Wednesday, 5 October 2016

New Peer-Reviewed Science on "biosolids" dangers ....

A Dozen recent peer-reviewed studies

 

1.      “Meta-analysis of biosolid effects on persistence of triclosan and
triclocarban in soil”
  2015
Qiuguo Fu, Edmond Sanganyado , Qingfu Ye, Jay Gan

Highlights:
"Biosolid amendment greatly enhances persistence of triclosan and triclocarban, likely due to enhanced sorption or decreased chemical bioavailability. This finding highlights the importance to consider the effect of biosolids when evaluating the environmental risks of these and other biosolid-borne PPCPs."

2.      “Metal stress and decreased tree growth in response to biosolids application
in greenhouse seedlings and in situ Douglas-fir stands”
  2011
Erica T. Cline, Quyen T.N. Nguyen, Lucy Rollins, James E. Gawel

Highlights:
"Phytochelatins e bioindicators of intracellular metal stress e were elevated in foliage of biosolids-amended stands, and significantly higher in roots of seedlings grown with fresh biosolids. These results demonstrate that biosolids amendments have short- and long-term negative effects that may counteract the expected tree growth benefits."

3.      “Occurrence, sources, and fate of pharmaceuticals in aquatic
environment and soil” 2013
W.C. Li

Highlights:
"Those pharmaceuticals which cannot be degraded and attenuated by natural and
human process will accumulate in the environment and lead to potential effects on the organism or even human."

4.      “Influence of organic amendment on fate of acetaminophen
and sulfamethoxazole in soil”
  2015
Juying Li , Qingfu Ye, Jay Gan

Highlights:
"Land application of biosolids or compost constitutes an important route of soil contamination by emerging contaminants such as acetaminophen and sulfamethoxazole. Addition of biosolids or compost appreciably accelerated the formation of bound residue, likely due to the fact that the organic material provided additional sites for binding interactions or introduced exogenous microorganisms facilitating chemical transformations. This effect of biosolids or compost should be considered in risk assessment of these and other emerging contaminants."

5.      “Soil contamination by organic micropollutants”

2015,  Vodyanitskii.

Highlights:
"The input of organic micro and nano-pollutants into the environment has increased in recent years. Emerging pollutants are defined as new chemicals without regulatory status and which impact on environment and human health are poorly understood. The list of emerging compound classes consists of pharmaceuticals, steroid and hormones, surfactants, flame retardants, industrial additives and agents, gasoline additives. There are two main potential routes of environmental exposure associated with these compounds: the land application of municipal biosolids (typically to agricultural fields) and wastewater use in irrigated agriculture. These pollutants contaminate groundwater, soil and are transferred to plants. Drugs have especially strong influence on soil biota (bacteria, earthworms and others). In contaminated soil microorganism reaction to these compounds is determined not only by the composition and amount of emerging pollutants but geochemical and environmental factors."


6. “Nanomaterials in Biosolids Inhibit Nodulation, Shift Microbial Community Composition, and Result in Increased Metal Uptake Relative to Bulk/Dissolved Metals”  2015                                                                                                                                      Jonathan D. Judy, David H. McNear, Jr. Chun Chen,Ricky W. Lewis,Olga V. Tsyusko
Paul M. Bertsch, William Rao, John Stegemeier, Gregory V. Lowry, Steve P. McGrath,
Mark Durenkamp, and Jason M. Unrine

Highlights:
"Engineered nanomaterials (ENMs) are entering waste streams in increasing quantities as a result of their use in an increasing variety of consumer products employing nanotechnology.1 The majority of these ENMs have been shown to partition to the sludge within wastewater treatment plants (WWTP), and there is a risk of environmental harm in agroecosystems where biosolids are land-applied as fertilizer, which has yet to be fully evaluated. While regulations exist that limit the land application of biosolids that contain elevated concentrations of certain metals, these regulations do not specifically consider the incorporation of metal-containing nanomaterials."

"While the metal concentrations used in this study are high relative to near-term predicted soil ENM concentrations, we have clearly demonstrated that there is a distinct plant and microorganism response as a result of exposure to biosolids containing ENMs compared to biosolids containing bulk/dissolved metal of the same composition. This result suggests that soil accumulation of ENMs could potentially affect critical ecosystem services, agricultural productivity, and ultimately human well-being."

7.“Toxicogenomic Responses of the Model Legume Medicago truncatula to Aged Biosolids Containing a Mixture of Nanomaterials (TiO2, Ag, and ZnO) from a Pilot Wastewater Treatment Plant”   2015                                                                                                                                             Chun Chen, Jason M. Unrine, Jonathan D. Judy, Ricky W. Lewis, Jing Guo, David H. McNear, Jr.and Olga V. Tsyusko

Highlights:
"The field of nanotechnology is developing rapidly, and engineered nanomaterials (ENMs) are being incorporated into an increasing number of industrial and consumer products. The ENMs within these products are being released into the environment, which raises concerns about their possible impacts on human and ecosystem health."

"In summary, this study provides the first comprehensive insight into the toxicogenomic responses of M. truncatula grown in soils amended with aged biosolids containing a mixture of ENMs (Ag, TiO2, and ZnO). Considering the results from the companion study,18 the gene expression patterns are consistent with the hypothesis that inhibition of nodulation by ENM exposure was a result of plant toxicity rather than microbial toxicity, particularly because population densities of S. meliloti were similar in the bulk/dissolved and ENM treatments. We identified multiple genes involved in nodulation and inorganic nitrogen metabolism that were down regulated. In addition, genes involved in oxidative stress response were up-regulated. The companion study showed that Zn concentrations and uptake were higher in shoots from the ENM treatment than in the bulk/dissolved treatment while Ti and Ag concentrations were not significantly different.18 The present study showed that several genes involved in metal binding and Zn homeostasis were up-regulated. Taken together, these findings suggest that inhibition of growth and nodulation in M. truncatula exposed to ENM treatment is likely the result of enhanced bioavailability of Zn ions in the biosolids-amended soil containing aged ENMs resulting in phytotoxicity."

8. “Dissipation of contaminants of emerging concern in biosolids applied to nonirrigated farmland in eastern Colorado.” 2014                                                                                                                    Tracy J.B. Yager, Edward T. Furlong, Dana W. Kolpin, Chad A. Kinney, Steven D. Zaugg, and Mark R. Burkhardt

Highlights:
"This study indicates that some CECs are sufficiently persistent and mobile to be vertically transported into the soil column following biosolids applications to the land surface, even in semiarid regions"

"Eggen et al. (2011) reported uptake of pharmaceuticals by plants (carrots, wheat and barley cereals, meadow fescue, turnip rape seed) and negative effects on growth and development of carrots; however, the wheat samples from the Colorado study were not analyzed for pharmaceutical CECs. Holling et al. (2012) reported pharmaceutical and triclosan uptake by cabbage roots and aerials."

"Triclosan, a synthetic antimicrobial compound, was persistent in biosolids through the 180 days of sampling (Figure 3). Large concentrations in the first (top) soil interval dissipated little over time."

"Concentrations of 4-nonylphenol (sum of all isomers), a detergent or metabolite, were substantial in the Colorado biosolids (approximately 200 ppm) and persisted through at least 180 days post-application"

"the persistence of this CEC in biosolids and soil indicates the potential for long-term environmental effects."

"A plasticizer and flame retardant, TBEP, was detected in biosolids at relatively small concentrations compared to other CECs but was consistently detected in biosolids through 180 days post-application"

"The results of this study indicate that CECs in biosolids persisted in a real field-application environment. Between 180 and 468 days post-application, select CECs migrated deeper into the soil profile or were taken up by plant roots."

"This study demonstrates that agronomic applications of biosolids result in detectable concentrations of CECs in soil, and that CECs can persist in surficial biosolids and in soil-biosolid mixtures at detectable concentrations on time scales exceeding one year, particularly under the semiarid conditions present at this study site."

 

9. “Bioavailability of perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA) in biosolids-amended soils to earthworms (Eisenia fetida)” 2014                                                         Bei Wena, Hongna Zhang , Longfei Li , Xiaoyu Hu , Yu Liu , Xiao-quan Shan , Shuzhen Zhang

Highlights:
"Accumulation of organic contaminants implies a risk to not only earthworm populations but also many vertebrate species feeding on earthworms. So far information about the accumulation of PFASs by earthworms from soil is quite limited."

"land application of biosolids not only increases the OM contents, but also results in the accumulation of PFASs in soils."

"Earthworms may take up contaminants from soil and porewater, both through their skin (dermal) and by ingestion (oral). It is assumed that only contaminants that can be released from
soil/sediment are available to biological receptors.....The results verified that the soil PFOS and PFOA concentrations and soil OM content ([OM]) are two key factors controlling the bioavailability of PFOS and PFOA in soils."

"These suggested that soil concentration and OM content dominated the bioavailability of PFASs in soils. Soil pH and clay content appeared relatively unimportant for PFOS and PFOA bioavailability....The results of this study demonstrated that contamination of PFOS and PFOA in soils as a result of biosolids land application led to accumulation of PFOS and PFOA in earthworms with higher concentration of PFOS than that of PFOA."

“Identification of Viral Pathogen Diversity in Sewage Sludge by Metagenome Analysis”
  2013 Kyle Bibby and Jordan Peccia

Highlights:
"The large diversity of viruses that exist in human populations are potentially excreted into
sewage collection systems and concentrated in sewage sludge. "

"Two important, novel contributions can be drawn from this work’s results. The first is the broad diversity of human viruses revealed in the sludge samples. In every sample surveyed, the degree of viral pathogen diversity is greater than had been previously demonstrated in any environmental or wastewater sample. The realistic implications of this diversity include the need to consider a broader selection of viruses in environmental fate and transport studies, and importance of considering multiple human exposure routes to sewage sludge and wastewater. For the second major contribution, this work demonstrates the utility of metagenomic approaches for viral pathogen identification."

"The results of this study serve to expand our view on the type, occurrence and abundance of viral pathogens in raw sewage sludge and class B biosolids. These results strongly suggest that current regulations for pathogens in sewage sludge that focus on fecal coliform indicators or the presence of Enterovirus, do not capture the full degree of pathogen diversity to which the public may be exposed during biosolids land application. Emerging viruses including Parechovirus, Klassevirus, Bocavirus, and Coronavirus HKU1, were abundantly identified, highlighting previously undemonstrated pathogen diversity in sewage sludge."

 

10. "We Should Expect More out of Our Sewage Sludge" 2015
Jordan Peccia and Paul Westerhoff

 

Highlights:
" Sludge management practice must shift from treatment of a liability toward recovery of the embedded energy and chemical assets, while continuing to protect the environment and human health. This shift will require new research, treatment technologies and infrastructure and must be guided by the application of green engineering principles to ensure economic, social, and environmental sustainability. "

cia and Paul Westerhoffcia and Paul Westerhoff

 

11. "Heavy Metal Accumulation in Small Mammals following Sewage Sludge Application to Forests" 1989                                                                                                                                                             Linda J. Hegstrom and Stephen D. West

 

Highlights:

“Small mammals have been shown to accumulate heavy metals after sewage sludge was applied to forest lands. Shrews, shrew-moles, and deer mice absorbed metals from sludge”

 

12. "Uptake of Polychlorobiphenyls Present in Trace Amounts from Dried Municipal Sewage Sludge Through an Old Field Ecosystem" 1981                                                                                             Thomas S. Davis et.al.

 

Highlights:

“Insects in the soil absorb toxins, which then accumulate in birds.”

 

 

 

 

 

 

 

 

 

Other Government Reviews not examined by the so-called Literature Review

 

“Sewage Sludge Management in Germany” – in-depth German government study 104 pages. https://www.umweltbundesamt.de/…/sewage_sludge_management_i…  (2013)

Highlights:
"More than 30,000 tons of pharmaceutical drugs are used in Germany annually. After being used for therapeutic purposes or being disposed of improperly (in toilets), residues of these drugs end up in municipal sewage systems. Depending on the sewage treatment methods used, a greater or lesser portion of the pharmaceutical drug residues removed from sewage are deposited in sewage sludge. According to a German Advisory Council on the Environment (Sachverständigenrat für Umweltfragen, SRU) report on pharmaceutical drugs in the environment, although only a handful of pharmaceutical drugs accumulate in sewage sludge, it would be advisable to gradually phase out the use of sewage sludge as a fertilizer so as to avoid diffuse loads of potentially harmful substances in soil [SRU]."
"Expert reports issued by the German Advisory Council on the Environment (SRU) concerning pharmaceutical drugs in the environment indicate that the spread of antibiotic resistance in the environment resulting from resistant bacteria inputs poses a greater public health hazard than antibiotic inputs per se [SRU].”
"Sewage sludge fertilizer is a pollution sink for harmful sewage components from households, businesses and diffuse sources, concerning whose environmental relevance too little is known. Notwithstanding tighter controls and stricter limit values for certain sewage sludge pollutants, uncontrolled pollutants such as hydrocarbons inevitably find their way into the soil. Incorporation of certain pollutants into the food chain cannot always be avoided, despite the fact that, for example, plants normally do not absorb organic pollutants. Nonetheless, new breakdown products of pharmaceutical drugs are discovered in sewage sludge all the time, and they are incorporated into sewage sludge via human excretion carried by the wastewater that is treated by sewage treatment plants."

 

The official notice from Switzerland stopping the use of Sewer Sludge on farmland - (note that they cite the Precautionary Principle)

 

"Although sludge contains plant nutrients such as phosphorus and nitrogen it also comprises a whole range of harmful substances and pathogenic organisms produced by industry and private households. For this reason, most farmers already avoid using sludge as a fertiliser since they are aware of the risk of irreversible damage to the soil, the danger to public health and possible negative effects on the quality of the food they produce. For this reason the Federal Council plans to ban the use of sludge as a fertiliser, although this will mean breaking a nutrient cycle which is in itself useful. Prevention – a key principle of the law on health and the environment – requires, however, that any consequences for the environment which could be damaging or negative must be limited as early as possible, even there is no conclusive scientific evidence for such damage being caused."


 

 

 

 

 

Other studies questioning the safety of “biosolids” released after the Literature Review

 

1.      “Pathogenic Escherichia coli and enteric viruses in biosolids and related top soil improvers in Italy.” 2016                                                                                                                                               Tozzoli R, et al.

 

Highlights:
"Four samples were positive for the presence of nucleic acids from human norovirus, two of them being also positive for human adenovirus. Real Time PCR screening gave positive results for many of the virulence genes characteristic of diarrheagenic E. coli in 21 samples. These included the Verocytotoxin-coding genes, in some cases associated with intimin-coding gene, and markers of enteroaggregative, enterotoxigenic, and enteroinvasive E. coli. CONCLUSIONS: These results provide evidence that enteric viruses and pathogenic E. coli may be released into the environment through the use of sludges-derived TSI (what in Europe they call sewer sludge and manures - Top Soil Improvers )"Our results highlight that the TSI-related environmental risk for the food chain should be more deeply assessed."

 

2.      “Long-term field application of sewage sludge increases the abundance of antibiotic resistance genes in soil.” 2016                                                                                                                                                               Qinglin Chena, Xinli Ana, Hu Lia, Jianqiang Sua, Yibing Mab, Yong-Guan Zhu

Highlights:
“Compared to the control soil (which contained around 40 antibiotic resistance genes), and to the soil fertilised only with chemical fertiliser (which contained a similar number), treatment with chicken manure (10 tonnes per hectare — t/ha) and sewage sludge (36 t/ha) more than doubled the number of antibiotic resistance genes (to around 100)…They also found that the effects increased with the amount of treatment that was applied… The highest number of antibiotic resistance genes were detected following sewage sludge treatment (36 t/ha).”

 

3.      “Are agricultural soils dumps for microplastics of urban origin?” 2016                                          Luca Nizzetto, Martyn Futter, and Sindre Langaas

Highlights:
"Based on new microplastics emission estimates in industrialized countries, we suggest that widespread application of sewage sludge from municipal wastewater treatment plants (WWTPs) to farmlands is likely to represent a major input of microplastics to agricultural soils, with unknown consequences for sustainability and food security."

 

4.      “Microplastics – Also in Our Food?” 2015                                                                                 Christophe Goldbeck, Peter Fürst, Hans-Ulrich Humpf, Darena Schymanski,

 Highlights:
"microplastics has gained attention as an environmental problem. Microplastics has been detected in the ocean, in rivers, in effluents from sewage treatment plants and sewage sludge. It is spread as fine dust in the air, such as tire wear, as sewage sludge fertilizer and landfill leachate on the ground, and also with rainwater."

"Our results highlight that the TSI-related environmental risk for the food chain should be more deeply assessed

5.      “The fetal ovary exhibits temporal sensitivity to a ‘real-life’ mixture of environmental chemicals” 2016                                                                                                                                  Richard G. Lea, Maria R. Amezaga, Benoit Loup, Béatrice Mandon-Pépin, Agnes Stefansdottir, Panagiotis Filis, Carol Kyle, Zulin Zhang, Ceri Allen, Laura Purdie, Luc Jouneau, Corinne Cotinot, Stewart M. Rhind, Kevin D. Sinclair, Paul A. Fowler. ive, enterotoxigenic, and enteroinvasive E. coli.
CONCLUSIONS: These results provide evidence that enteric viruses and pathogenic E. coli may be released into the environment through the use of sludges-derived TSI (what in Europe they call sewer sludge and manures - Top Soil Improvers )

Highlights:
"The study highlights potential risks associated with the common practice of grazing livestock on pastures on which human sewage sludge-derived fertilizer has been used.”

"More worryingly, since low-level chemical exposure poses a threat to human reproductive development, the consumption of products from animals grazing such pastures may be of considerable environmental concern."

Thursday, 1 September 2016

Prof. Caroline Snyder speaks at Public Hearing on Sewage Sludge

Prof. Caroline Snyder speaks at the House Democratic Policy Committee
Re: Public Hearing on sewage sludge
From: Caroline Snyder
Date: August 29, 2016



To: PA House Democratic Policy Committee


Re: Public Hearing on sewage sludge

From: Caroline Snyder

Date: August 29, 2016

My name is Caroline Snyder. I am emeritus professor at the Rochester Institute of Technology where I designed, administered, and taught interdisciplinary environmental science courses and chaired the Department of Science, Technology, and Society. In 2001 I founded the nonprofit group, Citizens for Sludge-Free Land.

I appreciate the opportunity to submit written testimony at this public hearing. A re-evaluation of the Commonwealth’s biosolids policies is long overdue. HR 60 is a good first step.

Land-applied municipal sewage sludge (biosolids) is a highly complex and unpredictable mixture of biological and chemical pollutants. Most of the 90,000 man-made chemical compounds in commerce today - with 1000 new ones added annually - end up in sewage, and many of those, concentrate in the resulting biosolids .107 They include carcinogens, mutagens, neurotoxins, endocrine disrupters, solvents, pharmaceuticals, radioactive waste, leachates from landfills and superfund sites, as well as disease causing and antibiotic resistant pathogens. 52,61,66,79,87, 97,104, Upgrading and building improved treatment plants that will remove more pollutants from sewage, will cause sludge to become even more contaminated. Biosolids generated in our large industrialized urban centers - and 84% of landapplied sludge originates in those centers - is very likely the most pollutant- rich waste mixture of the 21st century.

The US EPA Office of Water (OW) regulates biosolids. The regulations, 40 CFR Part 503, are usually referred to as the 503s. Despite the agency’s claim to the contrary, OW also promotes land application. This is a gross conflict of interest. Government agencies should not be in bed with the industries they are supposed to regulate 82 As a consequence of this industry-government alliance, the 503s are full of loopholes. The most damaging loop hole of all is the so-called "Domestic Sewage Exclusion" which permits every industry connected to a sewer to pipe its hazardous waste into POTWs. A partial list of those pollutants is posted on our webpage 106 When these hazardous chemicals are mixed with sewage, they become exempt from RCRA ‘s solid and hazardous waste laws. Industries and municipalities benefit from the Domestic Sewage Exclusion in several ways: they can avoid the expense of properly treating pollutants or refrain from piping hazardous waste into POTWs in the first place; and once these two waste streams mix, industries are no longer liable for any damages that might result from this toxic mixture., especially when it is processed and land applied. In an unpublished and un-dated document, titled Gatekeepers: Who are They? What They think about Us? And What can we do about it? Bill Toffey, a spokesperson for the biosolids industry and advocate of land application, tells his audience in no uncertain terms how important it is for industries to support the Domestic Sewage Exclusion:
You may have missed the proposed rulemaking to change the reporting requirements for lead as a "persistent and bioaccumulative toxic." The proposal would reduce from 10,000 to 10 the number of pounds annually that an entity can dispose without reporting, and the de minimis lead concentration for reporting would be eliminated. At first reading, it seemed to me that this reporting rule would capture most of Philadelphia’s recycling programs. But apparently all other POTWs and we are saved by the fact that the rule doesn’t apply to POTWs . This is one case where being a POTW making a fertilizer is preferred to being a manufacture [sic] making a fertilizer; we are in the right SIC code. But this is cold comfort. Some folks in Congress, in the environmental community and in EPA itself believe it is in the public’s and environment’s best interest to track the lead that is spread on land. Someday they will get us, and we need to be prepared. Fighting changes to the Domestic Sewage Exclusion may haunt us as an

example to the environmental community that our claim to being concerned for the environment is a sham.
 
 
After ocean dumping was banned, land application increased, as did the reports of serious health, livestock, and environmental damage. The first comprehensive scientific appraisal of the 503s was published in 1999 by internationally renowned soil scientists at the Cornell Waste Management Institute (CWMI) - whose teams have been researching biosolids since the 1970s. Aptly titled The Case For Caution the report warns that the 503s do not protect human health, agriculture, or the environment 23 Around the same time a team assembled by David Lewis - formerly a senior level EPA research microbiologist - documented human and animal sicknesses and deaths linked to land application under the 503 rule, the first scientist to do so. 35, 36, 37, 84 Because of increasing concerns about health impacts, the National Academy of Sciences (NAS) was asked to examine the scientific basis of the 503s. Its 2002 report, Biosolids Applied to Land, questioned the science and risk assessment models of the rule and urged EPA to implement health studies of neighbors who lived adjacent to sites that had been treated with sludge. NAS panel members had available not only the work of Lewis’ team and that of the CWMI, but also a 382 page document put together by sludge activist Helane Shields listing sludge "incidents" that had occurred in virtually every state of the union. 54 Particularly worrisome where the many reports of sicknesses and several deaths. 90 To include published papers that documented these incidents in the scientific literature would hurt the land application program. So industry-friendly NAS panel members deleted all references to David Lewis’ papers in the published report, which includes the statement that there is "no documented evidence" that anyone was ever harmed by sludge. In the absence of any credible science that supports land application, industry and government agencies continue to cite the "no documented evidence" claim, making sure the evidence is not documented, or, if it is, to ignore or discredit it. 92

Yet people are not easily fooled. Every week there are reports of sludge battles, especially in the heavily populated areas of the country where most sludge is produced and spread. Residents who believe they have been or will be harmed are pitted against government and industry officials who assure them that the practice is beneficial and safe. For example during a 2014 Town Meeting in Bell

County Township, Clearfield County PA angry residents demanded an end to sludge spreading in their community because it was making some of them sick. Despite the usual misleading assurances by state officials that biosolids will enrich the soil and improve the overall health of land and animals, residents wanted the practice stopped. One neighbor who lives close to the permitted site was hospitalized with bronchial spasms when the spreading began. Her doctor said that such spasms, which resemble a heart attack, can be caused by air borne irritants. Other people attending the meeting complained of headaches and nausea. 96

Government and industry representatives at these meetings usually assure affected residents that their health problems or their contaminated wells were caused by something else. For example, a few years ago, when an astute NH property owner learned that his neighbor uphill was about to use sludge, he decided to have his well water tested before and after the spreading. Not surprisingly, test results taken after the application showed high levels of pathogenic bacteria. After he complained a representative of the sludge company visited his home, looked around, and stated that the well must have become contaminated by his bird feeder!

However when deaths are linked to sludge-exposure, bird feeder explanations do no longer work. Two of those deaths occurred right here in the Commonwealth. The PA DEP and the company that spread the sludge went through extraordinary lengths to cover up the cause of these deaths. For a summary see Appendix A.

Evidence keeps piling up that there is something seriously wrong with the 503s. Why, many people ask, are EPA and USDA - agencies whose mission it is to protect human health, promote sustainable and productive agriculture, and protect the environment - why are these agencies not substantially tightening the current land application rules, or better yet, why are they continuing to spend our tax dollars on a million- dollar Public Acceptance Campaign, when, instead, they should be using those funds to invest in safer and more sustainable alternatives?

One part of the answer is simple. Top managers at EPA’s Office of Water and a highly influential agronomist at the USDA wrote the 503s. They decided that it would be acceptable for biosolids to contain hazardous waste, reasoning that small amounts do not matter, that the waste stream is getting cleaner, and that pretreatment of industrial waste is working. None of those assumptions proved to be true. Even very small amounts - parts per trillion - of some pollutants can harm developing organisms, and instead of getting cleaner, the waste stream is getting more complex and more polluted. Several recent EPA Inspector General Reports, indicate that hundreds of priority pollutants discharged by industry are showing up in effluent and sludge. But the individuals who wrote the rules are still in charge of the nation’s biosolids policy and have staked their reputation on the adequacy of the 503s. Apparently no amount of evidence will persuade them that they were wrong. 92

The other part of the answer is also simple. Not only the sludge brokers who are paid for every ton of sludge they remove from sewage treatment plants, but also - as we explained earlier - industrial users and municipalities save substantial sums by continuing this inexpensive method of sludge disposal. Communities are learning more about what biosolids are, and what they do when land applied. They are experiencing first- hand the resulting harm to their health, 51, 55, 68, 71, 108, 109 their drinking water, 12, 71, 77, 99, 101 and their animals. 74,79,83,94,105 To counter this new awareness, government agencies and the sludge industry are spending millions to rev up their PR campaign to convince farmers, the media, legislators, and the public that spreading this incredibly complex contaminated mixture on land is sustainable., beneficial and safe.

A key flaw of the 503s is that they depend on Quantitative Chemical-by-Chemical Risk Assessment (QRA) to assess health and environmental impacts. QRA works for calculating how strong a bridge must be to withstand the weight of daily traffic on a particular highway, but QRA cannot be used to assess the health and environmental impacts of such a complex and unpredictable mixture as land applied sewage sludge. See Appendix B

Instead of calculating health and environmental risks using QRA models, the NAS panel recommended a different approach:
"Even if a summary index of an adverse response to mixtures was available, it would not necessarily reflect the total hazards of exposure to biosolids because of the inability to identify all of its hazardous constituents and their potential for interaction in vivo . . . thus it is not possible to conduct a risk assessment for biosolids at this time (or perhaps ever) that will lead to risk-management strategies that will provide adequate health protection without some form of ongoing monitoring and surveillance . . . the degree of uncertainty requires some form of active health and environmental tracking."
 
 
A number of the biosolids incidents might have been prevented had there been exposure studies and health and environmental tracking.

Many serious health impacts have been linked to Class B sludge exposure, especially when this material is stockpiled and top dressed rather than incorporated into the soil. Sludge advocates are now promoting a material that is deceptively referred to as Exceptional Quality (EQ) Class A sludge. Many people do not realize that Class A EQ sludge contains just as many persistent toxic chemicals as Class B. When sludge is further processed to reduce indicator pathogens, it turns into Class A. However as the more

vulnerable indicators are deactivated, much more robust pathogens survive and evolve. In the absence of microbial competition, they multiply and thrive, especially in in cool and moist climates. Some of the treatment methods prescribed to reduce the level of indicators are not working, so Class A sludge is often Class B sludge or turns into Class B sludge after it is spread or stockpiled. Further processing also appears to encourage the growth of superbugs which explains why many neighbors exposed to sludge contract MRSA infections. The question arises, why, if all of this is true, are industry and government agencies encouraging the production and use of Class A materials?

Again, the answer is simple. Under the current rules, Class A is virtually unregulated. As long as it contains some nitrogen, it can be spread anywhere - including on home vegetable gardens - during any weather, at any time during the year, in any amounts, and does not require public notices, public hearings, or the expense of getting a permit. Also Class A products can be sold in garden centers, often misleadingly labeled. But are they really safe? Consider two incidents. One took place in the summer of 2007 in Milwaukee, where sludge is used to make the Class A product Milorganite. Sewer workers dislodged large amounts of PCBs during a routine sewer cleaning operation. This resulted in thousands of tons of contaminated sludge - some containing superfund high levels of PCBs - to be spread on dozens of school playgrounds and parks. When the problem finally was discovered, the contaminated material had to be removed and shipped to out-of-state hazardous waste landfills. The entire incident cost the city millions. 104

Consider another incident that happened in Shirley MA . In January of 2014 a farmer spread Earthlife on his frozen snow-covered field. Earthlife is a Class A product made by Casella Organics and fully approved and registered for use in MA, CT, and VT. Three weeks later, after a thaw, residents living next to the field on 15 and 20 Bumpus Road turned on their faucets and out came diluted sewage. Both families got their water from shallow wells. Earthlife apparently had leached into the water table and contaminated their wells. I was invited to attend a February 28 meeting of concerned neighbors and provided information and hand-outs. Appealing to the town for help was useless because what the farmer had done was legal under the 503s. Despite conclusive test results that the contamination was caused by Earthlife , the homeowners could not afford litigation. A month went by and I did not hear from the affected home owners. So I contacted them to see how they were doing. During that interval Casella had paid for drilling a bedrock well at one home and had paid for a filtration system for the other family. In return, the home owners were put on a gag order and told never to discuss the case or share test results. Settlements like these explain why many sludge incidents remain unknown or are underreported.

The practice cannot be banned overnight. Something needs to be done with the millions of tons of sludge produced every year. Until more sustainable waste-to-energy technologies are in place to handle this volume, states might want to encourage increasing disposal in well sited subtitle 2 landfills with methane capture for energy and heat. Reclamation of contaminated land may also be an option as long as the site is securely fenced and signed, to prevent another Tony Behun tragedy. It is absolutely crucial that we preserve our dwindling productive farm land for future generations. We must not apply sewage sludge and other industrial waste on the land where we grow our food and forage.

Meanwhile, states, counties, and towns can put in place more protective inexpensive management practices that will at least reduce some of the risks. These would include permanently prohibiting land

application on grazing fields to prevent contamination of meat and dairy products; immediate incorporation of sludge into the soil to prevent pollutants from moving off site; prohibiting stockpiling; permanent pH management to prevent metals and other contaminants from becoming bioavailable; much more protective horizontal and vertical buffers from occupied buildings; and limiting the acreage and frequency of application.

The number of individuals and organizations that oppose land application is growing. There isn’t a community in the country that welcomes the arrival of sludge trucks. Many farmers are no longer taken in by the brochures and videos that promise instant savings and high yields from this free mislabeled "natural organic" fertilizer. Over a hundred environmental organizations - many supporting sustainable farming practices - oppose growing food and forage on biosolids-treated land. Among them are the Sierra Club, the Natural Resources Defense Council, the Rodale Institute, the Institute for Agriculture and Trade Policy, Western Growers, the National Farmers Union, the Food Rights Network, and the Organic Consumers Association. All of these organizations depend on impartial scientific information to form their policy positions.

In conclusion PA legislators might be interested in the recommendations of Professor Jordan Peccia, Associate Professor of Engineering at Yale University and Professor Paul Westerhoff, Professor at the School of Sustainable Engineering at Arizona State University in their paper titled,
We Should Expect More out of Our Sewage Sludge: The culmination of previous incremental technologies and regulations aimed at solving a current treatment problem, rather than developing the practice for the higher goals of sustainability have resulted in sludge becoming an economic and social liability. Sludge management practice must shift from treatment of a liability toward recovery of the embedded energy and chemical assets, while continuing to protect the environment and human health. This shift will require new research, treatment technologies and infrastructure and must be guided by the application of green engineering principles to ensure economic, social and environmental sustainability. 103




We Should Expect More out of Our Sewage Sludge
 
 
Jordan Peccia*† and Paul Westerhoff‡

† Department of Chemical and Environmental Engineering, Yale University, Mason Laboratory, 9 Hillhouse Avenue, P.O. Box 208286, New Haven, Connecticut 06520, United States

‡ School of Sustainable Engineering and The Built Environment, Arizona State University, Box 3005, Tempe, Arizona 85287-3005, United States

Environ. Sci. Technol., 2015, 49 (14), pp 8271–8276

DOI: 10.1021/acs.est.5b01931

Publication Date (Web): June 24, 2015

Copyright © 2015 American Chemical Society

*Phone: (203) 432-4385; fax: (203) 432-4387; e-mail: Jordan.Peccia@yale.edu.

Biography

Jordan Peccia is an associated professor of Chemical and Environmental Engineering at Yale University. His research interests lie at the intersection of engineering and microbiology and include human exposure to and risk of infective agents produced during the land application of biosolids.

Paul Westerhoff is a Professor in the School of Sustainable Engineering and the Build Environment and Vice Provost for Academic Research Programming at Arizona State University. He is interested in the physical and chemical characterization of water and wastewater treatment systems, including the fate of nanomaterials in biosolids.

Synopsis

Sewage sludge and biosolids production and management are a central component of water and sanitation engineering. The culmination of previous incremental technologies and regulations aimed at solving a current treatment problem, rather than developing the practice for the higher goals of sustainability have resulted in sludge becoming an economic and social liability. Sludge management practice must shift from treatment of a liability toward recovery of the embedded energy and chemical assets, while continuing to protect the environment and human health. This shift will require new research, treatment technologies and infrastructure and must be guided by the application of green engineering principles to ensure economic, social, and environmental sustainability.

Abstract

Sewage sludge and biosolids production and management are a central component of water and sanitation engineering. The culmination of previous incremental technologies and regulations aimed at solving a current treatment problem, rather than developing the practice for the higher goals of sustainability have resulted in sludge becoming an economic and social liability. Sludge management practice must shift from treatment of a liability toward recovery of the embedded energy and chemical assets, while continuing to protect the environment and human health. This shift will require new research, treatment technologies and infrastructure and must be guided by the application of green engineering principles to ensure economic, social, and environmental sustainability.

Sunday, 5 June 2016

The cost of "Free" Sewer Sludge By Dr. Richard Honour

What is the Cost of Free Sewage Sludge?

If a State/Province, County or Municipality provides Toxic Sewage Sludge to foresters, farmers, sludge brokers and composters at no apparent cost to the user/consumer, or at minimal cost, and if that farmer benefits from using the no-cost or low-cost Toxic Sewage Sludge as a fertilizer replacement, what then is the cost to us for what he gets for free, or nearly free?

How much does Free cost?

Free is not without cost, and may result in extreme cost.

The payers or victims of this practice are the people and the environment who suffer extreme costs in the form of the adverse consequences of long-term exposure to low levels of environmental contaminants and pollutants, which manifest as killed soil, ecosystem disruption, GHG emissions, filthy food, and the endless list of human chronic diseases, as well as the associated healthcare costs (Good for healthcare providers and insurance carriers; very bad for us).

The cost of free is very high.

The University of Washington already proved after 20+ years of forestry research that (in the recent words of a Forest Management executive), ‘… no tree ever benefitted from applied sewage sludge.’ Thus, forest dumping of sewage sludge is no more than forest disposal of sewage sludge, without exception!

Who benefits if the apparent Cost is Free?
Sewage sludge planners, producers, brokers, haulers, spreaders, consumers, etc.
Healthcare providers
Insurance firms
Farmers

Who pays the Cost of Free?
Everyone else, and the environment!

Reading the URL links below makes us even more enlightened, when the reports are considered from the perspective of the Free Sewage Sludge market in which we live. Free ‘Nitrogen Content’ or ‘Free Micronutrients’ are without meaning when balanced against the human and environmental health costs, seen or unseen, i.e., the Externalities.

If nothing else, the North American Alliance for Clean land (NAACL) should take on the crucial project of performing an economic evaluation of the true costs of Free (or low-cost) Sewage Sludge, and of Land-Disposed Toxic Sewage Sludge, in general.

Personally, I have never encountered an economic analysis of the true costs for exposing human populations and the environment to wholesale Toxic Sewage Sludge Disposal (No; processing at a POTW or WWTP does not render Toxic Sewage Sludge as being ‘treated’ or ‘safe;’ it remains as Toxic Sewage Sludge). And in this context, I include all of the other toxic wastes that are or may be part of the sewage sludge milieu, and that may be disposed on any land, anywhere, for any cause or reason.

We may have to change the game and stop looking at a few dead birds or fish, and some contaminated air and water, and the very ill humans who are the targeted victims, and direct our undivided attention to the economic Externalities, which, from the perspective of economics, describes for us all of the costs of open dumping of toxic waste into our living environment, no matter what may be the resulting added direct dollar cost to farmers, if they may have to switch to commercial fertilizer – like, who really cares; I will be happy to pay more for clean and safe veggies, air and water. I want my kids and grandkids to safe and healthy, not victim of the sewage sludge cartel.

My prediction is that a formal economic analysis of the real costs of open dumping of toxic sewage sludge, by any name, including with a major emphasis on the Externalities, will show that the US, as a nation, can no longer afford this ill practice. We are experiencing a major explosion in chronic diseases in the US and the rest of the world, because as populations increase/accelerate, and wastes accumulate/accelerate, and tobacco, alcohol and drug-use proliferate, all within a booming industrial expansion, our exposures to toxic wastes accelerate in parallel.

At least taking on the toxic sewage sludge element of this global horror will give us something useful to do, whereby a positive change can be observed and measured.

Solution? Switching from land-disposal of toxic wastes, including sewage sludge, as just one bad example, to Thermal Decomposition of all toxic wastes, using available enhanced technologies, will save countless lives, if you think that is worth doing. Why else are we doing this?

The resulting new awareness of the actual cost redistribution, or cost shift model, will be that the costs are shifted to the health insurance and healthcare provider industries (one and the same), not to farmers or foresters. We will continue to pay for any and all Land-Disposed Sewage Sludge, but now as higher health insurance premiums, not as actual costs for diagnosis and treatment of the directly-associated diseases.

The Objective must be the Abolition of Land-Disposed Toxic Sewage Sludge and other Toxic Wastes, purely as a function of the economic incentives provided by improvements in human and environmental health.

Richard Honour (June 5/2016)

http://www.yourrenewablenews.com/waste-to-energy+technologies+-+key+trends+and+opportunities+2016+%E2%80%93+2023_130697.html
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http://www.stmarysstar.com.au/story/3868203/incinerator-proposal-on-backburner/

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http://www.hawkesbay.co.nz/general/17701-gas-to-electricity-project-at-hawke-s-bay-landfill-a-finalist-in-renewable-energy-awards.html

https://waste-management-world.com/a/16m-sugarcane-waste-to-biofuel-pilot-plant-project-underway-in-queensland

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http://www.wastedive.com/news/the-50-states-of-waste-how-waste-to-energy-definitions-vary-across-the-nat/416197/

http://www.inquisitr.com/2921003/energy-from-rotten-tomatoes-researchers-speculate-floridas-culled-tomatoes-could-power-disney-world-90-days-a-year/

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http://www.letsrecycle.com/news/latest-news/carlisle-efw-proposed-as-part-of-cumbria-waste-plan/