Maryland issues first fish advisory for PFAS
Measure limited to Piscataway Creek - contaminated by Joint Base Andrews
Limited advisory adopts weak standards
By Pat Elder
October 19, 2021
View looking northwest to the spot where Piscataway Creek flows out of Joint Base Andrews in Maryland. Notice the containment boom inside the base that may be used as a temporary floating barrier to contain oil or chemical leaks.
The Maryland Department of the Environment (MDE) Water and Science Administration has issued a Fish Consumption Advisory for tidal and non-tidal waters of Piscataway Creek in Prince George’s County, Maryland, about 6 miles south of Washington. Piscataway Creek is a tributary of the Potomac River. The advisory is the first time Maryland has issued a warning for PFAS compounds in fish. The regulatory action covers fish contaminated with Per fluoro octane sulfonate (PFOS). The state has determined that “Exposure to PFOS over certain levels may increase the risk of developmental health effects during pregnancy or to breastfed infants, as well as the risk of cancer, immune system damage, damage to the liver, thyroid, or other organ systems.”
The new regulatory measures adopt weak standards that fail to protect public health. The fish consumption advisory lacks enforcement mechanisms. It remains to be seen if the state will post signs at popular fishing grounds or plans to notify the health community and expectant mothers.
MDE found that PFOS concentrations in the tissue of a redbreast sunfish and yellow bullhead catfish in the non-tidal portion of Piscataway Creek exceeded MDE limits. PFOS concentrations in a largemouth bass in the tidal headwaters of Piscataway Creek also exceeded the limits. See the MDE Report here.
MDE recommends that adults and children should consume no more than 1 meal per month of Redbreast Sunfish from the affected area. An adult serving is 8 ounces. A Redbreast Sunfish was found to contain 359,000 ppt of PFOS and 374,850 ppt of total PFAS.
MDE also recommends consumption of no more than 7 meals per month (for children only) of Yellow Bullhead Catfish. A child’s serving is 3 ounces. The Yellow Bullhead Catfish had 24,700 ppt of PFOS and 29,180 ppt overall. That’s concentrations of 204,260 ppt. allowed per month for children.
Finally, MDE recommends that adults should limit their consumption of Largemouth Bass to 3 meals per month. A Largemouth Bass had 94,200 ppt of PFOS and 100,690 total PFAS. The state allows total concentrations up to 302,070 ppt.
MDE-calculated risk-based screening concentration for PFOS for fish consumption
We’ll examine the state’s guidelines for Women of child-bearing age (67 kg.)
· Consumption Rate MG/Day 29,825
· The state says it’s OK for pregnant women to consume 48 “8-ounce” meals per year.
· Fish Tissue cooked Screening Concentrations are 64 ug/kg for women of child-bearing age. (64,000 ppt)
Just a little math:
· 29,825 mg-day = 1.05 ounces/day
· 8 ounces = 227 grams
· 48 “8 ounce meals” is same as 48 “227 gram meals.”
· 48 meals x 227 grams = 10,896 grams of the poisoned fish allowed per year.
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So, the state of Maryland says it’s OK for a pregnant woman to consume 8 ounces of fish containing 64,000 ppt of PFOS 48 times a year. If the filet of the fish contains 64,000 ppt of PFOS, that’s 64 parts per billion, which is the same as 64 nanograms per gram. So, 64 ng/g x 227 g = 14,528 ng of PFOS.
To recap: An 8-ounce serving of fish with a concentration of 64,000 ppt contains 14,528 nanograms of PFOS. This is an amount of the toxic fluorosurfactant.
Despite all the talk and bluster, the EPA and the FDA have failed to set standards. The European Food Safety Authority (EFSA) has set a Tolerable Weekly Intake of 4.4 nanograms per kilogram of body weight for PFOS (and several other PFAS) in food. So, according to this guideline, our expectant mom weighing 150 pounds (67.8 kilos) can “safely” consume about 300 nanograms per week of PFAS chemicals. (4.4 ng x 67.8 kg = 298.32)
One meal of the fish containing 14,528 ng of PFOS is 48 times greater than the European weekly limit, while the state of Maryland is telling pregnant women they can eat this fish 48 times in a year or 12 times during their first trimester.
- European Food Safety Authority
The MDE says there is not enough data to apply this advisory to the much larger Potomac River - 301 Bridge to the DC line area. The MDE is making excuses for its lack of attention to this pressing public health crisis. It has repeated this refrain in public forums. In essence, they’re saying there are no fish advisories because they haven’t done the testing. Meanwhile, a few miles up the Potomac, the government of the District of Columbia has done nothing to protect public health from the ravages of these chemicals. Almost all of the PFAS in our bodies comes from the food we eat, especially fish from contaminated waters.
The MDE report contains contradictions. MDE says it has issued these advisories and “strongly urges the public to avoid eating these [three] fish, especially if you are pregnant or may become pregnant,” yet, the guidelines allow frightening amounts of these poisonous fluoro surfacants to be consumed by expectant mothers.
A Bluegill was found in Piscataway Creek with 5,210 ppt of PFOS and 6,170 ppt of total PFAS. A Blue Catfish had 2,520 ppt of PFOS and 3,510 of overall PFAS. Although the state dismisses these concentrations, they’re allowing the public to consume unlimited amounts of these fish - and the chemicals that accumulate in the human body and never break down. It’s all bad.
MDE only tested for three varieties of the 8,000 kinds of PFAS: PFOS, PFOA, and PFBS. MDE says PFOA and PFBS were not detected in any fish tissue samples, but the following chemicals were detected, several with concentrations in the many parts per trillion:
PFHxS
PFNA
PFDA
PFUnA
PFDoA
PFTrDA
PFTA
There’s a lack of space and time to explore how consumption of these unheralded chemicals can also destroy our health and progeny, but MDE would prefer not to address these compounds in the fish.
The extraordinarily deadly PFOA (Per fluoro octanoic acid) does not travel well in water like PFOS. There is a case to be made that this particular compound is the most lethal of all PFAS.
Until last month, the Air Force had reported levels of 30,000 ppt for PFOS and 4,500 ppt for PFOA in the groundwater at J.B. Andrews. Those numbers were revised upward to 33,000 ppt for PFOS and a staggering 435,000 ppt for PFOA. Only Edwards (1.2 million), Pt. Mugu (1.71 million), England AFB in Alexandria, LA (3.82 million), and Plattsburgh (981,000) had higher numbers for PFOA.
This region of Prince George’s County, Maryland joins the league of the most severely contaminated places on earth. The land is destroyed in perpetuity.
One day, I suspect, Marylanders will begin to take this threat seriously.
Eastern Shore Sampling for PFAS?
The MDE says, “The results from the regular fall fish collection in the Eastern Shore Region showed no levels of concern.” It’s curious because the state has never before published PFAS testing for fish. Where are those results?
The word “swimming” appears 22 times in the 28 page report. The word “fishing appears 3 times.
Maryland Department of the Environment
Military Poisons
Summary of Total PFAS and PFOS Sampling Results for Surface Water
_________________________________________________________________________
Location Media Maximum Maximum
Concentration Concentration
PFAS (ng/L) PFOS (ng/L)
_________________________________________________________________________
Pisc. Creek non-tidal surface 2,781.8 894.7
water
_________________________________________________________________________
Pisc. Creek tidal surface 234.4 93.9
water
_________________________________________________________________________
The MDE’s non-tidal test sampled water at Commo Rd, more than three miles downstream from the location where the creek empties from the southern boundary of the base. The sample collected by Military Poisons was taken at the boundary of the base.
Although the state says PFAS compounds “were only intermittently detected at or near the analytical detection limits in the Nanjemoy Creek reference sites,” the fact remains that the presence of these chemicals at these miniscule levels pose a risk to public health due to the propensity of these chemicals to bioaccumulate in fish tissue. The Wisconsin Department of the Environment says any levels above 2 parts per trillion pose a threat, while the European Union has set a regulatory threshold of .65 ppt in surface water.
According to the text of the MDE report, the results within Piscataway Creek ranged to as high as 3,193 ng/L total PFAS in the non-tidal headwaters along Colonial Lane just south of Joint Base Andrews. Figure 1 Site Map, however, shows that a sample taken at Colonial Lane, very close to the boundary of the base, contained 3,452 ng/L.
The MDE notes that PFAS surface water concentrations in Piscataway Creek dissipated with distance as the creek progressed downstream of potential sources at Joint Base Andrews. The concentration of PFAS in the tidal headwaters of Piscataway Creek was reported to be 207 ppt which included 74 ppt of PFOS. The MDE failed to mention that the Piscataway Wastewater Treatment Plant in Accokeek is also a likely culprit for contaminating the creek and the Potomac River with these carcinogens. The facility, also located at the tidal headwaters of the creek, includes about 20 buildings spread over approximately 300 acres on the shores of the creek.
The sanitary sewer system on the western side of JB Andrews discharges to the Piscataway WWTP, (shown in photo), while the eastern half of the base sends sewage to the Western Branch WWTP which flows into Western Branch, less than a mile from the scenic Jug Bay on the Patuxent River. The severely contaminated groundwater and surface water from the base drain into the Potomac and the Patuxent rivers.
As a teenager I lived on Lyons Creek on the Patuxent River, on the other side of the river, just south of the spot where the Western Branch empties into Jug Bay. I remember motoring up there in a little skiff and noticing the light brown water entering the river. I don’t know if it is still that way. Regardless, PFAS is colorless and odorless. All wastewater treatment plants discharge PFAS. This one may be a heavy hitter. It’s a shame MDE isn’t more on the ball.
The Western Branch WWTP allows open burning which may threaten the air of folks downwind in Anne Arundel, Prince Georges, and Calvert counties in Maryland.
The Piscataway treatment plant is undergoing construction of a new 60 million gallon per day raw wastewater pumping station to replace the existing 30 million gallon per day station. Wastewater treatment plants do not treat for PFAS. The carcinogens are pumped into creeks and rivers. In 2018 almost a million gallons of untreated wastewater flowed into Piscataway Creek from the Piscataway Wastewater Treatment Plant.
More on the fish
MDE
According to the MDE, “Although concentrations of PFOS were detected in all fish species tested within the Nanjemoy Creek reference sites the concentrations were below all the site-specific health-based consumption screening criteria. PFOS fish tissue concentrations in the Nanjemoy Creek reference site were less than the PFOS fish tissue concentrations for the equivalent species within the Piscataway Creek study area.”
The state is saying it’s no big deal that fish in Nanjemoy Creek were shown to have 10 ug/kg of total PFAS, which includes 5 ug/kg of PFOS. We need to break this down.
10 ug/kg is 10 parts per billion. 10 parts per billion is 10,000 parts per trillion. Eating a fish with concentrations of 10,000 parts per trillion is below the state’s “site-specific health-based consumption screening criteria.”
To provide a basis for comparison, many states have set a limit for 5 compounds of PFAS (including PFOA and PFOA) at 20 parts per trillion or less in drinking water. The EPA has a non-mandatory advisory that suggests municipalities provide water that does not exceed 70 parts per trillion. Testing performed by MDE has shown that most water service providers are adhering to the 70 ppt advisory. It seems that PFAS is a big deal in drinking water, while it’s OK to eat as much fish as you like from Nanjemoy Creek containing 10,000 parts per trillion of PFAS.
Of course, the MDE just shrugged its shoulders three years ago when a smallmouth bass was found to have blood plasma concentrations of 574,000 ppt where Antietam Creek empties into the Potomac.
Military Poisons - Test Results - Piscataway Creek where it flows out of Joint Base Andrews
I was joined by Sherman Hardy on the half-mile hike up Piscataway Creek from the end of Clendinnen Drive off of Woodyard Road in Clinton. Sherman lives in Clinton and was determined to test the waters coming out of the Air Force Base.
Here, the environmental activist and Air Force veteran shows the samples he collected where the creek drains out of J.B. Andrews. Sherman sent emails to dozens of county and state officials with his results which nearly mirrored those above. He was disappointed that no Prince George’s County or state of Maryland officials responded to his results and questions regarding the impact on public health in the vicinity.
Military Poisons - Test Results
Mouth of Piscataway Creek at Farmington Landing, a popular fishing destination
Alpha Analytical
The MDE contracted the services of Alpha Analytical Mansfield Laboratory for sample analysis of fish tissue and surface water. In September 2020, the Maryland MDE released a report entitled “St. Mary’s River Pilot Study of PFAS Occurrence in Surface Water and Oysters.” (PFAS Pilot Study) that analyzed the levels of PFAS in seawater and oysters. Specifically, the PFAS Pilot Study concluded that although PFAS is present in tidal waters of the St. Mary’s River, the concentrations are “significantly below risk based recreational use screening criteria and oyster consumption site-specific screening criteria.”
While the Pilot Study makes these broad conclusions, the analytical methods and basis for the screening criteria used by MDE are questionable, resulting in a misleading of the public, and providing a deceptive and false sense of safety. The tests performed by Alpha Analytical Laboratory had a detection limit for oysters at one microgram per kilogram (1 µg/kg) which is equivalent to 1 part per billion, or 1,000 parts per trillion. (ppt.)
Oysters I tested using Eurofins found 2,070 ppt of PFAS. I don’t eat them anymore.
In 2004 Alpha Analytical had to pay a $700,000 fine to the state of Massachusetts because the state found the company mislabeled containers of hazardous waste, failed to take required safety precautions, and improperly operated a wastewater treatment system.
Psychology
Plug in to the psychology here while accepting the evidence from the Air Force that large quantities of these toxins are flowing out of Joint Base Andrews. Here’s the MDE:
“In addition to potential PFAS sources emanating from Joint Base Andrews the Department continues to track down potential sources in the watershed and is working with the Prince George’s Fire Department Fire/EMS Training Academy, which is present along Commo Road adjacent to Piscataway Creek, to determine if there are PFAS sources associated with the facility or others in the watershed.”
Why does the state refer to “potential sources emanating from Joint Base Andrews”? Why do they cast a shadow of doubt? A reader might reasonably assume the Air Force isn’t to blame, especially when the MDE says it’s examining other sources. Why hasn’t Maryland joined multiple states in testing all of these obvious culprits?
The MDE says, “The results and conclusions from this study will be used by MDE to determine the need for more immediate risk reduction actions, such as the issuance of fish advisories.”
It’s hollow. Their advisories do little to protect human health.