I Filed a CERCLA Petition to Put the South Bay (Boston, MA) on the National Priorities List

Read the full petition here: Petition to put South Bay on the NPL (Feb. 13 2026).

For those of you following my work, this is going to be a surprise. I've been dealing with a second environmental disaster — this one in Boston — while simultaneously litigating against Apple and navigating bankruptcy. I didn't talk about it publicly because I needed to be sure of what I was looking at before I said it out loud, but I'm sure now & it's a real mess.

Today I filed a Petition for Preliminary Assessment under CERCLA § 105(d) and a Sixty-Day Notice for a Citizen Suit under the Clean Water Act and CERCLA, nominating the South Bay in Boston for the National Priorities List. There have never been any NPL sites in the City of Boston. The petition argues there should have been one a long time ago.

Most people who visit Boston don't realize that at least a third of the city shouldn't exist. The Shawmut Peninsula (the original landmass) was a tiny, hilly island barely connected to the mainland by a narrow tidal isthmus called "the Neck." Everything around it was ocean, tidal flats, salt marshes, and bays. The South Bay was one of the largest of these. It was a working harbor, a port of international importance, and the economic heart of early colonial Boston. Tidal streams, including the Roxbury Creek and Dorchester Brook, fed into it. The ocean ebbed and flowed, with high tides twice a day.

Over approximately two hundred years, Boston filled this bay. They filled it with garbage, sewage, construction debris, coal ash, rubble from the Great Fire of 1872, cinders, street sweepings, and dredged harbor mud. The wharves were built on timber cribbing and wood pile foundations; the spaces between were stuffed with whatever was available. Sugar refineries, iron foundries, and slave-trade shipping operations filled the shoreline for their own purposes. The South Boston Iron Works, the largest foundry in the country by mid-century, repeatedly filled its land from the 1830s through 1860. The Boston Wharf Company (whose directors were also shareholders in the Bay State Sugar Refinery and notorious slave owners) filled the areas around Fort Point Channel. The Gillette razor company moved in around 1905 and was still filling (with straight-up bricks) into the 1960s. The City and Commonwealth were involved in or approved nearly all of it.

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By 1854, the South Bay covered 306 acres. By 1898, it covered only about sixty acres. Today it is a neighborhood. The fill is still there. The garbage is still there. The wood piles are rotting. And the ocean is still trying to come in twice a day through 1,360 miles of Victorian brick sewers that were documented as "ill-adapted" and "usually leaky" in 1885, so is certainly in even worse condition now. They also documented that the groundwater in the fill across the old South Bay is "tidally influenced" meaning the tides are ebbing and flowing through the garbage, ash, sewage, and hazardous waste every day, pushing it inland and moving it all around.

The sewer system serving the South End, Lower Roxbury, and surrounding neighborhoods was mostly built between 1877 and 1894 as combined sewers (meaning sewage and stormwater flow in the same pipes at a per-building level). Buildings constructed before 1877 predate the entire system. (My basement apartment was built in 1864 with sewers built in the 1850s). Where their sewage went originally is unknown. It may have gone into cesspits under the buildings, into old "common sewers" that discharged directly into waterways, or straight into the canal and ocean.

The Roxbury Canal was designated an open cesspool and a menace to public health for over a century. In the 1960s, the City enclosed it in concrete box culverts (twin barrels roughly 10 by 15 feet) and paved over the top. They did not clean it. They did not remove the accumulated sewage. They sealed it in and built on top of it. The conduit has no tide gates. It is hydraulically connected to Boston Harbor. Water levels inside fluctuate 10 to 13 feet with the tides.

The first inspection of the conduit in over sixty years, conducted in 2019, found several feet of sediment that had accumulated over more than fifty years, iron-oxidizing bacteria visible as orange biofilms, and marine worms swimming in murky water. When I visited in Dec. 2025, it is still full of feces... and wheelchairs. I took photos and sent them to the EPA.

Every high tide raises water levels in this system, backing contaminated water up through the connected sewers and into the houses. A 1967 engineering report documented that "because of the extremely poor conditions of the tide gates, regulators, and outlets, lower reaches of the principal sewerage system throughout the city are surcharged by tidewater on flood tides." In the area where I lived, "on outgoing tides, raw sewage is discharged through the tide gates into the harbor each day, regardless of weather conditions." There is no physical barrier between the ocean and the inside of the Victorian row houses. The only things that might slow it are P-traps that can dry out, building sewer valves that are usually missing or broken, and building envelopes that don't exist in 1860s construction.

This has been a known problem since at least 1876, when the Boston Evening Transcript calculated that 8,000 cubic feet per minute of sewer gas was being distributed among approximately 800 houses every day by the tides. In 2026, the City's response to this continues to be a mixture of denial, hostility, and "new phone, who dis?"

I asked the Boston Public Works & Boston Water and Sewer Commission where my sewage went when I flushed my toilet (from ancient buildings, even older sewers, and in one of the most notoriously polluted and neglected areas in Boston). Based on the sparse records I could find, it appears that for over two years, my sewage went directly into the ocean where my neighbors were swimming and fishing, if its not just now part of the sludge lining that canal. Everyone refused to answer this question & their refusal was informative.

The Boston City Hospital was opened in 1864 on what the City's own history describes as "agricultural fair grounds" that flooded at high tide, where "a large portion of the site was water flats, largely of dock mud." The old Roxbury Canal, carrying Roxbury's raw sewage to tidewater, ran through one corner of the hospital grounds. The basements were built 3.5 feet below ground level without any building envelope to exclude moisture, producing "a great deal of dampness." The hospital's sewers created "seepage of ooze and flow of tides in some parts of the building."

The City's own Medical Staff documented that "all patients with surgical open wounds who were assigned to beds near the air inlets invariably had erysipelas, pyaemia, or some other septic complication, many of whom died." The ventilation system was designed in such a way that "air vitiated with sewer gas" was "pushed into the wards." The City's own institutional history acknowledged that the Roxbury Canal was "a villainous site for a hospital ward."

The City opened its first Infectious Disease department around 1865, creating a separate facility on the banks of the South Bay and the Roxbury Canal. The hospital's basement laboratory, where "extensive bacteriological experiments were made of the air," found "innumerable colonies of moulds." That laboratory was approximately 830 feet from the Roxbury Canal and less than 500 feet from where I later lived in another unfinished Victorian basement, with no building envelope or drainage, actively water intrusion and holes in the walls directly to the exterior, and connected by dozens of utility lines, pipes, and conduits.

Between 1935 and the 1970s, approximately half of all patients who died from bacterial infections at the hospital acquired those infections at the hospital. On average 20 days after admission, people dying approximately 15 days after the first positive blood culture. The hospital had a documented, decades-long epidemic of hospital-acquired infections and never disclosed the ongoing sewage hazards or the proximity to the cesspool as a potential contributing factor.

There are 160 years of discharges of infected bodily fluids at that location, seeping into my living room and bedroom. The adjacent South Burial Ground contains hundreds if not thousands of bodies of people who died from typhoid, smallpox, diphtheria, and scarlet fever. All of it draining through the same combined sewers, into the same conduit, into the same harbor, and backing up into the same houses twice a day with the tides, including mine.

New England Nuclear Corporation (NEN), later acquired by DuPont, was one of the largest commercial producers of radiolabeled compounds in the United States. It occupied at least seven buildings across three streets in the South End (on Albany Street, East Canton Street, and East Dedham Street) manufacturing tritium, carbon-14, sulfur-35, phosphorus-32, iodine-125, and other radiolabeled compounds at production scale. Its NRC license covered "any byproduct material with atomic numbers 3 through 94" which was a blanket authorization covering essentially every radioisotope from lithium through plutonium.

NEN discharged radioactive waste from holding tanks into the Boston combined sewer system as a routine disposal practice. Those are the same combined sewers that overflow untreated into Fort Point Channel during wet weather. NRC inspection records documented 25 million liters per year of water use at the Boston site, all discharging to Deer Island via the combined sewer. Radionuclides captured in treatment sludge also went to the harbor. Radionuclides that leaked through century-old sewer pipes went into the shallow groundwater at approximately 5 feet below grade.

Meanwhile, the City Hospital and Boston University Medical Center operated one of the largest continuously operating medical radioisotope facilities in the northeastern United States, on the same site, above the same shallow groundwater, discharging to the same combined sewers. NRC enforcement records document decades of violations: lost materials, stolen materials, mis-administered radioiodine (accidently injecting patients with radioactive substances and then saying "whoops"), the hot lab door left open with 200 millicuries of technetium-99m unsecured, radioactive material tossed into the trash and buried in landfills, and sewer lines that had to be removed due to radioactive buildup. Boston University, Harvard University, and the City Hospital also burned hundreds of radioactive dogs and emitted the waste into the air across the South End neighborhood and onto the Roxbury Canal cesspool, with no abatement controls or monitoring.

The same sewers that carried bacterial counts of 790,000 to 2,600,000 per cubic centimeter in 1905 later carried NEN's radiochemical waste stream (tritium, carbon-14, iodine-125, and cesium-137) through fill that also contains off the charts levels of TCE, lead at 38,000 mg/kg, coal tar PAHs, and reactive sulfide. All of it discharging through the same outfall into the same harbor. All of it backing up into the same houses.

My CERCLA petition documents a systematic pattern of concealment by the City and the Commonwealth. The Roxbury Canal was removed from the City's own records. Geographic features were renamed (for example, a portion of the Roxbury canal was given the same name as a river in another city, "Bass River") so that searches for these sites would return incomplete and misleading results. The Commonwealth's wetland maps omit the Site. The Commonwealth claims there are no natural resources at the Site. Boston's landfills, dumps, and waste management facilities at the Site are unreported. The Commonwealth invented a "historic fill" legal exemption and applied it dozens of times at the Site to immunize itself from the federal environmental laws these actions violate.
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The City operated a municipal incinerator for over 25 years without air emission controls, creating "black rain" that fell across the South End. It refused to stop even after the EPA and the courts ordered it shut down. The incinerator ash (containing pollution like heavy metals, dioxins, and furans) was used as "fill" material for the development of buildings, including residential. This is the same ground where people now live. And Boston is currently building dense residential housing on top of all of it, again, with no mitigation and no disclosures.

I moved to Boston in late 2023. I lived in a basement apartment at Worcester Square. It was an unfinished 1864 Victorian cellar one block from the former City Hospital, directly over filled tidelands connected to the Roxbury Canal through the combined sewer system and so close that it would have been part of the high tide "cesspool." Boston's zoning code forbids basement apartments in South End and South Boston. The City granted a variance anyway in 1991. When I asked Boston for records about why basements are forbidden they claimed to have no records or documentation and to not remember why.

The apartment had no modern building envelope, legally insufficient ventilation, active water intrusion, and recurring sewage backups. The air was thick with sewer gas and hydrogen sulfide. I reported these conditions starting in July 2025. The City documented many violations (holes in the walls, crumbling walls and brick, insecure counters, cross-metering, broken floor tiles, etc.) but refused to document anything related to sewage, plumbing, ventilation, mold, or drainage. The Mayor's Office even sent a task force who confirmed the apartment was unsafe, confirmed violations while concurrently stating the City would not cite them, and then asked me why I didn't just leave — as if it were my burden to fix and/or absurd for me to tolerate conditions they refuse to condemn. 

I was sleeping 14 to 18 hours a day. I had sinus pain and rashes. My hair was falling out. My teeth were deteriorating, a chunk of my molar fell out. My body smelled like "death." 

I purchased a microscope. I was covered in bacterial growths. I identified organisms that should not exist in a residential building: Mariprofundus ferrooxydans, an iron-oxidizing bacterium first described from deep-sea hydrothermal vents; Beggiatoa, a sulfur-oxidizing bacterium whose presence proves hydrogen sulfide is reaching living space; Thioploca, which requires both nitrate and sulfide; Thiolava veneris, a pioneer colonizer of volcanic substrates first described in 2017; and cable bacteria capable of centimeter-scale electron transport that produced electrical shocks strong enough to stun me and leave my dog unable to walk for two days.

I also discovered a wall void with dissolution patterns consistent with biogenic sulfuric acid corrosion — the mechanism that destroys concrete sewers — with Beggiatoa colonizing the edges. The void functions as a chimney from the subsurface to occupied living space.  My hair samples came back substantially Gammaproteobacteria. My blood was consistent with colorful filaments and iron-oxidizing bacteria in my bloodstream — organisms that eat iron for energy, in my blood, which is iron-rich and oxygenated, which is functionally identical to their natural habitat at a hydrothermal vent. The extreme fatigue quickly improved with beef liver iron supplementation and Trametes versicolor powder for Beta-glucan polysaccharides. They organisms thrived on these substances when cultured, confirming I was replacing what they had been depleting. While scientifically validating, this is also emotionally horrifying. 

I brought samples to medical providers at Boston Medical Center, located one block from my apartment. This was the successor institution to the City Hospital, the same hospital that had been discharging infected bodily fluids and radioactive waste into the shared sewer system one block from my apartment for 160 years, the same hospital that had a decades-long epidemic of hospital-acquired infections it never explained. Clinicians examined my microscope photos of several of the organisms and their own sample under microscopy, admitted they were novel and not in existing reference materials, and refused to provide medical care, botched labs, harassed me, and intentionally mis-coded the medical visits, or didn't send it to insurance at all, leaving me with a $1k+ debit and helping drive me into Chapter 7 bankruptcy, where I am now. The hospital that helped create the conditions refused to treat the consequences, and took every action available to avoid documenting its own misconduct, obstructing witness reports, and hiding evidence of their wrongdoing. 

When the City finally cited a ventilation violation at the unregistered rental property (that there was illegally insufficient ventilation and light in the basement apartment), my landlord's partner (a person I had filed a police report against for breaking and entering and threatened assault) was permitted to appear at the City's hearing and argue that the zoning variance exempted the property owner from providing tenants with oxygen, even if I might die. When I objected and asked for his removal, City officials told me to shut my mouth, let him talk, and only speak when called upon. The City upheld the violations, cancelled the reinspection, took no enforcement action, and refused to provide me copies of the defendants petitions and communications. 

I found this baffling and it was what caused me to drop everything and start looking into the environmental conditions in this area. There had to be a reason everyone was going to such lengths to cover something up and I wanted to find out what that something was. It took two months and most of it is documented in the Petition/Notice but there was even more. In addition, I found other issues.

Like, the geology - this is the part that took me the longest to be certain about, and the reason the petition took much longer than it should have. The geological evidence in the petition presents a case that the Boston Basin is a bolide impact site — specifically, a ground-zero impact site for the Younger Dryas Impact Hypothesis, dating to approximately 12,900 years ago. If confirmed, this would be the first identification of such a site and would make the Boston Basin an irreplaceable resource for scientific research.

The evidence includes: basin-wide kaolinization of bedrock to depths exceeding 200 feet along fault-controlled pathways, requiring temperatures of 175–350°C with no volcanic or tectonic heat source in over 400 million years; a thermal decay curve from over 700°C down to below 200°C; a mineral suite that matches the predicted alteration products of an ordinary chondrite meteorite mixed with sedimentary target rock, including at least three titanium-bearing phases representing one original mineral in multiple stages of post-impact alteration; Rock Quality Designation of 0% at virtually every boring in the basin center; platinum group elements at five times background that are not decreasing after cessation of anthropogenic sources; and a damage pattern that is inverted (shallowest rock most destroyed, deepest rock least damaged) the opposite of every natural metamorphic process and exactly correct for an impact from above. 

I only found this because I had to define the geology and hydrology for my CERCLA and Clean Water Act complaint, Boston's geology and hydrology is described as notoriously "complex" and "unknowable," and most of its key features use mythological terms invented by a very questionable Harvard University professor in the mid and late 19th century insisting that anything unknown must be explained by glaciers. These Elvish-like concepts (drumlins, tillite, moraine, till, erratic boulders, etc.) have always been generalized theories often seen as contentious and debated. As time passed, especially over the last few decades, advances in science were able to put forward evidence-based explanations for many glacial-related formations and the explanations were often included causation not related to glaciers at all.

However, Boston held on to the glacial explanations with a white-knuckled grasp, and left me in an impossible situation because as a prior Engineering Program Manager and a lawyer, I refused to recite unsubstantiated glacial Elvish and ignore a significant amount of evidence (from articles, borings, assessment, etc.) that is facially impossible to explain with glaciers (for example, glaciers cannot cause heat-shock alternations because they're cold, not hot). Comparing Boston's evidence to modern impact analysis, a bolide impact explains everything that is supposedly unexplainable. Further, the Younger Dryas research advancement over the last five years and the already admitted overlapping timing of Boston's features with that timeline, confirm this isn't any bolide swarm impact zone, it appears to be the first identified "ground zero" for a Younger Dryas impact to the Laurentia ice sheet over New England and would thus validate the hypothesis. 

If true, it would also significantly change any environmental analysis, remediation planning, and risk assessment for the pollution noted above. It also would have introduced its own pollution and hazards. The impact-generated sulfide mineralogy appears to be actively producing acid mine drainage, dissolving metals from the hydrothermal ore assemblage, and discharging them into Boston Harbor via groundwater through a fracture network. If so, every conceptual site model in the basin is built on incorrect geological assumptions: the marine clay is not a reliable confining layer, the till is not glacial sediment, and the bedrock is not an impermeable base. The bedrock is itself an active contamination source that no remediation plan has ever accounted for, and the communities most affected — Roxbury, Dorchester, East Boston, South Boston — are disproportionately low-income communities of color built on the most severely impact-damaged substrate, receiving the highest flux of naturally leached metals from below. Accordingly I argued the bolide impact was also a CERCLA release and under the CERCLA petition statute, EPA will be required to assess this as an impact site (likely in partnership with USGS and NASA). 

You can sign a Change.org petition calling for an full re-assessment of the Boston Basin's geology here: Petition: A Formal Reassessment of the Geology of the Boston Basin

The petition names the City of Boston, the Commonwealth of Massachusetts, Harvard University, Boston University and Boston Medical Center, E.I. Du Pont De Nemours & Co., Procter & Gamble-Gillette, and organized crime entities operating through condominium associations at the Site (long story; go read the complaint if you have questions). The full list and the basis for each party's liability is in the petition but its just a starting point and the government has a year to investigate themselves before I'd have to take action. 

The petition requests that the EPA conduct a mandatory preliminary assessment for NPL listing, with cross-agency coordination with the Army Corps of Engineers and ATSDR. If the South Bay is not on the NPL and actively being restored to a functional marine ecosystem within one year, I intend to file a citizen suit in federal court and have a judge order them to clean up their mess.

The full CERCLA petition is available below and at DOI: 10.5281/zenodo.18634019.
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You can sign a Change.org petition supporting the CERCLA complaint here: The South Bay Needs a Superfund Investigation

I didn't want to have to write any of this. I only moved to Boston for a job - the only job offer I could get after Apple fired me. I ended up in a basement full of hydrothermal vent bacteria, teaching myself BLAST, publishing fifteen papers on evolutionary biology, and piecing together the geological history of a 12,900-year-old impact event from boring logs that nobody had ever assembled — all while litigating against Apple, navigating bankruptcy, and trying to get someone, anyone, in the City of Boston to care that I couldn't breathe in my own apartment.

What I found is that, generally, the City of Boston has been a stupid little brat about its environmental obligations for approximately two-hundred years. It filled a bay with garbage, burned radioactive dogs over the neighborhood, ran an open cesspool for a century, burned the city's trash while releasing the garbage fumes unabated and covering the neighborhood and bay with "black rain," sealed the evidence under even more garbage, removed it all from the records, renamed it so you can't find it, got the Commonwealth to invent a ("historic fill") legal exemption so you can't make them clean it, and is currently building luxury housing on top of it. When someone got hurt (when I got hurt) the City's hospital now run by Boston University refused to treat me and helped bankrupt me, and the City's code enforcement told me to shut my mouth about it. 

There have never been any NPL sites in the City of Boston.

That changed today.

Now, back to Apple. 

-Ashley 

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