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.
Thursday, 1 September 2016
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
http://magazine.rewmag.com/article/april-2016/model-performance.aspx
http://www.pennenergy.com/articles/pennenergy/2016/04/waste-to-energy-electricity-generation-concentrated-in-florida-and-northeast.html
http://waste360.com/waste-energy/agricultural-wte-projects-taking-shape-north-carolina-and-oregon
https://www.engineersaustralia.org.au/portal/news/overseas-interest-sydney-unis-waste-bio-crude-conversion-technology
http://americanrecycler.com/8568759/index.php/news/waste-news/1727-exploring-waste-to-energy-trends
http://renewables.seenews.com/news/australias-westpac-to-issue-aud-500m-green-bond-526363
http://www.prnewswire.com/news-releases/act-environmental-services-introduces-next-generation-medical-waste-to-energy-program-300270174.html
https://www.qut.edu.au/news/news?news-id=103724
http://waste360.com/anaerobic-digestion/how-one-massachusetts-grocer-converting-food-waste-energy
http://www.smh.com.au/business/consumer-affairs/waste-to-energy-plant-gives-unsold-fruit-and-vegetables-a-second-life-20160505-gonmdt.html
http://www.starweekly.com.au/news/food-waste-gives-more-energy-to-burn/
http://www.businessgreen.com/bg/feature/2456969/how-sainsburys-is-tackling-food-waste-sustainability-and-energy-security-in-one-swoop
https://www.linkedin.com/pulse/waste-energy-potential-case-study-saudi-arabia-abdul-sattar-nizami
http://www.letsrecycle.com/news/latest-news/carlisle-efw-proposed-as-part-of-cumbria-waste-plan/
http://www.dailytelegraph.com.au/newslocal/west/full-list-of-blacktown-council-recommendations-for-proposed-eastern-creek-incinerator/news-story/aef21f5f20386dd216079e5236c6e907
http://www.stmarysstar.com.au/story/3868203/incinerator-proposal-on-backburner/
http://www.dailytelegraph.com.au/newslocal/west/blacktown-council-call-for-parliamentary-inquiry-into-standards-for-eastern-creek-energyfromwaste-facility/news-story/13d64104fb5790be6056b28a4b7faeb2
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
http://www.wastedive.com/news/covanta-ceo-stephen-jones-says-waste-to-energy-is-companys-bread-and-butte/416661/#.VwH-_Nt03r4.facebook
http://www.smh.com.au/business/energy/farmers-tap-into-clean-energy-finance-corporation-to-bolster-productivity-20160324-gnq8kl.html
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/
http://www.rewmag.com/article/scientists-tomato-waste-electricity-american-chemical-society/
http://www.theguardian.com/commentisfree/2016/mar/14/love-waste-incinerator-bjarke-ingels-copenhagen
http://fortune.com/2016/03/11/united-airlines-waste-biofuel-power-flights/
http://www.abc.net.au/news/2016-03-09/green-waste-plant-pumping-electricity-back-into-grid-in-wa-first/7234188
http://www.hydrogenfuelnews.com/plans-revealed-for-worlds-first-enzymatic-untreated-waste-to-energy-plant/8527664/
http://www.letsrecycle.com/news/latest-news/carlisle-efw-proposed-as-part-of-cumbria-waste-plan/
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?
Healthcare providers
Insurance firms
Farmers
Who pays the Cost of Free?
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
http://magazine.rewmag.com/article/april-2016/model-performance.aspx
http://www.pennenergy.com/articles/pennenergy/2016/04/waste-to-energy-electricity-generation-concentrated-in-florida-and-northeast.html
http://waste360.com/waste-energy/agricultural-wte-projects-taking-shape-north-carolina-and-oregon
https://www.engineersaustralia.org.au/portal/news/overseas-interest-sydney-unis-waste-bio-crude-conversion-technology
http://americanrecycler.com/8568759/index.php/news/waste-news/1727-exploring-waste-to-energy-trends
http://renewables.seenews.com/news/australias-westpac-to-issue-aud-500m-green-bond-526363
http://www.prnewswire.com/news-releases/act-environmental-services-introduces-next-generation-medical-waste-to-energy-program-300270174.html
https://www.qut.edu.au/news/news?news-id=103724
http://waste360.com/anaerobic-digestion/how-one-massachusetts-grocer-converting-food-waste-energy
http://www.smh.com.au/business/consumer-affairs/waste-to-energy-plant-gives-unsold-fruit-and-vegetables-a-second-life-20160505-gonmdt.html
http://www.starweekly.com.au/news/food-waste-gives-more-energy-to-burn/
http://www.businessgreen.com/bg/feature/2456969/how-sainsburys-is-tackling-food-waste-sustainability-and-energy-security-in-one-swoop
https://www.linkedin.com/pulse/waste-energy-potential-case-study-saudi-arabia-abdul-sattar-nizami
http://www.letsrecycle.com/news/latest-news/carlisle-efw-proposed-as-part-of-cumbria-waste-plan/
http://www.dailytelegraph.com.au/newslocal/west/full-list-of-blacktown-council-recommendations-for-proposed-eastern-creek-incinerator/news-story/aef21f5f20386dd216079e5236c6e907
http://www.stmarysstar.com.au/story/3868203/incinerator-proposal-on-backburner/
http://www.dailytelegraph.com.au/newslocal/west/blacktown-council-call-for-parliamentary-inquiry-into-standards-for-eastern-creek-energyfromwaste-facility/news-story/13d64104fb5790be6056b28a4b7faeb2
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
http://www.wastedive.com/news/covanta-ceo-stephen-jones-says-waste-to-energy-is-companys-bread-and-butte/416661/#.VwH-_Nt03r4.facebook
http://www.smh.com.au/business/energy/farmers-tap-into-clean-energy-finance-corporation-to-bolster-productivity-20160324-gnq8kl.html
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/
http://www.rewmag.com/article/scientists-tomato-waste-electricity-american-chemical-society/
http://www.theguardian.com/commentisfree/2016/mar/14/love-waste-incinerator-bjarke-ingels-copenhagen
http://fortune.com/2016/03/11/united-airlines-waste-biofuel-power-flights/
http://www.abc.net.au/news/2016-03-09/green-waste-plant-pumping-electricity-back-into-grid-in-wa-first/7234188
http://www.hydrogenfuelnews.com/plans-revealed-for-worlds-first-enzymatic-untreated-waste-to-energy-plant/8527664/
http://www.letsrecycle.com/news/latest-news/carlisle-efw-proposed-as-part-of-cumbria-waste-plan/
Tuesday, 15 March 2016
Poisoning our Future - Biosolids in our Parks ...
Biosolids are being used in parks, playgrounds, gardens, flower-beds and golf courses – this is a reckless practice, and we need to stop it.
Many cities use their sewer sludge (aka biosolids) as a fertilizer / compost for their green-spaces. This practice should stop immediately as the science does not support this method of dealing with a city’s sewage residuals. Proponents talk of “completing the cycle” of returning the resource “back to the soil.” Well perhaps someone can tell me what soil had flame retardants, superbugs, cancer drugs, prions, nanomaterials, and pharmaceuticals in it? This is NOT recycling folks – this is toxin dispersal masquerading as something “green.”
Why would we subject the most vulnerable members of our society, our children, to the concentrated end-product of our waste water treatment facilities? There are known to be thousands of chemicals/toxins in these residuals. Cities need to get rid of their piles of sludge waste, but spreading it around the city environment is a reckless, short-sighted method of dealing with their toxic burden. Let’s get on the right side of history and move towards gasification / pyrolysis. Let’s give future generations a better inheritance than an environment compromised by our city’s toxins.
New science is showing just how problematic biosolids (sewer sludge) can be. Below are some recent highlights. Ask yourself if you want your children exposed to these issues!!
1. 2016 - Mother Earth News – “Biosolids - More Harm than Good"
Dr. David Lewis writes that, "Sewage sludge is semi-solid organic matter, mostly human feces and animal fats, which settles out at wastewater treatment plants. More than half of the sewage sludges produced in the United States and Canada are biologically and chemically treated, usually by adding lime, to reduce odors and indicator pathogen levels. Once treated, the product is called biosolids. It is repeatedly applied to farms, forests, school playgrounds, public parks and other public and private lands at rates measured in tons per acre....It regulates only 9 of 27 heavy metals found in sewage sludge (As, Cd, Cu, Pb, Hg, Mo, Ni, Se, Zn), and no toxic organic chemicals. Many chemicals found at high (ppm) levels in biosolids are the worst of the worst, which EPA lists as priority pollutants. These are the ones we worry about most. They are highly persistent, biomagnified up the food chain, and known to cause adverse health effects in humans and animals.”
“Priority pollutants include endocrine disruptors, pesticides, pharmaceuticals, plasticizers and other chemical groups that concentrate in animal fats. As the fat solubility of chemicals increase, so does their neurotoxicity. Not surprisingly, exposures to these chemicals are linked to autism, ALS, Alzheimer’s disease, Parkinson’s disease and other neurological diseases and disorders." … "No wonder our children are developing autism at steadily increasing rates; teenagers are starting to get colon cancer; and more elderly people are getting Alzheimer’s disease and other neurological disorders. We must all spread the word, and tell our cities to stop spreading toxic biosolids. Hazardous chemical wastes must be contained and destroyed—not spread all around us. We have the technology, we just need to use it.”
2. 2016 - Duff Hale – “Environmental and health problems from using sewage sludge”
“A 2013 study by the Cornell University Waste Management Institute sampled people exposed to Class B sludge that lived within1 mile of sludged land. The results revealed health-related symptoms were statistically higher among exposed residents. They exhibited excess secretion of tears, abdominal bloating, jaundice, skin ulcers, dehydration, weight loss and general weakness, and also increased occurrence of bronchitis and upper respiratory infection.”
3. LATimes – 2016 – “Deadly superbugs from hospitals get stronger in the sewers”
“ a growing number of studies show sewage plants can't kill the superbugs. Instead the facilities serve as "a luxury hotel" for drug-resistant bacteria, a place where they thrive and grow stronger, said Pedro Alvarez, a professor of environmental engineering at Rice University, one of the scientists studying the problem.....Researchers have tried for years to raise the alarm about hospital sewage. The sludge includes not just waste from patients suffering from drug-resistant infections but also high levels of antibiotics prescribed to treat them.
As the sewage mixes, the antibiotics kill off weaker bacteria, leaving the more lethal ones to thrive. The bugs reproduce rapidly, and different species can swap genes, transferring their ability to withstand the drugs.”
4. Newsweek Magazine, 2016 “Eating Meat Grazed on Human Sewage…”
Richard Lea, a reproductive biologist at the School of Veterinary Medicine and Science at the University of Nottingham and lead author of the study, found that: "There is a concern that by eating the meat from the sheep, we’re taking onboard these chemicals," "Given that these chemicals are very persistent, and they’ve survived the very intensive processing of the sewage to begin with, there’s a very high chance that they’ll end up inside of us” ... “his team did identify certain constituents in the sewage that are known to impair hormone behavior in humans and animals alike.”
And so I ask – Do we really want to continue subjecting our children to these unnecessary dangers?
Sunday, 13 March 2016
Sowing Sludge, Reaping Death
Sowing Sludge, Reaping Death
If you had been on the fence about the pros and cons of using sewer sludge (aka biosolids) as an agricultural fertilizer, a read through some of the most recent scientific literature should leave you in no doubt - THIS STUFF IS TOXIC !! THIS PRACTICE IS RECKLESS!! TIME TO STOP THE LAND-APPLICATION OF BIOSOLIDS!!
Take a look at these recent publications from just the past two or three weeks -
1. Eating Meat Grazed on Human Sewage Might Lower Female Fertility http://www.newsweek.com/eating-meat-grazed-human-sewage-might-lower-female-fertility-432537
2. Deadly superbugs from hospitals get stronger in the sewers http://www.latimes.com/business/la-fi-superbug-sewers-20160307-story.html
3. Scientists’ open letter on the dangers of biosolids http://m.thespec.com/opinion-story/6368861-scientists-open-letter-on-the-dangers-of-biosolids
4. Biosolids: More Harm than Good - MOTHER EARTH NEWS http://www.motherearthnews.com/nature-and-environment/biosolids-more-harm-than-good-zbcz1602.aspx
5. Are Prescription Drugs on Your Menu for Dinner? https://shar.es/14B65S
6. Environmental and health problems from using sewage sludge http://www.elliscountypress.com/2016/news/editorials/environmental-and-health-problems-from-using-sewage-sludge/
7. Lidia Epp, Molecular Biologist reflects on Biosolids http://www.motherearthnews.com/nature-and-environment/a-tree-hugger-reflections-on-sludge-zbcz1603.aspx
8. http://www.motherearthnews.com/nature-and-environment/sludge-train-zbcz1604.aspx
These should be quite enough to convince any rational being that we must invoke the Precautionary Principle, and cease using our farmlands and forests as toxin dispersal sites. There are greener alternatives !!
Thursday, 25 February 2016
Recent Science on the Dangers of Biosolids
These pages are examples of some of the more recent science around biosolids and its land application. All raise serious issues about this practice. All state that more study needs to be done. All, in the absence of clear evidence of safety, suggest that we act with precaution.
Each Journal entry is followed by some quotes which highlight the problematic issues:
2013 – Sewage Sludge Management in Germany – in-depth government study 104 pages. https://www.umweltbundesamt.de/sites/default/files/medien/378/publikationen/sewage_sludge_management_in_germany.pdf
"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]."
"Another study concerning the soil breakdown and mineralization of steroid hormones that end up in fields as the result of sewage sludge fertilization (among other applications) found that oestrogen is a stable compound in the soil. The study’s lab experiments showed that oestrogen in soil is subject to vertical displacement and should thus be factored into risk assessments concerning groundwater as well as surface waterbodies that are affected by groundwater. Another subject of debate among scientists concerning sewage sludge application on land is the spread of pathogens that are resistant to antibiotics. There is evidence that in part owing to the elevated bacterial concentrations found in sewage treatment plants, antibiotic resistance can be exchanged between bacteria that are input with sewage from facilities such as hospitals [UBA]. This phenomenon could potentially give rise to new constellations of antibiotic resistance being transmitted to heretofore nonresistant bacteria. According to another study [EIBISCH], the continuous input of antibiotics into soil over a prolonged period can result in elevated concentrations of bacteria that promote the growth of antibiotic-resistant bacteria, resulting in the possibility of gene transfers of the resistance genes of such antibiotics. 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."
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A very good piece of objective journalism from The Guardian a few years ago, clearly maps out the issues with land application of "biosolids" –
"Switzerland - which used to land-apply 40% of its sludge - has banned the practice because of fears from farmers that it was harming their soil. The Netherlands has banned agricultural use of sludge, and national farmers' associations in France, Germany, Sweden, Luxembourg and Finland are against it, partly because of concerns about organic contaminants such as PCBs and brominated flame retardants (linked to liver and neuro-developmental toxicity and hormone disruption), which some research has shown persist in sludge."
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"National Toxics Network of Australia" media release from May, 2015 recommends - "Stop the use of biosolids as fertiliser pending further investigation of pharmaceutical contaminants"
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A new study (2012) from Scientists at the University of Aberdeen "studying sheep maintained on pastures fertilized with sewage sludge ... found a high incidence of abnormalities in the animals." As the article states, "It is our opinion that all spreading of sewage sludge, humanure and biosolids on agricultural land in the UK should be stopped until it is PROVED to be safe"
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Nanomaterials in Biosolids Inhibit Nodulation, Shift Microbial Community Composition, and Result in Increased Metal Uptake Relative to Bulk/Dissolved Metals June / 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
Mark Durenkamp, and Jason M. Unrine
"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."
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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 June 2015
Chun Chen, Jason M. Unrine, Jonathan D. Judy, Ricky W. Lewis, Jing Guo, David H. McNear, Jr.and Olga V. Tsyusko
"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."
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DISSIPATION OF CONTAMINANTS OF EMERGING CONCERN IN BIOSOLIDS APPLIED TO NONIRRIGATED FARMLAND IN EASTERN COLORADO
Tracy J.B. Yager, Edward T. Furlong, Dana W. Kolpin, Chad A. Kinney, Steven D. Zaugg, and Mark R. Burkhardt April 2014
"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"
"however, 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."
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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
"Perfluoroalkyl substances (PFASs) have been used for over the past 60 years in an increasing variety of consumer and industrial products, such as fire-retardant foams, inks, paper, lubricants, cosmetics, upholstery and so on. As a result of the large production and wide application, PFASs are broadly present in the environment. Within the PFAS group, perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA) are the most commonly used and found compounds (Hu et al., 2011). They have garnered intense scientific and regulatory interests due to their extraordinary persistence, bioaccumulation tendencies and potential toxicological effects. So far, PFOS and PFOA have been found in atmosphere (Li et al., 2011), soil (Yoo et al., 2010), surface water (Hu et al., 2011), sediment (Higgins et al., 2005), and biota (Müller et al., 2011). They were also present in the serum of wildlife and humans and could be biomagnified in terrestrial and aquatic food webs (Müller et al., 2011; Houde et al., 2011). Sewage sludge is an important sink of PFOS and PFOA (Higgins et al., 2005; Sun et al., 2011). The land application of treated sewage sludge (biosolids) is the option favored internationally for sludge management as it contributes to improve soil fertility and properties (Clarke and Smith, 2011). However, the use of biosolids as fertilizer in agriculture can cause contamination of PFASs in soils (Yoo et al., 2010; Washington et al., 2010; Sepulvado et al., 2011; Wen et al., 2014). Organisms are liable to take up organic contaminants and may accumulate high level of PFASs when they live in contaminated soil environment. A few studies have been conducted and revealed plant uptake of PFASs from soils (Yoo et al., 2011; Wen et al.,2014; Zhao et al., 2014)."
"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."
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."
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Effect of Land-Applied Biosolids on Surface-Water Nutrient Yields and Groundwater Quality in Orange County, North Carolina 2014
By Chad R. Wagner, Sharon A. Fitzgerald, Kristen Bukowski McSwain, Stephen L. Harden, Laura N. Gurley, and Shane W. Rogers
"A paired agricultural watershed study was conducted in the Collins Creek and Cane Creek watersheds in Orange County, North Carolina, to better understand the transport of nutrients and bacteria from biosolids application fields to groundwater and surface water and to provide a scientific basis for evaluating the effectiveness of the current biosolids land-application regulations"
"data for field properties and water-quality constituents, including metals, major ions, and contaminants of emerging concern (household-, industrial-, and agricultural-use compounds, pharmaceutical compounds, hormones, and antibiotics) also were collected and used in the analyses."
"Compared to the background field, the biosolids land-application fields had elevated concentrations of copper, mercury, molybdenum, TKN, and TP. The background field had the highest median concentrations of cadmium, lead, selenium, and fecal coliform. Finally, the median concentrations of five constituents (arsenic, chromium, nickel, zinc, and E. coli.) overlapped between the application fields and the background field. The potential short-term effect of land application of biosolids to agricultural fields was evaluated using both the chemical concentration and dry mass of the biosolids samples in relation to that of the (pre-application) soil onto which it was applied. "
"Selected biosolids and soil samples were collected and analyzed for contaminants of emerging concern (household-, industrial-, and agricultural-use compounds, sterols, pharmaceuticals, hormones, and antibiotics) from biosolids land-application fields ... Pharmaceuticals were largely detected only in the application fields and biosolids."
"Compounds that were often detected in both the biosolids-application soils and the biosolids samples but not in the background field include 2,6-dimethylnaphthalene, benzo[a]pyrene, acetylhexamethyl tetrahydronaphthalene (AHTN), 2,2',4,4'-tetrabromodiphenylether (PBDE 47), d-limonene, and triclosan. For these compounds, biosolids are likely the dominant source to the biosolids-application soils. "
"The first step used to characterizing the effect agricultural watersheds with and without land-applied biosolids had on constituent concentrations in the underlying shallow groundwater was statistical comparison testing to evaluate if there were statistically significant differences ..... Wells OR-687 and OR-688 are located adjacent to and topographically downgradient from the biosolids application fields and were found to be statistically different and have higher nitrate concentrations than all the other wells. "
"To further evaluate any differences in the shallow groundwater quality under agricultural fields with and without land-applied biosolids and the contribution to surface water, the concentrations of EPA-listed contaminants with ceiling concentrations for land-applied biosolids and nutrients were analyzed.... Shallow groundwater samples were collected in December of 2011 and analyzed for contaminants of emerging concern (household-, industrial-, and agricultural-use compounds, sterols, pharmaceuticals, hormones, and antibiotics) from five of the six monitoring wells."
"Concentrations of E. coli and fecal coliform bacteria were higher by orders of magnitude and statistically different in storm samples at the three sites compared to baseflow samples."
"Overall, the most compelling conclusions of the study can be summarized by the following ...
Copper, molybdenum, total Kjeldahl nitrogen, and TP were elevated in the soil from biosolids land-application fields relative to the background field ... Shallow groundwater in transitional zone wells, which are located adjacent to and topographically downgradient from all the biosolids-application fields, were found to be statistically different and had higher nitrate concentrations (medians greater than the EPA drinking-water standard of 10 mg/L) than all the other wells sampled as part of the study."
"Nutrient surface-water concentrations and yields (pounds per square mile), primarily nitrate, were higher at the monitoring site on Collins Creek downstream from the biosolids application fields than the other background study sites"
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Monitoring Bacteroides spp. markers, nutrients, metals and Escherichia coli in soil and leachate after land application of three types of municipal biosolids 2014
Crystal A. McCall, Katerina S. Jordan, Marc B. Habash, Kari E. Dunfield*
School of Environmental Sciences, University of Guelph, Guelph, Ontario N1G 2W1, Canada
Municipal biosolids " can also be non-point source contributors of metals, human-pathogens and
xenobiotics (Singh et al., 2006). The excessive nutrient and metal loads either from improper application rates or unexpected bioconversion is a concern"
"there is always potential for leaching and run-off of microbial contaminants from land-applied
biosolids into surface water and groundwater after extreme weather events including heavy rainfall or flooding (Jamieson et al., 2002; Samarajeewa et al., 2012)."
biosolids into surface water and groundwater after extreme weather events including heavy rainfall or flooding (Jamieson et al., 2002; Samarajeewa et al., 2012)."
"MBs (Municipal biosolids) can contain other human pathogens that are not reported or enumerated under the current regulations, including Legionella pneumophila, Staphylococcus aureus, Clostridium difficile and Mycobacterium spp. (Bibby et al., 2010; Viau and Peccia, 2009).
"Treatment processes for MBs can be designed to eliminate many pathogens (Singh et al., 2006); however, unregulated category (CP2, or Class B) products are frequently used as a soil amendment on agriculture lands, in part because wastewater treatment plants often lack the capability to test for the presence of viruses and helminth ova and therefore cannot guarantee their absence."
"Conclusions - Land application of both CP1/Class A and CP2/Class B MBs can lead to drainage and surface water contamination based on an increased concentration of fecal indicators, NO3eN and total-P found in leachate samples."
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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
"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 ... 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."
" CONCLUSIONS - 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 atthis study site."
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Toward a Consensus View on the Infectious Risks Associated with Land Application of Sewage Sludge 2011
Emily Viau, Kyle Bibby, Tania Paez-Rubio, and Jordan Peccia
"Other than accidental direct ingestion, the highest public risks of infection from land application are associated with airborne exposure."
"Such analysis demonstrates that the tradition of monitoring pathogen quality by Salmonella spp. and enterovirus content underestimates the infectious risk to the public"
"Over the last ten years, the scientific basis for the Part 503 regulations has been criticized. These criticisms stem fromthe lack of biosolids research on pathogen content and aerosol transport,
the lack of epidemiological studies, and the growing number of anecdotal health complaints from citizens living near land application sites."
"Such analysis demonstrates that the tradition of monitoring pathogen quality by Salmonella spp. and enterovirus content underestimates the infectious risk to the public"
"Over the last ten years, the scientific basis for the Part 503 regulations has been criticized. These criticisms stem fromthe lack of biosolids research on pathogen content and aerosol transport,
the lack of epidemiological studies, and the growing number of anecdotal health complaints from citizens living near land application sites."
"To provide new and important insights into biosolids land application and human health, this review conducted a literature survey on pathogen content and inactivation, compiled and analyzed the results of previous risk studies, and produced new risk estimates using the most up-to-date pathogen content information. Pathogen survey results clearly demonstrate that fecal coliform indicator concentration and associated class A treatment or monitoring requirements do not confirm that class A biosolids are pathogen free, nor is fecal coliform inactivation a conservative measure of pathogen inactivation. The comparison of available quantitative risk studies suggests that, other than accidental ingestions, which the Part 503 regulations to prevent site access are aimed at reducing, aerosols were identified to be the most important route of human exposure to infectious agents. Although there is a consensus among independent risk assessments on the probability of aerosol infection from enteroviruses, inclusion of adenovirus and especially norovirus in risk estimates clearly demonstrates that previous and current risk values for enteroviruses and Salmonella spp. are an underestimate of the total infective risk of pathogens contained in biosolids. Moreover, the consideration of pathogens (such as norovirus) in risk analysis that were not considered during the original analysis for Part 503 rule demonstrates that previous standards based on Salmonella spp. and enterovirus will not achieve the level of protection intended in these regulations."
"The lack of a clearly defined acceptable risk threshold for residents living near biosolids land application sites precludes the use of risk as a definitive measure of safety ... The USEPA originally promulgated biosolids rules based on expedience, reducing pathogen exposure through treatment by the most direct and least-costly approach in view of the uncertainty associated with taking a more risk-based precautionary approach."
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Identification of Viral Pathogen Diversity in Sewage Sludge by Metagenome Analysis 2013
Kyle Bibby and Jordan Peccia
"The large diversity of viruses that exist in human populations are potentially excreted into
sewage collection systems and concentrated in sewage sludge. "
"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."
Tuesday, 16 February 2016
Scientists' Open Letter on the Dangers of Biosolids
Scientists' Open Letter on the Dangers of Biosolids
(originally published in http://www.merrittherald.com/opinion-the-risky-business-of-land-based-biosolids-disposal/)
As scientists, we have been watching the issue with increasing concern.
An unimaginably large number of chemical and biological contaminants exist in these materials, and they persist in the product up to, and after, land disposal. Scientific investigations have identified only a tiny fraction of the total contaminant load. We cannot even say with any degree of confidence what the true range of contaminant risk is from the sludge. Call it an “unknown unknown.” Because of potential synergistic interactions between the contaminants in the sludge, the risks are largely unknowable.
Most public discussions of the chemical contaminants in sewage sludge involve well known groups such as heavy metals, flame retardants, and pharmaceuticals, among many others. But these are just the contaminants we have identified. To refer to our current knowledge base as the tip of the iceberg would be grossly overestimating how much we actually do know.
Regulators and others -- including elected officials -- up and down the policy chain appear to lack a real appreciation for the scope of the problem, and the costs of beginning to understand it. If a city were to test the sludge just once for all possible contaminants in the material, the bill would be well into the hundreds of thousands of dollars.
You are not going to find a problem if you don't look for it. Of course, over time, that problem may also come looking for you.
To illustrate the difficulties, take just one group of persistent, bioaccumulative, and toxic compounds known to be in sewage sludge at high concentrations: brominated flame retardants. Perhaps the most well known sub-class of the brominated flame retardants are called polybrominated diphenyl ethers (PBDEs). There are 209 different PBDEs, each of which has a unique toxicology and environmental fate. PBDEs have been studied around the world for several decades, and despite many millions of dollars in research and thousands of dedicated researchers, we still have a very poor understanding of the true risks from their release into the environment.
This is just one contaminant class among many. There are also 209 different members of the PCBs. Similarly, add in another 210 chlorinated dioxin “congeners.” And on the total number of contaminants in sewage sludge climbs as we begin to consider that effectively all current and legacy industrial chemicals end up in our sewage, and during the treatment process they move into the sludge. If you apply the sludge to the land, we have transferred our toxic effluent onto the landscape.
Now consider that while the tens of thousands of these commercial chemicals are a possible problem which we barely understand, the risks from the much larger suite (i.e., millions) of possible degradation products are essentially unknown. Then add on all pharmaceuticals and personal care products, as well as any other compound we use in the home or at work, and all their potential degradation products.
We are often asked by regulators, politicians, and the general public what to do about the issue. Give us the tests and we will do them, they claim. In response, we say that not only can you not afford to do all the required tests on your own (the costs must be distributed across entire countries and the international community as best we can, and even that is almost unaffordable), but many of the required tests require advances in technology which we do not yet possess.
The complexity discussed so far just touches on the chemical contaminants. Add to that the massive numbers of biological contaminants -- bacteria, viruses, prions, etc. -- and what we see are the decision makers throwing their hands up in frustration. As they should. The current and future problem is inconceivably large, particularly since the human population is producing sewage sludge at a rapidly growing rate.
Those from the large public and private sector industry that has developed around marketing and selling sewage sludge for land disposal -- which we collectively term Big Sludge -- claim the materials are “non-toxic” and a resource to be cherished, not shunned. The state of the science does not agree with this oversimplification.
While there have been some attempts to review the science surrounding sewage sludge, these are generally wanting. Either the reviews are out-of-date and incomplete, failing to account for all that we do know about emerging contaminants and what we don't know about all contaminants, or they are written more as promotional materials for Big Sludge in an attempt to sell the product to an ever more sceptical public.
What should we do in response to all these concerns? Immediately halt the land disposal of sewage sludge as a starting point, and begin either stockpiling or landfilling the material in secure locations with full leachate collection systems until a more responsible means of dealing with the problem is implemented. In the meantime, the science must continue in an effort to better understand the risks and to develop more effective treatment technologies.
We also see municipalities and regional districts talking about the revenue stream from selling their sludge for land disposal, but are they telling the taxpayers they are supposed to represent about the very large potential risks from the knowing and wilful contamination of lands, waters, and the atmosphere that arises from these choices? Increased health care costs, decreased property values, and toxic tort lawsuits have collective liabilities to Big Sludge over time that far outweigh the relatively small cash flows currently coming in to the public purse.
Governments are playing Russian roulette with sewage sludge, and over time there is a high probability this game will be lost at the public's expense.
Sierra Rayne, PhD
John Werring, MSc, RPBio
Richard Honour, PhD
Steven R. Vincent, PhD
Sierra Rayne is an independent scientist; John Werring is a senior science and policy advisor for the David Suzuki Foundation; Richard Honour is the executive director for The Precautionary Group; Steven R. Vincent is the Louise Brown Professor of Neuroscience with the Department of Psychiatry at the University of British Columbia.
Sierra Rayne is an independent scientist; John Werring is a senior science and policy advisor for the David Suzuki Foundation; Richard Honour is the executive director for The Precautionary Group; Steven R. Vincent is the Louise Brown Professor of Neuroscience with the Department of Psychiatry at the University of British Columbia.
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