Epidemiologist Seeks Grant to Test for Pfas

By Kathleen Cooper December 17, 2024- 

In spite of the continued lack of interest in the health of Wisconsinites that have been impacted by PFAS by our state legislators (who have been withholding funds budgeted for PFAS mitigation for the past year and a half), OCCWA has good news that has nothing to do with our state government. Amy Schultz, a scientist at UW Department of Population Health Sciences and Epidemiology Senior Data Scientist, contacted OCCWA for introductions to the Oneida County Health Department and the people in Stella.

   Dr. Schultz is in the process of writing a grant submission to the National Institutes of Health (NIH) for a community-based research project to quantify human PFAS exposure and community-level risk for the residents of Stella. As previously stated on the OCCWA website, the Town of Stella was found to have the highest PFAS levels in their groundwater, and consequently in their private wells, of anywhere in Wisconsin. This study will consist of a community-based participatory research approach which will recruit interested Stella residents, who consent to have blood samples taken to detect PFAS levels in their bodies. Dr. Schultz has proposed setting up a 12-day phlebotomy clinic at a community site in Stella where residents will have blood drawn to test for PFAS levels, a test that would normally cost $400-$600. Residents who agree to have their blood tested (for free) will be paid $40. Individual results will be shared with the volunteer participants via mail, and aggregate results will be shared at the Stella Town Hall, in keeping with the privacy of the participants. After the blood tests are completed, 40 participants who had the highest PFAS blood levels will be offered an at-home visit where PFAS levels will be tested in their home environment. These at-home participants will be paid an additional $20.

   The purpose of this study is to learn of human exposure to PFAS and PAP’s (which are newer chemicals intended to eventually replace PFAS), to learn of community level risks in Stella compared to the general population, to learn of PFAS in garden and outdoor soil and household dust, and to learn of additional ways to limit exposure.

   Participation is optional, but the study is seeking 160 people to participate. These participants will receive updates regularly or as requested, of the findings and final report. Interested participants will be offered the opportunity to serve on the Stella Study’s Advisory Board, guaranteeing local involvement.

   This study has limited scope and outreach, but once completed can open the way for additional studies, both locally and statewide, so that we can finally understand the scope of the problem of PFAS contamination, the health consequences of high blood PFAS levels, and possibly may persuade our state legislators to finally release the state funding that they have budgeted for PFAS testing/remediation. Perhaps they will even allocate more money in the next budget session! I know, I am a serial optimist, but I can dream, right?

   Many thanks to Dr. Amy Schultz for her interest in and compassion for the rural residents of our state. Also thank you to our Oneida County Board of Health Committee for being proactive on this matter. Last but certainly not least, we at OCCWA would like to acknowledge committee member and Stella resident William (Casey) Crump for his valuable input and commitment to his community on this issue.

Link to Power Point presentation of study overview- https://uwmadison.box.com/shared/static/3jhvxsiev01zm8jp5niaolxhy73iedb2.pdf

Related OCCWA Q&A with Wisconsin DHS following May 1st Stella PFAS meeting 

After the May 1st meeting presented by the Wisconsin DNR and Wisconsin DHS addressing the Stella PFAS contamination, OCCWA asked a few questions we felt were not addressed. The questions asked are directly related to the current proposed study. Those questions and answers are posted below.

• Question- Does the DHS recommend residents of Stella to have their blood tested for PFAS?
  • DHS Answer- DHS does not currently broadly recommend blood testing for PFAS. Blood PFAS levels do not give actionable data yet—for now, we can only compare levels to national averages, we cannot estimate risks for any specific health effects. If individuals are concerned, they can talk with their healthcare providers about whether blood testing would be appropriate—ATSDR has factsheets that address this for both residents and clinicians.
• Question- Is there any financial assistance from the DHS or the State of Wisconsin for blood testing?
  • DHS Answer- DHS does not have funding available to support blood testing at this time.
• Question- Does the DHS recommend cancer screenings and what level of PFAS exposure warrants it?
  • DHS Answer- DHS recommends that all Wisconsin residents follow recommended cancer screenings, regardless of PFAS exposure.  At this point, DHS is not recommending additional screenings.
• Question- Does the DHS or any federal agency plan on any historical medical comparisons of Stella residents to non PFAS contaminated communities.
  • DHS Answer- There are not currently plans or resources to investigate a medical comparison. The Agency for Toxic Substances and Disease Registry (ATSDR) has conducted some health and exposure studies nationwide and has information available on their website.
• Question- Has the DHS studied AMA tracking of PFAS related illnesses in Oneida County and how they rank historically statewide?
  • DHS Answer- DHS does not have the resources available to conduct an investigation into health impacts/illnesses at this time.

 OCCWA Commentary: In three of the five DHS answers they reference " do not have the resources" (money) or "does not have funding available" (money). This in a state with a $4.6 billion budget surplus and a $1.9 billion rainy day fund. Oh, and by the way, for the last year and a half the legislature can't seem to find a way to release the measly $120 million dollars for PFAS relief for impacted citizens across the state. Though extremely grateful for any beneficial information garnered from the Stella proposed study, one has to ask, what are our legislators thinking?

Posted 12/5/2024- Epidemiologist solicits letters of support for a grant proposal to measure PFAS in Stella residents. Dr. Amy Schultz an environmental epidemiologist & researcher at UW-Madison is seeking local letters of support for her submission of an NIH grant proposal to measure PFAS in Stella residents (serum samples). Dr. Schultz has been added to the meeting agendas of the Oneida County's Board of Health Committee and the Stella Town Board. Both meetings will be held on Monday December 10th, 9am for the Board of Health meeting and 5:15 pm for the Stella meeting.  Below is an excerpt from Dr. Schultz' Aim Statement.
"In late 2022, the Wisconsin Department of Natural Resources discovered some of the highest drinking water levels of PFAS in the country. In Stella, a town in the northern woods of Wisconsin, PFAS levels as high as 36,000ppt were measured in private wells, with overwhelmingly high PFOA - greatly exceeding the EPA’s health advisory of 4ppt in drinking water for PFOA. Sludge from the local paper mill, a suspected source, showed low levels of PFAS. The source of the exposure has yet to be determined, and no human sampling has occurred. There is an urgent need to measure human exposure in the community and determine what ongoing exposures are still occurring from water and non-water sources. While many community members have switched to drinking bottled or filtered water since learning of the contamination, the long half-life of PFAS in humans allows for a limited but important window to measure historic exposure to PFAS. We hypothesize human exposure in the community is orders of magnitude higher than statewide levels for PFOA, and community members continue to be exposed to PFOA and other PFAS through water and non-water sources from historic and recent spreading of industrial sludge and the biotransformation of PFAS precursors.We propose the following aims:Aim 1: Implement a community-based participatory research approach. A community advisory board (CAB) will be formed of community members and meet bi-monthly to inform the research process, and advise on recruitment, return of results, and policy implications of findings. The community will be updated quarterly at town hall meetings and via mailed and online newsletters.Aim 2: Quantify and characterize PFAS exposure. We will measure serum PFAS levels in a sample of Stella residents (n=160), compare existing statewide levels (n=605), and characterize by household proximity to historic sludge spreading, waterways, drinking water levels, dietary behaviors, etc. Aim 3: Evaluate sources and routes of ongoing PFAS exposure. Among the highest quartile of PFAS exposure (n=40), we will (a) quantify PFAS in household drinking water, dust, and outdoor soil, (b) examine associations between environmental PFAS and human serum PFAS levels, and (c) what PFAS precursors (i.e. PAPs) in the environment are a source of human PFAS exposure.Impact: This study will inform residents of their PFAS exposure, ongoing sources, and how to reduce exposure. It will also inform local and state officials of ongoing sources of human exposure in the environment, and whether future monitoring or regulations should consider unique PFAS precursors."  At Oneida County Clean Waters Action, we are dedicated to promoting environmental awareness and protecting our planet. We believe in sustainable living and strive to help individuals and communities make more eco-friendly choices. Our organization was founded in 2005 and has since been working towards a greener future for all.

 ** Update ** posted 12/12/24- Oneida County Board of Health Committee and Stella Town Board supply letters of support for PFAS study grant. On December 10th, both the County Board of Health and Stella Town Board meetings considered the letter of support request for a grant to study PFAS levels in Stella residents' blood. (See study's Aim Statement in original post) Both the County and Stella's Town Board agreed to sign letters of support for the potential study.  With the local letters of support as well as letters of support from the DNR and Department of Human Health Services in hand, epidemiologist Dr. Schultz will apply for an NIH grant to fund the project.  For those who were not able to attend either of the meetings, Dr. Schultz has provided a link to a PDF of her Power Point presentation from the Tuesday meetings below. https://uwmadison.box.com/shared/static/3jhvxsiev01zm8jp5niaolxhy73iedb2.pdf OCCWA will share updates on the progress of the grant process going forward.

By Eric Rempala June 4th, 2024- To be sure the DNR has been quite busy addressing PFAS across the state. When they last met with Oneida County residents (See our May 2nd post) they were unable to address all of OCCWA's and residents pre-submitted questions. To that point the DNR has most graciously answered those questions and provided answers by email, which we share with you below. Reviewing these questions, we hope, will give a much more complete picture of where the PFAS issue in Stella stands. 

  Once again, we have to compliment the DNR for their timely and professional response. 

1) Has there been any determination on which biosolid is most likely for the contamination, municipal wastewater treatment plant or Industrial?

  No, not at this time. The DNR has not determined the source(s) of the contamination.

2)   Are there any plans of testing soil in the Stella area?

  The DNR is currently working on a plan to collect limited soil samples from fields in the Stella area where land spreading occurred, as well as deeper soil samples to assist in understanding the migration of PFAS.  This work will be conducted under an EPA Site Inspection plan which gathers information for the EPA Superfund scoring process. The sampling will take place in late summer or the fall of 2024.

 3) Any thoughts on soil remediation, such as soil replacement or phytoremediation?

  It is too early in the process to determine a remedy for soil contamination. The degree and extent of soil contamination needs to be assessed prior to determining a remedial action approach for soil. 

4) Is there any consideration for providing a one source community well?

  A community drinking water system sourced by its own groundwater source(s) or connected to an existing community water system could be a potential solution. The feasibility of this as an option would depend on a variety of factors such as engineering viability, cost, and public will. For this option to be viable, a municipal entity would be the primary entity to propose, construct and manage ongoing operation, maintenance, and overall future fiscal responsibility. Currently the Bipartisan Infrastructure Law can provide some funding for the potential development of community water system in rural PFAS impacted areas.  

Since Stella already has exceptionally high PFAS levels, is there any consideration to banning biosolid spreading that has any PFAS content?  

5) No, not at this time. There are no current federal or state standards regulating PFAS concentrations in biosolids or industrial sludge. The department has developed an Interim strategy for land application of biosolids and industrial sludges containing PFAS PFAS_BiosolidsInterimStrategy.pdf (wisconsin.gov)  to assist facilities in making decisions on handling biosolids and industrial sludge. 

6) Does the DNR have the pre-1996 paper records of certified spreading in Oneida County?

  No, the department does not have these records.  

7) Is there any plan to offer free well testing to areas that may be suspected due to biosolid spreading records evaluation?

  The DNR continues to seek and request additional resources to potentially expand PFAS sampling for those who may be impacted. The DNR submitted a 13.10 request to the State Legislature’s Joint Finance Committee that would allow the DNR to access the $125 million PFAS Trust Fund. If granted access, the DNR would distribute funding to counties and local communities to support sampling efforts in impacted and potentially impacted communities across Wisconsin.  

8) Can surface water testing be effective in identifying hot spots in county if there is a lack of volunteered well testing options?   

 Surface water testing can sometimes be used to identify potential areas of contamination, but not always. Typically, surface water testing is combined with other lines of evidence (groundwater sampling, soil sampling and historical land use information) to identify areas or potential areas of contamination.   Generally, groundwater flows into surface water, so if results from a lake surface water test come back high, that could be indicative of a hot spot.  A low result from the lake surface water test, however, would not necessarily mean wells in the area are safe. Groundwater flow paths due to varying geology can be complicated, and it should not be assumed groundwater flows in the direction towards the closest waterbody. The DNR is aware of several sites in the state where wells are contaminated, but nearby surface water concentrations of PFAS are low since the groundwater is not flowing in the direction of the nearest surface water.   

9)Would DNR consider offering free PFAS testing to Oneida County Lake Associations?       No, not at this time. The DNR has sampled waterbodies throughout the area at sites that we have determined to be high priority. Additional sampling will occur in 2024. The information gained through this sampling will help to define and determine the extent of the area of contamination in surface water. 

10) Have all Oneida County municipal WWTP's had their sludge tested for PFAS?

  No. PFAS sampling is included in Wisconsin Pollutant Discharge Elimination System (WPDES) permits as they are reissued. It may take up to 5 years for all facilities in Oneida County to have PFAS sampling requirements for sludge included in their permits.

11) Does the DNR have an opinion on the recent Oneida County PFAS Resolution?

  The DNR continues to utilize a public health-led approach to address PFAS in Wisconsin, which includes gathering and sharing information about PFAS presence in drinking water. The DNR has been made aware of several counties that have conducted outreach to private well owners to inform and/or encourage sampling, and in some cases has provided access to free or subsidized sampling and analysis.  

(12) When contamination impacts a community, it requires coordination and cooperation across units of government to help mitigate the risk to human health and the environment. The DNR submitted a 13.10 request to the Joint Finance Committee that would allow the DNR to access the $125 million PFAS Trust Fund. If granted access, the DNR would distribute funding to counties and local communities to conduct sampling, disrupt exposures and begin to work on mitigation.  

13) Also is there any consideration to speeding up the process to stop any excessive PFAS biosolid spreading sooner?

  It is unclear what process is being referred to. The department will update the Interim Strategy as new information becomes available. EPA is currently conducting a Risk Assessment related to PFAS in biosolids. EPA uses Risk Assessments to characterize the nature and magnitude of health risks to humans and ecological receptors (e.g., plants and animals) from chemical contaminants and other stressors. The EPA is scheduled to complete the Risk Assessment for PFAS in biosolids at the end of 2024.  

14) Are permits still being issued for sludge/sewerage dumping?

  Land application of municipal biosolids, industrial sludge and septage is still allowed in accordance with Wisconsin Pollutant Discharge Elimination System (WPDES) permits and septage licenses.  

15) How long are sludge/sewerage permits good for? Can these permit time lengths be shortened?

  Wisconsin Pollutant Discharge Elimination System (WPDES) permits are issued for 5 years. There are procedures in code for revoking and reissuing or modifying permits. Shorter permit terms are also  allowable under code.  Who monitors sludge/sewerage dumping and how often?  Facilities are required to monitor and self-report to the Department. Reporting is done on an annual basis

16). Can contaminated soil be treated?

  Current treatment options for PFAS are mostly limited to situations when PFAS is in water. Groundwater that is in contact with soils can be treated for PFAS. If unsaturated soils contain PFAS contamination, these soils can be excavated and disposed at a licensed landfill or, in some situations, the excavated soil is incinerated.    

17) Can contaminated stream/lake water be treated?

  Contaminated water can be treated to remove PFAS; however, in most situations, the water must be captured and run through an engineered treatment system. Thus, the size of the water body, flowrate of  the stream and how the stream or lake are connected to groundwater will influence how effective  treatment will be at improving water quality in the lake or stream.  Treating surface water is more  applicable in small defined areas like a localized spill with a very small defined outflow that can be  handled by a granular activated carbon (GAC) bed. This would likely not be a practical approach for large  waterbodies, rivers, and extensive areas of contamination. 

By Eric Rempala February 16, 2024- In a recent discussion with the DNR Oneida County Clean Waters Action was able to confirm that the DNR has completed a preliminary assessment (PA) for the U.S. EPA. As we understand this submission is the first step in determining if the EPA will classify the PFAS contamination in Stella as a Superfund Site. Here is the introduction language from that assessment.  "Under authority of the Comprehensive Environmental Response Compensation Liability Act of 1980 (CERCLA), and the Superfund Amendments and Reauthorization Act of 1986 (SARA), the Wisconsin Department of Natural Resources (WDNR) was tasked by the U.S. Environmental Protection Agency (EPA) to conduct a Pre-CERCLA Screening (PCS) and a Preliminary Assessment (PA) at the Township of Stella PFAS Contamination Site in Oneida County, Wisconsin (Site) as part of the fiscal year 2023 –  2024 Cooperative Agreement. The PCS form is included in Appendix C. The purpose of this PA was to collect information concerning conditions at the Site sufficient to assess the threat posed to human health and the environment and to determine the need for additional CERCLA/SARA or other appropriate action. The scope of the PA included review of available file information, a comprehensive target survey, and Site reconnaissance." This language as well as the complete assessment can be viewed here  WDNR EM/RR BOTW (wi.gov) by selecting the accompanied Stella PDF under Actions and Documents portion.

  Per the EPA " Thousands of contaminated sites exist nationally due to hazardous waste being dumped, left out in the open, or otherwise improperly managed. These sites include manufacturing facilities, processing plants, landfills and mining sites." More information on Superfunds can be found here.   What is Superfund? | US EPA 

  One important point to consider is that the EPA will attempt to hold polluters responsible as indicated by this excerpt from EPA site  "Under the authority of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA, commonly known as Superfund), the Superfund enforcement program gets hazardous waste sites cleaned up by finding the companies or people responsible, known as potentially responsible parties (PRPs), for contamination at a site and negotiating with them to do the cleanup themselves or to pay for the cleanup done by another party (e.g., EPA, state, or other parties)."

  As you may know; accountability has become a real concern in our state as legislators argue about and delay the $125 million designated this past August for PFAS cleanup. The sticking point being the DNR's ability to hold polluters financially responsible. See our December 21st post as well as WXPR coverage  Senate passes PFAS funding bill, critics say it protects polluters | WXPR .

  We understand there is much information to digest here and hope that the links provided in this post will help those interested to get a clearer picture. 

By Eric Rempala December 21, 2023- As reported in Kathleen Coopers December 13th post, the Oneida County Board of Health Committee has forwarded a resolution on PFAS to be considered by the County Board in their January board meeting. 

 We at OCCWA have been urging the DNR to use their certified PFAS spreading site list to determine where other potential contamination may be in county. The DNR not only has a list of all DNR certified sites in Oneida County but supposedly also have records of amounts spread at these sites over the years. Just how far back records go is up for debate. By the way, the county has the authority to make an open records request to acquire these records.

  Understanding these facts, one would surmise that with those records one might be able to determine where the highest concentrations of PFAS may be located elsewhere in county. While most people might think this is common sense, the DNR has yet to respond whether this logic is valid. 

  The county's Board of Health Committee addressed this concern with one of their asks on the proposed resolution. "Therefore, be It resolved that all areas within a 2-mile radius surrounding where the DNR permitted biosolids to be applied will be offered well water testing to be paid for by the DNR or the state of Wisconsin." 

  The other request in the resolution asks that that all biosolids from Wastewater Treatment Facilities and those facilities suspected of potentially having PFAS concentrations in their biosolids be tested before being spread.  Res-16-2024-Direct-DNR-to-test-well-water-for-PFAS.pdf (oneida.wi.us) 

  Both these requests seem quite reasonable considering recent circumstances and application of Wisconsin Common Sense. So, there you have the upbeat part. Refreshing right?

  Now for the Not So Much part. The DNR recently sent out notice that they are halting work on setting PFAS standards that the NRB more than a year ago dropped the ball on. Part of the DNR statement read " The final economic impact analysis of proposed groundwater standards for PFAS is in excess of $10 million for a 2-year period. As required by state statutes, the DNR has stopped work on this proposed rule and has notified the state legislature. The state legislature will need to grant the DNR authority to continue the rulemaking process for setting PFAS standards in drinking water." The statute is commonly referred to as the REINS act. 

  We share with you now Wisconsin Examiner coverage for more information.  Evers calls on Legislature to release PFAS funds, approve DNR groundwater rule - Wisconsin Examiner 

  I have withdrawn a quote from the Examiner article "The folly of the REINS Act has become clear when the legislature appropriates $125 million to ‘begin’ addressing PFAS contamination but then triggers a ‘cease and desist’ order to DNR because a PFAS groundwater standard might cost more than $10 million,” Doug Oitzinger, the former mayor of Marinette, said in a statement." 

 I can tell you that Mr. Oitzinger is a fantastic advocate for his city and has done yeoman's work on this issue for many years already, and his frustration level is absolutely palpable for good reason. We in Oneida County are just learning what a slow process this will be. 

Update by Eric Rempala October 11, 2023- We are sharing the DNR's recent surface water tests results posted on 10/9. Here is the DNR quote " The DNR sampled additional waterbodies in the Town of Stella area for PFAS in mid-August, and sampling results are now available. Results show that lakes Second, Fourth and Fifth in the Moen chain of lakes, as well as Twin Lakes Creek have levels of PFAS above Wisconsin’s surface water standards. PFAS were also detected in lakes Thompson, George and Stella, but were at levels lower than the surface water standard and similar to many other waterbodies around the state."  

  I think the DNR statement speaks for itself, some good news and some bad. Here is the link to DNR map with test results  Stella and Rhinelander Surface Water PFAS Testing - Maps and Tables (wisconsin.gov) 

 Just a reminder that the Oneida County Board of Health Committee has PFAS as an agenda item on October 16th at 10am, meeting link has yet to be posted on the county website.

 By Eric Rempala September 13, 2023- Recent WDNR testing of Rhinelander's paper mill sludge are in and the results are promising. As we stated in a previous article, Ahlstrom Munksjo who provided the sludge sample, acquired the mill several years ago and may not be responsible for the PFAS issue in Stella. As originally suspected by residents, but not yet determined by the DNR, the PFAS issue in Stella could well be a legacy pollution issue stemming back to previous mill owners. To be clear, there has been no determination of the PFAS source by the DNR as of yet. 

  OCCWA found the test results  Ahlstrom Munksjo PFAS Sludge Sample Set Report (wisconsin.gov) a bit confusing, so we contacted the DNR for clarification. Provided is the DNR response. 

"The PFOS results are the results listed under Perfluoro-n-octane sulfonic acid (1.67 ng/g).  PFOA results are those listed under Perfluoro-n-octanoic acid (0.342 ng/g).

There are currently no limits in state or federal code pertaining to biosolids for any PFAS chemicals for the Department to compare the results to.  The Department does have an Interim Strategy for Land Application of Biosolids Containing PFAS (https://dnr.wisconsin.gov/sites/default/files/topic/PFAS/PFAS_BiosolidsInterimStrategy.pdf).  This document is intended to assist municipal Wastewater Treatment Facilities in making decisions in how they handle biosolids containing PFAS (specifically PFOS and PFOA) based on the best information the Department has at this time.  While the Ahlstrom paper mill sludge is regulated as an industrial sludge under ch. NR 214, Wis. Adm. Code as opposed to municipal biosolids which are regulated under ch. NR 204, Wis. Adm. Code, you can see that the concentration of PFOS and PFOA would not result in any suggested restrictions in land application.  

Michigan has collected a lot of data on PFAS concentrations in municipal biosolids.  They found the median PFOS concentration of all 162 WWTPs they sampled was 8.25 ppb and the average was 14.39 ppb.  The Ahlstrom sample had a PFOS concentration of 1.67 ppb which is significantly below the median and average.  Ahlstrom has indicated on its website that it has switched to a fluorine free product.  The Department is not aware of when this change occurred.  The Department is not aware of and has not been provided any PFAS results from samples taken before this recent sample which the Department collected.

The EPA is currently developing a risk assessment to better understand the potential public health and ecological risks associated with PFAS in land-applied biosolids.  This information will be used by the department and EPA to inform decisions on the need to regulate biosolids."

 I would be remiss at this time to not acknowledge the DNR for their quick response as well as their professionalism in answering all questions posed by OCCWA.

  One point to clarify from the DNR statement. It appears Michigan has been way ahead of Wisconsin on PFAS testing, taking positive action as far back as 2021.   Land Application of Biosolids Containing PFAS Interim Strategy (michigan.gov) Are our Wisconsin legislators not as interested in protecting water quality as Michigan's? Let's hope not, but it's a legitimate question as our local legislators have in the past opposed public opinion on mining as well as Pelican River Forest.

  We would also like to share WXPR's Katie Thoresen's coverage of the DNR sludge testing results.  Rhinelander papermill sludge testing shows low PFAS levels | WXPR  As we have stated before WXPR and in particular Katie, have done a fantastic job covering this local issue.

 A couple of points to be considered going forward. Where did the PFAS contamination come from? If the contamination in fact came from past mill spreading, where else was that sludge spread and what other towns may be affected? What is Oneida County's responsibility pertaining to this issue? Well hopefully the last question will be addressed soon, as the Oneida County Board of Health Committee has chosen to add the PFAS discussion to their October 16th meeting agenda. See Kathleen Coopers update article below for more details. Job well done Kathleen and compliments to the Oneida County Board of Health Committee for their consideration.

Update By Kathleen Cooper September 13, 2023-  Eric Rempala and Kathleen Cooper attended the Oneida County Board of Health Committee meeting on September 12 to urge this committee to become more involved in the widespread PFAS problem in Oneida County. The Town of Stella appears to be the hardest hit, but it has also caused Rhinelander city wells to be shut down. The full extent of the problem in Oneida County is not yet known, but PFAS is suspected to be more prevalent than we know at this point in time.

 There have been various resolutions passed in Ashland, Kenosha, and Marinette Counties urging the DNR to dedicate time and resources to enforce PFAS standards. In Douglas County, a resolution was passed unanimously to require the testing of any sludge that is spread on their fields. This resolution was used as an example for the Board of Health to model an Oneida County resolution. 

 This item was well received by the Board of Health and was placed on the agenda for the October 16 meeting. It is a first step in minimizing any more contamination of our soil and water. The public can help by contacting their County Board supervisors and expressing their support of this potential resolution.

WPR coverage by Danielle Kaeding including Douglas County Resolution link- DNR Offers To Test Municipal Sewage Sludge For PFAS » Urban Milwaukee  

 WPR excerpt- "In the meantime, northern Wisconsin leaders are concerned PFAS contamination could stem from spreading biosolids on farm fields. Douglas and Bayfield counties passed resolutions this spring that seek to require PFAS testing of all sewage sludge spread on lands in Wisconsin."

By Kathleen Cooper August 29, 2023- I was at a town meeting in Stella last month, and we have a public health emergency on our hands. I looked at the faces of the people of Stella while the DNR was telling them of the PFAS levels in their wells, lakes, and waterways, and I saw shock, disbelief, fear, and hopelessness. The DNR has no clear answers for these people, no certainty that their water will ever be safe to drink. Home filtration systems, (only if the PFAS level is under 200 parts per trillion, and many were much higher) or drilling new wells are the only options open to them. These options still don’t guarantee clean water.

 What happened in Stella could happen to any of us, maybe is already happening to us. It is not an isolated incident. It is happening all over the state, from Rhinelander, to Menominee, to Wausau, and many other municipalities. The contamination has drained into other waterways, like the Pelican River, and the Wisconsin River from the contaminated lakes and streams in Stella.

 PFAS are a group of man-made chemicals that are used in a variety of products, ranging from firefighting foam to Teflon and other non-stick substances, paper and cardboard wrappers for fast food and bakery goods, stain resistant furniture and carpets, clothes, and even in personal care products and cosmetics. They are called “forever chemicals” because they do not break down in the environment, and build up in fish, wildlife, and human beings. PFAS affects growth and development in humans, and is linked to testicular, kidney, liver, and pancreatic cancer, reproductive problems, weakened childhood immunity, low birth weight, endocrine disruption, increased cholesterol, and weight gain in children and dieting adults.

 Some PFAS chemicals (the “long chain” variety) have been phased out but have now been replaced with similar “short chain” replacements, which the FDA has recklessly allowed. The new chemicals may pose even worse risks than the long chains, which supports scientists’ growing agreement that the entire class of PFAS are hazardous. Unreleased federal data suggest that up to 110 million Americans could have PFAS-contaminated drinking water. It continues to be discharged into the environment, because there are currently no restrictions on industrial PFAS discharges under the federal Clean Water Act or the Clean Air Act. Not only has manufacturing discharged PFAS into the environment, but the military has used firefighting foam containing PFAS for decades and is fighting efforts to clean up legacy pollution. The EPA has failed to set a legal limit for any PFAS in tap water, and its non-enforceable health advisory level for PFAS is 70 times higher than what independent studies show is needed.

 The cause of the PFAS contamination in Stella has not been proven as of yet, but it is suspected that decades of sludge spreading on local fields from the papermill, and that of biosolids from the wastewater treatment plant may be the culprits. There is also PFAS contamination in the City of Rhinelander It is suspected that the firefighting foam from the Rhinelander airport may have played a role. Nothing has been determined conclusively, partly because testing for PFAS in the sludge and biosolids is voluntary, and the entities who caused the problem do not want to be responsible for cleaning it up. Ahlstrom Munksjo, the owner of the paper mill in Rhinelander, has consented to testing, with no results back at this time.

 The people in Stella who are affected have been given bottled drinking water, and have been offered monetary help to install new filtration systems or drill wells. The amount of money offered is less than what is needed, but it helps. The manufacturers and others suspected of causing the problem, as well as our state senator, do not want to “place blame” and expect it to be cleaned up with taxpayer money.

 Other Wisconsin counties such as Douglas County and Ashland counties, have proposed resolutions to stop the spreading of sludge and biomass in their fields. Oneida County continues to ignore the problem, and has done nothing, not even showing up in Stella for informational meetings. The problem continues, with no end in sight, no regulation, and no solutions. The DNR is still allowing sludge spreading in six area fields. Meanwhile the people in Stella are receiving bottled drinking water, but not much else.

Here is an article documenting some of Marinette and Peshtigo's PFAS consequences. 'The Middle of a Massive Contamination': Marinette and Peshtigo Residents Struggle with Aftereffects of PFAS (pbswisconsin.org) Both towns are four years beyond their initial PFAS contamination discovery.

By Eric Rempala August 25, 2023-  OCCWA would like to share a link to the Wisconsin DNR's Interim Strategy for Land Application of Biosolids (Sludge) Containing PFAS dated September of 2021.  Interim Strategy for Land Application of Biosolids Containing PFAS (wisconsin.gov)  Here is an excerpt from said document.

" 3.0 Proposed Interim Strategy for Land Application of Biosolids Until a fully vetted, risk-based assessment is completed for PFAS in biosolids, similar to other states DNR is implementing the following strategy to assist WWTFs and landowners/farmers who make decisions relating to land application of biosolids with detectable concentrations of PFAS. Note, the department expects that this interim strategy be used in conjunction with the requirements of NR 204, Wis. Adm. Code. 

 The strategy primarily focuses on three-parts for success: • PFAS Biosolids Sampling. Sample and analyze biosolids suspected to be impacted by PFAS prior to land application.

  • PFAS Source Identification and Reduction. PFAS analytical results from biosolids sampling will dictate the level of source identification and reduction efforts. Note, while PFAS sources are often associated with industrial manufacturing, other sources, including a variety of commercial businesses, have the potential to substantially contribute PFAS loading to WWTFs.

 • Farmer and Landowner Communication. It is important that PFAS concentrations in biosolids and source reduction efforts are communicated with the landowner and/or farmer receiving the biosolids. DNR will assist in providing analytical information and additional educational resources specific to PFAS in biosolids in Wisconsin."  

  So, this document is what the DNR is using for monitoring and testing of sludge applications until a more permanent testing process is put in place. The testing of the Rhinelander paper mill sludge which the DNR referenced in their August 15th meeting with the town of Stella falls under this document. We would recommend anyone wishing to get a better understanding of the spreading of sludge in Wisconsin review the entire link provided above (approximately 8 pages). 

  Another excerpt from the cited document is " Because there are potentially many sources of PFAS within biosolids, source identification is necessary to ensure biosolids are protected from industrial and commercial contamination. Common industrial sources of PFAS include metal finishers, landfills (leachate), paper manufacturing, mixed manufacturing, paint manufacturing, leather tannery facilities, commercial industrial laundries, chemical manufacturers, centralized waste treaters, and a variety of miscellaneous sources. Aqueous film forming foam (AFFF) used as fire-fighting foam can also have lingering impacts as a source of PFAS as residuals within sewers or from infiltration into the sewer collection system.

  For small WWTFs, small commercial operations including operations that appear innocuous, such as floor mat cleaning, commercial laundries and truck washes, may be PFAS sources and identified as potentially impacting PFAS concentrations in biosolids.

  The department is eager to partner with any WWTF operators wanting to establish a PFAS source identification and reduction program and stands ready to assist if requested."

  In the Stella January meeting it was brought to the DNR's attention by local residents, that they felt their PFAS issues were due to land spreading. At this point the DNR seems to be directing their investigation in that direction. Identifying the source of the PFAS is the first step in stopping the continuation of the contamination. 

 If you require more reason for concern from paper mill sludge, reference this Portland Press Herald article dated July of 2021.  Trail of ‘forever chemicals’ leads to Maine paper mills (pressherald.com)  

Article excerpt provided, 

" Paper mills have used a lot of PFAS – and in some cases still do – in the coatings that keep grease or liquids from soaking through picnic plates, takeout food containers, pizza boxes, microwave popcorn bags and fast-food wrappers."

“They have legacy use of PFAS, almost certainly,” said John Gardella, an attorney at CBMG3 Law in Boston who specializes in environmental law and advises clients on PFAS issues. “The question is, how long were you using it and what did you do with the (sludge) that came from the waste?” 

Update August 15, 2023- We at OCCWA are sharing two recent television pieces. First one being WJFW coverage of the Rhinelander paper mill lawsuit.  Rhinelander Paper Mill sued in class action suit | News | wjfw.com We hope to garner more information when we attend the DNR Stella meeting tonight August 15.

 Also we are sharing WSAW coverage of PFAS advocates' discussion on Senate Bill 312.  PFAS advocates came together to discuss 312 Senate Bill (wsaw.com) As we have shared previously on other posts as well as this very post (see below)"PFAS Bill Would Let PFAS Polluters Off the Hook and Shift Cleanup Costs to Wisconsin Taxpayers" PFAS Advocates continue to have concerns with Senate Bill 312 pertaining to DNR's ability to hold polluters responsible. Wausau Alderperson Tom Killian WSAW direct quotes “While this bill provides much-needed funding to address PFAS in local communities, it also creates a polluter loophole that will restrict DNR authority, and our Spills law,” said Wausau District 3 Alderperson Tom Kilian.  

“Routinely our legislative processes have been polluted by money interest and corporate lobbyists who routinely have traded our people’s health protections for profit, and we see this in this element of the bill,” said Kilian. 

These quotes echo concerns stated by Midwest Environmental Advocates and shared on previous OCCWA articles. 

Update July 17 2023- The Wisconsin DNR now offers to test sewage sludge for PFAS from wastewater treatment facilities.  If facilities are concerned and want results, the DNR would pay for testing at both industrial and municipal plants. If a landowner considering sludge applications should request testing for PFAS from the facility, the excuse of cost considerations should no longer be an issue. This is an excellent decision on the DNR's part. See WPR coverage  Wisconsin DNR offers to test sewage sludge for PFAS at wastewater facilities | Wisconsin Public Radio (wpr.org) 

By Eric Rempala June 27, 2023- Results are in from the most recent expanded DNR PFAS tests for the town of Stella. Provided is a direct quote from the latest DNR update. 

"The DNR expanded private well sampling to an additional 56 full-time residences and two summer camps within 2.5 miles of the Stella Town Hall. As of May 3, 2023, a total of 50 wells were sampled within the 2.5-mile expanded area. Of those, the DNR sampled 43 full-time residences, and three residences sampled their own well prior to being contacted by the DNR. Of the 50 private wells sampled:

• 20 wells were “no detection” for any PFAS tested.
• 19 wells detected PFAS, but levels were below DHS' recommended health guidelines.
• 11 wells had PFAS levels above DHS' recommended health guidelines.

Homeowners that found their private well is impacted by PFAS above DHS' recommended health guidelines are eligible for in-home bottled water paid for by the DNR. The DNR will correspond with impacted homeowners to initiate the process."

  It appears the further away from the Stella Town Hall the better the tests get. Mind you, there were still 11 wells that tested above DHS's recommended health guidelines. No other determinations were given by the DNR. Most recent information including a map of testing results is available at the DNR town of Stella website.   PFAS Contamination in the Town of Stella | | Wisconsin DNR 

Testing of surface waters in Stella is being done this summer and we will share those results when they become available.

  I recently attended the DNR's PFAS External Advisory Group meeting PFAS_EAGMeeting_20230616.mp4 (widen.net) There was much valuable information to be had. At the 57-minute mark a presentation was given on the spreading of industrial and sewage sludge on the land and the permitting process. This process is called soil amendments. Right now, 85% of all sludge is used for land applications.

  At this time testing for PFAS is not required on the sludge but there is some monitoring being done. At the 1:41 mark during public comment, I posed a question as to when testing may be required. The answer was, until the EPA sets a standard for PFAS content in sludge which hopefully will occur within the next year, no testing requirements will be implemented. No solid timetable can be determined at this time, but the DNR understands the public's concern and hopes to move forward as soon as possible.

  A recent WXPR article covering potential PFAS legislation here  Wisconsin Republicans vote to spend $125 million to combat PFAS pollution, but not right away | WXPR 

  Also provided below is a recent news release by Midwest Environmental Advocates

 Midwest Environmental Advocates (midwestadvocates.org) 

Supporters of a bill under consideration in the Legislature say it would provide much-needed funding to communities impacted by PFAS contamination, but the bill could end up leaving Wisconsinites worse off. That’s because it contains troubling provisions that limit the state’s enforcement authority and shift the cost of cleanup from polluters to taxpayers. 
Last month, the Legislature voted to create a $125-million-dollar fund to address PFAS contamination in communities across the state. A companion bill creating a municipal grant program was subsequently introduced. The news was greeted with cautious optimism, but that optimism quickly faded when it became clear that the bill would make it harder for the state to hold PFAS polluters accountable under Wisconsin's Spills Law. 
Shifting responsibility away from polluters would come at an extraordinary cost to taxpayers. Consider, for example, the potential cost of remediating PFAS pollution originating from JCI/Tyco's fire technology center in Marinette. The company reportedly set aside $140 million in 2019 and an additional $255 million in 2022 for remediation efforts. When you consider that more than 100 sites of PFAS contamination have so far been identified in Wisconsin, it's easy to see how statewide cleanup costs could quickly exceed the $125 million allocated by the Legislature. 
This attempt to undermine the Spills Law in the Legislature comes at a time when the same law is also under attack in the courts. (See previous article.) Unless the bill is amended to remove limitations on the state’s enforcement authority, MEA will call on Governor Evers to use his veto pen to reject it."

What kind of financial damages are we talking about with PFAS? See article on 3M 10.3 billion dollar settlement.    3M reaches $10.3 billion settlement over contamination of water systems : NPR 

WXPR provides article on most effective PFAS filters  Nearly half the nation's tap water may contain PFAS. Here's how some filters rank at removing them. | Wisconsin Public Radio (wpr.org)