Comments to the EPA Draft Sewage Sludge Risk Assessment for Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonic Acid (PFOS) collectively known as PFAs. (https://www.epa.gov/biosolids/draft-sewage-sludge-risk-assessment-perfluorooctanoic-acid-pfoa-and-perfluorooctane)
Save Carbon County is a non-profit 501(c)(4) organization in Carbon County, Pennsylvania, dedicated to making our county a better place today and for future generations. The comments below reflect our organization of over 100 members. Carbon County is a rural Pennsylvania county whose residents' median income of $67,877 is well below the state and federal median income levels and where 12% of the population lives in poverty. (https://www.census.gov/quickfacts/fact/table/carboncountypennsylvania/PST045224)
Select areas of Carbon County are identified as Environmental Justice areas (https://gis.dep.pa.gov/PennEnviroScreen/). Carbon County also suffers from a high rate of cancer as compared to other counties in Pennsylvania (13th highest rate), as indicated by (https://statecancerprofiles.cancer.gov). Carbon County is home to two active Super Fund sites.
Approximately 5% of the farmers in Carbon County apply Synagro-provided sewage sludge on their fields. Concerned neighbors alerted Save Carbon County in 2022. After further investigation, including lab testing and extensive research, Save Carbon County identified multiple toxins in the sewage sludge, including PFOA and PFOS. As a result, Save Carbon County worked with local municipalities and our county government to raise awareness of the harmful effects of sewage sludge on farmers, livestock, nearby residents, and wildlife. Twenty-one of 23 county municipalities adopted ordinances calling for local control of land-applied sewage sludge which is currently prohibited by our state’s Right to Farm laws.
Save Carbon County is grateful for the opportunity to comment on the Draft Sewage Sludge Risk Assessment for PFOA and PFOS. This opportunity is especially relevant as the Town of Palmerton has recently found that their municipal water suppy exceeds the state guidelines for PFOA/PFOS. We believe this problem is linked to the use of sewage sludge.
An EPA-supervised attempt to remediate the Palmerton Zinc Pile Superfund site used Ecoloam (a mixture of municipal sewage sludge, power plant fly and/or bottom ash, and agricultural limestone) for the hillside above the municipal wells starting in 1991. Ecoloam was applied at a rate of 60 dry tons per acre. The municipal water supply now exceeds the guidelines for PFOA/PFOS. It is not a reach to believe that the application of sewage sludge played a role in this contamination. (https://www.frtr.gov/costperformance/profile.cfm?ID=396...)
The Borough of Palmerton is now expected to remediate the situation, but there are no clear guidelines on approved filtration systems, funding sources, or validation techniques.
The EPA must:
• Increase monitoring for PFOA/PFOS in waste and wastewater by wastewater treatment plants (WWTP) and companies that recycle the waste and wastewater (e.g., Synagro).
• Enforce PFOA/PFOS limits for WWTP and companies that recycle waste and wastewater (e.g., Synagro).
• Require increased monitoring for PFOA/PFOS in municipal water supplies to accurately assess the scope of PFOA/PFOS presence in drinking water.
• For those municipalities that measure PFOA/PFOS and exceed guidelines in their water supplies, the EPA must define the specifications for appropriate water filtration.
• Provide guidance for municipalities designated as Environmental Justice regions impacted by excessive PFOA/PFOS in their drinking water. The resulting documentation must be publicly posted and made available for public comment.
• Stop all PFAS discharges from multiple industrial categories through the Effluent Guidelines Program. The specific actions include revising the Organic Chemicals, Plastics, and Synthetic Fibers Effluent Limitations Guidelines (ELGs) to address wastewater discharge from PFAS manufacturing facilities; revising the Metal Finishing and Electroplating ELGs to address wastewater discharge from metal finishing and electroplating operations focusing on facilities using PFAS-based fume suppressants and wetting agents; and revising the Landfills ELGs to address PFAS discharges from landfill leachate.
• Partner with organizations, including the World Health Organization, National Oceanic and Atmospheric Administration, and USDA, to monitor the scale and scope of PFAS-related effects on humans, livestock, and wildlife in rural communities.
• The EPA must offer grants for municipal-scale water filters, systems such as anaerobic digestion, and for developing similar systems that can significantly reduce the amount of sewage sludge produced by traditional wastewater treatment practices.
• The EPA must call for an end to using sewage sludge in fields that grow animal feed or food for humans.
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