TRURO — The 40-page “Report on Private Wells and Truro Safe Water” released in September by a group calling themselves Docs for Truro Safe Water has been promoted by critics of the 39-unit Cloverleaf development as a peer-reviewed scientific treatise on how nitrogen contamination of drinking water threatens North Truro. The document has been cited repeatedly in arguments that the Cloverleaf should not be given the waivers it needs to proceed with construction as affordable housing under the state’s Chapter 40B.
The authors of the report, questioned by a reporter for the Independent about their peer-review process at their Dec. 1 presentation to the board of health, asked to be allowed to respond in writing. The next day, they claimed that they themselves were the “peer reviewers” of their own work.
“We are all cross-disciplinary peers and jointly reviewed the underlying science to prepare our report and presentation,” they wrote. “We jointly share authorship of the report and the presentation.”
Meanwhile, a groundwater scientist from the Cape Cod Commission who examined the report said that it misrepresents the commission’s standards on nitrogen.
A constellation of North Truro property owners has argued that effluent from the Cloverleaf would poison their wells with nitrates. Others, including Truro Health Agent Emily Beebe, say that groundwater quality in the area has much more to do with existing residential systems — septic systems that aren’t properly maintained and antiquated cesspools that dump nitrogen into the ground basically untreated.
The authors of the “Docs” report are epidemiologist Ron Fichtner; Dr. Frederick Ruymann, a gastroenterologist; Dr. Robert Brown, a neurologist; Mary Pearl, a conservation biologist; Christopher Clark and Brian Boyle, both engineers; and Robert Simpson, who holds a doctor of social work degree and specializes in behavioral health.
All seven hold doctoral degrees and are recognized scholars. Their report primarily focuses on the evidence for increased incidence of various cancers even at relatively low levels of nitrate in drinking water. The report concludes with a call for the Truro Board of Health to reset local standards for nitrogen in drinking water to half or less of the E.P.A. standard.
The authors have not responded to repeated requests by the Independent to interview them.
Fichtner and Ruymann also signed various letters to the zoning board of appeals from the “Members of the Pond Village Community,” including an Oct. 19 letter describing the Docs report as “an expert peer-reviewed analysis.” DocsTruro.org describes its own report with the phrase “Status: peer review.”
That same Oct. 19 letter attacks the town’s peer-review process of the Cloverleaf wastewater plan. “The process the Town has followed falls far short of any standards or guidance for peer review we can find,” states the letter. “A more comprehensive multidisciplinary peer review process — with experts in public health, drinking water safety, health economics, environmental sampling and monitoring, and ecology — is essential to garner confidence in this complex process and merit consideration for ZBA approval.”
This passage also includes a footnote, which offers the E.P.A.’s Peer Review Handbook (4th edition) as an example of standards for peer review.
But the Docs’ own report does not meet these standards. According to the E.P.A. standards, the Docs’ report was not peer-reviewed at all. One cannot both write a report and “peer review” it.
The first page of the E.P.A. Handbook states prominently: “The goal of peer review is to obtain an independent review of the product from experts who have not contributed to its development.”
From that same page of the Peer Review Handbook: “Peer review is an in-depth assessment of the assumptions, calculations, extrapolations, alternate interpretations, methodology, acceptance criteria and conclusions pertaining to the scientific or technical work product, and of the documentation that supports them.… It is conducted by qualified individuals (or organizations) who are independent of those who performed the work….”
Truro’s contracted peer reviewer for the Cloverleaf, Horsley Witten, lists 38 people at its Sandwich office, including two hydrogeologists, three environmental engineers, three environmental scientists, a watershed planner, and an ecologist.
Tim Pasakarnis is a water resources analyst for the Cape Cod Commission with a Ph.D. in environmental engineering; his graduate and postgraduate work focused on groundwater chemistry. He said the Docs for Truro Safe Water did not reach out to his office for advice, but he would have responded if they did.
“The Cape Cod Commission does not have a drinking water recommendation, or an alternate minimum contamination level [MCL] for drinking water,” said Pasakarnis.
The commission has a 5mg/liter site-wide loading standard, but that is not a drinking water standard.
“There have been a couple of instances in [the Docs’] documentation that have misconstrued or misrepresented the commission’s reports,” said Pasakarnis. “The way [a citation on page 5] is written is not specific enough to be useful for interpreting accurately. It’s just saying a nitrate concentration. It’s not saying what it represents. It does not represent a drinking water MCL.”
He’s also not aware of any jurisdiction with an MCL for drinking water below 10mg/L, the E.P.A. standard.
“I can’t say there isn’t one,” said Pasakarnis, “but based on the extensive research that I’ve done, I have not found either a drinking water or a surface water MCL that’s lower than 10mg/L.” Nor was Pasakarnis aware of a debate about the federal MCL.
If Truro follows the Docs’ recommendation and imposes a new local standard for nitrate concentrations in drinking water, it would likely be the first jurisdiction anywhere to depart from the federal MCL for drinking water.
People who work on water quality issues — including Pasakarnis; Beebe; Brian Baumgaertel, director of the Alternative Septic System Test Center in Mashpee; and Jason Silva, vice chair of the Truro Board of Health, who is also a septic engineer — frequently bring the conversation back to the same issue: existing systems that don’t perform well.
“We have 200-plus cesspools, four or five in Pond Village, putting out anywhere from 20 to 200 mg/L, which is shocking,” said Silva. “I’m not seeing people voluntarily changing their cesspools to Title 5 septic, or their Title 5 to I/A systems. People are not reaching into their pocket and pulling out $30,000 because it’s the best thing to do.
“I also don’t see people routinely pumping their systems,” Silva continued. “I talk to my friends who run septic companies, and I ask them, ‘Have you been doing a lot of pumping in the area?’ They tell me, ‘No, I’m not really getting any calls.’ Here’s a $300 possible fix, and it’s not even being acted on.”
There is a county loan program that can spread the cost of a septic upgrade over 20 years, said Baumgaertel. But $30,000 is a lot of money, no matter how you slice it. Could town money ever go towards private septic and cesspool upgrades?
“There are several nonprofits on Cape Cod that have made funds available for people to have retrofits or upgrades to private septic systems,” said Pasakarnis. “There are certainly some towns exploring possibilities for financing this. None of those are in place or established yet, but several are exploring what that might look like.”
Editor’s note: This article has been revised and expanded for clarity. Due to a copy editing error, an earlier version reported that the Cape Cod Commission’s groundwater scientist had said the “Truro Docs” misrepresented the commission’s findings on Cloverleaf; in fact, he said the misrepresentation was about its findings on nitrogen levels in groundwater.