How much PFAS is in Madison Metropolitan Sewerage District (MMSD) sludge, applied to 5000 acres of Dane County farmland?
From MMSD’s (TRC) Sept. 30, 2021 report:
- MMSD Class A Biosolids: 35,000 ppt (parts-per-trillion) PFOS/PFOA combined; 169,600 ppt total PFAS
- MMSD Class B Biosolids: 11,600 ppt PFOS/PFOA combined; 75,900 ppt total PFAS (2nd duplicate)
- See footnote [1]
Wisconsin’s proposed groundwater standard for PFOS/PFOA combined? 20 ppt
PFAS, per- and polyfluoroalkyl substances, are so persistent in the environment they are called “forever chemicals.” They are associated with a long and growing list of health problems in human and/or animal studies: immune system dysfunction, reproductive problems, infertility, kidney and testicular cancer, liver disease, obesity, increased cholesterol, pre-eclampsia (hypertension) in pregnancy, decreased infant birth weights, birth defects, development problems, and more. A recent study associated PFAS with lower sperm counts and smaller penises in young men. They are potent hormone disruptors.
But not to worry! Martye Griffin, MMSD’s Ecosystem’s Services Director, assured Wisconsin State Journal reporter Chris Hubbuch that nobody is exposed to the utility’s PFAS: “Just because we’re pumping out PFAS does not mean there’s an exposure risk,” he said.[2]
Really? So we are to believe that none of the tens of thousands of parts-per-trillion of PFAS in the sludge spread on farmfields here for decades have seeped into the groundwater and people’s shallow drinking water wells near these fields?
In fact, MMSD’s own report says: “The Maine Department of Environmental Protection (DEP) has established screening levels for beneficial use of solid wastes for PFOS (5.2 ug/kg), PFOA (2.5 ug/kg)… which are based on the leaching to groundwater pathway (Maine DEP, 2018).” These levels–5.2 ug/kg and 2.5 ug/kg–translate to 5,200 ppt and 2,500 ppt.) Clearly, the amounts of PFAS in MMSD’s sludge significantly exceed these levels–and their report actually admits that.
What are the PFAS levels in Dane County fields where MMSD sludge has been applied year after year? What are the PFAS levels in the groundwater beneath these fields? In private wells near them? Nobody knows, because nobody has measured. The national Sierra Club and Ecology Center report “Sludge in the Garden: Toxic PFAS in Home Fertilizers Made From Sewage Sludge”–cited in the Sept. 30 MMSD report–says: “Since the chemicals do not break down in the environment, levels in farm fields will slowly increase every time more biosolids are applied to a piece of land.” [3]
This PFAS doesn’t only seep into groundwater and drinking water–it is also taken up into crops, cows that eat the crops–and eventually, people who eat these crops and/or dairy products and meat from cows that ate them. As a recent Guardian story about the Sierra Club study said: “Spreading biosolids or sewage sludge where we grow food means some PFAS will get in the soil, some will be taken up by plants, and if the plants are eaten, then that’s a direct route into the body,” citing Gillian Miller, a co-author and senior scientist with the Michigan-based Ecology Center.
PFAS chemicals in farmland soils also run off into nearby rivers, creeks, and lakes–where they build up in fish that people eat–especially subsistence anglers, often low income people of color.
Yet at the Sept. 30 MMSD Commission meeting to “study” these PFAS results, MMSD commissioners, including Ezra Meyer of Clean Wisconsin, raised no questions or concerns about the implications of the district’s sludge PFAS levels for public and environmental health. It was not discussed at all. Other than my questions submitted during the meeting in the Zoom chat, absolutely no members of the public–and no environmental groups–commented on these MMSD PFAS results. Nada.
Apparently nobody cares.
Is environmentalism totally dead in Madison?
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[1] This was single point-in-time testing–in other words, only a snapshot and not representative of the full range of levels in biosolids over different seasons and from different batches of sludge. Also, importantly, the methods MMSD used were not the most sophisticated, state-of-the-art PFAS analytical methods currently available, and likely significantly underestimated the PFAS levels.
The Sierra Club report cited in the MMSD report found that Milorganite, a commercial home-fertilizer product made from 100% Class A biosolids from Milwaukee’s sewerage treatment plant, had 670 ppt PFOA and 8,660 ppt PFOS in it, and total PFAS levels of 49,000–significantly less than the PFAS levels in MMSD’s Class A and Class B sludge. Why would a heavily industrial city like Milwaukee have lower PFAS levels than Madison’s in its sludge?
[2] Only someone who is completely ignorant of ecology, fate and transport of chemicals in the environment, biomagnification and bioaccumulation would make this claim. Mr. Griffin, a former DNR water policy manager with a Masters of Science, is not ignorant of this well-known science–he is just repeating these common wastewater industries’ public relations talking points–“there is no risk to the public!” because that’s what his MMSD supervisor Michael Mucha, utility attorneys, and public relations staff at MMSD directed him to do.
[3] MMSD could have applied to participate in this UW State Lab of Hygiene project, which would have involved much more accurate and comprehensive state-of-the-art analyses of their influents, effluents, biosolids, farmland that had applied MMSD sludge, and groundwater/surface water nearby–at no cost. The objectives of this study included (from the linked powerpoint, pg. 22):
“(1) Provide a critically needed assessment of the presence and persistence of PFAS compounds in municipal biosolids impacted agricultural fields foundational information that is currently lacking.
(2) Provide new information on the impacts of land spreading of municipal biosolids on soil water and shallow groundwater.”
By now, MMSD could have had much more accurate results like these for its influents/effluents and biosolids. But MMSD declined to even apply to participate in this project. Why? Among other reasons, MMSD likely wanted control over the analytical methods used, what was tested and not tested, the timing of the testing and public release of results, the interpretation of the data–and did not want the data to be publicly accessible.
