In 10 minutes, volunteers collected nearly 700 nurdles at Rotary Park in Carlsbad earlier this month. Nurdles are tiny, pre-production plastic pellets about the size of a lentil or a fish egg, and they’re a problem.

“They are the raw material used to manufacture virtually every plastic product in existence. We’re talking water bottles, food packaging, car parts, almost all of those start as nurdles,” said Patrick McDonough, senior attorney for San Diego Coastkeeper, a nonprofit working for the protection and restoration of San Diego County waters. “I also want to add that because ‘nurdle’ is a cute word, and they are these tiny little things, I want to be clear that they’re pretty insidious. They are a product of fossil fuels, and the explosion in natural gas fracking in the U.S. has actually led to a boom in plastic production.”

These pieces of plastic often spill while they’re being transported, resulting in their polluting of the land and water. One effort to address this pollution is the International Plastic Pellet Count, a month-long effort organized by the U.S. Public Interest Research Group Education Fund and partnering organizations to collect and document these pellets from bodies of water and coastlines, and use the data to come up with ways to solve this problem. McDonough took some time to talk about the scale of this issue, and recent success in changes to national policy from a national railway company about securing the transporting of containers filled with pellets to stop the spilling. (This interview has been edited for length and clarity.

Q: San Diego Coastkeeper, Oceana, Surfrider Foundation San Diego, and CALPIRG are participating in the second International Plastic Pellet Count through the end of this month. What kind of issue do these pellets pose, both locally and more broadly?

A: A lot of the nurdles in the U.S. are manufactured in the Gulf region. They have a lot of oil and gas facilities there. Then they’re shipped all over the world. They’re so small because it’s easier for the manufacturers to ship them everywhere if they just make these little beads and put them into containers because they’re completely malleable. They’re shipped all over the world via trains, ships, containers, trucks; and, unfortunately, huge numbers of nurdles frequently spill, both during the manufacturing and the transportation all throughout that process. Because these are so small and they actually float, they typically end up in our waterways and coastlines and rivers. The figures are pretty staggering, globally. Apparently, 10 trillion plastic pellets now enter our oceans every year, which is really hard for the human mind to understand. Twenty-five to 30 billion pellets every day, which still is absolutely astronomical, and that’s just for nurdles; we’re not talking plastic bottles or bags or anything else because this is all linked to the global plastic crisis.

Another insane figure is that humans use about 1.3 billion single plastic bottles every day (according to “Drowning in Plastic,” a 2019 report from Reuters), whether those are soda or water bottles or whatever it is, and the Great Pacific Garbage Patch is now twice the size of Texas. It just creates a very heavy burden on all of our environments. We’re not just talking the ocean, we’re talking about our soils. Plastics are now found in the air and the polar ice caps and in the human body. How plastics get to those locations, first of all, nurdles themselves look like fish eggs, so they’re eaten by birds, fish, sea turtles that mistake them for food. Those animals can’t digest plastic, so the ingestion commonly causes starvation or death, and some of that plastic is leached into the bodies of those animals, and those toxins move up the food chain. Microplastics have now been detected in human blood and our lungs, liver, our brain tissue, the placenta. Most people don’t know what a nurdle is, and that’s a huge issue because you can’t fix a problem if you don’t know a problem exists.

Q: In 2024, San Diego Coastkeeper and the Coastal Environmental Rights Foundation notified BNSF Railway of an intent to sue because it was in violation of the Clean Water Act due to a large amount of these plastic pellets coming out of their train cars and into local waters. This past February, the railway company reached an agreement to update policies and protocols that require its customers to properly seal rail cars carrying these pellets, refusing to pick up cars that are noncompliant while assessing fines for noncompliance, and a donation in support of the local work to address plastic pollution. What was the specific violation of the Clean Water Act from the rail cars, and how did your organizations initially learn about it?

A: A great nonprofit organization called Trash4Tokens started noticing nurdles in their beach cleanups, near railroad tracks. They brought this to the attention of local regulators, the North County Transit District, which owns the railroad tracks and stormwater infrastructure alongside of those railroad tracks; it wasn’t making much of a difference, so they reached out to us and the Coastal Environmental Rights Foundation. The more we looked into how many nurdles were right next to the railroad tracks, the more it became apparent that there was some slow leak and spillage issue continuously happening over time, as opposed to a big spill or a derailment or something like that. This wasn’t a one-time or infrequent type of event; it seemed more like slow leaks and spills. We filed something called a notice of intent to sue. Before a nonprofit organization brings a Clean Water Act litigation or lawsuit, it has to notify the party saying, “Hey, we are planning on bringing a lawsuit unless you fix these things.” To BNSF’s credit, they reached out and we engaged in substantive discussions on what’s really happening, and how do we fix this problem.

BNSF is one of the largest rail freight companies. They don’t manufacture nurdles, they don’t ship nurdles, they just pull their freight around the United States, but their customers are the ones who are nurdle transporters or manufacturers. So, the hypothesis was that the nurdle freight cars are filled and then shipped to their ultimate destination throughout the United States, and then they are emptied by these giant vacuum hoses. After that happens, they’re not fully empty. These things are so small that there are still some residual nurdles left within these, what are called hopper cars. They’re very similar to old freight train cars, where they’re loaded from the top, sealed from the top, and then there are giant vacuum valves at the bottom. Once they have been unloaded, there were still a number of nurdles inside the cars, but some of the customers would fail to properly cap and seal those bottom valves. As the train cars returned back to the Gulf region, or to places where they would be cleaned, they would shake loose and spill little bits of nurdles all along the way. What we hope will be helpful at alleviating some of this slow leak and spillage problem is BNSF forcing their customers to properly cap and seal unloaded freight cars.

(The Clean Water Act violation was that) those nurdles fall directly into lagoons, especially in the North County area of San Diego. The rail tracks go very close to the ocean, and they cross over multiple lagoons, and they end up in the storm water channels that are managed by the North County Transit District. Every time it rains, the rain just washes them into our waterways, so there’s a direct pathway between the nurdles falling wherever they’re falling along the railroad tracks, and then getting into our waterways.

Q: The U.S. PIRG Education Fund’s website says that volunteers search for these pellets and record what they find, “so we can all have a better understanding of where this pollution is happening and make the case for action.” What do we know about where this pollution is occurring and what kind of action is being considered or implemented?

A: We’re seeing a lot of nurdles along railroad tracks, so what we’re seeing here in San Diego is happening across the United States. Unfortunately, there is some legal uncertainty, I’ll say, as to whether plastic pellets constitute a pollutant under the Clean Water Act. In California, we have a specific law that says trash is a pollutant under the Clean Water Act, and very specifically, pre-production plastic pellets are a pollutant under the Clean Water Act, but that doesn’t apply in every state across the United States. You’d think it would be a no-brainer that little bits of plastic entering waterways would constitute a pollutant, but that’s not clear. So, there is legislation out there. One is called the Plastic Pellet Free Waters Act, from U.S. Rep. Mike Levin (D-San Juan Capistrano). That would direct the (Environmental Protection Agency) to prohibit plastic pellet discharges into U.S. waterways.

Another policy push from our friends at Trash4Tokens is that they’re advocating for better international shipping standards. The idea is to treat nurdles like hazardous materials, which require significantly stricter shipping regulations to prevent spills and leaks, like double walled barriers.

Another idea that has been floated is to simply make these things larger. They’re so small that they spill very easily, and then when they’re in the environment, they’re nearly impossible to clean up effectively. If you make them larger, you can still ship them, you can still melt them down. If you make them the size of small Lego instead of a tiny lentil, then you probably would prevent a lot of this spillage, but it would significantly change the way the industry has to do things, so there’s always pushback where money is being made.