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PFAS and Saratoga Biochar

PFAS and Saratoga Biochar
A Backgrounder from Clean Air Action Network of Glens Falls, Feb. 2024


PFAS Emissions and Releases into the Environment


Saratoga Biochar claims that its pollution control equipment (thermal oxidizers, which
will act as incinerators) will destroy PFAS “forever chemicals” from the sewage sludge
that the plant would pyrolyze (burn in an oxygen-deprived environment).
DEC has not required Saratoga Biochar to provide sufficient data to support its claims. as
As its primary evidence for these claims, the company submitted to DEC a study
conducted by the Water Environment Federation, which is the trade association of the
nation’s wastewater treatment plants.


NYS DEC’s draft air permit for Saratoga Biochar allows emissions of 0.001 lb. of PFOA
per hour.


PFOA is one of the most studied PFAS chemicals. In most cases, it has been replaced by
other PFAS compounds, which are often called “regrettable substitutes” because studies
show they cause the same types of serious health problems as PFOA.
US EPA estimates that there re 15,000 different PFAS chemicals. The EPA approved air
test can detect only 50 different PFAS.


Also PFOA is the only PFAS chemical that NYS has an air limit for.
PFAS chemicals break down and recombine when they are subjected to high
temperatures like those in a pyrolysis chamber. These breakdown products are known as
PICs, which stands for Products of Incomplete Combustion. Given that the PFAS
compounds present in the sewage sludge when it is delivered to the plant could easily be
transformed into novel PFAS molecules, it would be essential to monitor for other PFAS


NYS DEC’s draft air permit for Saratoga Biochar allows 7.2 lbs. of PFOA to be released
into the air every year.
PFAS chemicals are extremely persistent in soil, water, and in the bodies of people and
other animals. That’s why they are called “forever chemicals.” They break down in

geological time, not a human life span. PFAS are linked to cancer and a host of serious
health problems.


PFAS are also taken up in plants from the soil they’re growing in and the water that is
essential for their survival. PFAS also bioaccumulate in living organisms. Animals higher
up on the food chain, like people and birds of prey, the more PFAS they will accumulate
in their bodies.


Compare that amount with the NYS maximum contaminant level (MCL) for drinking
water, which especially covers public drinking water supplies. The MCL in NY is 10
parts per trillion (ppt). EPA is expected to finalize a lower federal drinking water standard
in 2024.


It’s very hard to imagine 10 parts per trillion because it is such a tiny amount. One part
per trillion equals one drop in 20 Olympic-sized swimming pools — so 10 ppt would be 1
drop in 2 Olympic swimming pools.


When a molecule of a PFAS compound exits from a smoke stack of an industrial plant, it
later falls down to the ground or into the water of a lake or creek or river.
Many PFAS, like PFOA, readily leach through the soil into groundwater.
Seven municipalities in the Mid Hudson Valley draw their drinking water from the
Hudson River. (
Fort Edward has a reservoir in the Town of Moreau.


PFAS water pollution
The wastewater generated by Saratoga Biochar’s plant would also be a threat to the
environment. SB projects that the plant would produce 30,000 gallons of wastewater
daily, used to quench the charcoal that would be made by pyrolyzing the sewage sludge.
The company would also collect contaminated wash water from hosing down the trucks
used to transport the sewage sludge to the plant. Since sewage sludge is contaminated
with PFAS, it would be reasonable to anticipate PFAS in the wastewater.
This large quantity of wastewater would be piped to the Glens Falls wastewater treatment
plant. The city of Glens Falls does not require pre-treatment of wastewater for PFAS.

Saratoga Biochar did not provide DEC or the city of Glens Falls with any data about the
concentrations of PFAS chemicals or other pollutants that would be present in the
wastewater. The company did not apply for a permit to discharge contaminated water into
a water body, because it plans to discharge it into the sewer system, for which no DEC
permit is required. DEC did not ask Saratoga Biochar any questions about its wastewater.


Like other wastewater treatment plants, Glens Falls does not have any technology for
detoxifying or removing PFAS for wastewater, sewage sludge or effluent. After
wastewater is treated at the plant, and sewage sludge is separated from water, the treated
water called effluent would be discharged into the Hudson River.
Surface water throughout the U.S. is contaminated with PFAS chemicals. Fish and other
organisms living in rivers, streams, and lakes concentrate PFAS chemicals in the water.
As a result, freshwater fish in the U.S. are highly contaminated with PFAS and are
becoming unsafe to eat.


The PFAS chemicals that a person absorbs in drinking water and by eating contaminated
fish or other foods behave the same way in our bodies. By eating just one serving of
freshwater fish, a person would be consuming as much PFAS as they would if the level of
PFAS in their drinking water was 5 times the NYS allowable level over a month.
Health effects linked to PFAS exposure in humans
From “Guidance on PFAS Exposure, Testing, and Clinical Follow-Up.” National
Academies of Sciences, Engineering, and Medicine. July 28, 2022. Excerpted from
Chapter 3. Potential Health Effects of PFAS.


A review of studies on PFAS exposure and human health effects found the following:
The committee found sufficient evidence of an association for the following diseases and
health outcomes:
• decreased antibody response (in adults and children),
• dyslipidemia (in adults and children),
• decreased infant and fetal growth, and
• increased risk of kidney cancer (in adults).


The committee found limited or suggestive evidence of an association for the following
diseases and health outcomes:
• increased risk of breast cancer (in adults),
• liver enzyme alterations (in adults and children),

• increased risk of pregnancy-induced hypertension (gestational hypertension and
• increased risk of testicular cancer (in adults),
• increased risk of thyroid disease and dysfunction (in adults), and
• increased risk of ulcerative colitis (in adults).


For a range of other health effects, the evidence was inadequate or insufficient. These
include type 1 and gestational diabetes; cardiovascular disease; metabolic syndrome;
obesity; infertility; male and female reproductive effects; reproductive hormone levels;
and cancers other than kidney, breast, and testicular.


Every day, studies reveal new evidence about the human health consequences of
exposure to PFAS chemicals. For example, scientists have now found an association
between exposure to PFOA and pancreatic cancer. Studies have also discovered a link
between severe non-alcoholic fatty liver disease in children and elevated levels of PFAS
chemicals in their blood.


While our understanding is in its infancy, there is a strong consensus that PFAS exposure
increases our risks of serious health conditions. Saratoga Biochar would increase the
amount of PFAS dispersed into the environment and therefore this project would be a
threat to the public health of communities already burdened by pollution.

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