Mega-Dumps -- Nuclear
The Proximity Hotel - Greensboro, NC
Nov. 16,17,18, 2007
Sponsored by: Center for Health and
Environmental Justice and Blue Ridge
Environmental Defense League
PRECAUTIONARY ACTION SHOULD BE MANDATORY
RECLAIMED WATER AND SLUDGE BIOSOLIDS FROM SEWAGE
The 1990's was the decade of EPA/WEF sludge biosolids 2000 PR Program to change public perception about the danger of
pollutant contaminated sludge. We can not speak of regulators because there are no enforcement and compliance
personnel involved in the program. But that is not all -- "the decade of the 1990's may be characterized as "the decade of
the microbe" with the emergence and re-emergence of infectious pathogens as a serious challenge to both food and
water safety. "PATRICIA L. MEINHARDT, MD, "Recognizing Waterborne Disease and The Health Effects of Water
The key question, which scientific, engineering and waste industry experts can not explain is why EPA/WEF claim a few
thermotolerant environmental (rather than enteric) E. coli growing at 112.1° F (44.5°C) in a fecal coliform test indicate proof
that there are no necrotizing (flesh eating) E. coli or any of the other 1,406 disease organisms (that does the most harm to
the human body), which grow at 98.6°F (37°C) or less) in reclaimed water and biosolids from sewage, as well as in food and
drinking water? They just don't appear to understand the problem.
In An Inconvenient True, Al Gore explains the problem when he quotes Upton Sinclair, "It is difficult to get a man to
understand something when his salary depends on not understanding it." Sludge biosolids is a major source of global
warming gases. Apparently, Gore didn't understand this when he was a young Senator from Tennessee opposing EPA's
proposed sludge regulation. In 1989, EPA's Hugh Kaufman said, "As a result of that proposed regulation, politicians
from all over the country started to pressure EPA -- a young senator, Al Gore from Tennessee, the head of the Environment
Protection Agency in New York City -- all of them implying and/or stating directly that they could not land apply their sludge if
EPA promulgated the regulations that were similar to the rest of the developed world."
The politicians won and EPA promulgated a regulation based on exclusions in the laws.. Eighteen years later, EPA still has
not assigned the first enforcement and compliance employee to the program.
by Jim Bynum
Retired Safety Consultant Revised 1/16/2008
Notes on why we need precautionary action on the effluents (reclaimed water and sludge
biosolids) from wastewater treatment plants. Before the conference, a tour of a local treatment
plant caused quite a shock. The waste industry is trying to convince sludge victims they suffer
from a psycho-somatic condition meaning its all in their mind, but they use the wrong word. As
shown in the following example.
The somatic disease outbreak in the Orange Water and Sewer Authority (OWASA) wastewater treatment
plant was completely unexpected and rather comical. Now, I don't think our host, Nancy Holt, intended to
cause the fear and panic when she arranged the treatment plant tour. Holt's mind works fairly well, but she
is trying to understand the brain damage that seems to have been caused by exposure to pathogenic
bacteria, viruses and chemical aerosols coming off a neighbors sludged fields which damaged her
somatic body cells.
The outbreak was a visible presence when plant management recognized, and realized, the highly vocal
Canadian sludge researcher Maureen Reilly had just toured the upgraded sewage treatment plant. Reilly is
the Chair of Sludge Watch Working Group and very concerned about how Multi resistant bacteria
develop in sewage treatment plants. Three sludge researchers in the plant at one time really
concerned management, who plan to start distributing bacterial contaminated sewage effluent in the
community as reclaimed water and makeup water for UNC chiller cooling towers.
Not a good idea, comments Chris Snyder of Master Engineers, Inc., who said, "I've seen enough trash laden
and scum [biofilm] covered cooling tower basins with potable water for their make-up water to think using
effluent is anything less than criminal." Furthermore, "every cooling tower owner that maintains one knows
that they are already “high maintenance” machines. (now they need to know if they need to don breathing
Dennis Opheim, Ph.D., Quinnipiac University, outlines the problem, "Biological control is the foundation of
cooling tower water treatment. Biofilm can directly cause corrosion problems (microbial induced corrosion,
MIC), pathogen concerns (Legionella), increased pump pressure, heat-transfer problems, dermatological
effects, and malodors. With the increasing restrictions being imposed at the federal and state level
regarding chemical use in cooling towers (CAA, CWA, OSHA, FIFRA), biological control has become much
According to Siemens Water Technologies, "Legionella pneumophila, the pathogenic bacterium
associated with a frequently fatal form of pneumonia known as Legionnaires’ disease, has been the subject
of numerous investigations since its isolation and identification in 1976. Although work is ongoing, a
correlation of health risk with Legionella counts in cooling water has been made1,2. Legionella
contaminated aerosols have been found to originate from a number of sources. These include cooling
towers, evaporative condensers, showerheads, whirlpool spas, hospital hot water systems, medical
respiration devices, decorative fountains, and grocery store misting machines."
While we are not dealing with rocket science, Duane L. Pierson, Ph.D., NASA/Johnson Space Center,
explains some of the pathogen problems we are dealing with. Pierson said, "Microbes' colonization of
inanimate surfaces and hardware of the spacecraft can also lead to biodeteriortion of critical life support
instrumentation and equipment, as well as the release of toxic volatiles. All of these are conditions
associated with an Earth problem commonly called "sick building syndrome" (SBS) or "building-related
illness" (BRS). Reducing risk to SBS requires monitoring both the habitation environment and the
occupants, such that the levels and types of microbes do not reach critical levels."
While the wastewater industry organization, Water Environment Federation and it's Foundation, (WEF-
WERF) claim exposure to pathogenic microbial contaminated sewage effluents (sludge biosolids and
reclaimed water) are safe since the 1994 public relations program to change public perception about the
danger, the wastewater industry is a very danger career field. In fact, before the name change to WEF, one
1987 Water Pollution Control Federation (WPCF) study noted, Sam "Hadeed reported that the wastewater
industry has retained its number one status as the most dangerous career field based on the results of the
1986 Annual WPCF Safety Survey."
There are studies to back up Hadeed's claim, such as, "Neurotoxic Effects of Solvent Exposure
on Sewage Treatment Workers" in the Archives of Environmental Health, July/August, 1988, 43, (4), pp.
263-68. They found after examining nineteen STWs (Sewage Treatment Workers) exposed to industrial
sewage that contained benzene, toluene, and other organic solvents at a primary sewage treatment plant in
New York City (Plant A). "that fourteen (74%) complained of central nervous system (CNS) symptoms
consistent with solvent exposure, including lightheadedness, fatigue, increased sleep requirement, and
In Epidemiological Studies of Neurotoxic, Reproductive, and Carcinogenic Effects of Complex
Mixtures, Carl M. Shy, UNC, September 1990-September 1992, states, Epidemiological studies of cancer
risks per se are practically infeasible in these environments due to inadequate populations at risk,
undefined exposures, and short time since first exposure. However, it is feasible to study the biological
uptake of some of the associated compounds in these populations."
In a 1985 Cornell Study, J.G.Babish said, "A recent study (63) indicated that rats consuming cabbage
and beets grown on sludge^amended soil produced urine which was mutagenic to TA98 in the presence /
of a metabolic activating system. Thus, it seems possible for the mutagenic components of sludge to be
transported through the crops grown on it." Furthermore, "fifteen to thirty minutes after dosing, the Boston
sludge-treated animals began to show signs of effects on the central nervous system." Of the animals who
died, "No gross lesions were observed in any animals which could be associated with the test materials. "
"Over all, this study demonstrates that an organic extract of municipal sewage sludge can be extremely
toxic." "Moreover, the absence of information concerning the organic constituents of municipal sewage
sludges must not be equated with low risk or safety. Under conditions of minimal data, maximal risk must be
assumed in order to protect public health."
Actually, farming, especially when sludge biosolids and reclaimed water is involved is the most dangerous
career. Federal and state regulators, and their partners lie to the farmers about the safety of sewage
effluents. So far they have gotten away with lying to the farmers because they are already at risk for
respiratory distress syndrome, one of the first and most unrecognized symptoms of aerosol exposure. U.S.
experts call the disease Organic toxic dust syndrome or Pulmonary Fibrosis? Canadian experts calls it
"extrinsic allergic alveolitis".= Sewage Sludge Disease www.ccohs.ca/oshanswers/diseases/alveolitis.
While Australian experts also calls it extrinsic allergic alveolitis" which may be caused by sewage sludge
contaminated with micro-organisms. www.rma.gov.au/SOP/97/057.pdf
Not all sewage effluent released into surface waters or as sewage sludge given away or sold as a biosolids
fertilizer are created equal. Basically, there are three levels of sewage treatment plants: Primary;
Secondary; and, Tertiary (a third treatment step is added for sewage effluent, such as chemical
precipitation, which cause solids to settles out into sludge). Even multi-million dollar treatment plants are
very inefficient and don't work very well. As an example, lets look at 177,000 gallons of Burlington, NC lime
stabilized sludge at 3.27 percent biosolids delivered to one 14 acre farm. The 177,000 gallons of sewage
effluent weighed 743 tons, yet, there were only 24 tons of biosolids. To dispose of this 24 tons of biosolids
dumped on the 14 acre farm, Burlington had to use 295 18 wheel tankers which only carried 162 pounds of
biosolids in each 6,000 gallon (25 ton) truck load. Using an 18 wheel tank truck to deliver 162 pounds of
fertilizer would make no sense at all. But, let's compare that to Burlington's aerobic digested sludge which is
only 2.03 percent biosolids. There would be only 15 tons of biosolids in the 743 tons of biosolids
contaminated liquid sewage effluent. The 295 18 wheel tankers would only be carrying 101 pounds of
biosolids in each 6,000 gallon (25 ton) truck load. For some strange reason North Carolina regulators
believe that extra 719 -- 728 tons of biosolids pathogen contaminated liquid sewage effluent will not run
down hill to the nearest creek when its disposed of on a 10% slope.
Bacteria are the work horses that break down some of the biosolids material, then they create biofilms, or
slime, that binds most of the remaining biosolids together as sludge. As we noted in Deadly Deceit (1998)
scientists found that the bacteria exposed with current testing procedures are those on the outside of the
biofilm. EPA's microbiologist David Lewis found that ultrasound would break up the biofilm and release the
encapsulated bacteria in the biofilm aggregate.
In Reilly's January 29, 2005 SludgeWatch post, the author states, "As bacteria wind their way through
these treatment processes, the selective pressures against them increase. In consequence, there is a
greater effort by bacteria to pass on survival enhancing genetic information. Additionally, as the
environmental stresses increase, the bacteria up-regulate numerous other survival mechanisms to assure
that they and their genetic material survive. These can include chlorine resistance."
Public exposure to deadly disease causing organisms have been a major concern since the Drinking Cup
Study in 1907 when one in five deaths was caused by these organisms; The drugtolerant micrococci dental
student study of 1960; and; The Raleigh, North Carolina Public Health Services study of Staphlococcus and
Micrococcus on skin tissue in 1971 (published 1975). Raleigh has a long history of sludge disposal
problems including groundwater contamination. The public health exposure concerns all changed in 1989
when the wastewater industry started spreading pathogen contaminated water and sludge sewage effluents
with multidrug antibiotic resistant disease organisms on our food crops, parks, school grounds and lawns.
In one study, EPA's David Lewis discovered that staphlococcus found on people living near sludge disposal
sites in 2002 had become multidrug resistant. Human health problems (as well as animal and marine life)
reported associated with sewage effluents (includes biosolids) have included: abscesses, asthma, coughs,
cysts, eye irritation, flu-like symptoms, gastrointestinal complications, headaches, immunodeficiency
problems, lesions, flesh eating MRSA, nausea, neurotoxcity, nosebleeds, rashes, respiratory
complications, reproductive complications, tumors, necrotizing soft tissue infections, weight loss, and
The medical profession did/does not seem to be aware of this practice of spreading pathogen
contaminated reclaimed water and biosolid sewage effluents in the public environment. How do doctors
explain this to patients as multiple pandemics spread across the country. According to a December 24,
2007 Newsweek article by Mary Carmichael (a doctor's wife), doctors "don't always know whats wrong with
the patient or what to do in response. They grapple with uncertainty. Increasingly, they are sharing that fact
with their patients,"
According to PATRICIA L. MEINHARDT, MD, "Recognizing Waterborne Disease and The Health
Effects of Water Pollution", "the decade of the 1990's may be characterized as "the decade of the
microbe" with the emergence and re-emergence of infectious pathogens as a serious challenge to both
food and water safety. This "new" microbial era presents many formidable tasks to those responsible for
water safety as well as healthcare practitioners who may be unaware or unfamiliar with the growing list of
potential waterborne pathogens to consider when evaluating their patients. In addition, healthcare
practitioners must have heightened awareness that these waterborne microbial exposures may lead to
serious morbidity and mortality for susceptible populations in their clinical practice who are more vulnerable
to waterborne disease."
The North Carolina Occupational, Environmental and Epidemiology Branch of the Health
Department prepared a report on the potential dangers of sludge biosolids use with additional safe guards
above those mentioned in part 503. Dr. Rudo lists 39 cancer causing chemicals found in sludge biosolids
including arsenic, cadmium, lead and nickel. It would appear Dr. Rudo found documentation the biosolids
expert scientists and regulators just couldn't find --- even though some of the documents were written by the
biosolids expert scientists. What is worse is that EPA admitted in 1995 that it did not do a risk cancer
assessment for chemicals (includes metals), yet, stated, EPA's less conservative 1 in 10,000, instead
of 1 in a 1,000,000, risk assessment for cancer was used because "the 1 in 10,000 risk level reduces the
regulatory impact of the rule allowing the Agency to regulate the use and disposal of sewage sludge without
needlessly burdening the regulated community or negatively impacting beneficial reuse." (58 FR p. 9281)
Douglas Campbell, Head of the Agency, sent the report on to appropriate departments in January of
2005. Yet, none of the recommendations in "That Damn Report" have received any action.
Attending the Precautionary Action Conference after touring the OWASA wastewater treatment plant was
somewhat anticlimactic. The major question facing the Conference participants was: How do we, the public,
get the regulators and waste industry to take a precautionary approach in the disposal of chemical,
pathogen and radioactive contaminated waste to protect public health and the environment?
Participant, Dr. Ellen Harrison, Director of Cornell Waste Management Institute, has studied the sludge
biosolids problem for years. Due to the lack of information on contaminants in sludge, the lack of
regulations addressing those contaminants, and the victims with health problems associated with
sludge biosolids disposal sites, Harrison recommends banning all use of sludge biosolids as fertilizer or
soil amendments because. "No substantial health related investigations were conducted by federal, state, or
local officials. A system for tracking and investigation is needed. Analysis of the limited data suggests that
surface-applied Class B sludges present the greatest risk and should be eliminated. However, even under
less risky application scenarios, the potential for off-site movement of chemicals, pathogens, and biological
agents suggests that their use should be eliminated."
Participant, Dr. Caroline Snyder, Chair, Citizens for Sludge-Free Land agrees. Snyder says, "Serious
illnesses, including deaths, and adverse environmental impacts have been linked to land application of
sewage sludge. EPA and the wastewater treatment industry have worked with Congress to fund
wastewater trade associations to promote land application, supporting industry-friendly scientists and
discouraging independent research, to prevent local governments from restricting land application and to
thwart litigation against municipalities and the industry."
This writer has been slightly biased toward banning sludge use. The New Mexico Environmental
Department publish a paper I wrote in February 1993 in which I stated, "This paper examines the
Environmental Protection Agency's (EPA) policy of sanctioning the beneficial use of sewage sludge on
farmland as a cheap fertilizer and soil conditioner in light of recent revelations of human and animal health
problems associated with the use of sludge. Some environmental organizations and scientists are
concerned with its deleterious effects on public health. The paper looks at the existence, nature and
causality of the illnesses and fatalities that can arise from the use and disposal of sewage sludge under
current EPA guidelines." That was written before EPA's James Ryan and USDA's Rufus Chaney gutted
the few safety provisions which had been included in the 1989 proposed part 503.
It is worse than I could have imagine in 1993, Pandemics are now raging through the United states. A
major pandemic is foodborne illnesses/poisoning. In 1998, CDC's Dr. Patricia Griffin, Chief of the
Foodbourne Diseases Epidemiology Section of CDC’s Foodborne and Diarrheal Branch, said, "A recent
annual estimate of acute diarrhea from FoodNet data, indicates a reported 360 million cases. In most of
these cases, the cause (food, water, other) is unknown." EPA started tracking foodborne illnesses in
1986 when there was only two million cases. The CDC quit tracking foodborne illnesses in 1999 after the
GAO estimated numbers exceeded 81 million cases annually. CDC settled on an estimate of 76 million
foodborne illnesses in 1999 and it is still sticking to those same numbers today. Today, CDC has the public
focusing on the much smaller number of E. coli 0157:H7 cases. According to the literature, this dangerous
E. coli strain does not show up in either FDA's coliform test for E. coli that grow at 98.6 degree
Fahrenheit or EPA's thermotolerant fecal coliform test for an environmental E. coli that grow at 112.1
Wastewater treatment experts appear to have no knowledge concerning the nature of a coliform or fecal
coliform or why they test for an environmental strain of E. coli that grows at a very high temperature rather
than testing for pathogens that grow at body temperature. Our treatment plants don't work very well, our
water ways are contaminated with chemicals and pathogens, and because of this, as the wastewater
industry claims, we are already drinking recycled sewage water. That may explain the pandemics raging
through this Country, but it doesn't explain why the industry wants to contaminated the rest of our drinking
water supply with this recycled sewage water or why they want to expose the public in general to the
contaminated recycled sewage water on lawns and school grounds.
As demonstrated in the Conference, the environmental laws no longer work to protect public health and the
environment. Federal and state employees promote the dumping of chemical, pathogen and radioactive
contaminated waste as close to the public as they can get it. This program is based on the EPA Office of
Water's part 503 policy and the fact that EPA Office of Enforcement and Compliance has refused to get
involved with the its con game. "The [EPA] OIG says, "As can be seen from the table (in the report), the
Office of Water provides the majority of the Headquarters FTEs (4) [full time employees] managing the
biosolids program, while the Office of Enforcement and Compliance Assurance (OECA) provides none,
even though it has program responsibilities. As we explained in our prior report, that office has disinvested
from the biosolids program." In other words, OECA leaders want to keep their hands clean."
There is no science or conscious involved. Congress has given EPA employees qualified immunity to put
your life in danger based on their discretionary authority decisions.
Attorney participants at the Conference, F. Edwin Hallman, Jr and Chris Nidel, confirmed that the courts are
biased against the victims and that EPA employees have conspired with some scientists to fund studies
using false information to "prove" sludge biosolids are safe for use on our food crops and for public
contact. THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA (CASE NO.
3:06-CV-16(CDL) has ruled that EPA's qualified immunity does not cover John Walker and Robert Brobst
setting up fake studies using government funds. Walker, as we will show, knew pathogenic contaminated
sludge biosolids was dangerous for public health in 1973.
A complete disregard for public safety and truth is OK. It has been EPA's Office of Water position that it
does not have the data to determine the safety of most chemicals and pathogens found in sludge-biosolids
and for that reason no cancer risk assessment for metals, chemicals or pathogens was ever done..
Therefore, EPA relies on public tax funded scientific studies which are used against victims suffering health
problems. When EPA is forced to directly address the safety of sludge-biosolids, as EPA's William Sanjour
noted in 1989, the Con Game response is that sludge is safe if all federal laws and regulations are
followed. As noted, part 503 reflects EPA policy rather than the laws and regulations that address the
disposal of toxic/hazardous chemical waste and public health.
Yet, in 1993, EPA funded a public relations study by Jody Powell and Sheila Tate for the Water Environment
Federation (WEF) to be used to change the public's perception about sludge. John Stauber and Sheldon
Rampton exposed this scheme in their 1995 book Toxic Sludge is Good for You. The story can be found
at PR Watch. Because of the PR study, the name was changed to biosolids to fool us country folks.
Government funded PR and not health is the motivating force behind the promotion of sludge as
biosolids and sewage effluent as reclaimed water recycling.
By federal law (RCRA), biosolids is simply sewage sludge which must be disposed of in a sanitary landfill.
Until 1991, when EPA created the municipal co-disposal landfill regulation Part 258 under the Resource
Conservation and Recovery Act (RCRA) and Clean Water Act (CWA), sludge was regulated as a solid
waste. EPA admitted in the preamble that it did not have the data to do a risk assessment for co-disposal
landfills and put that requirement for 62 chemicals on the individual states, who had even less people and
less data. Under Part 258.3 The owner or operator of a municipal solid waste landfill unit must comply with
any other applicable Federal rules, laws, regulations, or other requirements. That is not true with part 503.
According to Phil Loar, Water Pollution Control Bureau, Arlington, Va., who attended the Conference, EPA
will only allow 20 percent sludge-biosolids in a municipal co-disposal landfill. It would appear EPA has set
out to force municipalities to find another method of disposal -- which just happens to be available under
EPA's policy regulation Part 503 where there was no risk assessment for chemicals or pathogens, even
though EPA has betrayed us and spent millions of dollars pretending to do a risk assessment backed up by
the best scientists it could buy. Part 503 is unique in that there is no provision requiring compliance with
federal law. In fact, part 503.4 states, "Disposal of sewage sludge in a municipal solid waste landfill unit, as
defined in 40 CFR 258.2, that complies with the requirements in 40 CFR part 258 constitutes compliance
with section 405(d) of the CWA." Whoops, looks like someone exposed EPA's Con Game and modified part
503 and it wasn't caught by Rubin and Walker before they retired.
What was most troubling about Mr. Loar, as well as the waste water employees and industry is that they
can not tell you what the EPA's coliform or fecal coliform tests reveals. The tests only reveal gram
negative bacterial pathogens. Yet, these tests are held up as the gold standard for proving sludge-biosolids
and reclaimed water sewage effluent is safe. E. coli is one of the coliform group and a thermotolerant
environmental form of E. coli is the primary fecal coliform that grow at a higher test temperature than the
coliform group. It too is becoming pathogenic.
According to Arlington Wastewater website, "The plant’s overall mission is to protect and preserve the
environment -- especially the Chesapeake Bay --" Hey, what about the health of people exposed to the
pathogenic disease organisms?
Arlington purchases polymer to mix with low biosolids content (about 3%) sludge to increase the solids
content to 23-28 percent. Basically, the polymer soaks up the water to make sludge look more solid than it
is. Then Arlington puts lime in the mix to raise the pH to 12. At that point, any chromium 3 in the sludge is
converted to the carcinogenic Chromium 6, which is readily taken up by crops. Chromium was removed from
part 503 when it was pointed out to EPA that the allowable 3,000 ppm in 503.13 for beneficial use was five
times high than could be disposed of in a part 503.23 regulated surface disposal site which requires a real
honest to God permit. Walker lied when he said the court ordered chromium removed from the regulation.
While lime and pH 12 temperatures do inactivate some bacteria for a short time, USDA researcher, John
Walker, who later went to work for EPA, reported to EPA's R.B Dean and James Smith, Jr., in a 1973
sludge conference, that inactivation of Salmonella only lasted about 30 days and then there was regrowth
of bacteria. EPA's R. B. Dean " then acknowledged that this was found very frequently and that a stabilized
limed sludge, if stored too long, would also putrefy." Can you imagine, EPA and the waste industry lying to
us about bacteria being destroyed for the past 35 years -- and getting away with it? Victims can testify that
the smell off bacterial putrefied sludge-biosolids sites are horrible.
Arlington also claims there are only "small amounts of trace metals and organic compounds" in its Class B
biosolids. However, it fails to note that Class B sludge-biosolids may contain up to two million fecal
coliform per gram of sludge biosolids (1 gram = 0.035 273 962 ounce). The "non-pathogenic" fecal
coliform they look for in the test is a environmental thermotolerant E. coli growing at 112.1 degree F.
Unfortunately, studies now confirm that many environmental bacteria are picking up the thermotolerant traits
and have become human disease causing organisms.
Federal and state waste disposal permitting employees say not to worry, these are opportunistic pathogens
which primarily infect people with compromised immune systems. This explains why only a few people may
be affected near each disposal site in this new game of Russian Roulette. Federal and state employees
hold the gun to your head, spin the cylinder holding the bullet, and pull the trigger. If your immune system is
good, the gun doesn't fire. If your immune system is compromised and the gun fires, its not their fault and it
may be hours, days, months or even years before you know the bullet has hit you. Then, it must just be
your imagination that you have become a victim of this con game?
Closer to the Conference is the Orange Water and Sewer Authority (OWASA) wastewater treatment plant
we toured. It serves the University of North Carolina at Chapel Hill. According to the literature, OWASA is
using treatment technology that has never been totally effective against the tougher microbes and in the
process it also creates antibiotic resistant pathogenic microbial organisms. Treatment plants were not
designed to remove 100 percent of the solids, and much less for the pollutants.
Another problem has been pointed out by retired wastewater engineer Peter Maier. He said "It was
estimated that after EPA allowed the inhibited BOD test( the same BOD test, except with a certain chemical
added to kill selectively only the autotrophic bacteria (nitrifiers)) 60% of all the sewage treatment plants out
of compliance got into compliance by adding this few cents of chemicals to the test. By doing so, EPA
lowered the goal of the Clean Water Act from elimination (100% treatment) to a measly 85% of 40% = 35 %
treatment and ignored all the pollution caused by nitrogenous (urine and part of the protein) waste. EPA
did lower the goals without even informing the Congress."
According to OWASA, the treated wastewater effluent discharged to the creek is disinfected with ultraviolet
light. "In addition, reclaimed water made available for non-drinking purposes will be further disinfected with
chlorine." That statement admits ultraviolet light does not work very well, which is why our waters are so
contaminated, but it is supposed to make you feel better even if it's just another PR statement.
Reclaimed sewage water for non-drinking purposes was used in Salinas Valley on lettuce and spinach.
E. coli was spread across the country. Retired government soil scientist Frank Pecarich warns, "To
begin, let’s remember that E. coli 0157:H7 is one of the disease and death causing pathogens that can
survive and pass successfully through sewage treatment plants and “escape” into the natural environment.
Secondly, these pathogens are incredibly hardy in the environment and have successfully lived for weeks
and months on vegetation, soil surfaces and in water." Frank said, "I have written repeatedly and
voluminously about the obvious smoking gun that exists by having 12,000 acres of vegetables – including
leafy greens – overhead sprinkler irrigated with tertiary treated sewage water. I have gained the attention of
food safety experts all over the nation who correspond with me and offer encouragement on keeping this
information about pathogens in irrigation water in the foreground of our discussions. At the same time,
virtually all of these experts have requested anonymity should their employers and financial benefactors
become angry that they were consorting with someone who might reveal the secrets."
Dr. Edo McGowan points out another major health risk. He said, "Missing in this discussion is the transfer of
genetic information ----two types---one for antibiotic resistance and the other for enhanced virulence. Then
on top of that is the genetic material supplied by phages---abundant in sewage. The Panton-Valentine
Leukocidin of MRSA's necrotizing pneumonia is an example. As Amy Pruden has amply demonstrated
the genetic material is not affected by chlorine at levels used in either waste or drinking water treatment nor
many of the filtering systems. Thus there are large holes in these processes where pathogens can get
through." MRSA Staph has also become pandemic since EPA's sludge biosolids program started..
It makes it tough when the medical profession can not depend on scientific studies. A case in point,
recently, (Nov-2007) a National Institute of Health (NIH) press release stated, "Up until a year ago, most
scientists studying S. aureus believed they had narrowed their search for the cause of severe CA-MRSA
infections, focusing on the Panton-Valentine leukocidin (PVL) toxin produced by certain strains. But then
last year, Dr. Otto and his RML colleagues published a study indicating that PVL does not play a major role
in CA-MRSA infections." (http://www3.niaid.nih.gov/news/newsreleases/2006/staphtoxin.htm).
Now, NIH states, "Newly described proteins in drug-resistant strains of the Staphylococcus aureus bacterium
attract and then destroy protective human white blood cells—a key process ensuring that S. aureus
survives and causes severe disease, according to scientists at the National Institute of Allergy and
Infectious Diseases (NIAID), part of the National Institutes of Health."
It is clear, we are now in the process of developing the scientific technology to understand the
environmental and economic damage the wastewater industry has caused in the last 35 years. By polluting
our surface water, and some groundwater, they have allowed endocrine disruptors to get into our drinking
water and the effects are showing up in our children and grandchildren. Here is what EPA had to say about
endocrine disruptors 10 years ago in the 1998 paper, Developmental Neurotoxicology of Endocrine
Disruptors and Pesticides: Identification of Information Gaps and Research Needs.
EPA's Hugh A. Tilson, said,
"It has been estimated that 70% of developmental defects have no known cause and that
some of these defects may be related to chemical exposure acting alone or in combination with
genetic or nutritional factors (1). It is now generally accepted that developmental exposure to
chemicals can have adverse effects on the structure or function of the nervous system.
Possible functional defects in neurodevelopment include severe and mild mental retardation,
cerebral palsy, psychoses, epilepsy, abnormal neurologic development or disrupted
maturational milestones, cognitive deficits, andlor sensory dysfunction (2)."
"As mentioned previously, it is generally accepted that disruption of endocrine function could
have a number of neurodevelopmental effects, including altered reproductive behaviors
mediated by the hypothalamic-pituitary axis, hypothalamically mediated body metabolism,
sexual differentiation in brain morphology, and cognitive and psychomotor development.
Sexual and brain development are under the influence of estrogenic and androgenic hormones
and chemicals that interfere with these hormones during development can adversely affect
neurodevelopment. Thyroid hormones also play an important role in the development of the
nervous system, and chemical-induced alterations of thyroid function during development can
produce developmental neurotoxicity (15). Moderate to severe alterations in thyroid hormone
concentrations during development result in motor dysfunction, cognitive deficits, and other
neurologic abnormalities. In addition, recent research (18) suggests that developmental
hypothyroidism in rats can cause permanent ototoxicity."
"There are several chemicals or classes of chemicals that could cause neurodevelopmental
alterations by interfering with neuroendocrine function, including polychlorinated biphenyls,
dioxin, and chlorinated pesticides, some metals (e.g., methylmercury, lead, organotins), insect
growth regulators, dithiocarbamates, synthetic steroids, tamoxifen, phytoestrogens, and
triazine herbicides (13,14). Research is needed to determine if other chemicals or classes of
chemicals affect neurodevelopmental processes by disrupting endocrine function during
development. Any compounds that mimic or antagonize the actions of neurotransmitters,
hormones, and growth factors in the developing brain have the potential to adversely affect
Of course the waste industry promoters just ignores the scientific studies anyway -- even if they do them.
The wastewater experts don't even want to mention the really tough bacteria such as "Bacteria of the genus
Deinococcus [which] are extremely resistant to ionizing radiation (IR), ultraviolet light (UV) and desiccation."
The bacteria will survive radiation doses thousands of times those that kill other pathogens or humans.
E. coli has been used to clone many of its gene expressions and Deinococcus was first reported found in
the human stomach 2006. However, it was associated with meningitis as early as 1991. It is one of the
pyogenic bacterial that makes pus. Deinococcus was formally known as Micrococcus radiodurans, a source
of blood stream infections. In 1935 it was reported, "The mortality rate judged from 44 cases of
septicemia in which the outcome is stated is 50 per cent." Changing the name from Micrococcus to
Deinococcus does not make it safer, just as changing the name of sludge to biosolids does not make it
In 1982, EPA's Mark Meckes' study on UV light reported surviving bacteria were even more deadly after
ultraviolet (UV) treatment. He said, "Total coliforms and total coliforms resistant to streptomycin, tetracycline,
or chloramphenicol were isolated from filtered activated sludge effluents before and after UV light
irradiation. Although the UV irradiation effectively disinfected the wastewater effluent, the percentage of the
total surviving coliform population resistant to tetracycline or chloramphenicol was significantly higher than
the percentage of the total coliform population resistant to those antibiotics before UV irradiation."
Effective disinfection only means the effluent met the EPA requirements for discharging effluent to a moving
body of water in 1982 where it would be diluted to meet the recreational water standards. Even there, the
surviving antibiotic bacteria double about every 20 minutes.
In a 2005 study, James D. Oliver, et.al, University of North Carolina (Charlotte), reported that
chlorine caused the bacteria to enter a viable but nonculturable state. They said, "We examined the effects
of chlorine disinfection on Escherichia coli and Salmonella typhimurium in secondary-treated wastewater to
determine whether such treatment might induce these bacteria into the viable but nonculturable (VBNC)
state. In this state, cells lose culturability but retain viability and the potential to revert to the metabolically
active and infectious state. To examine the effects of chlorination on cells in different physiological
states, cells from the logarithmic and stationary phases, or nutrient starved, or grown in natural wastewater,
were studied. Isogenic cells with and without plasmids were also examined. Whereas a mixture of free and
combined chlorine, as occurs under typical wastewater disinfection, was found to be rapidly lethal to most
cells, regardless of their physiological state or plasmid content, c. 104 of the original 106 cells-ml-1 did
survive in the VBNC state."
Can you imagine, only two cells out of 106 actually died? As the studies continue to point out, those little
germs that survive the treatment processes come out lean and meaner than a junk yard dog.
In spite of the first hand knowledge as well as the studies showing deadly bacteria survive the treatment
process, in a November 9, 2007 press release OWASA announced it had received authority to start
distributing reclaimed water (sewage effluent) for:
- irrigation of public and private landscapes and turf;
- street sweeping (but not street cleaning [?]);
- soil compaction and dust suppression;
- industrial purposes such as cooling tower make-up water, or concrete mixing;
- vehicle washing at government-owned facilities (no steam cleaning, engine or parts washing);
- sewer cleaning by OWASA personnel or OWASA authorized contractors; and
- fire fighting and fire suppression
However, before they can dispose of the effluent in public places, training is required because the
reclaimed water is dangerous. "OWASA will begin allowing tank trucks to be filled as soon as the first
training session for haulers has been completed," "OWASA encourages reclaimed water haulers to inform
the community that they can provide reclaimed water to the general public for purposes allowed under the
State rules." There is nothing in the literature that says kids can not play in the pathogen contaminated
water or on the area where it is disposed.
Lord help the students at the University of North Carolina because they will be exposed to this
pathogen contaminated water first on the grounds and Athletic Fields. Then the contaminated water will be
used in the four main campus chiller cooling towers and after that, the University hospital chiller cooling
tower -- as soon as the 11 million dollar reclaimed water purple piping system is in place. "in Spain in
2001, a hospital cooling tower caused 449 cases of the disease [LEGIONELLA] and killed 2" USING
DRINKING WATER. This is another case of "Waste regulators push[ing] sewage on unsuspecting public
using bad science and a grin"
Just in time, a December 20, 2007 WERF press release states that "The Water Environment Research
Foundation (WERF) has completed the first phase of research designed to provide a protocol for
responding to reports of symptoms of illness by neighbors of sites where soil amendments, including
biosolids, animal manures, food residuals, septage, and compost are applied to land. "Steve Wing, Ph.D
UNC, was the principal author of the protocol, "Epidemiologic Surveillance and Investigation of Symptoms of
Illness Reported by Neighbors of Biosolids Land Application Sites." It has taken EPA/WERF five years to
develop the protocol on what questions to ask, and they claim it is yet to be tested to see if it will provide
useful information. Perhaps, the same protocol can be used to investigate UNC student and employee
symptoms of illness that will be reported from exposure to reclaimed sewage effluents used on the grounds
and in school and hospital cooling towers.
Winn, WC Jr, 1988, reported, "Legionellaceae have been established as important causes of respiratory
disease. The sources of the infecting bacteria are environmental, and geographic variation in the frequency
of infection has been documented. Airborne dissemination of bacteria from cooling towers and evaporative
condensers has been responsible for some epidemics, but potable water systems are perhaps more
Sharon G. Berk, et.al, found,"Two Acanthamoeba species, fed at three temperatures, expelled vesicles
containing living Legionella pneumophila cells. Vesicles ranged from 2.1 to 6.4 μm in diameter and
theoretically could contain several hundred bacteria. Viable L. pneumophila cells were observed within
vesicles which had been exposed to two cooling tower biocides for 24 h. Clusters of bacteria in vesicles
were not dispersed by freeze-thawing and sonication. Such vesicles may be agents for the transmission of
legionellosis associated with cooling towers, and the risk may be underestimated by plate count methods."
"Rowbotham (11) hypothesized that the inhalation of vesicles of tightly packed legionellae is dangerous
when the particles are of respirable size (1 to 5 μm in diameter) and contain motile bacteria. He stated that
such a particle, protected by a membrane, may reach the alveoli of the lungs and contain an infectious
dose of legionellae."
Since 1982, multi-drug resistant bacteria infections have become epidemic and EPA has placed additional
restrictions on discharging contaminated effluent to surface water. California will not allow many treatment
plants to discharge effluent to streams in the dry season. EPA explains the wastewater treatment plants
problem this way, "The investment in treatment technologies required to meet restrictive discharge limits
has lead an increasing number of industries and communities to consider other uses for their treated
wastewater effluents --" http://www.epa.gov/ORD/NRMRL/pubs/625r04108/625r04108.pdf
EPA has given the industries and communities a way out. With reclaimed water they don't have to do a lot of
testing and they may only have to post a small warning sign to prevent public exposure. How many children
will understand what non-potable water means? I have personally seen children playing in water from a
posted non-potable water faucet in a Virginia state park.
Experts will tell you the fecal coliform test for environmental thermotolerant E. coli at 14 colony forming units
per 100 mililiter-miligram assures the safety of reclaimed water, because, this E. coli is not a pathogen - well
-- except for the 9 types of virulent toxic producing E.coli; and except as FDA puts it, "Although
most strains of E. coli are not regarded as pathogens, they can be opportunistic pathogens that
cause infections in immunocompromised hosts."
These mutant strains of thermotolerant bacteria were first publicly reported in Biocycle, June of 1996,
"There is some evidence that coliforms and Salmonella sp. [salmonella is a coliform] can survive prolonged
exposure to temperatures of 55 C." 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)".
Eleven years later EPA and the waste industry still doesn't understand the problems. The detection limit is
based on culturable bacteria and does not take into account the heat stressed viable, but nonculturable
bacteria. On the other hand, EPA still says, "503.32(a)(ii)(A) When the percent solids of the sewage sludge
is seven percent or higher, the temperature of the sewage sludge shall be 50 degrees Celsius or higher;
the time period shall be 20 minutes or longer;"
Wastewater industry studies indicate that after 40 years of research they know little about microbiology.
Bacteria become inactive due to lack of food or stress. The stress is indicated in the Material Safety Data
Sheets for Escherichia coli and Salmonella which states, PHYSICAL INACTIVATION: Inactivated by moist
heat (121° C for at least 15 min (249.8 degree Fahrenheit)) and dry heat 160-170° C for at least 1 hour
( 320-338 degree Fahrenheit). Remember, EPA's test for E.coli is done at 112.1 degrees F. That is less
than half the lowest heat to inactivate E. coli in the laboratory.
"In May 2006, University of Minnesota researchers published data showing that extremely high
numbers of multi-drug resistant bacteria in effluent (treated water) at high levels are being released into
the environment from highly efficient, award winning, sewage wastewater treatment plants."
A tour of the OWASA treatment plant was provided by wastewater specialist, Walter Gottschalk. According
to the OWASA website, Gottschalk is the Biosolids Recycling Manager. This was an opportunity to get a
few questions answered by an expert.
One of the first questions I ask Gottschalk was; did OWASA use biosolids and reclaimed water on the plants
lawn and trees? The answer was no, they do not have a permit to use biosolids and reclaimed water. In
effect, if sludge or reclaimed water is used on the grounds -- it would be a sewage spill.
The second question I ask Gottschalk was; what kind of bacteria are used in the secondary biological
treatment system? The answer, "the same kind of bacteria found in the creek." I didn't have the heart to ask
if that was after sewage effluent was released into the creek?
The same question was put to Gottschalk when we got to the anaerobic digesters. He mentioned the
Actinomycetes species for increased methanogenesis and the Methanogens bacteria which produce
methane gas. Gottschalk neglected to mention that the facultative aerobic bacteria transferred from the
secondary biological treatment tanks become anaerobic after entering the digester.
"Most of the bacteria that absorb the organic material in a wastewater treatment system are facultative in
nature. This means they are adaptable to survive and multiply in either anaerobic or aerobic conditions.
The nature of individual bacteria is dependent upon the environment in which they live. Usually, facultative
bacteria will be anaerobic unless there is some type of mechanical or biochemical process used to add
oxygen to the wastewater. When bacteria are in the process of being transferred from one environment to
the other, the metamorphosis from anaerobic to aerobic state (and vice versa) takes place within a couple
of hours." It would appear this is the time period when samples are pulled for testing.
No one in the waste industry seems to want to talk about the full list of facultative bacteria in sludge
biosolids and effluent. In any study or article, only a few will be mentioned.
As an examples:
"Facultative anaerobic bacteria are the Staphylococci (Gram positive), Corynebacterium (Gram
positive), and Listeria (Gram positive). Organisms in the Kingdom Fungi can also be facultative anaerobic,
such as yeasts."
Facultative bacteria are those that can grow with or without oxygen. Unfortunately, most of the bacteria
implicated in foodborne illness are facultative in varying degrees. Salmonella, Shigella, Staphylococcus
aureus, and Bacillus cereus are generally considered to be facultative bacteria.
For complete list of aerobic and facilitative bacteria click here
For a growing list of bacteria and the diseases they cause click here
The secondary biological foaming going to the digester was worrisome. According to M. Fiorella de los
Reyes et.al.,1998, "Previous studies have shown the predominance of mycolic acid-containing filamentous
actinomycetes (mycolata) in foam layers in activated sludge systems. Gordona (formerly Nocardia)
amarae often is considered the major representative of this group in activated sludge foam."
According to C. Sundaram, Indian J Pathol Microbiol. 2006 Jul ;49 (3):317-26 17001876, "Brain abscess
continues to be a serious medical problem with increasing incidence despite advances in diagnostic and
surgical methods, and advent of new antibiotics. This is due to increase in immune suppressed individuals,
opportunistic pathogens and resistance to antibiotics." The Actinobacteria and nocardia bacteria are soil-
inhabiting microorganisms that now cause brain and other organ abscesses in humans.
A little research found foaming worried the engineers as well. Neil Massart, process engineer for the
engineering firm of Black & Veatch, states, "Excessive foaming is a serious problem that seems to be
becoming more prevalent among anaerobic digesters throughout North America. Researchers attribute
increased foaming to the rise in advanced biological treatment processes and corresponding changes in
the quantity and characteristics of waste activated sludge (WAS). He said a little foam is not bad but,
"Excessive foam, on the other hand, escapes the digester and plugs the gas-piping system." Without proper
training and personal protective equipment this puts the treatment plant employees' health, who have to
clean up the mess, in jeopardy.
Massart said, "Filamentous bacteria, such as Nocardia, in the WAS feed from secondary treatment
processes could be the primary cause of excessive digester foaming. When these bacteria are the culprit,
performance also will degrade in other treatment processes, such as the primary clarifier and the aeration
Lennard A Nadalo, MD, et.al., University of Texas Southwestern Medical School, agrees the Nocardia can
cause brain abscesses. He said, "Occasionally, organisms other than pyogenic bacteria cause cerebral
abscesses. Examples include Mycobacterium tuberculosis, nontuberculous mycobacteria, fungi, parasites,
and Actinomyces and Nocardia species. Focal intracranial infections due to Salmonella organisms are rare
and are associated with positive results in blood cultures in some patients."
However, Nadalo said, "the organisms most frequently isolated from cerebral abscesses include
streptococci (both aerobic and anaerobic) and staphylococci, although gram-negative organisms are an
increasing cause of cerebral abscess. In neonates, the most frequently implicated organisms include
Citrobacter, Proteus, Pseudomonas, and Serratia species, as well as Staphylococcus aureus.
These abscesses are often large and have poorly formed capsules."
These bacteria flow out into the effluent - reclaimed water and sludge biosolids when the digester gets
gastroenteritis -- that is when there are too many acid producing bacteria in the digester which also
prevents methane producing bacteria from doing their job. There was a good indication of the problem at
OWASA by the bags of bicarbonate of soda stacked in a stairwell by the digesters. When the digesters are
working properly, $100,000.00 of the $115,000.00 energy cost can be recovered each month. Otherwise, it
appears from the above photograph, the gas is flared off.
Since EPA began exposing the public to sludge and reclaimed water use, the industry claims there have
been no health problems within the wastewater industry. Therefore the public can not possible experience
any health problems from exposure to sludge and reclaimed water. That is a serious indicator that we can
not trust the words of the wastewater treatment industry. In fact, Hadeed, National Biosolids
Partnership (NBP) Technical Communications Director it appears, likes to have a little fun at the
expense of country folks, He said "Odors, quite frankly, are the number one reason for lack of public
acceptance of biosolids." Then he gives us a little rhyme, "Odors, odors everywhere and all the biosolids
did stink, Odors, odors everywhere but Not In My Back Yard you fink! - Rhyme of the Ancient Biosolids
Manager (S.J. Hadeed, 2000)"
It would appear that the rhyme might have been in response to Bradley Stiebig's 1999 study, Quantifying
the Emission Rate of Ammonia and Trimethyl Amine From Biosolids. Stiebig found that bacterial
active sludge biosolids releases 29 chemicals in odors. At least 27 of the chemicals are very dangerous,
particularly, when inhaled. EPA's David Lewis has also discussed the amine problem with sludge.
It would also appear Mr. Hadeed never completely read the EPA document on Amines in ODOR
CHARACTERIZATION, ASSESSMENT AND SAMPLING from sludge. Based on the above opinion, it is
probable that Mr. Haeed stopped reading when EPA mentioned somatic impacts of odors. Somatic means
"of the body", or Somatic Cells from the body that compose the tissues, organs, and parts of that
individual other than the germ (sex) cells.
Psychosomatic (neurotic) appears to be the way the term somatic was interpreted.Like Hadeed, "William
Toffey, who oversees Philadelphia's waste program, swears biosolids is safe. He is, in fact, a little giddy
about composted human waste. "Biosolids are fun," he said." Toffey even wrote a paper, Biosolids
Odorant Emissions as a Cause of Somatic Disease . However, Toffey admits, "noxious odors, have
occurred, even with some regularity. Examples of such cases are putrid biosolids compost along highways,
noxious advanced-alkaline stabilized biosolids near elementary schools, and stinky piles of biosolids pellets
in a farmer’s field." But then he said, " Experts to the wastewater profession have not been able to dismiss
the role of biosolids in triggering IEI and psychogenic illnesses." "The psychogenic theory presupposes that
idiopathic environmental intolerance (IEI) is an overvalued idea explained by psychological and
psychosocial processes." I do believe he just said us old country folks are crazy and the industry bought
experts will not consider otherwise?
Actually Hadeed and Toffey hoped we would never read the MSDS documents for the chemicals they admit
will cause the odors. The MSDS documents show the odor causing chemicals can cause serious health
problems and EPA states, "These compounds can be produced in easily detectable quantities during high
temperature processes. In composting, amines result from microbial decomposition that involves
decarboxylation of amino acids. The amines that are produced are easily volatilized when temperatures are
elevated above about 27 C [80.6 degree Fahrenheit]. In biosolids produced with polymeric flocculating
agents, high ambient temperatures can accentuate volatilization of amines that may be microbially split off
from the core backbone of the polymer. Amines include: methylamine, ethylamine, trimethylamine, and
diethylamine. Amines often accompany ammonia emissions, and if chlorine is used chloramines may be
The chemical hygiene experts understand odors have a purpose. "Warning properties include odor,
irritation, and color--chemical properties that warn you the chemical is in the area. Chemicals with good
warning properties don't sneak up on you; you can smell, see or feel them, so you know to look for the
source or leave the area. Chemicals with poor warning properties don't warn you of their presence, so are
potentially more dangerous. People often link "strong smell" with "dangerous," and ignore the fact that
some dangerous chemicals lack odor."
From the digester, the sludge is transferred to the Solids Building where it is mixed with PRAESTOL 853 BC
acrylamide polymer to bulk up the solids content by absorbing the water. "Acrylamide is a potent
neurotoxin affecting both the central and peripheral nervous systems. The magnitude of the toxic effect
depends on the duration of exposure and the total dose." In 2001 the price for Acrylamide was $1.76 –
1.86 per pound.
"Exposure to acrylamide produces a distal axonopathy (also known as "dying-back" neuropathy) in both
humans and experimental animals. Both central nervous system (CNS) and peripheral nervous system
(PNS) neurons are affected although CNS damage appears to require exposure to much higher
concentrations. There is some potential for regeneration of PNS neurons but damage to CNS neurons is
permanent." Dying back simply means that something very toxic has enter that part of the brain which can
literally kill your body one part at a time, starting with the toes and fingers.
From the evidence, it would appear sewage treatment workers with compromised immune systems are
subject to health effects ranging from gastroenteritis to brain tumors. Unfortunately, I neglected to question
Gottschalk about the potential health effects suffered by his employees. On the 14th of January 2008, I
emailed the question to OWASA plant manager Pat Davis and Arlington PR agent Phil Loar. It is strange
that Davis evaded the question and Loar claimed he had not seen any work related illnesses in 26 years.
Nancy Holt's brain damage could also be one of the expected health effect damages from exposure to
pathogen and chemical contaminated sludge biosolids through the air, water and food, just as EPA foretold
in part 503.9(t).
Holt is not the only sludge biosolids victim with neurological damage.
Helane Shields documented a few victims exposed to sludge biosolids in the published document
SLUDGE VICTIMS: VOICES FROM THE FIELD
For additional sludge biosolids victims and health effects see the website:
EPA Office of Water has created a beneficial reclaimed water and sludge biosolids sewage effluent use
program that puts public health and the national economy at risk based on Congressional immunity and
EPA's Office of Enforcement and Compliance's refusal to get involved in this con game. EPA has funded
studies intended to protect itself and the wastewater industry from liability knowing that the effluent and
sludge treatment processes did not work. EPA has lied about doing a sludge biosolids risk assessment.
EPA has forced a test for environment E. coli on the industry knowing that it would not reveal normal human
pathogens in sewage effluent, sludge and drinking water. EPA has funded public relations programs aimed
at getting the wastewater industry and politicians to convince the public to accept disease organism
contaminated sewage effluent and sludge on food crops, school grounds, parks and lawns. EPA has
created unusually strict regulations for landfills and NPDES permits on effluents which literally forced the
wastewater industry to disposed of these effluents as close to the public as they can get the contaminated
waste. As a general rule, it appears the wastewater industry has no understanding of the rules they are
required to obey and EPA has no requirement that treatment plant operators have any understanding of
biology or microbiology. After 40 years, EPA and its partners are still trying to change public perception of
the danger associated with exposure to sewage effluents. They also spend a lot of public money on the
claim that they are still studying the problems and sometimes in the future they may look at health effects
caused to victims.
It is time to hold Congress accountable for EPA's lack of respect for the laws and this
environmental and economic disaster!
Secondary biological treatment.
Bacteria break down the organics.
Solids are bound by bacterial biofilm slime
and settle out as sludge. When air is caught
in the biofilm slime it creates foam or scum
on the surface.
The sludge and scum are sent to the
digester where bacteria consume the
remaining organics and create methane gas.
If the organics and bacteria are not in
balance, the digester will fail, excess
foaming will occur and the gas collection pipe
will plug up creating a hazardous situation.
Burning off the digester methane.
When the equipment is working properly, the
digester could produce 90% of the energy
needed against a $115,000.00 monthly
$300,000 + dollars dewatering
equipment = essentially mixes
polymers with sludge to absorb water
and bulk the solids content which is
then sent out for composting
You would never guess the dewatered
sludge is actually less than 30 percent
solids and its only Class B sludge
destined for a commercial composter
where it may be sold to you local
Subject: Fwd: Revised PRECAUTIONARY ACTION
SHOULD BE MANDATORY
Date: 1/14/2008 5:01:17 P.M. Pacific Standard Time
To: firstname.lastname@example.org, email@example.com
I wanted to say thanks for the tour of the treatment
plant in November. I have written a short piece
which included some of the information on the
plant. I have asked EPA to review it for any factual
errors. I will also ask you to review it for factual
errors. There is one point I failed to address. Have
you had any employees who may have, or had,
illnesses that could be attributed to the pollutants in
sewage or the aerosols from sewage during the