Response to the Boston Globe, December 2019

Here’s what the Boston Globe published, December 1, 2019, fact-checked:

QUINCY — The sludge arrives by the ton, pumped through miles of underwater pipes from Deer Island to a waste-water treatment plant on the banks of the Weymouth Fore River, where it’s spun through centrifuges into a kind of wet cake, dried by large furnaces, and made into fertilizer pellets.

CORRECT. And the source of the sludge is all Boston residents. Management of wastewater, and the solids (sludge) that results, is not optional. It is a critical public health and environmental function. Every Boston resident and every Boston job depends on Massachusetts Water Resources Authority (MWRA) functioning exceptionally well 24/7/365. Shut down wastewater treatment, and you’re done for the day. Swimming in the harbor is possible because of MWRA, its Deer Island Treatment Plant, and the sludge management facility at Fore River.

Converting much of the region’s sewage into a valuable byproduct was a major achievement of the Boston Harbor cleanup. Over the past three decades, the fertilizer has been sold or given away in massive amounts: tens of thousands of tons a year sent to farms and golf courses, parks and gardens across the region.

“We call it black gold,” said Carl Pawlowski, manager of residuals operations at the Massachusetts Water Resources Authority, which sells the pellets in colorful 40-pound bags as Bay State Fertilizer, billed on its packaging as “The Responsible Choice for Healthier Lawns and Gardens.”

CORRECT. Supporting recycling is responsible, and this is one of Boston’s leading recycling success stories. Keeping that organic matter out of landfills avoided massive amounts of greenhouse gas emissions (methane is generated from sludge in landfills, adding to climate change). And farmers have valued Bay State Fertilizer for many reasons.

But recent tests of the fertilizer, which has been sold for nearly 30 years, have caused concern.They show levels of toxic chemicals known as PFAS, which have been linked to low infant birth weights, kidney cancer, and a range of other diseases.

CORRECT, BUT INCOMPLETE: With PFAS, levels discussed are miniscule - in the parts per trillion (ppt), the analytical lowest limit of detection in water, and parts per billion (ppb), the analytical lowest limit of detection in soils. A ppt = 1 second in 31,700 years. A ppb = 1 second in 31.7 years. Scientists can measure a lot of traces of chemicals we use in our daily lives, like PFAS, in many places. What matters is whether there is human or environmental exposure that causes harm. The traces of PFAS in Bay State Fertilizer are unlikely to affect anyone; human exposure is far greater in modern daily living environments.

And the health impacts of low, ambient background levels of PFAS are not certain. What water quality professionals are working on, however, is keeping PFAS out of drinking water, which is an important route of human exposure. The most efficient way of doing that is to phase out use of the most concerning PFAS.

The MWRA tested the material in March, after similar contamination was discovered at other treatment plants around the country. The results were alarming — the fertilizer contained more than 18,000 parts per trillion of just three PFAS chemicals. The overall amount of PFAS is probably higher, given the lack of testing for other chemicals.

MISLEADING. The levels of PFAS in Bay State Fertilizer are typical of all biosolids that are not impacted by industrial inputs. PFAS are in every biosolids in single to tens of parts per billion. (Parts per billion is the conventional way of characterizing PFAS in solids and soils, because analytical abilities only detect down to parts per billion. It is misleading to convert those ppb levels to parts per trillion and compare them to standards for water quality.)

Neither federal nor state regulators have set standards for the amount of PFAS — known as “forever chemicals” because they don’t fully degrade — allowed in waste-water sludge.

But in drinking water, the US Environmental Protection Agency recommends that municipalities alert the public if two of the most common chemicals add up to 70 parts per trillion. Massachusetts uses the same level for five PFAS chemicals.

As a growing body of research has found that the chemicals can be toxic in much smaller amounts, federal and state regulators are reviewing their standards. Massachusetts officials are poised to lower the limits in ground water and drinking water to 20 parts per trillion for six of the chemicals combined.

MISLEADING: A drinking water standard is never comparable to a soil or biosolids standard, for any contaminant of concern.

Scientists and environmental advocates have urged regulators to set standards for the sludge, also known as “biosolids,” because it can leach into ground water, get absorbed by plants, and be ingested by livestock.

“Applying biosolids with such high levels of PFAS to land risks contaminating drinking-water supplies and food crops,” said Laurel Schaider, a research scientist at the Newton-based Silent Spring Institute.

MISLEADING: Research designed to show plant uptake has shown plant uptake of trace amounts of PFAS. However, data from real-world field conditions shows very little plant uptake, especially of the more-concerning long-chain PFAS, such as PFOA and PFOS. Testing of cow feed and milk at farms in Maine and New Hampshire that have used biosolids annually for decades found non-detections for PFAS. The only potential concern with biosolids use is the possibility of traces leaching to groundwater. But biosolids is a minor potential source compared to many others. As Silent Spring Institute research has shown, home septic systems are putting PFAS into the groundwater at levels similar to Massachusetts’ proposed drinking water standards (20 ppt for 5 PFAS combined). So, before blaming biosolids, look at your own septic system - we all contribute these traces of PFAS that are in wastewater everywhere, and in all biosolids in low parts per billion. The levels in Bay State Fertilizer are typical of all biosolids that are not impacted by industrial inputs.

MWRA officials declined to answer questions about whether they should continue selling the fertilizer, but a spokeswoman said their products comply with current regulations.

“In the absence of existing state or federal standards for PFAS in biosolids, the Commonwealth, through the Department of Environmental Protection, will begin developing testing protocols and screening levels for biosolids and continuing to require entities that sell, distribute, and apply biosolid products to test for PFAS,” Ria Convery said in a statement. “Recognizing the emerging issue of PFAS contamination and the importance of ensuring public health, the MWRA will continue to test biosolid pellets for PFAS chemicals, while meeting all state and federal requirements for waste-water contaminants.”

CORRECT: Beginning in January 2019, Massachusetts DEP began imposing testing of biosolids products for PFAS. Setting appropriate screening levels for soils and biosolids is complex and has not been done in any state except Maine (where, NEBRA and others have shown, the risk calculations are flawed and not scientifically defensible).

But Schaider and others noted that MWRA’s fertilizer exceeds limits imposed this year in Maine after elevated levels of PFAS were found on a dairy farm in Arundel, which for decades used a similar type of fertilizer.

Tests of the farm’s milk showed that it contained 1,420 parts per trillion of PFAS. The owners of the farm, Fred and Laura Stone, were later found to have more than 20 times the normal amount of PFAS in their blood.

MISLEADING: Maine DEP determined that the likely cause of elevated levels of PFOS - the only chemical that caused harm at this one Maine farm - was an industrial sludge material applied on the farm in the 1980s. See the details here.

In response, Maine banned farms from using waste-water sludge that contained elevated amounts of three common PFAS chemicals. The MWRA sludge, which is trucked across the region, had more than triple the amount for one of the chemicals.

Because of exemptions in Maine’s new rules, the MWRA has been allowed to sell its sludge to farms in Maine, though in smaller amounts per acre. That has angered some environmental advocates who learned of the high concentrations from the Globe. The MWRA has done little to publicize its test results.

CORRECT, MOSTLY: Maine DEP approved Bay State Fertilizer for use in Maine. But it was not because of an “exemption.” Although it exceeded Maine’s extremely conservative screening value, risk evaluation indicated that its use over many years would not cause soil levels above the standards and would not pose any significant risk.

“It shouldn’t be sold here or anywhere,” said Patrick MacRoy, deputy director of the Portland-based Environmental Health Strategy Center, a public health advocacy group. “It should be treated as contaminated waste and disposed of in a safe way — not given to farmers and gardeners.”

COMMENT: What is “safe?” The three options for managing wastewater sludge are land application of highly-regulated, treated, and tested biosolids or landfill disposal (causing greenhouse gas emissions, wasting nutrients and organic matter and landfill space) or incineration (causing greenhouse gas emissions, wasting nutrients and organic matter, using abundant fossil fuels, and maybe putting PFAS into the air). Widely distributing tiny traces of chemicals in soils, where the are bound or leach very slowly is not any more risky than the other options. Sorry to say, there is no easy answer. Unfortunately, we are not going to get rid of all PFAS in the environment. Rather than focusing attention and huge sums of money on addressing them at the end of the pipe and disrupting important recycling programs, we should focus attention on getting them out of commerce.

The MWRA has long tested the fertilizer, which comes from the waste water of 43 communities, for pathogens and heavy metals, as federal regulators require. But it only began testing for PFAS in March — after Maine set its standards — and is screening for just three out of thousands of PFAS chemicals, many of which are ubiquitous in the environment after being used for decades in everything from food packaging to furniture.

WRONG: Data the Boston Glove reporter saw included tests of 17 PFAS. And it is misleading to suggest that biosolids are the only place all these PFAS are found: unfortunately, decades of widespread use have resulted in traces almost everywhere. Vermont background soils average less than 1 ppb to 9 parts per billion, even where there is no obvious source of the PFAS.

Since 2016, the MWRA has sold more than 100,000 tons of New England Fertilizer, the brand name it uses for bulk sales, earning the agency over $1 million. In the same time, it has sold or given away more than 1,300 tons of Bay State Fertilizer, which goes mainly to individuals, earning about $61,000.

“The MWRA does not profit from the sale of Bay State Fertilizer or New England Fertilizer,” Convery said. “The MWRA’s goal is beneficial reuse of the disposed waste.”

She added: “The successful cleanup of Boston Harbor is tied directly to the cessation of dumping sludge into the harbor.”

EPA officials declined to comment on whether the MWRA should continue selling the fertilizer but said the agency is studying the issue.

“Addressing the uncertainty around potential risk for pollutants identified in biosolids is a top priority,” said Dave Deegan a spokesman for the EPA’s New England office. “The agency will also be taking steps very soon to bolster research efforts related to PFAS in biosolids.”

Researchers are working to determine whether ingesting crops grown from contaminated fertilizer is dangerous. It probably depends on the amount of fertilizer applied and the type of soil. The chemicals can also leach into water supplies, but the amount depends on the depth of ground water and the distance to wells.

Asked about the risks of consuming crops grown with contaminated sludge, Linda Birnbaum, a toxicologist who recently retired as director of the National Institute for Environmental Health Sciences, said she had concerns.

“I wouldn’t want to use the more highly contaminated samples,” she said.

CORRECT: Dr. Birnbaum is a leader in raising concerns about health impacts of PFAS, and she points to “highly contaminated samples” of biosolids fertilizer as a concern. Bay State Fertilizer is not ‘highly contaminated.” It has typical to somewhat below average levels of PFAS compared to other biosolids from wastewater that is not industrially impacted. There are rare cases where large industrial inputs to sewers have caused highly contaminated biosolids, and those situations have been or are being addressed by stopping those industrial discharges.

Linda Lee, an environmental chemist at Purdue University, has tested sludge from treatment plants around the country, including from the MWRA, where she found that Bay State Fertilizer contained 34,000 parts per trillion of more than a dozen of the chemicals.

At this point, however, she doesn’t think such fertilizers should be banned.

Reusing the sludge is preferable to dumping it in landfills or burning it in incinerators, which increase carbon emissions and could disperse it over large areas if released through smokestacks.

The best solution is to remove PFAS from consumer products, she said.

“These compounds are persistent, and they can cause adverse effects,” she said. “But we should also be concerned about the unintended consequences of overreacting.”

Officials at the North East Biosolids & Residuals Association, a trade group that represents the sludge industry, said the MWRA should continue selling its fertilizer, citing a National Academy of Sciences study in 1996 — conducted when few understood the dangers of PFAS — that found sludge use on soils presents “negligible risk.”

“Biosolids recycling is a significant part of making communities sustainable,” said Janine Burke-Wells, the association’s executive director.

But environmental and public health advocates said the risks of exposure to PFAS chemicals outweigh the benefits of recycling the waste. They also note that in 2018, after scientists established that even minute amounts of PFAS can be harmful to human health, the EPA’s inspector general told the agency that it shouldn’t rely on the outdated National Academy of Sciences report and that it should recognize more studies were needed.

COMMENT: That EPA inspector general report was flawed and was strongly contested by EPA’s Office of Water. See NEBRA’s coverage. We agree that ongoing research is a good idea.

Kyla Bennett, science policy director of the Public Employees for Environmental Responsibility, a Washington-based advocacy group, said it “defies logic” that the state recognizes the threats of PFAS while “simultaneously selling the exact same chemicals to be spread across farms, backyards, and golf courses throughout the state.”

“We need to pause and figure out a better answer,” Bennett said.

On a recent tour of the MWRA’s sprawling treatment plant in Quincy, where the sharp smell of ammonia fills the air, Carl Pawlowski acknowledged the concerns.

He compared PFAS to DDT, another toxic chemical that doesn’t break down easily and has had major environmental and health consequences. Standing beside four tanks that each hold a million gallons of the so-called black gold, he said he hoped federal regulators would place stricter limits on PFAS chemicals, reducing the amount produced.

Asked if he thought the state should be selling the fertilizer, Pawlowski appeared conflicted and weighed his answer carefully.

“At the end of the day, I just don’t know,” he said.

FINAL COMMENT: The Globe story was intended to raise concerns about biosolids. It has stimulated interest and discussion, and those of us working on biosolids management welcome that. We hope the Globe will aid that discussion with further coverage of other aspects of the biosolids story. It is important to inform the public about the relative risks of exposure to PFAS via biosolids versus our every day living environments. And we share the goal expressed by the environmental groups quoted in by the Globe: phasing out the most concerning PFAS should be the priority.