THE COMMONWEALTH OF MASSACHUSETTS
WATER RESOURCES COMMISSION
100 C A M B R ID G E S TR EET , B O S TO N MA 02114
REPORT OF THE FINDINGS, JUSTIFICATIONS AND DECISION
OF THE WATER RESOURCES COMMISSION
Relating to the Approval of the
Littleton Electric Light and Water Department’s
Request for an Interbasin Transfer
Pursuant to M.G.L. Chapter 21 § 8C
DECISION
On September 12, 2024, by a nine to zero (9-0) vote with one abstention, the Water Resources
Commission (WRC) approved, with Conditions, the Littleton Electric Light and Water
Department’s request for a water supply connection with Boxborough, which will facilitate an
interbasin transfer of 0.060 million gallons per day (MGD). This vote was taken after review of
the facts provided by the applicant, analysis of the associated data, and consideration of public
and agency comments received concerning this proposal.
INTRODUCTION
On May 7, 2024, the Massachusetts Water Resources Commission (WRC) received a request from
the Littleton Electric Light and Water Department (LELWD) for approval of an action to increase
the present rate of interbasin transfer under the Interbasin Transfer Act (ITA) (M.G.L. Chapter 21
§§ 8B-8D) as part of a Single Environmental Impact Report (SEIR) and supplemental filing
submitted to the Massachusetts Environmental Policy Act (MEPA) Office. The proposed project
includes a new 0.529 million gallons per day (MGD) water supply well (Taylor Street Well1) and
pumping station in Littleton for the LELWD, connection of the new water supply well to a water
treatment plant in Littleton via a raw water transmission main, and construction of a finished 4.5
mile 12- to 8-inch diameter water main from the LELWD system to bring a treated water supply
to properties within the Town of Boxborough. The Secretary’s Certificate on the SEIR was
issued on May 17, 2024. The WRC accepted LELWD’s application as complete at its June 13,
2024 meeting.
LELWD is proposing to transfer a maximum of 0.065 MGD of water, 0.060 MGD of which is
subject to review under the ITA, to properties in the Town of Boxborough that are experiencing
contamination of per- and polyfluoroalkyl substances (PFAS), sodium, and chloride in their
existing on-site water supplies. This interconnection triggers the ITA because Littleton’s sources
are located in the Merrimack River Basin, and Boxborough has land area in the Concord (aka
SuAsCo) and Merrimack River Basins. Wastewater from these properties in Boxborough is
discharged on-site.
1
The Taylor Street Well is also known as the Trumbull Well.
Page 1 of 19
The maximum transfer of 0.065 MGD from LELWD to properties in Boxborough is limited by
an Inter-Municipal Agreement (IMA) between the two towns. The maximum hydraulic capacity
of the proposed 8-inch finished water main is expected to be approximately 850 gallons per
minute (gpm) to support potential fire flow demand as modeled at the southern terminus of the
water main with a 20 pound per square inch (psi) residual pressure in the main. Fire flow would
only occur during an emergency condition and is not anticipated to last for an entire day. A
significant 4 hour, 850 gpm fire flow demand occurring at the southern terminus of the water
main in Boxborough would be approximately 0.2 MGD. However, typical fire events are far less
than 4 hours in duration. Although the capacity of the new pipe is greater than 0.065 MGD, the
maximum daily flow will be limited by the IMA.
A summary of the facts described in the application is as follows:
1. Littleton’s sources are located in the Merrimack River Basin.
2. Boxborough does not have a municipal water supply.
3. Properties in the Town of Boxborough are experiencing contamination of PFAS, sodium,
and chloride in existing water supplies.
4. Areas of Boxborough to be served by LELWD are in the Merrimack River Basin and the
Concord River Basin.
5. As a portion of the area to be served in Boxborough is in the Merrimack River Basin, only
the portion of water that will be serving properties located in the Concord River Basin
(maximum transfer of 0.060 MGD) is subject to the ITA.
6. A MEPA environmental review, pursuant to M.G.L. c. 30, §§ 61-62I, was required for this
proposed action. The ITA application was submitted as part of the SEIR for this project
(EOEEA #16736) followed by a supplemental filing with MEPA. Additional information
for ITA review was requested during the MEPA process and provided by LELWD.
7. The Secretary’s Certificate on the SEIR was issued on May 17, 2024, stating that no further
MEPA review was needed.
8. Two required public hearings were held virtually via Zoom to take comment on this
application, for the donor basin on July 24, 2024 and for the receiving basin on July 25,
2024. Written public comments were accepted until August 1, 2024 and were supportive
of the project.
9. A Staff Recommendation to approve the request was presented to the WRC on August 8,
2024.
10. A public hearing on the Staff Recommendation was held virtually via Zoom on August
15, 2024. Written public comments were accepted until August 22, 2024 and none were
received.
EVALUATION OF THE PROPOSED INTERBASIN TRANSFER
This Interbasin Transfer application was reviewed on its own merits and is applicable solely to
LELWD’s transfer of water supply to Boxborough in the amount of 0.060 MGD. This Decision
is made based on facts contained in LELWD’s MEPA submissions and additional information
submitted at the WRC’s request during the MEPA process and during staff review. The
application was evaluated against the seven Criteria outlined in the ITA regulations (313 CMR
4.09), as well as the ITA Performance Standards and with consideration of comments received
from the agencies and through the public comment process.
Page 2 of 19
SYNOPSIS OF THE EVALUATION CRITERIA (313 CMR 4.05)
Criteria Application Meets?
Criterion #1: MEPA Compliance Yes
Criterion #2: Viable In-Basin Sources Yes
Criterion #3: Water Conservation Yes, with conditions
Criterion #4: Forestry Management Not Applicable
Criterion #5: Reasonable Instream Flow Yes
Criterion #6: Impacts of Groundwater Withdrawals Yes, with conditions
Criterion #7: Cumulative Impacts Yes
BASIS FOR THE WRC DECISION
This application was reviewed by Executive Office of Energy and Environmental Affairs (EEA),
WRC staff at the Department of Conservation and Recreation’s (DCR) Office of Water
Resources, Department of Environmental Protection (MassDEP), and Department of Fish and
Game’s (DFG) Division of Fisheries and Wildlife (MassWildlife) and Natural Heritage and
Endangered Species Program. This Decision was made after an evaluation of LELWD’s
application and compliance with the six applicable Criteria of the ITA regulations and the ITA
Performance Standards. The following section describes in detail compliance with the Criteria.
Figure 1: LELWD’s Sources and the Project Area
Page 3 of 19
Criterion #1: Compliance with MEPA
An environmental review, pursuant to MEPA (M.G.L. c. 30, §§ 61-62I) and the MEPA regulations,
301 CMR 11.00, was required for this proposed transfer. The ITA application was submitted as
part of the SEIR for this project (EOEEA #16736) and a supplemental filing with MEPA. The
SEIR was submitted in April 2024 and the supplemental filing was received by WRC staff on May
7, 2024. The SEIR Certificate was issued on May 17, 2024 and stated that no further MEPA review
was necessary.
Criterion #2: Viable In-Basin Sources
LELWD was required to demonstrate that all reasonable efforts have been made to identify and
develop all viable sources in the receiving area (Boxborough). Multiple studies have been
completed for the Town of Boxborough in an effort to mitigate the PFAS, sodium, and chloride
contaminated groundwater sources currently serving 11 small public water systems (PWS)
including 1,100 residents living in condominiums representing about 20% of the town.
Alternatives have been evaluated in the receiving basin, including drilling individual replacement
wells for each PWS, adding enhanced treatment for each PWS, and exploring other sources
within Boxborough. However, none of these alternatives was deemed an acceptable solution that
would provide the capacity needed. Based on the information in the completed studies,
providing suitable drinking water from the existing water supply sources in Boxborough is a
challenge due to contamination, technical feasibility of treatment, and financial constraints.
Following is a summary of all issues considered relating to viability.
Sources within the Town of Boxborough
The only source of water that would avoid an interbasin transfer would have to be located within
Boxborough, as the Town has land area in two basins. The ITA regulations allow a city or town
with land area in multiple basins to supply itself with water, as long as the water does not cross a
municipal boundary. Boxborough does not have a municipal water supply or any associated
infrastructure. Groundwater in and around Boxborough has elevated levels of sodium and
chloride ions associated with the storage and use of road salt. The elevated levels of sodium and
chloride not only affect water taste and quality but also pose risks to individuals on sodium-
restricted diets and can lead to infrastructure corrosion. For example, the Boxborough Executive
Office Center, like several of the PWS wells in Boxborough, has excessive levels of sodium
(1,295 mg/L) and chloride (1,500 mg/L) well above the Office of Research and Standards
Guideline (ORSG) of 20 mg/L and the Secondary Maximum Contaminant Level (SMCL) of 250
mg/L, respectively. This PWS has also exceeded the action levels for lead and copper on
numerous occasions since 2011. The high levels of both sodium and chloride are likely
contributing to the corrosiveness of drinking water, enabling the persistent lead and copper
action level exceedances. In addition, PFAS are present in these water supplies. Per MassDEP,
ten of the 11 impacted PWS in Boxborough have PFAS levels exceeding MassDEP's maximum
contaminant level (MCL) of 20 parts per trillion (ppt). The PWS exceeding the standards are
currently providing bottled water to reduce exposure of the contaminants to the consumers.
Bottled water is a temporary short-term solution until a long-term solution is available.
A study completed in 2002 summarized the existing hydrogeological data for Boxborough and
recommended sites for municipal test well exploration in overburden deposits and bedrock. Test
well exploration was conducted in 2006 at several locations in town. The conclusions of the
Page 4 of 19
study suggested that the most favorable results were found from the overburden drilling on land
owned by the Harvard Sportsmen’s Club, located in the northwest corner of Boxborough. Based
on preliminary testing, it was estimated that a single gravel-packed production well could yield
500-700 gpm or more. The Harvard Sportsmen’s Club location is in the same aquifer as
Littleton’s proposed Taylor Street Well but further upgradient in the watershed. Due to the
location, the upgradient recharge would be significantly less than the Taylor Street Well,
potentially creating a larger ecological impact to associated wetlands at the same withdrawal
volume. In addition, there is no existing municipal water infrastructure or treatment plant in
Boxborough to which this potential well could connect.
Alternatives Analysis
An alternatives analysis was performed to identify, evaluate, and select potential water supply
alternatives to provide a treated water supply to eleven small public water systems (PWS) in
Boxborough that are currently impacted by PFAS, sodium, and chloride. Four alternatives,
including a no-action alternative, for water supply were reviewed. Methods for providing water
supply included implementing additional treatment for existing sources, bringing new sources
online, and an interconnection with Littleton or surrounding towns.
Alternative 1: No Build
Under this alternative, no construction would occur. While there would be no impacts to
wetland resources, the impacted PWS would not be provided with an alternative water supply
and would continue to suffer serious water quality issues. The residents would not have access
to drinking water that meets all of MassDEP’s Drinking Water Standards and Guidelines.
Alternative 2: Drill Individual Replacement Wells for each PWS
Under this alternative, each individual PWS would have a new source of supply drilled and the
contaminated wells could be abandoned. Replacing the water supply sources on the same
property to develop a source that is not contaminated is not an option due to 1) lack of enough
property for the Zone I wellhead protection area and setbacks from the Title V septic systems, 2)
the bedrock aquifer in which the sources would need to be developed is contaminated with
PFAS, sodium and chloride. Due to the extent of the contamination in the local aquifers,
replacement wells would likely need to be drilled in different geological formations, which may
require thousands of additional feet of water main to be constructed for each system. In addition,
there is no guarantee of water quality in the short or long term at the replacement wells.
Alternative 3: Add Treatment to each PWS
Under this alternative, each individual PWS would be updated to include treatment for the
contaminants of concern and the new well would not be constructed in Littleton. Treatment
systems for the contaminants of concern require significant infrastructure, operations and
maintenance, and produce individual waste streams that may negatively impact the environment.
Reverse osmosis (RO) would be the only feasible treatment for treatment of sodium and chloride
contamination. This treatment process, which is costly and energy-intensive, produces a
concentrated waste stream that would ultimately be disposed of through underground injection.
The discovery of the PFAS contamination in the area groundwater complicates the viability of
this treatment alternative, as the concentrations of PFAS within the waste streams of each
individual system will limit disposal options. Treatment of PFAS in drinking water for each of
Page 5 of 19
the impacted PWS is typically achieved with the use of Granular Activated Carbon (GAC)
filters, which can be expensive for individual point of entry treatment and further complicated by
the need to treat for other constituents. The treatment of these contaminants individually at each
source is technically challenging and cost prohibitive.
Alternative 4: Municipal Interconnection
Under this alternative, the impacted PWS would be connected to a nearby municipal water
system. Systems within 1 mile of the impacted PWS were considered due to feasibility of design
and construction of the project.
The Town of Harvard operates a small system with approximately 98 service connections that is
served by two wells and has a third well for emergency supply. This system has no treatment
and does not have capacity to connect the impacted PWS. Harvard’s municipal sources are
located in the Nashua River Basin so this option would not avoid an interbasin transfer. This
system was not considered further for an interconnection.
LELWD operates a water system serving residents in Littleton. LELWD has recently completed
construction of a water treatment plant (WTP) at Whitcomb Avenue with a capacity of 1.8 MGD
to treat water from its groundwater wells for PFAS as well as other contaminants. LELWD has
also been conducting hydrogeological testing and investigation over the past 35+ years to locate
a new well source to provide additional redundancy within their system. With the addition of the
Taylor Street Well to the system, and the treatment capacity at the Whitcomb Avenue WTP,
LELWD will have the additional supply necessary to provide treated water to the PWS in
Boxborough.
Interconnection with LELWD
Littleton's water system has the necessary infrastructure that can be extended to serve
Boxborough, thereby reducing the need for significant new infrastructure investments in
Boxborough. The interconnection leverages existing resources, economies of scale, and state
funding opportunities (such as grants and loans with favorable terms), which can alleviate the
financial burden on Boxborough’s residents. The Town of Boxborough is designated as an
Environmental Justice Population. Interconnecting with Littleton’s water system reduces the
need for extensive new construction and the associated disturbance. Furthermore, it supports
community health by resolving the current contamination issues more rapidly and effectively
than alternative solutions could. In summary, the interconnection with Littleton is considered the
best option due to its immediate impact on improving water quality, cost-efficiency, technical
feasibility, regulatory support, and long-term sustainability benefits, providing a comprehensive
solution to Boxborough's pressing water supply challenges. MassDEP concurs with the
Proponent’s viability criteria assessment outlined in the May 2024 supplemental MEPA filing
that identified the LELWD interconnection as the preferred alternative.
In conclusion, the basic requirement of the ITA is that an applicant shows that local water supply
sources are used to the maximum extent possible and that other sources cannot be reasonably
developed prior to the applicant obtaining permission to transfer water from out of basin. Given
the abo