Sewer Sludge from Blue Plains Advanced Wastewater Treatment Plant in Washington, DC is highly contaminated with PFAS
Report by DC Statehood Green Party warns of the dangers of PFAS in the city.
Greens point to toxic Bloom Soil Conditioner, a product of DC Water
By Pat Elder
July 31, 2021
DC Water treats wastewater from the District of Columbia, Maryland, and Virginia at the Blue Plains Advanced Wastewater Treatment Plant.
The DC Statehood Green Party (Green Party) sent a letter this week to Tommy Wells, Director of the Washington, D.C. Department of Energy & Environment, warning of unregulated PFAS contamination in the nation’s capital. The left-of-center party cited a study by the Sierra Club and the Ecology Center that found astronomical levels of toxic PFAS (per- and polyfluoroalkyl substances) in Bloom Soil Conditioner produced by DC Water’s Blue Plains Advanced Wastewater Treatment Plant. The product, sold in hardware stores in the district, contains 100% sewer sludge, euphemistically referred to as “biosolids.”
The firm SGS AXYS Analytical Services measured levels of PFAS chemicals in the soil products from nine garden fertilizers in eight states and the District of Columbia. Total PFAS ranged from 38,000 parts per trillion (ppt) to 223,000 ppt.
Bloom soil conditioner was the most contaminated at 223,000 ppt for all PFAS tested. Bloom’s product contained 23,800 ppt of Perfluorooctanoic acid (PFOA) and 22,100 ppt of Perfluorooctane sulfonic acid (PFOS), two of the most toxic varieties of PFAS.
Ann Wilcox, a longtime DC Statehood Green party leader and 2020 candidate for DC Council, said, “Our preliminary inquiry shows that PFAS are dangerous chemicals that must be regulated by the DC Government. We call on DC authorities to conduct comprehensive testing for PFAS in DC soil, water, and fish."
Sewer sludge is poisonous and we’re spreading it over our gardens and farm fields. The rains come and the waters drain into the aquifer and run into surface water. Both paths ultimately lead to human consumption. The stuff doesn’t break down. PFOS may be the most frightening of all varieties of PFAS because it travels far in water and wildly bioaccumulates in fish. Levels of PFOS above 2 ppt in rivers are believed to be a threat to public health.
The DC Government’s toxic sludge is spread on the city’s school gardens.
People catch catfish and bass in the Potomac just south of DC Water’s Blue Plains Advanced Wastewater Treatment Plant. They catch it and they eat it. What’s in the fish?
Michigan tested 2,841 fish for PFAS last year and found the average fish contained 93,000 ppt of PFAS. Almost all of it was PFOS. The state limits PFOS in drinking water to 16 ppt, but people can eat the fish.
Wilcox sounded an alarm on the quality of the water in the Potomac River in Washington. "We're deeply concerned with the levels of PFAS in the wastewater that enters the Potomac from Blue Plains, particularly its impact on the fish.”
All types of PFAS are unregulated by the US government and the DC government, meaning that military and industrial sites are legally allowed to flush PFAS chemicals down wastewater drains where they settle in the solid materials during wastewater treatment.
Sonya Lunder, Senior Toxics Policy Advisor for the Sierra Club, said, “EPA and states must take swift action to enact strong standards to safeguard us from toxic PFAS continuing to flow into our wastewater and keep contaminated sewage wastes out of home gardens and farmlands.”
The DC Statehood Green Party is working in the nation’s capital to do the same.
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Following is the Green Party’s compelling critique of DC Water’s website pertaining to PFAS, followed by a brief look into potential sources of PFAS entering Blue Plains.
DC Water & PFAS
See the PFAS Frequently Asked Questions page from the DC Water website.
Read the questions and answers regarding PFAS that DC Water poses and see our responses. Many of the answers provided by DC Water are misleading or incomplete.
DC Water - WHAT ARE PFAS/WHERE DO THEY COME FROM?
PFAS are a group of more than 3,000 man-made chemicals that are fire, oil, grease, water and stain resistant, and are found in a wide array of consumer and industrial products, including non-stick cookware, stain repellant, dental floss, cleaning products, and cosmetics.
Over the last 70 years, PFAS, like Teflon, have been used around the world to enhance everyday products. Exposure to humans can occur by eating, inhaling, or even touching the product. Some PFAS are now known to be bad for human health. While there are hundreds of banned PFAS, there are thousands more in existence, and more than 600 still used commercially in the United States.
Green Response - There are nearly 8,000 PFAS varieties that have been developed, while only two, PFOS and PFOA, are included in the EPA’s Lifetime Health Advisory of 70 ppt for drinking water. The US government, the DOD, and manufacturers like 3M have known these chemicals are harmful for 50 years. The use of aqueous film-forming foam, or AFFF is one of the most likely sources of PFAS in our drinking water. AFFF is the active ingredient in fire-fighting foams used by the four branches of the military, as well as the Coast Guard, and, very likely, DC Fire.
Consuming seafood caught from waters contaminated with PFAS is the primary source of the contamination in our bodies. The European Food Safety Authority EFSA estimates that fish and other seafood account for up to 86% of dietary PFAS exposure in adults. Foods grown in soils treated with sewer sludge, euphemistically called “biosolids,” are the second most prevalent pathway for human exposure. Water is a distant third, although it is still a significant source for contamination. The people catching catfish and bass and other species from the Anacostia and Potomac rivers are likely to be the most endangered, although we can’t say for sure until a robust testing regime is carried out by a truly independent firm for the surface waters and aquatic life in the district.
DC Water - WHY ARE PFAS A PROBLEM?
PFAS do not break down or go away in the environment. In fact, these compounds have been found in rainwater samples, and one or more PFAS is found in the blood of most Americans, at low levels.
However, this does not mean they will cause a health problem. Research is ongoing to understand the human health effects from the compounds, and the EPA and the U.S. Centers for Disease Control and Prevention describe the health effects from exposure to low environmental levels of PFAS as uncertain.
Green Response - It’s time to update your website. New findings confirming disastrous health impacts are being published almost every day. In May, 2021, the Agency for Toxic Substances and Disease Registry, (ATSDR) published its Toxicological Profile for Perfluoroalkyls. They summarize their findings:
“Evidence from epidemiological studies suggest associations between perfluoroalkyl exposure and several health outcomes including liver damage, increases in serum lipids, thyroid disease, immune effects, reproductive toxicity, and developmental toxicity. The primary health effects observed in laboratory animals are liver, developmental, and immune toxicity.”
Pub Med, a publication of the NIH’s National Library of Medicine is an amazing resource https://pubmed.ncbi.nlm.nih.gov/ Simply search for an individual PFAS by its acronym. For instance, a search for PFOA returns 3,210 results, like this: J Endocrinol Invest 2017 Feb;40(2):105-121. doi: 10.1007/s40618-016-0572-z. Epub 2016 Nov 11. Thyroid disruption by perfluorooctane sulfonate (PFOS) and perfluorooctanoate (PFOA) F Coperchini 1, et. al.
No one should have PFAS in their blood. The toxins don’t break down in our bodies and they typically bioaccumulate. PFAS are a very real threat to the residents of Washington, DC. The Environmental Working Group says we ought to limit PFAS consumption in water to 1 part per trillion per day.
DC Water - HOW DOES PFAS GET INTO WATER SUPPLIES?
The main sources of PFAS contamination in water are industries that make or use PFAS in their products, and military bases and airfields that have conducted fire-fighting training. The PFAS gets into wastewater and storm water and runs off into streams, rivers or groundwater.
Green Response - DC Water left out landfills and transfer stations, both present and past.
In 2019, three mattresses, two box springs, two couches, and one chair were pulled out of the waste stream at the Coventry Landfill in Vermont and tested for per-and poly fluoroalkyl substances, (PFAS) chemicals. Small swatches of fabric were analyzed and found to contain a combined concentration of 1,215,330 ppt of PFAS. (See Appendix C).
DC Water - WHAT ABOUT THE DISTRICT’S DRINKING WATER?
In 2014, DC Water and other utilities that use water from the Potomac River tested drinking water supplies for several PFAS. No detectable levels of these compounds were found in D.C.’s drinking water. These test results were published at www.dcwater.com/UCMR3results (Unregulated Contaminant Monitoring Rule, UCMR3)
Newer, more precise methods of testing have been developed since the 2014 testing to detect extremely low levels of PFAS. The Environmental Working Group recently released a study which detected PFAS in District drinking water at levels well below any established EPA health advisory for these compounds.
Green Response - At the time of the UCMR3 monitoring, the laboratory minimum reporting levels required by EPA for the six PFAS compounds tested varied from 10 ppt to 90 ppt. per compound. Some of the laboratories that analyzed the samples taken during UCMR3 achieved lower reporting limits than those required by EPA, but only reported concentrations greater than EPA’s required reporting limits.
The PFAS levels in Washington DC in 2014 are likely much higher than the 21.7 ppt officially announced. People in Washington, DC who have been drinking the city’s water for many years have accumulated high levels of PFAS in their bodies.
UCMR3
Detection Detection
PFAS Min. Limits - 2014 Min. Limits Today
PFOA 20 ppt 2 ppt
PFOS 40 ppt 4 ppt
PFHxS 30 ppt 3 ppt
PFHpA 10 ppt 2 ppt
PFNA 20 ppt 2 ppt
PFBS 90 ppt 9 ppt
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To take this to mathematical extremes, the chart illustrates that samples collected in 2014 could have contained values up to the following levels that would not have been reported:
PFOA 19
PFOS 39
PFHxS 29
PFHpA 9
PFNA 19
PFBS 89
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All of DC's water comes from the Potomac so we must analyze that source. There are military installations, industrial sites, and wastewater treatment plants up and down the Potomac north of Washington that discharge PFAS into the river, although we don’t have test results.
The Blue Plains Advanced Wastewater Treatment Plant
There does not appear to be any type of regulatory oversight in the District of Columbia for PFAS. There is no mention of PFAS in the current Blue Plains #DC0021199 Authorization to Discharge under the National Pollutant Discharge Elimination System permit. https://www.epa.gov/sites/production/files/2018-10/documents/blueplains_2018_final_permit.pdf
PFAS is not monitored in the influent, effluent, or sludge at Blue Plains. See: https://www.dcwater.com/pretreatment. Then, see: 2020 DC Water’s Pretreatment Annual Report (Part 1 of 2)
The following military sites that are known to use PFAS and discharge waste to Blue Plains:
· Andrews AFB (through Piscataway WWTP then to Blue Plains)
· Naval Support Activity Bethesda, MD
· Fort Detrick - Forest Glen
· Naval Research Lab
· Naval Support Facility Carderock
· Joint Base Anacostia-Bolling*
See Tables 1 & 2: https://www.dcwater.com/sites/default/files/permit_files/2019%20Annual%20DC%20Water%20Pretreatment%20Report%20with%20Attachment%201.pdf
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Documentation of PFAS use at these military installations:
Andrews sends sewage to Piscataway WWTP p. 3-4 https://www.jba.af.mil/Portals/38/documents/About-Us/Environmental/AFD-130827-015.pdf
The Piscataway WWTP sends its sewage to Blue Plains.
Search: BLUE PLAINS SERVICE AREA (BPSA) PHASE I – FACILITY PLANNING STUDY A Strategic Wastewater Conveyance Treatment Capacity Evaluation for the BPSA Through the Year 2030
Naval Support Activity, Bethesda
Bethesda is included in a database compiled by the Department of Defense Environmental Restoration Program (DERP - no longer online) showing Sites with Potential PFC/PFAS Contamination. The former lab disposal area has been designated as an area of concern, (AOC). Bethesda is responsible for base operational support for its major tenant, the Walter Reed National Military Medical Center.
Fort Detrick - Forest Glen https://home.army.mil/detrick/application/files/2716/0855/2521/RAB_Minutes_AUG_2020_Final-12-4-20-upload.pdf
Naval Research Lab
https://www.ehn.org/pfas-free-firefighting-foam-2645972099.html
Naval Support Facility Carderock
“Aqueous Film Forming Foam Report to Congress Nov 3, 2017 - DoD Installations with a Known or Suspected Release of PFOS/PFOA. No other information is known on this base regarding PFAS contamination.
*Joint Base Anacostia-Bolling the sewage from JB Anacostia-Bolling is sent to Blue Plains. How much PFAS is contained within the sewage? The US Air Force Civil Engineer Center contains no record of PFAS contamination present in the groundwater, soil, etc. at the old Bolling AFB site. This may be unique among all Air Force installations across the country. To gain a perspective of the nature of the problem see this list of the 100 most contaminated military sites across the country.
Green Party, continued -
We don’t know whether these facilities deliver PFAS-laden sewage or leachate to Blue Plains, although this is a common practice nationwide. Leachate is contaminated liquid that moves through the soil and into groundwater and surface water.
We don’t know the levels of these chemicals in the river and in aquatic life. We don’t know the levels of PFAS contamination in the sludge leaving the plant that is likely spread on agricultural fields. We don’t know where the sludge is spread and the levels of contamination in the soils and agricultural produce grown on the contaminated farms. We want to find out.
Six directors of environmental agencies in New England wrote a historic letter to incoming EPA chief Michael Regan in early February, 2021. The environmental chiefs pleaded with the EPA to step up to develop PFAS surface water standards and fish consumption guidance values. They made it clear that wastewater treatment plants are the source of much of the PFAS contamination crisis.
PFAS entering wastewater treatment facilities from commercial, military, industrial, waste, and residential sources is not removed from the effluent at Blue Plains or anywhere else. Special Projects Manager Ned Beecher of the North East Biosolids & Residuals Association (NEBRA) says all wastewater contains PFAS. He would know.
The EPA hasn’t been much help. The EPA’s interim guidance on PFAS tells us they’re not sure how to manage PFAS. They’re uncertain about how to handle wastewater saturated with PFAS. They don’t know very much about incineration and how bad it likely is. They don’t know the extent of PFAS-tainted leachate that seeps from landfills, and the EPA is not sure about the contamination caused by spreading PFAS-contaminated sewer sludge on farm fields. They just don’t know what to do, so they’ve decided not to regulate the stuff in any meaningful way, while agreeing to study it more. It’s been their playbook since way before the Trump disaster. We’ll see if the Biden administration gets tougher.
The point here is that it is up to the DC government to take measures to protect public health from the ravages of these chemicals.
Ft. Totten Transfer Station houses roughly two-thirds of the district’s waste while the Benning Road Transfer Station receives the other third. 3,000 tons a day are shipped to Covanta Fairfax Waste-to-Energy.
Covanta says its plant takes non-hazardous waste - otherwise destined for the landfill - and incinerates it to generate electricity. If we consider the couch and the carpet from Vermont’s landfill, it is certain Covanta is burning hazardous waste and sprinkling toxic powder on communities in Fairfax County. We say PFAS is hazardous. The EPA does not, so Covanta can burn it.
The District also sends waste with unspecified amounts of PFAS to the following locations:
Annapolis Junction Transfer Station Jessup, Md
GeoCycle Waste to Energy 2175 Gardner Blvd, Holly Hill, SC
Covanta Energy Corporation Waste to Energy Lorton, VA
Alexandria Waste to Energy, Alexandria, Virginia
Wheelabrator Baltimore Waste to Energy, Baltimore, MD
We have so many questions.
How is the leachate handled from these stations and from retired landfills? Specifically, where does the leachate from the old landfill at Joint Base Anacostia Bolling go? Are Industrial discharges to Blue Plains coming from JB Anacostia-Bolling? Where does the leachate from the old Kenilworth Landfill go?
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Ann Wilcox with the DC Statehood Green Party said she expects a response to the letter from Tommy Wells, DC’s environmental chief.