From Toilet to Table: Sewage Sludge Invades Pennsylvania!
- cetherid11
- 17 hours ago
- 5 min read
The Delaware Riverkeeper Network webinar on sewage sludge was eye-opening! Did you know that Pennsylvania imports MORE sewage sludge (aka biosolids) than it produces? Ewww - we must do better! We must demand that the Pennsylvania Department of Environmental Protection (PA-DEP) do its job and BAN the land application of all biosolids (aka sewage sludge) known to contain PFAS/PFOS. The most common sources of biosolids that contain PFAS/PFOS are known and most often come from outside of Pennsylvania - from places like New Jersey and New York, which have stricter regulations on the land application of sewage sludge.
Please submit your comments to the proposed regulations today online by clicking here or at https://www.ahs.dep.pa.gov/eComment/. To start, here's a sample letter:
RE: PAG-07 GENERAL PERMIT FOR BENEFICIAL USE OF EXCEPTIONAL QUALITY BIOSOLIDS (DRAFT) 3850-PM-BCW0339;
PAG-08 GENERAL PERMIT FOR BENEFICIAL USE OF BIOSOLIDS (DRAFT) 3850-PM-BCW0340;
PAG-09 GENERAL PERMIT FOR BENEFICIAL USE OF RESIDENTIAL SEPTAGE (DRAFT) 3850-PM-BCW0341
Dear Pennsylvania DEP, thank you for the opportunity to comment. Biosolids are sewage sludge processed to meet certain DEP standards. Evidence shows that the practice of applying biosolids to land is polluting the environment with dangerous contaminants. Waterways and groundwater - and potentially our drinking water sources – are being negatively impacted. The health of Pennsylvania communities and farms require more protective measures to prevent this pathway of pollution.
Regarding all 3 General Permits:
· I am concerned about pollution to water, soil, air, food, and the environment from the land application of biosolids in Pennsylvania, even with the proposed changes to the General Permits. DEP is proposing to improve the current permits, which I support, but needs to go much further to sufficiently protect us and PA agriculture.
· DEP needs to hold public hearings on the proposed revisions to be fair and inclusive; more and diverse public input will benefit the DEP in its decision making.
· DEP must require more frequent sampling and reporting of all contaminants in biosolids, including PFAS; sampling 2 to 4 times per year will allow pollutants to be discharged but not recorded. Sampling and reporting should occur monthly with independent sampling by the agency to verify results; annual reporting of sampling results leaves everyone in the dark for a year, pollution can slip through the cracks.
· DEP should require real-time public disclosure of all sampling data on DEP’s web.
· Greater setbacks distances from land application of biosolids from waters are needed, as detailed in my comments re. buffers from stored/staged biosolids.
· DEP should require no application or storage of biosolids that could negatively affect or cause nuisance to adjoining public uses such as schools and parks.
Regarding PFAS controls in PAG-07 and PAG-08 I request:
· DEP ban the land application of biosolids that contain 1 ppb for PFOA and/or PFOS, which is supported by the EPA Draft Sewage Sludge Risk Assessment 2025 OR ban the application if any amount of PFAS is detected in the biosolids.
· DEP’s “Tiered Approach” is not sufficiently protective because it allows biosolids containing PFAS (“forever chemicals”) at concentrations known to have negative health impacts to continue to be released into our water, air, soil, on our farms, harming people, animals and the environment.
· More PFAS compounds should be included in required sampling and to inform whether biosolids contain these highly toxic chemicals. EPA has identified 12 toxic PFAS in biosolids, methods for sampling are in use at labs. We need more comprehensive coverage than what’s provided by only PFOA and PFOS sampling.
Regarding Phosphorus Controls in PAG-07 and PAG-08:
· I support use of P-Index to reduce P runoff for all General Permits; phosphorus is in biosolids, its runoff degrades our waterways, kills fish and aquatic life with toxic algae and eutrophication, and harms drinking water quality drawn from surface waters in PA.
· The P-Index should be used in all watersheds, not only those “agriculturally impaired” and should be used in all waterways, not only PA-DEP’s Special Protection Waters.
· DEP must require greater setbacks from water and water supply sources if using P-Index; preventing pollution is the most effective way to protect water quality, trying to repair degradation after the fact is expensive and typically ineffective.
Regarding Staging and Storage of biosolids on the application site in PAG-07 and PAG-08. Wide setback distances protect water quality, preventing the entry of pollutants. DEP should require greater than the minimal proposed setbacks of stored biosolids.
· 1000’ setback from Exceptional Value (EV) wetlands and drinking water sources is required by some states i.e. Missouri but at least a 300’ setback from drinking water sources is enforced by some states i.e. Wisconsin.
· 300’ buffers for exceptional value and high quality streams is supported by science and enforced in neighboring New Jersey but in Pennsylvania at least a 150’ buffer is required for EV and High Quality (HQ) wetlands and waterways.
· 150’ buffers for all other perennial and intermittent streams is required in other states, i.e. Mississippi.
· For best water quality protection, buffers are to be vegetated, as per USDA NRCS Code.
DEP should limit the length of biosolids storage time on the application site to 30 days and, at DEP’s discretion up to 60 days due to weather or other limitations. Allowance for a whole year (and longer with DEP’s permission) is unacceptable, increases opportunity for polluted runoff, leaching into groundwater, and odor and vector increase.
DEP should require complete roof covering of all stored biosolids, no tarps, for any length of time and storage pads. Storage pads must provide containment of run-off.
Regarding Processing of “Non-captive sewage sludge, biosolids and food waste”. DEP must abandon the proposal to blend “food waste” into a sewage plant’s anaerobic digester to generate methane to facilitate “waste to energy”.
· These General Permits are asserted for beneficial use for agricultural, benefiting the growing of crops, livestock, farm products, and enrichment of soil as per USEPA. It is wrong to assume that generating energy is one of the benefits of the land application of biosolids. “Waste to Energy” is not an agricultural pursuit and is totally inappropriate for these permits.
· DEP presents no research or data proving the effectiveness, efficiency, or safety of intentionally producing methane through comingled food waste at the sewage treatment plant. In fact, methane is a very small molecule, leaks profusely, and is very difficult to contain, as per technical reports.
· Methane is dangerous for workers and proximate populations should it escape because it’s flammable, explosive, displaces oxygen so can suffocate those nearby. Methane is a highly potent greenhouse gas, which exacerbates climate change (it’s ~85% more powerful than carbon in warming atmosphere on 20yr. time frame). I oppose MORE methane to be produced for sale to natural gas companies; we need to ratchet back methane production to meet PA’s stated climate goals, not increase.
Regarding PAG-09:
DEP should produce the data that proves that there is no potential for pollution from septage applied on land. Because septage is human waste it can become a pollution pathway in all the same ways as Class A and Class B biosolids so should be subject to all the same restrictions I have recommended in this comment for PAG-07 and PAG-08. Thank you.
More information is in the image below.
