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Weekly Musings

April 1, 1998

The ReSource Institute for Low Entropy Systems
179 Boylston Street
Jamaica Plain, MA 02130 USA

email: info@riles.org; Tel 617 524-7258; Fax 617 522-0690
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On March 4, 1998 an email correspondence about sludge started between Jim Chisholm, chair of the Environmental Committee of the Canadian Union of Public Employees Loc. 79 and Laura Orlando, director of the ReSource Institute.

The question addressed by Chisholm and Orlando is whether or not a moratorium on the use of sewage sludge as a fertilizer would stymie efforts to clean-up industrial discharges into municipal sewer systems. In a climate of deceit and confusion generated by multi-million dollar public relations and advertising campaigns, it is difficult to plop oneself on one side of the fence or the other. It is hard to choose where to put one's energy; in stopping the land application of sludge, improving its quality so as to reduce the risks of using it, or support its use as a fertilizer without revising the current rules. Perhaps this correspondence, eight letters in all, will help you decide where you stand on the issue.

Laura Orlando
editor

1.
Date: Wed, 4 Mar 1998
To: resource@riles.org
From: "Jim Chisholm" chisholm@web.net
Subject: Sludge web site

Laura Orlando. I understand that you have a web site dealing with sewage sludge. I am the chair of the Environmental Committee of the Canadian Union of Public Employees Loc. 79. On March 31 we will be having a seminar on the "beneficial" use of sewage sludge (aka biosolids). My own feeling is that we should make sure that the sewage sludge is not a hazardous wastes before any such consideration is given. A City of Toronto Councillor who was the chair of the Council's Biosolids Utilization Committee will also be speaking at the seminar as well as myself and another person. Any information you may have regarding the US experience on this issue would help me in my preparation for the seminar.

2.
Date: Fri, 6 Mar 1998
To: "Jim Chisholm" chisholm@web.net
From: "Laura Orlando" orlando@riles.org
Subject: Re: Sludge web site

Dear Jim,

I wouldn't call what we have a true web site on sludge, but ReSource does carry a few papers that help spell out the issue of land application of sewage sludge.

Our position on the land application of sewage sludge boils down to a simple maxim: municipal sewage sludge should never be spread on land.

I wrote a paper on sludge for a magazine called Dollars & Sense, which you can find at: http://www.riles.org/paper2.htm

Peter Montague's article in Rachel's Environmental Health Weekly is a must read on the subject: http://www.monitor.net/rachel/r561.html

I can get you copies of these papers if you would like to make them available during the seminar.

The story of the US experience is still unfolding. In the early nineties, the cost of disposing sewage sludge began to climb with escalating landfill fees and the banning of ocean dumping of sludge. The US Environmental Protection Agency, along with the wastewater treatment community (municipal plants, engineering firms that build them, the folks that lay the sewer pipe, etc.), hatched a plan to market sludge as a fertilizer thus circumvent disposal costs by either giving it away to farmers or bagging and selling it. It is an easy plan to subscribe to. Feels like recycling. Feels like you are taking a product out of the landfills and using it for good things.

Milwaukee had been selling their sludge for many years under the brand name Milorganite. Why not take the program national and turn a headache into a "recycling" success story? Trouble is, on any given day one never knows what is going down the sewer drain. Most industries compliance with the rules and regulations for pre-treatment of their waste is voluntary. Car repair shops, hospitals, photo processing plants, and dry cleaners make up a short list of the many businesses using the municipal sewer system. My dad is a mechanic. He means well. He cares about the environment. I see what goes down the drain at his shop. I don't want to eat it.

My degree is in Civil Engineering. When I learned how to build wastewater treatment plants, I was taught that the undesirable components of wastewater -- that which harms living things -- could be taken out of the water if the appropriate level of treatment was utilized. Components, such as, PCBs [polychlorinated biphenyls]; dioxins and furans; chlorinated pesticides [such as DDT, DDD, DDE, dieldrin, aldrin, endrin, chlordane, heptachlor, lindane, mirex, kepone, 2,4,5-T, and 2,4-D]; carcinogenic polynuclear aromatic hydrocarbons [PAHs]; heavy metals [arsenic, mercury, lead, selenium, cadmium, etc.]; bacteria, viruses, parasitic worms, and fungi;[1] industrial solvents; asbestos; and petroleum products would end up in the sludge.

What does testing mean? Who tests it? How often? What do we test for (right now the testing covers only heavy metals)? Who is liable if something goes wrong? Right now in the US, it is the farmer that takes the sludge. All liability is transferred to him or her.

Finally, if there is any question of the safety of this material, why eat it? Why introduce it into the web of life; through the soil, through the organisms that live in the soil, through plant uptake, by leaching into waterways. It is not the kind of thing that we can shrug our shoulders about 50 years from now and say geez, that was a mistake and walk away from it. Remediation will be impossible. The damage to human health measured in numbing cancer statistics.

You probably represent some of the people that work in municipal wastewater treatment plants. We are in no way attacking the work that they do. In fact, the more toxic the sludge, the better job they (and the technology they are looking after) are doing (as they are cleaning the wastewater and putting harmless water back into our waterways).

Hope this helps.

Good luck with your seminar.

Laura Orlando

3.
Date: Fri, 6 Mar 1998
To: "Laura Orlando" orlando@riles.org
From: "Jim Chisholm" chisholm@web.net
Subject: Re: Sludge web site

Laura,

Thank you for your for the information. You indicate that your position is that municipal sewage sludge should never be put on land. Does this not presume that it is impossible to stop the discharge of harmful chemicals at the various sources? Would it not be more effective to say that communities should work for strengthened sewer-use by-laws and enforcement so that any chemicals that could contaminate sewage sludge would be controlled or prevented from entering the sewer? It seems to me that if one concedes that sewage sludge will always be hazardous and will never be suitable for land application, that the need to control and prevent the discharge of hazardous chemicals at source is greatly reduced.

I haven't been able to open your web site yet. I will try later.

Jim Chisholm, Toronto

4.
Date: Mon, 9 Mar 1998
To: "Jim Chisholm" chisholm@web.net
From: "Laura Orlando" orlando@riles.org
Subject: Re: Sludge web site

Jim,

Controlling the discharge of hazardous chemicals is critical to human and environmental health and an important step in managing the disposal of sewage sludge. Unless industries that produce hazardous waste are disconnected from the pipes that feed the municipal treatment plant, controlling discharges is next to impossible. One need only look at the US experience with industrial pre-treatment. The temptation -- from homeowner to plant manager -- to dump whatever is in the pail down the drain seems to be powerful and quite difficult to control (see the Environmental Working Group's research paper: "Dishonorable Discharge" for more information on this topic -- it is accessible on our web site).

Given the design of sewers and the lack of public disclosure about what chemicals are being produced by industry and understanding about their effect on human health, I feel confident in saying that we can never know what is going down the drain and thus cannot afford to use sludge as a fertilizer on our soil and our food crops.

Your point about prodding industry to take care of their own wastes is a good one. But the goal should not be the use of sludge as a fertilizer. Instead, it should be the reduction of its production and its safe disposal. Source separation would mean a safer sludge for disposal and less of it. It also translates into cost savings for some industries - as recycling wastes has proven profitable for some businesses (a good deal of work is being done to demonstrate the efficacy of re-using waste materials in industry) and an opportunity for us to take a good hard look at what wastes are being produced in the manufacturing process and whether or not we might be better off without some products.

Let me know if you continue to have problems opening the web site. I can mail you some materials if you'd like something while we work out the problem with our ISP.

Laura

5.
Date: Mon, 9 Mar 1998
To: "Laura Orlando" orlando@riles.org
From: "Jim Chisholm" chisholm@web.net
Subject: Re: Sludge web site

Laura,

I understand what you are saying. The main trouble that I have with saying that sewage treatment plants that service industries can never use their sludge for agricultural land (or other beneficial use?) is that there would be much less concern about the quality of their sewage sludge. For example, if the fate of sewage sludge is to end up in a well contained sanitary landfill site, where would the pressure be to stop source discharge of toxic materials that end up in the sludge. I believe that if one does not put the protection of sewage sludge from contamination high on the priority list, then the result will be much less control and prevention of the discharge of contaminants at source.

If we insist that sewage sludge be free of harmful contaminants, this would become the driving force for industries and households to stop discharging harmful material.

6.
Date: Tue, 10 Mar 1998
To: "Jim Chisholm" chisholm@web.net
From: "Laura Orlando" orlando@riles.org
Subject: sludge quality

Jim,

I certainly see your point. Improving the quality of sewage sludge will lead to the stricter control of discharges. But why do we have to have the goal be the land application of sewage sludge? If safeguarding human health is a societal priority than it is an unattainable goal.

One need only look at the campaign to promote the beneficial use of "biosolids" and U.S. EPA regulatory guidelines that define sludge quality to see how dangerous to our health the emphasis on quality can be. The EPA adamantly argues that their guidelines mandate that only the highest quality, and thus safest, sludge be used for land application. What is safe to the EPA is not safe to me. The parameters that they and the beneficial use community use to define "safe" are both too narrow and too lax. Redefining the parameters means coming to some agreement on acceptable risk. Why not say we won't accept any risk from eating food grown with sludge; we won't gamble with our soil and ecological health? It is not inevitable that sludge be spread on land. Here is where the argument must be redirected, from beneficial use to reduction and safe disposal.

Sewage treatment plants and the private and public entities that control them should be mandated to care about the quality of the sludge. Reducing the hazards in sludge will make it safer to store and increase the options for disposal. Technologies such as gasification, an incinerator process that does not produce dioxin, could be safely used for disposal. Our ingenuity and concern should be directed at reducing the amount of sludge produced, improving the quality of the sludge, and finding safe and effective ways to dispose of it. The uncertainty of what is in sewage sludge and what amount of contaminant is safe to digest should be enough to steer the debate away from using sludge as a fertilizer to how can we make it safer for disposal.

Laura

7.
Date: Tue, 10 Mar 1998
To: "Laura Orlando" orlando@riles.org
From: "Jim Chisholm" chisholm@web.net
Subject: Re: sludge quality

Laura,

I find your comments refreshing. The main direction of the sewage sludge issue here in Ontario and in Toronto in particular is to rename sewage sludge to "biosolids" and look towards "beneficial" use. Many well meaning environmentalist have been taken captive by this issue and have not considered the real hazards of the sludge. Thus, to here you say that no risk is acceptable is certainly refreshing.

Nevertheless, I would not go as far as you have for the following reasons:

1) You call for zero risk. Yet you propose a form of incineration you call gasification. Even if it were possible to incinerate without generating dioxins, there are many other hazardous chemicals that we need to be concerned about. For example mercury. What happens to mercury in sewage sludge in the gasification process? I don't see incineration as a viable zero risk option.

2) I believe that one can establish a risk that they are willing to accept for sewage sludge. That risk should be virtually zero for toxic, persistent and bioaccumulative chemicals and for chemicals that can disrupt the endocrine system. Imagine the impact on source discharges if there were a regulation or law calling for strong source control and prevention of hazardous chemicals so that the sludge from the receiving sewage treatment plant (STP) would have virtually zero concentration of toxic, persistent and bioaccumulative chemicals and other highly hazardous chemicals such as alkyl phenols. For other less hazardous chemicals there may be some debate. I am tempted to support a call for the total elimination of all other less hazardous chemicals. However, in my opinion, such a call would have to wait for another day. Until that day, more stringent criteria should be developed to better control those chemicals. For others who insist that there be no risk even from the less hazardous chemicals, then is it not logical to call for the virtual elimination of such chemicals. Imagine the impact that would have on the control and prevention of source discharges. It would revolutionize the way industry and households operate.

3) If one dismisses the need to clean up sewage sludge because its fate will be "safe" disposal, a significant reason for effective source control and prevention of hazardous wastes will be removed.

4) In my mind, the least damaging disposal of contaminated sludge would be into a well contained, publicly run and publicly accountable sanitary landfill site. Even here however, hazards in the sewage sludge would not be isolated from the environment. For example, an important environmental fate of many highly hazardous chemicals such as PCBs is to partition into the air. Such chemicals can be advected for considerable distances and cause significant environmental damage in remote locations. For example, high levels of PCBs are found in the Arctic. This chemical is well established in the food chain in the Arctic.

Because we are at the top of the food chain, it should not be a great surprise that all of us have such chemicals as PCBs and dioxins in our bodies for the same type of reason.

Succeeding in preventing sewage sludge being applied on land for agricultural use would not reduce the risk to the food supply to zero. If contaminants were allowed to remain in high concentration in sewage sludge, even if disposed in a sanitary landfill site, eventually the persistent of many of these chemicals would either migrate from the landfill site or partition out of the site and be advected to other areas. Such chemicals would end up in the food chain.

It strikes me that spending energy on the "safe" disposal of such sludge would be much better spent in trying to prevent and to control the discharge of contaminants at source.

8.
Date: Mon, 16 Mar
To: "Jim Chisholm" chisholm@web.net
From: "Laura Orlando" orlando@riles.org
Subject: Re: sludge quality

Jim,

The moment you begin to work toward establishing "a risk that they are willing to accept for sewage sludge," you have thrown in the towel and lost the game. Science, public relations, and politics will come together in that magical place that looks like a house of mirrors, where the most money and the loudest voice rises above the chatter of reason and good sense. This is not hyperbole. One need only look at the EPA's current "biosolids" management program to see the ugly reflection of "beneficial use."

Energy spent on safe disposal includes significant expenditures on preventing and controlling the discharge of contaminants at the source. To do so is no less a stand for public health and environmental protection than demanding the control of discharges because the sludge will be spread on land rather than landfilled. In fact, it is undoubtedly a more responsible position. The difference the choice of the disposition of sewage sludge makes for the sludge haulers and the industrial dumpers is twofold. The first is liability. Liability for whatever is in the sludge is transferred to the owner of the land on which it is spread. This is the metal jacket on the bullet that will pierce any plan for truly controlling discharges. The second is economics. It costs less money to spread sludge as a fertilizer on land than to landfill it as a hazardous waste. Being relieved of all liability and saving money is quite the incentive for the "beneficial use" of sludge.

Eliminate the uncertain risk of disease and death from the land application of sewage sludge. Don't spread it. As long as there is uncertainly about what that risk might be on any given day, for any given application, there is no reason to take it. "They" will never agree to the elimination of "toxic, persistent and bioaccumulative chemicals and for chemicals that can disrupt the endocrine system." Neither the environmental community nor the scientific community can even agree on what those chemicals are. With thousands of new chemicals entering the environment every year, the task of tagging them good or bad is formidable, if not impossible. In a perfect world eliminating the dangers from municipal sludge would be impossible. In our world to call for such action is to turn a blind eye to malfeasance and the easy temptation of dumping whatever is in the bucket down the drain.

You are right about the gasification. I do not know enough about it to argue for its use or disuse. Lined, publicly accountable landfills are the way to go. Sludge will not cease to be produced anytime soon. We can press for source control on both public health and environmental ground. I say again, we don't have to aim to eat it to ask that it be as "clean" as possible. Reducing the risk form airborne particulates and leaching into soil and groundwater is enough reason to clamp down on industry and work toward treatment at the source. Ironically, this would be the best path to "beneficial use," as a close look at the industrial ecology movement will demonstrate the cost and material savings from some recycling of industrial waste.

You say that "succeeding in preventing sewage sludge being applied on land for agricultural use would not reduce the risk to the food supply to zero." Right again, but the risk would be statistically insignificant compared to the risk from the application of millions of pounds of sludge as fertilizer.

You say demand that sludge be safe enough to put on land as a fertilizer and as a result, tightly control discharges into the sewer. Yet the regulatory bodies in the United States that define what is safe and what is not safe are insisting that they have thoroughly studied sludge and that if the US EPA's rules are followed there is no danger from its application on land. There is no unbiased party to which you can make your appeal. The judge, in our case the US EPA, is on the take.

The prescription for fixing the problem of sludge disposal begins with a policy to back off sewers. Reduce the amount of sludge produced by stopping additional sewer hook-ups and moving people off the sewer as alternatives become available. Make the sludge less dangerous by legislating on-site treatment for some industry and closing others that produce waste so nefarious it cannot be safely managed. Those that do discharge into the public sewer must discharge only material that meets standards set by a board representing the real stakeholders: you, me, our families, and our neighbors.

Control discharges at every spigot, not for the quality of the sludge, but for the quality of our lives.

Laura

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Last updated: 2-April-1998
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