The Coalition of Recyclers of Residual Organics by Practitioners of Sustainability (CRROPS) was created in early 2022 to lobby for the concerns of receivers of PFAS including water and wastewater utilities and landfills and especially concerns for how PFAS is impacting these public utilities and beneficial recycling programs. On February 9th, CROPPS teamed up with the Association of Metropolitan Water Agencies, the American Water Works Association, the National Association of Clean Water Agencies, the Orange County Water District, Purdue University, and the Water Environment Federation, for an important congressional PFAS briefing to examine the implications of PFAS policymaking. The briefing was held in the Senate Committee on Environment and Public Works hearing room in Washington D.C.

CRROPS designed the briefing to ensure that congressional staff tasked with advising Members of Congress have the benefit of knowledge of the water sector’s efforts to ensure that the public and environment is protected, while preserving management practices that leverage the resource value of biosolids.  The briefing covered a range of topics including the underlying science of PFAS, the need to recognize that PFAS exposure through water sector activities is minimal, including biosolids, and that any responsibility for PFAS cleanups must reside with manufacturers of PFAS and not passive receivers, like public agencies and related contractors.  According to CRROPS, congressional staffers seemed open to considering these issues as legislative proposals are developed this year.

Here is a summary of the briefing from Northwest Biosolids (LINK): 

Dr. Linda S. Lee, Professor of Agronomy, Purdue University explained how PFAS was developed over several decades.  In the course of the discussion, Lee noted that the presence of PFAS is ubiquitous in the environment, and that the actual pathways of exposure needed to be understood to ensure that any policies addressed the key sources of PFAS exposure.  She closed by stating that it is imperative that PFAS be regulated to eliminate nonessential uses and to ensure that we focus on source control.

Maile Lono-Batura, Director, WEF Biosolids Program, presented an overview on how biosolids are treated in compliance with federal and state standards.  She emphasized that PFAS properly addressed do not pose a threat to crops through uptake.  She highlighted that the dialogue is missing key issues such as the value of resource recovery that is biosolids.

Holly Kiser, who is a full-time farmer in Maryland, noted that they are stewards of the land and that they work to make certain that their use of biosolids conform and comply with all applicable standards and allow important nutrients to be returned to the environment. 

Chris Peot of D.C. Water/BLOOM noted that D.C. Water has successfully treated and produced a high quality biosolid that is used safely for landscaping and agricultural purposes.  On the issue of crop PFAS take-up, science has illustrated the reality that biosolids were not a problem.  In fact, he cited science documents that 80% of PFAS exposure is in the home.  He noted that the science needs to guide controls because the costs of compliance are significant.

Chris Moody, Regulatory and Technical Director, American Water Works Association discussed the challenges of developing and implementing PFAS standards.  In closing, he noted that PFAS is not used in water treatment and that as industry produces changes in the PFAS chemical chain, the challenges will grow.  He pointed to the need for source control. 

Dan Hartnett, Chief Advocacy Officer, Association of Metropolitan Agencies, highlighted the role that drinking water agencies serve the public by protecting public health.  In his remarks, he highlighted the challenges of holding producers of PFAS responsible.  The simple solution is to provide a narrow and specific exemption (for receivers) under Superfund if Congress considers legislation. He noted that Congress has provided such exemptions in the past.

Jason Dadakis, Executive Director Water Quality and Technical Resources for the Orange County (California) Water District, provided an update on the efforts required to address actual PFAS contamination of a groundwater supply.  He cited his agency’s commitment of resources to protect the public.  For the last several years, he noted that his agency detected PFAS in the groundwater basin.  He closed by noting that Congress has provided exemptions for others like Brownfields. This same consideration needs to be provided to water agencies, he emphasized.