SOUND SLUDGE SCIENCE                    Pages 1, 2, 3, 4
                                   and the need for
EPA/WEF Rapid Incident Response to Health Complaints From Land Application of Biosolids

by Jim Bynum                                                                                                                                                                                        5/20/2008
Help for Sewage Victims
Retired Safety Consultant

We Didn't Know the Gun Was Loaded, or Did We?

When the body count starts rising, similar types of illness appear around sludge biosolids disposal sites and food
poisoning incidences explode, you wonder if perhaps EPA and WEF may have made a mistake concerning sound
sludge science. It tends to be a little alarming that CDC is still giving out 10 year old statistics for food poisoning as
current data. The questioning becomes more important when you consider hormone disrupter's and viruses from
wastewater and sludge runoff may contaminate our drinking water affecting neural development of our children and
giving them sexual transmitted diseases while enjoying a bath as well as causing other
epidemics/pandemics.

"Ask not for whom the bell tolls; it tolls for thee!" This cryptic message to a vocal California farmer opposed to
sludge/biosolids use on farmland, was attached to a Water Environment Federation (WEF) letter dated February 28,
1996, with the heading, "DEAR MEMBER OF CONGRESS:" The signature on the message indicated it was signed by
the
WEF's temporary Senior Scientist,  who was loaned to WEF by the EPA. The implied threat to the California farmer
was contained in the WEF letter sent to each member of Congress. WEF was asking for Congress to place the blame
for water pollution on farmers and their operations, because, "Water Quality 2000 found that "polluted runoff from
agricultural activities...is a major cause of impairment of our nation's waters. Congress must make a clear statement
that agriculturally derived
water pollution problems is a national priority." Current Farm Bill provisions have produced
some progress in water quality. But future improvements will require a new way of thinking about these problems.
Agricultural conservation and environmental protection programs should be re-oriented to make pollution prevention
the primary focus."

EPA
Administrator Johnson speaking to American Water Works Association in March 2006 said, "The use of sound
science is particularly necessary in our efforts to confront a major threat to water quality and sources of drinking water
– nonpoint source pollution. 35 years ago, the threats to our nation’s water were clearer - and we set out to stop the
practice of dumping of waste directly into our rivers and waterways. We must continue to teach people that their
individual actions can add up to big environmental gains."  Johnson is following the PR line known as

A little EPA/WEF humor here aimed at Congress. Nonpoint source polluted runoff from agricultural activities are
protected by a Congressional Statutory exclusion in the
CWA, which is why EPA will allow, and WEF members, are
dumping hundreds of tons of polluted liquid sludge at two percent solids, on 10%> slopes, ten meters (32 feet) from the
banks of our nations waters -- calling it a fertilizer. That is a little of
EPA's Sludge Magic. As we discovered in Kansas
City, property lines are not very good at stopping the polluted runoff either, even when the slope is less than 3%. While
high levels of calcium runoff was the major indicator that our farm was being polluted, pathogen tests from an EPA
certified laboratory
revealed Salmonella and E. coli at 800,000 cfu per 100ml. The strange part was EPA's coliform
bacteria tests only registered 3000, 9000 coliform for those two tests. Even stranger, is that Salmonella and E. coli are
part of the
coliform group of gram negative bacteria. We also did a test to make sure they were human pathogens. We
immediately quit farming this parcel since pathogen may be taken
up inside the crops which went directly into the
human food supply. The crops from the City's sludge site continued to go directly into the human food supply as EPA
has no standards for disease organisms in soil or food..

"The
Birmingham Treatment Plant in Kansas City has repeatedly violated its state issued NPDES permit.  According to
Missouri records, Kansas City had reported 5 recent NPDES violations, some of them more than once, and no one in
the state DNR even acknowledged it. The ground water monitoring system was installed when the sludge site was
created under the solid waste rules in Part 257.  The State has retained the monitoring wells under the NPDES program
for the plant because, according to the Environmental Assessment Reports, the soil was never suitable for the
construction of sludge lagoons or landfills".  "In December of 1997, it was revealed by state records, there was ground
water contamination both on and off Kansas City's sludge application site." There was "ground water contamination
from high levels of nitrogen, aluminum, arsenic, and fecal coliform." "All fourteen test wells were above the limits for
nitrogen and many of the test wells were above the permit limits for aluminum. One well was above the NPDES limit for
arsenic." And the neighboring women around this site were dying off.

Two more sides of the coin -- 10 years apart.

The EPA/WEF PR position is that there are 50 years of research to prove that sludge use is safe when the laws and
regulations are followed. However, the sludge / biosolids policy part 503  has no supporting law.
RCRA, CWA, CERCLA,
CAA, and OSHA regulations are very clear about the toxic and hazardous pollutant contaminates in sludge that are
serious health hazards by direct exposure or indirect exposure through the air, food or water. To get around the laws
which are designed to make sludge safe, EPA had to consider disposal of sludge was a normal application of fertilizer
(it's not), there are no carcinogenic chemicals in sludge (there are), crops don't take up toxic metals or disease
organism (they do), disease organisms do not cause disease in farm workers (they do), liquid sludge does not run
down hill (it does), and no one was smart enough to catch them lying (they were wrong).

The EPA PR line is that sludge treatment processes reduce pathogenic disease organisms to a safe levels based on
testing for the indicator
fecal coliform group that only grows at 112.1 degree F.  It is kind of funny when you think
about it, because these pathogen indicators are the mutant
superbugs of the coliform group that grow best at 96-98
degree F.

The WEF PR line is that sludge treatment kills all pathogens in sludge. However, in
1996, BioCycle reported, "Some
pathogens have even developed resistance to time- tested controls such as heat and refrigeration. Several of the
alternatives to reduce pathogens in sludge products use heat at temperatures of 55 C and above to achieve Class A
status. However, according to the article  "Pathogen Destruction and Biosolids Composting" in BioCycle of June of
1996, "There is some evidence that coliform and Salmonella sp. can survive prolonged exposure to temperatures of
55 C." They cite a study done by Droffner and Brinton (1995) using DNA gene probes, where they detected E. coli and
Salmonella sp. in samples collected from an in-vessel composting  facility after the first 15 days of active composting at
a temperature above 55 C. In Table 5-4 Processes to Further Reduce Pathogens in
A Plain English Guide to the EPA
Part 503 Biosolids  Rule
, composting time and temperature requirements for within-vessel composting method was
55 C or higher for three days! Droffner and Brinton found that it took 56 days and 90 days for the densities of
Salmonella sp. and E. Coli, respectively, to decline below the detection limit...These investigators also "cite evidence of
mutant strains of E. coli and Salmonella sp. resistant to thermal environments in composting." (p. 68)

BioCycle found that many
in-vessel composting facilities were closed because the equipment didn't work properly. But,
the sludge was sold as a safe Class A potting soil for direct public contact, thereby putting the
public health at risk. You
might want to think about that the next time  you consider picking up potting soil at the
local nursery or taking a potted
plant to a sick friend or relative in the hospital.

In 2006, WEF took a new approach to the in-vessel composting pathogen problem. The press release was shocking:
"According to a recent Water Environment Research Foundation (WERF; Alexandria, Va.) study, fecal coliform counts
can increase dramatically in anaerobically digested biosolids, but the reason is unclear.", but the header indicated
everything was under control:
"Organizations Respond Quickly to Evidence of Coliform Reactivation  (bacterial
regrowth)"
They say:
“Basically, what happens is when you come out of digestion and go into a dewatering device, you have one
density of fecal coliform and then, immediately after dewatering, that level increases by one, two, three, or
four orders of magnitude,” said Matthew Higgins, associate professor in the Department of Civil and
Environmental Engineering at Bucknell University (Lewisburg, Pa.), and a principal investigator for the
WERF study.

Because the bacteria cannot reproduce that quickly, researchers have concluded that this phenomenon is
due to the reactivation of bacteria. That is, the fecal coliform were always present in the samples but were
invisible to standard culturing methods until dewatering somehow spurred them to function fully.

Higgins described several mechanisms that could account for this nonculturable state. The first theory is
that the
bacteria could have been injured but not destroyed during digestion and that dewatering enabled
them to repair themselves and become active again. The second theory points to the bacteria entering a
viable but nonculturable state; this state would be a defense mechanism to the conditions of the digestion
process. The third theory, Higgins explained, is that an
inhibitor present in the digested solids is removed
by the dewatering process."

That is not a real problem: "the regulations also include process-based equivalents for Class A and B that
require no subsequent testing. In these cases, the observed reactivation and regrowth could push the
fecal coliform concentrations above the allowed levels unbeknownst to utilities."

EPA's Mark "Meckes emphasized that reactivation and regrowth have only been seen in bacterial indicator
organisms, not pathogens. Moreover, he said that this issue is strictly a bacterial one. Viruses, protozoa,
and other monitored organisms require a living host to multiply. Meckes said the chances of those
pathogens reactivating or regrowing after digestion are “slim to none.”

Notice:
Meckes indicates bacteria are not pathogens. Was that a senior moment? Not only that but he did not say --
the viruses, protozoa and helmiths do not survive the process.(They do)

WEF/WERF imply: 2.   These forms of treatment are designed to kill disease-causing microscopic organisms
(pathogens). But then
WEF/WERF admits:"The issue of viable but nonculturable (VBNC) bacteria was advanced in the
1980s, and  gained significant interest in medicine, the food industry, and many other fields."
Except the waste and
water industry which never considered the potential effect on public health.

But, wait a second: "EPA's 2006,  Biosolids Technology Fact Sheet, Use of Composting for Biosolids Management,  
based on
Yanko's 1988 study states, "Under some conditions, explosive regrowth of pathogenic microorganisms is
possible." "Composting is not a sterilization process and a properly composted product maintains an active population
of beneficial microorganisms that compete against the pathogenic members."
[Note: EPA and partners have assured the public that composting destroys pathogenic disease causing
organism]"

According to the preamble to and the final
part 503.33, there is another problem: "The vector attraction reduction
requirement concerning incorporation of sewage sludge into the soil also requires that sewage sludge that is Class A
with respect to pathogens be applied to or placed on the land within eight hours after being discharged from the
pathogen treatment process. After that, the sewage sludge must be incorporated into the soil within six hours after
being applied (beneficial use) or placed (disposed of) on the land.  The purpose of this requirement is to ensure that
regrowth of Salmonelle sp. bacteria do not occur between the time the sewage sludge is discharged from the pathogen
process and the time the sewage sludge is applied or placed on the land." (FR. 58, p. 9353, 9401

Sludge pathogens are not the only wastewater screwup by EPA and WEF members:

In May 2006,
University of Minnesota researchers published data showing that extremely high numbers of
multi-drug resistant bacteria  (173) in effluent (treated water) at high levels are being released into the
environment from highly efficient, award winning, sewage wastewater treatment plants. Researchers were
very concerned when they found extremely fast transfer of the drug resistant gene between bacteria in
the treatment plant which confirmed EPA studies from the 80s. They appeared to be somewhat confused
because the
bacteria taken out of the treated water were not detectable in sludge.

In the study, Municipal Wastewater Treatment: A Novel Opportunity to Slow the Proliferation of
Antibiotic-Resistant Bacteria?
 Timothy M. LaPara (May, 2006,) an associate professor at the University of
Minnesota published critical research on mulit-drug resistant disease organisms released in the effluent (cleaned water
and sludge) from public owned wastewater treatment plants.  The common belief was that most disinfection processes
used by treatment plants adequately inactivated multi-drug resistant disease organisms in the cleaned water before it
was released into the rivers or used to irrigate public access areas, food crops or used in building cooling systems. You
will notice the key word was
inactivate, which indicates the disease organism are still viable but nonculturable by
standard laboratory methods

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