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PGC and PFAs-filled Biosolids and Industrial Sludge

What has the County done to protect its citizens from PFAs contamination coming from the application of biosolids or industrial sludge onto farmland and closed mining sites? See below for the letter sent to Prince George's officials regarding the lack of information from the County about this threat and their stance on the issue. Please feel free to use this letter as a template for your own letter on this matter. After the letter are notes from current research on local and state regulation of biosolid and industrial waste transport, storage and usage.


letter


County Executive Angela Alsobrooks, CPESC District Manager/Executive Director Steven Darcey, District 9 Councilman Sydney Harrison, Council Members-at-Large Mel Franklin and Calvin Hawkins, State Senator Michael Jackson, State Representative Jeffrie Long


To Whom It Should Concern: May 10th, 2024

Dear Prince George’s County Officials and Representatives,


I am a resident of Baden, Maryland and I am reading with growing unease many articles regarding the unregulated levels of PFAs in biosolids and industrial sludge, products that are promoted to local farmers for use on land as fertilizer and for the remediation of mined areas in this county. I see that counties across the State have, or are considering, a moratorium on the storage and use of these products until more data and consensus make clear how to avoid the migration of PFAs, or “forever chemicals”, into local soil, water and from there to plants, fish and animals, such as deer, and then to people.

I read that MDE has paused issuing new permits to use biosolids on farmland until more can be learned about the level of PFAs within them. I see that a bill has been signed by Governor Moore regarding the permitting and regulation of industrial sludge transport, storage and use in the state. (HB 0991/S1074) The enactment of this bill is overdue as neighboring states have been transporting their sludge to Maryland making us the recipient of more than half of the land-applied sludge in the region. And often, it is written, more sludge is applied than necessary verging on “dumping” on Maryland’s farmlands instead of “farming”. As you may know, excess fertilizer in any form is not good for the waters going into the Chesapeake Bay. I hope we can agree that the Bay and local well water should not have high levels of “forever chemicals” going into them either.

I see that PGC Soil Conservation District has posted a tame and ambiguous statement based on National guidelines with nothing guiding or informing locals about the current state of concern or new data on PFAs contamination. I see a PGC Ordinance, 21-108, regarding the permitting of transportation of sludge in the County but that no permission is needed when the Department of Health has issued a permit for “subsoil injection of sludge for fertilization purposes” or if under contract with the Washington Health and Sanitary Commission. Does this currently take into consideration PFAs levels? It is unclear to me that it does.

My reason for writing is that I do not see one word written on this issue about what my county is doing in response to this environmental threat. What is Prince George’s County doing about preventing PFA contaminated biosolids and industrial sludge from getting into our farmland and water? I would like to see the plans you have and what steps you’ve taken.

With hope for the future,

(Signed with Address)


( See below for Articles Cited)

Articles Cited:

The County Must Prohibit Use of Fertilizers With Off the Charts Levels of Forever Chemicals (PFAS) - Mo-Co Alliance

Off-the-Charts PFAS in Maryland Biosolid Fertilizers https://www.epa.gov/biosolids/risk-assessment-pollutants-biosolids

COMMENTARY | The Hidden Dangers of Biosolids

Interactive Map: PFAS Contamination Crisis: New Data Show 5,021 Sites in 50 States

https://www.aol.com/maryland-takes-aim-industrial-sludge-092927577.html#:~:text=Counties%2 0including%20Caroline%20and%20Wicomico,Here's%20what's%20in%20works.

Commentary: Stop Md. from becoming an even bigger dumping ground for industrial sludge - Maryland Matters


Notes:

Sludge/Biosolid Research toward Moratorium Proposal PGC


Start of concern: Bloom Presentation given locally earlier this year.

(Certified Organic Farms do not allow S/B use as fertilizer.)













Joanne’s notes from Bloom info meeting in Jan at the American Legion, Hughesville:

The presenter from Bloom gave a slide presentation on their state of the art equipment. Which kills all pathogens…. They are among the 11% in the Nation that has this type of equipment and make the highest grade # 1 product. Their biosolid product is sold by the truckload to farmers and as potting soil in local gardening supply outlets. They touched on the PFAS in their product, saying that because they only accept residential waste and not industrial waste the amount of PFAS found in their product is negligible. By comparison the presenter said that the dust in people's homes has more PFAS than their biosolid product or that ag fields before application have tested positive PFAS. PFAS are forever chemicals and do not break down. PFAS accumulates and can contaminate water, air, all that is grown on the land and in us! I asked about heavy metals being in their product and I got the same answer, that heavy metals would come from industrial waste which they do not accept.


There were 6 - 7 people representing the Bloom company. Also in attendance at this meeting were approximately 12 farmers, some who had used biosolids on their land and others who wanted to find more information. Also recognized among attendees was a person from the government -MDA?


Our local rural area has farms that use the biosolids as fertilizer. Recently we heard of or smelled the stench of sludge / biosolids that was being applied to mined out land near Malcolm just over the PGCo/Charles Co. line. That was a different company from Bloom who says “their poop does not stink" (It is likely that this was industrial sludge not biosolids).


One year earlier this article had appeared.


Montgomery Countryside Alliance- News 1/24/23

PEER, the Montgomery Countryside Alliance, and the Sugarloaf Citizens Association are asking Montgomery County officials to prohibit the application of class A and B biosolids, such as Bloom fertilizer products, on county agriculture fields, golf courses and public lands to prevent further contamination of ground and surface waters.

Off-the-Charts PFAS in Maryland Biosolid Fertilizers

Eurofins Laboratory testing of Bloom biosolid fertilizer commissioned by PEER shows –

PFOA (a major form of PFAS) levels of 21 parts-per-billion (ppb). This is 5.3 million times higher than the EPA Lifetime Health Advisory Level for PFOA in drinking water, which is .004 parts- per-trillion;

PFOS (another major PFAS) levels of 26 ppb parts, an amount is that is 1.3 million times higher than EPA’s Lifetime Health Advisory Level for PFOS in drinking water, which is .02 ppb; and

Dangerously high levels of other PFAS, such as PFHpA and PFBS, which were found at 65 ppb and 30 ppb, respectively.

Apparently Bloom felt the need to assure PGC farmers that their product was not to be feared. Bloom is from the DC water treatment plant. PGC is also the location of a biosolid/sludge incinerator in Piscataway that is used by the Washington Suburban Sanitation Commission. That department issues permits for the transportation of sludge through the county and the routes taken.


COMMENTARY | The Hidden Dangers of Biosolids 12/7/22

Biosolids are sewage sludge.

Biosolids, or sewage sludge, are the treated solids that are separated from the massive quantities of sewage waste created by Americans each day. Nearly half of biosolids are treated to kill pathogens and are then spread on farms, pastures, and wildlands.


Unfortunately, there is little federal regulation to ensure the safety of biosolids. EPA has currently identified more than 350 pollutants in biosolids, but has only regulated nine. As a result, biosolids carry a variety of persistent and toxic chemicals, like per- and polyfluoroalkyl substances (PFAS), which can threaten our food supply and can contaminate our water sources.

And in terms of Bloom’s claim that they are safe because they only use residential waste:


Home fertilizers made out of sewage waste all containing PFAS

PFAS are legally washed down sewer drains from homes and industry. EPA and states can limit pollution from industry, but the only way to end PFAS from homes and commercial businesses is to stop using the chemicals in consumer and industrial products. (Bloom uses residential waste btw)


The Sierra Club and the Ecology Center identified dozens of home fertilizers made from biosolids. We purchased nine fertilizers:


Cured Bloom (Washington DC)

TAGRO Mix (Tacoma, Washington)

Milorganite 6-4-0 (Milwaukee, Wisconsin)

Pro Care Natural Fertilizer (Madison, Georgia)

EcoScraps Slow-Release Fertilizer (Las Vegas, Nevada)

Menards Premium Natural Fertilizer (Eau Claire, Wisconsin)

GreenEdge Slow Release Fertilizer (Jacksonville, Florida)

Earthlife Natural Fertilizer (North Andover, Massachusetts)

Synagro Granulite Fertilizer Pellets (Sacramento area, California)


Our tests reveal that American gardeners can unwittingly bring PFAS contaminants home when they buy fertilizer that is made from sludge-biosolids. Eight of the nine products exceeded screening limits for two chemicals—PFOS or PFOA—set by Maine, the state with the most robust action on PFAS in biosolids. The chemicals were measured at levels that would not be acceptable for the state’s agricultural soils. Of the 33 PFAS compounds analyzed in the products, 24 were detected in at least one product. Each product contained from 14 to 20 detectable PFAS compounds. Additional tests showed they also contained two to eight times greater mass of precursor compounds and hundreds to thousands of times more unidentifiable synthetic fluorine compounds.

The above is from a paper summarizing Biosolid risks from the Sierra Club. It contains a glossary and a bibliography on the issue. I believe it is an on-going online statement paper as it has no date.


Feb 2023

Industrial sludge utilization permit, MDE to issue, set fee, inspect enforce; MDE issues permits to allow framers to use biosolids on non-human consumption crops (land apply) Now on pause for any new permits to new users until more is known re PFAS


EPA proposes first-ever limits on PFAS in drinking water | Grist

3/14/23

In recent years, as the EPA mulled over how strict to make its PFAS standard, some states — including Alaska, Massachusetts, and Vermont — chose to move forward without the agency and propose or set their own limits on forever chemicals.

The proposed limits would cap two common types of PFAS contamination- the chemicals PFOA and PFOS- in drinking water at just 4 parts per trillion.

While their water-resistant properties are convenient, the chemicals have been linked to adverse health effects in humans, such as compromised immune systems, thyroid disorders, and kidney and testicular cancers, among other issues.

In total, the rule would apply to six commonly used types: PFOA, PFOS, PFNA, PFBS, PFHxS, and GenX. Besides limiting PFOA and PFOS to 4 parts per trillion, the remaining four types of chemicals would be restricted based on their combined effects.


Alarm bells in Maine and States imposing limits as well as local governments


Forever chemicals — or perfluoroalkyl and polyfluoroalkyl substances (PFAS) — are an umbrella group for thousands of compounds known for their ability to linger in the human body and the environment. PFAS are linked to kidney cancer, thyroid disease, testicular cancer and other illnesses.

Most notorious for their presence in jet-fuel firefighting foam and industrial discharge, PFAS are also key ingredients in a variety of common products like biosolids used on farms, nonstick pans and cosmetics.

While some critics of the bill have questioned where the sludge will go instead, Pluecker stressed that Maine has designated space for such substances in its own landfills. The state has also stopped taking waste from its neighbors, he added.


Pluecker described the new law as “a win for Maine’s farmers” and for the state in general, which has also been encountering PFAS contamination in its fish and deer.


Where is PFAs contamination known to be present? And where is it known to be present near me? Apparently near and on military facilities old and new.


Interactive Map: PFAS Contamination Crisis: New Data Show 5,021 Sites in 50 States


La Plata



Andrews AFB



PFAs also present in the superfund site in Brandywine- as per presentation at GBACA meeting

PFAS Investigation - Mr. Burris (Notes from talk below)


PFAS - Per- and poly-floroalkyl substances

Perfluorooctane sulfonic acid PFOS

Perfluorooctanoic acid PFOA


Chains of carbons with strong fluorine bonds

PFAS are hydrophobic and lipid-phobic. They are common stain resistant, fire resistant, and they are in scotch guard and teflon, carpet, fabric, cosmetics, paints, sealants, and fire fighting foam.They don’t degrade or break down very easily because the bond between the carbon and the fluorine are very strong and don’t oxidize or get eaten by microbes because it takes an enormous amount of energy to break the bonds.


What risks are associated with PFAS. All information on PFAS chemicals come from populations and epidemiological studies of towns where the chemicals are manufactured. They have seen significant correlation from high cholesterol to various cancers

Once the materials enter our bodies they also cannot break down, connect to our fat, or move out of our system since it is hydrophobic and lipid-phobic. It tends to attach to proteins especially in the blood

There are currently no federal regulatory standards, only advisory levels. Some states have standards on them. Maryland has not yet created one.


The former advisory level for PFAS is 70 parts per million (seems high)

Current advisory level for PFOA is 0.004 parts per trillion and PFOS is 0.02 parts per trillion

GenX chemicals are another class of PFAS chemicals at 20 ppt


Proposed standards are that they would like zero parts per trillion in our drinking water.

2016 collected samples for PFAS and got 495 ppt. (In Brandywine Superfund site)


Burris says in response to a question regarding local drinking water : “NONE! At least as far as we currently know” that it is not affecting anyone’s drinking water.

The people above it are on public water and the groundwater moves slowly (35 feet per year).

They have to determine the nature and extent of pollution which only started last month. The risk assessment for humans and ecology are going to take a while longer. They have only taken 6 or 7 samples and those are only last month from the site but expect that the PFAS has followed a similar plume and overflow as here. (Re: previous solvent pollution plume)


There is PFAS at Andrews as well and at the headwaters of Piscataway Creek. At Piscataway Creek the testing was done at DNR and they did find PFAS in the fish.

Reverse osmosis has been seen to filter out PFAS, but the problem with that system is it would send the PFAS right into the septic or sewer and back into the system


The firefighting trucks at Joint Base Andrews do not have PFAS compounds but have C6 compounds. That foam is only used on the trash rescue trucks. The training areas only use water now. The hangar foam systems have been either removed or locked out. The air force is moving toward water deluge systems on the base. These foams were used since 1970s and the majority of their use was in training programs.

PFAS have also shown up in waste water treatment plants, food processing plants.


Industrial Sludge

There is more activity on the local level here in MD around the transportation, use and storage of industrial sludge, particularly sludge that is an untested mix of biological processing and which can really stink. Maryland is catching up in the regulation of this material with neighboring states.


12/27/23

DAF sludge- animal product waste

Being shipped to MD due to lax regulations on use and storage


4/22/24

The legislation will close a loophole in state oversight and keep Maryland on-par with neighboring states by:

Requiring a utilization permit for the use, storage and hauling of industrial sludge in the state;

Ensuring local governments issue all necessary approvals before someone can use sludge;

Authorizing the Maryland Department of Agriculture to enter and inspect any site where industrial sludge is used; Increase penalties for users who willfully violate Maryland’s nutrient management regulations.

(from article) Bill to Gov HB 0991/S1074 re DAF regs (dissolved flotation materials)(Food processing residuals) Caroline and Wicomico co acted to ban storage in meantime. MD does not require a permit for industrial sludge- gets a ton from nearby states. Carroll officials considering moratorium on spreading of industrial sludge. (Baltimore Sun)


Commentary: Stop Md. from becoming an even bigger dumping ground for industrial sludge - Maryland Matters

2/24 update

Delaware and Virginia require permits for businesses that transport and spread sludge on farms. That’s why more than half of the region’s industrial sludge in recent years was land-applied in Maryland, according to a 2023 study by the University of Maryland.

Too often it’s become dumping, not farming.


Personal Protection?

Duke study home water filters

Your Water:

- Check to see if your drinking water source has been tested for PFAS; if not, consider collecting tap samples and sending them for testing to My Tap Score. Given the relatively reasonable costs, consider ordering both the advanced water test AND the PFAS test.

-Duke and NC State compared a number of water filters for their ability to filter out PFAS.

(Above from Montgomery county bulletin)


Dental flosses that are PFAS free


Period and Incontinence products:

General Info:


Prince George’s County: Total lack of stand on this issue

This was all I could find when searching online.



PGC Soil Conservation District Guidelines:

From National Conservation Practice Standards only

Do not apply amendments:

• Such as raw manure or biosolids. When applying soil amendments such as raw manure and

biosolids refer to NRCS Conservation Practice Standard Nutrient Management (Code 590).

When feedstocks have higher risk of synthetic organic or heavy metal contaminants, evaluate amendment as appropriate for contaminant and amendment type (e.g., processed municipal waste feedstocks that may contain pesticide residues, polycyclic aromatic hydrocarbons (PAHs), polychlorinated biphenyls (PCBs), and polyfluoroalkyl substances (PFAS), etc.).


Question: What is PGC doing in this regard? Particularly its farms and mining sites being contaminated by PFAs contaminated sludge?





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