Administrative, Testing, Landfilling Costs are Among the Results of Crackdowns on PFAS

An industry study finds PFAS regulations having substantial impacts on clean-water agencies’ beneficial biosolids reuse programs.

Administrative, Testing, Landfilling Costs are Among the Results of Crackdowns on PFAS

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PFAS is topic of significant public concern and a challenge for municipal water and wastewater utilities charged with protecting public health and the environment.

Biosolids management programs have seen substantial impacts from new regulations, including rising costs, administrative burdens and negative public perceptions of land-applied products. Some states have imposed regulations that in effect ended beneficial use programs.

To gain a better understanding of the financial and other impacts of PFAS on biosolids programs, the Water Environment Federation collaborated with the National Association of Clean Water Agencies (NACWA) and the North East Biosolids and Residuals Association (NEBRA) on an in-depth survey of affected facilities. The CDM Smith engineering firm conducted the survey.

The survey team contacted water resource recovery facilities, residuals haulers, biosolids land appliers, and facilities dedicated to incineration, composting, landfilling and agriculture, asking for detailed information on the cost and operational impacts from PFAS policies and regulations at the federal and state levels.

The team spoke with staff members at 29 solids management facilities or operations, choosing participants based on impacts from PFAS policies they expected or had experienced. Based on the data provided, the average biosolids management cost increased by about 37%, although the impacts varied greatly with the type of biosolids management, geographic location, and other factors.

Eric Spargimino, chair of the New England Water Environment Association Residuals and Biosolids Committee and a project manager and biosolids specialist at CDM Smith, talked about the survey in an interview with Treatment Plant Operator.

What was the motivation for conducting this survey?

Spargimino: WEF, NACWA and NEBRA realized that their memberships were seeing more and more impacts from PFAS, especially related to managing biosolids. The U.S. EPA several years ago put out a health advisory level related to drinking water. Since then, some states have seemingly engaged in a race to zero in imposing PFAS limits on biosolids. So they all saw a need to look holistically at how much costs have gone up and what the unintended consequences are of these regulations.

What was the essential purpose of this study?

Spargimino: We wanted to put something in front of regulators, politicians and the public saying: Let’s pause for a minute, because while we need to protect public health, we also need to make sure any regulation is based on facts and on science. We can’t just race to zero because PFAS are harmful. We have to respond based on all the available science and research, so that we’re not detrimentally affecting beneficial reuse programs and all the environmental benefits that are happening because of land application.

What was the geographic focus of this study?

Spargimino: We tried to get a sampling of states that have been impacted by PFAS. New England and the Mid-Atlantic states are ahead of the curve because their regulators have been more aggressive. So many of the survey participants are in those states, but we did reach out to California, Arizona, Michigan and some other states.

What channels did you use for gathering information?

Spargimino: Mostly we used email and phone interviews. Between NEBRA, NACWA and WEF, we have a very strong network, and CDM Smith has a very strong client network throughout the country. We tried to call on all our connections to help get feedback and make everyone comfortable that this report was designed to help us, as water and wastewater engineers and stewards of the environment, in educating the public and regulators. We had to get over the hurdles of: Why do you want to know this information? Who is asking? Once we did, everyone was incredibly helpful, and we got some really great responses and feedback.

How strict have some of the state PFAS regulations been?

Spargimino: Maine led the pack by putting a moratorium on land application of biosolids. That impacted the whole state. Since then they have had the various programs test their biosolids for PFAS, and on that basis some have been allowed to continue land-applying. They have also implemented screening levels that have helped a couple of programs get back up and running and continue beneficial reuse.

What other approaches have states taken?

Spargimino: Vermont has established background levels of PFAS. They’ve said: Our background PFAS soil concentration is X, so if your biosolids level is less than that, it may be safe to continue to land-apply. Maine has established screening levels that are a little different. Instead of looking at it the same as a drinking water limit where people have direct exposure to the material, they acknowledge that with biosolids the risk is contact with the skin, or that a toddler might eat a handful of soil. So the limit is an order of magnitude higher than what you would expect to see in a drinking water limit.

To what extent do you feel these restrictions are justified scientifically?

Spargimino: There is a lot of great research going on right now. CDM Smith is doing a handful of projects with the Water Research Foundation, one of which is looking at the fate and transport of PFAS in the wastewater treatment plant, looking to identify how it gets from the influent side of the plant to the effluent and biosolids side.

What about the fate of PFAS in the environment after land application?

Spargimino: We’re doing another project looking at the leachability of PFAS from land-applied biosolids — how it moves in soil column and leaches into the groundwater or is taken up by plants that a person or an animal might eat. There’s a whole body of research being done right now into those exposure pathways.

Have these projects yielded any meaningful findings so far?

Spargimino: There are some findings that the longer-chain molecules tend to stay in the soil column; the shorter chains migrate farther down. The farther down you go in the soil column, depending on the molecule, the more it gets hung up, so not all of it ends up leaching down.

What have you learned about the behavior of PFAS in treatment processes?

Spargimino: Different PFAS molecules partition in different ways. Because some of the PFAS molecules tend to go to the air-water interface, then possibly there is a way to skim it off the surface. That may be more cost-effective than trying to treat the effluent or treat the biosolids before it goes to beneficial use.

How would you describe the impacts of PFAS regulations on costs and administration of beneficial reuse programs?

Spargimino: We interviewed some communities where the costs went up 300%. Some were applying biosolids on a farm adjacent to their plant, and now they’re hauling it up to Canada. That was one side of it. But then there are the unintended consequences. Land-applying on site significantly reduces greenhouse gases and sequesters carbon from the atmosphere. But if you’re trucking it to faraway places, or putting it in a landfill, or incinerating it, all those generate more greenhouse gases.

What has happened to community acceptance of biosolids as a result of PFAS?

Spargimino: Some of these biosolids products go to farms, and it’s how some small farms are able to survive, because biosolids is a very low-cost fertilizer. In some cases the farms just had to stop taking it because of the perception of the community. And their cost to operate went up because now they had to buy synthetic fertilizers.

Have concerns about PFAS affected any consumer-based composts and other biosolids products?

Spargimino: I haven’t seen any quantification of that. I know qualitatively that some folks have stopped taking it and putting it on their lawns in residential areas. I’ve heard of some compost facilities that are now putting all their biosolids material in landfills instead of distributing to the community. In the U.S. we have limited landfill capacity, and now our biosolids and composts are going to landfill because there isn’t as much a demand for them anymore.

Are there costs to the PFAS regulations beyond trucking and landfilling?

Spargimino: Yes. For example, Michigan and Massachusetts require sampling of biosolids for PFAS. The EPA just published a letter recommending to each state that they implement PFAS monitoring and best practices. Analysis of samples for PFAS is definitely not cheap. Not all labs are capable of doing it, and since there is no EPA-approved method, the validation of any data is really difficult.

How would you characterize the way survey respondents were feeling about PFAS and the regulations?

Spargimino: Overall, folks were anxious to get guidance. Every state is acting independently right now, and utilities are frustrated that there hasn’t been a lot of guidance from the EPA. There seems to be a race to the bottom for who can regulate the tightest and the lowest. The frustration is that we need to make sure any regulations are science-based. We want to make sure that we’re protecting human health, but we need to do it appropriately.

Beyond the cost impacts of PFAS, what would you say are the key take-aways from this survey?

Spargimino: States that don’t have regulations right now and only have monitoring are not seeing dramatic effects financially, but they know the writing is on the wall, and so they are putting in tremendous man-hours to get prepared and to educate and work with their regulatory agencies. One of the biggest take-aways is that community education needs to be a big part of this. PFAS contamination starts with us, the consumer. PFAS is in a lot of great products, and so through education of the public we can start to influence change in how we use these products responsibly, while we wait for the science to catch up.

Are any manufacturers starting to phase out certain PFAS compounds?

Spargimino: Yes. EPA has taken steps toward limiting some of these products — their use and manufacturing and what can be brought into the country. Over the last couple of years we’ve seen PFAS concentrations in wastewater and in people’s blood reduced with some of these efforts. The improvement is already there. We just need to keep doing it.

Have any of these substances been banned or restricted?

Spargimino: I believe some of the PFAS compounds have been phased out, at least in the U.S. They’ve been replaced by other compounds with similar benefits to the consumer, but the science is still out on their toxicology. Are we going to ban one product and replace it with something worse? Firefighting foam is another issue. The Federal Aviation Administration still requires it to be on site and used at airports. That is one of the more harmful PFAS compounds, but it’s also very effective at fighting fires. Should we have a foam that’s not as effective at fighting fires, or one that is better for the environment?

What advice would you give to a utility or a biosolids program manager about dealing with PFAS and related issues?

Spargimino: I would say be proactive. Gauge your community early and start educating. Work with your regulators. Let them know the impact it would have if you could no longer land-apply biosolids, so that they get a well-rounded picture. Work with your politicians to help fund the research programs that are ongoing. Be transparent with your community about the implications and potential costs of PFAS. As operators and sanitary engineers, we’re the original environmentalists. It’s our job to protect the environment, so we want to make sure that PFAS is taken care of appropriately. That means continuing all the benefits of land application and beneficial reuse programs, with regulations founded in science.   


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