant Level (MCL) which at the time was 70 ppt (parts per trillion).  Test results were submitted to the Massachusetts Department of Environmental Protection (DEP) Water Supply program by our water supply operator.  DEP’s Waste Site Cleanup program contacted the Town in November 2019 and communicated its determination that the detection of PFAS was subject to Chapter 21E, and DEP directed the Town to conduct an Immediate Response Action (IRA), including testing of private water supplies on properties in the area of the Town Hall campus.   
 
DEP required the Town to begin by testing all potable wells within 500 feet of the Town Hall campus well. If any of those wells were found to have PFAS6, we were then required to test all wells within 500 feet of that well. This process was repeated until there were no new wells containing PFAS6. This testing determined the affected area that is referred to as the “Disposal Site” under Chapter 21E. A map of the affected area can be found here.
 
Under the IRA plan approved by DEP, we regularly test all potable wells in the affected area, provide POETS (point of entry treatment systems) to those homes with PFAS6 levels at or above 20 PPT; and offer bottled water to those homes with detectable levels below 20 PPT. Special Town Meeting in November 2021 authorized spending up to $120,000 for single vessel POETs for houses in the affected area instead of bottled water. This was above and beyond what was required of the Town by DEP.
 
The Selectboard has engaged the environmental consulting firm Tighe and Bond, and their Licensed Site Professional Jeff Arps, and environmental attorney Barry Fogel, to assist in addressing the PFAS issue and complying with DEP’s requirements.  We hold quarterly public information meetings so that residents have an opportunity to ask questions. Tighe and Bond regularly submits status reports and semi-annual IRA Plan Reports to DEP, which coincide with the quarterly information meetings.  
 
As part of the work required by DEP’s regulations, the LSP is required to develop a Conceptual Site Model (CSM) about the possible source(s) of this contamination. The following CSM statement is from the latest IRA Plan Report:
 
“In summary, based on the activities completed to date, the current conceptual site model is that there are four possible sources of PFAS at the Site: (1) fire training at the Town Campus conducted several decades ago; (2) the firefighting at 30 Mountain Road in 2017, (3) the firefighting at 54 Mountain Road in 1967, and (4) septic system discharges of well water impacted by PFAS and wastewater impacted by domestic, household sources of PFAS.“ DEP also has identified “atmospheric deposition” as a general source of PFAS.
 
You can access the information related to this release on the MDEP website using the Release Tracking Number 2-0021072.
 
PFAS is an emerging problem both in Massachusetts and around the country.  In 2018, DEP and the Massachusetts Department of Fire Services (DFS) announced a program to inventory and dispose of pre-2003 firefighting foam that contain PFAS chemicals. The drinking water standard in Massachusetts was lowered from 70 ppt for PFOA and PFOS to 20 ppt for the sum of PFAS6 in December 2020. 
 
We have asked what legal options are available to recover costs from responsible parties.  We recently engaged special counsel to represent Princeton and file a suit on our behalf in Federal court as part of the Multi-District Litigation against companies that designed, manufactured, marketed, distributed, and/or sold PFAS.
 
If you have any questions after reading the information on this page, please contact Town Administrator Sherry Patch at (978) 464-2102 or townadministrator@town.princeton.ma.us
 
For those residents who want to read more about the PFAS problems and the Town’s action, we provide additional information below.
According to EPA, Per- and polyfluoroalkyl substances (PFAS) are a group of man-made chemicals that includes PFOA, PFOS, GenX, and many other chemicals. PFAS have been manufactured and used in a variety of industries around the globe, including in the United States since the 1940s. PFOA and PFOS have been the most extensively produced and studied of these chemicals. Both chemicals are very persistent in the environment and in the human body – meaning they don’t break down and they can accumulate over time. There is evidence that exposure to PFAS can lead to adverse human health effects.
 
PFAS can be found in:
  • Food packaged in PFAS-containing materials, processed with equipment that used PFAS, or grown in PFAS-contaminated soil or water.
  • Commercial household products, including stain- and water-repellent fabrics, nonstick products (e.g., Teflon), polishes, waxes, paints, cleaning products, and fire-fighting foams (a major source of groundwater contamination at airports and military bases where firefighting training occurs).
  • Workplace, including production facilities or industries (e.g., chrome plating, electronics manufacturing or oil recovery) that use PFAS.
  • Drinking water, typically localized and associated with a specific facility (e.g., manufacturer, landfill, wastewater treatment plant, firefighter training facility).
  • Living organisms, including fish, animals and humans, where PFAS have the ability to build up and persist over time.
Certain PFAS chemicals are no longer manufactured in the United States as a result of phase outs including the PFOA Stewardship Program in which eight major chemical manufacturers agreed to eliminate the use of PFOA and PFOA-related chemicals in their products and as emissions from their facilities. Although PFOA and PFOS are no longer manufactured in the United States, they are still produced internationally and can be imported into the United States in consumer goods such as carpet, leather and apparel, textiles, paper and packaging, coatings, rubber and plastics. 
 
The DEP adds “Because these chemicals have been used in many consumer products, most people have been exposed to them. 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 communities where these chemicals have contaminated water supplies.”
 
Note that DEP does not have the authority to regulate consumer products, food, and other sources of PFAS.
 
On October 2, 2020 the DEP amended Massachusetts Drinking Water Regulations, and established a Maximum Contaminant Level (MCL) of 0.000020 milligrams per liter (mg/l) or 20 ng/l (also called parts per trillion or ppt) for the sum of six PFAS compounds (PFOS, PFOA, PFHxS, PFNA, PFHpA and PFDA), known as PFAS6. Previously the MCL was 70 ppt. The regulations detail the sampling requirements and corrective actions that a Public Water System must take when the MCL is exceeded, as well as the provisions for public education and notice of exceedances so that communities can be educated and proactive in protecting their drinking water quality.

To download the latest Massachusetts Drinking Water PFAS Maximum Contaminant Level (MCL) Amendments, click here.  

For a Quick Reference Guide on Per- and Polyfluoroalkyl Substances (PFAS) Drinking Water Regulations, click here.
 
DEP's comprehensive regulations under Chapter 21E, 310 CMR 40.0000, also known as the Massachusetts Contingency Plan (MCP), govern how the Town must proceed. The first step in the Town's response was to engage a Licensed Site Professional (LSP) to manage the process. Jeffrey Arps of Tighe & Bond, our LSP, filed an Immediate Response Action Plan (IRA) with DEP. The IRA lays out the steps the Town will take to manage the situation.
 
There are five (5) phases to the MCP:
  • Phase I – (submitted November 9, 2020). Initial Site Assessment and Tier Classification (site is Tier I due to drinking water impacts)
  • Phase II – )submitted November 11, 2023). Define vertical and horizontal extent of PFAS in all media (soil, groundwater, surface water, air), risk characterization
  • Phase III – due November 2024. Evaluation of remedial alternatives
  • Phase IV - due with Phase III. Plan to implement remedy selected in Phase III
  • Phase IV Completion/Phase V – due November 2025. Document remedy completion
The IRA runs parallel to the “phase” process with no deadlines of its own other than regular IRA Status Reports submitted to DEP. Note that sites can be closed at any time during this process with a Permanent Solution or Temporary Solution.
 
We are currently in Phase III even as we are conducting the IRA. 
 
310 CMR 40.0424 dictates the information that should be contained in the IRA. Status updates are routinely filed and describe updates to various sections of the IRA. Some of the information that is of particular interest to Princeton residents is:
  • a description of the release or threat of release;
  • a description of any Immediate Response Actions undertaken to date at the site;
  • proposed IRA activities (next steps) including treatment systems (POETs), potable and groundwater monitoring well sampling
  • Conceptual Site Model (this evolves over time as our LSP learns more through testing)
  • Recommendations
  • Maps of affected area (residences)
  • Test data (well water, surface water, monitoring well water, soil)
Note that the LSP can and does request IRA Modifications as more information becomes available and the situation is understood more clearly. Modifications accepted by DEP are described in the next IRA Status report.
 
See the section below to view the most recent Immediate Response Action (IRA) Status Report submitted by Tighe and Bond on behalf of the Town of Princeton. 
 
  • Princeton is ensuring that all potable wells in the affected area are being tested regularly for PFAS
  • Residents in the affected area with levels of PFAS6 at or above 20 parts per trillion (PPT) are receiving point of entry treatment systems (POETs)
  • Those with detectable amounts of PFAS6 under 20 PPT are receiving bottled water unless they have a POET or they state they don't want or need bottled water. Special Town Meeting in November 2021 authorized spending up to $120,000 for single vessel POETs for houses in the affected area instead of bottled water. This was above and beyond what was required of the Town by DEP.
  • We continue to investigate the scope of the problem by testing wells at the borders of the affected area, testing ground water and surface water, and by doing surface and deeper soil testing.
  • We have engaged special counsel to represent Princeton in filing a suit in Federal court as part of the multi-district litigation against companies that designed, manufactured, marketed, distributed, and/or sold PFAS.
 
FOR A FULL LIST OF ALL MDEP ELECTRONICALLY SUBMITTED FORMS VISIT https://eeaonline.eea.state.ma.us/EEA/fileviewer/Rtn.aspx?rtn=2-0021072
 

FILINGS TO AND RESPONSES FROM MASSDEP (most recent first)

3//11/2024Immediate Response Action Plan Status Report No. 9
11/13/2023Phase II Comprehensive Site Assessment Report
9/11/2023Immediate Response Action Plan Status Report No. 8
3/7/2023Immediate Response Action Plan Status Report No. 7
9/7/2022Immediate Response Action Plan Report No. 6
6/6/2022Quarterly Status Report
3/8/2022Immediate Response Action Plan Report No. 5
12/13/2021Quarterly Status Report
9/7/2021Immediate Response Action Plan Report No. 4
6/22/2021IRA Modification Conditional Approval
6/4/2021Quarterly Status Report
3/10/2021Quarterly Status Report
2/2/2021Immediate Response Action Plan Modification Conditional Approval
12/15/2020Immediate Response Action Plan Modification
11/30/2020Monthly MassDEP Update
11/5/2020Phase I initial Site Investigation and Tier Classification
10/17/2020Monthly MassDEP Update
9/10/2020Immediate Response Action Status Report No. 2 & Imminent Hazard Evaluation
9/2/2020Immediate Response Action Plan Modification Approval
8/25/2020Monthly MassDEP Update
8/18/2020Immediate Response Action Plan Modification
7/8/2020Summary Spreadsheet - June 2020
6/10/2020Summary Spreadsheet - May 2020
3/25/2020March Summary
3/3/2020IRA Status Report No. 1 & IRA Plan Modification
2/7/2020February Summary
1/24/2020IRA Plan Conditional Approval
1/3/2020Release Notification and Immediate Response Action Plan
11/25/2019Notice of Responsibility

ADDITIONAL RESOURCES

Recording of 1/18/22 PFAS Information Session - no longer available
Recording of 4/26/22 PFAS Information Session - no longer available
April 12, 2023  PFAS Public Information Session (recording, powerpoint)
October 5, 2023 PFAS Public Information Session (powerpoint, no recording available)
 
Note: Residents have asked what the proper disposal method is for used sediment pre-filters from their POET systems. Our LSP has informed us that the sediment filters are not being used to filter out PFAS.  Typical PFAS molecules have a maximum diameter of 0.002 micron, which is four orders of magnitude smaller than the pore openings of 5 microns in the sediment pre-filters that EPA and DEP recognize remove sediment particles and extend the life of the granulated activated carbon (GAC) filters designed to remove PFAS from water.  With PFAS molecules passing through these sediment pre-filters, they are properly disposed of in the standard manner as solid waste.
 

PFAS Summary of Actual Expenditures - As of 6/7/2023