The following comments were submitted on Dec. 12, 2024 to the Minnesota Pollution Control Agency.
MPCA’s guiding principles on PFAS pollution are laudable ones, and they are principles that we agree should be pursued:
Prevent PFAS pollution wherever possible.
Manage PFAS pollution when prevention is not feasible or pollution has already occurred.
Clean up PFAS pollution at contaminated sites.
The comments we submit today are focused on preventing PFAS pollution. Any amount of PFAS in soil is dangerous, for a number of reasons.
Do not spread biosolids with any PFOA or PFOS on farmland: find ways to store safely while reducing waste
All four tiers of concentration levels proposed by MPCA are too high for PFOA and PFOS. The Environmental Protection Agency and other federal government agencies such as the Department of Health and Human Services have said there is no safe level of ingestion of PFOA and PFOS, which is why the maximum contaminant level goals (MCLGs) for drinking water are zero. Until MPCA can demonstrate that no PFOA or PFOS will enter food (whether for humans or animals) grown on a sludged site, sludge with any measurable level of PFOA or PFOS should not be land applied. The same for demonstrating that no PFOA or PFOS will enter ground or surface waters after land application.
MPCA has said it is looking to Michigan as a model for its strategy. Michigan’s interim biosolids strategy establishes concentrations levels for PFOA and PFOS at which biosolids cannot be applied and levels for notifying the state and landowner before application, much like the proposed MN PFOA and PFOS rules. These do not seem to be based on any health risk analysis, nor are they based, like Maine’s 2018 strategy, on the potential for groundwater contamination. These levels and actions seem to be based on what wastewater treatment plants can achieve. While these plants will be important partners in implementing any biosolids strategy, we must have higher standards when it comes to human and animal health. The current strategy is not sufficiently protective of human health, animal health, or farmer livelihoods.
To continue reading, please download a PDF of the full comments.
