Biosolids Corner, January February March 2022 Issue        By Diane Garvey


A Trip Down Memory Lane

At the beginning of a new year, it can be interesting to look back. The following are topics covered in Biosolids Corner over the years. Some of these titles look like reoccurring themes. Some make me think, I should read that again. Overall I would say; the more things change, the more they stay the same.

2000- Phosphorous Index Adopted in Maryland
2001-How to get positive press coverage- use catch phrases like “slush from a flush” and using words like biosolidarity and biosolidologist
MABA launches research to answer the question “ Why do biosolids stink?”
2002- Youthful Perspective Needed – Start of the YP program
2003- Biosolids Odor Control Plan Guidance
2004- Changes Proposed to General Permits for Land Application of Biosolids
2005- Landfill Prices Increasing by 35 or 50%
2006- Storage of Biosolids
2007- Distribution and Marketing of Heat Dried Biosolids
2008- National Biosolids Conference Focuses on Climate Change, also number of issues of Water Quality Manager Magazine changed from 6 per year to 4 per year
2009- The Future of Heat Dried Biosolids
2010- WERF Researchers Examine Connect ions bet ween Odors and Pathogens
2011- Charting the Future of Biosolids Management
2012- New Sewage Sludge Incineration (SSI) regulations
2013- Land Applier’s Compliance Checklist
2014- Biosolids Legal Update. Gilbert v. Synagro
2015- The Truthiness of Climate Change, Evolution…and Biosolids - a shift in trust from science fact to pseudo-science opinions has reached critical mass.
2016- Does biosolids qualit y improve during st orage? It can, if the conditions are
2017- The Compatibility of Biosolids Land Application with Nutrient Management Regulations and the P-Index
2018- PWEA Provides Comment s on PADEP Draft Guidelines for Beneficial Use of Biosolids at Active Mine Sites
2019- Literature on Positive Impacts of Biosolids
2020- COVID-19 as It Relates to Biosolids
2021- Potential Changes to General Permits for Land Application of Biosolids


Monitoring Biosolids for PFOS and PFOAs (1):

In the last Biosolids Corner article we covered aspects of the Pre draft General Permit. This included proposed monitoring for PFAS at a frequency the same as monitoring for metals and PCBs which varies from one to twelve times per year. Briefly, points made in that article


  • There are no standard methods or PADEP accredited labs to analyze PFAS. It will be at least 2 years until there are.
  • The cost of monitoring for PFAS is very high, about $1700 per sampling event.
  • PFAS are ubiquitous. Biosolids are not a significant source of PFAS exposure for humans.
  • Monitoring conducted in 2022 will not be representative of biosolids quality in 3 or 4 years because PFAS concentrations will be going down. The two most common forms, PFOS and PFOA are no longer used in manufacturing.

Continued examination of this concept during meetings with the Eastern PA Water Pollution Control Operators Biosolids Ad Hoc Committee and more recently with the PADEP Biosolids Workgroup has resulted in additional ideas.

By simply monitoring PFAS concentration in biosolids PADEP is not seeing the big picture. We should look at what we learned during the Lewis and Clark Expedition. Part of their assignment was to describe the flora and fauna they observed along the way. If, for example, Lewis and Clark wanted to describe a certain bird, first, they would kill it. Then they would
nail it to a board and measure the wingspan, count the feathers, report the color, the shape of the beak and the weight of the bird. If you were to ask a Native American to describe this bird, they would tell you how it interacted with the environment. They would tell you what it ate, what ate it, where it lived, what habitat it needed to live, how it raised its young, what conditions are needed for it to reproduce, etc. Just like the bird, simply taking PFAS measurements does not provide enough knowledge to determine the best way to manage its impact on, and disposition in the environment.

The proposed PFAS monitoring results is an expense to WRRFs and ultimately every sewer user. WRRFs are not the source of PFAS. We should be guided by the concept that the polluter pays. DEP and EPA should be providing incentives for product stewardship by manufacturers, not penalizing everyone who flushes.

PFAS monitoring requirements should be subject to a complete cost benefit analysis. These costs and benefits should encompass economic, environmental and societal impacts. Forexample, PSAF monitoring will likely lead to less land application and more landfill disposal and incineration. What are the pathways of exposure from landfill and incineration? These should be studied concurrently.

PADEP is currently developing MCLs for PFAS in drinking water. What if they do not take a holistic approach? Are they doing a full cost benefit analysis? How many public water supplies will have to install activated carbon filters to remove PFAS? Are they considering the ultimate disposal of the activated carbon used to remove PFAS from drinking water(2)? How will this influence water and sewer rates in economically disadvantaged cities? What will be the MCLs for groundwater, surface water and remediated soils? Will PFAS MCLs in surface water result in PFAS limits in NPDES permits? What about cleanup standards for PFAS in soils in areas where firefighting foam was used? Will we have to condemn these areas and isolate them like Chernobyl?

Industrial discharges that could be PFAS sources to WRRFs include:
• Landfills
• Centralized Waste Management Facilities
• Airfields – Commercial, Private, and Military
• Department of Defense Facilities
• Fire Department Training Facilities
• Industrial Laundries
• Petroleum or Petrochemical
• Chemical Manufacturers
• Plastics Manufacturers
• Textile and Leather Facilities
• Paint Manufacturers
• Pulp and Paper Facilities


(1) Per- and polyfluoroalkyl substances (PFAS) are a group of man-made chemicals that includes PFOA, PFOS, GenX, and many other chemicals. PFAS have been manufactured and used in a variety of industries since the 1940s. Although PFOA and PFOS are now banned, they were
used in firefighting foam, fast food containers/wrappers, microwave popcorn bags, pizza boxes, candy wrappers, nonstick cookware, stain resistant coatings used on carpets, upholstery, and other fabrics, water resistant clothing, cleaning products and more. PFAS are found almost everywhere including in most public water supplies, wastewater, and biosolids.


(2) To regenerate activated carbon filters they must heat to over 1600 degrees C to destroy PFAS. However, at this temperature, unacceptable levels of mercury are released. Do the used activated carbon filters have to be disposed at a hazardous waste site? Or are they disposed in a solid waste landfill where the PFAS impact the leachate quality?


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Diane Garvey was recently awarded the David A. Long Memorial Educational Service Award by the Pennsylvania Water Environment Association!


This award was established in honor of Dr. David A. Long in recognition of his lifelong service and dedication toward the education and training of wastewater and water treatment plant operators and environmental professionals.


This award is presented to individuals who distinguish themselves through their efforts and contributions to the education of water quality professionals.

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