Transcript The Land Application of Municipal Sludge

The Land Application of
Municipal Sludge
“The liberty of a democracy is not safe if the
people tolerate the growth of private power to a
point where it becomes stronger than their
democratic state itself” Franklin Delano Roosevelt
Gary Scott
Al Guidry, PHD
Acknowledgements
C. W. Williams, Chair
Bioslolids Information Group
VDH-BURAC-Citizens Representative
Al Guidry, PHD
Biological Research in Agriculture
37 years research with USDA
Nelson County Resident
CPS Medical
Home Medical Equipment
Charlottesville, VA
434-984-2888
Commonwealth Coalition (35 County Coalition)
Campbell County Against Toxic Sludge (CATS)
Shenandoah County Alliance Against Toxic Sludge, LLC
Gary Scott
Al Guidry, PHD
Outline
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Farm Facts
Overview
History of Sludge
Permit Process
The Rest of The Story
What can be done?
Summary
Gary Scott
Al Guidry, PHD
Farm Facts
• The average farm household income will be
$75,848 in 2006, down 5.1%
• 86.7% of that $75,848 is OFF farm income
• There will be a 30% decrease in real farm
income in 2006.
source: USDA
• Fertilizer whether chemical or organic is
expensive, cover crops as fertilizer are
expensive
Gary Scott
Al Guidry, PHD
Farm Facts (cont’d)
Nelson County
• 2002 total market value of Production
was $7,565,000 up 10% from 1997
• 84,691 acres in farmland
• Nelson County ranks #4 in fruits, tree
nuts, and berries out of 95 VA counties
• Nelson County ranks #19 in vegetables,
melons, potatoes, and sweet potatoes
production out 95 VA counties
source: USDA
Gary Scott
Al Guidry, PHD
Overview
What are Biosolids
Biosolids are solid, semi-solid, or liquid
materials, resulting from treatment of
domestic sewage, that have been
sufficiently processed to permit these
materials to be safely land-applied.
source: Virginia Cooperative Extension
Gary Scott
Al Guidry, PHD
Overview (cont’d)
What are Biosolids
• Treated sewage sludge, also known as biosolids,
is a material formed when wastewater is processed
at a treatment plant. Biosolids contain nutrients
and organic matter that are useful to plants.
• However, contaminants including metals such as
arsenic, cadmium, and mercury, organic chemical
pollutants and disease causing organisms may be
present in low levels.
source: Virginia Department of Health
Gary Scott
Al Guidry, PHD
Overview (cont’d)
U.S. produces 8 million tons per year
so what do we do with it?
• Sludge can be incinerated
• Sludge can be placed in land-fills
• Sludge can be land applied, which
is the least expensive method
• Can be Converted to biomass fuels
Gary Scott
Al Guidry, PHD
Overview (cont’d)
In an effort to make sludge more
marketable and ease public
concern, the industry adopted the
word biosolids
Thus the campaign began to
promote sludge as a safe fertilizer
Gary Scott
Al Guidry, PHD
History of Sludge
• In 1988, Congress passed the Ocean Dumping
Reform Act, as part of the Clean Water Act thus
requiring a complete end to ocean dumping by
June 1991
• As an alternative, the EPA promulgated in 1993
what has become known as the 503 Rule which
allows the land application of processed sewage
sludge (biosolids). Sets minimum standards for
nine heavy metals.
• The 503 Rule regulates Land Application
Gary Scott
Al Guidry, PHD
History of Sludge
(cont’d)
Rule 503 permits two classes of biosolids
• Class A, where essentially 98% of
pathogens are reduced to undetectable
levels. Class A can be purchased in stores
(Milorganite)
• Class B, in which about 90% of the
bacteria, 90% of the viruses, a lower
percentage of parasites are said to be
killed
Gary Scott
Al Guidry, PHD
History of Sludge (cont’d)
• Class B is the sludge being land applied,
because it is less expensive because it
is less treated
• The proposed sites in Nelson County
would be receiving Class B Sludge with
the initial source being Middlesex, NJ
Gary Scott
Al Guidry, PHD
History of Sludge (cont’d)
The Environmental Protection Agency
(EPA) and the Virginia Department of
Health (VDH) have determined that the
land application of municipal sludge
when applied “properly” poses no
serious environmental or health risk.
Gary Scott
Al Guidry, PHD
History of Sludge (cont’d)
The Virginia Department of Health
(VDH)states:
“VDH has been assessing both the
environmental and possible health
effects of biosolids. VDH is unaware of
any scientific evidence to support a link
between the land application of
biosolids and these illnesses.”
Gary Scott
Al Guidry, PHD
History of Sludge (cont’d)
Minimum distances (feet) to land application area.
Surface
Application
Incorporation
Winter
Occupied dwellings
200
200
200
Water supply wells or springs
100
100
100
Property lines
100
50
100
Perennial streams and other
surface water, except
intermittent streams
50
35
100
Intermittent streams/drainage
ditches
25
25
50
All improved roadways
10
5
0
Rock outcrops and sinkholes
25
25
25
Agricultural drainage ditches with
slopes equal to or less than 2%
10
5
10
Adjacent feature
Source: VDH
Gary Scott
Al Guidry, PHD
History of Sludge (cont’d)
Regulations
• Cattle cannot graze on fields for 30 days after
sludge application
• Dairy cows cannot graze on fields for 60 days
after sludge application
• No public access on the site for a one year period
• The farmer is not allowed to harvest food crops
for 38 months when sludge applications remain
on the surface for time period of less than 4
months prior to incorporation
Gary Scott
Al Guidry, PHD
Nelson County History
The following Nelson County
landowners/farmers have applied for permits
to apply class B biosolids on 572.1 acres
Maynard Carter, Jerry Saunders, Jr., Nancy
Saunders, Charles & Jessie Umbarger, Annie
Umbarger, Virginia Brewer, Joseph C. Goodwin,
Charles Goodwin, and Jay Goodwin
The agreements with Synagro indicate
Middlesex, NJ as the initial source
Gary Scott
Al Guidry, PHD
Who is Synagro?
“A Residuals Management Company”
•“We supply farmers and commercial
growers with organic fertilizers that
enhance their soils and improve crop
yields
• “ Public Education and participation
are vital components of our successful
programs.”
Source: Synagro Brochure
Gary Scott
Al Guidry, PHD
Permit
Process
Land/Owner Farmer
Agreement
Site Maps Obtained
Field Work by Land Applier
Permit Application is Assembled & Permitted
DCR
VDH
notification
COUNTY
30 Days
Recommendation
Field
Inspections
Comments
Local Monitor Review
Inspection
Public Meeting
Additional comments up to 30 days following public meeting
Approval of Permit Application
Source: VDH
Fields Included in Permit May
Receive Biosolids When Available
The Rest of the Story
• The United States Federal Clean Water Act
defines municipal sewage sludge as a
pollutant.
• On September 6, 2000 Robert Swank, former
Research Director of at the EPA’s ORD at
Athens, GA, stated under oath: “We did not
think that rule (503) passed muster. If the
sludge rule were put to the test today, it
would miserably fail EPAs own scientific peer
review process.”
Gary Scott
Al Guidry, PHD
The Rest of the Story (cont’d)
Hugh Kaufamn, Environmental Engineer,
EPA said on CNN:
“The Official U.S. Government policy is to
grow food chain crops on poison and
not tell the public.”
Gary Scott
Al Guidry, PHD
The Rest of the Story (cont’d)
• David Gilman, PHD., EPA Assistant Administrator in
a response to a question about recent research was
quoted as saying “Because of significant
uncertainties we cannot say that it is safe or not
safe”
• David Lewis, PHD, after 30 years of service to the
EPA was forced out for questioning the safety of
land application of sludge. Testified before Congress
under The Whistle Blower Act.
Gary Scott
Al Guidry, PHD
The Rest of the Story (cont’d)
In 2002, a National Academy of Science
panel warned that sludge is such a
complex and unpredictable mix of
biological and chemical wastes, that its
risks when used for farming, cannot be
reliably assessed. The panel concluded
that standard strategies to manage
these risks "do not protect public
health."
Gary Scott
Al Guidry, PHD
The Rest of the Story (cont’d)
• In Federal government-sponsored research published
in September 2006, scientists found dozens of
medical, industrial, pharmaceuticals and household
compounds in treated sewage sludge.
• Thomas Burke PHD, professor of Public Health Policy
at Johns Hopkins University, said this research and
other studies amount to a "wake-up call" to the U.S.
Environmental Protection Agency to scrutinize the
effects of chemicals in the waste stream.
Gary Scott
Al Guidry, PHD
The Rest of the Story (cont’d)
• Dr. Rob Hale, William & Mary, Virginia Institute of
Marine Sciences “Studies indicate that chemicals and
toxins in sludge are making their way into the
environment and our bodies.
• Cornell University's Waste Management Institute,
which has studies for over 25 years, has been
warning about the need for further research, Dr. Ellen
Harrison said new research underscores previous
calls for increased regulatory scrutiny.
Gary Scott
Al Guidry, PHD
The Rest of the Story (cont’d)
Other Organizations opposed to the land
application of Sludge
National Farmers Union enacted a policy
stating: “The current practice of spreading
hazardous wastes and Class B biosolids on
land surfaces should be discontinued to
protect the soil and water of agricultural
lands, from which the nation’s food is
produced.”
Gary Scott
Al Guidry, PHD
The Rest of the Story (cont’d)
Other Organizations apposed to the land
application of Sludge
H.J. Heinz Company, Del Monte, National Food
Processors Ass., American Frozen Food
Institute, Western Food Growers
“ J. M. Dryer, GM of Heinz’ Food & Technology
Systems, wrote: “The risk of utilizing municipal
sludge, which is known to be high in heavy metals,
such as cadmium and lead, is not a health risk which
we need to take. This is not a publicity statement
since it is rigorously enforced and we have at times
dropped suppliers who have used sludge on their
crop land.”
Gary Scott
Al Guidry, PHD
What can we do?
VDH Suggestions:
• VDH encourages counties/municipalities to adopt an
approved local ordinance.
• Each locality approved to use biosolids may hire a
local monitor for monitoring and testing.
 The expense is paid by a $2.50 per ton fee that is
assessed to the water treatment facility. The County’s
actual expense are reimbursable from the VDH
reimbursement fund
• VDH and the local monitor will monitor the use of
biosolids on county lands.
What can we do TODAY?
Nelson County Supervisors can request that VDH extend
another 30 days for public comment and request no
application of sludge until an ordinance is passed
Gary Scott
Al Guidry, PHD
What can be done?
VDH Suggestions:
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Each potential application site
Will have site specific requirements
Testing of soils and biosolids before landapplication
Nutrient management plans
Disclosure to the public and land owner
Monitoring and reporting
County-led inspections
Gary Scott
Al Guidry, PHD
What can be done? (cont’d)
Regulations are being revised:
• Posting of signs at locations near the sites
that land appliers are planning to operate
• Signs will contain contact phone numbers
for additional information
Gary Scott
Al Guidry, PHD
What can be done? (cont’d)
Recent legislation passed by the 2005
General Assembly
• Will require land appliers to provide 100
days notice to the local governing body of
planned land application
• Notification may be in the form of a list of
available permitted sites
• Notification shall include the expected
source of biosolids
Gary Scott
Al Guidry, PHD
Summary
Sludge Source Characteristics
• Processing, Stabilization and Monitoring methods?
• Transportation & Storage facilities?
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Human & Animal Health Risks:
Heavy Metals, Pathogens, Carcinogens?
Interaction & reaction effect of these coming
together?
Effectiveness of Rules for Land Application?
Potential Drinking Water Contamination?
Creek and River Contamination?
Deer and other wildlife health risk?
Gary Scott
Al Guidry, PHD
Summary
• Like biosolids, DDT and tobacco
were once beneficial to farmers.
• Asbestos was once believed
beneficial, has been deadly.
Gary Scott
Al Guidry, PHD
Thank You !
Gary Scott
Al Guidry, PHD