by Liz Theiler
4/21/2018

17 Norland St.
Holliston, MA 01746

April 13, 2018

James A. McQuade

DEP Solid Waste Section Chief

8 New Bond Street

Worcester, MA 01606

RE: DEP Recycling, Composting or Conversion Operation (RCC)

Draft Permit BWP SW47

American Recycled Materials, Inc.

Dear Mr. McQuade:

Thank you for coming to Holliston to listen to the concerns of the residents with regard to the business at 157-165 Lowland St.

As a former elected Board of Health member I am concerned about the operations of the business and its location in the vulnerable zone II, the hydrogeologically defined area of contribution to a public drinking water supply wellhead, of three (public drinking water well 5, 6 and 7) wells of the operating five shallow public drinking water wells of Holliston. This affects the health of all the residents of Holliston.

E. Inspection of Incoming Materials:

1. The Operator shall visually inspect all incoming loads to determine the presence of unacceptable materials,

Is it possible for the Operator to visually inspect up to 500 tons of material a day?

H. Permit Modification by MassDEP: Mass DEP reserves the right to rescind, (bold added for emphasis) …this permit  ... based on the determination of an actual or potential adverse impacts from the Operation.”(bold added for emphasis)

Due to the history of non-compliance at this business as documented in the written comments given/sent to you by the Holliston Board of Selectmen, the Planning Board, the Board of Health and the Conservation Commission as well as the Cease and Desist Order of February 12, 2018 issued by the Inspector of Buildings added to the testimony both written and oral of residents there are potential adverse impacts from the operation.

Further, the Public Drinking Water wells are shallow and highly vulnerable. “All wells are gravel-packed only 25-40 feet to base of extraction pipe.” Integrated Assessment of Shallow-Aquifer Vulnerability to Multiple Contaminants and Drinking-Water Exposure Pathways in Holliston, Massachusetts.” Water 2018, 10(23).

There are potential adverse impacts from the operation due to leaching potential of the petroleum hydrocarbons and toxic poly-aromatic hydrocarbons from the asphalt into the groundwater. Again due to non-compliance issues, leaching of toxic compounds from unknown materials should be considered.

We need DEP to help us protect our drinking water. The uncertainty and the toxicity of the materials received as well as processed at this site require officials to error on the side of caution to protect our aquifer and the health of the residents.

We need DEP to help protect our water supply, as noted there are no comments sent regarding this draft permit by the Holliston Water Department, even though potential contamination of public drinking waters is a major concern. According to the MassDEP Office of Research and Standards: “MassDEP is responsible for ensuring the quality of Massachusetts public drinking waters.”

Sincerely,

Elizabeth Theiler, Ph.D.

DEP's decision is pending.