Meeting, Article Offer One-Sided View of Biosolids, -- a review of Garvey's facts at:
http://lancasterfarming.com/eeditions?dt=20090328§ion=A&page=12
DIANE GARVEY
Garvey Resources, Inc.
To paraphrase the late, great Paul Harvey, the readers of Lancaster Farming deserve to get the "rest of the story"
about biosolids.
Garvey must have been referring John Walker's 1994 memo "Candidates for the Rest of The Story" in
which in which EPA ordered the sewage experts at Water Environment Federation to hire a writer to cover
up the sludgicide stories. To make it sound like scientists were involved they created the Water
Environment Research Foundation to further the goal.
The March 14 article "Farmers Urged to Take a Second Look at Biosolids" was certainly accurate in its coverage of the
claims of two Georgia farmers and a college professor who spoke at the anti-biosolids meeting. However, the article
only presented one side of the issue — a very narrow and distorted view of biosolids and one that is not shared by a
majority within the scientific community and thousands of farmers across the nation.
What Garvey means is sewage experts at the Water Environment Federation claim to be the majority in the
scientific community. That community was shocked by a 2006 "Examination of Reactivation and Regrowth
of Fecal Coliforms in Centrifuge Dewatered, Anaerobically Digested Sludges”when it was discovered that
"Based on the data collected in this study, researchers determined that more [pathogenic] coliforms may
have actually been present after anaerobic digestion but were not picked up by the standard culturing
method. " "Of the seven facilities tested during this study, researchers observed large increases in fecal
coliforms at four facilities after anaerobically digested solids were processed using high-solids
centrifuges. In some cases these increases were as much as several orders of magnitude." It is a shame
the treatment did not work.
The anti-biosolids meeting on March 10 was theater, and the producers and actors all did their best to scare the
daylights out of their audience with horror stories that have been discredited by the research of the scientific
community and by the federal and state regulators charged with protecting our nation's health and environment.
Actually we get an indication of the research of the scientific community and how the horror stories were
discredited by looking at 1994 EPA memos to the Water Environment Federation especially in the third
memo which started funding horror stories coverup. Garvey has been a very active member of the Water
Environment Federation which has received millions of dollars to cover up the horror stories. The Water
Environment Federation is guilty of using that money to write fact sheets on and about the victims. The
victims were sent a copy for review, and the Water Environment Federation claimed they were reviewed by
the victim but comments were not allowed or included in the fact sheets. An example is the fact sheet on
the Linda and Ray Zander dairy. Compare that to Zander's real story.
To hear these actors tell it, the whole world is involved in a giant conspiracy to make .people and animals sick and then
cover it up. This alleged conspiracy includes anyone who challenges their claims-water treatment professionals, other
farmers, the legal system, university researchers, state and federal environmental agencies. The Georgia farmers have
also shown a willingness to sue just about anyone who dares to disagree.
Is it a conspiracy when EPA tests for fecal coliform which is in fact the name of a test for the pathogenic
thermotolerant members of the family of Enterobacteriaceae that include E. coli, klebsiella, Salmonella,
shigella, etc., and then states these are only indicators of pathogens and the Water Environment
Federation knows better but claims they do not cause disease? As an industry consultant for 20 years
Garvey gets paid to discredit sludge victims. The Georgia farmers are not the only people or animals hurt
by sludge. Check out THEY ARE KILLING US WITH SLUDGE/BIOSOLIDS or CATTLE DEATHS and www.
sludgevictims.com
Those who heard these claims on March 10 and the readers of this publication might want to consider the following: If
biosolids are so bad, why could the opponents only find two farmers from 700 miles away who had such a tale of woe?
And what is the relevance of something that happened nearly 20 years ago, before implementation of the extensive
federal and state regulations that ensure the high quality and safety of today's biosolids? And given that thousands of
farmers across the nation have used biosolids for decades, many in Pennsylvania, why haven't others had the same
problems? If biosolids are so bad, then there should be hundreds of other farmers with the same complaints.
What happened 20 years ago is relevant because it is what can be expected in the future when the only
benefit is to the sludge dumper who make a lot of money while the farmer is left with the liability. Not to
mention the fact that the solid waste sludge regulation part 257 used at that time was very restrictive and
would still prohibit the use of this high quality biosolids. Lets not forget that some of this high quality
sludge can not be applied to a Part 503 surface disposal site. Actually, they could have invited me, since
we had a farm destroyed by extremely high levels of E. coli and Salmonella -- over 800,000 of each bacteria
per 100 grams of soil just from runoff from Kansas City, Missouri's sludge farm. But then I was too sick to
make the trip. The fact is these Georgia farmers are two of the very few to win a lawsuit without having the
courts prohibiting the release on any information about the lawsuits..
But in fact, the organizers of the March 10 show can't produce other farmers with documented harm. The reason is
simple. The land application of biosolids is safe and highly beneficial to family farms. The land application process is
based on solid science, ongoing research, the experience of thousand of farmers, the dedication of water treatment
professionals and the diligence of environmental protection officials at the federal level and in every state in the nation,
especially Pennsylvania,
Early claims were based on sound science even though EPA acknowledged a lack of science behind Pat
503. Furthermore, EPA has admitted that there was no risk assessment for organic or hazardous
substances and pathogens even though Part 503 specifically states if you are exposure to these
substances they could cause death, disease cancer, etc. You have to remember this is Federally
authorized sludgicide and there are only 7 states approved by EPA's Part 501 rule to participate. Neither
Pennsylvania or Virginia is included on that EPA list -- so they are creating prohibited solid waste open
dumps.
The record compiled by university researchers and the Environmental Protection Agency shows clearly that biosolids
did not cause the problems with the dairy herds in Georgia. According to the record — which was not revealed on
March 10 — the cows were suffering from multiple infections resulting from dairy herd management issues, such as
Johne's disease, bovine leukosis virus (BLV), malignant lymphoma, and metabolic diseases.
The AP reported that "USDA Ordered to compensate Georgia farmer for contaminated cropland. Officials
admit knowing that sludge chemical contaminated milk had been sold to public since 1999." When EPA
agents with an agenda funds a sludge study, scientific researchers should beware! Julia Gaskin of the
University of Georgia is learning this lesson the hard way, in court charged with fabricating data to cover
up cattle deaths on a Georgia farm. "She also says that the paper was never intended to study problems
with biosolids on the dairy farms. “The purpose of this paper was not the focus that has been alleged,” she
says. “That was not part of this effort." But then Judge Alaimo did refute Garvey's charge more elegantly.
Your readers should also be aware of other facts about the Georgia claims. First, the farmers who spoke on March 10
never allowed the EPA to sample the soils and forage they claimed to be affected. Secondly, the University of Georgia
performed extensive tests on the other farms that had received the same biosolids and tested the soil and the hay and
grass grown on the farms. These scientific studies determined that the land and the crops were safe and did not have
toxic levels of heavy metals, as claimed by the plaintiffs. These other farmers had no problems and have continued to
use biosolids, as have other farmers in the area.
EPA doesn't do soil samples on Federally authorized dump sites. EPA's John Dunn really pissed off
Missouri DNR's James Macy when he promised to do soil samples on our farm and then backed out even
though sludge site monitoring wells showed groundwater contamination. As Gaskin said of her Georgia
study, that was not the purpose of the study -- the EPA just offered money for a study without telling her
the purpose. There are extreme odds against Garvey admitting that the pathogenic coliforms in biosolids
will kill humans and animals or admitting that Fecal coliform is just the name of a test for the
thermotolerant coliforms and that the test actually suppress the growth of bacteria except a few that grow
slowly at an elevated temperatures. Actually Georgia's double standard on Salmonella contamination is
going to be a problem for farmers. Georgia promotes spreading Salmonella on food crops, then wants to
send someone to jail and fine them when Salmonella reaches the consumer.
So much for the claims from the Peach State. But what do we make of the professor who spoke and raised all kinds of
questions about biosolids? The answer is that it is easy to raise questions-anyone can do that, even without a PhD.
What we should expect from a scientist, however, is answers based on the best available research and practical
experience. What we got from Dr. McBride was speculation based mainly on his narrow field of expertise and his
opinion, which was not based on the great body of research that has been conducted on biosolids.
An observation, as one of the industry attack dogs, Garvey with a B.S. degree, does not have to abide by
the same scientific rules of ethics as a Ph.D. Cornell's Dr. McBride has been researching sludge for a long
time (over 25 years) including the study "MOBILITY AND SOLUBILITY OF TOXIC METALS AND NUTRIENTS IN
SOIL FIFTEEN YEARS AFTER SLUDGE APPLICATION" Cornell has also done something Garvey's group will
not do, honestly investigate health complaints INVESTIGATION OF ALLEGED HEALTH INCIDENTS
ASSOCIATED WITH LAND APPLICATION OF SEWAGE SLUDGES
Throughout his presentation, and when questioned, Dr. McBride was forced to admit that his knowledge of numerous
issues related to the safety of biosolids was limited. But that didn't keep him from making sweeping assertions that were
calculated to place doubts in the minds of his audience. What his audience and your readers need to understand is
that McBride, while knowledgeable in certain areas, is well out of the mainstream when it comes to the scientific
community's findings regarding biosolids recycling. The overwhelming weight of scientific evidence compiled during
decades of university research supports the safety of biosolids land application as currently regulated in the nation and
in Pennsylvania. New research is constantly adding to our understanding of biosolids.
The facts are that there has never been a pro sludge scientist study on sludge/biosolids use that did not
have severe limitations, especially, demanding more study and more money. EPA and partners ignored the
most damaging study which showed the toxic extracts for sludge would kill without leaving a trace marker
to indicate the cause of death. "Organic Toxicants and pathogens in Sewage Sludge and Their
Environmental Effects," JG Babish, DJ Lisk, GS Stoewsand, and C Wilkinson, A Special Report of the
Subcommittee on Organics in Sludge, Cornell university, College of Agriculture and Life Sciences,
December 1981.
As another example Garvey's group will tell you that using lime to raise the pH to 11-12 will cause
pathogens to be nondetectable-- or killed. What they will not tell you is that USDA and EPA refuted that
science in 1973 when it was discovered that Salmonella only remained undetectable for about 30 days in
the limed sludge and suddenly they were all back. Neither will they tell you that raising the pH to 11-12
causes chromium three to convert into the deadly cancer causing chromium six, especially when inhaled
and it is easily taken up by crops..
The organizers of the March 10 event presented their one professor. Supporters of biosolids can produce hundreds of
peer-reviewed scientific studies, conducted by hundreds of university professors and their researchers, that confirm the
safety and benefits of biosolids. Some of this research has been conducted at our own Penn State College of
Agricultural Sciences. But don't just take my word for it, support for the safety and benefits of biosolids recently came
from two major studies, one commissioned by the Center for Rural Pennsylvania, a legislative agency of the
Pennsylvania General Assembly, and the other by an Expert Panel created by the Virginia General Assembly. The
Pennsylvania study, which was produced by Penn State, concluded: "Land application of biosolids should be continued
because of the numerous benefits to the farming community."
It is strange that two states that have not requested or received delegation from EPA to handle sludge
permitting are two states that refuse to allow communities the rights to protect themselves from sludgicide.
Having one land grant university professor show up to speak for sludge victims is a miracle in courage.
The is one of the professors that EPA tied to get fired for writing "The Case for Caution" on sludge
biosolids. What Garvey actually means is that due to strict EPA regulations, land application of biosolids
should continue because otherwise these high quality biosolids would have to be placed in a highly
regulated landfill in which the Superfund act would apply.
The Virginia Expert Panel said that during its 18-month study it had "uncovered no evidence or literature verifying a
causal link between biosolids and illness." Membership on the Virginia panel included physicians, public health
educators, university researchers, sanitation professionals, environmental and public health officials, and private
citizens.
Actually, retired EPA employee Alan Rubin, who spent 21 years defending the Part 503 rule disagreed with
the report. Excerpt from Rubins statement was:
"I now have a significant concern about one aspect of a human health impact that land
application can have on certain pollutant sensitive individuals in communities hosting
biosolids land application projects. While I was employed at USEPA, I received and
reviewed hundreds of media reports as well as direct complaints from citizens who
claimed adverse human health impacts as well as "quality of life" (aesthetic) impacts
which they attributed to their exposure to biosolids as a consequence of residing in close
proximity to biosolids land application and biosolids storage sites. Follow up or
investigation of these complaints by USEPA Headquarters and/or regional permitting and
enforcement personnel were minimal and can be explained as follows. An analysis of
these reported incidences indicated that they were originating from a relatively small
number of States and even within these States, the reported incidences were confined to
a "few" communities in which a small portion of the community's population was involved.
USEPA judged complaints were being received from at most 100 communities either
generating biosolids and land applying in their communities or more likely from
communities that were hosting biosolids projects where non-local biosolids were being
land applied. Subsequently, USEPA made no determination on either the validity or
severity of the potential health consequences of these complaints. This was based on
USEPA's position that this issue was not a National issue but more of a locality by locality
site-specific issue that should be addressed more appropriately by either State or local
governments. Furthermore, the internal EPA position was that it was possible that the
land application of biosolids could generate a mixture of volatile substances (volatile
organic chemicals, bioaerosols, allergens, dusts, etc.) that could impact local populations
residing adjacent to land application sites either as a human health effect or as a
minimum a quality of life effect (odor, etc.) via an air transmission route. However, at the
time that the National Part 503 Standards for Biosolids were promulgated, USEPA did not
possess the means to scientifically evaluate this potential exposure pathway and
resultant human health impact and, therefore, was unable to add protective requirements
to the Part 503 Standards to resolve this issue. USEPA expected the States and local
jurisdictions to develop additional regulations to afford the needed protection for this
transmission pathway and these pollutant sensitive individuals."
"In a more personal case, I observed my two sons experiencing a feeling of "sickness"
when we visited a biosolids processing facility many years ago. Their reaction continued
for several hours after we left the facility."
These studies and other factual information can be seen at a new Web " site sponsored by the Pennsylvania Biosolids
Recycling Alliance at www.pabiosolids.com.
On the other hand you could get much more factual information about the sewage experts and their public
relations programs at www.thewatchers.us or www.deadlydeceit.com or www.sludgevictims.com or
www.sludgefacts.org or www.sludgenews.org or http://www.boostdam.
net/stories/Biosolids_TheProofofthePudding.html, or http://www.boostdam.net/sludge/ or
http://penweb.org/issues/sludge/
Finally, as an environmental engineer who has worked for decades to help protect our water, land and air, I think the
organizers of the March 10 event owe an apology to the thousands of water quality professionals who operate our
Pennsylvania treatment facilities. The implication that these dedicated professionals would produce and distribute a
product that would harm the public health and the environment borders on liable.
Actually, Gavey's associate, Philadelphia's Sludge Manager, William Toffey, accuses sludge victims of
having physiological problems so I don't think there is an apology due when they are lying to the public.
You have to admire Garvey's gall as an industry attack dog. She knows the biosolds rules are based on
exclusions in the environmental laws: 1) domestic sewage exclusion in the solid waste law RCRA for
hazardous waste in residential sewage pipes before it gets to the treatment plant; 2) the agricultural
stormwater runoff exclusion in the CWA: 3) the Superfund Act CERCLA exclusion for a normal application
of fertilizer; and 4) The preamble to Part 503 states, "Under CERCLA (Superfund Act) protection from liability
is also provided when there is a release of a CERCLA hazardous substance and the release occurs
pursuant to Federal authorization." Garvey really should read what the CERCLA hazardous substances are
since Part 503 states that if you are exposed to those in biosolid they will cause death, disease, cancer, etc.
Not many people know what happens to wastewater when it leaves their homes and work places. Little is known of the
dedicated water quality professionals who manage wastewater and protect public health and the environment. This
group of scientists, engineers, operators and technicians work quietly and efficiently every day to wipe out waterbom
diseases and create clean water for even the most sensitive aquatic species.
This is another area of concern. These water quality professions are in a bind. In 1982 EPA discovered
antibiotic resistant genes were being transferred between bacteria in treatment plants. 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 efficent, 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 fron the 80s. They appeared to be somewhat confused
because the bacteria taken out of the treated water were not detectable in sludge.
Since the sludgicide program began foodborne diseases have skyrocketed. from 2 million in 1986 to 76
million in 1999. The CDC quit keeping track after that.
These same water quality professionals have evaluated the alternatives for managing the residuals produced during
waste-water treatment. These residuals, once processed and analyzed, are called biosolids, and can be safely recycled
as a valuable fertilizer and soil conditioner for our Pennsylvania Farms.
The problem is that this residuals are not analyzed for chromium or pathogens or chemicals. The most
dramatic example is that there can be unlimited chromium (up to a 100,000 ppm) in biosolids, but there can
only be 600 ppm of chromium if it is biosolids disposed of in a part 503 landfill. The hazardous waste level
for chromium is 5 ppm. Cadmium, Mercury and Selenium are even less.
Diane Garvey is an environmental engineer and president of Garvey Resources, Inc. an environmental consulting
company based in Lansdale, Pa.
Jim Bynum is a retired safety consultant and VP of Help for Sewage Victims